RECORD OF DECISION (RODS) - Records Collections · IRP—Installation Restoration Program: The term used to describe the Navy’s environmental restoration program. LTM ... Public

EPA/ROD/R20060300013372006

EPA Superfund

Record of Decision:

ALLEGANY BALLISTICS LABORATORY (USNAVY) EPA ID: WV0170023691 OU 02MINERAL COUNTY, WV02/09/2006

Record of Decision

Site 5: Groundwater, Surface Water, and Sediment (Operable Unit 2)

at the

Allegany Ballistics Laboratory Rocket Center, West Virginia

October 2005

Glossary

ABL—Allegany Ballistics Laboratory

ATK – ATK Tactical Systems Company LLC

Alluvium—Unconsolidated (loose) soil (clay, silt, sand, and gravel) laid down by a stream. Groundwater moves through alluvium (called an alluvial aquifer) by traveling around the individual particles.

Aquifer—A fully saturated, underground soil or rock formation that is capable of producing a significant quantity of water.

ARAR—Applicable or Relevant and Appropriate Requirements – These are federal, state, or local rules and regulations that need to be considered in selecting and implementing a remedial action.

Bedrock—Consolidated (solid) material formed at high temperatures and/or pressures deep underground. Groundwater moves through bedrock (called a bedrock aquifer) by traveling through cracks and channels.

CERCLA—Comprehensive Environmental Response, Compensation and Liability Act (1980), also known as the Superfund Law, as amended by the Superfund Amendments and Reauthorization Act of 1986. CERCLA provides the authority and procedures for responding to releases of hazardous substances, pollutants, and contaminants from inactive hazardous waste disposal sites.

CFR—Code of Federal Regulations

COC—Constituent of Concern: A constituent identified in the risk assessment as posing an unacceptable potential risk to the current and/or potential future receptors identified at the site.

CS—Confirmation Study: A phase of environmental investigation under the Navy Assessment and Control of Installation Pollutants program where samples are collected to confirm the presence of and determine the nature of contamination at a site.

ERA—Ecological Risk Assessment: An evaluation of the potential health risks posed to plants and animals from exposure to existing levels of contamination.

ERD – Enhanced Reductive Dechlorination: A treatment method that uses microorganisms in the subsurface to remove chlorine atoms from chlorinated hydrocarbons, such as trichloroethene. Once all chlorine atoms have been removed, carbon dioxide and ethene remain in the groundwater.

FS—Feasibility Study: Part of the CERCLA process, the FS develops and evaluates potential alternatives to address contamination identified, quantified, and evaluated (including potential risks) during a Remedial Investigation. When an FS is prepared for a single site or medium, it may be referred to as a Focused Feasibility Study.

Groundwater—Subsurface water that moves in soil and geologic formations that are fully saturated (aquifers).

WDC052790008 III

RECORD OF DECISION FOR SITE 5 GROUNDWATER, SURFACE WATER, AND SEDIMENT

HHRA—Human Health Risk Assessment: An evaluation of the potential health risks posed to people from exposure to existing levels of contamination.

HI—Hazard Index

HQ—Hazard Quotient

IAS—Initial Assessment Study

IRIS— Integrated Risk Information System

IRP—Installation Restoration Program: The term used to describe the Navy’s environmental restoration program.

LTM—Long-term Monitoring: A program, generally implemented in conjunction with a remedial action, that facilitates periodic evaluation of the effectiveness of the remedy and progress toward meeting the environmental restoration goals.

LUC—Land use controls

MCL—Maximum Contaminant Level: A level established by the United States Environmental Protection Agency that represents the highest concentration of a particular constituent allowed in drinking water.

µg/L—micrograms/liter

MNA—Monitored Natural Attenuation: Natural attenuation is the result of naturally occurring processes that cause a reduction in the mass, concentration, volume, toxicity, or mobility of contaminants in soil or groundwater. These processes may include biodegradation, dispersion, dilution, sorption, volatilization, and chemical or biological stabilization, transformation, or destruction of contaminants.

msl—mean sea level

NACIP—Navy Assessment and Control of Installation Pollutants Program

NAVFAC—Naval Facilities Engineering Command

NCP—National Oil and Hazardous Substances Contingency Plan: Regulations at 40 CFR Part 300 that provide the organizational structure and procedures for preparing for and responding to discharges of oil and releases of hazardous substances, pollutants, and contaminants.

Nine Evaluation Criteria for Remedial Alternatives:

• Overall Protection of Human Health and the Environment—Addresses whether a remedy provides adequate protection and describes how risks posed through each pathway are eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.

• Compliance with ARARs—Addresses whether a remedy will meet all of the Applicable or Relevant and Appropriate Requirements of other Federal and State environmental laws and/or justifies a waiver of the requirements.

• Long-Term Effectiveness and Permanence—The expected residual risk and the ability of a remedy to maintain reliable protection of human health and the environment over time, once clean-up goals have been met.

IV WDC052790008

GLOSSARY

• Reduction in Toxicity, Mobility, or Volume through Treatment—The anticipated performance of the treatment technologies a remedy may produce.

• Short-Term Effectiveness—The period of time needed to achieve protection and any adverse impacts on human health and the environment that may be posed during the construction and implementation period until clean-up goals are achieved.

• Implementability—The technical and administrative feasibility of a remedy, including the availability of materials and services needed to implement an option.

• Cost—Estimated capital, operation and maintenance, and present worth costs.

• State Acceptance—State agency acceptance of the Proposed Plan.

• Community Acceptance—The public’s general response to the alternatives described in the Proposed Plan. The specific responses to the public comments are addressed in the Responsiveness Summary section of the ROD.

NPL—National Priorities List: Nationwide list, established by Congress under CERCLA and compiled by USEPA under CERCLA regulations, that identifies sites for priority investigation and remedial action.

OU—Operable Unit: Term for each of a number of separate activities undertaken as part of a Superfund site cleanup. For example, cleanup of soil and groundwater could be two separate OUs.

Pathway—Describes how a constituent moves through the environment (migration pathway) or comes into contact with a person, plant, or animal (exposure pathway).

PRAP—Proposed Remedial Action Plan: A public document describing the remedial alternatives at a site and the regulator’s preferred cleanup remedy that is used to solicit community participation in the decision-making process.

PRB—Permeable Reactive Barrier: Permeable reactive barriers are installed perpendicular to the groundwater flow path of a contaminated groundwater plume, allowing the groundwater to flow through the wall, while prohibiting the movement of contaminants. The movement of the contaminants is stopped by material within the wall such as zero-valent metals, chelators, sorbents, and microbes, which either degrade or retain the contaminants.

PRG–Preliminary Remediation Goal: For a given COC, the PRG is the concentration that represents an acceptable level for ecological and/or human receptors within a given exposure pathway. It is generally the level used for evaluating various remedial alternatives with respect to their ability to achieve it.

Public Comment Period—The time allowed for the members of a community to express views and concerns regarding an action proposed to be taken by USEPA, such as a rule making, permit, or Superfund remedy selection.

Public Meeting—A meeting at which the lead agency presents and discusses the PRAP and accepts written and verbal comments and questions from the community members.

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Public Notice—An announcement, generally published in local newspapers, notifying the community members of the availability of the PRAP and the Administrative Record in advance of the Public Meeting.

RAB—Restoration Advisory Board: An informal public interest group, which includes stakeholders from the community, the site owners, and regulatory agencies.

RAO—Remedial Action Objective: An objective of the remedial action, generally developed in conjunction with a number of other objectives, that is based on the contaminated media; contaminant types; potential risks to people, plants, and animals; and regulatory criteria or requirements.

RBC—Risk-Based Concentration: Concentrations for individual constituents, calculated by the USEPA, that correspond to fixed levels of risk in water, air, fish tissue, and soil. The primary use of RBCs is for constituent screening during the baseline risk assessment.

RI—Remedial Investigation: An in-depth study designed to gather data needed to determine the nature and extent of contamination at a Superfund site and the potential risks posed to people, plants, and animals by the contamination.

ROD—Record of Decision: A public decision document that establishes which cleanup alternative(s) will be used at a NPL site.

SARA—Superfund Amendments and Reauthorization Act of 1986

SVOC —Semi-volatile organic compound

TBC—To-be-considered criteria are non-enforceable guidelines that are used to help evaluate the merits of a remedial alternative.

TCE—trichloroethene: TCE is in a group of constituents known as volatile organic compounds, or VOCs. In addition to their tendency to vaporize readily, many VOCs have the ability to absorb or dissolve other substances, such as oil and grease, making them valuable as degreasers and solvents for many industrial applications. Historically, TCE use as an industrial degreaser was widespread. Although its use at ABL was discontinued by the early 1990s, TCE was commonly used at the facility to degrease fabricated metal parts and to clean rocket casings.

USEPA—United States Environmental Protection Agency

VOC—Volatile organic compound: Type of chemical that readily vaporizes, often producing a distinguishable odor. Examples of VOCs include various ingredients in fingernail polish remover, household cleaners, and gasoline. VOCs tend to readily dissolve in groundwater, spread with the groundwater flow, remain in the groundwater for extended periods of time, and have both carcinogenic and non-carcinogenic health effects.

WVDEP—West Virginia Department of Environmental Protection

ZVI—Zero valent iron

VI WDC052790008

Contents

Glossary..............................................................................................................................................III 1 Declaration .................................................................................................................................1-1

1.1 Site Name and Location ..................................................................................................1-1 1.2 Statement of Basis and Purpose .....................................................................................1-1 1.3 Assessment of the Site .....................................................................................................1-1 1.4 Description of the Selected Remedy..............................................................................1-1 1.5 Statutory Determinations................................................................................................1-2 1.6 ROD Data Certification Checklist ..................................................................................1-2 1.7 Authorizing Signatures ...................................................................................................1-4

2 Decision Summary....................................................................................................................2-1 2.1 Site Name, Location, and Brief Description .................................................................2-1 2.2 Site History and Enforcement Activities.......................................................................2-1

2.2.1 Site History...........................................................................................................2-1 2.2.2 Previous Investigations ......................................................................................2-2 2.2.3 CERCLA Enforcement Activities ......................................................................2-4

2.3 Community Participation ...............................................................................................2-4 2.4 Scope and Role of Operable Unit or Response Action................................................2-5 2.5 Site Characteristics ...........................................................................................................2-6

2.5.1 Site Overview.......................................................................................................2-6 2.5.2 Sampling Strategy ...............................................................................................2-7 2.5.3 Source of Contamination....................................................................................2-7 2.5.4 Nature and Extent of Contamination...............................................................2-7

2.6 Current and Potential Future Land and Water Uses ..................................................2-9 2.6.1 Current Use ..........................................................................................................2-9 2.6.2 Potential Future Uses..........................................................................................2-9

2.7 Summary of Site Risks ...................................................................................................2-10 2.7.1 Baseline Human Health Risk Assessment.....................................................2-10 2.7.2 Baseline Ecological Risk Assessment .............................................................2-13 2.7.3 Basis for Action..................................................................................................2-13

2.8 Remedial Action Objectives..........................................................................................2-13 2.9 Description of Alternatives ...........................................................................................2-14

2.9.1 Alternative 1 — No Action ..............................................................................2-15 2.9.2 Alternative 2 — Enhanced Reductive Dechlorination.................................2-15 2.9.3 Alternative 3—Permeable Reactive Barrier...................................................2-15 2.9.4 Alternative 4—Groundwater Extraction and Treatment ............................2-16 2.9.5 Common Elements and Distinguishing Features of Each Alternative......2-17 2.9.6 Expected Outcomes of Each Alternative .......................................................2-17

2.10 Comparative Analysis of Alternatives ........................................................................2-17 2.10.1 Threshold Criteria .............................................................................................2-18 2.10.2 Primary Balancing Criteria ..............................................................................2-19 2.10.3 Modifying Criteria ............................................................................................2-20 2.10.4 Remedial Alternatives Comparative Analysis Summary ...........................2-20

WDC052790008 VII


VIII WDC052790008

2.10.4 Remedial Alternatives Comparative Analysis Summary........................... 2-20 2.11 Principal Threat Wastes ................................................................................................ 2-21 2.12 Selected Remedy............................................................................................................ 2-21

2.12.1 Summary of the Rationale for the Selected Remedy ................................... 2-21 2.12.2 Description of Selected Remedy..................................................................... 2-21 2.12.3 Summary of Estimated Remedy Costs .......................................................... 2-22 2.12.4 Expected Outcomes of Selected Remedy ...................................................... 2-23

2.13 Statutory Determinations ............................................................................................. 2-23 2.13.1 Protection of Human Health and the Environment .................................... 2-23 2.13.2 Compliance with ARARs................................................................................. 2-24 2.13.3 Cost Effectiveness ............................................................................................. 2-24 2.13.4 Permanent Solutions and Technologies ........................................................ 2-24 2.13.5 Reduction of Toxicity, Mobility, or Volume as a Principal Element ......... 2-24 2.13.6 Five-Year Review Requirements .................................................................... 2-24

2.14 Documentation of Significant Changes from Preferred Alternative of Proposed Plan ....................................................................................................................................2-24

3 Responsiveness Summary ...................................................................................................... 3-1 4 References .................................................................................................................................. 4-1 Appendixes

A Transcript of Public Meeting for ABL Site 5 PRAP B Applicable or Relevant and Appropriate Requirements Tables (Tables are located at the end of each section.)

2-1 Range of Constituents of Concern Concentrations 2-2 Selection of Exposure Pathways 2-3 Toxicity Information for Constituents of Concern 2-4 Human Health Risk Assessment Summary by Receptor 2-5 Preliminary Remediation Goals for Groundwater Constituents of Concern 2-6 Components of Remedial Alternatives for Groundwater 2-7 Detailed Evaluation of Remedial Alternatives Summary 2-8 Cost Estimate Details, Alternative 3

Figures (Figures are located at the end of each section.)

2-1 Location of IRP Sites 2-2 Schematic Cross Section of Site 5 2-3 Groundwater Elevation Map for Alluvial Aquifer 2-4 Groundwater Elevation Map for Bedrock Aquifer 2-5 Conceptual Site Model for Potential Human Exposures 2-6 Historical Concentrations of TCE in Alluvial Aquifer 2-7 TCE Alluvial Groundwater Plume 2-8 Historical Concentrations of Iron in Alluvial Aquifer 2-9 Historical Concentrations of Manganese in Alluvial Aquifer 2-10 Conceptual Diagram of the Permeable Reactive Barrier 2-11 Area of Restricted Groundwater Use

SECTION 1

Declaration

1.1 Site Name and Location Operable Unit (OU) 02: Groundwater, Surface Water, and Sediment Site 5: Former Inert Landfill Allegany Ballistics Laboratory (ABL), Rocket Center, West Virginia National Superfund Database Identification Number: WV0170023691

1.2 Statement of Basis and Purpose This decision document presents the final selected remedy for Site 5 Groundwater, Surface Water, and Sediment at ABL in Rocket Center, West Virginia. The final selected remedy was chosen in accordance with the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on the Administrative Record file for this site. The State of West Virginia concurs with the Selected Remedy.

1.3 Assessment of the Site There has been a release of trichloroethene (TCE), iron and manganese at Site 5, OU 02. The response action selected in this Record of Decision (ROD) is necessary to protect public health or welfare or the environment from actual or threatened releases of hazardous substances, pollutants, or contaminants in groundwater, surface water, and sediment at Site 5.

1.4 Description of the Selected Remedy This ROD addresses OU 02, the second of two operable units at Site 5. The two OUs identified at Site 5 are:

• OU 01, consisting of the landfill contents and surface soils. This OU was addressed in a ROD signed in February 1997 and by the subsequent installation of a landfill cap in September 1997.

• OU 02, consisting of the alluvial and bedrock groundwater beneath and downgradient from the landfill and of the surface water and sediments of the North Branch Potomac River adjacent to Site 5.

Four remedies were evaluated in the Remedial Investigation and Feasibility Study (RI/FS) (CH2M HILL, 2004a) and presented in the Proposed Remedial Action Plan (PRAP) (U.S. Navy, 2005) for Site 5, OU 02. The Preferred Alternative selected for OU 02 is Alternative 3, installation of a Permeable Reactive Barrier (PRB). The components of Alternative 3 are:

WDC052790008 1-1


• PRB to treat the trichloroethene (TCE) in the alluvial aquifer

• Monitored Natural Attenuation (MNA) to address the TCE in the alluvial aquifer outside of the influence of the PRB, TCE in the bedrock, and iron and manganese in both aquifers

• Long-Term Monitoring (LTM) of the groundwater and river to monitor the progress of the PRB and MNA toward meeting the remedial action objectives (RAOs) and cleanup levels

• Groundwater use restrictions to prohibit the use of groundwater from the alluvial and bedrock aquifer for potable use until LTM demonstrates that the RAOs and cleanup levels have been achieved.

Alternative 3 will achieve the remedial goals and will protect human health and the environment. The PRB will passively reduce the TCE concentrations in groundwater to acceptable levels by converting TCE to ethene and carbon dioxide. The iron and manganese concentrations will be reduced to acceptable levels by natural attenuation.

1.5 Statutory Determinations The Selected Remedy for Site 5 OU 02, Alternative 3, is protective of human health and the environment, complies with Federal and State requirements that are legally applicable or relevant and appropriate to the remedial action, is cost effective, and utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable. Alternative 3 also satisfies the statutory preference for treatment as a principal element of the remedy.

Because this remedy will result in hazardous substances, pollutants, or contaminants remaining on-site above levels that allow for unlimited use and unrestricted exposure for a portion of the remedy’s period of performance, a statutory review will be conducted within 5 years after initiation of remedial action to ensure that the remedy is, or will be, protective of human health and the environment.

1.6 ROD Data Certification Checklist The following information is included in the Decision Summary section of this ROD. Specific subsections where each item can be found are shown in parentheses. Additional information can be found in the Administrative Record for ABL Site 5.

• Constituents of Concern (COCs) and their respective concentrations (Section 2.5.4)

• Baseline risk represented by the COCs (Section 2.7)

• Cleanup levels established for the COCs and the basis for these levels (Section 2.8)

• An explanation of how source materials constituting principal threats are addressed (Section 2.11)

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SECTION 1—DECLARATION

• Current and reasonably anticipated future land use assumptions and current and potential future beneficial uses of groundwater used in the baseline risk assessment and ROD (Sections 2.6 and 2.7)

• Potential land and groundwater use that will be available at Site 5 as a result of the successful execution of the Selected Remedy (Section 2.12.4)

• Estimated capital, annual operation and maintenance, and total present worth costs, discount rate, and the number of years over which the remedy cost estimates are projected (Section 2.9)

• Key factor(s) that led to selecting the remedy (Sections 2.10 and 2.12)

WDC052790008 1-3

RECORDOF E C I S I O N FOR SITE 5 GROUNDWATER. SURFACE WATER, AND SEDIMENT

1.7 Authorizing Signatures

~ a v i d h . Anderson, Director Installations and Equipment Office, by direction of Commander Naval Sea Systems Command

Abraham Ferdas, Director Hazardous Site Cleanup Division U.S. EPA Region 111

P

Date

2(9 ( 0 ~ Date

The State of West Virginia has reviewed this Record of Decision and the materials on which it is based and concurs with the selected remedy.

Ken Ellison, Director Division of Land Restoration West Virginia Department of Environmental Protection

Date

SECTION 2

Decision Summary

2.1 Site Name, Location, and Brief Description OU 02: Groundwater, Surface Water, and Sediment Site 5: Former Inert Landfill Allegany Ballistics Laboratory (ABL), Rocket Center, West Virginia National Superfund Database Identification Number: WV0170023691 Lead Agency: Department of the Navy, Naval Facilities Engineering Command (NAVFAC), Atlantic (hereafter referred to as “the Navy”) Source of Cleanup Monies: Environmental Restoration, Navy (ER, N)

ABL is a research, development, and production facility located in Rocket Center, West Virginia, in the northern part of Mineral County. The facility is situated along a reach of the North Branch Potomac River, separating West Virginia and Maryland. The facility consists of two plants. Plant 1, owned by the Navy and operated by ATK Tactical Systems Company LLC (ATK), occupies approximately 1,577 acres, of which only about 400 acres are within the developed floodplain of the North Branch Potomac River. The remaining acreage is primarily forested and mountainous. Plant 2, a 57-acre facility adjacent to Plant 1, is owned and operated by ATK.

In June 1993, the United States Environmental Protection Agency (USEPA) proposed the Plant 1 portion of the ABL facility for inclusion on the National Priorities List (NPL) based upon potential risks to human health and the environment. The Plant 1 portion of ABL was added to the NPL as documented in the Federal Register, Volume 59, Number 27989, on May 31, 1994. Figure 2-1 shows the location of ABL (including Plant 1 and Plant 2) and the approximate locations of its CERCLA sites.

Site 5, a formerly used landfill for inert wastes, is located in an undeveloped section on the southern end of Plant 1 at ABL (Figure 2-1). The groundwater beneath Site 5 and surface water and sediment in the North Branch Potomac River (defined as OU 02) are addressed by this ROD.

2.2 Site History and Enforcement Activities 2.2.1 Site History The Site 5 inert landfill operated from the early 1960s to 1985, accepting inert wastes generated by ABL. For purposes of the landfill, inert wastes were defined as wastes not contaminated with explosives nor generated at an area on the facility where explosives were managed. Wastes reported to have been disposed of at Site 5 include drums that previously contained chlorinated solvents including TCE, fluorescent tubes, unknown laboratory and photographic chemicals, fiberglass and other resin-coated fibers, metal and plastic machining wastes, and construction and demolition debris. As a result, the Navy has investigated potential risks associated with several site-related media: landfill contents,

WDC052790008 2-1


associated surface soils, groundwater, surface water, and sediment. These investigations are further discussed below.

2.2.2 Previous Investigations Several remedial investigations and actions within the CERCLA and Installation Restoration Program (IRP) processes have been conducted at ABL. Those relevant to Site 5 are summarized briefly below. More detailed information about these activities is presented in the Focused Remedial Investigation/Feasibility Study (RI/FS) Report (CH2M HILL, 2004a) and other reports referenced below.

2.2.2.1 Initial Assessment Study/Confirmation Study (1983 through 1987) The Initial Assessment Study (IAS), performed at ABL in 1983 under the Navy Assessment and Control of Installation Pollutants Program (NACIP), identified and assessed sites presenting a potential threat to human health or the environment as a result of former hazardous materials handling and operations (ES&E, 1983). Site 5 was investigated based upon information obtained from historical records, photographs, site inspections, and personnel interviews. The IAS concluded that this site did not pose an immediate threat; however, a confirmation study (CS) was conducted at Site 5 to assess suspected contamination. The CS, initiated in June 1984 and completed in August 1987, focused on identifying the existence, concentration, and extent of contamination.

As a result of SARA, the Navy changed its NACIP terminology and scope under the IRP to follow the rules, regulations, guidelines, and criteria established by the USEPA for the Superfund program. Accordingly, the results of the CS are documented in the Interim RI Report (Roy F. Weston, 1989). The Interim RI Report recommended further remedial investigation activities for some sites at ABL, including Site 5.

2.2.2.2 Remedial Investigation (1992) Based on the recommendations of the Interim RI Report and in accordance with the Navy’s modified IRP policy, an RI was performed following USEPA RI/FS guidance under CERCLA, as described in the USEPA document Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA (USEPA, 1988).

The results of the 1992 Draft RI are presented in the Remedial Investigation of the Allegany Ballistics Laboratory Report (CH2M HILL, 1996a), which recommended further investigation at Site 5 to assess the extent of volatile organic compounds (VOC s) contamination in the alluvial aquifer downgradient of the landfill at Site 5.

2.2.2.3 Phase II Remedial Investigation (1994) In 1994, the Phase II RI was conducted to further define the nature and extent of contamina-tion at several ABL sites, including Site 5. During this investigation, a baseline human health risk assessment (HHRA) and a ecological risk assessment (ERA) were performed to evaluate potential risks posed by each site. The results of the Phase II RI are presented in the Phase II Remedial Investigation at Allegany Ballistics Laboratory Superfund Site Report (CH2M HILL, 1996b), which recommended that remedial alternatives for Site 5 be evaluated in a FS.

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SECTION 2—DECISION SUMMARY

2.2.2.4 Focused Feasibility Study for Site 5 Landfill Contents and Surface Soil (1996) Based upon the results of the 1992 RI and 1994 Phase II RI at Site 5, a Focused FS for Site 5 OU 01 (landfill contents and surface soil) was conducted (CH2M HILL, 1996c). In addition, a Focused FS for Site 5 OU 02 groundwater was initiated to develop and evaluate alternatives to address potential risk associated with Site 5 OU 02 groundwater. However, completion of the OU 02 Focused FS report for Site 5 groundwater was postponed because the Navy, USEPA, and West Virginia Department of Environmental Protection (WVDEP) agreed to evaluate groundwater data for 5 years after implementation of the Site 5 OU 01 landfill cap, in order to determine the cap’s affect on groundwater contaminant concentrations.

2.2.2.5 OU 01 Record of Decision and Remedial Action (1997) The Navy held a public comment period for the Site 5 OU 01 Proposed Remedial Action Plan (PRAP) from October 22, 1996 through December 9, 1996. In February 1997, the Navy, WVDEP, and USEPA signed the Site 5 OU 01 ROD (U.S. Navy, 1997) for the Site 5 landfill contents and surface soil. In accordance with the OU 01 ROD, a cap was installed on the Site 5 landfill to mitigate potential risks posed by the landfill contents and surface soils, including continued migration of contaminants to the underlying groundwater. The Site 5 OU 01 landfill cap and gas collection trench installation was completed in September 1997. The landfill cap consists of a geosynthetic clay liner installed atop a clay-grading layer, followed by a geomembrane, and has a built-in composite drainage net (OHM Remediation Services Corporation, 1997).

An OU 01 long-term monitoring (LTM) program for groundwater, stormwater, and landfill gas was implemented in 1998 as part of the operations and maintenance of the landfill cap remedy. Under the LTM program associated with the OU 01 ROD, landfill cap maintenance and groundwater sampling are conducted to provide continual evaluation of the remedy’s performance. See the previous investigations referenced above and the Focused RI/FS (CH2M HILL, 2004a) for more detailed information of these activities.

2.2.2.6 OU 02 Final Focused RI/FS Report (September 2004) A Site 5 Focused RI/FS (CH2M HILL, 2004a) was conducted to assess contamination and potential risks associated with groundwater, surface water, and sediment at and adjacent to Site 5. The first objective of the Focused RI/FS was to collect additional site characterization data to supplement the 1992 RI and 1994 Phase II RI and to further define the nature and extent of contamination in groundwater, surface water, and sediment at Site 5. The second objective was to revise estimates of potential human health and ecological risks based on a more comprehensive set of data and using new risk assessment guidance.

Based on the information collected during the Site 5 Focused RI/FS and previous RIs, groundwater was found to be the only remaining medium at Site 5 to pose an unacceptable level of potential risk to human health. No unacceptable risk to ecological receptors was identified. Therefore, remedial alternatives were evaluated to address the potential human health risk posed by the contaminated groundwater. The results of this evaluation are presented in the Final Focused Remedial Investigation and Feasibility Study for Site 5 Groundwater, Surface Water, and Sediment Report (CH2M HILL, 2004a).

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2.2.2.7 Long-Term Monitoring Reporting The current Site 5 LTM and landfill operation and maintenance programs include monitoring of groundwater, river water and sediments; stormwater; and landfill gas. The various LTM reports discuss samples collected and the results of the analyses of the samples (CH2M HILL, 2004b and 2004c).

2.2.3 CERCLA Enforcement Activities No CERCLA enforcement activities have occurred at Site 5.

2.3 Community Participation The Navy, as lead agency for Site 5, has met the public participation requirements of CERCLA Section 117(a) and Section 300.430(f)(3) of the NCP as follows:

• The notice of availability of the PRAP for Site 5 Groundwater, Surface Water, and Sediments was published in the Cumberland Times-News on February 23, 2005 and in the Mineral Daily News on February 21, 2005. The Navy held the public comment period on the Site 5 Groundwater, Surface Water, and Sediment PRAP from March 1, 2005 to March 31, 2005.

• The Site 5 Administrative Record (i.e., the PRAP and supporting documents related to Site 5) was made available to the public at the following information repositories:

LaVale Public Library 815 National Highway LaVale, Maryland 21502

Fort Ashby Public Library Lincoln Street, IGA Plaza P.O. Box 74 Fort Ashby, WV 26719

• The Navy held a Public Meeting on March 1, 2005 to explain the PRAP and to address public comments. The meeting proceedings were transcribed by Word for Word Reporting of Swanton, MD. The meeting transcript was added to the Site 5 Administrative Record, located in the previously indicated repositories, and is included as Appendix A to this ROD.

• Verbal questions and comments were received and answered during the Public Meeting. No written comments were received during the public comment period. Based on the comments received, the public did not object to proceeding with the selected remedy.

In addition to the statutory and NCP public participation requirements, the Navy and ABL have had a comprehensive public involvement program for several years. Starting in 1993, a Technical Review Committee met on average twice a year to discuss issues related to investigative activities at ABL. The Technical Review Committee comprised mostly governmental personnel; however, the meetings were open to the public and a few private citizens attended the meetings.

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In early 1996, the Navy converted the Technical Review Committee into a Restoration Advisory Board (RAB) and 8 to 10 community representatives joined. The RAB is co-chaired by a community member and has held meetings, which are open to the public, approximately every 6 months since its establishment.

To assist the Navy in meeting the needs of the local community for information about, and participation in, the ongoing investigative and remedial processes at ABL, the Navy developed a Community Relations Plan in 1994, which was updated in 2001. The Community Relations Plan identifies community concerns about the investigation and restoration of potentially contaminated sites at ABL and outlines community relations activities to be conducted during the ongoing and anticipated future restoration activities. Recommendations for future community relations activities are based on information about community concerns and the effectiveness of public participation activities to date, which were obtained during interviews with members of the local community.

2.4 Scope and Role of Operable Unit or Response Action Site 5 is one of several sites identified in the Federal Facility Agreement for ABL. A list of all sites can be found in the Site Management Plan (SMP) for ABL (CH2M HILL, 2004d). Since 1997, RODs have been signed for four sites at ABL in accordance with the priorities established in the SMP.

Remedies have been implemented at 4 of the 12 top priority sites at ABL. The designation, media, and remedial action for each site are listed below:

• Site 1 Groundwater, Surface Water, and Sediment (OU 03): site-wide groundwater extraction and treatment (ROD May 1997)

• Site 5 Landfill Contents and Surface Soil (OU 01): capping (ROD January 1997)

• Site 7 Landfill Contents: removal in 1997 (NFA ROD September 2001)

• Site 10 Groundwater (OU 05): interim remedial action --focused groundwater extraction and treatment (Interim ROD June 1998)

This ROD addresses OU 02, the second of two operable units at Site 5. The two OUs identified at Site 5 are:

• OU 01, consisting of the landfill contents and surface soils. Site 5 OU 01 was addressed by a ROD issued in 1997 (U.S. Navy, 1997), subsequent installation of a cap in September 1997, and LTM. The installation of the landfill cap addressed the principal contamination (i.e. the source of contamination) of Site 5 and potential exposure risks to human and ecological health related to the landfill contents and surface soils. In addition, continued leaching of contamination from the landfill to the groundwater, due to percolation of water through the landfill contents, was reduced or eliminated.

• OU 02, consisting of the alluvial and bedrock groundwater beneath and downgradient from the landfill and the surface water and sediments of the North Branch Potomac River adjacent to Site 5.

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This ROD for Site 5 OU 02 presents the final response action for this site and addresses a principal threat at the site through the reduction of contaminants. The selected remedial alternative for Site 5 OU 02 is intended to satisfy the remedial objectives of: (1) reducing potential human health and ecological risks posed by contamination resulting from historical landfill activities and (2) meeting constituent-specific maximum contaminant levels (MCLs) and Applicable or Relevant and Appropriate Requirements (ARARs).

2.5 Site Characteristics 2.5.1 Site Overview Site 5 is a 1.3-acre former landfill located on an elevated portion of land (a terrace) above the North Branch Potomac River (Figure 2-2). Land use immediately surrounding Site 5 is industrial to the north (Plant 2) and undeveloped mountainous woodland to the south and east. Farmland is immediately across the river to the west. The majority of the site is grass- and tree-covered. There are no areas of archeological or historical importance at Site 5.

The Site 5 landfill cap, installed in 1997, covers an area of approximately 4 acres. The Site 5 topography gently slopes toward the North Branch Potomac River, but becomes steeper immediately adjacent to the river. Elevations at Site 5 range from approximately 680 to 700 feet above mean sea level (msl) (Figure 2-3).

An unvegetated drainage ditch system borders the Site 5 landfill. This ditch system, portions of which are reinforced with large gravel (rip-rap), converges at a point just northwest of the landfill. Surface runoff from the landfill cap and higher areas to the east, flows into these ditches and then in a northwestern direction into the North Branch Potomac River.

Two geologic layers exist in the subsurface near the landfill: a shallower alluvial layer and a deeper bedrock layer. Detailed descriptions of the Site 5 geology and hydrogeology are presented in the Focused RI/FS Report (CH2M HILL, 2004a) and previous reports, including the RI Report (CH2M HILL, 1996a), the Phase II RI Report (CH2M HILL, 1996b), and the Phase I Aquifer Testing Report (CH2M HILL, 1998).

An alluvial (shallow) aquifer, consisting of 6 to 8 feet of clayey gravel, extends from approximately the eastern edge of the landfill to the river. The alluvial aquifer consists of an unconfined aquifer above a fractured bedrock aquifer. Water-level data indicate that the saturated zone occurs in the silty clay or clayey gravel alluvium on the north, west, and south sides of the landfill.

While the primary direction of groundwater flow in the alluvial aquifer in the vicinity of the landfill is toward the river, a north to northwest component of groundwater flow, along the river, also exists (Figure 2-3). This secondary flow direction may be due to the presence of a former river channel that creates a preferential flow pathway for alluvial groundwater. The average linear velocity of alluvial groundwater downgradient of the landfill is estimated to be 0.81 ft/day, or 293 ft/yr.

A bedrock (deeper) aquifer also exists below the Site 5 landfill. As with the alluvial aquifer, there is a north to northwest component of groundwater flow, but it is much less defined than in the alluvium (Figure 2-4). The average bedrock groundwater velocity at Site 5 has

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been calculated to be at least several times faster than the alluvial groundwater velocity. The absence of a confining unit and the relatively small difference in hydraulic head between the two aquifers indicate that the bedrock and alluvial aquifers are well connected. In general, the vertical hydraulic gradients were downward between the alluvial and bedrock aquifers.

The predominant hydrologic feature at ABL is the North Branch Potomac River, which borders the western and northern sides of the facility (Figure 2-3). The elevation of the river ranges from about 645 feet above msl at the eastern end of Plant 1 to about 655 feet above msl in the vicinity of Site 5, located on the western border of ABL. The river flows south to north past Site 5. The average annual river flow rate is estimated to be 886 cubic feet per second, as measured at the United States Geological Service Pinto gauging station.

Figure 2-5 presents the conceptual site model for potential human exposure to contaminants at the site. This conceptual site model presents the potential routes of exposure; however, not all are complete exposure routes. An exposure pathway must be complete or exposure cannot occur. The conceptual site model illustrates that the suspected source of groundwater contamination was the former landfill and that the contamination resulted from leaching through the soil and landfill contents to the underlying groundwater. The conceptual site model also shows the potential receptors for the contaminated groundwater. The potential risks posed by the contaminated groundwater to these receptors are discussed in Section 2.7.

2.5.2 Sampling Strategy Information about Site 5 media has been gathered from the numerous soil and groundwater samples that have been collected at the site since the CS (Section 2.2.2). The majority of groundwater samples have been collected from over 20 monitoring wells at the site. The sample results for the COCs are discussed in Section 2.5.4. Additional sample information is presented in the Focused RI/FS (CH2M HILL, 2004a) and other historical documents.

2.5.3 Source of Contamination The suspected source of groundwater contamination at Site 5 is the landfill contents. As noted in Section 2.2.1, inert wastes were disposed of in the landfill from the 1960s to 1985. Capping of the landfill in 1997 was performed to eliminate or minimize further leaching of contaminants to groundwater.

2.5.4 Nature and Extent of Contamination Data collected during the various investigations conducted (Section 2.2.2) defined constituent concentrations in groundwater, surface water, and sediment, such that the nature and extent of contamination and potential risks have been adequately evaluated. The nature and extent of the COCs is discussed below by medium.

2.5.4.1 Groundwater TCE, iron, and manganese were identified as OU 02 COCs for groundwater in the HHRA. The distribution of these COCs is discussed below.

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TCE Based on historical data, the concentrations of TCE in the alluvial aquifer appear to be relatively stable. TCE has been detected at concentrations exceeding the MCL (5 µg/L) only in alluvial wells located along the northern side of the landfill (i.e., wells 5GW09, 5GW13, 5GW15, 5GW17, 5GW18, 5GW20, and 5GW22). Figure 2-6 graphically displays TCE concentrations detected in original groundwater samples collected from the alluvial monitoring wells since 1994. Figure 2-7 provides the estimated horizontal extent of TCE in the alluvial aquifer above its MCL over four monitoring events. These data suggest that the alluvial TCE plume has a crescent shape, initially migrating northward from the landfill before adopting a more westerly flow direction and approaching or discharging to the North Branch Potomac River in the vicinity of well 5GW20. Groundwater flow along a former river channel may be responsible for this plume configuration.

In the bedrock aquifer wells, the concentration of TCE has varied from below detection limits to a maximum of 19 µg/L. TCE has not been detected in the bedrock aquifer upgradient (5GW06), or along the southern (5GW10) or northern (5GW12 and 5GW16) boundaries of the landfill. TCE has been detected in the bedrock aquifer along the western boundary of the landfill (5GW02, 5GW03, and 5GW14), at concentrations between 4 µg/L and 19 µg/L. However, TCE has consistently been detected only in wells 5GW02 and 5GW03, and concentrations have been near or just above the MCL. This information suggests TCE is not extensive in the bedrock aquifer.

Iron and Manganese Iron and manganese were the only inorganics identified in the Focused RI/FS as COCs in alluvial and bedrock groundwater. USEPA has not established MCLs for these contaminants; therefore, iron and manganese concentrations are discussed below relative to USEPA Region III tap water risk-based concentrations (RBCs). The RBCs are used as screening values in Region III as part of the risk evaluation process.

Although iron and manganese are identified as COCs in groundwater, the concentrations tend to decline to below RBCs as groundwater migrates away from the landfill (Figure 2-8 and Figure 2-9). This trend indicates that the landfill may locally influence groundwater chemistry and that the iron and manganese present may be naturally occurring in the soil, and their concentration in the groundwater is influenced by altered geochemical conditions. Naturally occurring iron and manganese in soil is leached from the soil and dissolved into groundwater during reducing conditions such as those typically present at landfills. In both the alluvial and bedrock aquifers, the highest concentrations of iron were most frequently detected in wells located immediately downgradient of the landfill. This influence is anticipated to decline over time because the landfill cap is restricting percolation of water through the landfill, and subsequent leaching of contaminants, to the groundwater. Further, the remedial action for groundwater is anticipated to help naturally occurring metals concentrations in the groundwater to return to normal levels.

2.5.4.2 Surface Water and Sediment As discussed in the Site 5 Focused RI/FS Report (CH2M HILL, 2004a), surface water and sediment samples have been collected from four locations, within the North Branch Potomac River, upstream, adjacent to, and downstream from Site 5.

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Volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), explosives, and metals were evaluated in the surface water and sediment samples collected. Detected concentrations in the surface water and sediment samples are presented in the Focused RI/FS Report (CH2M HILL, 2004a). The risk assessments determined there are no COCs in surface water or sediment in the North Branch Potomac River adjacent to and attributable to Site 5. Therefore, the surface water and sediment of the North Branch Potomac River were not found to pose an unacceptable risk to human health or the environment. Because no unacceptable potential risk to human health or the environment was identified for the surface water and sediment, no further action is necessary for these media.

2.6 Current and Potential Future Land and Water Uses 2.6.1 Current Use As noted in Section 2.1, Site 5 is located in the southern portion of Plant 1 in the undeveloped area. Site 5 is a capped, former landfill adjacent to the North Branch Potomac River. Other than monthly site inspections and periodic sampling events, there are no regular human activities at the site. The Navy anticipates that this area will remain under its ownership and continue in the same capacity for the foreseeable future.

Land access to the site is currently restricted to onsite workers by fences and security guards. It is possible to access the site via the North Branch Potomac River, but the presence of perimeter fencing and “No Trespassing” signs are meant to discourage this activity. Access to the North Branch Potomac River, which borders the site on the west, is unrestricted, and the river is used for recreational purposes.

Groundwater is not currently used as a potable water supply at Site 5. The closest potable groundwater supply is located approximately 2,000 feet upgradient of Site 5. Testing of these water supply wells indicated that they do not influence groundwater (and, therefore, contaminant) flow directions at Site 5. The current understanding of groundwater flow directions and contaminant distribution at Site 5 supports the test results. Therefore, pathways associated with current groundwater use at the facility are incomplete and were not included in the quantitative risk analysis.

In accordance with Section 22-18-21 of the West Virginia Code, a notation will be filed as a separate notice with the ABL Plant 1 property deed that indicates Site 5 historically managed hazardous waste. This notation does not dispose, alienate, or encumber any real property interests held by the United States and creates no independent enforcement authority in the State of West Virginia or any third parties.

2.6.2 Potential Future Uses Due to the presence of the landfill and the land use restrictions, Site 5 is anticipated to remain an industrial area in the future. Even though the site is expected to remain industrial, the HHRA evaluated the future construction worker, future adult resident and future child resident exposure scenarios to provide the most conservative risk estimate. As such, the use of alluvial and bedrock groundwater at Site 5 as domestic potable water supplies was included in the risk analysis.

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If the facility is converted to residential use in the future, it is possible that bedrock and alluvial groundwater at Site 5 could be used as a potable water source. In addition, as presented in Section 2.8, one of the RAOs for Site 5 is to restore groundwater beyond the landfill boundaries to MCLs, or, in the absence of MCLs, risk-based levels.

It is assumed that the future use of the surface water and sediment will be the same as the current scenario (i.e., recreational use).

2.7 Summary of Site Risks This section summarizes the results of the baseline HHRA and ERA for Site 5 OU 02 (i.e., groundwater, surface water, and sediment). The baseline risk assessment estimates the potential risks the site poses if no action is taken. It provides the basis for taking action and identifies the contaminants and exposure pathways that need to be addressed by the remedial action. The complete HHRA and ERA are provided in the Focused RI/FS Report (CH2M HILL, 2004a).

Because of the dynamic nature of groundwater, surface water, and sediment, the risk assessments were based primarily on data collected after the landfill cap was installed. The cap isolated the landfill contents from direct surface contact and minimized leaching of contaminants to groundwater. In addition, the risk assessments were based on LTM data collected before February 2002. The LTM data that has been collected since February 2002 are consistent with the earlier data. Therefore, the risk assessments and conclusions remain current.

2.7.1 Baseline Human Health Risk Assessment 2.7.1.1 Identification of Constituents of Concern Site 5 OU 02 groundwater, surface water, and sediment constituent levels were evaluated in a baseline HHRA using current and future land use scenarios. Conservative estimates of current and future human exposure to site contaminants were used.

The result of the Site 5 OU 02 HHRA is a list of COCs that may pose unacceptable risks to human receptors defined for the site. The COC identification process included collection of site data, identification of data of acceptable quality, screening data against concentrations that are protective of human health, and calculation of the potential risk to identified receptors from the COCs.

Based on the risk assessments performed for Site 5 OU 02, exposure to alluvial and bedrock groundwater contamination poses an unacceptable potential risk to human health. The following three constituents were identified as the COCs responsible for the potential risk associated with groundwater:

• TCE • Iron • Manganese

Concentration ranges for the identified COCs are presented in Table 2-1.

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2.7.1.2 Exposure Assessment Exposure assessment is the determination or estimation (qualitative or quantitative) of the magnitude, frequency, duration, and route of exposure of potential receptors to contaminated media. Human exposure to constituents in groundwater can occur through ingestion of groundwater by drinking or eating, dermal contact during bathing, or inhalation of VOCs volatilized from groundwater during showering. The site conceptual model is shown in Figure 2-5 and the exposure pathways for Site 5 OU 02 evaluated in the HHRA are summarized in Table 2-2.

Because no current groundwater exposure pathway exists, a current groundwater exposure scenario for onsite workers and construction workers was not evaluated quantitatively. Current recreational use was evaluated for surface water and sediment because the North Branch Potomac River is available for recreational use. In addition to the future construction worker, future resident, the most conservative of the various future scenarios, was selected for the HHRA. For both of these hypothetical future groundwater supply scenarios, the exposures that were quantified were ingestion of constituents in groundwater (children and adults), dermal contact with groundwater during bathing (children only), and inhalation of VOCs during showering (adults only). The approach used to estimate the inhalation exposure to VOCs in groundwater was based on the model by Foster and Chrostowski (1987).

2.7.1.3 Toxicity Assessment The purpose of a toxicity assessment is to examine the available evidence regarding the potential for particular constituents to cause adverse effects in exposed individuals and to provide, where possible, an estimate of the relationship between the extent of exposure to a constituent and the increased likelihood or severity of adverse effects. When assessing human health risks, health effects are divided into two broad groups (i.e., non-cancer and cancer) that are evaluated independently. However, some constituents have both non-cancer and cancer effects and are therefore considered in both groups (e.g., arsenic).

Detailed toxicity information is presented in the Focused RI/FS Report (CH2M HILL, 2004a). Toxicity values were used to estimate the likelihood of adverse effects occurring in humans at different exposure levels. The toxicity information used in the baseline HHRA was mainly derived from the Integrated Risk Information System (IRIS) and Health Effects Assessment Summary Tables (HEAST) databases (IRIS, 2000; USEPA, 1994).

If toxicity values were not available through IRIS or HEAST, the USEPA’s Environmental Criteria and Assessment Office values were used, where available.

2.7.1.4 Risk Characterization For carcinogens, risk is evaluated as the incremental probability of an individual developing cancer over a lifetime as a result of exposures to the carcinogen. Excess lifetime cancer risk is calculated from the following equation:

Risk = CDI x SF

where: Risk = the probability (e.g., 2 x 10-5) of an individual developing cancer CDI = chronic daily intake averaged over 70 years (mg/kg*day) SF = slope factor (mg/kg*day)-1

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These risks are probabilities that usually are expressed in scientific notation (e.g., 1 x 10-6). An excess lifetime cancer risk of 1 x 10-6 indicates that an individual experiencing the reasonable maximum exposure estimate has a 1 in 1,000,000 chance of developing cancer as a result of site-related exposure. This risk estimate is referred to as an “excess lifetime cancer risk” because the cancer risk is in addition to all the other cancer risks (e.g., smoking, etc.). USEPA’s acceptable risk range for site-related exposures is 10-4 to 10-6.

The potential for non-carcinogenic effects is evaluated by comparing an exposure level over a specified period of time with a reference dose (RfD) derived for a similar exposure period (i.e., chronic, sub-chronic, or short term). An RfD represents a level that an individual may be exposed to that is not expected to cause any deleterious effects. The ratio of the exposure (actual or potential) to the RfD is the hazard quotient (HQ), which is how non-cancer risk posed by an individual constituent is expressed. An HQ less than 1 indicates that non-carcinogenic effects from exposure to the constituent are unlikely. Non-carcinogenic effects are likely if the HQ is greater than 1. The HQ is calculated as follows:

HQ = CDI/RfD

where: CDI = chronic daily intake RfD = reference dose

The hazard index (HI) is the cumulative non-cancer effect and is generated by adding the HQs for all constituent of potential concern (COPCs) that affect the same target organ (e.g., liver) or act through the same mechanism in a given medium. Similar to the HQ, an HI less than 1 indicates that a cumulative non-carcinogenic effect from all the constituents is unlikely. Conversely, an HI greater than 1 represents a potential non-carcinogenic effect from exposure to the constituents. HI is calculated as follows:

HI = HQ1 + HQ2 + . . . + HQn

where: n = the nth COPC

The HHRA concluded that both alluvial and bedrock groundwater are the only media at OU 02 that potentially pose an unacceptable risk to human health. No potential human health risks were identified in surface water and sediment. The potential risk from the groundwater, driven by TCE, iron, and manganese, was identified for the following receptors:

• A future adult resident, child resident, lifetime resident, and construction worker exposed to alluvial groundwater; and

• A future adult resident, child resident, and lifetime resident exposed to bedrock groundwater.

Risks and hazards identified in the HHRA are summarized by receptor for Site 5 groundwater in Table 2-4.

Several sources of uncertainty are inherent to estimates of excess lifetime cancer risk and non-cancer hazard. These sources are generally associated with:

• Potential sampling and analysis variability and error. Rigorous quality assurance and quality control procedures are carried out to reduce this source of uncertainty.

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• Potential alternative source(s) of contamination. Evaluation of historical information and assurance of adequate spatial distribution of sample locations and associated analytical parameters are two methods used to minimize this source of uncertainty.

• Exposure assumptions. Conservative exposure scenarios and exposure-point concentrations are utilized in order to minimize the possibility of underestimating potential risk.

• Toxicity of COPCs. Uncertainty in toxicity derives from a number of sources, including extrapolation from animals to humans and variability in humans (e.g., gender, age, diet, hereditary factors, etc.). Additionally, some constituents have no published toxicity information.

• Methods for calculating cancer and non-cancer risks. Assumptions used in the risk calculations have uncertainty associated with them (e.g., RfDs, summation of individual HQs, etc.)

2.7.2 Baseline Ecological Risk Assessment An ERA was conducted to characterize the potential risks to the fauna and flora posed by sediment and surface water in the North Branch Potomac River adjacent to Site 5. Several groups of species known or likely to occur in the area were evaluated to determine their potential for exposure to constituent concentrations found in the sediment and surface water. The ERA was conducted in accordance with the Navy Policy for Conducting Ecological Risk Assessments (CNO, 1999), the Navy guidance for implementing this ERA policy (NAVFAC, 2001), and the Navy/Tier II ERA approach developed for USEPA Region III.

Following these procedures, no unacceptable potential ecological risks were identified for the sediment and surface water.

2.7.3 Basis for Action Based on the HHRA and ERA, the response action selected in this ROD is necessary to protect the public health or welfare or the environment from actual or threatened releases of hazardous substances, pollutants, or contaminants in groundwater at Site 5.

2.8 Remedial Action Objectives This section presents general and site-specific RAOs identified for Site 5 OU 02. General RAOs are defined by the NCP and CERCLA (as amended by SARA), and are applicable to all CERCLA sites. The NCP requires that the selected remedy meet the following general objectives:

Each remedial action selected shall be protective of human health and the environment (40 Code of Federal Regulations (CFR) Section 300.430 (f)(1)(ii)(A) and CERCLA Section 121(d)).

•

• Onsite remedial actions that are selected must attain those ARARs that are identified at the time of the ROD signature (40 CFR Section 300.430(f)(1)(ii)(B)).

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Each remedial action selected shall be cost-effective, provided that it first satisfies the threshold criteria set forth in 40 CFR Section 300.430 (f)(1)(ii)(A) and (B). A remedy shall be cost-effective if its costs are proportional to its overall effectiveness (40 CFR Section 300.430 (f)(1)(ii)(D)).

•

•

•

•

•

•

Each remedial action shall use permanent solutions and alternative treatment technologies or resource-recovery technology to the maximum extent practicable (40 CFR Section 300.430 (f)(1)(ii)(E) and CERCLA Section 121(b)).

The least-favored remedial actions are those that include “offsite transport and disposal of hazardous substances or contaminated materials without such treatment . . . where practicable treatment technologies are available” (CERCLA Section 121(b)).

Both the level of contamination and the potential exposure routes are considered when developing RAOs for protecting public health and the environment. The future protection of environmental resources and the means of minimizing long-term disruption to existing facility operations are also considered. The site-specific RAOs for Site 5 OU 02 groundwater are:

Prevent or minimize exposure of potential future onsite residents and construction workers to contaminated groundwater originating from Site 5 at concentrations exceeding MCLs or, in the absence of MCLs, an excess lifetime cancer risk of 1 x 10-4 or a HI = 1.

Prevent or minimize river media from becoming impacted by the Site 5 groundwater COCs such that resulting concentrations present an unacceptable risk to human health or the environment.

Restore groundwater beyond the landfill boundaries to MCLs, or, in the absence of MCLs, risk-based levels.

Based on the identified RAOs for Site 5 OU 02 groundwater, preliminary remediation goals (PRGs) were developed. PRGs are a list of COCs and associated numeric concentrations that represent acceptable levels for ecological and/or human receptors within a given exposure pathway. Although the site is currently used for industrial purposes, and anticipated future use of the site is the same, risk-based PRGs were developed for potential future residential receptors, the most conservative scenario. The PRG calculation process is detailed in the Focused RI/FS Report (CH2M HILL, 2004a). Table 2-5 presents the PRGs for Site 5 groundwater.

In addition to the RAOs, three types of ARARs were identified for Site 5 OU 02: chemical-specific, location-specific, and action-specific. ARARs are distinguished by the USEPA as either being applicable to a situation or relevant and appropriate to it. ARARs are defined in USEPA guidance (USEPA, 1988). ARARs for Site 5 are presented as Appendix B.

2.9 Description of Alternatives The remedial alternatives described in this section are designed to meet the RAOs previously defined. The RAOs focus on reducing potential human exposure to contaminants, preventing a decline in river quality, and remediating the groundwater to cleanup goals within a

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reasonable time frame. Groundwater remedial alternatives were developed for Site 5 by identifying and screening various technologies and process options. The components of each alternative are listed below and summarized in Table 2-6. A detailed description of the alternatives and development process is provided in the Focused RI/FS Report (CH2M HILL, 2004a). The remedial alternatives identified for further evaluation were:

• Alternative 1—No Action • Alternative 2—Enhanced Reductive Dechlorination (ERD) • Alternative 3—Permeable Reactive Barrier • Alternative 4—Groundwater Extraction and Treatment

2.9.1 Alternative 1—No Action The no-action alternative is required by the NCP and serves as the baseline alternative. All other remedial action alternatives are judged against the no-action alternative. Under this alternative, no controls or remedial technologies would be implemented. However, a 5-year review would be performed because CERCLA (Section 121(c)), as amended by SARA (1986), requires that the site be reviewed every 5 years when contamination remains onsite.

2.9.2 Alternative 2—Enhanced Reductive Dechlorination ERD uses microorganisms in the subsurface to remove the chlorine atoms from chlorinated hydrocarbons (e.g., TCE) and convert them into less toxic molecules. The microorganisms are activated by injecting a substrate (food for the microorganisms) into the subsurface. The metals concentrations in the alluvial and bedrock aquifers and the bedrock contamination would be reduced to regulatory limits through return of the groundwater conditions to a more normal geochemistry, as verified through MNA.

The components of Alternative 2 are:

• ERD to treat the TCE within the 50 µg/L area in the alluvial aquifer;

• MNA to address the TCE outside the 50 µg/L area in the alluvial aquifer, TCE in the bedrock, and iron and manganese in both aquifers;

• Groundwater and river monitoring to monitor the progress of the ERD and MNA; and

• Groundwater use restrictions to prohibit the use of groundwater from the alluvial and bedrock aquifers for potable use until groundwater monitoring demonstrates that the RAOs and cleanup levels have been achieved.

The costs associated with this alternative are:

Capital $593,000 LTM and reporting $367,000

Net present worth (30-year) $1,602,000

2.9.3 Alternative 3—Permeable Reactive Barrier The main feature of this alternative is installation of a passive PRB in the most contaminated portion of the alluvial aquifer. The PRB is a trench that is filled with a reactive material. The trench is constructed in the alluvial aquifer perpendicular to the groundwater flow direction

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and vertically through the saturated part of the subsurface (i.e., the aquifer). As groundwater passes through the PRB, the reactive material removes the chlorine atoms from the TCE, producing ethene and carbon dioxide. Groundwater exiting the PRB is expected to meet the required concentration levels for TCE and any of its breakdown products. MNA, as defined in the previous section, is expected to address TCE in the alluvial aquifer in the area not treated by the PRB, TCE in the bedrock aquifer, and iron and manganese in both aquifers.


• PRB to treat the TCE in the alluvial aquifer;

• MNA to address the TCE in the alluvial aquifer in the area not treated by the PRB, TCE in the bedrock, and iron and manganese in both aquifers;

• Groundwater and river monitoring to monitor the progress of the PRB and MNA; and

• Groundwater use restrictions to prohibit the use of groundwater from the alluvial and bedrock aquifer for potable use until groundwater monitoring demonstrates that the RAOs and cleanup levels have been achieved.


Capital $617,000 LTM and reporting $112,000


2.9.4 Alternative 4—Groundwater Extraction and Treatment Groundwater extraction and treatment involves pumping the groundwater out of the subsurface and using various methods to remove the contamination.


• Groundwater extraction and treatment to treat the TCE, iron, and manganese in the most contaminated portion of the alluvial and bedrock aquifers;

• Groundwater and river monitoring to monitor the effectiveness of the remedial alternative to extract contamination; and

• Groundwater use restrictions to prohibit the use of groundwater from the alluvial and bedrock aquifer for potable use until groundwater monitoring demonstrates that the RAOs and cleanup levels have been achieved.


Capital $1,272,000 LTM and reporting $156,000


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2.9.5 Common Elements and Distinguishing Features of Each Alternative With the exception of Alternative 1, the “no action” alternative, all alternatives meet the ARARs. Common elements and distinguishing features of the alternatives (with exception of the “no action” Alternative 1) are summarized below.

Common Elements:

• Alternatives 2, 3, and 4 provide treatment of the groundwater to meet the RAOs.

• Groundwater and river monitoring are common to Alternatives 2, 3, and 4.

• Groundwater use restrictions will be required for Alternatives 2, 3, and 4 until RAOs are met.

Distinguishing Features:

• Alternative 2: implementation is simple with minimal operational requirement.

• Alternative 3: groundwater will be passively remediated with minimal operational requirement.

• Alternative 4: groundwater will be extracted to prevent further migration but will require construction of associated structures and more extensive operational requirements.

2.9.6 Expected Outcomes of Each Alternative Under all alternatives, except the “no action” alternative, it is anticipated that groundwater will be remediated to a level that achieves unrestricted residential use. Because of the uncertainties of the duration of natural attenuation, Alternatives 2 and 3 will likely require additional time to achieve levels for unrestricted groundwater use.

2.10 Comparative Analysis of Alternatives Each alternative was developed to address potential risks to human health and the environment posed by contaminated groundwater. The NCP requires the remedial alternatives be evaluated against the nine criteria listed below.

To be considered for remedy selection, an alternative must meet the two following threshold criteria:

1. Overall protection of human health and the environment 2. Compliance with ARARs

The primary balancing criteria are then considered to determine which alternative provides the best combination of attributes. The primary balancing criteria are:

1. Long-term effectiveness and permanence 2. Reduction in toxicity, mobility, or volume through treatment 3. Short-term effectiveness 4. Implementability 5. Cost

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The alternatives are evaluated further against the two modifying criteria:

1. Acceptance by the State 2. Acceptance by the community

The alternatives proposed for Site 5 groundwater were evaluated in the PRAP with respect to the first seven criteria. The two additional modifying criteria are evaluated after the public comment period. The detailed evaluation of alternatives is included in the Focused RI/FS Report (CH2M HILL, 2004a) and summarized by criterion below.

2.10.1 Threshold Criteria 2.10.1.1 Overall Protection of Human Health and the Environment Overall protection of human health and the environment addresses whether each alternative provides adequate protection of human health and the environment and describes how risks posed through each exposure pathway are eliminated, reduced, or controlled, through treatment, engineering controls, and/or institutional controls.

All of the alternatives, except the “no action” alternative, are protective of human health and the environment from groundwater contamination at Site 5. Alternative 4 is most protective because the groundwater is extracted from both the alluvial and bedrock aquifers and it does not rely upon natural attenuation for contaminant reduction. However, all four of these alternatives include the same groundwater use restrictions to minimize potential human exposure to the groundwater until the RAOs are achieved.

2.10.1.2 Compliance with Applicable or Relevant and Appropriate Requirements Section 121(d) of CERCLA and 40 CFR Section 300.430(f)(1)(ii)(B) require that remedial actions at CERCLA sites at least attain legally applicable or relevant and appropriate Federal and State requirements, standards, criteria, and limitations, which are collectively referred to as “ARARs,” unless such ARARs are waived under CERCLA section 121(d)(4). The ARARs identified for the remedial actions at Site 5 are listed in Appendix B.

The NCP, at 40 CFR Section 300.5 defines “applicable requirements” as follows:

{T}hose cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under Federal environmental or State environmental or facility-siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA site. Only those State standards that are identified by a state in a timely manner and that are more stringent than Federal requirements may be applicable.

The NCP, also at 40 CFR Section 300.5, defines “relevant and appropriate requirements” as follows:

{T}hose cleanup standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under Federal environmental or State environmental or facility-siting laws that, while not “applicable” to a hazardous substance, pollutant, contaminant, remedial action, location, or other circumstances at a CERCLA site, address problems

2-18 WDC052790008


or situations sufficiently similar to those encountered at the CERCLA site and their use is well-suited to the particular site. Only those State standards that are identified in a timely manner and are more stringent than Federal requirements may be relevant and appropriate.

In addition, the NCP, at 40 CFR Section 300.400(g)(3), invites the lead agency to identify criteria or guidance to be considered (TBC) in deciding upon implementation of a remedial action. TBCs are guidance, advisories, or criteria developed by USEPA, other federal agencies or states that may be useful in developing a CERCLA remedy; however, TBCs are not promulgated rules or laws.

Compliance with ARARs addresses whether a remedy will meet all of the applicable or relevant and appropriate requirements of other Federal and State environmental statutes or provides a basis for invoking a waiver.

All of the alternatives, except the “no action” alternative, are anticipated to meet the ARARs established for Site 5 groundwater.

2.10.2 Primary Balancing Criteria 2.10.2.1 Long-Term Effectiveness and Permanence Long-term effectiveness and permanence refers to expected residual risk and the ability of a remedy to maintain reliable protection of human health and the environment over time, once clean-up levels have been met. This criterion includes the consideration of residual risk that will remain onsite following remediation and the adequacy and reliability of controls.

All of the alternatives, except the “no action” alternative, are anticipated to achieve long-term effectiveness and permanence. Review at least every 5 years, as required, would be necessary to evaluate the effectiveness of any of these alternatives until the RAOs are achieved.

2.10.2.2 Reduction of Toxicity, Mobility, or Volume through Treatment Reduction of toxicity, mobility, or volume through treatment refers to the anticipated performance of the treatment technologies that may be included as part of a remedy.

All of the alternatives, except the “no action” alternative, utilize treatment as a component of the remedy. Therefore, all of the alternatives will reduce the toxicity and volume of the groundwater contamination through treatment. Alternative 4 will reduce the mobility of the groundwater plume through site-wide groundwater extraction. Alternatives 2 and 3 will reduce the mobility of a portion of the contamination through in-situ treatment and the remainder through MNA.

2.10.2.3 Short-Term Effectiveness Short-term effectiveness addresses the period of time needed to implement the remedy and any adverse impacts that may be posed to workers, the community, and the environment during construction and operation of the remedy until cleanup levels are achieved.

Because Site 5 is located in an undeveloped area of ABL, impact to facility operations will be minimal during implementation of any of the active remedial alternatives. By using safe work practices and groundwater use restrictions until the RAOs are achieved, there will be

WDC052790008 2-19


minimal exposure risk to workers or the community during implementation of any of the active remedial actions.

Alternative 2 is estimated to remediate the TCE plume in 3 years within the injection zone and 21 years in the remainder of the plume. Alternative 3 is estimated to remediate the TCE plume in 16 years. Alternative 4 is estimated to remediate the TCE plume in 7 years. The land use of the Site 5 is not expected to change into the foreseeable future, so the time difference to achieve the RAOs among the alternatives is not expected to make a significant impact on workers, the community or the environment.

2.10.2.4 Implementability Implementability addresses the technical and administrative feasibility of a remedy from design through construction and operation. Factors such as availability of services and materials, administrative feasibility, and coordination with other governmental entities are also considered.

There are no significant technical difficulties associated with implementing any of the alternatives. Implementing Alternative 2 would require design and installation of new wells. Alternative 3 would involve design and construction of the PRB. Alternative 4 would involve design and construction of an extraction system and discharge system.

2.10.2.5 Cost The estimated present worth costs for the alternatives are listed below:

• Alternative 1: $0 • Alternative 2: $1,602,000 • Alternative 3: $1,347,000 • Alternative 4: $1,984,000

2.10.3 Modifying Criteria 2.10.3.1 State of West Virginia Acceptance The WVDEP, on behalf of the State of West Virginia, has reviewed the information available for Site 5 groundwater, surface water, and sediment (OU 02) and concurs with the selected remedy.

2.10.3.2 Community Acceptance Comments were received from the community during the Public Meeting held on March 1, 2005. A copy of the Public Meeting transcript is provided in Appendix A of this ROD. During the public comment period from March 1 to March 31, 2005, no written or verbal comments were received.

2.10.4 Remedial Alternatives Comparative Analysis Summary Table 2-7 summarizes the comparative analysis of the alternatives discussed in Section 2.10.

2-20 WDC052790008


2.11 Principal Threat Wastes The NCP (Section 300.430(a)(1)(iii)(A)) establishes an expectation that USEPA will use treatment to address the principal threats posed by a site wherever practicable. The “principal threat” concept is applied to the characterization of source materials at a CERCLA site. A source material is material that includes or contains hazardous substances, pollutants, or contaminants that act as a reservoir for movement of contamination to groundwater, surface water, or air, or acts as a source for direct exposure. Contaminated groundwater that does not contain non-aqueous phase liquids (NAPLs) is generally not considered to be a source material. The data collected to date suggest groundwater at Site 5 does not contain NAPLs. Therefore, there are no principal threat wastes in Site 5 groundwater.

2.12 Selected Remedy 2.12.1 Summary of the Rationale for the Selected Remedy Alternative 3, the PRB, is the selected alternative for contaminated groundwater at Site 5. Alternative 3 provides the best balance of the nine NCP evaluation criteria described in Section 2.10. Alternative 3 is protective of human health and the environment because it significantly reduces the toxicity, mobility, and volume of contaminants in the groundwater by destroying the VOCs as they migrate through the PRB. Compared to the remaining alternatives, Alternative 3 will achieve ARARs, short- and long-term effectiveness, contaminant reduction, and implementability. In addition, the cost for Alternative 3 is less compared to the other active remedial alternatives.

2.12.2 Description of Selected Remedy The PRB will consist of reactive material placed in the subsurface to intercept groundwater contaminated by TCE. As the contaminated groundwater naturally flows through the PRB, the TCE will be reduced to ethene and carbon dioxide.

Iron metal, or zero-valent iron (ZVI), is the most common reactive media in PRBs that treat VOCs like TCE. Scrap iron for this purpose can be obtained in a granular form in the large quantities needed. Where the groundwater contacts the ZVI (the surface of the ZVI granules), an electron transfer from the iron to the TCE occurs. The result is the replacement of a chlorine atom by a hydrogen atom. Once the three chlorine atoms on the TCE have been replaced, ethene and carbon dioxide remain in the groundwater. The PRB is not expected to significantly raise the level of iron in the groundwater.

The PRB will be placed downgradient from the landfill, on the northern side of the landfill, as close as practicable. The PRB will be approximately 200 feet long and constructed from 3 to 21 feet below ground surface (i.e., throughout the vertical profile of the alluvial aquifer). Figure 2-10 presents a conceptual diagram of the PRB.

Implementation of the PRB will consist of several phases. The first phase is a treatability study, in which small scale tests, using groundwater from the site, will be performed to evaluate the ability of the ZVI to treat the TCE and determine if any undesirable side reactions may occur. The results will be used to improve the design of the PRB. The second

WDC052790008 2-21


phase will include installation of the PRB at Site 5. Contaminants located between the landfill and the PRB move toward the PRB location and are remediated through the PRB.

Alternative 3 also includes MNA to address the contaminants not treated by the PRB, TCE in the portion of the alluvial aquifer that is not treated by the PRB, TCE in the bedrock aquifer, and iron and manganese in both aquifers. Existing contaminants located between the PRB and the river will also be remediated through MNA. A decline in contaminant concentrations in these areas is expected to occur primarily through MNA processes of diffusion, geochemical reactions, volatilization, advection, adsorption, and dispersion.

In order to evaluate the effectiveness of the remedial action (PRB and MNA), LTM will be conducted. In addition, the use of the Site 5 groundwater as a potable water source will be prohibited until it is determined that the groundwater does not pose a potential threat to human health or the environment.

2.12.2.1 Land Use Control (LUC) Implementation Institutional controls will be implemented for Site 5 groundwater to meet the following LUC objectives:

• Ensure no extraction of groundwater, except for monitoring purposes, in the restricted area at Site 5 (Figure 2-11), until the RAOs for OU 02 are met and risks from groundwater use are shown to be reduced to acceptable levels.

• Ensure no construction, maintenance work, or land use in or access to the restricted area without protection from groundwater contaminants, including vapors.

• Maintain the integrity of any current or future remedial equipment or remedial monitoring operation in the restricted area.

The Navy is responsible for implementing, inspecting, reporting, and enforcing the LUC objectives in accordance with a LUC Remedial Design. The LUC Remedial Design will be developed during the design phase, submitted to USEPA and WVDEP within 180 days of signature of this ROD, and will be subject to review and approval by the USEPA.

In the event that any LUC Remedial Design implementing action fails or any LUC objective is not met, the Navy will ensure that appropriate actions are taken to reestablish the action and ensure compliance with the LUC Objectives. The Navy may initiate legal action against a third party to compel action and/or to recover the costs for remedying any LUC violation.

Institutional controls will be maintained until the RAOs for OU 02 are met and the concentration of hazardous substances in the groundwater are at such levels to allow for unrestricted use and exposure.

2.12.3 Summary of Estimated Remedy Costs The detailed breakdown of costs associated with this remedy is presented in Table 2-8. The information provided in the cost estimate is based on the best available information regarding the anticipated scope of the remedial alternative. Changes in the cost elements are likely to occur as a result of new information and data collected during the engineering design of the remedial alternative. Changes may be documented in the form of a memorandum in the Administrative Record file, an Explanation of Significant Differences,

2-22 WDC052790008


or a ROD amendment, depending upon the significance of the change. The cost estimate provided in Table 2-8 is an order-of-magnitude engineering cost estimate that is expected to be within +50 to –30 percent of the actual project cost.

Expenditures that occur over time are analyzed using present worth, which discounts future costs to a common base year. Present-worth analysis allows the cost of remedial action alternatives to be compared on the basis of a single figure representing the amount of money that, if invested in the base year and disbursed as needed, would be sufficient to cover all costs throughout the life of the remedial project. Assumptions associated with the present-worth calculations include a discount rate of 3.2 percent (OMB Circular No. A-94, Appendix C, Revised January 2000), cost estimates in the planning years in constant dollars, and a period of performance of 20 years.

2.12.4 Expected Outcomes of Selected Remedy The purpose of the response action is to control risks posed by contact with contaminated groundwater, minimize the migration of contaminated groundwater, and document the change in the contaminant levels in the groundwater at Site 5 over time. The results of the baseline HHRA for potential future groundwater users at Site 5 indicate that, at the existing contamination levels, an unacceptable risk exists for the alluvial and bedrock aquifers.

Control of groundwater exposure and reduction in TCE, iron, and manganese concentrations are expected to be accomplished as a result of this final remedy. Upon completion of the remedy, projected to be 16 years in duration, it is anticipated that the aquifers at Site 5 will restored to beneficial use as a potable residential water supply, but that land use controls in accordance with the ROD for OU 01 will continue to be necessary due to the presence of the landfill.

2.13 Statutory Determinations Remedial actions must meet the following statutory requirements of CERCLA Section 121 (b) (1):

1. Protection of human health and the environment,

2. Compliance with ARARs (or justification of a waiver),

3. Cost effectiveness,

4. Utilization of permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable, and

5. Treatment that reduces the toxicity, mobility, or volume as a principal element, or explanation as to why the statutory preference for treatment was not selected.

A discussion of how the selected remedy satisfies each of these statutory requirements is provided in the following subsections.

2.13.1 Protection of Human Health and the Environment The selected remedy for Site 5 groundwater is protective of human health and the environment through treatment of contaminated groundwater, natural attenuation

WDC052790008 2-23


processes, and implementation of groundwater use restrictions through appropriate administrative mechanisms until the RAOs are achieved. These components of the selected remedy will eliminate the pathways of potential exposure to contaminated groundwater and ensure that COC levels are reduced to or below the PRGs. In addition, short-term risks associated with exposure to contaminated groundwater during PRB installation and groundwater monitoring will be minimized through safe work practices and the use of personal protective equipment.

2.13.2 Compliance with ARARs The selected remedy will be implemented in compliance with Federal and State requirements that are legally applicable or relevant and appropriate to the remedial action whether chemical-, action-, or location-specific. The ARARs identified for Site 5 groundwater are summarized in Appendix B.

2.13.3 Cost Effectiveness The selected remedy is the most cost effective alternative because it provides the greatest level of remediation for the lowest present worth costs of the active remedies evaluated.

2.13.4 Permanent Solutions and Technologies The selected remedy represents the maximum to which permanent solutions and alternative treatment technologies can be utilized in a practicable manner for groundwater at Site 5. The selected remedy uses treatment technologies by breaking down TCE molecules into ethane and carbon dioxide. It also satisfies the criteria for long-term effectiveness by reducing VOC contaminant levels permanently.

2.13.5 Reduction of Toxicity, Mobility, or Volume as a Principal Element The selected remedy will reduce the toxicity of the groundwater by breaking down TCE in the alluvial aquifer through treatment. In-situ natural attenuation will also reduce the toxicity of the groundwater in both the alluvial and bedrock aquifers by breaking down the TCE and the metal contaminants.

2.13.6 Five-Year Review Requirements In accordance with Section 121(c) of CERCLA and the NCP at 40 CFR Section 300.430(f)(4)(ii), because the selected remedy will result in hazardous substances, pollutants, or contaminants remaining on-site above levels that allow for unlimited use and unrestricted access, a statutory review will be conducted within 5 years after initiation of the remedial action to ensure that the remedy is, or will be, protective of human health and the environment.

2.14 Documentation of Significant Changes from Preferred Alternative of Proposed Plan

The PRAP for ABL Site 5 groundwater, surface water, and sediment was presented for public comment on March 1, 2005. The PRAP recommended Alternative 3, installation of a PRB, as the Preferred Alternative for Site 5 groundwater. No written comments were

2-24 WDC052790008


received during the public comment period of March 1 through March 31, 2005. Verbal comments were communicated and addressed during the Public Meeting on March 1, 2005. The Navy, USEPA, and WVDEP reviewed all comments and determined that no significant changes to the proposed alternative, as originally identified in the PRAP, were necessary or appropriate.

WDC052790008 2-25

OU 02 Record of DecisionSite 5, Allegany Ballistics LaboratoryRocket Center, West Virginia

Alluvial GroundwaterConstituent Minimum Maximum Units Location Frequency of

Concentration Concentration of Maximum DetectionConcentration

Trichloroethene 2 150 µg/L 5GW22 9/11Iron 218 13,800 µg/L 5GW11 10/11Manganese 18.8 2,840 µg/L 5GW13 11/11

Bedrock GroundwaterConstituent Minimum Maximum Units Location Frequency of

Concentration Concentration of Maximum DetectionConcentration

Trichloroethene 7.1 11 µg/L 5GW03 3/5Iron 939 71,600 µg/L 5GW14 5/5Manganese 131.0 1,680 µg/L 5GW14 5/5

Notes:Data collected February 2002.

TABLE 2-1Range of Constituent of Concern Concentrations

Table 2-2Selection of Exposure PathwaysOU 02 Record of DecisionSite 5, Allegany Ballistics LaboratoryRocket Center, West Virginia

Scenario Medium Exposure Exposure Receptor Receptor Exposure On-Site/ Type of Rationale for Selection or ExclusionTimeframe Medium Point Population Age Route Off-Site Analysis of Exposure Pathway

Current/Future Surface Water Surface Water Site 5 Surface Water Other Recreational Person Adult Dermal Absorption On-Site Quant Recreational users may contact surface water during recreational

activities.

Ingestion On-site Quant Recreational users may ingest surface water during recreational activities.

Adolescents Dermal Absorption On-site Quant Recreational users may contact surface water during recreational

activities.

Ingestion On-site Quant Recreational users may ingest surface water during recreational activities.

Sediment Sediment Site 5 Sediment Other Recreational Person Adult Dermal Absorption On-site Quant Recreational users may contact sediment during recreational

activities.

Ingestion On-site Quant Recreational users may ingest sediment during recreational activities.

Adolescents Dermal Absorption On-site Quant Recreational users may contact sediment during recreational

activities.

Ingestion On-site Quant Recreational users may ingest sediment during recreational activities.

Future Groundwater Groundwater Alluvial Aquifer-Tap Water Resident Adult Ingestion On-site Quant Although unlikely, groundwater evaluated for use as future potable water supply.

Child Dermal Absorption On-site Quant Although unlikely, groundwater evaluated for use as future potable

water supply.

Ingestion On-site Quant Although unlikely, groundwater evaluated for use as future potable water supply.

Adult/Child Ingestion On-site Quant Although unlikely, groundwater evaluated for use as future potable water supply. This is for cancer risk only.

Alluvial Aquifer-Water in Excavation Pit Construction Worker Adult Dermal

Absorption On-site Quant Construction workers may contact groundwater while performing construction or excavation activities.

Ingestion On-site None Ingestion of groundwater during construction activities expected to be minimal.

Air Alluvial Aquifer-Water Vapors at Showerhead Resident Adult Inhalation On-site Quant Although unlikely, groundwater evaluated for use as future potable

water supply.Child Inhalation On-site None Children are assumed not to shower.

Alluvial Aquifer-Volatilization from Water in

Excavation PitConstruction Worker Adult Inhalation On-site Quant Construction workers may inhale vapors from groundwater while

performing construction or excavation activities.

Groundwater Bedrock Aquifer-Tap Water Resident Adult Ingestion On-site Quant Although unlikely, groundwater evaluated for use as future potable water supply.

Child Dermal Absorption On-site Quant Although unlikely, groundwater evaluated for use as future potable

water supply.

Ingestion On-site Quant Although unlikely, groundwater evaluated for use as future potable water supply.

Adult/Child Ingestion On-site Quant Although unlikely, groundwater evaluated for use as future potable water supply. This is for cancer risk only.

Air Bedrock Aquifer-Water Vapors at Showerhead Resident Adult Inhalation On-site Quant Although unlikely, groundwater evaluated for use as future potable

water supply.Child Inhalation On-site None Children are assumed not to shower.

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TABLE 2-3Toxicity Information for Constituents of ConcernOU 02 Record of DecisionSite 5, Allegany Ballistics LaboratoryRocket Center, West Virginia

Chemical of Potential ConcernNON-CANCER TOXICITY DATA -- ORAL/DERMALChronic/ Subchronic Chronic Subchronic Chronic Subchronic Chronic SubchronicOral RfD Value (mg/kg-day) 3.0E-01 N/A 2.0E-02 N/A 3.0E-04 N/AOral to Dermal Adjustment Factor (1) 20% N/A 35% N/A 80% N/AAdjusted Dermal RfD (mg/kg-day) (2) 6.0E-02 N/A 7.0E-03 N/A 2.4E-04 N/APrimary Target Organ Gastrointestinal N/A CNS N/A Liver, Kidney N/ACombined Uncertainty/Modifying Factors 1 N/A 1 N/A N/ASources of RfD: Target Organ NCEA N/A IRIS N/A NCEA N/ADates of RfD: Target Organ (3) (MM/DD/YY) 9/30/2002 N/A 3/21/2002 N/A N/ANON-CANCER TOXICITY DATA -- INHALATIONValue Inhalation RfC (mg/m3) N/A N/A 5.01E-05 N/A 3.50E-02 N/AAdjusted Inhalation RfD (mg/kg-day) (2) N/A N/A 1.43E-05 N/A 1.00E-02 N/APrimary Target Organ N/A N/A CNS N/A Liver, Kidney N/ACombined Uncertainty/Modifying Factors N/A N/A 1000 N/A N/ASources of RfC:RfD: Target Organ N/A N/A IRIS N/A NCEA N/ADates (3) (MM/DD/YY) N/A N/A 3/21/2002 N/A 9/3/2002 N/ACANCER TOXICITY DATA -- INHALATIONUnit Risk (ug/m3)-1 N/A N/A N/A N/A 1.1E-04 N/AAdjustment (4) N/A N/A N/A N/A 3500 N/AInhalation Cancer Slope Factor (mg/kg-day) -1 N/A N/A N/A N/A 4.0E-01 N/ASource N/A N/A N/A N/A NCEA N/ADate (3) (MM/DD/YY) N/A N/A N/A N/A 9/30/2002 N/A

Notes:N/A = Not Applicable or Not Available. IRIS indicates that calculations of dermal risks may not be appropriate for this chemical.(1) Refer to RAGS, Part A. Source is EPA Region III Oral Absorption Values for Oral-to-Dermal Extrapolation , April 8, 1999. For constituents not available in the Region III document the following general values were used: VOCs - 80%,

Pesticides/PCBs - 50%, dioxins/furans - 50%, and metals - 20%. IRIS = Integrated Risk Information System NCEA = National Center for Environmental Assessment(2) Equation for derivation provided in the RI/FS (CH2M HILL, 2004a).(3) For IRIS values, date IRIS was searched is listed. For NCEA values, the date of the article provided by NCEA is listed.CNS = Central Nervous SystemRfD = Reference DoseRfC = Reference concentration(4) Adjustment Factor applied to Unit Risk to calculate Inhalation Slope Factor = 70kg x 1/20m3/day x 1000ug/mg

Iron Manganese (nonfood) Trichloroethene

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TABLE 2-4Human Health Risk Assessment Summary by ReceptorOU 02 Record of DecisionSite 5, Allegany Ballistics LaboratoryRocket Center, West Virginia

Future Adult/Child Resident (Age adjusted)

Cancer Non-cancer Cancer Non-cancer Cancer Cancer Non-cancerReasonable Maximum ExposureAlluvial AquiferIngestion NA 20 NA 54 1.0E-03 NA NADermal Contact NA NA 5.1E-05 5.0 5.1E-05 9.0E-06 5.6Inhalation 1.1E-03 0.78 NA NA 1.1E-03 3.8E-07 0.035Total 1.1E-03 21 5.1E-05 59 2.2E-03 9.4E-06 5.6Bedrock AquiferIngestion NA 9.5 NA 26 5.4E-05 NA NADermal Contact NA NA 2.9E-06 0.49 2.9E-06 NA NAInhalation 6.1E-05 0.04 NA NA 6.1E-05 NA NATotal 6.1E-05 9.6 2.9E-06 26 1.2E-04 NA NAAll MediaTotal 1.1E-03 30 5.3E-05 85 2.3E-03 9.4E-06 5.6Central TendencyAlluvial AquiferIngestion NA 1.2 NA 21 1.6E-04 NA NADermal Contact NA NA 8.1E-06 2.4 8.1E-06 NA 4.2Inhalation 2.7E-04 NA NA NA 2.7E-04 NA NATotal 2.7E-04 1.2 8.1E-06 23 4.4E-04 NA 4.2Bedrock AquiferIngestion NA 4.4 NA 9.9 NA NA NADermal Contact NA NA NA 0.33 NA NA NAInhalation NA NA NA NA NA NA NATotal NA 4.4 NA 10 NA NA NAAll MediaTotal 2.7E-04 5.6 8.1E-06 33 4.4E-04 NA 4.2

Notes: The groundwater cancer risk for inhalation is calculated for an adult, for ingestion it is calculated for combined child and adult (age-adjusted), and for dermal is calculated foNA - Not Applicable, not evaluated

Future Adult Resident Future Construction WorkerFuture Child Resident

TABLE 2-5Preliminary Remediation Goals for Groundwater COCsOU 02 Record of DecisionSite 5, Allegany Ballistics LaboratoryRocket Center, West Virginia

Maximum Concentration (ug/L) (a)

USEPA Safe Drinking Water Act (MCL)

Risk-Based Concentrations — Human Health (b)

Volatile Organic CompoundTrichloroethene 150 5 3.7MetalsIron 16,800 (dissolved) NA 4,000Manganese 8,030 (dissolved) NA 260

Notes:MCL—Maximum contaminant level.NA—No standard available or not applicable.

(b) Risk-based concentrations based on exposure to the future child resident for non-carcinogenic RBCs, and the future age-adjusted resident for carcinogenic risk-based concentrations via a combined ingestion, dermal (child only), and inhalation (adult only) scenario.

Bolded with bold outline indicates recommended PRG. See Focused RI/FS (CH2M HILL, 2004a) text for rationale for

Concentration (ug/L)

(a) Excludes well 5GW01, which is upgradient of the site.

TABLE 2-6Components of Remedial Alternatives for GroundwaterOU 02 Record of DecisionSite 5, Allegany Ballistics LaboratoryRocket Center, West Virginia

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Technology/ Process Option No Action

Enhanced Reductive

Dechlorination

Permeable Reactive Barrier

Groundwater Extraction and

Treatment No Action X Administrative Restrictions on Groundwater Use X X X Groundwater and River Monitoring X X X Groundwater Extraction Wells X Monitored Natural Attenuation X X In-Situ Enhanced Reductive Dechlorination X In-Situ Metal Enhanced Reductive Dechlorination X Ex-Situ Air Stripping Treatment X Discharge to Surface Water X

TABLE 2-7Detailed Evaluation of Remedial Alternatives SummaryOU 02 Record of DecisionSite 5, Allegany Ballistics LaboratoryRocket Center, West Virginia


Evaluation Criteria No ActionEnhanced Reductive

DechlorinationPermeable Reactive Barrier

(PRB) Groundwater Extraction and

TreatmentOverall Protection of Human Health and the EnvironmentPrevent or Minimize Exposure to Contaminated Groundwater by future onsite residents

No reduction in risk of exposure over current levels.

Groundwater use restrictions will minimize potential for exposure and ERD in the source area will prevent spread of VOC contamination further downgradient. Contamination in groundwater sidegradient of the treatment area and in the bedrock is to naturally attenuate.

Groundwater use restrictions will minimize potential for exposure and PRB will prevent spread of VOC contamination downgradient. Contamination in groundwater downgradient of PRB and in the bedrock is to naturally attenuate.

Groundwater use restrictions will minimize potential for exposure and will and alluvial aquifer extraction will prevent spread of COC contamination. Also will result in collection of bedrock groundwater via induced upward gradients

Prevent or minimize river media from becoming impacted by the Site 5 groundwater COCs such that resulting concentrations present an unacceptable risk to human health or the environment.

Contamination would continue to migrate at present levels. These levels currently do not pose an unacceptable risk to human health or the environment. Natural attenuation will occur without monitoring.

ERD in the source area coupled with attenuation minimizes possibility of offsite migration from alluvium. Migration of alluvial contamination sidegradient of treatment area and in the bedrock would continue until naturally attenuated; monitoring would be used to track constituent concentrations and migration and ensure concentrations in river do not pose an unacceptable risk.

PRB prevents river contamination from site alluvium. Migration of alluvial contamination downgradient of PRB and in the bedrock would continue until naturally attenuated; monitoring would be used to track constituent concentrations and migration and ensure concentrations in river do not pose an unacceptable risk.

Alluvial aquifer extraction system will prevent offsite migration. Also will result in collection of bedrock groundwater via induced upward gradients; monitoring would be used to track constituent concentrations and migration and ensure concentrations in river do not pose an unacceptable risk.

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TreatmentReturn Groundwater to PRGs within a Reasonable Time Frame (estimate based on batch flushing method and assumptions)

Natural attenuation should reduce TCE to MCL in 30 years assuming no further releases from the landfill and linear desorption. Iron and manganese concentrations maypersist at concentrations exceeding PRGs.

ERD in combination with natural attenuation should reduce TCE to MCL in 21 years assuming no further releases from the landfill and linear desorption. This is considered a reasonable time giventhe low potential for exposure. Iron and manganese concentrations may persist at concentrations exceeding PRGs, but ICs will prevent exposure to groundwater.

The PRB in combination with natural attenuation should reduce TCE to MCL in 16 years assuming no further releases from the landfill and linear desorption. This is considered a reasonable time given the low potential for exposure. Iron and manganese concentrations may persist at concentrations exceeding PRGs, but ICs will prevent exposure to groundwater.

The groundwater collection and treatment system is estimated to reduce TCE to MCL in 7 years assuming no further releases from the landfill and linear desorption. Iron and manganese concentrations may persist at concentrations exceeding PRGs, but ICs will prevent exposure to groundwater.

Compliance With ARARsARARs Does not comply with ARARs Meets ARARs. Will meet

substantive requirements of injection permit.

Meets ARARs. Meets ARARs. Will meet substantive requirements of discharge permit.

Long-Term Effectiveness and PermanenceMagnitude of Risks Current conditions. ERD should reduce TCE more

quickly than attenuation alone. However, iron and manganese concentrations increase during ERD implementation. Potential risks are minimized by ICs.

PRB should reduce COC concentrations more quickly (roughly 16 years) than natural attenuation alone. Iron and manganese concentrations may persist at concentrations exceeding PRGs. Potential risks are minimized by ICs.

Extraction would reduce TCE concentrations and possibly iron and manganese concentrations. However, iron and manganese concentrations may persist at concentrations exceeding PRGs. Risks are minimized by ICs.

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TreatmentAdequacy and Reliability of Controls

No controls. Substrate injection has been proven to be effective at various sites. IC plan is expected to reliably prevent exposure to groundwater until TCE MCL is achieved. In the event of continued releases from the landfill additional substrate injections would be required.

PRBs have been proven to be effective at various sites. IC plan is expected to reliable prevent exposure to groundwater until TCE MCL is achieved. In the event of continued releases from the landfill, the PRB may require replacement after about 20 years.

Groundwater collection and treatment are effective for removing VOCs and some iron and manganese from groundwater. IC plan is expected to reliably prevent exposure to groundwater until cleanup goals are achieved. Possibility that ICs can be lifted more quickly than with other alternatives. If TCE continues to be released from the landfill or aquifer material groundwater collection can easily be continued as necessary.

Reduction of Toxicity, Mobility, or Volume Through TreatmentEstimated amount of TCE removed and treatment time.

Natural attenuation will remove the estimated 4.9 pounds of TCE over 30 years. Contaminated groundwater will continue to migrate to the river at low levels until naturally attenuated. No active remediation.

ERD will biologically degrade an estimated 2.4 pounds of TCE. The remaining 2.5 pounds of TCE in the alluvial aquifer will naturally attenuate over 21 years. TCE in the bedrock aquifer and metals will naturally attenuate.

The PRB will abiotically degrade an estimated 1.2 pounds of TCE. The remaining 3.7 pounds of TCE in the alluvial aquifer will naturally attenuate over 16 years. TCE in the bedrock aquifer and metals will naturally attenuate.

The groundwater collection system will remove nearly all the estimated 4.9 pounds of TCE from the aquifer within 7 years. The cascade aeration channel will result in treatment of about 90% or 4.4 pounds of TCE. The removed TCE will be transferred to the air where it will photolytically degrade.

Page 3 of 5






TreatmentShort-Term EffectivenessImpacts on workers, the community and the environment during implementation.

Not relevant. Impacts on the facility would be minor, and consist primarily of increased activity in the area. ERD will result in increase in iron and manganese in aquifer which are expected to persist and cause objectionable taste long after the TCE has been reduced to MCLs. Also ERD may result in iron staining along the banks of the river.

Impacts on the facility would be minor, and consist primarily of temporary increase in construction traffic.

Impacts on the facility would be minor, and consist primarily of temporary increase in construction traffic.

Time Until Action Is Complete (Estimate based on batch flushing method and assumptions provided in the Focused RI/FS.)

Not applicable. Estimated at 3 years within injection zone (area of highest levels of contamination). Estimated at 21 years for TCE remediation of plume.

Estimated at approximately 16 years for TCE remediation of plume.

Estimated at approximately 7 years for TCE remediation of plume, provided all assumptions are met and no additional TCE is released from the landfill or aquifer material.

Page 4 of 5






TreatmentImplementability

Not applicable. Implementation is simple and straightforward. Easily constructed; minimal operational requirement.

Laboratory/pilot scale testing is required. Easily constructed; minimal operational requirement.

Easily constructed and operated. Aquifer testing activities required prior to final design.

CostCapital Cost $0 $593,000 $617,000 $1,272,000 Annual O&M Cost $0 $186,000 (Years 1 and 2) $66,000 (Years 1 through 10) $109,000 (Years 1 through 7)

$59,000 (Years 3 through 10) $26,000 (Years 11 through 20)$26,000 (Years 11 through 25)

Post-Closure Cost $0 $98,000 $23,000 $47,000 Present-Worth $0 $1,602,000 $1,347,000 $1,984,000 State Acceptance

Not Acceptable Acceptable Acceptable AcceptableCommunity Acceptance

Not Acceptable Acceptable Acceptable Acceptable

Page 5 of 5

Table 2-8Cost Estimate Details, Alternative 3OU 02 Record of DecisionSite 5, Allegany Ballistics LaboratoryRocket Center, West Virginia

Assumptions1. The accuracy of the cost estimate is +50%/-30%

Detailed Capital and Operations and Maintenance Costs

CAPITAL COSTItem/Activity Qty Unit Unit Cost Cost Comments and References

Preliminary Assessment / Treatability Study 1 ls 25,000$ 25,000$ LUCIP Preparation 1 ls 2,000$ 2,000$

EarthworkMob/Demob 1 ls 2,200$ 2,200$ Clearing/Grubbing 0.4 ac 4,900$ 1,960$ Backfill, Common Earth 520.0 cy 4.4$ 2,288$ Topsoil/Fine Grade/Seed 1400 sy 6.9$ 9,660$

PRB Wall Construction (Vendor Costs)Iron Material (Delivered) 225 ton 425$ 95,625$ Vendor Quote: 200 x 15 x 1 ft = 3,000 cf of Iron Material. Bulk Mobilization of Trenching and Injection Equipment 1 ls 50,000$ 50,000$ Density of Iron = 0.075 ton/cf; 3,000 cf x 0.075 ton/cf = 425 tonsBiopolymer Installation of Iron Material 1 ls 105,000$ 105,000$ Vendor QuoteLicense Fee 12% of 250,625$ 30,075$ Vendor Quote

Waste DisposalOffsite Disposal of Excavated Soil as Haz. Waste 178 ton 145$ 25,778$ Engineer's Estimate; Assume 1.6 tons/cy

Field OversightField Oversight 15 day 755$ 11,325$ Assume $105/day per-diem and $65/hour x 10 hour/day

Subtotal Capital Cost 360,911$

Site Work Allowance 5% of 360,911$ 18,046$ Mechanical Allowance 0% of 360,911$ -$ Instrumentation and Controls Allowance 0% of 360,911$ -$ Electrical Allowance 0% of 360,911$ -$ Miscellaneous Equipment Allowance 2% of 360,911$ 7,218$


Project Management 8% of 386,175$ 30,894$ Design 10% of 386,175$ 38,617$ Construction Management 10% of 386,175$ 38,617$ Subcontractor General Requirements 5% of 386,175$ 19,309$


Contingency 20% of 513,612$ 102,722$

TOTAL CAPITAL COST 617,000$

Page 1 of 4


OPERATION AND MAINTENANCE COSTSItem/Activity Qty Unit Unit Cost Cost Comments and References

Analytical CostsGroundwater Samples TCL Low-concentration Volatiles by CLP (OLC03) 0 samples $126 -$ Sample quantities include 15 monitoring well locations, Methane/Ethane/Ethene (RSK 175/147) 31 samples $131 4,069$ plus QA/QC samples TAL Metals plus B and Mo (ILM04) 0 samples $110 -$ (Includes both total and dissolved metals analyses) Total Recoverable Phenolics (EPA 420) 0 samples $32 -$ Cyanide 0 samples $21 -$ Hardness (130.2) 0 samples $16 -$ Chemical Oxygen Demand (COD) 24 samples $25 605$ Total Organic Carbon (TOC) (415.2/ 9060) 24 samples $34 806$ Nitrate (353.2/ 353.3/ 354.1) 24 samples $21 504$ Ammonia-Nitrogen (350.1/ 350.2) 0 samples $20 -$ Biological Oxygen Demand - 5 day (BOD) 0 samples $25 -$ Nitrite (353.2/ 354.1) 24 samples $21 504$ Sulfate (375.4) 24 samples $19 454$ Chloride (325.1/ 325.3) 24 samples $19 454$ Bicarbonate 0 samples $16 -$ Total Dissolved Solids (160.1) 0 samples $13 -$ Alkalinity (310.1) 24 samples $15 353$ Surface Water Samples TCL Low-concentration Volatiles by CLP (OLC03) 8 samples $126 1,008$ TAL Metals (ILM04) 7 samples $100 698$ Cyanide (ILM04) 7 samples $21 147$

Labor Costs (Sampling, Sample Mgt, Validation, Reporting) Project Manager 8 hours 90$ 720$ Project Scientist 80 hours 65$ 5,200$ GIS/Database Professional 0 hours 65$ -$ Project Chemist 8 hours 65$ 520$ Field Technician 80 hours 65$ 5,200$ Data Technician 50 hours 65$ 3,250$ Equipment Manager 4 hours 55$ 220$

Other Expenses (Sampling, Sample Mgt, Validation, Reporting) Field Equipment 1 LS 5,000$ 5,000$ Reprographics 1 LS 250$ 250$ Data Validation 1 LS 1,600.00$ 1,600$ Travel 1 event 1,000.00$ 1,000$

Subtotal O&M Cost 32,561$

Project Management 8% of 32,561$ 2,605$ Design 0% of 32,561$ -$ Construction Management 0% of 32,561$ -$ Subcontractor General Requirements 5% of 32,561$ 1,628$


Contingency 20% of 36,794$ 7,359$

COST PER MONITORING EVENT 45,000$

Page 2 of 4


REPORTING COSTSItem/Activity Qty Unit Unit Cost Cost Comments and ReferencesLabor Costs (Sampling, Sample Mgt, Validation, Reporting) Project Manager 8 hours 90$ 720$ Project Scientist 40 hours 65$ 2,600$ GIS/Database Professional 8 hours 65$ 520$ Project Chemist 0 hours 65$ -$ Field Technician 0 hours 65$ -$ Data Technician 40 hours 65$ 2,600$ Equipment Manager 0 hours 55$ -$

Other Expenses (Sampling, Sample Mgt, Validation, Reporting) Field Equipment 0 LS 5,000$ -$ Reprographics 1 LS 250$ 250$ Data Validation 0 LS 2,000.00$ -$ Travel 0 event 1,310.00$ -$

Subtotal Reporting Cost 6,690$

Project Management 8% of 6,690$ 535$ Design 0% of 6,690$ -$ Construction Management 0% of 6,690$ -$ Subcontractor General Requirements 0% of 6,690$ -$


Contingency 20% of 7,225$ 1,445$

REPORTING COSTS 9,000$

Page 3 of 4


POST CLOSURE OPERATIONS AND MAINTENANCEItem/Activity Qty Unit Unit Cost Cost Comments

ReportingLabor - Engineer/Hydrogeologist 100 hr 90$ 9,000$ Labor - Editor 50 hr 65$ 3,250$ Labor - CAD Technician 25 hr 65$ 1,625$

Subtotal Reporting 13,875$

Project Management 8% of 13,875$ 1,110$ Technical Support 15% of 13,875$ 2,081$ Construction Management 10% of 13,875$ 1,388$ Subcontractor General Requirements 5% of 13,875$ 694$

Subtotal Post-Closure Operations and Maintenance 19,148$

Contingency 20% of 19,148$ 3,830$

TOTAL POST-CLOSURE OPERATIONS AND MAINTENANCE COST 23,000$

Present Worth AnalysisCost Factor Applied Present Worth Cost

Capital Costs 617,000$ none 617,000$ Triquarterly Monitoring Costs (Years 1 through 10) 63,000$ (P/A, 3.2%, 10) 531,959$ Assume 14 tri-quarterly monitoring events over 10 yearsBiannual Monitoring Costs (Years 11 through 20) 23,000$ (P/A, 3.2%, 10) (P/F, 3.2%, 10) 141,732$ Assume 5 bi-annual monitoring events over 10 yearsReporting Costs (Every 3 Years) 3,000$ (P/A, 3.2%, 20) 43,818$ Year 20 Post-Closure Cost 23,000$ (P/F, 3.2%, 20) 12,250$

Total Present Worth 1,347,000$

Page 4 of 4

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Schematic Cross-section of Site 5OU 02 Record of Decision

Site 5, Allegheny Ballistics Laboratory

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Contamination Mechanisms Mechanisms Point Media Routes Receptor Receptor

Alluvial Aquifer Ingestion, Future

Leaching/Desorption Groundwater Flow On-site Groundwater Inhalation, and Construction Workers/ Dermal Absorption Residential Users

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Absorption Recreational Users

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DiffusionInhalation of Future Site Workers

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Emissions

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Excavation Inhalation of Future Site Workers

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Emissions

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Direct Contact Site 5 Soil Exposed Dermal Future Construction Worker with Soil Material Absorption Future Resident

Complete Pathway Figure 2-5Incomplete Pathway Conceptual Site Model for Potential Human Exposures

OU 02 Record of DecisionSite 5, Allegany Ballistics LaboratoryRocket Center, West Virginia

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Permeable Reactive BarrierOU 02 Record of Decision

Site 5, Allegheny Ballistics Laboratory

Rocket Center, West Virginia

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SECTION 3

Responsiveness Summary

The selected alternative for Site 5 groundwater is the installation of a PRB downgradient from the landfill. No written comments were received during the public comment period, which was held from March 1, 2005 through March 31, 2005. A Public Meeting was held on March 1, 2005 to present the Proposed Plan for Site 5 groundwater and address any questions or comments on the Proposed Plan and on the documents in the information repositories. One person, in addition to representatives from the agencies involved, attended the Public Meeting. Several questions were asked and answered during the meeting and are documented in the meeting transcript included as Appendix A of this ROD. It was determined that no significant changes to the remedy, as originally identified in the PRAP, were necessary or appropriate.

A summary of the questions addressed during the public meeting is presented below. Paraphrasing or clarifying annotations to the questions and responses are shown in brackets.

1. Where will the [iron and manganese] going to go?

Navy Response: As the reducing conditions of the aquifer decrease over time, the iron and manganese will precipitate out of the groundwater and into the soil matrix.

2. You’re putting iron back [into the groundwater with the PRB system]?

Navy Response: The iron will reduce the concentrations of TCE in the groundwater but is not expected to raise the concentrations of iron in the groundwater.

3. Is [the alluvial aquifer] the only aquifer there, or is there one below it?

Navy Response: There’s an aquifer in the bedrock as well.

4. Then how is the water in [the bedrock aquifer]?

Navy Response: There is a small amount of TCE contamination in the bedrock aquifer, but it is just above the MCL.

5. The pump and treat method, is that taking it out and bringing it over to the treatment plant?

Navy Response: The alternative which includes the pump and treat system would bring the groundwater to the ground surface and channel it through the riprap channel to the river. The TCE would transfer from the groundwater to the air. It is not a destructive treatment, although is acceptable per the ARARs, but is not the preferred remedy.

6. You have all this iron and all this manganese in the groundwater that you say goes into the Potomac. How come they don’t find it in the sediment?

Navy Response: The groundwater discharges to the Potomac River. Iron and manganese are detected at elevated concentrations adjacent to the landfill. Reducing conditions are

WDC052790008 3-1


encountered adjacent to the landfill and return to natural conditions downgradient from the landfill, before discharge to the Potomac River. The geochemical change in the groundwater as it flows toward the Potomac River facilitates the precipitation of these two metals, resulting in reduced iron and manganese concentrations before discharge to the Potomac River.

7. Did you test for arsenic or anything else that is naturally occurring in the soil?

Navy Response: Yes. The soil was tested for arsenic. However, the concentrations were not large enough to be identified as a human health risk.

8. Do you have [dense non-aqueous phase liquids (DNAPLs)] in the soil above groundwater?

Navy Response: We have not identified any DNAPLs.

9. Is the landfill lined underneath?

Navy Response: No. There is a Subtitle C cap on the landfill.

10. What’s the maintenance of this barrier that you will put in?

Navy Response: Very little to none. Once the PRB is in place, monitoring will occur downgradient of the PRB. If TCE concentrations increase, potentially signaling a breakthrough, the material in the PRB would be regenerated.

3-2 WDC052790008

SECTION 4

References

CH2M HILL, Inc. 1996a. Remedial Investigation of Allegany Ballistics Laboratory Superfund Site, Rocket Center, West Virginia. Prepared for Department of the Navy, Atlantic Division, Naval Facilities Engineering Command, Norfolk, Virginia. January.

CH2M HILL, Inc. 1996b. Phase II Remedial Investigation at Allegany Ballistics Laboratory Superfund Site. Prepared for Department of the Navy, Atlantic Division, Naval Facilities Engineering Command, Norfolk, Virginia. August.

CH2M HILL, Inc. 1996c. Focused Feasibility Study for Site 5 Landfill Contents and Surface Soil at Allegany Ballistics Laboratory Superfund Site. Prepared for Department of the Navy, Atlantic Division, Naval Facilities Engineering Command, Norfolk, Virginia. August.

CH2M HILL, Inc. 1998. Final Phase I Aquifer Testing at Allegany Ballistics Laboratory Superfund Site, Rocket Center, West Virginia. Prepared for Department of the Navy, Atlantic Division, Naval Facilities Engineering Command, Norfolk, Virginia. December.

CH2M HILL, Inc. 2004a. Final Focused Remedial Investigation and Feasibility Study for Site 5 Groundwater, Surface Water, and Sediment. Prepared for Department of the Navy, Naval Facilities Engineering Command, Atlantic. September.

CH2M HILL, Inc. 2004b. Final Long-Term Monitoring Report for Sites 1, 5, and 10, Allegany Ballistics Laboratory. Prepared for Department of the Navy, Atlantic Division, Naval Facilities Engineering Command, Norfolk, Virginia. March.

CH2M HILL, Inc. 2004c. Final Long-Term Monitoring Report for Site 5, Allegany Ballistics Laboratory. Prepared for Department of the Navy, Atlantic Division, Naval Facilities Engineering Command, Norfolk, Virginia. April.

CH2M HILL, 2004d. Site Management Plan (SMP) for ABL. April.

Chief of Naval Operations (CNO). 1999. Navy Policy for Conducting Ecological Risk Assessments. Memorandum from Chief of Naval Operations to Commander, Naval Facilities Engineering Command. Ser N453E/9U595355. April.

Environmental Science and Engineering (ES&E). 1983. Initial Assessment Study of Allegany Ballistics Laboratory. January.

Naval Facilities Engineering Command (NAVFAC). 2001. Navy Guidance for Conducting Ecological Risk Assessments. http://web.ead.anl.gov/ecorisk/. February.

OHM Remediation Services Corp. 1997. Draft Construction Closeout Report, Landfill Cap Construction Site 5 – Inert Landfill, Allegany Ballistics Laboratory, Mineral County, West Virginia. November.

Roy F. Weston. 1989. Interim Remedial Investigation for Allegany Ballistics Laboratory. October.

WDC052790008 4-1


Unites States Environmental Protection Agency (USEPA). 1994. Region III Modifications to National Functional Guidelines for Organic Data Review EPA 903/1994.1. September.

U.S. Navy. 1997. EPA Superfund Record of Decision: Allegany Ballistics Laboratory (USNAVY). USEPA ID: WV0170023691. 2/12/1997.

USEPA. 1988. Interim Final, Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA. October.

USEPA. 2000. Integrated Risk Information System (IRIS). www.epa.gov/iris

U.S. Navy. 2005. Proposed Remedial Action Plan for Site 5 Groundwater, Surface Water, and Sediment. March.

4-2 WDC052790008

Appendix A Transcript of Public Meeting for

ABL Site 5 PRAP

ORIGINAL1

2

3 PUBLIC MEETING

4 FOR ABL SITE 5 PRAP

5

6

7 * * * * * *

8

9 TRANSCRIPT OF PROCEEDINGS

10 Allegany Ballistics Laboratory, Building 300

11 Rocket Center, West Virginia

12 March 1, 2005

13

14 * * * * * *

15

16

17

18

19

20

21

22Word for Word Reporting

Swanton, MD 21561301-387-8414

Page 2

1 PRESENT:

2 ALLEGANY COUNTY HEALTH DEPARTMENTBetsy Kagey

3

4 ATKKaren Weakley

5 David Gosen

6 CH2M HILLSteve Glennie

7 Laurie AldapeJose Amayo

8 EPA REGION III

Mark Stephens910 NAVFAC

Steve Martin11

NAVSEAR. W. Aubert

12 Louis Williams

13 WVDEPTom Bass

14

15

16

17

18

19

20

21

22Word for Word Reporting

Swanton, MD 21561301-387-8414

Page 3

1 P R 0 C E E D I N G S

2 (The meeting was called to order at 5:42 p.m.

3 by Steve Glennie. )

4 MR. GLENNIE: We're starting a public meeting

5 for the Proposed Remedial Action Plan for Site 5 at

6 Allegany Ballistics Lab, and it's March 1st of 2005.

7 We've issued the -- the Navy has issued a Proposed

8 Remedial Action Plan for Site 5, which I'll give you a

9 copy of.

10 MS. KAGEY: Is this my copy?

11 MR. GLENNIE: That's your copy. Along with

12 the Plan, we've also done a brief fact sheet that

13 summarizes the highlights of the Proposed Plan for

14 Site 5 and also provides a space for folks to comment.

15 The plan and the fact sheet have been distributed.

16 Actually, one has been distributed at the LaVale Public

17 Library -- or will be distributed at the LaVale Public

18 Library, and the other one at Fort Ashby has already

19 been distributed.

20 So, Site 5 is across 956. So as you're coming

21 into the plant from the Maryland side, as you come over

22 the river, you turn left into the developed portion of

Page 4

1 ABL. If you turned right, back about a quarter mile

2 that direction, there is a landfill, and Site 5 is

3 right along the riverfront there. So the objectives

4 of this particular proposed plan is to present the

5 findings and site investigations that we've had at

6 Site 5.

7 There is already a remedy in place for the

8 soil at Site 5, and we've recently completed an RI/FS

9 for the groundwater beneath the Site, as well as the

10 surface water and sediment of the North Branch Potomac

11 River adjacent to the site. So the PRAP presents a

12 remedial alternative selection process that's been

13 completed. It provides a recommended preferred

14 alternative for the Site, so based on the investigations

15 and feasibility studies, the Navy and the regulatory

16 agencies have come up with a preferred alternative,

17 and this is the public's opportunity to review that

18 alternative and comment on it, and then once those

19 comments are received, a final alternative will be

20 selected.

21 The components of the PRAP are -- there's

22 multiple components, and they're bulletized here on

Page 5

1 the screen, plus gives the Site background information,

2 which we'll go over briefly tonight and the characteristics

3 of the Site. The scope of the investigations are spelled

4 out. Potential human health and ecological risks to

5 the Site are spelled out in the PRAP. Objectives of

6 remedial action are described, and the different

7 evaluation criteria of each alternative are presented,

8 and the preferred alternative is described. So if

9 there are any questions, we can do those during the

10 presentation, if there's a specific thing that comes

11 up. Please don't hesitate to ask, or we can have a

12 formal question process at the end as well.

13 Site 5, as I mentioned, is a non-developed

14 portion of ABL. It's a landfill that operated from

15 1960 to 1985, accepting inert materials, and inert, as

16 defined by the facility, are non-energetic materials,

17 so it doesn't mean chemically inert; it means --

18 MS. KAGEY: They just don't go bang.

19 MR. GLENNIE: They just don't go bang; non-

20 explosive materials. In the past, before the landfill

21 was covered with an impermeable cap, there was

22 infiltration through the landfill of precipitation that

Page 6

1 caused groundwater contamination. To eliminate that

2 pathway, a cap, an impermeable cap, was installed over

3 the landfill.

4 As I mentioned before, it's located in an

5 undeveloped portion of ABL, and the groundwater and

6 surface water are the next media, the remaining media,

7 to be evaluated. And during our evaluation of the

8 groundwater, there were three chemicals of concern that

9 were identified: trichloroethene, which is chlorinated

10 solvent; and two inorganics, iron and manganese. For

11 surface water sediments, there were no chemicals of

12 concern identified. So again, we did take samples of

13 the surface water and sediment, which were adjacent to

14 Site 5, and the groundwater from Site 5 does discharge

15 to the river, but there are no potential risks

16 identified for human health or the environment in the

17 river or sediment immediately adjacent to Site 5.

18 So to determine what needed to be -- or what

19 needs to be completed for the groundwater at Site 5,

20 we've developed remedial action objectives, what we hope

21 to achieve by taking some action here. And it' s essentially

22 to prevent or minimize exposure of construction workers

Page 7

1 that may work the site or hypothetical future on-site

2 residents to contaminated groundwater at Site 5 -- bad

3 concentrations either exceeding MCLs, which are the

4 maximum contaminant levels allowed by EPA for drinking

5 water, or in the case of iron and manganese, to risk

6 criteria. So we're looking, really, at two receptors

7 that are potentially at risk. One are construction

8 workers that could dig into the site and become exposed

9 to the groundwater during any type of construction

10 activities that would dig deep into the site to encounter

11 the groundwater below the water table, or a resident

12 that may put in a well and use that water as a primary

13 source of potable water.

14 MS. KAGEY: I don't think they'd drink it with

15 that much iron in it.

16 MR. GLENNIE: It's probably not a likely

17 scenario, but the most conservative approaches were

18 taken on evaluating the risk. Two other objectives are

19 preventing or minimizing impacts to the adjacent river

20 and restoring the groundwater to either MCLs, where those

21 exist, and that's specifically for trichloroethene, or

22 risk-based levels, specifically for iron and manganese.

Page 8

1 So there are four alternatives that we

2 evaluated. The first of these is the No Action

3 Alternative, and as part of the CERCLA process, the No

4 Action Alternative is always included as the baseline.

5 Is doing nothing an acceptable answer, essentially?

6 Then there are three other alternatives that

7 we looked at, which I won't go into great detail unless

8 you folks are interested in hearing more, but they are

9 enhanced reductive dechlorination, which is essentially

10 promoting natural biodegradation of the constituents,

11 natural biological breakdown of the constituents.

12 MS. KAGEY: You're just talking about the

13 organics?

14 MR. GLENNIE: That would just affect the

15 organics; that's correct, and I'll talk about that in

16 just a moment. Alternative 3 is a permeable reactive

17 barrier wall, which is a wall of reactive materials,

18 and as the groundwater passes through those reactive

19 materials, the organics again are treated.

20 And then the fourth one is groundwater

21 extraction and treatment, where you are pumping the

22 water out of the ground surface, treating it at the

Page 9

1 surface, and then releasing to the river. And those

2 alternatives were evaluated because the iron and

3 manganese concentrations are only elevated immediately

4 adjacent to the landfill and just downgradient of the

5 landfill, and we think that' s due to reducing conditions

6 associated with the landfill.

7 So you've got reducing conditions from decay

8 of organic materials in the landfill, which is very

9 common adjacent to all types of municipal, other types

10 of landfills, and as you get away from the landfill,

11 we see -- in those reducing conditions, we see elevated

12 iron and manganese in the groundwater. As you get a

13 short ways away from the landfill, you see the reducing

14 conditions return to normal and the iron and manganese

15 dropping back to acceptable levels. So the conceptual

16 MS. KAGEY: Are --

17 MR. GLENNIE: I'm sorry?

18 MS. KAGEY: I'll wait.

19 MR. GLENNIE: So the conceptual idea is that

20 as the reducing conditions decrease over time, so will

21 the iron and manganese concentrations decrease, and

22 there will be monitoring in place, too, to see if

Page 10

1 that's the case.

2 MS. KAGEY: But, where are they going to go?

3 Into the river.

4 MR. GLENNIE: They'll precipitate out back

5 into the soil, so the iron and manganese are present in

6 the soil matrix.

7 MS. KAGEY: Uh-huh, right.

8 MR. GLENNIE: And when the chemical properties

9 of the groundwater change, such that they're taken from

10 a precipitated state into solution, we see them in the

11 groundwater. But as those conditions change over time,

12 as we expect them to change, then iron and manganese

13 will precipitate out into the soil. So they are only

14 risks when they're in a dissolved state in the ground-

15 water. So because of that observation, the primary

16 focus was remediating the TCE, the trichloroethene.

17 So we have the four criteria, the four

18 alternatives that we were looking at and compared them

19 against different criteria, and the first two are

20 called threshold criteria, and if you don't cross this

21 threshold, the alternative drops out and is no longer

22 considered. And that threshold is, number one,

Page 11

1 protective -- overall protection of human health and

2 the environment and compliance with applicable relevant

3 and appropriate regulations, or ARARs.

4 So if a remedy does satisfy those threshold

5 requirements, there are balancing criteria that we

6 evaluate to determine if the remedy's acceptable, and

7 those include: long-term effectiveness and permanence;

8 reduction of toxicity, mobility, or volume through

9 the treatment process; short-term effectiveness;

10 implementability; and cost. So we balance the

11 different attributes of those different criteria to

12 help select the preferred remedy. That's essentially

13 where we are now. We're going to talk about the

14 preferred remedy in just a moment.

15 Then the next step is acceptance by the

16 State -- in this case, the State of West Virginia, and

17 acceptance by the community, and that's the reason for

18 having the RAB -- I'm sorry, public meeting, and

19 issuing the PRAP and having that available for public

20 comment. So comments are received during the public

21 comment period, which actually started today, and taken

22 into consideration and based on those comments, the

Page 12

1 remedy would be changed or could be changed.

2 So again, the alternatives that I mentioned

3 earlier: No Action is number 1; Enhanced Reductive

4 Dechlorination; Permeable Reactive Barrier Wall, number

5 3; and number 4, Groundwater Extraction and Treatment,

6 and then the four here are compared against some of

7 these different criteria that I've just gone through.

8 So again, the threshold criteria here in these two

9 columns, and the no action alternative, which is number

10 1, does not meet the threshold criteria, so therefore,

11 it's not going to be considered. It's not protective

12 of human health and the environment.

13 The other three alternatives that we evaluated

14 all met the remedial action objectives, which is the

15 first column here. They're all in compliance with

16 ARARs. They're all protective of human health and the

17 environment. They have different costs and different

18 time to completion in years. So there are some other

19 balancing criteria that we looked at, but these are the

20 primary ones.

21 So we could focus on this for a minute, and

22 you can see that the longest is basically in decreasing

Page 13

1 years of completion, and enhanced reductive dechlorination

2 is 21 years. It takes the longest time to complete, at

3 $1.6 million. The permeable reactive barrier wall is

4 estimated to be completed in 16 years, at $1.3 million,

5 and then pump and treat the groundwater is estimated to

6 be completed in 7 years, at $2 million. And the cost

7 here is present worth, so it includes both the capital

8 costs, that in this case, the Navy would have to put

9 forward to implement the remedy, plus the long-term

10 costs. So 7 years, 10 years, 16 years, whatever it

11 takes until the remedy's completed. We can come back

12 to this slide if we have questions. I'm going to the

13 preferred alternative now.

14 So based on those criteria that I just

15 discussed and the other criteria that we evaluated, the

16 preferred alternative is alternative 3, which is a

17 permeable reactive barrier wall, and I'll talk a little

18 bit more about what that is, specifically, and it's

19 defined, and I'll call it PRB for short.

20 It's determined best to meet the remedial

21 action objectives and achieve the clean-up goals, or

22 it's equally acceptable to the other alternatives, 2

Page 14

1 and 4. Destroys volatile compounds in the groundwater

2 as groundwater moves passively through a barrier, so

3 the groundwater's moving under natural gradient, and

4 due to that natural gradient, will pass through the

5 location of this barrier wall and be treated. And iron

6 and manganese, as I had mentioned earlier, are expected

7 to decline over time based on changes to groundwater

8 chemistry, basically, as reducing conditions change

9 back to more stable conditions.

10 So what is a permeable reactive barrier wall?

11 Essentially, it's a trench that we dig in the ground

12 perpendicular to the groundwater flow direction, and in

13 this case, through the alluvial aquifer, which is the

14 shallow aquifer at the top of the bedrock. And then

15 within that trench, we put a reactive material which is

16 typically iron, zero-valent iron, specifically, and as

17 the groundwater moves through that iron, the chlorine

18 atoms --

19 MS. KAGEY: You're putting iron back in?

20 MR. GLENNIE: Yes. It's a good question.

21 I'll get to that in a second. So as groundwater moves

22 through that area, through that wall, chlorine atoms are

Page 15

1 removed from the volatile compounds, and eventually,

2 those are broken down to carbon dioxide and water. So

3 although iron was a risk driver, immediately downgradient

4 of the landfill, the iron in this permeable reactive

5 barrier wall does not increase -- is not expected to

6 increase the iron concentration in the groundwater.

7 So here's a conceptual model of the PRB, the

8 permeable reactive barrier wall. It's just conceptual,

9 not to scale, of course. We have a landfill here and a

10 river downgradient of that landfill, and also, in the

11 subsurface downgradient of the landfill, we have VOCs,

12 volatile organic compounds, except the TCE is the

13 primary contaminant concern in the groundwater. So the

14 alluvial aquifer against the shallow aquifer, as it

15 passes through this wall, the groundwater will be

16 remediated, so downgradient of that wall will

17 essentially have clean groundwater.

18 And this slide presents, procedurally, what

19 the next steps are in the process. So there's a

20 comment period that's open today, and it lasts 30 days,

21 through the 31st of this month, and on the fact sheet

22 that I passed out earlier, there's a place to put in

Page 16

1 comments and to mail it to the Navy's public relations

2 point person, who is Mr. Robin Willis, and whatever

3 comments would need to be postmarked by March 31st in

4 order to be considered in the decision process.

5 And there's additional information in the fact

6 sheet and also in the proposed plan that's at the two

7 public libraries. And also at the public libraries, or

8 repositories, there's back-up documentation to support

9 the PRAP. And the two local repositories for the

10 administrative record are the LaVale Public Library

11 located over the mountain in LaVale, Maryland, and

12 Fort Ashby Public Library located in Fort Ashby, West

13 Virginia. So we have some time for questions.

14 MS. KAGEY: Might as well. We're here; aren't

15 we? Okay, a couple of things. Is this the only aquifer

16 there, or is there one below it?

17 MR. GLENNIE: There's an aquifer in the bedrock

18 as well.

19 MS. KAGEY: Then how is the water in that?

20 MR. GLENNIE: There is a small area of TCE

21 contamination in the bedrock aquifer, but it's just

22 above MCLs. It's just above drinking water standards.

Page 17

1 MS. KAGEY: Phew; right?

2 MR. GLENNIE: Yes. So it is above 5, which is

3 the value, 5 parts per billion per TCE, and it's -- I

4 don't remember the specific number, but I believe it's

5 about 12 or 15 parts per billion.

6 MS. KAGEY: Okay, second question. The pump

7 and treat method, is that taking it out and bringing it

8 over to the treatment plant?

9 MR. GLENNIE: It's actually not. Surprisingly

10 enough, the groundwater concentrations, the TCE

11 concentrations --

12 MS. KAGEY: Are not high enough.

13 MR. GLENNIE: -- are low enough in the

14 alluvial aquifer that we could pump it out to the

15 ground surface --

16 MS. KAGEY: Aerate it?

17 MR. GLENNIE: -- and channel it through the

18 riprap channel to the river, and just through that

19 physical process of the groundwater --

20 MS. KAGEY: Put it into the air.

21 MR. GLENNIE: -- it would transfer into the

22 air. It's not a destructive treatment.

Page 18

1 MS. KAGEY: You get rid of it, though.

2 MR. GLENNIE: It's transferring from one media

3 to another, and that is acceptable, per the ARARs, but

4 not our preferred remedy. Our preferred remedy does

5 actually break the contaminants down into carbon

6 dioxide and water, so that's another benefit of this

7 remedy over pump and treat.

8 MS. KAGEY: One more question.

9 MR. GLENNIE: Okay.

10 MS. KAGEY: Okay, you have all this iron and

11 all this manganese in this groundwater that you say

12 goes into the Potomac. How come they don't find it in

13 the sediment?

14 MR. GLENNIE: Good question. I did not say

15 that it would go into the Potomac, though, just one

16 clarification.

17 MS. KAGEY: The picture shows it going in.

18 MR. GLENNIE: The groundwater does go into the

19 Potomac --

20 MS. KAGEY: Yes.

21 MR. GLENNIE: – but the elevated iron and

22 manganese that we see is immediately adjacent. On

Page 19

1 this conceptual diagram, it is showing the VOCs that

2 would eventually discharge into the Potomac here, but

3 the elevated iron and manganese, we're only seeing

4 immediately adjacent to the landfill. So we don't

5 see --

6 MS. KAGEY: In the groundwater?

7 MR. GLENNIE: In the groundwater. So the

8 elevated iron and manganese is in the groundwater --

9 sorry -- adjacent to the landfill, so what we believe

10 is happening is that we have reducing conditions in the

11 subsurface alluvial aquifer that's causing the iron and

12 manganese to come out of the soil matrix and into a

13 dissolved state in the groundwater, but as you move

14 away from that, but before you get to the river, those

15 reducing conditions change back to natural conditions.

16 The iron and manganese precipitate out solution, and

17 therefore, we don't see elevated iron and manganese.

18 MS. KAGEY: Did you test for arsenic or

19 anything else that is naturally occurring in the soil?

20 MR. GLENNIE: We did test for arsenic. I

21 don't remember the specific concentrations, but it did

22 not show up as a human health risk, an unacceptable

Page 20

1 risk.

2 MS. KAGEY: Do you have DNAPLs in the soil

3 above the groundwater?

4 MR. GLENNIE: We've not identified any DNAPLs.

5 Again, the concentrations --

6 MS. KAGEY: Are so low?

7 MR. GLENNIE: – in the groundwater, yeah,

8 they're much lower than we see in other areas,

9 specifically, at Site 1, where we have much, much

10 higher concentrations.

11 MS. KAGEY: Where they put them there.

12 MR. GLENNIE: Yeah. So the concentrations

13 here are such that, as I said before, you could

14 literally break the ground surface, and they would

15 volatize out through mechanical means. So we don't

16 think that there is any DNAPLs present.

17 MR. BASS: Supposedly, it's from the drum

18 disposals within the landfill.

19 MS. KAGEY: Now this is old? Is the landfill

20 lined underneath?

21 MR. BASS: No.

22 MS. KAGEY: I mean I can't remember going back

Page 21

1 to --

2 MR. BASS: No.

3 MS. KAGEY: So there's just a cap on it?

4 MR. BASS: That's correct, subtitle C cap.

5 MS. KAGEY: Uh-huh.

6 MR. GLENNIE: So there were drums disposed of

7 in the landfill, and those presumably leaked TCE.

8 Whether there's a continuing source from those, I think

9 is unknown.

10 MS. KAGEY: Well, if it's not too high, then

11 they're probably not. Well, they seem to be going down

12 over time.

13 MR. GLENNIE: Actually, the VOC concentrations

14 are fairly stable over time, but they're not as

15 elevated as we've seen at other sites.

16 MS. KAGEY: Yeah, not as many commas. What's

17 the maintenance of this barrier that you put in?

18 MR. GLENNIE: Very little to none, so

19 essentially, once the barrier's in place, we'll have

20 monitoring downgradient of the barrier to insure that

21 it's effective, but there is no specific maintenance

22 required of the barrier. I believe within the expected

Page 22

1 life cycle, 16 years, that the barrier will remain

2 active. If we did see TCE concentrations increase, you3 know, we would suspect that there was a break through

4 the barrier, and we would have to rejuvenate it, but

5 there's no maintenance required, and it's another

6 benefit over a pump and treat system where you've got

7 much more mechanical and operation and maintenance

8 requirements.

9 Any other questions? Well, thank you, and

10 please feel free to comment on PRAP. That ends our

11 public meeting.

12 (Whereupon the meeting was concluded at 6:07

13 p.m.)

14 * * * * *

15

16

17

18

19

20

21

22

Page 23

1 STATE OF MARYLAND, SS:

2 COUNTY OF GARRETT, to-wit:

3 I, Christina D. Pratt, a Notary Public of

4 the State of Maryland, do hereby certify that I

5 recorded the Proceedings of the Public Meeting held

6 March 1, 2005, and this transcript is a true record of

7 those proceedings.

8 Given under my hand and Notarial Seal this

9 3rd day of March, 2005.

10

11

12

13 My commission expires:

14 November 1, 2008

15

16

17

18

19

20

21

22

Appendix B Applicable or Relevant and Appropriate

Requirements

APPENDIX B TABLE B-1 Chemical-Specific Applicable or Relevant and Appropriate Requirements OU 02 Record of Decision Site 5, Allegany Ballistics Laboratory Rocket Center, West Virginia

APPENDIX B: TABLE B-1 1

Chemicals & Relevant

Media Requirement Prerequisites Citation ARAR or TBC Comments Groundwater, residential water supplies

Meet National Primary Standards for MCLs. Drinking water source or potential source.

SDWA: 40 CFR 141 National Primary Drinking Water Regulations

Relevant and Appropriate MCL used as TCE PRG.

Groundwater standards

Standards may be more restrictive than the maximum contaminant levels where it finds that such standards are necessary to protect drinking water use where scientifically supportable evidence reflects factors unique to West Virginia or some area thereof, or to protect other beneficial uses of the groundwater. For contaminants not regulated by the federal SDWA, standards for such contaminants shall be established to be no less stringent than may be reasonable and prudent to protect drinking water or any other beneficial use.

None West Virginia Code §22-12-4

CCLeachate Management

Any liquid, which comes in contact with waste or accumulates in a portion of the facility where active waste disposal operations are occurring, must be handled as leachate and properly treated.

None. 33 CSR 1-4.8 Applicable During construction of the PRB, dewatering may be necessary and the groundwater will require proper management.

Alternative Groundwater Protection Standards

An alternative groundwater protection standard may be considered in consultation with the environmental water quality board for constituents for which water quality standards have not been established.

None. Groundwater Quality Standard Variances 47 CSR 57; 33 CSR 1-4.11

Applicable The selected remedial action will improve the groundwater quality at the site.

Waste Disposal

No person may dispose in the state of any solid waste in a manner which endangers the environment or the public health, safety or welfare as determined by the director:

None. West Virginia Code §22-15-10e

Applicable This regulation is applicable for remedial actions that may affect waste disposal in the State of West Virginia.

Surface waters of the State

Protect and maintain the quality of surface water in the State of Maryland. Criteria and standards for discharges. Limitations and policy for anti-degradation of the State's surface water.

Activities that will pollute the State's surface waters

COMAR 26.08.01 through 26.08.07

Potentially Applicable This regulation is applicable for remedial actions that may affect surface water quality in the North Branch Potomac River, State of Maryland. This state law would apply to the extend that it is more stringent than the federal standard.

Surface water Water-quality standards and restrictions on direct discharges to water. Activities that affect or may affect the surface water onsite

40 CFR 122 Applicable Used in the development of groundwater PRGs. These regulations apply to remedial actions that may affect surface water quality in the North Branch Potomac River, State of Maryland.

Carcinogens in groundwater

Not to exceed media-specific concentration that causes a lifetime cancer risk not to exceed 1 in 10,000

Potential exposure RAGS TBC

Carcinogens in groundwater

For known or suspected carcinogens, acceptable exposure levels are generally concentration levels that represent an excess upper bound lifetime cancer risk to an individual of between 10-4 and 10-6 using information on the relationship between dose and response.

Potential exposure 40 CFR 300.430 (e)(2)(i)(A)(2)

Applicable Used to calculate site-specific PRGs for groundwater.

APPENDIX B TABLE B-1 Chemical-Specific Applicable or Relevant and Appropriate Requirements OU 02 Record of Decision Site 5, Allegany Ballistics Laboratory Rocket Center, West Virginia


Chemicals & Relevant

Media Requirement Prerequisites Citation ARAR or TBC Comments Systemic toxicants in groundwater

Not to exceed media-specific levels where people could be exposed by direct ingestion or inhalation on a daily basis without appreciable risk of deleterious effects.

Potential exposure 40 CFR 300.430 (e)(2)(i)(A)(1)

Applicable Used to calculate site-specific PRGs for groundwater.

Air It is unlawful for any person to cause a statutory air pollution, to violate the provisions of this article, to violate any rules promulgated pursuant to this article to operate any facility subject to the permit requirements of the director without a valid permit.

None. West Virginia Code §22-5-3 Applicable Causing statutory pollution unlawful; article not to provide persons with additional legal remedies.

CAA – Clean Air Act CERCLA – Comprehensive Environmental Response, Compensation, and Liability Act CFR – Code of Federal Regulations COMAR – Code of Maryland Regulations CSR – Code of State Regulations CWA – Clean Water Act MCL – Maximum contaminant level

NPDES - National Pollutant Discharge Elimination System PRB – permeable reactive barrier PRG – preliminary remediation goal RAGS–Risk Assessment Guidance for Superfund RCRA - Resource Conservation and Recovery Act SDWA - Safe Drinking Water Act TBC - To be considered TCE - trichloroethene

APPENDIX B TABLE B-2 Location-Specific Applicable or Relevant and Appropriate Requirements OU 02 Record of Decision Site 5, Allegany Ballistics Laboratory Rocket Center, West Virginia


Location Requirement Prerequisite Citation ARAR or TBC Comments

Federal Location-Specific ARARs Fish and Wildlife Coordination Act, Fish and Wildlife Improvement Act of 1978, Fish and Wildlife Conservation Act of 1980

Area affecting streams or other water bodies

Provides protection from actions that would affect streams, wetlands, other water bodies or protected habitats. Any action taken should protect fish or wildlife.

Diversion, channeling or other activity that modifies a stream or other water body and affects fish or wildlife.

16 USC 662; 16 USC 2901;

Applicable

Response actions will incorporate protection for any area water body, wetlands, or protected habitats.

Resource Conservation and Recovery Act (RCRA) Within 100-year Floodplain

Facility must be designed, constructed, operated, and maintained to avoid washout.

RCRA hazardous waste; treatment, storage, or disposal of hazardous waste.

40 CFR 264.18 (b)

Relevant and Appropriate Portions of the site are within the flood plain. However, actions are not expected to involve hazardous waste.

Executive Order 11988, Protection of Floodplains Within floodplain

Actions taken should avoid adverse effects, minimize potential harm, restore and preserve natural and beneficial values.

Action that will occur in a Floodplain (i.e., lowlands, and relatively flat areas adjoining inland and coastal waters and other flood-prone areas).

40 CFR 6, Appendix A; excluding Sections 6(a)(2), 6(a)(4), 6(a)(6); 40 CFR 6.302

Applicable Portions of the site are within the flood plain. Therefore the requirements of this regulation are applicable for any response actions that might involve the use of these areas.

Maryland State Location-Specific ARARs Water Pollution Control Law Waters of the State

Establishes effective programs and provides additional and cumulative remedies to prevent, abate, and control pollution of the waters in the state.

Activities that will pollute the waters in the state.

COMAR 26.08.01 thru .07

Potentially Applicable

This regulation is applicable for remedial actions that may affect water quality in local streams.

Water resources of the State

Provides for the conservation and protection of the water resources of the State by requiring that any land-clearing, grading, or other earth disturbances require an erosion- and sediment-control plan. Also provides that stormwater must be managed to prevent offsite sedimentation and maintain current site conditions.

Activities that affect the water resources of the State.

COMAR 26.17.01.05 and COMAR 26.17.02.05

Applicable

The design for the remedial action will incorporate the requirements of this regulation.

West Virginia State Location-Specific ARARs Groundwater Protection Standards for Industrial Establishments

Groundwater monitoring stations shall be located and constructed in a manner that allows accurate determination of groundwater quality and levels, and prevents contamination of groundwater through the finished well hole or casing. All groundwater monitoring stations shall be accurately located utilizing latitude and longitude by surveying, or other acceptable means, and coordinates shall be included with all data collected.

Groundwater monitoring must be completed upon order of the Director.

47 CSR 58-4.9. Relevant and Appropriate Groundwater monitoring will be part of the long-term monitoring program for the PRB.

Groundwater Protection standards for Industrial Establishments

Each industrial establishment shall have a comprehensive groundwater protection plan including inventory of all operations that may reasonably be expected to contaminate the groundwater resources and procedures designed to protect groundwater, a summary of all activities carried out under other regulatory programs that have relevance to groundwater protection, a discussion of all available information reasonably available to the facility/activity regarding existing groundwater quality and provisions for employee training and quarterly inspections

None. 47 CSR 58-4.11 Relevant and Appropriate This relevant and appropriate requirement can be met with the Long Term Monitoring Plan

APPENDIX B TABLE B-2 Location-Specific Applicable or Relevant and Appropriate Requirements OU 02 Record of Decision Site 5, Allegany Ballistics Laboratory Rocket Center, West Virginia


Location Requirement Prerequisite Citation ARAR or TBC Comments Groundwater Facility or activity design must adequately address the issues

arising from locating in karst, wetlands, faults, subsidence, delineated wellhead protection areas determined vulnerable.

Sensitive natural resource or geologic areas

47 CSR 58-4.10 Applicable The design and location of the PRB will incorporate the requirements of this regulation.

ABL – Allegany Ballistics Laboratory ARAR – Applicable or relevant and appropriate requirement CFR – Code of Federal Regulations COMAR – Code of Maryland Regulations

HWCA – Hazardous Waste Control Act RCRA – Resource Conservation and Recovery Act TBC – To be considered USC – United States Code

APPENDIX B TABLE B-3 Action-Specific Applicable or Relevant and Appropriate Requirements OU 02 Record of Decision Site 5, Allegany Ballistics Laboratory Rocket Center, West Virginia


Action Requirement Prerequisite Citation Determination Comments Federal Action-Specific ARARs

Resource Conservation and Recovery Act, 42 USC 6901 et seq.* Onsite waste generation

Waste generator shall determine if waste is hazardous waste.

Generator of hazardous waste. 40 CFR 262.11

Applicable

Applicable for any operation where waste is generated. Remedial alternatives for the site may generate hazardous wastes.

Hazardous waste accumulation

Generator may accumulate waste on site for 90 days or less or must comply with requirements for operating a storage facility.

Accumulate hazardous waste.

40 CFR 262.34


If waste generated at ABL is determined to be hazardous, any storage of the hazardous waste will not exceed 90 days. Accumulation of hazardous wastes onsite for longer than 90 days would be subject to the substantive RCRA requirements for storage facilities.

Excavation

Movement of excavated materials to new location and placement in or on land will trigger land disposal restrictions for the excavated waste or closure requirements for the unit in which the waste is being placed.

Materials containing RCRA hazardous wastes subject to land disposal restrictions are placed in another unit.

40 CFR 268.40


Applicable to disposal of soil to a new location and placement in or on land containing land-disposal-restricted RCRA hazardous waste. The wastes generated from response actions are not anticipated to be hazardous. However, soils will be sampled to characterize the waste profile.

Maryland State Action-Specific ARARs Air Quality Actions that involve Emissions to air

Provides ambient air quality standards, general emissions standards, and restrictions for air emissions from construction activities, vents, and treatment technologies such as incinerators. Also includes nuisance and odor control. Construction activities may emit particulate matter into the ambient air. Remedial activities must follow regulations.

Actions that involve emissions to air above specific limits.

COMAR 26.11.04.04

Applicable May apply to the emissions of contaminants to the air via construction activities. Actions will be taken to control dust emissions during construction. On-site monitoring will take place during construction and operation of the PRB.

West Virginia State Action-Specific ARARs

Air Pollution Control Act and the Hazardous Waste Management Act Release of emissions of hazardous waste constituents

Provides requirements for the facility design, construction, maintenance, and operation to minimize the release of hazardous waste constituents to the air.

Applies to all owners and operators of hazardous waste storage, treatment, or disposal facilities.

45 CSR 25-4.3 Relevant and Appropriate It is not anticipated that hazardous constituents will be released into the air during the construction and operation of the PRB.

Air Pollution Control Act Release of fugitive or toxic air pollutants

Adopts by reference Table 25-A of the CFR. Applies to all owners and operators of hazardous waste storage, treatment, or disposal facilities.

45 CSR 25-3.2 Relevant and Appropriate Actions will be taken to keep dust down during construction of the PRB.


APPENDIX B: TAB 6

Action Requirement Prerequisite Citation Determination

LE B-3

Comments Federal Action-Specific ARARs

Adoption of Best Available Technology requirements for the discharge of emissions of Toxic Air Pollutants

For the prevention and control of the discharge of toxic air pollutants requiring the application of best available technology from a "Chemical Processing Unit" meaning an assembly of reactors, tanks, distillation columns, heat exchangers, vaporizers, compressors, dryers, decanters, and/or other equipment used to treat, store, manufacture, or use toxic air pollutants.

45 CSR 27-3 Potentially Applicable May apply to the emissions of contaminants to the air via construction activities. Actions will be taken to control dust emissions during construction. On-site monitoring will take place during construction and operation of the PRB.

Adoption of Best Available Technology requirements for the discharge of Fugitive Emissions of Toxic Air Pollutants

For the prevention and control of the discharge of toxic air pollutants requiring the application of best available technology from a "Chemical Processing Unit" meaning an assembly of reactors, tanks, distillation columns, heat exchangers, vaporizers, compressors, dryers, decanters, and/or other equipment used to treat, store, manufacture, or use toxic air pollutants.

45 CSR 27-4 Applicable

Groundwater Pollution Control Act Achieve standards for purity and quality for groundwater in the State

Except as provided in Sections 3.2 and 3.3, the standards of purity and quality for groundwater in the state shall be the constituent concentrations found in Appendix A.

46 CSR 12-3.1 to 3.3 Applicable Protection of groundwater quality Establishing acceptable constituent criteria

Constituents in groundwater shall not cause a violation of the standards found at 46 CSR Series I in any surface water

None. 46 CSR 12-3.3 Applicable

Installation of groundwater well

Subsurface borings shall be constructed, operated and closed in a manner that protects groundwater

None. 47 CSR 58-4.2 Potentially Applicable

Construction of groundwater wells and associated storage/treatment facilities

New areas used for storage shall be designed, constructed and operated to prevent release of contaminants. Groundwater monitoring stations may be necessary to assure protection of the groundwater resource.

None. 47 CSR 58-4.3.b Potentially Relevant and Appropriate

Loading and unloading stations including but not limited to drums, trucks and railcars shall have spill prevention and control facilities and procedures as well as secondary containment.

None. 47 CSR 58-4.4.a Potentially Relevant and Appropriate

Requirements for secondary containment for sumps and above ground tanks.

None. 47 CSR 58-4.8 Not Applicable



Action Requirement Prerequisite Citation Determination Comments Federal Action-Specific ARARs

Groundwater monitoring stations shall be located and constructed in a manner that allows accurate determination of groundwater quality and levels, and prevents contamination of groundwater through the finished well hole or casing. All groundwater monitoring stations shall be accurately located utilizing latitude and longitude by surveying, or other acceptable means, and coordinates shall be included with all data collected.

None. 47 CSR 58-4.79.c to 4.9.g Potentially Applicable


Rule governing the certification of monitoring well drillers and monitoring well installations and alterations.

Well installation. 47 CSR 59-4.1 to 4.7 Potentially Applicable


Requirements and procedures governing the installation and development and/or redevelopment and reconditioning or abandonment of temporary or permanent monitoring well(s), piezometer(s), recovery well(s), well(s), and boreholes.

Boring installation. 4 7CSR 60-5 to 22 Applicable

Establishment of industrial activities with the potential to contaminate groundwater

Each industrial establishment shall have a comprehensive groundwater protection plan including inventory of all operations that may reasonably be expected to contaminate the groundwater resources and procedures designed to protect groundwater, a summary of all activities carried out under other regulatory programs that have relevance to groundwater protection, a discussion of all available information reasonably available to the facility/activity regarding existing groundwater quality and provisions for employee training and quarterly inspections

None. 47 CSR 58-4.11 Relevant and Appropriate

Clean up actions shall be permanent and shall not rely primarily on dilution and dispersion if active remedial measures are technically and economically feasible.

None. 47 CSR 58-8.1.a to 8.1.c Relevant and Appropriate Groundwater Remediation

Facility or activity design must adequately address the issues arising from locating in karst, wetlands, faults, subsidence, delineated wellhead protection areas determined vulnerable.

Sensitive natural resource or geologic areas.

47 CSR 58-4.10 Applicable

ABL – Allegany Ballistics Laboratory CFR – Code of Federal Regulations COMAR – Code of Maryland Regulations CSR – Code of State Regulations

PRB – Permeable Reactive Barrier RCRA - Resource Conservation and Recovery Act USC – United States Code

Documents

RECORD OF DECISION (RODS) - Records Collections · IRP—Installation Restoration Program: The term used to describe the Navy’s environmental restoration program. LTM ... Public