Corrective_Action_Plan_Part_B,_AVGAS_Sludge_Burial_Site_A_(DP-06).pdf

Dobbins ARB

ADMINISTRATIVE RECORD

ARNUMBER

A. o7. oo!o~

DECISION DOCUMENT FOR

A VGAS SLUDGE BURIAL SITE B (DP-06)

Dobbins Air Reserve Base, Georgia

Department of Defense United States Air Force

Installation Restoration Program Decision Document

Site owner:

94 Airlift Wing (94 A W)

1430 First Street Dobbins Air Reserve Base, Georgia 30069-5009

Restoration Project Manager:

94 Support Group/Environmental Quality Flight (94 SPTG/CBV)

884 Industrial Drive Dobbins Air Reserve Base, Georgia 30069-4210

11 May2000

DECISION DECLARATION STATEMENT AND SUPPLEMENTAL INFORMATION

To ANAL DECISION DOCUMENT dated September 1997

--------~AVGASSLUDGEBURIALSITEB (DP..OS}---------

DObbins Air Reserve Base, Georgia -------------United sta1esAir Force

11 May2000

DECISION DECLARATION STATEMENT

To FINAL DECISION DOCUMENT dated September 1997 and SUPPLEMENTAL INFORMATION dated 11 May 2000 for Installation Restoration Program Site

AVGAS SLUDGE BURIAL SITE B (DP-06)

OWner: Dobbins Air Reserve Base, Georgia United States Air Force

11 May2000

The following information is supplemental to the. Decision Document dated September 1997.

Please insert these pages in the front of the September 1997 Decision Document just prior to the Cover Page.

Executive Summary:

The following supplemental information is provided to further document actions taken in the approximate two and one-half years since the unsigned Draft Decision Document was released for comment. This Draft Decision Document, dated December 1996, was released for Public Comment in June 1997 and received by the State of Georgia Environmental Protection Division (EPD) on 6 June 1997. The Air Force did not receive any comments from either the State EPD or the Public. After the comment period terminated, the Air Force prepared the Decision Documents in final format in September 1997, correcting minor spelling and grammar errors noted during another internal review.

The final Decision Document remained unsigned at the request of the State's Hazardous Site Response Program Office and Headquarters Air Force Reserve Command while awaiting the State evaluation under the Hazardous Site Response Act for status on the Hazardous Site Inventory. In January 1998, the Georgia EPD notified the Air Force that a listed site was de-listed from the Hazardous Site Inventory and that releases at other sites did not exceed reportable quantities.

The finalized document does not change any of the facts and positions postulated in the original draft document that was made available for public and State review. This supplement restates the Declaration Statement made in the original Decision Document. The Air Force, fulfilling its responsibilty as lead agent in this process, signs this Decision Document into record in accordance with Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Contingency Plan (NCP).

DECISION DECLARATION STATEMENT AND SUPPLEMENTAL INFORMATION

To FINAL DECISION DOCUMENT dated September 1997

----------AVGASSLUDGE BURIAL SITE B(DP..()61l-------- Dobblns f>Jr Reserve Base, Georgia United states Air Force

11 May2000

DECISION DECLARATION STATEMENT

To FINAL DECISION DOCUMENT dated September 1997 and SUPPLEMENTAL INFORMATION dated 1 May 2000 for Installation Restoration Program Site

AVGAS SLUDGE BURIAL SITE B (DP-06)

OWner: Dobbins Air Reserve Base, Georgia United States Air Force

1 May2000

DECLARATION

This Decision Document has been prepared for A VGAS Sludge Burial Site B (DP-06), which is designated under the Installation Restoration Program (IRP) located at Dobbins Air Reserve Base (ARB), Georgia (Figure 1-1). This Decision Document has been prepared based on Category m decision criteria presented as guidance by United States Air Force (USAF) entitled NFRAP Guide, A Resource for Making, Documenting, and Evaluating No Further Response Action Planned Decisions (USAF, 1995). This Decision Document is organized into two parts. The first part presents the Declaration, and the second part presents the Decision Summary.

STATEMENT OF BASIS AND PURPOSE

This Decision Document presents the selected action for the site, located at Dobbins ARB, Georgia. This decision is based on information obtained from the Remedial Investigation (RI) Report prepared by Parsons Engineering-Science (ES) (ES, 1995) and the Comprehensive Analytical Report (CAR) prepared by Montgomery Watson (Montgomery Watson, 1996). The primary information from these reports used in this Decision Document is the comparison of site concentrations in all environmental media with applicable or relevant and appropriate requirements (ARARs) or to be considered (TBC) criteria, and risk assessment of current or existing exposures to public health and the environment The risk assessment also evaluated hypothetical future exposures and this evaluation is summarized in Section 3.0. However, for the purposes of this Decision Document, only current or existing exposures were critically reviewed. This is consistent with Air Force guidance. (USAF, 1995)

The primary purpose of this Decision Document is to demonstrate that the response at the site is complete and therefore ''no further response action is planned" (NFRAP). Section

2.2.9 of Air Force Instruction 32-7020 (USAF, 1994) states that NFRAP status has been achieved when any of the following conditions apply:

• Investigation :finds no evidence of contsmination, insignificant levels of contsmination, or low levels of contamination that pose no significant current or existing threat to public health or the environment

• The removal of contsmination is complete.

Page D1

I I I I I I I

I I I I I I

I

DECISION DECLARATION STATEMENT AND SUPPLEMENTAL INFORMATION

To FINAL DECISION DOCUMENT dated September 1997

----------AVGAS SLUDGE BURIAL SITE B (DP-06,)----------

Dobbins PJr Reserve Base, Georgia --------------United Slates Air Forc:e

11 May2000

• The cleanup system is in place and operating effectively.

DESCRIPTION OF SELECfED REMEDY

Studies have demonstrated that contamination is limited in nature and does not pose a significant existing or current risk to human health or the enviromnent. Dobbins ARB, therefore, has determined that the response at this site is complete and NFRAP status has been achieved.

DECLARATION STATEMENT

This Decision Document represents the selected action for this site developed in accordance with the IRP which uses as its basis the Comprehensive Enviromnental Response, Compensation, and Liability Act (CERCLA), as amended by Superfund Amendments and Reauthorization Act of 1986 (SARA), and the National Contingency Plan (NCP). It also satisfies the requirements of the National Enviromnental Policy Act that applies to CERCLA response actions. It has been determined that the selected remedy of no further action is protective of human health and the environment, attains federal and state requirements that are applicable or relevant and appropriate, and is cost effective. The statutory preference for further treatment is not satisfied because contaminant levels at the site have been determined to present no significant threat to human health or the enviromnent under current use scenarios for the site.

Willi~ P. Kane, Colonel, USAFR Commander, Dobbins Air Reserve Base

Date

SUPPLEMENTAL INFORMATION AND DECISION DECLARATION STATEMENT

To FINAL DECISION DOCUMENT dated Saptember 1997

----------A)IGAS SLUDGE BURIAL SITE B (OP..()6}-----------

Dobbins Air Reserve Baas, Gaorgla ---------------United states Air Force

11 May2000

DECISION DECLARATION STATEMENT

To FINAL DECISION DOCUMENT dated September 1997 and SUPPLEMENTAL INFORMATION dated 1 May 2000 for Installation Restoration Program Site

AVGAS SLUDGE BURIAL SITE B (DP-06)

Site Manager:

94SPTG/CEV

884 Industrial Drive

OWner: Dobbins Air Reserve Base, Georgia United States Air Force

1 May2000

Dobbins ARB, GA 30069-4210

(770) 919-4898 or (770) 919-3547

SUPPLEMENTAL INFORMATION TO FINAL DECISION DOCUMENT DATED

SEPTEMBER 1997:

The following supplemental information Is provided to further document actions taken In the approximate two and one-half years since the unsigned Draft Decision Document, dated December 1996, was prepared and forwarded to the State of Georgia Environmental Protactlon Division on 6 June 1997and released to the public for review and comments. Following an extended period where the AJr Force awaited Stata and Public review and comments and having receMld none, the Air Force finalized the draft documents, correcting minor wording errors made In the original draft document, finalizing the Decision Documents In September 1997. Again, these documents remained unsigned at the request of the State's Hazardous Site Response Program Office and Headquarters Air Force Reserve Command while awaiting the State evaluation under the Hazardous SHe Response Act for status on Hazardous SHe Inventory.

These finalized document do not change any of the facts and positions postulated In the original draft document made available for public and State review. Lastly, this supplement restates the Declaration Statement made In the original Decision Document. Tha Air Force, In Hs position as lead-agent In this process, signs this Decision Document Into record In accordance wHh Comprehensive Environmental Response, Compensation, and UabiiHy Act (CERCLA) and the National Contingency Plan (NCP).

-5ECTION 1.2: SITE HISTORY AND ENFORCEMENT ACTMTIES

Addition as e new bullet statement: Section 1.2, Include as tl1e 4th bullet: The Georgia EPD notified the Base by letter dated 24 Jan 94 that a site at Dobbins ARB warranted listing the Base on the State's Hazardous Slta Inventory.

Renumber bullet statements: Section 1.2: Renumber t11e original 4th bullet to become t11e 5th bullet: "Georgia DNR reviewed .... •

Addition as a new bullet statement: Section 1.2, Include as a 6th bullet The Air Force delivered the Draft Decision Document to the State of Georgia Environmental Protection Division on 6 June 1997. Review was officially requested by 30 days, but since the Decision Document was not signed and published at that time, Dobbins AFB remained open to accept any comments until today. To data, the Air Force has not received any written comments or recommendations from the State on this Decision Document.

Addition as a new bullet statement Section 1.2, Include as a~ bullet In September 1997, the Air Force Incorporated minor corrections as recommended through Internal Air Force sources

Page 1 of Supplemental Information

To FINAL DECISION DOCUMENT dated September 1997

---------------------AVGASSLUDGEBU~SITEB(~6r------------------- Dobbins AJ.r Reserve Sese, Georgia ----------------------------United StaleS AJ.r Foroa

11 May2000 Into the draft Decision Document and prepared a final Decision Document dated September 1997. The Air Force has made no substantial change to the draft Decision Documents that would alter the data collected by the Air Force or the decisions made for the sites. The Air Force delayed signing these documents while awaiting further action, determinations and recommendations by the Georgia Hazardous Waste Branch pertaining to the listing of the site on the State's Hazardous Site Inventory, and the Stele's review of any and all other documents previously submltled to the Stete.

Addition as a new bullet statement: Section 1.2,lnclude as a 801 bullet The Stete of Georgia Hazardous Site Response Program Management Office within the State's Hazardous Waste Management Branch lndlceted on 23 July 1998 and 31 July 1998 that either sites FT-02, OT-04, DP-06, DP-06 (by reference), and OT -07 did not have raporteble quantities or that the Stete had no reason to believe that a release exceeding the raporteble quantity had occurred at these sites.

The Stete, In effect, de-listed the sites from the Hazardous Site Inventory.

Addition as a new bullet statement Section 1.2, Include as an 901 bullet: The Facilities Compliance Program Office of the Hazardous Waste Management Branch performed a RCRA Facility Assessment (RFA) at Dobbins ARB on Tuesday, 20 July 1999. To date, the Base has not received any written comments or direction from the Stete on the results of the RFA or the Intents of the Stete. In addition, the Stele Hazardous Waste Branch has not provided any review comments or suggestions on any of the subsequent Installation Restoration Program draft and final reports and plans forwarded by the Air Force after the Draft Rl report submltled In 1995.

SECTION 1.3: HIGHLIGHTS OF COMMUNITY PARTICIPATION

Clarification to second paragraph: Page 1-2, Para 1.3, Second paragraph, Third sentence:

The Air Force made Public Notification on 22m!, 24111

, 25111 , and 26111 June 1997 via the local newspaper and letter mailed to the locel community leaders, adjacent property owners, and parties that had previously expressed and Interest In the environmental restoration program at Dobbins ARB. The Base sponsored Public Meeting was held at the Cobb County Central Ubrary on 26 June 1997, as scheduled, In conjunction with the Restoration Advisory Board's (RAB) Scoplng Meeting. Public review and comment period wes officially I aft open until 1 August 1997, but since the Decision Document wes not signed and published at that time, Dobbins AFB has remained open to accept any comments until 1 May 2000. The Air Force has received no comments.

During this second RAB Scoplng meeting held on 26 June 1997, representatives from the Base outlined the overall Installation Restoration Program at Dobbins ARB, described the purpose and benefits of the establishment of a Restoration Advisory Board, announced the availability of the Draft Decision Documents for review, and announced the comment period. The representetlves from the Base outlined the plan to prepare the final Decision Documents, after the public had been afforded the opportunity to address concerns. Community members participating had the opportunity to ask questions; none of the attendees expressed either exception to the date provided or concern with the Air Force's stated position or future plans. In addition, the Base received no additional comments at that time or at any time since that date. As a result of the apparent limited interest from the public and regulatory agencies, the Base Commander determined that community stakeholder Interest was neither sufficient nor sustainable to form a RAB; however, attendees wera placed on the mailing list for subsequent environmental restoration nollflcetions and advertisements.

Addition as a third paragraph: The Air Force sponsored a third Restoration Advisory Boerd Scoplng Meeting to determine community and regulatory agency's Interests In the formation of a Restoration Advisory Board on 30 Sep 1999. Only one community member attended; no regulatory agencies attended. The Dobbins Remedial Program Manager outlined the overall environmental restoration program on-going at Dobbins Air Reserve Base. The community member attending this scoplng meeting did not express concern with the Air Force's

Page 2 of Supplemental Information

To ANAL DECISION DOCUMENT dated September 1997

-----------A'VGASSWDGEBURJALSITE B (DP-06i)----------- Dobblns/'Jr Reserve Base, Georgia ---------------United Slates /'Jr Force

11 May2000 management of the program, or any past action to investigate the sites, nor future plans. Based on guidance provided by the Air Force, and the limited community stakeholder attendance at the scoplng meeting, the Base Commander elected not to form a Restoration Advisory Board, opting Instead to continue notifying local interested parties, elected officials, and State regulatory agencies of changes, phases, or discoveries.

APPENDIX 8: ADMINISTRATIVE RECORD INDEX

The following documentation and correspondence has been Introduced Into the Administrative Record since the June 1997 submission of the draft Decision Document. Each line Item Is an addition to the line Items currently shown In the referenced draft Decision Document and should be Included In the appropriate location as Indicated by the Administrative Record File No (AR File No.) fcund In .the first column.

Addition as a new Administrative Record database line Item updates:

AR Title Type Author Recipient Date Site{&) Notes FileNo

A:J.o. UnUUed correspondence- Corrref RobertP. Jennifer 5Jun LF01, Llrof

L1r ofTrensrnfUal of Drefl DrefiDD Ooersctmer, Kaduck, GA 97 FT02, Transrnll of Decision Oocumen!s to Base CJvJI EPD FT03, DndtDD to GAEPD Engineer, 94 OT04, S1ateEPD

=CE, DP06,

OT07

A.20. UnUUed correspondence- Corrref WDIIarn F Jennifer 19June LF01, l.lr to Publlc

0025 Letters enncuncJna Dec Dec Dec Haber, Kaduck,GA 1997 FT02, Olllclels.

Dec end RAB sc:cpJns end RAB Colonel, EPD, et. al. FT03, Regulatory

ScopJna Conumtnder OT04, agencies, DP06 end DP06, ccntnllll1i1¥ OT07 Slakeholders

A21. UnUUed correspondence Corr ref Alexandra Y. Doerschner July23, FT~ HSRAde-reference "'..sslng on the HSRA Cleary, GA (USAF) 1998 OT-04, JJstJng of H&zardous Stte Inventory" EPD OP-00, stle& And de-Jistlng of 008 OT-07 stle&

A.21. UnUUed correspondence Corrref Jennifer R Doerschner July31, Ref HSRAde-

0015 reference "HSJ 1 0178" HSJ Kaduck, Haz (USAF) 1998 OP-06 JJstJng of stle (DP-06) (HSRA) WealeMnmgt Omplled

Branch, GA reference Is EPD to all stle& on

Dobbins)

A.22. Staff SUmmary Sheet- Corrfor 94SPTG/CEV 94 AW offices 8July AOC1 Jnternel

0010 Decision Oocument fer AOCOO 1999 AOC2 Review& Areas of Concern CocrdlneJJon

Sheet for Pres DO

8.07. DecJsJon Occurnent- Are DO JefferyW. General Publlc April AClC-1 Anal

0110 TnnrungPttlndusUUU lppcllto, 1998 Decision ~ Une (AOC-1) Colcnel, Occurnent

Commander

8.07. Decision Occument- DO JefferyW. General Publlc April AClC-2 Anal

0120 Lockheed POL end Ippolito, 1998 Decision lnd~Wastewater Colonel. Dccument Unes AOC,.2) Commander

C.o1. Community Relations PP..CRP ColWIIJiamP PubUc AflaJrs, Nov LF01, Plan

0010 Plen Kane, Environmental 1999 FT02, nw!eWed Conumtnder, Quality FOght FT03, sernlennually Dobbin& ARB OT04, , ARIJRwiU

DP05, rna!ntelll OP06, Jstest edi1Jon.

OT07,

ST08

Page 3 of Supplemental Information

-------------1\':VGASSLUDGE BURIAL SITES (DP-06}----------

Dobbins />Jr Reserve Base, Georgia ----------------United S1ates />Jr Force

11 May2000

C.02.s Mise RAB Maating PP- 94 SPTG/CE':V General Public 26Juna LF01, RABSccplng Documanta!lon • 1997 RABM!sc 1997 FT02, Agandaand .0040 FT03, Slgn.ln

OT04, Shee1s, DP05, DP06, OT07

C.02.J; Mise RAB Maating PP- 94 SPTG/CE':V General Pubnc Sap LF01, RABSccplng

.0050 Documantation -1999 RABM!sc 1999 FT02, Sign-In

FT03, Sheets, OT04, SQBnda,and DP06, prasantaticn

DP06,

OT07

C.02.~ Untitled ocuespcudanoa- Ccrrref WDIIamF Jannlfer 21 Feb LF01, l.tr to Publlc Lettera announcing RAB RAB Haber, Kaduck,GA 1995 FT02. Olllclals, .0030 seeping Seeping Colona~ EPD FT03, Regulalo!y

Ccmmander OT04, agencies, DP06 and DP06, ocmrnunlt¥ OT07 Stakeholders c.~ UniiUed correspcndance- Ccrrref WDUamF Jannlfer 19Juna LF01, l.tr to PubHc Lettera announcing Dac RAB Haber, Kaduck,GA 1997 FT02. Olllclals, .0040 Doc end RAB seeping Seeping Colonel, EPD, el al. FT03, Ragulatory andDac Ccmmandar OT04, sgancles, Doc DP05 and

DP05, ocmmunlty OT07 Stakeholdars

C.02. Unutled Ccrrespondenoa Ccrr ref JoyoaH. Hal Huddleston 26June LF01, l.trto Base

.0045 .,. Letter Hal Huddleston RAB Carter 1997 FT02. RestoJaUon dated 26 Juna 1997 FT03, Project

OT04, Msneger DP06 about DP06, Interest In

OT07, RAB

ST-06

C.02.t UniiUed ocrrespcndence- Ccrrref JellreyW. Jannlfer 24 LF01, l.tr to PubHc Lettera announcing RAB RAB Ippolito, Kaduck, GA Sap tam FT02. Olllclals, .0050 seeping with maiHng list Seeping Colonel, EPD, et. al. ber FT03. Regulalmy Ccmmandar 1999 OT04, agancles.

DP05 end DP06, ocmrnunlt¥ OT07, Stakeholders

ST..Q8

C.02.~ Restoration Advlecry PP- JefferyW HQ />JFRCICE':V 8May LF01, Cmdr's Boerd Sfalus RASCon Ippolito, 2000 FT02. Declslcn to .0055 Chairperson, FT03, Not Forma

Envlrcnmantal OT04, RAB Protection DP05, Cc~ DP06, OT07, ST08

C.os. Fact Shaet RAB PP.fact 94 SPTG/CE':V General Public 1995 LF01, Fact5hee1s

0010 Sheets &94AWIPA FT02.

FT03,

OT04,

DP05,

DP06,

OT07

C.oa. FactS-. RAB,IRP, PP-Fac 94 SPTG/CE':V General Public 1999 LF01, IRPprogram

0030 Silas s- &94AWIPA FT02. endauaues FT03, Fact Sheets

OT04,

DP05,

DP06,

OT07,

ST08

Page 4 of Supplemental Information

------------AVGASSLUDGE BURIAL SITE B (DP-Q6i)---------- Dobbins /'Jr Reserve Base, Gsorgla ---------------United States /'Jr Force

11 May2000

C.04.

RAB Sooplng Mastlng PP-

Announcemen(S, Atlanta Public Journal Constitution and Nollcs Marl- Dally Journal

C.04.

RAB SCoplng Meeting PP-

AnnOUncements, Atlanta Public Journal Constitution and Notlcs Marietta Dally Journal

Abbreviation reference:

M'- Air Force M'RC- Air Force Reserve Command AOC- Area of Concern Cmdr- Commander Corr- Correspondence DD or Dec Doc- Decision Document DP- Disposal Site e-mail- Eleclronlc Messaging

94AWIPA

94AWIPA

EPD- Environmental Protection DMslon FT- Fire Training facility GA-Georgla HSI - Hazardous Site lnventcry HSRA- Hazardous Site Response Act IRP - Installation Restcretlon Program LF - past Base landfill OT- Lake sediment PP- Public Participation RAD - Restcratlon Advisory Board ST- Tank AsSOciated Raleese

Gsnaral Public

General Public

22, 24, LF01, RABIDD

25,and FT02, Newspaper 26 FT03, Ad June OT04, 1997 DP05, DP06, OT07

Sep LF01, RABIDD 1999 FT02. Newspaper

FT03, Ad

OT04,

DP05,

DP05,

OT07

---------End of Supplemental information;-------

Page 5 of Supplemental Information

FINAL

DECISION DOCUMENT FOR

A VGAS SLUDGE BURIAL SITE B (DP-06)

ENVIRONMENTAL MONITORING PROGRAM

DOBBINS AIR RESERVE BASE, GEORGIA

Contract No. F09609-95-D-0001

Delivery Order No. 5008

Prepared for:

94SPfGICEV 84 Industrial Drive

Dobbins Air Reserve Base, GA 30069-4210

Prepared by:

Montgomery Watson 460 East Swedesford Road, Suite 3010

Wayne, Pennsylvania 19087

September 1997

TABLE OF CONTENTS

Section Page No.

DECLARATION ............................................................................................................... D-1

DECISION SUMMARY

1. INTRODUCTION .................................................................................................... 1-1

1.1 SITE LOCATION AND DESCRIPTION .................................................... l-1

1.2 SITE lllSTORY AND ENFORCEMENT ACTIVITIES ............................. l-1

1.3 IDGHLIGHTS OF COMMUNITY PARTICIPATION ............................. l-2

1.4 SCOPE AND ROLE OF RESPONSE ACTION .......................................... 1-3

2. SUMMARY OF SITE CHARACTERISTICS ........................................................ 2-1

2.1 GEOLOGIC SETTING, PHYSIOGRAPHY, AND CLIMATOLOGY ...... 2-1

22 SOIL ............................................................................................................... 2-2

22.1 Soil Setting ........................................................................................ 2-2

2.2.2 Soil Contamination ........................................................................... 2-2

2.3 GROUNDWATER. ....................................................................................... 2-2

2.3.1 Hydrogeologic Setting ....................................................................... 2-2

2.32 Groundwater Contamination ............................................................ 2-3

2.4 SURFACE WATER ...................................................................................... 2-3

2.5 SEDIMENT ................................................................................................... 2-3

2.6 RECEPTORS ................................................................................................. 2-3

3. RISK ASSESSMENT ............................................................................................... 3-1

3.1 HUMAN HEALTH RISK ASSESSMENT .................................................. 3-1

3.1.1 Current or Existing Exposures .......................................................... 3-3

3.1.2 Hypothetical Future Exposures ....................................................... 3-4

3.2 SUMMARY ...................................................... , ........................................... 3-5

4. DESCRIPTION OF NFRAP ALTERNATIVE ....................................................... 4-l

APPENDIX A REFERENCES

APPENDIX B ADMINISTRATIVE RECORD INDEX

i September 1997 SHARED:FED PROJECI'S:AFRC-126'100!1:08 Dobbins EMP-.Reports:I)Ds Finai:A VOAS SJudse B (DP4l6) DD:Tcxt:Tc:u AVGAS B DDl.doc

9/12197 12:!18 PM

LIST OF FIGURES

Figure No.

1-1 Location Map 1-2 Installation Location Map 1-3 Site Map

2-1 Sample Location Map

LIST OF TABLES

Table No.

2-1 Maximum Detected Concentrations for Constituents of Concern in Soil 2-2 Maximum Detected Concentrations for Constituents of Concern in

Groundwater During the 1995 and 1996 Sampling Rounds

3-1 Exposure Pathway Scenarios ii September 1997 SHARED-.FED PROJECTS:AFRC·I26'11m:OS Dobbt1Ss EMP-.Rcpons:DDs FID:al:AVOAS Sludge 8 (DP-06) DD:Tcxt:Text AVGAS 8 DDZ.dnc

9/1219712:48 PM

• AFCEE

AFFF

API

AFP

AFRC

AFSC

ARARs

ARB

CAR

CFR

COPC

COPEC

DNR

EMP

EPA

ER-L

ER-M

ERA

ES

ESE

F

FS

HHRA

HI

HQ

HSI

HSRA

IRP

MCL

MSL

NAS

NFRAP

NOAA

oc PAHs PCBs

POL

RI

svoc

TBC

IDS

TPH

TSS

USAF

USAFOEHL

USEPA

voc

September 1997

LIST OF ACRONYMS AND ABBREVIATIONS

Air Force Center for Environmental Excellence Aqueous Film-Forming Foam Air Force Instruction Air Force Plant Air Force Reserve Command Air Force Systems Command Applicable or Relevant and Appropriate Requirements Air Reserve Base Comprehensive Analytical Report Code of Federal Regulations Contaminants of Potential Concern Contaminant of Potential Ecological Concern Department of Natural Resources Environmental Monitoring Program Environmental Protection Agency Effects Range - Low Effects Range - Medinm Ecological Risk Assessment Parsons Engineering-Science Environmental Science & Engineering Inc.

Fahrenheit Feasibility Study Hnman Health Risk Assessment Hazard Index Hazard Quotient Hazardous Site Inventory Hazardous-Site Response Act Installation Restoration Program Maximum Contaminant Level Mean Sea Level Naval Air Station No Further Response Action is Planned National Oceanic and Atmospheric Administration Organochlorine Polynuclear Aromatic Hydrocarbons Polychlorinated Biphenyls Petroleum, Oil, and Lubricant Remedial Investigation Semivolatile Organic Compound To Be Considered Total Dissolved Solids Total Petrolenm Hydrocarbuns Total Suspended Solids United States Air Force USAF Occupational and Environmental Health Laboratory United States Environmental Protection Agency Volatile Organic Compound iii SHARED:fED PROJECTS:AFRC-126100S:OS Dobbins EMP-.Rcporu!l)Ds Final:AVGAS Sludge 8 {J)P.()6) OD!Ten:Text AVOAS B DD2.doc

9/12J9712:48 PM

DECLARATION

This Decision Document has been prepared for the AVGAS Sludge Burial Site B (DP-06), a site designated under the Installation Restoration Program (IRP) located at Dobbins Air Reserve Base (ARB}, Georgia (Figure 1-1). This Decision Document has been prepared based on Category ill decision criteria presented as guidance by the United States Air Force (USAF) entitled NFRAP Guide, A Resource for Making, Documenting, and Evaluating No Further Response Action Planned Decisions (USAF, June 1995). This Decision Document is organized into two parts. The first part presents the Declaration, and the second part presents the Decision Summary.

STATEMENT OF BASIS AND PURPOSE

This Decision Document presents the selected action for the site, located at Dobbins ARB, Georgia This decision is based on information obtained from the Remedial Investigation (RI) Report prepared by Parsons Engineering-Science (ES) (ES, 1995) and the Comprehensive Analytical Report (CAR) prepared by Montgomery Watson (Montgomery Watson, 1996). The primary information from these reports used in this Decision Document is the comparison of site concentrations in all environmental media with applicable or relevant and appropriate requirements (ARARs) or to be considered (TBC) criteria, and risk assessment of current or existing exposures to public health and the environment. The risk assessment also evaluated hypothetical future exposures and this evaluation is summarized in Section 3.0. However, for the purposes of this Decision Document, only current or existing exposures were critically reviewed. This is consistent with USAF guidance (USAF, 1995). A summary of the administrative record index of documents prepared for IRP sites at Dobbins ARB is presented in Appendix B.

The primary purpose of this Decision Document is to demonstrate that the response at the site is complete and therefore "no further response action is planned" (NFRAP). Section

2.2.9 of Air Force Instruction 32-7020 (USAF, 1994) states that NFRAP status has been achieved when any of the following conditions apply:

• Investigation finds no evidence of contamination, insignificant levels of contamination, or low levels of contamination that pose no significant current or existing threat to public health or the environment.

• The removal of contamination is complete.

• The cleanup system is in place and operating effectively .

D-1 ~1997 SHARED-.FED PROJECTS:AFRC·I26'1005:08 Dobblm EMP'.Reports:I)Ds Final:AVGAS Sludge 8 (DP-06) DD:Text:T~ AVOAS B DDl.doc

9/12JIJ7 12:48 PM

DESCRIPTION OF SELECTED REMEDY

Studies have demonstrated that contamination was detected at the site at levels that pose no significant risk to public health or the environment. Therefore, Dobbins ARB, has determined that the response at this site is complete and NFRAP status has been achieved.

DECLARATION STATEMENT

This Decision Document represents the selected action for this site developed in accordance with the IRP which nses as its basis the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended by Superfund Amendments and Reauthorization Act of 1986 (SARA), and the National Contingency Plan (NCP). It also satisfies the requirements of the National Environmental Policy Act that applies to CERCLA response actions. It has been determined that the selected remedy of no further action is protective of human health and the environment, attains federal and state requirements that are applicable or relevant and appropriate, and is cost-effective. The statutory preference for further treatment is not satisfied because contaminant levels at the site have been determined to present no significant threat to human health or the environment under current use scenarios for the site .

Colonel William F. Haber, USAFR Date

D-2 September 1997 SHARE~>' .FED PROJECJ'S:AFRC·126700S:08 Doblrins EMP'.Reports:I>Ds Final:AVGAS Sludge 8 (DP'-06) DD:Tcxt:Texl AVOAS B DDl.doc

9112J9712:59 PM

DECISION SUMMARY

1. INTRODUCTION

This Decision Document has been prepared for the A VGAS Sludge Burial Site B (DP-06), a site designated under the Installation Restoration Program (IRP) located at Dobbins Air Reserve Base (ARB), Georgia (Figure 1-1). This Decision Document has been prepared based on Category ill decision criteria presented as guidance by United States Air Force {USAF) entitled NFRAP Guide, A Resource for Making, Documenting, and Evaluating No Further Response Action Planned Decisions (USAF, June 1995). This Decision Smnmary is organized into four sections; Section 1 presents the site introduction, Section 2 presents the site characteristics, Section 3 presents the risk assessment results, and Section 4 presents NFRAP decision summary.

This Decision Document was prepared as part of Delivery Order Number 5008 of Contract Number F09609-95-D-0001 dated September 30, 1995. The contract was issued by the Air Force Reserve Command (AFRC), Dobbins ARB Contracting, Dobbins ARB, Georgia.

1.1 SITE LOCATION AND DESCRIPTION

The AVGAS Sludge Burial Site B (DP-06) is located at Dobbins ARB (Figure 1-2).

Dobbins ARB is located approximately 5 miles northwest of the city limits of Atlanta and consists of 1,964 acres of land under the command of AFRC. An adjoining 709 acres in two parcels located to the north of the site house Air Force Plant 6 (AFP 6), operated by Lockheed-Martin for Air Force Systems Command (AFSC). The Naval Air Station (NAS) Atlanta occupies a tract of land located adjacent to Dobbins ARB. (ES, 1995)

Figure 1-3 presents a map of the site. The AVGAS Sludge Burial Site B (Site DP-06) is located in the area of the present Georgia Army National Guard, Buildings 554 and 555, which is situated on a broad knoll. Diesel and gasoline USTs and a single dispenser island are presently located along the southern side of the building. An interviewee reported during the 1982 record search that a very small quantity of AVGAS sludge (15 gallons) may have been buried at the site; however, no evidence of AVGAS slt!dge burial has been identified during any investigation. Earthmoving activities at the site uncovered some bottles and debris during the 1982 building construction.

1.2 SITE lllSTORY AND ENFORCEMENT ACTIVITIES

The following is a summary of the site history and enforcement activities applicable to the site:

1-1 September 1997 SHARED:FED PR.OJEC'TS:AFRC-1267005!08 Dobbt11s EMP-.Rcpotts:DDs Phlai::A VGAS Sludge B {DP.o6) DD:Text:Text A VGAS B 002.doc

9/12197 3:00PM

• In April 1982, an IRP Records Search was completed by CH2M Hill Inc. for Dobbins ARB. The purpose of the records search was to identify the potential for environmental contamination from past waste management practices and to assess the probability for contaminant migration. The site was identified to pose a potential contamination problem. An interviewee reported during the 1982 record search that a very small quantity of AVGAS sludge (15 gallons) may have been buried at the site. (ES, 1995)

• Following the record reviews, the site was then evaluated to assess its potential for hazardous material contamination and migration. The A VGAS Sludge Burial Site B was found to have a significant potential for contaminant migration, and was recommended for further study. (ES, 1995)

• The site was included in the IRP in 1982. A sample from Well D6-W39 collected in 1990, which contained 115 mg!l of total lead, caused Dobbins ARB to be placed on the Georgia Hazardous Site Inventory (HSI) in 1994. Lead was not detected in samples collected from this well in 1995 or 1996. Investigations and risk assessments were conducted by Environmental Science & Engineering (ESE) in 1988 and 1991, Parsons Engineering-Science (ES) in 1992, and Montgomery Watson in 1995 to address concerns at the site.

• Georgia DNR reviewed a Draft RI Report prepared by ES for the site in 1995. The comments were incorporated into the Final RI Report by ES.

• On June 5, 1997 the Draft Decision Document was submitted to the Georgia Environmental Protection Division (GAEPD). However, the document was not reveiwed by GAEPD.

1.3 illGHLIGIITS OF COMMUNITY PARTICIPATION

An Administrative Record was established in 1988 for the IRP in accordance with CERCLA. A scoping meeting was held in March 1995 to determine the public interest in and availability for the formation of a Restoration Advisory Board (RAB). However, based on the results of that meeting, the RAB was not formed in 1995. The USEPA was actively involved in the review and development of actions and documents during the early stages of the IRP. In addition, GAEPD has reviewed the initial RI documentation, and this documentation is retained within the Georgia Hazardous Site Response Act (HSRA) section .

1-2 September 1997 SHAR.ED-.FED PROJECJ'S:AFRC-1267005:08 Dobbins EMP:Rcpons:I>Ds Final:A VGAS Slt!dgc B CDP.(J6} DD:Text:Te:u AVOAS B DD2.doc

9112191 12:48 PM

A public announcement was placed in the Marietta Journal on June 22, 24, 25, and 26 for the consideration of the formation of a RAB and for the release of the Draft Decision Documents for public review and comment. The public announcement invited interested parties to a public meeting of the RAB on June 26. However, due to a lack of interest the RAB Meeting was not held The public announcement also provided for a review period from June 27 to August 1, 1997 for the Decision Documents. During the review period there was no record of comment on the Decision Documents by the public or the state.

1.4 SCOPE AND ROLE OF RESPONSE ACTION

The following is a chronology of the investigations conducted at the site which included an IRP Phase II Stage 1 Confirmation/Quantification study, a Site Characterization Study, a Remedial Investigation (RI), and an Environmental Monitoring Program (EMP).

In August 1986, ESE completed an IRP Phase II Stage 1 Confirmation/Quantification study. The purpose of this study was to confirm or deny the presence and/or migration of contaminants at the site. The investigation at the A VGAS Sludge Burial Site B consisted of the installation of groundwater monitoring wells, and sampling and analysis of groundwater.

In August 1986, ESE prepared a Phase II- Confirmation/Quantification Stage 1 Final Report and submitted the report to USAF Occupational and Environmental Health Laboratory (USAFOEHL) Technical Services Division. The report recommended that additional monitoring be conducted at the site. (ESE, 1986)

In October 1988, Hunter/ESE conducted a two-part Site Characterization Study in support of an RI to confirm previous results, establish the lateral and vertical limits of contamination, and assess potential risks posed by past waste disposal at the site. As part of the investigation, soil borings and additional monitoring wells were installed at the site and groundwater samples were collected for analysis. In April 1991, ESE prepared a Final Site Characterization Summary for the above investigation and submitted the report to AFRC and Air Force Center for Environmental Excellence (AFCEE). The report was revised by AFRC and AFCEE in December 1991. (ESE, 1991)

In 1992, Parsons Engineering-Science (ES) conducted a RI that included an investigation of the A VGAS Sludge Burial Site B. The purpose of the RI was to document the nature and extent of contamination at the site. Analytical data collected during the previous investigations were supplemented with additional data from the chemical analysis of surface water, sediment and groundwater samples. In 1995, a Remedial Investigation Report was prepared by ES that documented the results of the 1992 investigations and the risk assessment conducted at the site as part of the IRP. (ES, 1995)

In 1995 and 1996, Montgomery Watson conducted an Environmental Monitoring Program (EMP) at the site. The purpose of the EMP was to obtain more recent data for the site, 1-3 September 1997 SHAREI>-..FED PROJECTS:AFRC·126100S:08 Dobbitls EMP-.Re:pons:DDs Flnai:A VGAS Sludse 8 (Dp.()6) DD:TextTCU AVGAS B DD2.doc

9/12197 12:48 PM

compare this data to previous data, and conduct a revised quantitative human health risk assessment (HHRA) that incorporated the new 1995 and 1996 data into the existing data for the site. The five monitoring wells were selected based on the results of previous sampling rounds for additional monitoring to characterize groundwater quality in the vicinity of the site. The results of the EMP as well as historical data were summarized and presented in the Comprehensive Analytical Report (CAR) (Montgomery Watson, 1996) .

1-4 September 1997 SHAREI>-.PED PROJECTS:AFRC·l26100S:08 Dobbl:ns EMP-.hpmts:DJ)s Final:AVOAS Sludge B (DNl6) OD:Teu:Tcxt AVGAS 8 D02.doc

2. SUMMARY OF SITE CHARACI'ERISTICS

This section presents a summary of site characteristics, geology, physiography, soils, groundwater, surface water, sediment, and biota. The receptors at the A VGAS Sludge Burial Site B (DP-06) are also discussed in this section. The analytical data obtained at the site were compared to applicable, or relevant and appropriate requirements (ARARs) or to be considered (TBC) criteria. Georgia Hazardous Site Response Act (HSRA) Type 3 risk reduction levels for soil (Georgia HSRA 391-3-19 Appendix Ill) were used for soil ARARs at the site. Georgia HSRA Type 3 Risk Reduction Levels were used for groundwater ARARs at the site. For most analytes the Georgia Type 3 Risk Reduction Levels for groundwater are the same as the USEPA Maximum Contaminant Levels (MCLs) for public water supplies. Figure 2-1 shows sample locations at the site. A complete summary of ARARs for detected analytes at the site is presented in the CAR (Montgomery Watson, 1996).

2.1 GEOLOGIC SETIING, PHYSIOGRAPHY, AND CLIMATOLOGY

The A VGAS Sludge Burial Site B (DP-06) is located in the Central Uplands district of the Piedmont physiographic province. This district is characterized by a series of low, linear ridges separated by broad, open valleys. Streams flowing through this area are generally transverse to the underlying geologic structure and occupy valleys 150 to 200 feet below the ridge crests. The site is underlain by the Powers Ferry Formation, which is part of the Sandy Springs Group. The Powers Ferry Formation consists of interbedded gneisses, schists, and amphibolites. Depth to bedrock was encountered at the site at 4 and 20.4 feet respectively. (ES, 1995)

The general area around Dobbins ARB is situated on a gently rolling plateau that slopes gradually downward to the Southeast. The plateau is dissected by several small stream channels, including Rottenwood and Poorhouse Creeks. Elevation at the site is approximately 1,040 feet above mean sea level (MSL).

The climate at the site is characteristic of the northern temperate zone, with four clearly separated seasons and a predominant weather movement from west to east. The average annual temperature at Dobbins ARB is 61 degrees Fahrenheit ("F), with an average daily maximum and minimum of 70 °F and 51 °F respectively. Dobbins ARB experiences an average of 58 days with freezing temperatures each year. (ES, 1995)

The average annual rainfall at Dobbins ARB is 52.6 inches. Precipitation is distributed fairly evenly throughout the year, although minor peaks in the rainfall curve are generally recorded in early spring and in mid-summer. An average of about 2 inches of snowfall is recorded each year between December and March. Lake evaporation is approximately 40

2-1 September 1997 SHARED:FED PROlECTS!AFRc-l2671XJS:Q8 DobbinS EMP'.Repons'.DDs Final:AVOAS Sludge B {01416) DD:Tcxt:T~ AVGAS B DD2.aoc

9112197 12:48 PM

inches per year; evapotranspiration over land areas may be greater or less than this value, depending on vegetative cover type. (ES, 1995)

2.2 SOIL

2.2.1 Soil Setting

Soil at the site consists of silt, sandy silt, and silty clay. The depth to bedrock beneath the site is unknown, as bedrock has not been encotmtered in any borings advanced at the site.

(ES, 1995)

2.2.2 Soil Contamination

A summary of historical soil analytical results obtained at the site is presented in the CAR.

Table 2-1 summarizes the maximum concentrations for constituents of concern in soil samples collected at the site. No volatile organic compotmds (VOCs), semivolatile organic compotmds (SVOCs), pesticides or PCBs (Pest!PCBs) were detected above regulatory limits in any of the soil samples collected from the AVGAS Sludge Burial Site B. Total petroleum hydrocarbons (TPH) at two soil boring locations exceeded the Georgia tmdergrotmd storage tank (UST) rules for non-sensitive sites that were effective at the time that the RI Report (Parsons ES, 1995) was written. Current Georgia UST rules do not contain such values for TPH (State of Georgia, 1990). These borings were located in the central part of the site. For metals, antimony, arsenic, beryllium, chromium, cobalt, nickel, thallium, vanadium and zinc were all detected above Type 3 Risk Reduction Levels (as listed in Table 2-1) in more than one sample. However, based on soil results obtained at Dobbins ARB, the elevated metals concentrations may be naturally occurring.

2.3 GROUNDVVATER

2.3.1 Hydrogeologic Setting

Grotmdwater from A VGAS Sludge Bmial Site B flows eastward towards Big Lake based on grotmdwater measurements recorded in November 1995 and March 1996. Depth to grotmdwater below grotmd surface (bgs) at the site ranged from approximately 2.5 feet bgs in the northern end of the site to almost 30 feet bgs at the location of well D6-W16. The gradient at the site as measured between wells D6-W16 and D6-W27 in March 1996 and November 1995 is 0.03 feet/foot. Information regarding the hydraulic conductivities of subsurface materials at the site is not available. Grotmdwater potentiometric surface measurements obtained during the most recent sampling rotmds at the site are consistent with data reported previously, suggesting that the direction of grotmdwater flow does not change seasonally .

2-2 September 1997 SHAREO-.PED PROJECJ'S:AfRC·I26700S:08 Dobblas EMP:Repans:DDs Finai:AVOAS Slmlgc B (DP-06) DD:TcxtText AVOAS B DDl.doc

9112NI 12!48 PM

2.3.2 Groundwater Contamination

A summary of historical grmmdwater analytical results obtained at the site is presented in the CAR. Table 2-2 summarizes the maximum concentrations for constituents of concern detected in groundwater samples collected during the two most recent sampling rounds (1995 and 1996) at the site. The only VOC detected at the site that exceeded ARARs was 1,2-dicbloropropane (during the 1989 sampling round). However, 1,2-dicbloropropane was not detected at the site in any of the samples obtained in subsequent sampling rounds. As shown in Table 2-2, VOCs were not detected at concentrations that exceeded the Georgia Type 3 Risk Reduction Levels at the site during the 1995 and 1996 groundwater sampling rounds. The only SVOC detected in groundwater collected from A VGAS Sludge Burial Site B that exceeded the ARAR of 20 (.Lgl1 is naphthalene. Pesticides and PCBs have not been detected in groundwater samples collected from the site. Although several metals exceeded Georgia Type 3 Risk Reduction Levels in unfiltered samples collected during the 1989 and 1990 sampling rounds, only cadmium and lead exceeded the ARAR of 5 (.Lgl1 when samples were collected during the 1995 and 1996 sampling rounds at the site.

2.4 SURFACEWATER

No surface water was identified during the R1 or EMP as being potentially affected by site operations. As a result, no surface water samples were collected for analysis at the site.

2.5 SEDIMENT

No sediment was identified during the R1 or EMP as being potentially affected by site operations. As a result, no sediment samples were collected for analysis at the site.

2.6 RECEPTORS

1n the risk assessment, two risk scenarios were evaluated for this site; current use and hypothetical future use. For the purposes of this decision document, only the current use exposure scenario is critically reviewed. Under the current land use scenario, the potential hmnan receptors at the site are the base personnel and nearby residents who may or may not have access and exposure to present AFRC operations. No exposure to groundwater exists for hmnan receptors under the current land use scenario. Dobbins ARB presently receives its water from Air Force Plant 6 (AFP 6), which in turn, receives its water from the Cobb-Marietta Water Authority. This water supply is derived from off-site surface water sources. No public groundwater supply wells exist within 3 miles of Dobbins ARB.

Sixteen inactive water supply wells were located on Dobbins ARB or Air Force Plant 6, however, the wells have been inactive since the early 1950s. Fifteen of these previous well locations were filled in and covered during the early 1980s and are no longer accessible. The

2-3 September 1997 SHARBO:FEI> PROJECTS:AFRC•J26700l:03 Dobbias EMP'.Repon:s:DDs Final:AVOAS Sludp 8 (DP-()6) DD:Text:Tcxt AVGAS 8 DD2.doc

9112191 12:48 PM

closure status of the remaining inactive well location is not known. (ES, 1992) As a result, no human receptors to groundwater exist under the current land use scenario.

Under the current use scenario, installation personnel were found to be potentially exposed to surface soils at the site. No ecological receptors were identified for this site under the current use scenario, however.

Under the future use scenario, the hypothetical future commercial use scenario was chosen because of the likelihood that, should the base be closed, it would be developed as a municipal-type airport with associated businesses and industries. The potential human receptors under this hypothetical future scenario are industrial workers or construction workers at a industrial/commercial facility located at the site. No ecological receptors were identified for this site under the future use scenario .

2-4 September 1997 SH.ARED-.FED PROJEC'I'S:AFRC·I26700S:OS Oobbtos EMP'.Repons:DDs Fillal:AVGAS Sludge B {DP-06) DD:Tcxt:Tcxt AVGAS B DD2.doc

911211J7 12:48 PM

• 3. RISK ASSESSMENT

A baseline risk assessment was initially conducted to characterize the potential risks to hmnan health (HHRA) and the enviromnent (ERA) posed by constituents detected at AVGAS Sludge Burial Site B (DP-06). The HHRA was conducted for the site by ES to assess the risks associated with potential exposures to receptors, and the results were presented in the Rl Report (ES, 1995). A qualitative HHRA was conducted by Montgomery Watson in 1996 to establish whether differences in the data obtained during the 1995 and 1996 sampling rounds could potentially result in increased hmnan health risks, and if so, necessitate a revised quantitative risk evaluation. The HHRA presented in this section is based on the quantitative HHRA presented in the Rl Report prepared by ES (ES, 1995).

3.1 HUMAN HEALTH RISK ASSESSMENT

The HHRA evaluates the contaminants detected at this site, potential exposure pathways between compounds and hmnan receptors and the potential hmnan health risks posed by these exposures. The four basic steps in this assessment are as follows: (1) identification of contaminants of potential concern (COPC), (2) exposure assessment, (3) toxicity assessment, and (4) risk characterization.

All constituents detected in the various enviromnental media during multiple sampling investigations (ES, 1995; Montgomery Watson, 1996) were evaluated to determine COPes for analysis in the risk assessment. Traditional risk assessment criteria (EPA, 1989a) used in selection of COPes included frequency of detection, comparison with laboratory and field blanks, and comparison with background concentrations.