EPA Document April 2009
EPA Document for the Revised National Priorities List Final Rule - Fort Detrick Area B Ground Water
Following is an excerpt of the EPA document April 2009
3.2 Need for Listing
Comment: The Army maintains that listing of the site on the NPL is unnecessary. It claims that it has made substantial progress on the completion of the environmental remediation of Fort Detrick, working in close cooperation with the State, local community, and more recently EPA. The Army stated that it “has CERCLA remedies in place or has achieved complete response [sic] for 35 of 42 sites [sources], has provided alternative drinking water supplies to affected and potentially affected drinking water well users, and has performed or will be conducting CERCLA remedial capping actions in Spring 2009 at source areas for the Area B Ground Water contamination.” The Army argued that the work was performed under the Defense and Environmental Restoration Program (DERP) and CERCLA, and the final response for the site action is underway. The Army stated that it will continue to work in full cooperation with EPA, MDE, the Restoration Advisory Board (RAB), and members of the public to complete the necessary remediation regardless of the decision to list the site on the NPL.
Response: EPA considers it appropriate and advisable to add the site to the NPL, to facilitate protection of human health and the environment. The addition of the Fort Detrick Area B Ground Water site to the NPL is fully consistent with EPA regulations and guidance. To date, despite repeated State requests and a 1999 recommendation from the Army's own expert Advisory Panel, a thorough investigation of the nature and extent of contamination of ground water has not been completed; thus, progress has not been as positive as the Army suggests. Since Fort Detrick Area B is in close proximity to the drinking water supply for one of the most densely populated and fastest growing areas of Frederick County, the lack of a completed investigation is of concern and represents an unacceptable risk to human health and the environment. The formal regulatory process provided by NPL listing will help ensure that the threat posed by releases of TCE and PCE to the ground water in the area of Fort Detrick that are attributable to the Fort Detrick Area B Ground Water site is addressed properly and promptly. However, The State of Maryland agrees with EPA regarding the listing, as documented in the March 6, 2008, letter from Governor Martin W. O’Malley. Governor O’Malley was explicit in his support for placing the site on the NPL. His letter states:
The State of Maryland strongly urges the U.S. Environmental Protection Agency to carry out its responsibilities under federal law and to place Fort Detrick's Area B parcel on the National Priorities List. The formal regulatory process provided by a NPL listing is critical to ensure that the State's groundwater supply in the area of Fort Detrick is protected for our citizens.
Since the early 1990s, Maryland has worked with Fort Detrick to encourage investigation of chemical contamination and the potential offsite impacts to groundwater. The facility ultimately acknowledged responsibility for the release and provided potable water connections for several impacted residential properties. . .
Fort Detrick Area B Ground Water NPL Listing Support Document April 2009
While we are greatly encouraged by the leadership and communication of the current command staff at Ft. Detrick, it is imperative that EPA list the site on the NPL to ensure a long term commitment to this investigation and cleanup.
Moreover, the aquifer underneath the Fort Detrick Area B Ground Water site is among the most contaminated aquifers in the nation. In the HRS evaluation of the site, the ground water pathway yielded a site score of 50.00, the highest possible score for evaluation of a single migration pathway, and substantially above the 28.50 required for listing a site on the NPL. While some progress has been made on the remediation of some areas of the site (see, for example, sections 3.8.1, Waste Quantity after Removal Actions, and 3.14.1, Provision of Alternative Water Supplies, of this support document), other sources identified in the HRS documentation record at proposal have not been addressed, and no plans for final remediation of the contaminated ground water have been agreed upon by EPA.
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