Camp Hero FUDS — public meeting transcript and appendices

The investigation area for this RI was limited to the subset of Camp Hero State Park that contains the footprint of the former military operations, excluding the two parcels Area H and Area K. The majority of the Camp Hero FUDS property (415 acres of the total 461 acres) is used as an NYS Park. Approximately 46 acres within the Camp Hero FUDS boundary is owned by the Town of East Hampton and used for affordable housing, which consists of 27 former Air Force housing units located along the south side of Montauk Highway (Route 27).

Future land use is anticipated to remain the same. Correspondence from NYSOPRHP to the USACE on future park use plans indicated that NYSOPRHP may add new camping areas and new trails to the Park.

The purpose of the Responsiveness Summary is to provide responses and information to all inquiries and concerns provided during the public review of the PP for the Camp Hero FUDS in Montauk, New York. The PP was issued by the USACE, which is the DoD executive agent for the DERP - FUDS program, in coordination with the NYSDEC, NYSDOH, and the NYSOPRHP. The USACE issued the PP as part of its public participation responsibilities under CERCLA Section 117(a), 42 USC Section 9617(a) and the NCP Section 300.430(f)(2).

The USACE issued the PP for public review on 1 October 2019 and invited interested members of the public to review and comment on the PP during a 45-day Public Comment Period from 1 October 2019 to 15 November 2019. A Public Meeting and Hearing was hosted on 24 October 2019. Participants in the public meeting included general community members and representatives of the USACE, NYSDEC, NYSDOH, and NYSOPRHP. Oral comments were received during the Public Meeting. USACE did not receive any written comments.

The regulatory agency (NYSDEC) and property owner (NYSOPRHP) agreed with the NFA decision. However, there were concerns from the public, including the Town of East Hampton, concerning the lack of an investigation of the UGA from which drinking water is obtained.

This responsiveness summary presents the oral comments received during the public meeting as well as written comments provided by the Town of East Hampton. A response to each comment is provided as stated during the public meeting and additional follow up responses, where applicable. A transcript of the public meeting discussions is provided in Appendix B.

Public Meeting Attendee: 203, is that the generator building? Did you test for chromium and antifreeze and stuff like that there? Because I heard rumors from guys that actually work there who gave direct to discharge stuff right on the ground.

USACE Response to Comment 1: The most common antifreeze solutions are mixtures of water and either ethylene glycol or propylene glycol. Because these chemicals are clear and colorless, a green or yellow dye is often added. The RI records review indicated that solvents may have been discharged to the ground in the area behind former Building 203 and adjacent to the former USTs.

In 1994, during the UST removal at the former Building 203, a green liquid that appeared to be ethylene glycol was observed on the sidewalls of the excavation and on water standing in the bottom of the excavation. Additionally, several drums of glycol were identified at the site during the 1993 UST removal action and several hundred feet of piping containing 150 gallons of ethylene glycol were noted in the former power generator building, presumably used for cooling the generators (NYSDEC Spill Report 93-09575, 1993).

However, unless there is a continuing source of ethylene or propylene glycol, these chemicals will not be detected one or two decades after they have been released. Because the ethylene glycol in the soil and the piping was removed during the 1994 UST excavation and building demolition, no samples were collected for ethylene glycol during the RI.

The RI soil, surface water, sediment and groundwater samples were analyzed for VOCs, SVOCs, PCBs, and metals. The metals total chromium and hexavalent chromium were evaluated in soil and groundwater at the former Building 203 (DU01), and in surface water and sediment downgradient of former Building 203 (stream exposure area [SEA] 06). The HHRA indicated that total chromium and hexavalent chromium did not pose adverse health effects from exposure to site media.

Public Meeting Attendee: That's also the source of a 10,000 gallon fuel oil spill going all the way down to Oyster Pond, that according to your document, looks connected to the aquifer that we were using. Have any of the contaminates actually been plotted on a map to see if there's a general trend of where these things are and where they're going? I know you said it's all unperched water, but it was actually a runoff for the fuel all the way down to Oyster Pond back in -- what was that -- the 80s? Just before we moved in there, I think it was, or just after we moved in there, about '84, I think it was. It was a 10,000-gallon discharge, approximately, from the large aboveground storage tank that was at the generator station. Did they do core samples immediately adjoining that area, next to that?

USACE Response to Comment 2: The RI records search identified a 1,000 gallon release reported on 13 January 1991 from the aboveground petroleum storage tank (RI Site AST35). The release was caused by vandals opening a valve on the abandoned 200,000-gallon AST35. The petroleum from AST35 drained to a small creek which eventually flows to Oyster Pond approximately 4,500 feet to the northwest.

The NYSDEC Spills Response Team responded on 14 January and placed petroleum absorbents in the creek and along the creek embankments. A spill cleanup company (Tyree Brothers) was hired to perform cleanup. Cleanup activities continued daily from January through March 1991. On March 15, 1991, NYSDEC inspected the site and determined that no further contaminated debris removal was necessary. NYSDEC also required that all petroleum storage tanks remaining at Camp Hero be checked for petroleum and that all remaining petroleum be removed.

During the RI, the AST35 area was investigated including sampling of soil and groundwater from three wells installed in the petroleum release area. No contamination was found in the soil, groundwater, surface water, or sediment samples that posed a risk above USEPA ecological or human health risk screening criteria. The RI Addendum identified a few petroleum-based constituents in new monitoring wells located in the approximate downgradient direction of AST35. However, none of the constituents exceeded the most conservative screening levels. Any residual constituents of the spill from over 30 years ago would have naturally biodegraded.

Public Meeting Attendee: Oh, were there any carcinogenics identified in any of these things? Because we have an abnormal amount of cancer up in that small residence up there. 27 families and it's a little unheard of to have, like, 20 percent of them that have cancer. That's it.

USACE Response to Comment 3: The human health risk assessment evaluated potential carcinogenic and non-carcinogenic risks from exposure to site media, including soil, groundwater, surface water, and sediment. The risk assessment findings demonstrated that there are no unacceptable risks to human health or the environment from constituents in site media attributable to former DoD activities at Camp Hero FUDS. The RI did not identify any cancer causing chemicals in the site media at concentrations that would pose an unacceptable carcinogenic risk to receptors at the Site. Although this evaluation does not address every potential source of exposure, it does address the potential for exposure from constituents that have been detected in site media from former DoD activities at Camp Hero FUDS.

Public Meeting Attendee: You said in 1994, I believe it was, that you took 100 truckloads of dirt out of there? I live there, I never saw one truck leave that place ever. I live up there. I've lived there since '87, and I never -- I mean, I think I would have saw these big trucks. I certainly saw them coming in and dumping the dirt on the beach in town. I never saw them going out of my neighborhood ever. So that's a little weird to me.

USACE Response to Comment 4: The waste manifest for each truck is included in the UST Closure Report, UST #'s 16 and 18, Building 203, Camp Hero, Montauk, New York, Contract Number: DACA51-93-C-0035. Non-hazardous petroleum impacted soil was properly disposed at Grand Central Sanitary Landfill in PenArgl, PA, and recycled at Soil Remediation of Philadelphia, PA. UST contents, drums, and Building 203 floor debris was disposed as hazardous waste at Chemical Conservation of Georgia, in Valdosta, GA.

Public Meeting Attendee: And also, all this study is being done because, why? Because of a proposed plan to put a campground back there? Or why all of a sudden there's being a study done?

USACE Response to Comment 5: Actually, this site is a Formerly Used Defense Site. These 18 sites have been in the queue for many, many years. We just happened to get funding about three years ago to get started with this investigation because the defense department is trying to close out all these sites by the year 2020. Camp Hero, I think it was towards the end of the whole list of sites that we had in New York. Of course, this process started back in the early '90s. The investigation is really trying to wrap everything up at the site. The only thing that moved us to get out here and to get this site prioritized was really the advocacy of the State of New York to try to help us get more sites done in New York State. It had nothing to do with what anybody's plan for the site was, to the best of my knowledge.

Additional Response: Congress created the FUDS program in the mid-1980s. Under Army oversight, USACE executes the program pursuant to CERCLA. That work includes identifying eligible properties, investigating their condition and addressing any contamination by hazardous substances that was the result of DoD activities.

Public Meeting Attendee: Does this range to the old dump at Flamingo where the Army deposited most of their junk? The old town dump on Flamingo Road? I hear they buried a ton of stuff over there from, like, my grandfather and stuff like that. I was wondering if that encompassed that area too?

USACE Response to Comment 6: No records of off-base disposal from FUDS activities at Camp Hero were identified as an area of concern in the Camp Hero FS/Hazardous Materials Survey, prepared by NY State Parks contractor, Cashin Associates, in 1998.

Public Meeting Attendee: Do you have a list of the things that you tested for? I came a little late, I didn't know if you mentioned it.

USACE Response to Comment 7: Yes. In that small book, the proposed plan handout on the table. In one of the attachments is a list of all the contaminants.

Public Meeting Attendee: All that dirt that you said was removed, did they replace it with dirt? Did they bring dirt back in?

USACE Response to Comment 8: Yes, with clean material. There is a separate report that documents all that work. The UST excavation was backfilled with fill material. There are no required forms or regulatory records required to document fill material placed into an excavation.

Public Meeting Attendee: What about the wells? Did you take any samples in the base itself where our houses are there? Because we have had a lot of problems up there.

USACE Response to Comment 9: All the results of the wells are in the report. We did not sample any wells in anyone's personal residences. Tests were not done of any private residential areas.

Additional Response: Following the public meeting and in response to public comments, USACE decided to complete a limited study of the deep aquifer used for drinking water. Seven onsite and seven offsite wells were sampled including one of the Madison Hill wells. The 14 wells were sampled in December 2020 and February 2021. Groundwater from the monitoring wells was analyzed for a full suite of chemical constituents. A total of 44 constituents were detected at least once with 15 constituents exceeding the most conservative screening level (SL). Data collected from the Madison Hill well exceeded SLs for polychlorinated biphenyls (PCBs), arsenic, manganese, and sodium. The constituents arsenic, manganese, and sodium are naturally occurring in the Montauk area. A risk assessment did not identify any adverse health effects from drinking water from the deep aquifer related to PCBs or any other constituents.

From a historical standpoint, a Freedom of Information Act (FOIA) request was submitted by USACE to the Suffolk County Department of Health Services, Office of Water Resources, to obtain groundwater sample results from drinking water wells in the residential neighborhoods surrounding Camp Hero.

Public Meeting Attendee: Up in that area we had our own kind of water district -- three major wells that a whole development drew off of. And nobody up there has a private well. We're currently on the Suffolk County water system now, mostly. But originally, we had our own separate water district where we drew off of our own separate wells up in that area. Were those wells tested?

USACE Response to Comment 10: That question would need to be directed to Suffolk County. If somebody tested those wells, it wasn't the Army Corps that tested those wells. See also response to Comment 9.

Public Meeting Attendee: I live adjacent to the camp and I have a well that I'm drawing my water at 188 feet. I'm right off the fence line. I'm wondering, when you were doing those testings, was any testing done at your own wells that went down 135 feet or was it basically just the perched water? We're talking about 50 years of potential -- I'm not on public water, I'm still getting water out of the ground, so are my neighbors. We're all wondering if our water has been tested, in any way, by the government. All the water that's perched water there works its way to Oyster Pond. So all part of that watershed, it all runs down there. I'm not concerned as much about perched water as I am about the potential that the water could have leeched down into the water that we're drinking.

USACE Response to Comment 11: We didn't test your well, obviously. Because we would not expect to see anything through a confining layer. That question would need to be directed to Suffolk County.

Additional Response: Specific to the location near the residences on Old Montauk Highway, four new deep aquifer monitoring wells were installed on the southwest corner of Camp Hero property as part of the Phase IV RI. Nested monitoring wells CH-MW044S (shallow) and CH-MW044D (deep) were installed to a total depth of 120 and 157 feet below ground surface, respectively. Nested monitoring wells CH-MW045S (shallow) and CH-MW045D (deep) were installed to 95 and 136 feet below ground surface, respectively. The depths of the shallow monitoring wells were intended to be consistent with the depths of the older drinking water wells along Old Montauk Highway. The depths of the deep monitoring wells were intended to be consistent with the depths of the newer drinking water wells along Old Montauk Highway, which are now required by Suffolk County private water well regulations to be installed a minimum of 40 feet below the water table.

The analytical data collected from the four new deep aquifer wells indicated multiple detections above the most conservative SLs; however, based on a human health risk evaluation, none of the detections indicated adverse health effects from drinking water from the deep aquifer. The visual geology and geotechnical samples confirmed the presence of a significant confining layer between the perched water lenses and the drinking water aquifer. The revised CSM states that the deep aquifer is likely recharged from areas of less slope and less till thickness, such as wetland areas, stream beds, and drainage swales. There is no direct evidence of contaminant migration from any of the Camp Hero FUDS sites through four phases of investigation.

NYSDOH recommends annual testing of private wells for total coliform. USEPA and the National Groundwater Association (NGWA) also recommend annual testing of private wells for total coliform, nitrate, total dissolved solids, and pH. Suffolk County Department of Health Services (SCDHS) provides a private well water quality testing program for a sampling fee of $100. Suffolk County resolutions 245-2000 and 1009-2000 require that when a home with a private well is purchased, the well must be tested prior to closing.

Public Meeting Attendee: Perched water is funny stuff. It actually goes through gravel and sand layers and it can pop up miles down the road. I mean, I could tell you a story very near Camp Hero when we put a road in to move a house back in the '70s. On the top of the hill, one morning they go up here and it's a bubble in the road, and I drove my Toyota truck -- the truck fell in a hole, it was water that popped up from miles away. We scraped enough of the ground, and the water pressure pushed the clay up and drove my truck over and went right into it. But perched water is funny stuff. It's not very easy to tell where the contaminates go from A to B. It could be over at Z, is what I'm saying. It does migrate.

USACE Response to Comment 12: Please see responses to Comments 9 and 11.

Public Meeting Attendee: What does the army do with these sites when they do close them? Do they sell them?

USACE Response to Comment 13: It all depends what timeframe you're talking about. Bases closed before 1986 are addressed by the Formerly Used Defense Site Program. Sites closed after 1986 were usually part of the Base Realignment Closure Program. What happens to the sites depends. Some sites get deeded over to states, some sites get sold off. Here in the case of Camp Hero, a part was transferred to the state, a part was transferred to East Hampton, and part was deeded to the Coast Guard. So here we have one site where several transfer actions took place.

Public Meeting Attendee: When the department of environmental conservation came in and took away the petroleum, what happened after that? And they felt it was contained and removed and replaced with clean top soil; is that what happened? So you're saying there's no concern to look any further?

USACE Response to Comment 14: They didn't take the petroleum away, the Army Corps took it away. That was a spill that DoD was responsible for. The soils were removed and the clean material was put back in place. But what we have now is because there was some impact to the perched groundwater in that area. That perched groundwater is still in contact with the soils; so therefore, there is some residual fuels located within that area. We don't think there is any concern at this point to look further. See also response to Comment 4.

Public Meeting Attendee: Do we have to formally put this in writing to get a response to this?

USACE Response to Comment 15: No, she's taking notes, and we will be more than happy to respond. That's why we have Sara taking notes for us.

The East Hampton Town Planning and Natural Resources Departments have reviewed the Remedial Investigation and the Proposed Plan for the Formally Used Defense Site (FUDS) at Camp Hero at Montauk New York. The Proposed Plan recommended No Further Action (NFA) pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Town representatives also attended the public meeting conducted by the Corps of Engineers at the Montauk Library on October 24, 2019.

The Town respectfully encourages the Corps to conduct further testing to ensure that all hazardous materials are properly identified and remediated prior to considering the property for any new use under consideration by New York State Parks. Specifically, the extensive clay, silt and other poorly drained sediments that contribute to the extensive freshwater wetlands, streams and surface waters are not uniform as a confining layer to prevent hazardous materials from reaching deeper groundwater resources. The Town strongly suggests the Corps install a series of deep groundwater monitoring wells in conjunction with a groundwater sampling regime to confirm the absence of contaminants from the Upper Glacial Aquifer prior to a final determination for No Further Action. Furthermore, the Corps should allow the Suffolk County Department of Health Services (SCDHS), the local agency with the greatest expertise in groundwater quality issues, an opportunity to review and comment upon the test results.

The Town notes that the Human Health Risk Assessment (HHRA) and the Ecological Risk Assessment (ERA) Appendices are not available at the Corps project website. The absence of Chemicals of Concern that warrant remediation pursuant to CERCLA does not necessarily indicate the absence of contaminants that may impact human health or the environment.

USACE Response to Comment 16: USACE took this comment and others from the residents in serious consideration, which led to the funding and execution of the Phase IV RI field effort. As provided in the RI Addendum Report, USACE completed a review of the potential sources for all constituents detected as well as conducting a human health risk evaluation on the CERCLA hazardous constituents that exceeded the most conservative screening levels. The HHRE concluded the absence of contaminants that impact human health in the deep UGA used for drinking water.

A Phase IV RI was completed following the public meeting to address community concerns related to the potential impacts from Camp Hero FUDS to the deep aquifer used for drinking water.

Letter from John B. Swartwout, P.E., Section Chief, Division of Environmental Remediation, Remedial Bureau A, New York State Department of Environmental Conservation, to Mr. Gregory Goepfert, U.S. Army Corps of Engineers. Re: Remedial Investigation Report, Camp Hero, DEC ID# 152231. January 7, 2019.

The New York State Departments of Environmental Conservation and Health (NYSDEC and NYSDOH) have completed reviews of the Draft Final Remedial Investigation Report for Camp Hero dated November 2018. Comments are enclosed for your consideration.

NYSDEC and NYSDOH comments on Draft Final Remedial Investigation Report for Camp Hero, November 2018:

1. DU-01 (Building 201 Area): As discussed, based on the finding of floating product (LNAPL) in the vicinity of Building 203, DEC will require further evaluation to determine if remedial action is possible/required. The USACE will provide a supplemental report specific to DU-01 with their proposal to address the LNAPL. Specifically, the data will be reviewed and a proposal that will include a NSZD (Natural Source Zone Depletion) Evaluation will be submitted for review and comment.

2. AOC 107 (Building 107): DEC requires submission of a supplemental proposal to address the PCB contamination near the "Transformer Remnants."

3. AOC B113 (Battery 113): DEC requires submission of a supplemental proposal to address the PCB contamination near the "Transformer Remnants" and the two AGT located inside the battery which still contain weathered diesel fuel.

4. We are in agreement with your recommended path forward (NFA under CERCLA) for the other areas of concern/decision units/stream exposure areas.

Signed: John B. Swartwout, P.E., Section Chief.

Letter from John B. Swartwout, P.E., Section Chief, to Mr. Gregory Goepfert, U.S. Army Corps of Engineers, New York District. Re: Technical Memorandum — Former Building 203 (DU-01), October 2019, Camp Hero, DEC ID# 152231. January 6, 2020.

The New York State Department of Environmental Conservation has reviewed the Technical Memorandum — Former Building 203 (DU-01) dated October 2019. The Department approves this document and will close the Spill Number associated with former Building 203. We do, however, request that the language be revised from "Pollution Complaint Number (PC-1602757)" to read simply "NYS DEC Spill Number 16-02757." We do not refer to our Spill Numbers as a Pollution Complaint Number (PC), so this reference should be removed throughout the document to prevent any confusion.

Signed: John B. Swartwout, P.E., Section Chief.

Letter from Brian Frank, Chief Environmental Analyst, East Hampton Town Planning Department, to U.S. Army Corps of Engineers, New York District. Re: Proposed Army Corps of Engineers plan for the former Camp Hero, Montauk, NY, Formerly Used Defense Site, Property No. C02NY0024. November 15, 2019.

The East Hampton Town Planning and Natural Resources Departments have reviewed the Remedial Investigation and the Proposed Plan for the Formally Used Defense Site (FUDS) at Camp Hero at Montauk New York. The Proposed Plan recommended No Further Action (NFA) pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Town representatives also attended the public meeting conducted by the Corps of Engineers at the Montauk Library on October 24, 2019.

The Town respectfully encourages the Corps to conduct further testing to ensure that all hazardous materials are properly identified and remediated prior to considering the property for any new use under consideration by New York State Parks. Specifically, the extensive clay, silt and other poorly drained sediments that contribute to the extensive freshwater wetlands, streams and surface waters are not uniform as a confining layer to prevent hazardous materials from reaching deeper groundwater resources. The Town strongly suggests the Corps install a series of deep groundwater monitoring wells in conjunction with a groundwater sampling regime to confirm the absence of contaminants from the Upper Glacial Aquifer prior to a final determination for No Further Action. Furthermore, the Corps should allow the Suffolk County Department of Health Services (SCDHS), the local agency with the greatest expertise in groundwater quality issues, an opportunity to review and comment upon the test results.

The Town notes that the Human Health Risk Assessment (HHRA) and the Ecological Risk Assessment (ERA) Appendices are not available at the Corps project website. The absence of Chemicals of Concern that warrant remediation pursuant to CERCLA does not necessarily indicate the absence of contaminants that may impact human health or the environment.

Camp Hero currently provides residential housing to a number of East Hampton community members in addition to the invaluable parkland resource. Thank you for the opportunity to provide these supplemental comments. The Town's Planning and Natural Resources Department remain available to work with the Corps on any future investigations at this property.

Signed: Brian Frank, Chief Environmental Analyst.

Letter to John Swartwout, Division of Environmental Remediation, New York State Department of Environmental Conservation. Re: U.S. Army Corps of Engineers, Formerly Used Defense Site Program, Proposed Plan, Camp Hero, Site 152231, Montauk, Suffolk County. August 20, 2019.

The Proposed Plan notes on pages 3 and 4 that a potability analysis was conducted as part of the Remedial Investigation (RI) and concluded that the perched groundwater lenses at the site are not feasible sources of potable water supply due to poor well yield, recharge, and water quality. The RI also notes that the perched groundwater lenses beneath Camp Hero are not hydraulically connected to any drinking water resources in Suffolk County. The potability analysis also notes that before a potable groundwater well could be installed at Camp Hero, the well would be required to conform to standards for community or private water wells issued by Suffolk County Department of Health Services (SCDHS). Since the perched groundwater at Camp Hero would not likely meet those standards, the installation of potable wells within the site would most likely not be allowed by SCDHS. These requirements reinforce the Proposed Plan's Human Health Risk Assessment (HHRA) conclusion that further evaluation of residential exposures to site-related contaminants of concern is not warranted. I request that the SCDHS requirements for installation of private wells be included in the Proposed Plan as supporting information.