Proving
U.S. Army Garrison
Aberdeen Proving Ground, Maryland
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Bush River Study Area
Record of Decision - Remedial Action at the
Operable Unit 3 Surface Units (EABRll-C,
EABRll-G, EABRM-H, and EABR11-I)
Final, September 2013
DISTRIBUTION RESTRICTION STATEMENT
APPROVED FOR PUBLIC RELEASE
DISTRIBUTION IS UNLIMITED :i!1521-A-l
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MDE
MARYLAND DEPARTMENT OF THE ENVIRONMENT
1800 Washington Boulevard • Baltimore MD 21230
410-537-3000 • 1-800-633-6101* www.mde.state.md.us
Martin O'Malley Robert M. Summers, Ph.D.
Governor Secretary
Anthony G. Brown
Lieutenant Governor
September 23, 2013
USAGAPG/Department of the Army
IMAP/PWE Mr. Rurik Loder
4304 Susquehanna Avenue
3rd Floor, Wing B
APG, MD 21005-5001
Re: Draft Final Record of Decision, Remedial Action at the Bush River Study Area
Operable Unit 3 Surface Units (EABR11-C, EABR11-G, EABR11-H, and
EABR11-1), Bush River Study Area, U.S. Army Garrison, Aberdeen Proving
Ground, Maryland - September 2013
Dear Mr. Loder:
The Federal Facilities Division (FFD) of the Maryland Department of the Environment's
Land Restoration Program has reviewed the referenced document. This Record of Decision
documents the Army's selected remedy for Operable Unit (OU) 3 Surface Units (EABR11-C,
EABR11-G, EABR11-H and EABR11-1) in the Bush River Study Area, which is located on the
Edgewood portion of Aberdeen Proving Ground. Operable Unit 3 Surface Units include the 22nd
Street Landfill, the Building E2364 Underground Storage Tank (UST) Site, the Former Adamsite
Storage Vault, and the Radioactive Material Disposal Facility, referred to as the "Rad Yard".
The selected remedy for the 22nd Street Landfill is Maintenance of Existing
Improvements with Land Use Controls (LUC) and Monitoring. The selected remedy for the
remaining OU3 Surface Units (Building E2364 (UST) Site, the Former Adamsite Storage Vault,
and the Rad Yard) is No Further Action (NFA) with Existing LUCs. These selected remedies
are based upon the human health and ecological risk assessments performed during the Remedial
Investigation and on the State of Maryland's landfill closure regulations. The remedy selected
by the Army is in compliance with the Comprehensive Environmental Response, Compensation
and Liability Act.
The selected remedy for the 22nd Street Landfill, Maintenance of Existing Improvements
with Land Use Controls (LUCs) and Monitoring, required a variance from the State's landfill
closure regulations as stated in Code of Maryland Regulations 26.04.07.10 and 26.04.07.21. A
copy of the letter approving this variance dated September 23, 2013 is enclosed as a reference.
Recycled Paper
www. mde.state.md.us
TTY Users 1-800-735-2258
Via Maryland Relay Service
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Mr. Rurik Loder
Page 2
A public meeting was held on July 25, 2013, and a fact sheet on the Proposed Plan was mailed to
approximately 1985 citizens and elected officials. The Army's responses to the written
comments received are viewed satisfactorily by the FFD. Based upon the acceptable level of
protection to human health and the environment provided by the remedy, the FFD concurs with
the selected remedy for OU3 Surface Units: for EABR11-C, the 22nd Street Landfill,
Maintenance of Existing Improvement with Land Use Controls (LUCs) and Monitoring; for the
remaining 3 OU3 Surface Units, NFA with Existing LUCs.
If you have any questions, please contact me at (410) 537-4238.
Sincerely,
Linda Gustafson /
Remedial Project Manager
Federal Facilities Division
LG:bm
cc: Ms. Yazmine Yap-Deffler
Mr. Horacio Tablada
Mr. James Carroll
Recycled Paper
www.mde.state.md.us
TTY Users 1-800-735-2258
Via Maryland Relay Service
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REPORT DOCUMENTATION PAGE
Form Approved
OMB No. 0704-0188
The public reporting burden for this collection of information is estimated to average 1 hour per response, including the time for reviewing instructions, searching existing data sources,
gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection
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PLEASE DO NOT RETURN YOUR FORM TO THE ABOVE ADDRESS.
1. REPORT DATE (DD-MM-YYYY) 2. REPORT TYPE
September 2013 Technical
3. DATES COVERED (From - To)
4. TITLE AND SUBTITLE
Record of Decision
Remedial Action at the Bush River Study Area, Operable Unit 3
Surface Units (EABR11-C, EABR11-G, EABR11-H, and EABR11-1)
Aberdeen Proving Ground, Maryland
5a. CONTRACT NUMBER
W91ZLK-04-D-0013
5b. GRANT NUMBER
5c. PROGRAM ELEMENT NUMBER
6. AUTHORfS)
U.S. Army
5d. PROJECT NUMBER
5e. TASK NUMBER
Delivery Order No. 0018
5f. WORK UNIT NUMBER
7. PERFORMING ORGANIZATION NAMEfS) AND ADDRESSfES)
GP Strategies Corporation
500 Edgewood Road, Suite 110
Edgewood, Maryland 21040
8. PERFORMING ORGANIZATION
REPORT NUMBER
GP-R-123E13005
9. SPONSORING/MONITORING AGENCY NAMEfS) AND ADDRESSfES)
Directorate of Public Works, Environmental Division
IMAP-PWE
Aberdeen Proving Ground, Maryland 21010
10. SPONSOR/MONITOR'S ACRONYMfS)
11. SPONSOR/MONITOR'S REPORT
NUMBERfS)
12. DISTRIBUTION/AVAILABILITY STATEMENT
Approved for Public Release: Distribution is Unlimited. #11521-A-l
13. SUPPLEMENTARY NOTES
14. ABSTRACT
This Record of Decision (ROD) presents the remedies selected by the U.S. Army and the U.S. Environmental Protection Agency
(USEPA) Region III to address the Bush River Study Area (BRSA) Operable Unit 3 (OU3) Surface Units within the Edgewood
Area of Aberdeen Proving Ground. The OU3 Surface Units are comprised of 22nd Street Landfill; Building E2364
Underground Storage Tank (UST) Site; Former Adamsite Storage Vault; and, Radioactive Material Disposal Facility (referred to as
the "Rad Yard"). The Selected Remedy for the 22nd Street Landfill is Maintenance of Existing Improvements with Land Use
Controls (LUCs) and Monitoring. The Selected Remedy for the Remaining OU3 Surface Units is No Further Action with Existing
LUCs. The Selected Remedies were chosen in accordance with the Comprehensive Environmental Response, Compensation and
Liability Act, as amended, and the National Oil and Hazardous Substances Pollution Contingency Plan. This decision is based on
the Administrative Record for these sites. The State of Maryland concurs with the selected remedies.
15. SUBJECT TERMS
Bush River Study Area, Operable Unit 3, 22nd Street Landfill, Rad Yard, Former Adamsite Storage Vault, Building E2364
Underground Storage Tank Site, Land Use Controls
16. SECURITY CLASSIFICATION OF:
17. LIMITATION OF
ABSTRACT
SAR
18. NUMBER
OF
PAGES
84
19a. NAME OF RESPONSIBLE PERSON
Mr. Rurik Loder (DPW-ED)
a. REPORT
Unclassified
b. ABSTRACT
Unclassified
c. THIS PAGE
Unclassified
19b. TELEPHONE NUMBER (Include area code1
410-436-7313
Standard Form 298 (Rev. 8/98)
Prescribed by ANSI Std. Z39.18
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FINAL
RECORD OF DECISION
REMEDIAL ACTION AT THE
BUSH RIVER STUDY AREA
OPERABLE UNIT 3 SURFACE UNITS
(EABR11-C, EABR11-G, EABR11-H, and EABR11-I)
ABERDEEN PROVING GROUND, MARYLAND
SUBMITTED BY:
ENVIRONMENTAL DIVISION
DIRECTORATE OF PUBLIC WORKS
U.S. ARMY GARRISON ABERDEEN PROVING GROUND
EDGEWOOD, MARYLAND 21010
SEPTEMBER 2013
DISTRIBUTION RESTRICTION STATEMENT
APPROVED FOR PUBLIC RELEASE:
DISTRIBTION IS UNLIMITED: #11521-A-1
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Record of Decision Final
Bush River Study Area Operable Unit 3 September 2013
Aberdeen Proving Ground, Maryland Page i
TABLE OF CONTENTS
PARTI: DECLARATION 1
1 SITE NAME AND LOCATION 1
2 STATEMENT OF BASIS AND PURPOSE 1
3 ASSESSMENT OF THE SITES 2
4 DESCRIPTION OF THE SELECTED REMEDY 3
5 STATUTORY DETERMINATIONS 5
6 DATA CERTIFICATION CHECKLIST 5
7 AUTHORIZING SIGNATURES 6
PART 2: DECISION SUMMARY 7
1 SITE NAME, LOCATION AND DESCRIPTION 7
2 SITE HISTORY AND ENFORCEMENT ACTIVITIES 10
3 PUBLIC/COMMUNITY INVOLVEMENT 14
4 SCOPE AND ROLE OF RESPONSE ACTION 15
5 SITE CHARACTERISTICS 16
5.1 Topography and Drainage 16
5.2 Geology and Hydrogeology 18
5.3 Habitat 19
5.4 Remedial Investigation Summary 20
5.5 Conceptual Site Model 23
6 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES ... 24
7 SUMMARY OF SITE RISKS 26
7.1 Human Health Risk Assessment 27
7.2 Ecological Risks 29
8 REMEDIAL ACTION OBJECTIVES 29
9 DESCRIPTION OF ALTERNATIVES 30
9.1 Alternative 1 - No Action 31
9.2 Alternative 2 - Maintenance of Existing Improvements with LUCs and
Monitoring 31
9.3 Alternative 3 - Low-Permeability Cap with Wetland Mitigation, LUCs,
Site Maintenance, and Monitoring 32
10 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 33
10.1 Overall Protection of Human Health and the Environment 33
10.2 Compliance with Applicable or Relevant and Appropriate
Requirements 33
10.3 Long-Term Effectiveness and Permanence 35
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Record of Decision Final
Bush River Study Area Operable Unit 3 September 2013
Aberdeen Proving Ground, Maryland Page ii
10.4 Reduction of Toxicity, Mobility, or Volume through Treatment 35
10.5 Short-Term Effectiveness 35
10.6 Implement ability 35
10.7 Cost 35
10.8 State Acceptance 35
10.9 Community Acceptance 36
10.10SUSTAINABILITY CRITERIA 36
10.11 Summary of Comparative Analysis of Alternatives 36
11 PRINCIPAL THREAT WASTES 36
12 SELECTED REMEDIES 37
12.1 Description of the Selected Remedies 37
12.2 Summary of the Rationale for the Selected Remedies 43
12.3 Summary of Estimated Remedy Costs 44
12.4 Expected Outcomes of Selected Remedies 44
12.5 Performance Standards for the Selected Remedies 47
13 STATUTORY DETERMINATIONS 47
13.1 Protection of Human Health and the Environment 47
13.2 Compliance with Applicable or Relevant and Appropriate
Requirements 47
13.3 Cost-Effectiveness 48
13.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable 48
13.5 Preference for Treatment as a Principal Element 48
13.6 CERCLA 121(c) Five-Year Review Requirement 48
14 DOCUMENTATION OF SIGNIFICANT CHANGES 48
PART 3: RESPONSIVENESS SUMMARY 49
1 OVERVIEW 49
2 BACKGROUND ON COMMUNITY INVOLVEMENT 49
3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES 51
PART 4: REFERENCES 53
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Record of Decision Final
Bush River Study Area Operable Unit 3 September 2013
Aberdeen Proving Ground, Maryland Page Hi
LIST OF FIGURES
Figure 1. Location of Bush River Study Area 8
Figure 2. Location of Operable Unit 3 Surface Units 9
Figure 3. Site Conditions Prior to Landfilling (Circa 1960) 12
Figure 4. Site Features and Topography Prior to TCRA 17
Figure 5. Soil Sampling Locations Outside of Rad Yard 21
Figure 6. Sediment and Surface Water Sampling Locations 22
Figure 7. Conceptual Site Model for Operable Unit 3 Surface Units 25
Figure 8. TCRA Site Improvements 39
Figure 9. Land Use Restrictions Relevant to the OU3 Surface Units 42
Figure 10. Sample Newspaper Advertisement 50
LIST OF TABLES
Table 1. Summary of Risks Associated with Exposures to Surface Soil 28
Table 2. Remedial Alternative Evaluation Criteria 34
Table 3. State of Maryland ARARs 45
Table 4. Detailed Costs for the Selected Remedy for 22nd Street Landfill 46
LIST OF ATTACHMENTS
Attachment A. Request For Variance from COMAR 26.04.07.21
Attachment B. Memorandum Implementing BRSA-Wide Land-Use Controls and
Environmental Overlay
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page iv
ACRONYMS AND ABBREVIATIONS
AEDB-R Army Environmental Database - Restoration
AOC Area of Concern
APG Aberdeen Proving Ground
ARAR Applicable or Relevant and Appropriate Requirement
BRAC Base Realignment and Closure
BRSA Bush River Study Area
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS Comprehensive Environmental Response, Compensation, and Liability
Information System
COC Chemical of Concern
COMAR Code of Maryland Regulations
CSM Conceptual Site Model
CWM Chemical Warfare Materiel
DDD 4,4'-dichlorodiphenyldichloroethane
DERP Defense Environmental Restoration Program
FFA Federal Facility Agreement
FS Feasibility Study
ft feet
GIS Geographic Information System
HI Hazard Index
HQ Hazard Quotient
IRP Installation Restoration Program
LTM Long-Term Management
LUC Land-Use Control
MEC Munitions and Explosives of Concern
MDE Maryland Department of the Environment
mg/kg milligrams per kilogram
MRICD Medical Research Institute of Chemical Defense
msl mean sea level
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NFA No Further Action
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Final
September 2013
Page v
ACRONYMS AND ABBREVIATIONS (CONTINUED)
NPL
National Priorities List
O&M
Operation and Maintenance
OSWER
Office of Solid Waste and Emergency Response
OU
Operable Unit
pCi/L
picoCuries per liter
RAB
Restoration Advisory Board
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act
RD
Remedial Design
RFA
RCRA Facility Assessment
RG
Remedial Goal
RI
Remedial Investigation
RI/FS
Remedial Investigation/Feasibility Study
RME
Reasonable Maximum Exposure
ROD
Record of Decision
SD
Sediment Sample
SRI
Supplemental Remedial Investigation
ss
Surface Soil Sample
SWMU
Solid Waste Management Unit
TCRA
Time Critical Removal Action
USAEC
U.S. Army Environmental Command
USAEHA
U.S. Army Environmental Hygiene Agency
USATHAMA U.S. Army Toxic and Hazardous Materials Agency
USEPA
U.S. Environmental Protection Agency
UU/UE
Unlimited Use and Unrestricted Exposure
UST
Underground Storage Tank
UXO
Unexploded Ordnance
VOC
Volatile Organic Compound
WP
White Phosphorus
Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
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Bush River Study Area Operable Unit 3 September 2013
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 1
RECORD OF DECISION
REMEDIAL ACTION AT THE BUSH RIVER STUDY AREA
OPERABLE UNIT 3 SURFACE UNITS
(EABR11-C, EABR11-G, EABR11-H, and EABR11-I))
ABERDEEN PROVING GROUND, MARYLAND
SEPTEMBER 2013
PARTI: DECLARATION
1 SITE NAME AND LOCATION
The Bush River Study Area (BRSA) Operable Unit 3 (OU3) Surface Units, located
within the Edgewood Area of Aberdeen Proving Ground (APG), Maryland have been
designated for Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA) response actions to address the impact of historical waste management
practices. The BRSA, located in the northeastern portion of the Edgewood Area,
occupies the peninsula between Lauderick Creek, the Bush River, and Kings Creek. U.S.
Army CERCLA response actions are tracked in the Army Environmental Database-
Restoration (AEDB-R) system.
The OU3 Surface Units are managed under four separate AEDB-R numbers:
• EABR11-C - 22nd Street Landfill;
• EABR11-G - Building E2364 Underground Storage Tank (UST) Site;
• EABR11-H - Former Adamsite Storage Vault; and,
• EABR11-I - Radioactive Material Disposal Facility, referred to as the "Rad
Yard".
OU3 also includes the underlying groundwater in the northern portion of the Southern
Bush River surficial aquifer; however, the OU3 groundwater is being addressed as a
separate CERCLA action.
CERCLA activities at APG are being conducted under a Federal Facility Agreement
(FFA) signed by the Army and U.S. Environmental Protection Agency (USEPA) on
March 27, 1990. The USEPA Superfund Site Identification Number is MD 2210020036.
This Record of Decision (ROD) is listed under OU-48 (Bush River Surface Units) in
USEPA's Comprehensive Environmental Response, Compensation, and Liability
Information System (CERCLIS) database.
2 STATEMENT OF BASIS AND PURPOSE
This ROD presents the remedies selected by the U.S. Army and the USEPA Region III to
address the BRSA OU3 Surface Units. The Selected Remedy for the 22nd Street Landfill
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 2
is Maintenance of Existing Improvements with Land Use Controls (LUCs) and
Monitoring. The Selected Remedy for the Remaining OU3 Surface Units (Rad Yard,
Building E2364 UST Site, and Former Adamsite Vault) is No Further Action (NFA) with
Existing LUCs. The Selected Remedies were chosen in accordance with CERCLA, as
amended, and the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision is based on the Administrative Record for these sites. The State of
Maryland concurs with the selected remedies.
3 ASSESSMENT OF THE SITES
As mentioned previously, the OU3 Surface Units are comprised of the 22nd Street
Landfill, Rad Yard, Building E2364 UST Site, and Former Adamsite Vault. The current
and planned future use of these sites is for military/industrial activities.
22nd Street Landfill
The 22nd Street Landfill was active from the mid- to late-1960s to circa 1970, and was
used primarily for the disposal of sanitary waste and demolition debris. During the
Remedial Investigation (RI), constituents in the cover soil and adjacent surface water and
sediment at the 22nd Street Landfill did not pose any unacceptable risk to industrial
workers or ecological receptors. In 2008, elevated metals were identified in one isolated
hot spot in a heavily vegetated drainage channel along the southwestern boundary of the
landfill (in the vicinity of sediment sample SD-64). However, the metals in sediment
samples collected upstream and downstream of location SD-64 were not contaminated.
The landfill has not been identified as a source of volatile organic compounds (VOCs) to
groundwater. However, there is concern that the landfilled waste has not been fully
characterized, and it is possible that hazardous materials, if present in the subsurface
waste, could pose risk if exposed by inadvertent excavation into the landfill or through
erosion. There are also safety concerns regarding the potential for encountering munitions
and explosives of concern (MEC) [i.e., unexploded ordnance (UXO)], especially in
wetland areas.
A Time Critical Removal Action (TCRA), completed at the 22nd Street Landfill in 2012,
mitigated most of the risk associated with potential exposure to subsurface waste through
the construction of shoreline stabilization measures and amendments to the existing
landfill cover.
Remaining OU3 Surface Units
Prior removal actions have reduced the risks to industrial workers and ecological
receptors to acceptable levels within the three remaining OU3 sites (Rad Yard, Building
E2364 UST Site, and Former Adamsite Vault). Therefore, no further action is required
for these sites under a military/industrial land use scenario.
It is assumed that, throughout the BRSA, unlimited use and unrestricted exposure
(UU/UE) would not be possible because: a) constituents remain in surface media at
concentrations that would pose unacceptable risk to hypothetical future residents; and/or,
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 3
b) the data, while sufficient to evaluate risk to military/industrial receptors and the
environment, are not sufficient to evaluate risk for residential land use. Therefore, the
ROD for nearby OU2B (signed in July 2010) included an LUC prohibiting the use of the
entire BRSA for residential use, including family housing, elementary and secondary
schools, child care facilities, playgrounds, and other residential land use. This residential
LUC serves as a critical component of the final response actions for the OU3 Surface
Units.
The response actions selected in this ROD are necessary to protect public health, welfare
and the environment from actual or threatened releases of pollutants or contaminants
from this site which may present an imminent and substantial endangerment.
4 DESCRIPTION OF I II I SELECTED REMEDY
The Selected Remedy for the 22nd Street Landfill is Maintenance of Existing
Improvements with LUCs and Monitoring. The components of the Selected Remedy are
summarized below.
• Maintenance of Existing Improvements: The soil cover constructed in the upland
areas and shoreline stabilization structures installed at the toe of the landfill
during the 2012 TCRA will be maintained to prevent direct contact with
subsurface waste. Periodic inspections will be conducted to verify that the site
improvements remain in place and protective of human health and the
environment.
• Long-Term Monitoring: Groundwater, surface water, and sediment sampling will
be conducted on a semi-annual basis for five years, with a potential to decrease
the frequency based on the results of the first five-year review. Details regarding
the sampling plan will be provided in the Remedial Design (RD).
• Land-Use Controls: The current and planned future use of the 22nd Street Landfill
is for military/industrial activities. The Army recently implemented a residential
LUC for the entire BRSA as part of the final remedy for OU2B.
The following quote is from Section 4 of the Declaration in the ROD for OU2B,
signed in July 2010: "LUCs will be implemented at BRSA to prevent site
activities that would result in unacceptable exposure. A BRSA-wide LUC will
prevent future family housing, elementary and secondary schools, child care
facilities, playgrounds, and other residential land use within OU2B and the
remainder of the BRSA."
Additional OU3-specific LUCs will be implemented to prohibit the use of
groundwater and to restrict excavation and other activities that could result in the
exposure of receptors to subsurface materials potentially containing hazardous
constituents. These LUCs will also prevent disturbance of the existing shoreline
stabilization structures and the existing vegetative cover, thereby maintaining
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 4
remedy effectiveness into the future. These restrictions will be maintained until
such time as contaminant levels in soil and groundwater are at levels that allow
for UU/UE.
Five-year remedy reviews will be conducted as required by Section 121(c) of CERCLA
and the NCP at 40 CFR 300.430(f)(4)(ii), since hazardous substances, pollutants, or
contaminants will remain at the site above levels that allow for UU/UE. The five-year
reviews for the 22nd Street Landfill and the Remaining OU3 Surface Units will be
conducted during the consolidated CERCLA review for the Edgewood Area of APG
(with the next review due in 2018).
The Selected Remedy for the Remaining OU3 Surface Units is NFA with Existing LUCs.
Residential LUCs were implemented for the entire BRSA under a previous ROD for
OU2B (U.S. Army, 2010). There are no additional site-specific LUCs required for the
Rad Yard, Building E2364 UST Site, or Former Adamsite Vault.
The U.S. Army will be responsible for implementing, maintaining and enforcing the site-
specific LUCs at the 22nd Street Landfill described in this ROD and the subsequent RD.
As part of the U.S. Army's inspection and reporting responsibilities, periodic reviews of
the restrictions and objectives outlined above will be undertaken and a review report will
be submitted to USEPA and Maryland Department of the Environment (MDE). The
LUCs will include implementation through the APG Master Planning System with
Geographic Information System (GIS) support. As set forth in this ROD, the U.S. Army
will not modify or terminate LUCs or implement actions without prior notification to
USEPA, after conferring with MDE. The U.S. Army will seek prior concurrence before
taking an action that would disrupt the effectiveness of the LUCs.
If the U.S. Army transfers property in the areas addressed by this ROD, the U.S. Army
will place a deed notification in the local property record that describes the restrictions on
site activities and states that this notification is filed with the appropriate agencies, so that
current and future property owners will be aware of these restrictions. Specific deed
notification language and the appropriate agencies will be identified in the transferring
documents. While the U.S. Army maintains ultimate responsibility for LUC enforcement,
the Army may require the transferee or lessee in cooperation with other stakeholders to
assume responsibility for LUC implementation actions. Third-party LUC responsibility
will be incorporated into pertinent contractual, property and remedial documentation,
such as a purchase agreement, deed, lease and RD addendum.
To the extent permitted by law, a transfer deed shall require the LUCs imposed as part of
a CERCLA remedy to run with the land and bind all property owners and users. If the
U.S. Army intends to transfer ownership of any site, the Army may, if Federal and/or
State law allows, upon transfer of fee title, grant the State an environmental covenant or
easement that would allow the State to enforce LUC terms and conditions against the
transferee(s), as well as subsequent property owner(s) or user(s) or their contractors,
tenants, lessees or other parties. This covenant will be incorporated by reference in the
transfer deed and will run with the land in accordance with State realty law. This State
enforcement right would supplement, not replace, the U.S. Army's right and
responsibility to enforce the LUCs.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 5
The Selected Remedies will achieve the Remedial Action Objectives (RAOs) for the 22nd
Street Landfill and Remaining OU3 Surface Units. Implementation of the remedy at the
22nd Street Landfill is anticipated within 12 months of ROD approval. The total capital
cost (including implementation of the site-specific LUCs) is estimated to be $58,400,
with $1,271,300 for long-term operation and maintenance. Since residential LUCs have
already been implemented for the entire BRSA, there is no additional cost for
implementation at the 22nd Street Landfill, Rad Yard, Building E2364, or Former
Adamsite Vault.
Cost Summary
Capital Cost
$58,400
Operation and Maintenance (O&M) /
Long-Term Management (LTM) Costs
$1,271,300
Total Present Worth Costs
$1,329,700
O&M Time Frame
30 Years
Time to Achieve RAOs
Less than 1 year
5 STATUTORY DETERMINATIONS
This remedial response meets the requirements of CERCLA Section 121 and, to the
extent practicable, the NCP. The Selected Remedies are protective of human health and
the environment; provide long- and short-term effectiveness; and, comply with
Applicable or Relevant and Appropriate Requirements (ARARs). Although the remedy
does not comply with the State of Maryland capping requirement for landfill closure, it
qualifies for a variance from that requirement as provided for by the regulations, since the
Selected Remedy for the 22nd Street Landfill is at least as effective in protecting human
health and the environment as a capping remedy would be, with less impact on the
surrounding wetlands and forested areas. A low permeability cap would not be an
effective technology for preventing leaching at the 22nd Street Landfill, because much of
the waste is present below the water table.
The Selected Remedies will result in hazardous substances, pollutants or contaminants
remaining on site at levels that do not allow for UU/UE. Therefore, LUCs will be
maintained to prevent site activities that would result in unacceptable exposure. The
OU3 Surface Units will be included in the consolidated five-year CERCLA remedy
reviews of the Edgewood Area's National Priorities List (NPL) sites, to ensure that the
remedies remain protective of human health and the environment.
6 DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary, Part 2 of this ROD.
Additional information can be found in the Administrative Record file.
• Chemicals of concern (COCs) and their respective concentrations (Decision
Summary, Section 5).
• Baseline risk represented by the COCs (Decision Summary, Section 7).
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Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 6
• RAOs established; since no COCs identified, no Remedial Goals (RGs)
established for the sites (Decision Summary, Section 8).
• The absence of source materials constituting principal threats (Decision
Summary, Section 11).
• Current and reasonably anticipated future land and groundwater use assumptions
(Decision Summary, Section 6)
• Potential land and groundwater uses that will be available as a result of the
Selected Response Actions (Decision Summary, Section 12,4).
• Estimated capital, O&M, and total present worth costs, and the number of years
over which the response cost estimates are projected (Decision Summary, Section
• Key factor(s) that led to selecting the remedial response (i.e., describes how the
Selected Response Actions provide the best balance of tradeoffs with respect to
the balancing and modifying criteria, highlighting criteria key to the decision)
(Decision Summary, Sections 10 and 12.2),
7 AUTHORIZING SIGNATURES
The appropriate approval authority for this action is the APG Garrison Commander.
9).
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Aberdeen Proving Ground, Maryland
Kathifyn A. llodgkiss
Acting Director
Hazardous Site Cleanup Division
U.S. Environmental Protection Agency, Region III
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 7
PART 2: DECISION SUMMARY
1 SITE NAME, LOCATION AND DESCRIPTION
APG is an approximately 72,500-acre Army installation located in southern Harford and
southeastern Baltimore counties, on the western shore of the upper Chesapeake Bay
(Figure 1). The installation is bordered to the east and south by the Chesapeake Bay; to
the west by Gunpowder Falls State Park, the Crane Power Plant, and residential areas;
and to the north by the City of Aberdeen and the towns of Edgewood, Joppatowne,
Magnolia, and Perryman. The Bush River divides APG into two areas: the Edgewood
Area to the west and the Aberdeen Area to the east. The BRSA is in the Edgewood Area
part of the APG NPL Site, USEPA Superfund Site Identification Number MD
2210020036. The site owner and lead agency is the U.S. Department of the Army
(Army), with USEPA as the lead regulatory agency and MDE as the supporting
regulatory agency.
Established as the Ordnance Proving Ground in 1917, the Aberdeen Area of the
installation became a formal military post, designated as APG, in 1919. Traditionally,
APG's primary mission involved the testing and development of weapon systems,
munitions, vehicles and a wide variety of military support materiel. The Edgewood Area
(formerly Edgewood Arsenal) was appropriated by presidential proclamation in 1917 and
has since been a site of laboratory research; field testing of chemical materiel and
munitions; pilot-scale manufacturing; production-scale chemical agent manufacturing
and related test, storage and disposal operations [U.S. Army Toxic and Hazardous
Materials Agency (USATHAMA), 1983],
The Bush River Study Area lies in the northeast portion of APG's Edgewood Area and
encompasses approximately 500 acres on a peninsula bounded to the north by Lauderick
Creek, to the east and south by Bush River, and to the southwest by Kings Creek
(Figure 1). As early as 1918, this area was used for training, test activities, waste disposal
and chemical storage.
The southern portion of the Bush River Study Area has been investigated as three
separate OUs:
OU1 - Surficial Aquifer Groundwater (Southern Plume);
OU2 - 26th Street Disposal Site (OU2A), and Kings Creek Chemical Disposal
Site and 30th Street Landfill (OU2B); and,
OU3 - Radioactive Material Disposal Facility (Rad Yard/Toxic Gas Yard),
Building E2364 UST Site, Former Adamsite Storage Vault, 22nd Street Landfill,
and Surficial Aquifer Groundwater (Northern Plume).
The OU3 Surface Units lie on the western shore of Bush River in the southern portion of
the Bush River Study Area (Figure 2).
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 10
2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
During 1984 and 1985, APG was evaluated as a potential NPL site. In 1985, the
Edgewood Area of APG was proposed for inclusion on the NPL. The final listing
occurred on February 21, 1990. In 1986, between the time of the proposed listing and the
final listing, a Resource Conservation and Recovery Act (RCRA) corrective action permit
(MD3-21-002-1355) was issued by the USEPA Region III to address solid waste
management units (SWMUs) in the Edgewood and Aberdeen areas of APG. As required
by the RCRA permit, the U.S. Army Environmental Hygiene Agency (USAEHA)
performed a RCRA Facility Assessment (RFA) for the Edgewood Area. The RFA
identified sites in the Edgewood Area that were either SWMUs or areas of concern
(AOCs) for potential contamination (USAEHA, 1989).
On March 27, 1990, the FFA was signed by the U.S. Army and USEPA Region III. The
FFA established schedules for commencing Remedial Investigation/Feasibility Study
(RI/FS) activities and required remedial actions be completed as expeditiously as
possible. The FFA identified specific Study Areas within the Edgewood Area, including:
Canal Creek, Old O-Field, J-Field, Carroll Island, Graces Quarters, Westwood, Nike Site,
Other Edgewood Areas, and the BRSA. New O-Field and Lauderick Creek were grouped
under Other Edgewood Areas, along with the Edgewood Area SWMUs and AOCs not
specifically listed above. In 1991, the Generic Work Plan for RI work at the Edgewood
Area was published and divided known potential source areas into "clusters" of sites by
geographic area. The BRSA contains seven clusters of sites numbered 3, 7, 11, 15, 18,
35, and 36.1 The OU 3 sites are part of Cluster 11, in the Southern Bush River Area.
RI/FS activities at APG are conducted under the Defense Environmental Restoration
Program (DERP), in accordance with CERCLA, as amended, and the NCP. BRSA RI
field investigations were conducted from 1994 to 1997. Activities included historical
document and aerial photograph reviews, geophysical surveys, installation of wells to
monitor the groundwater, and the sampling of groundwater, surface water, sediment and
soil. Feasibility Study (FS) field investigations were completed between 1998 and 2003,
and included geophysical surveys, test pit excavations, sampling and analysis of soil and
sediment, and toxicity testing of sediment. Additional sampling and analysis of surface
water and sediment was accomplished in 2008 to fill data gaps.
22nd Street Landfill
The 22nd Street Landfill is approximately 10.4 acres and was created by the disposal of
solid waste in the tidal wetland located north and west of the Rad Yard. The western
portion of the landfill was vegetated with grass, while the drainage channels and eastern
portion of the landfill were dominated by phragmites (common reed).
This landfill was active from the mid to late 1960s to circa 1970, and was operated using
the area-fill method. The waste disposed at the 22nd Street Landfill was primarily sanitary
waste and demolition debris. During this time period the designated disposal locations for
1 Former Cluster 55 has been incorporated into Cluster 36.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 11
ordnance and industrial waste generated by the Edgewood Area of APG were the O-Field
and J-Field disposal sites.
During the RI, constituents in the cover soil and adjacent surface water and sediment at
the 22nd Street Landfill did not pose any unacceptable risk to industrial workers or
ecological receptors. In 2008, elevated metals were identified in one isolated hot spot in
a heavily vegetated drainage channel along the southwestern boundary of the landfill (in
the vicinity of sediment location SD-64). However, the metals in sediment samples
collected upstream and downstream of location SD-64 were not contaminated.
The landfill was not identified as a source of VOCs to groundwater. However, there was
concern that the landfilled waste had not been fully characterized, and it was possible that
hazardous materials, if present in the subsurface waste, could pose risk if exposed by
inadvertent excavation into the landfill or through erosion. There were also safety
concerns regarding the potential for encountering MEC (i.e., UXO), especially in wetland
areas.
During 2001, field workers in the area adjacent to the Chemical Agent Storage Yard
noted two fallen trees along the southern drainage ditch through the 22nd Street Landfill.
The root mass for both trees had been lifted, exposing debris and waste associated with
the landfill. A removal action was accomplished to remove the trees and replace cover
material where waste had been exposed (Weston, 2002).
A TCRA was performed at the 22nd Street Landfill from April through August 2012. The
shoreline along the 22nd Street Landfill was stabilized to prevent erosion and potential
migration of waste into the Bush River. Improvements to the existing soil cover were
made in the western portions of the 22nd Street Landfill (i.e., western and southern
portions of the site). To the extent practicable, the existing soil cover was amended to
increase cover thickness in areas where it was thin (i.e., areas with less than 24 inches of
cover), thereby enhancing effectiveness of the containment. The existing vegetative cover
in the large tidal wetland adjacent to Bush River (i.e., northeastern portion of the site)
was left undisturbed. Additional details are provided in the Completion Report for the
TCRA at 22nd Street Landfill (GP, 2013a).
Rad Yard, Adamsite Storage Vault, and Building E2364 UST Site
The Rad Yard is a 3.1-acre area adjacent to the Bush River. Constructed in 1931, the
facility was first used by the U.S. Army for chemical agent storage and identified as the
Toxic Gas Yard. The original Toxic Gas Yard was the fenced area enclosing the storage
yard, a building providing sheltered workspace and equipment storage (E2360), and
another building (E2370) containing pits for underwater storage of white phosphorus
(WP). Circa World War II, additional buildings were constructed to provide workspace
(E2362) and WP storage (E2364).
The Ton-Container Steam out Facility was constructed in 1938 in the easternmost portion
of the Toxic Gas Yard (Figure 3), and was operated intermittently until the late 1950s or
early 1960s. The facility consisted of a steam boiler (in Building E2368), a steel frame
structure and chain trolley hoist (E2366), a platform with rails, and an insulated exhaust
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 13
line for wastes. The function of the facility was to clean and decontaminate ton-
containers for re-use in the storage of chemical warfare agents. The ton-containers
cleaned had been previously filled with mustard, chloropicrin, Lewisite and other
chemical agents that were liquid at normal temperature and pressure.
The Steamout Facility was operated by introducing high pressure steam into the ton-
container and through the exhaust line to first heat the container, the line, and sludge in
the container, and to then force the sludge from the container out through the exhaust
line. The exhaust line initially went to an earthen pit about 8 feet (ft) square and 5 ft deep
that was located at the edge of the marsh approximately 100 to 150 ft north of Building
E2366. The sludge later went into a wooden box (4 ft by 8 ft by 4 ft) set into a pit at the
edge of the marsh. Sludge from the wooden box was periodically removed and disposed
in either J-Field or O-Field. The total amount of sludge waste generated and how much of
the sludge remained in the marsh is uncertain.
Ton-containers that had held undistilled mustard contained up to 600 pounds of sludge.
The amount of sludge in ton-containers that had been used for storage of distilled mustard
was much less, and there would have been very little sludge in containers for
chloropicrin, Lewisite, and other chemical agents. The mustard sludge would have
contained a substantial percentage of mustard. There is no current day evidence of the
sludge pit or box at the ground surface. The concrete floor slabs are all that remain of the
Ton-Container Steamout Facility structures. The structures were demolished as part of
the removal action addressing radionuclide contamination in the Rad Yard (2004 - 2007).
During 1960, waste Adamsite was stored in drums in the Building E2370 pits originally
constructed for underwater storage of WP. The drums containing the waste Adamsite
were stacked vertically in two layers in the southwest pit within E2370, with sand placed
around and in a layer over the drums, and the storage vault was then sealed with a 1-ft
thick layer of concrete. The drums of waste Adamsite were recovered from the storage
vault by the U.S. Army in 1983, with the waste shipped from APG for proper disposal. A
removal action in 1996 closed the vault. The closure consisted of the removal and
disposal of waste from within the vault, demolition of the above ground portion of the
vault, and filling of the vault with flowable fill to within 1 ft of grade (Foster Wheeler,
1997).
In the late 1950s or early 1960s the Toxic Gas Yard facilities were modified to support
radioactive waste management operations. The Rad Yard was in service from then until
October 2002, with the largest waste volumes being handled during the 1960s. No actual
disposal of radioactive waste occurred at the site. The radioactive waste management
activities were primarily receiving, storage, repackaging and shipment, with some
treatment of contaminated water to reduce volume. Prior to 1985, wastes were received
from a large portion of the eastern United States for processing, and at one point in time
the Rad Yard received all Army radioactive wastes generated within the continental
United States. After 1985, only small quantities of waste generated on APG were stored
at the site.
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Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 14
A removal action was performed at the Rad Yard from 2004-2007, with activities
including:
> Excavation of contaminated soil;
> Demolition of seven buildings and structures;
> Excavation and demolition of the radioactive wastewater system;
> Packaging, transportation, and disposal of waste soil and debris; and,
> Performing a final status survey to support approval of the Rad Yard
decommissioning by the U.S. Nuclear Regulatory Commission.
The Rad Yard removal action, while focused on radionuclides, also removed most of the
arsenic-contaminated soil. However, three arsenic hot spot areas remained. These hot
spot areas were later addressed in March 2012. The arsenic-contaminated soil was
shipped off-site for proper disposal and the excavations were backfilled with soil from an
approved source.
A 5,000-gallon UST, associated with Building E2364, was encountered northeast of the
valve pit during removal of the wastewater line headed toward Bush River. The UST
(approximately 8 ft by 12 ft by 8 ft) was constructed of concrete and filled with
wastewater. Approximately 5,000 gallons of wastewater were removed from the UST,
filtered and transferred to a tanker truck. A composite sample of the wastewater
contained no radionuclides above the method detection limit of 4 picoCuries per liter
(pCi/L). As a result, the wastewater was transported to the APG Sewage Treatment Plant
(Weston, 2007).
Sediment in the base of the UST was solidified with concrete, removed, and disposed of
as radioactive-contaminated material. The walls and floor of the tank were surveyed for
radioactive contamination, along with soil samples from test trenches at the inlet and
outlet sides of the tank. Sample results were below release criteria, so the UST was filled
with approximately 22 cubic yards of flowable concrete and abandoned in place (Weston,
2007). The remainder of the line from the Rad Yard property boundary to the 22nd Street
Landfill was abandoned in-place.
3 PUBLIC/COMMUNITY INVOLVEMENT
CERCLA Sections 113 (k) (2) (B) and 117, the NCP, Department of Defense and Army
policy require the involvement of the local community as early as possible and
throughout the Installation Restoration Program (IRP) process. To accomplish this, APG
conducts routine public meetings with the APG Restoration Advisory Board (RAB) to
exchange information and review progress regarding the IRP. The RAB is made up of
community, regulatory and governmental members, and is co-chaired by representatives
from the Army and the community. Over the past few years, the RAB has been briefed on
the status of the BRSA sites in July 2005, June 2006, July 2007, May 2008, August 2009,
September 2010, January 2012, and January 2013.
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Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 15
On July 17, 2013, APG mailed fact sheets on the OU3 Proposed Plan to 1,985 citizens
and elected officials on its IRP mailing list. The Proposed Plan for the OU3 Surface
Units was officially made available to the public on July 17, 2013. The Administrative
Record, which contains the information used to select the remedial response, may be
found at the Aberdeen and Edgewood branches of the Harford County Public Library and
at the Miller Library at Washington College. The notice of the availability of these
documents was published in The Aegis and The Cecil Whig on July 17, 2013, and Kent
County News, The Avenue News, and East County Times on July 18, 2013. A public
meeting was held on July 25, 2013. The public comment period was held from July 17 -
August 16, 2013. Responses to the public comments received during this period are
included in the Responsiveness Summary, Part 3 of this ROD.
4 SCOPE AND ROLE OF RESPONSE ACTION
This ROD presents the final response actions for the OU3 Surface Units. The Selected
Remedy for the 22nd Street Landfill is Alternative 2 (Maintenance of Existing
Improvements with LUCs and Monitoring). The Selected Remedy for the Rad Yard,
Building E2364 UST Site, and Adamsite Storage Vault is NFA with Existing LUCs,
since these sites have been adequately addressed by previous response actions.
The Selected Remedies are protective of human health and the environment; provide
long- and short-term effectiveness; and, comply with all ARARs. Although the remedy
does not comply with the State of Maryland capping requirement for landfill closure, it
qualifies for a variance from that requirement as provided for by the regulations, since the
Selected Remedy for the 22nd Street Landfill is at least as effective in protecting human
health and the environment as a capping remedy would be, with less impact on the
surrounding wetlands and forested areas. A low permeability cap would not be an
effective technology for preventing leaching at the 22nd Street Landfill, because much of
the waste is present below the water table.
Response actions have been selected and documented in RODs for the following BRSA
sites:
• Cluster 3 - Old Bush River Road Dump (1999);
• Cluster 3 - Lead Contaminated Soil Area and Transformer Storage Area (2005);
• OU2B - Kings Creek Chemical Disposal Site and 30th Street Landfill (2010);
and,
• OU2A - 26th Street Disposal Area (2011).
The remedy implemented for the Old Bush River Road Dump involved construction of a
permeable soil cover. This remedy was designed to reduce the migration of contaminants
by reducing infiltration, stabilizing the soil to prevent erosion, and containing the possible
explosion of 4.2-inch mortar shells that may have been buried in the dump. The second
ROD for the Lead Contaminated Soil Area at Cluster 3 specified excavation and on-site
reuse, with ex-situ treatment as necessary, and accepted the removal action as the final
action for the Transformer Storage Area. The OU2B ROD addressed the final response
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Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 16
actions for landfilled waste, surface and subsurface soil, sediment and surface water
within the Kings Creek Chemical Disposal Site and the 30th Street Landfill. The selected
alternative was Existing Cover with LUCs, Site Maintenance, and Monitoring. The
selected remedy for the 26th Street Disposal Area was Excavation and Off-Site Disposal.
The current and planned future use of the BRSA is for military/industrial activities.
Therefore, it is anticipated that for all of the BRSA any active remediation of surface
media as part of response actions will focus on protecting military/industrial workers and
the environment. It is also anticipated that UU/UE will not be possible because: a)
constituents will remain in surface media at concentrations that would pose unacceptable
risk to hypothetical future residents; and/or, b) the data, while sufficient to evaluate risk
to military/industrial receptors and the environment, are not sufficient to evaluate risk for
residential land use. As a result, an LUC prohibiting the use of the entire BRSA for
family housing, elementary and secondary schools, child care facilities, playgrounds, and
other residential land use was implemented under the ROD for OU2B (U.S. Army, 2010).
The BRSA-wide LUC prohibiting these residential-type uses is an integral part of the
final remedies for the OU3 Surface Units.
Groundwater in the surficial aquifer in the Southern Bush River Area of the BRSA is
impacted with chlorinated VOCs. The eastern and southern plumes of that impacted
aquifer are being managed as OU1. The northern plume is included in OU3. Remedial
responses for the groundwater associated with OU1 and OU3 will be addressed as
separate OUs, and will be evaluated, proposed and implemented under separate FS,
Proposed Plan, and ROD documents.
5 SITE CHARACTERISTICS
The characteristics of the OU3 Surface Units are briefly discussed below.
5.1 Topography and Drainage
The OU3 Surface Units occupy an area of roughly 16 acres that is approximately 800 ft
north to south and 900 ft east to west. The only remaining building within the area is
E2354, formerly used as a change house by Rad Yard workers. Topography is shown on
Figure 4.
The Rad Yard and the adjacent area along the Bush River shoreline are approximately 6
acres in size. The Rad Yard area is largely open space. The surface in the open storage
yard is largely crushed stone or backfill material high in sand and gravel. The area is
sparsely vegetated. The ground surface elevation in this area ranges from about 2.5 ft
above mean sea level (msl) along the shoreline to more than 12 ft above msl at the
topographic high in the center of the Rad Yard open storage area. Runoff from the Rad
Yard area southwest of the topographic high is southwest to where it is intercepted by a
drainage swale that carries the runoff south and then southeast to the Bush River. Runoff
from the eastern portion of the Rad Yard is east and northeast to the Bush River, except
from the northern corner where drainage is north to the marsh associated with the eastern
end of the 22nd Street Landfill.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 18
The 22nd Street Landfill was constructed entirely within a wetland. Based on an
interpretation of an aerial photograph circa 1960 (Figure 3), the original stream
meandered through the northern portion of what became the 22nd Street Landfill. The
landfilling operations in the tidal wetland re-routed drainage at the site into two channels:
• Northern Drainage - along the northern edge of the Landfill, at the edge of the
former wetland
• Southern Drainage - running through the center of the Landfill, dividing the
northern and southern lobes (at the edge of the former wetland in that area)
The drainage basin from which runoff flows through the 22nd Street Landfill is relatively
large (68 acres)2, but observation indicates that the amount of runoff through the drainage
channels is small. Much of the drainage basin is vegetated or wooded area from which
there is little runoff, and stormwater drainage from the area of the former chemical
demilitarization facility is to stormwater retention basins.
Prior to the TCRA in 2012, this portion of the site had changed little since the landfill
was closed in 1970. The western, more upland, portion of the landfill was vegetated with
grass, while the drainage channels and eastern portion of the landfill were dominated by
phragmites. The topographic high was approximately 11 ft above msl in the southern
portion of the landfill, which sloped down to less than 2 ft above msl near the shoreline of
Bush River (Figure 4).
Circa 1970, a crushed-stone trail was created that extended from the end of 22nd Street to
the Rad Yard. In the late 1970s or early 1980s, this trail was extended northward to
provide for north-south traffic across the landfill. While the north-south trail still
remains, the stone trail running east-west was eliminated during the 2012 TCRA soil
cover construction activities.
5.2 Geology and Hydrogeology
The OU3 Surface Units are located within the Atlantic Coastal Plain Physiographic
Province. Underlying the area of investigation are predominately fine-grained
unconsolidated sediments, comprised primarily of clay with a lesser fraction of sand and
gravel.
Three aquifers have been identified at the BRSA: the Surficial Aquifer, the Canal Creek
Aquifer, and the Lower Confined Aquifer. The uppermost water-bearing unit is the
surficial (water table) aquifer, which thins to the north and thickens to the south-
southeast. The surficial aquifer is mostly unconfined or semi-confined, with some
instances of confined conditions. Pleistocene streams created by past drainage patterns of
the Bush River have eroded sections of clay layers in the surficial aquifer and the clay
confining unit below the surficial aquifer. This erosion followed by subsequent
deposition of permeable sediments created paleochannels, locally increasing the depth
and dimensions of the surficial aquifer. The surficial aquifer in the Southern Bush River
2 Approximately one third of the drainage area is within the area where the chemical stockpile
demilitarization plant was constructed. That construction may have modified the drainage pattern that
existed since the 1940s, and which was not substantially different from natural drainage.
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Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 19
Peninsula is a complex sequence of interfingered sands, clays and silts. Fluctuating
periods of erosion and deposition have produced a complex layering of sediments with
variable hydraulic properties. Throughout the middle and eastern portions of the
peninsula, the surficial aquifer is unconfined or semi-confined. The surficial aquifer has
a thickness of approximately 15 ft in the north and 25 to 30 ft in the south. The thinnest
part of the surficial aquifer occurs in the area of the 26th Street Disposal Site where the
surficial aquifer is thin to absent above an east-west oriented clay ridge in the underlying
confining layer (GP, 2002).
The surficial aquifer can be divided into a discontinuous upper section (averaging 7 ft
thick) and a lateral continuous lower section (averaging 16 ft thick). The northern
portion of OU3 consists of an upper and lower section of the surficial aquifer separated
by laterally, discontinuous silt/clay layers, approximately 3 to 14 ft thick. The specific
sediments that comprise the aquifer consist of silty-sand to fine-grained well-sorted sand
in the upper section, and fine to medium grained well-sorted to poorly-sorted sand in the
lower section. The upper section of the surficial aquifer is absent offshore of the 22nd
Street Landfill and other OU3 sites from river erosion. The lower section of the aquifer
grades into offshore water-bearing units under the Bush River, which consist of sand
layers ranging from 3 to 13 ft thick that are often overlain by an average of 12 ft of fine
grained, organic silt and clay. Sandy-gravel to gravelly-sand lenses are present in the
offshore water-bearing units. Further to the south, the discontinuous silt/clay layers are
less dominant; therefore, the upper and lower sections are represented as one sandy
surficial aquifer.
A massive clay confining unit averaging 40 ft in thickness defines the base of the
surficial aquifer. This upper confining unit separates the surficial aquifer from the deeper
underlying Canal Creek aquifer. The Canal Creek aquifer strata follow a southeastern
dip, causing this aquifer to be shallow in the northern portion of the Bush River Study
Area at 30 ft below msl and deeper in the southern part of the study area at 80 ft below
msl. A second confining unit separates the Canal Creek aquifer from a third aquifer.
This lower confined aquifer is at an average depth of 140 ft below msl (GP, 2002).
5.3 Habitat
The forest, field, and wetland habitats within the BRSA support a wide variety of wildlife
and vegetation. Although there are no endangered flora or fauna species known to exist
within the southern portion of the BRSA, the bald eagle (which is a protected species) is
known to forage in and around BRSA. The closest known active bald eagle nest is
located on the north shoreline of Lauderick Creek, approximately 3,000 ft north of the
Southern Bush River Area.
Secondary forest within this area is dominated by tulip poplar, various species of oak,
maple, and pine, and sweet gum. Fauna within this area includes: red fox, gray squirrel,
white-tailed deer, American crow, and a variety of songbirds. Herbaceous plants
including various shrubs and native grasses dominate ground cover across major portions
of the Southern Bush River Area. Typical open area faunal species include field mice,
voles, cottontail rabbits, bobwhite quail, mourning dove, killdeer, and various species of
hawks and songbirds.
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Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 20
The wetland habitat within the Southern Bush River Area includes pockets of palustrine
(freshwater) forested and emergent marsh environments. The majority of the wetlands in
the area are estuarine (brackish water) emergent marsh environments. Wetland plants
common to the palustrine emergent areas include: common reed (phragmites), cattails,
and various species of rush. Palustrine forested areas contain red maple and sweet gum
trees; while estuarine emergent species include phragmites, cordgrass, three squares, and
rushes. Wetland species include muskrats, turtles, snakes, great blue heron, puddle and
diving ducks, and a variety of shorebirds, including spotted sandpiper and rails. Estuarine
fish expected within nearby Kings Creek and Bush River include striped and largemouth
bass, carp, white and yellow perch, bluefish, catfish, sunfish, Atlantic silverside, and eels.
5.4 Remedial Investigation Summary
BRSA RI field investigations were conducted from 1994 to 1997. Activities included
historical document and aerial photograph reviews, geophysical surveys, installation of
wells to monitor the groundwater, and the sampling of groundwater, surface water,
sediment and soil. FS field investigations were completed between 1998 and 2003, and
included geophysical surveys, test pit excavations, sampling and analysis of soil and
sediment, and toxicity testing of sediment. Additional sampling and analysis of surface
water and sediment was accomplished in 2008 to fill data gaps.
22nd Street Landfill
Although the RI and FS investigations confirmed the presence of waste within the 22nd
Street Landfill, contaminants were not identified at levels that constitute a principal
threat.
Surface and Hydric Soil - Based on extensive soil sampling and test pits, the existing
cover soil on the 22nd Street Landfill is uncontaminated, with no constituents posing
unacceptable risk to either human health or ecological communities. The only detections
of metals at concentrations higher than background were lead at a concentration of 136
milligrams per kilogram (mg/kg) at surface soil sample (SS) location SS-151 and copper
at 350 mg/kg at location SS-143 (Figure 5).
Sediment Surface Water, and Pore Water - Elevated metals were detected in sediment
sample (SD) location SD-64 (Figure 6), which lies in a heavily vegetated drainage
channel along the west and south edges of the original marsh. This southern drainage
channel bisects the 22nd Street Landfill and drains toward the Bush River into the current
phragmites-covered marsh. Sediment in the drainage channel is uncontaminated at
location C36-SD-06 (100 ft upstream) and downstream locations (the closest of which is
SD-62 located 200 ft downstream).
Metals were detected in surface water samples collected from the drainages, but most
were within the range of reference background. The metals found at elevated
concentrations in sediment at location SD-64 were not in surface water samples at this
point or downstream points in the southern drainage channel.
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APPROVED BY:
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 23
The characterization of pore water also indicates that the 22nd Street Landfill is not
impacting water quality.
The removal action for the Rad Yard, conducted from 2004 through 2007, was effective
in remediating radionuclides, eliminating contaminated structures, and reducing
radionuclide activity levels in soil to background levels. The removal action, which
focused on radionuclides, was also effective in substantially reducing the amount of
arsenic in Rad Yard Soil. The mean arsenic concentration was reduced by roughly 50%
in both the 0- to 1-ft and 1- to 2-ft depth intervals, while the median concentrations were
reduced by approximately two-thirds. The post-removal action mean arsenic
concentration in the 0- to l-ft depth interval of 24.2 mg/kg was only slightly higher than
the removal action goal of 20 mg/kg, and the mean arsenic concentration in deeper soil
was less than the removal action goal.
Much of the residual arsenic in Rad Yard soil remained in two hot spots in the
southwestern portion of the yard, and to a lesser extent, in a small hot spot just within the
former entry gate into the yard. These three hot spots, representing approximately 9.4%
of the Rad Yard area, contained approximately 35% of the arsenic within surface soil
(total arsenic in top foot of soil). The three hot spot areas were removed in March 2012,
resulting in a mean arsenic concentration below the removal action goal, at
approximately 15.5 mg/kg in the 0- to 1-ft depth interval.
Groundwater
The surficial aquifer in a large portion of the Bush River Study Area south of the 22nd
Street Landfill is contaminated with chlorinated VOCs. Groundwater in this area is being
addressed under a separate CERCLA action for OU3 Groundwater (Northern Plume).
The surficial aquifer in this area is divided into a discontinuous upper section (averaging
7 ft thick) and a lateral continuous lower section (averaging 16 ft thick). The
groundwater is contaminated with chlorinated VOCs. The northern plume, with
concentrations largely less than 1 mg/L total VOCs, extends northeast toward the Bush
River. The 22nd Street Landfill is not releasing constituents to groundwater or surface
water at levels that pose risk to the environment.
5.5 Conceptual Site Model
A Conceptual Site Model (CSM) is an integrated representation of the physical and
environmental characteristics of a site, as well as the complete, potentially complete, and
incomplete exposure pathways between sources of contaminants at a site and potential
human and environmental receptors. For a potential risk to be associated with a
contaminant release, a complete pathway from the source to a receptor must exist, and the
receptor must be present when the contamination arrives or still exists. In addition, the
CSM documents when an uncertainty is or is not significant (i.e., illustrates why data
collection activities are or are not needed to support the decision-making process).
Rad Yard
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 24
The following current or possible future exposure pathways are identified for
industrial/military workers:
• Exposure to landfilled waste subsequent to shoreline erosion or inadvertent
excavation into the landfill.
• Exposure to VOCs through vapor inhalation from groundwater during
construction or excavations, or as a result of vapor intrusion into future structures.
The pathways of potential concern are those related to landfilled waste (Figure 7).
Currently, human contact with waste materials from inadvertent excavation into
subsurface waste is possible at the 22nd Street Landfill. Ecological exposures to soil,
sediment, and surface water are also pathways of potential concern that were evaluated
during the risk assessment.
Potential vapor intrusion risks are not addressed in this ROD, but will be addressed by the
response action for groundwater. The possible vapor sources are the VOCs in
groundwater and the VOC sources that are releasing to groundwater. Risk assessment
did not identify unacceptable risk to workers from VOCs via exposure pathways other
than inhalation. Therefore, it is most appropriate that the groundwater FS address the
VOC sources, considering potential risks associated with both vapor inhalation and
groundwater ingestion.
Overall, the data quality objectives for OU3 were developed based on future
military/industrial land use. The number, depth, and spatial distribution of samples,
while appropriate for that land use, are not sufficient to fully assess risk to hypothetical
future residents. Therefore, controls restricting residential land use are required to
prevent exposure to potentially-contaminated material.
6 CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES
The U.S. Army currently uses the Edgewood Area for military/industrial land use
activities. According to the APG Real Property Master Plan, current and planned future
use of BRSA is for supply and storage areas.
APG lies adjacent to the Chesapeake Bay, approximately 20 miles northeast of Baltimore,
Maryland, with most of the installation lying within Harford County. Major rail and road
corridors run through southern Harford County. Major road corridors include U.S.
Interstate 95, U.S. Route 40, Maryland Route 7, and Maryland Route 24. Extensive
passenger and cargo rail traffic travels on the Amtrak and Conrail lines that run northeast to
southwest along the APG installation boundary.
Land use surrounding APG is a mix of commercial and residential use, but also includes
some agricultural use. Industry is most concentrated along Route 40. Primary population
centers within eight miles of the Edgewood Area include the communities of
Joppatowne/Magnolia (population 12,616); Edgewood (population 25,562); and Bel Air
(population 88,397). Smaller communities surrounding the Edgewood Area include
Abingdon, Belcamp, Chase, and Van Bibber. The population of Harford County was
estimated at 248,622 in 2012 (www.census.gov).
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Figure 7. Conceptual Site Model for Operable Unit 3 Surface Units - Bush River Study Area, APG
POTENTIAL
RECEPTORS
PRIMARY
SECONDARY
KNOWN
HYPOTHETICAL
ECOLOGICAL
PRIMARY
RELEASE
SECONDARY
RELEASE
EXPOSURE
On-Unit
Trespasser/
Industrial
On-Unit
Terrestrial
Aquatic/
SOURCE
MECHANISM
SOURCE
MECHANISM
PATHWAY
ROUTE
Worker
Recreational
Worker
Resident
Semi-aquatic
Ingestion
O
o
o
—
o
—
Dermal Contact
O
o
o
—
o
—
Historic
Waste Handling
and Disposal
Activities
Biotic Uptake
Biota
Surface Water
Stormwater Runoff
& Erosion
Ingestion
O
—
Ingestion
O
o
Dermal Contact
o
o
Soil/Sediment
Ingestion
O
o
o
—
o
o
Dermal Contact
O
o
o
—
o
o
Infiltration/
Percolation
Subsurface
Leaching
Groundwater
Ingestion
Soil
Showering9
LEGEND
= Pathways - current and future
•
= Complete or potentially complete pathway posing unacceptable risk
o
= Insignificant pathway
—
= Incomplete pathway
©
= Potentially complete pathway requiring further evaluation
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 26
The APG workforce is comprised of more than 21,000 civilian, military and contractor
employees (http://www.apg.army.mil/facts.cfim). Approximately 2,000 military
dependents reside at APG. In the Edgewood Area, the workforce and residential areas are
concentrated in the northern portion of the facility. As part of the "APG 2012
Transformation" Program, improvements have been made to infrastructure, facilities, and
services at APG. Several facilities, including the new U.S. Army Medical Research
Institute of Chemical Defense (MRICD) Campus, are being constructed within the
Edgewood Area as part of this program and in response to Base Realignment and Closure
(BRAC) activities. Enhanced use leasing options are also being considered for parcels
adjacent to the northern boundary of the Edgewood Area, by the Maryland Department of
Transportation and Northeast Maryland Waste Disposal Authority. Currently, there are no
plans for BRAC development within the BRSA.
By 1918, the BRSA was being used for training and test activities as well as for chemical
warfare materiel (CWM) storage and waste disposal. During World War I and World War
II, the area served as a storage and transshipment depot for chemical-filled munitions and
included a large dock for off- and on-loading of CWM. Historically, the southern portion
of the peninsula, designated as A-Field, was the location of activities such as artillery
firing, training, and testing. It also housed smoke and incendiary munitions testing
facilities. The lower two-thirds of the peninsula have been used in the past for the storage
of chemical agents and materials needed for various operations in Edgewood Area. It is
currently used to store hazardous wastes and materials in preparation for off-site disposal.
Mustard agent was stored in bulk and later demilitarized at the former secured area. The
OU3 Surface Units are currently not in use.
Groundwater within the deeper confined aquifer and surficial aquifer in the surrounding
areas of BRSA is not currently utilized as a drinking water source. Any remedial action to
address groundwater in these areas will be selected in the RODs for BRSA OU 1 and OU 3
(separate from this action for the OU3 Surface Units).
The waters surrounding APG support both commercial and recreational fishing. Boat
traffic within the installation boundaries is restricted by range control during firing
exercises and enforced by APG patrol boats. There are no designated recreational areas
within the BRSA. The Army has posted no trespassing signs on shorelines informing
potential trespassers of hazards associated with UXO. Access to the area is limited to
properly cleared personnel or individuals in an escorted capacity. A wide variety of
physical security countermeasures, including barrier systems, sensors and random patrols
by law enforcement personnel, are in place to prevent unauthorized access.
7 SUMMARY OF SITE RISKS
Risk assessments are usually performed on sites that contain measurable levels of COCs
in environmental media such as soil or groundwater. Using concentrations of COCs, risks
to human health and the environment can be estimated.
Surface soil, sediment, and surface water data were evaluated during the human health
and ecological risk assessments for OU3. The groundwater associated with OU3 will be
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 27
addressed as a separate OU; therefore, risks associated with the ingestion of groundwater
are not discussed in this ROD.
7.1 Human Health Risk Assessment
The human health risk assessment is required by the NCP, 40 CFR 300.430(d)(4), and
provides a quantitative evaluation of whether carcinogenic risk or non-carcinogenic
hazards are associated with the compounds and analytes detected in samples of
environmental media at the site. The upper-bound excess lifetime carcinogenic risk
estimates (expressed as a statistical probability) were compared to the USEPA's
acceptable risk range of 1.0 x 10"6 to 1.0 x 10"4 for remediation at CERCLA sites. An
excess lifetime cancer risk of 1.0 x 10"6 means the statistical probability of an incidence
of cancer resulting from site conditions is one in one million, i.e., if one million people
were exposed, one incidence is predicted, or one individual's risk is estimated as one
chance in one million. A risk of 1.0 x 10"4 indicates a probability of one in ten thousand.
The non-carcinogenic risk estimates [expressed as a Hazard Index (HI)] were compared
to unity. When an HI is less than one, it can be concluded with a high level of confidence
that the level of risk is acceptable. While an HI greater than one indicates the potential for
unacceptable risk, the actual presence of unacceptable risk is not at all certain. However,
as the magnitude of the HI increases the potential for risk increases.
The total upper-bound excess lifetime cancer risk for a receptor is the sum of the risk
probabilities calculated for each individual COC for which a complete or potentially
complete exposure pathway(s) to that receptor exists. For non-carcinogenic risk, a
Hazard Quotient (HQ) is calculated for each COC and each pathway of concern by taking
the ratio of the anticipated exposure to the reference dose, the exposure at which no
adverse health effects are anticipated to occur. The HI is the sum of all the HQs for the
receptor.
USEPA Office of Solid Waste and Emergency Response (OSWER) Directive 9355.0-30
states that, where cumulative carcinogenic site risk to an individual based on reasonable
maximum exposure (RME) for both current and future land use is less than 1.0 x 10"4,
and the non-carcinogenic HI is less than one, action is generally not warranted unless the
potential exists for adverse environmental effects to occur (USEPA, 1991).
The human health risks associated with possible exposure pathways were quantitatively
assessed for Rad Yard soil, 22nd Street Landfill cover soil, and soil within the 24th Street
drainage ditch adjacent to the 22nd Street Landfill3 (Table 1). The potential risks
associated with VOC inhalation and subsurface wastes were evaluated qualitatively.
Risks to hypothetical future residents were not evaluated because such use is restricted by
the ROD for OU2B. Land use for the area occupied by the 22nd Street Landfill will be
further restricted to prevent uses that could cause direct contact with waste.
3 The "24th Street Drainage Ditch" is a subset of soil/sediment data associated with a small swale west of
the 22nd Street Landfill near 24th Street.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 28
Arsenic was identified as a human health COC in the Rad Yard soil because the
associated carcinogenic risk exceeded 1.0 x 10"6 for industrial (indoor and outdoor)
workers. Although the risks were within the acceptable risk range of 1.0 x 10"6 to
1.0 x 10"4, and remediation to protect workers was not necessary, APG removed the
remaining arsenic hot spot areas at the Rad Yard in 2012.
Arsenic was also the only constituent identified as a potential human health COC for the
22nd Street Landfill cover soil. The arsenic concentrations ranged from 2.4 to 9.3
mg/kg,), typical of background concentrations. The estimated carcinogenic risks to
industrial workers were in the lower end of the acceptable risk range and non-cancer His
were less than one (Table 1). Therefore, arsenic in the 22nd Street Landfill cover soil was
not retained as a final COC for industrial workers.
The soil/sediment in the 24th Street drainage ditch (adjacent to the southwestern boundary
of the 22nd Street Landfill) was evaluated separately from the landfill cover soil. The
pesticide compound 4,4'-dichlorodiphenyldichloroethane (DDD) and arsenic were
retained as potential COCs. The combined non-carcinogenic His for industrial exposure
to DDD and arsenic in soil/sediment within the 24th Street drainage ditch were less than
one. The combined excess lifetime cancer risk from exposure to DDD and arsenic in
drainage ditch soil was less than 1.0 x 10"6 for construction workers and within the 1.0 x
10"6 to 1.0 x 10"4risk range for both indoor workers and outdoor workers (Table 1).
Table 1. Summary of Risks Associated with Exposures to Surface Soil*
Non-Carcinogenic Hazard
Carcinogenic Risk
Indoor
Outdoor
Const
Indoor
Outdoor
Const
Route of
Constituent
Exposure
Worker
Worker
Worker
Worker
Worker
Worker
22nd Si reel ( o\er Soil (SRI. 1 "sihie 30)
Arsenic
Soil Ingestion
0.01
0.01
0.04
1.1E-06
2.0E-06
6.7E-08
Dust Inhalation
0.00
0.00
0.00
2.6E-10
1.4E-09
4.1E-10
Dermal Absorption
0.00
0.00
0.00
0.0E+00
4.3E-07
6.4E-09
Total
0.01
0.02
0.05
1.1E-06
2.5E-06
7.4E-08
Kad Ya
d Soil (SKI
Tahle 31)
Arsenic
Soil Ingestion
0.04
0.07
0.23
6.3E-06
1.1E-05
3.8E-07
Dust Inhalation
0.00
0.00
0.00
1.4E-09
7.9E-09
2.3E-09
Dermal Absorption
0.00
0.01
0.02
0.0E+00
2.4E-06
3.6E-08
Total
0.04
0.09
0.26
6.3E-06
1.4E-05
4.1E-07
24(h Si reel Drainage Swale Soil f SKI. Table 29)
Aibciuc
Soil Ingestion
0.04
0.0"
0.24
O.4L-0O
i.:l-o5
3.8L-0"
Dust Inhalation
0.00
0.00
0.00
1.5E-09
8.0E-09
2.3E-09
Dermal Absorption
0.00
0.01
0.02
0.0E+00
2.4E-06
3.6E-08
DDD
Soil Ingestion
0.00
0.00
0.00
1.4E-07
2.5E-07
8.1E-09
Dust Inhalation
0.00
0.00
0.00
3.1E-12
1.7E-11
4.9E-12
Dermal Absorption
0.00
0.00
0.00
0.0E+00
5.4E-08
8.1E-10
Total
0.04
0.09
0.26
6.6E-06
1.4E-05
4.3E-07
Risks to hypothetical future residents were not evaluated because such use is prohibited by the BRSA-
wide LUCs implemented under the ROD for OU2B (U.S. Army, 2010).
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 29
Most of the carcinogenic risk from soil ingestion, dust inhalation, and dermal absorption
was from arsenic.
The risk assessment did not identify unacceptable risk to future site workers from VOCs
via exposure pathways other than inhalation of vapor emanating from groundwater. The
OU3 groundwater remedy (managed as a separate OU) will address the VOC inhalation
risks.
There is potential that landfilled waste could include hazardous materials and constituents
that could pose a hazard or risk if inadvertent excavation created an exposure pathway.
7.2 Ecological Risks
The site-wide median and mean arsenic concentrations in Rad Yard soil are lower than
APG-specific toxicity reference values for terrestrial plants, soil invertebrates and
wildlife. Three remaining arsenic hot spot areas contained concentrations that were
potentially toxic to soil invertebrates. These three hot spot areas were removed in March
The ecological risk evaluation for the 22nd Street Landfill indicated concentrations of
lead, copper, antimony, arsenic, iron, manganese, and selenium in soil/sediment of the
southern drainage ditch (in the vicinity of sample SD-64) could potentially cause toxic
effects to ecological receptors. While the effects to ecological receptors were uncertain,
given the maximum size of the affected area (approximately 1/30 of an acre) effects to
communities were not expected. No other area of the 22nd Street Landfill indicated the
potential for ecological risk in soil, surface water, or sediment.
8 REMEDIAL ACTION OBJECTIVES
RAOs are goals developed for the protection of human health and the environment. These
objectives can be achieved by reducing exposure (e.g., capping an area or limiting access)
as well as by reducing the concentration level of COCs.
The primary RAO for the 22nd Street Landfill is to:
• Prevent direct exposure to landfilled waste.
The risk assessments identified no unacceptable risks to industrial workers or ecological
communities. There are no COCs and no environmental media of concern. Therefore,
no RGs have been developed for protection of workers or the environment. The disposed
waste within the 22nd Street Landfill has not been fully characterized. However, there is
no need to develop RGs for constituents that possibly exist in waste, because the
presumptive containment remedy will prevent exposure to constituents in waste.
The following RAO applies to all of the OU3 Surface Units, including the 22nd Street
Landfill, the Rad Yard, the Building E2364 UST Site, and the Former Adamsite Storage
Vault:
2012.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 30
• Prohibit land use that would result in unacceptable risks to receptors through
exposure to site-related contaminants.
As mentioned previously, the ROD for OU2B included a residential LUC prohibiting the
use of the entire BRSA for family housing, elementary and secondary schools, child care
facilities, playgrounds, and other residential land use. These area-wide LUCs,
implemented in April 2011, meet this RAO for the OU3 Surface Units.
9 DESCRIPTION OF ALTERNATIVES
The Rad Yard, Building E2364 UST Site, and Former Adamsite Storage Vault have been
addressed by previous removal actions. These sites do not present any unacceptable risks
to human health under the current industrial use or to ecological receptors. However,
these sites are not suitable for UU/UE. Since LUCs prohibiting family housing,
elementary and secondary schools, child care facilities, playgrounds, and other residential
land use were implemented for the entire BRSA under the ROD for OU2B, NFA was
proposed for these sites.
Remedial alternatives were developed and screened to address potential contaminants
remaining at the 22nd Street Landfill. Under CERCLA, the presumptive remedy for
municipal landfill sites is containment (OSWER Directive 9355.0-49FS), and this
presumptive remedy is applicable to the 22nd Street Landfill (OSWER Directive 9355.1-
67FS). Sampling and analysis at the site have demonstrated that no releases to
environmental media are occurring, and the remaining pathway of concern for the OU3
Surface Units is the potential for direct contact with the waste at the 22nd Street Landfill
via inadvertent excavation or erosion.
As required by the NCP [40 CFR 300.430(e)(6)], a No Action Alternative (Alternative 1)
was developed to serve as a baseline for comparison in the evaluation of potential
remedial alternatives. Additional alternatives evaluated for the 22nd Street Landfill during
the preliminary screening included: Maintenance of Existing Improvements with LUCs
and Monitoring (Alternative 2); Low-Permeability Cap with Wetland Mitigation, LUCs,
Site Maintenance, and Monitoring (Alternative 3); and Excavation and Off-Site Waste
Disposal (Alternative 4). The remedial alternatives were initially screened for
effectiveness, implementability, and cost [40 CFR 300.430(e)(7)],
Alternative 4 (Excavation and Off-Site Waste Disposal) was eliminated during the initial
screening in the FS, for several reasons. The cost of Alternative 4 for the 22nd Street
Landfill was extremely high due to the large volume of waste and impacted soil/sediment
that would require UXO screening followed by disposal at an off-site industrial waste
facility. The presumptive remedy for landfills is containment, and impacts to the wetland
environment from excavation and off-site disposal would be significant. Therefore,
Alternative 4 was not retained for detailed alternative evaluation.
Alternatives 1 through 3 were evaluated in detail for the 22nd Street Landfill, as described
in the FS Report (GP, 2013b). For purposes of cost comparison, a project duration of 30
years was assumed for all alternatives.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 31
9.1 Alternative 1 - No Action
The NCP [40 CFR 300.430(e)(6)] requires consideration of "No Action" as a baseline
with which to compare other alternatives. Under this alternative, no remedial efforts
would be made to control risk; treat or contain source materials; or reduce toxicity,
mobility or volume of contaminated media. Site-specific LUCs (e.g., restricting
excavation and groundwater use) would not be implemented.
Estimated Capital Cost: $0
Estimated O&M / LTM Cost: $0
Estimated Total Present Worth Cost: $0
Estimated O&M Timeframe: None
Estimated Time to Achieve RAOs: Will not achieve
9.2 Alternative 2 - Maintenance of Existing Improvements with LUCs and
Monitoring
This alternative involves containment of the landfilled waste, which is a presumptive
remedy for landfills. The improvements to the soil cover and shoreline stabilization
measures implemented at the 22nd Street Landfill during the 2012 TCRA, would continue
to be maintained and monitored as part of this alternative. Periodic inspections would be
conducted to verify that the amended soil cover and shoreline stabilization structures
remain in place and protective of human health and the environment. Monitoring of
environmental media would be conducted to detect potential releases to the Bush River.
This alternative could be readily implemented, as no construction is required.
The soil cover (as amended during the 2012 TCRA) conserves and protects public health
and the environment to at least the same extent as would be obtained by a low
permeability cap at this site, because most of the waste lies within or below the water
table. Although this alternative does not satisfy the low permeability cap requirements for
a landfill specified in Code of Maryland Regulations (COMAR) 26.04.07.21, it is
considered to be as protective, and, therefore, would satisfy the requirements necessary to
qualify for a variance as described in COMAR 26.04.07.26.
LUCs preventing family housing, elementary and secondary schools, child care facilities,
playgrounds, and other residential land use were implemented for the entire BRSA under
a previous ROD for OU2B (U.S. Army, 2010). Additional OU3-specific LUCs would
prohibit the use of groundwater4 and restrict excavation and other activities that could
result in the exposure of receptors to subsurface materials potentially containing
hazardous constituents. These restrictions would be maintained until such time as
contaminant levels in soil and groundwater were at levels that allowed for UU/UE.
Five-year remedy reviews, as required by Section 121(c) of CERCLA and the NCP, at 40
CFR 300.430(f)(4)(ii), for remedial actions that result in hazardous substances,
4 Potential risks from inhalation and ingestion of OU3 groundwater will be addressed under a separate remedial
action (managed as a separate OU). However, due to State requirements, LUCs would be required under
Alternatives 2 and 3 for 22nd Street Landfill, to prevent the use of groundwater within 100 ft of a known landfill.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 32
pollutants, or contaminants remaining at a waste site above levels that allow for UU/UE
would be conducted at the 22nd Street Landfill.
The costs for Alternative 2 include capital costs for site-specific LUC implementation
and O&M costs for monitoring, inspections, and maintenance of the improved soil cover
and shoreline stabilization structures.
Estimated Capital Cost: $58,400
9.3 Alternative 3 - Low-Permeability Cap with Wetland Mitigation, LUCs, Site
Maintenance, and Monitoring
This alternative involves the construction of a low-permeability cap that would meet the
State of Maryland requirements for landfill closure. To achieve adequate sloping and
drainage, the footprint of the low permeability cover would be substantially larger than
the existing soil cover (with the landfill footprint approximately doubling in size, from
10.4 acres to over 21 acres). Extensive mitigation efforts would be required to replace the
loss in tidal, non-tidal, and forested wetlands within the expanded footprint of the low
permeability cap.
Site inspections would verify that the integrity of the cap remains intact and protective of
human health and the environment. Periodic sampling of groundwater, surface water,
and sediment would be accomplished to verify the long-term effectiveness of the remedy.
RAOs would be achieved within 2 years, but O&M would continue for the life of the
landfill5.
LUCs preventing family housing, elementary and secondary schools, child care facilities,
playgrounds, and other residential land use would be required; however, they have been
implemented for the entire BRSA under the ROD for OU2B (U.S. Army, 2010).
Additional site-specific LUCs would be implemented to prohibit groundwater use and
prevent disturbance of the cap and subsurface waste at the 22nd Street Landfill. These
restrictions would be maintained until such time as site contaminants were at levels that
allowed for UU/UE. Five-year remedy reviews would also be required by statute, since
hazardous substances, pollutants, or contaminants would remain at the site above levels
that would allow for UU/UE.
Capital costs include cap construction, wetland mitigation, stream diversion, and UXO
support. Long-term O&M costs include site maintenance, monitoring, site-specific
LUCs, and five-year reviews.
Estimated O&M /LTM Cost:
Estimated Total Present Worth Cost:
Estimated O&M Timeframe:
Estimated Time to Achieve RAOs:
$1,271,300
$1,329,700
30 Years
Less Than 1 Year
5 For cost estimating purposes, a 30-year project duration is assumed.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 33
Estimated Capital Cost:
Estimated O&M / LTM Cost:
Estimated Total Present Worth Cost:
Estimated O&M Timeframe:
Estimated Time to Achieve RAOs:
$12,753,700
$3,457,500
$16,211,200
30 Years
2 Years
10 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In evaluating remedial alternatives, the potential performance of each alternative is
evaluated in terms of the nine evaluation criteria required by the NCP at 40 CFR
300.430(e)(9)(iii). The nine criteria are categorized into one of three categories:
threshold criteria, primary balancing criteria and modifying criteria (Table 2). The
alternative selected must satisfy the threshold criteria, which are of primary importance.
The primary balancing criteria are used to weigh the major tradeoffs among the
alternatives, and the modifying criteria are considered in light of the public comments on
the Proposed Plan.
The alternatives must also be considered from a "green and sustainable" perspective,
considering potential environmental effects, such as energy consumption, greenhouse gas
emissions, water consumption, resource use or consumption, and worker safety.
10.1 Overall Protection of Human Health and the Environment
Alternative 1 (No Action) would not be protective because it does not provide for
maintenance of the existing landfill cover to prevent potential exposures to hazardous
constituents, nor does it include the additional LUCs necessary to prevent excavation in
the landfill, which could also result in exposure to hazardous constituents. Therefore,
Alternative 1 will not be considered further in this evaluation, since it fails one of the
threshold criteria.
Alternative 2 (Maintenance of Existing Improvements with LUCs and Monitoring)
provides for protection of human health and the environment by maintaining the existing
cover soil and implementing LUCs and long-term monitoring. Alternative 3 (Low
Permeability Cap) provides protection by improving the landfill cover. However, there
are significant environmental impacts associated with construction of the low
permeability cap, including the loss of wetland and forested areas.
10.2 Compliance with Applicable or Relevant and Appropriate Requirements
There were no COCs carried through the risk assessment; therefore, no chemical-specific
ARARs apply to this site. Alternative 2 (Maintenance of Existing Improvements with
LUCs and Monitoring) would not comply with the low permeability cap requirements of
COMAR 26.04.07.21. However, Alternative 2 is considered to be as protective as the
low-permeability cap in this circumstance, and, therefore, would satisfy the requirements
to qualify for a variance under COMAR 26.04.07.26. Alternative 3 (Low Permeability
Cap) would satisfy the capping requirements of COMAR 26.04.07.21.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 34
Table 2. Remedial Alternative Evaluation Criteria
Threshold Criteria:
• Overall Protection of Human Health and the Environment refers to whether a
remedy provides adequate protection against harmful effects. It calls for
consideration of how human health or environmental risks are eliminated, reduced,
or controlled through treatment, engineering controls, or institutional controls.
• Compliance with Applicable or Relevant and Appropriate Requirements addresses
whether a remedy meets all the applicable or relevant and appropriate requirements
of federal and state environmental statutes.
Primary Balancing Criteria:
• Long-Term Effectiveness and Permanence refers to the magnitude of residual risk
and the ability of a remedy to maintain reliable protection of human health and the
environment after cleanup goals have been met.
• Reduction of Toxicity, Mobility, or Volume through Treatment refers to the
effectiveness of the treatment technologies in reducing the toxicity, mobility, or
volume of contaminants.
• Short-Term Effectiveness refers to the speed with which the remedy achieves
protection and to the remedy's potential during construction and implementation to
have adverse effects on human health and the environment.
• Implementability refers to the technical and administrative feasibility of a remedy,
including the availability of required materials and services.
• Cost includes capital expenditures and operation and maintenance costs.
Modifying Criteria:
• State Acceptance indicates whether the state concurs with, opposes, or has no
comment on the preferred alternative based on its review of the RI/FS Reports,
Proposed Plan, and public comments.
• Community Acceptance is documented in the ROD following consideration of public
comments on the Proposed Plan.
Sustainabilitv Criteria:
• Sustainability refers to the generation of greenhouse gases and air emissions, water
and energy usage, accident risk and community impacts, and loss of resources.
Additional factors that can be considered as applicable include use of renewable,
reusable, or recyclable materials, and waste avoidance or reduction.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 35
10.3 Long-Term Effectiveness and Permanence
Through continued maintenance of the cover systems and shoreline stabilization
structures, Alternatives 2 (Maintenance of Existing Improvements with LUCs and
Monitoring) and 3 (Low Permeability Cap) would provide for long-term effectiveness
and permanence.
10.4 Reduction of Toxicity, Mobility, or Volume through Treatment.
Neither Alternative 2 nor Alternative 3 involves treatment. Therefore, neither Alternative
satisfies the criterion to reduce toxicity, mobility or volume through treatment.
10.5 Short-Term Effectiveness
Alternative 2 (Maintenance of Existing Improvements with LUCs and Monitoring) has
no planned construction and no short-term impacts to the public, remedial workers, or
environment. Alternative 3 (Low Permeability Cap) poses moderate risks to remedial
workers during construction in the wetland environment, but significant impacts to the
environment. The RAOs would be achieved under Alternative 2 within 1 year and
Alternative 3 within 2 years.
10.6 Implementability
Alternative 2 (Maintenance of Existing Improvements with LUCs and Monitoring) could
be readily implemented. Alternative 3 (Low Permeability Cap) would be extremely
difficult to implement in the wetland environment.
Alternative 2 (Maintenance of Existing Improvements with LUCs and Monitoring) has
moderate costs. Alternative 3 (Low Permeability Cover) has the highest capital cost, due
to the complexities associated with diversion of the drainages and construction in a
wetland environment containing potential UXO. The most significant O&M costs are
associated with 30-year maintenance of the cover systems and long-term environmental
monitoring. The total present worth costs are: $16,211,200 (Alternative 3) and
$1,329,700 (Alternative 2).
10.8 State Acceptance
State representatives have reviewed the alternatives in the Proposed Plan for remedial
action at OU3. Based on a thorough review of the remedial response alternatives and
public comments, MDE concurs with Alternative 2 (Maintenance of Existing
Improvements with LUCs and Monitoring) for 22nd Street Landfill and NFA with
Existing LUCs for the Remaining OU3 Surface Units.
10.7 Cost
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 36
10.9 Community Acceptance
A summary transcript of the Public Meeting held on July 25, 2013, is available in the
Administrative Record. Responses to written comments received from the community
are presented in Part 3 of this document.
10.10 Sustainability Criteria
Alternative 2 poses low potential for environmental effects, with respect to energy
consumption, greenhouse gas emissions, water consumption, resource use or
consumption, or worker safety. Alternative 3 poses a medium to high potential for
environmental effects, primarily associated with worker safety (accident risks) and
resources lost (acres of tidal and non-tidal wetlands and forested area impacted by the
expanded footprint required for a low permeability cap).
10.11 Summary of Comparative Analysis of Alternatives
Alternative 1 (No Action) would not provide protection of human health or the
environment, because the existing cover would not be maintained and restrictions would
not be placed on excavation or groundwater usage. Although Alternative 3 (Low
Permeability Cap) would fully comply with the requirements for landfill closure specified
in COMAR 26.04.07.21, due to site constraints and the potential for encountering UXO,
a low permeability cap would be extremely difficult to construct at this site. In addition,
since most of the landfilled waste lies within or below the water table, an impermeable
cover would not prevent infiltration or reduce leachate. There are also no measureable
gas emissions to manage. Environmental impacts would also be significant and
mitigation efforts would be required, due to the proximity of the landfill to tidal streams,
tidal and non-tidal wetlands, and forested land (which would need to be cleared).
Alternative 2 (Maintenance of Existing Improvements with LUCs and Monitoring) would
contain the waste and minimize exposure to the same extent as a low permeability cap.
Alternative 2 would achieve the RAOs and protect human health and the environment by
preventing exposure to subsurface waste through maintenance of the improved soil cover
and shoreline stabilization structures and implementation of site-specific LUCs.
Although this alternative would not meet the low permeability cap requirements for
landfill closure specified in COMAR 26.04.07.21, it is considered to be as protective,
and, therefore, would meet the requirements to qualify for a variance to the capping
requirements as provided in COMAR 26.04.07.26.
Alternatives 2 and 3 are both considered "green and sustainable" remedies, but with
moderate to high risks associated with construction of the low-permeability cap.
11 PRINCIPAL THREAT WASTES
Principal threat wastes are those source materials considered to be highly toxic or highly
mobile that generally cannot be reliably contained, or would present a significant risk to
human health or the environment should exposure occur. Materials remaining at the OU3
Surface Units would not constitute a principal threat waste.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 37
12 SELECTED REMEDIES
12.1 Description of the Selected Remedies
22nd Street Landfill
The Selected Remedy for the 22nd Street Landfill is Alternative 2 (Maintenance of
Existing Improvements with LUCs and Monitoring). In Maryland, the presumptive
remedy for landfills is containment, including a low permeability cap. However, at the
22nd Street Landfill, the construction of a low permeability cap would not reduce the
production of leachate or improve water quality since the waste is predominantly below
the water table. There are also no measureable gas emissions to manage. Therefore,
Alternative 2 is as protective as the presumptive remedy for landfills. Due to the nature
of the contents of the landfill and nearby sensitive environments, the Army and the
USEPA believe, and MDE concurs, that a variance to the capping requirements of
COMAR 26.04.07.21, as provided by COMAR 26.04.07.26 (Attachment A), is
appropriate in this case. The Selected Remedy for the 22nd Street Landfill will be at least
as effective in protecting human health and the environment as a low permeability cap
would be, and will not impact the surrounding wetland or forest environments.
The components of the Selected Remedy are summarized below.
• Maintenance of Existing Improvements: The soil cover constructed in the upland
areas and shoreline stabilization structures installed at the toe of the landfill
during the 2012 TCRA (Figure 8) will be maintained, to prevent direct contact
with subsurface waste. Periodic inspections will be conducted to verify that the
site improvements remain in place and protective of human health and the
environment.
• Long-Term Monitoring: Groundwater, surface water, and sediment sampling will
be conducted on a semi-annual basis for five years, with a potential to decrease
the frequency based on the results of the first five-year review. Details regarding
the sampling plan will be provided in the RD.
• Land-Use Controls: The current and planned future use of the 22nd Street Landfill
is for military/industrial activities. The Army recently implemented a residential
LUC for the entire BRSA as part of the final remedy for OU2B.
The following quote is from Section 4 of the Declaration in the ROD for OU2B
(U.S. Army, 2010):
"LUCs will be implemented at BRSA to prevent site activities that
would result in unacceptable exposure. A BRSA-wide LUC will
prevent future family housing, elementary and secondary schools,
child care facilities, playgrounds, and other residential land use
within OU2B and the remainder of the BRSA."
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 38
Section 12.2 of the ROD for OU2B (U.S. Army, 2010), also applies to the entire
BRSA, including the OU3 Surface Units:
"The U.S. Army will be responsible for implementation,
maintenance, periodic inspection, reporting on and enforcement of
LUCs in accordance with the RD and this ROD. Although the U.S.
Army may transfer these responsibilities to another party by
contract, property transfer agreement, or through other means, the
Army will remain responsible for:
> conducting CERCLA Section 121(c) five-year reviews;
> notifying USEPA and MDE and/or local government
representatives of any known LUC deficiencies or
violations;
> obtaining access to the property to conduct periodic
inspections and any necessary response; and
> ensuring that the LUC objectives are met to protect the
integrity of the selected remedy.
As set forth in the RD, the U.S. Army will not modify or terminate
LUCs or implementing actions without prior approval of USEPA,
after conferring with MDE. The U.S. Army will seek prior
concurrence with USEPA and MDE before taking an action that
would disrupt the effectiveness of the LUCs.
If the U.S. Army transfers property in the areas addressed by this
ROD, the U.S. Army will ensure that the restrictions on site
activities are included in the deed to the property recorded in the
local property records and that notification of the restrictions in the
deed is filed with the appropriate agencies, so that current and
future property owners will be aware of these restrictions. At the
earliest possible time, but no later than 60 days prior to leasing or
transferring Army-owned property under this LUC to another
agency, person, or entity (including federal to federal transfers) the
Army will provide notice to USEPA and MDE of such intended
lease or transfer. Specific deed restriction language and the
appropriate agencies will be identified in the approved RD. While
the U.S. Army maintains ultimate responsibility for LUC
enforcement, the Army may require the transferee or lessee in
cooperation with other stakeholders to assume responsibility for
LUC implementation actions. Third-party LUC responsibility will
be incorporated into pertinent contractual, property and remedial
documentation, such as a purchase agreement, deed, lease and RD
addendum."
-------
LEGEND
~ Structure
Treeline
Road
Water
' - ¦ Gravel Path
Site Boundary
Tidal Wetland
l Non-Tidal Wetland
Topography prior to Soil Cover Improvements
Topography of Soil Cover Improvements
Leading the world to better performance
500 Edgewood Road, Suite 110
Edgewood, MD 21040
(410) 676-8835
www.gpworldwide.com
(./M il i/ rinsfts coki'ok i iio\
TCRA SITE
IMPROVEMENTS
CARTOGRAPHER:
B. JOYCE
DATE:
06-06-2013
APPROVED BY:
K. THORPE
FIGURE:
8
Wgenphysics.com \Edgewood\A ccoun tingUnits\lS3\Edge wood Gra phics \ GEOGRA PHICS\BRSA \OU3\ Case Presentation \Scenario 8_As-Built.i
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Record of Decision Final
Bush River Study Area Operable Unit 3 September 2013
Aberdeen Proving Ground, Maryland Page 40
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 41
"To the extent permitted by law, a transfer deed shall require the
LUCs imposed as part of a CERCLA remedy to run with the land
and bind all property owners and users. If the U.S. Army intends to
transfer ownership of any site, the Army may, if federal and/or
state law allows, upon transfer of fee title grant the state an
environmental covenant or easement that would allow the state to
enforce LUC terms and conditions against the transferee(s), as well
as subsequent property owner(s) or user(s) or their contractors,
tenants, lessees or other parties. This covenant will be incorporated
by reference in the transfer deed and will run with the land in
accordance with state realty law. This state enforcement right
would supplement, not replace, the U.S. Army's right and
responsibility to enforce the LUCs."
A copy of the memoranda implementing the LUCs for the BRSA, including a
figure showing the LUC boundaries, is provided as Attachment B to this ROD.
These residential LUCs are required until contaminant concentrations reach a
level that allows for UU/UE.
Additional site-specific LUCs will be implemented to prohibit the use of
groundwater within 100 ft of the 22nd Street Landfill (Figure 9) and to prevent soil
excavation or other activities that could result in the exposure of receptors to
subsurface materials potentially containing hazardous constituents. These LUCs
will also prevent disturbance of the existing shoreline stabilization structures and
the existing vegetative cover, thereby maintaining remedy effectiveness into the
future. These restrictions will be maintained until such time as contaminant levels
in soil and groundwater are at levels that allow for UU/UE.
The additional LUC restrictions will be incorporated into the APG Geographic
Information System and Real Property Master Plan. The LUC information and
notation of the NPL status of the site will be included in BRAC, property, or real
estate documents necessary for transfer of ownership of the site or any portion
thereof.
Five-year remedy reviews will be conducted as required by Section 121(c) of CERCLA
and the NCP at 40 CFR 300.430(f)(4)(ii), since hazardous substances, pollutants, or
contaminants will remain at the site above levels that allow for unlimited use and
unrestricted exposure. The five-year reviews for the 22nd Street Landfill and the
Remaining OU3 Surface Units will be conducted during the consolidated CERCLA
review for the Edgewood Area of APG (with the next review due in 2018).
The Selected Remedy for the 22nd Street Landfill will achieve the RAOs within 12
months of RD approval.
-------
RESIDENTIAL USE RESTRICTION
PROPOSED GROUNDWATER RESTRICTION
PROPOSED SOIL EXCAVATION RESTRICTION
1200 900 600 300
1200
2400
GRAPHICAL SCALE
IN FEET (1" = 1200')
1:14400
L
G
N D
Water I I Non-tidal Wetland
Road -
» Residential Use Restriction
Groundwater Well
Restriction
Soil Excavation
Restriction
Tidal
Wetland
Leading the world to better performance
500 Edgewood Rd, Suite 110 (410) 676-8835
Edgewood, MD 21040 www.gpworldwide.com
TITLE:
LAND USE RESTRICTIONS
RELEVANT TO THE OU3 SURFACE UNITS
CARTOGRAPHER:
B. JOYCE
APPROVED BY:
K. THORPE
DATE:
07-22-2013
FIGURE:
Wgenphysics.com\Edgewood\AccountingUnits\133\Edgewood Graphics\GE0GRAPHICS\BRSA\0U3\Case Presentation\0U3 Land Use Restrictions.dgn
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 43
Rad Yard, Building E2364 UST Site, and Adamsite Storage Vault
The Selected Remedy for the three Remaining 0U3 Surface Units is NFA with Existing
LUCs. As mentioned previously, the LUCs implemented in response to the ROD for
OU2B prohibit the use of the entire BRSA, including the OU3 Surface Units, for family
housing, elementary and secondary schools, child care facilities, playgrounds, and other
residential land use.
Five-year remedy reviews would be conducted as required by Section 121(c) of
CERCLA and the NCP at 40 CFR 300.430(f)(4)(ii), since hazardous substances,
pollutants, or contaminants will remain at the sites above levels that allow for UU/UE.
12.2 Summary of the Rationale for the Selected Remedies
The Selected Remedies meet the threshold criteria, provide the best balance of tradeoffs
with regard to the primary balancing criteria as compared to the other alternatives, and
satisfy the modifying criteria. The Selected Remedies satisfy the following statutory
requirements of CERCLA Section 121(b) to:
• Be protective of human health and the environment;
• Comply with ARARs, unless waived;
• Be cost-effective;
• Utilize permanent solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable; and
• Satisfy the preference for treatment as a principle element when justified.
The risk assessments identified no unacceptable risks to industrial workers or ecological
communities. There are no COCs and no media of concern. Therefore, no RGs have
been developed for protection of workers or the environment. The disposed waste within
the 22nd Street Landfill has not been fully characterized. However, there is no need to
develop RGs for constituents that possibly exist in waste, because the presumptive
containment remedy will prevent exposure to constituents in waste.
The Selected Remedies do not employ treatment to reduce toxicity, mobility or volume of
hazardous substances, pollutants, or contaminants and, therefore, do not satisfy the
statutory preference for remedies that employ treatment as a principal element. The only
potential risk is posed by inadvertent excavation/exposure of subsurface waste and,
therefore, LUCs to prevent site activities that would result in unacceptable exposure will
effectively protect human health and the environment.
The 22nd Street Landfill was created by landfilling into a tidal marsh. The landfilled
waste lies beneath the water table. The existing cover soil is uncontaminated and does not
contain constituents at concentrations that pose risk to either human health or the
environment. Because of these factors, a low-permeability cap would not protect human
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 44
health or the environment to a greater extent than the existing soil cover, provided that
the soil cover is maintained.
Table 3 lists the ARARs for the Selected Remedy. The existing soil and natural
vegetation cover does not meet the State of Maryland regulation for landfill closure.
However, the existing cover for the 22nd Street Landfill conserves and protects public
health and environment to at least the same extent as would be obtained by a low
permeability cap at this site, and , therefore, satisfies the requirements to qualify for a
variance to the capping requirement as provided by COMAR 26.04.07.26.
The Selected Remedy and associated remedial activities do not pose a risk to remedial
workers. Trained personnel following proper health and safety procedures will conduct
all intrusive activities (such as well installation, if needed). All RAOs will be achieved
upon implementation.
The Selected Remedies will result in hazardous substances, pollutants or contaminants
remaining on site at levels that do not allow for UU/UE. Therefore, LUCs will be
maintained to prohibit site activities that would result in unacceptable exposure. These
sites will be included in the periodic CERCLA Section 121(c) remedy reviews of the
Edgewood Area's NPL sites.
12.3 Summary of Estimated Remedy Costs
The information in the cost estimate summary is based on the best available information
regarding the anticipated scope of the remedial response. Changes in the cost elements
are likely to occur as a result of new information and data collected during RD and post-
remediation verification. This is an engineering cost estimate that is expected to be within
-30 to +50 percent of the actual project cost (USEPA, 1999; USEPA, 2000). The
estimated cost for each site includes total capital cost, annual O&M costs and present
worth over a 30-year period.
The total capital cost for the Selected Remedy for the 22nd Street Landfill is estimated to
be $1,329,700. The detailed costs are provided in Table 4.
There is no additional cost for the Selected Remedy for the Remaining OU3 Surface
Units. Residential LUCs have been implemented for the entire BRSA under a ROD for
OU2B (U.S. Army, 2010).
12.4 Expected Outcomes of Selected Remedies
Maintenance of the Existing Cover with LUCs, Site Maintenance, and Monitoring
remedy will effectively control potential risk of exposure upon implementation. The
OU3 Surface Units are prohibited from residential land use under the BRSA-wide LUCs
implemented pursuant to the previous ROD for OU2B. Land-use at the site will remain
military/industrial, with restrictions on unauthorized excavation and groundwater use in
the area of the 22nd Street Landfill, as indicated on Figure 9.
-------
CODE OF MARYLAND REGULATIONS (COMAR) SECTION
26.04.04.07 Well Construction - Construction Standards
26.04.04.10 Well Construction - Well Owners' Responsibilities
26.04.04.11 Well Construction - Abandonment Standards
26.04.07.21 Solid Waste Management - Sanitary Landfill, Closure
26.04.07.22 Solid Waste Management - Sanitary Landfills, Post-Closure
Monitoring and Maintenance
Table 3. State of Maryland ARARs
REQUIREMENT
Establishes requirements for sanitary protection during well
construction, water used for drilling, well design, construction
materials and construction procedures.
Requires well owners to maintain wells so that groundwater is
protected and wells can be identified.
Establishes standards for abandonment of wells.
SUBSTANTIVE REQUIREMENTS
ARAR TYPE CONSIDERED
Action-Specific Applicable for any new or replacement
monitoring wells constructed in the future.
Action-Specific Applicable for exsiting monitoring wells and
any new or replacement wells constructed in
the future.
Action-Specific Applicable for exsiting monitoring wells and
any new or replacement wells constructed in
the future.
Establishes requirements for closure of sanitary, rubble and Action-Specific Relevant & Appropriate
industrial waste landfills, including specifications for the closure
cap.
Establishes requirements for post-closure inspections and Action-Specific Relevant & Appropriate
maintenance for landfills.
26.04.07.26 Solid Waste Management - Variances
Establishes the framework for obtaining variances to the
requirements of the solid waste management regulations,
including closure cap requirements.
Action-Specific
Relevant & Appropriate
-------
Table 4. Detailed Costs for the Selected Remedy for 22nd Street Landfill
COST ELEMENTS
Study / Design / Capital Costs
Design Documentation
LUC Design/Monitoring Plan
LUC Implementation
Interval
# of Between
Events/ Events
Years (years)
Discount Discount
Starting Quantity Units
2012
2012
Cost per
Event/Year
$21,000
$37,400
for
Future
Start
1.00
1.00
Rate
per
Interval
2.3%
2.3%
Total Capital Cost
Non-
Discounted
Cost
$21,000
$37,400
$58,400
Present
Value
Cost
$21,000
$37,400
$58,400
Estimate Source
RACER 10.2
RACER 10.2
Operation & Maintenance Costs
Maintenance of Remedy
LTM for Initial Five Years
LTM after Initial Five Years
Site Inspections, LUC Enforcement, & Maintenance
Remedy Reviews and Site Closeout
Five Year Reviews
Site Closeout Documentation
Total O&M Costs
TOTAL COST
5
6
30
6
1
2012
2017
2012
2012
2047
$54,300
$52,200
$30,100
$28,000
$14,300
1.00
0.89
1.00
1.00
0.45
2.3%
12.0%
2.3%
12.0%
2.3%
$271,500
$313,200
$903,000
$168,000
$14,300
$259,600
$214,400
$662,000
$128,800
$6,500
RACER 10.2
RACER 10.2
RACER 10.2
RACER 10.2
RACER 10.2
$1,670,000 $1,271,300
$1,728,400 $1,329,700
RACER 10.2 (AECOM, 2009) unit costs escalated to 2012 dollars,
using an escalation factor of 1.0501 (Army Inflation Index for DERA
Program, updated Jan 2011)
Discount Rate for Present Value Calculations [Appendix C of OMB
Circular No. A-94] (30-Year)
Remedial Time Frame
1.0501
2.3%
2012 Base Year
30 Years
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 47
12.5 Performance Standards for the Selected Remedies
The following performance standards were established for OU3 Surface Units:
• There shall be no development or use of the OU3 Surface Units for future family
housing, elementary and secondary schools, child care facilities, playgrounds, and
other residential land use in accordance with the BRSA-wide residential LUCs
established in the ROD for OU2B (U.S. Army, 2010).
• Restrictions will be placed in the APG GIS and Real Property Master Plan to: i)
prevent groundwater use within 100 ft of the 22nd Street Landfill; ii) prevent
excavation or other activities within the 22nd Street Landfill that could result in
exposure of receptors to subsurface materials that potentially contain hazardous
constituents; and, iii) prevent disturbance of the shoreline stabilization structures at
the toe of the landfill adjacent to Bush River (Figure 8).
• Maintain the existing cover material and vegetation at the 22nd Street Landfill and the
shoreline stabilization measures at the toe of the landfill adjacent to Bush River, to
protect human health and the environment.
13 STATUTORY DETERMINATIONS
13.1 Protection of Human Health and the Environment
Potential exists for risk to human health and the environment if no remedial action is
undertaken. This remedial response meets the requirements of CERCLA Section 121 and,
to the extent practicable, the NCP. The Selected Remedies are protective of human health
and the environment, through the implementation and continued maintenance of LUCs,
and the maintenance of the existing cover soil on the 22nd Street Landfill.
The Selected Remedies do not pose a risk to remedial workers. Trained personnel
following proper health and safety procedures will conduct all intrusive activities (such as
well installation, if needed).
All RAOs will be achieved upon implementation of the Selected Remedies.
13.2 Compliance with Applicable or Relevant and Appropriate Requirements
State of Maryland ARARs are provided in Table 3. CERCLA Section 121(e) exempts
any Federal onsite remedial action from administrative requirements for Federal, State,
and/or local permits. However, onsite actions must still comply with the substantive
technical aspects of these requirements.
The existing cover for the 22nd Street Landfill conserves and protects public health and
environment to at least the same extent as would be obtained by a low permeability cap at
this site, and, therefore, satisfies the requirements to qualify for a variance to the capping
requirement as provided by COMAR 26.04.07.26.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 48
Location-specific ARARs for non-tidal and tidal wetlands were considered relevant and
appropriate in the FS for low permeability cap construction, but do not apply to the
maintenance of existing structures and LUCs under the Selected Remedy for the 22nd
Street Landfill.
13.3 Cost-Effectiveness
A containment alternative for the 22nd Street Landfill is consistent with the presumptive
remedy for landfills. The Selected Remedy is at least as effective in protecting human
health and the environment as a capping remedy would be, with a much lower
environmental impact to the surrounding wetlands and forested areas than a more costly,
low-permeability cap. The Selected Remedy for the Remaining OU3 Surface Units is
also considered cost-effective, because the costs for implementation of the residential
LUCs have already been addressed by the previous remedial action for OU2B.
13.4 Utilization of Permanent Solutions and Alternative Treatment Technologies to
the Maximum Extent Practicable
The Selected Remedies are permanent solutions, but will require ongoing O&M and
LTM. While the Selected Remedies do not employ any treatment or resource recovery
technologies, they are considered permanent solutions which provide the best balance of
tradeoffs compared to the other proposed alternatives.
13.5 Preference for Treatment as a Principal Element
Although there were no COCs identified during the RI in the cover soil that would
require treatment, subsurface wastes will remain on site within the 22nd Street Landfill.
As a result, the Selected Remedies do not employ treatment to reduce toxicity, mobility
or volume of hazardous substances, pollutants or contaminants and, do not satisfy the
statutory preference for remedies that employ treatment as a principal element.
13.6 CERCLA 121(c) Five-Year Review Requirement
The Selected Remedies will result in hazardous substances, pollutants or contaminants
remaining on site at levels that do not allow for UU/UE. Therefore, the OU3 Surface
Units will be included in the consolidated five-year CERCLA remedy reviews of the
Edgewood Area's NPL sites, to ensure that the remedy is, or will be, protective of human
health and the environment. Five-year reviews will be conducted in accordance with
DERP policy and OSWER Directives 9355.7-03B-P and 9234.2-25, or their most current
revision or replacement.
14 DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes were made to the Proposed Remedial Action Plan since it was
noticed to the public.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 49
PART 3: RESPONSIVENESS SUMMARY
The purpose of the Responsiveness Summary is to provide a summary of the public's
comments, concerns and questions about the Edgewood Area Proposed Plan for
Remedial Action at the OU3 Surface Units, and the Army's responses to these concerns.
APG held a public meeting on July 25, 2013 to formally present the Proposed Plan and
response actions and to answer questions and receive comments. The summary transcript
of this meeting is part of the Administrative Record for APG. During the public
comment period, which ran from July 17, 2013 to August 16, 2013, APG also received
written comments. All comments and concerns summarized below have been considered
by the Army and USEPA in selecting the response actions for the OU3 Surface Units.
1 OVERVIEW
At the time of the public comment period, the U.S. Army and USEPA had endorsed the
Maintenance of Existing Improvements with LUCs and Monitoring for the 22nd Street
Landfill and NFA with Existing LUCs for the Remaining OU3 Surface Units, to protect
human health and the environment.
Based on a thorough review of the remedial response alternatives and public comments,
MDE concurs with the Selected Remedies.
2 BACKGROUND ON COMMUNITY INVOLVEMENT
APG has maintained an active public involvement and information program for the IRP
since the early 1990s. APG's specific community relations activities for BRSA OU3 are
discussed below:
• The status of the BRSA Sites was briefed to the RAB in July 2005, June 2006, July
2007, May 2008, August 2009, September 2010, January 2012, and January 2013.
• APG released the OU3 Proposed Plan for public comment on July 17, 2013. Copies
were available to the public through APG's administrative record locations at the
Edgewood and Aberdeen branches of Harford County Library and Miller Library at
Washington College in Kent County.
• APG prepared a release announcing the availability of the Proposed Plan, the dates of
the public comment period, and the date and time of the public meeting. APG placed
newspaper advertisements announcing the public comment period and meeting in The
Aegis and The Cecil Whig on July 17, 2013; and, The Avenue News, East County
Times, and Kent County News on July 18, 2013. A sample newspaper advertisement
announcing the public comment period and the public meeting is provided as Figure
10.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 50
Figure 10. Sample Newspaper Advertisement
U.S. ARMY INVITES PUBLIC COMMENT
ON PROPOSED PLAN FOR THE
BUSH RIVER STUDY AREA
OPERABLE UNIT 3 - SURFACE UNITS
The U.S. Army at Aberdeen Proving Ground (APG) invites the public to comment on its
Proposed Plan for the Bush River Study Area Operable Unit 3 - Surface Units.
FACT SHEET
APG lias prepared a fact sheet on the proposed,
plan which includes a comment form that can be
returned to APG.
If you are not on APG's mailing list, you
can request a copy of the fact sheet by calling
APG's 24-hour Environmental Information
Line at (410) 272-8842 or (800) APG-9998.
PUBLIC MEETING
APG invites the public to attend a meeting on:
DATE: Thursday, July 25,2013
TIME: 6:30 p.m. - informal poster/
information session
7:15 p.m. - presentation
PLACE: Raraada Conference Center
1700 Van Bibber Road
Edgewood, MD 21040
The meeting location is wheelchair accessible,
and an interpreter for the hearing impaired is
available with 72-hours advance notice (call
800-APG-9998),
WRITTEN COMMENTS
The 30-dav public comment period on the
proposed action extends from July 17 through
August 16, 2013. Written comments, postmarked
by August 16, 2013, should be sent to:
Mr. Rurik Loder
Project Officer/IRP Team Leader
Directorate of Public Works
Environmental Division
ATTN: IMAP-PWE
Aberdeen Proving Ground. MD 21010; or
Ms. Yazmitic Yap-Deffler
U.S. Environmental Protection Agency,
Region III,
Hazardous Site Cleanup Division
1650 Arch Street
Philadelphia, PA 19103-2029; or
Ms. Linda Gustafson
Maryland Department of the Environment
Land Restoration Program
Federal Facilities Division
1800 Washington Boulevard, Suite 625
Baltimore, MD 21230
PROPOSED ACTION
APG has prepared a Proposed Plan to address surface media (i.e.. waste material and soil)
within the Bush River Study Area (BRSA) Operable Unit (OU) 3 Surface Units. The OU3
area is comprised of the 22nd Street Landfill, Building E2364 Underground Storage Tank
(UST) Site, Adamsite Storage Vault, and Former Radioactive Material Disposal. Facility.
22nd STREET LANDFILL
No Action. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP)
requires consideration of "No Action" as a baseline with which to compare other alternatives.
Under tins alternative, no remedial efforts would be made to control risk; treat or contain
source materials; or reduce toxicity, mobility, or volume of contaminated media. Site-specific
land use controls (LUCs) would not be implemented. Cost: $0
Maintenance of Existing Improvements with LUCs and Monitoring. The site
improvements implemented at 22nd Street Landfill during the 2012 Time Critical Removal
Action (TCRA) would continue to be maintained and monitored as part of this alternative.
Periodic inspections would be conducted to verify that the amended soil cover and shoreline
stabilization structures remain in place and protective of human health and the environment.
Periodic sampling of groundwater, surface water, and sediment would be accomplished to
verify the long-term effectiveness of the remedy. LUCs preventing residential land uses were
implemented for the entire BRSA under a previous Record of Decision (ROD) for OU2.B.
Additional site-specific LUCs would be implemented to prevent groundwater use and prevent
disturbance of the cover and subsurface waste. Five-year remedy reviews would also be
accomplished as required by the NCP. Cost: $1,329,700
Low Permeability Cap with Wetland Mitigation, LUCs, Site Maintenance, and
Monitoring. This alternative would involve the construction of a low-permeability cap. To
achieve adequate sloping and drainage, the footprint of the low permeability cover would be
substantially larger than the existing soil cover. Site inspections would verify that the
integrity of the cap remains intact and protective of human health and the environment.
Periodic sampling of groundwater, surface water, and sediment would be accomplished to
verify the long-term effectiveness of the remedy. LUCs preventing residential land uses were
implemented for the entire BRS A under a previous ROD for OU2B. Additional site-specific
LUCs would be implemented to prevent groundwater use and prevent disturbance of the cap
and subsurface waste. Five-year remedy reviews would also be accomplished as required by
the NCP. Cost: 516,211,200
Based on analysis of the alternatives, APG prefers Maintenance of Existing
Improvements with LUCs and Monitoring.
REMAINING OU3 SITES
The Rad Yard, Building E2364 UST Site, and Former Adamsite Storage Vault have been
addressed by previous removal actions. These sites do not present any unacceptable risks to
human health under the current industrial use or to ecological receptors. However, these sites
are not suitable for unlimited use or unrestricted exposure. Since LUCs prohibiting family
housing, elementary and secondary schools, child care facilities, playgrounds, and other
residential land use were implemented for the entire BRSA under a previous ROD for OIJ2B,
No Further Action is proposed for these sites.
The preferred alternative may be modified or new alternatives may be developed based on
public input. The final alternatives selected will be documented in a ROD that summarizes the
decision-making process. APG will summarize and respond to comments received during the
comment period as part of the ROD. Copies of the Feasibility Study and the Proposed Plan
are available for review at the APG information repositories. The repositories are located at
Hie Edgewood (410-612-1600) and Aberdeen (410-273-5608) branches of the Harford County
Library and Miller Library at Washington College in Kent County (410-778-7292).
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 51
• APG prepared and published a fact sheet on the Proposed Plan including information
on the public meeting. APG mailed copies of this fact sheet to approximately 1,985
citizens and elected officials on its IRP mailing list on July 17, 2013. The fact sheet
included a form, for citizens to use to send APG their comments.
• The 30-day public comment period on the Proposed Plan ran from July 17, 2013
through August 16, 2013.
• On July 25, 2013, APG held a public meeting at the Ramada Conference Center in
Edgewood, Maryland. Representatives of the Army, USEPA, and MDE were present
at the meeting. APG representatives presented information on the sites and on the
proposed response actions.
3 SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND AGENCY RESPONSES
Comments raised during the public comment period are summarized below. The
comments are categorized by source.
COMMENTS FROM QUESTIONNAIRE INCLUDED WITH FACT SHEET
As part of its fact sheet on the Proposed Plan, APG included a questionnaire that
residents could return with their comments. APG received 6 forms; 3 forms had
comments. The alternatives preferred by individuals returning comment forms were:
ALTERNATIVES FOR 22nd STREET LANDFILL
1 No opinion
1 1. Take No Action
3 2. Maintenance of Existing Improvements with LUCs and Monitoring
1 3. Low-Permeability Cap with Wetland Mitigation, LUCs, Site Maintenance,
and Monitoring
Written comments included on the forms are summarized below.
Comment #1: If continued monitoring indicates a change in previously
determined concentration location either upstream or
downstream, then other measures may need to be considered.
Response: The protectiveness and effectiveness of the remedy will be
evaluated annually in long-term monitoring reports and every five
years during the CERCLA remedy reviews. The Army and EPA,
in consultation with MDE, will determine whether additional
remedial measures will be required.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 52
Comment #2:
Response:
Comment #3:
Response:
What were the findings of all the comprehensive environmental
studies? This site is located in a very dangerous area! Clean it
up and cap it.
Detailed results from the environmental studies are provided in the
Supplemental RI and FS reports for OU3, which are available in
the Administrative Record. The results of these studies
(summarized in Sections 5.4 and 7 of this ROD) do not indicate
any unacceptable risks from exposure to the environmental media
at the site under a military/industrial land use scenario or to
environmental receptors. Residential land uses have already been
prohibited by the LUCs implemented under the 2010 ROD for
OU2B. The objective of the remedial action required under this
ROD is to ensure that any potential risk posed by buried waste is
mitigated through maintenance of the existing cover and the
implementation of restrictions on digging and prohibition on
groundwater use in the area of the 22nd Street Landfill.
In 2012, improvements were made to the existing soil cover to
prevent erosion and minimize exposure. Since much of the waste
is located within the water table, the soil cover provides the same
level of protectiveness as a low-permeability cap.
Dear Friends, My property almost joins your property at E.
Michaelsville Road...I know nothing about the above Landfill so
I cannot give you my opinion... [personal information omitted].
Thank you for your interest in the APGIRP.
COMMENTS FROM PUBLIC MEETING
No written comments were submitted at the public meeting.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 53
PART 4: REFERENCES
Foster Wheeler, 1997. Final Technical Report for the Adamsite Storage Vaults Storage
Vaults Removal Action, Edgewood Area, Aberdeen Proving Ground, MD.
Prepared for APG, Directorate of Safety, Health and Environment. January 1997.
General Physics Corporation (GP), 2002. Southern Bush River Remedial Investigation
Report, Bush River Study Area. Prepared for APG, Directorate of Safety, Health
and Environment. December 2002.
GP, 2004a. Human Health Radiological Risk Assessment, Radioactive Waste
Management Facility, Bush River Study Area, Aberdeen Proving Ground,
Maryland. Prepared for APG, Directorate of Safety, Health and Environment.
January 2004.
GP, 2004b. Southern Bush River Focused Feasibility Study Data Report, Operable Unit 3
- Ton-Container Steamout Site, Bush River Radioactive Material Disposal
Facility, 22nd Street Landfill and Northern Groundwater Plume, Southern Bush
River, Bush River Study Area. Prepared for APG, Directorate of Safety, Health
and Environment. February 2004.
GP, 2010. Supplemental Remedial Investigation (SRI) Report, Operable Unit 3 Surface
Units, Bush River Study Area. Prepared for APG, Directorate of Public Works,
Environmental Division. August 2010.
GP, 2011. Work Plan for Field Activities at the Former Rad Yard and 26th Street Drum
Dump. Prepared for APG, Directorate of Public Works, Environmental Division.
November 2011 (Page Revisions, January 2012).
GP Strategies Corporation (GP), 2012. Supplemental Remedial Investigation Report,
Southern Bush River Surficial Aquifer Operable Unit 3 (EABR11-C, -D, -E, -F, -
G, -H, -I), Bush River Study Area. Prepared for APG, Directorate of Public
Works, Environmental Division. September 2012.
GP, 2013a. Completion Report for the Time Critical Removal Action (TCRA) at 22nd
Street Landfill, Bush River Study Area. Prepared for APG, Directorate of Public
Works, Environmental Division. February 2013.
GP, 2013b. Feasibility Study Report, Operable Unit 3 Surface Units Bush River Study
Area, Aberdeen Proving Ground, Maryland. Prepared for Aberdeen Proving
Ground, Maryland. June 2013.
ICF Kaiser Engineers (ICF). 1997. Baseline Risk Assessment for Southern Bush River
Area, Aberdeen Proving Ground, Maryland. Abingdon, MD. Prepared for the
Directorate of Safety, Health and Environment, Aberdeen Proving Ground,
Maryland.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 54
U.S. Army. 2010. Record of Decision, Remedial Action at the Bush River Study Area,
Operable Unit 2B, Kings Creek Chemical Disposal Site (EABR15-A) and 30th
Street Landfill (EABR15-B). Environmental Division, Directorate of Public
Works, U.S. Army Garrison Aberdeen Proving Ground, Edgewood, MD.
U.S. Army Environmental Center (USAEC). 1998. U.S. Army Restoration Advisory
Board and Technical Assistance for Public Participation Guidance. April 1998.
U.S. Army Environmental Hygiene Agency (USAEHA). 1989. Resource Conservation
and Recovery Act Facility Assessment for the Edgewood Area of Aberdeen
Proving Ground, Maryland. Report No. 39-26-0490-90. Aberdeen Proving
Ground, MD: U.S. Department of the Army.
U.S. Army Toxic and Hazardous Materials Agency (USATHAMA). 1983.
Environmental Survey of the Edgewood Area of Aberdeen Proving Ground. U.S.
Army Toxic and Hazardous Materials Agency. Aberdeen Proving Ground, MD.
USEPA Region III, APG, and U.S. Department of the Army. 1990. Federal Facility
Agreement under CERCLA Section 120, Aberdeen Proving Ground, Maryland.
Administrative Docket Number III-FCA-CERC-004. USEPA Region III and U.S.
Department of the Army.
U.S. Environmental Protection Agency (USEPA), 1991. Role of Baseline Risk
Assessment in SuperfundRemedy Selection Decisions. OSWER Directive 9355.0-
30 Memo from Don R. Clay. Washington, DC: Office of Solid Waste and
Emergency Response (OSWER).
USEPA, 1993. Presumptive Remedy for CERCLA Municipal Landfill Sites. EPA/540/F-
93-035, Directive 9355.0-49FS. OSWER.
USEPA, 1996. Application of the CERCLA Municipal Landfill Presumptive Remedy to
Military Landfills. EPA/540/F-96-020, Directive 9355.0-67FS. OSWER.
USEPA, 1999. A Guide to Preparing Superfund Proposed Plans, Records of Decision,
and Other Remedy Selection Decision Documents. EPA 540-R-98-031.
USEPA, 2000. A Guide to Developing and Documenting Cost Estimates During the
Feasibility Study. EPA 540-R-00-002.
USEPA, 2011. Toolkit for Preparing CERCLA Records of Decision. Prepared by
USEPA with collaboration with the Department of the Navy. OSWER 9355.6-10.
Weston Solutions, Inc. (Weston), 2002. After Actions Report for Time Critical Removal
Action, Bush River Area, 22nd Street Landfill, Edgewood Area, Aberdeen Proving
Ground, Maryland. Prepared for Aberdeen Proving Ground, Maryland.
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Record of Decision
Bush River Study Area Operable Unit 3
Aberdeen Proving Ground, Maryland
Final
September 2013
Page 55
-. 2007. Removal Action Report for Non-Time Critical Removal Action,
Radioactive Waste Management Facility, Bush River Study Area, Aberdeen
Proving Ground, Maryland. Prepared for Aberdeen Proving Ground, Maryland.
-. 2008. Final Status Survey Report, Radioactive Waste Management Facility,
Bush River Study Area, Edgewood Area, Aberdeen Proving Ground, Maryland.
Prepared for Aberdeen Proving Ground, Maryland.
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Record of Decision Final
Bush River Study Area Operable Unit 3 September 2013
Aberdeen Proving Ground, Maryland Page 56
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ATTACHMENT A
REQUEST FOR VARIANCE FROM COMAR 26.04.07.21
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REPLY TO
ATTENTION OF
DEPARTMENT OF THE ARMY
US ARMY INSTALLATION MANAGEMENT COMMAND
US ARMY GARRISON ABERDEEN PROVING GROUND
4510 BOOTHBY HILL AVENUE
ABERDEEN PROVING GROUND MARYLAND 21009-5001
22 February 2013
Directorate of Public Works
Ms. Linda Gustafson
State of Maryland Department of the Environment
Federal Facilities Division, Hazardous Waste Program
1800 Washington Boulevard, Suite 625
Baltimore, Maryland 21230
Dear Ms. Gustafson:
The U.S. Army hereby requests a variance from the requirements of the Code of Maryland
Regulations (COMAR) 26.04.07.21, which governs the closure of landfills, with respect to the
22nd Street Landfill in the Bush River Study Area (BRSA) of the U.S. Army Garrison Aberdeen
Proving Ground (APG). This request is made as part of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) remedy decision-making process on the
basis that the existing soil cover is as protective as a full Resource Conservation and Recovery
Act (RCRA)-compliant cap for this site.
The 22nd Street Landfill is a 10.4-acre landfill that was created by the disposal of solid waste,
primarily sanitary and demolition debris, into a tidal wetland. The landfill was active from
approximately 1964 to 1970, based on historic aerial photographs. The location of the 22nd
Street Landfill within the BRSA is shown on Figures 1 and 2. Geophysical survey results are
displayed with respect to the location of the original tidal wetland and shoreline, approximated
from a 1961 aerial photograph, on Figures 3 and 4. Currently, the site is an open, grass- and
marsh-covered area, with drainage streams flowing along the northern boundary and through the
central portion of the landfill (Figure 5). No unacceptable risks were identified for either human
(industrial) or ecological exposure to the original landfill cover soil. The landfill is not releasing
constituents of concern to groundwater or surface water at levels that pose a risk to the
environment.
On 29 November 2011, the Army met with representatives from the Maryland Department of
the Environment (MDE) to discuss the 22nd Street Landfill. Based on this meeting, MDE agreed
that action should be taken to minimize the potential for shoreline erosion and exposure of buried
waste within 22nd Street Landfill. A Time Critical Removal Action (TCRA) was initiated in
April 2012 and completed in August 2012. The shoreline along the 22nd Street Landfill was
stabilized to prevent erosion and exposure of waste into the Bush River. Improvements to the
existing soil cover were made in the upland portions of 22nd Street Landfill (i.e., western and
southern portions of the site). To the extent practicable, the existing soil cover was amended to
increase cover thickness in areas where it was thin (i.e., areas with less than 24 inches of cover),
DISTRIBUTION RESTRICTION STATEMENT:
APPROVED FOR PUBLIC RELEASE
DISTRIBUTION IS UNLIMITED #11341-A-7
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thereby enhancing effectiveness of the containment. The existing vegetative cover in the large
tidal wetland adjacent to Bush River (i.e., northeastern portion of the site) was left undisturbed.
As discussed in the Feasibility Study, construction of a RCRA-compliant cap (or full-scale
excavation) within the confines of the tidal wetland would be extremely difficult to implement.
Substantial stream diversion and dewatering would be required, along with extensive soil
stabilization to ensure that the foundation under the cap was firm enough for construction. It is
also likely that several transecting access roads would be required for the construction equipment
to reach the far limits of the marsh.
The purpose of a cap or cover over a landfill is to: i) contain the waste; ii) minimize
exposure on the surface; iii) inhibit vertical infiltration of water into wastes that would generate
leachate; iv) manage gas emissions; and, v) generate a soil surface that can maintain vegetation
and/or be used for further purposes. At this site, the construction of a full RCRA-compliant cap
would not reduce the production of leachate or improve water quality since the waste is
predominantly below the water table. There are also no measureable gas emissions to manage.
Construction of a RCRA-compliant cap would also result in a comparatively greater risk to
human health and the environment. The drainage basin from which runoff flows through the site
encompasses approximately 68 acres. To accommodate the new drainage patterns required to
achieve the specified cover thickness and slope for a full RCRA-compliant cap, the area of
disturbance could exceed 21 acres. The resulting impact includes the destruction of
approximately 7.1 acres of forest, 2.8 acres of tidal wetland, and 1.6 acres of non-tidal wetland
(Figure 6), primarily within the Chesapeake Bay Critical Area.
The CERCLA remedy proposed for the 22nd Street Landfill involves continued maintenance
of the TCRA site improvements (i.e., amended soil cover and shoreline stabilization structures,
shown on Figure 5), land-use controls, five-year remedy reviews, and monitoring. This
proposed remedy would achieve the remedial action objectives (RAOs) specified in the
Feasibility Study, i) preventing inadvertent excavation into the 22nd Street Landfill that would
result in direct exposure to landfilled waste; and ii) prohibiting land use that would result in
unacceptable risks to residential receptors through exposure to site-related contaminants. Since
reducing leachate and managing gas emissions are not relevant to the 22nd Street Landfill site, the
amended soil cover and shoreline stabilization structures constructed under the TCRA, along
with land-use controls, will contain the waste and minimize exposure to the same extent as a
RCRA-compliant cap.
An area-wide land-use control, implemented in response to the Record of Decision for
Operable Unit 2B [Kings Creek Chemical Disposal Site (EABR15-A) and 30th Street Landfill
(EABR15-B)], prohibits the use of the entire BRSA, including 22nd Street Landfill, for family
housing, elementary and secondary schools, child care facilities, playgrounds, and other
residential land use. Additional site-specific land-use controls would be implemented to prohibit
the use of groundwater within 500 feet of 22nd Street Landfill and to prevent soil excavation or
other activities that could result in the exposure of receptors to subsurface waste materials.
Monitoring of site conditions would verify that the remedy remains effective and protective
of human health and the environment. The soil cover and shoreline structures would be
-------
inspected on a semi-annual basis, with repairs and maintenance conducted as needed. Sampling
of surface water, sediment, and groundwater would be conducted on a semi-annual basis for the
first five years, with a potential for ramp-down after the first CERCLA five-year review. The
details for long-term monitoring would be further developed in the Remedial Design.
The Feasibility Study (Revised Draft, February 2013) and Supplemental Remedial
Investigation Report (Final, August 2010) provide additional supporting information for your
review and consideration. Should you have any additional questions, comments or concerns,
please contact Mr. Rurik Loder, Environmental Division, at 410-436-7313.
Enclosures
Copy Furnished:
Yazmine Yap-Deffler, EPA Region III
Rurik Loder, APG DPW
Francis Dunkerly, GP Strategies Corporation
Sincerely,
VANCE G. HOBBS
Acting Environmental Division Chief
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TCRA SITE
IMPROVEMENTS
CARTOGRAPHER:
B. JOYCE
APPROVED BY:
J. HARRIS
DATE:
FIGURE:
4 JAN 2013
Universal Transverse Mercator Projection - Zone 18, Geodetic Datum: North American 1983, WGS84 Ellipsoid, Measured in Survey Feet
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A
A
V
0*
LEGEND
~ Structure
Road
Proposed Impermeable
Cover Footprint
i Water
' 1 Gravel Path
Intermittent Stream, Drainage Ditch
CZX3 Forested Area
I I Tidal Wetland
i Non-Tidal Wetland
Existing Topography to Ftemain
Proposed Topography to Cut or Fill
Unaffected Area 100'from Tidal
Area of proposed cap footprint
21.59 acres
Forested area within footprint
7.09 acres
"Tidal wetlands within footprint
2.84 acres
Non-tidal wetlands within footprint
1.60 acres
500 Edgewood Road, Suite 110
Edgewood, MD 21040
(410) 676-8835
www.gpworidwide.com
Leading the world
Universal Trans^rae Mercator Projection -
TO~
Zona IB, Geodetic Datum: North American 1333 WGSB4 Ellipsoid, Measued In Survey Feet
T3~
to better performance
GENERAL PHYSICS
TITLE:
ENVIRONMENTAL
IMPACTS
ASSOCIATED
WITH IMPERMEABLE
COVER
CARTOGFiAPHER:
B. JOYCE
DATE:
03-01-2011
APPROVED BY:
J. HARRIS
FIGURE:
I'•* \ Edge wo o d Gra ph ics \ GEOGRA PHICS \ BRSA \0U3\ Prop ose d Scen a rios \4\ Seen ari o 4 Im pact 11x17. dgn
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MDE
MARYLAND DEPARTMENT OF THE ENVIRONMENT
1800 Washington Boulevard • Baltimore MD 21230
410-537-3000 • 1-800-633-6101* www.mde.state.md.us
Martin O'Malley
Governor
Anthony G. Brown
Lieutenant Governor
September 23,2013
USAGAPG/Department of the Army
IMAP/PWE Mr. Rurik Loder
4304 Susquehanna Ave.
3rd Floor, Wing B
APG, MD 21005-5001
RE: Request for variance from COMAR 26.04.07.21, letter dated 23 February 2013
Dear Mr. Loder:
The Federal Facilities Division (FFD) of the Maryland Department of the Environment's
(MDE) Land Restoration Program has completed its review of the referenced communication.
This letter describes the Army's proposed final remedy for the 22nd Street Landfill in the Bush
River Study Area, which is a former disposal area. The selected final remedy is Maintenance of
Existing Improvements with Land Use Controls and Monitoring. The Army is conducting this
action in compliance with the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA).
The selected remedy requires a variance to the State's landfill closure regulations for
landfills, which are Applicable or Relevant and Appropriate Requirements under CERCLA. The
FFD in consultation with MDE's Solid Waste Program has reviewed the selected remedy and the
requested variance. If maintained and monitored adequately, the proposed remedy should be as
protective as the State's landfill closure regulations, which are stated in Code of Maryland
Regulations (COMAR) 26.04.07.21. Consequently, in accordance with the variance provision
contained in COMAR 26.04.07.26, the Army's request for a variance is considered favorably
because the following conditions are adequately addressed in the Record of Decision for this site:
i. Land use controls ensure that future land use does not include residential use and
that excavation and other activities that may result in contact with subsurface
materials are restricted.
ii. Long-term maintenance activities protect the integrity of existing cover material
and shoreline erosion control measures with monitoring adequate to meet the
needs of the FFD.
iii. Long-term monitoring of ground water, surface water, and sediment will be
conducted to detect releases to Bush River. This monitoring program must meet
Robert M. Summers, Ph.D.
Secretary
Recycled Paper
www. mde.state.md.us
TTY Users 1-800-735-2258
Via Maryland Relay Service
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Mr. Rurik Loder
Page 2
the needs of the FFD in evaluating the adequacy of the remedy and the continued
use of the variance provision contained in COMAR.
If you have any questions, please contact me at (410) 537-4238.
Sincerely,
Remedial Project Manager
Federal Facilities Division
LG:lg
cc: Ms. Yazmine Yap-Deffler
Mr. Horacio Tablada
Mr. James Carroll
Recycled Paper
www.mde.state.md.us
TTY Users 1-800-735-2258
Via Maryland Relay Service
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ATTACHMENT B
MEMORANDUM IMPLEMENTING BRSA-WIDE LAND USE
CONTROLS AND ENVIRONMENTAL OVERLAY
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This page was intentionally left blank.
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REPLY TO
ATTENTION OF
DEPARTMENT OF THE ARMY
US ARMY INSTALLATION MANAGEMENT COMMAND
US ARMY GARRISON ABERDEEN PROVING GROUND
2201 ABERDEEN BOULEVARD
ABERDEEN PROVING GROUND, MARYLAND 21005-5001
IMNE-APG-PWE
18 April 2011
MEMORANDUM FOR Directorate of Public Works,
ATTN: IMNE-APG-PWM (Robert Melascaglia)
SUBJECT: Implementation of Land Use Controls Required by CERCLA Record of Decision
for the Bush River Area
1. A Record of Decision (ROD), signed July 1, 2010, established a requirement for land use
controls in the Bush River Area of the Aberdeen Proving Ground. The land use controls prohibit
residential use of the Bush River peninsula and soil excavation and vegetation and shoreline
stabilization structure disturbance in the Kings Creek/30,h Street area. Details concerning the
land use controls are contained in the remedial design, approved March 29, 2011. For your
convenience, copies of the record of decision and remedial design are provided in electronic
format on the enclosed CD. The Environmental Division respectfully requests that the Planning
Office implement the land use controls, as required by the ROD.
2. The attached environmental overlay identifies the location and dimensions of the land use
controls. The enclosed CD contains a GIS file in DGN format that portrays the land use controls.
3. In addition, the remedial design requires the recording of a survey plat incorporating these
land use control objectives for the limited purpose of providing public notice of the
environmental conditions and limitations on the use of the property. The plat shall also be placed
in the Information Repository for CERCLA actions. The documentation associated with
recording the survey plat should be staffed through the Environmental Division and the APG
Legal Office.
4. Please notify the Chief of the Environmental Division in writing upon initiation, and again
upon completion, of the actions necessary to implement these land use controls.
5. Please direct questions, comments, and notifications to my point of contact,
Mr. Rurik Loder at 5-7313.
Encl
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1 I 2 I 3 I 4 I 5 I 6 I 7
1 | 3 | 3 | 4 | 5 | $ | 7
LAND USE CONTROLS
SOIL EXCAVATION RESTRICTION
This LUC prohibits any excavation and other activities within 0U2B that could result in
exposure of receptors to subsurface materials that potentially contain hazardous
constituents. This LUC also prevents disturbance of the existing shoreline stabilization
structures and the existing vegetative cover, thereby maintaining remedy effectiveness
into the future. This area is defined by the coordinates:
© N1280165.70, ~4308734.46 © N1281075.24, E14308922.75
© N1280471.30, E14309050.60 (?) N1281115.00, E143083B3.00
© N1280550.27, E14308880.00 ® N1280840.00, E14308263.00
© N1280782.55, ~4308867.00 © N1280805.08, ~4308104.77
The area is further defined by a line 50 feet from the shore of Kings Creek between
points 1 and B.
RESIDENTIAL USE RESTRICTION
1200 900 600 300 0 600 1200 2400
GRAPHICAL SCALE
IN FEET (1" = 1200') 1:14400
LEGEND
Water Tidal Wetland
Road Non-tidal Wetland
Leading the world to better performance
J 500 Edgewood Rd, Suite 110 (410) 676-8835
iiii*~^ Edpewood, MD 21040 www.qpworldwide.com
This LUC prohibits future family housing, elementary and secondaiy schools, child care
facilities, playgrounds and cither residential use within the Bush River Area. The area is
defined by coordinates:
© N1277542,07, E14312278.80 © N1277310.23, E14311281.12
© N1278454.27, E14312074.80 ( 6) N1277270.92, E143111TI.94
© N1275918.43, E14312068.45 (7) W1277363.91, E14310601.28
© N1275815.90, E14311340.70 ® NI277774.87, E14310064.53
The area is further defined by the Bush River Area shorelines along Lauderid< Creek,
Bush River, and Kings Creek between points 1 and 8.
TITLE:
BUSH RIVER OU2B
ENVIRONMENTAL OVERLAY
FOR LAND USE CONTROLS
CARTOGRAPHER:
B. JOYCE
APPROVED BY:
F. DUNKERLY
DATE:
07 14 10
FIGURE:
1
i:\Edgewood Graphics\GEOGRAPHICS\Bush River\0U2B Env Ov\LUC.dgn
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