Land Use Control Remedial Design for Site 5 - Former Fire Training Area

Transcription

1 Land Use Control Remedial Design for Site 5 - Former Fire Training Area Former Naval Air Station Joint Reserve Base (NAS JRB) Willow Grove, Pennsylvania Naval Facilities Engineering Command Mid-Atlantic Contract No. N D-1001 Contract Task Order WE05 May 2013

2 PHIL LAND USE CONTROL REMEDIAL DESIGN for SITE 5 - FORMER FIRE TRAINING AREA FORMER NAVAL AIR STATION JOINT RESERVE BASE (NAS JRB) WILLOW GROVE, PENNSYLVANIA COMPREHENSIVE LONG-TERM ENVIRONMENTAL ACTION - NAVY (CLEAN) CONTRACT Submitted to: Naval Facilities Engineering Command Mid-Atlantic 9742 Maryland Avenue Norfolk, Virginia Submitted by: Tetra Tech 234 Mall Boulevard, Suite 260 King of Prussia, Pennsylvania CONTRACT NO. N D-1001 CONTRACT TASK ORDER WE05 MAY 2013 PREPARED UNDER THE DIRECTION OF: APPROVED FOR SUBMISSION BY: PROJECT MANAGER TETRA TECH KING OF PRUSSIA, PENNSYLVANIA ~G~.--L HN TREPANOWSKI, P.E. PROGRAM MANAGER TETRA TECH KING OF PRUSSIA, PENNSYLVANIA

3 TABLE OF CONTENTS SECTION PAGE ACRONYMS... ii 1.0 INTRODUCTION BACKGROUND AND SITE DESCRIPTION LAND USE CONTROLS LAND USE CONTROL IMPLEMENTATION ACTIONS REFERENCES... 7 APPENDICES A LAND USE CONTROL COMPLIANCE INSPECTION CHECKLIST TABLE NUMBER 1 SUMMARY OF LAND USE CONTROL IMPLEMENTATION ACTIONS NUMBER 1 SITE 5 - LOCATION MAP 2 SITE 5 - LAND USE CONTROL AREA FIGURES L/DOCUMENTS/NAVY/02014/25012 i CTO WE05

4 ACRONYMS BRAC CERCLA CTO DoD EPA FFA FS FFTA GIS LUC MNA NAS JRB NAVFAC NCP OU PADEP PAH RD RI ROD RPM VOC Base Realignment and Closure Comprehensive Environmental Response, Compensation, and Liability Act Contract Task Order Department of Defense Environmental Protection Agency Federal Facilities Agreement Feasibility Study Former Fire Training Area Geographic Information System Land use control Monitored Natural Attenuation Naval Air Station Joint Reserve Base Naval Facilities Engineering Command National Contingency Plan Operable Unit Pennsylvania Department of Environmental Protection Polycyclic aromatic hydrocarbon Remedial design Remedial Investigation Record of Decision Remedial Project Manager Volatile organic compound L/DOCUMENTS/NAVY/02014/25012 ii CTO WE05

5 1.0 INTRODUCTION This document constitutes the Land Use Control (LUC) Remedial Design (RD) for Site 5 - Former Fire Training Area (FFTA) at the former Naval Air Station Joint Reserve Base (NAS JRB) Willow Grove, in Horsham, Pennsylvania. This document was prepared by Tetra Tech, Inc. (Tetra Tech) for the Navy s Naval Facilities Engineering Command (NAVFAC) under Contract No. N D-1001, Contract Task Order (CTO) No. WE05. The Navy s Base Realignment and Closure (BRAC) Program Management Office, Northeast, is the lead agency conducting the evaluation and cleanup of NAS JRB Willow Grove. The LUC RD was developed as part of the remedial design for Site 5 FFTA to address land use control implementation actions in accordance with the Site 5 Record of Decision (ROD) (Navy, 2012) and the Federal Facilities Agreement (FFA) for NAS JRB Willow Grove. This document is considered a primary document in accordance with the FFA, and has been prepared in accordance with the Navy Principles as agreed to by the U.S. Environmental Protection Agency (EPA) and the Department of Defense (DoD) (DoD, 2003). 2.0 BACKGROUND AND SITE DESCRIPTION The former NAS JRB Willow Grove is located in Horsham Township in Montgomery County, Pennsylvania. NAS JRB Willow Grove occupied approximately 900 acres of the 1,100 acres the Department of Defense (DoD) maintained at the Air Station (Figure 1). The primary mission of NAS JRB Willow Grove was to provide support for operations involving aviation training activities, and to train Navy reservists. NAS JRB Willow Grove supported other DoD tenants such as the Marine Reserve and the Army Reserve, and shared facilities and services with the Air Force Reserve. The former NAS JRB Willow Grove was selected in 2005 by the BRAC Commission for closure, and was officially disestablished on March 30, Site 5 originated from an FFTA located on the southern side of the former NAS JRB Willow Grove that covered an irregularly shaped area of approximately 1.25 acres (Figure 1). Fire training operations included the temporary staging and subsequent burning of flammable liquid wastes from 1942 through 1975, when burning operations ceased. Suspected sources of contamination at Site 5 include the spillage of waste volatile organic compounds (VOCs) temporarily staged along the access road before transfer to the former burn ring, and minor amounts of polycyclic aromatic hydrocarbons (PAHs) in waste liquids that were spilled in the immediate vicinity of the burn ring during their burning. When excavated, the burn ring was found to have a competent steel bottom, which accounts for the lack of VOC contamination in the vicinity of the ring. L/DOCUMENTS/NAVY/02014/ CTO WE05

6 Site 5 groundwater was designated as operable unit (OU) 2. Remedial Investigation (RI) results showed VOC concentrations in groundwater at levels producing unacceptable risks for future exposure scenarios. VOC concentrations were greatest at the water table immediately below the staging area, and decreased with both lateral distance away from and vertical depth below this zone of highest contamination. The Feasibility Study for Site 5 groundwater, completed in 2008, evaluated several remedial alternatives to address the unacceptable risks identified during the remedial investigation (Tetra Tech, 2008). In April 2009, the Navy began implementation of a Site 5 groundwater bioremediation pilot study which utilized biostimulation to promote population growth of native bacterial populations by creating more favorable environmental conditions. Biostimulation consisted of injection and recirculation of sodium bicarbonate and sodium lactate. Analytical results for most of the parameters monitored indicated that the first stages of the test were successful, except that there was an insufficient bacterial population capable of degrading vinyl chloride. In June 2010, the Navy, in consultation with EPA and the Pennsylvania Department of Environmental Protection (PADEP), decided to continue pilot testing at Site 5 with the addition of appropriate biological stocks (bioaugmentation), including bacteria capable of degrading vinyl chloride. Results indicate that bioremediation has proven to be an effective strategy for destroying the Site 5 groundwater contaminants through the anaerobic, reductive dechlorination process. In addition, the Site 5 groundwater recirculation system has been very effective at distributing the biostimulation amendments throughout the remediation cell (Tetra Tech, 2011). The results of the pilot test provided the basis for determining that bioremediation should be a major component of the remedy for the site. In September 2012, the ROD for Site 5 groundwater was signed by the Navy and EPA. The major components of the Selected Remedy for Site 5 groundwater include the following: In-situ anaerobic bioremediation of contaminated groundwater within the source area until VOC concentrations meet established cleanup levels (i.e., remedial goals). Monitored Natural Attenuation (MNA) of the groundwater plume downgradient of the source area. Implementation of LUCs to prohibit the use of untreated OU 2 groundwater, and to mitigate the potential for vapor intrusion from the subsurface into future structures until contaminants in groundwater are at levels that allow for unlimited use and unrestricted exposure. The use of treated groundwater must be approved by the Navy, EPA, and PADEP. L/DOCUMENTS/NAVY/02014/ CTO WE05

7 Long-term groundwater monitoring until the plume has attenuated to concentrations that meet the established cleanup levels. 3.0 LAND USE CONTROLS LUCs are used at sites where contaminants are left in place at levels that do not allow for unlimited use and unrestricted exposure. The LUCs ensure that any remaining contaminants do not pose an unacceptable risk to human health and the environment. LUCs can consist of institutional controls and/or engineering controls. Institutional controls, such as restrictions and notifications, are typically legal documents in the form of deed restrictions, easements, and restrictive covenants. In the form of a legal document, the institutional controls will run with the land. Engineering controls are typically barriers, such as a fence. The ROD selected LUCs, including institutional controls, as components of the final remedy for Site 5 groundwater to control or restrict certain types of property use. The LUCs included in the selected remedy will be maintained until concentrations of hazardous substances have been reduced to levels that allow for unlimited use and unrestricted exposure. The following is the Site 5 groundwater LUC performance objective: Prohibit the use of untreated groundwater, and mitigate the potential for vapor intrusion from the subsurface into future structures until contaminants in groundwater are at levels that allow for unlimited use and unrestricted exposure. Require that existing buildings install a system to mitigate potential intrusion of VOCs from the subsurface into the structure, or be subject to a vapor intrusion investigation that documents that an unacceptable risk to future occupants is not present at that structure. The use of treated groundwater must be approved by the Navy, EPA, and PADEP. Institutional controls will be implemented to ensure that the above LUC performance objective is met. Figure 2 presents the area encompassing Site 5, the groundwater VOC plume, and the LUC boundary. The LUCs established for Site 5 groundwater include the set of restrictions defined below. Following EPA and PADEP approval of the LUC RD, the restrictions will be imposed on the site property to ensure that the LUC performance objective is met. The following activities and uses are inconsistent with the LUC performance objective and are prohibited. Use of untreated groundwater at the site. The use of treated groundwater must be approved by the Navy, EPA, and PADEP. L/DOCUMENTS/NAVY/02014/ CTO WE05

8 Construction of future structures without measures to mitigate the potential for vapor intrusion from the subsurface into the structure. Use of existing buildings without installation of a system to mitigate potential intrusion of VOCs from the subsurface into the structure, or without the performance of a vapor intrusion investigation that documents that an unacceptable risk to future occupants is not present at that structure. The following activities and uses are consistent with the LUC performance objective and will be allowed in the Site 5 groundwater LUC Area as shown on Figure 2: Environmental investigations and/or remedial actions conducted per approved work plans. Implementation actions to be taken to ensure that the LUC objectives are met are discussed in the following section. Section 4.0 also defines the required notifications and authorizations, and the roles and responsibilities for implementing the actions. 4.0 LAND USE CONTROL IMPLEMENTATION ACTIONS Pursuant to the ROD, the Navy is responsible for implementing, inspecting, reporting, and enforcing the institutional controls in accordance with this LUC RD. For purposes of the LUC RD, the term implementation actions means actions to implement, operate, maintain, and enforce the LUC component of the remedy. The Navy will perform all short- and long-term implementation actions at Site 5 per DoD guidance (DoD, 2003), the FFA, the ROD, and applicable Navy directives. Although the Navy may in the future delegate or transfer authority to conduct these actions to another entity as part of property transfer agreements (i.e., deed), the Navy shall retain ultimate responsibility for remedy integrity. As set forth in this LUC RD, the following implementation actions will be performed by the Navy to ensure that the LUC objectives are met in accordance with the FFA and the ROD. These are summarized in Table Prepare a map defining the Site 5 groundwater LUC Area boundaries. Depict on this map the location and boundaries of Site 5 and the extent of area over which the LUCs apply (Figure 2). 2. Submit a copy of Figure 2 and a listing of the LUCs that have been imposed to the land record office of Horsham Township, Montgomery County, Pennsylvania, for the limited purpose of providing public notice of the property s environmental conditions and use limitations. Additionally, provide copies of Figure 2 to EPA Region 3 and PADEP. L/DOCUMENTS/NAVY/02014/ CTO WE05

9 3. Monitor compliance with the LUCs. Conduct LUC monitoring to verify LUCs are being properly implemented and that the LUC objective is being met. Conduct LUC compliance inspections on an annual basis unless the frequency is reduced by agreement with the Navy, EPA Region 3, and PADEP. A checklist to be used during LUC inspections is provided as Appendix A. Provide the LUC monitoring and compliance inspection results to EPA Region 3 and PADEP as part of an annual report. 4. Report to and notify regulatory agencies. The following is a summary of the notification requirements: a. Notify EPA Region 3 and PADEP 45 days in advance of any proposed change in land use that would require modifications to the LUCs to maintain consistency with the LUC objective or the selected remedy. In the notice, describe how the LUCs will be changed, and the mechanisms by which the new LUCs will be implemented to maintain protectiveness of the remedy. b. Notify EPA Region 3 and PADEP by telephone and written communication as soon as practicable, but within 10 working days, after discovery of any activity that is inconsistent with the LUC objective, or any other action that may interfere with the effectiveness of the LUCs. Notify EPA and PADEP regarding how the breach will be or has been addressed within 10 working days of sending the initial discovery notification of the breach activity. For more complex breach situations, initiate a telephone call within this 10-day period among Navy, EPA Region 3, and PADEP to discuss options for addressing the breach; this will be considered sufficient to meet this notification requirement. Furthermore, address as soon as practicable any activity that is inconsistent with the LUC objectives or use restrictions, or any other action that may interfere with the effectiveness of the LUCs. In all cases, initiate this process no later than 10 days after the Navy becomes aware of the breach. c. Notify EPA Region 3 and PADEP in writing at least 6 months prior to any anticipated sale or transfer of the property out of Navy custody and control which is subject to LUCs, including any federal-to-federal transfer; this will be done so that EPA Region 3 and PADEP can be involved in the discussion with Navy on the appropriate provisions to be included in the transfer terms and conveyance documents to maintain effective LUCs. If it is not possible to make this notification at least 6 months prior, make this notification as soon as possible, but no later than 60 days prior to the transfer or sale of the property subject to LUCs. Provide a copy of the executed deed or transfer documents to EPA Region 3 and PADEP within 30 days of the effective date of the transfer. L/DOCUMENTS/NAVY/02014/ CTO WE05

10 d. Submit reports of annual monitoring no later than the 30 th day of September annually. Conduct LUC compliance monitoring and inspections annually, and submit the results to EPA Region 3 and PADEP. Use the annual reports in the preparation of the Five-Year Review to evaluate the effectiveness of the remedy. Evaluate the status of the LUCs in the annual report, and discuss how any deficiencies or inconsistent uses of the property have been addressed. Also in the annual report, address whether Navy instructions remain current in regards to LUC enforcement, and whether use of the property has conformed with such restrictions and controls. 5. Obtain EPA Region 3 concurrence, in consultation with PADEP, prior to modifying or terminating the LUCs or implementation actions. Seek prior concurrence from EPA Region 3, in consultation with PADEP, before taking any anticipated action that may disrupt the effectiveness of the LUCs, or before taking any action that may alter or negate the need for LUCs. 6. Evaluate the effectiveness of the LUCs as part of each Five-Year Review. Site remedy reviews are required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Contingency Plan (NCP) as specified by the Site 5 ROD. Submit Five-Year Reviews to EPA Region 3 and PADEP for review as per the FFA. Should the Navy fail to complete a required LUC implementation action, EPA shall notify the Navy Remedial Project Manager (RPM) and seek immediate action. If the Navy fails to complete a required LUC implementation action within a reasonable time of being so notified, EPA may notify the Deputy Assistant Secretary of the Navy (Environment), who will ensure that necessary action is taken. Should a subsequent owner of or a third party at the Site 5 property fail to complete a required LUC implementation action, for which such owner or party is responsible, EPA and the Navy will consult on the appropriate enforcement action. If after the property has been transferred, the Navy fails to complete a required LUC implementation action for which it is responsible, EPA will notify the Navy RPM. If necessary, EPA may notify the Deputy Assistant Secretary of the Navy (Environment), who will ensure that necessary action is taken. LUCs may no longer be needed should hazardous substances, pollutants, or contaminants cease to remain on site above levels precluding unlimited use and unrestricted exposure to groundwater. L/DOCUMENTS/NAVY/02014/ CTO WE05

11 5.0 REFERENCES DoD (Department of Defense), The Principles and Procedures for Specifying, Monitoring and Enforcing Institutional Controls and Other Post-ROD Actions. Navy (U.S. Department of the Navy), Record of Decision for Site 5 Former Fire Training Area, Naval Air Station Joint Reserve Base Willow Grove, Pennsylvania. June. Tetra Tech, Feasibility Study for Site 5 - Fire Training Area, Groundwater (OU 2), NAS JRB Willow Grove. November. Tetra Tech, Site 5 Pilot Test Report, NAS JRB Willow Grove. May. L/DOCUMENTS/NAVY/02014/ CTO WE05

12 TABLE

13 TABLE 1 SUMMARY OF LAND USE CONTROL (LUC) IMPLEMENTATION ACTIONS SITE 5 FORMER FIRE TRAINING AREA GROUNDWATER FORMER NAS JRB WILLOW GROVE WILLOW GROVE, PENNSYLVANIA LUC REQUIREMENT/DESCRIPTION Issue final LUC RD Conduct LUC compliance inspections Issue Inspection Report to EPA and PADEP Navy must notify EPA and PADEP of activities that are inconsistent with LUC objectives, restrictions, or effectiveness and how these activities were/will be addressed Navy will notify EPA and PADEP of proposed land use change(s) inconsistent with LUCs or any component of the selected remedy Navy will notify EPA and PADEP prior to transfer or sale of the Site 5 property Navy will notify EPA and PADEP and invite comment prior to modifying, terminating, or implementing internal LUC-related policies or procedures if such changes are likely to negatively impact the effectiveness of the LUCs FREQUENCY INSTITUTIONAL CONTROLS Once Annually Annually NOTIFICATION REQUIREMENTS Per event, within 10-days after the event has occurred Per event, 45 days in advance Per event, typical 6 months advance notice, but not less than 60 days Per event, 14 days prior to implementation of requested change L/DOCUMENTS/NAVY/02014/25012 CTO WE05

14 FIGURES

15

16 NATURAL ATTENUATION, LONG-TERM MONITORING, AND LAND USE CONTROLS IN-SITU ANAEROBIC BIOREMEDIATION TOTAL VOCs LEGEND TOTAL VOCs, SUMMER 2005

17 APPENDIX A LAND USE CONTROL COMPLIANCE INSPECTION CHECKLIST

18 LAND USE CONTROLS (LUCs) INSPECTION CHECKLIST SITE 5 FORMER FIRE TRAINING AREA (GROUNDWATER) FORMER NAS JRB WILLOW GROVE Page 1 of 2 SITE 5 (GROUNDWATER) LAND USE CONTROLS Prohibition of groundwater use for human consumption without Navy, EPA and PADEP approval Require that future structures contain measures to mitigate the potential for vapor intrusion from the subsurface Require that existing buildings, prior to reuse, install a system to mitigate potential for vapor intrusion from the subsurface or conduct a vapor intrusion investigation that documents there is no unacceptable risk to future occupants SITE 5 (GROUNDWATER) LUC INSPECTION CHECKLIST Inspection Item Y/N/NA Summary of Inspection Performed/Comments Has site use changed since last inspection? Is there visual evidence of unauthorized groundwater use? Is there any visual evidence of reuse of the existing buildings? If reuse of existing buildings has occurred, has a vapor intrusion mitigation system been installed or has an investigation documenting no unacceptable risk been performed? Is there visible evidence of new building construction? If new buildings have been constructed, do they contain vapor intrusion mitigation measures?

19 LAND USE CONTROLS (LUCs) INSPECTION CHECKLIST SITE 5 FORMER FIRE TRAINING AREA (GROUNDWATER) FORMER NAS JRB WILLOW GROVE Page 2 of 2 SITE 5 DOCUMENTATION CHECKLIST Inspection Item Y/N/NA Summary of Inspection Performed/Comments Are there correspondence records ( s, letters) on file documenting EPA and PADEP notifications regarding LUCs? If yes, explain. Are activities inconsistent with LUCs? Are corrective actions regarding activities inconsistent with LUCs? Are there changes in procedures affecting LUCs? Are there proposed land use changes? Is there a proposed transfer or sale of the property? Navy Annual Certification: I hereby certify that a complete and thorough inspection and an evaluation of compliance with land use controls established for the site in the 2012 Record of Decision have been performed and that the items noted on this inspection form have been assessed with respect to the intent of the implemented remedial action objectives for the site. Navy Representative Title Signature Date Onsite Inspection Team: Lead Inspector Title/Affiliation Signature Date Others present: Name Affiliation Name Affiliation