PB99-963911
EPA541-R99-Q15
1999
EPA Superfund
Record of Decision:
USA Vint Hill Farms Station
AREEs 3, 5, 7,10,16-2,17,18,20,
24,25,26,29-1, 29-2, 29-3,30, & 33
Warrenton, VA
7/1/1999
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1
FINAL
DECISION DOCUMENT
AREEs 3, 5, 7, 10,16-2, 17, 18, 20, 24,
25, 26, 29-1, 29-2, 29-3, 30, AND 33;
SITE-WIDE GROUNDWATER;
SOUTH RUN AT AREEs 1 AND 2;
AND OTHER SITE DRAINAGES
VINT HILL FARMS STATION
WARRENTON, VIRGINIA
Prepared for:
U.S. Army Communications-Electronics Command
Prepared by:
IT Corporation
Edgewood, Maryland
June 1999
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TABLE OF CONTENTS
Section
Pace
1.0 INTRODUCTION
1
2.0 SITE BACKGROUND
1
3.0 SITE CHARACTERISTICS
3.1 Site Topography 3
. 3.2 Adjacent Land Use .'. 3
3.3 Surface Water Hydrology ZZZZZZ"! 3
3.4 Geology/Hydrogeology '.".'.'."."' • 3
* ' • • 5
4.0 SITE HISTORY AND INVESTIGATION FINDINGS
4.1 AREE 3 - Warehouse... -. 5
4.2 AREE 5 - EPIC Building ZZ 5
ii AoII L~ Electrical Equipment Facility Setreatrr^rrt Tank Z *
A A«^E 1° ~ Former Photographic Wastewater Lagoon !
4.5 AREE 16-2- Possible Firefighter Training Pit "" 6
4.6 AREE 17-Dump#3 7
4.7 AREE 18 - Grease Pit ZZZ! 7
4.8 AREE 20 - Incinerator Septic Tank and Leach Field 8
4.9 AREE 24 - Transformer Storage Area 8
4.10 AREE 25 - Sugar Tree 8
4.11 AREE 26 - Outdoor Wash Racks 8
4.12 AREE 29-1 - Salvage Yard 9
4.13 AREE 29-2 - Possible Sludge DisposaTArea ' 9
4.14 AREE 29-3 - Possible Disposal Area • 9
4.15 AREE 30-Motor Pool... 9
4.16 AREE 33 - Household Debris Pile 10
4.17 Site-wide Groundwater. 1°
4.18 South Run at AREEs 1 andV! 10
4.19 Other Site Drainages 11
' 11
5.0 SUMMARY OF SITE RISKS.
5.1 AREE 3 - Warehouse : 12
5.2 AREES - EPIC Building ZZ."" ' 13
I'A £plII~EIectricalE9^ '' I*
ei AREE10-Former Photo9raphic Wastewater Lagoon ]*
5.5 AREE 16-2-Possible Firefighter Training Pit ]4
5.6 AREE17-Dump#3 : 14
5.7 AREE 18-Grease Pit Z."! 15
f'S A^EE2°-|ncineratorSeptic"fank"and"Lea7h"Fieid - If
5.9 AREE 24 - Transformer Storage Area 15
5.10 AREE25-SugarTree -15
5.11 AREE 26-Outdoor Wash Racks 1S
5:12 AREE 29-1 - Salvage Yard 15
5.13 AREE 29-2 - Possible Sludge DisposaTArea I!
5.14 AREE 29-3 - Possible Disposal Area 16
5.15 AREE 30 - Motor Pool 16
••"••• •• 16
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TABLE OF CONTENTS fCQnfim.»Hj
Section
5.16 AREE 33 - Household Debris Pile
5.17 Site-Wide Groundwater ; 16
5.18 South Run at AREEs 1 and2 17
5.19 Other Site Drainages " 17
. ' : 17
'6.0 SELECTED ALTERNATIVE.
; "- - 18
7.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
: .....18
8.0 RESPONSIVENESS SUMMARY
8.1 Selected Newspaper Notices I!!!!!!!!!!!!!!!!!!!!!!!! 18
!'? ?°™ments Raised During the Public Meeting on Apni 15,' 1999 It
8.3 Public Meeting Attendance Roster 19
8.4 Active Restoration Advisory Board Members"!..!.."..".'.".' '. 20
8.5 Written Comments Received During the PubBc'^mm'errt'p7ri^~!!]"ZZZ.".""": 20
9.0 REFERENCES
21
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LIST OF FIGURES
Figure
1 General Location of VHFS 2
2 General Locations of AREEs at VHFS Z'Z"ZZZ"ZZZZ 4
LIST OF ATTACHMENTS
Attachment 1 Response to USEPA Comments on the Final Phase I Reuse Area Rl Report
Attachment 2 Response to USEPA Comments on the Final Phase II Reuse Area Rl Report
Attachment 3 Proposed Plan
Attachment 4 Public Notice
Attachment 5 Public "Meeting Roster
Attachment 6 Written Comments From Regulators and U.S. Army Responses
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AAFES
AREE
AST
AWQC
bgs
BRA
BRAC
CECOM
CERCLA
CERFA
DD
EEQ
ENPA
EPIC
ERA
ER-L
ft
HHRA
HI
HQ
ICFKE
IMMC
MCL
MSL
NCR
PAH
PCB
ppb
PPm
RBC
RCRA
Rl
SAIC
SARA
SDWA
SI
SOV
SRI
STP
TPH
TRV
USAGE
USAEC
USEPA
UST
VDEQ
VHFS
VOC
WSRT
ABBREVIATIONS AND ACRQMYMg
Army, Air Force Exchange Service
Area Requiring Environmental Evaluation
aboveground storage tank
Ambient Water Quality Criteria
below ground surface
Baseline Risk Assessment
Base Realignment and Closure
Communications-Electronics Command
Comprehensive Environmental Response, Compensation, and Liability Act
Community Environmental Response Facilitation Act
Decision Document
environmental effects quotient
Enhanced Preliminary Assessment
Environmental Photographic Interpretation Center
Ecological Risk Assessment
effects range-low
feet
Human Health Risk Assessment'
Hazard Index
Hazard Quotient
ICF Kaiser Engineers, Inc.
Intelligence Materiel Management Center
maximum contaminant level
mean sea level
National Oil and Hazardous Substances Pollution Contingency Plan
polynuclear aromatic hydrocarbon
polychlorinated biphenyl
parts per billion
parts per million
risk-based concentration
Resource Conservation and Recovery Act
Remedial Investigation
Science Applications International Corporation
Superfund Amendments and Reauthorization Act
Safe Drinking Water Act
Site Inspection
soil organic vapor
Supplemental Remedial Investigation
, Sewage Treatment Plant
total petroleum hydrocarbon
toxicity reference value
U.S. Army Corps of Engineers
U.S. Army Environmental Center
U.S. Environmental Protection Agency
underground storage tank
Virginia Department of Environmental Quality
Vint Hill Farms Station
volatile organic compound
western South Run tributary
IV
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DECLARATION FOR THE DECISION DOCUMENT
REMEDIAL ALTERNATIVE SELECTION
Site Name and Location
Areas Requiring Environmental Evaluation (AREEs) 3,5,7,10,16-2,17,18,20,24,25,26,29-1,29-2,
29-3,30, and 33; Site-wide Groundwaten South Run at AREEs 1 and 2; and Other Site .Drainages
Vint Hill Farms Station
Warrenton, Virginia
Statement of Basis and Purpose
This Decision Document (DD) presents a determination that no action is necessary to protect human health
and the environment for soil at AREEs 3, 5,7,10,16-2,17,18,20,24,25,26,29-1,29-2,29-3,30, and 33; site-
wide groundwater; South Run at AREEs 1 and 2; and other site drainages at Vint Hill Farms Station (VHFS),
Warrenton, Virginia. This determination was developed in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act (SARA) of 1986 and the National OH and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.F.R. Part 300.' This document was prepared as a joint effort between the U.S.
Army, the Virginia Department of Environmental Quality (VDEQ), and the U.S. Environmental Protection Agency
(USEPA). The no action decision is supported by documents contained in the Information Repository.
Description of the Selected Remedy
No action is the selected remedy for AREEs 3, 5,7.10,16-2,17,18,20,24,25,26,29-1,29-2,29-3,30, and 33;
site-wide groundwater; South Run at AREEs 1 and 2; and other site drainages. The Baseline Risk Assessment
(BRA), conducted as part of the investigation activities, supports the no action decision.
Declaration
The no action remedy selection is based upon the findings of the BRA which determined risks within USEPA's
acceptable risk range for each of AREEs 3,5,7,10,16-2,17,18,20,24,25,26,29-1,29-2,29-3,30, and 33; site-
* groundwater; South Run at AREEs 1 and 2; and other site drainages. Therefore, the selected remedy is
protective of humarrhe$lth and the environment. A five-year review will not be necessary for these AREEs, site-
wide oroundwat/r, Sodrh Run at AREEs 1 and 2, or the other site drainages.
1/99
ROBERT L. NABORS \_ . Date'
Major General, USA
Commanding
U.S. Army Communications-Electronics Command
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DECISION SUMMARY
1.0 INTRODUCTION
Inn JL° a^°n df,aDSi0n fe based on the Phase ' Reuse Area Remedial Investigation (Rl) Report (USAEC 1998)
and the Phase II Reuse Area Rl Report (USAGE, 1 999) which include Baseline Risk Assessment (BRAs
documenting the njks .torn Contamination in fl» soil I at Areas Requiring Enwonmenta. Evaluati™ ^AREE^I
5 InlM ' J :, ' ' ' 25> 26> 29"1' 29"2' 29'3' 30' and 33; site-wide aroundwater; South Run at AREEs 1 and
Ik 5? o« ™ ? toaoaf ea '" the BRAS> Jt Was dete™ned '"at ^e soils at AREEs 3, 5. 7, TO 16-21718 20
1' 2?"2'^3' 3°' 3nd 33 d° "Ot pose ""acceptable risks to human health and he env ronmen°'
'
3 "Iff ARE!f L6qUire n° 3Cti0n t0 be Pr°tective of human health and *» env onmen
a ARF 1 ? d2ermmed thatjhe site^ide-groundwater, surface water and sediment in South Run
to hum!n h^th ' rf"l * W3ter fnd sediment in «» oth^r site drainages do not pose unacceptable risks
to human health and the enwonment. Therefore, site-wide groundwater, South Run at AREEs 1 and 2 and
other site drainages require no action to be protective of human health and the environment
2.0 SITE BACKGROUND
fCECn™ LH h , r3110" ^F? lf Paft °f the U'S- Army Coronuntealions - Electronics Command
(CECOM) and while active, pnmanly functioned as an Army installation engaged in communications
mtenigence. VHFS ,s located approximately 40 miles southwest of Washington DC., in FauqSer Bounty
Virgmta as shown on F.gure 1 . The installation occupies approximately 701 acres of land near he town of
oTZnS^"1^ fApPr°xiTat,ely 1 5° acres of the installation are imPr°^d Sounds in the sou hem porton
9^rr~ iS* t ' 'nd.UStnal operatlons- administration buildings, and residential housing. Approximately
457 nn!mn±LeaSt!rn P°*°" °f *? pr°p6rty 3fe mature hardwood forest- and *e majority of the
acres ln the northem porton of the property are used
_ VHFS was designated for closure in March, 1993, under the Base Realignment and Closure (BRAcV
Act. Pursuant to the decision to close the installation, an Enhanced Preliminary ATSessmen?(ENP^fa^ a
f ™ronmefntal Response Facilitation Act (CERFA) investigation of VHFS were conducted by
Pp^ernai°n?1 Corporation to asse^ the environmental condition of the inste nation
=RFA -nvestig^on s were completed in April and May, 1994, respectively. The ENPA identified
? rev,ew of mstaliation records, aerial photographs, installation personnel interviews federal
o ^ * inspection. Of these 42 AREEs, 27 were recommended for further
* lnve!?9ated from September, 1 994, to June, 1 995, as part of the Site Inspection
nd thh *, • Th*6 °bJ!CtlVe °f th6 Sl W3S t0 determine toe P^sence or absence of coronation
and the chemical nature of any detected contamination. The final SI Report (USAEC 1996) which was
completed in June, 1996 identified 24 AREEs which required further investKjation. In addton foS'new ARsIs
were identified during site reconnaissance to warrant further investigation subsequent to the SI AREEs that
were determined to warrant further investigation were investigated as part of the Phase I and -Phase II reuse
area RIs, and the Supplemental Remedial Investigation (SRI) conducted by ICF Kaiser Engineers Inc (ICF
S Jf H pUrpOSH °ItheSe ^P0* Were to evaluate: 1) ^e nature and extent of contamination; and 2) the
level of nsk posed to human health and the environment. The final Rl Reports for the Phase I and Phase M
T^Pdr^P f^S1/,1,?^^5^ 1"9) W6re COmP'eted ln April' 1"8 and JanUarV- 1999 respeSy
The draft SRI Report (USAGE, 1 998) was completed in November, 1998.
Sixteen AREEs and three other sites were identified in the SI and RIs as having contamination which
poses no unacceptable human health risks and/or significant adverse ecological effects: °n Wnicn
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JEFFERSON) /
(W.VA.) (/
MONTGOMERY
MARYLAND
ANNE
ARUNOEL
\
VINT HILL
FARMS STATION
\ PRINCE WILLIAM
FAUQUIER J
GENERAL LOCATION
OFVHFS
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• AREE 3 - Warehouse;
• AREE 5 - Environmental Photographic Interpretation Center (EPIC) Building;
• AREE 7 - Electrical Equipment Facility Pretreatment Tank;
• AREE 1 0 - Former Photographic Wastewater Lagoon;
• AREE 1 6-2 - Possible Firefighter Training Pit;
AREE 17 -Dump #3;
• AREE 1 8 - Grease Pit;
• AREE 20 - Incinerator Septic Tank and Leach Field;
• AREE 24 - Transformer Storage Area;
• AREE 25 - Sugar Tree;
• AREE 26 - Outdoor Wash Racks;
• AREE 29-1 - Salvage Yard;
• AREE 29-2 - Possible Sludge Disposal Area;
• AREE 29-3 - Possible Disposal Area;
• AREE 30 - Motor Pool;
• AREE 33 - Household Debris Pile;
• Site-Wide Groundwater;
South Run at AREE 1 (Dump #1) and AREE 2 (Sewage Treatment Plant [STP]); and
• Other Site Drainages.
The locations of these AREEs are shown on Figure 2.
3.0 SITE CHARACTERISTICS
3.1 Site Topography
«. rr „ ,VHFS is located w™*1 the Piedmont Plateau physiographic province, approximately 20 miles west of
the Fall Line. The Fall Line is a physiographic boundary that separates the folded and faulted crystalline rocks
of the Piedmont Plateau physiographic province from the unconsolidated sediments of the Atlantic Coastal
Plain physiographic province. The topography of the Piedmont Plateau in the vicinity of VHFS consists of gently
rolling hills with slopes generally less than 1 0%. Surface elevations on the installation vary from 335 to 430 feet
(ft) above mean sea level (MSL).
3.2 Adjacent Land Use
Land use in the immediate vicinity of VHFS consists mainly of agriculture (mostly horse farms) and
residential areas. With the exception of a few residences to the north, the majority of residential development
is located to the south of VHFS. A small county recreation park is located adjacent to VHFS along South Run.
3.3 Surface Water Hydrology
VHFS is located in the Occoquan watershed. Most of VHFS drains to South Run via intermittent
tnbutaries and drainage ditches, as shown o.n Figure 2. South Run is a small Class III Virginia stream which
discharges into Lake Manassas, a recreation and drinking water reservoir built on Broad Run for the City of
3 . .
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ow-os-w
AREEs LOCATIONS:
J WAREHOUSE
' (PK BUILDING
7 ELECTRICAL EQUIPMENT FAOUTY
'0 FORMER PHOIOCRAPHIC WASIEWAIER
UGOON
IB-2 POSSIBLE FIREFIGHTER TRAOTNG PIT
17 OUUP /J
18 CREASE PIT
20 IHOHERAtOR
24 ' .TRANSFORMER STORAGE ARfA
25 SUCAR IREE
26 .OUTDOOR *ASI RACKS
""' SALVAGE TARO
M-2 POSSIBU SlUOCE DISPOSAL AREA
"^ POSSIBLE OISPOSAL AREA
~ MOTOR POOL
JJ HOUSEHOID DEBRIS PILE
N
PHASE I REUSE AREA
FIGURE 2
GENERAL LOCATIONS
OFAREEsATVHFS
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Manassas. Lake Manassas discharges to Broad Run, which drains to the Occoquan Reservoir Drainage for
the southern portion of the installation flows south and east to Kettle Run. Kettle Run converges with Broad Run
approximately 10 miles downstream from Lake Manassas.
3.4 Geology/Hydrogeology
The central portion of VHFS is underlain by folded sedimentary rocks of the Catharpin Creek Member
which consists of sandstone, arkosic sandstone, siltstone, shale, and claystone. Intrusions of basalt oriented
northeast to southwest, cut the bedrock in the central and western portions of the VHFS installation The
northeastern flank of VHFS is underlain by intrusions of diabase. Quaternary alluvium is present alona the
. major drainage channels within the installation.
The overburden is thickest (20-40 ft) in the southern regions of the site and thins to 0-10 ft in the
northern areas. The overburden consists primarily of saprolite (a chemical and physical weathering product of
the underlying bedrock) which underlies lesser amounts of clayey and silty soils.
Groundwater at VHFS occurs in fractured bedrock and to a lesser extent in the overburden The
bedrock aquifer is semi-confined, with the unfractured bedrock and saprolite acting as confining units Recharge
to the fractured bedrock aquifer occurs at outcrop areas and from percolation from the overburden alonq
fractures. In the overburden, the aquifer is unconfined.
4.0 SITE HISTORY AND INVESTIGATION FINDINGS
The RIs for these sites were conducted to evaluate the nature and extent of contamination associated
with past site activities. Environmental samples collected and analyzed during the RIs were used in conjunction
with the results from the SI and the SRI to assess the condition of each of the areas. The environmental media
investigated included surface soil (0 to 2 ft below ground surface {bgsl), subsurface soil (greater than 2 ft bgs)
surface water, sediment, and groundwater. Analytical results were compared to background concentrations
and regulatory screening levels to determine if environmental media had been adversely impacted by site
activities. A brief description of each of the areas and the significant findings of the RIs SI and SRI are
presented in the following paragraphs. A detailed presentation of the samples collected and the analytical
results can be found in the SI Report (USAEC, 1996), the Phase I Reuse Area Rl Report (USAEC 1998) the
Phase II Reuse Area Rl Report (USAGE, 1999), and the SRI Report (USAGE, 1998) available in the Information
Repository. Comments received from the U.S. Environmental Protection Agency (USEPA) on the final Phase
I Reuse Area Rl Report and on the final Phase II Reuse Area Rl Report regarding these sites along with the
U.S. Army's responses are provided in Attachments 1 and 2, respectively.
4.1 AREE 3-Warehouse
The Warehouse (Building 309) was used as a vehicle maintenance area from 1943 to 1967. Two sets
of pits, which formerly were used for the hydraulic lifts and grease pit, were filled with concrete in 1967. The
Warehouse also may have been used for the temporary offloading of drums of oil, grease, solvent, paint, acid,
and industrial organic chemicals. Three areas of possible contamination have been identified at the
Warehouse: the hydraulic lift pit; the grease pit; and the outlet of a floor drain located at the south end of the
building, in a former lavatory. Drain pipes from a sink and water fountain run underneath the floor into the floor
drain. The overflow from the floor drain discharges to the field south of the Warehouse.
Surface soil samples were collected at the drain outlet; and subsurface soil samples were collected
beneath the drain outlet, grease pit, and hydraulic lifts. Benzo(a)pyrene, a polynuclear aromatic hydrocarbon
(PAH), was detected in samples taken at the drain.outlet at levels above the risk-based concentrations (RBC)
established by the USEPA Region III for screening analytical results. Benzo(a)pyrene was.detected above the
residential soil RBC (0.087 parts per million [ppm]) in a.surface soil sample at a concentration of 0.155 ppm
and above the industrial soil RBC (0.78 ppm) in a subsurface soil sample at a concentration of 2.9 ppm Totai
petroleum hydrocarbon (TPH) was detected (25.9 to 40.5 ppm) below the State's TPH soil action level for
5
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underground storage tanks (USTs) of 100 ppm in soil samples collected underneath the hydraulic lifts No
contamination was observed in subsurface soil samples collected along the perimeter of the hydraulic lifts and
the grease pit.
4.2 AREE 5 - EPIC Building
The EPIC Building was used for photographic operations from 1958 to 1995. From 1958 to 1968
wastewater generated during the photographic process was discharged from the building via a 6-inch industrial
sewerline constructed of vitrified clay to the Former Photographic Wastewater Lagoon (AREE 10). In 1966 the
first silver recovery units were installed for wastewater pretreatment in 1968. the lagoon at AREE 10 was
dredged to recover silver in the sediment and then filled. Wastewater was then diverted through the industrial
sewerline directly into the western South Run tributary (WSRT). In 1973, an ion-exchange system was installed
to remove cyanide, ammonia, phenols and silver from the photographic wastewater before being discharged
through the industrial sewerline to WSRT. This practice continued until 1983 when the photographic wastewater
was diverted to the VHFS STP. Leakage was suspected in the sewerline that carried the EPIC wastewater to
AREE 10 and WSRT due to its age and the nature of the acidic wastewater.
The interior of the 2.700-foot sewerline at AREE 5 was inspected by closed-circuit television to reveal
locations of cracks and other points where leakage would most likely occur. These locations were then selected
for soil boring placement. Results from the subsurface soil samples collected near the sewerline did not show
contamination from photographic wastewater. In order to characterize potential contamination from the
sewerfine, an effluent sample was collected at the outfall of the sewerline into WSRT. Effluent results indicated
that silver exceeded the Ambient Water Quality Criteria (AWQC); however, the silver concentration was qualified
with a B, indicating blank contamination. Based on the results of subsurface soil and sewerline effluent
sampling and analysis, it does not appear that the EPIC sewerline has impacted subsurface soil or is an
ongoing source of contamination to WSRT.
4.3 AREE 7 - Electrical Equipment Facility Pretreatment Tank
The Electrical Equipment Facility (Building 2400) was used for classified military activities associated
with the Intelligence Materiel Management Center (IMMC) including Wack and white photo developing, metal
etching, and graphics work from 1965 to 1995. In 1978, a concrete pretreatment tank containing a layer of rock
and a layer of sand was installed to filter wastewaters generated in Building 2400 before discharging to the
sanitary sewer. Wastes discharged to the pretreatment tank included chromic acid from metal etching, painting
wastewater, and photographic wastewater (that was first neutralized in the neutralization pit). The floor
drainage system also discharged spills of process chemicals and floor wash water from Building 2400 into the
pretreatment tank between 1978 and 1990. Prior to 1978, the floor drains discharged directly to WSRT. The
sand sludge removed from the pretreatment tank was disposed of in the Sludge Disposal Area (AREE 13) prior
to 1981, and was managed as hazardous waste (based on chromium, silver, and lead content) off site starting
in 1981. The pretreatment tank was closed in 1995, and no cracks in the concrete walls or stained soils were
found when ft was removed in 1997. The neutralization pit closed in May. 1990. and is being remediated
according to the requirements of the Resource Conservation and Recovery Act (RCRA) under the purview of
the Virginia Department of Environmental Quality (VDEQ).
Subsurface soil samples were collected around the perimeter of the pretreatment tank which indicated
'that operation of the pretreatment tank had not impacted the subsurface soil.
4.4 AREE 10-Former Photographic Wastewater Lagoon
The Former Photographic Wastewater Lagoon was an earthen holding pond approximately 90 ft in
diameter and 4-4.5 ft deep. Photographic wastewaters from the EPIC Building were discharged to the lagoon
from 1958 to 1968. The photographic wastewater was acidic and contained significant amounts of silver and
cyanide. The lagoon and WSRT were connected naturally such that overflow from the lagoon discharged
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directly into WSRT. In 1 968, flow problems developed in the lagoon, and it was dredged to recover silver from
the sediments. The lagoon was then filled, and effluent was diverted directly to WSRT.
Subsurface soil samples were collected from within the area of the lagoon The Drimarv inoraanics
sl^hY / and T^6' rre notdetected in »• subsurface soil samples with the^eTcepton of onl
sample hat contained s,h,er well below the residential soil RBC. These results support the conclusion that
most of the contaminated sediments.from the former lagoon were removed during the 1968 dredging
"Ot CO"eCted at AREE 10 because the Ia9°on nad b^n dredged and
would be present at the base of *• former la^on <-e • ^-5
4.5 AREE 16-2 - Possible Firefighter Training Pit
• ... Sit® ^istory indicated that a Firefighter Training Pit was used at VHFS; however the exact location of
T£ nST M T" ^of ainty> AREE 16'2 represents °ne Possible location of the Firefighter T ainlng P?
The Firefighter Tram.ng Rtwas used monthly by the VHFS Fire Department for training in the mid-1970s The
unjned prt was approximately 50 ft in diameter and 3 ft deep. During training activities, thL prt taTpaSny fiS
with petroleum and natural gas odorant and then ignited, Solvents and other combustible materials may have
also been used in the pit. In the mid-1 980s the pit was filled with VS-inch gravel. maien^ may nave
tn rioter TPH ^ screening of Jhe soil at AREE 1 6-2 was conducted to delineate the area of contamination and
to determine where soil samples should be collected for laboratory analysis. Surface and subsurface son
saZ £ Scted'l ARbPTdfi0; P°SfVe TH reSU'tS fr°m the field scre*™9- Surface and subsurSce so
samples collected at AREE 16-2 contamed arsenic at concentrations (up to 33.8 pom) that exceeded its
S5, 1' SO''RBC <°f PPm> as well as its maximum background concentration £» ppm to 5 4 ppm?
Analytical results indicate that soils have not been adversely impacted by firefighter training activities because
arsenic was the only contaminant that exceeded screening levels at AREE 1 6-2 anj £" Snte^rtStoS
were determined to be statistically within background levels.. concentrations
4.6 AREE 17 -Dump #3
Dump #3 is a 318-foot by 390-foot area that has been in use since 1958 to dispose of compost
nS con,str"ctio.n df *• Slirffl. from the STP and Former STP and small amounts of sLSng
#3 ° P e°triCal EqujPment Faciiity
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4.7 AREE 18-Grease Pit
The grease pit was a 50-foot long by 2-foot wide by 4-foot deep trench used to dispose of kitchen
grease, oily rags and possibly motor oil. The pit was covered with fill material in 1981 and has not been used
since that time.
Surface and subsurface soil samples were collected at AREE 18. Manganese (3,100-ppm) and
•arsenic (10.1 ppm maximum) were the only analytestnat exceeded both residential soil RBCs (1.800 ppm and
0.43 ppm, respectively) and maximum background concentrations (2,970 ppm and 4.89 ppm. respectively) in '
surface soil samples. In subsurface soil, arsenic (up to 14.7 ppm) was the only analyte to exceed both its
residential soil RBC (0.43 ppm) and its maximum background concentration (5.4 ppm).
4.8 AREE 20 - Incinerator Septic. Tank and Leach Field
The Incinerator (Building 282) was used from 1973 to 1985 to bum household and office garbage, and medical
waste. Some hazardous wastes (e.g., solvents, pesticides, and waste oil) were also burned in the Incinerator.
The incinerator was temporarily closed from 1985 to 1987 for renovations. The Incinerator was operated for
4 months in 1987 until it was shut down permanently in July, 1987, when a series of explosions in the furnace
damaged the structure. The Incinerator has 8s own septic system, which consists of a 500-galion septic tank
and a 135-foot leach field. The septic system is connected to the sinks and toilets in the Incinerator building.
All floor washings were discharged to the septic system. Although there is no record of hazardous wastes
having been disposed of in the septic system, any spills of liquid hazardous wastes inside the Incinerator
building could have also discharged via the floor drains to the septic system.
Subsurface soil samples collected from the septic system leach field indicated that subsurface soils
had not been impacted by the operation of the incinerator septic system.
'4.9 AREE 24-Transformer Storage Area
:• : •: - ' •• 4ft
AREE 24, the Transformer Storage Area, is located west of Building 272 in the engineering compound.
It is an unbermed asphalt area that was used to store poiychlorinated biphenyl (PCB) transformers (PCBs in
oil greater than 500 ppm) and PCB-contaminated transformers (PCBs in oil between 50 and 500 ppm) before
their removal by Aptus Environmental Services in 1990. The area is currently used for general storage of
materials on pallets, including new "non-PCB" transformers. The area has also been used to store drums
containing oil and fuel filters. No spills of transformer cooling ofl we*e observed or recorded in this area.
Surface soil samples were collected for PCB field screening and laboratory analysis. PCBs were not
, detected during the field screening or subsequent laboratory analysis. TPH was detected below the State's TPH
so3 action level of 100 ppm in the laboratory samples. Evaluation of the field screening and laboratory analysts
results indicate that surface soil has not been impacted from PCB transformer storage activities at AREE 24.
4.10 AREE25-SugarTree
AREE 25, Sugar Tree, is located in the northeastern portion of VHFS. just south of Route 215. AREE
25 is an area where small amounts of paint and solvents may have been disposed; however, no stressed
vegetation or other evidence of contamination has been observed in the area. At one point, a 200-gaJlon diesel
aboveground storage tank (AST) was located in this area for approximately six months for vehicle fueling during
construction of a sewage lift station.
• Soil organic vapor (SOV) surveys and surface and subsurface soil sampling were conducted at AREE
25. These studies indicated minimal impact from possible disposal of paint and solvents. At the former location
of the diesel AST. however. TPH-diesel (930 ppm) was detected in excess of the State's TPH soil action level
for USTs (10'O ppm) in the duplicate surface soil sample sent to the laboratory. However, the primary surface
soil sample and the duplicate surface soil sample were collected from different locations within a few inches
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of one another and TPH was not detected in the primary sample. The large disparity in results of
indicates ttiat conlamlnafcn Is
4.11 AREE 26 -Outdoor Wash Racks
rtnrm*r h, Racks a™a 'mcludes *»o automobile wash areas: one southeast of Building 161
™Sn ,T? T^XS ?6 southwest of Buildin9 161 (cu"ent wash racks). The current wash racks were
constructed in Apnl, 1 982, to replace the former wash racks. Each current wash rack has 1 0-inch concrete
to amnSrit°rPhreVeh mn;0ffha!ld V3mped enfranCe t0 prevent run-°n' Drains from the curren wLh racksTed
to a gnt chamber, which d.scharged effluent to the sanitary sewer. Drains from the former wash racS
discharged to the surrounding soils. In February. 1992, the grft chamber and adjacent sewage Ift Sn were
8
. ,
a" ^ 3nd Sed?e ntS Wer6 diSp°Sed- These fluids and sediments contamoo
Surface soil samples were collected from around both the current and former wash racks Samples
"6 WaS ^ 6 C°lleCted in Cl°Se pr°Ximity t0 the 9* chamber and in
M ,
hnth , IT'? dll°hlrge if the drains t0 the grit chamber were cl°99ed- Me^ls were detected a"
both locabons at levels below background concentrations. TPH was detected in surface soil samples from the
nnm nn 7?r ^ E™ ?* Parkin9 3rea a°d CUTOIt Wash racks could overflow at concentratonso^S 4
ppm and 1 1 1 ppm (slightly above the State's TPH soil action level for USTs of 1 00 ppm).
4.1 2 AREE 29-1 - Salvage Yard
- - - - - -i the northwestern section of VHFS, near Route 652. It was active in the
1-1»/us as a small fenced storage yard containing drums and debris. The ground in the enclosure was
SeriatnhaMh^£l0fHTaterial W6re Lde"f **in a 1977 aerial Photo9raph- Aerial photographs from 1982
cated that the facility had been removed. There has been no evidence, either by aerial photographs or from
installation personnel, indicating that hazardous materials were released or stored in this area
and shallow test pit excavations conducted at AREE 29-1 identified assorted
B of AREE 29-1. A subsurface soil sample was collected at the site of the buried
past storage practices and burial of inert debris at the salvage yard have not
4.13 AREE 29-2 - Possible Sludge Disposal Area
_ , _ The Possible Sludge Disposal Area is located near the northernmost boundary of VHFS, near Route
ij,,^ Scarred ground and a pile of gray material, possibly sludge, were identified in the area in 1977 and 1978
EPIC aerial photographs. The ground in the area is very uneven, indicating that material may have previously
oeen piled on the ground. >
Surface soil samples were collected from the area which indicated that the piles identified in the area
have not impacted surface soil. No sludge was present at the time of sampling.
4.14 AREE 29-3 - Possible Disposal Area
* «, T*6 f°ssible DisP°sal Area is located southeast of the fixed ammunition magazine. WSRT flows just
to the east of the area. Review of 1950 aerial photographs indicated possible disposal activities based on
ground scamng and the presence of mounds of material and possible equipment. Review of 1958 photographs
indicated that the area was revegetating and an ammunition storage building had been constructed nearby
Neither aerial photographs, site visits, nor discussions with installation personnel provided evidence that
hazardous materials had been released or stored in this area.
9
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A geophysical survey was conducted to evaluate the potential for buried debris within the area. Test
pits were excavated perpendicular to the magnetic anomalies. Subsurface soil samples collected from the test
pits indicated that no soil contamination had occurred. Ground scarring observed in aerial photographs may
be attributable to bedrock outcrops.
4.15 AREE 30 - Motor Pool
•
AREE 30 (Building 305) served as a motor pool for approximately 20 years. The building is now
surrounded by asphalt; however, the asphalt parking lot was once gravel. According to VHFS personnel,
vehicles were brought to the motor pool for maintenance and repair. Vehicle maintenance activities occurred
on the gravel parking lot A drainage grate is located at the eastern end of Building 305. In 1995, during repair
of a gas line located adjacent to the drainage grate, a petroleum odor was detected in the soil surrounding the
gas line.
Subsurface soil samples were collected in the area of the drainage grate. No contamination above
screening levels was observed in the subsurface soil samples. The screening levels used included USEPA
Region III RBCs, the USEPA screening level for lead in residential soil, Virginia's TPH soil action level for USTs,
and maximum background concentrations.
4.16 AREE33-Household Debris Pile
The Household Debris Pile is located southeast of the STP in a predominantly wooded and vegetated
area. The debris pile contains items including, but not limited to, aluminum and tin cans, glass bottles, pots and
pans, and bricks. A house known to exist in this approximate location in 1938 may have been the source of the
debris. The pile consists of two small mounds approximately .2 ft high. The larger mound has a 15-foot
diameter, and the smaller mound has a 14-foot diameter.
A test pit was excavated in the larger debris mound, and one subsurface soil sample was collected
from the test pit. The PAH benzo(a)pvrene (1.86 ppm in the duplicate sample) was the only compound that
exceeded its industrial soil RBC (0.78 ppm). The benzo(a)pyrene concentration (0.0001 ppm) in the primary
sample did not exceed the industrial soil RBC. Industrial soil RBCs were used to screen soil results at AREE
33 because the soil sample was collected from greater than 2 ft bgs (i.e., excavation workers are the most likely
human receptor as discussed in Section 5).
4.17 Site-wide Groundwater
.Site-wide groundwater was investigated to determine the character and composition of the aquifer, and
to evaluate potential contamination at the various AREEs. The groundwater aquifer of concern at VHFS
consists of groundwater in the overburden and in fractured bedrock which are interconnected (i.e., there is no
defined confining unit). Groundwater in .the western and central portions of VHFS generally flows to the north-
northwest, while groundwater flows toward the east in the eastern portion of the facility. Groundwater at VHFS
was sampled from a total of 43 monitoring wells at 14 different AREEs and 5 other site locations during the
Phase I reuse area Rl, Phase II reuse area Rl, and SRI sampling events.
During the Phase I and II reuse area RIs, the following significant findings resulted:
''« AREE 1 pump #1): the pesticide aldrin (0.006 ppb) exceeded its tap water RBC (0.0039 parts
per billion [ppb]), but a TPH plume identified during the SI was not confirmed;
. * AREE 2 (STP): the chlorinated volatile organic compounds (VOCs) bromodichloromethane
(0.553 ppb) and chloroform (1.65 ppb) exceeded their tap water RBCs (0.17 ppb and 0.15 ppb,
respectively) but were well below their Safe Drinking Water Act (SDWA) maximum
contaminant levels (MCLs) (80 ppb and 80 ppb, respectively);
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• AREE 5 (EPIC Building Industrial Sewertine): hexachlorobutadiene (0.265 ppb) and
PPb) exceededtheir taP w^er RBCs (0.14 ppb and 0 0066 ppb,
* ?pb)-E 9 0/ehiCle Maintenance Area): benzene (9.43 ppb) exceeded its tap water RBC (0.36
" RBCs bPh°9raPhiC ^^ La9°°n): Chl°rinated V°Cs 6XC6eded
^^^^^
It should be noted that the aldrin contamination at AREE 1, the chlorinated VOC contamination
oontaminafion at ^ =• and the benzene
Bis(2-ethylhexyl)phthalate, a common field and laboratory contaminant was detected in ste and
background samples above the tap water RBC. Bis(2-ethylhexyl)phthalate fe beteve f £ bTan artfacTof
Kn±ra SafmP"n9 Hpr°CedUre and the samP'in9 equipment used rather than a ste related con?am?nant
Known areas of groundwater contamination at AREE 4 (Auto Craft Shop) and AREE 27 (Armv Air S?rp
4.18 South Run at AREEs 1 and 2
p=5S=
to South Run and are flanked by small tributaries that feed South Run. Seepage and mnnaff from AREE 1 and
treated effluent dIScharged from the STP into South Run are possible souses of contaminS
AREEs lSa2|e^32l™|d Sfdime"t samP|es were collected from South Run and its tributaries adjacent to
vww 1L nn^ to detemi'nettn5 natura and extent of possible contamination. Dissolved copper and total iron
(0.188 ppm and 0.213 ppm, respectively) exceeded their effects range-lows (ER-Ls) (0 085 ppm and 0 0005
SEISF V I- m, 1 6 S8diment Samp'eS from S°Uth Run and te tributarie« at AREEs 1 and ? l
d,ox.ns/furans, wh.ch do not have screening levels, were also detected in sediment samples
4.19 Other Site Drainages
thrnnnhJ-t6 ^T,!? draina9es include tne drainages in the northern portion of VHFS that remain drv
throughout most of the year and only contain water immediately following storm events Accordinalv these
t0 C°ntain aquatic life "«*»* for a limited nur"ber of opportunistic ^sSs ckpaWe
!S- Jhe,SUBrface water draina9es a* VHFS discharge to eitheTloSh Tun or
- and
for thP nn Water SaTPl6S W6re C°"eCted fr°m the other site drai"ages during storm events to account
Ljpnt «m ? m^ement of contaminants to downstream water bodies during storm events. During storm
of ?hl «fa P n9,' ? Ir°n and a'Uminum 6XCeeded AWQC and maximum background concentrations^ moTt
of the sample locat,ons in the other -site drainages. Aluminum (dissolved), zinc (total and dissoTvld) and
11
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cadmium (dissolved) were also found to exceed AWQC and maximum background concentrations at isolated
spots within the other site drainages.
Sediment samples were also collected from the other site drainages. Metals. PAHs, and pesticides
were detected at concentrations above screening levels. The screening levels used were the more stringent
of the ER-L and the No Effects Levels or Lowest Effects Levels for sediment which are protective of benthic
organisms, and maximum background concentrations Arsenic exceeded its ER-L and maximum background
concentration at nearly all of the sample locations. Zinc, chromium, iron, lead, and manganese were found
in isolated samples above their ER-Ls and maximum background concentrations. 2-Methylnaphthalene (0 621
ppm), acenaphthene (0.911 ppm). anthracene (0.657 ppm). and pyrene (1.81 ppm) are a few of the PAHs that
exceeded their ER-Ls (0.065 ppm, 0.15 ppm, 0.085 ppm, and 0.35 ppm, respectively). Pesticides exceeded
their ER-Ls in samples collected near the headwaters of a drainage area in the southern portion of VHFS.
Alpha-chlordane (0.034 ppm maximum), gamma-chlordane (0.025 ppm maximum), and chlordane (0.16 ppm
maximum} exceeded their ER-Ls (0.005 ppm for each). Aldrin (0.0025 ppm), DDE (0.0051 ppm), and endrin
(0.0072 ppm) also exceeded their ER-Ls (0.002 ppm, 0.002 ppm, and 0.00002 ppm, respectively).
5.0 SUMMARY OF SITE RISKS
BRAs were conducted as part of the Rls.to assess the human health and ecological problems that
could result if the contamination at the AREEs and in site-wide groundwater. South Run at AREEs 1 and 2, and
' the other site drainages was not remediated. The Human Health Risk Assessment (HHRA) was prepared to
evaluate the magnitude of potential adverse effects on human health associated with current
industrial/commercial and potential future residential exposures to site-related chemicals at the sites. The
Ecological Risk Assessment (ERA) was conducted to characterize the potential threats to ecological receptors
posed by contaminants at the sites.
' The HHRA follows a four-step process:
* Selection of Chemicals of Potential Concern - identifies the contaminants of potential concern
based on their toxicity, frequency of occurrence, and concentration by comparing the maximum
concentrations of detected chemicals with RBCs which are health-protective chemical
concentrations that are back-calculated using toxicrty criteria, a 1x10"6 target carcinogenic risk or
a 0.1 hazard quotient (HQ, defined below), and conservative exposure parameters;
• Exposure Assessment - identifies the potential pathways of exposure, and estimates the
concentrations of contaminants to which people may be exposed as well as the frequency and
duration of these exposures;
• Toxicitv Assessment - determines the toxic effects of the contaminants; and
• Risk Characterization - provides a quantitative assessment of the overall current and future risk
to people from site contaminants based on the exposure and toxicity information.
The HHRA evaluated health effects which could result from exposure to soil, groundwater, surface
.water, and sediment contamination in the Phase I and Phase II reuse areas of VHFS. The HHRA evaluated
potential risks to current workers who could be exposed to contaminants in surface soil, and to current
trespassers who could be exposed to contamination in surface soil, surface water, and sediment. In addition,
the HHRA evaluated potential risks to hypothetical future adult residents who could be exposed to contaminants
In groundwater and surface soil and to hypothetical future child residents who could be exposed to
contaminants in groundwater. surface soil, surface water, and sediment. Potential risks to future excavation
workers who could be exposed to contaminants'in subsurface soil were also evaluated in the HHRA.
Subsurface soil was only evaluated for excavation workers and not residents since residents would be unlikely
to be exposed to subsurface soil. In addition, the concentrations of contaminants currently present in subsurface
soil would not be representative of the concentrations that might be present if landscaping activities were to
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occur which would involve mixing of subsurface soils with surface soil, clean topsoil, and other soil
amendments. Therefore, it would not be appropriate to evaluate risks to residents using available subsurface
soil data.
Potential carcinogenic (cancer-related) effects and noncarcinogenic effects (including various impacts
on different organ systems, such as lungs, liver, etc.) were evaluated in the HHRA. Carcinogenic effects are
expressed as the probability that an individual will develop cancer from exposure to the contaminants from each
site. The evaluation of noncarcinogenic effects is based on the hazard index (HI), which is the summation of
the HQs for individual chemicals. The HQ is a comparison of chemical-specific chronic exposure doses with
the corresponding protective doses derived from health criteria. The USEPA recommends that remedial
actions may be warranted at sites where the carcinogenic risk to any person is greater than 1x10"4 or the HI is
greater than 1. A carcinogenic risk of 1x10"4 means that there is a potential of one additional person in a
population of 10,000 developing cancer from exposure to contaminants at a site if the site is not remediated.
A HI greater than 1 indicates a potential for noncarcinogenic health effects if the site is not remediated.
The ERA also follows a four-step process:
• Problem Formulation - develops information that characterizes habitats and potentially exposed
species and identifies contaminants of concern, exposure pathways, and receptors;
• Exposure Assessment - estimates exposure point concentrations for selected indicator species;
• Ecotoxicoloaic Effects Assessment - identifies concentrations or doses of contaminants that are
protective of indicator species; and
• Risk Characterization - estimates potential adverse effects from exposure to contaminants based
on exposure and toxicity information.
The ERA evaluated ecological effects which could result from exposure to surface soil, surface water,
and sediment contamination in the Phase I and II reuse areas of VHFS. The ERA evaluated potential adverse
ecological effects to terrestrial plants and terrestrial invertebrates (represented by earthworms) exposed to
contaminants in surface soil. In addition, potential adverse ecological effects to mammals (represented by
shrews) and birds (represented by robins) through bioaccumulation in the food web and exposure to
contaminants in surface soil were evaluated. Potential adverse ecological effects to aquatic life from exposure
to contaminants in surface water and sediment were also evaluated in the ERA. Further, the potential adverse
ecological effects to mammals (represented by minks) and birds (represented by herons) through
bioaccumulation in the food web and exposure to contaminants in sediment were evaluated for South Run at
AREEs 1 and 2.
The evaluation of significant potential adverse ecological effects is based on the Environmental Effects
Quotient (EEQ). The EEQ is the ratio of the estimated exposure concentrations/doses for the chemicals of
potential concern and the toxicity reference values (TRVs) for the ecological receptors. If the EEQ is greater
than 1, there is a potential for adverse ecological effects to occur. As the magnitude of the EEQ becomes
greater than 1, the potential for adverse ecological effects becomes more significant.
The results of the BRAs for the subject sites are presented in the following paragraphs. A detailed
presentation of the BRAs can be found in the final Phase I Reuse Area Rl Report (USAEC, 1998) and the final
Phase II Reuse Area Rl Report (USAGE, 1999), available in the Information Repository.
5.1 AREE 3 - Warehouse
The HHRA concluded that, under both current industrial/commercial and potential future residential
land-use conditions, the risks to workers, trespassers, residents, and excavation workers are acceptable for
exposure to site-related contaminants at AREE 3. The highest estimated upper-bound excess lifetime cancer
risk (6X10"6) is for child residents exposed to contaminants in surface soil by incidental ingestion, and the
13
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highest noncarcinogenic risk (Hl=2) is for child residents exposed to contaminants in surface soil by incidental
ingestion. Although the HI associated with incidental ingestion exposures by child residents exceeded 1,
inorganic compounds that were statistically determined to be within background levels accounted for the
exceedance. Although industrial soil RBCs were exceeded by contaminants in subsurface soil as indicated in
Section 4.1, the concentrations of contaminants yielded risks lower than those for residents exposed to surface
soil; therefore, only the risks for residents are presented. The ERA determined that contaminants in surface
soil at AREE 3 did not pose significant potential adverse ecological effects. Based on these results, no action
, is recommended at AREE 3.'
5.2 AREE 5-EPIC Building
No surface soil samples were collected at AREE 5 because the industrial sewerline is buried at least
5 ft bgs, so the HHRA only evaluated risks to future excavation workers. The highest estimated upper-bound
excess lifetime cancer risk (2X10"6) and the highest noncarcinogenic risk (Hl=2) are for incidental ingestion of
contaminated subsurface soils by excavation workers. Although the HI associated with incidental ingestion
exposures by excavation workers exceeded 1, inorganic compounds that were statistically determined to be
within background levels accounted for the exceedance. An ERA was not conducted for soil because surface
soU data were not available. No chemicals of potential concern were selected from the results of the sewerline
effluent sampling so neither a HHRA or an ERA was completed. Based on these results, no action is
recommended at AREE 5.
5.3 AREE 7 - Electrical Equipment Facility Pretreatment Tank
A streamlined risk assessment was conducted for current industrial/commercial and potential future
residential land uses at AREE 7. Human health risks were calculated only for the incidental ingestion pathway.
The highest estimated upper-bound excess lifetime cancer risk (5X10"6) is for child residents exposed to
contaminants in soil through incidental ingestion, and the highest noncarcinogenic risk (Hl=2) is for child
resident exposures to contaminants in soil via incidental ingestion. Although the HI associated with incidental
ingestion exposures by child residents exceeded 1, inorganic compounds that were statistically determined to
be within background levels accounted for the exceedance. An ERA was not conducted as part of the
streamlined risk assessment Based on these results, no action is recommended at AREE 7 pending clean
closure of AREE 7 under RCRA by VDEQ.
5.4 AREE 10 — Former Photographic Wastewater Lagoon
Mo surface soil samples were collected at AREE 10 because the lagoon was dredged and backfilled
such that any residual contamination would be at the base of the former lagoon and'not at the soil surface, so
the HHRA only evaluated risks to future excavation workers. The highest estimated upper-bound excess
lifetime cancer risk (6X10"6) is for excavation workers exposed to contaminants in subsurface soil by dermal
absorption, and the highest noncarcinogenic risk (Hl=0.9) is for excavation workers exposed to contaminants
$n subsurface soil by incidental ingestion. No ERA was conducted at AREE 10 because all samples were
collected at depths of greater than 6 inches. Based on the results of the HHRA, no action is recommended
at AREE 10.
6.5 AREE 16-2 - Possible Firefighter Training Pit
The HHRA determined that site-related contamination at AREE 16-2 does not pose an unacceptable
human health risk under either current industrial/commercial or potential future residential land-use conditions.
Discounting naturally-occurring metals that were statistically determined to be within background
concentrations, the highest estimated upper-bound excess lifetime cancer riskXBXIO"5) is for child residents
exposed to contaminants in surface soil by dermal absorption, and the highest noncarcinogenic risk (Hl=0.9)
is for excavation workers exposed to contaminants in subsurface soil by incidental ingestion. The ERA
determined that surface soil at AREE 16-2 does not pose significant potential adverse ecological effects. Based
on these results, no action is recommended at AREE 16-2.
14
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5.6 AREE 17 - Dump #3
The HHRA concluded that under both current industrial/commercial and potential future residential
land-use condrtions, the risks to workers, trespassers, residents, and excavation ^^m^SSSSki
exposure to contaminants. Discounting naturally-occurring metals that were statistically determined to be within
background concentrations, the highest estimated upper-bound excess lifetime cancer risk (TxioV forbid
M-rfS Suf rShdn C°ntaminants j" surface soi[ bV de<™' absorption, and the highest noncarcinogen c risk
for P*± 1 I eXS°Sed t0 site-related ^"taminants in surface soil by incidental ingestion and
for excavation workers exposed to contaminants in subsurface soil by incidental ingestion The ERA
£fP7neth 3t SUrffr S0i' 3t AREE 1 7 d°eS n0t P°Se Si9nificant P°ter^ial for adverse ecotogical
Based on these results, no action is recommended at AREE 17.
5.7 AREE 18 -Grease Pit
„ d!!termil?ed that- under botn current industrial/commercial and potential future residential
-use condrtions, srte-retated contamination at AREE 18 does not pose an unacceptable human health risk
a!r^°CC"™9 metals that were statistical|y determined to be wft background
, the highest estimated upper-bound excess lifetime cancer risk (2X1 0'5) is for child residents
exposed to contaminants in surface soil by incidental ingestion, and the highest noncarcinogenic risk (Hl=0 9)
is for excavation workers exposed to contaminants in subsurface soil by incidental ingestion. The ERA
.
-« ef«SU^ toDsrte-related contaminants at AREE 18 does not pose significant potential
adverse ecological effects. Based on these results, no action is recommended at AREE 18,
5.8 AREE 20 - Incinerator Septic Tank and Leach Field
rocwon/, f treamlined f k assessment was conducted for current industrial/commercial and potential future
resdential land uses at AREE 20. Risks were calculated only for the incidental ingestion pathway. The higheS
estimated upper-bound excess lifetime cancer risk (7X10*) and noncarcinogenic risk (HI = 0.7) were calculated
for ch.ld residents exposed to contaminants in soil through incidental ingestion. The streamlined risk
assessment did not include an ERA. Based on these results, no action is recommended forthe AREE 20 septic
Ldiilx cinCI i63CD TIGiQ,
5.9 AREE 24 - Transformer Storage Area
The HHRA concluded that, under both current industrial/commercial and potential future residential
land-use conditions, the risks to workers, trespassers, and residents are acceptable for exposure to site-related
contaminants in surface soil. Discounting naturally-occurring metals that were statistically determined to be
within background concentrations, the highest estimated upper-bound excess lifetime cancer risk (1X10'5) is
for child residents exposed to contaminants (i.e., aluminum) in surface soil by incidental ingestion, and the
taghesl: noncarcinogenic risk (HI-0.9) is for adult residents exposed to contaminants in surface soil by dermal
absorption. The ERA determined that surface soil at AREE 24 poses no significant potential for adverse
ecological effects. Based on these results, no action is recommended at AREE 24.
5.10 AREE 25-Sugar Tree
Since TPH is not evaluated in either the HHRA or the ERA, and no other chemicals of potential
concern were identified, no unacceptable risk was determined due to contaminants at AREE 25 Based on the
BRA and the fact that only one sample of a duplicate pair was found to contain TPH above the State's TPH soil
action level for USTs, no action is recommended at AREE 25.
5.11 AREE26-OutdoorWash Racks
Streamlined risk assessments were conducted for current industrial/commercial and potential future
residential land uses at both the current and former wash racks at AREE 26. Risks were calculated only for
15
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the incidental ingestion pathway. The highest upper-bound excess lifetime cancer risk (1X10"5) and
noncarcinogenic risk (Hl=1) were calculated for child residents exposed to contaminants in surface soil at the
current wash racks. The streamlined risk assessment did not include an ERA. Based on these results, no
action is recommended at AREE 26.
5.12 AREE29-1-SalvageYard
No chemicals of potential concern were identified in the subsurface soil sample at AREE 29-1;
therefore, the HHRA determined no unacceptable human health risk from exposure to contaminants in
subsurface soil. An ERA was not completed because the AREE 29-1 sample was collected at a depth greater
than 6 inches, thus eliminating the potential for exposure to ecological receptors. Based on these results, no
action is recommended at AREE 29-1.
5.13 AREE 29-2 - Possible Sludge Disposal Area
The HHRA determined that site-related contamination in surface soil at AREE 29-2 does not pose
unacceptable human health risks under either current industrial/commercial or potential future residential land-
use conditions. Discounting naturally-occurring metals that were statistically 'determined to be within
background concentrations, the highest estimated upper-bound excess lifetime cancer risk (6X10"6) is for child
residents exposed to contaminants (i.e., aluminum) in surface soil by incidental ingestion, and the highest
noncarcinogenic risks (Hl=0.3) are for child residents exposed to site-related contaminants in surface soil by
incidental ingestion and dermal absorption. The ERA found no significant potential for adverse ecological
effects from surface soil at AREE 29-2. Based on these results, no action is recommended at AREE 29-2.
5.14 AREE 29-3 - Possible Disposal Area
The results of the HHRA indicated that, under both current industrial/commercial and potential future
residential land-use conditions, the risk to workers, trespassers, residents, and excavation workers are
acceptable for exposure to site-related contaminants. Discounting naturally-occurring metals that were
statistically determined to be within background levels, the highest estimated upper-bound excess lifetime
cancer risk (8X10'^ is for child residents exposed to contaminants.in surface soil by dermal absorption, and
the highest noncarcinogenic risk (Hl=0.9) is for excavation workers exposed to contaminants in subsurface soil
by incidental ingestion. An ERA was not conducted because all soil samples were collected at depths greater
than 6 inches. Based on these results, no action is recommended at AREE 29-3.
S.15 AREE30-MotorPool .
Only subsurface soil samples were collected at AREE 30; therefore, an ERA was not conducted, and
human health risks were only evaluated for future excavation workers. All analytes were detected below their
screening levels (i.e., USEPA Region 111 industrial soil RBCs and the USEPA screening level for lead in
residential soil) and were eliminated as chemicals of potential concern such that risks to excavation workers
were determined to be acceptable. Based on these results, no action is recommended at AREE 30.
S.16 AREE 33 - Household Debris Pile
*
Only subsurface soil was sampled at AREE 33 because the purpose of the sampling was to determine
if the household debris had impacted the native soils which were encountered at greater than 2 ft bgs;
therefore, an ERA was not conducted, and human health risks were only evaluated for future excavation
workers. The highest estimated upper-bound excess lifetime cancer risk (9X10"7) is for excavation workers
exposed to contaminants through incidental ingestion. of subsurface soil. No noncarcinogenic risks were
'estimated because no noncarcinogenic chemicals of potential concern were identified. Based on these results,
no action is recommended at AREE 33.
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5.17 Site-Wide Groundwater
that was detected in the majonty of the on-site and background groundwater samples (i e is not ste reTaS
Excluding b,s(2-ethy!hexyl)phthalate along with naturally-occurring metals that werestatisticalSrmteri tn
be wrtNn background levels, the highest estimated upper-bound excess Ihime^n^SlTSu^
HHO 5?isTr°Sh?H C°ntaminante in site-wide groundwater by ingestion, and the highestnoncarc^ogenic risk
cnL"£m n» ^SK?***? eXpOSed to contaminants •" ***** groundwater by ingestion The sfeSed
SSL , P ief 6atf ? 'mpact °n cancer Hsks and "'"carcinogenic hazards a?e beryllium and barium
respectively. Remediation of the site-wide groundwater is not recommended based on the reTuIte ofTe HHR^'
5.18 South Run at AREEs 1 and 2
! 1 a^H ?^ T at srte-related contamination in the sediment and surface water of South Run
or ™tnL ? ? H n°« P,?e unaccePteble ""man health risks under either current industrial/commeSal
or potential future residential land-use conditions. Cancer risks were not estimated for exDosure to Sr J
water m South Run at AREEs 1 and 2 because no carcinogenic chemicals of poTential SrSS^uSSK
^C*T0*9e™ ^ 1H! = °-°°4) associated "*" surface wat*r in Soutft ?SS "a\ TAREES 1 a^fd
*|W. "f"18"* exposures by dermal absorption. For sediment in South Run at AREEs V and 2 the
estimated upper-bound excess lifetime cancer risk (1X1Q-6) is for child residents exnosedtn
sna±o,n Srie?imenttbV .">*« ntal in9esti0"- «"d the highest noncarcinogenic risk (H?9) is'for ^5
s exposed to contaminants in sediment by incidental ingestion. Although the HI' associated wh
incidental mgestion exposures to sediment in South Run at AREEs 1 and 2 by child I residents exceeded 1 C
exceedance was driven by metals believed to be naturally occurring, it should be ^SZSS^^Si
Idim/nttSC°rted PrLt0 Ca'CUlf "9 n"SkS beC3USe stafetical compansons could not bf conducted S
sediment sample results because of the limited number of available background samples. nQUCtea tor
°f the f ^ flr SUrface Water in South Run at AREEs 1 and 2 i^icate very little potential for
« "fe fr°m the presence of chemfca|s in surface water. The ERA determined S?he?e
Ru X Rl heCtS t0 ^ ?EQ = 19) 8nd mink (EEQ = 54) from selenium in sedSfrom SouS
^f^P*^^^^
^=s^fh?srs^^^^^^
effects are over-estimated by the ERA and are actually limited. ' mereiore, tne adverse
Based on these results, no action is recommended for South Run at AREEs 1 and 2.
5.19 Other Site Drainages
The HHRA determined that contamination in the sediment of the other site drainages does not oose '
,£? hUmMn healh "f t Under 6ither CUrrent industrial/commercial or potentia??uture resSeS
K ^ HUman hea'th riskS assodated ^ surface water in the other site drainages were no
ff n"56 hT WT b?fc8 °nly C°ntain flOWing w"tor duri"9 stOTm evente thus limiting the poensa
^^^9 ?*^ ** were statistically determined to be wrthi? background
thrn,nh n H « ^^^ upper-bound excess lifetime cancer risk (4X1 0'5) is for child residents
through madental mgestion of srte-related contaminants in sediment in the other site drainages The highest
-------
noncarcinogenic risk (Hi = 1) is for child residents exposed to site-related contaminants in sediment in the other
site drainages through incidental ingestion.
The ERA determined that the contaminants in the surface water and sediments of the other site
drainages do not pose significant potential for adverse ecological effects to aquatic life.
Based on these results, no action is recommended for the other site drainages.
6.0 SELECTED ALTERNATIVE
No action is selected by the U.S. Army for AREEs 3.5, 7,10,16-2,17.18.20.24.25,26.29-1, 29-2,
29^3,30, and 33; site-wide groundwater; South Run at AREEs 1 and 2; and other site drainages because these
sties do not pose unacceptable human health or ecological risks. USEPA and VDEQ concur with this decision.
, The estimated cost to implement this alternative is $0.
7.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Proposed Plan for AREEs 3,5,7,10.16-2,17.18,20,24,25,26,29-1,29-2.29-3. 30, and 33;
site-wide groundwater; South Run at AREEs 1 and 2; and other site drainages was released to the public on
• or about March 31,1999 (see Attachment 3). This document was made available for public review in the
Information Repository at the following location:
Fauquier County Library
• Warrenton Branch - Reference Section
11 Winchester Street, Warrenton, VA
{540)347-8750
Monday - Wednesday: 10:00 a.m. to 9:00 p.m.
Thursday — Saturday: 9:00 a.m. to 5:00 p.m.
Sunday: 1:00 p.m. to 5:00 p.m.
The notice of availability of the Proposed Plan (see Attachment 4) was published in The Fauouier
Citizen, the Fauauier Times-Democrat and the Manassas Journal Messenger during the week of March 29,
1899. A public comment period was held from April 1,199S, through April 30,1999. In addition, a public
meeting was held on April 15.1999. to present the Proposed Plan for AREEs 3,5.7,10,16-2,17,18.20,24,
25, 26, 29-1, 29-2, 29-3, 30, and 33; site-wide groundwater; South Run at AREEs 1 and 2; and other site
drainages and to answer questions and receive public comments. The public meeting minutes have been
transcribed, and a copy of the transcript is available to the public at the aforementioned location. A
Responsiveness Summary, included as part of this Decision Document (DD). has been prepared to respond
to the significant comments, criticisms, and new relevant information received during the comment period. Upon
signing the DD, the U.S. Army wSI publish a notice of availability of this DD in The Fauauier Citizen, the Fauquier
Times-Democrat and the Manassas Journal Messenger, and place the DD in the Information Repository.
8.0 RESPONSIVENESS SUMMARY
The purpose of this Responsiveness Summary is to provide the public with a summary of citizen
' comments, concerns, and questions about AREEs 3, 5,7,10,16-2,17,18,20,24,25,26,29-1, 29-2,29-3,
30, and 33; site-wide groundwater; South Run at AREEs 1 and 2; and other site drainages. A public meeting
was held on April 15,1999, to present the Proposed Plan and to answer questions and receive comments. At
'• the public meeting, USEPA had a question regarding the Proposed Plan; the citizens present did not have any
comments on the Proposed Plan. However, one citizen had a question regarding the use of radioactive
materials at VHFS. No written public comments were received during the April 1,1999, through April 30,1999,
public comment period. Written comments, however, were received from USEPA and VDEQ.
-------
The Responsiveness Summary is divided into the following sections:
• Selected newspaper notices announcing dates of the public comment period and location and
time of the public meeting;
• Comments raised during the public meeting on April 15, 1999;
• Public meeting attendance roster;
• Restoration Advisory Board Members; and
• Written comments received during the public comment period.
All comments and concerns summarized in this document have been considered by the U S Army in makina
a decision regarding the selected alternative. «-»•». «rmy in mawng
8.1 Selected Newspaper Notices
P *"n°uncin? th± ^'''ability of the Proposed Plan and the public meeting was published
ofrrhTiQoTRhni ^"qu'f^rnes-Democrat. and the Manassas Journal M~nn~ Hnrinjih. week
of March 29, 1 999. This public notice is provided in Attachment 4.
8.2 Comments Raised During the Public Meeting on April 15, 1999
are preserved beTo^ * C°mment dDrin9 fte public mee}ing- USEPA'S question and the U.S. Army's response
USEPA QUESTION: Is the explanation for bis(2-ethylhexyl)phthalate being found in background groundwater
because it is a common laboratory contaminant used to make plastics pliable?
- Bis<2:ethylehexyl)phthalate is both a laboratory and a field contaminant. Bis(2-
is used in plastic gloves and tubing to make them pliable. Plastic tubing is used to collect
fhmUn raised a question regarding the use of radioactive materials at
. The citizen s question and the U.S..Army's response are presented below:
CONCERNED CITIZEN: Has the U.S. Army investigated the use of radioactive materials at VHFS? The citizen
recollected that radioactive materials were used in the basement of a building located adjacent to the
educational offices and catty-cornered to the1 mess hall.
ARMY RESPONSE: In 1 996, the U.S. Army conducted a historical site assessment to establish the history of
the handling of radioactive sources/commodities at VHFS including the location of these materials- the types
of operations that used them; and any accidents, incidents, or leaks that may have occurred Durina this
assessment, it was determined that there was a high probability that a Radioactive Source Set had been stored
in the basement of Building 160; this item was removed from VHFS in 1967. Subsequent to the assessment
a radiation survey was conducted in the buildings, 'rooms, and areas known to or which could have had
radioactive materials on the premises (including the basement of Building 160) to determine if there was any
residual radioactive contamination at VHFS. The findings of the assessment and the radiation survey were
documented in Industrial Radiation Historical Site Assessment and Final Status Radiation Survey" published
19
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in August 1996 (U.S. Army CECOM, 1996). No radioactive contamination was detected durina the radiatinn
survey.
. 8.3 Public Meeting Attendance Roster
The public meeting was held on April 15, 1999, at the Former Headquarters Conference Room
(Building 101) at VHFS. The members of the community that attended the public meeting included Pat White
Mary Noel McMullen, and William McMullen (see Attachment 5).
8.4 Active Restoration Advisory Board Members
1. Chris Kencik
2. Dean Eckelberry
3. JohnMayhugh
4. OwenBludau
5. TtmTarr
6. Kevin Bell
7. Steve Mihalko
8. Robert Stroud
9. JoePhelan .
8.5 Written Comments Received During the Public Comment Period
No written comments were received from citizens during the public comment period. Written comments were
received from USEPA and VDEQ during the public comment period and are provided in Attachment 6. The U.S.
Army's responses to these comments are also provided in Attachment 6 and were distributed to the public
during the public comment period. Most of the USEPA's comments suggested wording changes or requested
clarification regarding specific information. Wording changes and clarifications requested by USEPA (see
Attachment 6 for details) have been incorporated into this DD. Substantive comments and the U S Army's
responses are presented below: 4tth
USEPA COMMENT: Is it appropriate to base decision-making on the draft SRI Report.
ARMY RESPONSE: The SRI Report does not include risk assessment All risk conclusions were made based
on the Rls. Therefore, the status of the SRI Report has no impact on the no action decision made for the
subject sites.
USEPA COMMENT: Can.we say that the property is okay for unrestricted future use if residential risk has not
been evaluated for subsurface soil? If not, we'll need institutional controls, a remedy. Consider a scenario
where the property is reused as residential and trees are planted, with the tree pits dug below 2 ft bgs.
Subsurface soil could then sit at the surface and be consumed by a child.
ARMY RESPONSE: The U.S. Army's understanding of USEPA's position is that soil below 2 ft bgs only needs
to satisfy target risk levels for excavation workers and not residents since residents would be unlikely to be
exposed to subsurface soils. In addition, the concentrations of contaminants currently present in subsurface
soB would not be representative of the concentrations that might be present if landscaping activities were to
occur which would involve mixing of subsurface soils with surface soil, clean topsoil, and other soil
amendments. Therefore, it would not be appropriate to evaluate risks to residents using available subsurface
soil data.
USEPA/VDEQ COMMENT: Since AREE 7 is to be closed under RCRA, clean closure must be approved by
tie VDEQ's Office of Waste Permitting before a no action alternative can be selected for this AREE.
20
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;s^
^
^
h benthic
in the trtbutariss to South Run at ARE& M I and 2hZiSf =^ H.°,wevr' the habitatfor b^io organisms
ERA and are -
9.0 REFERENCES
"
U.S.
21
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ATTACHMENT 1
RESPONSE TO USEPA COMMENTS ON THE
FINAL PHASE I REUSE AREA Rl REPORT
-------
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Response to Comments on the
Final Phase I Reuse Area RI Report, Vint Hill Farms Station
from USEPA Region III
RESOLUTION OF PREVIOUS COMMENTS
Comment
Response:
Regarding data validation, please explain why no J, K, or L qualifiers appear on any of the
data. Since there was a discrepancy between the IRDMIS database and the
AREE *a ' P'eaSe indiC3te the meth°d US6d When Determining SuTat
Since the data qualifiers had to be hand entered, only the qualifiers that affect the risk
SSTTr ^ 'IT**8' the conclusions °f ^e Phase i Reuse AreaR?Report were
entered into the database and presented in the report. •
Since the Site Inspection (SI) Report was supposedly prepared usinq the IRDMIS
database the IRDMIS database information was used when a dlcrepancy was found
between the IRDMIS database and the SI Report. ' screpancy was found
IMPACT OF NEW TOXICITY FACTORS ON RISK AT PHASE I
NOTE:
r? ,^P US,EPA S comments inct«ding point-by-point impacts of the toxicity
factor changes are provided in Attachment 1 to these responses. USEPAs comments are
summarized herein to focus attention on the overall conclusions made by USEPA
0 R.
Comment:
a °.rS !°me chemica!s have Chan9£d since April, when this report was
lnum°St CaSeS' the Chan9es would not alter the °utc°™ of the risk
nnfi , Hcfever-'n a few cases, the impacts on risk-management decisions could
significant. As we discussed during our conference call on December 2 1998 in
b *^fac tor,s could possibly change risk decisions a technical memo wi11
be developed that rationalizes no further action decisions at selected AREEs This
technical memo should include rationalizations for AREEs 12 13 16-1 27 29-4 and
groundwater wells that reveal high levels of bis(2-ethylhexyl)phthalate (BEHP).'
a) For AREE 12 subsurface soil, future residential risks did exceed 1E-4 due to
benzo[a]pyrene.
b)
c)
For AREE 13. aluminum, iron, and possibly vanadium also contributed.
For AREE 16-1 surface soil, risks did exceed NCP targets, due to arsenic, TCDD
and chromium. The concentrations of arsenic and TCDD at AREE 16-1 pose a
total cancer risk of 2E-4 for the child/adult scenario. Chromium is a possible
driver of an HI above 1.
DACA31-94-D-0064
ESPS4-81
January 1999
Response to USEPA Comments
Final Phase I Reuse Area RI Report
Vint Hill Farms Station
-------
d) For AREE 27. chromium and cadmium contribute to an HI above 1 .
' e) For AREE 29-4 surface soil, the aluminum HI of 1 .4 was borderline.
f) For site-wide groundwater, the BEHP is a potential concern. Although phthalates
are common laboratory contaminants, BEHP was detected in several wells at
high levels that were not attributed to blank contamination. On the other hand,
the presence of BEHP in background wells at similar levels implies that there may
be a regional BEHP issue. As a base-closure issue, the groundwater BEHP
could be important, since it exceeds both NCP target risks and the MCL.
Response: The U.S. Army appreciates USEPA's assessment of risks for the Phase 1 reuse area
based on the recent toxicity factor changes. However, for the record, the U.S. Army
'cannot agree with the details of USEPA's assessment and the risk numbers presented
without conducting the assessment itself. Reassessment of risks is not productive since
the report is final based on the toxicity factors valid at the time the report was finalized
and requested by USEPA in its comments on the Draft Phase I Reuse Area Rl Report.
Therefore, rather than addressing the specific numbers presented in USEPA's comments,
the goal of these responses is to address the major conclusions made by USEPA during
its assessment of the toxicity factor changes.
It is important to note that the toxicity factors used in USEPA's assessment were not
' available at the time the Phase I Reuse Area Rl Report was being finalized and the
remediation decisions were being made. Rather, the Phase 1 Reuse Area Rl Report was
prepared, and the remediation decisions made, based on the toxicity factors that were
valid at the time (i.e., toxicity factors published in October, 1997). However, in light of the
recent toxicity factor changes, the U.S. Army still believes that the no further action
conclusions made in the Final Phase I Reuse Area Rl Report are protective for the five
AREEs identified in USEPA's comments and site-wide groundwater as discussed in the
following paragraphs. . - .
a) For AREE 12 (Dump #2) subsurface soil, the. no further action decision is
protective for two reasons. First USEPA has previously established a policy
position that only industrial exposures (i.e.. construction wprkers) be considered
when evaluating soils below 2 ft below ground surface (bgs). Therefore, the
observation made by the USEPA toxicologist that the recently published toxicity
factor changes cause future residential risks from exposure to subsurface soil at
AREE 12 to exceed 1E-4 due to benzo[a]pyrene is not relevant. Construction
worker exposures remain below the target risk levels even in light of the recent
toxicity factor changes. Second, it is important to note that AREE 12 is a
permitted construction debris landfill, and the U.S. Army intends to institute deed
restrictions which will prevent exposure to subsurface soil.
b) For AREE 13 (Sludge Disposal Area), USEPA identified aluminum, iron, and
. ' possibly vanadium as compounds that contribute to elevated non-carcinogenic
risk As discussed in Section 8 of the Final Phase I Reuse Area Rl Report, the
son samples from AREE 13 were collected from 1-3 ft bgs which straddles the
surface/subsurface soil boundary (i.e.. 2 ft bgs). To be conservative, these
samples were evaluated as surface soil samples in the Human Health Risk
Assessment (HHRA) and thus were statistically compared to surface soil
' background results which are based on samples collected from 0-0.5 ft bgs
However, a more appropriate comparison can be made using the background
0^1-94^006.
ESP54-B1 . v«nt Hill Farms Station
January 1999
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subsurface soil sample results since surface soil was likely removed along with
the sludge in 1992. Iron concentrations in background subsurface soil samples
.are highly variable, ranging from 9,360 ng/g to 180,000 ng/g. Aluminum
concentrations in background subsurface soil samples range from 4,410 ng/g to
60,600 ng/g, and vanadium concentrations in background subsurface soil
samples range from 44.3 ng/g to 531 ng/g. The variability of iron, aluminum and
vanadium concentrations in the background subsurface soil samples is most
likely due to the variability of soils that were sampled. The composition of soil is
primarily controlled by the composition of the bedrock from which it is formed
Figure 2-1 of the Final Phase I Reuse Area Rl Report shows the geology of
shallow bedrock across VHFS. For example, the background subsurface soils
which have the highest iron concentrations (SB-BK-002 [91,000 ng/g at 3 ft bgsl
and SB-BK-003 [180,000 ng/g at 5 ft bgs and 100,000 ng/g at 18.5 ft bgs]) are
. located in areas where intrusions of mafic material (i.e., basalt) have occurred.
Mafic rocks are rich in iron and magnesium and will produce soils that are rich in
iron and magnesium. Iron concentrations in soil at AREE 13 range from 75,200
ng/g to 230,000 u.g/g. According to the Environmental Contamination Survey
(USATHAMA, 1986), a mafic intrusion (Hickory Grove Basalt) bisects AREE 13
and the sludge disposal area lies over the geological contact area of the
Catharpin Creek ' Member . and the Hickory Grove Basalt. The high iron
concentrations are most likely a product of the parent material from which the soil
in this area is derived. In addition, it should be noted that the aluminum and
vanadium concentrations at AREE 13 (53,300 ng/g to 73,100 pg/g for aluminum,
and 221 ug/g to 317 ng/g for vanadium) are more comparable to the subsurface
soil background ranges than they are to the surface soil background ranges
Furthermore and more importantly, aluminum, iron, and vanadium are not
anticipated to be present in environmental media at AREE 13 based on site
history. Other metals (e.g., silver, cadmium, lead, and mercury) which are more
likely to be site-related contaminants based on site history were either not
detected or were detected at concentrations below screening levels. Therefore,
aluminum, iron, and vanadium are not site-related contaminants but rather are
representative of background concentrations in soil derived from the type of
bedrock present at AREE 13. No further action is a protective recommendation
for AREE 13.
c) For AREE 16-1 (Possible Firefighter Training Pit) surface soil, USEPA found that
the concentrations of arsenic and TCDD pose a total cancer risk of 2E-4 for the
child/adult scenario. Even when ingestion and dermal absorption exposure routes
are added as was done by USEPA, the cancer risk is borderline compared to the
target risk of 1 E-4. Based on the borderline cancer risk associated with arsenic
and TCDD, the small size of the firefighter training pit (i.e., 50 ft diameter for one
of the possible pits which was most likely AREE 16-2 based on terrain) for which
typical exposure assumptions are exaggerated, and the uncertainty that AREE .
16-1 truly represents a former firefighter training pit, no further action at AREE 16-
1 is protective.
USEPA also found that chromium is a possible driver of a HI above 1 given the •
recently lowered (i.e., more stringent) toxicity factor for hexavalent chromium. It
should be noted that there is a great deal of conservatism built into the calculation
of the HI for chromium in surface soil at AREE 16-1 for the following reasons: 1 )
the HHRA is based on the conservative assumption that all chromium present at
Response to USEPA Comments
Januan, 1 999 Rnal Phase ' Reuse Area Rl ReP°rt
January 1999 Vint Hill Farms Station
-------
AREE 16-1 is hexavalent chromium which is not supported by site history; and 2)
the oral RfD for hexavalent chromium has an uncertainty factor of 900 which
indicates high uncertainty associated with the RfD. Hexavalent chroniium is
typically found in the environment as a result of contamination from electroplating
or conversion coating operations where hexavalent chromium is used in the
process solutions. The residential soil risk-based concentration (RBC) for trivalent
chromium, the form of chromium more commonly found in the environment when
electroplating and conversion coating operations are not involved, is three orders
of magnitude higher (i.e., less stringent) than the corresponding RBC for
hexavalent chromium (i.e., 1.2E5 ng/g versus 2.3E2 fig/g). In the case of AREE
16-1, which was a possible firefighter training pit, operations that used hexavalent
chromium were not conducted. In fact, operations using chromium in any form
were not conducted.
In addition, although chromium at AREE 16-1 was not statistically within
background, the data do not suggest widespread chromium contamination that
would be present if the contamination was site-related. Four surface soil samples
were collected at AREE 16-1 and yielded chromium at concentrations ranging
from 27.2 pg/g to 59.9 ng/g, with an arithmetic mean concentration of 41.0 fig/g.
Background concentrations in surface soil were detected at concentrations as
high as 60 jig/g. A common sense review of the data in light of site history
indicates that it is reasonable to find the chromium concentrations to be
representative of background concentrations.
Based on the conservatism of the HI calculation for. chromium, the lack of site
history involving chromium, and the fact that the detected chromium levels are
• potential background levels, the no further action decision for AREE 16-1 is
protective.
d) For AREE 27 (AAFES Service Station) surface soil, although cadmium and
chromium both contribute to a HI above 1. chromium is the risk driver because of
the recently lowered (i.e., more stringent) toxicity factor for hexavalent chromium.
Therefore, this response focuses on chromium. As discussed in Section 8 of the
Final Phase I Reuse Area Rl Report, there is a great deal of conservatism built
into the calculation of the HI for chromium in surface soil at AREE 27 for the
following reasons: 1) the HHRA is based on the conservative assumption that all
chromium present at AREE 27 is hexavalent chromium which is not supported by
site history; and 2) the oral RfD for hexavalent chromium has an uncertainty
factor of 900, which indicates high uncertainty associated with the RfD.
Hexavalent chromium is typically found in the environment as a result of
. contamination from electroplating or conversion coating operations where
hexavalent chromium is used in the process solutions. The residential soil RBC
for trivalent chromium, the form of chromium more commonly found in the
environment when electroplating and conversion coating operations' are not
involved, is three orders of magnitude higher (i.e.. less stringent) than the
corresponding RBC for hexavalent chromium (i.e.. 1.2E5 ng/g versus 2.3E2
pg/g). In the case of AREE 27, which was a fuel and service station, operations
that used hexavalent chromium were not conducted. .In fact, operations using
chromium in any form were not conducted.
In addition, although chromium at' AREE 27 was not statistically within
background, the data do not suggest widespread chromium contamination that
OACA31-94-D-0064
CSPS4-B1
January 1999
Response to USEPA Comments
Final Phase I Reuse Area Rl Report
Vint Hill Farms Station
-------
e)
would be present if the contamination was site-related. Nine surface soil samnl»«
2*4 ? ua nC2d7?,AREf " *? yWded C*°™m « "nwnXS ingfngfrom
ei'lS8 H ?9 9> W'th 3n arithmetic mean ^entration of 40.6 ugT
Background concentrations in surface soil were detected at concentrations as
high as 60 ng/g. A common sense review of the data in light of the Ste ThiL™
.nd,cates that it is reasonable to find the chromium cVncSn^tions to h«
representative of background concentrations. concentrations to be
Based on the conservatism of the HI calculation for chromium the lack
the fact that the ^tecte
deCiS'"°n for
are
*
27
(DisposaI Area) surface soil. USEPA calculated a HI for aluminum
ey acknowled9e is borderline. Based on the fact thatihe OK R£
f 3n uncertainty fa<=tor °f 100 and the Hlis not signiffcantly
drn TJ 6Ven WhSn ingesti°n and dermal Absorption exposure roues a re
added, no further action at AREE 29-4 is protective.
9roundwater- the fact t"at BEHP is both a common laboratory
and a common field contaminant is an important point Althouoh t fe
BEHP X t^^ a" BEHP deteCti°nS W6re b'ank qualifi'd« theSarsource of
BFHP ,« ^HS3mP 9, equ'Pment in Combination with the sampling technique
BEHP was Hptaf H .P'lStlCIZer in the flexible tubing used to sample the we.ls'
BEHP was detected in the equ.pment blanks prepared in the field at lower levels
SnT °H d I" S°me °f the 9roundwater samples primarily because oThow the
coKd .n 1 nrr^^6^ V6rSUS h°W the 9roun^ater samples were
Si « , * u PreParat'on of the equipment blanks, water was pumped through
SLhlT H ° acomparative|y raPid rate which did not allow for significant
leaching and accumulate* of BEHP in the sample. Conversely, the Tow-flow
t9h^ nhWfh m°ni Onn9 we" samplin9 method involved pumping of groundwS
trough the sample tubing at low flow rates. Many of the monitoring wells we7e
rCeShand reqrd ,PUmpin9 3t V6ry IOW flow rates- The low "0^3
-L^* iubmg ^'^ Sroundwater sampling increased the
ah i, E r,!° 'eaCh int° the Sample and concen^te This finding iJ
supported by the fact that elevated BEHP was found in site wells and background
wells at similar levels. Neither site nor regional history support USEPA's
suggestion that the BEHP found in the groundwater samples may represent a
regional issue. Groundwater samples were analyzed for a wide range of
fn°nmSn t^H and uE*?fP WaS the °n'y C°nstituent that exceeded screening ?eve^
in most of the wells. If the BEHP were the result of site or regional groundwater
Shl^hT ?' " T 'd ^ bSen f°Und in combination with SthercSntamlnante
rather than alone. Therefore, the conclusion that the BEHP is present as a result
of field contamination is appropriate, and no further action is a protective
recommendation for site-wide groundwater at VHFS.
DACA31-94-D-0064
ESPS4-81
January 1999
Response to USEPA Comments
Final Phase I Reuse Area Rl Report
Vint Hill Farms Station
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OTHER RISK-RELATED ISSUES
Comment: Cancer risks were presented separately for children and adults. In order to estimate the
• -lifetime cancer risk when exposure includes both childhood and adulthood, the risks
would be:
(Adult cancer risk x 24/30) + (Child cancer risk).
Response: Remediation decisions have all been made based on separate adult and child exposures
1 since this comment had not been made until well into the decision-making process (i.e.,
after the Final Phase I Reuse Area Rl Report was submitted). Furthermore, this
methodology is consistent with that used in other HHRAs performed for and accepted by
USEPA Region 111.
Comment: The soil-to-skin adherence factors are generally reported at lower levels in the new
• Exposure Factors Handbook than previously (Section 7.1.2.3; Tables 7-16. 7-17, 7-19, 7-
24). Therefore, it is possible that dermal soil risks are overestimated in this respect
Response: The uncertainty associated with the soil-to-skin adherence factors and their impact on risk
estimates is already discussed in the Uncertainty Section of the Final Phase I Reuse Area
RI Report.
DACA31-94-D-0064
ESPS4-81
January 1999
Response to USEPA Comments
Final Phase I Reuse Area Rl Report
Vint Hill Farms Station
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ATTACHMENT 1
DETAILED COMMENTS FROM USEPA REGARDING NEWTOX.CITY FACTORS
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IMPACT OF NEW TOXICITY FACTORS ON RISK AT PHASE I
Toxicity factors for some chemicals have changed since April, when this report was submitted In most
cases, the changes would not alter the outcome of the risk assessment. However, in a few cases the
impacts on risk-management decisions could be significant As we discussed during our conference call
on December 2. 1998, in cases where toxicity factors could possibly change risk decisions a technical
memo will be developed that rationalizes no further action decisions at selected AREEs This technical
memo should include rationalizations for AREEs 12,13. 16-1, 27, 29^ and groundwater wells that reveal
high levels of BEHP. To assist in the facilitation of this memo, EPA has provided a table in this letter that
indicates the impacts of the toxicity changes on the final estimates of risk. The toxicity-factor changes
would also impact other tables and sections of the Rl, on which the final risk estimates are built For
informational purposes, the changes to those "building-block," non-summary sections are included in an
attachment to this letter.
1. Table 7-155 (and pages 7-62 to 7-73):
The table should not be split by route; total risks are more informative. Also, given the changes
noted in the attachment, the risks on this table would be as follows:
MEDIUM/
LOCATION
WORKER
CA. RISK
WORKER
HL
ADULT
RES.
CA.
RISK
ADULT
RES.
HI
CHILD
RES.
CA. RISK
CHILD
RES.
HI
SURFACE SOIL:
AREE S
AREE11
AREE 13
AREE 16-1
AREE 16-2
AREE 17
AREE 18
AREE 19
AREE 21
AREE 24
AREE 27
AREE 29-2
AREE 29-3
AREE 29-4
Groundwater
—
3E-5
— •
—
—
—
—
—
—
—
_ .
-
—
—
—
— '
1.6 c
1.7 c
1.3
—
"~ i
—
—
—
— '
—
—
—
2.3 a
—
—
7E-5
—
1E-4
-
-
-
_.
-
-
-
-
-'
-
6E-4
1.9 c
4a
4
2.7 a
-
2c
2c
2.4 c
1.6 c
2.2 c
3
1.4 c
—
5a
8
—
5E-5
—
1E-4
—
—
—
—
—
—
—
—
—
—
3E-4
6.5 a
11
14
8
3.6 a
3a
6a
7
6a
7a .
7.5
4.3 a
3.1 c
16
18
-------
MEDIUM/
LOCATION
SEDIMENT:
EASTERN
•NORTHERN
WESTERN
WORKER
CA. RISK
WORKER
HI
ADULT
RES.
CA.
RISK
—
—
—
—
—
—
—
—
_
ADULT"
RES.
HI
—— — — — ™*-^^™ ^^__
«.
-_
~
CHILD
RES.
CA. RISK
1
«•
1E-4
SUBSURFACE SOIL:
AREE 12
Central AREEs
AREE 27
(Footnotes have th
_
—
e same meanin
1.8 c
1.6 c
n as in fho /irin'
1E-4
-
nol t>^Mn \
1.5 c
2c
2a
2E-4
CHILD
RES.
HI
— — — — — __
12a
. —
10a
__
22
5.1 a
7a .
6.7 a
2. The conclusions on page 7-63 should be altered slightly:
a) Add AREE 12 subsurface soil, benzo[a]pyrene.
b) Add AREE 29-4 surface soil, aluminum.
c) Add AREE 16-1 surface soil, arsenic, TCDD, and chromium.
d) To AREE 13, add aluminum and possibly vanadium.
e) To AREE 27, add cadmium.
3. Table 8-1: .
a) For AREE 12, future residential risks did exceed 1E-4 due to benzo[a]pyrene.
b)
c)
For AREE 13, aluminum and possibly vanadium also contributed; the reason that no
remediation is recommended is not clear.
e)
f)
ThP ™E I6"1' riSkS y 6XCeed NCP targets' due to arsenic- TCD°. and chromium
The reason for no remediation is not clear. . «J.,,,U,M.
For AREE 27, cadmium was- also a contributor. The reason for no remediation given the
yes in unacceptable health risks, is not clear. •
For AREE 29-4, the aluminum HI of 1 .4 was borderline.
R^, Proundwaf -the bis(2-ethylhexyi)phthalate (BEHP) is a potential concern
Reported levels were not all attributed to blank contamination.
4.
r App diS(Tussion of AREE 12 subsoil, AREE 16-1 surface soil, AREE
surface soil, AREE 13 iron, aluminum, and vanadium (as elevated metals in a sludge
-------
disposal area), and AREE 27 (for which the increase in the chromium toxicity factor has increased
the HI, although the point about valence state is well taken).
5. Section 8.2 should not dismiss the BEHP lightly. Although phthalates are common laboratory
contaminants, BEHP was detected in several wells at high levels that were not attributed to blank
contamination. On the other hand, the presence of BEHP in background wells at similar levels
implies that there may be a regional BEHP issue. As a base-closure issue, the groundwater
BEHP could be important, since it exceeds both NCP target risks and the MCL
6.. Page ES-2: For AREE 12. subsoil cancer risks exceed 1E-4 for potential residential exposure.
. For AREE 13, it is not clear that no action should be taken for metals exceeding background
levels in a sludge disposal area.
7. PageES-3:
a) The concentrations of arsenic and TCDD at AREE 16-1 pose a total cancer risk of 2E-4
for the child/adult scenario. Chromium is a possible driver of an HI above 1. Therefore, it
is not clear that no action is appropriate.
b) For AREE 27, chromium and cadmium contribute to an HI above 1.
8. Page ES-4:
a) For AREE 29-4, the aluminum HQ is 1.4.
b) For groundwater, further consideration should be given to the BEHP results.
c) For the summary bullets, antimony and arsenic should be added to AREE 19. AREE 13
(aluminum, iron, and possibly vanadium) should be added. AREE 16-1 (arsenic, TCDD,
and chromium) should be added. AREE 29-4 (aluminum) and AREE 12 subsurface soil
(benzo[a]pyrene) may warrant inclusion. Groundwater BEHP should receive further
consideration. AREE 27 (cadmium and chromium) may warrant inclusion.
OTHER RISK-RELATED ISSUES
9. Cancer risks were presented separately for children and adults. In order to estimate the lifetime
cancer risk when exposure includes both childhood and adulthood, the risks would be:
(Adult cancer risk x 24/30) + (Child cancer risk).
10 Appendix F- This appendix generates residential risks, but uses industrial RBCs to screen. If
residential RBCs were used, then additional COPCs (with their EPCs shown here) would be
identified:
AREE 12: aluminum (16100 mg/kg). chromium (24.7 mg/kg), iron (40400 mg/kg). manganese
(605 mg/kg), vanadium (95 mg/kg)
Central AREEs: aluminum (18900 mg/kg). antimony (0.27 mg/kg), cadmium (0.4 mg/kg).
chromium (27 mg/kg). manganese(2390 mg/kg). silver (0.44 mg/kg). vanadium (110 mg/kg)
AREE 27: aluminum (15000 mg/kg). arsenic (12.2 mg/kg). chromium (46 mg/kg). iron (48000
mg/kg), manganese (950 mg/kg), vanadium (116 mg/kg)
-------
11< ^o^^s^^-s^^^r' frr^13 in the ni* a-*—
b possibte that derma, rtSSSiSSStalSh ^J£ ^ M9' 7** ^'^ "
-------
ATTACHMENT: DETAILS ON RISK ASSESSMENT SECTIONS IMPACTED BY NEW TOXIC1TY
FACTORS
1. Tables 4-2 and F-1: Screening RBCs for beryllium, chromium, vinyl acetate. 1.3-dichlorobenzene.
2-chloronaphthalene, bis(2-ch!oroethyl)ether, dibenzofuran, 2-methylnaphthalene, naphthalene,'
the chlordanes. toxaphene, dinoseb. and Aroclor 1016 have been updated. As will be seen, only
the differences for beryllium, chromium, and chlordane are generally significant for Vint Hill.' The
1,2,3,7,8-PeCDF RBCs were incorrect on this table. However, since the correct numbers were
used elsewhere in the report, this is not a major issue.
2. Beryllium's RBC would be higher and it would no longer be e COPC, and chromium's RBC would
be lower but its COPC status would not change, on Tables 4-3 through 4-6, Tables 5-2 through 5-
8. Table 5-10 (chromium only), Table 5-1-1. Table 5-12, Tables 5-15 through 5-23, Tables 5-25
through 5-30, Tables 5-33 through 5-43, Table 5-45, Table 6-1, Table 7-2, and in Sections 4.2.1
4.2.2. 4.2.3. 5.1.2, 5.1.4. 5.2.2. 5.2.4, 5.2.5, 5.3.2.1. 5.3.2.2, 5.3.4.1, 5.3.4.2, 5.4.4, 5.5.1, 5.7.4.2,
5.7.5.2. 5.8.4.1. 5.8.4.2, 5.9.2, 5.9.4, 5.10.4.1. 5.10.4.2, 5.10.5, 5.11.2. 5.11.3, 5.12.1. 5.14.2,
6.14.4. 5.15.4, 5.16.2, 5.17.4, 5.18.2. 5.18.4. 5.18.5, 5.19.2, 5.19.4, 5.19.5, 6.4.1.1, 6.4.2.1, and
7.1.1.4; also on page 7-6. 3rd paragraph.
2-Methylnaphthalene's RBC would be lower, but its COPC status would not change, on Tables 5-
2. 5-9, 5-19, 5-35. 5-41, 5-45, and 7-2, and in Sections 5.1.2, 5.3.4.1, 5.3.4.2, 5.8.4.1, 5.14.4,
5.18.4. 5.18.5, 5.19.4, and 5.19.5.
Chlordane's RBC would be higher, but its COPC status would not change, on Tables 5-7, 5-11, 5-
20. and 5-43. and in Sections 5.3.2.1, 5.3.2.2. 5.4.4, 5.8.4.2, 5.19.2, and 5.19.5. The COPC
status of total chlordane would not change on Tables 5-8 and 5-9, and in Sections 5.3.4.1 and
. 5.3.4.2. Chlordane would no longer be a COPC on Table 5-19 and in Section 5.8.4.1.
.Naphthalene's RBC would be lower, but its COPC status would not change, on Tables 5-8, 5-9, 5-
11, 5-19. 5-41; 5-42, 5-45, and 7-2, and in Sections 5.3.4.1, 5.3.4.2, 5.4.4, 5.8.4.1. 5.18:4, 5.18.5,
5.19.4, and 5.19.5. "
3. On Tables 7-4 and 7-11 (also pp. 7-7 through 7-10), the COPC selections would change as
follows:
AREEs9, 13, 19, 21, 24. 29-2, 29-3: beryllium no, chromium yes;
AREEs 11. 16-1. 16-2.18. 27, 29-4: beryllium no;
AREE 17: chlordane no, beryllium no, chromium yes.
4. On Tables 7-6 and 7-11 (also on p. 7-12), the COPC selections for occupational use would
change as follows: Central AREEs: beryllium no.
5. On Tables 7-8 and 7-11 (also on p. 7-12), the COPC selections would change as follows:
chlordane no. •
(
6. Or. Tables 7-10 and 7-11 (also on pp. 7-13 and 7-14), the COPC selections would change as
follows:
i
Eastern: beryllium no;
Northern: beryllium no, chromium yes;
Western: alpha-chlordane no, gamma-chlordane no, beryllium no.
-------
7. Table 7-14:
aTO ,s
Surface soil, AREE 1 3: Chromium should be added, with an EPC of 28.9 mg/kg.
Surface soil, AREE 17: Chromium should be added, with an EPC of 35 mg/kg.
Surface soil, AREE 1 9: Chromium should be added, with an EPC of 23 mg/kg.
Surface soil. AREE 21: Chromium should be added, with an EPC of 20 mg/kg.
Surface soil, AREE 24: Chromium should be added, with an EPC of 33.6 mg/kg.
Surface soil, AREE 29-2: Chromium should be added, with an EPC of 36 6 mg/kg
"—•———
8. Table 7-25:
°'35 per ^^^ the
are
The 1 ,2-dichloroethane target organs include the stomach and thymus.
. The barium target organs include the kidney.
The new chromium oral RfD is 3E-3 mg/kg/day.
The inorganic mercury target organ is the immune system.
9. Table 7-26:
The new unit risk for chlordane is 1 E-4 per ug/m3; the new RfC is 7E^ mg/m3.
The 1 ,2-dichloroethane target organs include possible kidney effects.
The provisionaf aluminum RfC is 3.5E-3 mg/m3.
-------
The new beryllium RfC is 2E-5 mg/m3.
The new chromium RfC is 1 E-4 mg/m3.
'"• %^Z^££S£ZSEH St^ttZSXZSXZ*
accordance with their new oral numbers. numoers would change i
11. The risk drivers for AREE 9 surface soil would be iron, manganese chromium and
wh,ch are all s.milar to background levels (chromium tested with MannlwhiTney)
Jhio^'f drife^-^r AREE 11 SUrfaCe S0i! wouid be chromium. vanadium, mercury iron and
chlordane. of which mercury and chlordane exceed background levels.
The risk drivers for AREE 13 surface soil would be aluminum, iron, chromium, and vanadium of
which only chromium is similar to background levels (chromium tested with Mann-Whitney)
The risk drivers for AREE 16-1 surface soil would be arsenic, chromium, iron manganese
vanadium, and TCDD. of which arsenic. TCDD. and chromium exceed background levels
to
The risk drivers for AREE 17 surface soil would be iron, manganese, chromium, and vanadium
wh.ch are all s.milar to background levels (chromium tested with Mann-Whitney). naaium-
are an
v»n f- 19 SUrfaCe SOH W0uld be jron- antimony, chromium, arsenic and
vanadium, of which ant.mony and arsenic exceed background levels (chromium tested with Mann-
The risk drivers for AREE 21 surface soil would be iron, manganese, chromium, and vanadium all
ot which are similar to background levels (chromium tested with Mann-Whitney).
The risk drivers for AREE 24 surface soil would be iron/manganese, chromium, and vanadium all
of which are similar tc background levels (chromium tested with Mann-Whitney).
The risk drivers for AREE 27 surface soil would be chromium, vanadium, cadmium and iron of
which chromium and cadmium exceed background levels.
The risk drivers for AREE 29-2 surface soil would be iron and chromium, which are both similar to
background levels (chromium tested with Mann-Whitney).
The risk drivers 'for AREE 29-4 surface soil would be chromium, vanadium, beryllium iron
aluminum, and manganese, of which only aluminum exceeds background levels. • '
• The risk drivers for groundwater are manganese and bis(2-ethylhexyl)phthalate (BEHP) of which
both are similar to background levels, although BEHP is not naturally occurring.
The risk drivers for western tributary sediment are arsenic, chromium, iron manganese and
vanadium, of which arsenic exceeds background levels.
The risk drivers for eastern tributary sediment are iron, chromium, manganese, and vanadium all
of which are similar to background levels.
-------
12.
[SSW.SSS&S*1*lron'and vanadium' a»of w*"
The risk drivers for AREE .12 subsurface soil would be iron
.SS'Sn-Cnert °nly ""«*»'"» ^are " —-
all of whit
Whitney).
nsk drivers are still manganese and BEHP. with manganese attributed tcI backgroun?
HQ * ' °
5E'5; the TCDD <**<** risk «» 8E-5 (total 1E-4) the
At AREE 27, the cadmium HQ is 0.21; the chromium HQ is 1.22; these are potentially additive
o
-------
increase, while risks for beryllium and chlordane would decrease. However, all cancer risks would
be less than 1E-4, and all His would be at or below 1 after consideration of target oraans and
background, except for the following: a
At AREE 11. the mercury HQ is 1.8; the chlordane HQ is 2.7. The chiordane cancer risk is 4E 5
The cancer risk on Table 7-149 should not be attributed to background.
At AREE 13. the aluminum HQ is 1.2; the iron HQ is greater than 10; the vanadium HQ is ? R
Vanadium may not be attributable to background.
At AREE 16-1. the arsenic cancer risk is 5E-5; the TCDD cancer risk is 7E-5 (total 1E^V the
chromium HQ is 2.5. Chromium may not be attributable to background. The cancer risk's on
Table 7-149 should not be marked "b."
At AREE .19, the antimony HQ is 1.5; the arsenic HQ is 1.4; these are potentially additive The
His on Table 7-149 should not be marked "e."
At AREE 27. the cadmium HQ is 0.4; the chromium HQ is 2.2;' these are potentially additive The
His on Table 7-149 should not be marked "b."
At AREE 29-4. the aluminum HQ is 1.4; this was not attributed to background.
18. For Tables 7-138 through 7-141 and 7-150, along with pages 7-53 and 7-54: Beryllium risks would
decrease, while risks for chromium would increase. However, all cancer risks would be less than
1E-4. and all His would be at or below 1 after consideration of target organs and background.
19. For Tables 7-142. 7-143. and 7-151. along with pages 7-54 and 7-55: Risks for chromium would
increase, white risks for beryllium and chlordane would decrease. However, all cancer risks would
be less than 1E-4. and all His would be at or below 1 after consideration of target organs and
background, except for the following:
For western tributary sediment, the arsenic HQ is 2.5 and the arsenic cancer risk is 9E-5 (added
to a chlordane risk of 1E-5). The cancer risk should not be marked "c" on Table 7-151.
20. Beryllium should not be a cancer driver on Tables 7-144 through 7-151.
21. Table 7-152. Section 7.1.4.3, Section 7.1.5.4: AREE 16-1 now has the highest cancer risk, and
AREE 29-4 has the highest HI. The risks on this table would change as previously noted.
-------
-------
ATTACHMENT 2
RESPONSE TO USEPA COMMENTS ON THE
FINAL PHASE (I REUSE AREA Rl REPORT
-------
-------
Response to Comments on the
Final Phase II Reuse Area Ri Report, Vint Hill Farms Station
from USEPA Region III
RESOLUTION OF PREVIOUS COMMENTS
Comment: The change was made to Table 5-12
Response:
but
Comment:
Response:
Comment:
Response:
the addition of certain hu™n health COPCs
not expected to greatly impact the usefulness of the risk assessment '
Comment:
Response:
®ffpjfi|ffiijg
Comment:
lh*"-«"1"
comparisons -for
DACA31-95-D-0083
TERC18-46
May 1999
Response to USEPA Comments
Final Phase II Reuse Area Rl Report
Vint Hill Farms Station
-------
Response:
The pesticides in question (chlordane and heptachlor) were not mentioned in Sections
groundwater at VHFS.
Comment
Response:
The finding of thallium in sediment was worthy of mention in the text, particularly since this
chemical was a. risk driver, and it should have been added. However discussion of
sediment thallium appears elsewhere in the Rl. and this wording issue is not expected to
affect the conclusions of the risk assessment
Thallium was not discussed in Section 6.4.3.1 because it is not considered to be a
significant contaminant in sediment at VHFS. No further response is required since the
conclusions of the risk assessment are not affected.
Comment:
Response:
The PEF equation was added tc the report, but the SSL equation (SSL = ?) does not
appear. The site-specific SSL equation, which combined PEF and VF and therefore
cannot be determined by consulting the general guidance, should be provided.
Residential SSLs were based on residential child exposure parameters for
noncarcmogenic compounds and integrated child and adult exposure parameters for
carcinogenic compounds. Industrial SSLs were based on industrial worker exposures for
both noncarcmogenic and carcinogenic compounds. The following equations were used
to develop the SSLs:
RESIDENTIAL
THQ-BW-AT-Days" RfDj
INDUSTRIAL
EF" IR ' ED * (1/WF +1 / PEF)
TR-AT "Days
EF- IFA*f (1 / VF + 1 / PEF; - CSF,
THQ'BWAT-Days- ff/D,
- IR • £0 * (1/ VF +1 / PEF)
where:
THQ
TR
BW
AT
Days
RfD,
CSF,
£F
(Non)cancer son screening level (mg/kg);
Target hazard quotient (dimensiontess);
Target cancer risk (dimensionless);
Body weight (kg);
Averaging-Time (yr);
Conversion factor (d/yr);
Inhalation reference dose (mg/kg-d);
Inhalation cancer slope factor (mg/kg-d)-1;
BACA31-95-D-0083
1EHC1B-46
May 1599
Response to USEPA Comments
Foul Phase n Reuse Area R« Report
Vint Hill Farms Station
-------
EF
ED
IR
PEF
VF
Exposure frequency (d/yr);
Exposure duration (yr);
Inhalation rate (m3/d);
Age-adjusted inhalation factor (m3-yr/d-kg)-
Particulate Emission Factor (1.15 x109 m3/kaV and
Volatilization Factor (m'/kg). 9)>
Comment
Response:
^^
Comment:
Response:
'°
« is no, dear whether «. expianation appea
The explanation can be found on Page 7-7.
Comment:
Response:
hee
Wowing equation: [(Adult 30-year risk /1J) x 24) " (ChiKyear rt
Comment:
Response:
Comment:
DACA31-95-D-0083
TERC18-46
May 1999
overestimated because volatilization was not
" dermal exposure during showering. However,
Response to USEPA Comments
Final Phase II Reuse Area Rl Report
Vint Hill Farms Station
-------
Response:
the results are very close to EPA estimates (e.g.. adult dermal HI of 4 vs. 5), and the
bottom-line conclusions remain the same.
Since the bottom-line conclusions of the risk assessment remain the same, no response
is required.
Comment: It should be noted that chromium and manganese are also risk drivers, although attributed
to background. This information is not expected to greatly impact the conclusions of the
risk assessment
• Response: The U.S. Army does not agree with listing background metals as risk drivers.
Comment: It should be noted that vanadium and manganese are also risk drivers, although attributed
to background. This information is not expected to greatly impact the conclusions of the
•risk assessment
Response: The U.S. Army does not agree with listing background metals as risk drivers.
• Comment: The adult resident for AREE1 has a total cancer risk of 1E-4.
Response: The U.S. Army agrees with this comment
Comment The child resident dermal HI for AREE 14 is 1 (c). which is notable because the ingestion
• HI is greater than 1 (possible additive effects).
Response: Since all of the COPCs for surface soil at AREE 14 are metals statistically determined to
fee within background levels, additive effects are not a concern.
"Comment: For AREE 31. the child resident ingestion HI is 1.3 (d) and the dermal Hi" is 0.5 id); the
total Hi exceeds 1.
"Response: Although the U.S. Army does not agree with the values quoted in the comment the Phase
II Reuse Area Rl Report did conclude mat the risks associated with surface soil at AREE
31 exceeded USEPA's target risk range for health protectiveness at Superfund sites.
' Surface soil at AREE 31 has since been remediated.
Comment:
Response:
'The child resident dermal HI for AREE 32 is 1.3 (c), which is notable because the
ingestion HI is greater than 1 (possible additive effects).
The only COPC which was not statistically determined to be within background levels in
AREE 32 surface son was aluminum. The total HI for aluminum (i.e., incidental ingestion
plus dermal absorption) is 0.3. Therefore, additive effects are not a concern.
•PACA31-95-D-0083
TERC16-46
May 1999
Response to USEPA Comments
Final Phase II Reuse Area Rl Report
Vint Hill Farms Station
-------
Comment
Response:
Comment:
Response:
seParated by
Page 7-41, AREE 2 worker: the total HI is 1, but is less than 1 when separated by
target organ; '
Page 7-43 of the report was missing and should be provided;
Page 7-45 last paragraph; and page 7-46, 4th paragraph: no effects are
to 1> contrary to the text statements that effects
The following involve wording in the risk characterization section (now pp. 7-39 through 7-
a)
b)
c)
d)
e)
f)
9)
h)
a)
b)
c)
d)
e)
f)
g)
h)
Page 7-46^ AREE 1 adult resident: the total HI is 1 ;
Page 7-47, AREE 31 child resident: the total HI is approximately 1, but is 1 or less
when separated by target organ;
Page 7-47, AREE 32 adult resident: the total HI is 1, but is less than 1 when
separated by target organ;
Page 7-51, 1st paragraph, last sentence: it is more accurate to state that exposed
children may have adverse effects, rather than that this is likely, given the levels
found at most of these AREEs.
The U.S. Army agrees with this comment.
The U.S. Army agrees with this comment.
Page 7-43 is attached. - .
The U.S. Army acknowledges and agrees with this comment.
The U.S. Army believes this comment was meant to be on either AREE 4 or
AREE 14. If this is the case, the U.S. Army agrees with this comment.
The U.S. Army agrees with this comment.
The U.S. Army agrees with this comment.
The U.S. Army acknowledges and agrees with this comment.
The page in question is now 7-56; it should be noted that chromium and dioxins and
furans are also contributors to risk.
The U.S. Army agrees that chromium and dioxins/furans also contribute to risk for AREE
1 surface soil although to a lesser extent than the contaminants listed.
Comment: It is difficult to determine whether the sediment metals are site-related, because the two
nearest AREEs (1 and 2) are a dump and a sewage treatment plant, both of which could
DACA31-95-D-0083
TERC18-46
May 1999
Response to USEPA Comments
Final Phase II Reuse Area Rl Report
Vint Hill Farms Station
-------
Response:
be associated with a wide variety of contaminants, including metals. However, the
similarity of the non-thallium metals to background and the low frequency of the thallium
(one detection) are the strongest arguments for the facility's interpretation of the sediment
metals pattern.
Based on this comment, USEPA appears to agree with the arguments presented in the
Phase II Reuse Area Rl Report regarding metals in South Run sediment at AREEs 1 and
2 not being, site-related.
Comment: Table 8-1: For groundwater issues at AREE 1 and AREE 28-5. please refer to my review
of the SRI. No further amendment of the Phase 2 Rl is expected with respect to this
issue.
Response: Comments regarding the SRI Report will be addressed separately.' Since the comment
indicates that no further amendment to the Phase II Reuse Area Rl Report is required, no
response is necessary.
Comment: It is difficult to support the claim that iron is not site-related at AREE 2, because the on-
site levels were statistically greater than.background and because the nature of the site
(sewage treatment plant) could be associated with a variety of metals. As noted in the
report, there are also arguments to made against site attribution of iron, but in my view
they are not conclusive. The facility should explain how and if the planned mercury
remedy will address iron (whether incidentally or intentionally).
Response: Although the U.S. Army maintains that iron in AREE 2 surface soil is attributable to
background, the planned remediation of surface soil at AREE 2 as a result of mercury
contamination (i.e., excavation and off-site disposal) will also address iron in the surface
soil.
. DACA31-95-D-0083
TERC1&-46
May 1999
Response to USEPA Comments
Final Phase II Reuse Area Rl Report
Vint Hill Farms Station
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ATTACHMENT 3
PROPOSED PLAN
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™ • ' 16"2> 17> 18j20-24'25«26>29-1'
-2, 29-3, 30, and 33, and Site-wide Groundwater,
South Run at AREEs 1 & 2, and Other Site Drainages
Vint Hili Farms Station, Virginia
March 1999
INTRODUCTION
SB
Fauquier County Library
Warrenton Branch - Reference Section
1 1 Winchester Street, Warrenton VA
(540) 347-8750
Monday - Wednesday: 1 0:00 a.m. to 9:00 p.m
Thursday - Saturday: 9:00 a.m. to 5:00 p.m.
Sunday: 1:00 p.m. to 5:00 pm
than April an loop to: P ' P'eaSe Send your ^^ments, postmarked -nn later
Kevin Bell, Public Affairs Officer
Building 2500, Helms Road
Vint Hills Farm Station
Warrenton. VA 22187
Thursday, April 15, 1999 at 7:00 p.m.
Building 101 - Former Headquarters Conference Room
Vint Hill Farms Station, Warrenton. VA
Special provisions will be made for the handicapped and hearing impaired
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e
SITE BACKGROUND
». e
operation sites. o e Pr°PertX are used for stationa iy and
,
^
™H n« enasm
MenUM 24 AREEs vrtifch required Hi*eHnvS5.Sf In LS5 ^ ™h'Ch """ °»nPW« " June. 1996.
r, 1998. and isrner** ^ "" SR' rePOrt WaS
—
AREE 3 -Warehouse;
AREE 5 - Environments Photographic Interpretation Center (EPIC) Building-
AREE 7 - Electrical Equipment Facility Pretreatment Tank; '
AREE 10 - Former Photographic Wastewater Lagoon;
AREE 16-2 - Possible FirefighterVraining Pit;
AREE 17 -Dump #3;
AREE 18 -Grease Pit;
AREE 20 - Incinerator Septic Tank and Leach Field;
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MONTGOMERY
MARYLAND
PRINCE GEORGES
VINT HILL
FARMS STATION
*\
PRINCE WILLIAM
0 5 10
2^3
SCALE IN MILES
GENERAL LOCATION
OFVHFS
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AREE 24 - Transformer Storage Area;
AREE 25 -Sugar Tree;
AREE 26 - Outdoor Wash Racks;
AREE 29-1 -Salvage Yard;
AREE 29-2- Possible Sludge Disposal Area;
AREE 29-3 -Possible Disposal Area;
AREE 30 -Motor Pool;
AREE 33 - Household Debris Pile;
Site-Wide Groundwater
The locations of these AREEs are shown on Figure 2.
RESULTS OF THE REMEDIAL INVESTIGATION
media investigated included surface so I 0 to ?l» h f°ndltlon of each.of the areas. The environment
°
final Phase II Reuse
the Fauquier County
AREE 3-Warehouse
• » - -
Warehouse may have been used for the temD™ S£ 9^ .I?1 Were ""^ with concrete «" 1967 The
and .ndustrial organic chemicals Th« ^areaTof St N9 °f dmm8 of oil' 9rease- solvent, paint aekf
Wff °f e: "^e hydraulic lift'pit; the^ase pit anl ff^^S*"!?'1. "^ been iden«^d at ?he
the budding. ,n a former lavatory. Drain pipes from a sink and wLtf00' ^ 'OCated at the south end «rf
hydrocarbon (PAH), was detected in samples t ^ h HBen2o(a)Pyrene. a polynuclear aromatic
concent rations (RBC, established by T£" u?^ ££?,£"!* 3t tevels above the nsk-bSd
soTfi±r?e W3S detected above ** resLntfaTsSlRBCmOflyn^ $Creening analytical res"'^-
so sample at a concentration of 0.155 ppm anc I aboS iS • ^( ? , P ** per million fPPm» in' a surface
sort sample at a concentration of 2.9 pP3 ? Tote, nSSJum h J"8^ SOi' RBC (0'78 PPm> in a subsurface
ppm) below the State's TPH soil acffi.^finSt^'T^ TPH) WaS detected <25-9 to 40.5
samples collected underneath the hydraufc fts No conSinS-396 ta"kS (USTs) of 10°
samples col,ecteda,ong the penmeter'of the hydSu^ifts^^^ in Sub
in
in
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002-05-04
OTHER SITE
DRAINAGES
AREEs LOCATIONS:
WAREHOUSE
EPKBUIOING
OECraiCAl. EOUPXENT FAOIOT
FORMER PHOTOGRAPHIC KASTWAim
LAGOON
16-2 POSSIBLE nREfKHTOI TRAMW PIT
17 DWIPfJ
18
20
WESTERN
SOUTH
TRIBUTARY
IRANSfCRWH STORAGE AREA
SUGAR IREE
.OUTDOOR WASH RACKS
SALVAGE YARD
•POSSIBLE SLUOGE DISPOSAL AREA
POSSIBLE DISPOSAL AREA
MOTOR'POCH
HOUSOKHO DEBRIS PUS
PHASE I REUSE AREA
PHASE H REUSE AREA
GENERAL LOCATIONS
OFAREEsATVHFS
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AREE B- EPIC Buffering
'he
c
and no""1' SiVefl and lead "***«> off site sTarting in 198r Cana9ted f S hazardous ^ste (based on
and no cracks in the concrete walls or stained Ink ! ,The Pretreatment tank was closed in 1995
neutrahzatton pit closed in MayTs»0 aiSTbS? SIL l"^ Whe" Jt Was removed ^ 1997 The
Resource Conservation and Recovery Ac^c^ the requirements of tnl
-Former Photographic Wastewater Lagoon
— - .e conB
sediments
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AREE 16-2 - Possible Firefighter Training Pit
« •» *
^^^^^^^^n^MK
samples were collected based on p^rfce^H rSute tern fh^ Jf^- ?Ulfe°e anlf «*""*" ««
pa,^, resu,i ^'sr^rnT^
- — - -
soil's afAppn -t-7 i,~ ..u . ° -•--'-»• "aoou ULI uieiesiwsortne test ptsamolino thp
sons at AREE 17 have not been impacted b« nmwimie H;..^^^-, __.:..:il 7 M »dinpnng, me
- Grease Pit
1
only analyte to
w —• i%i MVIWI t (5.4 ppm)
- Incinerator Septic Tank and Leach Field
Incinerator building. All floor washS^vere 'dbStaS!^ ^connected to the sinks and toilets in the
indicated lhat
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AREE 24 - Transformer Storage Area
fi
laboratory analysis results indicate that surfaoJ £ El ? ff^' Evaluation <* *e field screening and
activities at AREE 24. SUrfaCe S0" has not been imPa°ted from PCB transformer storage
AREE 25-Sugar Tree
^
vegetation or other evidence of oonSS^ S' *"*? h°WeVer' no
• sa:
, of the diese. AST. however. TPH-d Si S^SJtlE?11 ^ SO'VentS' At 'the former
level for underground storage tanks (JIVs) (lOolmft S? ,'" f06^ °f ^ State-=,oU- „.— :
constructed in April. 1982. to replace the Serwas? tracks Eat SS» K CUTOnt Wash racks were
berms to prevent run-off and a ramped entrance ^toDrevIr.t LS n IW3Sh rack has 1°-inch co™*e
a gnt chamber, which discharged iVffluent t? thJ ^^^ ^J8 *°m *» ^^"t ««sh racks ted to
discharged to the surrounding soils In Febmarv 1992 tl TK I™"8 from the former wa«h racks
were steam cleaned and all fluids and sedSs lere'
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AREE 29-2 -Possible Sludge Disposal Area
5T C°eCted fr°m ^ area ^ JndiCated ** the <>»- *entifed in th. area have
AREE 29-3 - Possible Disposal Area
AREE 30 - Motor Pool
- Household Debris Pile
• and
Site-wide Groundwater
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Durtng the Phase , ana „ reuse m R,s
(Vet"°"i Ma«lte"a™* *-» *™« (9.43 ppb) exceeded «s tep rater RBC
USTs):
confirmed during the SRI. ' ' d the benzene contamination at AREE 9 were not
of
d. thus, have been segregated from site-wide
South Run at AREEs land 2
only analytes detected above screenirfg evete ?n t °l^°P?8r *"* ^ ir°n were the
not been impacted by activities at AREEs 1 and
"
creenrg evete n the «
not been impacted by activities at AREEs 1 and 2 MM*? D?U ^P S' lndlcatin9 that surface water has
levels in the sediment samples Fo/exampte "he PAH Sh^ andH^stidde« exceeded their screening
and 0.213 ^ ffecte S5?SS^l!^e*laidlTO(0-18e PP"
h Run HSK ^ (f * ( 85 Ppm and °-0005 PPm>
^
mp e AH
and 0.213 ppm. respectively) «T* effecte -
respectively) in the sediment samples from South Run HSK ^ (f * ( 85 Ppm and °-0005
PS^
*
10
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Other Site Drainages
several wanrnvater fish spectes ely t0 SUppCrt aquatic invert^rates, amphibians, and
™j.^»
HUMAN HEALTH AND ECOLOGICAL RISK ASSESSMENT
The HHRA follows a four-step process-
'
.
a 0.1 hazard quotient (defined below), and conservative exposure parameters
- determines the toxic effects of the contaminants- and
S^^3±^r4S^^^
11
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"
different organ SSTJSS tof eto", •SSS*' feete **««"» vanous impacts on
^^
^
-9
there ,s a potential of one additional peraon in a DODSfnn ofVn ±^ran^enic risk of 1x1^ means that
contaminants at a site ff the site is not emedE I A H ' °°°f deleIoPin9 ^er from exposure to
noncaranogenio health effects if the site is noSSSd. 9reater "^ 1 indicates a potential for
The ERA also follows a four-step process: ' '
SBsas±sssss«=ssss,±sr«--
=====±=1
ssssss-" aaveree etecte *- «— » -*»
,p E •
ecological effects to terrestrial plants and terrestrial b™2S * . / ^e ERA evalua*ed potential adverse
South Run atAREEs 1 and 2. exposure to contaminants in sediment were evaluated for
ls tesea on m -
potenHal concern and the tM^'alm^a^tmMl^r cofe"tral""'='doses for the chemicals of
Ulan 1, Oiere is a potential for advers^ ^wSw SSS'L60™1 re°epl°rs- lflhe EE°
'
" -
Reuse Area
- Warehouse
«— « *.
The M9hes,
12
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AREE S - EPIC Building '
-r lamuP'eS W6re C°"ected at AREE 5' so fte HHRA only evaluated risks to future excavation
The highest estimated upper-bound excess lifetime cancer risk (2X10*) and
es
SSTSSSSh^f? ^ !°^inc;!d6ntal ih9estion of contaminated subsurface sois by excafon
workers. Although the HI associated with incidental ingestion exposures by excavation workers exceed^
iSS™nTnS?BtlWW StatiStiCa"y determined t0 be Within »^SeC3fSS^
ERA W3S not ^ducted fo
Within
^ducted for soil because surface soil data were not available No
HH orFRA , Se'eCted fr°m the reSUltS Of the seweriine •fflueTaa^^££iaE
a HHRA or an ERA was completed. Based on these results, no further action is recommended at AREE
AREE 7 -Electrical Equipment Facility Pretreatment Tank
A streamlined risk assessment was conducted for current and future land uses at AREE 7 Human health
nsks were calculated only for the incidental ingestion pathway. The highest ^atedupper-JounS
SSy^ (5X1° } IS fof Chi'd reSidentS 6XpOSed to contaminants in soil througMnciSS
n. and the highest noncarcmogenic risk (Hl=2) is for child resident exposures to contaminants in
sn222LdT?HOn- MhOU9h ^ H' aSSOdated WUh inddentat '"9^ion eioLrerSy ch S
alctS for \*T^C°mPOUT 21 W6re statistical|y determined to be within background
accounted for the exceedance. An ERA was not conducted as part of the streamlined risk
assessment. Based on these results, no further action is recommended at AREE 7. *iream"ned nsk
AREE 10 - Former Photographic Wastewater Lagoon
No surface soil samples were collected at AREE 10. so the HHRA only evaluated risks to future
excSn r?erS" ThS ,highSSt eStimated W*-»™« excess lifetime cancer S 6X10°) s for
excavation workers exposed to contaminants in subsurface soil by dermal absorption, and the highes
tSSSSSSSS n MHSA9) iS f°r 6XCavati0n W°rkerS 6XP°sed to contortnartB in subsurface so? by
arSfPr fh»n9! H ' N°DER^ was conducted at AREE 10 because all samples were collected at depths of
greater than 6 inches. Based on the results of the HHRA, no further action is recommended at AREE 1 0
AREE 16-2 - Possible Firefighter Training Pit
that site-related contamination at AREE 16-2 does not pose an unacceptable
" either current or potential future land-use conditions. Discounting naturally-
0 statistically determined to be within background concentrations the highest
!SS lifetime cancer risk (6X10'5) is for child residents exposed to contaminants
woSsCLnnLriytdermf absorPtion' and lhe ni9hest noncarcinogenic risk 9) is for
2)S^ ifXP°Sed t0 site-related contaminants in surface soil by incidental ingestion' and for
excavation workers exposed to contaminants in subsurface soil by incidental ingestion The ERA
13
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- Grease Pit
«* «~M
^
^^^^
exposure to site-related oontam^S^^s^S^nn"88^ The ERA **w*>* 5
Based on these results, " **
,
-Incinerator Septic Tank and Leach Field
) and
on
"Pl»r-boUnd excess lifetime
no
ls
**
- Transformer Storage Area
AREE 25 -Sugar Tree
r^l^^^
- Outdoor Wash Racks
-bound excess •rtrn
for child residents exposed to oontaminans
AREE 29-1 - Salvage Yard
so,L An ERA was not completed because e AREE 29
•nches, thus eliminating the potential for expos^ta
further action is recommended at AREE 29?
""*le.nu" '™«8lto" !»»»**. The
h. ^ ^Oara"°9en5 nsk (Hl-1) were calculated
soii sampie at AREE
"^ tO contamin^s «n subsurface
f "eCted at a depth 9reater than 6
receptors. Based on these results, no
14
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AREE 29-2- Possible Sludge Disposal Area
contaminants in surface soil by incidental InoUon «S fhTLh . ) - Chlld residents exposed to
child residents exposed to siL reatedh»SSS,?lthejrshest "oncaranogenic risks (Hl=0.3) are for
AREE 29-3-Possible Disposal Area
AREE 30 - Motor Pool
AREE 33 - Household Debris Pile
ingestion of subsurface soil No noo^rfn^" T SXP°Sed tO contaminants through incidental
^
Site-Wide Groundwater
South Run atAREEs 1 and 2
^^ Site-related ^lamination In the sediment and surface water of South Run at
15
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s^rsft ^^*,™ 1 and a *• wshest -*—
exceedance was driven by metals believed to be natuSfy o^ulg eXCeeded 1' ""
from South Run at AREEs 1 and 2; however the adverse eff^tAST ^l Se'en'Um in sediment
om out Run at AREEs 1 and 2; however the adverse efftT n'Um n sediment
detected ,in one sediment sample The greatest ^otentilfl^H « beoaUSe selenium was only
tributaries to South Run at AREEs 1 andTdue to S/? effe°tS tO benthic Or9an'sms is in the
pesticides (primarily chlordane [liao" and 001^1?;. S^ "T^ ^°DD {EEQ=57« and
by the limited aquatic habitat provided by ^mese smallSariis '' ^^ effects W°uld be limited
Based on these results, no further action is recommended for South Run at AREEs 1 and 2
Other Site Drainages
concentrations, the SsTestM u^l^L statlstlcal|V ^termined to be within background
"'* " ex
exp to
B.s«d on U.S. results, no falh.r Mon i, recomm.ndea tern,, om.r sit, Mn.ges.
PREFERRED ALTERNATIVE
* 'S^'S'S^fSflo'iS' ? "i"*™1 •«««*• "" «BS 3. 5. 7. 10.16-1
4»
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ATTACHMENT4
PUBLIC NOTICE
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Ttip United States Army ' •
at Vint ffill Farms Station, Virginh
Invites Public Comment / '
ON RECENTLY PROPOSED ENVIRONMENTAL ACTIONS
- FOR WT HILL FARMS STATES A™ EsS-™
OF THE ,BASE CLOSURE PROCESS ; !
, - -• PUBLIC M^E™^'*' —-" ••-•
r, ...,. ' """"My. AprilIS,' 1939'»7:'db p m '"•' i"":
• Buildmg 101 <0,d Headquarters B,dg.). Conf^nce F
. «,„. urn„ 1 station, VA 20187 .
^&£3SSS^
=z^oS.««
property are used for tlalionarv »nd mobile ant.nn, «».„,•„.-"T™P4J, «emi.improvod acre* in 1h« northern poitlori'of tifU
the Base R..Eo.m.ril «nd Ck3uJ.pwSSTA" ^ l?" '*"« ^ rac'k" ™" d«'9n»l.d to clo.ur.-in March^Sl^ni.? |j
S
PURPOSED
BACKGROUND
^
- Warehoale: '••*--*,'..• '• • AREE'ZO
" S!i?,n,™r^'rh,?if'"1Plllclnl«rP'«>tl''n -' AREE 24
center (EPIC) Building; • .. : ARPTTC
- Electrical Equlprr,^nt.p,c|ltty: • «„ j:
- Former Photographic Waatewata. Lagoon; A^EE 2T
Sludae Dixnaui a».. . . ' . _„ r!
AREES
AREET '
^p^ ' — •"•si rnvujyopniC IT
AR||" r^L'S^ls.1!.0'?1*^.
- Incinerator Se'pllcfanfcind Lejii
- Tranaformef Storai
- SugarTre«; .~'-"i
- Outdoor"- ' -'
AREE2M -
- AAFES S
e Y,fd;
Dump»3;
. . . _- Mai,;^, naiiav,^.:, - . - . • ** • ' AMCC at& A •»«irfag«B iara, . > .. ..,*_(,.$, . vj_
116-1 - Pos»lbleFlr.nghter Training Pit;.. V-1,-/"' AREB2« - P°JJj"e Sludoe Olipojal Area;
r»nnnoH. ^ _ AREE2*4-ST-'.6lfpo«aIArea;--.1'- •".':'
AREE 30 - Motor Pool; and '
. ,. AREE 33 - Household Debria Pile: '
AREE 1 a - creaaepit;
The U.S. Army «
PROPOSAL
VHFS evilual,
uln Sell, Public Affairs Officer
Vint HIM F.rim Station
Building 2600, Helmi Road •
Warrenton. VA 20187 ,'—-'••'
1 fou. remedial allernalives to addreu ,oil cwltaroinotiw „ AREE 1.'^
ALTERMA-TIVE2:"1 Excavallonof Lan
ALTERMATIVE4:.; LlnerCap.
conaiala of eonilrucSng . liner cap over the AREE 1 landfill
ira »dOT,,.t« prelection of human " • •• • •
•oducma Ih.
«W«mlo.fI.c»e,,.a,,h.widov.l,w yc<
.ffecl».ne.s and Ih. abllily to Implement.
Commonweallh oT Virginia resuialioni.
r. ...».»:„ (VHUIIDH io'r .'.IraalrrMrrl
—: ld"',»«iy»tr«atrn»n'tinfaBn«ofco«l-
w in accordance^irith appllcjble^PiJeral •
VMFS e
tal ,li.,MUv« to rtd,.tt a» lm:
ALTERNATE,: KoAct,on;
ALTER«AT2:
.
,^
'-.
. ' -i^1-• . - '-«i*r..'i-c !-) - -»s !•'!
• •JWa.fr.-l'.v.-JfS-tsg'hlM**. '
'. '•?%;. .-r-.i-v.fc -.fjisiv «•
' xT ,3 **""•' V !1"- -'W £***' ^' '
'• «•».•. —U'KH-tBj — 'l'..1.^''. Trt'"'Srt,ijtfyf> *|
Pi^Il
aM« lh.» a,,,s now no .ma
FOR MORE INFORMATION
". Fauquler County Ublary
Warrenton Branch - Rererwce Section
:;; 11Wlricha«erE|feot ••• — -
WarreSilonYvA jfJUfj •••••
Phocxt: (540) 3J7-8750
'
Uffllll M-W .1«>-'n..»pJn..Th.^.'l:9;Jn;.S,.™.;.ndsUn. i p n, .5p.m.
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ATTACHMENT 5
PUBLIC MEETING ROSTER
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vimiiiu i nimo
Recently Proposed Environmental Actions
for Vint Hill Farms Station, as a Result of
the Base Closure Process
Public Meeting 7:00 P.M.
If you wish to speak, please sign in on «he lines below Your name will be called in the order that it appears. Thank you.
Continued on Back
u
I
c
. *•
TJ
<3
t-i
CTi
OD
t-i
I
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Vint Hijl Farms Station
Recently Proposed Environmental Actions
for Vint Hill Farms Station, as a Result of
the Base Closure Process
Sign-In Sheet
Thursday, AprIM 5,1999
Public Meeting 7:00 P.M.
If you wish to speak, please sign in on Ihe Ikies below. Your name will be called in Ihe order that II appears. Thank you.
u,st*r,,Jrt!'VMx&i
Continued on Back
.-u
'5
E
U)
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ATTACHMENT 6
WRITTEN COMMENTS FROM REGULATORS AND U.S. ARMY RESPONSES
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and VDEQ to the pub Please n
be incorporated into tne
-
ses to comments from
•*""" * 6y '** tt&
u-,= Comments on the-Proposed Plans for
Vint Hill Farms Station from USEPA Region III
^ „ ,.. ^Tj^raaTuaiMiagBBiaiffliiHBa^pO^Mmmatff^l^l^
Response: The U.S. Army agrees with this suggested wording change.
Comment:
Response:
Comment:
Response:
Comment:
Response:
If the report is still being reviewed, how can we rely on a report conclusion about risk?
T~k on —•«••• <-«•«! i «k>wui, iiai^r
(1982) By whom? Any regulator invoh/ement? (1992) By regulator or Army decision to
Comment: As part of Rl?
Response: Samples* AREE 13 were collected during the SI and the Rl.
Nothing in the hit zone?
The
Comment: Why "possible" in heading but not text?
-------
Response:
Possible locations of the Firefighter Training Pit represent two
Comment: Discharges or discharged?
Response: Discharges.
Comment:
Response:
Mentions arsenic and lead but what about chromium (see page 9)?
Comment: Should stored be disposed?
Response: Yes.
Comment:
Response:
Comment:
Response:
Comment:
Response:
Isn't iron naturally occurring? If so, why wasn't it discounted?
Current and future land-use conditions... What are these?
See response to Comment 10.
•Soil in those... was excavated.' Removed and disposed off site?
Yes, the excavated soil was removed and disposed off site.
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—^^^^^^"•"•**SM««rt^^^^^^^^^HB^^i^»B^^^S^^3^^^^^^E
Comment: Current and future land-use conditions... What are these?
Response: .See response to Comment 10.
Comment: "contaminants'... Are you referring to arsenic, TCDD?
Response: Yes.
Comment: Current or future land-use conditions... What are these?
Chromium not mentioned on page 6. What about arsenic?
Response: See response to Comment 10.
See response to Comment 8 regarding chromium.. Arsenic was not a risk driver at AREE
Comment: "Therefore, the HI of 1.3 ..." instead of "therefore a HI of 1.3 ..."
Response: The U.S. Army agrees with this suggested wording change.
Comment:
Response: The U.S. Army agrees with this suggested wording change.
Comment:
Response:
Comment:
Response:
Comment:
Response:
Current or future land-use conditions ... What are these?
See response to Comment 10.
Are you referring to aluminum. benzoOJpyrene, beryllium, arsenic, and iron?
tef JYeferrin9 to™y contaminant identified as a chemical of potential concern that
££2FT!!1? be nat"ral|y-°ccu^9- Benzo(a)Pyrene and aluminum areThe on?
two contaminants that meet these criteria.
17. 18. 20. 24. 25 3B
is this a No Further Action or No Action Proposal?
No Action.
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Consent: DeleteCrimination at' so the sentence reads "aKernativelo"
Response: The U.S. Army agrees with this suggested wording change.
Comment:
Response:
address selected Areas
IT*, report is s. Mng revfemKt
See response to Comment 2.
„„ a report conclusion * ,
Comment:
Response:
, "--^^»*v.^irflwre8BHaraigi»^
~~^
«Pon».
Comment:
Response- ^usT™"* ^ ^*" ~'**«°f"?he Wareh°USe™* ha-
Response. The U.S. Army agrees with this suggested wording change.
Comment:
»gs. Sul>surface soi,
"*
conoentraaons
involve mixing of subsurface i
Comment:
Response:
AREE 7 will need to be closed under RCRA by VDEQ before FOST/transfer
Comment:
Response:
How was the overflow from the lagoon discharged? Via earthen trench? Pipe?
l and WSRT were connected naturaHy. .The ,agoon overflowed direc%
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Comment:
Response:
^^""'•Mae'IHI^HHgBB***ial*l>l^ff^Hm
What about sampling of the surface soil around the lagoon?
Comment:
Response:
Why is it the "Possible" Firefighter Training Pit?
See response to Comment 6.
Comment:
Response:
soTL!Tonly disousses surface soi!s'Was the sampling differentf°r the «««>
Comment:
Response
The AREE 16-1 text doesn't give this range
Response:
Comment:
Response:
How deep is the dump? Is it unlined?
Comment: Are there any elevated lead levels?
Response: No.
Comment: Is groundwater contamination a concern?
-------
Response: No.
Comment: Were hazardous materials stored in the 'Salvage Yard"?
Response: To the U.S. Army's best knowledge, no.
Comment: What about the sludge piles themselves?
Response:
Comment: Were.hazardous materials stored at the "Possible Disposal Area"?
Response: To the U.S. Army's best knowledge, no.
Comment: -a petroleum odor was detected" instead of "a petroleum odor was observed-
Response: The U.S. Army agrees with this suggested wording change.
Comment: «No contamination above screening levels..." What were the screening tevels?
Response: nf-~>. — - »
Comment:
Response:
industrial soil RBCs were used as the screening levels. Why not residential (subsurface)
Comment: "...composition of the aquifer..." Is there only one aquifer?
R~
Comment:
dettctea
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Response:
St?n9fnt °^the Effeots Ra"9e - Lows and the No Effects Levels or Lowest
"which are protectlve of benthic or9anisms-
Comment
Response:
c^ufd S ~n« "HRA'evaluated Potential risks to hypothetical future adult residents who
251 « -H T hcontaf"'nants to groundwater and surface soil and to hypothetical S
chHd res.dents who could be exposed to contaminants in groundwater surface soif
surface water, and sediment," What about subsurface soil? unawater. surface soil,
mncuv S0i'' me HHRA evaluated risk* to excavation workers, the human receptor
most likely to be exposed to subsurface soil. Also, see response to Comment 25 P
Comment:
Response: See response to Comment 10.
Comment:
Response:
conditions
-What are these? Maybe say "current
or u'nrestS
Comment:
Response:
Comment:
Response:
Comment:
Response:
Hi
Comment:
Response:
Is there any reason to collect surface soil samples?
teast Tft fag?08 S0i' SamP'eS W6re C0"e0ted beC3USe the industrial sewerli"e '« burled at
Risks to excavation workers are presented. What about residential exposure risks?
See response to Comment 25.
Current and future land-use conditions ... What are these?
See response to Comment 10.
Why were surface soil samples not collected?"
See response to Comment 28.
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Comment:
Response:
See response to Comment 25.
Comment:
Response:
'No ERA was conducted at AREE 10 because all
greater than 6 inches." Depths from 0 Ss to
Internal inconsistency created.
for HHRAs and ERAs differ with
fOnc saraa AxsttAn^w r-i-» A _ .
°°l!ected at deP*s <*
are defined as "surface soil".
collected from the 0-e Hnch
coated from the 0-2
Surface soil Pes.
Comment:
Response:
Comment:
Response;
Why is it the "Possible" Firefighter Training Pit?
See response to Comment 6.
Current or potential future land-use conditions ... What are these?
See response to Comment 10.
Comment:
Response:
What about residential risks to subsurface soil?
See response to Comment 25.
Comment:
Response:
SOI
Comment:
Response:
Current and future land-use conditions ... What are these?
See response to Comment 10.
What about residential'risks to subsurface soil?
See response to Comment 25.
Comment:
Response:
Current and potential future land-use conditions ... What are these?
See response to Comment 10.
Comment:
Response:
Did the HHRA consider residential exposure to subsurface soil?
See response to Comment 25.
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Comment:
Response:
Current and future land uses ..-. What are these?
See response to Comment 10.
Comment:
Response:
Current and future land-use conditions... What are these?
"... risk to workers, trespassers, and ..." should be «... risks to workers, trespassers, and
See response to Comment 10.
The U.S. Army agrees with this suggested wording change.
Comment:
Response
ifinSE^StSK t0 C°nteminants in •«*» soi, ..." What are these
Comment:
Response:
Are toxicologists satisfied that this area is okay for residential use?
Comment: Current and future land uses ... What are these?
Response: See response to Comment 10.
Comment: Current and potential future land-use conditions ... What are these?
Response: See response to Comment 10.
Comment:
Response:
^^^^^^^^mm^i^^^mt^mif^^H^^^^^SSi^^Si^iii^^SSZ
"...for child residents exposed to contaminants in surface soil
contaminants? -
What are these.
was" 'not
mleHhese -ena
"**"*** identified as a *emteal of potential concern that
naturally-occurnng. Aluminum is the only contaminant that
Comment: What about the materials which were piled there?
Response: See response to Comment 37.
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Comment:
Response:
Comment:
Response:
Current and future land-use conditions ... What are these?
See response to Comment 10.
HemWeiTep
Comment:
.that
contaminants meet these criteria. The risks nLanSi w h-M 3.,SUrfece soil- no
ys^^^
which were on,y discounted if ^weSrd^S^
SiCn^.Seia^^ *n ^^r ™* Of *. detected
background concentrations) res.dent.al soil RBCs and maximum
^""••••'••^{^••^^ipffl^
See resonse to C
Response: See response to Comment 52.
Comment:
Response:
n" —~>wateaaBaB°ffTOTaffflff^^^™^^)]am^
«... human health risks were only equated for future excavation workers.' Whyi
see response to Comment 25.
Comment-
Response:
Why were only subsurface soil samples collected at AREE 33?
10
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Comment:
Response:
Comment:
Response:
Comment:
Response:
Why is there no information regarding residential reuse risks?
See response to Comment 25.
Comment-
Response
Comment:
Response:
"naturally- occurring" should be "naturally-occurring"
The U.S. Army agrees with this suggested wording change.
Response:
contaminant
f"3 With natura«^ccumng metals that were
mgSti°n' and the highest noncarcinoaenic risk (Hl=0.5) "s for
oundwater by ingestion. The slteS
haZards are
Current or future land-use conditions ...: What are these?
See response to Comment 10.
' Tan!!
in°idental in96sBon exP°sures to sedi^^t in South Run
reSldents 6xceeded 1. the exceedance was driven by metals
U' l
Run APP! Pfen^ 5f adverse effects to benthio nanisms in the tributaries to South
Run at AREEs 1 and 2 .dentified in the ERA. shouldn't an action alternative be evaluated?
The ERA estimated the potential for adverse effects to benthic organisms based on the
benthtePo°raaS 3 V'abK "f^ f°r benthi° °rganisms existed- However. »•» habSt for
SfL ?h H '" « tnbutaries to Sou«n R™ at AREEs 1 and 2 is limited and
therefore, the adverse effects are over-estimated by the ERA and are actually limited No
action is warranted based on the existing conditions
Comment:
Response:
Current or potential future land-use conditions... What are these?
See response to Comment 10.
11
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AREEJM
Comment:
Response:
Delete "contaminated materials at".
The U.S. Army agrees with this suggested wording change.
Comment:
Response:
Comment:
Response:
Comment:
Response:
"major characteristic' should be replaced with 'major component'.
The U.S. Army agrees with this suggested wording change.
Shouldread.... thestruCture(andtheArmyshutdowntheincineratorPermanently -
The U.S. Army agrees with this suggested wording change.
Replace"... (i.e., boxes..." with "... (e.g., boxes ..."
The U.S. Army agrees with this suggested wording change.
Comment:
Response:
Delete "further" in "no further action".
The U.S. Army agrees with this suggested wording change.
Comment:
Response:
So1
How big is the incinerator?
Approximately 45 ft long.
Comment:
Response:
Under which regulatory program?
Comment: Under which regulatory program?
12
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Response:
Comment:
Response:
Replace "e.g." with "i.e."
The U.S. Army agrees with this suggested wording change.
0fiPA>S,f°mment' a No Action Dec'sion Document will be written for AREE
and dispose °f the ash
This doesn't appear to be warranted under CERCLA As a CER
would seem to be appropnate. The ash and oi, remova^ems
Response: See response to Comment 92.
Rnn n^
se°piate°
AREE1
Comment:
Response:
Comment:
Response:
Delete "contaminated so!T
TheU-S. Army agrees with this suggested wording change.
Replace "characteristics" with "components".
TheUS. Army agrees with this suggested wording change.
Comment:
Response:
Delete"... and is currently undergoing regulatory review."
The U.S. Army agrees with this suggested wording change.
Comment: Under all scenarios?
Response: Yes. under ail scenarios evaluated.
Comment: Spell out Rl.
Response: This is not necessary since Rl was spelled out on page 2.
13
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——
Comment:
Response:
•2,3,7,8-TCDF"... spell outTCDF.
Tetrachlorodibenzoftiran.
Comment: Insert "of after construction .
me
—pi^
Comment:
Response:
-
™strfcllonSwill
in me D«c!s«m Document for AREE 1
_ Response:
°f lhe
selectea, and will be incliMea
transferred, tend use
l5
" " *»
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Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Wi" R0t ^required Pn"or to raP construction. Access restrictions fe <,
—tructionto
~~
Response: See response to Comment 104.
^^
Replace "because it removes" with "because it would remove".
The as. Army agrees with this suggested wording change.
Replace "will be implemented' with "would be implemented".
The U.S. Army agrees with this suggested .wording change.
DOT and OSHA regulations are not ARARs.
The U.S. Army acknowledges this comment.
evaluated/determined? What about landfill design standards in the waste
non-hazardous waste and, therefore, would
Comment: Change "form" to "from".
Response: The U.S. Army agrees with this suggested wording change
Comment:
Response:
w* I10 deta"S re9ardin9 the institutiona'
. What are the reuse plans in and around this area?
around this area
have been
15
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Comment: No basis to evaluate implementability of institutional controls.
Response: See response to Comment 104.
Comment:
Response:
What about the cost of institutional control implementation and future monitoring?
See response to Comment 103.
Comment-
Response:
What about institutional controls?
The preferred alternative will include land use restrictions (a.k.a, institutional controls).
Response to Comments on the Proposed Plans for
Vint Hill Farms Station from VDEQ
selected for this AREE.
Response: See response to Comment 26.
. ,
before a no further action alternative can be
16
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0
45 0 0
— V.*H
M- &'""
0 /i* z.
3 — "
4- -
0)00^
>
0£,So
'
CD'S iS
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