RECORD OF DECISION

FT-03, Fire Training Area 2 Andrews Air Force Base, Maryland

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••• United States• Air Force

United States Environmental Protection Agency Region III

FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

TABLE OF CONTENTS

1.0 DECLARATION ...... 1 1.1 Site Name and Location ...... 1 1.2 Statement of Basis and Purpose ...... 1 1.3 Assessment of the Site...... 1 1.4 Description of the Selected Remedy ...... 1 1.5 Statutory Determinations ...... 4 1.6 ROD Data Certification Checklist...... 5 1.7 Authorizing Signatures ...... 5

2.0 DECISION SUMMARY...... 6 2.1 Site Name, Location, and Description ...... 6 2.2 Site History, Enforcement Activities, and Investigations ...... 6 2.2.1 Site History ...... 6 2.2.2 Previous Investigations...... 7 2.2.3 Focused Feasibility Study (2007)...... 10 2.2.4 Enforcement Activities ...... 10 2.3 Community Participation...... 11 2.4 Scope and Role of Response Action ...... 11 2.5 Site Characteristics...... 12 2.5.1 Physical Setting ...... 12 2.5.2 Conceptual Site Model...... 13 2.5.3 Nature and Extent of Contamination...... 14 2.6 Current and Potential Future Land and Water Uses...... 17 2.7 Summary of Site Risks ...... 18 2.7.1 Baseline Human Health Risk Assessment Process...... 18 2.7.2 Baseline Human Health Risk Assessment Results—General...... 21 2.7.3 Baseline Human Health Risk Assessment Results—Soil ...... 22 2.7.4 Baseline Human Health Risk Assessment Results—Groundwater...... 22 2.7.5 Uncertainty Associated with HHRA for Soil and Groundwater...... 23 2.7.6 Ecological Risk Assessment...... 23 2.7.7 Conclusions of Risk Assessment and Basis for Action...... 23 2.8 Remedial Action Objectives...... 24 2.9 Description of Remedial Alternatives for Soil and Groundwater ...... 24 2.9.1 Alternative 1: No Action ...... 24 2.9.2 Alternative 2: Institutional Controls ...... 25 2.9.3 Alternative 3: Institutional Controls with Monitoring ...... 25 2.9.4 Alternative 4: Excavation and Off-Site Disposal of Contaminated Soil and Institutional Controls with Monitoring ...... 26 2.9.5 Alternative 5: In-Situ Chemical Oxidation and Institutional Controls with Monitoring...... 27 2.9.6 Common Elements and Distinguishing Features of Each Alternative.... 28

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2.9.7 Expected Outcomes of Each Alternative ...... 29 2.10 Summary of Comparative Analysis of Alternatives...... 29 2.10.1 Threshold Criteria ...... 30 2.10.2 Balancing Criteria ...... 30 2.10.3 Modifying Criteria...... 31 2.11 Principal Threat Wastes ...... 31 2.12 Selected Remedy for Soil and Groundwater...... 32 2.12.1 Rationale for the Selected Remedy ...... 32 2.12.2 Detailed Description of the Selected Remedy ...... 33 2.12.3 Summary of the Estimated Remedy Costs ...... 36 2.12.4 Estimated Outcomes of Selected Remedy ...... 37 2.13 Statutory Determinations for Groundwater Remedy...... 37 2.13.1 Protection of Human Health and the Environment...... 38 2.13.2 Compliance with ARARs...... 38 2.13.3 Cost Effectiveness...... 38 2.13.4 Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery) Technologies to the Maximum Extent Practicable 39 2.13.5 Five-Year Review Requirements ...... 39 2.14 Documentation of Significant Changes...... 39

3.0 RESPONSIVENESS SUMMARY...... 40 3.1 Overview ...... 40 3.2 Background on Community Involvement ...... 40 3.3 Summary of Comments Received During the Public Comment Period and Air Force Responses ...... 41

4.0 REFERENCES...... 43

FIGURES

2-1 Andrews Air Force Base and Vicinity Map 2-2 Location of FT-03 Within Andrews AFB 2-3 1960 Aerial Photograph Showing Former Fire Training Area Near Central Portion of FT-03 2-4 Aerial Photograph, Year 2008 Golf Course 2-5 Soil Sampling Locations and Areas of Soil Contamination 2-6 Groundwater Sampling Locations with Detected Concentrations (µg/L) Driving Potential Risk 2-7 Conceptual Site Model Diagram Prior to the Human Health Risk Assessment 2-8 Boundary of Institutional Controls Implementation

Page ii FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

TABLES

2-1 Summary of Receptor Cancer Risks Exceeding 1 x 10-4, Unrestricted Use Scenario 2-2 Summary of Receptor Non-Cancer Hazard Indexes (HI) Exceeding 1, Unrestricted Use Scenario 2-3 Summary of Detected COCs with Associated Locations at FT-03 2-4 Cost Comparison for Remedial Alternatives 2-5 Comparative Analysis of NCP Evaluation Criteria for the FT-03 Remedial Alternatives 2-6 Cost Summary—Alternative 3, Institutional Controls with Monitoring

APPENDICES

Appendix A Maryland Department of the Environment Concurrence Letter Appendix B Public Meeting Newspaper Notices Appendix C Summary Transcript of the Public Meeting for the Proposed Remedial Action Plan – FT-03 Site, February 21, 2008

Page iii FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

ACRONYMS and ABBREVIATIONS

AFB Air Force Base ARAR Applicable or Relevant and Appropriate Requirement

BEHP Bis(2-ethylhexyl)phthalate BTEX Benzene, toluene, ethylbenzene, xylenes

CD-ROM Compact disc-read only memory CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC Contaminant of concern COMAR Code of Maryland Regulations COPC Contaminant of potential concern CSF Cancer slope factor CSM Conceptual site model

D.C. District of Columbia DCE Dichloroethene DP Direct push

ER Environmental restoration ERA Ecological Risk Assessment

FFS Focused Feasibility Study FT-03 Fire Training Area 2

GIS Geographic Information System gpm Gallons per minute

HHRA Human Health Risk Assessment HI Hazard index HQ Hazard quotient

IC Institutional control ISCO In-situ chemical oxidation

MCL Maximum Contaminant Level MD Maryland MDE Maryland Department of the Environment mg/kg Milligram per kilogram MOGAS Motor vehicle gasoline MW Monitoring well

Page iv FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

NCP National Oil and Hazardous Substances Pollution Contingency Plan (commonly referred to as the National Contingency Plan) NPL National Priorities List ng/kg Nanogram per kilogram

O&M Operation and maintenance

PAH Polynuclear aromatic hydrocarbons PA/SI Preliminary Assessment/Site Investigation PCB Polychlorinated biphenyl PID/FID Photoionization detector/flame ionization detector PRAP Proposed Remedial Action Plan

RAO Remedial Action Objective RBC Risk-based criteria RfD Reference dose RI Remedial Investigation RME Reasonable maximum exposure ROD Record of Decision

§ Section SARA Superfund Amendments and Reauthorization Act SVOC Semivolatile organic compound

TCDD 2,3,7,8-tetrachlorodibenzo-p-dioxin TEQ Toxicity Equivalent Quotient TPH Total petroleum hydrocarbon

µg/kg Microgram per kilogram µg/L Microgram per liter USAF United States Air Force U.S.C United States Code USDA United States Department of Agriculture USEPA United States Environmental Protection Agency

VOC Volatile organic compound

WSSC Washington Suburban Sanitary Commission

Page v FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

1.0 DECLARATION 1.1 Site Name and Location Site FT-03 Andrews Air Force Base, Maryland EPA Superfund Site ID No. MD0570024000

1.2 Statement of Basis and Purpose

This Record of Decision (ROD) presents the selected remedy for Fire Training Area 2 (FT-03 or “the site”), located at Andrews Air Force Base (AFB), in Prince George’s County, Maryland. The remedy was chosen in accordance with the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act (SARA), and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). Andrews AFB was listed on the National Priorities List (NPL) by the United States Environmental Protection Agency (USEPA) on May 10, 1999 (64 Fed. Reg. 24949).

The United States Air Force (USAF) and USEPA have selected the remedy for FT-03 based on information contained in the Administrative Record file for the site. The Maryland Department of the Environment (MDE) concurs with the selected remedy. A letter from MDE indicating its concurrence is provided in Appendix A.

1.3 Assessment of the Site

The response action selected in this ROD is necessary to protect the public health and the environment from actual or threatened releases of pollutants or contaminants of concern (COCs) from the site. The COCs at the site originate from primarily the flammable liquids such as jet fuel and solvents that were reportedly poured on the ground surface and ignited prior to fire training activities from 1959 to 1972. Under the current and reasonably foreseeable land use (recreational), the site poses no unacceptable risk. Contaminants in groundwater do not exceed USEPA maximum contaminant levels (MCLs). However, if in the future the site was converted to residential use, there could be a risk to residents from exposure to shallow groundwater and vadose-zone soils.

1.4 Description of the Selected Remedy

The remedy selected for FT-03 is institutional controls (ICs) with groundwater monitoring. Of the five alternatives analyzed as potential remedies for contamination at FT-03, this remedy is the alternative best suited to address contamination, based on FT-03 site conditions and reasonably anticipated future land use as a golf course. FT-03 lies beneath the 14th, 15th, 16th, and 17th holes of the Base South Golf Course.

The major components of the selected remedy, Alternative 3, are ICs and monitoring. The objectives of the ICs at FT-03 are to ensure that:

• Groundwater is not used as drinking water;

Page 1 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

• Additional groundwater monitoring wells are installed to adequately monitor groundwater contamination; • Groundwater data is collected over time to establish trends of COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) and assess whether additional actions are necessary; • Groundwater monitoring data is evaluated to potentially target select areas within FT­ 03 for active treatment, if an increase in COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) concentrations occurs, or if natural degradation is not sufficient to reduce COCs; • Construction activities on-base do not interfere with required monitoring; • Construction workers are protected during any future construction activities at the site; • The site is not used for residential use unless site conditions change to allow for unlimited use and unrestricted exposure (the site will be maintained as a golf course); • Any proposed changes from current land use (i.e., golf course) will be evaluated to ensure that the risk presented by the new land use is not unacceptable; • Any intrusive work is conducted in a safe manner to ensure that workers are protected from exposure to groundwater or vapors that may present an unacceptable risk; and • Any impacted groundwater extracted for monitoring purposes that exceeds relevant regulatory criteria is appropriately handled.

The components of the groundwater monitoring program to be implemented at FT-03 are:

• Semi-Annual Sampling for the first two years of groundwater monitoring; • Annual Sampling during years three, four, and five of the first five-year cycle (three sampling events total); • Statistical Analysis of Monitoring Data (by using a Mann-Kendall test and trend analysis) to assess trends in naphthalene, benzo[a]pyrene, chromium, and arsenic concentrations. The monitoring frequency may need to be increased if a rebound in the COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) is observed to provide sufficient information for a protectiveness determination in the next five-year review; and • Five-Year Reviews to confirm the concentration or absence of COCs at the FT-03 site and to determine if human health and the environment are continuing to be protected by the remedy. The data gathered will also be used to evaluate the long-term monitoring program and to determine if the groundwater monitoring program should be increased, decreased, or remain unaltered for another five-year review cycle; or if more active/aggressive remedial action is needed to achieve unlimited use and unrestricted exposure for groundwater only. The data collected for the long-term monitoring program will be analyzed and relied upon to support proposed changes to the monitoring frequency. After the first five years following implementation of the remedy, the

Page 2 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

groundwater monitoring program will continue at five-year intervals until concentrations of COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) have decreased sufficiently to allow for unlimited use and unrestricted exposure. Six five-year reviews were included for purposes of estimating remedial costs. Based on the evaluation of alternatives, Alternative 3 is chosen as the remedy for FT-03 because it will protect human health and the environment, comply with applicable or relevant and appropriate requirements (ARARs), and be cost effective. There is currently no use of shallow groundwater in the area or anywhere on Andrews AFB, and future use of shallow groundwater at the site as a potable source is highly unlikely because potable water at Andrews AFB is provided by the Washington Suburban Sanitary Commission (WSSC). Moreover, drilling of wells for drinking water is forbidden by Maryland law when public water is available. Existing data shows that the migration of contaminants via groundwater from the site is, and will continue to be, limited, and any potential contaminant plume will likely be stationary or very slow moving. Additionally, ICs required by this remedy will prevent the potable use of shallow groundwater and limit dermal contact with shallow groundwater as long as COC concentrations are above established concentrations. If COC concentrations are shown through monitoring and statistical analysis to be below the calculated site-specific risk-based concentrations, a human health risk assessment could be conducted to determine if the groundwater still poses unacceptable risks.

During the implementation of Alternative 3, the analytical data collected through the installation of additional groundwater monitoring wells and the data collected during the groundwater monitoring program will be statistically evaluated (using a Mann-Kendall test and trend analysis) to assess if the concentrations in groundwater allow for unlimited use and unrestricted exposure. If an increase in the concentrations of COCs is observed during the monitoring program, an assessment will be performed to decide whether maintaining or increasing the frequency of groundwater monitoring is appropriate or if treatment is necessary, in which case a feasibility study would be developed. Five­ year reviews will be required to ensure that the remedy is still protective and that ICs are being maintained. In addition, data used for the five-year reviews will be used to support any proposed changes to the monitoring frequency or if active treatment is required for groundwater. In the latter case, a feasibility study would be prepared. A proposed plan for an amendment to this ROD would then be made available to the public for comment because treatment would be a fundamental change from this selected remedy.

The selected remedy will meet the threshold criteria of protecting human health and the environment and complying with ARARs, and provides the best balance compared with the other alternatives with respect to the balancing and modifying criteria (see Section 2.10 for a discussion of these criteria). The USAF and USEPA expect the selected remedy to satisfy the following statutory requirements of CERCLA Section 121, 42 U.S.C. § 9621: (1) be protective of human health and the environment; (2) comply with ARARs; and (3) be cost effective. The selected remedy does not fulfill the statutory preference for treatment because undertaking treatment would not be cost effective. Implementation of ICs to protect human health from site COCs and groundwater monitoring to track the effectiveness of volatilization, biodegradation, and geochemical processes (adsorption, precipitation) to decrease the concentrations of the COCs in groundwater at the site is

Page 3 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008 far more cost effective in light of the present and reasonably anticipated future land use (as a golf course) at FT-03.

The selected remedy addresses soil and groundwater contamination at FT-03 and fits into the overall strategy to investigate and address the 33 Environmental Restoration (ER) Program sites at Andrews AFB. This remedy is selected jointly by the USAF and the USEPA, in coordination with MDE. The remedial actions selected in this ROD will be performed by the USAF, under the authority of CERCLA as delegated to the USAF as lead agency by Executive Order 12580.

1.5 Statutory Determinations

The selected remedy is protective of human health and the environment, complies with Federal and State ARARs, and is cost effective. However, the remedy does not utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable, as preferred pursuant to CERCLA Section 121(b)(1), because the cost to treat the COCs would render the remedy cost ineffective, given the current and projected future land use of the site as a golf course. To ensure that there is no human exposure to COCs remaining in soil and groundwater, ICs will be implemented. The companion groundwater monitoring program will track COC concentrations (naphthalene, benzo[a]pyrene, chromium, and arsenic) in groundwater until site conditions allow for unlimited use and unrestricted exposure to groundwater only. A more aggressive treatment approach may be initiated at the site if concentrations of COCs in groundwater do not continue to decline over time, or if they increase. Because the selected remedy allows for hazardous substances to remain in soil and groundwater on site above levels that allow for unlimited use and unrestricted exposure, reviews to ensure that the remedy remains protective of human health and the environment will be conducted at five-year intervals in accordance with CERCLA Section 121 (c). Six five-year reviews were included for purposes of estimating remedial costs.

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1.6 ROD Data Certification Checklist

The Decision Summary section of this ROD includes a description of the site and a summary of the investigations conducted at the site; more detailed information can be found in the Administrative Record file for FT-03. The USAF certifies that this ROD contains specific information on:

• COCs present at the site and their respective concentrations (Sections 2.5.3 and 2.7); • Baseline risk represented by all COCs (Sections 2.7.3 and 2.7.4); • 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 (Section 2.6); • Potential land and groundwater use that will be available at the site as a result of the selected remedy (Section 2.12.4); • Estimated capital, annual operation and maintenance (O&M), and total present worth costs, discount rate and the number of years over which the remedy cost estimates are projected (Section 2.12.3); • Key factor(s) that led to selecting the remedy (Section 2.12.1); and • How source materials constituting principal threats have been addressed (Section 2.11).

1.7 Authorizing Signatures

nd the USEPA select this remedy with the concurrence ofMDE.

N M. SHEPRO, Colonel, USAF Co ander, 316th Wing Andrews AFB, Maryl d

Page 5 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

2.0 DECISION SUMMARY

2.1 Site Name, Location, and Description

Andrews AFB is located in Prince George's County, Maryland, about five miles southeast of Washington, D.C. (Figure 2-1). The principal features of the base occupy approximately 4,300 acres and consist of runways, airfield operations, an industrial area, and housing and recreational facilities. Military and civilian personnel work and live on base. Andrews AFB is the home of Air Force One, the official airplane for the President of the United States. In May 1999, Andrews AFB was added to the NPL. The National Superfund electronic database identification number for Andrews AFB is MD0570024000.

Site FT-03 occupies approximately 16 acres southwest of the west runway at Andrews AFB. Figure 2-2 shows the location of FT-03 within Andrews AFB. FT-03 was used as a fire training area from 1959 until 1972. Fire training activities occurred at a 300- to 400-foot diameter training area within the site.

The USAF is the lead agency and provides funding from the Air Force environmental restoration account for the remedial action discussed in this ROD. This document is issued by the USAF (the site owner) and the USEPA (the federal regulatory agency responsible for overseeing compliance with CERCLA), in consultation with the MDE.

2.2 Site History, Enforcement Activities, and Investigations

2.2.1 Site History As mentioned above, FT-03 was used for fire training activities from 1959 until 1972, which occurred at a 300- to 400-foot diameter training area and an adjacent drum storage area. During fire training activities, a bermed area was saturated with water; then, an estimated 1,000 to 2,000 gallons of flammable liquids consisting of waste oil, jet fuel, paint thinner, and other liquids were poured into the bermed area and ignited. Protein foams, carbon tetrachloride, and chlorobromomethane were then used to extinguish the fires. Fire training activities were reported to have occurred two or three times per day until the mid 1960s, when they were reduced to once per day (USGS, 1989).

The adjacent drum storage area was reportedly situated on exposed soil, and the drums contained hazardous flammable materials such as waste oil, jet fuel, paint thinner, and other liquid wastes from shops at Andrews AFB. The exact location of the drum storage area, however, is unknown because it was never located on any historic aerial photographs or identified during any investigation.

In addition to the fire training activities, a small, unidentified area of FT-03 immediately adjacent to the fire training area may have been used for the burial of several hundred five-gallon containers of leaded motor vehicle gasoline (MOGAS) in the late 1960s. This information was based on a single source and has not been verified by any other personnel familiar with the activities at FT-03.

Page 6 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

The potential contaminant sources at FT-03 are the waste oils, jet fuels, paint thinner, fire extinguishing chemicals, and other liquid wastes that were not consumed during the fire training exercises, as well as spills or releases in the drum storage area. Any material remaining following fire training activities would have been absorbed into the soil column and potentially could have migrated into groundwater beneath the site. Residual chemicals potentially present from the fire training activities include volatile organic compounds (VOCs), including chlorinated solvents, benzene, toluene, ethylbenzene, and xylenes (BTEX); SVOCs; total petroleum hydrocarbons (TPH); polychlorinated biphenyls (PCBs); and metals. A potential source of contamination could also be sewage sludge reported to have been applied at the site.

When FT-03 was demolished circa 1972, contaminated soil was removed. There is no documentation of the volume of soil removed or if there was any established cleanup criteria. Clean soil was brought in, the site was graded, sludge was applied to aid in grass growth, and soccer fields were constructed. In 1995, a golf course was built in the area. The 14th hole green, 15th hole tee box, and 17th hole fairway of the South Course now cover the location of the former FT-03 site. The 16th hole is also located within the overall FT-03 site area. During the building of soccer fields and the golf course, surface soil at FT-03 was graded and subsequently covered with at least two to four feet of clean fill. Consequently, subsurface soils at FT-03 beneath the clean fill are the primary affected medium. Limited detections of site contaminants in groundwater below USEPA MCLs support the conclusion that there has been little movement of contaminants from impacted soils to the shallow groundwater beneath the site.

Figure 2-3 shows the former FT-03 in 1960 prior to the construction of the soccer field and golf course. Figure 2-4 presents an aerial photograph showing the site in 2000 after the golf course was constructed.

2.2.2 Previous Investigations Environmental investigations have been conducted at the base since 1985 and are being pursued under the USAF's ER Program. The ER Program was developed by the Department of Defense in 1981 to identify, investigate, and clean up former disposal sites on military bases. FT-03 was identified as an environmental site through the ER Program. The results of studies and investigations at FT-03 are summarized below.

2.2.2.1 Interim Removal Actions No interim removal actions have occurred at FT-03; however, during the dismantling of FT-03 in the early 1970s, contaminated soil was removed. There is no documentation concerning the volume of soil removed, or if there was any established cleanup criteria for soil to protect groundwater resources.

2.2.2.2 Phase I Records Search – 1985 In 1985 a Phase I Records Search was conducted at Andrews AFB to investigate and document past management, use, and/or disposal of hazardous substances and areas where such materials may have been used and/or disposed. Site FT-03 was identified in this study, which included a review of site operations and base records, interviews with base personnel, and field inspections.

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2.2.2.3 Historic Field Investigations – 1989 through 2003 Six separate environmental investigations were conducted at FT-03 after the Phase I Records Search through 2003. Soil gas surveys, soil sampling, and groundwater monitoring well installation and sampling were components of the early studies. Contaminants identified in soil included VOCs, TPH, and metals; VOCs and some metals were found in site groundwater. Groundwater flow velocity was estimated to be between 0.2 and 28 feet per year. The investigations concluded that ecological risk was insignificant due to the lack of surface soil contamination and absence of sensitive habitats or endangered species within FT-03.

A 1995 soil study refined the areas of soil impacts into two areas: one area was centered approximately 800 feet east and 200 feet north of the intersection of South Perimeter Road and Wheeling Road; the second area of soil contamination was centered approximately 300 feet northeast of the first area. (These areas were further defined as Soil and Groundwater Exposure Areas 1 and 2 in the 2004 remedial investigation (RI) discussed below; see Figures 2-5 and 2-6 for the locations of these areas.)

A 1995-1996 Preliminary Assessment/Site Investigation (PA/SI) at FT-03 included further site history research, interviews with Andrews AFB personnel, and a site reconnaissance. During interviews, a single source reported that, in addition to the fire training activities, a small unidentified area of FT-03 immediately adjacent to the fire training area may have been used for the burial of several hundred metal five-gallon containers of MOGAS in the late 1960s. The scope of the SI, therefore, included a geophysical survey (specifically, a magnetometric survey) to identify locations of metal debris within FT-03. Groundwater and soil samples were not collected as part of this study.

The geophysical survey identified a considerable amount of metallic debris present throughout the site. Two anomalies detected by the survey appeared to represent burial/disposal pits. In March 1996, these two anomalies were excavated to original grade (as determined by visual inspection of soil type) to determine the nature of the materials buried in these areas. The excavations uncovered rebar-reinforced concrete and metal fence posts. No evidence of the alleged buried MOGAS containers was detected during the excavations.

During 2002 and 2003, two groundwater sampling events were performed, which did not identify any significant trends or contaminant plumes. Monitoring well locations are shown in Figure 2-6. Ten monitoring wells sampled in 2002 and 2003 at FT-03 revealed no exceedances of MCLs for VOCs. The only SVOC detected in FT-03 groundwater was bis(2-ethylhexyl)phthalate (BEHP), which was detected in one sample in 2002 at 80 micrograms per liter (µg/L), exceeding the MCL of 6 µg/L. In 2003, the BEHP concentration detected had decreased to 8.2 µg/L.

In 2002, arsenic and lead were the only metals detected at concentrations above their respective MCLs of 10 and 15 µg/L. Two of ten samples contained lead concentrations at 19.9 and 59.9 µg/L. Arsenic exceeded the 10 µg/L MCL in one sample (12.2µg/L), while its duplicate sample contained arsenic at 5 µg/L, below the MCL. In 2003, arsenic and lead concentrations in groundwater samples were below their respective MCLs. PCBs were not detected in any FT-03 groundwater samples.

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2.2.2.4 Remedial Investigation (2004-2007) The following discussion of the RI conducted at FT-03 summarizes all contaminants detected in samples of soil and groundwater; the COCs identified in soil and groundwater are discussed in Sections 2.7.3 and 2.7.4 of this ROD, respectively.

During the RI, fourteen soil borings were advanced at FT-03. The locations of these borings were chosen based on a review of previous data and historical aerial photos. Soil and groundwater samples were obtained from these borings, and VOCs were detected that included primarily petroleum products and breakdown compounds. Concentrations of VOCs found in surface and subsurface soil did not exceed USEPA Region III industrial risk-based concentration (RBC) screening values. SVOCs, including benzo[a]pyrene, were detected at concentrations exceeding industrial RBCs. The results showed that the highest concentrations of benzo[a]pyrene occurred in samples six to eight feet below the ground surface collected from boring location DP09 in the vicinity of where fire training activities had occurred (see Figure 2-5). Since detected contamination is six to eight feet deep, there is little potential for human exposure.

In groundwater, five VOCs exceeded Region III tap water RBCs in samples collected from temporary borings (as opposed to groundwater samples collected from constructed monitoring wells). However, none of these detections exceeded applicable MCLs, which suggests that VOCs are not a chemical category of concern in groundwater at this site.

Monitoring well samples detected nine VOCs in groundwater at FT-03; however, no detections exceeded the respective MCLs. An SVOC, benzo[a]pyrene, exceeded its tap water RBC in groundwater samples from wells MW04 and MW11 (see Figure 2-6). Arsenic and iron were detected in groundwater at concentrations exceeding their respective tap water RBCs. Arsenic exceeded its tap water RBC of 0.045 µg/L in three monitoring wells, with detections ranging from 4.9 to 7.7 µg/L. None of these detected arsenic concentrations exceeded the arsenic MCL of 10 µg/L. The RBC for iron, which is 11,000 µg/L was exceeded in three out of eight wells at levels that also exceeded the base-wide background concentration (20,100 µg/L), with detections ranging from 27,000 to 59,000 µg/L. The fact that these background exceedances occurred in only three of eight monitoring wells indicates that they may not representative of overall site conditions.

Human Health Risk Assessment The investigation identified several contaminants that exceeded screening levels and were thus determined to be contaminants of potential concern (COPCs), which were further evaluated in a baseline human health risk assessment (HHRA). The purpose of the HHRA is to determine if the COPCs pose an unacceptable risk to current or potential future users; if so the COPCs are designated as COCs. These risks are calculated based on the toxicity of the contaminants on site, the different groups of people who may be exposed to these chemicals (e.g., maintenance workers or recreational users), and the pathways by which these chemicals may reach people.

CERCLA mandates that protectiveness for current and reasonably anticipated future land use must be achieved. At FT-03, the current and reasonably anticipated future land use is recreational (a golf

Page 9 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008 course). Although not planned or anticipated, other potential future land uses (e.g., residential and industrial) were evaluated in the HHRA to determine if the site could present an unacceptable risk if the site were available for other uses. As required by CERCLA and MDE, groundwater was evaluated as a drinking water source, although groundwater is not currently used for drinking and drinking water wells are prohibited under Maryland regulations when public drinking water is available, as at Andrews AFB.

Ecological Risk Assessment A formal ecological risk assessment (ERA) was not undertaken as part of the FT-03 RI. However, a base-wide ERA was conducted and concluded that FT-03 is not a potential source area. In addition, as part of the RI, an ecological screening study was conducted by comparing analytical data of surface and shallow (up to two feet below the ground surface) subsurface soil to USEPA Region III Biological Technical Assistance Group criteria; several SVOCs and metals in surface soil samples were found to exceed these ecological screening criteria. However, since there are no sensitive habitats (e.g., wetlands) or endangered species associated with the FT-03 site, and due to its urban nature and the presence of the golf course, it was determined that a full ERA is not necessary because there are limited receptors and habitats at this site.

2.2.3 Focused Feasibility Study (2007) A Focused Feasibility Study (FFS) was undertaken in 2006 and 2007 to evaluate remedial action alternatives to address risk posed by subsurface soil contamination and shallow groundwater at FT-03. Five alternatives were evaluated:

• No action (evaluation required by CERCLA and the NCP); • ICs alone; • ICs with continued monitoring of groundwater; • Excavation and off-site disposal of contaminated subsurface soil; and • In-situ chemical oxidation of subsurface soil, along with ICs and monitoring.

These five alternatives were then compared against the nine criteria specified in the NCP at Title 40 Code of Federal Regulations (CFR) 300.430(e)(9)(iii) to determine which alternative best meets the criteria for a remedial action under CERCLA and the NCP. Additional details about the remedial alternatives evaluated in the FFS and the alternative selected as the preferred alternative are provided in Sections 2.9, 2.10, 2.12.1, and 2.12..2 of this ROD.

2.2.4 Enforcement Activities No enforcement activities have occurred at FT-03. Environmental investigations have been conducted at the base since 1985 under the USAF's ER Program, which identified FT-03 as an environmental site. On May 10, 1999, USEPA listed Andrews AFB on the NPL. As a result, the USAF is working closely with USEPA, as well as MDE, to ensure that all possible risks at environmental sites on Andrews AFB, including FT-03, have been evaluated and that the remedial alternative selected for each site is protective of human health and the environment.

Page 10 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

2.3 Community Participation

Andrews AFB continues to conduct outreach to the local community stakeholders via several means, including periodic newsletters, a web page, and public notices on clean-up activities. The base coordinates with the Prince George's County Health Department on communications with the local community. In February 2007, the base published an ER Program newsletter, which was sent out to the surrounding community near the base. The newsletter discussed the environmental activities being conducted at FT-03.

The FT-03 RI was made available to the public in November 2007. The FFS and Proposed Remedial Action Plan (PRAP) for FT-03 at Andrews AFB were made available to the public in February 2008. These documents and all documents related to FT-03 that were relied upon to make this remedial decision are held in the Administrative Record file, which is kept at the Environmental Flight, 3466 North Carolina Avenue, Andrews AFB, Maryland. For the convenience of the public, a copy of the Administrative Record is maintained in an Information Repository located at:

Prince George's County Memorial Library-Surratts-Clinton Branch 9400 Piscataway Road Clinton, Maryland 20735 Phone (301) 868-9200 Hours: Monday-Wednesday 10 am-9 pm, Thursday-Friday 10 am-6 pm Saturday 10 am-5 pm, Sunday 1 pm-5 pm

A notice of the availability of the RI, FFS, and PRAP was published in the Star Community News section of the Prince George's County Gazette on February 7, 2008. On February 8, 2008 the same announcement was published in the Andrews AFB newspaper, the Capital Flyer, and on February 14, 2008 it was published in the Washington Post-Prince George's "Extra" weekly edition. Copies of these newspaper notices are provided in Appendix B. A 30-day public comment period was held from February 7, 2008 to March 7, 2008, inclusive. In addition, a public meeting was held on February 21, 2008, to present the PRAP to interested community members. At this meeting, representatives from the USAF and USEPA were present to answer questions about the conditions at the site and the remedial alternatives and to listen to any comments. The USAF's and USEPA's responses to the comments received during the public comment period are included in the Responsiveness Summary, which is Section 3 of this ROD.

2.4 Scope and Role of Response Action

This ROD summarizes the five remedial alternatives evaluated and selects a remedy for FT-03. The selected remedy will address groundwater and subsurface soil contamination at FT-03 and is consistent with the overall strategy to investigate and appropriately address the 33 ER program sites at Andrews AFB. The actions described in this ROD will be performed under the authority of USAF and USEPA, in coordination with MDE.

Page 11 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

This ROD is prepared for the FT-03 site and is the sixth ROD prepared for environmental sites at Andrews AFB.

Since being listed on the NPL, six CERCLA RODs have been signed for sites at Andrews AFB and Brandywine DRMO, a nearby site managed by Andrews AFB for purposes of CERCLA. As of the date of this ROD, remedial decisions have been implemented at four of the sites. The designation, media, and remedial action identified in the ROD for each of the sites are:

• Site ST-10, PD-680 Spill Site, Groundwater Monitoring and ORC Injection (ROD September 28, 2005); • Site FT-04, Fire Training Area 3, Monitoring of HRC Treatment and Institutional Controls (ROD November 22, 2005); • Site SS-01, Brandywine DRMO, Bioaugmentation and Carbon Substrate Addition with Gradient Control (Interim ROD September 29, 2006); • Site SD-23, Sludge Disposal Area, No Action (ROD May 23, 2007); and

• Site ST-14, Former East Side Gas Station (ROD September 21, 2007).

2.5 Site Characteristics

2.5.1 Physical Setting FT-03 is located underneath the 14th hole green, 15th hole tee box, and 17th hole fairway of the Base South Golf Course, which is dominated by flat grassy areas interspersed with small knolls/mounds. There are no natural or manmade surface water bodies on FT-03; however, surface runoff at FT-03 is controlled by the rolling ground surface of the golf course, and the several sand traps present at the site are not thought to noticeably affect the site hydrology. In order to maintain the golf course grass cover, it is irrigated during dry periods to mimic average rainfall conditions. During periods of heavy rainfall, surface water flows from the course into drainage ditches adjacent to the roads that border the site. Surface water from FT-03 eventually enters Piscataway Creek approximately 3,000 feet east-southeast of FT-03. The closest surface water body to FT-03 is Freedom Lake, located approximately 1,200 feet southeast of the site.

The original ground surface was altered during grading activities and when the fire training area was decommissioned. Two to four feet of clean fill was placed on top of FT-03 during construction of the South Golf Course. The fill material used to construct the golf course included soil and other materials capable of enhancing site drainage and ultimately supporting the turf grass covering the course. The RI documented that the thickness of this soil layer varies, but it is generally greater than 20 inches. Prior to construction of the golf course, FT-03 surface soil was classified as smooth Udorthents (U1) in the U.S. Department of Agriculture Natural Resource Conservation Service’s Soil Survey of Andrews AFB (USDA, undated).

During the RI at FT-03, soils at the site were found to include a wide-variety of soil types consistent

Page 12 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008 with construction activities of the golf course. Silts, clays, sands, and gravel were all encountered in the upper 5 to 10 feet during soil sampling. A layer of charred material identified in the subsurface that may represent the surface of the former fire training area was encountered in 6 of the 14 boreholes. The depth of this charred material layer (thickness less than one foot) varied from 4 to 15 feet below the ground surface. Samples of this material were collected for laboratory analysis and trace levels of SVOCs and metals including arsenic were detected.

The former ground surface at FT-03 was described as unconsolidated fine to coarse sand with gravel and some silt and clay layers (USGS, 1989). This original ground surface represents the first soil layer that could have been contaminated by the FT-03 activities. This layer consists of undifferentiated Upland Deposits that are found across Andrews AFB. The depth to the underlying low permeability aquitard (the Calvert Formation) has not been determined at FT-03, although it has been documented to be 10 to 50 feet below the ground surface in adjacent areas. Based on investigations at FT-03 and adjacent areas, the Calvert Formation is likely found between 35 and 50 feet below the ground surface at FT-03.

Shallow groundwater in the area is found in the Upper Miocene to Pliocene-age Upland Deposits. The shallow unit is unconfined and consists of unconsolidated deposits (sands, gravels, silts, and clays). At FT-03, the groundwater depth varied from approximately 8 to 21 feet below the ground surface. In the shallow unit, average yield ranged between two and five gallons per minute (gpm), while the maximum yield was recorded as high as 12 gpm. Groundwater flow is generally to the east/southeast with a northeasterly component in the northern part of the site. Groundwater flow is estimated to be between 0.2 and 28 ft/year.

There are no receptors that come into contact with groundwater at FT-03 as contaminated groundwater does not appear to be migrating off site, the groundwater is not currently being used as a potable water source, and there are no springs in the area. Potable water is supplied by the WSSC. Additionally, there are no nearby surface water bodies that could be impacted by FT-03 groundwater.

There are no archaeological or historically significant cultural resources of importance at or in the vicinity of FT-03.

2.5.2 Conceptual Site Model The conceptual site model (CSM) for a site illustrates contaminant sources, release mechanisms, exposure pathways, migration routes, and potential receptors; it provides a basis for the risk assessment summarized later in this ROD and is the basis for any necessary response actions. Figure 2-7 is the CSM outlining contaminant sources, exposure pathways, and potential human receptors that were evaluated in the course of the HHRA for FT-03.

Human receptors evaluated for exposure to contaminants in soil and groundwater (including vapors originating from VOCs in the soil and/or groundwater) at FT-03 include hypothetical future residents (adult and child), current and future recreational users and maintenance workers, and future construction and industrial workers. MDE categorizes shallow groundwater at FT-03 as a potential

Page 13 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008 drinking water source. Therefore, the HHRA evaluated potential residential use of groundwater as drinking water by future receptors, although this future scenario is unlikely to occur. Current and potential future land and groundwater uses are discussed further in Section 2.6. Potential risks to human health are identified in Sections 2.7.1 through 2.7.5, and 2.7.7.

Exposure pathways for ecological receptors were not included in Figure 2-7. Pathways for contaminant exposure to ecological receptors are extremely limited at FT-03, as described further in Section 2.7.6. There is limited ecological habitat at FT-03. Potential ecological risks pertaining to the contaminants present at FT-03 were evaluated in a basewide ERA conducted for Andrews AFB. Conclusions of the basewide ERA for FT-03 are summarized in Section 2.7.6.

2.5.3 Nature and Extent of Contamination This subsection summarizes the nature and extent of contamination in groundwater and soil at FT­ 03 based on the data collected during the RI. Historic data from previous investigations were used to design the RI sampling strategy; these data can be found in the Administrative Record.

Based on the results of investigations of the site, FT-03 was split into two areas, Areas 1 and 2, for purposes of evaluating potential exposure to soil and groundwater contaminants. Area 1 covers the former fire training pits, and Area 2 is located in the northern part of the site where soil disturbance activity was noted in historic aerial photographs (see Figures 2-5 and 2-6).

Soil and groundwater samples were collected from the 14 direct-push soil borings at FT-03 in June 2004, and groundwater samples were collected from 8 of the 12 monitoring wells present at FT-03 in July 2005. Groundwater, surface soil, and subsurface soil samples collected during the RI were submitted to a fixed laboratory for analysis using USEPA-approved methodologies. The analytical results for these samples are included in the RI report and summarized below. Data collected during ongoing investigations at LF-06 (east of FT-03) and Freedom Lake (south of FT-03) were used to supplement the groundwater data collected at FT-03.

Continuous soil samples were collected from the ground surface to the top of groundwater in each of the 14 borings. Soil samples were screened using a combination photoionization detector/flame ionization detector (PID/FID). The direct-push locations at FT-03 were chosen based on a review of previous investigation and historical aerial photos. Five direct-push soil borings were advanced and sampled at the location of the oval of intense fire training activity visible in the 1960 aerial photo of FT-03. Six direct-push soil borings were advanced and sampled across the debris piles visible on the aerial photographs from 1958 to 1968. Three direct-push soil borings were advanced and sampled in the northeast portion of the FT-03 where activities were visible on the 1960 aerial photograph.

2.5.3.1 Direct-Push Soil Sampling Results VOCs. Seventeen VOCs were detected in the soil samples collected at FT-03. None of the detected concentrations exceeded the industrial RBCs. The detected VOCs included primarily petroleum products and breakdown compounds. The detected VOCs were 1,1,2,2-tetrachloroethane, 1,2,4­

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trimethylbenzene, 1,3,5-trimethylbenzene, acetone, chloromethane, dichlorodifluoromethane, ethylbenzene, isopropylbenzene, m+p-xylene, methylene chloride, naphthalene, n-butylbenzene, n­ propylbenzene, o-xylene, p-isopropyltoluene, sec-butylbenzene, and toluene.

SVOCs. Twenty-nine SVOCs were detected in the soil samples collected at FT-03. None of the detected concentrations exceeded the industrial RBCs and were several orders of magnitude below the RBCs, indicating that SVOCs are not a significant contaminant at FT-03.

PAHs. Six PAHs were detected in the soil samples collected at FT-03. Only benzo[a]pyrene was detected at concentrations exceeding the industrial RBCs. Benzo[a]pyrene was detected in four of 37 samples at concentrations (ranging from 450 to 2,500 micrograms per kilogram [µg/kg]) exceeding the RBC of 390 µg/kg. Other PAHs detected at concentrations below the RBCs in FT-03 soils included benzo[a]anthracene, benzo[b]fluoranthene, chrysene, dibenzofuran, and indeno[1,2,3­ c,d]pyrene. These results indicate that PAHs are the most significant contaminant of FT-03 soils. The results also indicate that the highest concentrations occur in soils six to eight feet below the ground surface in the southwestern portion of the golf course. The current depth to the PAH- contaminated soil minimizes the potential for exposure.

Metals. Sixteen metals were detected in the soil samples collected at FT-03. Arsenic was the only metal detected in FT-03 soils at concentrations exceeding the industrial RBCs. Arsenic exceeded the RBC of 1.9 milligrams per kilogram (mg/kg) in 21 of the 37 soil samples at estimated concentrations ranging from 1.9 to 4.8 mg/kg. However, the arsenic detected was at concentrations within the range detected in the background study at Andrews AFB. Twelve other metals were detected in all 37 soil samples including aluminum, barium, cadmium, chromium, cobalt, copper, lead, manganese, mercury, nickel, thallium, and zinc. Antimony was detected in 17 samples, beryllium in 28 samples, and silver was detected in 14 samples.

Cyanide. Cyanide was detected in 6 of the 37 soil samples collected at FT-03 at estimated concentrations ranging from 0.18 to 0.28 mg/kg, well below the RBC of 20,000 mg/kg.

PCBs. Five soil samples were collected for PCB analysis from the depth believed to be the former fire training area surface based on historic aerial photos, topographic interpretation, and the PID/FID soil screening. These samples included the six- to eight-foot deep sample from FT-03-DP01, the 8- to10-foot deep sample from FT-03-DP02, and the 10- to 12-foot deep samples from FT-03-DP03, FT-03-DP04 and FT-03-DP05. No PCBs were detected in any of the five soil samples.

Dioxins/Furans. The total 2,3,7,8-TCDD toxicity equivalent quotient (TEQ) value for the five soil samples collected at FT-03 ranged from 3.464 to 3.923 nanograms per kilogram (ng/kg). None of the soil samples analyzed for dioxins/furans exceeded the total 2,3,7,8-TCDD TEQ RBC of 4.3 ng/kg. These samples were collected from the same soil borings and sample depths as the PCB samples.

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2.5.3.2 Direct-Push Groundwater Sampling Results Groundwater screening samples were collected from all 14 direct-push soil borings and were analyzed for VOCs, SVOCs, and low-level PAHs.

VOCs. Fourteen VOCs were detected in the groundwater samples collected at FT-03. Five VOCs were detected at concentrations exceeding the Region III tap water RBCs, but below the MCLs. Benzene was detected in one sample collected from location FT03-DP10 at a concentration of 0.45 µg/L exceeding its RBC of 0.34 µg/L. Carbon tetrachloride was detected in samples collected from location FT03-DP12 at an estimated concentration of 2.1 µg/L, exceeding its RBC of 0.16 µg/L. Chloroform was detected in one sample collected at location FT03-DP12 at an estimated concentration of 0.21 µg/L exceeding the corresponding RBC of 0.15 µg/L. Hexachlorobutadiene exceeded its respective RBC of 0.86 µg/L in samples collected from location FT03-DP12 (estimated 1.1 µg/L); and 1,1,2,2-tetrachloroethane was detected in one sample collected from location FT03- DP01 at an estimated concentration of 0.18 µg/L exceeding the corresponding RBC of 0.053 µg/L.

SVOCs. Four SVOCs were detected in the groundwater screening samples collected at FT-03. BEHP was detected in two samples at estimated concentrations that exceeded both the corresponding tap water RBC (4.8 µg/L) and the MCL (6 µg/L). BEHP was detected at estimated concentrations of 7.3 µg/L and 7.4 µg/L in samples collected from FT03-DP05 and FT03-DP08, respectively. These concentrations are below the detection limit of 10 µg/L. SVOC analyses are typically not performed on groundwater samples collected using direct-push screening techniques because resultant samples are usually turbid due to suspended solids in the sample. Since SVOCs have a tendency to adsorb onto soil/suspended solids present in the turbid groundwater samples, the SVOC analytical results from these screening samples may not be representative of constituents dissolved in the groundwater.

Another SVOC, 3,3'-dichlorobenzidine, was detected in samples collected from location FT03-DP12 at an estimated concentration of 20 µg/L. This concentration exceeds the respective RBC of 0.15 µg/L. Other SVOCs detected in FT-03 screening groundwater at concentrations below the screening criteria were 1,4-dichlorobenzene and pyrene.

PAHs. Six PAHs were detected in the groundwater screening samples collected at FT-03. Four of the six PAHs were detected at concentrations exceeding the tap water RBCs. Benzo[a]pyrene was detected in five samples and one duplicate sample at concentrations exceeding the RBC of 0.0092 µg/L. The highest concentrations of benzo[a]pyrene occurred in groundwater samples collected from FT-03-DP03, located in the center of the former fire training area, and in samples collected from FT03-DP10 and FT03-DP11, located in Exposure Area 1. Concentrations in the samples collected from these locations ranged from 0.12 to 0.17 µg/L. Benzo[a]anthracene, benzo[b]fluoranthene, and indeno[1,2,3-cd]pyrene were also detected at concentrations exceeding the tap water RBCs. The distribution of these detections was similar to that of benzo[a]pyrene. Two other PAHs, chrysene and dibenzofuran, were also detected in FT-03 screening groundwater samples at concentrations below the RBCs.

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2.5.3.3 Monitoring Well Groundwater Sampling Results VOCs. Nine VOCs were detected in the groundwater samples collected at FT-03. The detected VOCs were acetone, chloroform, chloromethane, cis-1,2-DCE, isopropylbenzene, naphthalene, p­ isopropyltoluene, sec-butylbenzene, and vinyl chloride. Of the nine detected VOCs, two had concentrations exceeding their respective Region III RBCs for tap water, which are further discussed below. No VOCs exceeded their respective MCL.

Chloroform was detected at concentrations exceeding its RBC of 0.15 µg/L in samples collected from three sample locations. Concentrations ranged from an estimated 0.23 µg/L to 0.41 µg/L. However, this is a common laboratory contaminant, so these detections are not considered significant. The vinyl chloride estimated concentration of 0.82 µg/L detected in the sample collected from monitoring well FT-03-MW12 clearly exceeds the tap water RBC of 0.015 µg/L. A duplicate sample was collected from FT-03-MW12, and vinyl chloride was detected at a similar estimated concentration of 0.77 µg/L.

SVOCs. No SVOCs were detected in the groundwater samples collected at FT-03; therefore, SVOCs do not contribute to the groundwater contamination at FT-03.

PAHs. Four PAHs were detected in two of the nine groundwater samples collected at FT-03, and only one had a concentration that exceeded its corresponding tap water RBC. Benzo[a]pyrene exceeded the RBC of 0.0092 µg/L in monitoring wells FT-03-MW04 and FT-03-MW11 at concentrations of 0.047 µg/L and 0.013 µg/L, respectively. The PAH detections are the most significant contaminant of the FT-03 groundwater.

Total Metals. Fifteen total metals were detected in the groundwater samples collected at FT-03. Two metals had concentrations exceeding their respective tap water RBCs: arsenic and iron.

Dissolved Metals. Fourteen dissolved metals were detected in the groundwater samples collected at FT-03. Two dissolved metals had concentrations exceeding their respective tap water RBCs: arsenic and iron.

Cyanide. Cyanide was detected in samples collected from three of the eight monitoring wells including the duplicate sample. Detected concentrations ranged from an estimated 2.66 µg/L to an estimated 5 µg/L. These concentrations were well below the tap water RBC of 730 µg/L.

2.6 Current and Potential Future Land and Water Uses

The FT-03 site is located southwest of the base airfield and is currently located beneath part of the Andrews AFB South Golf Course. The land use at FT-03 is expected to remain recreational for the foreseeable future, and ICs required by this ROD will ensure that the site is re-evaluated for potential risk before any land use change is implemented.

To evaluate risk, current and reasonably anticipated future receptors were quantitatively evaluated in the HHRA for FT-03. Current and reasonable future receptors consist of recreational users (i.e.,

Page 17 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008 golfers) and maintenance workers. These receptors may be exposed to soils at the site, but are not expected to be exposed to contaminated soil in the subsurface because it is located at a minimum of six feet below the existing ground surface. These receptors are not expected to contact groundwater for similar reasons.

In addition to the reasonably anticipated land uses, several less likely potential future land uses were evaluated in the HHRA to determine if the site was acceptable for unlimited use and unrestricted exposure. These unlikely potential future uses include industrial land use and residential land use. As required by CERCLA and MDE, the HHRA included an analysis of the risks that would be posed to a future resident using the shallow groundwater at the site for drinking and showering. However, since the land use for the foreseeable future is not expected to change from recreational use, as a golf course, potable use of the shallow aquifer is unlikely.

There are no water supply wells located at Andrews AFB, including at FT-03. Shallow groundwater at FT-03, and throughout Andrews AFB, is not used as a potable water source, and it is not expected to be used for such purposes in the future. Andrews AFB is currently served by public water supplied by WSSC and, according to the Code of Maryland Regulations (COMAR) 26.03.01.05, drinking water and supply wells are not permitted to be installed in areas where public water infrastructure is available. Surface water obtained from both the Potomac and Patuxent Rivers is the source of the municipal water supply for WSSC.

Silt and clay underlying the surficial aquifer act as a semi-confining layer that limits the vertical migration of contaminated groundwater from FT-03. Although groundwater at FT-03 is not currently used as a potable water source, and the migration of impacted groundwater appears to be limited, groundwater is considered a natural resource under the Maryland Anti-Degradation Policy (COMAR 26.08.02.04). Under the policy, the quality of the waters of the state, including groundwater, is to be maintained and degradation is to be prevented. To comply with the COMAR requiring the beneficial use of groundwater at FT-03, the site was evaluated under a residential land use scenario, with groundwater as the primary drinking water source for the residents.

2.7 Summary of Site Risks

A baseline HHRA was conducted for soil and groundwater in the RI for FT-03 (Earth Tech, 2007). The following subsections summarize the risk assessment processes, results, and uncertainties.

The ERA for Andrews AFB was conducted on a facility-wide basis. Results as they relate to FT-03 are discussed in Section 2.7.6. A complete discussion of the Basewide ERA methodologies and results is provided in the Final Basewide Ecological Risk Assessment Report (CH2M Hill, 2005).

2.7.1 Baseline Human Health Risk Assessment Process The baseline HHRA estimates the risks that exposure to groundwater and soil at the site would pose if no remedial action were taken. It provides the basis for taking action and identifies the contaminants and exposure pathways that need to be addressed by the remedial action. It can also be used to support the determination that no remedial action is necessary to protect human health. The

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following sections outline the process used to conduct the baseline HHRA. The risk characterization results for soil and groundwater at FT-03 are discussed in Sections 2.7.2, 2.7.3, and 2.7.4.

2.7.1.1 Identification of Contaminants of Potential Concern The selection of COPCs is a conservative screening process that identifies those chemicals that are present at the site at concentrations that could result in risks to exposed receptors. The maximum detected concentration of each constituent in each medium (surface and subsurface soil, and groundwater) was compared to a screening value to select the COPCs. If the maximum detected concentration of a constituent exceeded the screening value, the constituent was selected as a COPC and retained for further evaluation. The USEPA Region III RBCs for residential land use were used as the screening levels to identify COPCs (USEPA, 2004a). These RBCs are conservatively set to represent an excess lifetime cancer risk of 1 x 10-6 (a 1 in 1,000,000 chance of developing cancer over a 70-year lifetime) or a noncancer hazard index (HI) of 1.0 (the threshold level below which noncancer adverse health effects are not expected to occur) as a result of site-related exposure. Chemicals eliminated from further evaluation at this step present acceptable risks to exposed human receptors. The COPCs were then further evaluated by comparing the COPC concentrations to the basewide background levels for soil and groundwater that were reported in the Andrews Basewide Background Study (CH2M HILL, 2004). COPCs which were not determined to be consistent with background concentrations were considered in the evaluation of site-related risk.

Subsurface soil samples collected during the RI for laboratory analysis that detected contamination were all from depths of greater than six feet below the ground surface. A majority of the contamination was detected at depths of between 12 and 20 feet below the ground surface (i.e., beneath the clean fill material that was placed over the area after the FT-03 fire training pits were demolished and when the golf course was constructed in 1995). Because the contaminated subsurface soil samples were collected from 6 to 20 foot depths, it is unlikely that any of the current or future receptors (future residents or workers) would be exposed to these soils. Exposure would also be unlikely for a construction worker involved in excavation activity because excavations do not typically extend below a depth of eight feet. The only contaminants detected in the subsurface soil in concentrations exceeding USEPA RBCs were benzo[a]pyrene and arsenic.

COCs are a subset of the COPCs. COCs are identified as those site-related constituents that must be considered for a response action because they contribute to a significant cancer risk or non-cancer hazard. Following a comprehensive HHRA, naphthalene was identified in soil as a COC through vapor inhalation computer modeling. The COCs identified in groundwater were benzo[a]pyrene, arsenic, and chromium. These COCs present a dermal contact and ingestion risk to the future resident that is above acceptable limits.

2.7.1.2 Exposure Assessment The exposure assessment defines and evaluates the type and magnitude of human exposure to the chemicals present at a site or migrating from a site. The exposure assessment depicts the physical setting of the site, identifies potentially exposed populations, and estimates chemical intakes under the identified exposure scenarios. A complete exposure pathway consists of all five of the following elements: source (i.e., release of COCs); environmental transport medium (e.g., subsurface soil);

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mechanism for release and migration of chemical (e.g., leaching from subsurface soil); point or site of potential human contact (exposure point, e.g., airborne soil particles); and route of intake (e.g., inhalation of airborne soil particles). The compilation of contaminant sources, potentially complete exposure pathways, and potential human receptors evaluated in the risk assessment is depicted graphically in the CSM in Figure 2-7.

The potential human receptors evaluated for exposure to soil and groundwater at FT-03 are identified in Section 2.5.2 and Figure 2-7. The reasonable maximum exposure (RME) scenario was evaluated for each receptor. The RME scenario represents a conservative (or reasonable maximum) level of human exposure and is intended to be protective of human health.

Pathway-specific information for these receptors, such as the values of exposure parameters used to quantify exposure, is presented in the RI. Exposure factors used in the HHRA were compiled from USEPA sources (USEPA, 1989, 1990, 1991, 1993, 1995, and1997) and professional judgment when necessary, as described in the complete HHRA included in the RI report (Earth Tech, 2007).

2.7.1.3 Toxicity Assessment This section provides toxicity values used for the characterization of the potential human health risks associated with the potential exposure to media at FT-03. The toxicity assessment identifies the potential adverse health effects in exposed populations. Toxicity values used in the HHRA were obtained from sources in accordance with the USEPA policy on human health toxicity values and were consistent with those presented in the April 2006 version of the USEPA Region III RBC Tables (USEPA, 2005). The sources of toxicity values are discussed in the FT-03 RI (Earth Tech, 2007).

The toxicity value used to evaluate carcinogenic effects is the cancer slope factor (CSF). The CSF is an upper-bound estimate of the probability that a person will develop cancer over a lifetime based on a given dose. The toxicity value used to evaluate noncarcinogenic effects is the reference dose (RfD). The RfD is an estimate of the daily exposure level for the human population that is unlikely to result in adverse health effects.

2.7.1.4 Risk Characterization The results of the exposure and toxicity assessments were used to develop numerical estimates that characterize the potential health risks associated with site-related contamination.

For carcinogens, risks are generally expressed as the incremental probability of an individual developing cancer over a lifetime as a result of exposure to the carcinogen. These risks are probabilities that usually are expressed in scientific notation (e.g., 1 x 10-6). A lifetime excess cancer risk of 1 x 10-6 indicates that an individual receiving the RME dose of a contaminant has a one in a million chance of developing cancer as a result of site-related exposure. This risk caused by exposure to the contaminant is referred to as "lifetime excess cancer risk" because it would be in addition to the risks of cancer individuals face from other causes, such as smoking or exposure to too much sun. According to the NCP at 40 CFR Section 300.430(e)(2)(i)(A)(2), a generally acceptable risk range for site-related exposures is 1 in 10,000 to 1 in 1,000,000 (1 x 10-4 to 1 x 10-6).

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The potential for noncarcinogenic effects is evaluated by comparing the dose of a noncarcinogenic chemical to an established RfD for that chemical. A RfD represents a dose to which an individual may be exposed that is not expected to cause any deleterious effect. The ratio of the chemical dose to the RfD is called a hazard quotient (HQ). A HQ of less than one indicates that a receptor's dose of a single contaminant is less than the RfD and that toxic noncarcinogenic effects from that chemical are unlikely. The HI is generated by adding the HQs for all COCs. A target organ HI is generated by adding HQ values for chemicals that affect the same target organ (e.g., liver) or that act through the same mechanism of action within a medium or across all media to which a given individual may reasonably be exposed. A target organ HI of less than one indicates that, based on the sum of all HQs from different contaminants and exposure routes, toxic noncarcinogenic effects from all contaminants are unlikely. An HI of greater than or equal to one indicates that site-related exposures as assumed in the HHRA may result in adverse health effects.

2.7.2 Baseline Human Health Risk Assessment Results—General The following current and future receptors were quantitatively evaluated in the HHRA for FT-03. Current land use at FT-03 is recreational, and current human receptors include:

• Recreational users (i.e., golfers); and • Maintenance workers. Several potential future land uses were identified:

• Continued recreational land use (a golf course); • Industrial land use; or • Residential land use.

Potential future receptors at FT-03 include:

• Recreational users (i.e., golfers); • Maintenance workers; • Indoor/outdoor industrial workers; • Construction workers; and • Although unlikely, future on-site child/adult residents.

The HHRA determined that the only potential receptors at FT-03 that could be exposed to unacceptable risk would be the future resident. Cancer and non-cancer risks associated with residential exposure at FT-03 are presented in Tables 2-1 and 2-2, respectively. Table 2-2 defines the non-cancer risks associated with HI drivers and identifies target organs that may be impacted by exposure to specific COCs.

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Table 2-3 presents a summary of the COC concentrations detected in Exposure Areas 1 and 2, and identifies applicable MCLs and background levels.

2.7.3 Baseline Human Health Risk Assessment Results—Soil The concentrations of naphthalene discovered in the vadose zone soils (i.e., above the groundwater table) at two locations at Soil Exposure Area 1 (see Table 2-3) would pose unacceptable levels of risk to future child/adult residents who could be exposed via inhalation of volatilized naphthalene in indoor air. However, since FT-03 will not be converted to residential use in the reasonably anticipated future, this exposure pathway does not exist and there are no risks associated with soil under current and future anticipated FT-03 land use.

2.7.4 Baseline Human Health Risk Assessment Results—Groundwater There are currently no complete exposure pathways to contaminated shallow groundwater at FT-03. The groundwater at FT-03 is not used currently for drinking, washing, or industrial uses because the base is served by public water supplied by the WSSC. In addition, the groundwater does not discharge to surface water via a spring or seep so exposure to contaminated groundwater is unlikely. As a conservative measure, however, the baseline HHRA evaluated potential risks from exposure to groundwater for future residents (adult and child), current/future construction workers, and future maintenance/industrial workers at FT-03. Although the residential exposure scenario is unlikely, it was evaluated in order to determine if remedial action was necessary for site conditions to allow for unlimited use and unrestricted exposure.

The complete exposure routes evaluated for hypothetical future residents included ingestion of, and dermal contact with, groundwater. The HHRA concluded that concentrations of several chemicals in groundwater found during the RI would pose unacceptable risks to future child/adult residents if exposed via ingestion of, and dermal contact with, groundwater. While there is no groundwater plume (i.e., large area of contaminated groundwater), conservative assumptions about residential groundwater use led to a calculation of a potential cancer risk due to exceedances of RBCs for benzo[a]pyrene, arsenic, and chromium. These exceedances occurred in 5 out of 25 samples for benzo[a] pyrene, three out of nine samples for arsenic, and two out of eight samples for chromium. All of the risk exceedances exist only for the very unlikely future residential land use scenario, and the detected concentrations did not exceed USEPA MCLs.

Of the metals detected in the shallow groundwater, most do not generate an unacceptable risk individually; cumulatively, they do pose unacceptable risk under the unlikely future residential use scenario. Since iron and manganese exist at concentrations comparable to background concentrations across most of the site, these metals are not considered COCs because they are probably present naturally and not due to site-related activity.

Residential groundwater use is not allowed under the Andrews Base General Plan, and potable use of groundwater would be prohibited under Maryland law as a public water infrastructure already exists on base. There is no indication that contamination in soil poses a risk to future degradation of groundwater.

Page 22 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

2.7.5 Uncertainty Associated with HHRA for Soil and Groundwater Various factors throughout the risk assessment lead to uncertainty that can overestimate or underestimate the potential risk associated with a COC. For example, site-related groundwater contamination would be expected to decrease over time, but in accordance with USEPA guidance, the risk assessment assumed that the concentrations would remain constant throughout the exposure period.

Uncertainties associated with fate and transport modeling to determine volatilization from groundwater during excavation near the water table, and uncertainties in noncarcinogenic and carcinogenic toxicity factors may also lead to either an overestimation or underestimation of risk. The combination of conservative assumptions (i.e., in the exposure assessment and in the toxicity assessment) will most likely result in an overestimate of risk at the site. Thus, the risk to human health is unlikely to be greater than that predicted by the risk assessment.

Another uncertainty associated with the HHRA is that benzo[a]pyrene was detected in only one groundwater sampling event, and that sampling event was conducted using direct-push screening techniques for sample collection directly beneath contaminated soil. Direct-push sampling techniques typically result in groundwater samples with considerable turbidity from suspended solids. Since PAH compounds have an affinity to adsorb to suspended solids, analytical results may not be reflective of constituents dissolved in the groundwater. The presence or absence of benzo[a]pyrene will be confirmed by direct groundwater sampling and analysis through the installation of groundwater monitoring wells as part of the monitoring program component of the selected remedy.

2.7.6 Ecological Risk Assessment A formal ERA was not undertaken as part of the FT-03 RI. However, a basewide ERA was conducted and concluded that FT-03 is not a potential source area presenting ecological risk (CH2M Hill, 2005). In addition, as part of the RI, an ecological screening study was conducted that compared surface and shallow (up to two feet below the ground surface) subsurface soil analytical data against USEPA Region III Biological Technical Assistance Group risk-screening criteria; several SVOCs and metals in surface soil samples were found to exceed these criteria. However, since there are no sensitive habitats (e.g., wetlands) or endangered species associated with the FT-03 site, and due to its urban nature and presence of the golf course, it was determined that a full ERA is not necessary and that the conclusions of the basewide ERA were appropriate at this site.

2.7.7 Conclusions of Risk Assessment and Basis for Action There is no risk to current or reasonably anticipated future users of the site (golfers and maintenance workers) through exposure to either soil or groundwater. Contaminants in groundwater were detected at levels below MCLs, which indicate that movement of contaminants from soil into groundwater has been limited. Natural degradation of benzo[a]pyrene in groundwater may occur over time reducing the concentrations. Although groundwater at FT-03 is not currently being used for potable supply or any other purpose, it is remotely possible that, in the future, the groundwater could become a resource for residential

Page 23 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

use. Also, naphthalene in soil poses an inhalation risk to future residents. For these reasons, a remedial action is required to determine when groundwater conditions allow for unlimited use and unrestricted exposure and, in the meantime, to ensure that the groundwater is not used as a potable supply or for washing purposes. The remedial action is also required to restrict land use to ensure that naphthalene in soil does not pose an inhalation risk.

2.8 Remedial Action Objectives

Remedial action objectives (RAOs) for FT-03 are based on an evaluation of site conditions, the HHRA, the nature of the site contaminants, and ARARs.

• Protect human receptors from exposure to contaminated subsurface soil; and • Restrict the use of shallow groundwater until it does not pose an unacceptable risk.

Unlimited use of, and unrestricted exposure to, the site was considered and rejected as a RAO. However, two alternatives using excavation and off-site disposal or treatment to remediate the site to achieve conditions that allow for unlimited use and unrestricted exposure to all media were evaluated to understand the requirements and associated costs that would be necessary, and to compare active remediation alternatives to protective alternatives.

2.9 Description of Remedial Alternatives for Soil and Groundwater

Five remedial alternatives were developed in the FFS for FT-03 to address the COCs identified in the HHRA.

• Alternative 1 – No Action; • Alternative 2 – ICs; • Alternative 3 – ICs with Monitoring; • Alternative 4 – Excavation/Off-Site Disposal of Contaminated Soil with ICs and Monitoring; and • Alternative 5 – In-Situ Chemical Oxidation of Soil with ICs and Monitoring.

Each alternative is summarized below. Table 2-4 presents the cost and implementation time for each alternative.

2.9.1 Alternative 1: No Action This alternative, required by the NCP, served as the baseline against which the other alternatives were compared during the FFS. Under this alternative, no further efforts or resources would be expended to remediate or monitor the contaminated soil and/or the shallow groundwater at FT-03, nor would efforts be made to prevent human exposure to COCs present at the site.

Page 24 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

2.9.2 Alternative 2: Institutional Controls This alternative would require the implementation and maintenance of the ICs at the FT-03 site for soil and groundwater. The ICs to be implemented are the same as those described below for Alternative 3 (see Section 2.9.3 below).

2.9.3 Alternative 3: Institutional Controls with Monitoring This alternative requires the implementation of ICs and the periodic sampling and analysis of groundwater monitoring wells at FT-03. Benzo[a]pyrene is the limiting parameter in the return of FT-03 groundwater to beneficial use. The monitoring program of Alternative 3 would be used to:

• Install additional groundwater monitoring wells to evaluate concentrations of the COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic concentrations) in groundwater through periodic sampling and chemical analysis; and • Verify that there is no further degradation of groundwater by demonstrating through statistical validation using a Mann-Kendall test and trend analysis that the contaminant concentrations of naphthalene, benzo[a]pyrene, chromium, and arsenic are stable and/or decreasing.

The groundwater monitoring component of this alternative includes semi-annual sampling and analysis for two years, followed by annual sampling and analysis for three additional years, followed by sampling and analysis at five-year intervals to coincide with data generation and analysis for purposes of five-year reviews required by CERCLA Section 121(c). The analytic data would be further analyzed statistically using the Mann-Kendall test and subsequent trend analysis to determine trends in COC concentration changes, if any.

Because Alternative 3 does not include active treatment for the soil or groundwater, the timeframe to achieve acceptable risk levels for COCs cannot be confidently estimated. However, the low concentrations in these media indicate that achievement of acceptable risk levels may occur within five years. Data collected would be used to evaluate trends in COC concentrations in groundwater and determine whether:

• The remedy is still protective; • An increase in COCs has occurred, or if natural degradation is not sufficient to reduce COCs in groundwater, necessitating evaluation of select areas for active treatment; • The monitoring program can be narrowed or must be enhanced; or • Conditions at the site are appropriate for unlimited use and unrestricted exposure for groundwater only and, thus, ICs can be eliminated.

In addition to the monitoring program, ICs will be implemented at FT-03. The objectives of the ICs at FT-03 are to ensure that:

Page 25 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

• Groundwater is not used as drinking water or for washing; • Construction activities on-base do not interfere with required monitoring and ensure protection of construction workers during any future construction activities at the site; • Any proposed changes in land use are evaluated in terms of consistency with RAOs and IC objectives; • Any intrusive work is conducted in a safe manner to ensure workers are protected; and • Any impacted groundwater that exceeds relevant regulatory criteria is appropriately handled and properly disposed of. The following ICs would be applied to FT-03:

• Any changes in land use, including construction of new facilities or additions to existing facilities at FT-03 must be reviewed and approved through the Andrews AFB Facility Review Board, which interacts with the Community Planner using the Base General Plan as a guide to land use issues; • The Base General Plan would be updated to include restrictions at FT-03. All ER Program sites and restrictions at Andrews AFB are identified in the Base General Plan. Any proposed activity or construction on an ER Program site requires an "ER Program Waiver to Construct" memorandum, approved and signed by USAF Headquarters, Air Force District Washington; • Signs would be posted at the site identifying FT-03 as a CERCLA site, summarizing the nature of contamination at the site, and stating that construction or excavation activities and groundwater use are not permitted within the area without written authorization by the USAF. Contact information for the ER Program project manager would also be included on the signs; • Environmental personnel would review Work Orders and Dig Permits to ensure that potable groundwater wells and intrusive digging do not occur at FT-03; and • Potable use of groundwater would continue to be prohibited at FT-03 (as it is across Andrews AFB, in general). COMAR 26.03.01.05 prohibits individual residents or businesses from using private water supply wells when public water supplies are available; therefore, the installation of groundwater wells intended for potable use would not be approved.

2.9.4 Alternative 4: Excavation and Off-Site Disposal of Contaminated Soil and Institutional Controls with Monitoring Alternative 4 would include ICs and groundwater monitoring as in Alternative 3 and in addition, include the excavation and off-site disposal of approximately 2,400 cubic yards of contaminated soils from two discrete locations within Soil Exposure Area 1 to achieve the acceptable site-specific clean-up level for naphthalene (439 µg/kg). Following the completion of the soil removal and

Page 26 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

clearance sampling and analysis to ensure that soil COCs are reduced to acceptable levels, the ICs described for Alternative 3 would be employed along with a monitoring program to insure that the site-specific clean-up levels are achieved.

The groundwater monitoring periods associated with Alternative 4 are the same as those indicated for Alternative 3.

The monitoring program incorporated into Alternative 4 would be used to:

• Assess the effectiveness of the removal action to decrease the concentrations of the COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) below the established acceptable risk-levels; and • Collect groundwater data to establish trends in concentrations for naphthalene, benzo[a]pyrene, chromium, and arsenic, and assess whether additional action is required. If contaminant concentrations increase, an evaluation would be performed to statistically evaluate (using a Mann-Kendall test and trend analysis) the need for additional remedial action measures to protect human health and/or the environment. If remedial actions are necessary, they will be implemented via a ROD amendment.

The components of the monitoring program envisioned for Alternative 4 are the same as described for Alternative 3. The five-year reviews would determine if the remedy is still protective, or whether additional sampling or remediation is required at the site.

2.9.5 Alternative 5: In-Situ Chemical Oxidation and Institutional Controls with Monitoring Like Alternative 4, this alternative assumes the adoption of an RAO that would clean up the site soil to levels consistent with unlimited use and unrestricted exposure. Alternative 5 includes in-situ chemical oxidation (ISCO) using a slurry injection to treat two specific areas, DP01 and DP09, which exhibit the highest concentrations of naphthalene within the subsurface soil at FT-03. Following a confirmation sampling effort, the dosing requirements for the chemical oxidation injections would be calculated. The baseline sampling event would be followed by periodic monitoring, as described for Alternative 4. This information would be used to evaluate statistical trends (using a Mann-Kendall test and trend analysis) or possible rebounds in both soil and groundwater, which may require supplemental treatment to achieve the established cleanup levels.

The chemical oxidation treatment phase would be conducted prior to and in conjunction with the implementation of ICs and groundwater monitoring as described for Alternatives 3 and 4. It is anticipated that chemical oxidation injections would reduce the concentrations of benzo[a]pyrene, naphthalene, and arsenic to clean-up levels in less than five years. However, due to uncertainties in the timeframe required, costs for two five-year reviews are included.

Page 27 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

2.9.6 Common Elements and Distinguishing Features of Each Alternative One significant element common to Alternatives 1 through 4 is that contaminants would remain in the soil and groundwater at FT-03 for at least five years at concentrations above those consistent with unlimited use and unrestricted exposure. Alternatives 2 through 5 would also require ICs until naphthalene, benzo[a]pyrene, chromium, and arsenic concentrations in groundwater are consistent with site conditions that allow for unlimited use and unrestricted exposure to groundwater. However, ICs would remain in place for soil. Therefore, all alternatives would require five-year reviews, and for costing purposes in this ROD it is assumed that six five-year reviews will be conducted for Alternatives 2 through 4. Because Alternative 5 includes active treatment of soil and groundwater, two five-year reviews are assumed for costing purposes.

A distinguishing feature of Alternative 3 is the statistical evaluation of trends in concentrations of COCs requiring remediation during long-term monitoring. The statistical analysis (using a Mann- Kendall test and trend analysis) would allow for interpretation of data to determine if natural degradation is effectively remedying the groundwater or if active treatment of the groundwater contaminants could be warranted. This determination would be documented in future five-year reviews and achieved through a ROD amendment. A distinguishing feature of Alternatives 4 and 5 is the use of active treatment to achieve conditions favorable for decreasing COC concentrations in the soil and groundwater at FT-03 in a shorter timeframe than the other alternatives.

Alternative 1 does not include measures to prevent potential receptors from exposure to contaminants in subsurface soil or groundwater. Therefore, this alternative is not protective of human health and the environment. Alternative 2 includes ICs, which are protective of human health through limiting exposure to COCs; however, these controls are not accompanied by monitoring, which is needed to define when ICs can be terminated for groundwater. While Alternatives 3, 4, and 5 comply with ARARs, a distinguishing feature of Alternatives 4 and 5 is that incorporation of active treatment into these alternatives probably would achieve decreases in COC concentrations in a shorter timeframe than Alternative 3. Alternatives 3, 4 and 5 achieve long-term reliability through the use of groundwater monitoring, statistical evaluations of trends in concentrations of COCs (using a Mann-Kendall test and trend analysis), and implementation of ICs; however, Alternatives 4 and 5 also achieve long-term reliability through active treatment of COCs. Alternative 1 does not achieve long-term reliability because no action such as monitoring, active treatment, or controls would be taken. Alternative 2 may achieve long-term reliability but the protectiveness of the remedy would not be determined until the first five-year review.

Alternatives 3 through 5 would allow for unlimited use of, and unrestricted exposure to, groundwater once the concentrations of COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) are below acceptable risk-levels and an updated HHRA shows that reduced concentrations allow for unlimited use and unrestricted exposure. Alternatives 4 and 5 would achieve unlimited use and unrestricted exposure for soil. Under Alternatives 1 and 2, returning groundwater to unlimited use and unrestricted exposure may be possible through natural biodegradation, but site conditions cannot be verified without monitoring. While contaminants remain on-site, Alternative 1 does not provide measures to protect human health and the environment.

Page 28 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

As shown in Table 2-4, the present worth cost of Alternative 1 ($0) is the lowest cost of the five alternatives. The present worth cost of the other alternatives are: Alternative 2 ($105,000); Alternative 3 ($171,000); Alternative 4 ($1,293,000); and Alternative 5 ($641,000).

2.9.7 Expected Outcomes of Each Alternative Under Alternative 1, potential unacceptable risks to human health and the environment would likely continue. Under Alternative 2, ICs would be implemented to protect human health by preventing human contact with the site COCs, but there would be no mechanism for verifying any reduction in toxicity, mobility, or volume of the contaminants.

Alternatives 3, 4, and 5 would be protective of human health and the environment immediately through the use of ICs to prevent contact with the COCs in subsurface soil and groundwater. Alternatives 3 and 4 would likely allow for unrestricted groundwater use throughout the site at some point after five years, as compared to Alternative 5, which is estimated to require less time due to active subsurface treatment of groundwater and soil. The longer-term cleanup of FT-03 groundwater under Alternative 3, which is anticipated to return the groundwater to beneficial use and allow for unlimited use and unrestricted exposure to groundwater, is still a reasonable timeframe because ICs are appropriately protective and easily implementable for the foreseeable future at FT­ 03. The site is completely within the control of a USAF installation and is expected to continue to be used for recreational land use.

To gauge whether the groundwater is ready for unlimited use and unrestricted exposure, the site conditions would be monitored under Alternatives 3, 4, and 5 and a human health risk assessment would be conducted to document acceptable risk levels. If in the future the USAF determines that it would prefer that the land use be available for an alternative use, subsurface soils could be sampled and the results statistically analyzed (using a Mann-Kendall test and trend analysis) to determine if an acceptable risk level has been reached.

If acceptable risk levels in groundwater have been attained, then beneficial use has been restored to the shallow aquifer. If acceptable risk levels have been attained for benzo[a]pyrene, but not for arsenic and chromium, then a statistical comparison to background could determine whether background levels have been achieved for arsenic and chromium. Pursuant to CERCLA Section 104(a)(3)(A), naturally occurring substances are exempt from CERCLA response authority; thus hazardous substances, pollutants or contaminants determined to be background do not require response under CERCLA.

2.10 Summary of Comparative Analysis of Alternatives

The five remedial alternatives discussed above were evaluated individually and comparatively against the nine criteria identified in the NCP at 40 CFR 300.430(e)(9)(iii) to help select a preferred alternative. Table 2-5 summarizes how well each alternative satisfies each evaluation criterion and indicates how it compares to the other alternatives under consideration. A more detailed analysis and evaluation is presented in the FFS for FT-03. The purpose of this analysis is to identify the

Page 29 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008 relative advantages and disadvantages for each of the five alternatives.

The NCP, at 40 CFR 300.430(f)(1)(i), divides the nine evaluation criteria into three groups: threshold, primary balancing, and modifying criteria. To be considered for remedy selection, an alternative must meet the two following threshold criteria:

1. Overall protection of human health and the environment; and 2. Compliance with ARARs or ARAR waiver in accordance with CERCLA Section 121 (d)(4).

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

3. Long-term effectiveness and permanence; 4. Reduction in toxicity, mobility, or volume through treatment; 5. Implementability; 6. Short-term effectiveness; and 7. Cost. Then, the alternatives are considered against the modifying criteria to determine if the selected remedy should be modified in light of new information or opinion. The modifying criteria are: 8. State acceptance; and 9. Community acceptance. These criteria are discussed below as applied to the potential remedial alternatives identified for the FT-03 site.

2.10.1 Threshold Criteria The “no action” alternative does not meet the threshold criteria as it is not protective of human health and the environment because the site is not currently safe for unlimited use and unrestricted exposure. All of the other alternatives meet the threshold criteria because they would protect human health and the environment for current and reasonably anticipated future uses. All of the alternatives comply with ARARs because concentrations of COCs do not exceed MCLs or action levels.

2.10.2 Balancing Criteria Alternative 2 is not fully effective over the long term. Although there is no risk from groundwater under current land use conditions, this alternative does not include monitoring, and therefore would not provide information verifying that additional releases from subsurface soil to groundwater are not occurring. Alternatives 3, 4, and 5 would be equally effective over the long term. Since there are presently no plans to convert the golf course at FT-03 to residences in the short- or long-term, and the contamination at the site is present at very low concentrations well beneath the ground surface, active treatment (Alternatives 4 and 5) to remediate site contamination would serve merely to

Page 30 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

shorten the time until the site conditions allow for unlimited exposure and unrestricted use. Alternative 2 requires limited on-site activities, such as posting signs, and therefore poses virtually no risk during implementation. Alternative 3 would pose a minimal risk because on-site activities are restricted to posting signs and inspecting for compliance with ICs and periodic sampling of groundwater wells. Alternatives 4 and 5 would pose greater risks than Alternative 3 because on-site remedial activity could result in human contact with COCs and other safety risks. Alternative 4 would require approximately 200 trucks moving about 3,600 tons of soil off-site. This activity could contribute to air contamination from fugitive dust and to increased noise and traffic off-site. Alternative 5 would require further on-site soil sampling and analysis to plan the injection grid, handling of large quantities of a chemical oxidation agent, and operation of large machinery to accomplish the injections. Only Alternative 5 includes treatment to reduce toxicity, mobility or volume. All alternatives can be implemented. Alternatives 4 and 5 would require substantial coordination with golf course managers. Both alternatives would require shutting down the golf course while the soil remediation is conducted. In the case of Alternative 4, this closure would involve a substantial period of time and require rebuilding that portion of the golf course. Alternative 1 has no associated costs and fails to meet threshold criteria. Alternatives 2 and 3 have similar costs, with Alternative 3 being somewhat more costly but providing more information about site conditions and control over when ICs can be discontinued. Alternative 5 is almost four times as costly as Alternative 3, while Alternative 4 is approximately twice the cost of Alternative 5 or over seven times the cost of Alternative 3. Given that implementation of neither Alternative 4 nor 5 is necessary for the site to be protective under the current or planned-future land use, these costs are disproportionate to their level of effectiveness.

2.10.3 Modifying Criteria This ROD has been developed in cooperation with the MDE and the Prince George’s County Health Department, both of which have concurred with the selection of Alternative 3 as the remedy for FT­ 03. Other than the discussions at the public meeting held on February 21, 2008 (see Section 3.3 and Appendix C), no public comment was received by the USAF on the PRAP for site FT-03.

2.11 Principal Threat Wastes

The NCP, at 40 CFR 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 NPL sites. A source material is material that includes or contains hazardous substances, pollutants, or contaminants that act as a reservoir for migration of contamination to groundwater, surface water, or air, or acts as a source for direct exposure. Contaminated groundwater generally is not considered to be a source material. Principal threat wastes are those source materials that are highly toxic or highly mobile that generally cannot be reliably contained or would present a significant risk to human health or the environment should exposure occur.

Page 31 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

There are no principal threats at the FT-03 site. The contaminants identified at the FT-03 are at low concentrations (most only slightly above residential RBCs), which will not act as a source for further degradation of groundwater. In addition, the COCs are not highly toxic or highly mobile.

2.12 Selected Remedy for Soil and Groundwater

The remedy selected in this ROD is Alternative 3, ICs and monitoring. The remedy was selected in recognition of the following site circumstances:

• There is no current or likely future unacceptable risk presented because the land use is expected to remain as recreational; and • Future potable use of shallow groundwater at the site is extremely unlikely because drinking water wells are prohibited by State of Maryland regulation at this location.

In addition, the migration of contaminants from the site via groundwater is not likely, since detections are already below MCLs at the site. This alternative provides acceptable protection of human health and the environment, will be in compliance with ARARs, and will be cost effective. Furthermore, the ICs implemented pursuant to Alternative 3 will prevent the potable use of shallow groundwater and limit dermal contact with shallow groundwater as long as it poses risks that are unacceptable for unlimited use and unrestricted exposure. The Alternative 3 monitoring program will require the installation of additional monitoring wells to collect groundwater data over time to monitor the concentrations of COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) and document changes, if any, to determine if the remedy is still protective for the five-year reviews. The monitoring data will be evaluated through statistical measures (using a Mann-Kendall test and trend analysis) to determine if changes to the monitoring frequency (increase, decrease or possibly terminate) are appropriate, or if ICs alone are protective of human health based upon a human health risk assessment for naphthalene, benzo[a]pyrene, chromium, and arsenic in groundwater. In addition, the monitoring data will be used to evaluate whether areas within FT-03 require active treatment if the COC concentrations increase.

2.12.1 Rationale for the Selected Remedy Based on the evaluation of the remedial alternatives, Alternative 1 was dismissed because the “No Action” alternative does not include ICs and therefore does not protect human health and the environment. Alternative 2 includes ICs and is, therefore, protective of human health, but it is not accompanied by a monitoring program to ensure that COC concentrations do not increase (rebound) and to determine statistically whether or not site-specific risk-based levels in groundwater have been achieved. Alternative 4 includes active treatment of soil but not of groundwater, so the time for degradation of COCs in groundwater would be the same as for Alternative 3. Alternative 4 also poses more short-term risks in implementation and would cost over seven times more than Alternative 3. Finally, Alternative 5 actively treats soil and groundwater, which would speed reduction of COC concentrations but is almost four times more costly than Alternative 3, when the site poses no unacceptable risk to human health under the current and planned-future land use.

Page 32 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

Given the lack of risk under current land use, Alternative 3 is far more cost effective than Alternative 5.

Based on the detailed evaluation of alternatives, Alternative 3 best satisfies the evaluation criteria and is, thus, the selected remedy. This alternative provides protection of human health and the environment, will be in compliance with ARARs, and will be cost effective. It is anticipated that this alternative will reduce the magnitude of risks identified at FT-03 to acceptable levels within a reasonable timeframe. The future use of shallow groundwater at the site as a potable source or for bathing/showering is extremely unlikely since potable water is presently provided by WSSC and drinking water wells are prohibited by Maryland regulation when public water is available. The migration of COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) via groundwater from the site will be limited because groundwater at FT-03 is stationary or very slow moving. Additionally, the ICs implemented using Alternative 3 will prevent the potable use of shallow groundwater and limit dermal contact with shallow groundwater. Groundwater monitoring wells will be installed to monitor the COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) until the concentrations in groundwater decrease to levels that allow for unlimited use and unrestricted exposure. ICs will be maintained for soil until there is no unacceptable level of risk to future child/adult residents who could be exposed via inhalation of volatilized naphthalene in indoor air. Alternative 3 will also include a long-term groundwater monitoring program to establish trends in concentrations of COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic). Groundwater monitoring wells will be installed to effectively conduct this component of the remedy. As part of the CERCLA-mandated five-year review process, the concentrations of all COCs will be evaluated to determine whether the remedy is still protective. The monitoring data will be used to evaluate the monitoring program at FT-03 to determine if the monitoring frequency may be modified (increased, decreased, or terminated) or if active treatment is required. If the monitoring program is altered, these changes along with supporting data would be documented. If it is determined that treatment of groundwater is required because the COC concentrations have increased or if natural degradation is not sufficient to decrease concentrations over a reasonable time, a proposed plan will be issued for public comment prior to a ROD amendment. The proposed plan would detail the objectives of the treatment as well as cleanup criteria.

Based on information currently available, the USAF believes the selected remedy meets the threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria. The USAF expects the selected remedy to satisfy the following statutory requirements of CERCLA Section 121, 42 U.S.C. § 9621: (1) be protective of human health and the environment; (2) comply with ARARs; and (3) be cost-effective.

Andrews AFB and the USEPA, with concurrence from MDE, agree on Alternative 3 as the selected remedy for site FT-03.

2.12.2 Detailed Description of the Selected Remedy The primary components of Alternative 3 are to:

Page 33 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

• Install groundwater monitoring wells and perform groundwater monitoring to determine concentration trends of COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) through statistical evaluation (using a Mann-Kendall test and trend analysis) and to serve as the basis for conducting five-year reviews. The monitoring program will continue to be implemented until a human health risk assessment demonstrates achievement of acceptable risk levels. If the groundwater monitoring program is altered, changes will be concurred upon by USEPA before implementation and then documented and subsequently reported in the five-year review report; • Implement and maintain ICs to restrict land use to ensure that residential use does not occur, industrial uses are protective, and construction workers are appropriately protected (until such time as a change in land use is approved in accordance with Section 2.12.2.2); and • Implement and maintain ICs for groundwater until a human health risk assessment demonstrates achievement of acceptable risk levels.

2.12.2.1 Groundwater Monitoring and Statistical Trend Evaluations The components of the groundwater monitoring program to be implemented at FT-03 include: • Installation of Groundwater Monitoring Wells to conduct the groundwater monitoring program. The number of groundwater monitoring wells and their locations will be determined and concurred upon by USEPA as part of the remedial design/remedial action work plan. • Semi-Annual Sampling for the first two years of groundwater monitoring. If a COC (naphthalene, benzo[a]pyrene, chromium, and arsenic) is not detected after four consecutive sampling events, it will be dropped as a COC. • Annual Sampling during years three, four and five of the first five-year cycle (three sampling events total). • Statistical Analysis of Monitoring Data (using a Mann-Kendall test and trend analysis) to assess trends in naphthalene, benzo[a]pyrene, chromium, and arsenic concentrations. If a rebound in the COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) is observed, the monitoring frequency may need to be increased to provide sufficient information for a protectiveness determination in the next five-year review. • Five-Year Reviews to confirm the concentration or absence of COCs at the FT­ 03 site and to determine if human health and the environment are continuing to be protected by the remedy. The data gathered will also be used to evaluate the long-term monitoring program and to determine if the groundwater monitoring program should be increased, decreased, or remain unaltered for another five-year review cycle; or if more active/aggressive remedial action is needed to achieve unlimited use and unrestricted exposure. The data collected for the long-term

Page 34 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

monitoring program will be analyzed and relied upon to support proposed changes to the monitoring frequency as well as to determine if site conditions allow for unlimited use and unrestricted exposure such that ICs can be eliminated. After the first five years following implementation of the remedy, the groundwater monitoring program will continue at five-year intervals until concentrations of COCs (naphthalene, benzo[a]pyrene, chromium, and arsenic) have decreased to allow for unlimited use and unrestricted exposure. Six five­ year reviews were included for purposes of estimating remedial costs.

2.12.2.2 Institutional Controls As discussed in Section 2.9.3, ICs are necessary to protect human health. The IC objectives are to ensure that:

• Groundwater is not used as drinking water; • Construction activities on-base do not interfere with required monitoring; • The site is not used for residential purposes; • Any proposed changes in land use are evaluated for consistency with acceptable risk-levels; • Any intrusive work is conducted in a safe manner to ensure workers are protected; and • Any impacted groundwater that exceeds relevant regulatory criteria is appropriately handled.

The USAF is responsible for implementing, monitoring, maintaining, reporting on and enforcing the ICs at FT-03. Under Alternative 3, the site (exact area shown in Figure 2-8) will be designated as a “restricted use” area in the base Geographic Information System (GIS). This designation prohibits activities such as residential development or use of groundwater. Additionally, groundwater use is currently restricted, as documented in the Base General Plan, and procedures are in place to limit contact with groundwater through the issuance of permits to conduct subsurface work or activities. Records of the groundwater contamination will be kept in the base GIS/environmental database. The restricted-use designation will remain in place until groundwater monitoring indicates that acceptable risk-levels are achieved.

Any activity that is inconsistent with the IC objectives or use restrictions, or any other action that may interfere with the effectiveness of the ICs will be addressed by the USAF as soon as practicable. In no case will the process be initiated later than 10 days after the USAF becomes aware of the breach. The USAF will notify USEPA and MDE regarding how the USAF has addressed or will address the breach within 10 days of sending USEPA and MDE notification of the breach. The ICs can be modified as new data are analyzed; however, the USAF will not modify or terminate ICs, implementation actions, or modify land use without approval by USEPA and the MDE. The USAF

Page 35 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

will seek prior concurrence before any anticipated action that may disrupt the effectiveness of the ICs or any action that may alter or negate the need for ICs.

The following ICs will be applied to FT-03:

• Any changes in land use, including construction of new facilities or additions to existing facilities at FT-03 must be reviewed and approved through the Andrews AFB Facility Review Board, which interacts with the Community Planner using the Base General Plan as a guide to land use issues; • The Base General Plan will be updated to include restrictions at FT-03. All ER Program sites and restrictions at Andrews AFB are identified in the Base General Plan. Any proposed activity or construction on an ER Program site requires an “ER Program Waiver to Construct” memorandum, approved and signed by USAF Headquarters, Air Force District Washington; • Signs will be posted at the site identifying FT-03 as a CERCLA site, summarizing the nature of contamination at the site, and stating that construction or excavation activities and groundwater use are not permitted within the area without written authorization by the USAF. Contact information for the ER Program project manager will also be included on the signs; • Environmental personnel will review Work Orders and Dig Permits to ensure that any intrusive subsurface activities do not occur unless appropriate health and safety measures are implemented at FT-03; and • Potable use of groundwater will continue to be prohibited at FT-03 (as it is across Andrews AFB, in general). COMAR 26.03.01.05 prohibits individual residents or businesses from using private water supply wells when public water supplies are available; therefore, the installation of groundwater wells intended for potable use will not be approved by the state.

Monitoring of the environmental use restrictions and controls will be conducted annually by Andrews AFB. The monitoring results will be included in a separate report or as a section of another environmental report, if appropriate, and provided to USEPA and MDE for informational purposes only. The monitoring reports will be used in preparation of the five-year reviews to evaluate the effectiveness of the remedy. The monitoring reports will evaluate the status of the ICs and how any IC deficiencies or inconsistent uses have been addressed. Andrews AFB shall notify USEPA and MDE 45 days in advance of any proposed land use changes that are inconsistent with IC objectives or the selected remedy.

2.12.3 Summary of the Estimated Remedy Costs The estimated present worth cost of the selected remedy, based on a 5.1 percent real discount rate over a time period of 30 years, is approximately $171,000.

Page 36 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

The cost estimate was based on the best available information regarding the anticipated scope of the remedy. A contingency factor of 20 percent was included in the capital, O&M, and periodic costs. The details of the cost estimate for the selected remedy are presented in Table 2-6. Changes in the cost elements may occur as a result of new information and data collected during implementation of the remedy. This order-of-magnitude engineering cost estimate is expected to be within +50 to -30 percent of the actual project cost.

2.12.4 Estimated Outcomes of Selected Remedy The desired outcome of implementing Alternative 3 at the site is to:

• Protect human receptors from exposure to contaminated subsurface soil; and • Restrict the use of shallow groundwater until the shallow groundwater does not pose a risk.

The site COCs are likely to reach site-specific acceptable risk-levels in groundwater within a reasonable timeframe. If the groundwater monitoring program and statistical analysis indicates that COCs are increasing in concentration or degrading very slowly, more aggressive treatment may be required that will speed up the time required to achieve the acceptable risk-levels. However, treatment is not a component of Alternative 3 and an amendment to this ROD would be required to treat the COCs at FT-03.

The anticipated community impacts of the selected remedy are the potential availability of additional groundwater for possible drinking water in the future. The anticipated environmental benefit of the selected remedy is eventual restoration of the aquifer to its original condition prior to environmental releases from FT-03.

2.13 Statutory Determinations for Groundwater Remedy

The selected remedy for groundwater satisfies the statutory requirements of Section 121 of CERCLA, 42 U.S.C. Section 9621. Under CERCLA, remedial actions at sites must achieve protection of human health and the environment, comply with federal and state ARARs, be cost­ effective, and utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable. In addition, remedies that employ treatment that permanently and significantly reduces the volume, toxicity, or mobility of hazardous wastes as a principal element are preferred. The selected remedy does not include treatment because employing a treatment option at FT-03 would have rendered the remedy cost ineffective.

The selected remedy satisfies the threshold criteria of protection of human health and the environment and compliance with federal and state ARARs. The selected remedy also satisfies all balancing criteria and modifying criteria and was determined by USAF and USEPA to be the most appropriate solution for the site. The criteria that were most decisive in the selection of the remedy were overall protection of human health and the environment, compliance with ARARs, implementability, and cost-effectiveness. USAF and USEPA also considered the two modifying

Page 37 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

criteria (i.e., state and community acceptance) in selection of the remedy. No written comments were received that disagreed with the selected remedy. Comments received during the public meeting are discussed in the Responsiveness Summary in Section 3.0 below. No comments were received during the public meeting that disagreed with the proposed alternative detailed in the proposed remedial action plan.

2.13.1 Protection of Human Health and the Environment The selected remedy for groundwater will be protective of human health and the environment. ICs will prevent direct exposure to contaminated groundwater and soil containing COCs above acceptable levels. There are no short-term threats associated with the selected remedy for soil and groundwater that cannot be readily controlled. In addition, no adverse cross-media impacts are expected from the selected remedy. Monitoring and statistical evaluation (using a Mann-Kendall test) of trends in concentrations of COCs will ensure that the selected groundwater remedy is effective and that the COCs are not expanding or unexpectedly increasing in concentration. If statistical trends indicate that COC concentrations will not meet acceptable risk-levels within the anticipated time for remediation, either additional treatment will be proposed for the site with a proposed ROD amendment or the remedy will be continued as ICs with groundwater monitoring at five-year intervals.

2.13.2 Compliance with ARARs The selected remedy complies with all chemical- and action-specific ARARs because groundwater COC concentrations are all currently below MCLs and investigation-derived waste (groundwater samples) will be handled and disposed of in accordance with applicable regulation. No location­ specific ARARs were identified for the site. The ARARs identified for the selected remedy are chemical-specific MCLs and the state’s anti-degradation of groundwater quality requirement.

2.13.3 Cost Effectiveness According to the NCP at 40 CFR 300.430(f)(1)(ii)(D), a remedy is cost-effective if its costs are proportional to its overall effectiveness. USAF and USEPA have determined that the selected remedy is cost-effective. Overall effectiveness was evaluated by assessing three of the five balancing criteria in combination (long-term effectiveness and permanence; reduction in toxicity, mobility, or volume through treatment; and short-term effectiveness). Overall effectiveness was then compared to costs to determine cost effectiveness. The estimated total present worth of the selected remedy for both soil and groundwater is $171,000, which is just under four times less than the present worth of the second-ranked alternative (Alternative 5). The selected remedy is expected to be equally as effective as Alternative 5 for purposes of long-term effectiveness and permanence. Alternative 5 is more effective in reduction in toxicity, mobility, or volume through treatment because the treatment component of Alternative 5 would speed degradation of COCs faster than natural processes. However, natural processes, without treatment, are also expected to result in reduction of COCs over a reasonable time. Alternative 5 would likely be equally as effective as the selected remedy for short-term effectiveness because, although Alternative 5 is predicted to achieve site-specific clean-up levels sooner than the selected remedy, Alternative 5 would require on-site work that would present more risk of injury than implementation of the selected remedy. Because

Page 38 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

the USAF can effectively enforce ICs for the duration of either the selected remedy or Alternative 5, a longer timeframe to complete the remedy will not present a greater risk to human health or the environment. Thus, because the selected remedy is far less costly while providing the same level of protection to receptors under the current and planned-future land use, the selected remedy is the more cost-effective alternative.

2.13.4 Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery) Technologies to the Maximum Extent Practicable The USAF and USEPA, with MDE concurrence, have determined that the selected remedy represents the maximum extent to which permanent solutions and treatment technologies can be utilized in a practicable and cost-effective manner at the site. USAF and USEPA have determined that the selected remedy provides the best balance of trade-offs in terms of the five balancing criteria and that utilization of treatment technologies at FT-03 would render the selected remedy cost­ ineffective. Groundwater ICs will remain until acceptable risk levels are achieved. ICs for soil will remain in place unless future soil sampling documents that site conditions allow for unlimited use and unrestricted exposure.

2.13.5 Five-Year Review Requirements Since the selected remedy for soil and groundwater will result in hazardous substances, pollutants, or contaminants remaining on site, a review will be conducted no later than five years after initiation of the remedial action, in accordance with CERCLA Section 121(c). The purpose of this five-year review is to ensure and document that ICs are being implemented and that the remedy is still protective of human health and the environment. Six five-year reviews were included for purposes of estimating remedial costs.

2.14 Documentation of Significant Changes

The PRAP for FT-03 soil and groundwater at Andrews AFB, Prince George's County, Maryland, was released for public comment on February 7, 2008. The PRAP identified groundwater monitoring and ICs for soil and groundwater as the preferred alternative. The USAF and USEPA considered all comments received during the public comment period. This ROD includes costs for five-year reviews projected to be required for Alternatives 2 through 5. Thus, the cost estimates for the alternatives presented in the PRAP and issued for public comment differed from those presented here in the final ROD. The cost estimate for Alternative 2 increased from $59,000 in the PRAP to $105,000 or $46.000; Alternative 3 increased from $142,000 to $171,000; Alternative 4 increased from $1,263,000 to $1,293,000; and Alternative 5 increased from $636,000 to $641,000. The change from the PRAP to the ROD is only significant for Alternative 2 because the cost estimate increased by more than 50 percent for that alternative. It was determined that no other significant changes to the remedy, as originally identified in the PRAP, were necessary or appropriate.

Page 39 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

3.0 RESPONSIVENESS SUMMARY

The Responsiveness Summary provides a summary of the public's comments, concerns, and questions about the FT-03 soil and groundwater remedial action and the USAF's responses to these concerns.

The public comment period for the proposed remedy for FT-03 began on February 7, 2008. A public meeting was held on February 21, 2008, to describe the proposed remedy and to solicit and accept either written comments or verbal comments. The Notice of the Public Meeting was published on February 7, 2008, in the Star Community News section of the Prince George's County Gazette and again in the Washington Post-Prince George's “Extra” weekly edition on February 14, 2008. The notice was also placed in the Andrews AFB newspaper, The Capital Flyer, on February 8, 2008. Copies of the Public Notice published in these newspapers and the summary transcript from the public meeting are presented in Appendices B and C, respectively.

3.1 Overview

At the time of the public comment period, USAF had endorsed a preferred alternative (Alternative 3) for FT-03. The preferred alternative (i.e., groundwater monitoring and institutional controls (ICs) to address COCs in soil and groundwater at FT-03) presented to the public in the Proposed Remedial Action Plan (PRAP) is the selected remedy in this ROD.

No written public comments were received during the public comment period. Oral comments were received during the public meeting. One commenter inquired about the CERCLA process and FT­ 03, and Mr. Brian Dolan provided an oral summary of the PRAP, discussed the site history, and provided a hard copy of the PRAP to the commenter.

3.2 Background on Community Involvement

The USAF has maintained a public involvement and information program for the ER Program since 1990. The Administrative Record is the collection of documents that were relied upon to make remediation decisions and includes items that document public participation in the remediation process. The Administrative Record is a growing archive, and is located at the Environmental Flight, 3466 North Carolina Avenue, Andrews AFB, Maryland.

The publicly available copy of the Administrative Record is called the Information Repository. The Information Repository is contained on a set of CD-ROMs that consists of scanned images and fact sheets. The Information Repository contains the RI and FFS reports, the reports from previous investigations, and news releases. The Information Repository is updated to reflect additions to the Administrative Record.

Page 40 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

To review the Information Repository, visit:

Prince George's County Memorial Library-Surratts-Clinton Branch 9400 Piscataway Road Clinton, Maryland 20735 Phone (301) 868-9200

Andrews AFB does not have a Restoration Advisory Board at this time. Andrews AFB uses community groups to solicit input regarding environmental activities at the base, as well as newsletter/fact sheet mailings to share information with the community.

In February 2007, the base published and distributed to the surrounding community an ER Program newsletter, which discussed the environmental activities being conducted at FT-03. In addition, Andrews AFB has a website, http://www.andrews.af.mil/environmental, which the public can access for general information about environmental programs at Andrews AFB. Notices of public meetings are posted in local newspapers to encourage public involvement.

Andrews AFB community relations activities for the final selected remedy for FT-03 groundwater are listed below:

• The primary documents concerning the investigation and analysis of FT-03 groundwater and soil (i.e., RI and FFS Reports), as well as copies of the PRAP, were placed in the Information Repository. • Newspaper announcements on the availability of documents and the public meeting and comment period were published in the Star Community News section of the Prince George's County Gazette and the Washington Post-Prince George's “Extra” weekly edition on February 7, 2008 and February 14, 2008, respectively. The notice was also placed in the Andrews AFB newspaper, The Capital Flyer, on February 8, 2008. • A 30-day public comment period for the PRAP was established by the Air Force starting on February 7, 2008 and ending on March 7, 2008. • A public meeting was held on February 21, 2008, to present the PRAP, explain the proposed remedy for FT-03 soil and groundwater, and answer any questions the public had concerning FT-03 groundwater and soil.

3.3 Summary of Comments Received During the Public Comment Period and Air Force Responses

Two people attended the public meeting on February 21, 2008. There were questions and discussions about FT-03 and other sites at Andrews AFB. Discussions on FT-03 focused on the site history, the proposed plan for the site, and if the site presented a risk to the surrounding communities. One commenter inquired about the CERLA process and FT-03. Mr. Brian Dolan provided an oral summary of the PRAP, discussed the site history, and provided a hard copy of the

Page 41 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

PRAP to the commenter. Mr. Dolan explained that the preferred alternative is groundwater monitoring and ICs because the remedial investigation did not detect any significant contamination in soil and groundwater at the site. He also stated that the soil contamination is at levels that are not expected to impact groundwater in the future, that FT-03 is currently beneath the 14th hole green, 15th hole tee box, and 17th hole fairway of the South Golf Course, and that recreational use is expected to be maintained now and in the future. No comments questioned the preferred alternative presented in the PRAP. A summary transcript of the discussions at the meeting is provided in Appendix C of this ROD.

The USAF and the USEPA continue to believe that groundwater monitoring and ICs adequately and appropriately address soil and groundwater contamination at FT-03 in accordance with CERCLA Section 121 and the NCP.

Page 42 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

4.0 REFERENCES

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CH2M Hill, 2004. Final Basewide Background Study Report, Andrews Air Force Base, Maryland. March.

CH2M Hill, 2005. Final Basewide Ecological Risk Assessment Report – Step 7, Andrews Air Force Base, Maryland. March.

Cooke, 1952. Sedimentary Deposits of Prince George's County (Maryland) and the District of Columbia: Maryland Department of Geology, Mines, and Water Resources, Bull. 10, p. 1-53.

Cowherd, et al., 1985. Cowherd, C., Muleski, G., Engelhart, P., and Gillete, D., "Rapid Assessment of Exposure to Particulate Emissions from Surface Contamination," 1985. Prepared for U.S. EPA Office of Health and Environmental Assessment. EPA/600/8­ 85/002.

Dames and Moore, 1992. Technical Memorandum for the FT03 Site, Andrews Air Force Base, Maryland, prepared for Hazardous Waste Remedial Action Program, Martin Marietta Energy Systems Inc. Oak Ridge, Tennessee under General Order No. 70B­ 99786C Work Release No. K-06. October.

Darton, N.H., 1948. The Marlboro Clay: Economic Geology, v. XLIII, no. 2, p. 154-155.

Earth Tech, 2000. Environmental Assessment for Construction of Squadron Operations Facility and Demolition of Building 1622 at Andrews Air Force Base, Maryland, prepared for Air Force Center for Environmental Excellence, Brooks AFB, Texas. May.

Earth Tech, 2004a. Final Work Plan for the Remedial Investigation, FT-03, Fire Training Area 2, Andrews AFB, Maryland. July.

Earth Tech, 2004b. Final Field Sampling Plan for the Remedial Investigation, FT-03, Fire Training Area 2, Andrews AFB, Maryland. July.

Earth Tech, 2004c. Final Health and Safety Plan for the Remedial Investigation, FT-03, Fire Training Area 2, Andrews AFB, Maryland. July.

Earth Tech, 2004d. Final Quality Assurance Project Plan for the Remedial Investigation, FT­ 03, Fire Training Area 2, Andrews AFB, Maryland. July.

Page 43 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

Earth Tech, 2007. Final Remedial Investigation Report, FT-03, Fire Training Area 2, Andrews AFB, Maryland. October.

Engineering Science, 1985. Phase I Records Search, Installation Restoration Program, Andrews AFB, Maryland, prepared for the U.S. Air Force, AFESC/DEV, and HQ MAC/DEEV. June.

Foster and Chrostowski, 1987. Inhalation Exposures to Volatile Organic Contaminants in the Shower. ICF-Clement Associates, Inc. Washington D.C.

Glenn and Sadler Associates, Inc., 1995. Soil Investigation at FT-03 for the Golf Course Addition, Andrews Air Force Base, Maryland, NAF Projects: AJXF955001, A&E Contract: N62470-93-D-4049. August 28, 1995.

IT Corporation, 2000a. Installation-Wide Sampling and Analysis Plan Andrews Air Force Base, Maryland, prepared for Air Force Center for Environmental Excellence.

IT Corporation, 2000b. Installation-Wide Health and Safety Plan, Andrews Air Force Base, Maryland, prepared for Air Force Center for Environmental Excellence, Brooks AFB. July.

IT Corporation, 2000c. Installation-Wide Quality Assurance Project Plan, Andrews Air Force Base, Maryland, prepared for Air Force Center for Environmental Excellence, Brooks AFB, Draft Final. April.

IT Corporation, 2002. Preliminary Groundwater Sampling Results, FT-03. MACTEC, Inc., 2003. Preliminary Groundwater Sampling Results, FT-03. Maichle, Singh & Singh, 2004. ProUCL Version 3.02 User's Guide.

MDE, 2001. Maryland Department of the Environment. Summary Report: "Update to the Soil and Groundwater Cleanup Standard." August 15, 2001.

NRC, 1983. National Research Council. Risk Assessment in the Federal Government: Managing the Process. National Academy Press, Washington, D.C.

NRC, 1994. National Research Council. Science and Judgment in Risk Assessment. National Academy Press, Washington, D.C.

NATO/CCMS, 1988. North Atlantic Treaty Organization Committee on the Challenges of Modern Society. Scientific basis for the development of the International Toxicity Equivalency Factor (I-TEF) method of risk assessment for complex mixtures of dioxins and related compounds. Report No. 178. December.

Rodricks, Joseph, 1992. Calculated Risks: The toxicity and human health risks of chemicals in our environment. Cambridge University Press, Cambridge.

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SRC, 2005. Syracuse Research Corporation. CHEMFATE Environmental Fate Database. November. http://www.syrres.com/esc/chemfate.htm.

Tetra Tech, Inc., 1996. Final ERP RCRA Facility Investigation/Correction Measures Study Technical Report, Andrews AFB, Maryland, prepared for the Air Force Center for Environmental Excellence, HSC/PKCVCB Headquarters Human System Center (AFMC), Brooks Air Force Base, Texas. April.

TOXNET, 2004. Databases in Toxicology and Environmental Health. Hazardous Substances Data Bank, National Library of Medicine, Specialized Information Services, access via internet at http://sis.nlm.nih.gov/Tox/ToxMain.html

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USDA, undated. Soil Survey of Andrews Air Force Base.

USEPA, 1989a. Risk Assessment Guidance for Superfund, Volume I. Human Health Evaluation Manual (Part A) Interim Final. Office of Solid Waste and Emergency Response. Washington, D.C. December. EPA/540/1-89-002.

USEPA, 1990. Final National Contingency Plan. March.

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Page 45 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

and Reasonable Maximum Exposure, Draft.

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USEPA, 1998. RCRA, Superfund & EPCRA Hotline Training Module. Introduction to: Applicable or Relevant and Appropriate Requirements. EPA540-R-98-020, OSWER 9205.5-10A, PB98-963 228. USEPA, 2000a. Draft Exposure and Human Health Reassessment of 2,3,7,8­ Tetrachlorodibenzo-p-Dioxin (TCDD) and Related Compounds, Part I: Estimating Exposure to Dioxin-like Compounds, vol. 2 (Sources of Dioxin-like Compounds in the United States), and Part II: Health Assessment for 2,3,7,8-Tetrachlorodibenzo-p­ dioxin (TCDD) and Related Compounds, Chapter 9. Toxicity Equivalence Factors (TEF) for Dioxin and Related Compounds. Office of Research and Development, Washington, D.C. NCEA-I-0836. May. USEPA, 2001a. Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation Manual (Part D, Standardized Planning, Reporting, and Review of Superfund Risk Assessments), Final, Office of Emergency and Remedial Response, OSWER Directive 92857-47. December. USEPA, 2001b. Toxicological review of chloroform. In Support of the Summary Information on the Integrated Risk Information System. EPA/635/R-01/001. October. USEPA, 2002a. Supplemental Guidance for Development of Soil Screening Levels for Superfund Sites, Office of Emergency and Remedial Response, OSWER Directive 9355.4-24. December.

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Page 47 FT-03, Fire Training Area 2 Andrews Air Force Base, MD Record of Decision September 2008

Van den Berg et al., 1998. Toxic Equivalency Factor for PCBs, PCDDs, PCDFs for Human and Wildlife. Environmental Health Perspectives, Volume 106, Number 12. December.

Page 48

Figures

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1960 Aerial Photo Showing Former Fire Drawn By: DWC Project No.: ROD FT-03

Training Area Near Central Portion of FT-03 Checked By: RB File Name: Aerial Photo

Date: May 2008 Figure No.: 2-3 ---- FT-03 Boundary. Note: Base image is a light detection and ranging (LIDAR) image, 2004. FT-03 ROD Andrews AFB, Maryland Aerial Photograph, Year 2008 Golf Course Drawn By: DWC IProject No.: ROD FT-03 Checked By: RB File Name: Aerial Photo

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03 Boundary <> -N­

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Date: May 2008 Figure No.: 2-5 <>

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\Iron @ 27,000 J.l~ , Manganese @ 230 J.lg/L

Benzo(a)pyrene @ 0.14 J.lg/L Groundwate Iron @ 58,500 J.lglL Exposure -""--Manganese@ 470 ~ ~__~ Arl enzo(a)pyrene @ 0.12 J.lglL Benzo(a)pyrene\@ 0.17 J.lg/L

---- FT-03 Boundary. Note: Base image is a light detection and ranging (LIDAR) image, 2004. FT-03 ROD Andrews AFB, Maryland Groundwater Sampling Locations With Drawn By: DWC Project No.: ROD FT-03 Checked By: RB File Name: Driving Risk Detected Concentrations (Jlg/L) Driving Potential Risk Date: May 2008 Figure No.: 2-6 Exposed Populations (Receptors) Historical Primary Secondary Cm'ent Curent Future Future Future Future Future Source/ Release Secondary Release Contaminated Exposure RecreationaJ. Maintenance RecreationaJ. M aintenance Conm-ou ction In dustriaJ. Child/Adult Operation Mechanism Sources Mechanism Medium Route Users Workers Users Workers Workers Workers"'''' Residents

MowingIP lantinglWorking .~ Ingestion X X .X .X .X .X .X 11 Surface Soil'" .. in Surface Soil H I~ Dennal contact X X .X .X .X .x .x

Dusts and Vapors from Inhalation X X .X .X .X .X .X ~I Air Surface Soil H H Paliiculates

Digging and Grading in ~ Ingestion X X X X X Subsurface Soil l'B H Subsurface Soil H !] Dennal contact X X X X X Fire Training Using Infiltration/ Dusts and Vapors from __ Inhalation-VOCs Air m f-----+I Flammable ~H Subsurface Soil f----t> Leaching/ ---+ Soil H m Inhalation-VOCs Liquids and Percolation Indoor f------1'j X X ••Co "',.k" . ~ ...... ~ Extinguishing Fluids Ingestion f----tJ X Dennal contact r------. X X .Infiltration / Leaching / Inhalation-VOCs f------* X X r---­ Groundwater Percolation H ~ Indoor . , Inhalation-VOCs f-----+l X Showering

Surface Water (Piscataway Creek­ ..... Unnamed ~I Ingestion H Tributaty)/Freedom Dennal contact I I I I I I I Lake Groundwater / Stonnwater Lt-I Runoff t­ Sediment (piscataway Creek-Unnamed '~I Ingestion H .. Tributaty)/Freedom Dennal contact I I I I I I I Lake "'A minimum of two to KEY: ------l X [= Pathway is or illight be com plete; four feet of clean fill data are available and pathway evaluated. was placed over FT-03 during golf course I • [= For future land use, it was assumed that the receptor is exposed to soil from 0 to 12 inches construction. the ground surface that has been redeposited as surface soil during future construction actiti"

"''''Indoor and outdoor I [= Pathway is incomplete or insignificant

FT-03 ROD 11:­ Andrews AFB, Maryland

Conceptual Site Model Diagram Prior to the Drawn By: DWC Project No.: ROD FT-03 Human Health Risk Assessment Checked By: RB File Name: Conceptual Model

Date: May 2008 Figure No.: 2-7 -- Boundary of FT -03 FT-03 ROD Andrews AFB, Maryland Boundary of Institutional Controls Implementation Drawn By: DWC Project No.: ROD FT-03 Checked By: RB File Name: IC Implemenation

Date: May 2008 Figure No.: 2-8

Tables

Table 2-1 Summary of Receptor Cancer Risks Exceeding 1 x 10-4, Unrestricted Use Scenario

Record of Decision, Site FT-03 Andrews AFB, Maryland

Cancer Pathway(s) Receptor Risk Drivers Risk Contributing to Risk Ingestion – Groundwater Future On-site Residents at Arsenic 4 x 10-4 Dermal Contact – Exposure Area 1 Benzo(a)pyrene Groundwater Future On-site Residents at 2 x 10-4 Ingestion – Groundwater Arsenic Exposure Area 2 Source: Earth Tech RI (2007)

Table 2-2

Summary of Receptor Non-cancer Hazard Indexes (HI) Exceeding 1, Unrestricted Use Scenario

Record of Decision, Site FT-03

Andrews AFB, Maryland Receptor Pathway(s) Pathway(s) Target Organ HI HI Receptor HI Contributing to HI HI Drivers Exposure Area 1- Future On-Site Inhalation of VOCs in Indoor Air 9 2 Nasal (HI = 1.5) Naphthalene (HI = 1.5) Adult Resident Migrating from Vadose Zone Soil Inhalation of VOCs in Indoor Air 5 Nasal (HI = 4.3) Naphthalene (HI = 4.3) Exposure Area 1 - Future On-Site Migrating from Vadose Zone Soil 23 Child Resident Ingestion – Groundwater Skin, Vascular (HI = 1.7) Arsenic (HI = 1.7) 18 Dermal Contact - Groundwater No observed effects (HI = 2.0) Chromium (HI = 2.0) Ingestion, Dermal Contact – Soil Inhalation of VOCs in Indoor Air 0.5 None (1) None (1) Exposure Area 2 - Future On-Site 3 Migrating from Vadose Zone Soil Adult Resident Ingestion – Groundwater 2 None (1) None (1) Dermal Contact – Groundwater Ingestion, Dermal Contact – Soil Inhalation of VOCs in Indoor Air 2 None (2) None (2) Exposure Area 2 - Future On-Site 7 Migrating from Vadose Zone Soil Child Resident Ingestion – Groundwater 5 Skin, Vascular (HI = 1.4) Arsenic (HI = 1.3) Dermal Contact - Groundwater

(1) Although total receptor HI exceeds 1, no target organ HI exceeds 1. (2) No HI drivers were identified in soil.

Table 2-3 Summary of Detected COCs with Associated Locations at FT-03

Record of Decision, Site FT-03 Andrews AFB, Maryland Detected Background Parameter Media Location MCL (µg/L) Concentrations Concentration 2400 µg/kg @ 6’ – 8’ DP-01 (SEA1) NA 8.2 µg/kg 5400 µg/kg @ 9’ – Naphthalene Subsurface Soil 21’ 1700 µg/kg @ 6’ – DP-09 (SEA1) NA 8.2 µg/kg 10’ DP-03 (GEA1) 0.17 µg/L L 0.2 NA Benzo(a)pyrene Groundwater DP-10 (GEA1) 0.12 µg/L L 0.2 NA DP-11 (GEA1) 0.14 µg/L L 0.2 NA MW-04 (GEA1) 4.9 µg/L J 10 NA Arsenic Groundwater MW-10 (GEA2) 5.9 µg/L J 10 NA MW-11 (GEA1) 7.7 µg/L J 10 NA Chromium Groundwater MW-11 (GEA1) 64 µg/L J 100 34.3 µg/L SEA = Soil Exposure Area GEA = Groundwater Exposure Area J = Estimated Value L= Elevated Detection Limits NA= Not Applicable µg/kg = Micrograms per Kilogram µg/L = Micrograms per Liter

See Figures 2-5 and 2-6 for locations where contaminants of concern were detected within FT-03 Table 2-4: Cost Comparison for Remedial Alternatives

Total Lifetime O&M REMEDIAL ALTERNATIVE Implementation Capital Costs Costs Total Costs TOTAL PRESENT- No. Description Timeframe (yrs) (in 2008 $) (in 2008 $) (in 2008 $) WORTH COST

1 No-Action 30 $ - $ - $ - $ -

2 ICs 30 $ 10,300 $ 197,200 $ 207,500 $ 105,000

(1) 3 ICs & Monitoring 30 $ 10,300 $ 301,300 $ 311,600 $ 171,000

4 Excavation & Disposal of Contaminated (<1)2 30 $ 1,142,000 $ 301,300 $ 1,443,300 $ 1,293,000 Soil, with ICs & Monitoring 5 In-situ Chem Oxidation for Soil & GW with (<1)2 10 $ 505,000 $ 197,000 $ 702,000 $ 641,000 ICs & Monitoring

NOTES: (1) Selected Alternative based on Effectiveness, Implementability, ARARs, and Costs 2

Estimated Construction Time, Less than 1-yr

ICs = Institutional Controls

GW = Groundwater

All costs are rounded values. Table 2-5 Comparative Analysis of NCP Evaluation Criteria for the FT-03 Remedial Alternatives

Record of Decision, FT-03 Site Andrews AFB, Maryland Criteria Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5 Overall Protectiveness of Human Health { 9 z z z and the Environment Compliance with Applicable or Relevant { 9 z z z and Appropriate Requirements (ARARs) Long-Term Effectiveness and { 9 z z z Permanence Reduction of Toxicity, Mobility, or { { { z z Volume Through Treatment Short-Term Effectiveness { 9 9 z z Implementability { z z z z Cost 1 $0.00 $105,000 $171,000 $1,293,000 $641,000 State Acceptance N/A N/A Yes N/A N/A Community Acceptance Yes Yes Yes Yes Yes z Satisfies criterion to a high degree 9 Satisfies criterion to a moderate degree { Satisfies criterion to a low degree

Alternative 1 – No Action Alternative 2 – ICs Alternative 3 – ICs with monitoring Alternative 4 – Soil Excavation with ICs and monitoring Alternative 5 – ISCO with ICs and monitoring ICs = Institutional Controls ISCO = In-Situ Chemical Oxidation N/A = Not Applicable NCP = National Oil and Hazardous Substances Pollution Contingency Plan

1Cost is the total present worth value

Table 2-6 Cost Summary - Alternative 3 Institutional Controls with Monitoring

Record of Decision, FT-03 Site Andrews AFB, Maryland Estimated Cost COMPONENTS QTY Unit Cost (2008 $) Capital Cost Items: Institutional Controls and Planning Lump Sum $ 10,330 $ 10,330 Subtotal $ 10,330 Total Estimated Capital Cost $ 10,330 Operation & Maintenance Activities: Sampling and Analysis Program 11 Events $ 12,400 $ 136,400 Baseline, Annual, Biennial & 5-Year Events Data Interpretation & Reporting 11 Events $ 9,300 $ 102,300 Closure Reporting 1 Event $ 12,400 $ 12,400 O&M Costs Subtotal $ 251,100

O&M / Periodic Cost Contingency 20% $ 50,220 Total Lifetime O&M/Periodic Costs $ 301,320 TOTAL IMPLEMENTATION COST $ 311,650 TOTAL PRESENT WORTH COST $ 171,200

Appendix A

Maryland Department of the Environment Concurrence Letter

MARYLAND DEPARTMENT OF THE ENVIRONMENT 1 800 Washington Boulevard Baltimore 2 1230 1-800-633-6101

Martin Shari T. Wilson Governor Secretary

Anthony G. Brown Robert M. Summers, Lieutenant Governor Deputy Secretary

July 1,2008

Mr. Michael Mackiewicz 3 16 3466 North Carolina Avenue Andrews Air Force Base, Maryland 20762

RE: Final Record of Decision, Site FT-03, Andrews Air Force Base, Maryland (July 2008).

Dear Mr. Mackiewicz:

The Federal Facilities Division (FFD) of the Maryland Department of the Environment's (MDE) Hazardous Waste Program has reviewed the above referenced document. This Record of Decision (ROD) documents the joint concurrence of the Environmental Protection Agency (EPA) and the Air Force on the selected remedial action at this site; which is groundwater monitoring with institutional controls.

A public meeting was held on February 21,2008 to present the proposed remedial action contained in this ROD. Several people attended the public meeting and had general questions about the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), and how the 03 Site fit into the CERCLA process. All were addressed during the public meeting. The public comment period extended from February 7 through March 6,2008. There were no written or verbal questions submitted to the Air Force, EPA or MDE during the 30-day public comment period. The FFD supports the Air Force's remedy selection for this site.

If you have any questions, please contact me at (410) 537-3398.

Sincerely,

Rick Grills Section Head Federal facilities Division

Cc: Mr. Andrew Sochanski Mr. Manfred Reichwein Mr. Horacio Tablada Mr. Harold L. Dye

------. - -- Recycled Paper TTY Users 1-800-735-2258 Maryland Relay

Appendix B Public Meeting Newspaper Notices

2 PN Prince George’s News PS Prince George’s EXTRA IN BRIEF

INSIDE Room 223, Bladen Hall, 301 Largo Rd., Largo. To Free Tax-Preparation Help schedule an appointment, call 301-583-5254. Prince George’s County residents whose annual in­ Business 16 Dr. Gridlock 6 come in 2007 was $50,000 or less are eligible for free Extended Research Room Hours Community Events 15 Education 8 assistance through Prince George’s Community Col­ The National Archives will restore evening and lege’s Volunteer Income Tax Assistance program. weekend hours at its District and College Park re­ Crime Report 19 Entertainment 16 The services, which are provided by volunteers who search rooms, beginning April 14. The extended have completed training and have been certified by hours will be 9 a.m. to 9 p.m. Wednesday, Thursday HOW TO REACH US the Internal Revenue Service to prepare Form 1040, and Friday, and 9 a.m. to 5 p.m. Saturday. Hours on are available by appointment or on a walk-in basis. Monday and Tuesday remain 9 a.m. to 5 p.m. Residents should bring Social Security cards for Additional federal funds were provided in the agen­ THE WASHINGTON POST themselves and their dependents, last year’s tax re­ cy’s 2008 budget to restore the hours. Additional mon­ 9500 Arena Dr., Suite 400 | Largo, Md. 20774 turn, a voided check for direct deposit of refunds, a ey also was provided to hire staff for the Archival Re­ 301-618-1720 Tel | 301-618-1780 Fax | [email protected] W-2 form, a 1099 form and any other relevant docu­ search Room. The research room’s hours had been re­ ments. duced in October 2006 to cut costs. Volunteers will be available from 6 to 9 p.m. on The College Park facility is at 8601 Adelphi Rd. For EDITORS Politics and Government: Tuesdays and from 9 a.m. to noon Saturdays through information, call 202-357-5300. News: Rosalind S. Helderman April 12 at Prince George’s Community College, — Compiled by AKEYA DICKSON Lisa Frazier Page [email protected] [email protected] 301-618-1723 301-618-1781 Growth and Development: ON WASHINGTONPOST.COM Sports: Micah Pollack Ovetta Wiggins Now Online: Local Blog Directory [email protected] [email protected] 301-618-1732 301-618-1737 To find out what bloggers in your community are writing, go to projects.washingtonpost.com/ Photo: Debra G. Lindsey Religion and Communities: local-blog-directory. [email protected] Hamil R. Harris [email protected] REPORTERS 301-618-1724 Business: Sports: Josh Barr The United States Air Force Requests Anita Huslin [email protected] Public Comment on the [email protected] 301-618-1733 Proposed Remedial Action Plan for Site FT-03 301-618-1735 Editorial Aide: Courts: Akeya Dickson at Andrews AFB Ruben Castaneda [email protected] [email protected] 301-618-1722 The U.S. Air Force (USAF) and the U.S. Environmental Protection Agency (USEPA) have issued a 301-618-1736 Proposed Remedial Action Plan (PRAP) for addressing shallow groundwater and subsurface soil Education: OFFICE MANAGER contamination at a site called “FT-03” at Andrews Air Force Base. You are invited to review the PRAP Nelson Hernandez Diane Powell-Millard and its supporting documentation and submit your comments on the plan during the 30-day public [email protected] [email protected] comment period, February 7 – March 7, 2008. 301-618-1738 301-618-1721 General Assignment: SITE DESCRIPTION: The FT-03 area is located east of the flightline in the southwest portion of the Base. Avis Thomas-Lester CIRCULATION FT-03 was brought into the Environmental Restoration Program in 1985 because of historic fire training [email protected] SUBSCRIPTIONS & CUSTOMER SERVICE activities that occurred in a 300-foot diameter bermed area. Since then the USAF has conducted 301-618-1725 800-477-4679 several investigative efforts to determine the nature and extent of groundwater and subsurface soil Lonnae O’Neal Parker contamination resulting from the fire training activities. The primary contaminants in groundwater are [email protected] ADVERTISING benzo(a)pyrene, and the metals chromium and arsenic. Naphthalene is the primary contaminant in 301-618-1727 DISPLAY ADVERTISING subsurface soils. Eric Rich Martin J. Kady [email protected] 800-627-1150, Ext. 4-7500 PROPOSED REMEDIAL ACTION PLAN: The USAF and USEPA propose to implement institutional 301-618-1730 CLASSIFIED ADVERTISING controls and groundwater monitoring to address the low levels of contamination present at the site. Police and Crime: Prince George’s Extra Candace Rondeaux Ever Dinarte, 202-334-5474 FOR REVIEW: The PRAP and all supporting documents are available for review at Prince George’s [email protected] The Washington Post County Memorial Library System, Surratts-Clinton Branch, 9400 Piscataway Road, Clinton, 301-618-1725 800-753-2527 Maryland (301) 868-9200.

HOW TO SUBMIT MATERIAL TO LEARN MORE: The USAF and USEPA invite you to attend an information session on the PRAP. This will be held on Thursday February 21, 6:00-8:00 p.m. at the Colony South Hotel and Conference Letters to the Editor: Letters about local issues, which may be edited for space and Center, 7401 Surratts Road, Clinton, Maryland. The USAF will present and explain the PRAP and will clarity, should include your name, address, and day and evening telephone numbers so that receive oral and written comments at the meeting. 14, 2008 authorship can be verified. Letters must be exclusive to The Washington Post. Deadline is noon Monday for Thursday publication. Send them by mail to The Washington Post, 9500 TO SUBMIT COMMENTS: Written comments may be submitted by mail, email, or fax to: Arena Dr., Suite 400, Largo, Md. 20774; by fax to 301-618-1780: or by e-mail to 316th Airlift Wing Public Affairs Office (316 WG/PA) [email protected]. 1535 Command Drive Andrews AFB, MD 20762-7002 HOW TO OBTAIN REPRINTS AND PHOTOGRAPHS Telephone: 301-981-7888 Fax: 301-981-4588 Reprints: For information about obtaining permission to reprint material that appears in Email: [email protected] the Post, call The Washington Post Writers Group at 202-334-5666. Thursday, Thursday, February

Photographs: The general public may purchase copies of photographs online at www.washingtonpost.com/personalphotos. Individuals, businesses, organizations or publications seeking rights to reproduce images, including posting them on web sites, Build a career GHI should call The Washington Post Writers Group at 202-334-5666. washingtonpost.com Get the job you want. To read the Prince George’s Extra online, visit The local expert www.washingtonpost.com/princegeorges on local jobs. J108d 3x1.25 Prince George’s Extra Page A-li STAR COMMUNITY NEWS Thursday, February 7, 2008 urn Slain music producer's wife relieved by arrest

• Suspected gunman and thinking of that night. I miss 2006 after a towtruckwas used to neighborhood's entrance in the my husband desperately, and it's steal his Chrysler 300 luxury 11000 block ofSouthlake Drive. in 2006 homicide just sort of been plaguing me sedan from his driveway. Steele Brown said a man was "It's ahuge weight taken into custody Jan. 29 having seen this happen to my Brown called 911 to report the standingbeside the tow truckand husband right before my eyes." theft at approximately 2:30 am., her husband got out of the car to lifted offmy Alexis, of the 2000 block of but was told by dispatchers that ask him wby he was towing his BY JONATBAN STEIN East Marlboro Avenue, was he should call back after finding vehicle. shoulders. I have STAFF WRITER arrested Jan. 29 at his residence out whether the car was being Before he could finish the and charged with first-degree legitimately towed, said Steele question, Steele Brown said gun­ spent many, many The wife of Raymond Scott murder. He has been remanded Brown. fire ca.me from the tow truck, Brown saidshe is relieved to learn to the DepartmentofCorrections Steele Brown said she and her striking her husband in the chest. sleeple~s nights· ofthe county police department's with no bond husband then hopped into their "We had no ideaanybodywas recent arrest of 21-year-old CpL Henry Tippett, a police other car and drove toward the even in there because it was dark thinking ofmy Jamaal Alexis of Landover, the spokesman, said Alexis is entrance of the neighborhood to and the windows were tinted," alleged gunman in Brown's Octo­ believed to have been the shoot­ get information about the tow Steele Brown said. "I was scream­ husband and ber 2006 shooting death. er. truck company operating in the ing hysterically and in shock. I "It's a huge weight lifted off Brown, better known as development. couldn't believe what I saw and I thinking ofthat my shoulders," Danielle Steele "Scottie Beats''' was a 36-year-old Only a few blocks from their was left there holding my hus­ Brown said of the arrest. "I have Lake Arbor resident and Fort home in the 600 block of Stillwa­ band who was bleeding to death night" spent many, many sleepless Washington-based music pro­ ter Place, Steele Brown said they in my arms." nights thinking of my husband ducer who was killed Oct. 13, sawthe towtruck parked near the The suspects fled and Brown Danielle Steele Brown, was taken to a hospital, where he lake Arbor resident The United States Air Force Requests was pronounced dead a short Public Comment on the time later. Proposed Remedial Action Plan for Site FT-63 1Wo police dispatchers and a truck and that Edmonds followed at Andrews AFB supervisor were fired after an in a second vehicle. investigation showed they had The county enacted a new The u.s. Air Force (USAF) and the U.S. Environmental Protectlon Agency (USEPA) have Issued a Proposed not followed proper procedure in RtImedlal ActIon Plan (PRAP) for addressing shallow groundwater and subsurface soli contamination at a site called towing law as a result of Brown's "FT-03" at Andrews Air Force Base. You are Invited to review the PRAP and its supporting documentation and their handling ofthe incident. death. The law; which requires submit your comments on the plan dUring the 30-day public comment period, February 7 - March 7, 2008. Neiman Edmonds, 20, of tow truck drivers to notify police Upper Marlboro was arrested SITE DESCRlPTION: The FT-03 area is localedeast of the fllghUine in the southwest portion of the Base. FT-03 was before a car is towed and when brought into the Environmental Restoretion Progrem In 1985 bacause of historic fire training actlvities that oocurrad in April 10 and charged with sec­ the car is impounded, took effect a 3Oo-foot diameter banned area. Since then the USAF has conducted severallnvestigalive efforts to detennine the ond-degree murder in connec­ Jan. 3. nature and extent of groundwater and subsurface 5011 contamination resulting from the fire training actlvities. The tion with the case. primary conteminants in 9roundwater are benzo(a)pyrene, and the metals chromium and arsenic. Naphthalene Is the Tippett said it is believed that E-mailJonathan Stein at primary contaminant in subsurface 50115. Alexis was the driver of the tow [email protected]. PROPOSED REMEDIAL ACTION PLAN: The USAF and USEPA propose to implementinstilulional controls and groundwater monitoring to eddress the low levels of contamination present althe site. FOR REvIEW: The PRAP and all supporting documents are available for review at Prince George's County Memorial Ubrary System, Surratts-Cllnton Branch. 9400 Piscataway Road, Clinton, Maryland (301) 868-9200. To lEARN MORE: The USAF and USEPA Invlle you to attend an Infonnation session on the PRAP. This will be held Fire forces animals out on Thursday February 21, 6:00-8:00 p.m. at the Colony South Hotel and Conference Center, 7401 Surratta Road, Clinton, Maryland. The USAF wili present and explain the PRAP and will receive oral and writien comments at the meeting. - of Oxon Hill PetSmart To SUBMIT COMMENTS: Writien comments may be submitted by mail, email, or fax 10: 316th AlrliflWlng Public Affairs Office (316 WGIPA) 1535 Command Drive A fire at an Oxon Hill pet store and transported to another Andrews AFB, MD 20762-7002 store forced about two dozen PetSmart. Telephone: 301-981-7888 animals to be evacuated Thurs­ Anyone with information Fax: 301-981-4588 Email: 316PA.comreltlllandrews.af.milI61245O day, said Prince George's County about this fire is asked to call Fire Department spokesman Prince George's County Fire Mark Brady. Investigators at 301-77-ARSON. At I1:15 a.m., firefighters responded to a call from a PetS­ fn dam_ Alentown mart store, located at 6005 Oxon ~ashingtgllWQ!!I~!J Hill Road in Oxon Hill, to find racquetball con heavy smoke coming from the Prince George's County fire­ front doors and loading dock. On your lap or on your laptop"." fighters responded to a fire on The fire, contained by an the roofofthe racquetball courts read Washington Woman! automated sprinkler system, at the Allentown Fitness and Find our monthly print edition onli was located at the rear of the Splash Park on Thursday, store where the cat products according to Mark Brady, www.washingtonwoman.com were located. The blaze was spokesman for the Prince completely extinguished by fire­ George's County Fire Depart­ fighters within 15 minutes. The ment. cause of the fire is considered At around 3:20 p.m. Thurs" "suspicious" and is under inves­ day, firefighters encountered a tigation, Brady said. Damage fire on the peaked roof of the from the fire is estimated at building that houses two rac­ $25,000. No injuries were report­ quetball courts. No one was in ed. that section at the time. but the About two dozens cats and indoor swimming pool was dogs in the grooming section of occupied by several people and the store were evacuated by was safelyevacuated, Bradysaid. employees and shoppers, who Allentown Fitness and Splash housed the pets in their vehicles Park is located at 7210 Allentown until their owners arrived to Road in Temple Hills. claimthern. The fire required 30 firefight­ One adult cat escaped dur­ ers about 45 minutes to contain. ing the evacuation and is still No one was injured, and the fire missing, Brady said. Dozens of is believed to have caused by a smaller pets - such as reptiles, malfunctioning heater in the small furry animals and fish that roof. Damages are estimated at were sold in the store - were $100,000. deemed safe, removed from the - RYAN McDERMOTI Page 14 CAPITAL FLYER Friday,February 8, 2008

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Appendix C Summary Transcript of the Public Meeting for the Proposed Remedial Action Plan – FT-03

February 21, 2008

PUBLIC MEETING FOR THE PROPOSED REMEDIAL ACTION PLAN - SITE FT-03, ANDREWS AIR FORCE BASE, MARYLAND

Summary Transcript of Meeting

Date: 21 February 2008 Time: 6:00 PM to 8:00 PM Location: Colony South Hotel and Conference Center 7401 Surratts Road, Clinton, Maryland

The meeting began at 6:00 pm. In attendance were: Mr. Andy Sochanski, Remedial Project Manager, United States Environmental Protection Agency, Region III, Philadelphia, Pennsylvania. Mr. Brian Dolan, Acting Chief, Environmental Flight, Andrews Air Force Base. Mr. Michael Mackiewicz, Project Manager, Environmental Flight, Andrews Air Force Base. Mr. Scott Truesdale, Project Manager, Tetra Tech, Inc., Falls Church, Virginia. Ms. Erin McMahan, Environmental Scientist, Tetra Tech, Inc., Falls Church, Virginia.

MEETING SUMMARY

There were no attendees between 6:00 and approximately 7:00 pm.

At approximately 7:00 pm, Ms. Tamara Davis Brown, representing the Windbrook Area Citizens Association in Clinton, Maryland, arrived. Ms. Brown initially questioned how the contaminated sites on base will affect the nearby community. Andrews Air Force Base (AFB) personnel gave an overview of the Environmental Restoration (ER) Program at the base, using a map of Andrews AFB showing the location of all the ER Program sites as a visual aid.

Ms. Brown asked what does the Air Force do to clean up these sites, and which sites on base have been remediated. Andrews AFB personnel explained the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) process that is followed at the base, focusing on the human health risk assessment process, and gave a summary of the status of site remediation for sites where remedial actions have occurred.

Ms. Brown was also interested in the types of land uses at the base and Andrews AFB personnel provided a summary, again using the base map as a visual aid.

She further asked how does the Air Force prioritize the site cleanups across the base, and why wouldn’t they do the sites near military housing first. Andrews AFB personnel explained all the factors involved in site cleanup, including knowledge of site history and conditions, level of risk, and funding implications.

Ms. Brown expressed specific interest in the Brandywine site. She then asked for a summary of the plan for the FT-03 site, the site history, and if the site would affect local communities. Andrews AFB personnel gave an oral summary of the Proposed Remedial Action Plan (PRAP), discussed the site history, and provided Ms. Brown with a hard copy of the PRAP. Mr. Dolan explained that the preferred alternative is groundwater monitoring and institutional controls (ICs) because the remedial investigation did not detect any significant contamination in either soil or groundwater at the site. He also stated that the soil contamination is at levels that are not expected to impact groundwater in the future.

Ms. Brown was also interested if Andrews AFB was looking into how the latest Base Realignment and Closure (BRAC) actions will affect the base and the ER Program sites. Andrews AFB personnel gave an overview of the base’s activities concerning future BRAC consolidation at Andrews AFB and that the gaining activities are expected to have little to no impact to the base as well as the infrastructure of the area. There was also a discussion of the possibility of future residential development along the southeast border of the base.

At approximately 7:40, Mr. Dean Evans of Clinton, Maryland, arrived. Mr. Evans was interested in the overall ER Program at Andrews AFB, and specifically was interested in the potential for activities at Andrews AFB to affect the nearby residential developments.

Andrews AFB personnel explained that there are two ER Program sites that have affected areas off base. A discussion of LF-05 and the Brandywine site followed. There was no discussion of FT-03.

The meeting ended at approximately 8:10 pm.