DRAFT FEASIBILITY STUDY - RVAAP · Draft Feasibility Study for Erie Burning Grounds ... CTT closed, transferring, and ... NCP National Contingency Plan

DRAFT

FEASIBILITY STUDY for Erie Burning Grounds

(RVAAP-02)

Ravenna Army Ammunition Plant Ravenna, Ohio

March 2006

Contract No. GS-10F-0076J

Delivery Order No. W912QR-05-F-0033

Prepared for: U.S. Army Corps of Engineers

Louisville, Kentucky

Prepared by: Science Applications International Corporation

8866 Commons Boulevard, Suite 201 Twinsburg, Ohio 44087

ALouisville District

Draft Feasibility Study for Erie Burning Grounds

(RVAAP-02)

Ravenna Army Ammunition Plant Ravenna, Ohio

March 2006

Contract No. GS-10F-0076J Delivery Order No. W912QR-05-F-0033

Prepared for: U.S. Army Corps of Engineers

Louisville, Kentucky

Prepared by: Science Applications International Corporation

8866 Commons Boulevard, Suite 201 Twinsburg, Ohio 44087 1700.20060331.002

Draft Feasibility Study for Erie Burning Grounds

(RVAAP-02) Ravenna Army Ammunition Plant

Ravenna, Ohio

March 2006 Contract No. GS-10F-0076J

Delivery Order No. W912QR-05-F-0033

RVAAP 6 High Priority AOCs EBG Feasibility Study Page i Draft March 2006

TABLE OF CONTENTS 1 2

LIST OF TABLES ................................................................................................................................iii 3 LIST OF FIGURES...............................................................................................................................iii 4 LIST OF PHOTOGRAPHS ..................................................................................................................iii 5 LIST OF APPENDICES .......................................................................................................................iv 6 LIST OF ACRONYMS..........................................................................................................................v 7 8 EXECUTIVE SUMMARY............................................................................................................ES-1 9 10 1.0 INTRODUCTION .......................................................................................................................1-1 11

1.1 PURPOSE .................................................................................................................................1-1 12 1.2 SCOPE.......................................................................................................................................1-2 13 1.3 REPORT ORGANIZATION ....................................................................................................1-3 14

15 2.0 BACKGROUND INFORMATION ...........................................................................................2-1 16

2.1 FACILITY-WIDE BACKGROUND INFORMATION ...........................................................2-1 17 2.1.1 General Site Description.....................................................................................................2-1 18 2.1.2 Demography and Land Use ................................................................................................2-2 19 2.1.3 RVAAP/RTLS Physiographic Setting................................................................................2-3 20

2.2 ERIE BURNING GROUNDS...................................................................................................2-3 21 2.2.1 Site History.........................................................................................................................2-3 22 2.2.2 Site and Surface Features ...................................................................................................2-4 23 2.2.3 Previous Investigations.......................................................................................................2-5 24 2.2.4 Nature and Extent ...............................................................................................................2-6 25 2.2.5 Fate and Transport Analysis ...............................................................................................2-8 26 2.2.6 Human Health Risk Assessment ........................................................................................2-8 27 2.2.7 Ecological Risk Assessment.............................................................................................2-10 28

2.3 RISK CHARACTERIZATION FOR TRESPASSER SCENARIO........................................2-14 29 30 3.0 REMEDIAL ACTION OBJECTIVES......................................................................................3-1 31

3.1 REMEDIAL ACTION OBJECTIVES......................................................................................3-1 32 3.2 ANTICIPATED FUTURE LAND USE....................................................................................3-3 33 3.3 HUMAN HEALTH PRELIMINARY CLEANUP GOALS .....................................................3-3 34

3.3.1 Land Use and Potential Receptors at EBG.........................................................................3-5 35 3.3.2 Chemicals of Concern ........................................................................................................3-7 36 3.3.3 Target Risk for Preliminary Cleanup Goals .......................................................................3-8 37 3.3.4 Preliminary Cleanup Goals.................................................................................................3-9 38 3.3.5 Risk Management Considerations ....................................................................................3-12 39

3.4 ECOLOGICAL PROTECTION..............................................................................................3-15 40 3.4.1 Ecological Preliminary Cleanup Goals for EBG..............................................................3-16 41 3.4.2 Ecological Cleanup Goal Development Weight of Evidence...........................................3-16 42

43 44 45

RVAAP 6 High Priority AOCs EBG Feasibility Study Page ii Draft March 2006

3.5 FATE AND TRANSPORT ASSESSMENT OF COCS IN SOILS........................................3-24 1 3.5.1 Refined Chemical Impacts to Groundwater Assessment..................................................3-25 2 3.5.2 Refined AOC-Specific Modeling Results ........................................................................3-25 3

3.6 COCS FOR REMEDIAL ALTERNATIVE EVALUATION AT EBG .................................3-25 4 5 4.0 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS......................4-1 6

4.1 INTRODUCTION.....................................................................................................................4-1 7 4.2 POTENTIAL ARARS FOR EBG .............................................................................................4-3 8

4.2.1 Potential Soil ARARs for RCRA Hazardous Waste ..........................................................4-4 9 4.2.2 Potential Location ARARs for Solid Wastes, RCRA Hazardous Wastes, 10

Construction and Demolition Debris Wastes or Clean Fill .................................................4-8 11 12 5.0 AGENCY COORDINATION AND PUBLIC INVOLVEMENT ...........................................5-1 13

5.1 STATE ACCEPTANCE ...........................................................................................................5-1 14 5.2 COMMUNITY ACCEPTANCE...............................................................................................5-1 15

16 6.0 CONCLUSIONS AND RECOMMENDATIONS ....................................................................6-1 17 18 7.0 REFERENCES ............................................................................................................................7-1 19

20

21

RVAAP 6 High Priority AOCs EBG Feasibility Study Page iii Draft March 2006

LIST OF TABLES 1 2 Table ES-1. Land Use Scenarios Assessed in the EBG FS ............................................................. ES-2 3 Table ES-2. Summary of COCs and Preliminary Cleanup Goals for Evaluation 4

of Remedial Alternatives in this FS for EBG..............................................................ES-2 5 Table 2-1. Summary of HHRA Risk Results for Direct Contact at the Erie Burning Ground......2-10 6 Table 3-1. Land Use Scenarios Assessed at EBG ...........................................................................3-2 7 Table 3-2. Soil Preliminary Cleanup Goals for Resident Subsistence Farmer Scenario at EBG ....3-9 8 Table 3-3. Surface Water Preliminary Cleanup Goals for Fire/Dust Suppression Worker 9

at EBG..........................................................................................................................3-10 10 Table 3-4. Surface Water Preliminary Cleanup Goals for Resident Subsistence Farmer 11

Scenario at EBG...........................................................................................................3-10 12 Table 3-5. Sediment Preliminary Cleanup Goals for Resident Subsistence Farmer Scenario 13

at EBG..........................................................................................................................3-11 14 Table 3-6. Groundwater Preliminary Cleanup Goals for Resident Subsistence Farmer 15

Scenario at EBG...........................................................................................................3-11 16 Table 3-7. Soil and Sediment COCs for Evaluation of Remedial Alternatives for 17

Unrestricted Land Use at EBG.....................................................................................3-13 18 Table 3-8. Surface Water and Groundwater COCs for Remedial Alternatives for 19

Representative Receptor (Fire/Dust Suppression Worker) and Unrestricted Land 20 Use at EBG...................................................................................................................3-14 21

Table 3-9. Summary of COCs and Preliminary Cleanup Goals for Evaluation of Remedial 22 Alternatives for EBG....................................................................................................3-15 23

Table 3-10. Distribution of COPECs in Environmental Media at EBG..........................................3-21 24 25 Table 3-11. Summary of COCs at EBG ..........................................................................................3-26 26 Table 4-1. Potential Action ARARs for Disposal of RCRA Hazardous Waste ..............................4-6 27

28

LIST OF FIGURES 29 30

Figure 2-1. General Location and Orientation of RVAAP/RTLS....................................................2-16 31 Figure 2-2. RVAAP/RTLS Installation Map....................................................................................2-18 32 Figure 2-3. Site Features of EBG .....................................................................................................2-19 33 Figure 2-4. Sample and Monitoring Well Locations at EBG ...........................................................2-20 34

35 36

LIST OF PHOTOGRAPHS 37 38

Photograph 2-1. Site Conditions at EBG, September 2005................................................................2-5 39 40 41

RVAAP 6 High Priority AOCs EBG Feasibility Study Page iv Draft March 2006

LIST OF APPENDICES 1 2

Appendix 2A. Risk Characterization for Trespasser (Adult and Juvenile) Scenario 3 Appendix 3A. Fate and Transport of COCs in Soil 4 Appendix 5A. Technology Types and Process Options ~ Aqueous Media 5

RVAAP 6 High Priority AOCs EBG Feasibility Study Page v Draft March 2006

LIST OF ACRONYMS 1

ALM Adult Lead Model amsl above mean sea level AOC Area of Concern ARAR Applicable and Relevant or Appropriate Requirements AT123D Analytical Transient 1-, 2-, 3-Dimensional BERA Baseline Ecological Risk Assessment bgs below ground surface BRAC Base Realignment and Closure CAMU Corrective Action Management Unit CBP Central Burn Pits CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CMCOC contaminant migration chemical of concern CMCOPC contaminant migration chemical of potential concern COC chemical of concern COEC chemicals of ecological concern COPC chemical of potential concern COPEC chemical of potential ecological concern cPAH Carcinogenic polycyclic aromatic hydrocarbon CSF Cancer slope factor CSM conceptual site model CTT closed, transferring, and transferred DERR Division of Emergency and Remedial Response DFFO Director’s Final Findings and Orders DNT dinitrotoluene DoD United States Department of Defense EBG Erie Burning Grounds EPC exposure point concentration USEPA United States Environmental Protection Agency ERA ecological risk assessment ESA Endangered Species Act ESV ecological screening value EU exposure unit FBQ Fuze and Booster Quarry Landfill/Ponds FRTR Federal Remediation Technologies Roundtable FS Feasibility Study FWHHRAM Facility Wide Human Health Risk Assessor Manual GAF Gastrointestinal absorption factor GOCO government-owned, contractor-operated GRA general response actions GSA United States General Services Administration

RVAAP 6 High Priority AOCs EBG Feasibility Study Page vi Draft March 2006

LIST OF ACRONYMS (CONTINUED) HHRA human health risk assessment HI hazard index HQ Hazard quotient ILCR incremental lifetime cancer risk IRP Installation Restoration Program LDR land disposal requirement LL12 Load Line 12 MCL maximum contaminant level MDC maximum detected concentration MEC munitions and explosives of concern MMRP Military Munitions Response Program MNA monitored natural attenuation MTR minimum technical requirements NCP National Contingency Plan NEPA National Environmental Policy Act NFA no further action NGB National Guard Bureau NPDES National Pollutant Discharge Elimination System OAC Ohio Administrative Code ODA2 Open Demolition Area #2 OHARNG Ohio Army National Guard Ohio EPA Ohio Environmental Protection Agency PAH polycyclic aromatic hydrocarbon PBC Performance Based Contract PBT persistent, bioaccumulative, and toxic PCB polychlorinated biphenyl POTW publicly owned treatment works PP Proposed Plan PRG preliminary remediation goal PWS Performance Work Statement RAB Restoration Advisory Board RAGS Risk Assessment Guidance for Superfund RAO Remedial Action Objective RBC risk-based concentration RCRA Resource Conservation and Recovery Act RD Remedial Design RDX hexahydro-1,3,5-trinitro-1,3,5-triazine RfC reference concentration RfD reference dose RI Remedial Investigation ROD Record of Decision

RVAAP 6 High Priority AOCs EBG Feasibility Study Page vii Draft March 2006

LIST OF ACRONYMS (CONTINUED) RQL Ramsdell Quarry Landfill RRSE Relative Risk Site Evaluation RTLS Ravenna Training and Logistics Site RVAAP Ravenna Army Ammunition Plant SAIC Science Applications International Corporation SERA Screening Ecological Risk Assessment SESOIL Seasonal Soil Compartment Model SRC site-related contaminant SVOC semi-volatile organic compound TBC to be considered TCLP toxicity characteristic leaching procedure TEF Toxicity Equivalency Factor THI target hazard index TNT Trinitrotoluene TR target risk TRV toxicity reference values TU temporary unit UCL95 95% upper confidence limit UHC underlying hazardous constituent USACE United States Army Corps of Engineers USEPA United States Environmental Protection Agency USP&FO United States Property and Fiscal Officer UTS universal treatment standards UV ultraviolet VOC volatile organic compound WQC water quality criteria 1 2

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1.0 INTRODUCTION 1

Science Applications International Corporation (SAIC) has been contracted by the United States Army 2 Corps of Engineers (USACE) Louisville District to provide environmental services to achieve interim 3 remedy for soils (including dry sediments) at six high priority areas of concern (AOCs) at the Ravenna 4 Army Ammunition Plant (RVAAP) in Ravenna, Ohio by September 30, 2007: 5 6

• RVAAP-01 Ramsdell Quarry Landfill (RQL); 7 • RVAAP-02 Erie Burning Grounds (EBG); 8 • RVAAP-04 Open Demolition Area #2 (ODA2); 9 • RVAAP-12 Load Line 12 (LL12); 10 • RVAAP-16 Fuze and Booster Quarry Landfill/Ponds (FBQ); and 11 • RVAAP-49 Central Burn Pits (CBP). 12

13 This work is being performed under a firm fixed price basis in accordance with United States General 14 Services Administration (GSA) Environmental Advisory Services Contract GS-10-F-0076J under a 15 Performance Based Contract (PBC) as specified in the Performance Work Statement (PWS) issued by the 16 Army on February 10, 2005 (USACE 2005h). In addition, planning and performance of all elements of 17 this work will be in accordance with the requirements of the Director’s Final Findings and Orders 18 (DFFO) dated June 10, 2004 (Ohio EPA 2004). 19 20 1.1 PURPOSE 21 22 The Feasibility Studies (FSs) for the six high priority AOCs present remedial alternatives to address 23 contaminated soil (including dry sediment). Remediation of impacts to aqueous media (groundwater and 24 surface water) and subaqueous sediment are not included under the scope of the PBC. Implementation of 25 an alternative to address only soil is; therefore, considered as an interim action or remedy. Groundwater 26 and surface water media are to be addressed under future decisions. The following steps summarize the 27 process supporting development and implementation of interim remedies for soil at the six high priority 28 AOCs: 29 30

1. Complete Remedial Investigation (RI) Reports; 31 2. Complete FSs and Reports; 32 3. Prepare Proposed Plan(s) (PP); 33 4. Prepare Record of Decision(s) (ROD); 34 5. Prepare Remedial Design (RD) Work Plans; 35 6. Implement the RD Work Plans; and 36 7. Prepare Remedial Action Reports. 37

38 Currently, the RI phase or work is complete for each of the six environmental AOCs. The RI phase of 39 work for EBG indicates evidence of impacts that requires further evaluation in a FS. This report 40


documents the FS for soil and dry sediment media at EBG in compliance with the Comprehensive 1 Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. 2 3 This FS evaluates remedial actions to reduce risks to the environment and human health at EBG in 4 accordance with remedial action objectives (RAOs) and to obtain interim remedy for soils/dry sediments. 5 RAOs are developed in the FS to protect receptors from impacted environmental media and chemicals of 6 concern (COCs) identified in the EBG RI Report (USACE 2005d). Applicable and relevant or 7 appropriate requirements (ARARs) also are identified. 8 9 Depending on the outcome of the evaluation in this FS, a preferred alternative will be submitted for 10 public review and comment. Public comments will be considered in the final selection of an interim 11 remedy which will be documented in a ROD. Responses to public comments will be addressed in the 12 responsiveness summary of the ROD. 13 14 1.2 SCOPE 15 16 The necessary CERCLA remediation and closure requirements with respect to soils and dry sediment will 17 be performed to achieve interim remedy at EBG. In addition, residual soils are evaluated to demonstrate 18 that the selected remedy for soil and dry sediment is protective of groundwater with respect to the 19 anticipated future land use. Remediation of aqueous media (i.e., groundwater, surface water, and 20 subaqueous sediments) is not included in the scope of this FS. Therefore, this remedy will be considered 21 interim. 22 23 Although remediation of impacts to groundwater, surface water, and subaqueous sediments are not 24 addressed under this FS, a preliminary evaluation of options to address impacts to aqueous media (i.e., 25 groundwater, surface water, and subaqueous sediments) is included in this FS, if appropriate. Remedies 26 evaluated for soil and dry sediment also incorporate the necessary engineering controls during 27 implementation to ensure protectiveness of surface water during implementation. In addition, removal 28 actions specifically addressing munitions and explosives of concern (MEC) issues or the potential 29 environmental impact from MEC removal are not included in the scope of this FS. In 2001, the 30 Department of Defense (DoD) established the Military Munitions Response Program (MMRP) to manage 31 the environmental, health, and safety issues presented by MEC as a result of historical activities at a site. 32 An inventory of the closed, transferring, and transferred (CTT) ranges or AOCs at RVAAP completed in 33 November 2003 identified 19 MMRP AOCs at RVAAP that are known or suspected to contain MEC, 34 including EBG. 35 36 Ohio Army National Guard (OHARNG) has established future land uses at EBG based on anticipated 37 training mission and utilization of the Ravenna Training and Logistics Site (RTLS) (USACE 2004c). 38 These anticipated future land uses in conjunction with the evaluation of unrestricted land use and 39 associated receptors form the basis for identifying and evaluating remedial alternatives in this FS. 40 41 This FS Report contains an evaluation of a trespasser scenario in addition to the anticipated current/future 42 receptors identified in the RVAAP Facility Wide Human Health Risk Assessment Manual (FWHHRAM, 43


USACE 2004b) (i.e., National Guard Trainee, National Guard Dust/Fire Control Worker, Security 1 Guard/Maintenance Worker, Hunter/Trapper/Fisher, and Resident Subsistence Farmer [adult and child]). 2 An Adult and Juvenile Trespasser scenario was evaluated to supplement the baseline human health risk 3 assessment (HHRA) detailed in the RI Report per the FWHHRAM Amendment #1 (USACE 2005c) to 4 provide risk managers with information to support determination of the need for continued security at the 5 facility. 6 7 1.3 REPORT ORGANIZATION 8 9 The organization of this report is based on the United States Environmental Protection Agency (USEPA) 10 guidance and includes seven major sections. This report presents the findings of the FS conducted for 11 EBG and is organized as follows: 12 13

• Section 2: Background Information; 14 • Section 3: Remedial Action Objectives; 15 • Section 4: Applicable or Relevant and Appropriate Requirements; 16 • Section 5: Agency Coordination and Public Involvement; 17 • Section 6: Conclusions; and 18 • Section 7: References. 19

20 Section 2 summarizes facility and AOC background information. Section 3 outlines the development of 21 RAOs for the constituents and media of concern. Section 4 presents the ARARs. Section 5 summarizes 22 partnering and public involvement activities. Section 6 presents conclusions. References are found in 23 Section 7, followed by the appendices. The appendices provide information supporting the evaluations 24 presented in the body of this FS Report: 25 26

• Appendix 2A: characterization of evaluation of trespasser (adult and juvenile) exposure scenario; 27 • Appendix 3A: contaminant fate and transport assessment; and 28 • Appendix 5A: technology types and process options for aqueous media. 29


2.0 BACKGROUND INFORMATION 1

2.1 FACILITY-WIDE BACKGROUND INFORMATION 2 3 2.1.1 General Site Description 4 5 RVAAP is a 1,481-acre portion of the 21,419-acre RTLS of the OHARNG. A total of 19,938 acres of the 6 former 21,419-acre RVAAP was transferred to the United States Property and Fiscal Officer (USP&FO) 7 for Ohio in 1996 and 1999 for use by the OHARNG as a military training site. The current RVAAP 8 consists of 1,481 acres in several distinct parcels scattered throughout the confines of the OHARNG 9 RTLS. The RVAAP and RTLS are co-located on contiguous parcels of property and the RTLS perimeter 10 fence encloses both installations. Since the Installation Restoration Program (IRP) encompasses past 11 activities over the entire 21,419 acres of the former RVAAP, the site description of the RVAAP includes 12 the combined RTLS and RVAAP properties. The RVAAP was previously operated as a government-13 owned, contractor-operated (GOCO) United States Army facility. Currently, the installation is jointly 14 operated by the United States Army Base Realignment and Closure (BRAC) Office and the OHARNG. 15 16 The RVAAP is located within the confines of the RTLS which is in northeastern Ohio within Portage and 17 Trumbull Counties, approximately 4.8 kilometers (3 miles) east northeast of the town of Ravenna and 18 approximately 1.6 kilometers (1 mile) northwest of the town of Newton Falls (Figure 2-1). The RVAAP 19 portions of the installation are solely located within Portage County. The installation consists of a 17.7-20 kilometer (11-mile) long, 5.6-kilometer (3.5-mile)-wide tract bounded by State Route 5, the Michael J. 21 Kirwan Reservoir, and the CSX System Railroad on the south; Garrett, McCormick and Berry roads on 22 the west; State Route 534 to the east, and the Norfolk Southern Railroad on the north. The installation is 23 surrounded by several communities: Windham on the north, Garrettsville 9.6 kilometers (6 miles) to the 24 northwest, Newton Falls 1.6 kilometers (1 mile) to the east, Charlestown to the southwest, and Wayland 25 4.8 kilometers (3 miles) southeast. 26 27 Industrial operations at the former RVAAP consisted of 12 munitions-assembly facilities referred to as 28 “load lines.” Load Lines 1 through 4 were used to melt and load 2,4,6-trinitrotoluene (TNT) and 29 Composition B into large-caliber shells and bombs. The operations on the load lines produced explosive 30 dust, spills, and vapors that collected on the floors and walls of each building. Periodically, the floors and 31 walls were cleaned with water and steam. The liquid, containing 2,4,6-TNT and Composition B, was 32 known as “pink water” for its characteristic color. Pink water was collected in concrete holding tanks, 33 filtered, and pumped into unlined ditches for transport to earthen settling ponds. Load Lines 5 through 11 34 were used to manufacture fuzes, primers, and boosters. Potential contaminants in these load lines include 35 lead compounds, mercury compounds, and explosives. From 1946 to 1949, LL12 was used to produce 36 ammonium nitrate for explosives and fertilizers prior to its use as a weapons demilitarization facility. 37 38 In 1950, the facility was placed in standby status and operations were limited to renovation, 39 demilitarization, and normal maintenance of equipment, along with storage of munitions. Production 40 activities were resumed from July 1954 to October 1957 and again from May 1968 to August 1972. In 41


addition to production missions, various demilitarization activities were conducted at facilities 1 constructed at Load Lines 1, 2, 3, and 12. Demilitarization activities included disassembly of munitions 2 and explosives melt-out and recovery operations using hot water and steam processes. Periodic 3 demilitarization of various munitions continued through 1992. 4 5 In addition to production and demilitarization activities at the load lines, other facilities at RVAAP 6 include sites that were used for the burning, demolition, and testing of munitions. These burning and 7 demolition grounds consist of large parcels of open space or abandoned quarries. Potential contaminants 8 at these AOCs include explosives, propellants, metals, waste oils, and sanitary waste. Other types of 9 AOCs present at RVAAP include landfills, an aircraft fuel tank testing facility, and various general 10 industrial support and maintenance facilities. 11 12 2.1.2 Demography and Land Use 13 14 RVAAP/RTLS consists of 8,668.3 hectares (21,419 acres) and is located in northeastern Ohio, 15 approximately 37 kilometers (23 miles) east-northeast of Akron and 48.3 kilometers (30 miles) west-16 northwest of Youngstown. RVAAP/RTLS occupies east-central Portage County and southwestern 17 Trumbull County. United States Census Bureau population estimates for 2001 indicate that the 18 populations of Portage and Trumbull counties are 152,743 and 223,982, respectively. Population centers 19 closest to RVAAP/RTLS are Ravenna, with a population of 12,100, and Newton Falls, with a population 20 of 4,866. 21 22 The RVAAP/RTLS facility is located in a rural area and is not close to any major industrial or developed 23 areas. Approximately 55% of Portage County, in which the majority of RVAAP/RTLS is located, 24 consists of either woodland or farmland acreage. The closest major recreational area, the Michael J. 25 Kirwan Reservoir (also known as West Branch Reservoir), is located adjacent to the western half of 26 RVAAP/RTLS south of State Route 5. 27 28 RVAAP is in the process of regulatory environmental closure and is operated by the BRAC Office. The 29 BRAC Office controls environmental AOCs at RVAAP. The National Guard Bureau (NGB) controls 30 non-AOC areas and has licensed these areas to OHARNG for training purposes. Training and related 31 activities at RTLS include field operations and bivouac training, convoy training, equipment 32 maintenance, C-130 aircraft drop zone operations, helicopter operations, and storage of heavy equipment. 33 As environmental AOCs are investigated and addressed or remediated, if needed, transfer of these AOCs 34 from the BRAC Office to NGB is conducted. 35 36 Until May 1999, approximately 364 hectares (900 acres) of land and some existing facilities at RVAAP 37 were used by the NGB for training purposes administered by OHARNG. In May 1999, NGB assumed 38 operational control of 16,164 acres of RVAAP and licensed OHARNG to use the facility for training and 39 other activities. In December 2001, operational control of an additional 1,528 hectares (3,774 acres) of 40 RVAAP was transferred to NGB bringing the total to 8,039 hectares (19,938 acres). 41 42


OHARNG has prepared a comprehensive Environmental Assessment and an Integrated National 1 Resources Management Plan to address future use of RTLS property (OHARNG 2001). The perimeter of 2 RVAAP/RTLS is currently fenced and the perimeter is patrolled intermittently by the facility caretaker 3 contractor. Access to RVAAP/RTLS is strictly controlled and any contractors, consultants, or visitors 4 who wish to gain access to the facility must follow procedures established by RVAAP/RTLS and the 5 facility caretaker contractor. 6 7 2.1.3 RVAAP/RTLS Physiographic Setting 8 9 RVAAP/RTLS is located within the Southern New York Section of the Appalachian Plateau 10 physiographic province (United States Geological Survey 1968). This province is characterized by 11 elevated uplands underlain primarily by Mississippian- and Pennsylvanian-age bedrock units that are 12 horizontal or gently dipping. The province is characterized by its rolling topography with incised streams 13 having dendritic drainage patterns. The Southern New York Section has been modified by glaciation, 14 which rounded ridges and filled major valleys and blanketed many areas with glacially derived 15 unconsolidated deposits (i.e., sand, gravel, and finer-grained outwash deposits). As a result of glacial 16 activity in this section, old stream drainage patterns were disrupted in many locales, and extensive 17 wetland areas developed. 18 19 2.2 ERIE BURNING GROUNDS 20 21 2.2.1 Site History 22 23 EBG is located in the northeastern corner of the RVAAP/RTLS facility and is approximately 35 acres in 24 size (Figure 2-2). The area may have been used for brick manufacturing prior to its acquisition by the 25 Army in 1940. From 1941 to 1951, the site was used to perform open burning of explosives and related 26 materials. This included bulk, obsolete, and off-specification explosives, propellants, rags, railcars used 27 for transporting explosives, and unspecified large metal items. Once treated, the metal items were 28 salvaged and processed as scrap. Ash residues were not removed. Historically a waste chute ran from the 29 end of rail line Track 49 to the former burn area. In addition, the borrow area between Tracks 49 and 10 30 may have also been used for open burning. In the 1990s, the area became a wetland due to sedimentation, 31 vegetation growth, and beaver activity, which plugged the primary outflow culvert and small streams that 32 drained EBG. The wetlands now cover approximately 60% of the AOC. 33 34 Potential primary sources of contamination include the Track 49 embankment, the gravel access road, and 35 the north leg of the T-area. Potential secondary sources of contamination are the sediments in the Former 36 Burn Area, the north side of the Track 49 embankment, the north leg of the T-area, and the north end of 37 the gravel access road. 38 39 EBG is classified as “Restricted Access” because of environmentally sensitive areas (i.e., wetlands), and 40 the potential for MEC (although minimal MEC has been found). Current plans call for EBG to remain 41 Restricted Access in the future. This means this area will not be opened to general training, primarily 42 because it is a wetland. EBG is closed to all normal training and administrative activities. Surveying, 43


sampling, and other essential security, safety, and natural resources management activities may be 1 conducted here only after personnel are properly briefed on potential hazards/sensitive areas. Individuals 2 unfamiliar with the hazards/restrictions are escorted by authorized personnel at all times while in the 3 restricted area (USACE 2004b). 4 5 2.2.2 Site and Surface Features 6 7 Elevations at EBG range from approximately 285.9 to 287.2 meters (938.1 to 942.4 ft) above mean sea 8 level (amsl) (Figure 2-3). Extensive beaver damming has turned a large portion of the site into wetlands. 9 There are four main surface water basins occupying the lowlands. The largest pond, North Surface Water 10 Basin, has a depth of 5 feet in the former drainage channel but is less than 1 foot in other areas. Surface 11 water flows from a culvert pipe and drainage ditch in the north and drains to the southwest through a pipe 12 beneath Track 10. Photograph 2-1 gives an indication of the amount of water at EBG. Overall, the site is 13 estimated to be 60% aquatic habitat. Structural features include a gravel access road, a 1,700-foot long 14 main drainage channel, three pairs of 250-foot long trenches, rail line Track 10, rail line Track HA, and 15 rail line Track 49. There are no buildings and no historical evidence of permanent buildings. The area 16 near the remains of Track 49 is littered with railroad ties and miscellaneous associated metal debris such 17 as rail spikes and plates. Wooden frame structures in the vicinity of the former waste chute and burn area 18 were observed during low water conditions at the time of the Phase I RI. Wooden frame debris in the 19 vicinity of the former burn area at the end of Track 49 were observed during low water conditions at the 20 time of the Phase I RI and are believed to be remnants of a wooden chute used to offload materials for 21 burning. 22 23 The soils in the area are predominantly silty loams. Historically, the native soil has been disturbed by the 24 construction of the railroad tracks and access road. In these areas, the native soil was replaced with sandy 25 fill, sand, ballast material, and slag. Near the access road, the soil is comprised of dark clayey silts and 26 silty clays. 27 28


1 Photograph 2-1. Site Conditions at EBG, September 2005 2

3 4 2.2.3 Previous Investigations 5 6 Five site investigations have been completed at EBG: 7 8

• Ravenna Arsenal, Ravenna, Ohio (Mogul Corporation, May 1982); 9 10 • Ravenna Water Quality Surveillance Program (United States Army Toxic and Hazardous 11

Materials Agency 1980-1982); 12 13

• Relative Risk Site Evaluation, RVAAP, Ravenna, Ohio, Hazardous and Medical Waste Study, 14 No. 37-EF-5360-97 (United States Army Center for Health Promotion and Preventive Medicine 15 1996); 16

17 • Phase I Remedial Investigation Report for EBG at the RVAAP, Ravenna, Ohio, DACA62-94-D-18

0029 (USACE 2001); and 19 20

• Phase II Remedial Investigation Report for EBG at the RVAAP, Ravenna, Ohio (USACE 21 2005c). 22


The Water Quality Surveillance Program monitored surface water and sediment and included the Parshall 1 flume located near the eastern boundary of the installation, and adjacent to Route 534 where surface 2 water at EBG leaves installation through this sampling point (PF534). The relative risk site evaluation 3 (RRSE) performed for EBG was limited to surface water and sediment. The Phase I RI analyzed 4 contaminant concentrations and evaluated the human health and ecological risks for soil, sediment, and 5 surface water, but not groundwater. The Phase II RI included groundwater characterization efforts. The 6 RI subsurface soil samples were collected to a depth of 3 feet below ground surface (bgs). 7 8 2.2.4 Nature and Extent 9 10 Nature and extent of contamination at EBG was determined based on the evaluation of the Phase II RI 11 data. Figure 2-4 shows the sample locations and groundwater monitoring wells at EBG. 12 13 2.2.4.1 Surface Soil Discrete Samples 14 15 Explosives were detected along the north and south embankment of Track 49. No explosives were found 16 in the wooded area in the northwest portion of the AOC. Inorganic site-related contaminants (SRCs) 17 included between 10 and 14 metals in each of the Phase II sample locations on the north and south sides 18 of Track 49 embankment. With the exception of cadmium, metals were not present above background in 19 the wooded area in the northwest or southeast portions of the AOC. Polychlorinated biphenyls (PCBs) 20 were not detected in Phase I or Phase II RI surface soil samples (0-1 ft bgs). 21 22 2.2.4.2 Surface Soil Multi-increment Samples 23 24 Multi-increment soil samples were collected from five separate areas at EBG. Explosives were detected 25 at one multi-increment sample location from the north Track 49 embankment area. Between 2 and 26 14 inorganic constituents were identified above background in the multi-increment sample areas. At least 27 one, and as many as 12, semi-volatile organic compounds (SVOCs) were detected in four of the five 28 multi-increment samples collected. SVOCs were not detected on the south of the embankment. The 29 greatest number of SVOCs was also observed in the multi-increment sample from the north Track 49 30 embankment. Seven SVOCs were detected in the vicinity of the Former Borrow Area. 31 32 2.2.4.3 Sediment Samples 33 34 Explosives or propellants in sediments were detected at the north inlet (nitrobenzene) and in the former 35 drainage channel in the south basin [HMX (octahydro-1,3,5,7-tetranitro-1,3,5,7-tetrazocine)]. Explosives 36 were not detected in the sediment samples collected downstream of the EBG outlet. Inorganic SRCs 37 were observed at the north and east inlets, the former drainage channel in the south basin, and 38 downstream of the EBG outlet. Bis(2-ethylhexyl)phthalate was detected in five of six sediment samples, 39 and fluoranthene was detected downstream of the EBG outlet. SVOCs were not detected in the surface 40 water basins or beyond the AOC boundary in the Phase I investigation. Volatile organic compounds 41 (VOCs) were also detected at the EBG outlet and stations downstream. PCBs were not detected in Phase 42


II RI samples. Methoxychlor was detected in the Phase II RI sediment sample from the former drainage 1 channel in the south basin. 2 3 2.2.4.4 Sediment Multi-increment Samples 4 5 Three multi-increment samples were collected from each of two multi-increment sampling areas, one 6 located in the north basin, and one in the south basin along the axis of the former drainage channel. 7 Overall, explosives, metals, SVOCs, and pesticides were more prevalent in the north basin 8 multi-increment samples than in the south basin multi-increment samples. 9 10 2.2.4.5 Surface Water Samples 11 12 Explosive compounds were not detected at the eight surface water stations sampled during the Phase II 13 RI. The propellant nitrocellulose was detected in the Phase II surface water sample collected from the 14 east inlet. A total of seven metals were detected above background criteria at least once in Phase II 15 surface water samples, including antimony, beryllium, cadmium, cobalt, lead, nickel, and vanadium. The 16 background criterion for all seven metals is zero, as they were not detected in the background data set. 17 As was seen for Phase II sediment, the greatest number of metals above background occurred in the 18 sample collected from the former drainage channel in the south basin. This area was identified as having 19 only minor contamination in the Phase I RI. Metals were detected above background at the EBG outlet 20 and stations immediately downstream, as well as the off-AOC location at PF534. The off-AOC sample 21 point at PF534 also contained inorganic SRCs above background criteria during the Phase I RI. SVOCs, 22 pesticides, and PCBs were not detected in Phase II surface water samples. The Phase II RI samples had 23 detectable VOCs for samples collected in the T-Area and at the east inlet, which was also noted in the 24 Phase I RI, and at PF534. VOCs had not been detected previously at the PF534 location. The VOCs 25 most frequently detected in the Phase I (acetone, toluene, carbon disulfide) were not detected in Phase II 26 samples. PCBs were not detected in either the Phase I or Phase II RIs. 27 28 2.2.4.6 Groundwater 29 30 Explosives were not detected in any of the groundwater wells installed and sampled during the Phase II 31 RI. Nine inorganic SRCs were detected in at least one of the eight EBG monitoring wells (antimony, 32 arsenic, barium, cobalt, copper, lead, nickel, vanadium, and zinc). Metals were detected above 33 background criteria as often in wells located at the AOC boundary on the northeast and southwest corners 34 (i.e., upgradient and downgradient) of EBG as in wells located in areas of known surface soil (0-1 ft bgs) 35 and sediment contamination. Maximum concentrations of SRCs ranged from 2 to 3 times background for 36 those constituents whose background criteria were greater than zero. 37 38 Two SVOCs, bis(2-ethylhexyl)phthalate and di-n-butyl phthalate, were detected in one to two wells. The 39 occurrence of SVOCs in groundwater was focused on wells located in the Track 49 embankment area and 40 the T-Area. The VOC carbon disulfide was detected in seven of eight wells during the Phase II RI. The 41 pesticide 4-4’-dichlorodiphenyltrichloroethene was detected in one well on the southwest corner of the 42 AOC. 43


2.2.5 Fate and Transport Analysis 1 2 Contaminant fate and transport modeling performed as part of the Phase II RI included leachate modeling 3 (Seasonal Soil Compartment Model [SESOIL]) of constituents in Track 49 embankment soil to the water 4 table. Groundwater modeling (Analytical Transient 1-,2-,3-Dimensional [AT123D]) was conducted from 5 the source to the nearest downgradient receptor (south surface water basin). 6 7 Hexahydro-1,3,5-trinitro-1,3,5-triazine (RDX) and arsenic were identified as final contaminant migration 8 chemicals of potential concern (CMCOPCs) for EBG based on source loading predicted by the SESOIL 9 modeling. These two constituents were also identified as final contaminant migration chemicals of 10 concern (CMCOCs) based on AT123D modeling. The maximum groundwater concentrations of these 11 constituents were predicted to exceed maximum contaminant levels (MCLs) or risk-based concentrations 12 (RBCs) at a downgradient receptor within the model time frame of 1,000 years. However, a refined 13 assessment of contaminant fate and transport demonstrated that, based on modeled timeframes to attain 14 peak leaching concentrations and on actual observed groundwater concentrations, none of the constituents 15 identified as CMCOCs are predicted to reach downgradient receptor locations. Either the predicted peak 16 leaching concentration has already occurred (e.g., 4 years for RDX) or actual groundwater concentrations 17 are less than modeling results, which indicates a higher degree of attenuation than that accounted for by 18 the conservative numerical model. A full discussion of contaminant fate and transport is presented in 19 Section 3.5 and Appendix 3A. 20 21 2.2.6 Human Health Risk Assessment 22 23 The HHRA at EBG was conducted to evaluate risks and hazards for two representative receptors 24 (Hunter/Trapper and Fire/Dust Suppression Worker). Three media were evaluated: shallow surface soil 25 (0-1 ft bgs), sediment, and surface water. In addition to the representative receptors described above, the 26 other three receptors described in the FWHHRAM [National Guard Trainee, Security Guard/Maintenance 27 Worker, and Resident Subsistence Farmer (adult and child)] were evaluated for exposure to shallow 28 surface soil (0-1 ft bgs), deep surface soil (0-3 ft bgs), subsurface soil (1-3 ft bgs) groundwater, sediment, 29 and surface water. These additional receptors are not anticipated at EBG due to physical constraints (e.g., 30 wetlands and MEC) and intended future land use by OHARNG. The Resident Subsistence Farmer 31 provides a baseline for evaluating this site with respect to unrestricted release. 32 33 No shallow surface soil (0-1 ft bgs) or sediment COCs were identified for either representative receptor at 34 EBG. One metal (arsenic) was identified as a carcinogenic COC for the Fire/Dust Suppression Worker 35 exposed to surface water at EBG. 36 37 The representative receptors are not exposed to groundwater. COCs identified for direct contact 38 pathways for all media for the other receptors evaluated are listed below: 39 40

• Two COCs [arsenic and benzo(a)pyrene] were identified in shallow surface soil (0-1 ft bgs). 41 42


• Three COCs (arsenic, chromium, and manganese) were identified in deep surface soil (0-3 ft 1 bgs). 2

3 • Two COCs [arsenic and benzo(a)pyrene] were identified in subsurface soil (1-3 ft bgs). 4

Subsurface soil samples were taken to a maximum depth of 3 ft bgs because there is no record of 5 wastes being buried at EBG. 6

7 • One COC (arsenic) was identified in groundwater. 8

9 • Five COCs [antimony, arsenic, chromium, manganese, and benzo(b)fluoranthene] were 10

identified in sediment. 11 12

• Two COCs (arsenic and manganese) were identified in surface water. 13 14 A summary of the HHRA results is provided in Table 2-1. 15 16


Table 2-1. Summary of HHRA Risk Results for Direct Contact at the Erie Burning Ground 1

Receptor Total HI Total ILCR

COCs Notes

Fire/Dust Suppression Worker (Representative Receptor) Shallow Surface Soila 0.0027 2.5E-07 None Sediment 0.0085 2.2E-07 None

Below USEPA and Ohio EPA target risk values for surface soil and sediment.

Surface Water 0.098 2.9E-06 As Exceeds USEPA deminimis risk but below Ohio EPA target risk.

Hunter/Fisher (Representative Receptor) Shallow Surface Soila 0.00052 6.3E-08 None Sediment 0.0017 5.5E-08 None Surface Water 0.023 4.0E-07 None

Below USEPA and Ohio EPA target risk values for all media.

Security Guard/Maintenance Worker

Shallow Surface Soila 0.057 7.5E-06 As, B(a)P Exceeds USEPA deminimis risk but below Ohio EPA target risk values

National Guard Trainee Deep Surface Soila 2.2 1.6E-05 As, Cr, Mn Sediment 2.2 2.8E-05 As, Cr, Mn

Exceeds USEPA and Ohio EPA target risk. Primary risk driver is chromium evaluated as Cr+6.

Surface Water 1.1 1.5E-05 As Exceeds USEPA and Ohio EPA target risk. Groundwater 0.29 4.7E-05 As Exceeds USEPA and Ohio EPA target risk. Resident Subsistence Farmer (Adult) Shallow Surface Soila 0.24 2.3E-05 As, B(a)P Subsurface Soila 0.14 1.5E-05 As, B(a)P Sediment 0.88 2.2E-05 As, B(b)F

Exceeds USEPA and Ohio EPA target risk. Primary risk driver is arsenic. Risk from B(a)P and B(b)F are below Ohio EPA target risk.

Surface Water 2.4 8.1E-05 As, Mn Exceeds USEPA and Ohio EPA target risk. Groundwater 2.6 5.4E-04 As Exceeds USEPA and Ohio EPA target risk. Resident Subsistence Farmer (Child) Shallow Surface Soila 1.5 2.3E-05 As, B(a)P Subsurface Soila 0.88 1.7E-05 As Sediment 6.6 2.5E-05 As, Sb

Exceeds USEPA and Ohio EPA target risk. Primary risk driver is arsenic. Risk from B(a)P is below Ohio EPA target risk.

Surface Water 6.5 6.6E-05 As, Mn Exceeds USEPA and Ohio EPA target risk. Groundwater 9.2 3.5E-04 As Exceeds USEPA and Ohio EPA target risk.

aShallow surface soil defined as 0-1 ft below ground surface (bgs); deep surface soil defined as 0-3 ft bgs; subsurface soil defined as 1-3 ft bgs. 2 Chemical abbreviations: 3 As = arsenic Cr = chromium (evaluated as hexavalent chromium) 4 B(b)F = benzo(b)fluoranthene Mn = manganese 5 B(a)P = benzo(a)pyrene Sb = antimony 6 COC = Chemical of concern. 7 HI = Hazard index. 8 ILCR = Incremental lifetime cancer risk. 9 Ohio EPA = Ohio Environmental Protection Agency 10 USEPA = United States Environmental Protection Agency 11 12 2.2.7 Ecological Risk Assessment 13 14 EBG contains sufficient terrestrial and aquatic (soil, sediment, and surface water) habitat to support 15 various classes of ecological receptors. The presence of suitable habitat and observed receptors at the site 16 warranted a screening ecological risk assessment (SERA). The Ohio Environmental Protection Agency 17 (Ohio EPA) protocol (Level I) was met and Level II was needed. The Army’s RVAAP Facility-wide 18 Ecological Risk Work Plan (USACE 2003a) was used to guide the work. 19 20 The SERA process provides a very conservative evaluation of the potential for risk to ecological 21 receptors by comparing the maximum detected concentration (MDC) of chemicals in soil, sediment, and 22 surface water to conservative medium-specific ecological screening values (ESVs). Chemicals with no 23 ESV are also retained. As part of this screen, all chemicals classified as PBT are retained regardless of 24


their concentration or frequency of detection. Inorganic PBT compounds include cadmium, lead, 1 mercury, and zinc. Organic PBT chemicals include any compound whose log Kow is at least 3.0. 2 Chemicals retained by the SERA process are considered chemicals of potential ecological concern 3 (COPECs). For the Level II Screen, specific receptors are not identified because the ESVs are 4 conservative screening toxicity benchmarks that are intended to protect multiple receptors. 5 6 The Baseline Ecological Risk Assessment (BERA) continues the SERA process. The focus is on soil, 7 sediment, and surface water and on specific ecological receptors, e.g., mammals, birds, and aquatic 8 organisms. Its input chemicals are COPECs and the BERA process produces chemicals of ecological 9 concern (COECs). COECs are identified as chemicals having a hazard quotient (HQ) > 1.0 for one or 10 more of the ecological receptors that were evaluated in the BERA, and chemicals for which there were no 11 toxicity reference values (TRVs) associated with an expected level of effect. The HQ is calculated as the 12 quotient of the exposure concentration or dose and the TRV. Terrestrial receptors evaluated included 13 plants, soil-dwelling invertebrates (earthworms), mammalian herbivores (deer mice and white-tailed 14 deer), insectivorous mammals (shrews), and top predators (red foxes and red-tailed hawks). Sediment 15 and surface water receptors evaluated included sediment biota, aquatic biota, herbivores (mallard ducks 16 and muskrats), and top predators (mink and great blue heron). 17 18 The BERA (Level III Baseline) identified multiple COECs in surface soil (0-1 ft bgs) and subsurface soil 19 (1-3 ft bgs) from the EBG (USACE 2005d). Surface soil COECs have the potential to pose a hazard to 20 plants and animals. 21 22 For surface soil (0-1 ft bgs), 38 total COECs were identified, including 11 inorganic COECs based on 23 having an HQ > 1 for one or more receptors, and 27 COECs (6 inorganics, 16 SVOCs, 1 pesticide, and 24 4 explosives) based solely on having no TRVs for at least one receptor (Table 2-2). For COECs based on 25 HQs > 1, iron had the largest HQ (2500 for plants), followed by the HQ for aluminum (842 for shrews). 26 Other large HQs included aluminum for plants (266) and rabbits (221), and chromium for earthworms 27 (57). Aluminum had large HQs for all terrestrial receptors except earthworms, foxes, and hawks. 28 29 For the subsurface soil (1-3 ft bgs), there were only 13 COECs, including 2 inorganics (antimony and 30 zinc) based on having an HQ > 1 for at least one receptor and 11 COECs based solely on no TRV for at 31 least one receptor (10 SVOCs and 1 explosive [nitrocellulose]) (Table 2-2). Antimony had the largest 32 HQ for shrews (3), followed by the HQ for zinc for plants (2) and the HQ for antimony for rabbits (1). 33 These were the only three HQs > 1 for subsurface soil. Thus, in contrast to surface soil (0-1 ft bgs), 34 subsurface soil had far fewer total COECs, including those based on HQs > 1, and the maximum HQ was 35 three orders of magnitude lower than the maximum HQ for surface soil. 36 37 In summary, the 38 surface soil COECs included 11 that had HQs > 1 for multiple ecological receptors 38 plus multiple COECs based on having no TRV for one or more receptors. Iron had the largest HQ (2500 39 for plants), followed by the HQ for aluminum (842 for shrews). The subsurface soil (1-3 ft bgs) had only 40 a third as many COECs as the surface soil (0-1 ft bgs) and did include COECs based on HQs > 1 and 41 having no TRVs. The maximum HQ for subsurface soil was about 1000-fold smaller than the maximum 42 HQ for surface soil. Although some of the HQs likely overestimate the risk of their COECs to ecological 43


receptors due to low availability of the chemicals for biological uptake from soil (e.g., aluminum) or low 1 confidence in the TRVs (e.g., iron for plants), the presence of multiple COECs with HQs > 1 and lack of 2 TRVs for multiple receptors indicates the potential for adverse effects to ecological receptors from these 3 chemicals in EBG surface and subsurface soil. 4

5

Table 2-2. Overview of Surface (0-1 ft) and Subsurface (1-3 ft) Soil COECs at EBG – BERA (Level III) 6

COECs with the Three Highest HQs Other COECs with HQs > 1 Media COEC HQ COEC Range of HQs

Surface Soil Iron 2500 Zinc 3 to 11 Aluminum 842 Vanadium 9 to 10 Chromium 57 Antimony 2 to 8 Arsenic 1 to 4 Lead 2 to 3 Barium 1 to 3 Manganese 2 Copper 1 Subsurface Soil Antimony 3 No others No others Zinc 2

aCOECs = chemicals of ecological concern 7 Note: the HQs are based on Lowest Observed Adverse Effect Levels for plants and invertebrates, but No Observed Adverse Effect 8 Levels for wildlife 9 HQs = hazard quotients 10 For surface soil, an additional 27 COECs were based solely on having no TRV (6 inorganics, 16 SVOCs, 1 pesticide, and 4 11 explosives) 12 For subsurface soil, an additional 11 COECs were based solely on having no TRV (10 SVOCs and 1 explosive) 13

14 The BERA (Level III Baseline) identified multiple COECs in sediment and surface water from the EBG 15 (USACE 2005d). 16 17 Regarding sediment, 62 total COECs were identified, including 23 COECs (10 inorganics, 10 SVOCs, 1 18 pesticide, 1 explosive, and 1 volatile) based on having an HQ > 1 for one or more receptors, and 39 19 COECs (16 inorganics, 15 SVOCs, 2 pesticides, 4 explosives, and 2 volatiles) based solely on having no 20 TRVs for at least one receptor (Table 2-3). For COECs based on HQs > 1, benzo(k)fluoranthene had the 21 largest HQ (144,900 for great blue herons), followed by the HQ for bis(2-ethylhexyl)phthalate (53,882 22 for great blue herons). Other large HQs included cyanide for sediment biota (10,100), and 23 benzo(a)anthracene for great blue herons (8920). Note that benzo(k)fluoranthene was detected in only 4 24 of 92 samples, meaning that it is not widely distributed around EBG. Further, the TRVs for birds are 25 rather conservative because some of the TRVs are extrapolated from acute lethality rather than chronic 26 reproductive effects. 27 28 Regarding surface water, there were only 10 COECs, all of them inorganics, based on having an HQ > 1 29 for at least one receptor and 9 COECs based solely on no TRV for at least one receptor [6 inorganics, 1 30 explosive (nitrocellulose), and 2 volatiles] (Table 2-3). Aluminum had the largest HQ for muskrats 31 (9552), followed by the HQ for manganese for muskrats (186) and the HQ for iron for aquatic biota 32 (127). There were an additional 7 COECs with HQs ranging from 1 to 68. Thus, in contrast to sediment, 33


surface water had far fewer total COECs, including those based on HQs > 1, and the maximum surface 1 water HQ was an order of magnitude lower than the maximum HQ for sediment. 2 3

Table 2-3. Overview of Sediment and Surface Water COECs at EBG – BERA (Level III) 4

COECs with the Three Highest HQs Other COECs with HQs > 1 Media COEC HQ COEC Range of HQs

Sediment Benzo(k)fluoranthene 144,900 Benzo(a)anthracene 2 to 8920 Bis(2-ethylhexyl)phthalate 53,882 Lead 7 to 2409 Cyanide 10,100 Indeno(1,2,3-cd)pyrene 1 to 2191 Chrysene 4 to 1600 Zinc 12 to 1041 Benzo(a)pyrene 2 to 191 Cadmium 3 to 149 PCB-1254 102 Antimony 28 Acetone 8 Copper 5 2,6-Dinitrotoluene 4 Silver 4 Pyrene 3 Phenanthrene 3 Fluorene 3 Aluminum 3 Fluoranthene 2 Nickel 1.5 Arsenic 1.4 Surface Water Aluminum 9552 Copper 9 to 68 Manganese 186 Mercury 17 Iron 127 Lead 2 to 17 Zinc 2 to 7 Barium 4 Cyanide 2 Cadmium 1 to 2

aCOECs = chemicals of ecological concern 5 Note: the HQs are based on Lowest Observed Adverse Effect Levels for sediment and aquatic biota, and No Observed Adverse Effect 6 Levels for wildlife 7 HQs = hazard quotients 8 For sediment, an additional 39 COECs were based solely on having no TRV (16 inorganics, 15 SVOCs, 2 pesticides, and 4 explosives, 9 and 2 volatiles). 10 For surface water, an additional 9 COECs were based solely on having no TRV (6 inorganics, 1 explosive, and 2 volatiles). 11

12 In summary, the 62 sediment COECs included 23 that had HQs > 1 for multiple ecological receptors plus 13 multiple COECs based on having no TRV for one or more receptors. Benzo(k)fluoranthene had the 14 largest HQ (for great blue herons), followed by the HQ for bis(2-ethylhexyl)phthalate (also for great blue 15 herons). The surface water had only a third as many COECs as the sediment and included 10 COECs 16 based on HQs > 1 and 9 COECs having no TRVs. The maximum HQ for surface water was about 10-17 fold smaller than the maximum HQ for sediment. Although the presence of multiple COECs with 18 HQs > 1 and lack of TRVs for multiple receptors suggest the potential for adverse effects to ecological 19 receptors from these chemicals in EBG sediment and surface water, some of the HQs likely overestimate 20


the risk of their COECs to ecological receptors due to low availability of the chemicals for biological 1 uptake from sediment (i.e., polycyclic aromatic hydrocarbons [PAHs], which have very high Kow values) 2 or low confidence in the TRVs (also PAHs, whose TRVs for birds are extrapolated from acute lethality 3 rather than from chronic reproductive effects). This is further tempered by findings from the Ohio EPA 4 rapid assessment of wetlands, which concluded that the wetlands are of high quality, and the facility-wide 5 biology and surface water study, which found a functioning and healthy aquatic ecosystem. These 6 additional facts, along with the conservative exposure assumptions, provide evidence that EBG is not 7 appreciably hazardous to sediment and aquatic receptors. 8 9 2.2.7.1 Level II Results 10 11 Forty-five chemicals were retained as COPECs for surface soil (0-1 ft bgs). For subsurface soil (1-3 ft 12 bgs), 18 chemicals were retained as COPECs. Forty chemicals were retained as COPECs for sediment. 13 Seventeen chemicals were retained as COPECs for surface water. 14 15 Because COPECs were identified and retained for surface (0-1 ft bgs) and subsurface (1-3 ft bgs) soil, 16 sediment, and surface water, ecological conceptual site models (CSMs) were prepared, along with the 17 identification of site-specific ecological receptors, relevant and complete exposure pathways, and 18 candidate assessment endpoints. These types of information were used to prepare a Level III Baseline. 19 20 2.2.7.2 Level III Results 21 22 Forty-three COECs for surface soil (0-1 ft bgs) were identified for the surface soil exposure unit (EU). 23 Three surface soil COPECs from the Level II SERA were identified as qualifying for no further action 24 (NFA) during the Level III BERA. Fifteen COECs for the subsurface soil (1-3 ft bgs) EU were 25 identified. Four subsurface soil COPECs from the Level II SERA were identified as qualifying for NFA 26 during the Level III BERA. Fifty-eight COECs were identified in sediment. Only one sediment COPEC 27 from the Level II SERA qualified for NFA during the Level III BERA. Nineteen COECs were identified 28 for the surface water EU. None of the surface water COPECs from the Level II SERA qualified for NFA 29 during the Level III BERA. 30 31 2.3 RISK CHARACTERIZATION FOR TRESPASSER SCENARIO 32 33 The baseline HHRA provided in the RI Report for EBG evaluates the potential health risks to humans 34 resulting from exposure to contamination at EBG. The HHRA presented in the Phase II RI Report is 35 based on the methods outlined in the FWHHRAM (USACE 2004b) which addresses five receptors to be 36 evaluated at RVAAP (National Guard Trainee, National Guard Dust/Fire Control Worker, Security 37 Guard/Maintenance Worker, Hunter/Trapper/Fisher, and Resident Subsistence Farmer [adult and child]). 38 39 In addition to the receptors in the FWHHRAM an Adult and Juvenile Trespasser is evaluated in this FS 40 per the FWHHRAM Amendment #1 (USACE 2005c) to supplement the baseline HHRA provided in the 41 RI Report to provide risk managers with information relating to potential trespasser exposure. This 42


supplemental risk characterization is presented in (Appendix 2A) and is incorporated into subsequent 1 sections of this FS as appropriate. 2 3


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1 Figure 2-4. Sample and Monitoring Well Locations at EBG 2


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3.0 REMEDIAL ACTION OBJECTIVES 1

This section of the FS describes the RAOs for EBG. RAOs specify the requirements that remedial 2 alternatives must fulfill in order to protect human health and the environment from contaminants. The 3 primary objectives of this section are: 4 5

1. To present the RAOs for EBG; 6 7 2. To identify media-specific preliminary cleanup goals to meet these RAOs; 8

9 3. To identify areas of soil, sediment, surface water, and groundwater where remediation may be 10

needed to meet the RAOs; and 11 12

4. To identify the extent of soils/dry sediment contamination to be used in volume calculations for 13 evaluating removal/treatment alternatives. 14

15 The discussion in this section is organized as follows: 16 17

• RAOs are presented in Section 3.1. 18 19

• Anticipated future land use is discussed in Section 3.2. 20 21

• Human health preliminary cleanup goals and the identification of COCs requiring further 22 evaluation for remedial alternatives to meet these RAOs are presented in Section 3.3. 23

24 • Ecological weight-of-evidence for meeting RAOs are presented in Section 3.4. 25

26 • An assessment of the potential for impacted soils to affect groundwater at the AOC and at an 27

exposure point downgradient of the AOC is summarized in Section 3.5. 28 29

• A summary of the COCs and corresponding preliminary cleanup goals established for each 30 AOC/medium from the information presented in Sections 3.1 through 3.4 is presented in Section 31 3.6. 32

33 3.1 REMEDIAL ACTION OBJECTIVES 34 35 RAOs specify the requirements remedial alternatives must fulfill to protect human health and the 36 environment from SRCs at EBG. In order to provide this protection, media-specific objectives that 37 identify major contaminants and associated media-specific cleanup goals are developed. These objectives 38 specify COCs, exposure routes and receptors, and acceptable constituent concentrations for long-term 39 protection of receptors. The baseline HHRA conducted for EBG is summarized in Section 2 of this FS 40 and detailed in Sections 6 and 7 of the Phase II RI Report for EBG (USACE 2005d). 41


As discussed in Section 2, the HHRA includes baseline risk calculations for a number of receptors for 1 representative (National Guard use) and unrestricted land use scenarios. Table 3-1 lists the representative 2 receptor and the unrestricted receptor for each land use scenario at EBG. 3 4

Table 3-1. Land Use Scenarios Assessed at EBG 5

AOC Land Use Scenario Receptor Restricted National Guard Dust Fire Suppression EBG Unrestricted Resident Subsistence Farmer

6 Land use at EBG may change in time, but the receptors in Table 3-1 are the receptors assessed for the 7 purposes of this FS. The representative receptors correspond to active (National Guard Trainee) and 8 restricted (Security Guard/Maintenance Worker, Fire/Dust Suppression Worker) National Guard land 9 uses. The Resident Subsistence Farmer provides a baseline for evaluating whether EBG may be eligible 10 for unrestricted release; however, EBG is not currently a candidate for unrestricted release because of the 11 suspected presence of MEC which will be investigated in the MMRP. Other receptors, in addition to the 12 representative receptor and Resident Subsistence Farmer, are evaluated in the baseline HHRA. The 13 representative receptors chosen for EBG are protective of other activities that may occur under 14 anticipated future land use. In addition to the receptors evaluated in the HHRA, an Adult and Juvenile 15 Trespasser are evaluated in this FS per the FWHHRAM Amendment #1 (Appendix 2A). 16 17 Cleanup goals are based on the evaluation of both the representative and unrestricted scenarios. More 18 information can be found in Section 3.3 regarding representative receptors, risk calculations, and 19 preliminary cleanup goals. 20 21 The ERA performed for EBG identifies a variety of ecological receptor populations that could be at risk 22 and identifies the COPECs and COECs that could contribute to potential risks from exposure to 23 contaminated media. Ohio EPA guidance (Ohio EPA 2003) allows a decision about remediation to be 24 made at the completion of each level of risk assessment. A decision whether it is necessary to remediate 25 because of potential harm to ecological receptors at EBG is not included in the RI Report. Section 3.4 26 provides weight-of-evidence input for that decision. 27 28 The necessary CERCLA remediation and closure requirements with respect to soils and dry sediment will 29 be performed to achieve interim remedy at EBG. Remediation of groundwater, surface water, and 30 subaqueous sediments are not included in the scope of this FS, therefore, any remedies will be considered 31 interim. However, remedy with respect to soils also must be protective of groundwater. The following 32 RAOs are developed accordingly for impacted soil and dry sediment at EBG: 33 34

• Restore impacted soils and dry sediments at EBG to a condition consistent with likely land use 35 by the representative group (i.e., representative OHARNG land use receptors) by achieving 36 preliminary cleanup goals for COCs in impacted soil and dry sediment. Preliminary cleanup 37 goals will be used as target concentrations (e.g., 95% upper confidence limit [UCL95] of the mean 38 of site data should be < preliminary cleanup goal) of COCs that remain at EBG. 39

40


• Remedy of impacted soil and dry sediments to be protective of other environmental media 1 (groundwater, surface water, and sediment) consistent with likely land use by the representative 2 group (i.e., representative OHARNG land use receptors) for COCs. 3

4 • Minimize transport of soil COCs to other environmental media (groundwater, surface water, 5

sediment, and air) during implementation of the remedial action. 6 7

• Prevent releases and other impacts that could adversely affect ecological receptors during 8 implementation of the remedial alternative(s). 9

10 At EBG, preliminary cleanup goals are developed for impacted environmental media including 11 groundwater, surface water, and subaqueous sediments in addition to soil and dry sediment to facilitate 12 future considerations with respect to selection of remedies for these media. 13 14 3.2 ANTICIPATED FUTURE LAND USE 15 16 OHARNG has prepared a comprehensive Environmental Assessment and an Integrated National 17 Resources Management Plan to address future use of RTLS property (OHARNG 2001). OHARNG has 18 established future land use for EBG as Restricted Access, No Digging based on anticipated training 19 mission and utilization of the RTLS (USACE 2004b). Future land use is discussed in more detail in 20 Section 3.3. 21 22 3.3 HUMAN HEALTH PRELIMINARY CLEANUP GOALS 23 24 This section documents the proposed land use and corresponding preliminary cleanup goals to support the 25 remedial alternative selection process for soil remediation at EBG. Preliminary cleanup goals are the 26 chemical-specific numeric cleanup goals used to meet the remedial action objective for protection of 27 human health. 28 29 The HHRA performed for EBG is detailed in the RI Report and summarized in Section 2 of this FS. The 30 risk assessment included in the Phase II RI Report documents a variety of potential human receptor 31 populations (e.g., National Guard Trainee, National Guard Dust/Fire Control Worker, Security 32 Guard/Maintenance Worker, Hunter/Trapper/Fisher, and Resident Subsistence Farmer [adult and child]) 33 that could be at risk, and identify the COCs that could contribute to potential risks from exposure to 34 contaminated media within EBG. In addition to the receptors in the HHRA, a Trespasser (Adult and 35 Juvenile) is evaluated in this FS (Appendix 2A) The HHRA also documents the calculation of risk-based 36 remedial goal options (RGOs) for human receptors for all media (i.e., soil, surface water, sediment, and 37 groundwater), all COCs, and all receptor populations evaluated in the RI Report. These risk-based RGOs 38 are referred to as risk-based cleanup goals in this FS. 39 40 Chemical-specific preliminary cleanup goals are established for restricted and unrestricted land use from 41 these risk-based cleanup goals, background concentrations, and other information in this section. 42 Preliminary cleanup goals for restricted land use are established for a representative receptor for likely 43


future land use by the OHARNG. The representative receptor provides a conservative surrogate for other 1 possible receptors (e.g., preliminary cleanup goals for the National Guard Trainee are also protective of a 2 hunter or a security guard). The potential for the representative receptor to be protective of a trespasser to 3 the site is also addressed. In addition to the representative receptor, preliminary cleanup goals are 4 established for a Resident Subsistence Farmer (adult and child) to provide a baseline for evaluating 5 whether this site may be eligible for unrestricted release. 6 7 The risk-based cleanup goals were calculated using the methodology presented in the Risk Assessment 8 Guidance for Superfund (RAGS), Part B (USEPA 1989), while incorporating site-specific exposure 9 parameters applicable to the five potential receptors outlined in the FWHHRAM. The process for 10 calculating risk-based cleanup goals was a rearrangement of the cancer risk or non-cancer hazard 11 equations, with the goal of obtaining the concentration that will produce a specific risk or hazard level. 12 For example, the risk-based cleanup goal for RDX at the cancer risk level of 1E-05 for the National 13 Guard Trainee is the concentration of RDX that produces a risk of 1E-05 when using the exposure 14 parameters specific to the National Guard Trainee receptor and the cancer slope factor for RDX. 15 Equations, exposure parameters, and toxicity values (cancer slope factors and non-cancer reference doses) 16 are provided in the HHRA and were taken from the FWHHRAM (USACE 2004b). 17 18 The FWHHRAM (USACE 2004b) identifies 1E-05 as a target for cumulative incremental lifetime cancer 19 risk (ILCR) (target risk [TR]) for carcinogens and an acceptable target hazard index (THI) of 1 for non-20 carcinogens consistent with Ohio EPA guidance (Ohio EPA 2004b), with the caveat that exposure to 21 multiple COCs might require downward adjustment of these targets for chemical-specific risks. The 22 chemical-specific TR and THI selected for EBG are dependent on several factors, including the number 23 of carcinogenic and non-carcinogenic COCs and the target organs and toxic endpoints of these COCs. 24 For example, if numerous (i.e., more than 10) non-carcinogenic COCs with similar toxic endpoints are 25 present, it might be appropriate to select chemical-specific preliminary cleanup goals with a THI of 0.1 to 26 account for exposure to multiple contaminants. AOC-specific TR and THI levels are established in 27 Section 3.3. 28 29 The risk-based cleanup goals assumed combined exposure through ingestion, inhalation of vapors and 30 fugitive dust, and dermal contact with contaminated media. For chemicals having both a cancer and non-31 cancer endpoint, risk-based cleanup goals were calculated for both cancer risk and non-cancer hazard at 32 the appropriate TR and THI. The preliminary cleanup goal is selected as the lower of the risk-based 33 cleanup goal for cancer risk and non-cancer hazard and the adult and child receptor (for the Resident 34 Subsistence Farmer), unless the risk-based cleanup goal is below background concentration. If the 35 applicable risk-based cleanup goal concentration is less than background, the background concentration is 36 selected as the preliminary cleanup goal. 37 38 The list of human health COCs for evaluation of remedial alternatives are identified for EBG based on 39 risk management considerations including: 40 41

• Comparison of exposure point concentration (EPC) to preliminary cleanup goal concentrations 42 (including background concentrations); 43


• Comparison of EPC to upgradient concentrations for sediment, surface water, and groundwater; 1 2

• Consideration of soil as the primary source of contamination (i.e., if soil concentrations are 3 below background at an AOC, that AOC is not contributing to contamination in other media); 4 and 5

6 • Other site-specific and receptor-specific considerations. 7

8 The remainder of this section provides the following detailed information: 9 10

• Land use and potential receptors at EBG (Section 3.3.1); 11 12

• A summary of COCs identified in the HHRA (Section 3.3.2); 13 14

• Identification of the appropriate TR level and THI for establishing preliminary cleanup goals 15 based on the number and type of COCs identified in the HHRA (Section 3.3.3); 16

17 • Chemical-specific preliminary cleanup goals (Section 3.3.4); and 18

19 • Risk management considerations and the identification of COCs to be carried through the 20

evaluation of remedial alternatives (Section 3.3.5). 21 22 3.3.1 Land Use and Potential Receptors at EBG 23 24 EBG may contain MEC and contains environmentally sensitive areas (i.e., wetlands). As a result, this 25 area is classified as Restricted Access. Current plans call for the site to remain Restricted Access in the 26 future. Restricted Access means this area will not be opened to general training, primarily because of the 27 suspected presence of MEC and the presence of wetlands. EBG is closed to all normal training and 28 administrative activities. Surveying, sampling and other essential security, safety, natural resources 29 management, and other directed activities may be conducted here only after authorized personnel are 30 properly briefed on potential hazards/sensitive areas. Individuals unfamiliar with the hazards/restrictions 31 are escorted by authorized personnel at all times while in the restricted area (USACE 2005d). 32 33 Given the restricted access and wetland, EBG may be used in the future by two receptor populations: 34 35

• National Guard personnel using surface water for fire or dust suppression. 36 • Recreational users involved in waterfowl hunting. 37

38 These limited activities are compatible with protection of the wetland resource and safety concerns 39 regarding MEC. Hunting is not currently allowed at EBG. Hunters are not allowed at areas that are 40 restricted for environmental reasons (i.e., due to known contamination hazards or during the remedial 41 investigation process). Hunting at RVAAP/RTLS is also restricted for reasons other than environmental, 42 including logistics, general safety, security, and military operations. Military and training site employees 43


are occasionally allowed hunting access to some restricted areas under direct supervision of someone 1 knowledgeable about the site and the security and safety issues associated with it. If hunting is allowed at 2 EBG in the future, hunters will be restricted as they are anywhere at RVAAP/RTLS. That is, hunters are 3 told where they can and cannot hunt and volunteers are responsible for making sure hunters know the 4 boundaries of their areas and for patrolling the perimeter of hunting areas. All hunters are briefed before 5 they go into the field and told to stay within their assigned areas and to keep vehicles on the roads. 6 7 These two receptors are evaluated as outlined in Table 5 of the FWHHRAM (USACE 2004b). The 8 National Guard fire/dust suppression worker is assumed to spend 4 hours/day for 5 days/year for fire 9 suppression and 4 hours/day for 10 days/year (i.e. 40 hours/year) for dust suppression and is assumed to 10 return to RVAAP/RTLS and the AOC of interest every year for their entire 25 year enlistment. The 11 hunter is assumed to be onsite 6 hours/day for 2 days/year and is assumed to hunt at EBG every year that 12 they live in the area (i.e., residential exposure duration of 30 years). Both of these receptors may be 13 exposed to shallow surface soil (0-1 ft bgs), surface water, and sediment. Subsurface soil (1-3 ft bgs) is 14 not evaluated for these receptors because they are not engaged in intrusive activities. The fishery at EBG 15 is very limited because the wetland is so shallow. According to the OHARNG – RTLS, EBG will never 16 be a good fishing pond. It is, however, a very good waterfowl habitat and waterfowl hunting area 17 (Morgan 2004). Thus, because of the surface water habitat characteristics (i.e., shallow with lots of 18 aquatic vegetation), a waterfowl hunter is evaluated, but a fisherman is not. 19 20 Exposures to contaminants in shallow surface soil (0-1 ft bgs), surface water, and sediment at EBG are 21 evaluated for incidental ingestion, dermal contact, and inhalation by a National Guard Fire/Dust 22 Suppression worker and Recreational Hunter/Trapper, and ingestion of waterfowl by the Recreational 23 Hunter/Trapper as defined in Tables 1 and 5 of the FWHHRAM (USACE 2004b). 24 25 In addition to the representative receptors described above, the other three receptors described in the 26 FWHHRAM [National Guard Trainee, Security Guard/Maintenance Worker, and Resident Subsistence 27 Farmer (adult and child)] are evaluated to provide additional information for evaluation in the FS (e.g., to 28 establish the need for institutional controls). Also, a Trespasser (Adult and Juvenile) is included to 29 provide information for evaluation in the event security protocols change. These additional receptors are 30 not anticipated at EBG due to physical constraints and intended future land use by OHARNG. The 31 National Guard Trainee is not anticipated due to physical constraints (e.g., wetlands, MEC) and 32 OHARNG land use plan which does not include training in this area. The Trespasser is not anticipated 33 due to security measures (e.g., perimeter fence, guards). The Resident Subsistence Farmer (adult and 34 child) provides a baseline for evaluating this site with respect to unrestricted release. 35 36 Anticipated use of surface water at EBG includes dust suppression, fire control, trapping, and waterfowl 37 hunting. The Fire/Dust Suppression Worker is used as the representative receptor for the intended land 38 use because exposures to this receptor are higher than exposures for the Hunter/Trapper. The Fire/Dust 39 Suppression Worker is also reasonably protective of a Juvenile Trespasser conservatively assumed to visit 40 the site 2 hours/day, 50 days/year (100 hours/year) for 10 years and an Adult Trespasser assumed to visit 41 the site 2 hours/day, 75 days/year (150 hours/year) for 30 years (compare to 40 hours/year for 25 years 42 for the Fire/Dust Suppression Worker). Estimated risks to a Trespasser are slightly (approximately 2 to 43


11 times) higher than the Fire/Dust Suppression Worker; however, the exposure assumptions for the 1 Trespasser are extremely conservative (i.e., the trespasser visits EBG every weekend (Juvenile) or more 2 (Adult) for 10 to 30 years). 3 4 In addition to the receptors described above the Resident Subsistence Farmer (adult and child) provides a 5 baseline for evaluating whether this site may be eligible for unrestricted release; However, EBG is not 6 currently a candidate for unrestricted release due to MEC concerns and the presence of wetlands; these 7 issue will most likely preclude EBG from unrestricted land use in the future. The Resident Subsistence 8 Farmer is considered a “worst-case” exposure scenario and is considered to be protective for all other 9 potential land uses. 10 11 3.3.2 Chemicals of Concern 12 13 COCs are identified in the HHRA as chemicals with an ILCR greater than 1E-06 and/or a hazard index 14 (HI) greater than 1 for a given receptor. COCs were identified in the HHRA for each exposure medium 15 and receptor evaluated. 16 17 3.3.2.1 COCs in Soil 18 19 The pond at EBG continuously contains water; therefore, the sediment is considered subaqueous and is 20 not included in the scope of this FS for interim soil remediation. 21 22 The total HI is less than 1.0 and the total ILCR is less than 1E-06 for the Fire/Dust Suppression Worker 23 exposed to contaminants in shallow surface soil (0-1 ft bgs); therefore, no COCs were identified for this 24 receptor. 25 26 For the Resident Subsistence Farmer (adult and child); no non-carcinogenic shallow surface (0-1 ft bgs) 27 and subsurface (1-3 ft bgs) soil COCs and two carcinogenic shallow surface and subsurface soil COCs 28 were identified including: one metal (arsenic), and one SVOC [benzo(a)pyrene]. 29 30 A Trespasser (Adult and Juvenile) is evaluated in Appendix 2A to supplement the representative 31 receptors and unrestricted land use. One soil COC (arsenic) is identified for both the Adult and Juvenile 32 Trespasser. 33 34 3.3.2.2 COCs in Surface Water and Sediment 35 36 The pond at EBG continuously contains water; therefore, the pond is evaluated for both surface water and 37 subaqueous sediment. 38 39 One surface water COC (arsenic) was identified for the representative receptor (Fire/Dust Suppression 40 Worker) at EBG. 41 42


Two surface water COCs (arsenic and manganese) were identified in the HHRA for the Resident 1 Subsistence Farmer (adult and child). 2 3 The total HI is less than 1.0 and the total ILCR is less than 1E-06 for the Fire/Dust Suppression Worker 4 exposed to contaminants in sediment; therefore, no COCs were identified for this receptor. 5 6 For the Resident Subsistence Farmer (adult and child), one non-carcinogenic sediment COC (antimony) 7 and two carcinogenic sediment COCs were identified including: one metal (arsenic), and one SVOC 8 [benzo(b)fluoranthene]. 9 10 Arsenic is also identified as a sediment (adult only) and surface water (adult and juvenile) COC for the 11 Trespasser. 12 13 3.3.2.3 COCs in Groundwater 14 15 The Fire/Dust Suppression Worker is not exposed to groundwater. 16 17 One groundwater COC (arsenic) was identified in the HHRA for the Resident Subsistence Farmer (adult 18 and child). 19 20 3.3.3 Target Risk for Preliminary Cleanup Goals 21 22 A TR of 1E-05 and THI of 1.0 are identified as appropriate for establishing preliminary cleanup goals for 23 soil at EBG based on the small number of COCs present and the types of COCs (carcinogenic or non-24 carcinogenic) as summarized below. 25 26 The Fire/Dust Suppression Worker is the representative receptor for EBG. No COCs were identified for 27 this receptor. Two soil COCs (both carcinogens) were identified for the Resident Subsistence Farmer. Of 28 these two COCs, one (arsenic) potentially produces respiratory system tumors while the other 29 [benzo(a)pyrene] is associated with stomach tumors. Based on these results, a chemical-specific TR of 30 1E-05 and THI of 1.0 were identified as appropriate for establishing preliminary cleanup goals for soil at 31 EBG. 32 33 Three sediment COCs (one non-carcinogen and two carcinogens) were identified for the Resident 34 Subsistence Farmer. Of the two carcinogenic COCs, one (arsenic) potentially produces respiratory 35 system tumors while the other [benzo(b)fluoranthene] is associated with stomach tumors. Based on these 36 results, a chemical-specific TR of 1E-05 and THI of 1.0 were identified as appropriate for establishing 37 preliminary cleanup goals for sediment at EBG. 38 39 Only two surface water COCs and one groundwater COCs were identified at EBG; therefore, a chemical-40 specific TR of 1E-05 and THI of 1.0 were also identified as appropriate for establishing preliminary 41 cleanup goals for these media at EBG. 42 43


3.3.4 Preliminary Cleanup Goals 1 2 3.3.4.1 Soil Preliminary Cleanup Goals 3 4 No soil COCs were identified for the Fire/Dust Suppression Worker; therefore, no preliminary cleanup 5 goals are identified for this receptor. 6 7 Risk-based cleanup goals calculated in the HHRA for COCs in soil, background concentrations for 8 inorganics, and preliminary cleanup goals for the Resident Subsistence Farmer are presented in Table 3-2. 9 10

Table 3-2. Soil Preliminary Cleanup Goals for Resident Subsistence Farmer Scenario at EBG 11

EPC (mg/kg) Risk-Based Cleanup Goal from

HHRA (mg/kg) Background

(mg/kg)

Preliminary Cleanup Goal

(mg/kg) Adult Child

COC Surfacea Sub

surfacea HI

= 1.0ILCR

= 1E-05HI

= 1.0 ILCR

= 1E-05 Surface Sub

surface SurfaceaSub

surfacea Inorganics

Arsenic 11 9.3 130 6.7 22 5.7 15 20 15 20 Semivolatiles

Benzo(a)pyrene 0.32 0.068 -- 0.59 -- 0.97 NA NA 0.59 0.59 a Shallow (0 to 1 ft below ground surface) surface soil and subsurface (1-3 ft bgs) soil are used for Resident Subsistence Farmer. 12 b Final facility-wide background values for the Ravenna Army Ammunition Plant from the Phase II Remedial Investigation Report for the 13 Winklepeck Burning Grounds at the Ravenna Army Ammunition Plant, Ravenna, Ohio (USACE 1999). 14 -- = Toxic endpoint not evaluated for this COC. 15 COC = chemical of concern 16 HHRA = human health risk assessment 17 HI = hazard index 18 ILCR = incremental lifetime cancer risk 19 NA = Not applicable. Background concentrations are used for inorganic COCs only. 20 21

Estimated EPCs of arsenic and benzo(a)pyrene are less than the preliminary cleanup goals for these 22 COCs for the Resident Subsistence Farmer Scenario. 23 24 3.3.4.2 Surface Water and Sediment Preliminary Cleanup Goals 25 26 Risk-based cleanup goals calculated in the HHRA for COCs in surface water, background concentrations 27 for inorganics, and preliminary cleanup goals for the Fire/Dust Suppression Worker are presented in 28 Table 3-3. 29

30

31

32

33

34

35


Table 3-3. Surface Water Preliminary Cleanup Goals for Fire/Dust Suppression Worker at EBG 1

Risk-Based Cleanup Goal from HHRA (mg/L)

COC

EPC

(mg/L) HI = 1.0 ILCR = 1E-05

Backgrounda

(mg/L)


(mg/L) Inorganics

Arsenic 0.072 4.1 0.25 0.0032 0.25 a Final facility-wide background values for the Ravenna Army Ammunition Plant from the Phase II Remedial Investigation Report for the 2 Winklepeck Burning Grounds at the Ravenna Army Ammunition Plant, Ravenna, Ohio (USACE 1999). 3 COC = chemical of concern 4 EPC = Exposure point concentration. 5 HHRA = human health risk assessment 6 HI = hazard index 7 ILCR = incremental lifetime cancer risk 8 NA = Not applicable. Background concentrations are used for inorganic COCs only. 9 10

The EPC for arsenic in surface water is less than the preliminary cleanup goal for this metal for the 11 Fire/Dust Suppression Worker. 12 13 Risk-based cleanup goals calculated in the HHRA for COCs in surface water, background concentrations 14 for inorganics, and preliminary cleanup goals for the Resident Subsistence Farmer are presented in Table 15 3-4. 16 17 Table 3-4. Surface Water Preliminary Cleanup Goals for Resident Subsistence Farmer Scenario at EBG 18

Risk-Based Cleanup Goal from HHRA (mg/L) Adult Child

COC

EPC

(mg/L) HI

= 1.0 ILCR

= 1E-05 HI

= 1.0 ILCR

= 1E-05

Backgrounda

(mg/L)


(mg/L) Inorganics

Arsenic 0.072 0.17 0.0089 0.042 0.011 0.0032 0.0089 Manganese 9.9 6.0 -- 2.6 -- 0.39 2.6

a Final facility-wide background values for the Ravenna Army Ammunition Plant from the Phase II Remedial Investigation Report for the 19 Winklepeck Burning Grounds at the Ravenna Army Ammunition Plant, Ravenna, Ohio (USACE 1999). 20 -- = Toxic endpoint not evaluated for this COC. 21 COC = chemical of concern 22 EPC = Exposure point concentration. 23 HHRA = human health risk assessment 24 HI = hazard index 25 ILCR = incremental lifetime cancer risk 26 NA = Not applicable. Background concentrations are used for inorganic COCs only. 27 28

No sediment COCs were identified for the Fire/Dust Suppression Worker; therefore, no preliminary 29 cleanup goals are identified for this receptor. 30 31 Risk-based cleanup goals calculated in the HHRA for COCs in sediment, background concentrations for 32 inorganics, and preliminary cleanup goals for the Resident Subsistence Farmer are presented in Table 3-5. 33 34

35

36


Table 3-5. Sediment Preliminary Cleanup Goals for Resident Subsistence Farmer Scenario at EBG 1

Risk-Based Cleanup Goal from HHRA (mg/kg)

Adult Child

COC EPC

(mg/kg) HI

= 1.0 ILCR

= 1E-05 HI

= 1.0 ILCR

= 1E-05 Backgroundb

(mg/kg)

Preliminary Cleanup

Goal (mg/kg)

Inorganics Arsenic 14 130 6.7 22 5.7 20 20 Antimony 160 250 -- 31 -- 0b 31

Semivolatiles Benzo(b)fluoranthene 0.64 -- 5.9 -- 9.7 NA 5.9

a Final facility-wide background values for the Ravenna Army Ammunition Plant from the Phase II Remedial Investigation Report for the 2 Winklepeck Burning Grounds at the Ravenna Army Ammunition Plant, Ravenna, Ohio (USACE 1999). 3 bAntimony was not detected in background sediment samples; therefore, background criterion is set to 0 mg/kg. 4 -- = Toxic endpoint not evaluated for this COC. 5 COC = chemical of concern 6 EPC = Exposure point concentration. 7 HHRA = human health risk assessment 8 HI = hazard index 9 ILCR = incremental lifetime cancer risk 10 NA = Not applicable. Background concentrations are used for inorganic COCs only. 11 12 Estimated EPCs for arsenic and benzo(b)fluoranthene in sediment are less than the preliminary cleanup 13 goals for these COCs for the Resident Subsistence Farmer Scenario. 14 15 3.3.4.3 Groundwater Preliminary Cleanup Goals 16 17 Risk-based cleanup goals calculated in the HHRA for COCs in groundwater, background concentrations 18 for inorganics, and preliminary cleanup goals for the Resident Subsistence Farmer are presented in Table 19 3-6. 20 21 Table 3-6. Groundwater Preliminary Cleanup Goals for Resident Subsistence Farmer Scenario at EBG 22

Risk-Based Cleanup Goal from HHRA (mg/L)

Adult Child

COC

EPC

(mg/L) HI

= 1.0 ILCR

= 1E-05 HI

= 1.0 ILCR

= 1E-05

Backgrounda

(mg/L)


(mg/L) Inorganics

Arsenic 0.029 0.011 0.00057 0.0031 0.00081 0.012 0.012 a Final facility-wide background values for the Ravenna Army Ammunition Plant from the Phase II Remedial Investigation Report for the 23 Winklepeck Burning Grounds at the Ravenna Army Ammunition Plant, Ravenna, Ohio (USACE 1999). A value of 0 is used for metals not 24 detected. 25 COC = chemical of concern 26 EPC = Exposure point concentration. 27 HHRA = human health risk assessment 28 HI = hazard index 29 ILCR = incremental lifetime cancer risk 30 NA = Not applicable. Background concentrations are used for inorganic COCs only. 31 32


3.3.5 Risk Management Considerations 1 2 3.3.5.1 Soil 3 4 No soil COCs were identified for the representative receptor in the HHRA; therefore, no COCs are 5 identified for evaluation of remedial alternatives in this FS. 6 7 Two soil COCs [arsenic and benzo(a)pyrene] were identified in the HHRA for the Resident Subsistence 8 Farmer. Neither of these COCs are identified for evaluation of remedial alternatives in this FS for 9 unrestricted land use because the EPCs in shallow surface (0-1 ft bgs) and subsurface (1-3 ft bgs) soil are 10 less than the preliminary cleanup goals for these chemicals for the Resident Subsistence Farmer Scenario 11 (Table 3-7). 12 13 3.3.5.2 Sediment and Surface Water 14 15 No sediment COCs were identified for the representative receptor in the HHRA. 16 17 Three subaqueous sediment COCs [antimony, arsenic, and benzo(b)fluoranthene] were identified for a 18 residential receptor in the HHRA. Antimony is identified as a COC for evaluation of remedial 19 alternatives for unrestricted land use. Arsenic and benzo(b)fluoranthene are not identified as COCs for 20 evaluation of remedial alternatives for unrestricted land use because the EPCs for these chemicals in 21 sediment are less than the preliminary cleanup goals for the Resident Subsistence Farmer Scenario (Table 22 3-7). 23 24 No surface water COCs are identified for evaluation of remedial alternatives for restricted or unrestricted 25 land use because arsenic and manganese generally are not present above background in the surrounding 26 soil or underlying sediment indicating no AOC-related source to the surface water. 27 28 3.3.5.3 Groundwater 29 30 No groundwater COCs are identified for evaluation of remedial alternatives for the representative 31 receptor because the Fire/Dust Suppression Worker is not exposed to groundwater. 32 33 No groundwater COCs are identified for evaluation of remedial alternatives for unrestricted land use 34 because, while the EPC for arsenic exceeds the preliminary cleanup goal established for the Resident 35 Subsistence Farmer (Table 3-8); the average concentration does not. Detected concentrations of arsenic 36 are similar to background in the overlying soil/sediment indicating no AOC-related source to the 37 groundwater. 38 39


Table 3-7. Soil and Sediment COCs for Evaluation of Remedial Alternatives for Unrestricted Land Use at EBG 1

Measured Concentration (mg/kg)

COCa Freq. of Detect Avg. Maxb EPCc

Bkgd (mg/kg)

Detects > Bkge

Preliminary Cleanup

Goalf (mg/kg)

Detects > Preliminary

Cleanup Goale Risk Management Considerations Recg

Shallow Surface Soil(0-1 ft bgs) Arsenic 69/69 9.2 26 11 15 7 15 7 EPC less than background/preliminary cleanup goal NC Benzo(a)pyrene 12/66 0.26 1.8 0.32 NA NA 0.59 1 EPC less than preliminary cleanup goal NC

Subsurface Soil(1-3 ft bgs) Arsenic 42/42 8.1 19 9.3 20 0 20 0 EPC less than background/preliminary cleanup goal NC Benzo(a)pyrene 3/42 0.21 0.068 0.068 NA NA 0.59 0 All detects less than preliminary cleanup goal NC

Sediment

Antimony 31/92 87 3160 156 0 31 31 11

Exceeds background and preliminary cleanup goal in soil/sediment

FSCOC

Arsenic 92/92 12 119 14 20 10 20 10 EPC less than background/preliminary cleanup goal NC Benzo(b)fluoranthene 9/92 0.54 0.70 0.64 NA NA 5.9 0 All detects less than preliminary cleanup goal NC

aChemical of concern (COC) identified in the HHRA. 2 bMaximum detected concentration. 3 cExposure point concentration (EPC) is 95th percent upper confidence limit (UCL95) or maximum detected concentration depending on number of samples and data distribution. 4 d Final facility-wide background values for the Ravenna Army Ammunition Plant from the Phase II Remedial Investigation Report for the Winklepeck Burning Grounds at the Ravenna Army Ammunition Plant, 5 Ravenna, Ohio (USACE 1999). Chemicals not detected in background are assigned a value of 0. 6 eNumber of detected concentrations exceeding the background criterion or preliminary cleanup goal. 7 fPreliminary cleanup goal from Table 3-2. 8 gRecommendation for COCs for evaluation of remedial alternatives. 9 FSCOC = COC for evaluation of remedial alternatives. 10 NA = not applicable. Background criteria are used only for naturally occurring inorganic constituents. 11 NC = not recommended as a COC for remedial alternative evaluation. 12 13 14


Table 3-8. Surface Water and Groundwater COCs for Remedial Alternatives for Representative Receptor 1 (Fire/Dust Suppression Worker) and Unrestricted Land Use at EBG 2

Measured Concentration (mg/L)

COCa Freq. of Detect Avg. Maxb EPCc

Bkgd (mg/L)

Detects > Bkge

Preliminary Cleanup

Goalf (mg/L)

Detects > Preliminary

Cleanup Goale Risk Management Considerations Recg

Surface Water – Representative Receptor (Fire/Dust Suppression Worker)

Arsenic 26/ 26 0.019 0.12 0.072 0.0032 18 0.25 0 EPC and all detects less than preliminary cleanup goal

NC

Surface Water – Resident Subsistence Farmer Arsenic 26/ 26 0.019 0.12 0.072 0.0032 18 0.0089 11 No AOC-related source from soil NC Manganese 25/ 26 2.4 11 9.9 0.39 16 2.6 7 No AOC-related source from soil NC

Groundwater– Resident Subsistence Farmer Arsenic 8/ 8 0.011 0.029 0.029 0.012 3 0.00057 8 No AOC-related source from soil NC

aChemical of concern (COC) identified in the HHRA. 3 bMaximum detected concentration. 4 cExposure point concentration (EPC) is 95th percent upper confidence limit (UCL95) or maximum detected concentration depending on number of samples and data distribution. 5 d Final facility-wide background values for the Ravenna Army Ammunition Plant from the Phase II Remedial Investigation Report for the Winklepeck Burning Grounds at the Ravenna Army Ammunition Plant, 6 Ravenna, Ohio (USACE 1999). 7 eNumber of detected concentrations exceeding the background criterion or preliminary cleanup goal. 8 fPreliminary cleanup goal from Tables 3-3, 3-4, and 3-5. 9 gRecommendation for COCs for evaluation of remedial alternatives. 10 NA = not applicable. Background criteria are used only for naturally occurring inorganic constituents. 11 NC = not recommended as a COC for remedial alternative evaluation. 12 13


3.3.5.4 Summary of COCs for Evaluation of Remedial Alternatives 1 2 A summary of the COCs and preliminary cleanup goals for the COCs identified for evaluation of 3 remedial alternatives is provided below and in Table 3-9 for the representative receptor and unrestricted 4 land use. 5 6 Table 3-9. Summary of COCs and Preliminary Cleanup Goals for Evaluation of Remedial Alternatives 7

for EBG 8

COC

Soil Preliminary

Cleanup Goal (mg/kg)

Sedimenta Preliminary

Cleanup Goal (mg/kg)

Surface Water Preliminary

Cleanup Goal (mg/L)

Groundwater Preliminary

Cleanup Goal (mg/L)

Representative Land Use (Restricted Access – Fire/Dust Suppression Worker) None -- -- -- --

Unrestricted Land Use (Resident Subsistence Farmer) Antimony -- 31 -- --

aSediment at EBG is subaqueous. 9 -- = Chemical is not a COC for evaluation of remedial alternatives in the FS for this medium. 10 COC = Chemical of concern. 11 12 13 3.4 ECOLOGICAL PROTECTION 14 15 The ERA performed for EBG is available in the RI Report and summarized in Section 2 of this FS. Ohio 16 EPA Levels I, II, and III were performed for EBG and show observed concentrations and TRVs where 17 HQs exceed one. The ERA in the EBG RI Report identifies a variety of ecological receptor populations 18 that could be at risk and identify the COPECs and COECs that could contribute to potential risks from 19 exposure to contaminated media. 20 21 The ERA for EBG also reported the ecological field work conducted at each site: ecological 22 reconnaissance of existing vegetation and animal life and Ohio Rapid Assessment for Wetlands that 23 involved a systematic documentation of the wetland quantity and quality that resulted in a numerical 24 score. These findings were published in the RI Report and are summarized in Section 3.4.2.1 of this FS. 25 A facility-wide biology and surface water study provides further information for consideration at EBG. 26 This information has been published in a separate report (USACE 2005a) and summarized in the RI 27 Report with a further short summary in this FS. All the studies document the presence of healthy and 28 functioning terrestrial and aquatic ecosystems. 29 30 These two pieces of information, risk assessment predictions (e.g., hazard quotients [HQs]) and field 31 observations, were combined in weight-of-evidence assessments. This combination of information shows 32 that (1) while ESV exceedance and HQs being greater than one suggest risk to plants and selected 33 animals at each AOC, (2) the field observations reveal the ecological system with the plants and animals 34 is functioning well and organisms appear to be healthy. Further, where surface water is involved, the use 35 attainments are being met per Ohio guidance. Because of the combined finding that ecological systems 36 are healthy as well as other reasons; no ecological preliminary cleanup goals are recommended and no 37


remediation for ecological risks is justified at EBG. The rationale for this is explained and summarized 1 below. 2 3 3.4.1 Ecological Preliminary Cleanup Goals for EBG 4 5 Ohio EPA guidance (Ohio EPA 2003) allows decisions regarding the need for remediation to be made at 6 the completion of each level of the ERA process. The remedial alternatives evaluation process includes 7 the development of preliminary remediation goals (PRGs) or COEC concentrations used to define areas 8 where remediation is needed to achieve protectiveness for ecological resources. A decision whether it is 9 necessary to remediate because of potential harm to ecological receptors and whether it is necessary to set 10 PRGs for ecological receptors at EBG is not included in the RI Report. The following weight-of-11 evidence discussions provide input for that decision. A Level II SERA and a Level III BERA was 12 conducted at EBG. 13 14 It is recommended that no quantitative preliminary cleanup goals to protect ecological receptors be 15 developed at EBG. This recommendation is based principally on three major conclusions: 16 17 • Field observations indicate that there are currently few adverse ecological effects, and there is ample 18

nearby habitat to maintain ecological communities at EBG and elsewhere on RVAAP/RTLS. These 19 observations imply that remediation to protect ecological resources is not necessary. 20

21 • Soil HQs are generally not highly elevated and impacts to ecological resources such as populations 22

and communities are not expected. 23 24 • Removal of soil or sediment to further reduce any adverse ecological effects would destroy habitat 25

without substantial benefit to the ecological resources at EBG. 26 27 Stewardship of the environment will be a major consideration in all phases of planning, design, and 28 implementation of the military mission at EBG. Presently, ecological risk is possible albeit the HQs are 29 mostly less than 1 and, if not, mostly less than 60 for conservative scenarios (aluminum and iron 30 excluded). Biological measurements showing a quality wetland and functioning aquatic ecosystem near 31 EBG corroborate the generally low HQs (i.e., low ecological risk). Any chemical remediation for 32 ecological protection must be balanced by the negative consequences to the physical habitat. 33 Remediation is likely to destroy valuable habitat, especially high quality wetland. Considering the rather 34 low concentrations of many COECs and the lack of readily observed harm to the environment, 35 remediation or habitat destruction is not justified at EBG. 36 37 3.4.2 Ecological Cleanup Goal Development Weight of Evidence 38 39 This section provides a rationale for why remediation for protection of ecological receptors, and the 40 associated development of quantitative preliminary cleanup goals, is not warranted for ecological risks at 41 this time. The rationale has the following elements: 42 43


• Onsite or near-site field studies show a healthy aquatic ecosystem and full attainment status 1 according to Ohio EPA guidance despite the BERA indication of risks to ecological receptors 2 based on HQs above 1. 3

4 • Soil HQs are generally not highly elevated. 5

6 • No unique ecological resources are found at EBG, and nearby habitat offers home ranges for 7

wildlife. 8 9

• Significant contaminant migration is not expected to occur from soil to nearby aquatic 10 environments. 11

12 • Mitigations are of two types (chemical and physical) where removal of impacted soil/sediment 13

(i.e., chemical) would lower the exposure and ecological risk and physical alteration such as 14 vegetation removal is a trade-off. 15

16 Each of these elements is explained below regarding the need for ecological preliminary cleanup goals or 17 remediation to protect ecological receptors and a recommendation follows. 18

19 3.4.2.1 Ecological Reconnaissance, EPA/USACE Biology and Surface Water Study, and Wetland 20

Assessment Show Functioning Ecological System 21 22

Level IV of the ERA process (Ohio EPA 2003) is an evaluation of exposures and any observable adverse 23 ecological effects at the site. Observation of a healthy ecological community can mitigate the conclusions 24 resulting from risk calculations based on theoretical exposure models. Although a Level IV risk 25 assessment was not done, some field observations have been made at EBG. These observations indicate 26 that despite the presence of COPECs, little adverse ecological effect has occurred at the site. 27 28 Ecological Reconnaissance 29 30 Vegetation and animals are found at EBG, descriptions of which are detailed in the RI Report (USACE 31 2005d): Briefly, vegetation consists of old-field communities with corridors and relatively large patches 32 of forest vegetation. Animals consist of soil invertebrates, many species of insects, mammals, including 33 nearby beavers, and birds. However, no known threatened and endangered species or unique natural 34 resources are present at EBG; substantiation of this is provided in Section 7 (ERA, natural resources 35 section) of the RI Report for EBG. Therefore, National Guard land use (restricted access with dust/fire 36 suppression and hunting) would be carried out in an environment in which the minor impact would be 37 limited to “normal” ecological resources. 38

39 Surface water represents a dominant part of EBG. The surface water attracts many types of life, 40 including waterfowl and fish. The adjacent wetlands constitute a high quality habitat as shown by the 41 Ohio Rapid Assessment Method. 42

43


EPA/USACE Biology and Surface Water Study 1

2 A facility-wide surface water investigation has been completed by USACE with cooperation of Ohio 3 EPA. In the investigation, water and sediment samples were taken from locations along major streams 4 and tributaries, ponds, and wetlands throughout RVAAP/RTLS at locations that could have been 5 impacted by former facility activities and sites where the streams entered RVAAP/RTLS. Fish were 6 caught, identified, and released in the sampling locations corresponding to the water and sediment sample 7 locations. Invertebrate biota were collected by Hester-Dendy samplers set in the same locations and by 8 qualitative sampling of organic debris and rocks in the stream reach. Funnel traps were additionally 9 placed in ponds and wetlands for further invertebrate sampling. The pond at EBG was among the 10 sampled water bodies. The details of the study, locations, techniques, and results from this study are 11 published in the Ravenna Facility-wide Surface Water Study: Streams and Ponds (USACE 2005i). 12 13 By way of summary, surface water quality at EBG, although slightly exceeding several chronic water 14 quality criteria (WQC), did not appear to impact the biological community. Water quality conditions 15 were comparable to reference ponds. Based on sediment sampling results, moderate contamination was 16 evident at EBG. Particularly noteworthy were elevated levels of several explosive compounds in the 17 sediment. 18 19 Macroinvertebrate communities in EBG were substantially different from the reference wetland Snow 20 Pond, which may be the result of the different plant communities and the soft anoxic sediments at EBG, 21 as well as potential sediment contamination. The fish community was not sampled due to shallow water 22 depth. 23

24 Ohio Rapid Assessment 25 26 The Ohio rapid assessment method for wetlands (Ohio EPA 2001) was applied at EBG. Habitat sketches, 27 the scoring boundary worksheet, narrative rating, and quantitative rating are found in Appendix O (Part 1) 28 of the EBG RI Report (USACE 2005d). The total score was 81, which indicates a high-quality wetland 29 habitat. 30 31 Beyond this brief introduction, the following details are provided about the methods and the results from 32 the Ohio Rapid Assessment for Wetlands. Regarding methods, there are six parts: background 33 information (e.g., location, including a map), scoring boundary worksheet (e.g., boundary definition in 34 the field), narrative rating (e.g., identification of type of wetland such as bog, fen, forest wetland, and so 35 forth), quantitative rating (e.g., field measurements about size, sources of water, floodplain information, 36 and numerical score about these characteristics), summary worksheet (self-explanatory), and wetland 37 categorization worksheet (a page of steps to determine the category from 1 to 3). Regarding results, the 38 wetlands at EBG received a total score of 81. This is a rather high score and as stated means that the 39 wetland is of rather high quality. For example, the hydrology score was the maximum of 30 points and 40 other metrics such as soil/sediment and plant communities received high individual scores to make the 41 total of 81. 42 43


3.4.2.2 Low Levels of Soil Contamination 1 2

Terrestrial habitats at EBG do not have the same rigorous level of biological measurements as the aquatic 3 environments; however, most of the soil HQs that exceed 1 are less than 10. Three metals have HQs 4 greater than 10 for low trophic level receptors; chromium (57 for earthworms), aluminum (842 for 5 shrews, 266 for plants, and 221 for rabbits), and iron (2500 for plants). The EPCs for chromium (EPC = 6 23 mg/kg, background = 17 mg/kg) and iron (EPC = 24,900 mg/kg, background = 23,100 mg/kg) are only 7 slightly above background. The EPC for aluminum (13,300 mg/kg) is less than the background criterion 8 (17,700 mg/kg) for this metal. Further the HQs for iron and aluminum are likely overestimates due to 9 low availability of the chemicals for biological uptake from soil (aluminum) or low confidence in the 10 TRV (iron). 11 12 Chromium is an example of a metal that occurs in different chemical forms with different bioavailabilities 13 and toxicities. Chromium exists in different oxidation states, predominantly as trivalent chromium [Cr 14 (III)] and hexavalent chromium [Cr (VI)]; Cr (III) is less bioavailable and less toxic than Cr (VI). 15 Natural Cr (VI) is rare in nature (James 2002), and, indeed, Cr (VI) was not detected in the soil samples. 16 Nearly all naturally occurring chromium is in the form of the Cr+3 (chromic) cation, which is in the Cr 17 (III) oxidation state. Compounds of Cr (III) such as chromic acetate [Cr (CH3O2)3] or chromic sulfate 18 [Cr2 (SO4)3] are soluble in water because they disassociate into Cr+3 ions and the corresponding anions 19 (e.g., acetate and sulfate), which are soluble. However, Cr+3 ions react with negatively charged ions in 20 soil and sediment and can form insoluble precipitates, which are not bioavailable. For example, Cr+3 21 reacts readily with hydroxide ions (OH-) to form Cr(OH)3, which has a solubility of about 5 × 10-8 μg 22 Cr/L at pH 8 (James 2002) and is, therefore, not bioavailable. Some chromates, especially BaCrO4, 23 HgCrO4, and PbCrO4 are also very poorly soluble in water (Clifford 1961) and, therefore, are not readily 24 bioavailable. Thus, Cr(III) forms insoluble compounds in soil that are not bioavailable. 25 26 3.4.2.3 Nearby Habitats Offer Home Ranges to Wildlife 27 28 As stated above, ecological resources are “normal,” and nearby terrestrial and aquatic habitats are 29 available to receive any wildlife that may leave EBG. Very little vegetation is expected to be removed 30 from within EBG. Old-field vegetation could be mowed or cleared in another way to make access to the 31 pond. Wildlife could be disturbed by the movement and noise of equipment as well as operations. 32 Wildlife can leave and enter adjacent old fields and forest patches and vegetative corridors and other 33 ponds. As inferred earlier, RVAAP/RTLS has thousands of acres of habitat like that at EBG, and wildlife 34 can find new home ranges there; therefore, any lack of protection as a result of not developing and 35 applying ecological preliminary cleanup goals would be minimal because sufficient reservoirs of habitat 36 and wildlife exist to maintain RVAAP/RTLS-wide ecological communities. 37 38 3.4.2.4 No to Low Contaminant Migration 39 40 The facility-wide surface water sampling and assessment revealed that, in general, surface water quality 41 in the streams at RVAAP/RTLS was good to excellent with few exceedances of Ohio Water Quality 42 Standards criteria. However, this does not preclude investigating surface water and sediment on an 43 individual basis as required by Ohio EPA. 44


At EBG, offsite migration is possible because water can theoretically move offsite. However, the pond 1 lies in depressions with beaver dams adding to the retention of water. There could be onsite contaminant 2 movement, and this is of such importance that a qualitative assessment was made. 3 4 Several lines of evidence and reasoning suggest that soil constituents are unlikely to result in higher 5 exposure and higher HQs for aquatic receptors in the future at EBG. First, site conditions – slope, soil 6 type, plant cover - are not conducive to erosion. Second, there is indication that only a few organic 7 compounds in soil are presently leaching to surface water and sediment in the pond, and this may apply to 8 inorganics as well. Most importantly, site conditions are unlikely to change in a way that would lead to 9 increases in surface water or sediment concentrations as a result of erosion or leaching from the soil. 10 Because current conditions appear not to be causing adverse impacts, future conditions are unlikely to 11 pose an increase in exposure and risk to aquatic ecological receptors. Each of these three lines of 12 evidence is discussed in more detail below. 13 14 One, the transport by erosion of soil constituents to surface water or sediment in ponds at EBG is likely to 15 be small. The site has predominately short slope lengths and low slope (See Figure 2-5), with the one 16 exception being the steep sides of the former railroad bed. The Sebring soils of the EBG, which is 17 located in the northeastern portion of the RVAAP/RTLS, have moderate erodibility (0.34), but high forest 18 and understory cover reduce by several orders of magnitude the potential soil loss that could result from 19 rainfall levels typical of temperate regions (42 inches/year). Soil loss, with its adsorbed chemical load, is 20 thus not expected to be a large future source of contaminants to the pond. 21 22 Two, future transport by leaching of soil constituents to surface water or sediment in EBG ponds is also 23 likely to be small for most organics and many inorganic chemicals. The affinity of a chemical for soil is 24 characterized by a partitioning coefficient. For organics, the coefficient used is the organic 25 carbon-partitioning coefficient (KOC), which is defined as the ratio of the concentration of the chemical 26 associated with soil organic carbon (mg/kg carbon) to the equilibrium concentration in water (mg/L). For 27 inorganics, the coefficient used is the soil-water equilibrium-partitioning coefficient (Kd), which is 28 defined as the ratio of the concentration of the chemical in soil (mg/kg soil) to the equilibrium 29 concentration in water (mg/L). These coefficients were used to make predictions about the potential 30 future concentrations of soil COPECs in surface water and sediment at EBG. 31 32 The potential for an organic constituent in soil to move into surface water is indicated by its KOC. For 33 example, nitrocellulose and acetone are found in both subsurface soil (1-3 ft bgs) and surface water at 34 EBG ponds (Table 3-10). Nitrocellulose has a KOC of 10, and acetone has a KOC of 0.95. In contrast, the 35 semi-volatile organics are found in soil but not in surface water (Table 3-10). These compounds have 36 KOC values ranging between 23,000 and 1,800,000. This suggests that constituents with low affinity for 37 soil are more likely to migrate to surface water than those with high affinity. The same principle applies 38 to inorganics; that is, inorganics with low Kds are more likely to migrate to water than those with high Kd 39 values. 40 41 Table 3-10 lists the site-related constituents and the COPECs identified in the Level II ERA for soil, 42 sediment, and surface water at EBG. Only TNT and two volatiles (acetone and toluene) were found in all 43


three media: soil, sediment, and surface water. Likewise, the few organic constituents and COPECs in 1 surface water and sediment are generally not found in soil (Table 3-10). Organic compounds in soil and 2 sediment would likely remain in place, and in general, organic compounds in soil and sediment are not 3 found in surface water at the EBG. This is consistent with the generally high KOC of organic compounds, 4 0.7% organic carbon content of soil, and the silty clay and clayey silt nature of the Sebring soils at the 5 EBG (USACE 2005d). 6 7 All inorganic constituents, except selenium, silver, and thallium, are found in all three media. One 8 possible explanation for this distribution pattern is that inorganic constituents are more likely to have 9 migrated directly and indirectly from soil to sediment and surface water and to remain there in a dissolved 10 or particulate-bound state. Also, metals are naturally occurring components of soil and sediment. 11 12

Table 3-10. Distribution of COPECs in Environmental Media at EBG 13

Soil

Surface (0-1 ft bgs) Subsurface (1-3 ft bgs) Sediment Surface Water Partitioning Coefficient

Media Summary

Inorganics Kd Kd > 500

Aluminum -- Aluminum Aluminum 1.50E+03a S, Sd, & SWBeryllium Beryllium Beryllium -- 7.90E+02b S & Sd

Lead Lead Lead Lead 9.00E+02b S, Sd, & SWMercury Mercury Mercury Mercury 1.00E+03b S, Sd, & SW

Vanadium -- Vanadium Vanadium 1.00E+03a S, Sd, & SW 10 < Kd < 500

Antimony Antimony Antimony Antimony 4.50E+01b S, Sd, & SWArsenic -- Arsenic Arsenic 2.90E+01b S, Sd, & SWBarium Barium Barium Barium 4.10E+01b S, Sd, & SW

Cadmium Cadmium Cadmium Cadmium 7.50E+01b S, Sd, & SWChromium -- Chromium Chromium 1.90E+01b S, Sd, & SW

Cobalt -- Cobalt Cobalt 4.50E+01a S, Sd, & SWCopper Copper Copper Copper 3.50E+01a S, Sd, & SWCyanide -- Cyanide Cyanide NA S, Sd, & SW

Iron -- Iron Iron 2.50E+01a S, Sd, & SWManganese -- Manganese Manganese 6.50E+01a S, Sd, & SW

Nickel -- Nickel Nickel 6.50E+01b S, Sd, & SWSodium Sodium Sodium Sodium 1.00E+02a S, Sd, & SW

Thallium -- -- -- 7.10E+01b S only Zinc Zinc Zinc Zinc 6.21E+01b S, Sd, & SW

Kd < 10 Calcium -- Calcium Calcium 4.00E+00a S, Sd, & SW

Magnesium -- Magnesium Magnesium 4.50E+00a S, Sd, & SWPotassium -- -- Potassium 5.50E+00a S & SW

Silver -- Silver -- 8.30E+00b S & Sd

14 15 16 17 18


Table 3-10. Distribution of COPECs in Environmental Media at EBG (continued)

Soil


Media Summary

Organics-Explosives KOC KOC > 500

2,4,6-Trinitrotoluene 2,4,6-Trinitrotoluene 2,4,6-Trinitrotoluene 2,4,6-Trinitrotoluene 1.83E+03c S, Sd, & SW-- -- -- HMX 1.85E+03c SW only 10 < KOC < 500

-- -- -- 1,3-Dintrobenzene 2.06E+01b SW only -- -- 2,6-Dinitrotoluene -- 4.19E+01b Sd only

2-Amino- 4,6-dinitro toluene -- -- -- 4.19E+01d S only

-- -- -- 3-Nitrotoluene 4.27E+02e SW only 4-Nitrotoluene -- -- -- 4.27E+02e S only

4-Amino- 2,6-dinitro toluene

-- -- -- 4.19E+01d S only

-- -- Nitrobenzene -- 1.19E+02 b Sd only KOC < 10

Nitrocellulose Nitrocellulose Nitrocellulose Nitrocellulose 1.00E+01c S, Sd, & SWOrganics-Semivolatiles KOC KOC > 500

2-Methylnapthalene -- -- -- 4.47E+03f S only Acenaphthylene -- -- -- 6.76E+03f S only

Anthracene -- -- -- 2.35E+04b S only -- -- Aroclor-1254 -- 4.48E+04c Sd only

Benzo(a)anthracene Benzo(a)anthracene Benzo(a)anthracene -- 2.60E+05b S & Sd Benzo(a)pyrene Benzo(a)pyrene Benzo(a)pyrene -- 9.69E+05b S & Sd

Benzo(b)fluoranthene Benzo(b)fluoranthene Benzo(b)fluoranthene -- 8.36E+05b S & Sd Benzo(g,h,i)perylene -- Benzo(g,h,i)perylene -- 1.82E+06f S & Sd

Benzo(k)fluoranthene Benzo(k)fluoranthene Benzo(k)fluoranthene -- 8.32E+05g S & Sd Bis

(2-ethylhexyl)phthalate Bis

(2-ethylhexyl)phthalateBis

(2-ethylhexyl)phthalate-- 1.11E+05g S & Sd

-- -- Butylbenzylphthalate -- 9.36E+03c Sd only Carbazole -- Carbazole -- 1.13E+04c S & Sd Chrysene Chrysene Chrysene -- 2.97E+05b S & Sd

Dibenzo(a,h)anthracene -- -- -- 1.79E+06b S only -- -- Di-n-butylphthalate -- 1.46E+03c Sd only

Fluoranthene Fluoranthene Fluoranthene -- 4.91E+04b S & Sd -- -- Fluorene -- 7.71E+03b Sd only

Indeno(1,2,3-cd) pyrene Indeno(1,2,3-cd) pyrene Indeno(1,2,3-cd) pyrene -- 4.11E+06b S & Sd -- -- Methoxychlor -- 8.00E+04b Sd only

Naphthalene -- -- -- 1.19E+03b S only

-- -- N-

nitrosodiphenylamine -- 5.62E+03c Sd only Phenanthrene Phenanthrene Phenanthrene -- 2.09E+04g S & Sd

Pyrene Pyrene Pyrene -- 6.80E+04b S & Sd 10 < KOC < 500


Table 3-10. Distribution of COPECs in Environmental Media at EBG (continued)

Soil


Media Summary

-- -- -- Phenol 2.20E+01b SW only KOC < 10

-- -- -- 4-Methylphenol 4.34E+00c SW only Organics-Volatiles KOC 10 < KOC < 500

-- -- -- Carbon disulfide 5.14E+01b SW only -- -- -- Chloroform 5.30E+01b SW only -- -- -- Chloromethane 6.00E+01b SW only

Toluene Toluene Toluene Toluene 1.40E+02b S, Sd, & SW KOC < 10

-- -- 2-Butanone -- 2.34E+00b Sd only Acetone Acetone Acetone Acetone 9.51E-01b S, Sd, & SW

Methylene chloride Methylene Chloride -- -- 1.00E+01b S only

COPEC = constituent of potential ecological concern retained based on Data and Media Evaluation as reported in EBG RI Report Tables O-5 1 through O-8 (SAIC 2005a ). 2 S = Surface Soil, Sd = Sediment, SW = Surface water 3 Bold font indicates retained Level II COPEC based on potential toxicity and bioaccumulation hazard as reported in EBG RI Report Tables O-9 4 through O-12 (SAIC 2005a). 5 a Baes et al. (1984). 6 b Section 5 and/or Appendix A-3 of the Human Health Risk Assessment Protocol (EPA 1998). 7 c Calculated using EPA EpiSuite; see http://www.epa.gov/oppt/exposure/docs/episuitedl.htm. 8 d Value for 2,6-Dinitrotoluene from Baes et al. (1984). 9 e Value for 2-Nitrotoluene from Mackay et al. (1992). 10 f Mackay et al. (1992). 11 g Errata to Human Health Risk Assessment Protocol (EPA 1999a). 12 13 Three, the strongest argument for concluding that current concentrations of constituents in soil do not 14 pose an increased future risk to ecological receptors exposed to surface water and sediment in EBG ponds 15 is that the current conditions are not adverse and in the pond and the adjacent wetland are functioning 16 well and nothing is expected to change. For example, the wetland assessment rated the EBG wetland as 17 high quality. Also, the results of the macroinvertebrate survey at the EBG from the site-wide biological 18 and surface water study indicate that the EBG pond is high quality habitat. This is not surprising, given 19 that sufficient rain has fallen and time lapsed since operations ceased at the site for labile soil constituents 20 to have already leached to deep soil horizons or migrated to the ponds and, from there, their ultimate sink 21 offsite or in the sediment. More recalcitrant constituents are likely to continue to remain in the soil or be 22 released so slowly as to be in equilibrium with losses from the system. Likewise, water levels have 23 undoubtedly fluctuated seasonally and annually with fluctuations in rainfall and the constructive and 24 destructive activities of beavers and humans, respectively, for low lying areas to be wetted and dried 25 enough times to have mobilized most soil constituents that can be mobilized. 26 27 By way of summary, the qualitative evaluation of the interaction between land and water at EBG is 28 comprehensive and provides a feasible explanation of why soil impacts to water are not going to increase 29 in the future at EBG and, therefore, that the low HQs (Level III computations) and low ecological effects 30 (site-wide biological and water study as well as the wetland study) are not expected to change in the 31


future. Current rates of erosion and leaching are likely small and unlikely to change in the future. 1 Rainfall amounts and water levels in the ponds will likely fluctuate in the future similarly to how they 2 have fluctuated over the past decades since contaminants were released to soil. Therefore, it is likely that 3 there will be no increase in the flux of both organics and inorganic COPECs from soil to the ponds in the 4 future and no increase in HQs for aquatic receptors. 5 6 3.4.2.5 Mitigation Trade-Off of Reducing Ecological Risk but Harming Environment 7 8 There is a trade-off of two kinds of ecological risk: physical alterations and residual contamination. That 9 is, the localized ecosystem either can have clean soil/sediment because of removal and replacement but 10 have a highly disturbed habitat as a result, or it can have exposure to contaminants in a habitat that is 11 minimally disturbed. In some cases, it can be appropriate to allow plants and animals low in the food 12 chain to be exposed to somewhat toxic concentrations, sparing important habitat, if animals higher in the 13 food chain (especially top carnivores) are not receiving toxic exposures. In the case of EBG activities, 14 the military mission does not require activities that will alter habitat or create high noise levels, thereby, 15 not resulting in much change to the presence and the exposure of ecological receptors. 16 17 There may be little benefit to removing contaminated media because COPEC concentrations are not 18 necessarily at harmful levels according to the field investigations. For example, of the 11 metal COPECs 19 in soil (Table 3-10), four, including iron and aluminum, have concentrations below 3 times background 20 criteria. This small factor means that concentrations are not likely to be an exposure and risk issue. 21 22 In conclusion, any remediation for ecological protection purposes can cause more habitat damage than 23 chemical risk reduction is worth. 24 25 3.5 FATE AND TRANSPORT ASSESSMENT OF COCS IN SOILS 26 27 Impacted soils at EBG also were evaluated to assess their potential to impact groundwater both at the 28 AOC (unrestricted land use exposure scenario) and at an exposure point downgradient of the AOC 29 (restricted land use exposure scenario) to ensure residual concentrations in soils are protective of 30 groundwater under both potential land use exposure scenarios. The process for identifying soil 31 constituents potentially impacting groundwater is detailed in Appendix 3A and summarized below: 32 33

• Assessment started with the soils CMCOPCs and CMCOCs identified in the conservative fate 34 and transport evaluation conducted in the RI. 35

36 • Constituents were assessed across media using AOC-specific analytical data and background 37

information to refine the list of soils CMCOPCs and CMCOCs. 38 39

• Constituents evaluated further if necessary using a refined version of the modeling performed in 40 RIs. The refinements include updated source areas, updated source concentrations, and an 41 updated depth to the water table (averaged over the new source areas) to further define potential 42 for impacted soils to leach to groundwater. 43


3.5.1 Refined Chemical Impacts to Groundwater Assessment 1 2 Based on the results of the Phase II RI for EBG two constituents are evaluated for potential impacts in 3 groundwater beneath the source and both constituents also are evaluated for potential impacts to 4 groundwater at downgradient receptors. Upon further analysis, neither of these constituents were 5 predicted or identified to impact groundwater at the AOC or downgradient of the AOC as summarized 6 below. 7 8

• Arsenic is removed from further consideration of future groundwater impacts because 9 concentrations detected in soils are consistent with background concentrations. Modeling results 10 indicate background levels of arsenic in soils may result in groundwater impacts in excess of the 11 MCL. 12

13 • RDX: RI SESOIL source load modeling with maximum impact predicted in 4 years. Given AOC 14

history (e.g., AOC operations ceased in 1951), the maximum impact likely occurred in the past. 15 RDX is removed from further consideration of future groundwater impacts at EBG because there 16 are only two detections in soils, the predicted time of maximum impact to groundwater is 4 years 17 (so maximum impact has likely passed), and RDX has not been detected in surface water or 18 groundwater samples at EBG. 19

20 3.5.2 Refined AOC-Specific Modeling Results 21 22 Based on the analyses in Section 3A.2.2 of the conservative fate and transport assessment performed in 23 support of the RI for EBG, no COCs were identified for further analysis using the SESOIL/AT123D 24 models previously developed. 25 26 Impacted soils at EBG are not predicted to impact underlying groundwater beneath the AOC. Therefore, 27 soil remediation for protection of groundwater is not required at EBG, and the AOC may be released for 28 unrestricted land use with respect to future groundwater impacts from impacted soils. 29 30 3.6 COCS FOR REMEDIAL ALTERNATIVE EVALUATION AT EBG 31 32 The final list of COCs for evaluation of remedial alternatives was identified for EBG in the previous 33 sections (Sections 3.3, 3.4, and 3.5) based on risk management considerations including: 34 35

• Comparison of EPC to preliminary cleanup goal concentrations (including background 36 concentrations); 37

38 • Comparison of EPC to upgradient concentrations for sediment, surface water, and groundwater; 39

40 • Consideration of soil as the primary source of contamination (i.e., if soil concentrations are 41

below background at an AOC, that AOC is not contributing to contamination in other media); 42 and 43


• Other site-specific and receptor-specific considerations. 1 2 No COCs are identified for the representative receptor at EBG. Antimony is recommended for evaluation 3 of remedial options for subaqueous sediment at EBG for unrestricted land use (Table 3-11). COCs 4 identified in aqueous media (i.e., subaqueous sediment) will be carried forward for an initial screening of 5 technologies in Appendix 5A of this FS Report. 6 7 No COCs are identified in soils/dry sediment for the representative receptor or unrestricted land use, 8 therefore no further action is recommended with respect to soils/dry sediment at EBG. 9 10

Table 3-11. Summary of COCs at EBG 11

Soil Sedimenta Surface Water Groundwater Representative Land Use (Restricted Access – Fire/Dust Suppression Worker)

-- -- -- -- Unrestricted Land Use (Resident Subsistence Farmer)

-- Antimony -- -- aSediment at EBG is subaqueous. 12 -- = Chemical is not a COC for evaluation of alternatives in the FS for this medium. 13 COC = Chemical of concern. 14 15


4.0 APPLICABLE OR RELEVANT AND APPROPRIATE 1

REQUIREMENTS 2

Agencies responsible for remedial actions under CERCLA must ensure selected remedies meet ARARs. 3 The following sections describe proposed ARARs for EBG. 4 5 4.1 INTRODUCTION 6 7 CERCLA Sections 121(d)(1) and (2) provide that remedial actions selected for a site must attain a degree 8 of cleanup of hazardous substances, pollutants, and contaminants that: (1) assures protection of human 9 health and the environment; and (2) complies with ARARs. ARARs are developed in accordance with 10 the statutory and regulatory provisions set forth in CERCLA and the National Contingency Plan (NCP). 11 12 A remedial action will comply with ARARs if the remedial action attains the standard established in the 13 ARAR for a particular hazardous substance. When a hazardous substance, pollutant, or contaminant will 14 remain onsite at the completion of a remedial action, then that substance must meet any limit or standard 15 set forth in any legally ARAR, criteria, or limitation under a federal environmental law. These standards 16 apply unless such standard, requirement, criteria, or limitation is waived in accordance with CERCLA 17 Section 121(d)(4). Any promulgated standard, requirement, criteria, or limitation under a State 18 environmental or facility siting law that is more stringent than any federal standard, requirement, criteria, 19 or limitation, and that has been identified by the state in a timely manner, can be an ARAR as well. 20 21 Regulatory language interpreting and implementing the statutory directive is found in the NCP. One 22 provision, 40 Code of Federal Regulation (CFR) § 300.400(g), provides that the lead agency (United 23 States Department of the Army) and support agency (Ohio EPA) shall identify applicable requirements 24 based upon an objective determination of whether the requirement specifically addresses a hazardous 25 substance, pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA 26 site. Under 40 CFR § 300.430(e), the lead agency has the ultimate authority to decide what requirements 27 are ARARs for the potential remedial activities. 28 29 Identifying ARARs involves determining whether a requirement is legally applicable, and if it is not 30 legally applicable, then whether a requirement is relevant and appropriate. Individual ARARs for each 31 site must be identified on a site-specific basis. Applicable requirements are those cleanup standards, 32 standards of control, and other substantive environmental protection requirements, criteria or limitations 33 promulgated under federal or state environmental or facility siting laws that specifically address a 34 hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance found at a 35 CERCLA site (40 CFR § 300.5). 36 37 If it is determined that a requirement is not legally applicable to a specific release, the requirement may 38 still be relevant and appropriate to the circumstances of the release. Determining whether a rule is 39 relevant and appropriate is a two-step process that involves determining whether the rule is relevant, and, 40 if so, whether it is appropriate. A requirement is relevant if it addresses problems or situations 41


sufficiently similar to the circumstances of the remedial action contemplated. It is appropriate if its use is 1 well suited to the site. 2 3 In addition to ARARs, the lead and support agencies may identify other advisories, criteria, or guidance 4 to be considered for a particular release. The “to be considered” (TBC) category consists of advisories, 5 criteria, or guidance that were developed by USEPA, other federal agencies, or states that may be useful 6 in developing CERCLA remedies. TBCs will be considered as guidance or justification for a standard 7 used in the remediation if no other standard is available for a situation to help determine the necessary 8 level of cleanup for protection of health or the environment. This may occur if no ARAR is available for 9 a particular contaminant or concern, or if there are multiple contaminants and/or multiple pathways not 10 considered when establishing the standards in the ARAR so that use of the ARAR does not allow the 11 remedial action to be protective of human health or the environment. 12 13 While onsite actions must comply with both applicable and relevant and appropriate requirements, offsite 14 actions must comply with only applicable requirements. Also, a determination of relevance and 15 appropriateness may be applied to only portions of a requirement, so that only parts of a requirement need 16 be complied with, whereas a determination of applicability is made for the requirement as a whole, so that 17 the entire requirement must be complied with. 18 19 CERCLA provides for a permit waiver for remedial actions that are conducted onsite and in accordance 20 with the NCP. Although the administrative requirement of permits has been waived by the statute, 21 substantive requirements of rules that would otherwise be enforced through permits are still applicable. 22 The Ohio EPA Division of Emergency and Remedial Response (DERR) has addressed this issue in two 23 policies, one in final form and one in draft form. The policy in final form, Final Policy Number DERR-24 00-RR-001, ARARs, 7/30/1998, states that: “…cleanup projects will not be subject to the administrative 25 requirements of permits, including permit applications, public notice, etc.”, particularly when the cleanup 26 project is governed by an enforcement order. The policy in draft form, Draft Policy Number DERR-00-27 RR-034, Use of ARARs in the Ohio EPA Remedial Response Program, 9/2/03, states that: “It has been 28 DERR’s policy to require responsible parties to acquire and comply with all necessary permits, including 29 all substantive and administrative requirements.” Permit waivers are specifically addressed in Section 30 VII. General Provisions (Paragraph No. 12) of the DFFO: 31 32 “e. It is Ohio EPA’s position that if state law related to a remedial or removal action requires a permit, 33 then a permit must be acquired in accordance with CERCLA Section 120(a)(4). It is Respondent’s 34 position that these Orders implement a CERCLA-based remediation program and that a permit is not 35 required in accordance with CERCLA Section 121(e). The Parties agree that the remedial or removal 36 actions anticipated at the RVAAP are not of the type that routinely require a permit under state law. If 37 Ohio EPA determines that a permit is required for a particular remedial or removal action at the RVAAP, 38 the Parties will meet and attempt in good faith to resolve to [sic] this issue.” 39 40 Any remedial response action at RVAAP must be conducted in accordance with the DFFOs, which 41 provide that, irrespective of ARARs, “all activities undertaken … pursuant to these Orders shall be 42


performed in accordance with the requirements of CERCLA, the NCP, and all other applicable federal 1 and state laws and regulations.” 2 3 4.2 POTENTIAL ARARS FOR EBG 4 5 USEPA classifies ARARs as chemical-specific, action-specific, and location-specific in order to provide 6 guidance for identifying and complying with ARARs (USEPA 1988): 7 8

• Chemical-specific ARARs are health- or risk-based numerical values or methodologies which, 9 when applied to site-specific conditions, allow numerical values to be established. These values 10 establish the acceptable amount or concentration of a chemical that may be found in, or 11 discharged to, the ambient environment (USEPA 1988). 12

13 • Action-specific ARARs are rules, such as performance or design or other activity-based rules, 14

which place requirements or limitations on actions. 15 16

• Location-specific ARARs are rules that place restrictions on the concentration of hazardous 17 substances or the conduct of activities solely because they occur in special locations (USEPA 18 1988). 19

20 As explained in the following paragraph, rules from each of these categories are ARARs only to the 21 extent that they relate to the degree of cleanup. 22 23 CERCLA Section 121 governs cleanup standards at CERCLA sites. ARARs originate in the subsection 24 of CERCLA that specifies the degree of cleanup at each site, CERCLA Section 121(d). In Section 25 121(d)(2), CERCLA expressly directs that ARARs are to address specific contaminants of concern at 26 each site, specifying the level of protection to be attained by any chemicals remaining at the site. 27 CERCLA Section 121(d)(2) provides that with respect to hazardous substances, pollutants, or 28 contaminants remaining onsite at the completion of a remedial action, an ARAR is: 29 30

“any standard, requirement, criteria, or limitation under any Federal environmental law … or any 31 promulgated standard, requirement, criteria, or limitation under a State environmental or facility 32 siting law that is more stringent than any Federal standard, requirement, criteria, or limitation” 33

34 CERCLA Section 121(d)(2) further provides that the remedial action attain a level of control established 35 in rules determined to be ARARs. 36 37 As such, most ARARs will be chemical-specific. Action- or location-specific requirements will be 38 ARARs to the extent that they establish standards addressing contaminants of concern that will remain at 39 the site. In addition, CERCLA Section 121(d)(1) directs that remedial actions taken to achieve a degree 40 of cleanup that is protective of human health and the environment are to be relevant and appropriate 41 under the circumstances presented by the release. Accordingly, any chemical-, action-, or location-42


specific requirements will be ARARs to the extent that they ensure that the degree of cleanup will be 1 protective of human health and the environment under the circumstances presented by the release. 2 3 In summary, chemical-, action-, or location-specific requirements will be ARARs to the extent that they 4 establish standards protective of human health and the environment for chemicals that will remain onsite 5 after the remedial action, and to the extent that they ensure a degree of cleanup which is protective of 6 human health and the environment under the circumstances presented by the release. 7 8 4.2.1 Potential Soil ARARs for RCRA Hazardous Waste 9 10 If soil contamination is determined to be Resource Conservation and Recovery Act (RCRA) hazardous 11 material, certain hazardous waste requirements are triggered. Some RCRA requirements prescribe 12 standards for treatment of hazardous materials. These requirements are generally not ARARs because 13 they do not relate directly to the degree of cleanup or to specific chemicals but rather to the method used 14 to obtain the degree of cleanup. Some RCRA requirements prescribe standards for disposal of hazardous 15 materials. Standards that directly address land disposal may be potential ARARs. These are: (1) land 16 disposal requirements (LDRs) prohibiting disposal of specific chemicals until they are treated to a 17 protective level, and (2) minimum technical requirements (MTRs) for land disposal units. 18 19 USEPA cautions that LDRs should not be used to determine site-specific cleanup levels for soils 20 (USEPA 2002). The purpose of LDRs is to require appropriate treatment of RCRA hazardous wastes that 21 are to be land disposed in order to minimize short and long-term threats to human health or the 22 environment. Performing treatment to meet certain standards is different from the CERCLA approach to 23 remediation, which is analyzing risk and then developing soil cleanup standards based on the risk present, 24 and may result in soil cleanup levels that are different from those of a risk-based approach. Nevertheless, 25 if RCRA hazardous materials are managed in a way that generates RCRA hazardous waste, and if that 26 waste is land disposed onsite, then the material must meet the standards established in the LDRs. 27 28 In order for LDRs to be triggered as potential ARARs, RCRA hazardous waste must be present. This 29 requires: (1) that soil contain contaminants that either derive from RCRA listed wastes or that exhibit a 30 characteristic of RCRA hazardous waste; and (2) that soils are managed in a way that “generates” 31 hazardous waste. Several methods of soil management that do not “generate” hazardous waste and so do 32 not trigger LDRs are available for use. These methods are: the AOC approach, use of a staging pile, use 33 of a storage or treatment corrective action management unit (CAMU), or use of a temporary unit (TU). 34 35 If soils are managed in a manner that generates hazardous waste, such as removing soil to an above-36 ground container, then redepositing the soil within the land unit for disposal, then LDRs become potential 37 ARARs. LDRs attach to the waste at the time that it is removed from the unit under an AOC approach, or 38 at the time that the soil is excavated and lifted out of the unit. Potential LDR ARARs in Ohio are 39 variances from treatment standards at Ohio Administration Code (OAC) § 3745-700-44, LDR standards 40 for contaminated debris at OAC § 3745-47, Universal Treatment Standards at OAC § 3745-270-48, and 41 Alternative Standards for Contaminated Soil at OAC § 3745-270-49. 42 43


Ohio has adopted the alternative soil treatment standards as promulgated by USEPA in its Phase IV LDR 1 rule, effective August 1998. Basically, the rules provide that if RCRA hazardous wastes are present, then 2 the material must meet either one of two sets of LDRs before being disposed in a land unit: (1) the 3 universal treatment standards (UTS); or (2) the contaminated soil (technology-based treatment) standards 4 promulgated in Phase IV of the LDRs, whichever is greater. Or, if a generator so chooses, he may use the 5 generic treatment standards at OAC § 3745-270-40 which apply to all hazardous wastes. Only the 6 alternative soil treatment standards are explained in this document. Under the alternative soil treatment 7 standards, all soils subject to treatment must be treated as follows: 8

9 1. For non-metals, treatment must achieve 90% reduction in total constituent concentration (primary 10

constituent for which the waste is characteristically hazardous as well as for any organic or metal 11 underlying hazardous constituent [UHC]), subject to item 3 below. 12

13 2. For metals and carbon disulfide, cyclohexanone, and methanol, treatment must achieve 90% 14

reduction in constituent concentrations as measured in leachate from the treated media (tested 15 according to the toxicity characteristic leaching procedure (TCLP) or 90% reduction in total 16 constituent concentrations (when a metal removal treatment technology is used), subject to item 3 17 below. 18

19 3. When treatment of any constituent subject to treatment to a 90% reduction standard would result 20

in a concentration less than 10 times the UTS for that constituent, treatment to achieve 21 constituent concentrations less than 10 times the UTS is not required. This is commonly referred 22 to as "90% capped by 10xUTS." 23

24 4. USEPA and Ohio EPA have established a site-specific variance from the soil treatment 25

standards, which can be used when treatment to concentrations of hazardous constituents greater 26 (i.e., higher) than those specified in the soil treatment standards minimizes short- and long-term 27 threats to human health and the environment. In this way, on a case-by-case basis, risk-based 28 LDR treatment standards approved through a variance process could supersede the soil treatment 29 standards. Any variance granted cannot rely on capping, containment, or other physical or 30 institutional controls. 31 32

If CAMUs are used as disposal units at EBG, then the design and treatment standards established at OAC 33 §3745-57-72 will be potentially relevant and appropriate to the response action. Only CAMU-eligible 34 waste can be disposed in a CAMU. CAMU-eligible waste includes hazardous and non-hazardous waste 35 that are managed for implementing cleanup, depending on the Director’s approval or prohibition of 36 specific wastes or waste streams. Use of a CAMU for disposal does not trigger LDRs or MTRs as long as 37 the standards specified in the rule are observed. The Director will incorporate design and treatment 38 standards into a permit or order. Design standards include a composite liner and a leachate collection 39 system that is designed and constructed to maintain less than a thirty centimeter depth of leachate over the 40 liner. A composite liner means a system consisting of two components; each component has detailed 41 specifications and installation requirements. The Director may approve alternate requirements if he can 42 make the findings specified in the rule. Treatment standards are similar to LDR standards for 43


contaminated soil, although alternative and adjusted standards may be approved or required by the 1 Director, as long as the adjusted standard is protective of human health and the environment. 2 3

Table 4-1. Potential Action ARARs for Disposal of RCRA Hazardous Waste 4

Media and Citation Description of Requirement Potential ARAR Status Standard Soil Contaminated with RCRA Hazardous Waste OAC § 3745-400-49 OAC § 3745-400-48 UTS

These rules prohibit land disposal of RCRA hazardous wastes subject to them, unless the waste is treated to meet certain standards that are protective of human health and the environment. Standards for treatment of hazardous contaminated soil prior to disposal are set forth in the two cited rules. Use of the greater of either technology-based standards or UTS is prescribed.

LDRs apply only to RCRA hazardous waste. This rule is considered for ARAR status only upon generation of a RCRA hazardous waste. If any soils are determined to be RCRA hazardous, and if they will be disposed onsite, then this rule is potentially Applicable to disposal of the soils.

All soils subject to treatment must be treated as follows: For non-metals, treatment must achieve 90% reduction in total constituent concentration (primary constituent for which the waste is characteristically hazardous as well as for any organic or metal UHC), subject to 3) below; For metals and carbon disulfide, cyclohexanone, and methanol, treatment must achieve 90% reduction in constituent concentrations as measured in leachate from the treated media (tested according to the TCLP or 90% reduction in total constituent concentrations (when a metal removal treatment technology is used), subject to 3) below: When treatment of any constituent subject to treatment to a 90% reduction standard would result in a concentration less than 10 times the UTS for that constituent, treatment to achieve constituent concentrations less than 10 times the UTS is not required. This is commonly referred to as "90% capped by 10xUTS."


Table 4-1. Potential Action ARARs for Disposal of RCRA Hazardous Waste (continued) 1

Media and Citation Description of Requirement Potential ARAR Status Standard Debris Contaminated with RCRA Hazardous Waste OAC § 3745-400-49 OAC § 3745-400-47

These rules prescribe conditions and standards for land disposal of debris contaminated with RCRA hazardous waste. Debris subject to this requirement for characteristic RCRA contamination that no longer exhibits the hazardous characteristic after treatment does not need to be disposed as a hazardous waste. Debris contaminated with listed RCRA contamination remains subject to hazardous waste disposal requirements.

If RCRA hazardous debris is disposed onsite, then these rules are potentially Applicable to disposal of the debris.

Standards are extraction or destruction methods prescribed in OAC § 3745-400-47. Treatment residues continue to be subject to RCRA hazardous waste requirements.

Soils/Debris Contaminated with RCRA Hazardous Waste – Variance OAC § 3745-400-44

The Director will recognize a variance approved by the USEPA from the alternative treatment standards for hazardous contaminated soil or for hazardous debris.

Potentially applicable to RCRA hazardous soil or debris that is generated and placed back into a unit and that will be land disposed onsite.

A site-specific variance from the soil treatment standards can be used when treatment to concentrations of hazardous constituents greater (i.e., higher) than those specified in the soil treatment standards minimizes short- and long-term threats to human health and the environment. In this way, on a case-by-case basis, risk-based LDR treatment standards approved through a variance process could supersede the soil treatment standards.

Soils Disposed in a Corrective Action Management Unit (CAMU) OAC § 3745-57-53

Only CAMU-eligible waste can be disposed in a CAMU. CAMU-eligible waste includes hazardous and non-hazardous waste that are managed for implementing cleanup, depending on the Director’s approval or prohibition of specific wastes or waste streams. Use of a CAMU for disposal does not trigger LDRs or MTRs as long as the standards specified in the rule are observed. The Director will incorporate design and treatment standards into a permit or order.

Potentially applicable to RCRA hazardous waste that is disposed in a CAMU.

Design standards include a composite liner and a leachate collection system that is designed and constructed to maintain less than a thirty centimeter depth of leachate over the liner. A composite liner means a system consisting of two components; each of which has detailed specifications and installation requirements. The Director may approve alternate requirements if he can make the findings specified in the rule. Treatment standards are similar to LDR standards for contaminated soil, although alternative and adjusted standards may be approved or required by the Director, as long as the adjusted standard is protective of human health and the environment. Treatment standards are de facto cleanup standards for wastes disposed in a CAMU.

CAMU = Corrective Action Management Unit 2 LDR = Land Disposal Restrictions 3 OAC = Ohio Administrative Code 4 RCRA = Resource Conservation and Recovery Act 5 TCLP = toxicity characteristic leaching procedure 6 UHC = Underlying Hazardous Constituent 7 UTS = Universal Treatment Standard 8


4.2.2 Potential Location ARARs for Solid Wastes, RCRA Hazardous Wastes, Construction and 1 Demolition Debris Wastes or Clean Fill 2

3 Location requirements include those established for potential remedial activities conducted within 4 wetlands or within a floodplain area, or with respect to threatened and endangered species. Generally, for 5 wetlands and floodplains, rules require that alternatives to remedial activity within the sensitive area be 6 pursued, and if that is not feasible, then adverse effects from any actions taken within the sensitive area be 7 mitigated to the extent possible. These requirements do not relate to specific chemicals, nor do they 8 further the degree of cleanup in the sense of protecting human health or the environment from the effects 9 of harmful substances. Rather, their purpose is to protect the sensitive areas to the extent possible. Under 10 CERCLA Section 121(d), relevance and appropriateness are related to the circumstances presented by the 11 release of hazardous substance, with the goal of attaining a degree of cleanup and control of further 12 releases that ensures protection of human health and the environment. 13 14 Rules ensuring protection of sensitive resources do not represent requirements that are relevant and 15 appropriate to circumstances presented by the release of hazardous substance, with a goal of attaining a 16 degree of cleanup and control of further releases that ensure protection of human health and the 17 environment. Location requirements for wetlands and floodplains do not relate to the degree of cleanup 18 as much as they relate to protection of these sensitive areas from the effects of remedial activities. This 19 purpose of the rule requirements does not address problems or situations sufficiently similar to those 20 encountered at the CERCLA site that their use is well suited to the particular site as an ARAR; that is, the 21 rule requirements are not sufficiently relevant and appropriate under CERCLA Section 121(d) as related 22 to the circumstances of the release, degree of cleanup, or protectiveness of remedial action, to include 23 these requirements as ARARs. 24 25 The Endangered Species Act (ESA) exists to protect the habitat or body of flora and fauna that are 26 threatened or endangered. Once again, these rules do not relate to specific chemicals, nor do they further 27 the degree of cleanup in the sense of protecting human health or the environment from the effects of 28 harmful substances. The purpose of these rules is to protect sensitive areas and plant and animal life to 29 the degree possible. This purpose does not address problems or situations sufficiently similar to those 30 encountered at the CERCLA site that its use is well suited to the particular site as an ARAR; that is, the 31 rule requirements are not sufficiently relevant and appropriate under CERCLA Section 121(d) as related 32 to the circumstances of the release, degree of cleanup, or protectiveness of the remedial action, to include 33 these requirements as ARARs. 34 35 Having determined that these requirements are not ARARs, it bears repeating that any action taken by the 36 Federal Government must be conducted in accordance with requirements established under the National 37 Environmental Policy Act (NEPA), ESA, and federal and state wetlands and floodplains construction and 38 placement of materials considerations, even though these laws and rules do not establish standards, 39 requirements, limitations, or criteria relating to the degree of cleanup for chemicals remaining onsite at 40 the close of the response action. 41 42


5.0 AGENCY COORDINATION AND PUBLIC INVOLVEMENT 1

The United States Department of the Army is the lead agency under the Defense Environmental 2 Restoration Program responsible for achieving interim remedy of the six high priority AOCs at RVAAP, 3 including EBG. This section reviews actions that have been conducted and that are planned in the future 4 to ensure regulatory agencies and the public have been provided with appropriate opportunities to stay 5 informed of progress of the six high priority environmental AOCs site remediation and to provide 6 meaningful input on the planning effort as well as the final selection of a remedy. 7 8 5.1 STATE ACCEPTANCE 9 10 State Acceptance considers comments received from agencies of the State of Ohio on the actions being 11 considered. For the process supporting closure (or interim remedy) of the six high priority AOCs, 12 including EBG, Ohio EPA is the lead regulatory agency and this FS has been prepared in consultation 13 with Ohio EPA. Ohio EPA has provided input during the ongoing investigation and report development 14 process to ensure the action ultimately selected for the six high priority AOCs, including EBG, meets the 15 needs of the State of Ohio and fulfills the requirements of the Director’s Findings and Orders (Ohio EPA 16 2004). Comments will be solicited from Ohio EPA on the FS and on the PP. The Army will obtain Ohio 17 EPA concurrence prior to the final selection of the remedy for EBG. 18 19 5.2 COMMUNITY ACCEPTANCE 20 21 Community acceptance considers comments provided by the community on the actions being considered. 22 CERCLA 42 U.S.C. 9617(a) emphasizes early, constant, and responsive community relations. The Army 23 has prepared a Community Relations Plan (USACE 2003b) for this project to ensure the public has 24 convenient access to information regarding project progress. The community relations program interacts 25 with the public through news releases, public meetings, public workshops, and Restoration Advisory 26 Board (RAB) meetings with local officials, interest groups, and the general public. The public also is 27 provided the opportunity to comment on draft documents submitted to the Administrative Record that 28 support interim remedy of EBG, including the previously completed RI Report and this FS Report. 29 30 CERCLA 42 U.S.C. 9617(a) requires that an Administrative Record be established “at or near the facility 31 at issue.” Relevant documents regarding the RVAAP/RTLS site have been made available to the public 32 for review and comment. The Administrative Record for this project is available at the following 33 location: 34 35

Ravenna Army Ammunition Plant 36 Building 1037 Conference Room 37 8451 St. Route 5 38 Ravenna, Ohio 44266-9297 39

40


Access to RVAAP/RTLS is restricted but can be obtained by contacting facility management at (330) 1 358-7311. In addition, an Information Repository of current information and final documents is available 2 to any interested reader at the following libraries: 3 4

Reed Memorial Library 5 167 East Main Street 6 Ravenna, Ohio 44266 7 8 Newton Falls Public Library 9 204 South Canals 10 Newton Falls, Ohio 44444-1694 11

12 Also, RVAAP has an online resource for site restoration news and information. This website can be 13 viewed at www.rvaap.org. 14 15 Similar to state agencies, comments will be received from the community upon issuance of the FS and the 16 PP. The Army will request public comments on the PP for EBG, as required by the CERCLA regulatory 17 process and the RVAAP Community Relations Plan. These comments will be considered in the final 18 selection of an interim remedy for EBG. Responses to these comments will be addressed in the 19 responsiveness summary of the ROD. 20 21


6.0 CONCLUSIONS AND RECOMMENDATIONS 1

This FS establishes RAOs and evaluates the need for remedial action to reduce risks to the environment 2 to obtain interim remedy of EBG with respect to soils/dry sediments. Chemical-specific preliminary 3 cleanup goals were established for restricted and unrestricted land use. Preliminary cleanup goals for 4 restricted land use were established for a representative receptor for likely future land use by OHARNG. 5 The representative receptor provides a conservative surrogate for other possible receptors (e.g., 6 preliminary cleanup goals for the National Guard Trainee are also protective of a hunter or a security 7 guard). The potential for the representative receptor to be protective of a trespasser (Adult and Juvenile) 8 also is addressed. In addition to the representative receptor, preliminary cleanup goals were established 9 for a Resident Subsistence Farmer (adult and child) to provide a baseline for evaluating whether this site 10 may be eligible for unrestricted release. EBG will be transferred to OHARNG. EBG is not currently a 11 candidate for unrestricted release due to the potential for MEC and the presence of environmentally 12 sensitive areas (i.e., wetlands). 13 14 The RAO analysis determined EBG required no further action with respect to impacted soils/dry 15 sediments. No COCs are identified in soils/dry sediment for the restricted land use representative 16 receptor or unrestricted land use at EBG. Therefore, it is the recommendation of this FS that EBG 17 requires no further action with respect to chemical contamination in soils/dry sediment. Any required 18 land use controls to address MEC issues will be developed and implemented by the Army and Ohio Army 19 National Guard under the auspices of the MMRP. These land use controls may also be tailored to 20 simultaneously ensure protectiveness with respect to wetland areas/subaqueous sediment. 21 22 The next step in the CERCLA process is to prepare a PP to solicit public input with respect to no further 23 action at EBG. The PP will present the RAO analysis performed in the FS supporting no further action at 24 EBG with respect to impacted soils/dry sediments. 25 26 The ROD will document the interim remedy for EBG. Comments on the PP received from state and 27 federal agencies and the public will be considered in drafting the ROD for EBG. The ROD will provide a 28 brief summary of the history, characteristics, risks, and selected remedy. The ROD also will include a 29 responsiveness summary, addressing comments received on the PP. 30 31


7.0 REFERENCES 1

FRTR, 2005. Federal Remediation Technology Roundtable: Remediation Technologies Screening Matrix - Version 4.0. http://www.frtr.gov/matrix2/top_page.html. Information downloaded May 2005.

Mogul Corporation 1982. Soil and Sediment Analyses Performed for: Ravenna Arsenal, Ravenna, Ohio, May.

Morgan, Tim 2004. Personal communication by telephone with C.R. Wenzel, SAIC, July 22, 2004. ODNR (Ohio Department of Natural Resources). 1993. Species and Plant Communities Inventory (1993)

Ravenna Army Ammunition Plant. ODNR and The Nature Conservancy, Columbus, Ohio, various pagination.

OHARNG (Ohio Army National Guard) 2001. Integrated Natural Resources Management Plan and

Environmental Assessment for the Ravenna Training and Logistics Site and the Ravenna Army Ammunition Plant, Portage and Trumbull Counties, Ohio, Prepared by AMEC Earth & Environmental, Louisville, KY.

Ohio EPA (Ohio Environmental Protection Agency). 2001. Ohio Rapid Assessment Method for Wetlands,

Division of Surface Water, ORAM Version 5.0. Ohio EPA 2003. Ecological Risk Assessment Guidance Document, Division of Emergency and Remedial

Response, Draft Final. Ohio EPA 2004. Director’s Final Findings and Orders in the matter of United States Department of the

Army, Ravenna Army Ammunitions Plant. June 2004. Ohio EPA, Division of Emergency and Remedial Response (DERR), 2004b. Technical Decision

Compendium: Human Health Cumulative Carcinogenic Risk and Non-carcinogenic Hazard Goals for DERR Remedial Response and Office of Federal Facility Oversight. April 28, 2004.

Persaud, D., R. Jaagumagi, and A. Hayton 1993. Guidelines for the Protection and Management of

Aquatic Sediment Quality in Ontario. Ontario Ministry of the Environment and Energy, 24 pp. Suter, G. W. II, B. W. Cornaby, C. T. Hadden, R. N. Hull, M. Stack, and F. A. Zafran 1995. An Approach

for Balancing Health and Ecological Risks at Hazardous Waste Sites, Risk Analysis 15(2):221–231.

USACE (United States Army Corp of Engineers) 1996. Preliminary Assessment for the Ravenna Army

Ammunition Plant, Ravenna, Ohio.


USACE 1998a. Phase I Remedial Investigation Report for 11 High-Priority Sites at the Ravenna Army Ammunition Plant, Ravenna Ohio, DACA62-94-D-0029, D.Os. 0010 and 0029, Final, February 1998.

USACE 1999. Phase II Remedial Investigation Report for the Winklepeck Burning Grounds at Ravenna

Army Ammunition Plant, Ravenna, Ohio, prepared for the United States Army Corps of Engineers Louisville District by SAIC, August 1999.

USACE 2001. Final Phase I Remedial Investigation Report for Erie Burning Grounds at the Ravenna

Army Ammunitions Plant. December 2001. USACE 2003a. RVAAP Facility Wide Ecological Risk Work Plan. Louisville District, United States

Army Corps of Engineers. May 2003. USACE 2003b. Ravenna Army Ammunition Plant, Ravenna, Ohio, Community Relations Plan. September 2003. USACE 2004b. RVAAP Facility Wide Human Health Risk Assessor Manual. January 2004. USACE 2005a. Facility-Wide Biological and Water Quality Study 2003, Ravenna Army Ammunition

Plant, Part 1 – Streams and Part II – Ponds. United States Army Corps of Engineers, Louisville District, with the State of Ohio Environmental Protection Agency, Division of Surface Water, pp. 144 and several appendices.

USACE 2005c. RVAAP Facility Wide Human Health Risk Assessor Manual: Amendment 1. November

2005. USACE 2005d. Phase II Remedial Investigation Report for Erie Burning Grounds (RVAAP-02).

Ravenna Army Ammunition Plant, Ravenna, Ohio. Delivery Order W912QR-05-F-0033, September 2005.

USACE 2005h. Performance Work Statement for Performance Based Contract of Six High Priority

RVAAP AOCs. February 10, 2005. USACE 2005i. Facility-wide Biological and Water Quality Study 2003, Ravenna Army Ammunition

Plant, Part 1 – Streams and Part II – Ponds. United States Army Corps of Engineers, Louisville District, with the State of Ohio Environmental Protection Agency, Division of Surface Water. Pp. 144 and several appendices.

USACHPPM (U. S. Army Center for Health Promotion and Preventive Medicine) 1996. Hazardous and

Medical Waste Study No. 37


USAEHA (United States Army Environmental Hygiene Agency) 1984. Hazardous Waste Management Study No. 37-26-0442-84.

USAEHA 1992. Geohydrologic Study No. 38-26-KF95-92. USATHAMA (United States Army Toxic and Hazardous Materials Agency) 1980 – 1992. Ravenna Water

Quality Surveillance Program (data only). USEPA (United States Environmental Protection Agency) 1988. Guidance for Conducting Remedial

Investigations and Feasibility Studies Under CERCLA Interim Final” Document No. EPA/540/G.

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(Part A), EPA/540/1-89/002, Washington, D.C. USEPA 1996. Soil Screening Guidance: Technical Background Document, Office of Solid Waste and

Emergency Response, Washington, D.C. USEPA 1997. Ecological Risk Assessment Guidance for Superfund: Process for Designing and

Conducting Ecological Risk Assessments. Interim Final. U. S. EPA Environmental Response Team, Edison, NJ, June 1997.

USEPA 1998. Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities,

Peer Review Draft, EPA/530/D-98/001B, United States Environmental Protection Agency, Washington, D.C., available at http://www.epa.gov/epaoswer/hazwaste/combust/risk.htm.

USEPA 1999a. Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities (Peer

Review Draft) – Errata. Solid Waste and Emergency Response. August 2, 1999. USEPA 1999b. “Use of the TRW Interim Adult Lead Methodology in Risk Assessment,” Memorandum

from EPA Region 5 Superfund Program, April 1999. USEPA 2002. Risk Assessment Guidance for Superfund Volume I: Human Health Evaluation Manual

(Part E, Supplemental Guidance for Dermal Risk Assessment) Interim, OSWER 9285.7-02EP, September 2002.

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Assessing Risks Associated with Adult Exposures to Lead in Soil, EPA-540-R-03-001, January 2003.

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USGS 1968. Mineral Resources of the Appalachian Region, USGS Professional Paper No. 580. 1


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Appendix 2A Risk Characterization for

Trespasser Scenario

RVAAP 6 High Priority AOCs EBG Feasibility Study Appendix 2A Draft March 2006 Page 2A-i

TABLE OF CONTENTS 1 2 2A.0 RISK CHARACTERIZATION FOR TRESPASSER SCENARIO ................................2A-1 3

2A.1 INTRODUCTION ....................................................................................................................2A-1 4 2A.2 DATA EVALUATION ............................................................................................................2A-1 5 2A.3 EXPOSURE ASSESSMENT .....................................................................................................2A-2 6 2A.4 TOXICITY ASSESSMENT ......................................................................................................2A-5 7 2A.5 RISK CHARACTERIZATION RESULTS FOR TRESPASSER FOR EBG .......................................2A-6 8

2A.5.1 EBG Surface Soil .........................................................................................................2A-6 9 2A.5.2 EBG Sediment .............................................................................................................2A-7 10 2A.5.3 EBG Surface Water .....................................................................................................2A-7 11 2A.5.4 Summary of Risk Characterization Results for Trespasser .........................................2A-8 12

2A.6 UNCERTAINTY ANALYSIS ...................................................................................................2A-8 13 2A.7 SUMMARY AND CONCLUSIONS ...........................................................................................2A-9 14

15 16

RVAAP 6 High Priority AOCs EBG Feasibility Study Appendix 2A Draft March 2006 Page 2A-ii

LIST OF TABLES 1

2 Table 2A-1. Exposure Media Evaluated for the Trespasser (Juvenile and Adult) Scenario ............2A-1 3 Table 2A-2. COPCs for Each Exposure Medium............................................................................2A-2 4 Table 2A-3. Exposure Parameters for Trespasser (Juvenile and Adult) Scenario...........................2A-3 5 Table 2A-4. Chemical-Specific Exposure Parameters ..................................................................2A-10 6 Table 2A-5. Non-carcinogenic Reference Doses for COPCs........................................................2A-11 7 Table 2A-6. Cancer Slope Factors for COPCs ..............................................................................2A-12 8 Table 2A-7. EBG Shallow Surface Soil (0-1 ft bgs) Calculations of Blood Lead 9

Concentrations for Juvenile Trespasser ...................................................................2A-14 10 Table 2A-8. EBG Shallow Surface Soil (0-1 ft bgs) Calculations of Blood Lead 11

Concentrations for Adult Trespasser .......................................................................2A-15 12 Table 2A-9. Juvenile Trespasser Shallow Surface Soil (0-1 ft bgs) Non-Carcinogenic 13

Hazards - Direct Contact .........................................................................................2A-16 14 Table 2A-10. Juvenile Trespasser Shallow Surface Soil (0-1 ft bgs) Carcinogenic 15

Risks - Direct Contact..............................................................................................2A-17 16 Table 2A-11. Adult Trespasser Shallow Surface Soil (0-1 ft bgs) Non-Carcinogenic 17

Hazards - Direct Contact .........................................................................................2A-18 18 Table 2A-12. Adult Trespasser Shallow Surface Soil (0-1 ft bgs) Carcinogenic 19

Risks - Direct Contact..............................................................................................2A-19 20 Table 2A-13. Juvenile Trespasser Sediment Non-carcinogenic Hazards - Direct Contact ........2Error! 21 Bookmark not defined. 22 Table 2A-14. Juvenile Trespasser Sediment Carcinogenic Risks - Direct Contact.......................2A-21 23 Table 2A-15. Adult Trespasser Sediment Non-carcinogenic Hazards - Direct Contact ...............2A-22 24 Table 2A-16. Adult Trespasser Sediment Carcinogenic Risks - Direct Contact...........................2A-23 25 Table 2A-17. Juvenile Trespasser Surface Water Non-Carcinogenic Hazards - Direct Contact ..2A-24 26 Table 2A-18. Juvenile Trespasser Surface Water Carcinogenic Risks - Direct Contact...............2A-24 27 Table 2A-19. Adult Trespasser Surface Water Non-Carcinogenic Hazards - Direct Contact ......2A-26 28 Table 2A-20. Adult Trespasser Surface Water Carcinogenic Risks - Direct Contact ...................2A-27 29 Table 2A-21. Summary of Risks and Hazards for Trespasser (Juvenile and Adult) at EBG.........2A-830

RVAAP 6 High Priority AOCs ODA2 Feasibility Study Appendix 2A Draft March 2006 Page 2A-1

2A.0 RISK CHARACTERIZATION FOR TRESPASSER SCENARIO 1

2A.1 INTRODUCTION 2 3 The baseline HHRA provided in the RI Report for EBG evaluates the potential health risks to humans 4 resulting from exposure to contamination at EBG. The HHRA presented in the RI Report is based on the 5 methods outlined in the RVAAP FWHHRAM (USACE 2004b) dated January 2004, which addresses five 6 receptors to be evaluated at RVAAP [National Guard Trainee, National Guard Dust/Fire Control Worker, 7 Security Guard/Maintenance Worker, Hunter/Trapper/Fisher, and Resident Subsistence Farmer (adult and 8 child)]. 9 10 An additional receptor (trespasser scenario) was added in an addendum to the FWHHRAM (USACE 11 2005c) released in November 2005. The Trespasser (Juvenile and Adult) is evaluated in this FS to 12 supplement the baseline HHRA provided in the RI Report to comply with the revised FWHHRAM and 13 provide risk managers with information to support determination of the need for continued security at the 14 facility. This supplemental risk characterization is organized into the same six major sections used in the 15 baseline HHRA: 16 17

• data evaluation and COPCs are discussed in Section 2A.2; 18 • exposure assessment is presented in Section 2A.3; 19 • toxicity assessment is summarized in Section 2A.4; 20 • results of the risk characterization are presented in Section 2A.5; 21 • the uncertainty analysis is presented in Section 2A.6; and 22 • the conclusions of the HHRA are summarized in Section 2A.7. 23

24 2A.2 DATA EVALUATION 25 26 Data evaluation and COPC screening were conducted as part of the baseline HHRA for EBG in the Phase 27 II Remedial Investigation Report (USACE 2005d). 28 29 Under this scenario, the Trespasser (Juvenile and Adult) may be exposed to COPCs in shallow surface 30 soil (0-1 ft bgs), sediment, and surface water. This receptor is not exposed to COPCs in subsurface soil or 31 groundwater. A summary of the exposure media evaluated for the Trespasser (Juvenile and Adult) 32 scenario at each AOC is provided in Table 2A-1. 33

34 Table 2A-1. Exposure Media Evaluated for the Trespasser (Juvenile and Adult) Scenario 35

Exposure Media AOC Shallow Surface Soila Sediment Surface Water EBG 1 EU 1 EU 1 EU

aShallow surface soil defined as 0-1 ft bgs for the Trespasser scenario. 36 AOC = area of concern. 37 EU = exposure unit. 38 No COPCs = no chemicals of potential concern (COPCs) identified for this exposure medium in the RI Report. 39


A summary of the COPCs identified for each medium in the baseline HHRA is provided in Table 2A-2. 1 2

Table 2A-2. COPCs for Each Exposure Medium 3

COPC Shallow (0-1 ft bgs)

Surface Soil Sediment Surface Water Quantitative COPCsa

Inorganics

Aluminum X X X Antimony X X X Arsenic X X X Barium X X Cadmium X X X

Chromiumb X X X Copper X X

Leadc X Manganese X X X Nickel X Vanadium X X X Zinc X X

Organics

2,4,6-Trinitrotoluene X X Benz(a)anthracene X Benzo(a)pyrene X Benzo(b)fluoranthene X X Chloroform X Indeno(1,2,3-cd)pyrene X

Qualitative COPCsd

Organics 2-Amino-4,6-dinitrotoluene X 4-Amino-2,6-dinitrotoluene X Benzo(g,h,i)perylene X Nitrocellulose X X X Phenanthrene X X

aQuantitative COPCs have approved toxicity values that allow for further quantitative evaluation in the human health risk assessment. 4 bChromium is conservatively evaluated with the toxicity values for hexavalent chromium. 5 cAlthough lead does not have toxicity values for which to quantify risks and/or hazards, it can be evaluated quantitatively with blood lead 6 models from the U. S. Environmental Protection Agency. 7 dQualitative COPCs do not have approved toxicity values that allow for further quantitative evaluation in the human health risk assessment. 8 COPC = Chemical of potential concern. 9 X = Chemical is a COPC for this medium. 10 11 2A.3 EXPOSURE ASSESSMENT 12 13 One receptor (Trespasser [Juvenile and Adult]) is evaluated in this supplemental HHRA. RVAAP/ RTLS 14 is a controlled access facility (i.e., it is fenced, gated, and patrolled by security guards); however, a 15 trespasser could enter the property and be exposed to contaminants in shallow surface soil (0-1 ft bgs), 16 sediment, and surface water at this AOC. The Juvenile Trespasser is assumed to visit the site 17 approximately once per week (i.e., 50 days/year) between the ages of 8 and 18. The Adult Trespasser is 18


assumed to visit the site slightly more often (75 days/year) for as long as he lives in the area (i.e., 30 1 years). In reality, the most likely adult trespassers are hunters or National Guard trainees entering 2 unauthorized areas with a much lower frequency than the Hunter/Fisher/Trapper and National Guard 3 Trainee receptors that are included in the baseline HHRA. A Juvenile Trespasser (ages 8 to 18) and 4 Adult Trespasser are evaluated quantitatively for exposure to contaminated shallow surface soil (0-1 ft 5 bgs) and sediment via incidental ingestion, inhalation of VOCs and particulates, and dermal contact. The 6 Trespasser (Juvenile and Adult) is also evaluated for exposure to contaminated surface water via 7 incidental ingestion and dermal contact. 8 9 Exposure equations for each of these pathways are provided in the FWHHRAM (USACE 2004b). 10 Exposure parameters used to calculate potential chemical intakes by the Trespasser (Juvenile and Adult) 11 are from Table 5 of the FWHHRAM Amendment 1 (USACE 2005c) and are provided in Table 2A-3. 12 Chemical-specific exposure parameters are provided for all COPCs in Table 2A-4 at the end of this 13 appendix. 14 15

Table 2A-3. Exposure Parameters for Trespasser (Juvenile and Adult) Scenarioa 16

Exposure Pathway and Parameter Units Value Surface Soilb

Incidental Ingestion

Soil ingestion rate (Adult/Juvenile) kg/day 0.0001 / 0.0002

Exposure time hours/day 2

Exposure frequency (Adult/Juvenile) days/year 75 / 50

Exposure duration (Adult/Juvenile) years 30 / 10

Body weight (Adult/Juvenile) kg 70 / 45

Carcinogen averaging time days 25,550 Non-carcinogen averaging time (Adult/Juvenile) days 10,950 / 3,650 Fraction ingested unitless 1 Conversion factor days/hour 0.042

Dermal Contact

Skin area (Adult/Juvenile) m2/event 0.57 / 0.815

Adherence factor (Adult/Juvenile) mg/cm2 0.4 / 0.2 Absorption fraction unitless Chemical Specific – Table 2A-4

Exposure frequency (Adult/Juvenile) events/year 75 / 50



Carcinogen averaging time days 25,550 Non-carcinogen averaging time (Adult/Juvenile) days 10,950 / 3,650

Conversion factor (kg-cm2)/(mg-m2) 0.01

Inhalation of VOCs and Dust

Inhalation rate m3/day 20





Table 2A-3. Exposure Parameters for Trespasser (Juvenile and Adult) Scenarioa (continued)

Exposure Pathway and Parameter Units Value


Volatilization factor m3/kg Chemical Specific – Table 2A-4

Particulate emission factor m3/kg 9.24E+08


Conversion factor days/hour 0.042

Sediment Incidental Ingestion

Soil ingestion rate (Adult/Juvenile) kg/day 0.0001 / 0.0002





Carcinogen averaging time days 25,550 Non-carcinogen averaging time (Adult/Juvenile) days 10,950 / 3,650 Fraction ingested unitless 1 Conversion factor days/hour 0.042

Dermal Contact

Skin area (Adult/Juvenile) m2/event 0.57 / 0.815

Adherence factor (Adult/Juvenile) mg/cm2 0.4 / 0.2 Absorption fraction unitless Chemical Specific – Table 2A-4

Exposure frequency (Adult/Juvenile) events/year 75 / 50




Conversion factor (kg-cm2)/(mg-m2) 0.01 Inhalation of VOCs and Dust

Inhalation rate m3/day 20





Volatilization factor m3/kg Chemical Specific – Table 2A-4

Particulate emission factor m3/kg 9.24E+08

Carcinogen averaging time days 25,550 Non-carcinogen averaging time (Adult/Juvenile) days 10,950 / 3,650 Conversion factor days/hour 0.042

1 2


Table 2A-3. Exposure Parameters for Trespasser (Juvenile and Adult) Scenarioa (continued)

Exposure Pathway and Parameter Units Value

Surface Water Incidental Ingestion

Incidental water ingestion rate L/day 0.1





Dermal Contact

Skin area (Adult/Juvenile) m2 0.57 / 0.815






Conversion factor (m/cm)(L/m3) 10 aExposure parameters are from Table 5 of the FWHHRAM Amendment 1 (USACE 2005c). 1 bSurface soil is defined as 0-1 ft bgs (shallow surface soil). 2 VOC = volatile organic compound 3 4 EPCs were calculated for each exposure medium in the baseline HHRA as detailed in the RI Report. 5 These EPCs are provided in Tables 2A-9 through 2A-20 at the end of this appendix. 6 7 2A.4 TOXICITY ASSESSMENT 8 9 Toxicity factors from EPA sources are provided in Table 2A-5 (noncancer reference doses [RfDs]) and 10 Table 2A-6 cancer slope factors (CSFs) at the end of this appendix. These are the same toxicity factor 11 values used to evaluate the five receptors evaluated in the baseline HHRA for EBG. 12 13 Chronic RfDs are developed for protection from long-term exposure to a chemical (from 7 years to a 14 lifetime); subchronic RfDs are used to evaluate short-term exposure (from 2 weeks to 7 years) 15 (EPA 1989). The Juvenile Trespasser scenario assumes an exposure duration of 10 years and the Adult 16 Trespasser assumes an exposure duration of 30 years; therefore, only chronic RfDs are used in this 17 supplemental HHRA. 18 19 Reference air concentrations (RfCs) and inhalation unit risks were converted to RfDs and CSFs using 20 default adult inhalation rate and body weight [i.e., (RfC × 20 m3/day)/70 kg = RfD, Unit Risk × 70 kg × 21 1,000 μg/mg)/20 m3/day = CSF] (EPA 1989). 22 Dermal RfDs and CSFs are estimated from oral toxicity values using chemical-specific gastrointestinal 23 absorption factors (GAFs) to calculate total absorbed dose as recommended by EPA (2004). The GAF 24


values used and resulting dermal toxicity values are listed in Tables 2A-5 and 2A-6 at the end of this 1 appendix. 2 3 As discussed in the baseline HHRA, total chromium is evaluated using the toxicity values for hexavalent 4 chromium at EBG. This is the form of chromium with the most conservative toxicity values. 5 6 Per the FWHHRAM (USACE 2004b) toxicity equivalence factors (TEFs) are applied to carcinogenic 7 polycyclic aromatic hydrocarbons (cPAHs) to convert the cPAHs to an equivalent concentration of 8 benzo(a)pyrene. 9 10 No RfDs or CSFs are available for some COPCs because the non-carcinogenic and/or carcinogenic 11 effects of these chemicals have not yet been determined. Although these chemicals may contribute to 12 health effects from exposure to contaminated media, their effects cannot be quantified at the present time. 13 COPCs without RfDs and CSFs are 2-amino-4,6-dinitrotoluene (DNT); 4-amino-2,6-DNT; nitrocellulose; 14 benzo(g,h,i)perylene; and phenanthrene. 15 16 No RfDs or CSFs are available for lead. EPA (1999) recommends the use of the interim adult lead model 17 (ALM) to support its goal of limiting risk of elevated fetal blood lead concentrations due to lead 18 exposures to women of child-bearing age. This model is used to estimate the probability that the fetal 19 blood lead level will exceed 10 μg/dL as a result of maternal exposure. Complete documentation of the 20 model is available at http://www.epa.gov/superfund/programs/lead/products/adultpb.pdf (EPA 2003). 21 The model-supplied default values were used for all parameters, with the exception of the site-specific 22 media concentration and exposure frequency. Input parameters and results of this model are provided in 23 Tables 2A-7 (Juvenile Trespasser) and 2A-8 (Adult Trespasser) at the end of this appendix. The IEUBK 24 model for lead in children (available at http://www.epa.gov/superfund/programs/lead/ieubk.htm) was not 25 used to evaluate the Juvenile Trespasser because this receptor is assumed to be age 8 to 18 years and the 26 IEUBK applies to children age 0 to 6 years. 27 28 2A.5 RISK CHARACTERIZATION RESULTS FOR TRESPASSER FOR EBG 29 30 Risk characterization integrates the findings of the exposure and toxicity assessments to estimate the 31 potential for receptors to experience adverse effects as a result of exposure to contaminated media. Risk 32 characterization for the Trespasser (Juvenile and Adult) in this supplemental HHRA follows the same 33 methodology used for risk characterization for the other receptors evaluated in the baseline HHRA. 34 35 Risk characterization results including identification of COCs are presented for in the following 36 subsections. COCs are defined as COPCs having an ILCR greater than 1.0E-06 and/or an HI greater 37 than 1. 38 39 2A.5.1 EBG Surface (0-1 ft bgs) Soil 40 41 Detailed hazard and risk results for direct contact with COPCs in shallow surface soil (0-1 ft bgs) are 42 presented in Tables 2A-9 and 2A-10 (Juvenile Trespasser) and 2A-11 and 2A-12 (Adult Trespasser) at 43


the end of this appendix. Direct contact includes incidental ingestion of soil, inhalation of VOCs and 1 particulates (i.e. dust) from soil, and dermal contact with soil. 2 3 The total HIs for the Juvenile Trespasser and Adult Trespasser exposed to shallow surface soil are 0.017 4 and 0.018, respectively, which are below the threshold of 1.0; thus, no non-carcinogenic shallow surface 5 soil COCs are identified at EBG for either receptor. 6 7 The total risk across all COPCs for the Juvenile Trespasser exposed to shallow surface soil is 7.7E-07, 8 which is below the threshold of 1.0E-06; thus, no carcinogenic shallow surface soil COCs are identified at 9 EBG for this receptor. The total risk across all COPCs for the Adult Trespasser exposed to shallow 10 surface soil is 2.8E-06, which is above the threshold of 1.0E-06. Arsenic is identified as a carcinogenic 11 COC for the Adult Trespasser exposed to shallow surface soil at EBG; however, the arsenic risk (1.6E-12 06) is not in excess of Ohio EPA’s level of concern of 1E-05 (Ohio EPA 2004b). 13 14 Lead was identified as a surface soil COPC at EBG. Lead model results for the Juvenile Trespasser and 15 Adult Trespasser are provided in Tables 2A-7 and 2A-8, respectively, at the end of this appendix. The 16 estimated probability of fetal blood lead concentrations exceeding acceptable levels is less than 1% for 17 both the Juvenile Trespasser and Adult Trespasser exposed to shallow surface soil at EBG; therefore, lead 18 is not a COC. 19 20 2A.5.2 EBG Sediment 21 22 Detailed hazard and risk results for contact with COPCs in sediment are presented in Tables 2A-13 and 23 2A-14 (Juvenile Trespasser) and Tables 2A-15 and 2A-16 (Adult Trespasser) at the end of this appendix. 24 Direct contact includes incidental ingestion of sediment, inhalation of VOCs and particulates (i.e., dust) 25 from sediment, and dermal contact with sediment. 26 27 The total HIs for the Juvenile Trespasser and Adult Trespasser exposed to sediment are 0.055 and 0.051, 28 respectively, which are below the threshold of 1.0; thus, no non-carcinogenic sediment COCs are 29 identified at EBG for either receptor. 30 31 The total risk across all COPCs for the Juvenile Trespasser exposed to sediment is 6.5E-07, which is 32 below the threshold of 1.0E-06; thus, no carcinogenic sediment COCs are identified at EBG for this 33 receptor. The total risk across all COPCs for the Adult Trespasser exposed to sediment is 2.2E-06, which 34 is above the threshold of 1.0E-06. Arsenic is identified as a carcinogenic COC for the Adult Trespasser 35 exposed to sediment at EBG; however, the arsenic risk (2.0E-06) is not in excess of Ohio EPA’s level of 36 concern of 1E-05. 37 38 2A.5.3 EBG Surface Water 39 40 Detailed hazard and risk results for direct contact with COPCs in surface water are presented in Tables 41 2A-17 and 2A-18 (Juvenile Trespasser) and Tables 2A-19 and 2A-20 (Adult Trespasser) at the end of this 42


appendix. Direct contact includes incidental ingestion of surface water and dermal contact with surface 1 water. 2 3 The total HIs for the Juvenile Trespasser and Adult Trespasser exposed to surface water are 0.59 and 4 0.45, respectively, which are below the threshold of 1.0; thus, no non-carcinogenic surface water COCs 5 are identified at EBG for either receptor. 6 7 The total risks across all COPCs for the Juvenile Trespasser and Adult Trespasser exposed to sediment 8 are 6.2E-06 and 1.7E-05, coming predominantly from arsenic. Arsenic is identified as a surface water 9 COC at EBG for both receptors. The arsenic cancer risk for the Juvenile Trespasser is 5.6E-06, which is 10 below Ohio EPA’s level of concern of 1E-05. The arsenic cancer risk for the Adult Trespasser (1.7E-05, 11 based on a concentration of 0.072 mg/L) is just above Ohio EPA’s level of concern of 1E-05; an arsenic 12 concentration of 0.043 mg/L would produce a risk of 1E-05. 13 14 2A.5.4 Summary of Risk Characterization Results for Trespasser 15 16 Risks, hazards, and COCs are summarized in Table 2A-21 for the Trespasser (Juvenile and Adult) 17 exposed to shallow surface soil (0-1 ft bgs), sediment, and surface water at EBG. 18 19

Table 2A-21. Summary of Risks and Hazards for Trespasser (Juvenile and Adult) at EBG 20

Exposure Medium Total HI Non-carcinogenic COCs Total ILCR Carcinogenic COCs Juvenile Trespasser

Shallow Surface Soil (0-1 ft bgs) 0.017 None 7.7E-07 None Sediment 0.055 None 6.5E-07 None Surface Water 0.59 None 6.2E-06 arsenic

Adult Trespasser Shallow Surface Soil( 0-1 ft bgs) 0.018 None 2.8E-06 arsenic Sediment 0.051 None 2.2E-06 arsenic Surface Water 0.45 None 1.7E-05 arsenic

COC = Chemical of concern. 21 HI = Hazard index. 22 ILCR = Incremental lifetime cancer risk. 23 24

2A.6 UNCERTAINTY ANALYSIS 25 26 Uncertainties associated with each step of the risk assessment process (i.e., data evaluation, exposure 27 assessment, toxicity assessment, and risk characterization) are described in the baseline HHRA. 28 29 While anticipated future land use has been identified for the RTLS (USACE 2004b), and OHARNG will 30 manage the property, there is uncertainty surrounding the future land use. To address this uncertainty a 31 Trespasser (Juvenile and Adult) is evaluated in this supplemental risk assessment. 32 33 34


2A.7 SUMMARY AND CONCLUSIONS 1 2 This supplemental HHRA was conducted to evaluate risks and hazards associated with impacted media at 3 EBG for a Trespasser (Juvenile and Adult) scenario. The following steps were used to generate 4 conclusions regarding human health risks and hazards: 5 6

• Identification of COPCs (in the baseline HHRA included in the RI Report); 7 • Calculation of risks and hazards; and 8 • Identification of COCs. 9

10 At EBG, all HIs for the Trespasser (Juvenile and Adult) are below the threshold value of 1.0. The total 11 ILCRs for the Juvenile Trespasser exposed to shallow surface soil (0-1 ft bgs) and sediment are below the 12 threshold value of 1.0E-06, while the total ILCRs for the Adult Trespasser exposed to shallow surface soil 13 and sediment are just above the threshold value of 1.0E-06. The total ILCRs for surface water exceed 14 1.0E-06 for both the Juvenile Trespasser and the Adult Trespasser. Arsenic is identified as the only COC 15 for the Trespasser (Juvenile and Adult) at EBG. 16


Table 2A-4. Chemical-Specific Exposure Parameters 1

COPC Dermal Absorption Factora

(unitless)

Permeability Constantb (cm/hr)

Volatilization Factorc (m3/kg)

Inorganics Aluminum 1.0E-03 2.1E-03 -- Antimony 1.0E-03 1.1E-03 -- Arsenic 3.0E-02 1.9E-03 -- Barium 1.0E-03 4.0E-04 -- Cadmium 1.0E-03 3.5E-04 -- Chromium (as Chromium VI) 1.0E-03 1.0E-03 -- Copper 1.0E-03 3.1E-04 -- Manganese 1.0E-03 1.3E-03 -- Nickel 1.0E-03 3.3E-04 -- Vanadium 1.0E-03 1.4E-03 -- Zinc 1.0E-03 3.4E-04 --

Organics 2,4,6-Trinitrotoluene 1.0E-01 1.1E-03 -- Benz(a)anthracene 1.3E-01 9.5E-01 -- Benzo(a)pyrene 1.3E-01 1.2E+00 -- Benzo(b)fluoranthene 1.3E-01 7.0E-01 -- Chloroform 1.0E-02 8.9E-03 2.8E+03 Indeno(1,2,3-cd)pyrene 1.3E-01 2.2E+00 --

a Chemical-specific absorption factor values from EPA, 2004. When chemical-specific values are 2 not available the following default values are used for soil and sediment only: 3 SVOCs = 0.1, VOCs = 0.01, inorganics = 0.001 per EPA Region 4 Supplemental Guidance to RAGS. 4 b From Risk Assessment Information System (RAIS) http://risk.lsd.ornl.gov/tox/tox_values.shtml for surface water. 5 c Volatilization factors (VFs) calculated using the 1996 EPA Soil Screening Guidance Methodology, using site- 6 specific parameter values for Cleveland, Ohio. Only used for soil and sediment VOCs. 7 COPC = Chemical of potential concern. 8 RAGS = Risk Assessment Guidance for Superfund. 9 SVOC = semivolatile organic compound 10 EPA = United States Environmental Protection Agency 11 VOC = volatile organic compound 12 -- = No value available. 13

14


Table 2A-5. Non-carcinogenic Reference Doses for COPCs

COPC

Oral Chronic

RfD (mg/kg-day)

Confidence

Level

% GI Absorptiona

Dermal Chronic

RfD (mg/kg-day)

Inhalation Chronic

RfD (mg/kg-day)

RfD Basis (vehicle)

Critical Effect

Uncertainty/ Modifying

Factor

Inorganics Aluminum 1.0E+00 NA 1 1.0E+00 1.4E-03 NA NA (O) UF=10

Antimony 4.0E-04 Low 0.15 6.0E-05 -- Oral, oral-water Gastrointestinal, liver, cardiovascular, and developmental toxicity (O) UF=1000

Arsenic 3.0E-04 Medium (O) 0.95 3.0E-04 -- Oral, oral-water Hyperpigmentation and keritosis and possible vascular complication (O) UF=3

Barium 7.0E-02 Medium (O) 0.07 4.9E-03 1.4E-04 Oral, oral-water, inhalation

(O) increased blood pressure (human) (I) baritosis (human)

(O) UF=3 (I) UF=1000

Cadmium (soil/food) 1.0E-03 High 0.025 2.5E-05 -- Oral, oral-water Renal toxicity, osteomalacia, osteoporosis, and significant proteinuria

(O) UF=1000

Cadmium (water) 5.0E-04 High 0.05 2.5E-05 -- Oral, oral-water Renal toxicity, osteomalacia, osteoporosis, and significant proteinuria

(O) UF=1000

Chromium (as Cr VI) 3.0E-03 Low (O) 0.025 7.5E-05 2.9E-05 Oral (rat) Reduced liver/spleen weight (O) UF=100

Copper 4.0E-02 NA 1 4.0E-02 -- NA NA

Manganese (food) 1.4E-01 Medium (O) 0.04 5.6E-03 1.4E-05 Oral (O) lethargy, tremors, mental disturbance, muscle tonus, and central nervous system effects

(O) UF=1 (O) MF=1

Manganese (soil/water) 4.6E-02 Medium (O) 0.04 1.8E-03 1.4E-05 Oral: water, inhalation

(O) lethargy, tremors, mental disturbance, muscle tonus, and central nervous system effects

(O) UF=1 (O) MF=1 (I) UF=1000

Nickel 2.0E-02 Medium 0.04 8.0E-04 -- Oral: diet (rat) Decreased body & major organ weights (rat) UF=100

Vanadium 7.0E-03 Low 0.026 1.8E-04 -- Oral (rat) Decreased hair cystine UF=100


Table 2A-5. Non-carcinogenic Reference Doses for COPCs (continued)

COPC

Oral Chronic

RfD (mg/kg-day)

Confidence

Level

% GI Absorptiona

Dermal Chronic

RfD (mg/kg-day)

Inhalation Chronic

RfD (mg/kg-day)

RfD Basis (vehicle)

Critical Effect

Uncertainty/ Modifying

Factor

Zinc 3.0E-01 Medium 0.3 9.0E-02 -- Oral

(O) copper deficiency & hypochromic microcytic anemia (human) (I) pulmonary & gastrointestinal effects (human)

UF=3

Organics 2,4,6-Trinitrotoluene 5.0E-04 Medium 1 5.0E-04 -- Oral (dog) Liver effects UF=1000

Chloroform 1.0E-02 Medium (O) 1 1.0E-02 -- Oral Liver fatty cyst formation (dog) (O) UF=1000

a % GI absorption values from EPA 2004. MF = Modifying factor (the default modifying factor is 1). -- = No value available 1 (O) indicates oral, (I) indicates inhalation. UF = Uncertainty factor. 2 RfD = Reference dose. NA = Not available 3 4 5

Table 2A-6. Cancer Slope Factors for COPCs

COPC

Oral Slope Factor

(mg/kg-day)-1

% GI

Absorptiona

Dermal Slope Factor

(mg/kg-day)-1

Inhalation Slope Factor (mg/kg-day)-1

EPA Class

TEF

Type of Cancer

Inorganics Arsenic 1.5E+00 0.95 1.5E+00 1.5E+01 A -- Respiratory system tumors Cadmium (soil/food) -- 0.025 -- 6.3E+00 B1 -- Respiratory tract and lung tumors Cadmium (water) -- 0.05 -- 6.3E+00 B1 -- Respiratory tract and lung tumors Chromium (as Cr VI) -- 0.025 -- 4.2E+01 A -- Lung tumors

Organics 2,4,6-Trinitrotoluene 3.0E-02 1 3.0E-02 -- C -- Bladder transitional cell papilloma Benz(a)anthracene 7.3E-01 0.58 7.3E-01 3.1E-01 B2 0.1 Stomach tumors (mouse) Benzo(a)pyrene 7.3E+00 0.58 7.3E+00 3.1E+00 B2 1 Stomach, nasal cavity, larynx, tracheak, and pharnyx Benzo(b)fluoranthene 7.3E-01 0.58 7.3E-01 3.1E-01 B2 0.1 Tumors Chloroform 6.1E-03 1 6.1E-03 8.1E-02 B2 -- Colon, rectum, bladder, and liver carcinoma (mouse) Indeno(1,2,3-cd)pyrene 7.3E-01 0.58 7.3E-01 3.1E-01 B2 0.1 Tumors


a % GI absorption values from EPA 2004. 1 TEF = Toxicity Equivalency Factor is based on the relative potency of each carcinogenic polycyclic aromatic hydrocarbon (PAH) relative to that of benzo(a)pyrene. 2 -- = No value available. 3 4


Table 2A-7. EBG Shallow Surface Soil (0-1 ft bgs) Calculations of Blood Lead Concentrations for Juvenile Trespasser

PbB Equation1 Juvenile Trespasser Exposure Variable 1* 2*

Description of Exposure Variable

Units GSDi = 1.8 GSDi = 2.1

PbS X X Soil lead concentration ug/g or mg/kg 165 165

Rfetal/maternal X X Fetal/maternal PbB ratio -- 0.9 0.9

BKSF X X Biokinetic Slope Factor ug/dL per ug/day 0.4 0.4

GSDi X X Geometric standard deviation PbB -- 1.8 2.1

PbB0 X X Baseline PbB ug/dL 2.2 1.7

IRS X Soil ingestion rate (including soil-derived indoor dust) g/day 0.2 0.2

IRS+D X Total ingestion rate of outdoor soil and indoor dust g/day 0.2 0.2

WS X Weighting factor; fraction of IRS+D ingested as outdoor soil -- -- --

KSD X Mass fraction of soil in dust -- -- --

AFS, D X X Absorption fraction (same for soil and dust) -- 0.12 0.12

EFS, D X X Exposure frequency (same for soil and dust) days/yr 50 50

ATS, D X X Averaging time (same for soil and dust) days/yr 365 365

PbBadult PbB of adult receptor, geometric mean ug/dL 2.4 1.9

PbBfetal, 0.95 95th percentile PbB among fetuses of adult workers ug/dL 5.7 5.8

PbBt Target PbB level of concern (e.g., 10 ug/dL) ug/dL 10.0 10.0

P(PbB > PbBt) Probability that PbB > PbBt, assuming lognormal distribution % 0.5% 0.9%

1 Equation 1 does not apportion exposure between soil and dust ingestion (excludes WS, KSD). When IRS = IRS+D and WS = 1.0, the equations yield the same PbBfetal,0.95. 1 * Equation 1, based on Eq. 1, 2 in EPA (2003). U.S. EPA Technical Review Workgroup for Lead, Adult Lead Committee. 2 PbB adult = (PbS*BKSF*IRS+D*AFS,D*EFS,D/ATS,D) + PbB0 3 PbB fetal, 0.95 = PbBadult * (GSDi

1.645 * R) 4 5 6 7 8


Table 2A-8. EBG Shallow Surface Soil (0-1 ft bgs) Calculations of Blood Lead Concentrations for Adult Trespasser 1

PbB Equation1 Adult Trespasser Exposure Variable 1* 2*

Description of Exposure Variable

Units

GSDi = 1.8 GSDi = 2.1

PbS X X Soil lead concentration ug/g or mg/kg 165 165

Rfetal/maternal X X Fetal/maternal PbB ratio -- 0.9 0.9

BKSF X X Biokinetic Slope Factor ug/dL per ug/day

0.4 0.4

GSDi X X Geometric standard deviation PbB -- 1.8 2.1

PbB0 X X Baseline PbB ug/dL 2.2 1.7

IRS X Soil ingestion rate (including soil-derived indoor dust) g/day 0.1 0.1

IRS+D X Total ingestion rate of outdoor soil and indoor dust g/day 0.1 0.1

WS X Weighting factor; fraction of IRS+D ingested as outdoor soil -- -- --

KSD X Mass fraction of soil in dust -- -- --

AFS, D X X Absorption fraction (same for soil and dust) -- 0.12 0.12

EFS, D X X Exposure frequency (same for soil and dust) days/yr 75 75

ATS, D X X Averaging time (same for soil and dust) days/yr 365 365

PbBadult PbB of adult receptor, geometric mean ug/dL 2.4 1.9

PbBfetal, 0.95 95th percentile PbB among fetuses of adult workers ug/dL 5.6 5.7

PbBt Target PbB level of concern (e.g., 10 ug/dL) ug/dL 10.0 10.0

P(PbB > PbBt) Probability that PbB > PbBt, assuming lognormal distribution % 0.4% 0.8% 1 Equation 1 does not apportion exposure between soil and dust ingestion (excludes WS, KSD). When IRS = IRS+D and WS = 1.0, the equations yield the same PbBfetal,0.95. * Equation 1, based on Eq. 1, 2 in USEPA (2003). U.S. EPA Technical Review Workgroup for Lead, Adult Lead Committee. PbB adult = (PbS*BKSF*IRS+D*AFS,D*EFS,D/ATS,D) + PbB0 PbB fetal, 0.95 = PbBadult * (GSDi

1.645 * R)

2 3 4


Table 2A-9. Juvenile Trespasser Shallow Surface Soil (0-1 ft bgs) Non-carcinogenic Hazards - Direct Contact

Daily Intake (mg/kg-d) Hazard Quotient (HQ)

COPC

EPC

(mg/kg) Ingestion Dermal Inhalation Ingestion Dermal Inhalation

Total HI Across All Pathways

COCa

EBG Aluminum 1.3E+04 6.7E-04 6.6E-05 7.3E-08 6.7E-04 6.6E-05 5.1E-05 7.9E-04 Antimony 8.0E+00 4.0E-07 3.9E-08 4.4E-11 1.0E-03 6.6E-04 1.7E-03 Arsenic 1.1E+01 5.5E-07 1.6E-06 5.9E-11 1.8E-03 5.4E-03 7.2E-03 Barium 2.5E+02 1.3E-05 1.2E-06 1.4E-09 1.8E-04 2.5E-04 9.5E-06 4.4E-04 Cadmium 1.8E+00 8.9E-08 8.7E-09 9.6E-12 8.9E-05 3.5E-04 4.4E-04 Chromium 2.3E+01 1.2E-06 1.1E-07 1.2E-10 3.8E-04 1.5E-03 4.4E-06 1.9E-03 Copper 8.2E+01 4.2E-06 4.1E-07 4.5E-10 1.0E-04 1.0E-05 1.1E-04 Manganese 8.0E+02 4.1E-05 4.0E-06 4.4E-09 8.9E-04 2.2E-03 3.1E-04 3.4E-03 Vanadium 2.1E+01 1.0E-06 1.0E-07 1.1E-10 1.5E-04 5.6E-04 7.1E-04 Zinc 5.7E+02 2.9E-05 2.8E-06 3.1E-09 9.7E-05 3.1E-05 1.3E-04 Inorganics Pathway Total 5.4E-03 1.1E-02 3.7E-04 1.7E-02 2,4,6-Trinitrotoluene 4.8E-01 2.4E-08 2.4E-07 2.6E-12 4.9E-05 4.8E-04 5.3E-04 Benz(a)anthracene 3.2E-01 1.6E-08 2.1E-07 1.8E-12 Benzo(a)pyrene 3.2E-01 1.6E-08 2.1E-07 1.8E-12 Benzo(b)fluoranthene 4.2E-01 2.1E-08 2.7E-07 2.3E-12 Indeno(1,2,3-cd)pyrene 3.0E-01 1.5E-08 1.9E-07 1.7E-12 Organics Pathway Total 4.9E-05 4.8E-04 5.3E-04 Pathway Total - Chemicals 5.4E-03 1.1E-02 3.7E-04 1.7E-02

a COPCs are identified as chemicals of concern (COCs) if the total HI across all pathways is > 1 (H). 1 COPC = Chemical of Potential Concern. 2 EPC = Exposure Point Concentration. 3 HI = Hazard Index. 4


Table 2A-10. Juvenile Trespasser Shallow Surface Soil (0-1 ft bgs) Carcinogenic Risks - Direct Contact

Daily Intake (mg/kg-d) Risk

COPC

EPC


Total Risk Across All Pathways

COCa

EBG Aluminum 1.3E+04 9.6E-05 9.4E-06 1.0E-08 Antimony 8.0E+00 5.8E-08 5.6E-09 6.2E-12 Arsenic 1.1E+01 7.8E-08 2.3E-07 8.5E-12 1.2E-07 3.4E-07 1.3E-10 4.6E-07 Barium 2.5E+02 1.8E-06 1.8E-07 1.9E-10 Cadmium 1.8E+00 1.3E-08 1.2E-09 1.4E-12 8.7E-12 8.7E-12 Chromium 2.3E+01 1.6E-07 1.6E-08 1.8E-11 7.5E-10 7.5E-10 Copper 8.2E+01 6.0E-07 5.8E-08 6.5E-11 Manganese 8.0E+02 5.8E-06 5.7E-07 6.3E-10 Vanadium 2.1E+01 1.5E-07 1.5E-08 1.6E-11 Zinc 5.7E+02 4.1E-06 4.0E-07 4.5E-10 Inorganics Pathway Total 1.2E-07 3.4E-07 8.8E-10 4.6E-07 2,4,6-Trinitrotoluene 4.8E-01 3.5E-09 3.4E-08 3.8E-13 1.0E-10 1.0E-09 1.1E-09 Benz(a)anthracene 3.2E-01 2.3E-09 2.9E-08 2.5E-13 1.7E-09 2.1E-08 7.8E-14 2.3E-08 Benzo(a)pyrene 3.2E-01 2.3E-09 3.0E-08 2.5E-13 1.7E-08 2.2E-07 7.8E-13 2.3E-07 Benzo(b)fluoranthene 4.2E-01 3.0E-09 3.8E-08 3.3E-13 2.2E-09 2.8E-08 1.0E-13 3.0E-08 Indeno(1,2,3-cd)pyrene 3.0E-01 2.2E-09 2.8E-08 2.4E-13 1.6E-09 2.0E-08 7.3E-14 2.2E-08 Organics Pathway Total 2.3E-08 2.9E-07 1.0E-12 3.1E-07 Pathway Total - Chemicals 1.4E-07 6.3E-07 8.9E-10 7.7E-07

a COPCs are identified as chemicals of concern (COCs) if the total ILCR across all pathways is > 1E-06 (R). 1 COPC = Chemical of Potential Concern. 2 EPC = Exposure Point Concentration. 3 ILCR = Incremental Lifetime Cancer Risk. 4 5


Table 2A-11. Adult Trespasser Shallow Surface Soil (0-1 ft bgs) Non-carcinogenic Hazards - Direct Contact 1


COPC

EPC



COCa

EBG Aluminum 1.3E+04 3.3E-04 8.9E-05 7.0E-08 3.3E-04 8.9E-05 4.9E-05 4.6E-04 Antimony 8.0E+00 1.9E-07 5.3E-08 4.2E-11 4.9E-04 8.9E-04 1.4E-03 Arsenic 1.1E+01 2.6E-07 2.2E-06 5.7E-11 8.8E-04 7.2E-03 8.1E-03 Barium 2.5E+02 6.0E-06 1.7E-06 1.3E-09 8.6E-05 3.4E-04 9.2E-06 4.3E-04 Cadmium 1.8E+00 4.3E-08 1.2E-08 9.3E-12 4.3E-05 4.7E-04 5.1E-04 Chromium 2.3E+01 5.6E-07 1.5E-07 1.2E-10 1.9E-04 2.0E-03 4.2E-06 2.2E-03 Copper 8.2E+01 2.0E-06 5.5E-07 4.4E-10 5.0E-05 1.4E-05 6.4E-05 Manganese 8.0E+02 2.0E-05 5.4E-06 4.3E-09 4.3E-04 2.9E-03 3.0E-04 3.7E-03 Vanadium 2.1E+01 5.0E-07 1.4E-07 1.1E-10 7.2E-05 7.6E-04 8.3E-04 Zinc 5.7E+02 1.4E-05 3.8E-06 3.0E-09 4.7E-05 4.2E-05 8.9E-05 Inorganics Pathway Total 2.6E-03 1.5E-02 3.6E-04 1.8E-02 2,4,6-Trinitrotoluene 4.8E-01 1.2E-08 3.2E-07 2.5E-12 2.3E-05 6.4E-04 6.7E-04 Benz(a)anthracene 3.2E-01 7.8E-09 2.8E-07 1.7E-12 Benzo(a)pyrene 3.2E-01 7.9E-09 2.8E-07 1.7E-12 Benzo(b)fluoranthene 4.2E-01 1.0E-08 3.6E-07 2.2E-12 Indeno(1,2,3-cd)pyrene 3.0E-01 7.4E-09 2.6E-07 1.6E-12 Organics Pathway Total 2.3E-05 6.4E-04 6.7E-04 Pathway Total - Chemicals 2.6E-03 1.5E-02 3.6E-04 1.8E-02 a COPCs are identified as chemicals of concern (COCs) if the total HI across all pathways is > 1 (H). COPC = Chemical of Potential Concern. EPC = Exposure Point Concentration. HI = Hazard Index.

2 3 4 5 6 7 8 9


Table 2A-12. Adult Trespasser Shallow Surface Soil (0-1 ft bgs) Carcinogenic Risks - Direct Contact 1


COPC

EPC



COCa

EBG Aluminum 1.3E+04 1.4E-04 3.8E-05 3.0E-08 Antimony 8.0E+00 8.3E-08 2.3E-08 1.8E-11 Arsenic 1.1E+01 1.1E-07 9.3E-07 2.5E-11 1.7E-07 1.4E-06 3.7E-10 1.6E-06 R Barium 2.5E+02 2.6E-06 7.1E-07 5.6E-10 Cadmium 1.8E+00 1.8E-08 5.0E-09 4.0E-12 2.5E-11 2.5E-11 Chromium 2.3E+01 2.4E-07 6.5E-08 5.2E-11 2.2E-09 2.2E-09 Copper 8.2E+01 8.6E-07 2.4E-07 1.9E-10 Manganese 8.0E+02 8.4E-06 2.3E-06 1.8E-09 Vanadium 2.1E+01 2.2E-07 5.9E-08 4.7E-11 Zinc 5.7E+02 6.0E-06 1.6E-06 1.3E-09 Inorganics Pathway Total 1.7E-07 1.4E-06 2.6E-09 1.6E-06 2,4,6-Trinitrotoluene 4.8E-01 5.0E-09 1.4E-07 1.1E-12 1.5E-10 4.1E-09 4.3E-09 Benz(a)anthracene 3.2E-01 3.3E-09 1.2E-07 7.2E-13 2.4E-09 8.7E-08 2.2E-13 8.9E-08 Benzo(a)pyrene 3.2E-01 3.4E-09 1.2E-07 7.3E-13 2.5E-08 8.8E-07 2.3E-12 9.0E-07 Benzo(b)fluoranthene 4.2E-01 4.4E-09 1.6E-07 9.5E-13 3.2E-09 1.1E-07 2.9E-13 1.2E-07 Indeno(1,2,3-cd)pyrene 3.0E-01 3.2E-09 1.1E-07 6.8E-13 2.3E-09 8.2E-08 2.1E-13 8.4E-08 Organics Pathway Total 3.3E-08 1.2E-06 3.0E-12 1.2E-06 Pathway Total - Chemicals 2.0E-07 2.6E-06 2.6E-09 2.8E-06 a COPCs are identified as chemicals of concern (COCs) if the total ILCR across all pathways is > 1E-06 (R). COPC = Chemical of Potential Concern. EPC = Exposure Point Concentration.

2


Table 2A-13. Juvenile Trespasser Sediment Non-carcinogenic Hazards - Direct Contact 1


COPC

EPC



COCa

EBG Aluminum 1.3E+04 6.5E-04 6.4E-05 7.1E-08 6.5E-04 6.4E-05 5.0E-05 7.7E-04 Antimony 1.6E+02 7.9E-06 7.7E-07 8.6E-10 2.0E-02 1.3E-02 3.3E-02 Arsenic 1.4E+01 7.1E-07 2.1E-06 7.7E-11 2.4E-03 6.9E-03 9.3E-03 Barium 3.2E+02 1.6E-05 1.6E-06 1.7E-09 2.3E-04 3.2E-04 1.2E-05 5.6E-04 Cadmium 3.5E+00 1.8E-07 1.7E-08 1.9E-11 1.8E-04 7.0E-04 8.8E-04 Chromium 3.8E+01 1.9E-06 1.9E-07 2.1E-10 6.5E-04 2.5E-03 7.4E-06 3.2E-03 Copper 1.5E+02 7.6E-06 7.4E-07 8.2E-10 1.9E-04 1.8E-05 2.1E-04 Manganese 5.6E+02 2.9E-05 2.8E-06 3.1E-09 6.2E-04 1.5E-03 2.2E-04 2.4E-03 Nickel 3.3E+01 1.7E-06 1.7E-07 1.8E-10 8.4E-05 2.1E-04 2.9E-04 Vanadium 2.3E+01 1.2E-06 1.1E-07 1.3E-10 1.7E-04 6.2E-04 7.9E-04 Zinc 1.5E+03 7.5E-05 7.3E-06 8.1E-09 2.5E-04 8.1E-05 3.3E-04 Inorganics Pathway Total 2.5E-02 2.6E-02 2.9E-04 5.1E-02 2,4,6-Trinitrotoluene 3.0E+00 1.5E-07 1.5E-06 1.6E-11 3.0E-04 2.9E-03 3.2E-03 Benzo(b)fluoranthene 6.4E-01 3.3E-08 4.2E-07 3.5E-12 Organics Pathway Total 3.0E-04 2.9E-03 3.2E-03 Pathway Total - Chemicals 2.5E-02 2.9E-02 2.9E-04 5.5E-02

a COPCs are identified as chemicals of concern (COCs) if the total HI across all pathways is > 1 (H). 2 COPC = Chemical of Potential Concern. 3 EPC = Exposure Point Concentration. 4 HI = Hazard Index. 5 6


Table 2A-14. Juvenile Trespasser Sediment Carcinogenic Risks - Direct Contact


COPC

EPC



COCa

EBG Aluminum 1.3E+04 9.3E-05 9.1E-06 1.0E-08 Antimony 1.6E+02 1.1E-06 1.1E-07 1.2E-10 Arsenic 1.4E+01 1.0E-07 3.0E-07 1.1E-11 1.5E-07 4.5E-07 1.7E-10 6.0E-07 Barium 3.2E+02 2.3E-06 2.2E-07 2.5E-10 Cadmium 3.5E+00 2.6E-08 2.5E-09 2.8E-12 1.7E-11 1.7E-11 Chromium 3.8E+01 2.8E-07 2.7E-08 3.0E-11 1.3E-09 1.3E-09 Copper 1.5E+02 1.1E-06 1.1E-07 1.2E-10 Manganese 5.6E+02 4.1E-06 4.0E-07 4.4E-10 Nickel 3.3E+01 2.4E-07 2.4E-08 2.6E-11 Vanadium 2.3E+01 1.7E-07 1.6E-08 1.8E-11 Zinc 1.5E+03 1.1E-05 1.0E-06 1.2E-09 Inorganics Pathway Total 1.5E-07 4.5E-07 1.4E-09 6.0E-07 2,4,6-Trinitrotoluene 3.0E+00 2.1E-08 2.1E-07 2.3E-12 6.4E-10 6.3E-09 6.9E-09 Benzo(b)fluoranthene 6.4E-01 4.7E-09 5.9E-08 5.1E-13 3.4E-09 4.3E-08 1.6E-13 4.7E-08 Organics Pathway Total 4.0E-09 5.0E-08 1.6E-13 5.4E-08 Pathway Total - Chemicals 1.6E-07 5.0E-07 1.4E-09 6.5E-07

a COPCs are identified as chemicals of concern (COCs) if the total ILCR across all pathways is > 1E-06 (R). 1 COPC = Chemical of Potential Concern. 2 EPC = Exposure Point Concentration. 3 ILCR = Incremental Lifetime Cancer Risk. 4


Table 2A-15. Adult Trespasser Sediment Non-carcinogenic Hazards - Direct Contact 1


COPC

EPC



COCa

EBG Aluminum 1.3E+04 3.2E-04 8.6E-05 6.8E-08 3.2E-04 8.6E-05 4.8E-05 4.5E-04 Antimony 1.6E+02 3.8E-06 1.0E-06 8.3E-10 9.5E-03 1.7E-02 2.7E-02 Arsenic 1.4E+01 3.4E-07 2.8E-06 7.4E-11 1.1E-03 9.4E-03 1.1E-02 Barium 3.2E+02 7.7E-06 2.1E-06 1.7E-09 1.1E-04 4.3E-04 1.2E-05 5.5E-04 Cadmium 3.5E+00 8.6E-08 2.4E-08 1.9E-11 8.6E-05 9.4E-04 1.0E-03 Chromium 3.8E+01 9.4E-07 2.6E-07 2.0E-10 3.1E-04 3.4E-03 7.1E-06 3.7E-03 Copper 1.5E+02 3.6E-06 1.0E-06 7.9E-10 9.1E-05 2.5E-05 1.2E-04 Manganese 5.6E+02 1.4E-05 3.8E-06 3.0E-09 3.0E-04 2.0E-03 2.1E-04 2.6E-03 Nickel 3.3E+01 8.1E-07 2.2E-07 1.8E-10 4.1E-05 2.8E-04 3.2E-04 Vanadium 2.3E+01 5.6E-07 1.5E-07 1.2E-10 8.0E-05 8.4E-04 9.2E-04 Zinc 1.5E+03 3.6E-05 9.8E-06 7.8E-09 1.2E-04 1.1E-04 2.3E-04 Inorganics Pathway Total 1.2E-02 3.5E-02 2.8E-04 4.7E-02 2,4,6-Trinitrotoluene 3.0E+00 7.2E-08 2.0E-06 1.6E-11 1.4E-04 3.9E-03 4.1E-03 Benzo(b)fluoranthene 6.4E-01 1.6E-08 5.6E-07 3.4E-12 Organics Pathway Total 1.4E-04 3.9E-03 4.1E-03 Pathway Total - Chemicals 1.2E-02 3.9E-02 2.8E-04 5.1E-02 a COPCs are identified as chemicals of concern (COCs) if the total HI across all pathways is > 1 (H). COPC = Chemical of Potential Concern. EPC = Exposure Point Concentration. HI = Hazard Index.

2 3 4

5 6 7 8 9 10 11 12


Table 2A-16. Adult Trespasser Sediment Carcinogenic Risks - Direct Contact 1

Daily Intake (mg/kg-d)

Risk

COPC

EPC



COCa

EBG Aluminum 1.3E+04 1.4E-04 3.7E-05 2.9E-08 Antimony 1.6E+02 1.6E-06 4.5E-07 3.5E-10 Arsenic 1.4E+01 1.5E-07 1.2E-06 3.2E-11 2.2E-07 1.8E-06 4.8E-10 2.0E-06 R Barium 3.2E+02 3.3E-06 9.0E-07 7.2E-10 Cadmium 3.5E+00 3.7E-08 1.0E-08 8.0E-12 5.0E-11 5.0E-11 Chromium 3.8E+01 4.0E-07 1.1E-07 8.7E-11 3.7E-09 3.7E-09 Copper 1.5E+02 1.6E-06 4.3E-07 3.4E-10 Manganese 5.6E+02 5.9E-06 1.6E-06 1.3E-09 Nickel 3.3E+01 3.5E-07 9.6E-08 7.6E-11 Vanadium 2.3E+01 2.4E-07 6.5E-08 5.2E-11 Zinc 1.5E+03 1.5E-05 4.2E-06 3.3E-09 Inorganics Pathway Total 2.2E-07 1.8E-06 4.2E-09 2.0E-06 2,4,6-Trinitrotoluene 3.0E+00 3.1E-08 8.5E-07 6.7E-12 9.3E-10 2.5E-08 2.6E-08 Benzo(b)fluoranthene 6.4E-01 6.8E-09 2.4E-07 1.5E-12 4.9E-09 1.8E-07 4.5E-13 1.8E-07 Organics Pathway Total 5.9E-09 2.0E-07 4.5E-13 2.1E-07 Pathway Total - Chemicals 2.3E-07 2.0E-06 4.2E-09 2.2E-06 a COPCs are identified as chemicals of concern (COCs) if the total ILCR across all pathways is > 1E-06 (R). COPC = Chemical of Potential Concern. EPC = Exposure Point Concentration.

2 3


Table 2A-17. Juvenile Trespasser Surface Water Non-Carcinogenic Hazards - Direct Contact


COPC

EPC

(mg/L) Ingestion Dermal Ingestion Dermal


COCa

EBG Aluminum 2.9E+01 8.9E-03 3.1E-03 8.9E-03 3.1E-03 1.2E-02 Antimony 1.1E-02 3.4E-06 6.0E-07 8.4E-03 1.0E-02 1.8E-02 Arsenic 7.2E-02 2.2E-05 6.9E-06 7.3E-02 2.3E-02 9.6E-02 Cadmium 4.0E-03 1.2E-06 6.9E-08 2.4E-03 2.7E-03 5.1E-03 Chromium 3.7E-02 1.1E-05 1.9E-06 3.8E-03 2.5E-02 2.8E-02 Manganese 9.9E+00 3.0E-03 6.3E-04 6.6E-02 3.4E-01 4.1E-01 Vanadium 5.7E-02 1.7E-05 3.8E-06 2.5E-03 2.1E-02 2.3E-02 Inorganics Pathway Total 1.7E-01 4.3E-01 5.9E-01 Chloroform 7.1E-04 2.2E-07 3.1E-07 2.2E-05 3.1E-05 5.3E-05 Organics Pathway Total 2.2E-05 3.1E-05 5.3E-05 Pathway Total - Chemicals 1.7E-01 4.3E-01 5.9E-01 a COPCs are identified as chemicals of concern (COCs) if the total HI across all pathways is > 1 (H). 1 COPC = Chemical of Potential Concern. 2 EPC = Exposure Point Concentration. 3 HI = Hazard Index. 4

5 6

Table 2A-18. Juvenile Trespasser Surface Water Carcinogenic Risks - Direct Contact 7


COPC

EPC

(mg/L) Ingestion Dermal Ingestion Dermal


COCa

EBG Aluminum 2.9E+01 1.3E-03 4.5E-04 Antimony 1.1E-02 4.8E-07 8.6E-08 Arsenic 7.2E-02 3.1E-06 9.9E-07 4.7E-06 1.5E-06 6.2E-06 R Cadmium 4.0E-03 1.7E-07 9.8E-09 Chromium 3.7E-02 1.6E-06 2.6E-07 Manganese 9.9E+00 4.3E-04 9.0E-05


Vanadium 5.7E-02 2.5E-06 5.4E-07 Inorganics Pathway Total 4.7E-06 1.5E-06 6.2E-06 Chloroform 7.1E-04 3.1E-08 4.5E-08 1.9E-10 2.7E-10 4.6E-10 Organics Pathway Total 1.9E-10 2.7E-10 4.6E-10 Pathway Total - Chemicals 4.7E-06 1.5E-06 6.2E-06 a COPCs are identified as chemicals of concern (COCs) if the total ILCR across all pathways is > 1E-06 (R). 1 COPC = Chemical of Potential Concern. 2 EPC = Exposure Point Concentration. 3 ILCR = Incremental Lifetime Cancer Risk. 4


Table 2A-19. Adult Trespasser Surface Water Non-Carcinogenic Hazards - Direct Contact 1


COPC

EPC

(mg/L) Ingestion Dermal Inhalation Ingestion Dermal Inhalation

Total HI Across

All Pathways

COCa

EBG Aluminum 2.9E+01 8.6E-03 2.1E-03 8.6E-03 2.1E-03 1.1E-02 Antimony 1.1E-02 3.3E-06 4.0E-07 8.1E-03 6.7E-03 1.5E-02 Arsenic 7.2E-02 2.1E-05 4.7E-06 7.1E-02 1.6E-02 8.6E-02 Cadmium 4.0E-03 1.2E-06 4.6E-08 2.3E-03 1.9E-03 4.2E-03 Chromium 3.7E-02 1.1E-05 1.2E-06 3.6E-03 1.7E-02 2.0E-02 Manganese 9.9E+00 2.9E-03 4.2E-04 6.3E-02 2.3E-01 2.9E-01 Vanadium 5.7E-02 1.7E-05 2.6E-06 2.4E-03 1.4E-02 1.6E-02 Inorganics Pathway Total 1.6E-01 2.9E-01 4.5E-01 Chloroform 7.1E-04 2.1E-07 2.1E-07 2.1E-05 2.1E-05 4.2E-05 Organics Pathway Total 2.1E-05 2.1E-05 4.2E-05 Pathway Total - Chemicals 1.6E-01 2.9E-01 4.5E-01 a COPCs are identified as chemicals of concern (COCs) if the total HI across all pathways is > 1 (H). COPC = Chemical of Potential Concern. EPC = Exposure Point Concentration. HI = Hazard Index.

2 3


Table 2A-20. Adult Trespasser Surface Water Carcinogenic Risks - Direct Contact 1


COPC

EPC

(mg/L) Ingestion Dermal Inhalation Ingestion Dermal Inhalation


COCa

EBG Aluminum 2.9E+01 3.7E-03 9.0E-04 Antimony 1.1E-02 1.4E-06 1.7E-07 Arsenic 7.2E-02 9.1E-06 2.0E-06 1.4E-05 3.0E-06 1.7E-05 R Cadmium 4.0E-03 5.0E-07 2.0E-08 Chromium 3.7E-02 4.7E-06 5.3E-07 Manganese 9.9E+00 1.2E-03 1.8E-04 Vanadium 5.7E-02 7.1E-06 1.1E-06 Inorganics Pathway Total 1.4E-05 3.0E-06 1.7E-05 Chloroform 7.1E-04 8.9E-08 9.1E-08 5.4E-10 5.5E-10 1.1E-09 Organics Pathway Total 5.4E-10 5.5E-10 1.1E-09 Pathway Total - Chemicals 1.4E-05 3.0E-06 1.7E-05 a COPCs are identified as chemicals of concern (COCs) if the total ILCR across all pathways is > 1E-06 (R). COPC = Chemical of Potential Concern. EPC = Exposure Point Concentration.


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Appendix 3A Fate and Transport of COCs in Soil

TABLE OF CONTENTS 1 2 3 4 5 6 7 8 9

10 11

12 13 14

3A.0 CONTAMINANT FATE AND TRANSPORT ...................................................................3A-1

3A.1 INTRODUCTION...............................................................................................................3A-1 3A.2 EVALUATION ...................................................................................................................3A-1

3A.2.1 RI Evaluation Process...................................................................................................3A-1 3A.2.2 AOC-Specific Evaluation .............................................................................................3A-2 3A.2.3 Refined AOC-Specific Modeling Results ....................................................................3A-3

3A.3 CONCLUSIONS .................................................................................................................3A-3

LIST OF TABLES

Table 3A-1. Potential Groundwater Impacts Identified in Phase II RI for EBG.............................3A-3


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3A.0 CONTAMINANT FATE AND TRANSPORT 1

2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40

3A.1 INTRODUCTION An assessment of impacted soils at EBG was conducted to evaluate their potential to impact groundwater both at the AOC (unrestricted land use exposure scenario) and at an exposure point down-gradient of the AOC (restricted land use exposure scenario) to ensure residual concentrations in soils are protective of groundwater under both potential land use exposure scenarios. The process for identifying these soil constituents with potential to impact groundwater is explained and executed in Section 3A.2. Section 3A.3 presents the conclusion of the evaluation: a list of AOC-specific constituents producing unacceptable impact to groundwater beneath the source (affecting unrestricted land usage) or at a receptor downgradient of the source (affecting restricted land usage). 3A.2 EVALUATION This section describes the steps implemented to identify constituents in soils impacting groundwater:

• Section 3A.2.1 lists constituents identified in the RI Report as potentially impacting groundwater.

• Section 3A.2.2 evaluates these constituents across multiple media to further refine the list of potential constituents.

• Section 3A.2.3 presents refinements to the modeling performed in the RI Report, if appropriate.

3A.2.1 RI Evaluation Process Constituents are identified in Section 5 (Contaminant Fate and Transport) of the RI Report that potentially impact groundwater at EBG. The RI Report identified potential impacts beneath the source and at receptor locations downgradient of the source. The RI Report identified constituents with potential or observed impacts beneath a source area as CMCOPCs. Potential impacts beneath the source were determined from model predictions of observed soil sample results where the predicted concentration at the water table beneath the source exceeded the MCL or Region 9 PRG. Constituents also are identified as CMCOPCs if they were detected in AOC groundwater and exceeded the MCL or Region 9 PRG. The RI Report identified constituents with potential groundwater impacts at receptor locations down gradient of the source area as CMCOCs. Potential impacts to receptors downgradient of the AOC source were determined in the RI Report based on modeling of contaminant migration (i.e., CMCOPC migration) within the groundwater aquifer. All CMCOPCs were evaluated for impacts at downgradient receptors.

RVAAP 6 High Priority AOCs EBG Feasibility Study Appendix 3A Draft March 2006 Page 3A-1

3A.2.2 AOC-Specific Evaluation 1 2 3 4 5 6 7

The constituents identified in Table 3A-1 are evaluated across multiple media. The evaluation examines characteristics of the constituents detected, distribution in soil or water compared to background concentrations, and the conservative nature of modeling completed during the RI. The criteria below were evaluated to determine the potential for impacts to groundwater from impacted soils at EBG.

8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Background: If model input source concentrations are less than either surface (0-1 ft bgs) or subsurface (1-3 ft bgs) background, predicted results are compared to observed groundwater data to assess the generally conservative nature of the modeling. As part of this evaluation, the soils data are reviewed for patterns of detections (both vertically and laterally) and nearby surface water and groundwater results are also reviewed to ensure consistency between predicted and observed results when source concentrations from the RI were at or below background:

• For CMCOPCs where all observed sample results are less than background (either surface or subsurface soils), the constituent is removed from further consideration of future groundwater impacts.

• For CMCOPCs where the source concentration (i.e., concentration input to modeling) is less than

background levels (either surface or subsurface soils), the constituent is removed from further consideration of future groundwater impacts.

• For CMCOPCs where one or more samples or the source concentration exceeds background

levels, RI data are further reviewed for pattern of detection (e.g., do elevated surface and subsurface soil results occur at the same location; is there a pattern of detections indicative of a contaminant plume; are the elevated detections located in separate areas with no recognizable pattern).

29 30 31 32 33 34 35 36

Predicted Time of Maximum Impact: If the predicted time of maximum impact in RI is short (e.g., less than 10 years) and activities ceased at the AOC long before that period of time, the predicted maximum impact has likely occurred in the past. In these cases, observed groundwater data are reviewed, and if maximum observed groundwater data are less than the constituent-specific MCL or RBC, the constituent is removed from further consideration of future groundwater impacts. If predicted maximum impact is less than the constituent-specific MCL or RBC, the constituent is removed from further consideration of future groundwater impacts.

37 38 39 40 41 42

Detected in Groundwater: If a constituent is detected in groundwater, but not detected in soils, the constituent is removed from further consideration of future groundwater impacts. If a constituent is detected in groundwater and is detected in soils at or below background levels, the constituent also is removed from further consideration of future groundwater impacts.


3A.2.2.1 Erie Burning Grounds 1 2 3 4 5 6 7 8 9

Based on the results of the Phase II RI for EBG two constituents are evaluated for potential impacts in groundwater beneath the source and both constituents also are evaluated for potential impacts to groundwater at downgradient receptors (Table 3A-1). Upon further analysis, neither of these constituents were predicted or identified to impact groundwater at the AOC or downgradient of the AOC as summarized below.

Table 3A-1. Potential Groundwater Impacts Identified in Phase II RI for EBG

Potential Groundwater Impact Beneath the Sourcea

Potential Groundwater Impact Downgradient of the Sourceb

EBG Arsenic Arsenic RDX RDX

aPotential groundwater impact beneath the source is determined from SESOIL+AT123D modeling in the RI of the concentration at the water table. bPotential groundwater impact downgradient of the source is determined from AT123D modeling of the contaminant plume migrating to receptors.

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32

• Arsenic is removed from further consideration of future groundwater impacts because

concentrations detected in soils are consistent with background concentrations. Modeling results indicate background levels of arsenic in soils may result in groundwater impacts in excess of the MCL.

• RDX: RI SESOIL source load modeling with maximum impact predicted in 4 years. Given AOC

history, the maximum impact likely occurred in the past. RDX is removed from further consideration of future groundwater impacts at EBG because there are only two detections in soils, the predicted time of maximum impact to groundwater is 4 years (so maximum impact has likely passed), and RDX has not been detected in surface water or groundwater samples at EBG.

3A.2.3 Refined AOC-Specific Modeling Results Based on the analyses in Section 3A.2.2 of the conservative fate and transport assessment performed in support of the RI for EBG, no COCs were identified for further analysis using the SESOIL/AT123D models previously developed. 3A.3 CONCLUSIONS Impacted soils at EBG are not predicted to impact underlying groundwater beneath the AOC. Therefore, soil remediation for protection of groundwater is not required at this AOC and the AOC may be released for unrestricted land use with respect to future groundwater impacts from impacted soils.




Appendix 5A Initial Screening of

Technologies ~ Aqueous Media

TABLE OF CONTENTS 1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20

21 22 23 24 25

5A.0 TECHNOLOGY TYPES AND PROCESS OPTIONS ~ AQUEOUS MEDIA................5A-1

5A.1 GENERAL RESPONSE ACTIONS ....................................................................................5A-1 5A.1.1 No Action .....................................................................................................................5A-1 5A.1.2 Land Use Controls and Five-Year Reviews .................................................................5A-1 5A.1.3 Containment .................................................................................................................5A-2 5A.1.4 Removal........................................................................................................................5A-2 5A.1.5 Treatment......................................................................................................................5A-2 5A.1.6 Disposal and Handling..................................................................................................5A-2

5A.2 INITIAL SCREENING OF TECHNOLOGIES ~ AQUEOUS MEDIA .............................5A-3 5A.2.1 No Action .....................................................................................................................5A-3 5A.2.2 Land Use Controls and Five-Year Reviews .................................................................5A-3 5A.2.3 Containment .................................................................................................................5A-3 5A.2.4 Removal........................................................................................................................5A-4 5A.2.5 Treatment......................................................................................................................5A-4 5A.2.6 Discharge......................................................................................................................5A-7

5A.3 RETAINED PROCESS OPTIONS FOR AQUEOUS MEDIA...........................................5A-8

LIST OF TABLES

Table 5A-1. Initial Screening of Technology Types and Process Options for Subaqueous Sediment................................................................................................5A-9

Table 5A-2. Retained Process Options for Subaqueous Sediment..................................................5A-8



RVAAP 6 High Priority AOCs EBG Feasibility Study Appendix 5A Draft March 2006 Page 5A-ii

5A.0 TECHNOLOGY TYPES AND PROCESS OPTIONS ~ AQUEOUS

MEDIA 1

2

3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41

This appendix describes the identification and screening of technology types and process options for COCs in impacted subaqueous sediment at EBG (as summarized in Section 3.6). Remediation of impacts to aqueous media (i.e., subaqueous sediments) are not addressed in this FS, however, a preliminary evaluation of options to address impacts to subaqueous sediments is included to support future considerations regarding the need for remedial action either on an AOC-specific or a facility-wide basis. The Federal Remediation Technologies Roundtable (FRTR) has provided guidance for the evaluation of remedial technologies. FRTR provides a screening matrix which assesses the effects potential technologies have on the types of contaminants. This guidance was used as a point of reference throughout this initial screening of technologies. 5A.1 GENERAL RESPONSE ACTIONS This section describes the general response actions (GRAs) and remedial technologies that are potentially applicable at EBG. GRAs are actions that will satisfy the RAOs (Section 3.1) for a specific medium, and may include various process options. GRAs are not remedial alternatives but are potential components of remedial alternatives. GRAs include no action, land use controls, monitoring, containment, removal, treatment, and disposal/handling. 5A.1.1 No Action In this GRA, no action would be undertaken to reduce any hazard to human health or the environment. This action complies with the CERCLA requirement to provide an appropriate option or component of a remedial alternative if no unacceptable risks are present and to provide a baseline against which other alternatives can be compared. 5A.1.2 Land Use Controls and Five-Year Reviews Generally, land use controls reduce the potential for exposure to contaminants, but do not reduce contaminant volume or toxicity. These controls are utilized to supplement and affect the engineering component(s) of a remedy (e.g., treatment, removal, etc.) during short- and long-term implementation. The primary goal of land use controls is to restrict the use of, or limit access to, real property using physical, legal, and/or administrative mechanisms to ensure protectiveness of the remedy. Particular land use controls under consideration at EBG include measures that will restrict land use changes over the long-term, such as governmental controls and enforcement tools. Governmental controls could include building restrictions and zoning controls, while enforcement tools may involve administrative orders, consent decrees or proprietary measures such as negative easements. Informational devices can be governmental (i.e., such as handing out information as part of a permit process) or proprietary (i.e.,


1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43

entering a notice on a deed) and are more short term than governmental controls. Land use controls can be used to supplement engineering controls; however, land use controls are not to be used as the sole remedy at a CERCLA site unless the use of active measures such as treatment and/or containment of source material are determined to not be practicable [(40 CFR § 300.430(a)(1)(iii)(D)]. If land use controls are selected as a component of a remedial alternative achieving restricted land use, the effectiveness of the remedy must undergo five-year reviews. The primary goal of the five-year reviews is to evaluate the implementation and performance of a remedy in order to determine if the remedy is or will be protective of human health and the environment. The five-year reviews may be discontinued upon the site achieving preliminary cleanup goals for unlimited use and unrestricted release. 5A.1.3 Containment Containment can effectively reduce contaminant mobility and the potential for exposure. However, containment actions do not reduce contaminant volume or toxicity. When consolidation is used in conjunction with containment, the overall area of contamination is reduced, thereby reducing the area of potential exposure to individuals. Containment actions for aqueous media include technologies that protect human health and the environment by physically precluding contact with the impacted media. Containment technologies prevent or alter the natural flow by constructing a low-permeability material barrier (e.g., sheet piles, geosynthetic membrane, slurry walls, jet grouting, soil freezing, and hydraulic barriers) to reduce the migration of COCs and the potential for exposure. 5A.1.4 Removal Removal of impacted subaqueous sediment would reduce the potential for long-term human exposure. Subaqueous sediment can be removed using construction equipment (e.g., excavator) or dredges. 5A.1.5 Treatment The treatment options evaluated for subaqueous sediment include various physical, chemical, biological, and thermal technologies. Physical processes involve either physically binding the contaminants to reduce their mobility or the potential for exposure or extracting them from a medium to reduce volumes. Chemical treatment processes add chemicals (in situ or ex situ) to react with contaminants to reduce their toxicity or mobility. Biological treatment involves using microbes to degrade or concentrate contaminants. 5A.1.6 Disposal and Handling Disposal and handling of aqueous sediments would involve the permanent and final placement of waste materials in a manner that protects human health and the environment. Dewatered sediments could be disposed onsite, disposed on site in an engineered facility, or offsite in a permitted or licensed facility such as a regulated landfill. Similarly, concentrated waste resulting from treatment processes could be disposed either on site in a permanent disposal cell or offsite in an approved disposal facility.


1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42

Transportation could be accomplished using a variety of modes. Truck, railcar, and/or barge transportation could be used to move soils onsite or ship waste materials offsite. 5A.2 INITIAL SCREENING OF TECHNOLOGIES ~ AQUEOUS MEDIA This section describes the identification and initial screening of potential technologies to achieve RAOs for aqueous media (i.e., subaqueous sediment) at EBG (as summarized in Section 3.6). Technology types and process options were selected on the basis of their applicability to the environmental media of interest (e.g., surface water). Process options were either retained or eliminated from further consideration on the basis of technical implementability and effectiveness against listed COCs. Results of the initial technology screening are summarized in Table 5A-1. 5A.2.1 No Action No action would be taken to implement remedial technologies to reduce any hazard to human health or the environment. This action complies with the CERCLA requirement to provide an appropriate option or component of a remedial alternative if no unacceptable risks are present. The No Action technology shall be retained as a process option to be further evaluated. 5A.2.2 Land Use Controls and Five-Year Reviews Actions being considered include land use controls and five-year reviews. Land use controls are physical, legal, and administrative mechanisms employed to restrict the use of, or limit access to, real property to prevent or reduce risks to human health and the environment. The implementability of legal and administrative mechanisms depends on an entity assuming responsibility for initiating, implementing, and maintaining the controls. The implementability of legal and administrative controls depends upon arrangements made between property owners in different governmental jurisdictions and the authority of local governments. Specific characteristics of the site determine which controls are appropriate. Legal impediments and costs also affect implementability and schedules. The NCP has outlined criteria to evaluate when the use of land use controls would be acceptable as a component of a remedial alternative. Sites containing residual contamination above acceptable concentrations for unrestricted land use require environmental monitoring and five-year reviews to determine whether the integrity of the controls remains intact. When the site achieves a level of contamination that allows for unlimited use and unrestricted exposure, then at that time five-year reviews may be discontinued. 5A.2.3 Containment Containment actions (e.g., sheet piles, geosynthetic membranes, and slurry walls) prevent or minimize contaminant migration and eliminate exposure pathways. Contaminated medium is neither chemically nor physically changed nor are the volumes of contaminated media reduced. Containment is not applicable for treatment of subaqueous sediment.


5A.2.4 Removal 1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16

Removal of contaminated subaqueous sediments would reduce the potential for long-term human and environmental exposure. Removal would minimize long-term direct human contact and the local migration of impacted material. Subaqueous sediment can be removed using construction equipment (e.g. excavator), dredges, or surface pumping. The process options evaluated for removal of subaqueous sediment include using pumps to remove contaminated sediment from a water body for treatment or disposal. There is the potential for a significant amount of water to be pumped from the wetlands at EBG; however this option will be retained through the initial screening process. 5A.2.5 Treatment Process options usually screened for the treatment of surface water consist of ex situ and in situ processes, including various physical, chemical, biological, and thermal options and can be used for treating collected sediment slurry water. 5A.2.5.1 In Situ Physical/Chemical Treatment 17

18 19 20 21

In situ physical/chemical treatment options include air sparging, geochemical immobilization, chelation, and electrokinetics.

22 23 24

Air Sparging: Air is introduced to volatilize organic contaminants, and is only effective for treatment of VOCs and therefore is not retained.

25 26 27 28 29

Geochemical Immobilization: Geochemical immobilization is an in situ process that involves locally adjusting the pH and reduction-oxidation (redox) conditions. This reduces the solubility and/or changes the speciation of contaminants, largely precipitating them in the saturated zone. This process is effective for the treatment of inorganic COCs which would potentially effective for sediment slurry at EBG.

30 31 32 33

Chelation: Chelating molecules exhibit a high degree of selectivity for many metals. Chelating agents are used to enhance the in situ solubility or mobility of target constituents. This process is effective for the treatment of inorganic COCs which would potentially be effective for sediment slurry at EBG.

34 35 36 37 38 39 40 41 42 43

Electrokinetics: Electrokinetics is an electrochemical process involving electrodes and permeable membranes in which cations (such as metals and hydronium ions) are driven through the saturated zone (or interstitial moisture above the water table) to one or more anodes, while anions are forced to the cathode(s). At the anode, metal contaminants cross a semi-permeable membrane and are extracted on the surface for treatment or disposal. This process is retained where water is impacted by inorganics. This would be applicable to the sediment slurry at EBG.


5A.2.5.2 Ex Situ Physical/Chemical Treatment 1 2 3 4 5 6 7

Ex situ physical/chemical process options evaluated included adsorption, advanced oxidation, air stripping/packed tower, crystallization, dissolved air flotation, evaporation ponds, granulated activated carbon, ion exchange, physical catalysis, reverse osmosis, sedimentation, sprinkler irrigation, and ultra/micro/nanofiltration.

8 9

10 11 12 13 14

Adsorption: Adsorption processes involve the displacement of contaminants from one medium to another. Some inorganics have shown good to excellent adsorption potential using activated carbon (see granulated activated carbon, below), alumina, or other media developed for water and wastewater treatment. Spent adsorption media may be regenerated and reused until efficiency declines to a predetermined level. This process option is applicable for inorganic COCs in water and is retained for sediment slurry water at EBG.

15 16 17 18 19 20

Advance Oxidation: Advanced oxidation processes including ultraviolet (UV) radiation, ozone, and/or hydrogen peroxide are used to destroy organic contaminants as water flows into a treatment tank. If ozone is used as the oxidizer, an ozone destruction unit is used to treat collected off gases from the treatment tank and downstream units where ozone gas may collect, or escape. This technology is not generally applicable to inorganic COCs and is not retained for subaqueous sediment.

21 22 23 24

Air Stripping/Packed Tower: Air stripping involves the addition of large volumes of air to the fluid to be treated. Air stripping is most frequently used for removal of volatile organics and radon gas and is not applicable to the subaqueous sediment COCs, so it is not retained.

25 26 27 28 29

Crystallization: In crystallization, solutes are crystallized from a saturated solution when the solvent is cooled, or water is separated from solution by cooling it until ice crystals form. The process is primarily applicable as a pretreatment or post-treatment process to remove contaminants. It is only moderately effective for inorganic COCs and is therefore not retained.

30 31 32 33 34

Dissolved Air Flotation: In dissolved air flotation, air is injected while the contaminated water is under pressure. Fine bubbles are released and attach to suspended solids, reducing their specific gravity and aiding their rise to the surface. This technology is not applicable to dissolved contaminants, so it is not retained.

35 36 37 38

Evaporation Ponds: Evaporation ponds involve the evaporation of water and consequent concentration of organic and inorganic wastes. The process is dependent upon climatic conditions and is not practical in non-arid and cold regions, so it is not retained.

39 40 41 42 43

Granulated Active Carbon: Contaminated water is passed ex situ through a filter pack containing granulated activated carbon, which is highly effective at absorbing organic molecules. The carbon filter can be disposed of or "regenerated" for reuse by rinsing with solvents. This process is not effective for inorganic COCs and is not retained.


1 2 3 4 5 6

Ion Exchange: Ion exchange has been widely used for the treatment of inorganic wastes. Ion exchange is effective in treating dilute concentrations of contaminants. Exchangers can be produced to remove low concentrations of toxic metals from a wastewater containing a high background concentration of other non-toxic contaminants. This process is retained for inorganic contaminated subaqueous sediment slurry water at EBG.

7 8 9

10

Physical Catalysis: The use of a suitable physical catalyst process allows a substance to be dehalogenated or otherwise reacted from one phase to another. Physical catalysis is generally not feasible for metals, and is mostly applicable to halogenated organics. This process is not retained.

11 12 13 14 15

Reverse Osmosis: In reverse osmosis, pressure is applied to the solution to force the solvent flow from the more dilute to the more concentrated solution. The membrane through which the solvent flows is impermeable to the dissolved ions. This process is typically used to separate water from inorganic ions. This process is retained for subaqueous sediment slurry water at EBG.

16 17 18

Sedimentation: Sedimentation is a post-treatment step that will be retained for possible use in conjunction with flocculation/precipitation. This process is retained.

19 20 21 22

Sprinkler Irrigation: Sprinkler irrigation passes contaminated water through a standard sprinkler system, which forces VOCs from the dissolved phase into the gaseous. This is not effective at treating metals and is not retained.

23 24 25 26

Ultra/Micro/Nano-Filtration: These filtration techniques use pressure and a semi-permeable membrane to separate nonionic materials from a solvent. This is generally used for suspended solids, oil and grease, large organic molecules, and complex heavy metals, and is not retained. 5A.2.5.3 Biological Treatment 27

28 29 30

Biological treatment involves using microbes in situ to degrade or adsorb groundwater contaminants.

31 32 33 34 35

Bioremediation: Bioremediation technologies are destruction or transformation techniques directed towards stimulating microorganisms growth and their consumption of the contaminants as a food or energy source. Bioremediation has been successfully used for some heavy metals and is retained for further consideration in sediment slurry water at EBG.

36 37 38 39 40 41 42

Biological Sorption: In biological sorption, various active and inactive microorganisms, such as algae and fungi, capable of adsorbing metallic ions are used to remove heavy metals from aqueous solutions. The process takes advantage of the natural affinity for heavy metal ions exhibited by algae cell structures. When the adsorptive capacity of the microorganisms is reached, the metals can be removed and concentrated for subsequent recovery. Biological sorption has been successfully used for some heavy metals and is retained for further consideration in sediment slurry water at EBG.


1 2 3 4 5 6 7 8 9

10 11

Constructed Wetlands: Constructed wetlands use natural geochemical and biological processes inherent in an artificial wetland ecosystem in order to accumulate and remove metals and other contaminants from influent waters. The process can use a filtration or degradation process. Although the technology incorporates principal components of wetland ecosystems; including organic soils, microbial fauna, algae, and vascular plants; microbial activity is responsible for most of the remediation. Influent water with explosive residues or other contaminants flows through and beneath the gravel surface of a gravel-based wetland. The wetland, using emergent plants, is a coupled anaerobic-aerobic system. The anaerobic cell uses plants in concert with natural microbes to degrade the contaminant. The aerobic, also known as the reciprocating cell, further improves water quality through continued exposure to the plants and the movement of water between cell compartments (FRTR 2005). This process option is retained.

12 13 14 15 16 17 18 19 20 21 22 23 24 25

Monitored Natural Attenuation: Monitored Natural Attenuation (MNA) is a passive remedial measure that relies on natural processes to reduce the contaminant concentration over time. MNA is a viable remedial process option if it can reduce contamination within a reasonable time frame, given the particular circumstances of the site, and if it can result in the achievement of remediation objectives. Use of MNA as a component of a remedial alternative is appropriate along with the use of other measures, such as source control. MNA has been retained. 5A.2.6 Discharge Onsite and offsite disposal and discharge options, as well as beneficial reuse, were considered for groundwater. The process options screened included: discharge to surface water, deep well injection, disposal to a Public Owned Treatment Works (POTW) or other disposal facility, land spraying/irrigation, and reclamation/recycle/reuse. 5A.2.6.1 Onsite Disposal/Discharge 26

27 28 29 30 31 32 33 34 35 36

Discharge to surface water and deep well injection were screened. Discharge to surface water could be used as a post-treatment step for treated water and thus the treated water would not need to be transported offsite. Under CERCLA, a National Pollutant Discharge Elimination System (NPDES) permit is not required for discharge to surface waters; however, the substantive requirements of a permit must be met. Deep well injection involves the injection of either treated or untreated water into an isolated underground zone. This option may be subject to meeting the substantive requirements of permitting. Both options are viable for the RVAAP/RTLS site and are retained for further consideration at all scenarios evaluated in this initial screening. 5A.2.6.2 Offsite Disposal/Discharge 37

38 39 40 41 42 43

Among the offsite disposal/discharge options are the use of existing POTWs or other commercial wastewater disposal facilities. Under this option, either treated or untreated water could be sent to these facilities, provided it is in compliance with the facility’s permits and waste acceptance criteria. This option is retained for further consideration. Both options are viable for the RVAAP/RTLS site and are retained for further consideration in this initial screening.



1 2 3 4 5 6 7 8

5A.3 RETAINED PROCESS OPTIONS FOR AQUEOUS MEDIA COCs identified in impacted subaqueous sediment at EBG were screened to identify potential remedial options to support future considerations regarding the need for remedial action. Table 5A-2 summarizes the process options identified during the initial screening process (Section 5A.2) for impacted subaqueous sediment at EBG.

Table 5A-2. Retained Process Options for Subaqueous Sediment

General Response Action Technology Type Process Option Government, Enforcement, Informational, Legal Mechanisms, Controls Physical Mechanism

Land Use Controls and Five-Year Reviews

Environmental Monitoring Groundwater, Surface Water Removal Pumping Surface Pumping

In Situ Physical/Chemical Geochemical Immobilization, Chelation, Electrokinetics

Ex Situ Physical/Chemical Adsorption, Ion Exchange, Reverse Osmosis, Sedimentation

Treatment

Biological Bioremediation, Biological Sorption, Constructed Wetlands, MNA

Onsite Discharge to Surface Water, Deep Well Injection Discharge Offsite Existing POTWs, Other Commercial Wastewater

Disposal Facilities

9

Table 5A-1. Initial Screening of Technology Types and Process Options for Subaqueous Sediment

General Response

Action Technology

Type Process Options Description Screening Comments

No Action None None

Current land use controls, access restrictions, and monitoring programs will be discontinued. No remedial technologies implemented to reduce hazards to potential human or ecological receptors.

Required to be carried through CERCLA analysis.

Government Controls (land use restrictions)

The regulatory authority of a state or local government agency to make land use restrictions and zoning ordinances is used to control the use of the land.

Enforcement Tools (administrative order, consent decrees)

Administrative orders and consent decrees available under CERCLA, can prohibit certain land uses by a party or require proprietary controls be put in place.

Informational Devices (registries, advisories)

Registries or advisories put in place to provide information that residual contamination is onsite

Legal Mechanisms (contractual mechanisms based on property law)

Easements, deed restrictions, etc. placed on a property as part of a contractual mechanism

Potentially applicable. May limit future land use, depending on alternative chosen and the amount of contamination remaining. Controls

Physical Mechanisms (fences, berms, warning signs)

Fences, berms, warning signs, and security personnel put in place to prevent contact with contaminated media

Potentially applicable. Used in conjunction with other alternatives to prevent incidental exposure to contaminated subaqueous sediment.

Groundwater Periodic monitoring of groundwater to keep track of contaminant plumes and concentrations

Land Use Controls and

Five-Year Reviews

Environmental Monitoring

Surface Water Periodic monitoring of surface waters to ensure that contaminant concentrations remain within acceptable limits

Potentially applicable. Used to assist in monitoring the effects subaqueous sediment has on GW/SW.


1 Table 5A-1. Initial Screening of Technology Types and Process Options for Subaqueous Sediment (continued)

General Response

Action

Technology Type Process Options Description Screening Comments

Sheet Piles Sheet piling is driven into the bed of the stream or lake in order to create a physical barrier to contain contaminated surface waters

Geosynthetic Membranes

Membranes used as barriers to groundwater movement, containing the spread of a contaminant plume Containment Vertical

Barriers

Slurry Walls Trenches or directionally drilled tunnels filled with slurry to contain groundwater movement.

Not applicable treatment for subaqueous sediment.

Potentially applicable. Subaqueous sediment may be able to be removed via surface pumping.

Removal Pumping Surface Pumping Traditional pumps used to remove contaminated surface water from a water body for treatment or disposal.

Air Sparging Air is introduced to groundwater using horizontal wells to volatilize organic contaminants.

Not applicable. Not effective for inorganic COCs.

Geochemical Immobilization

Involves locally adjusting the pH and reduction-oxidation (redox) conditions. This reduces the solubility and/or changes the speciation of contaminants, largely precipitating them in the saturated zone.

Potentially applicable. Effective for removing inorganics in sediment slurry water.

Chelation Chelating agents are used to enhance the in situ solubility or mobility of target constituents.


Treatment In Situ

Physical/ Chemical

Electrokinetics Electrodes are installed and electrical power used to drive contaminants to the anode for collection in an electrolyte solution. Potentially Applicable


Table 5A-1. Initial Screening of Technology Types and Process Options for Subaqueous Sediment (continued)

General Response

Action



Adsorption In liquid adsorption, solutes concentrate at the surface of a sorbent, thereby reducing their concentration in the bulk liquid phase.

Advanced Oxidation

Oxidation chemically converts hazardous contaminants to non-hazardous or less toxic compounds that are more stable, less mobile, and/or inert. The oxidizing agents most commonly used are ozone, hydrogen peroxide, hypochlorites, chlorine, and chlorine dioxide.


Air Stripping Large volumes of air are mixed with water in a packed tower to promote partitioning of VOCs to air.


Crystallization Process in which certain solutes crystallize out from a saturated solution when the solvent is cooled.

Not applicable. Separation/crystallization primary used as a pretreatment or post-treatment process to remove contaminants. Only moderately effective for inorganic COCs.

Dissolved Air Flotation

Air bubbles are introduced by pressurization/depressurization means, rise to the surface carrying low-density solids.


Evaporation Ponds Water is evaporated to concentrate contaminants present in liquid. Not applicable to cold climate regions.

Treatment (continued)

Ex Situ Physical/ Chemical

Granulated Activated Carbon

Contaminated water is passed ex situ through a filter pack containing granulated activated carbon, which is highly effective at absorbing organic molecules.


Ion Exchange Contaminated water is passed through a resin bed where ions are exchanged between resin and water.


Physical Catalysis A physical process used to accelerate a chemical change of contaminant.

Not applicable. Physical catalysis is generally not feasible for inorganics. Option most applicable for halogenated organics.

Reverse Osmosis Pressure is applied to force flow from dilute to concentrated solution through a membrane that is impermeable to a solute (dissolved ions).

Potentially applicable. Typically used to separate water from inorganic ions. May be used to treat slurry water of collected sediment.



General Response

Action


Sedimentation Suspended particles are allowed to settle depending on the particle diameter and specific gravity in a basin pond or pond enclosure.

Potentially applicable. Sedimentation is a post-treatment step that will be retained for possible use in conjunction with flocculation/precipitation for sediment slurry water.

Sprinkler Irrigation Sprinkler irrigation passes contaminated water through a standard sprinkler system, which forces VOCs from the dissolved phase into the gaseous.

Not applicable. Not effective at treating inorganic COCs.

Treatment (continued)

Ex Situ Physical/ Chemical

(continued)

Ultra/Micro/Nano-filtration

These filtration techniques use pressure and a semi-permeable membrane to separate nonionic materials from a solvent.

Not applicable. Ineffective for inorganic COCs.

Bioremediation Microbiological processes are used to degrade or transform contaminants to less toxic or nontoxic forms, thereby remedying or eliminating environmental contamination.

Potentially applicable. Bioremediation successfully used for treating some heavy metals.

Biological Sorption

Various active and inactive microorganisms, such as algae and fungi, capable of adsorbing metallic ions are used to remove heavy metals from aqueous solutions. The process takes advantage of the natural affinity for heavy metal ions exhibited by algae cell structures.

Potentially applicable. Inorganic COCs in sediment slurry can be removed and concentrated for subsequent recovery.

Constructed Wetlands

The constructed wetlands-based treatment technology uses natural geochemical and biological processes inherent in an artificial wetland ecosystem to accumulate and remove metals and other contaminants from influent waters.

Potentially applicable. Effective in treating inorganic COCs in sediment slurry.

Biological

MNA MNA is a passive remedial measure that relies on natural processes to reduce the contaminant concentration over time. Potentially applicable.



General Response

Action


Potentially applicable. May be acceptable treatment for sediment slurry with pretreatment.

Discharge to Surface Water

Discharges treated or untreated water into a suitable receiving body. May require discharge permits, etc.

Onsite

Deep Well Injection Injects treated or untreated water into a hydraulically isolated deep well for permanent storage. Requires the appropriate geology.

Potentially applicable. May be acceptable treatment for sediment slurry.

Existing POTWs Use existing POTW facilities to accept and treat the water. Water can be transported by truck.

Potentially applicable. May be acceptable treatment for sediment slurry. Pretreatment may be required.

Discharge

Offsite Other Commercial Wastewater Disposal Facilities

Water is transported to a commercial wastewater disposal facility for treatment and disposition.

Potentially applicable. May be acceptable treatment for sediment slurry.

1




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