EPA/ROD/R03-01/025
2001
EPA Superfund
Record of Decision:
ABERDEEN PROVING GROUND (EDGEWOOD AREA)
EPA ID: MD2210020036
OU 08
EDGEWOOD, MD
09/28/2001
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Installation Restoration Program
J-FIELD STUDY AREA
Record of Decision
Final Remedial Action
Final
September 2001
01P-1676
U.S. Army Garrison
Aberdeen Proving Ground, Maryland
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RECORD OF DECISION
FINAL REMEDIAL ACTION
J-FIELD STUDY AREA
Edgewood Area
Aberdeen Proving Ground, Maryland
Prepared for
DIRECTORATE OF SAFETY, HEALTH, AND ENVIRONMENT
Environmental Conservation and Restoration Division
Installation Restoration Program
U.S. Army Garrison Aberdeen Proving Ground, Maryland
September 2001
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Final Remedial Action, J-Field Study Area
RECORD OF DECISION
TABLE OF CONTENTS
Section Page
1. DECLARATION OF THE RECORD OF DECISION (ROD) 1-1
1.1 SITE NAME AND LOCATION 1-1
1.2 STATEMENT OF BASIS AND PURPOSE 1-1
1.3 ASSESSMENT OF THE SITE 1-3
1.4 DESCRIPTION OF THE SELECTED REMEDY 1-6
1.5 STATUTORY DETERMINATIONS 1-8
2. DECISION SUMMARY 2-1
2.1 SITE NAME, LOCATION, AND DESCRIPTION 2-1
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-6
2.2.1 History of the J-Field Study Area 2-6
2.2.2 History Site Investigations and Enforcement Activities 2-6
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-12
2.4 SCOPE AND ROLE OF ACTION 2-12
2.5 SUMMARY OF SITE CHARACTERISTICS 2-13
2.6 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES ... 2-15
2.7 SUMMARY OF SITE RISKS 2-15
2.8 REMEDIATION OF THE J-FIELD SURFICIAL AQUIFER 2-15
2.8.1 Description of the Alternatives 2-19
2.8.2 Summary of Comparative Analysis of Alternatives 2-27
2.8.3 The Selected Remedy 2-38
2.8.4 The Statutory Determinations 2-39
2.9 PERFORMANCE STANDARDS 2-40
3. RESPONSIVENESS SUMMARY 3-1
3.1 OVERVIEW 3-1
3.2 BACKGROUND ON COMMUNITY INVOLVEMENT 3-1
3.3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES 3-2
3 .4 COMMENTS FROM THE MARCH PUBLIC MEETINGS 3-6
3.5 WRITTEN COMMENTS RECEIVED 3-6
4. BIBLIOGRAPHY 4-1
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RECORD OF DECISION
LIST OF FIGURES
Title Page
Figure 1 Locations of Toxic Burning Pits Area Within J-Field 1-4
Figure 2 Contaminated Plume Showing Total VOC Contours 1-5
Figure 3 Location of J-Field in the Edgewood Area at the Aberdeen Proving Ground 2-2
Figure 4 Generalized Cross-Section of the Major Stratigraphic Units Underlying Aberdeen
Proving Ground 2-3
Figure 5 Groundwater Elevations for Surficial Aquifer, May 1999 2-4
Figure 6 Groundwater Elevations for Surficial Aquifer, August 1999 2-5
Figure 7 Confined Aquifer Sampling Results (October 2000) 2-11
Figure 8 Extent of TI Zone 2-26
LIST OF TABLES
Title Page
Table 1 Summary of DSERTS Sites Addressed by J-Field Remedial Actions 1-2
Table 2 Chemical-Specific ARARs to be Waived in the Surficial Aquifer 1-9
Table 3 J-Field Study Area: Previous Activities 2-7
Table 4 Comparison of Maximum Detected Concentrations of Contaminants to
Regulatory Criteria 2-16
Table 5 Surface Water Detections and Ambient Water Quality Criteria 2-18
Table 6 EPA Evaluation Criteria 2-28
Table 7 Chemical-Specific ARARs 2-30
Table 8 Action-Specific ARARs 2-31
Table 9 Location-Specific ARARs 2-34
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Final Remedial Action, J-Field Study Area
RECORD OF DECISION
LIST OF ACRONYMS
1,1,2,2-TeCA
1,1,2,2-tetrachloroethane
1,1,2-TCA
1,1,2-trichloroethane
1,1 -DCE
1,1-dichloroethene
1,2-DCA
1,2-dichloroethane
1,2-DCE
1,2-dichloroethene
ACLs
Alternate Concentration Levels
APG
Aberdeen Proving Ground
APG-EA
Aberdeen Proving Ground-Edgewood Area
APGSCC
Aberdeen Proving Ground Superfund Citizens Coalition
ARARs
Applicable or Relevant and Appropriate Requirements
ARS
Alternative Remedial Strategy
AWQC
Ambient Water Quality Criteria
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
COMAR
Code of Maryland Regulations
COPCs
Contaminants of Potential Concern
CWA
Clean Water Act
CWM
Chemical Warfare Material
CZMA
Coastal Zone Management Act
DNAPL
Dense Non-Aqueous Phase Liquid
DOD
Department of Defense
DOT
Department of Transportation
DSERTS
Defense Site Environmental Restoration Tracking System
EPA
U.S. Environmental Protection Agency
ESD
Explanation of Significant Differences
FS
Feasibility Study
GCW
Groundwater Circulation Wells
GIS
Geographical Information System
HE
High Explosives
HHRA
Human Health Risk Assessment
HRC
Hydrogen Release Compound
LTM
Long Term Monitoring
LUC
Land Use Control
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RECORD OF DECISION
LUCIP
MCLGs
MCLs
MDE
MNA
NCP
NESAHP
NPDES
NPL
O&M
OB/OD
OSHA
PCE
POTWs
PSB
RCRA
RI/FS
ROD
SARA
SDWA
SECs
SOU
TAGs
TBP
TCE
TI
USAEC
use
UVB
UXO
VC
VOCs
VX
LIST OF ACRONYMS (continued)
Land Use Control Implementation Plan
Maximum Contaminant Level Goals
Maximum Contaminant Levels
Maryland Department of the Environment
Monitored Natural Attenuation
National Oil and Hazardous Substances Pollution Contingency Plan
National Emission Standards for Hazardous Air Pollutants
National Pollutant Discharge Elimination System
National Priorities List
Operations and Maintenance
Open Burning/Open Detonation
Occupational Safety and Health Administration
tetrachloroethene
Publicly Owned Treatment Works
Protective Soil Blanket
Resource Conservation and Recovery Act
Remedial Investigation/Feasibility Study
Record of Decision
Superfund Amendments and Reauthorization Act
Safe Drinking Water Act
Shoreline Erosion Controls
Soil Operable Unit
Technical Assistance Grants
Toxic Burning Pit
trichloroethene
Technical Impracticability
U.S. Army Environmental Center
United States Code
Unterdruck-V erdampfer-Brunnen
Unexploded Ordnance
Vinyl Chloride
Volatile Organic Compounds
methylphosphonothioate
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Final Remedial Action, J-Field Study Area
RECORD OF DECISION
ABERDEEN PROVING GROUND
FINAL REMEDIAL ACTION
J-FIELD STUDY AREA
FINAL
RECORD OF DECISION
September 2001 Aberdeen Proving Ground, Maryland
1. DECLARATION OF THE RECORD OF DECISION (ROD)
1.1 SITE NAME AND LOCATION
J-Field Study Area
Edgewood Area
Aberdeen Proving Ground (APG), Maryland
The Defense Site Environmental Restoration Tracking System (DSERTS) number for the J-Field Surficial
Aquifer is EAJF05-B. DSERTS numbers for other areas covered under this Record of Decision (ROD)
and those areas covered under previous actions are listed in Table 1.
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the J-Field Study Area. Previous
removal and remedial actions have been implemented to address the J-Field Soil Operable Unit (SOU).
Remedial actions under this ROD will address the Surficial Aquifer, the Confined Aquifer, and remaining
soil areas, except for limited areas that remain active, in the J Field Study Area. No further action beyond
those presented herein and those underway in accordance with prior RODs is to be taken for remaining
soil areas in the J-Field Study Area. A listing of these soil areas and actions at J-Field is given in Table 1.
Available data from Remedial Investigation (RI) activities indicate that the chemical contaminants in these
soil areas do not pose a significant risk to human health or the environment under current Army access
controls and land use restrictions. Isolated unexploded ordnance and chemical warfare materiel
(UXO/CWM) may be present, although detailed review of available historical documents and field
investigations (geophysical surveys and RI/FS activities) show no evidence of extensive UXO/CWM
disposal areas remaining at J-Field. However, the potential presence of these items could pose a risk.
These risks are not addressed under this CERCLA action.
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Final Remedial Action, J-Field Study Area RECORD OF DECISION
Table 1
Summary of DSERTS Sites Addressed by J-Field Remedial Actions
DSERTS Site
Soil OU
ROD/
ESD"
J-Field Study Area
Projected
ROD Date
FY
Name
Number
Action
No
Further
Action
J-Field Study Area
EAJF00
2001
White Phosphorus Burning Pitb
EAJF01
Prototype Building
EAJF02
X
2001
Riot Control Burning Pit
EAJF03
X
2001
Robins Point Demolition Groundb
EAJF04
Toxic Burn Pitsa
EAJF05
X
X
1996
Toxic Burns Pits - Southern Main Pits Overall
EAJF05-A
X
X
1996
Surficial Aquifef
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)
EAJF010
X
2001
Ruins Site NE of Intersection (Area C)
EAJF011
X
2001
Ruins Site Area across from WPP
EAJF012
X
2001
Swamp 400 ft East of Ruins Site (Area D)
EAJF013
X
2001
Robins Point Tower Site
EAJF014
X
2001
Titanium Pits Site
EAJF015
X
2001
aThe ROD has been modified by an ESD (2001)
bPortions remain active; will be closed when appropriate
Clncludes the Confined Aquifer actions
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Final Remedial Action, J-Field Study Area
RECORD OF DECISION
Several limited areas at J-Field remain active for emergency response detonation operations. These areas,
the White Phosphorus Burning Pit and the Robins Point Demolition Ground, will be managed and closed in
coordination with environmental regulators under the appropriate environmental program(s) when their
use is no longer required for APG's mission.
This remedial action was developed in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986, and the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on the administrative record for this site. The
Maryland Department of the Environment (MDE) concurs with this remedy.
1.3 ASSESSMENT OF THE SITE
Volatile organic compounds (VOCs) are the primary chemicals found in the J-Field Surficial Aquifer.
These compounds include 1,1,2,2-tetrachloroethane (1,1,2,2-TeCA), 1,2-dichloroethane (1,2-DCA),
1,1-dichloroethene (1,1-DCE), 1,2-dichloroethene (1,2-DCE) (total), tetrachloroethene (PCE),
1,1,2-trichloroethane (1,1,2-TCA), trichloroethene (TCE), and vinyl chloride (VC). The
VOC-contaminated plume is confined to the Toxic Burning Pit (TBP) area located in the southwestern
portion of J-Field (Figure 1). The VOC-contaminated plume is shown in the enlarged TBP area map in
Figure 2.
Dense Nonaqueous Phase Liquid (DNAPL) is present in the Surficial Aquifer. Based on this, a Technical
Impracticability (TI) Evaluation has been prepared and a TI Waiver has been issued by the Army and the
U.S. Environmental Protection Agency (EPA). In addition, as is discussed in Section 2.2.2, contamination
was introduced into the Confined Aquifer from the Surficial Aquifer through leaky wells in past years.
Two of the faulty wells have been abandoned and replaced (WESTON, 2001b) and one additional well is
to be abandoned and replaced as part of the Selected Remedy presented in this ROD. Monitoring of the
Confined Aquifer will also continue as part of this remedy. Remaining soil areas within the J-Field Study
Area are listed in Table 1. No further action beyond those presented in this ROD and those underway in
accordance with previous RODs is to be taken for groundwater or remaining soil areas in the J-Field
Study Area except for active areas as previously noted.
The Human Health Risk Assessment (HHRA) evaluated hypothetical future residential use scenarios to
identify contaminants of potential concern (COPCs). The Risk Assessment concluded that cumulative
carcinogenic and non-carcinogenic risks associated with hypothetical child and adult resident exposures to
groundwater at J-Field were well above EPA's target ranges for health protection. The ecological risk
assessment indicated that there are currently no significant ecological risks associated with discharge of
the Surficial Aquifer groundwater to the freshwater marsh. The ecological risk assessment also indicated
that there is future potential for ecologic effects in the freshwater marsh.
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FIGURE 2 CONTAMINATED PLUME SHOWING TOTAL VOC CONTOURS
(1999 SAMPLING RESULTS)
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Final Remedial Action, J-Field Study Area
RECORD OF DECISION
The Selected Remedy under this ROD will represent the best balance of required and preferred features
for the J-Field Study Area, as defined by CERCLA guidance and the NCP.
1.4 DESCRIPTION OF THE SELECTED REMEDY
Based on the site assessment, the Army and the EPA developed response actions for this site. As
described in the TI Evaluation, the results of the investigations in the Surficial Aquifer indicate that
DNAPL is present in the Surficial Aquifer at the site. The TI Evaluation considered the following options
for the Surficial Aquifer:
P Treatment of entire contaminated plume.
P Containment of residual and mobile contaminant.
P If DNAPL containment is achievable, treatment of the remaining portion of the plume.
All of these options were found to be technically impracticable. Treatment of the entire plume is not
practicable as shown from the results of the Treatability Studies (discussed in Subsection 2.2.2).
Limitations in groundwater pumping and extraction rates from the Surficial Aquifer and the limited
influence of in situ technologies, both due to the low permeability of aquifer materials, make treatment
impracticable. Engineered containment of the DNAPL would be accomplished through placing a slurry
wall or similar impervious subsurface barrier around the perimeter of the hot spot of the plume.
Dewatering of the area inside the wall or capping the contained area with an impermeable material would
be required in conjunction with containment. If achievable, engineered containment may have offered
some environmental benefit; however, it is not practicable due to prohibitive costs associated with the
large area to be contained and costs associated with unexploded ordnance (UXO) clearance. Excavation
of the DNAPL area is also not practicable. All areas disturbed for construction of containment systems or
for excavation of materials would require clearance, removal, and disposal of any ordnance items or
CWM encountered. Previous experience at the J-Field SOU has shown that the potential for ordnance
items can make complete removal of materials cost-prohibitive. Removal of the DNAPL through
excavation would not be practicable. Therefore, it will not be possible to meet Applicable or Relevant and
Appropriate Requirements (ARARs) in the Surficial Aquifer. Details of this discussion are found in the TI
Evaluation (WESTON, 2001a).
As part of the TI Evaluation, an Alternative Remedial Strategy (ARS) was developed to reduce risk to
human health and the environment at the J-Field Study Area. This ARS includes establishing Institutional
Controls, continuation of phytoremediation, monitoring biodegradation processes, abandonment and
replacement of Confined Aquifer well JF-51, possible addition of a supplement to the replacement well for
JF-51 to foster degradation of the isolated contamination at JF-51 in the Confined Aquifer, continued
monitoring of the Confined Aquifer, and implementation of free phase DNAPL recovery in the localized
area where DNAPL was observed, temporary Geoprobe® well GP-53.
The goal of this remedy is to reduce the contaminant mass in the J-Field Surficial Aquifer through
DNAPL recovery, phytoremediation, and natural processes, to eliminate exposure to the groundwater and
to control off-site
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Final Remedial Action, J-Field Study Area
RECORD OF DECISION
contaminant migration from the Confined Aquifer.
The ARS consists of the following:
P CERCLA 5-Year Review.
P Restriction of Surficial Aquifer groundwater use, and the use of untreated upper Confined
Aquifer groundwater unless it meets all applicable standards and criteria, in order to prevent
exposure risks associated with contaminated groundwater.
P Prohibition of unauthorized excavation and well installation at the site.
P Provisions for implementation, monitoring, reporting, and enforcement of institutional controls
will be specified in the Land Use Control Implementation Plan (LUCIP).
P Planting additional trees over a minimum of a 1-acre area to further extend the
phytoremediation zone.
P Periodic sampling, monitoring, and maintenance of phytoremediation trees, which may include
measurements of sap flow, tree tissue, and/ or other sampling, and planting of new trees as
needed to replace damaged or dead ones. Following planting, the health of the trees would be
assessed periodically as the trees become established on the site. Fertilizer and soil
amendments may continue to be required, and it may be necessary to prune the trees during
their growing season.
P Groundwater sampling for COPCs and monitoring of attenuation and biodegradation
parameters to help determine whether the plume is stable or migrating, and the direction of
migration of the plume.
P Abandonment and replacement of Confined Aquifer Well JF-51.
P Implementation of free phase DNAPL recovery in the localized area where DNAPL was
observed, temporary Geoprobe® well GP-53.
P The addition of a supplemental material to foster degradation of the isolated contamination at
JF-51 in the Confined Aquifer will be considered in the Remedial Design.
P Monitoring of the Confined Aquifer.
P Monitoring of the freshwater marsh.
P Periodic maintenance inspections of the shoreline area for indications of erosion.
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Final Remedial Action, J-Field Study Area RECORD OF DECISION
1.5 STATUTORY DETERMINATIONS
This final remedial action is protective of human health and the environment and is intended to provide
adequate protection for the J-Field Study Area. This final remedial action is intended to comply with
federal and state ARARs for this action (except as waived with the TI Waiver), and is cost-effective. A
TI Waiver from selected Federal and State ARARs has been issued by the Army and the EPA.
(Appendix C, J-Field Study Area Feasibility Study - TI Evaluation, WESTON, 2001a). ARARs to be
waived are the Federal Safe Drinking Water Act (SDWA) Maximum Contaminant Levels (MCLs) and
non-zero Maximum Contaminant Level Goals (MCLGs) (40 Code of Federal Regulations [CFR]
141.11-12, 141.50-51, and 141.61-62), which were adopted by the State of Maryland in Code of Maryland
Regulations (COMAR) 26.04.01 Regulation of Water Supply, Sewage Disposal, and Solid Waste; and
State of Maryland Annotated Code Title 9 - Water Pollution Control (sections 9-302 and 9-322) as
implemented by COMAR 26.08.02.09 Groundwater Quality Standards. Other risk-based criteria listed in
the TI Evaluation will not be reached in the TI Zone. ARARS to be waived for the Surficial Aquifer are
presented in Table 2.
This remedy uses permanent solutions as currently available to the maximum extent practicable for this
site. Treatment will be used to the extent practicable by removing free phase DNAPL from localized
areas and groundwater treatment through phytoremediation and natural processes. Because this remedy
will result in hazardous substances above health-based levels remaining on-site, a CERCLA Five-Year
Review will be conducted to ensure that the remedy continues to provide adequate protection of human
health and environment within 5 years after commencement of the remedial action and every 5 years
thereafter as appropriate.
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Final Remedial Action, J-Field Study Area RECORD OF DECISION
Table 2
Chemical-Specific ARARs to be Waived in the Surflcial Aquifer
Act
Description
Status
Waiver
Federal Safe Drinking
Sets maximum
Relevant and
MCLs and non-zero MCLGs to be waived
Water Act 40 CFR
contaminant levels
Appropriate
for:
141.11-12,141.61-62
allowable for drinking
- Benzene
water.
- Carbon tetrachloride
- Chlorobenzene
- 1,2-Dichloroethane
- 1,1 -Dichloroethene
- cis-1,2-Dichloroethene
- trans-1,2-Dichloroethene
- Tetrachloroethane
- Trichloroethene
- Vinyl chloride
- Arsenic
- Cadmium
- Chromium
- Antimony
- Selenium
- Thallium
- Cyanide (free)
- Nitrate (as Nitrogen)
State of Maryland
Sets maximum
Relevant and
MCLs and non-zero MCLGs to be waived
Regulation of Water
contaminant levels
Appropriate
for:
Supply, Sewage
allowable for drinking
- Benzene
Disposal, and Solid
water.
- Carbon tetrachloride
Waste COMAR
- Chlorobenzene
26.04.01
- 1,2-Dichloroethane
- 1,1 -Dichloroethene
- cis-1,2-Dichloroethene
- trans-1,2-Dichloroethene
- Tetrachloroethane
- Trichloroethene
- Vinyl chloride
- Arsenic
- Cadmium
- Chromium
- Antimony
- Selenium
- Thallium
- Cyanide (free)
- Nitrate fas Nitrogen)
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Final Remedial Action, J-Field Study Area RECORD OF DECISION
Table 2
Chemical-Specific ARARs to be Waived in the Surflcial Aquifer
(Continued)
Act
Description
Status
Waiver
State of Maryland
Annotated Code Title
9 - Water Pollution
Control as
implemented by
COMAR 26.08.02.09
Groundwater Quality
Standards
State groundwater anti-
degration policy
Relevant and
Appropriate
Numerical Standards as implemented by
COMAR 26.08.02.09 Groundwater Quality
Standards
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Final Remedial Action, J-Field Study Area
JohW C. Doesburg
Commanding General
U.S. Army Aberdeen Proving Ground
RECORD OF DECISION
Date
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Final Remedial Action, J-Field Study Area
Abraham Ferdas
Director, Hazardous Site Cleanup Division
U.S. Environmental Protection Agency,
Region III
RECORD OF DECISION
Date
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Final Remedial Action, J-Field Study Area
RECORD OF DECISION
2. DECISION SUMMARY
2.1 SITE NAME, LOCATION, AND DESCRIPTION
APG is a 72,000-acre Army installation located in Baltimore and Harford Counties, Maryland, on the
western shore of the upper Chesapeake Bay (Figure 3). The installation is bordered to the east and south
by the Chesapeake Bay and to the west by Gunpowder Falls State Park, the Crane Power Plant, and
residential areas. APG consists of two areas: the Aberdeen Area and the Edgewood Area. Elevations
within Aberdeen Proving Ground-Edgewood Area (APG-EA) range from sea level near large rivers to
approximately 40 feet above mean sea level at several of the highest locations. APG-EA is listed on the
National Priorities List (NPL), which is EPA's list of hazardous substance sites in the United States that
are priorities for long-term remedial evaluation and response.
J-Field is located on the southern end of the Gunpowder Neck peninsula of the Edgewood Area (Figure
3). The contaminated groundwater plume in the J-Field Surficial Aquifer is confined to the TBP Area
(Figure 2).
There are four primary hydrostratigraphic units at J-Field that are classified in descending order as (1) the
Surficial Aquifer, (2) the Confining Unit, (3) the first-Confined Aquifer, and (4) undifferentiated
semiconfined to confined aquifer unit (Figure 4). A detailed description of the hydrogeologic framework
of J-Field is presented in the initial RI (Hughes, 1995). Previous studies by Otten and Mandle (1984),
Drummond and Blomquist (1993), and USACE (1997) detail the regional hydrogeologic framework
presented in Figure 4.
Groundwater flow in the Surficial Aquifer is to the east and southwest and discharges to surrounding
freshwater marshes. The source of the VOC plume, the former TBPs, resides on a local topographic
high. This area contributes to groundwater recharge to the Surficial Aquifer. Seasonal variations in areal
recharge result in approximately 3-ft fluctuations of the water table. These fluctuations in groundwater
elevations cause short-term shifts in hydraulic gradient and flow direction (Figures 5 and 6) (Phelan,
1998). The groundwater elevation data presented in Figure 6 indicates that there was a cone of
depression in the center of the phytoremediation area in August 1999. (Phytoremediation investigations
and activities are discussed in Section 2.2.2.) Detailed water level measurements are compiled in monthly
status reports (GP, 1999).
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EJujNnttn County
SDuroe: Adapted frarn the Draft Final Remedial IfiYsstjgatton Report. June 1994-
Q1P-323M
FIGURE 3 LOCATION OF J-FIELD IN THE EDGEWOOD AREA
AT THE ABERDEEN PROVING GROUND
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01P-QD24-13
FIGURE 4 GENERALIZED CROSS SECTION OF THE MAJOR STRATIGRAPHIC
UNITS UNDERLYING ABERDEEN PROVING GROUND
-------
FIGURE 5 GROUNDWATER ELEVATIONS FOR SURFICIAL AQUIFER (MAY 1999)
-------
LEGEND
01P* 1182-2
FIGURE 6 GROUNDWATER ELEVATIONS FOR SURFICIAL AQUIFER (AUGUST 1999)
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2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.2.1 History of the J-Field Study Area
APG was established in 1917 as the Ordnance Proving Ground and was designated a formal military post
in 1919. Testing of ammunition and materiel and operation of training schools began at APG in 1918.
APG-EA has been a center for the development, testing, and manufacture of military-related chemicals
since World War I.
The extent of activities at J-Field before World War II is unknown; however, a terrain map from the
1920s-1930s era indicates that some areas of J-Field were cleared at that time. (Argonne,1998) These
cleared areas may have been used for test activities. During World War II, J-Field was used for testing
High Explosives (HE) and munitions, and for thermal decontamination of chemical munitions. Chemical
agents, chemical wastes, and HE were burned or detonated in open pits.
Chemicals historically disposed of at J-Field include nerve agents (such as VX), blister agents, riot control
agents, white phosphorous, chlorinated solvents, and drummed chemical wastes generated by research
laboratories, process laboratories, pilot plants, and machine and maintenance shops (Argonne, 1998).
Between 1946 and 1971, limited testing of chemical agents continued at J-Field. Open-air testing of
chemical agents stopped in 1969.
J-Field has had only limited use since 1980. Current activities are conducted in accordance with applicable
regulations, including several limited areas at J-Field that remain active for open detonation operations.
These areas will be managed and closed under the appropriate environmental program(s) when their use
is no longer required for APG's mission.
2.2.2 History of Site Investigations and Enforcement Activities
Several environmental investigations have been conducted at J-Field since the mid-1970s. These studies
include: Environmental Contamination Survey, Munitions Disposal Study, RCRA Facility Investigation,
Hydrological Assessment, Remedial Investigations, treatability studies, Phytoremediation Demonstration,
groundwater plume modeling studies, and other field investigations. These investigations are listed in Table
3 and are described in detail in the FS.
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Table 3
J-Field Study Area:
Previous Activities
Activity
Date
Environmental Contamination
Survey
1977-78
Munitions Disposal Study
1983
RCRA Facility Investigation
1986
Hydrological Assessment,
Phase I
1987-92
Characterization and Interim
Remediation
1992
Hydrological Assessment, Phase II
1992
Sediment Sampling Study
1992
Piezometer Installation and
Sampling
1994
Toxic Pits Pilot Remediation
Study
1994
Deep Drilling
1995
Remedial Investigation
1991 - 1996
Ecological Risk Assessment
1994-96
Aquatic Toxicity Evaluation
1994-97
Well Installation and Sampling
1996
Natural Attenuation Study
1997-2000
Phytoremediation Demonstration
1997 - present
Honeybee Biomonitoring Program
1997 - present
Groundwater Level Monitoring
Study
1998 - present
Hydrogen Release Compound
(HRC) Treatability Study
1998-1999
Vacuum Vaporizer Well (UVB)
Technology Treatability Study
1998-1999
Biosolids Investigation
1999
Borehole Geophysical
Investigation
1999
Confined Aquifer Wells
Abandonment and Replacement
2000
Geochemical Evaluation of Arsenic
and Lead Mobility
2000
Time Critical Removal Action
2000
Sampling for Products of
Combustion
2000
ROD for TBPs
1996
Shoreline Erosion Controls
September 1998 - April 1999
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Completed activities at J-Field are as follows:
Soil Operahle TJnit
A ROD was signed for the J-Field SOU on 27 September 1996. The September 1996 ROD specified
limited removal of contaminated soils from the TBPs, followed by construction of a Protective Soil
Blanket (PSB) to prevent ecological exposure. Additional remedial components included shoreline erosion
controls along the southern shore of the Gunpowder Neck peninsula to prevent future erosion of
contaminated materials into the bay.
The September 1996 ROD implementation was conducted from March 1998 through May 1999. During
excavation of the TBPs, UXO and chemical warfare material (CWM) were encountered before
excavation to specified cleanup criteria was completed in some areas. However, sufficient material has
been removed to permit construction of the PSB as originally described in the September 1996 ROD. The
Army has evaluated the potential for migration of remaining contaminants to ecological receptors
(Accuscience, 2000). Based upon the results of this evaluation and the issues associated with excavation
of the remaining materials, the Army is modifying the remedial action at the TBP from that described in
the September 1996 ROD to include work completed to date, followed by construction of the PSB as
originally planned. An Explanation of Significant Differences (ESD) has been prepared to amend the
September 1996 ROD and construction of the PSB is currently underway.
In accordance with the ESD, excavation of the Northern and Southern TBPs and the Pushout Area will
not proceed beyond the materials already excavated. At this point, limited areas of arsenic and lead
contamination remain above the intended performance standards. However, the overall depth of the
excavation meets the 2-ft minimum depth specified in the September 1996 ROD. The PSB will be
constructed in full accordance with the September 1996 ROD, consisting of a minimum of 2 ft of clean
backfill and a barrier to burrowing animals. Therefore, the completed system will function as intended and
the intent of the original design will be met. Additional excavation would not enhance the protectiveness
of the remedy. Additionally, the J-Field Study Area is located in a restricted area of APG. Access to the
restricted area is strictly controlled and a wide variety of physical security measures are in place to
prevent unauthorized personnel from entering the area. Institutional Controls to be implemented under this
ROD will further enhance these restrictions and prevent future human exposure.
Shoreline Erosion Control
Shoreline Erosion Controls (SECs) were installed between September 1998 and April 1999 as specified in
the J-Field SOU September 1996 ROD. The J-Field Shoreline stabilization system mitigates shoreline
erosion of approximately 3,000 feet of the J-Field shoreline along the Chesapeake Bay from Ricketts
Point to the Eastern edge of Big Pond, and thereby prevents migration of hazardous materials. The
system consists of on-shore revetments and off-shore breakwaters. Construction details are provided in
the Final Technical Report (As-Built) (WESTON, 1999). Following construction of the revetments and
breakwaters, the area was vegetated with 32,000 wetland plants (Spartina patens and Scirpus
americanus) to provide support to the beach nourishment system. To maintain some intertidal exchange
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along the shoreline as requested by the U.S. Fish and Wildlife Service, a portion of the shoreline remains
unprotected.
Work was completed in April 1999. Inspection of the area in the summer of 1999 showed that
establishment of the vegetative layer is proceeding. After agency review, the shoreline protection system
was deemed appropriate by the Army and compliant with the September 1996 ROD requirements to
protect the eroding shoreline from further damage, while protecting valuable habitat. Erosion is being
monitored as presented in Post Construction Survey Monitoring Program for J-Field Shoreline Protection
Project (WESTON, September 2000b). Surveying events were conducted in July 2000 and July 2001.
Confined Aquifer Corrective Actions
In 1989, a series of monitoring wells was installed in the First Confined Aquifer that underlies J-Field to
examine groundwater quality (USGS, 1993). Over the ensuing monitoring periods, sampling of these wells
indicated that localized VOC contamination existed in the Confined Aquifer downgradient of the Former
TBPs (Argonne, 1998). The source of contamination was uncertain, but was suspected to originate as
leakage from the overlying Surficial Aquifer during the 1989 First Confined Aquifer well installation
activities. Due to range closures during well installation, the well boreholes were left open and may have
provided a path for downward leakage of VOCs. Between 1989 and 1999, sampling of Confined Aquifer
water quality indicated that VOC concentrations were declining in several of the wells (JF-41, -51, -61,
and -71) to near background levels. In contrast, concentrations in JF-81 continued to increase during this
period, suggesting the existence of another possible VOC source to the Confined Aquifer.
Examination of well construction records for the Confined Aquifer wells showed that the wells were not
double-cased to seal off the Surficial Aquifer as is the current construction practice for such wells. In
1999, a borehole geophysical study was conducted on the monitor wells screened in the Confined Aquifer
to evaluate their integrity and determine if downward leakage through the borehole(s) was possible.
Results indicated that grout loss and cracking had occurred in all wells and indicated that JF-81 and JF-82
also suffered from thin bentonite seals above the sand pack. It was determined that these construction
problems provided a potential path for VOC contamination in the Surficial Aquifer to migrate through the
clay layer to the First Confined Aquifer.
As a result, JF-81 and -82 were abandoned and sealed. Two double-cased downgradient wells (JF-211
and -221) and one replacement well (JF-81R) were installed (WESTON, 2001b). Groundwater sampling
was conducted to assess the extent of contamination in the First Confined Aquifer, and borehole
geophysical testing was conducted to confirm well construction quality. Results of the sampling indicated
that of the three downgradient monitoring wells, only MW-221 indicated detectable VOCs although
concentrations were below the respective MCLs. The downward trend of VOCs historically observed in
the Confined Aquifer wells was interrupted by elevated concentrations of cis-l,2-DCE and VC in JF-51
and PCE in JF-61. The cause for this unexpected increase in VOCs is not clearly understood, but could
be related to several factors including: (1) seasonal variation, (2) variable flow conditions, (3) possible
construction issues at other wells(s), and (4) the possibility that the VOCs were temporarily drawn over to
JF-51 from
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the area around JF-81 during recent well construction. Figure 7 shows results from the October 2000
sampling event. Additional remedial action for the Confined Aquifer will be taken with implementation of
this ROD to address these results.
Miscellaneous Actions
In addition to the items listed above, the following investigative or cleanup-related activities have also been
conducted at J-Field:
# Geochemical Evaluation of Arsenic and Lead Mobility.
# Biosolids Demonstration in the Pushout Area.
# Drum Removal Action.
# Removal of J-Field Soil/ Debris Piles.
Treatability Studies
The following treatability studies have been conducted at the J-Field Study Area:
# In-Well Aeration Using Groundwater Circulation Wells - The
Unterdruck-Verdampfer-Brunnen (UVB) system is an in situ groundwater remediation
system that develops a vertical groundwater circulation cell around a remediation well. The
groundwater circulation cell transports volatile and semivolatile contaminants in soil and
groundwater to the well where they are removed. Two UVB wells with different
configurations were installed and tested at the TBP area. It was determined that low
groundwater flow velocities and low permeabilities at the site limit the effectiveness of the
UVB system.
# Enhanced Biodegradation Using Hydrogen Release Compound (HRC) - HRC
involves adding a chemical compound to the groundwater to enhance natural anaerobic
biodegradation processes. The HRC was injected immediately upgradient of monitoring well
JFP-5 at 10 locations, forming a semicircle. Monitoring was conducted for approximately 6
months following injection. It was determined that mass removal by HRC is limited by the
velocity of groundwater flowing through the HRC injection points. Since the groundwater
velocity is slow, mass removal is not significant.
# Monitored Natural Attenuation (MNA) - The term "Monitored Natural Attenuation" is
defined as the reliance on natural attenuation processes (within the context of a carefully
controlled and monitored site clean-up approach) to achieve site-specific remedial objectives
within a time-frame that is reasonable compared to that offered by other, more active,
methods. The effectiveness of natural attenuation is determined by the contaminant
degradation rate. The faster the degradation rate, the higher the rate of
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FIGURE 7 CONFINED AQUIFER SAMPLING RESULTS (OCTOBER 2000)
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natural attenuation will be. MNA investigations at J-Field have been conducted over the past
5 years. These studies have included sampling of the Surficial Aquifer in the TBP area as
well as sampling from a series of piezometers extending out into and below the East Marsh.
Results of the initial study indicated that natural attenuation is proceeding efficiently in the
East Marsh area. Additional studies have been conducted to further define the effectiveness
of natural attenuation in the Surficial Aquifer (Argonne, 2000). These studies included
additional sampling in the upland and East Marsh areas as well as sampling along a new
transect into the South Marsh. The results of these studies confirm previous conclusions
regarding natural attenuation, and demonstrate similar natural attenuation activity in the
sediments below the South Marsh. These studies continue to show that, overall, natural
attenuation processes are highly effective in the dissolved portion of the groundwater
contaminant plume at the site.
# Phytoremediation - Phytoremediation is a technology that uses plants and their associated
rhizospheric microorganisms to remove, degrade, or contain chemical contaminants located in
the soil, sediment, groundwater, surface water, or atmosphere. Over 200 trees (primarily
hybrid poplars) were planted in the TBP area between 1997 and 1999. Based on data
collected to date, phytoremediation appears to contribute to the removal of VOCs from
groundwater.
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Draft J-Field Surficial Aquifer Feasibility Study was issued in February 2000. The Proposed Plan was
finalized and released to the public on March 9, 2001, initiating a 45-day comment period. These
documents, which are included in the Administrative Record for the site, have been made available to the
public at the Harford County Public Library (Aberdeen and Edgewood branches) and at the Miller
Library at Washington College in Chestertown, Maryland. The notice of availability of the Proposed Plan
was published in several local newspapers in Harford, Baltimore, Kent, and Cecil Counties. Public
meetings were held at the Edgewood Senior Center on March 20, 2001, and at the Chestertown Middle
School Media Center on March 22, 2001, to inform the public of the preferred alternative and to seek
public comments. At these meetings, the Army presented the preferred alternative. A representative from
MDE attended the 20 March 2001 meeting, but did not supply a formal statement at that time. EPA
provided an official statement in support of the Proposed Plan at both Community Meetings. The
statement is included in the meeting transcripts, which are also included in the Administrative Record for
the site. Responses to comments received during the 45-day comment period are included in the
Responsiveness Summary (see Section 3 of this document).
2.4 SCOPE AND ROLE OF ACTION
In accordance with CERCLA, a Feasibility Study (FS) was conducted for the J-Field Surficial Aquifer to
identify and evaluate long-term remedial actions for the mass removal of VOCs from the J-Field Surficial
Aquifer. The FS was
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conducted in accordance with the CERCLA Remedial Investigation/Feasibility Study (RI/FS) Guidance.
Investigative activities, which were conducted before and after the FS, are listed in Table 3 of this ROD.
A LUCIP will be developed and submitted to EPA within 6 months of ROD signature for review and
agreement. The LUCIP will include restriction of Surficial Aquifer groundwater use, and restriction of the
use of untreated upper Confined Aquifer groundwater unless it meets all applicable standards and criteria.
The LUCIP will clearly identify the Army authority responsible for implementation, monitoring, reporting,
and enforcement of the institutional controls.
As shown in Table 1, the White Phosphorous Burning Pit is an active unit and Robins Point Demolition
Ground is an active RCRA Interim Status Unit. Therefore, these areas are not covered in this ROD. The
locations of these units are depicted in Figure 1.
The HHRA identified COPCs in the case of hypothetical future residential use scenarios as discussed
below.
The ecological risk assessment indicated that there are currently no significant ecological risks associated
with discharge of the Surficial Aquifer groundwater to the freshwater marsh. The ecological risk
assessment also indicated that there is future potential for ecologic effects in the freshwater marsh.
The selected remedy under this ROD will represent the best balance of required and preferred features,
as defined by CERCLA guidance and the NCP.
2.5 SUMMARY OF SITE CHARACTERISTICS
The area near the northern and southern TBPs serves as a local groundwater recharge area for the
Surficial Aquifer. Groundwater generally flows out from the recharge area, primarily toward the east and
southwest. This groundwater flow pattern is reflected in the chemical distribution of total VOCs in the
groundwater, as evidenced in Figure 2. The J-Field Surficial Aquifer is primarily contaminated with
chlorinated ethanes and ethenes. The wastes that produced the VOC plume(s) were disposed in the
former TBPs between the late 1940s and 1970s (Yuen et al., 1997). The amount and exact point of
release of VOCs released to the subsurface are not documented.
As shown in Figure 2, the main VOC plume at J-Field appears to be bilobate and extends approximately
270 feet toward the southwest and approximately 360 feet to the east from the TBPs. The lobes are
approximately 140 to 160 feet wide. Based on concentrations of VOCs in well JF-173, which is screened
in the lower 5 feet of the Surficial Aquifer, and to a lesser extent on concentrations of VOCs in the
eastern well nests, groundwater contamination is present vertically throughout the Surficial Aquifer. A
significant proportion of VOC mass exists in the upper 20 feet of the Surficial Aquifer as evidenced by
the vertical location of the highest contaminated wells (JF-83, JFP-2, and GP-35). The VOC plume has
reached the marsh areas on both the East and South sides of the TBP area and undergoes significant
biodegradation in the marsh before discharging to surface water (Yuen et al, 1998; Yuen et al, 2001
DRAFT). Surface water sampling, which has been performed since 1993, shows decreasing
concentrations through
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time of all VOCs, except VC. The 1,1,2,2-TeCA concentrations in the East Marsh decreased more than
an order of magnitude between 1994 and 1997, and 1,1,2,2-TeCA was not detected in surface water
samples in the South Marsh in 1999 (Yuen et al, 1998; Yuen et al, 2001 DRAFT). Overall, groundwater
concentrations decrease at least three orders of magnitude in the 270 to 360 feet that the VOC plume has
migrated.
The Surficial Aquifer is primarily contaminated with chlorinated ethanes and ethenes. 1,1,2,2-TeCA,
TCA, TCE, 1,2-DCE, PCE, and VC have been measured at concentrations exceeding 100 mg/L (100,000
|_ig/L) in the Surficial Aquifer. The highest concentrations of VOCs in groundwater are located below the
southernmost TBP. In 1999, a maximum concentration of 390 mg/L of 1,1,2,2-TeCA was detected in
piezometer GP-35. Maximum concentrations of 110 mg/L of DCE, 93 mg/L of TCE, 11 mg/L of PCE, 7.1
mg/L of TCA, and 4.2 mg/L of VC have been detected in groundwater. Data collected during
phytoremediation field investigation efforts in July 2001 is included in Attachment B of this ROD. During
this sampling event, VOC concentrations higher than historical concentrations were found in a number of
sampling locations. Groundwater concentrations in exceedance of the reported solubility of 1,1,2,2-TeCA
were reported for two temporary Geoprobe wells. Also, apparent free phase DNAPL was found in the
laboratory sample collected from temporary Geoprobe well GP-53. Data from the July 2001 sampling
event are pending validation. Based on historical groundwater data and the observed free phase DNAPL,
residual DNAPL likely exists and continues to contribute VOC mass to the dissolved-phase plume.
Analyses of these historical data were conducted to assess the likely presence and extent of residual
DNAPL and are presented in the TI Evaluation.
Persistent contaminant sources are most commonly attributed to chlorinated solvents lingering as mobile,
free phase NAPLs (NAPLs that occur at sufficiently high saturations to drain under the influence of
gravity into a well) and immobile, residual phase NAPLs (NAPLs occurring at immobile, residual
saturations that are unable to drain into a well by gravity). Through time, groundwater flows through the
NAPL source zones and the more soluble constituents partition to the aqueous phase. These contaminant
source zones persist for long periods of time due to the slow processes that degrade the NAPL zones
(dissolution, volatilization, degradation) and continue to function as a source of groundwater
contamination.
Residual DNAPL remediation has been shown to be technically impracticable at the J-Field Study Area
(WESTON, 2001c). At sites where subsurface conditions permit the removal of some mobile NAPL,
some decrease in the time required to remediate the dissolved-phase plume may be achievable.
Nevertheless, implementing any type of removal, treatment, or containment of NAPLs is complicated by
the complex subsurface conditions at J-Field. Many of the technologies designed to remediate DNAPL
are severely limited by the heterogeneities and UXO identified at J-Field. Before DNAPL remediation,
even at the isolated area where it was observed, a field investigation is required to define the subsurface
heterogeneities and to estimate the 3-D distribution of mobile and residual DNAPL. The field investigation
will consist of using direct push technology in an effort to map the surface of the potential DNAPL
bearing formation so that the recovery well can be placed in a localized low point
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for most effective recovery. A plan for recovering free phase DNAPL from the J-Field Surficial Aquifer
will be submitted to EPA within 3 months of signature of the J-Field Study Area ROD.
2.6 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
Several limited areas at J-Field remain active for open detonation. These areas will be managed and
closed in coordination with environmental regulators under the appropriate environmental program(s)
when their use is no longer required for APG's mission.
The groundwater from the J-Field Surficial Aquifer is not being used and will not be used for drinking
water in the future. Access to J-Field is restricted and the Army intends to use the area only for military
industrial purposes. Institutional Controls, as described in this ROD, will further restrict usage.
2.7 SUMMARY OF SITE RISKS
The Human Health Risk Assessment included in the J-Field RI evaluated human health risks due to
groundwater for several hypothetical future residential use scenarios. It was determined that the potential
cumulative risks associated with hypothetical child and adult resident exposures to groundwater at J-Field
were well above EPA's acceptable risk range for health protectiveness at CERCLA sites. The study also
indicated that noncarcinogenic effects could occur if persons were exposed. The predominant VOCs
associated with high cancer risks and noncancer hazards in groundwater included 1,2-DCA; 1,1 -DCE;
1,2-DCE (total); 1,1,2,2-TeCA; PCE,1,1,2-TCA; TCE; and VC. A complete list of contaminants of
concern and the relevant regulatory criteria are presented in Table 4. Inorganic constituents which exceed
MCLs and non-zero MCLGs are found, with one exception, to be co-located with the VOC plume.
The ecological risk assessment indicated that there are currently no significant ecological risks associated
with discharge of Surficial Aquifer groundwater to the freshwater marsh. The ecological risk assessment
also indicated that there is future potential for ecologic effects in the freshwater marsh. A list of surface
water sampling results from the marsh and the applicable federal and state Ambient Water Quality
Criteria (AWQC) are shown in Table 5. Only detected contaminants with AWQC values are presented.
2.8 REMEDIATION OF THE J-FIELD SURFICIAL AQUIFER
Groundwater contamination exists in the J-Field Surficial Aquifer. With respect to remediating this site,
the Army focused on the risk of human exposure at the J-Field Study Area. Remedial actions at this site
may be warranted to reduce the contaminant mass in the plume to meet ARARs (except as waived by
the TI Waiver) and to eliminate exposure to the groundwater. The J-Field Surficial Aquifer FS identified
and analyzed several possible remedial
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Table 4
Comparison of Maximum Detected Concentrations of Contaminants
to Regulatory Criteria
Analyte
J-Field
Maximum
Detected
Concentration
Og/1)
Federal
MCLsa
Og/1)
Federal
MCLGs"
Og/1)
Maryland
MCLsc
Og/1)
EPA Region 3
RBCsd
Volatile Organic Compounds (VOCs) (fig/L)
Acetone
130
-
-
-
610
Benzene
77
5
0
5
0.36
Carbon disulfide
16
-
-
-
1,000
Carbon tetrachloride
6
5
0
5
0.16
Chlorobenzene
980
100
-
100
110
Chloroform
62
-
-
-
0.15
1,2-Dichlorobenzene
4
-
-
-
64
1,4-Dichlorobenzene
2
-
-
-
0.47
1,2-Dichloroethane
211
5
0
5
0.12
1,1-Dichloroethene
150
7
7
7
0.044
cis-1,2-Dichloroethene
81,000
70
70
70
61
trans-1,2-Dichloroethene
29,000
100
100
100
120
1,2-Dichloroethene, total
110,000
-
-
-
55
Ethylbenzene
52
700
700
700
1,300
Hexachlorobutadiene
2
-
-
-
0.86
Hexachloroethane
9
-
-
-
4.8
Methylene chloride
1,000
-
-
-
4.1
1,1,1,2-Tetrachloroethane
140
-
-
-
0.41
1,1,2,2-Tetrachloroethane
390,000
-
-
-
0.053
T etrachloroethene
11,000
5
0
5
1.1
Toluene
19
1,000
1,000
1,000
750
1,2,4-Trichlorobenzene
5
70
70
70
190
1,1,2-Trichloroethane
7,100
5
3
5
0.19
Trichloroethene
93,000
5
0
5
1.6
Vinyl chloride
4,200
2
-
2
0.019
Xylenes, total
163
10,000
10,000
10,000
12,000
Dissolved Metals (jig/L)
Mercury
0.95
2
2
2
-
Silver
1.6
-
-
-
180
Aluminum
14,400
-
-
-
37,000
Arsenic
78.6
50
-
50
0.045
Barium
820
2,000
2,000
2,000
2,600
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Table 4
Comparison of Maximum Detected Concentrations of Contaminants
to Regulatory Criteria
(Continued)
Analyte
J-Field
Maximum
Detected
Concentration
Og/1)
Federal
MCLsa
Og/1)
Federal
MCLGs
b (lig/1)
Maryland
MCLsc
Og/1)
EPA
Region 3
RBCsd
Beryllium
2.7
4
4
4
73
Cadmium
33.1
5
5
5
18 (water)
37 (food)
Cobalt
43.4
-
-
-
2,200
Chromium
578
100
100
100
55,000 (Cr+3)
110 (Cr+6)
Copper
2.62
-
1,300
-
1,500
Iron
196,000
-
-
-
11,000
Manganese
2,580
-
-
-
5,100
Nickel
2,190
-
-
100
730
Lead
124
-
0
50
-
Antimony
19
6
6
6
15
Selenium
54
50
50
50
180
Thallium
5.0
2
0.5
2
2.6
Vanadium
72
-
-
-
260
Zinc
1,880
-
-
-
11,000
Cyanide (free)
50.6
200
200
200
730
Nitrate (as nitrogen)
12,000
10,000
10,000
10,000
58,000
a Federal Maximum Contaminant Levels. Source: National Primary Drinking Water Regulations, 40 CFR 141.61,40
CFR 141.62.
b Federal Maximum Contaminant Level Goals: Source: National Primary Drinking Water Regulations, 40 CFR 141.50,
40 CFR 141.51.
c State of Maryland Maximum Contaminant Levels in Drinking Water. Source: COMAR 26.04.01.
dEPA Region III Risk-Based Concentrations for Tap Water. Source: EPA Region III RBC table of 12 April 1999.
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Table 5
Surface Water Detentions and Ambient Water Quality Criteria
Analyte
Maximum
Detected
Concentration1
(ug/L)
National Recommended Water Quality
Criteria for Freshwater Aquatic Life
MD Criteria for Ambient
Surface Waters
Maximum
Concentration
Criteria (ug/L)
Continuous
Concentration
Criteria (ug/L)
Acute
(ug/L)
Chronic
(ug/L)
Arsenic
3.8
340
150
340
150
Copper
18
13
9
13
9
Iron
181100
-
1000
-
-
Lead
20
65
2.5
65
2.5
Zinc
782
120
120
120
120
1 As reported in J-Field RI.
- Indicates no criteria.
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actions. The following six remedial alternatives were developed in the FS to address the contaminated
plume in the J-Field Surficial Aquifer:
# Alternative 1 No Action (required by CERCLA to be considered for comparison reasons).
# Alternative 2 Institutional Controls.
# Alternative 3 Phytoremediation with Institutional Controls.
# Alternative 4 Monitored Natural Attenuation (MNA) with Institutional Controls and
Phytoremediation.
# Alternative 5 Integrated Remedial System: In Situ Source Area Treatment Using
Groundwater Circulation Wells (GCW), MNA, and Phytoremediation.
# Alternative 6 Integrated Remedial System: Source Area Treatment Using Groundwater
Pumping, Transport, and Off-Site Treatment of Groundwater, MNA, and
Phytoremediation.
Estimated costs for all the alternatives were calculated for 30 years for consistency and comparison
purposes. The costs presented in this ROD for these six alternatives are found in the FS Addendum
available in the Administrative Record.
2.8.1 Description of the Alternatives
2.8.1.1 Alternative 1: No Action
CERCLA and the NCP require that the No Action alternative be evaluated at every CERCLA site to
establish a baseline for comparison. In some cases, No Action may be found to be the appropriate
alternative for implementation. This alternative as presented in the J-Field Surficial Aquifer FS includes
the following components:
# No active remedial activities would take place under the No Action alternative.
# As required under CERCLA, because hazardous substances will remain on the site, the site
would be reviewed after 5 years to reassess site conditions. These CERCLA reviews are
included in this and every other alternative in this ROD. They will be conducted every 5 years
until the action is completed. Costs associated with this review are not included in any of the
alternatives in this document.
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Cost Summary
Alternative 1
RECORD OF DECISION
Capital Cost
$0
Total Present Worth Costs (30 years)
$0
2.8.1.2 Alternative 2: Institutional Controls
This alternative as presented in the J-Field Surficial Aquifer FS includes the following components:
# CERCLA 5-Year Reviews (costs not included).
# Prohibition of untreated groundwater use in the Surficial and Confined Aquifers in order to
prevent exposure to the contaminants found in groundwater.
# Prohibition of unauthorized excavation and well installation at the site.
# Posting of at least 2 signs stating site restrictions / prohibitions (maintained for 30 years).
# Incorporation of all site restrictions / prohibitions into APG's GIS, which is used in the
development of APG's Real Property Master Plan.
# Inclusion of all site restrictions / prohibitions, a discussion of the NPL status of the site, and a
description of the chemical profile and the potential risks associated with the groundwater in
any real property or real estate documents necessary for the transfer of ownership from the
Army (in the unlikely event that the Army transfers this property). This will ensure that any
future property transfers recognize and maintain necessary institutional controls.
# Long-term groundwater monitoring.
Cost Summary
Alternative 2
Capital Cost
$18,000
Operations and Maintenance
(O&M) Costs (Present Worth)
$28,000
Total Present Worth Costs (30 years)
$46,000
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2.8.1.3 Alternative 3: Phytoremediation with institutional Controls
This alternative as presented in the J-Field Surficial Aquifer FS includes the following components:
# CERCLA 5-Year Reviews (costs not included).
# Institutional controls as described in Alternative 2.
# Periodic sampling and analysis of groundwater, periodic measurement of groundwater
elevation, and periodic monitoring of tree sap flow.
# Periodic sampling and monitoring of phytoremediation trees, and planting of new trees to
replace damaged or dead ones.
# Maintenance of trees as needed, such as pruning trees during their growing season.
Cost Summary
Alternative 3
Capital Cost: Institutional Controls
$18,000
O&M Costs: Institutional Controls (Present Worth)
$28,000
O&M Costs: Phytoremediation (Present Worth)
$953,000
Total Present Worth Costs (30 years)
$999,000
2.8.1.4 Alternative 4: MNA with Institutional Controls and Phytoremediation
The Monitored Natural Attenuation (MNA) alternative as presented in the J-Field Surficial Aquifer FS
involves the following components:
# CERCLA 5-Year Reviews (cost not included).
# Institutional controls as described in Alternative 2.
# Continuation of the phytoremediation demonstration as described in Alternative 3.
# Quarterly groundwater sampling during the first 4 years to help confirm that the plume is
stable, or determine the direction of movement if it is migrating, and to establish a baseline for
MNA performance verification. After the first 4 years, annual sampling would be conducted.
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Cost Summary
Alternative 4
Capital Cost: Institutional Controls
$18,000
O&M Costs: Institutional Controls (Present Worth)
$28,000
O&M Costs: Phytoremediation (Present Worth)
$953,000
O&M Costs: MNA (Present Worth)
$779,000
Total Present Worth Costs (30 years)
$1,778,000
2.8.1.5 Alternative 5: Integrated Remedial System: In Situ Source Area Treatment Using
GCW, MNA, and Phytoremediation
This alternative as presented in the J-Field Surficial Aquifer FS includes the following components:
# CERCLA 5-Year Reviews (costs not included).
# Institutional controls as in Alternative 2.
# Continuation of phytoremediation demonstration as described in Alternative 3.
# Continuation of MNA demonstration as described in Alternative 4.
# Installation of four Groundwater Circulation Wells.
# Periodic monitoring of groundwater.
# Periodic well maintenance as needed, including check for proper performance of equipment,
replacement of carbon canisters, periodic well redevelopment, and periodic removal of
deposits from well screens.
Cost Summary
Alternative 5
Capital Cost: Institutional Controls
$18,000
Capital Cost: GCW
$970,000
O&M Costs: Institutional Controls (Present Worth)
$28,000
O&M Costs: Phytoremediation (Present Worth)
$953,000
O&M Costs: MNA (Present Worth)
$779,000
O&M Costs: GCW (Present Worth)
$2,413,000
Total Present Worth Costs (30 years)
$5,161,000
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2.8.1.6 Alternative 6: Integrated Remedial System: Source Area Treatment Using
Groundwater Extraction, Transport and Off-site Treatment of Groundwater, MNA, and
Phytoremediation
This alternative as presented in the J-Field Surficial Aquifer FS includes two options, depending on the
treatment location. Option A involves treatment of groundwater at the Old O-Field treatment plant at
APG, and Option B involves treatment of groundwater at an off-site commercial treatment facility. This
alternative includes the following components:
# CERCLA 5-Year Reviews (costs not included).
# Institutional controls as described in Alternative 2.
# Continuation of phytoremediation demonstration as described in Alternative 3.
# Continuation of MNA demonstration as described in Alternative 4.
# Installation of four groundwater extraction wells.
# Installation of groundwater pumping systems on four wells.
# Installation of a temporary 10,000-gal. tank (to hold approximately 3 to 4 days' volume of
recovered groundwater at a total recovery rate of 2 gallons per minute [gpm] from all wells)
to store extracted groundwater.
# Periodic trucking of groundwater to the Old O-Field treatment plant (Option A) or to an
off-site commercial treatment plant for treatment and discharge (Option B).
Cost Summary
Alternative 6
Capital Cost: Institutional Controls
$18,000
Capital Cost: GW Extraction Wells
$174,000
O&M Costs: Institutional Controls (Present Worth)
$28,000
O&M Costs: Phytoremediation (Present Worth)
$953,000
O&M Costs: MNA (Present Worth)
$779,000
O&M Costs: GW Extraction Wells
Option A
$4,334,000
Option B
$16,434,000
Total Present Worth Costs (30 years)
Option A
$6,286,000
Option B
$18,386,000
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2.8.1.7 Alternative Remedial Strategy
As part of the TI Evaluation, an ARS was developed in order to protect human health and the
environment from risks associated with hazardous substances at the J-Field Study Area. This ARS
includes establishing Institutional Controls, continuation of phytoremediation, monitoring biodegradation
processes, abandonment and replacement of Confined Aquifer well JF-51, possible addition of a
supplement to the replacement well for JF-51 to foster degradation of the isolated contamination at JF-51
in the Confined Aquifer, continued monitoring of the Confined Aquifer, and collection of mobile DNAPL
at the location where it was observed in the July 2001 sampling event. This action will consist of the
following components:
# CERCLA 5-Year Review.
# Restriction of Surficial Aquifer groundwater use, and the use of untreated upper Confined
Aquifer groundwater unless it meets all applicable standards and criteria, in order to prevent
exposure risks associated with contaminated groundwater.
# Prohibition of unauthorized excavation and well installation at the site.
# Provisions for implementation, monitoring, reporting, and enforcement of institutional controls
will be specified in the LUCIP.
# Planting additional trees over a minimum of a 1-acre area to further extend the
phytoremediation zone.
# Periodic sampling, monitoring, and maintenance of phytoremediation trees, which may include
measurements of sap flow, tree tissue, and/or other sampling, and planting of new trees as
needed to replace damaged or dead ones. Following planting, the health of the trees would be
assessed periodically as the trees become established on the site. Fertilizer and soil
amendments may continue to be required, and it may be necessary to prune the trees during
their growing season.
# Groundwater sampling for COPCs and monitoring of attenuation and biodegradation
parameters to help determine whether the plume is stable or migrating, and the direction of
migration of the plume.
# Abandonment and replacement of Confined Aquifer Well JF-51.
# Implementation of free phase DNAPL recovery in the localized area where DNAPL was
observed, temporary Geoprobe® well GP-53.
# The addition of a supplemental material to foster degradation of the isolated contamination at
JF-51 in the Confined Aquifer will be considered in the Remedial Design.
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# Monitoring of the Confined Aquifer.
# Monitoring of the freshwater marsh.
# Periodic maintenance inspections of the shoreline area for indications of erosion.
Under the ARS, the requirement to meet MCLs and non-zero MCLGs within the TI Zone in the Surficial
Aquifer will be waived by EPA due to the presence of DNAPL. Components other than DNAPL are
also being waived because the presence of DNAPL will make remediation impracticable. The limits of
the TI Zone are shown in Figure 8. The specific limits of the TI Zone will be defined by contaminant
concentrations.
This alternative differs from the alternatives presented in the FS in that:
# Additional trees will be planted as part of the ARS.
# Phytoremediation sampling was decreased based on previous site experience.
# Confined Aquifer actions (including abandonment and replacement of JF-51) were included
and Confined Aquifer wells included in the monitoring strategy.
# Monitoring of the freshwater marsh will be conducted.
# DNAPL recovery due to recent finding of free phase contamination has been added to the
ARS.
Costs of the ARS are summarized below.
Cost Summary
Alternative Remedial Strategy
Capital Cost: Institutional Controls
$18,000
Capital Cost: Phytoremediation*
$240,000
Capital Cost: Confined Aquifer Well Abandonment and
Replacement
$70,000
Capital Cost: Free Phase DNAPL Recovery System
O&M Costs: Institutional Controls (Present Worth)
$28,000
O&M Costs: Phytoremediation (Present Worth)
$681,000
O&M Costs: Biodegradation parameters (Present
Worth)
$632,000
O&M Costs: Free Phase DNAPL Recovery System
(Present Worth)
Total Present Worth Costs (30 years)
$1,877,000
*Includes cost for UXO clearance
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2.8.2 Summary of Comparative Analysis of Alternatives
The remedial alternatives presented in Section 2.8.1 were evaluated in accordance with the regulatory
requirements of CERCLA using the nine evaluation criteria specified by EPA as set forth in the NCP
(see Table 6). The nine criteria are categorized into three groups: threshold criteria, primary balancing
criteria, and modifying criteria.'The alternative that is ultimately implemented must satisfy the threshold
criteria, which are the most important. Primary balancing criteria weigh the major trade-offs among
alternatives. Modifying criteria are considered after conclusion of the public comment period. This section
summarizes the relative performance of each remedial alternative with respect to these criteria.
2.8.2.1 Threshold Criteria
Overall Protection of Human Health and the Environment. Alternative 1 would not be protective of
human health or the environment, and, therefore, will not be considered further in this analysis. Alternative
2 would provide protection to humans by implementation of Institutional Controls. As shown in the Risk
Assessment, there are no complete groundwater exposure pathways. Institutional Controls will prevent
future exposures.
In the unlikely event that the property is transferred, Institutional Controls will still prevent groundwater
use. Long-term monitoring will be included to allow assessment of any changes in site conditions.
Alternatives 3 and 4 are passive treatment processes, which may require a longer time to make a
significant difference in protection to humans or the environment than some active processes. Alternatives
5 and 6 are focused on source control by treatment or disposal of contaminants. By active treatment of
contaminants, these alternatives would provide some increased protection in a relatively short time.
However, in the longer term, the performance of Alternative 3 is essentially the same as Alternatives 5
and 6. The ARS would be protective of Human Health and the Environment through the implementation
of Institutional Controls as well as ongoing phytoremediation and natural processes.
Compliance with ARARs. CERCLA, as amended, requires that remedial actions at NPL sites comply
with or obtain waivers from other State and Federal environmental laws and regulations that may be
applicable to the site or that address situations sufficiently similar to those at the site to be considered
relevant and appropriate. These ARARs may be: chemical-specific (requirements for managing site
contaminants); action-specific (requirements that may apply to specific types of remedial actions under
consideration); or location-specific (requirements that are related to the location of the site).
# Chemical-Specific ARARs-MCLs and MCLGs established under the Safe Drinking Water
Act (SDWA) are applicable to the J-Field Surficial Aquifer. Due to the presence of mobile
and residual DNAPL, it has been determined to be technically impracticable to attain the
cleanup levels (ARARs) for the individual DNAPL constituents and their degradation
products. Additionally, because inorganic contaminants are
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Table 6
EPA Evaluation Criteria
Criteria
Description
Threshold Criteria
Overall Protection of Human Health and the
Environment
Addresses whether or not a remedy provides adequate
protection and describes how risks posed through
each pathway are eliminated, reduced, or controlled
through treatment, engineering controls, or
institutional controls.
Compliance with ARARs
Addresses whether or not a remedy will meet all of the
applicable or relevant and appropriate federal and state
environmental statutes and requirements or whether
grounds exist for invoking a waiver.
Primary Balancing Criteria
Long-Term Effectiveness and Permanence
Refers to the ability of a remedy to maintain reliable
protection of human health and the environment over
time, once cleanup goals have been met.
Reduction of Toxicity, Mobility, and Volume Through
Treatment
Refers to the anticipated performance of the treatment
technologies a remedy may employ.
Short-Term Effectiveness
Addresses the period of time needed to achieve
protection and any adverse impacts on human health
and the environment that may be posed during the
construction and implementation period until the
cleanup goals are achieved.
Implementability
Refers to the technical and administrative feasibility of
a remedy, including the availability of materials and
services needed to implement a particular option.
Cost
Includes the estimated capital and operation and
maintenance costs and net present worth costs of each
alternative.
Modifying Criteria
State/Support Agency Acceptance
Indicates whether, based on a review of the RI/FS
reports and Proposed Plan, the state/ support agency
concurs, opposes, or has no comment on the preferred
alternative at the present time.
Community Acceptance
Indicates whether the public agrees with the selected
remedy, based on review of public comments received
on the Proposed Plan.
Each alternative was evaluated using the nine EPA evaluation criteria described above. Using the results
of this evaluation, the Army compared the alternatives and selected the preferred cleanup alternative for
the site presented in this Record of Decision.
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co-located with the VOC plume, it is also technically impracticable to achieve the ARARs for
inorganic constituents. EPA is waiving these ARARs due to technical impracticability.
ARARs to be waived are the SDWA MCLs and non-zero MCLGs (40 Code of Federal
Regulations [CFR] 141.11-12, 141.50-51, and 141.61-62), which were adopted by the State of
Maryland in Code of Maryland Regulations (COMAR) 26.04.01 Regulation of Water Supply,
Sewage Disposal, and Solid Waste; and State of Maryland Annotated Code Title 9 - Water
Pollution Control (Sections 9-302 and 9-322) as implemented by COMAR 26.08.02.09
Groundwater Quality Standards. RCRA groundwater protection standards referenced in
Chapter 40 of Code of Federal Regulations (CFR) Section 264.94 are not applicable to J-Field
groundwater since the TBPs are not regulated units. Furthermore, the Federal Facility
Agreement provides that a remedial action under CERCLA meets and is equivalent to
corrective action under RCRA. Federal and state AWQC are applicable to surface water in
the marsh. Chemical-specific ARARs are listed in Table 7.
¦ Action-Specific ARARs—Site work associated with Institutional Controls and monitoring
under Alternative 2 would meet action-specific ARARs. Action-specific ARARs associated
with Alternatives 3 and 4, such as the planting of new trees and the installation of additional
monitoring wells (if required), would be met. These action-specific ARARs would also be
met by the ARS. Action-specific ARARs associated with Alternative 5, such as well drilling
regulations and VOC emission requirements from the GCW system, would be met. In
Alternative 6, action-specific ARARs associated with well drilling, modifications to the Old
O-Field treatment plant (if Option A is selected and if modifications are required) would be
met. Action-specific ARARs are summarized in Table 8.
¦ Location-Specific ARARs—Site work associated with institutional controls and monitoring
under Alternative 2 would meet location- specific ARARs. In Alternatives 3 and 4, activities
associated with planting of additional trees would meet applicable location-specific ARARs.
Location-specific ARARs would also be met in Alternatives 5 and 6 during installation of
wells, and placement of the temporary storage tank and other temporary construction
features (Alternative 6) Location-specific ARARs would also be met by the ARS.
Location-specific ARARs are summarized in Table 9.
2.8.2.2 Primary Balancing Criteria
Long-Term Effectiveness and Permanence. Future risk could remain due to the movement of the
contaminated plume to the marsh. The additional Institutional Controls used in Alternative 2 will prevent
exposure of receptors to untreated groundwater by prohibiting its use. Monitoring can be added to
Alternative 2 to verify that exposure scenarios do not change. Because limited long-term performance
information is available through these technologies, the actual progress can be measured only through the
Long Term Monitoring (LTM) program.
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Table 7
Chemical-Specific ARARs
Act
Description
Status
Federal Safe Drinking Water Act 40 CFR 141.11-12,
141.61-62
Sets maximum contaminant levels allowable for
drinking water.
Relevant and
Appropriate
National Recommended Water Quality Criteria
published as a guidance in adopting water quality
standards pursuant to Section 303(c) of the CWA,
40 CFR 131, revised criteria from 63 FR 67548 of
7 December 1998
Surface water quality standards
Applicable
State of Maryland Regulation of Water Supply,
Sewage Disposal, and Solid Waste COMAR
26.04.01
Sets maximum contaminant levels allowable for
drinking water.
Relevant and
Appropriate
State of Maryland Annotated Code Title 9 - Water
Pollution Control as implemented by COMAR
26.08.02.09 Groundwater Quality Standards
State groundwater anti-degradation policy
Relevant and
Appropriate
State of Maryland Surface-Water Quality Criteria,
COMAR 26.08.02
State surface water quality standards
Applicable
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Table 8
Action-Specific ARARs
FEDERAL
Act
Action
Status
Description
RCRA -
Hazardous Waste
Management (40
CFR260 Subtitle
C)
Management
of hazardous
waste
generated
during
construction/
installation
and operation
of remediation
system
components
Applicable
RCRA regulates the generation, transport, storage, treatment, and
disposal of hazardous waste.
RCRA -
Preparedness and
Prevention (40
CFR 264.30- 31,
Subpart C)
Safety
procedures
during
construction/
installation and
operation of
remediation
system
components
Applicable
This regulation outlines requirements for safety equipment and
spill control.
RCRA -
Contingency Plan
and Emergency
Procedures(40
CFR 264.50-56,
Subpart D)
Safety
procedures
during
construction/
installation and
operation of
remediation
system
components
Applicable
This regulation outlines the requirements for emergency procedures
to be used following explosions, fires, etc.
RCRA - Closure
and Post Closure
(40 CFR 264.110-
120, Subpart G)
Post
remediation
monitoring
Relevant and
appropriate
This regulation details specific requirements for closure and
post-closure of hazardous waste facilities.
Clean Water Act
(CWA) - Surface-
water quality
criteria (CWA
Section 303(c), 40
CFR 131)
Discharges to
surface waters
Relevant and
appropriate
This regulation publishes the National Recommended Water
Quality Criteria as guidance in adopting water quality standards.
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Table 8
Action-Specific ARARs
(Continued)
FEDERAL (Continued)
Act
Action
Status
Description
Clean Water Act -
Effluent
limitations for
point source
discharge (CWA
Section 402,40
CFR 125 and 401)
Discharges to
surface waters
Relevant and
Appropriate
This regulation establishes National Pollutant Discharge
Elimination System (NPDES) program requirements for discharge
of treated water to a point source.
National
Recommended
Water Quality
Criteria (40 CFR
131)
Surface water
quality
Applicable
This regulation establishes Ambient Water Quality Criteria for
surface water bodies.
Clean Air Act -
Emission
Standards (40
CFR 61)
Emissions
from
remediation
system
components
Relevant and
Appropriate
This regulation establishes National Emission Standards for
Elazardous Air Pollutants (NESEIAPs) for owners or operators of
sources of
hazardous pollutants.
MARYLAND
CO MAR*
Subtitle
Action
Status
Description
MDE- Elazardous
Waste
Management
COMAR 26.13
Management
of hazardous
waste during
construction/
installation and
operation of
remediation
system
components
Applicable
Regulates the generation, transport, storage, treatment, and
disposal of hazardous waste.
Maryland Surface
Water Quality
Regulations
(COMAR
26.08.02)
Discharges to
surface waters
Relevant and
Appropriate
This regulation establishes Maryland Surface Water Quality
Criteria to protect public health or welfare, enhance the quality of
water, and protect aquatic resources.
Maryland Air
Quality
Regulations -
(COMAR
26.11.06)
Emissions
from
construction
and operation
of remediation
system
components.
Relevant and
Appropriate
This regulation sets general emission standards, prohibitions, and
restrictions on emissions generated from installations.
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Table 8
Action-Specific ARARs
(Continued)
MARYLAND (Continued)
CO MAR*
Subtitle
Action
Status
Description
Maryland Erosion
and Sediment
Control
Regulations
(COMAR
23.17.01)
Soil
disturbance
activities such
as monitor
well drilling
and tree
planting
Relevant and
Appropriate
This regulation regulates erosion and sediment controls to be
implemented during soil disturbance activities.
Maryland
Annotated Code
Title 3 - Noise
Control
Noise control
during
construction
activities
Applicable
Except as otherwise provided by law, MDE adopts environmental
noise standards, sound-level limits, and noise control rules and
regulations as necessary to protect the public health, the general
welfare, and property.
*COMAR = Code of Maryland Regulations.
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Table 9
Location-Specific ARARs
FEDERAL
Act
Action
Status
Description
RCRA - Location
of facilities in
floodplains (40
CFR 264.18(b))
Construction
activities in
floodplain
Relevant
and
Appropriate
This regulation states that a facility be designed, constructed,
operated, and maintained to prevent washout of any hazardous
waste by a 100-year flood.
Fish and Wildlife
Coordination Act
- Fish and wildlife
conservation (16
USC 661 etseq.,
40 CFR 6.302,
6(h))
Disturbances
to wildlife
from remedial
activities
Applicable
This regulation states that wildlife conservation be given equal
consideration and be coordinated with other aspects of water
resource development programs.
Endangered
Species Act (16
USC 1531 etseq.,
33 CFR 320-330,
40 CFR 6.302, 50
CFR 27, 50 CFR
200, 50 CFR
402.01, .02)
Activities
which may
affect
endangered
species from
remedial
activities
Applicable
This regulation provides a program for the conservation of
threatened and endangered plants and animals and the habitats in
which they are found. A variety of endangered species have been
identify in the EA and may be present at J-Field.
Coastal Zone
Management Act
(CZMA) (16 USC
1451, et seq.)
Remedial
activities
within the
coastal zone
Relevant
and
Appropriate
The Coastal Zone Management Act requires a consistency
determination and state agreement prior to the issuance or
expansion of activities within a state with a federally-approved
Coastal Management Program when activities that would occur
within, or outside, that states coastal zone will affect land or water
uses or natural resources of the states coastal zone.
Natural
Resources
Article, Subtitle
18, Chesapeake
Bay Critical
Area Protection
Program
Remedial
activities
within the
Chesapeake
Bay Critical
Area
Relevant
and
Appropriate
This subtitle establishes a Resource Protection Program for the
Chesapeake Bay and its tributaries by fostering more sensitive
development activity for certain shoreline areas to minimize
damage to water quality and natural habitats and implements the
Program on a cooperative basis between the State and affected local
governments, with local governments establishing and
implementing their programs in a consistent and uniform manner
subject to State criteria and oversight.
Executive Order
11988 -
Floodplain
management
Remedial
actions in the
floodplain
Applicable
This executive order calls for avoiding long- and short-term impacts
to a flood plain due to occupancy or modifications.
Executive Order
11988 - Protection
of wetlands
Reduce or
eliminate
wetlands
impact during
construction
activities
Applicable
This executive order requires federal agencies to take action to
avoid adversely impacting wetlands wherever possible, to minimize
wetlands destruction.
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Table 9
Location-Specific ARARs
(Continued)
FEDERAL (Continued)
Act
Action
Status
Description
Bald and Golden
Eagle Protection
Act (16 USC 668
et seq.) of 1940
Eliminate
disturbance to
Bald Eagle
during
construction
activities
Applicable
Establishes regulations to protect bald and golden eagles. These
species have been observed at EA and may be present at J-Field.
Migratory Bird
Treaty Act (16
USC 703 et seq.)
Eliminate
disturbance to
migratory
birds during
construction
activities
Applicable
Establishes regulations to protect migratory birds. Migratory birds
may be present at J-Field at certain times of the year.
MARYLAND
CO MAR*
Subtitle
Action
Status
Description
Maryland Tidal
Wetlands
Regulations
(COMAR
26.24.01)
Remedial
actions in the
wetlands areas
Applicable
This regulation sets goals to preserve the tidal wetlands of the State
of Maryland, prevent their loss and plunder, and strive for a net
resource gain in tidal wetland acreage and function.
The Maryland
Environmental
Policy Act
(Chapter 703 of
the Laws of 1973,
as codified in
Sections 1-301
through 1-305)
Remediation
activities
which may
have sort or
long term
impacts.
Relevant
and
Appropriate
This act mandates that state agencies, in balancing economic
development and environmental quality, will engage in thoughtful
consideration of the environmental effects of their proposed
actions.
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A reduction in risk can also be expected in Alternative 5. Although GCW systems have proven to be
successful at some sites, site conditions as described in the TI Evaluation make its implementation at
J-Field inefficient as a means of mass removal. The pump-and-treat or dispose technology used in
Alternative 6 is the most reliable method of reducing the risk posed by contaminants. In this alternative, all
of the groundwater that enters the well is pumped out completely, instead of recirculating a portion of it
back to the aquifer as in Alternative 5. Therefore, the mass removal of contaminants may be more
expeditious. Permanent removal of contaminants from groundwater makes the engineering controls used
in this alternative adequate and reliable. However, as with Alternative 5, this process will be restricted by
the low permeability soils and the presence of residual DNAPL.
Reduction of Toxicity, Mobility, and Volume. In Alternative 2, a verifiable reduction in toxicity,
mobility, and volume is not expected in the foreseeable future. In Alternatives 3 and 4 and in the ARS, a
reduction in toxicity, mobility, and volume of contaminants is expected over time through biodegradation
and/ or abiotic degradation of contaminants. The degree of reduction in toxicity, mobility, and volume of
the parent compounds, as well as the toxicity and volume of the degradation products, need to be
evaluated through the LTM program. Additionally, in the ARS, removal of free-phase DNAPL would
reduce the toxicity, mobility, and volume of contaminants. The extent of this reduction is dependent on the
amount of product recovered. In Alternative 5, the mobility of the contaminants would be reduced by
removing them from groundwater. The toxicity and volume would be reduced only if the contaminants
removed by the treatment system were chemically destroyed during the operations. However, permanent
removal of contaminants from groundwater would reduce the overall toxicity and volume of contaminated
groundwater at J-Field. In Alternative 6, the mobility of the contaminants would be reduced by the
removal of contaminants from groundwater. The toxicity and volume of the contaminants would also be
reduced by treatment and/or destruction of contaminants at the Old O-Field treatment plant or at an
off-site treatment plant.
Short-Term Effectiveness. Alternative 2 includes minor site activity such as posting signs indicating that
the area poses a potential threat to the community or the workers. Risk to site workers from these
activities can be easily controlled. There would be minimal additional risk in Alternatives 3 and 4 and in
the ARS during planting of trees, well drilling (if any additional monitoring wells are required), and
sampling activities. In Alternative 5, workers would be protected from noise, dust, and construction
hazards by taking appropriate safety precautions. Air emissions from the GCW system would be
controlled in accordance with emission requirements. There would be no significant effect on the
community because no one lives or routinely works in the TBP area or in the vicinity of J Field. In
Alternative 6, workers would be protected from noise, dust, and construction hazards by taking
appropriate safety measures. Precautions would be taken to prevent spillage of groundwater when
transferring stored groundwater from the temporary tank to the truck, during the transport process, and
when discharging to the Old O-Field or off-site treatment plant.
Implementability. There are no technical or administrative issues associated with the implementation of
Alternative 2. Alternatives 3 and 4 can be implemented easily because the only activities associated with
these alternatives are planting of additional trees and sampling activities. In Alternative 3 and the ARS,
sampling and monitoring activities
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can be performed by employing personnel trained in phytoremediation-related work. Implementation of
Alternative 5 requires vendor involvement because the GCW process is patented. Installation of GCWs
can be performed by local contractors specializing in well installation. Equipment must be ordered in
advance to meet schedule requirements. Installation of groundwater pumping wells in Alternative 6 can
be performed by local contractors specializing in well installation. All alternatives involving invasive
construction activities (Alternatives 2 through 6) would require UXO clearance. Transportation of
groundwater can be accomplished using a dedicated truck. If any modifications are needed to the Old
O-Field treatment plant, they can be performed using local vendors specializing in water treatment
equipment and installation. All alternatives require a TI Waiver for implementation.
Cost. Total present worth costs were estimated for the six alternatives for a period of 30 years. Costs for
CERCLA 5-Year reviews were calculated based on one review every 5 years for 30 years. Detailed
estimates for capital and O&M costs are included in the FS and the TI Evaluation, which is Appendix C
of the FS. A summary of present worth costs for the comparative evaluation of the alternatives as
presented in the FS is as follows:
Present-Worth Cost*
Alternative 1:
$0
Alternative 2:
$46,000
Alternative 3:
$999,000
Alternative 4:
$1,778,000
Alternative 5:
$5,161,000
Alternative 6:
Option A $6,286,000
Option B $18,386,000
Alternative Remedial
Strategy
$1,877,000
*Does not include cost of 5-Year Reviews
2.8.2.3 Modifying Criteria
State/Support Agency Acceptance.
MDE concurs with the Selected Remedy.
Community Acceptance.
Based upon responses received during the Public Comment Period, the public accepts the Selected
Remedy.
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2.8.3 The Selected Remedy
The ARS as presented in the TI Evaluation is the Selected Remedy since it best satisfies the threshold
CERCLA Evaluation Criteria of Overall Protectiveness and Compliance with ARARs that have not been
waived. Other criteria are also satisfied and the alternative is cost-effective in comparison with other
alternatives. The Selected Remedy consists of establishing Institutional Controls, continuation of
phytoremediation, monitoring biodegradation processes, abandonment and replacement of Confined
Aquifer well JF-51, possible addition of a supplement to JF-51 to foster degradation of the isolated
contamination at JF-51 in the Confined Aquifer, implementation of free phase DNAPL recovery in the
localized area surrounding temporary Geoprobe well GP-53, and continued monitoring of the Confined
Aquifer.
In the Selected Remedy, the implementation of Institutional Controls would involve prohibiting
unauthorized excavation, the restriction of Surficial Aquifer groundwater use, and the use of untreated
upper Confined Aquifer groundwater unless it meets all applicable standards and criteria, in order to
prevent exposure risks associated with contaminated groundwater. The ongoing phytoremediation
demonstration will be continued, including planting of additional trees and maintenance and monitoring for
all trees involved in the study. Groundwater will be monitored for contaminants as well as for
biodegradation parameters to assess the ongoing natural biodegradation processes which are treating the
contaminants. This monitoring will be conducted in accordance with the approved O&M/LTM Plan.
CERCLA reviews would be conducted every 5 years. Implementation of free phase DNAPL recovery in
the localized area surrounding temporary Geoprobe well GP-53 will be initiated.
The Selected Remedy provides long- and short-term protection to human health and the environment
through use restrictions. The adequacy and reliability of the institutional controls for restricting
groundwater use is considered high. Because no groundwater will be extracted, the alternative creates no
additional risks to the community, workers, or the environment due to the construction of an extraction and
treatment system.
The Selected Remedy provides contaminant mass reduction through Phytoremediation and biodegradation
processes, thus providing reduction in the toxicity, mobility, and volume of the contaminants.
The Selected Remedy is considered easy to implement Actions to be taken are limited to the prevention of
groundwater use to be regulated by the Army; the implementation of a monitoring program for
contaminants and for attenuation, biodegradation, and phytoremediation parameters; and planting of
additional phytoremediation trees.
Based on the best information available at this time, the preferred alternative will be protective of human
health and the environment through site management and will be cost-effective.
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Through the environmental program to monitor for contaminants in the Surficial and Confined Aquifers
and to monitor for biodegradation and phytoremediation parameters in the Surficial Aquifer, the Army will
be able to monitor the effectiveness of the remedy and determine whether adverse changes in risk have
occurred at the site.
2.8.4 The Statutory Determinations
The Selected Remedy discussed in Section 2.8.3 satisfies the requirements under Section 121 of
CERCLA for protecting human health and the environment, compliance with ARARs (except as waived
by the TI Waiver), and cost-effectiveness. The ARS (e.g. phytoremediation and natural processes) is
expected to prevent the further migration of the dissolved contaminant plume.
2.8.4.1 Protection of Human Health and the Environment
The Selected Remedy offers mitigation of risks to humans associated with the J-Field Surficial Aquifer
through Institutional Controls. Site access restrictions apply to the entire J-Field Study Area. Any adverse
short-term effects associated with the implementation of this alternative will be minimized to the maximum
extent practicable through the use of protective measures. For example, site workers will utilize all
appropriate safety clothing and employ safe work practices.
2.8.4.2 Compliance with ARARs
Chemical-specific, action-specific, and location-specific ARARs are presented in Tables 7, 8, and 9. The
Selected Remedy will comply with these ARARs, and with chemical-specific ARARs (except as waived
by the TI Waiver).
2.8.4.3 Cost-Effectiveness
The Selected Remedy is less costly than Alternatives 4, 5, and 6. Although the present worth cost of the
Selected Remedy is higher than the costs for Alternatives 1, 2, and 3, it does offer some additional
benefits.
2.8.4.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to
the Maximum Extent Practicable
This remedy utilizes phytoremediation, which is an innovative technology for groundwater. This remedy
utilizes permanent solutions as currently available to the maximum extent practicable for the site. This
action represents the final remedy for the J-Field Study Area, except for limited areas that remain active,
and represents the best balance of trade-offs among the alternatives with respect to the nine evaluation
criteria.
2.8.4.5 Preference for Treatment as a Principal Element
The preference for treatment as a principal element is not met in the TI Zone. The preference for
treatment is met by phytoremediation outside the TI Zone and by remedial actions in the Confined
Aquifer.
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2.8.4.6 Significant Changes from the Proposed Plan
The following significant changes from the Preferred Alternative in the Proposed Plan are included in this
ROD:
¦ During the July 2001 phytoremediation sampling event, VOC concentrations higher than
historical concentrations were found in a number of sampling locations. Groundwater
concentrations in exceedance of the reported solubility of 1,1,2,2-TeCA were reported for
two temporary Geoprobe wells. Also, apparent free phase DNAPL was found in the
laboratory sample collected from temporary Geoprobe well GP-53. Based on historical
groundwater data and the observed free phase DNAPL, residual DNAPL likely exists and
continues to contribute VOC mass to the dissolved-phase plume. The Selected Remedy
includes implementation of free phase DNAPL recovery in the localized area where DNAPL
was observed. The capital and O&M costs for the Selected Remedy have been modified to
include costs associated with this DNAPL recovery
¦ ARARs to be waived are the SDWA MCLs and non-zero MCLGs (40 Code of Federal
Regulations [CFR] 141.11-12, 141.50-51, and 141.61-62), which were adopted by the State of
Maryland in Code of Maryland Regulations (COMAR) 26.04.01 Regulation of Water Supply,
Sewage Disposal, and Solid Waste; and State of Maryland Annotated Code Title 9 - Water
Pollution Control (Sections 9-302 and 9-322) as implemented by COMAR 26.08.02.09
Groundwater Quality Standards.
2.9 PERFORMANCE STANDARDS
The requirement to meet MCLs and non-zero MCLGs within the portion of the zone defined as the TI
Zone in the Surficial Aquifer has been waived by EPA in the J-Field Surficial Aquifer due to the presence
of DNAPL. Standards for inorganic contaminants which are co-located with the VOC plume are also
being waived. ARARs to be waived are SDWA MCLs and non-zero MCLGs (40 Code of Federal
Regulations [CFR] 141.11-12, 141.50-51, and 141.61-62), which were adopted by the State of Maryland
in Code of Maryland Regulations (COMAR) 26.04.01 Regulation of Water Supply, Sewage Disposal, and
Solid Waste; and State of Maryland Annotated Code Title 9 - Water Pollution Control (sections 9-302
and 9-322) as implemented by COMAR 26.08.02.09 Groundwater Quality Standards. Monitoring of the
Surficial Aquifer groundwater within the TI Zone will be conducted to track the progress of the
phytoremediation and natural degradation processes and to detect plume migration. Specific details
regarding monitoring will be included in the O&M / LTM Plan.
The limits of the TI Zone are shown in Figure 8 and include the entire plume of contamination.
A plan for recovery of free phase DNAPL in the localized area, where DNAPL was observed during
phytoremediation sampling in July 2001 (near temporary Geoprobe well GP-53), will be developed within
3 months of ROD signature. A well will be installed in an appropriate location to attempt to intercept the
free phase DNAPL material. The well will be bailed manually periodically and any recovered product
and/ or water will be containerized
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for proper disposal. The specific well location will be determined by preliminary investigations using direct
push technology in an effort to map the configuration of the potential DNAPL bearing formation and
locate the well in a localized low point for most effective recovery.
ARARs will be achieved in all portions of the Confined Aquifer.
An Operations and Maintenance and Long Term Monitoring (O&M / LTM) Plan will be developed to
address the locations, frequency, and analytical parameters for monitoring of the phytoremediation and
biodegradation activity, and conditions in the Surficial and Confined Aquifer and the freshwater marsh.
The O&M / LTM plan will also specify maintenance procedures for remedy components including
maintenance of the phytoremediation trees and the Monitoring well network. The Draft O&M /LTM Plan
will be developed within 6 months of ROD signature.
A LUCIP will be developed and submitted to EPA within 6 months of ROD signature for review and
agreement. The LUCIP will include restriction of Surficial Aquifer groundwater use, and restriction of the
use of untreated upper Confined Aquifer groundwater unless it meets all applicable standards and criteria.
The LUCIP will clearly identify the Army authority responsible for implementation, monitoring, reporting,
and enforcement of the institutional controls.
CERCLA 5-Year Reviews will be conducted for this site. In addition to the requirements set forth in EPA
and DoD guidance documents, the Army will also conduct a technology review for innovative methods of
treating the groundwater in the Surficial Aquifer. Periodic inspections of the J-Field shoreline for signs of
erosion will be conducted.
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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 J-Field
Proposed Plan and the Army's responses to these concerns.
The Army held public meetings on March 20 and 22, 2001, to formally present the Proposed Plan and to
answer questions and receive comments. The transcripts of these meetings are part of the Administrative
Record for the site. During the public comment period, written comments were also received. All comments
and concerns summarized below have been considered by the Army and EPA in selecting the cleanup method
for the J-Field Surficial Aquifer.
This responsiveness summary is divided into the following sections:
3.1 Overview.
3.2 Background on community involvement.
3.3 Summary of comments received during the public comment period and the Army' s responses.
3.4 Comments from March Public Meetings.
3.5 Written Comments Received.
3.1 OVERVIEW
At the time of the public comment period, the Army had endorsed a preferred alternative for the J-Field
Surficial Aquifer. The Army proposed implementing institutional controls, continuing the phytoremediation
project and planting additional trees, and continuing groundwater sampling and monitoring of the
biodegradation process. In addition, the Confined Aquifer will be monitored. The addition of a supplemental
material to foster degradation of the isolated contaminants in Confined Aquifer well JF-51 will be considered
during Remedial Design. MDE concurs with the selected remedy. The community also agrees with the
selected alternative.
3.2 BACKGROUND ON COMMUNITY INVOLVEMENT
The Army has maintained a highly active public involvement and information program throughout the
CERCLA process. It is the Army's intent to actively solicit input from the community and to involve the
community through the decision making process. Highlights of the community's involvement in the J-Field
Proposed Plan and J-Field activities during the last few years follow:
# The Army has kept the Restoration Advisory Board updated on the J-Field Study Area since the
Board's creation; prior to that, the Army regularly discussed the J-Field Study Area with the
Board's predecessor, the Technical Review Committee. In January 2001, the Army discussed
the FS for the Surficial Aquifer
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and the alternatives that would be part of the Proposed Plan. The Army also provided the Board
members with a copy of the Proposed Plan for their review during the formal public comment
period.
# The Army released a Proposed Plan for the J-Field Surficial Aquifer for public comment on
March 9, 2001. Copies were available to the public through Administrative Record locations at
the Joppa and Aberdeen branches of Harford County Library and Miller Library at Washington
College in Kent County, as well as at two information repository locations at the Edgewood
Library in Harford County and the Cecilton Library in Cecil County. A copy of the Proposed
Plan also was posted on the Installation Restoration Program's Web Site, and the public was
invited to comment through the Web Site.
# A 45-day public comment period on the Proposed Plan ran from March 9 to April 23, 2001.
# The Army prepared a press release announcing the availability of the Proposed Plan, the dates
of the public comment period, and the date and time of the two public meetings. The Army
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.
# The Army prepared and published a fact sheet on the Proposed Plan including information on the
public meetings. The Army mailed copies of this fact sheet to more than 2,600 citizens and
elected officials on its Installation Restoration Program mailing list. The fact sheet included a
form which citizens could use to submit their comments.
# On March 20, the Army held a public meeting at the Edgewood Senior Center in Edgewood,
Maryland. Representatives of the Army and MDE were present. Army representatives
presented information on the site and on the proposed cleanup alternatives. On March 22, the
Army held a second public meeting at Chestertown Middle School in Chestertown, Maryland,
where information on the Proposed Plan also was presented.
3.3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
AND AGENCY RESPONSES
Comments raised during the public comment period on the J-Field Proposed Plan are summarized below. The
comments are categorized by source.
COMMENTS FROM QUESTIONNAIRE INCLUDED WITH FACT SHEET
As part of its fact sheet on the Proposed Plan, the Army included a questionnaire that residents could return
with their comments. Over 2,600 postage paid questionnaire forms were sent to the community to solicit the
public's preferences regarding remedy selection. The Army has received 8 completed forms. The Army
believes that the public's overall
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comfort with our progress on this site may be reflected in the fact that relatively few forms were returned
with comments. The alternatives preferred by individuals returning comment forms were:
Remedial Alternative
Favorable Responses
Alternative No. 1 - Take No Action.
0
Alternative No. 2 - Institutional Controls.
0
Alternative No. 3 - Phytoremediation with Institutional Controls.
0
Alternative No. 4 - Monitored Natural Attenuation with Institutional Controls and
Phytoremediation.
1
Alternative No. 5 - Integrated Remedial System: In-Situ Source Area Treatment Using
Groundwater Circulation Wells, Monitored Natural Attenuation, and Phytoremediation.
1
Alternative No. 6 - Integrated Remedial System: Source Area Treatment Using
Groundwater Pumping, Transport and Treatment of Groundwater, Monitored Natural
Attenuation and Phytoremediation.
0
Alternative No. 7 - Alternative Remedial Strategy.
5
Either Alternative No. 4 or Alternative No. 7.
1
Total Responses
8
Written comments included on the forms are summarized below.
Comment No. 1: [Commenter selected Alternative 4 or Alternative 7] "I accept #7 given that the sampling
and monitoring occurs on a quarterly basis as described for Alternative 4. It is not clear to me why option #7
will cost less than option #4 - the lower down amount leads me to believe that the sampling may occur less
frequently under option 7. If that is the case, I support option 4.1 very much approve of the phytoremediation
and biodegradation efforts and do not support trying to use this groundwater in any way."
Response No. 1:
The primary differences in cost between Alternative 4 and the Alternative Remedial Strategy (ARS)
(Alternative 7) are as follows:
# The biodegradation parameters will initially be monitored semi-annually for the ARS as compared
to quarterly for Alternative 4. In both cases, the monitoring frequency will decrease to annually
in the fourth year.
Fewer wells will be monitored under the ARS than for Alternative 4. The monitoring locations will still include
sites upgradient of the hot spot, at the hot spot, and downgradient from the hot spot. The higher level of
activity in Alternative 4 was to support the Monitored Natural Attenuation demonstration, which requires
analysis of contaminant trends over time and across the site to document more completely the degradation
processes. The Army feels that the monitoring frequencies provided in the ARS are sufficient to ensure that
site conditions are closely watched. Flow conditions in the Surficial Aquifer are very slow, and therefore,
semiannual monitoring is frequent
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enough to identify any movement in the contaminants. For example, as discussed at the January 2001 RAB
meeting, the velocity of the water in the Surficial Aquifer is estimated to be on the order of 2 feet per year,
and the contaminants move more slowly due to attenuation processes. Therefore, the distance the
contamination might move between semiannual events, if it moves at all, may be as little as 1-2 feet, affording
time to detect movement before contaminants migrate off-site.
Comment No. 2: [Commenter selected Alternative 5] "I am concerned about the use of chemical munitions
and disposal of radioactive waste on site. More information should be presented publicly so any concerns can
be addressed and remedied."
Response No. 2:
The Army conducted extensive background reviews during the Remedial Investigation (RI) and sampled for
materials which may have been disposed of at J-Field. Actions taken to date have considered these RI data.
A brief summary of the field investigations conducted to date in the J-Field Area includes:
# 72 groundwater monitoring wells installed.
# 271 groundwater samples taken.
# 607 soil samples (total) taken.
# 54 sediment samples taken.
# 100 acres of geophysical surveys to identify subsurface anomalies.
# 71 surface water samples taken.
# 2 Removal Actions conducted.
Over $15,000,000 has been invested to date in environmental investigations for the J-Field Study Area. The
Army's investigations have been extremely thorough. There is no need for further investigation of the
DSERTS sites covered in this ROD. The Army also will continue its program of keeping the public informed
of the results of its studies and investigations.
Comment No. 3: [Commenter selected Alternative 7] "Why are the activities at J-Field before WWII not
known? Certainly records were kept; you are using too general the proposition that APG isn't aware of the
specific explosives and chemicals that were used."
Response No. 3:
Prior to passage of environmental laws beginning in the 1970s, records regarding disposal activities were not
required to be kept by the military or by the private sector for environmental/pollution control purposes.
However, some operating records have been found. As provided in Appendix C of the J-Field Remedial
Investigation (Argonne, 1998), the Army conducted a comprehensive and exhaustive search of APG's
available records during the RI process.
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The Army knows of no additional records that have not been searched. The record search during the RI
included:
# Historical photographs.
# Interviews with long-time employees.
# Organizational History Files of Edgewood Arsenal, 1917-1942.
# Organizational History Files of Chemical Warfare Center 1942-1946.
# Organizational History Files of the Technical Escort Unit 1942 to 1985.
Based on this search, there is a reasonable understanding of the types of materials used at APG. Although
specific disposal records are not available, it is likely that some portion of these materials were disposed at
J-Field. The RI included looking for these types of materials, in addition to more conventional environmental
contaminants. Response No. 2 outlines the effort associated with this remedial investigation effort. Although
records of the precise activities conducted at a given location may be incomplete, the RI was wide-reaching
enough to account for these uncertainties.
Comment No. 4: [Commenter selected Alternative 7] "I'm in agreement with the recommended alternative.
This indicates that the contaminants will be confined in a defined area while being reduced in concentration.
Since there appears to be no urgent timeline to meet in future development of this land, the government can
continue to monitor the situation and address future technologies that apply. I think the overall situation is cost
effective with this alternative."
Response No. 4:
APG acknowledges and agrees with the statements in the above comment that the Selected Remedy is the
appropriate one at this time. As indicated in the Proposed Plan, the Army will continue to look at new
technologies as they become available. The Army appreciates the commenter's input in this regard.
Comment No. 5: [Commenter selected alternative 7] "I feel alternative #7 is the best method at this time.
Although I believe the Army is acting in a sincere manner, please keep everyone informed about this serious
environmental problem. I have lived in Bowley's Quarters for five years and only now have begun to
understand completely how things we did years ago impact us now. Thank you for your time."
Response No. 5:
APG acknowledges and agrees with the statements in the above comment that the Selected Remedy is the
appropriate one at this time. APG has maintained a highly active public involvement and information program
throughout the CERCLA process. It is the Army's intent to actively solicit input from the community and to
involve the community through the decision-making process. APG will continue to keep the community
informed and involved in remediation decisions and appreciates the community's involvement in these
decisions.
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3.4 COMMENTS FROM THE MARCH PUBLIC MEETINGS
A full transcript of the public meeting is at Administrative Record repositories. Following is a summary of the
comments made at the meeting.
Comment No. 6: A resident suggested the Army consider using the lower aquifer as an irrigation system
during dry spells.
Response No. 6:
APG will further evaluate this suggestion. Several factors will affect the feasibility of this option. One of the
goals of the phytoremediation grove is, of course, to draw water from the aquifer, and for this reason, it is
intended that the tree root systems reach into the deeper portion of the Surficial Aquifer. It is possible that
surface irrigation would tend to direct the roots to shallower zones. Therefore, the balance between the need
for deep roots, and the desirable goal of using Confined Aquifer water for supplemental irrigation, must be
evaluated. The evaluation will also consider potential negative consequences of pumping such as, but not
limited to, the effect on the movement of contaminants. The Army appreciates this suggestion and will
consider this during remedial design and operation.
3.5 WRITTEN COMMENTS RECEIVED
COMMENTS FROM ABERDEEN PROVING GROUND SUPERFUND CITIZENS COALITION
(APGSCC)
APGSCC is the recipient of Technical Assistance Grants (TAGS) from the U. S. Environmental Protection
Agency. These grants allow APGSCC to hire consultants to help them review and comment on technical
documents. The following comments have been prepared by Dr. Cal Baier-Anderson of the University of
Maryland.
"For a decade, APGSCC has worked closely with APG and the EPA in the remedial efforts at J-Field. We
have provided comments throughout the remediation process."
Comment No. 7: "APGSCC would have preferred to see a more aggressive groundwater treatment plan,
however, we understand that the nature of the contamination and the site geology make this technically
impractical, such that we concur with the preferred remedial strategy.
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Response No. 7:
The Army also would have liked to be able to implement a more aggressive groundwater treatment plan. The
Army has considered and tested a variety of technologies over the past 10 years to attempt to actively remove
or treat the contaminants in the Surficial Aquifer. As summarized in the various test reports and the FS, the
performance of these active technologies has been limited by site-specific constraints such as the high
heterogeneity and low permeability of the aquifer. Furthermore, the testing and modeling conducted during
the FS suggests that because of these aquifer limitations and the high degree of natural degradation in the
marsh areas, active treatment does not fundamentally improve the overall removal of contamination in the
long term. One of the potential advantages of the passive phytoremediation trees is that they can be planted
in large numbers at moderate cost to influence the groundwater.
The Army will continue to look for new technology that might be developed and would be effective at this
site. This will be formally reviewed in the CERCLA 5-Year Review process. However, ongoing review of
emerging approaches will continue in the interim.
Comment No. 8: "We would, however, like to express our concern that the Proposed Plan may give the
false appearance that the remedial actions at J-Field mean that it is now "safe" and can be cleared for
unrestricted use. Since we know this is not the case, it is extremely important that the Proposed Plan and the
Record of Decision (ROD), which will follow, present an accurate assessment of risks present at J-Field. For
example:
The documents should state that while chemical contamination under an industrial future use scenario may
not pose a significant risk to human health, the presence of unexploded ordnance and chemical agent
precludes unrestricted use until appropriate mitigating measures are technically and economically feasible.
Moreover, active open burning/open detonation sites at J-Field, not included in these investigations, may also
be contributing significant contamination that will require cleanup in the future. APG will undoubtedly face
increasing political pressure to find new uses for its former ranges. Hazards and risks associated with a site
may be ignored by those with political interests if not clearly stated. APG must be prepared to present a
complete and accurate assessment of all known and suspect risks and hazards, including unexploded ordnance
and chemical agent."
Response No. 8:
The Institutional Controls, which currently exist and which will be expanded as part of the Selected Remedy,
will be protective of human health from the standpoint of both chemical contamination and UXO/CWM.
During the CERCLA 5-Year Reviews, the Army will be looking for UXO throughout the site as well as
monitoring the Shoreline Erosion Control system. If the site use changes from that currently anticipated, the
Army will re-evaluate the protective measures. The remedial actions described in this ROD will not render
the J-Field Study Area "safe" for unrestricted use. The CWM and UXO present at the site preclude J-Field's
use as a residential area.
In accordance with DOD Policy, LUCs will be developed both for APG as a whole and for the J-Field Study
Area
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specifically. The LUC for APG has currently been prepared in Draft form.
As stated in the DOD guidance, LUCs include any type of physical, legal, or administrative mechanism that
restricts the use of, or limits access to, real property to prevent or reduce risks to human health and the
environment. Institutional Controls as discussed in the NCP and presented in this ROD, are legal mechanisms
imposed to ensure that restrictions on land use developed as part of a remedy decision stay in place. The
intent of the LUC policy is to ensure that land use activities in the future remain compatible with the land use
restrictions imposed on the property during the environmental restoration process. A LUCIP will be developed
and submitted to EPA within 6 months of ROD signature for review and agreement. The LUCIP will include
restriction of Surficial Aquifer groundwater use, and restriction of the use of untreated upper Confined
Aquifer groundwater unless it meets all applicable standards and criteria. This document will further clarify
the required restriction and further ensure protection against exposure to UXO/CXM concerns. The Army
will aggressively implement and monitor the Land Use Controls specified in the Plan to further ensure the
protectiveness of these restrictions.
At present, Open Burning/Open Detonation (OB/OD) is considered one of the few safe ways currently
available to dispose of explosives. Current OB/OD practices are aimed at making the process as
environmentally acceptable as is possible given the nature of the operation, by conducting the operations
during suitable weather conditions to control dispersion, when possible.
However, the Army is seeking alternatives to OB/OD and several alternative methods are under
development. Currently, there are no Open Burning activities at J-Field. Under the LUC plans, there may be
long-term monitoring for parameters from Open Detonation. During the RCRA permit application process,
an outline was prepared for a unit Closure Plan. The Closure Plan will be finalized when the unit is closed.
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4. BIBLIOGRAPHY
Accuscience Environmental. 2000. Geochemical Evaluation of Arsenic and Lead Mobility, Toxic Burning
Pit Area, J-Field, Aberdeen Proving Ground, MD. August 2000.
Argonne (Argonne National Laboratory). 1998. Draft Final Remedial Investigation Report for J-Field,
Aberdeen Proving Ground, Maryland, June 1998.
Army (U.S. Army). 1996. J-Field Soil Operable Unit Record of Decision, Final. September 1996.
Drummond, David D. and Joel D. Blomquist.1993. Hydrogeology, Water-Supply Potential, and Water
Quality of the Coastal Plain Aquifers of Harford County, Maryland. Report of Investigations No. 58,
Maryland Geological Survey.
GP (General Physics). 1999. Letter to Commander, Aberdeen Proving Ground. Re: J-Field Water Level
Measurements Monthly Update.
Hughes, W.B. 1995. Ground Water Flow and the Possible Effects of Remedial Actions at J-Field,
Aberdeen Proving Ground, Maryland. U.S. Geological Survey, Water-Resources Investigations Report.
95-4075. p. 39.
Otten, E.G., and R.J. Mandle. 1984. Hydrogeology of the Upper Chesapeake Bay Area, Maryland, with
Emphasis on Aquifers in the Potomac Group: Maryland Geological Survey Report of Investigation No.
39, p. 62.
Phelan, Daniel J., Lisa D. Olsen, Martha L. Cashel, Judith L. Tegeler, and Elizabeth H. Marchand.1998.
Assessment of Soil, Surface-Water, and Ground-Water Contamination at Selected Sites at J-Field,
Aberdeen Proving Ground, Maryland. U.S. Department of the Interior, U.S. Geological Survey.
USACE (U.S. Army Corps of Engineers). 1997. Geology and Geomorphology of Aberdeen Proving
Ground Aberdeen, Maryland. (Draft). U.S. Army Corps of Engineers, Waterways Experiment Station.
WESTON (Roy F. Weston, Inc.). 2001a. Technical Impracticability Evaluation for J-Field Surficial
Aquifer, Aberdeen Proving Ground, MD. April 2001.
WESTON (Roy F. Weston, Inc.). 2001b. Confined Aquifer Well Installation and Abandonment at J-Field,
Aberdeen Proving Ground, MD. August 2001.
WESTON (Roy F. Weston, Inc.). 2001c. Feasibility Study, J-Field Study Area, Aberdeen Proving
Ground, MD. September 2001.
WESTON (Roy F. Weston, Inc.). 2000a. Explanation of Significant Differences, J-Field Soil Operable
Unit Remedial Action, Edgewood Area, Aberdeen Proving Ground, MD. Final. October 2000.
WESTON (Roy F. Weston, Inc.). 2000b. Post Construction Survey Monitoring Program for J-Field
Shoreline Protection
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Project. September 2000.
WESTON (Roy F. Weston, Inc.). 1999. J-Field Phytoremediation, 1997Phytoremediation Study Final
Report, Aberdeen Proving Ground, Edgewood, Maryland, April 1999.
Yuen, C.R., J.Quinn, L.Martino, R.P. Biang, and T. Patton.1998. Natural Attenuation Study of
Groundwater at Toxic Burning Pits Area of Concern at J-Field, Aberdeen Proving Ground, Maryland.
Argonne National Laboratory, 1998.
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