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Record of Decision System (RODS)



Address:  OFF RTE 40 
City & State:  EDGEWOOD  MD  21010
County:  HARFORD
EPA ID:  MD2210020036
EPA Region:  03
NPL Status:  Currently on the Final NPL
ROD Type:  Record of Decision
ROD ID:  EPA/541/R-99/013
ROD Date:  06/11/1999
Operable Unit(s):  17
Media:  Groundwater, Sediment, Soil, Surface Water
Contaminant:  Metals, PAH, Pesticides, VOC
Abstract:  Cluster 1 (OU-11)
The Lauderick Creek Area covers approximately 1,530 acres and encompasses Cluster 1. It was used by the U.S. Army Chemical School for a wide variety of chemical warfare training activities between 1920 and 1951. Training activities included the use and firing of chemical ordnance; identification of chemical agents, riot control agents, and smokes; decontamination of personnel and equipment; clothing impregnation and laundering; and handling and maintenance of chemical warfare equipment. The training also provided instruction, and possibly field practice, in the disposal of chemical agents, riot control agents, smokes, chemical ordnance, and chemical agent contaminated
material. The materials used in training included smoke and tear gas, high explosives, and lethal-agent filled munitions. As a result of these training activities, UXO has often been found and is till present in the Lauderick Creek Area.

The Nike Site, constructed in School Fields Four and Seven of the Lauderick Creek Area, was used for the deployment of Nike antiaircraft missiles between 1954 and 1973. The Army deployed Nike missiles at many sites throughout then United States to protect major cities and strategic military installations from aerial attack. There were two types of Nike missiles: the Nike Ajax, which was used between 1954 and 1959, and the Nike Hercules, which was used between 1959 and 1973. The Nike missiles were removed from the missile silos when the Nike Site was decommissioned in 1973.

The Nike Site at APG consists of missile silo area, the Barracks Area, and the Control Area. In the Nike Site missile silo area, Nike missiles were assembled, stored, and maintained within each of the six silos. The Barracks Area consists of five buildings used as living quarters and office space. The Control Area is being investigated under CERCLA as part of the Lauderick Creek Study Area and therefore is not included as part of the Nike Site. The Maryland National Guard has leased the Lauderick Creek Area, including the Nike Site, from the Army since 1973. The Maryland National Guard uses the area for light infantry training.

UXO was recovered during activities at the Launch Area during range-clearing surface sweeps in 1977 and 1984 and
during site clearance for the facility investigation drilling. UXO may be present throughout Cluster 1.

In 1989, the US Army Environmental Hygiene Agency (AEHA) conducted a RCRA Facility Assessment (RFA) that addressed the entire Edgewood Area, including the former Nike Site. AEHA recommended that a number of sites within the former Nike battery area be designated as RCRA solid waste management units requiring further investigation and possible. These sites included parts of the wastewater systems, suspected landfill sites south and southwest of the Launch Area, an alleged French drain near Building E6871, the vehicle wash pad, and concrete lined ditches within the Launch Area.

While preparing the RFA, AEHA also sampled areas of probable or suspected contamination in and around the former Nike Site. The sample analyses became the basis of the RCRA Facility Investigation (RFI) conducted for the Site in 1990 to identify contaminants related to prior usage of the area, verify contaminant movement pathways, and provide source characterization data. The RFI concluded that past Nike-related activities caused limited contamination and that contamination was probably limited to known points of release. It was also suggested that past chemical warfare material (CWM)-related releases might be scattered throughout the area. The RFI concluded that any future release of
this property for unrestricted use would be severely affected by contamination related to UXO and to past training at the Chemical Warfare School.

An Enhanced Preliminary Assessment of the Nike Site, conducted by the U.S. Army Corps of Engineers' Toxic and Hazardous Materials Agency in 1990 recommended additional investigation and sampling. This request resulted in the preparation of a Sampling Design Plan in 1990 that focused on potential contaminant sources, locations of existing and former facilities, and past installation activities.

An Environmental Assessment for the Nike Missile Silos performed in 1993 for the USACE by Roy F. Weston recommended the silo water be removed and treated off-site and the silos be filled with an inert material. In July of 1993, a Work Plan to perform the work was prepared; the recommended remedial actions were implemented in late 1993 and early 1994.

A remedial investigation and feasibility study (RI/FS) for Cluster 1 was initiated in 1990 to determine the nature and extent of contamination and to identify alternatives available to clean up the area.

The remedial investigation (RI) identified four contaminated areas and media, including the launch Area septic tanks and lines, the unconfined groundwater, the Launch Southwest landfill, and UXO. The feasibility study (FS) recommended the remedial actions presented herein, with the exception of UXO. Although UXO was considered in the FS, it is not discussed herein because it is being addressed separately.

J-Field Soil Operable Unit Site (EPA/ROD/R03-96/228)

During World War II, J-Field was used to test high explosives and chemical munitions. J-Field was also used for the thermal and chemical decontamination of chemical munitions. Chemical agents, chemical wastes, and high explosives were burned or open detonated in the pits at J-Field. The Operable Unit (OU), EPA/ROD/R03-96/228, consists of two main burn pits (the Northern Main Burn Pit and Southern Main Burn Pit). It also includes the Push out Area, which consists of the VX Burn Pit, the Mustard Burn Pit and the Liquid Smoke Disposal Pit.

The pits were used extensively between the late 1940s and 1960s and to a lesser extent throughout the 1970s. The Northern and Southern Main Burn Pits are each approximately 300 feet long with a total area of about 4,500 sq. ft. High explosive-filled munitions, nerve agents, mustard, liquid smoke, chlorinated solvents, and wastes were disposed in these pits between 1940 and 1980. High explosive-filled munitions were also open burned or detonated here during this time. Three smaller pits include the Mustard Burn Pit (approx. 100 ft. long), a small Liquid Smoke Disposal Pit (approx. 24 sq. ft.), and the VX Burn Pit. The three smaller pits, located near the Push out Area, have been buried. These pits were used in the same manner to dispose of VX, Mustard (dichlorodiethyl sulfide), and the primary components of liquid smoke: titanium tetrachloride and sulfur trioxide/chlorosulfonic acid.

Open burning initially involved placing three to four wood dunnage in a pit. The materials to be burned were then placed on top of the dunnage. Fuel oil was added, and the material was ignited. Scrap metal items were removed and reburned in the same manner. The depths of the pits were maintained by pushing burned soil and ash out of the burn areas toward the adjacent marsh in an area that is collectively referred to as the Push out Area. The Push out Area occupies about 67,000 sq. ft. and extends more than 100 feet into the marsh.

The U.S. Army Toxic and Hazardous Materials Agency (renamed the U.S. Army Environmental Center (USAEC) reported that contamination at J-Field was first detected during an environmental survey of the Edgewood Area conducted in 1977 and 1978. Subsequent to this study, 11 groundwater monitoring wells were installed at J-Field to determine the extent of contamination. Contamination was also detected during a munitions disposal survey conducted in 1983.

In 1986, the USEPA issued a Resource Conservation and Recovery Act (RCRA) permit requiring a base-wide RCRA Facility Assessment (RFA) and a hydrogeologic assessment at J-Field. The US Geological Survey (USGS) conducted a two phased hydrogeologic assessment, which included soil gas investigations and the installation of several wells. A groundwater flow model of the J-Field area was developed based on the hydrogeologic assessment. Groundwater and surface water monitoring programs were initiated, and samples continue to be collected as part of that monitoring program. In 1989, the U.S. Army Environmental Hygiene Agency (renamed U.S. Army Center for Health Promotion and Preventative Medicine) conducted a RFA that addressed the entire Edgewood Area, including J-Field. The RFA recommended that a number of sites within the J-Field study be designated as RCRA Solid Waste Management Units (SWMU) requiring further investigation and possible remediation. The assessment of the J-Field SOU resulted in a recommendation that an additional investigation be conducted with a primary focus on marsh sediments and surface water adjacent to the J-Field SOU and a secondary focus on the shallow surficial aquifer.

The entire Edgewood Area was designated as an NPL Site on February 21, 1990. This resulted in the requirement for a Remedial Investigation/Feasibility Study (RI/FS) for the entire Edgewood Area, pursuant to Modification 2 of the RCRA Permit and a March 1990 Federal Facility Agreement (FFA) between USEPA Region III and the US Department of the Army. The current environmental study a J-Field is being conducted under the FFA which incorporates both RCRA and CERCLA requirements.

The J-Field RI, completed in 1996, entailed the investigation of 15 areas and features of J-Field including the J-Field SOU. The conclusion made from the RI was that the main sources of contamination at J-Field included former toxic burn pits, the demolition grounds, and the suspect burn areas. The primary contaminants were identified as heavy metals, petroleum related compounds, and chlorinated methanes, ethanes and ethenes. Pesticides and PCBs were also present a the J-Field SOU. The contaminants present are the direct result of disposal, open burning, pushout, and open detonation activities that occurred at J-Field. The Focused Feasibility Study (FFS) and Proposed Plan for J-Field were released to public on July 10, 1996, initiating a 45-day comment period.

Building 503 (Soils OU)
During WWII, Building 503 was set up as a filling plant for incendiary bombs. Incendiary filling was performed during the first half of 1942, and then the plant was remodeled as a smoke filling unit Approximately 50,000 incendiary ordnance items were filled during this pilot operation, and additional ordnance items were filled during a brief period of production. The bulk of smoke filling during WWII was with a smoke formulation containing mainly aluminum, zinc oxide and hexachloroethane (designated HC smoke). Small amounts of colored smoke filing operations were also performed in Building 503. Items filled included 105-mm canisters, 155-mm canisters, M1 smoke pots, M77 bombs, 60-mm shells, 2.36-in rockets, and grenades. Nearly 2.5 million items were filled in Building 503 during WWII. Since so may of the items being filled were M1 smoke pots, Building 503 became known as the Smoke Pot Plant.

It was constructed in 1918, and was intended to house a filling plant a trace caliber shell. Construction was not completed prior to end the WWI however, and there is no indicate at plant was ever commonly referred to in WWI literature as the large caliber filling plant. Small surrounding buildings also were used for operations related to filling. During at least a portion of the period between WWI and WWII, including the early and mid-1930s, Building 503 was used as a garage, gasoline filling station and carpenter shop.

Open burning at the north burn area probably started in 1943, primarily for disposal purposes, with off-specification batches of HC smoke mixture being burned in bulk on the ground surface. Also, mixing and filing operations inside Building 503 usually generated waste in the form of dust and small spillage of mixture ingredients. Solids that remained in the french drain after evaporation of the water were removed and taken outside and burned.

In the years immediately following WWII, Building 503 facilities continued to be used for the filling of smoke munitions, including smoke pots, candles, and cluster munitions. Open burning and testing at the south burn site started at this time, probably around 1951. Gradually, however, Building 503 evolved into a research and development (R&D) facility used t blend and test experimental smoke mixtures and to fill experimental munitions. A wide variety of smoke mixtures were burned, with many different ingredients. Some filling was performed, but the scale of filling activities was much smaller than during WWII. Much of the filling work was pilot scale, but some production-scale filling was accomplished. Both HC and colored smoke (CS) munitions were produced. Some incendiary munitions also were filled in Building
503. Beginning in 1959, Building 503 was used for CS grinding and packing activities. During recent years much of the work has been with red phosphorous. Use of both the north and south burn sites for testing and disposing purposes ceased in 1975. The burn sites are not currently used by the Army.

The north burn area was used as early as 1943, and the south site was in use starting about 1951. Use of these sites for testing and disposing of smoke mixtures and munitions ceased in 1975. The north burn site is the larger of the two, with an approximate total surface area of 10,540 ft2. The south site is smaller with a total area of approximately 2,160 ft2. The total area of the two barren sites is estimated to be about 12,700 ft2. The barren surface of the two burn areas can be characterized by visual observation of color and texture of the surface materials as two distinct areas: a central area covered with a granular ash and a surrounding perimeter or sandy soil with little or no vegetation. The ground surface is relatively level and flat with minor undulations and changes in elevation. Buildings and facilities at APG-EA have been assigned numbers using different systems during various time periods. During the early 1960s the original numbering system, consisting of one- to four- digit numbers, was changed to a four -digit numbering system. There is no correlation between the old and the new numbering systems. In the new numbering system, Building 503 was assigned the number E5265. Historical maps and records use the old numbering system. Development of documents for the Building 503 interim remedial action drew on existing documents. Therefore, the old numbering system is used in the ROD.

From 1976 through 1979, the US. Army Toxic and Hazardous Materials Agency (USATHAMA) conducted a surface and ground water investigation at APG-EA, including the Canal Creek Area. An initial assessment of the Building 503 burn sites was performed in 1976 as part of this investigation. In August 1985, APG contracted with the USGS to conduct a hydrogeologic assessment and an investigation of groundwater contamination in the Canal Creek Area. This investigation showed that groundwater beneath the Building 503 site is contaminated in the surfical aquifer and in the Canal Creek Aquifer. In 1989, the RCRA Facility Assessment (RFA) was performed by the US Army Environmental Hygiene Agency (AEHA) to document historical activities at APG-EA related to solid-waste management, to identify
potential sources of contaminant release in the Canal Creek Area, and to evaluate environmental quality at APG-EA with regard to past storage, treatment, and disposal of toxic and hazardous materials. The RFA recommended that the Building 503 burn sites be treated as an interim action, Additional soil sampling and analyses were performed by Roy F. Weston in February and March 1991 as part of a treatabliity study, and by Battelle in May 1993. Metals and semivolatile organic compounds were found in the soil during all these sampling events.

APG-EA has been listed by the EAP as a Federal facility meeting the criteria for inclusion on the National Priorities List (NPL) established pursuant to CERCLA. APG-EA entered the CERCLA process the Site Notification in January 1980. A Preliminary Assessment was completed in November 1980, and the Site Investigation was completed in December 1984. To facilitate the CERCLA process, APG-EA was broken down into several study areas. The Canal Creek Area is one of theses study areas. It is currently in the Remedial Investigation/Feasibility Stud (RI/FS) stage. To facilitate this ongoing Canal Creek RI/FS, the Canal Creek Study Area was further subdivided into 50 Installation Restoration
Program (IRP) sites, and solid waste management units (SWMUs) or operable units were identified at each IRP site. In September 1986, EPA issued a RCRA permit to APG which required an assessment of SWMUs at APG. In February 1990, APG-EA was placed on the NPL. The US Army and EPA signed a Federal Facility Agreement (FFA) in March 1990 which provides for the oversight and an enforcement of environmental investigations and remedial actions at selected APG-EA study areas. The Building 103 dump is on for the Edgewood Area study areas specified in the FFA. Regulatory oversight of the investigation is through the FFA.

OU A - Carroll Island Disposal Pits/Areas Edgewood Area

Carroll Island was acquired by the U.S. Army in 1918 as part of the original Edgewood Arsenal. Documentation on the use of Carroll Island before the 1940s is limited, but there is no evidence of U.S. Army activity during this period. In 1944, the U. S. Army reportedly used Carroll Point and the area north of Lower Island Point to test white phosphorus (a smoke munition) and high explosive ordnance. Also, a large field on the northeastern part of Carroll Island was cleared during the latter part of that decade and, along with other parts of the island, used as a CWM test area. Nerve and blister agents were released at the test area through 1969; riot control exercises and smoke-producing and simulant materials testing were conducted through 1971. Waste from testing activities was discarded via dumping or burial on the island. In 1975, the CWM testing facilities at Carroll Island were decommissioned [US Army Environmental Hygiene Agency (USAEHA) 1989].

From 1984 to 1985, APG was evaluated as a potential National Priorities List (NPL) site, and was listed on the NPL in 1990. In 1986, Resource Conservation and Recovery Act (RCRA) corrective action permit (MD3-21-002-1355) was issued by USEPA Region III to address solid waste management units (SWMUs) in the Edgewood and Aberdeen Areas of APG. As part of the RCRA permit, USAEHA performed a RCRA Facility Assessment (RFA) study for the Edgewood Area. Fifteen sites were identified as either SWMUs or areas with potential prior releases (USAEHA 1989). In 1986, the US Geological Survey (USGS), in cooperation with the US Army, conducted a hydrogeologic assessment of Carroll Island. A remedial investigation (RI) for Carroll Island was initiated in 1991 to determine the nature and extent of
contamination of the sites, and the RI did not detect contaminants migrating from OU A to the surrounding environment. However, the potential of contaminant migration from OU A disposal pits/areas to groundwater, soil, surface water, and sediment exists as long as the wastes remain buried on Carroll Island. The Focused Feasibility Study (FFS) for OU A identified and evaluated alternatives to remediate the disposal pits/areas presented in this ROD (EPA/ROD/R03-96/229). In 1993, an interim remedial action was performed at the Lower Island Disposal Area. This action included the removal of the contents of an open pit. The Proposed Plan for OU A was presented during a public meeting held on August 21, 1996. In June 1949, a spontaneous ignition occurred in one of the disposal pits at Old O-Field where a large variety of chemical-filled explosives/loaded munitions had been buried. As a result of this explosion, a broad area was contaminated with chemical warfare material, and unexploded ordnance was dispersed around the area. Between September 1949 and the early 1950s, the command of the Technical Exscort Detachment of Edgewood Arsenal performed a surface sweep and clearance of Old-Field. Activities included igniting drum contents, destroying mustard and lewisite one-tone containers, treating the surface of Old O-Field and excavating contaminated soil and burning the Old O-Field pits and contents.

From the late 1960s to the early 1970s, the Army performed surface sweeps of the area, which recovered chemical warfare material-filled rounds, and disposed of this material in the storage bunker at N-Field.

An Environmental Survey of the Edgewood Area was conducted in 1977 and 1978 by the U.S. Army. Results from ground water samples indicate that Volatile Organic Compounds (VOCs) and chemical agent degradation products are being released by the Old O-Field into the groundwater.

From 1976 through 1979, the U.S. Army Toxic and Hazardous Materials Agency (USATHAMA) conducted a surface and ground water investigation at the Aberdeen Proving Ground - Edgewood Area ( APG-EA), including the area covered by the Canal Creek Area.

APG-EA has been listed by the EPA as a Federal Facility meeting the criteria for inclusion on the National Priorities List (NPL). APG-EA entered the CERCLA process with Site Notification in January 1980. A Preliminary Assessment was completed in November 1980. The Site Investigation was completed in 1984.

To facilitate the CERCLA process, APG-EA was broken down into several study areas. The Canal Creek Area is one of these study areas. It is currently in the Remedial Investigation/Feasibility Study (RI/FS) stage. To facilitate this ongoing Canal Creek RI/FS, the Canal Creek Study Area was further subdivided into 50 Installation Restoration Program (IRP) Sites, and Solid Waste Management Units (SWMUs) or Operable Units. The Building 103 Dump is an IRP Site. The Canal Creek Aquifer beneath the Canal Creek Study Area is a separate Operable Unit.

In 1984, the U.S. Geological Survey began a study to investigate the source, extent, and possible migration of contaminants from the Old O-Field Area.

In August 1985, APG contracted with the United States Geological Survey (USGS) to conduct a hydro geologic assessment and an investigation of ground water contamination in the Canal Creek Area. This investigation is ongoing.

In September 1986, EPA issued a Resource Conservation and Recovery Act (RCRA) permit to APG which required an assessment of SWMUs at APG. The RCRA Facility Assessment (RFA), documented historical activities at APG-EA related to solid-waste management, and identified potential sources of contaminant release in the Canal Creek Area. The Building 103 Dump was investigated by AEHA as part of the RFA.

In 1987, the Army performed an engineering study for Old O-Field that addressed the feasibility of implementing a variety of source control alternatives. The study's results indicate that the total risk posed by the site is lower than the risks posed by any corrective action involving destruction or removal and none of the technologies considered is sufficiently developed to allow immediate selection.

In February 1990, APG-EA was placed on the National Priorities List (NPL). In March of 1990, the U.S. Army and EPA signed a Federal Facility Agreement (FFA) which provides for the oversight and enforcement of environmental investigations and remedial actions at selected APG-EA study areas. The Building 103 Dump site is one of the Edgewood Area study areas specified in the FFA. Apart from ground water monitoring wells installed at the dump by the USGS during the hydro geologic assessment, relatively little characterization work has been performed to date at the dump.

A limited geophysical investigation was performed by Argonne National Laboratory (ANL) in 1992 to assess the extent of the Building 103 Dump. No soil and/or ground water samples were collected during this study; instead, non-invasive geophysical techniques, including magnetic, resistivity, ground-penetrating radar, and seismic refraction were used to investigate the dump. Results indicated the dump was probably an outcrop of the surficial aquifer, and that head-ward erosion created a surface depression for the collection of sand, and for the later dumping of waste.

A recent removal action under Army authority at the dump included a voluntary action in 1992 for the removal of approximately 50 gallons of bromobenzyl cyanide (BBC) residue from a buried process vessel that had surfaced on its own, and the construction of a chain-link fence around the dump. A topographic survey of the dump was performed in June 1994. Additional geophysics also were performed at this time to more fully assess the extent of the dump. A passive soil gas survey was performed in June 1994 to determine if the dump was generating any gas and/or vapors.

In 1994, a Focused Feasibility Study for the Old O-Field Source Area was developed. This study evaluated the risks posed by Old O-Field and the potentially applicable remedial technologies for mitigating these risks. The Proposed Plan and Record of Decision for the Old O-Field source area are based on the results of the Focused Feasibility Study.
Remedy:  A soil cap is the selected remedy for remediation of the Old Bush River Road Dump OBRRD and will contain the risk of detonation of a 4.2-in. chemical mortar. The cap will consist of two layers. The first layer will be a minimum of three feet foundation layer and the second will be a minimum six inch layer of topsoil to support vegetation. The HELP model, shows that a soil cap with good vegetative cover will reduce infiltration of precipitation into the landfill by 76%. Both adjacent streams will be filled and relocated around the slope of OBRRD. The area of wetlands that will be disturbed will be reestablished on-site in accordance with State regulations. Long-term monitoring will occur for 30 years to ensure long-term performance of the cap, and sediments down gradient to the OBRRD will be sampled quarterly for the first year, and annually thereafter.

Institutional controls will be implemented in the area. A six foot fence with warning signs will be maintained around the OBRRD to restrict access. In addition, land use, access, and excavation restrictions will be included in Aberdeen Proving Ground's (APG's) Geographical Information System, and in APG's Real Property Master Plan. Quarterly inspections will be performed, and the Army will certify to EPA on an annual basis that the institutional controls are functioning. A site-wide (Land Use Control Assurance Plan) LUCAP is being developed for APG, and will incorporate Cluster 3.

Estimated Capital Costs: $881,856
Estimated Annual O&M Costs: $416,707
Estimated Present Worth Costs: $1,298,564

The purpose of the composite cap is to prevent infiltration by layering geosynthetic material to drain water off of the OBRRD, prevent infiltration through the composite layers, vent gases produced from the OBRRD, and contain any potential risk of detonation of a buried 4.2 inche chemical mortar. This type of cap is commonly used for municipal and hazardous waste landfills. A combination of a low-permeability geosynthetic clay layer and a flexible geomembrane would be installed as a highly effective means of reducing the potential for infiltration of water into the OBRRD, thereby reducing the possibility of contaminant migration.

Cap Cost: $1,257,628
O & M: $23,222
Net Present Worth: $1,701,884

The vegetative barrier cap, in conjunction with a soil cap, is an innovative technology used for landfill closure. This technology uses selected trees or grasses to further reduce infiltration into the OBRRD through transpiration. Although trees and certain grasses can increase the surface roughness of a landfill and thus increase infiltration, the transpiration rates should compensate for the added amount of infiltration entering the surface of the OBRRD. This technology uses alternative vegetation such as poplar trees and grasses to prevent precipitation from precolating beyond the root zone. This alternative will also contain any potential risk of detonation of a 4.2 inch chemical mortar

Cap Cost: $819,236
O & M: $ 19,652 to $54,963 (varies by year)
Net Present Worth: $1,308,699
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