PB99-963918
                              EPA541-R99-061
                              1999
EPA Superfund
      Record of Decision:
      Naval Surface Warfare Dahlgren
      Sites 19 and 29 OUs 13 and 14
      Dahlgren, VA
      9/27/1999

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SITE 19 - TRANSFORMER DRAINING AREA (SOILS)
                 AND
      SITE 29 - BATTERY SERVICE AREA
        (SOILS AND GROUNDWATER)

     NAVAL SURFACE WARFARE CENTER
             DAHLGREN SITE
           DAHLGREN, VIRGINIA
           RECORD OF DECISION
             SEPTEMBER 1999

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                             TABLE OF CONTENTS

SECTION                                                                   PAGE

1.0    THE DECLARATION	1-1
      1.1    SITE NAME AND LOCATION	1-1
      1.2    STATEMENT OF BASIS AND PURPOSE	1-1
      1.3    DESCRIPTION OF THE SELECTED REMEDY....	1-1
      1.4    DECLARATION STATEMENT REGARDING STATUTORY DETERMINATIONS	1-1

2.0    DECISION SUMMARY	2-1
      2.1    SITE 19 - NAME, LOCATION, AND DESCRIPTION	2-1
      2.2    SITE 19 - HISTORY AND ENFORCEMENT ACTIVITIES	2-1
      2.2.1  History of Site Activities	2-1
      2.2.2  Previous Investigations and Response Actions	2-5
      2.2.3  Enforcement Actions	2-5
      2.2.4  Highlights of Community Participation	2-6
      2.3    SCOPE AND ROLE OF RESPONSE ACTION FOR SITE 19	2-6
      2.4    SUMMARY OF SITE 19 CHARACTERISTICS	2-6
      2.4.1  1995 Remedial Investigation	2-6
      2.4.2  1999 Remedial Investigation/Feasibility Study	2-7
      2.5    CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES	2-8
      2.6    SUMMARY OF SITE 19 RISKS	2-8
      2.6.1  Environmental Evaluation	-	2-12
      2.6.2  Human Health Risks	2-12
      2.7    DOCUMENTATION OF SIGNIFICANT CHANGES	2-17
      2.8    SITE 29-NAME, LOCATION. AND DESCRIPTION	2-18
      2.9    SITE 29 - HISTORY AND ENFORCEMENT ACTIVITIES	2-18
      2.9.1  Historyof Site Activities, Previous Investigationsand Previous Response Actions	2-18
      2.9.2  EnforcementActtons	2-20
      2.9.3  Highlights of Community Participation	2-20
      2 10  SCOPEAND ROLE OF RESPONSE ACTION FOR SITE 29	2-20
      2.11  SUMMARY OF SITE 29 CHARACTERISTICS	2-21
      2.11.1 1995 Remedial Investigation	2-21
      2.11.2 Removal Action	2-21
      2.11.3 1999 Remedial Investigation/Feasibility Study	2-23
      2.12  CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES	2-27
      2.13  SUMMARY OF SITE 29 RISKS	2-27
      2.13.1 Environmental Evaluation	2-27
      2.13.2 Human Health Risks	2-28
      2.14  DOCUMENTATION OF SIGNIFICANTCHANGES	2-35

3.0   RESPONSIVENESS SUMMARY	3'1
      3.1     BACKGROUNDON COMMUNITY INVOLVEMENT	3-1
APPENDICES

       A     VIRGINIA CONCURRENCE LETTER
       B     PUBLIC COMMENTS
       C     TOXICITY PROFILES

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                                     LIST OF TABLES

  NUMBER
  2'1           Maximum Detected Concentrations for COPCs (Post Removal), Site 19	2-11
  2-2           Chemicals of Potential Concern and Exposure Point Concentrations, Site 19	2-13
  2'3           Dose-Response Parameters, Site 19	             2-14
  2-4           Maximum Detected Concentrationsfor PCOCs, Site 29	         2-25
  2-5           Chemicals of Potential Concern and Exposure Point Concentrations, Site 29	2-29
 2-6           Dose-Response Parameters, Site 29	;      .                     2-30

                                    LIST OF FIGURES
 NUMBER                                                                          ^
 2-1            NSWCDL Location Map, Site 19 ....:	                2-2
 2-2            Site Location Map, Site 19 and 29	                           2-3
 2-3            Site Map, Site 19	             2-4
 2-4            Rl Sampling Locations, Site 19	                  2-9
 2'5            Post Removal Verification Sampling Locations, Site 19	  2-10
 2-6           Site Map. Site 29	   2-19
 2-7           Potentiometric Surface Map, Site 29	                      2-22
2-8           Post Removal Verification Sampling Locations, Site 29	   2-24

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                                1.0  THE DECLARATION
1.1           SITE NAME AND LOCATION

Site 19, Transformer Draining Area and Site 29, Battery Service Area
Naval Surface Warfare Center Dahlgren Site
Dahlgren, Virginia

1.2           STATEMENT OF BASIS AND PURPOSE

This decision document focuses on remedial decisions and presents the selected remedial actions for Site
19 - Transformer Draining Area and Site 29 - Battery Service Area at the Naval Surface Warfare Center
Dahlgren Site (NSWCDL) Dahlgren, Virginia. This determination has been made in accordance with the
Comprehensive Environmental Response,  Compensation, and  Liability Act of 1980 (CERCLA),  as
amended by  Superfund  Amendments and Reauthorization Act of 1986 (SARA),  and  to  the  extent
practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision
is based on the administrative record for both sites.

The Commonwealth of Virginia concurs with the selected remedy (see Appendix A).

1.3           DESCRIPTION OF THE SELECTED REMEDY

The selected remedies for each site are as follows:

Site 19 Soil

No Further Action.  PCB-contaminated soils were removed in 1994.  Risk analysis conducted after the
removal revealed that residual risks to human health and the environment were within acceptable limits.

Groundwater at Site 19 will be addressed concurrently with adjacent Site 40 at a future date.

Site 29 Soil and Groundwater

No Further Action.  Contaminated soils were removed in 1994.  Risk analysis conducted after the removal
revealed that residual risks to human health and the environment were within acceptable limits.

1.4           DECLARATION STATEMENT REGARDING STATUTORY DETERMINATIONS

It has been determined that the Selected Remedy (no further action) for soil at Site 19 and soil and
groundwater at Site 29 is protective of human health and the  environment, complies with Federal and
State requirements that are applicable  or relevant and appropriate to the remedial action, is cost effective,
and uses permanent solutions and alternative treatment technologies to the maximum extent  practicable
because previous removal actions have eliminated the need to conduct further remedial action.

The statutory  preference for treatment as a principal element of a remedy is not applicable at  these sites
because the residual risks are within  an acceptable range and no further action is needed.  A 5-year
review will not be required  because constituents remaining onsite are at levels that do not require use
restrictions.
                                            1-1

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CAPT. Vaughn E. Mahaffey/0
Commanding Officer        '
Naval Surface Warfare Center
Dahlgren. Virginia
Abraham Ferdas, Director
Hazardous Site Cleanup Division
USEPA- Region III
Date
                                          1-2

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                                2.0 DECISION SUMMARY
This Record of Decision (ROD) is issued to describe the Department of the Navy's (NAVY) selected remedial
action for both Site 19 - Transformer Draining Area and Site 29 - Battery Service Area, at the NSWCDL, in
Dahlgren, Virginia (Figure 2-1).  Both sites are Installation Restoration (IR) sites (Figure 2-2) located at the
NSWCDL facility.

2.1            SITE 19 - NAME, LOCATION, AND DESCRIPTION

The Transformer Draining  Area is located  in  the south-central portion of the  NSWCDL  property,
approximately 150 feet east of Caskey Road (Figure 2-3). Access to the site is provided via Caskey Road
and a paved drive to the south of Building 120B, the Property Disposal Office, which forms the northern
boundary of Site 19.  The Building 120B Defense Reutilization and Marketing Office (DRMO) lot (Site 40),
located in the northeastern portion of the site, is surrounded by an approximately 7-foot-high chain-link fence,
and access is restricted. On the south are grassy areas.

The site is located on a relatively flat parcel of land, with elevations generally between 15 and 20 feet above
mean sea level (msl) and nearly level slopes (less  than 3 percent).  The ground surface at Site 19  is
characterized by a variety of surfaces, including pavement, gravel cover, and  grass (Figure 2-3).  Two
concrete pads are located approximately 10 feet directly southeast of Building 120B. In the past, a common
practice at NSWCDL was to drain transformer oil onto the ground behind Building 120B. The concrete pads
are the reported location where the transformers were drained.

Surface drainage at the site  is overland either southeast or southwest to drainage ditches. These ditches
ultimately flow into storm sewers beneath the developed area to the southeast of Site 19.

2.2            SITE 19 - HISTORY AND ENFORCEMENT ACTIVITIES

2.2.1           History of Site Activities

The history of Site 19 has been developed from information provided in the Initial Assessment Study (IAS),
the Confirmation Study, and an analysis of Environmental Photographic Interpretation Center (EPIC) aerial
photographs.  A summary of the site history is discussed in the following paragraphs.

Documentation  of activity at Site 19 began as early as 1943 with the open storage of materials to the
north, south, and east around what is presently identified as Building 120B.  Drainage of transformer oil
onto the ground behind Building  120B was a standard practice during the  1950s. The transformers were
then turned in to the Property Disposal Office. The IAS conducted in 1981 estimated that approximately
1,000 gallons of oil were involved; however,  no data were available regarding polychlorinated  biphenyl
(PCB) levels in the oil. Therefore, a Confirmation Study was recommended.

Ground-disturbing activities in the vicinity of Site 19 were first noted in the 1946 aerial photos and remain
evident in more recent aerial photographs.   In  the  1946 imagery,  evidence of a trench was observed
approximately 75 feet southeast of Building 120B, the east end of which was located near a south-flowing
drainage channel.  A pit was noted approximately 30 feet north of the trench. Evidence of a second pit,
containing an unknown liquid, was noted approximately 5 feet south of Building 120B and 15 feet west of
the concrete pads.  The trench and pits were no longer visible in either 1952 and 1958.
                                          2-1

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Source:
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May 99
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99

(WV.
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2-2

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                                                                              Swamp/March
                                                                              Opan Watar
                                                                              NSWCDL Boundary
                                                                              Roads
                                                                              Highways
                                                                           Shaft ID
                                 CONTRACT NCX
                                 7188-1801
OWNER. N«L
CT0261
                            Tetra Tech NUS, Inc
                           SITE LOCATION MAP
                             SHMl9and29
 COST/SCHEDJUttA
     NSWCDL
DAHLQREN, VIRGINIA
   SCALE
AS SHOWN
                                        2-3

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                                                       DEFENSE REUTIUirATKW AMD IMRKCTMC OFUCE
                                                       (MMO) LOT (SITE 40)
    LEGEND

x x *  M Fence
DRAWNBV BUTE
TF May 99
CHECXIOIV OWE
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COCT/tCHEDABEA
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1 As Shown
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                                 | Tetra Tech NUS, Ine
                                       Site Map
                                        Site 19

                                      NSWCDL
                                  Dahlgren, Virginia
                                                                                      Map «o:G:\£UWgrmi\3Jl«19\fig2.car
                                            2-4

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  i^enCe,?n!T trenChf!i °ne '°Cated 75 feet east of Buildin9 120B and the °ther about 10 feet south of
  Budding 120B,  was noted ,n the 1960s images. An unknown liquid was evident in the eastern Trench
  Neither trench was visible in the 1969 photographs.                                  Astern irencn.
                           theneastem Stora9* a^a and on the south side of Building 1208 in the late
  A   n                   S' DmmS were observed °n Building 1208's east side in 1985 photographs
  of Sna l?nS   f 3 rectan9ular mounded area- was constructed in 1990 approximately 40 feet south
                     ^^                             from the fenced -a to a~
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2.2.4          Highlights of Community Participation

In accordance with Section 113 and 117 of CERCLA, the Navy provided a public comment period from
July 21, 1999 through August 19. 1999 for the proposed remedial action, which is described in the
Remedial Investigation/Feasibility Study and the Proposed Remedial Action Plan for Sites 19 and 29.

These documents were available to the public in the Administrative Record and information repositories
maintained at the Smoot Memorial Library, King George,  Virginia;  the NSWCDL General  Library,
Dahlgren, Virginia; and the NSWCOL Public Record Room, Dahlgren, Virginia. Public notice was provided
in The Freelance Star newspaper on July 19, 1999 and The Journal newspaper on July 14, 1999, and a
public meeting was held in the King George Courthouse on July 28,1999. No written comments were
received during the comment  period.  Spoken comments and responses provided during  the public
meeting are presented in Appendix B.  Additional community involvement, including Restoration Advisory
Board (RAB) activities, are highlighted in Section 3.1.

2.3            SCOPE AND ROLE OF RESPONSE ACTION FOR SITE 19

Site 19 is one of many sites identified in the Federal Facility Agreement (FFA) for  NSWCDL.  In previous
years, RODs have been issued for several other sites in accordance with the priorities established in the Site
Management Plan (SMP).  A removal was performed at Site 19 in 1994 to address PCB contaminated soils.
This action follows the removal and provides closure for the site soils.

The selected remedy (no further action for soils) fits the Navy strategy to reduce risks at all NSWCDL sites
with minimal long-term care.  Site 19 soils are clean and require no future monitoring, allowing the Navy to
focus its resources on the  remaining NSWCDL sites.  The remedial action identified in this ROD addresses
contamination associated with Site 19 as identified in the Draft Final Rl Reports, Engineering Evaluation/Cost
Analysis Reports, Removal Action Reports, and the Addendum RI/FS Reports. The  PCB-contaminated soil
was removed from the site and the subsequent risk analyses indicated  the remaining risks are within
acceptable limits.

Future plans include addressing groundwater as part of adjacent Site 40.

2.4            SUMMARY OF SITE 19 CHARACTERISTICS

An RI/FS was completed in phases for Site 19.  Sampling activities, consisting of soil sampling and the
installation and sampling  of groundwater  monitoring  wells, were completed in  1994.  Additional soil
sampling was performed before and after the removal action was completed in 1994. A draft final Rf was
prepared in 1995.  An addendum RI/FS was prepared in 1999.

2.4.1          1995 Remedial Investigation

The Rl at Site 19 included a hydrogeologic investigation, contamination assessment, and risk assessment
The hydrogeologic investigation included the installation and sampling of two groundwater-monitoring wells
and the sampling of four existing groundwater-monitoring wells.  Physical descriptions of the subsurface, a
monitoring well elevation and  location survey, groundwater-level measurements, and two hydraulic
conductivity tests were also included in the hydrogeologic  investigation.  Site 19 is underlain by the Tabb
Formation, which is composed of sand, silt,  and clay. Groundwater elevations  based on  March 1994
measurements were approximately 13 feet above msl. The shallow aquifer exists within a relatively thin sand
layer at Site 19 (approximately 10 feet thick), and predominant groundwater flow at the site is to the east
The estimated hydraulic conductivities at Site 19 were 7.29 x 10"3 cm/sec and 1.5 x 10"3 cm/sec.

The contamination assessment included the collection and  analysis of samples from soil and groundwater.
Five surface  soil  samples, six subsurface soil samples, two samples  from  the concrete pads, and


                                         2-6

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groundwater samples from six wells (two new and four existing wells) were collected during the field
investigation at Site 19.

Based on the results of the Rl, previous investigations, and historical information, RGBs were identified as
contaminants of primary concern at Site 19 because of potential human health risks.  Risks to ecological
receptors were likely  to be minimal because of the  limited distribution of contaminants, and Site 19
provides minimal habitat for ecological receptors because of the heavy development and level of human
activity in the area.  Soil sampling conducted during the Rl confirmed the presence of PCB contamination
east of Building 120B, as previously identified in the Confirmation Study. Surface soil, subsurface soil, and
groundwater  samples  collected beyond the  previously identified  area did  not  indicate  contaminant
migration had occurred.

2.4.2           1999 Remedial Investigation/Feasibility Study

Follow-up remedial investigation activities consisting of a human health risk analysis were performed to
determine whether further action was required.  These results are summarized below.

2.4.2.1         Sources of Contamination

Extensive soil sampling was conducted to identify the extent of PCB contamination in the area where
transformer oil was drained onto the ground during the 1950s. The amount of oil involved was estimated
to be approximately 1,000 gallons.   Based on  multimedia sampling, it was determined that the PCB
contamination was confined to the soil over an area covering approximately 25 ft. by 70 ft. to a depth of
2 ft.  The PCB-contaminated soils were  removed and disposed offsite in  1994 as part of the removal
action.

2.4.2.2         Description of Contamination

Soil sampling conducted during the Confirmation Study at Site 19 identified an area of shallow PCB
contaminated soil.  No  PCBs were detected in groundwater samples. The  objective of the Rl at Site 19
was to determine the extent of contamination in both surficial and deeper soils and to verify that activity at
the site has  not  impacted groundwater quality.   Phase 1  field investigation  activities  involved
inspection/evaluation and rehabilitation of the four existing  IR monitoring wells at the site.  Phase 2 field
activities included the installation of two new monitoring  wells and the analysis of groundwater samples
from new and existing  wells, soil sampling, and sampling of concrete chips from  the existing concrete
pads.

The primary objective of the soil investigation at Site 19 was to identify the presence or absence of PCBs
and other contaminants in  the vicinity of the transformer draining area. The objective of the groundwater
investigation was to determine whether PCBs  had migrated from shallow soils into the surficial aquifer.
Surface water and  sediment samples were not collected during the Rl  investigation  because of  the
distribution of contamination in the soils, the immobile nature of PCBs, and the flat topography surrounding
Site 19.  Transport of contaminated soil via surface runoff was not expected to be significant.

PCBs were the contaminants of primary concern at Site 19 based on previous investigations and historical
information.  In addition to PCBs, samples were also analyzed for volatile and semivolatile compounds,
metals, cyanide, and total petroleum hydrocarbons (TPHs). Additional analyses were necessary because
it is not known what other materials were stored in the area. A Toxicity Characteristic Leaching Procedure
(TCLP) was completed on two soil samples to aid in evaluation of disposal options for soil at Site 19.

Rl soil  samples that were  collected  outside the PCB-contaminated area where the removal action
occurred at Site 19 are shown in Figure  2-4.  Post-removal verification sampling locations are shown in
Figure 2-5.  Table 2-1 lists the chemicals of potential concern (COPC) for each medium and the maximum
concentration detected. The results of the sampling and analyses are presented below.


                                          2-7

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  «nd vTnS    H t TH   ""f^ 'ndudin9 aluminum' ars*™> cadmium, chromium, iron, manganese
  and vanadium, detected m so.ls are identified in Table 2-1.  The arsenic and iron concentrations reflect
  backgroundI conditions based on statistical analyses.  Low-level Aroclor-1260 concentrations ("ess than
  the 1.0 mg/kg cleanup level) were detected in soil (2 ft. below ground surface [bgs]) after the removal
  action was completed.  The Aroclor-1260 contamination appears to be related to the past tranSml
  draining practices, whereas the metals contamination does not
  2.4.3.3
  Contaminant Migration
  The pnmary contaminant of concern at Site 19 was Aroclor-1260 in soils.  Aroclor-1260 does not appear
  to have migrated from the removal area via overland flow because none were detected in surface soil
       °* fQL^°"tside  the removal area.   There  also is no  evidence  of  subsurface migration of
              through leaching, because no  Aroclor-1260 was detected in  groundwater and  none
  nor™ HI    H ™9 %  '" ®ubsurface soil 2'ft b9s-  Subsurface soils at Site  19 are only  moderately
  permeable and include a clay layer, helping prevent the vertical migration of Aroclor-1260  Aroclor-1260 is
  unlikely to migrate via overland flow because the removal area was backfilled to  existing grade with clean
  soil. Aroclor-1260 is only slightly soluble in water, and the site topography is relatively flat.

 Aroclor-1260 is  not easily biodegradable and persists in  the environment.  The persistence of PCBs is '
 dependent on the number of chlorine atoms that comprise the compound. PCBs with one or two chlorine
 atoms degrade  more readily than  PCBs with three  to six chlorine atoms. Aroclor-1260 contains  more
 chlorine by weight (60 percent) than any other commercially manufactured PCB  product and therefore
 would be expected to persist in the environment for a long  time.

 2.5           CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE  USES

 Site 19 is located in the south-central portion of the Mainside, about 150 feet east of Caskey Road  The site
 is nearly'level A portion of the site is vegetated with grass and the remainder is covered with pavement or
 gravel The site is bordered on the north by Building 120B. which is regularly occupied.  A portion of this site
 D erl? °l  u £    fence Surroundin9 «ie DRMO Lot (Site 40). Access to the majority of Site 19 from Caskey
 Road (which borders the site on the west side) is unrestricted. The site is bordered to the south and east bv
 grassy fields. The base airstrip lies across Caskey Road immediately west of the site.

 A portion of Site 19 lies within the fenced DRMO Lot and is entered by DRMO personnel on a sporadic basis
 usually on a forklift to place or remove an item from storage.  Other portions of the site  have unrestricted
 access and have occasional foot traffic and grounds maintenance activities performed  Caskey Road is used
 by base personnel for jogging and bike riding.

 Site 19 is currently an industrial use area and is anticipated to remain an industrial use area in the future
 The mission of the base is currently expanding and future potential for base closure and conversion to
 residential land use is considered to be minimal.  Groundwater in the shallow aquifer beneath Site 19 is
 not a current source of drinking water.  Groundwater contaminants will be evaluated  in the future in
 conjunction with an adjacent site (Site 40).
2.6
SUMMARY OF SITE 19 RISKS
The ecological and human health risks associated with exposure to contaminated media at Site 19 were
evaluated in the Addendum RI/FS Report.
                                         2-8

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                                                 DEFENSE REUnUIZATON AND MARKETING OFFICE
                                                 (MHO) LOT  (SITE 40)
                                                       REMOVAL AREA

                                                       CRASS AREA

                                                   SS/SB19-1
    Legend
x x  X  Fence
 Soil Sample Location
                                     CONTRACT NO.
                                     7188-1801
                               Tetra Tech NUS, Inc
                             Rl Sampling Locations
                                    Site 19
 COST/SCHEDAHEA
    NSWCDL
Dahlgron, Virginia
    SCALE
  As Shown
                                                                                 Map «lo:G:\d«filgre
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Legend
 •  Floor Sample
 A  Wall Sample
                                               ES-25
                                                                     Source:  OHM, 1995
TF
         May 99
                              Tetra Tech NUS, Inc.
                                                            CONTRACT NO.
                                                                                 OWNER NO
CHECKED BY
 DM
            Mav99
                 Post Removal Verification Sampling Locations
    COfiT/CCHED-AREA
                                                                                    DATE
                                                         A^MIOVED BY
      SCAIE
    As Shown
                               NSWCDL
                           Dahlgren, Virginia
                                                         DRAWING NO.
                                                                      Figure 2-5
              rk_iM*lM-cu217-fl5.jnil
                                       2-10

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                       TABLE 2-1
MAXIMUM DETECTED CONCENTRATIONS FOR COPCs (POST REMOVAL)
            SITE 19: TRANSFORMER DRAINING AREA
               NSWCDL, DAHLGREN, VIRGINIA
SURFACE SOILS
Metals (mg/kg)
Aluminum
Arsenic
Chromium
Iron
Manganese
Vanadium
20,900
5.4
42.2
24,000
2,220
60.5
SUBSURFACE SOILS
Metals (mg/kg)
Aluminum
Cadmium
Chromium
Iron
Vanadium
Target Compound List (TCL) Pesticides/PCBs (mj
Aroclor-1260
102,000
4.1
105
37.000
125
3/kg)
0.81
                       2-11

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  2.6.1          Environmental Evaluation

  The PCB Aroclor-1260,  aluminum, arsenic, and manganese  are  present  in Site 19 surface soils in
  concentrations greater than their respective soil background and ecological risk screening concentrations
  Arsenic concentrations are not significantly different from background based on statistical analysis.  The
  three metals were detected in all five samples collected from this site,  whereas Aroclor-1260  was only
  present in one sample.   Aluminum concentrations exceeded the conservative ecological risk screening
  concentration used for this contaminant in all surface soil samples  collected at this site. Arsenic and
  manganese exceeded their ecological risk screening concentration in one and two samples, respectively.
  These data suggest that although the presence of these contaminants represents a potential  risk to
  surface-dwelling ecological receptors, actual risk posed to ecological receptors is likely to be minimal  Not
  only as a result of the limited distribution of contaminants, but also because of the heavy development in
  this area and the high level of human activity, this site represents minimal habitat for ecological receptors
  These conditions limit the likelihood that ecological receptors will come in  contact with these contaminants
  and thus significantly reduce the risks associated with these contaminants.

 2.6.2         Human Health Risks

 Exposure Pathways and Potential Receptors

 Base workers, construction workers,  and onsite residents (children and adults) were evaluated  as
 potential  receptors in the quantitative risk assessment  Base workers were considered for current and
 future conditions.  Construction workers and onsite residents were evaluated for future conditions only
 Although the potential for the base to be converted to residential land use is minimal, potential risks to
 future onsite residents were quantified for purposes of completeness. Under the current and future land
 use scenarios considered at Site 19, the exposure routes were incidental ingestion of soil and dermal
 contact with soil.

 The potential groundwater exposure route was not considered because contaminants in groundwater will
 be addressed in conjunction with an adjacent site in the future.  The potential inhalation of volatiles from
 soil and  inhalation of fugitive dust exposure route was not considered because the site is partially
 vegetated, relatively flat, and/or covered with asphalt or gravel.  Volatile organics are not COPCs at Site
 19, and fugitive dust emissions would be minimal under current land  use conditions.  It is assumed that
 good construction practices and moist soil at Site 19 (resulting from the shallow water table) will minimize
 emissions of fugitive dust.

 Exposure Assessment

 The COPCs that were evaluated and their maximum  exposure point concentrations are presented in
 Table 2-2. Exposure point concentrations are used to determine potential human health risks.

 Toxicity Assessment

 The toxicity assessment characterizes the nature and magnitude of potential health effects associated with
 human exposure to COPCs at each site.  Quantitative risk estimates for each COPC and exposure pathway
 are developed by integrating chemical-specific toxicity factors with estimated chemical intakes discussed in
 the previous section.

 Quantitative risk estimates are  calculated using  cancer slope factors  (CSFs) for COPCs  exhibiting
 carcinogenic effects and reference doses (RfDs) for COPCs exhibiting  systemic (noncarcinogenic) effects.
A summary of the RfDs and CSFs used in the baseline human health risk assessment is presented in
Tabte2-3.
                                          2-12

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                                 TABLE 2-2

CHEMICALS OF POTENTIAL CONCERN AND EXPOSURE POINT CONCENTRATIONS'1*
                   SITE 19, TRANSFORMER DRAINING AREA
                        NSWCDL, DAHLGREN, VIRGINIA

Organics
Chemical
Exposure Point
Concentration111
(mg/kg)
Inorganics
Chemical
Exposure Point
Concentration'11
(mg/kg)
Surface Soil (mg/kg)
Construction
Worker, Base
Worker, and
Future Residential
Scenarios
None
NA
Aluminum
Arsenic
Chromium
Iron *
Manganese
Vanadium
20,900
5.4
42.2
24,000
2,220
60.5
Subsurface Soil (mg/kg)
Construction
Worker, Base
Worker, and
Future Residential
Scenarios
Aroclor-1260
0.81
Aluminum
Cadmium
Chromium
Iron
Vanadium
102,000
4.1
105
37,000
125
    Maximum concentrations  are  used  as exposure  point concentrations for soil for  the
    Reasonable Maximum Exposure (RME) and Central Tendency Exposure (CTE) because, with
    the exception of the Aroclors, the post-removal soil database contains less than 10 samples.
    The maximum  detected Aroclor-1260 concentration  was used  as the exposure point
    concentration for Aroclors because the information  necessary to calculate the 95 percent
    upper confidence limit on the mean  was not available (i.e.,  sample  quantitation limits for
    nondetect results were not available).
                                2-13

-------
         M
                                                                           TABLE 2-3

                                                                DOSE-RESPONSE PARAMETERS
                                                            SITE 19: TRANSFORMER DRAINING AREA
                                                   NAVAL SURFACE WARFARE CENTER, DAHLGREN, VIRGINIA
Chemical
Aroclor-1260
Aluminum
Arsenic
Cadmium
Chromium VI (hexavatent)
Iron
Manganese • soil
Vanadium
1 USEPA, 1999a (IRIS
2 NA- Not available/a)
3 USEPA-NCEA provii
4 Values for high risk t
5 USEPA, 1997b
6 Assumed default val
7 ATSDR. 1991
8 ATSDR, 1993
9 USEPA, 1984
10 USEPA Region 1 Gu
RfDOral<"
(mg/kg-day)
NA">
1E+0<»
3E-4
SE-04
3E-3
3E-1
7E-3
>), unless otherw
jplfcabte. There
tional value, 199
ind persistence 1
je (USEPA, 198
dance. USEPA I
RfD
Inhalation")
(mg/kg-day)
NA
1E-3"'
NA
NA
3E-5
NA
1.43E-5
NA
ise noted.
are currently no
«a
>ased on USEPA
9)
*isk Uodates No
CSF Oral'"
(kg-day/kfl)
1.0E+0:CTE<4>
2.0E+0:RME(4)
NA
1.5E+0
NA
NA
NA
NA
NA
published values for
guidance for evalu.
vemhar IQQfiri "Th
CSF
Inhalation"'
(kg-day/mg)
1.0E+0:CTE'4'
2.0E+0:RME<4>
NA
1.51E+1
6.3E+0
4 1F+.i(5)
NA
NA
NA
parameters.
iting carcinogenic rig
Gastrointestinal
Absorption
Factor
NA
0.05<«>
0.95m
0.05
NA
0.03"°'
0.05<"
ks from PCBs (USEP
RfD Dermal
(mgftg-day)
NA
5.0E-2
2.85E-4
2.5E-5
3.0E-5
3.0E-1
4.2E-3
3.5E-4
A, 1996b).
CSF Dermal
(kg-day/mg)
NA
NA
1.S8E+0
NA
NA
NA
NA
NA
Weight of
Evidence
B2
NA
A1 - Inhalation
B1 - Inhalation
A1 - Inhalation
NA
D
D
USEPA's Weight of Evidence Classifications:
A1     Known human carcinogen.
B1     Probable human carcinogen; limited human data are available
       Probable human carcinogen; sufficient evidence in animals and inadequate or no evidence in humans
       Possible human carcinogen.
       Not classifiable as to human carcinogenicity.
                B2
                c
                D
.

-------
 CSFs and RfDs developed by USEPA are based on ingestion (bral) or inhalation routes of exposure rather
 than dermal contact.  Therefore, these values reflect administered doses  rather than absorbed doses
 USEPA guidance on assessment of dermal exposure (USEPA, 1992b) recommends that oral toxicity factors
 used  in dermal risk assessment be adjusted for gastrointestinal absorption efficiency, if such data  are
 available.  The methodology for the adjustment is presented in Appendix A to the USEPA Risk Assessment
 Guidance to Superfund, Part A (USEPA. 1 989).  The dermal RfDs and CSFs adjusted for Gl absorption are
 listed in Table 2-3.

 Chromium Toxicity

 Chromium was identified as a COPC in surface soil and subsurface soil  at Site 19. Analytical  results for
 this chemical are reported as total chromium. Chromium may be present  in different oxidation states. The
 hexavalent state, which is a less common state of chromium in environmental matrices, is the most toxic
 form of chromium.  No analyses were performed to distinguish between  the specific chromium oxidation
 states present at the site.  For the purposes of this risk assessment, it is  conservatively assumed that
 chromium is present in the hexavalent state.

 Toxicity profiles for COPCs are presented in Appendix C.

 Risk Characterization

 Excess lifetime cancer risks are determined by multiplying the intake level with the cancer slope factor.
 These risks are probabilities that are generally expressed in  scientific notation (e.g.,  1x10*). An excess
 lifetime cancer risk of 1  x 10* indicates that, as a plausible upper bound, an individual has a one in one
 million chance of developing cancer as a result of site-related exposure  to a carcinogen  over a 70-year
 lifetime, under the specific exposure conditions at a site.

 Potential concern for noncarcinogenic effects of a single contaminant in a single medium (i.e., water, soil,
 or air) is expressed as the hazard quotient (HQ) (or the ratio of the estimated intake derived from the
 contaminant concentration  in  a given medium to the contaminant's RfD).  By adding the  HQs for  all
 contaminants  within  a medium or across  all media to which a given  population may  reasonably  be
 exposed, the hazard index (HI) can be generated. The HI provides a useful reference point for gauging
 the potential significance of multiple contaminant exposures within a single medium or across media.

 Base Worker.  The cumulative noncancer His for ingestion of and dermal  contact with soils for Site  19
 under  industrial land use  conditions  are less than 1,  which indicates that no significant hazards are
 associated with soils at Site 19.

 The cumulative ingestion and dermal contact cancer  risk is I.SxIQ-6,  under a "reasonable maximum
 exposure" (RME) scenario. Although the incremental cancer risk for the base worker slightly exceeded
 1x10*. it is within USEPAs target risk range of 1x10-*to     "6
Construction Worker. The cumulative noncancer His for ingestion of and dermal contact with soils for
Site  19 under  industrial land use conditions are 1.2 for the RME.  The HI for the RME exceeds one
primarily as a result of the ingestion of aluminum and iron in subsurface soil. The RfDs for aluminum and
iron are not based on  any health effects but rather on recommended daily allowances.  If aluminum and
iron were eliminated as COPCs, the HI calculated for the construction worker would be 0.36, which is less
than one.  If the toxicity criterion for bivalent chromium was used in the risk assessment, the HI calculated
for the construction worker would be 0.96, which is also less than one.  A HI of less than one indicates no
significant hazards. Also,  His calculated on target organ/endpoint specific basis  do not exceed unity
indicating that adverse health effects are not anticipated for construction workers exposed to subsurface
soil.
                                         2-15

-------
 The cumulative ingestion and dermal contact cancer risk is 4.1x10-7, under a RME scenario, which is less
 than USEPA's target risk range of 1x10^to 1x10*.

 Future Resident. The cumulative noncancer His for ingestion of and dermal contact with soils for Site 19
 under hypothetical residential land use conditions are 2.6 for the RME.  The HI for the RME exceeds one
 primarily as a result of the ingestion of aluminum, arsenic, chromium, and iron in soil.  The RfDs for
 aluminum and iron are not based on any hearth effects but rather on recommended daily allowances.  It
 was conservatively assumed that all chromium is hexavalent chromium, which significantly overestimates
 the potential risks from exposure to chromium.  If aluminum  and  iron were eliminated as COPCs, and
 chromium was assumed to be trivalent chromium, the HI calculated for the hypothetical resident is 0.7,
 which is less than one. A HI of less than one indicates no significant hazards.

 The total residential incremental lifetime cancer risk based on cumulative ingestion and dermal contact
 with soils is 1.4x10's, under a RME scenario, which is within USEPA's target risk range of 1x10^ to
 1X10-6.

 Uncertainty Analysis

 The major sources of uncertainty specific to post-remedial conditions at Site 19 include:

        •       The exposure point concentrations for iron and arsenic (noncarcinogenic risk drivers for
               soil) may reflect background conditions.  In addition, the RfDs for iron and aluminum are
               not  based  on  any  health effects  but rather  on  recommended  daily allowances.
               Consequently, some  USEPA  Regions  (e.g.,  USEPA Region  I)  do  not  advocate
               quantitative risk assessment of these metals. If these constituents (aluminum, arsenic,
               and iron) are eliminated as COPCs in surface soil, the HI for the most sensitive receptor,
               the  hypothetical  future child resident, would  be 0.83, which is less than the USEPA
               benchmark of one.   If aluminum  and  iron are  eliminated as COPCs in subsurface soils,
               the  HI calculated  for the  hypothetical  child resident would be 1.6.   Additionally,  if
               chromium was evaluated as trivalent  chromium, the HI for the child exposed to surface
               soil would be 0.61, and the HI calculated for the child exposed to subsurface soil would be
               0.44.

       •       An evaluation of the risk estimates for chromium indicate that the risk for dermal contact
               with soil contributes more to the total HI for chromium than risk estimates for the ingestion
               route of exposure.  The risk estimate  for dermal contact results from a conservative oral
               absorption factor  (0.01) provided  by USEPA Region III that has been used to calculate a
               dermal RfD for chromium. The USEPA has recently published an oral absorption value of
               0.025 for hexavalent chromium. Consequently, risks from dermal absorption to chromium
               may be overestimated by a factor of 2.5.

       •       Arsenic, the only  carcinogenic constituent identified as a COPC in surface soil, may be
               present at concentrations reflecting background conditions.  If arsenic was eliminated as a
               COPC in surface soil, a cancer risk estimate would not be calculated for surface soils.

Summary and Conclusions

The following items summarize the  results of a human health  risk assessment conducted  based  on the
post-removal action soil database  for Site 19:

       1.       Hazard indices calculated for base workers who are exposed to soil do  not exceed one
               indicating that adverse health effects are not anticipated under the conditions established
               in the exposure assessment.  Cancer risk estimates developed for this receptor exceed
               1.0 X 10* only when arsenic concentrations in surface soil are evaluated.  However, the


                                         2-16

-------
               results of statistical comparisons of site concentrations with  background concentrations
               indicate that the arsenic concentrations in the Site 19 soils are reflective of background
               conditions.

       2.      His calculated for the construction worker exposed to surface  soil and subsurface soil are
               0.61 and 1.2 for the RME receptor exposed to surface and subsurface soils, respectively.
               The primary noncarcinogenic  n'sk drivers are aluminum and iron; however, significant
               uncertainty is reported for the available RfDs for aluminum and iron. The provisional oral
               RfDs available for these metals are based on allowable daily  intakes for human nutrition,
               instead of an  adverse  health effect.   Additionally, these metals do not affect the same
               target organs.  Consequently, target  organ/effect specific His would not exceed unity.
               Cancer risk estimates for the construction worker do not exceed 1E-6.

       3.      A hypothetical future resident was evaluated for purposes of completeness.  The His
               calculated assuming exposure  to surface and subsurface  soil were  2.5  and 4.9,
               respectively.  Arsenic (surface soil), aluminum,  iron, and chromium are the primary risk
               drivers.   However,  His  calculated  for  these  metals overestimate the site-related,
               noncarcinogenic risk: a) Arsenic concentrations in the surface soil reflect background
               conditions, b) The provisional RfDs available for aluminum  and iron are not based  on
               adverse health effects,  and c) The risk  assessment was prepared assuming that 100
               percent of the chromium was present in the soil in the hexavalent state.

       4.      Cancer risk estimates developed for the hypothetical future resident (RME case) are 1.4
               X 10's  and 4.1 X  10"6 for surface and subsurface  soils,  respectively.  Cancer risk
               estimates developed for the CTE case are 1.7 X 10"6 and 3.0 X 10'7 for the surface and
               subsurface soils, respectively.  Arsenic, detected at concentrations reflecting background,
               is the only COPC contributing to the risks calculated assuming surface soil exposure.
               Aroclor-1260, detected at concentrations less than the current USEPA soil screening level
               (SSL) for PCBs (for residential land use), is the only contaminant of potential concern
               (COPC) contributing to the risks calculated assuming subsurface soil exposure.

The cancer risk estimates for the human receptors evaluated are within or less than the USEPA target risk
range of 1 X 10"* to 1 X lO*. The maximum concentration of the primary site contaminant (i.e., the PCBs)
is less than the USEPA SSL  for residential land use.  The His calculated for the base worker and the
construction worker do not exceed one.  His calculated for the hypothetical future resident, which are less
than five, are expected to overestimate the site-related, noncarcinogenic risk to this receptor.

The  Rl conducted for Site 19  indicated  PCBs  in soil were the only contaminant that warranted remedial
action. Subsequently, the PCB-contaminated soil was excavated and disposed of offsrte. Sampling data
was  collected to verify the removal action achieved its objective.  This data was evaluated in a revised risk
assessment which indicated remaining risks are acceptable.

Therefore "no further action"  is the  selected remedy for soils at Site 19.  Groundwater will be further
evaluated in conjunction with an adjacent site (Site 40).

2.7            DOCUMENTATION OF SIGNIFICANT CHANGES

The  selected remedy is the same alternative identified as the recommended  alternative in the Proposed
Remedial Action Plan which was presented to the public at the public meeting held July 28,1999.

There were no significant changes to the recommended remedial action alternative in the Proposed Plan.
                                          2-17

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  2.8           SITE 29 - NAME, LOCATION, AND DESCRIPTION

  The Battery Service Area, located off Caskey Road in the south-central portion of the NSWCDL Mainside
  consisted of a former unlined neutralization pit used for disposal of battery acid resulting from handling and
  recharging of sulfunc acid batteries (Figure 2-6). The exact depth and width of the pit are unknown  The
  former pit, located behind Buildings 1121 and 338, was paved over and the location is used as a service
  area.  Access to the pit was through a concrete manhole type cover.  The pit was closed in the mid-1980s
  and was not backfilled, although the manhole was covered with soil.  The site, which is heavily developed
  and composed of closely spaced structures and pavement, is used by the Public Works Department mainly
  for the maintenance of heavy equipment and transportation vehicles. A grease rack is located approximately
  5 feet west of the former pit and is  currently used for the maintenance and lubrication of heavy machinery
  The majority of the base  maintenance vehicles  (e.g.,  plows, dump  trucks, buses, etc.) are parked
  approximately 200 feet north of the site.  The base golf course, which is separated from the Public Works
  area by a chain-link fence, is located approximately 150 feet west of the site. The base Cooling Pond  Site
  55  is located approximately 250 feet south of the site. Access to the site is provided via Caskey Road which
  is located approximately 200 feet east of the site.                                           au,w,,,w,

  Elevations in the site vicinity are between 10 and 20 feet msl. Slopes are gentle (less than 3 percent)  and
  surface drainage is overland to storm drains, which discharge to the Cooling Pond (Site 55).

  Several Solid Waste Management Units (SWMUs) are in the vicinity of Site 29, including the following:

        •       Cooling Pond (Site 55);

        •       Battery Locker Acid Draining Area (SWMU 98);

        •       Building 155 Auto Shop Waste Oil Filter and Underground Storage Tank (UST) (SWMU


        •      Oil/Water Separator(OWS) 1121-Old (SWMU 128);

        •      Building 1121 Former Waste Oil UST (SWMU 78);

        •      SWMU  127: OWS 1121-300, OWS 115-350,  OWS 402-30,000,  and OWS 486-1000
               (SWMU  127).

2.9            SITE 29 - HISTORY AND ENFORCEMENT ACTIVITIES

2>9>1          History of Site Activities. Previous Investigations and Previous Response Actions

The site history for Site  29 has been  developed from information provided in the IAS, the Confirmation
Study, and an EPIC analysis of aerial photographs.  A  summary of the site history is discussed in the
following paragraphs.

Information contained  in  the IAS was obtained through onsite records review,  site visits and personnel
interviews conducted  during 1981.   Waste battery acids were reported to have  discharged into an
underground tank at Site 29 at the rate of approximately 10 to 15  gallons per month.  The  tank was
apparently never emptied and, despite numerous inquiries by Fred C. Hart Associates Inc no  indication
showed where the tank drained.  At the time of the IAS, a dye  test  program was being developed and
implemented by the base to determine discharge  from the tank.   The IAS did not recommend a
Confirmation Study at Site 29 because of the planned dye test program.
                                         2-18

-------
, Approximate
1  Location of
: Neutralization
      P
               2-19

-------
 During a site reconnaissance for the Rl in March 1989 the results of the dye test were discussed, and it
 was concluded that no tank existed at this site. When the area was investigated, a concrete manhole (ike
 cover was removed and an unlined limestone-filled pit was found. When the investigation was completed,
 the pit was not backfilled, but the manhole was covered with soil. The top of the limestone in the pit was
 observed to be within approximately 2 feet of the surface. Use of the pit ceased around 1985.

 Analysis of aerial photographs of NSWCDL indicates that a concrete building, a bunker, and open service
 yard areas, all of which were accessed by Caskey Road, were located in the present-day Battery Service
 Area as early as 1937.  Evidence of what appeared to be a pit in the Battery Service Area was first noted
 in the 1952 imagery, and it remained apparent in the photography as late as 1977.

 An RI/FS was completed in phases for Site 29. Sampling activities, consisting of soil sampling, surface
 water and sediment sampling, and the installation and sampling of groundwater monitoring  wells were
 completed in 1994. Additional soil sampling was performed before and after the  removal action that was
 completed in 1997. A draft final Rl was prepared in 1995. An addendum RI/FS was prepared in 1999.

 In 1997, a removal action was performed and is described in Section 2.11.2.

 2.9.2         Enforcement Actions

 No enforcement actions have been taken at Site 29. The Navy has owned this property since 1918 and is
 identified as the responsible party. NSWCDL was added to the NPL in 1994.

 2.9.3         Highlights of Community Participation

 In accordance with Section 113 and 117 of CERCLA, the Navy provided a public comment period from
 July 21,  1999 through  August 19, 1999 for the proposed remedial action described in the Remedial
 Investigation/Feasibility Study and the Proposed Remedial Action Plan for Sites 19 and 29.

 These documents were available to the public in the Administrative  Record and  information repositories
 maintained at  the Smoot Memorial Library,  King  George,  Virginia; the NSWCDL General Library,
 Dahlgren, Virginia; and the NSWCDL Public Record Room, Dahlgren, Virginia.  Public notice was provided
 in The Freelance Star newspaper on July  19, 1999 and The Journal newspaper on July 14, 1999 and a
 public meeting was held in the King George Courthouse on July 28, 1999. No written comments were
 received  during the comment period.  Spoken comments and responses provided  during  the  public
meeting are presented in Appendix B.

Additional community involvement, including Restoration Advisory Board (RAB) activities, are highlighted
in Section 3.1.

2.10          SCOPE AND ROLE OF RESPONSE ACTION FOR SITE 29

Site 29 is one of many sites identified in the Federal Facility Agreement (FFA) for NSWCDL.  In previous
years, RODs have been issued for several other sites in accordance with the priorities established in the  Site
Management Plan (SMP). A removal was performed at Site 29 in 1997. This action follows the removal  and
provides closure for the site.
                                        2-20

-------
The selected remedy (no further action) fits the Navy strategy to reduce risks at all NSWCDL sites with
minimal long-term care.  Site 29 soils are clean and require no future monitoring,  allowing the Navy  to
focus its resources on the remaining NSWCDL sites. Soils at Site 29 are acceptable under the residential
use scenario.  Groundwater sampling at Site  29 indicated levels of metals that exceeded  Maximum
Contaminant Levels (MCLs); however, upgradient monitoring revealed that concentrations of these metals
entering the site were at the same level or higher. It was determined in the RI/FS that Site 29 was not
likely contributing to these concentrations.

2.11           SUMMARY OF SITE 29 CHARACTERISTICS

The RI/FS and removal action are summarized below.

2.11.1          1995 Remedial Investigation

The Rl at Site 29 included a hydrogeologic investigation, contaminant assessment, and risk assessment.
The hydrogeologic investigation included the installation and sampling of one shallow groundwater monitoring
well and the sampling of two existing shallow groundwater monitoring wells.  Physical descriptions of the
subsurface, a monitoring well elevation and location survey, groundwater-level measurements, and hydraulic
conductivity testing were also included in the hydrogeologic investigation. Two soil borings, including one
used for the completion of groundwater monitoring well GW29-2 (depth of 16 ft bgs), were completed in the
immediate vicinity of the former pit.  The subsurface in these borings consists predominantly of clayey sand
(possible fill) to approximately 10 feet underlain by clay extending to the bottom of the borings (12 and 20 ft
bgs).  A defined saturated zone was not encountered in either of the two  new borings.  Predominant
groundwater flow at the site is to the south-southwest (Figure 2-7). The estimated hydraulic conductivity in
GW29-2 was 4.9 x 1Q* cm/sec.

The contamination  assessment included the collection and analysis of samples from subsurface soil and
groundwater. Eight subsurface soil samples were collected from two locations within the immediate vicinity
of the pit (borings SB29-1 and SB29-2, completed to 10 feet bgs). Groundwater samples were collected from
the three wells. All samples were collected during the Phase 2 field investigation.

No organic compounds were detected in the groundwater samples at concentrations that exceeded either
the MCLs or the Region  III Risk-Based Concentration (RBC) screening values for tap  water.  Arsenic,
beryllium, lead, nickel, and zinc were detected in the unfiltered groundwater samples at this site at maximum
concentrations that exceeded either the  MCLs and/or the Region III criteria; therefore, the  untreated
groundwaterat this site may be considered to be unsuitable for potable use.

2.11.2          Removal Action

A removal action was completed at Site 29 in 1997 and consisted of removal and disposal of the metals
contaminated soil.   (The neutralization pit had been removed during a 1996 Rl sampling effort.)  Soils
contaminated with metals (antimony, arsenic,  iron, lead, and mercury) and petroleum hydrocarbons were
excavated and transported to the King & Queen Landfill located in Little Plymouth,  Virginia for disposal.
Target clean-up levels were based on USEPA Risk-Based Concentrations  (RBCs) for metals and the
VADEQ action  level for Total  Petroleum Hydrocarbon (TPH).  Approximately  200  cubic  yards of
contaminated soil were removed. The entire excavation was approximately 21.5 ft. by 38 ft. by 7 ft. deep.
Soil sampling and analyses were conducted from the sides and bottom of the excavation to confirm that all
soil with concentrations greater than or equal to  target clean-up levels was removed. Except for arsenic,
target clean-up concentrations were achieved at Site 29. Arsenic concentrations of 6.87, 7.62, and 7.64
(mg/kg) were detected at three sample locations.  The excavation was then  backfilled and covered with
asphalt pavement.
                                         2-21

-------
   APPROXIMATE LOCATION
   OF  NEUTRALIZATION  P
    STORMWATER   9.00
        OUTFALL
       LEGEND

       Monitoring W.IHGW)

       Subwrfic* Soil Boring (SB)

       Pottntiomttric Surfic* Contour*
DKAWNBV
 TF
   DATE
May 99
     Tetra Tech NUS, inc.
                                          CONTRACT Na
OWNER NQ
CT0261
CHECKED K
 DM
   OWTE
May 99
     COST/SCHEDWUttA
       CCAl£
     A* Shown
Potentiometric Surface Map
          Site 29

         NSWCDL
     Dahlgren, Virginia
                                   APPROVED IV
                                                                  DATE
                                                                 APPROVEDtY
                                                                                                DATE
                                                   MAWMONO.
                                                                 Figure 2-7
                                                                                       REV.
                                              2-22
                                                                        Map fito:G.UahlgnntMt29\poMnuo >urfw*.cdr

-------
2.11.3         1999 Remedial Investigation/Feasibility Study

Follow-up remedial investigation activities consisting of a human health and ecological risk analysis was
performed to determine whether further action was required.  These results are summarized below.

2.11.3.1        Sources of Contamination

Extensive soil sampling was conducted to identify the extent of contamination near the neutralization pit.
The only known waste to have been disposed of at Site 29 is battery acid, which was discharged to an
unlined  neutralization pit through a concrete manhole cover. Acid disposal into the pit ceased around
1985, at which time the pit was not backfilled.  The  neutralization  pit was  removed in 1996.  The
contaminated soil was removed in 1997 as part of the removal action.

2.11.3.2        Description of Contamination

Soil and groundwater sampling was conducted under the Rl because of the reported discharge of liquid
battery acid into an  unlined neutralization pit.  Initial data needs included the inspection, evaluation,  and
rehabilitation of the  existing monitoring wells originally installed in the  vicinity of Site 29 as part of UST
studies. These field activities were completed in June 1993 as part of the Phase 1 field activities under
the Rl.   Phase 2 activities included  the  collection of soil samples,  the  installation  of an additional
groundwater monitoring well, and the collection of groundwater samples from new and existing monitoring
wells.

Two main objectives were identified for the Rl at Site 29.  Subsurface samples were collected to determine
the presence  or  absence  of residual contamination in the pit  and  surrounding soils.  In  addition,
groundwater samples were collected to determine the presence or absence of contaminants in the shallow
aquifer resulting from potential migration of wastes from the pit  Depth and direction of groundwater flow
were also determined as part of the Phase 2 Investigation.

The analytical  parameters selected for soil and groundwater samples  from Site 29 included volatile  and
semivolatile organic compounds, metals, cyanide,  TPHs, and sulfate.  Groundwater samples were also
analyzed for hardness. The identified parameters were selected as representative constituents likely to be
present because  of the types of wastes disposed in the area.   Volatile and  semivolatile compounds,
metals,  and  cyanide were included because these constituents may be present from operations at the
adjacent grease rack.  TPH was included because of operations at the grease rack and the former USTs
in the area.  Sulfate analysis was included based on disposal of sulfuric acid in  the pit.  Lead was  a
concern because  it  may have been dissolved in the battery acid.  Determination of pH in groundwater
samples provided  a  simple analytical tool for indicating the presence of residual acidity.

Soil  samples collected  during the 1995 Rl indicated metals contaminated soils  in the vicinity of the
neutralization pit.  (Soil in these sample areas was excavated and transported offsite for disposal during
the 1997 removal  action.)  In addition, groundwater samples, shown in Figure 2-7, were collected as part
of the 1995 Rl. Post removal verification soil samples, shown in Figure 2-8, were collected from the side
walls and bottom  of the  excavation area after the removal action was completed in 1997.  Table 2-4  lists
the chemicals of  potential  concern for each medium and  the maximum concentration detected.  The
results of the sampling and analyses are presented below.

Subsurface Soils

Benzo(a)pyrene,  arsenic,  and chromium were  detected in subsurface soils  as  shown  in  Table 2-4.
Benzo(a)pyrene was  detected in one of the five  samples  at a concentration  of 160 jig/kg,  above the
residential Risk-Based Concentrations (RBC) screening level of 87ng/kg.  The arsenic concentrations
                                          2-23

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             RACK
     L • 9  • n rt
            EXCMMTKIN AREA
       A   aOM SAMPLES
       •   S»t«*aS TAKEN 4' SaOW OR*D£
       •   SIOOMUS TAKtN r BELOW CRADC
                          S  C  A  1    F
PJD««giwSit«m»mo»«*«>.i 6

f!7



-

BUILDING 1121


SAMPLES












r 1 DA29-046
2 DA29-047
3 DA29-048
4 DA29-049
5 DA29-050
6 DA29-051
7 DA29-052
8 DA29-053
9 DA29-054
10 DA29-055
11 DA29-056
12 DA29-057
13DA29-058
14 UA29-U59
15 DA29-060
16 DA29-061
17 DA29-062
18 DA29-068
	 Source: OHM. 1997

E
••



••wd
50 FEET
WLR May 99
DM

May 99

AS SHOWN
1
®Tetra Tech NUS, Inc.
Post Removal Verification Sampling Locations
Site 29

NSWCDL
Dahlgren, Virginia


CONTRACT NO.
7188-1601

APt^OVfeOBV^^^^ ^
Figure 2-8
OWNER NO.
lz*
-------
                                    TABLE 2-4
           MAXIMUM DETECTED CONCENTRATIONS FOR COPCs (POST REMOVAL)
                          SITE 29: BATTERY SERVICE AREA
                           NSWCDL, DAHLGREN, VIRGINIA
                                SUBSURFACE SOILS
Organics (mg/kg)
Benzo(a)pyrene
0.16
Metals (mg/kg)
Arsenic
                                         7.64
Chromium
                                         37.7
                                  GROUNDWATER
Organics (mg/L)
Benzene
                                         0.001
Metals (mg/L)
Aluminum
                                         9.71
Arsenic
0.0064
Iron
                                         23.2
Lead
                                         0.113
Manganese
Nickel
Zinc
2.62
0.0749
1.57
                                   2-25

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  marginally exceeded background.  The maximum and average site concentrations were 7.64 mg/kg and
  4.2 mg/kg, respectively.  The maximum background concentration of arsenic was 3.3 mg/kg  Chromium
  was detected at a maximum concentration of 37.7 mg/kg, above the residential RBC screening level of 23
  mg/kg. The maximum background concentration of chromium is 18.5 mg/kg.

  Groundwater

  Benzene,  aluminum,  arsenic,  copper,  iron, lead, manganese, nickel,  and zinc  were detected  in
  groundwater and maximum concentrations are presented on Table 2-4.

  Surface Water and Sediment

  Surface water and sediment samples were collected from the Cooling Pond (Site 55) in support of the Rl
  for Site 55. These results will be addressed in the Site 55 Rl.

  2.11.3.2.1      Contaminant Migration

  The predominant COPCs were metals. Before the removal action, several metals detected in subsurface
  soils in the vicinity of the former pit area exceeded metal concentrations in background soil samples
 These constituents  are believed  to  have been  the  result  of past practices in  the neutralization pit
  Groundwater transport was the only potential migration pathway  for these constituents because the
 contaminated soils were covered by asphalt pavement.  COPCs identified in  groundwater included
 aluminum, arsenic, copper, iron, lead, manganese, nickel, and zinc.

 Subsurface soils of the saturated zone at Site 29 vary between clay with fine sand to silly clay. Inorganic
 constituents exhibit  low mobility in clay and silty clay  soils.  The ability of soils  to absorb inorganic
 constituents increases with an increase in surface area  and  clay content of soil grains.  The mobility of
 zinc may vary between low to moderate in sandy clay and clay soils.  The mobility of copper is expected to
 be low in clay and sandy clay soils.  In addition, the hydraulic conductivity of the saturated soils at Site 29
 was estimated to be 1.0 x 10's cm/sec indicating low groundwater velocities.

 If sufficient acid waste is added to depress the soil pH  to less than five, then soils generally lose  their
 ability to retain metals.  More acidic soil conditions could therefore result in increased mobility of inorganic
 constituents in soil. The pH of the subsurface soils and  groundwater at Site 29 varied between five and
 six. These pH levels are similar to values detected at the other IR sites at NSWCDL Therefore, disposal
 activities at Site 29 do not appear to have significantly altered pH levels in soil and groundwater.

 Based on the soil characteristics, the potential for mobility of inorganic constituents at Site 29 appears to
 be low.  Considering the  retardation of contaminants in  clay soils and low groundwater velocity,
 mobilization and transport of inorganic constituents could be occurring at a slow rate at Site 29.

 Groundwater at  Site 29  appears to be discharging  into the Cooling Pond located downgradient of
 monitoring well GW 29-4 (see Figure 2-7).  The potential  for the migration of inorganic constituents to the
 Cooling Pond (from the former neutralization pit) was evaluated using a fate and transport model. Potential
 transport to surface water and sediment in the Cooling Pond was evaluated for groundwater COPCs
 identified in the ecological risk assessment  (aluminum, copper, lead, manganese, and zinc).  Transport of
 these constituents from subsurface soil to groundwater  to the Cooling Pond was assessed using the
 residual soil concentrations and existing groundwater concentrations.  Surface water dilution was based
 on runoff from the area draining into the upper leg of the Cooling Pond and a precipitation rate of 40 in/yr.
The groundwater discharge face was assumed to be the entire length along the upper leg of the Cooling
 Pond (600-ft).  No dispersion from the source area to the discharge point was conservatively assumed.
 Based on the evaluation, groundwater concentrations are not expected to negatively impact surface
waters or sediments in the Cooling Pond.
                                          2-26

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 2.12           CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES

 Site 29 is located in the south-central portion of the Mainside in the public work area.  The site is located
 behind Buildings 338 and 1121 and can be accessed via the road servicing these buildings. Buildings to the
 north, south, and east, and a chain-link fence to the west border the site.

 The site is paved, which limits the possibility of contact with contaminated materials. Immediately west of
 the fence is the base golf course.  Land within a  0.5 mile radius of the Battery Service Area is mainly
 developed for residential and base support activities.  Public works and operations areas of the base lie to the
 north, south, and east of the site. Residences are located with in 1,000 feet of the site. Roads adjacent to the
 site are used by base personnel for jogging and bike riding. In addition, fishing is allowed in the Cooling
 Ponds on a catch and release basis. A golf course is located just south of the site in the residential area.
 The buildings surrounding Site 29 are regularly occupied by base personnel. However, no significant activity
 happens outside the buildings. Access to the site is restricted on three sides because of the presence of
 buildings. However, the west side allows unrestricted access from within the inner security perimeter. Site
 29 is currently an industrial  use area and is anticipated to  remain an industrial use area in the future. The
 mission  of the base  is currently expanding and future  potential for base  closure and conversion to
 residential land use is considered to be minimal.

 The watertable (or Columbia) aquifer beneath Site 29 is a thin water  bearing zone underlain by a laterally
 persistent clay  confining layer (or Upper Confining  Unit).  Shallow groundwater at the Base is known to
 discharge  to  adjacent  shallow water  bodies,  in this case the  manmade  Cooling  Pond  located
 approximately 250 ft. from Site 29. The watertable aquifer at the Base is generally of poor quality because
 of high, naturally occurring concentrations of some metals  (i.e. iron and manganese) according to a United
 States Geological Survey (USGS)  study of basewide groundwater quality.  Poor water quality, coupled
 with the thin  saturated  thickness and  locally high  percentages of fine grain sediments, effectively
 diminishes the feasibility of using the  watertable aquifer as an industrial  or  potable  water source.
 However, in the risk evaluation for Site 29, the watertable aquifer is considered to be a potential source of
 potable water.

 2.13           SUMMARY OF SITE 29 RISKS

 The ecological and human health risks associated with exposure to contaminated media at Site 29 were
 evaluated in the Addendum RI/FS Report. The residential use scenario was evaluated for completeness;
 although the site is anticipated to remain in industrial use.

2.13.1         Environmental Evaluation

 During the  1995  Rl,  an Ecological  Risk Assessment  was  conducted.    It concluded  that shallow
groundwater associated with Site 29 flows toward the Cooling  Pond  (located nearby and to the south of
the Battery Service Area)  and likely discharges into the pond. This is  the primary mechanism for transport
of contaminants from  the Battery Service Area because the surface soils in the vicinity of the Battery
 Service Area are paved over and not exposed. Ecological receptors  inhabiting or using the Cooling  Pond
 may  come  in  contact with  potential contaminants  entering the  pond via groundwater discharges
 associated with Site 29.   Aluminum, lead, manganese/and zinc were identified as COPCs in groundwater.
 To investigate these exposure pathways, samples  of groundwater and subsurface soils were collected
 from the site, which are summarized in Table 2-4.  Based on current conditions at Site 29 and fate and
transport modeling  of groundwater constituents, it is unlikely that ecological receptors will come in contact
with any  contaminants present in these two media; therefore, risks to ecological receptors are believed to
 be minimal, requiring no further action.
                                          2-27

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  2-13.2         Human Health Risks

  Exposure Pathways and Potential Receptors

  Base workers, construction workers,  and onsite residents (children and  adults)  were evaluated as
  potential receptors in the quantitative risk assessment.  Base workers were considered for current and
  future conditions.  Construction workers and  onsite residents were evaluated for future conditions only
  Although the potential for the base to be converted to residential land use is minimal, potential risks to
  future onsite residents were quantified for purposes of completeness.  Under the current and future land
  use scenarios considered at Site 29, the exposure routes were incidental ingestion of soil and dermal
  contact with soil.

  The potential  groundwater  exposure route was considered for hypothetical future residents   These
  residents were assumed to be exposed by ingestion of groundwater, dermal contact with groundwater
 and inhalation of volatiles emitted from water while showering.  The potential inhalation of volatiles and
 dust from soil was not considered because the site is relatively flat, and covered with asphalt or buildings
 Volatile orgamcs are not COPCs at Site 29, and dust emissions would be minimal under current land use
 conditions.  It is assumed that good construction practices and moist soil at Site 29 (resulting from the
 shallow water table) will minimize emissions of dust.

 Exposure Assessment
    ,    *    that Were evaluated and  tne'1" maximum exposure point concentrations are presented in
 Table 2-5. Exposure point concentrations are used to determine potential human health risks.

 Toxicity Assessment

 The toxicity assessment characterizes the nature and magnitude of potential health effects associated with
 human exposure to COPCs at a site.  Quantitative risk estimates for each COPC and exposure pathways are
 developed by integrating chemical-specific toxicity factors with estimated chemical intakes discussed in the
 previous section.

 Quantitative risk estimates are calculated using  cancer slope factors  (CSFs) for COPCs exhibiting
 carcmogeniceffects and reference doses (RfDs) for COPCs exhibiting systemic (noncarcinogenic)effects  A
 summary  of the RfDs and CSFs used in the baseline human health risk assessment is presented  in
 I 3D (6 fc~D.

 CSFs and RfDs developed by USEPA are based on ingestion (oral) or inhalation routes of exposure rather
 than dermal contact.  Therefore, these values reflect administered doses rather than absorbed doses
 USEPA guidance on  assessment of dermal exposure (USEPA, 1992b)  recommends that oral toxicity
 factors used in dermal risk assessment be adjusted for gastrointestinal absorption efficiency, if such data
 are available. The dermal RfDs and  CSFs adjusted for gastrointestinal absorption are listed in Table 2-6
 The dermal toxicity criteria are derived per the methodology presented  in Appendix A of the Risk
Assessment Guidance for Superfund, Part A (USEPA. 1989). According to USEPA Region III policy  the
dermal contact exposure pathways is not evaluated quantitatively for PAHs. Therefore, potential risks from
dermal contact exposure to benzo(a)pyrene in soil are not quantified in this risk assessment.
                                         2-28

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                                     TABLE 2-5

     CHEMICALS OF POTENTIAL CONCERN AND EXPOSURE POINT CONCENTRATIONS'1'
                           SITE 29, BATTERY SERVICE AREA
                            NSWCDL, DAHLGREN, VIRGINIA


On
Chemical
games
Exposure Point
Concentration'1'

0.113 (ND)'2'
2.62 (2.62)12'
0.0749 (0.0734)'2'
1.57 (0.556)(2>
1     Maximum concentrations are used as exposure point concentrations for RME and CTE in soil and
      groundwater because the post-removal soil and field investigation groundwater databases contain
      less than 10 samples.

2     Values in parentheses are maximum concentrations from filtered samples.

ND = Not Detected
                                     2-29

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                                                                      TABLE 2-6
CJ
o
                                                           DOSE-RESPONSE PARAMETERS
                                                         SITE 29:  BATTERY SERVICE AREA
                                                           NSWCDL, DAHLGREN, VIRGINIA
        8
        9
        10
Chemical
Benzene
Benzo(a)pyrene
Aluminum
Arsenic
Chromium VI (hexavalent)
Iron
Lead
Manganese -water
Nickel
Zinc
RfD Oral11'
(mg/kg-day)
3E-3<"
NA">
1E+0">
3E-4
3E-3
oc 4(3)
NA®
2E-2")
2E-2
3E-1
RfD
Inhalation'"
(mg/kg-day)
1.7E-315'
NA«
1E-3<«
NA°>
3E-5
NA1 '
HA®
1.43E-5
NA®
NA«
CSF Oral'"
(kg-day/kg)
2.9E-2
7.3E+0
NA<»
1.5E+0
NA®
NA«
NA»
NAP)
NA«
NA«>
CSF
Inhalation'"
(kg-day/mg)
2.9E-2
3.1 E+0
NAW
1.51E+1
4.1E+1'4'
NA")
NA«
NAO)
NA
NA«'
0.05
0.95<5'
0.01'6'
NA^
MAO
0.03'"
0.04'"
0.5<10>
	
RfD Dermal
(mg/kg-day)
3E-3
NA'2>
5E-2
2.85E-4
3E-5
3E-1
NA">
6E-4
8E-4
1.5E-1
CSF Dermal
(kg-day/mg)
NA'«
NA'2)
^^— fc^-^— »^— ™— .
NA'»
1.58E+0
., .—
NAm
NA®
NA">
NA'J»
NA«>
NA«»
Weight of
Evidence
B2
82
NAW
A - Inhalation
	
1 A
NA">
B2
D
D
D
USEPA, 1999a (IRIS), unless otherwise noted.
NA - Not available/applicable.
USEPA-NCEA provisional value, 1998a
HEAST, 1997b.
ATSDR, 1991.
ATSDR, 1993.


                               ^
USEPA, 1984
ATSDR, 1993
Elinder, 1986
       USEPA's Weight of Evidence Classifications:
       A1      Known human carcinogen.
       B1      Probable human carcinogen; limited human data are available

                                    sufficient evklence in animais
               Not classifiable as to human carcinogenieity.

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  Chromium Toxicity
            Tfnt±h      * 3 S?PC '" subsurface soil at Site 29  Analytical results for this chemical are
         H t     chromium.  Chrom.um may be present in different oxidation states.  The hexavalent
        wh(ch ,s a less common state of chromium in environmental mixtures, is the most toxic form of
                         f^*** *** performed to distinguish among the specific chromium oxidation
                         ^purposes of risk assessment, it is assumed conservatively that chromium is
  Lead Toxicity

  The equations and methodology used to evaluate other COPCs cannot be used to evaluate exposure to
          aUSe ?™ f S6nce °f published dose-resPonse parameters for this constituent.   Lead was
          as a COPC for groundwater because the maximum detected concentration of lead 1 13 ng/L in

                                                                        **  (S°WA) Action  Level
                                                  the USEPA lntegrated Exposure Uptake Biokinetic
 to      n   t     n      ,     '  ?94a) f°r 6XpOSUre to sma" children- This model evaluates exposure
 to lead in water and/or soil and is designed to estimate blood lead levels based on either default or site-
 specific input values.  The evaluation of lead is discussed below.

 The toxicity profiles for the COPCs are presented in Appendix C.

 Risk Characterization

 Excess lifetime cancer risks are determined by  multiplying the intake level and the cancer slope factor
 These risks are probabilities that are generally expressed  in scientific notation (e g   ixlQ-6)  An excess
 hfetime cancer risk of 1 x 10* indicates that, as  a plausible upper bound, an  individual has a one in one
 milhon chance  of developing cancer as a result  of site-related exposure to a carcinogen over a 70-year
 lifetime, under the specific exposure  conditions at a site.

 Potential concern for noncarcinogenic effects of a single contaminant in a single medium (i.e water air
 or soil) is expressed as the hazard  quotient (HQ) (or the  ratio of the estimated intake derived from the
 contaminant concentration  in a given medium to the contaminant's RfD).   By adding  the HQs for all
 contaminants within a medium or across all media to which a given  population may reasonably be
 exposed,  the HI can be generated.  The HI  provides a useful reference point for gauging the potential
 significance of multiple contaminant exposures within a single medium or across media.

 Base Worker.  The cumulative noncancer His for ingestion of and dermal contact with soils for Site 29
 under  mdustnal land use conditions are less than one, which indicates that are no significant hazards are
 associated with soils at Site 29.

 The cumulative ingestion and dermal contact cancer risk is 2.8x10*. under a RME scenario  Although the
 incremental cancer nsk for the base worker slightly exceeded 1x10*  it is within USEPA's target risk ranqe
 of 1x10 to 1x10.

 Construction Worker. The cumulative noncancer His for  ingestion of and dermal contact with soils for
 Site 29 under industrial land use conditions are less than one, which indicates  that no significant hazards
are associated with soils at Site 29.
                                                                                       i
The cumulative  ingestion and dermal contact cancer risk is 6.3x1 0'7, under a RME scenario which is less
than USEPA's target risk range of 1 x1 0" to 1 x1 0"6.
                                         2-31

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 Future Resident. The cumulative noncancer His for ingestion of and dermal contact with soils for Site 29
 under hypothetical residential land use conditions are less than one, which indicates that no significant
 hazards are associated with soils at Site 29.

 The total residential incremental lifetime cancer risk based on cumulative ingestion and dermal contact
 with soils is 7.8x1 0/6, under a RME scenario, which is within USEPA's target risk range of 1x10"* to
 The cumulative noncancer His for exposure to groundwater for Site 29 under hypothetical residential land
 use conditions are 16.5 for the RME. The HI for the RME exceeds one primarily as a result of the
 ingestion of aluminum, arsenic, iron, and manganese in groundwater.  The RfDs for aluminum and iron are
 not based on any health effects but rather on recommended daily allowances for human nutrition.
 Therefore, the risks for aluminum and iron are overstated. USEPA's risk assessment guidance allows the
 Navy and USEPA to discount risk based on exceeding recommended  maximum daily allowances for
 nutrition.  Additionally, evidence suggests that the arsenic, manganese  and iron occur naturally in the
 ground water at Site 29.  The Superfund law forbids the Navy and USEPA from taking remedial action in
 response to the release of "a naturally  occurring substance in its unaltered form, or altered solely through
 naturally occurring processes or phenomena, from a  location where  it is naturally found." 42 U.S.C. §
 9604(a)(3).   Accordingly,  USEPA's risk assessment  guidance  permits EPA to discount risks that are
 caused by naturally occurring conditions.  A significant portion of the  HI for ground water is due to iron,
 manganese and arsenic.  Background samples of ground water at NWSDL— i.e., ground water samples
 designed to  measure naturally occurring  concentrations  of substances — show that arsenic occurs
 naturally in filtered ground water at concentrations ranging from 0-8 parts per billion (ppb), with average
 background concentrations of 2-4 ppb.  Arsenic was detected at 2.9 ppb in filtered ground water samples
 taken from site 29, which is within the average background concentration range. Thus, it appears that
 arsenic in ground water is due to conditions that occur naturally at NWSDL.  Iron  and manganese
 concentrations are also within the range of background and appear to be naturally occuring conditions.  In
 these circumstances, USEPA and the Navy are permitted to discount risk  due to iron, manganese and
 arsenic in ground  water.   If aluminum, arsenic, iron, and manganese are eliminated as COPCs, the HI
 calculated for the hypothetical resident is less than one. A HI of less than one indicates that there are no
 significant hazards.

 According to the risk assessment, a  person  who  lived at the site for their entire  life would face an
 increased risk, equivalent to 14 chances in 100,000 (1.4 x 1Q-4), of developing  cancer because she drank
 unfiltered ground water.  This risk is very slightly above the upper boundary of USEPA's acceptable risk
 range, 1 x 10"4. USEPA risk assessment guidance, however, states that "The  upper boundary of the risk
 range is not a discrete line at 1 x 10"4 ....   A specific risk estimate around 10"* may be  considered
 acceptable if justified based on site-specific  conditions."   Role of the  Baseline Risk Assessment in
 Superfund Remedy Selection Decisions at pg. 2,  EPA Office of Solid  Waste and Emergency  Response
 (OSWER) Directive 9355.0-30 (April 22, 1 991 ).

 After considering the circumstances of Site 29, the Navy, USEPA and VADEQ have concluded that the
 incremental cancer risk associated with drinking ground water is within acceptable limits.  There are at
 least two reasons for this conclusion.   First, the element arsenic is by far the greatest contributor to the
 incremental cancer risk associated with drinking  ground water at Site 29.  As noted above, however,
 evidence  suggests that the arsenic concentrations in ground water at Site 29 are due to naturally
 occurring conditions.  In these circumstances, USEPA  and the Navy are permitted to discount risk due to
 arsenic  in ground water.  When this is done, the  incremental cancer risk attributable to drinking ground
water at Site 29 is within acceptable limits.

Second, the 1.4 x  10"* figure is based on the assumption that an adult resident would drink unfiltered
ground water for a lifetime. This is unlikely  due to the naturally poor  quality of groundwater, and some
filtration would be necessary. The calculated incremental cancer risk for filtered water at Site  29 is 8.8 x
 10-s, which is within USEPA's acceptable risk range.


                                         2-32

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 Exposure to lead in groundwater (and soil) was evaluated using unfiltered groundwater concentrations
 and maximum soil  concentrations, respectively.  Because of the absence of published  dose-response
 parameters for lead, the exposure and potential risks associated with lead are addressed through the use
 of the USEPA Integrated Exposure Uptake Biokinetic (IEUBK) Model for the child 0-7years old. Based on
 this model, the calculated risk was just equal to the established level of "concern" (10 ug/dL). However
 risk due to lead is overstated based on the following factors:

        •      Maximum lead soil and groundwater concentrations were used in the IEUBK Model rather
               than average concentrations.  If average concentrations were used, the blood lead  level
               would be significantly lower.

        •      Unfiltered metals concentrations were evaluated in the risk assessment.  Lead was not
               detected in filtered samples  collected during the field investigation, indicating turbidity
               (suspended particulates) is influencing the metal concentrations reported for the unfiltered
               samples. An analysis based on filtered samples would not include lead in groundwater
               and the risk would be correspondingly reduced.

 Uncertainty Analysis

 The following sources of uncertainty are specific to post-remedial conditions at Site 29:

        •       Because less than 10 subsurface soil and groundwater samples are available  in the post-
               removal data sets for Site 29, the maximum reported  concentrations were used  as the
               exposure point concentrations. The total risk estimates may be overestimated as a result
               of the evaluation of maximum  concentrations for all COPCs.

        •       The arsenic concentrations in groundwater reflect background (or upgradient) conditions
               (i.e., upgradient and  downgradient concentrations are similar). If arsenic was eliminated
               as a COPC for groundwater, then the total carcinogenic risk estimate for the hypothetical
               future resident exposed to soils and groundwater would fall within USEPA's target risk
               range.

        •       The RfDs for iron and aluminum are not based on any  health  effects  but rather on
               recommended daily allowances for human nutrition.  Consequently, some USEPA regions
               (e.g., USEPA Region I) suggest that quantitative risk assessments not be performed for
               aluminum and iron. If these constituents are eliminated as  COPCs for groundwater, the
               HI for the hypothetical future child and adult residents would be substantially reduced.

Summary and Conclusions

The following items  summarize the results of  a human health risk assessment conducted based on the
post-removal action soil and groundwater databases for Site 29:

        1       His calculated for base workers who are exposed to soil do not exceed one indicating  that
               adverse health effects are  not anticipated under the conditions  established  in  the
               exposure assessment. Cancer risk estimates developed for this receptor are 2.8 X  10*
               and  5.0 X1Q-7 for the RME and Central  Tendency  Exposure (CTE) case, respectively.
               Arsenic is  the primary risk  driver.  However,  arsenic concentrations  appear to only
               marginally exceed  background.   The arsenic concentrations in the Site 29 soils  range
               from 2.38 mg/kg to 7.64 mg/kg (average concentration was 4.2 mg/kg).  The maximum
               arsenic concentration in the background soil data set was 3.3 mg/kg.
                                         2-33

-------
        2.      His calculated for the construction worker exposed to subsurface soil are less than one.
                Consequently,  adverse noncarcinogenic  health effects  are not anticipated for this
                receptor.  Cancer risk estimates for the construction worker do not exceed 1x10*.

        3.      A hypothetical  future resident was evaluated for purposes of completeness.  The His
                calculated assuming exposure to subsurface soil are less than one.   The cancer risk
                estimates developed assuming exposure to soils for the RME and CTE cases (2.2x10's
                and 2.2x1 0* respectively) are within USEPA's target risk range  of 1x10-* to 1x10*.  The
                primary risk driver is arsenic.  However, arsenic concentrations in the Site 29 soils are
                marginally greater than background.

        4.      His were  also developed for a hypothetical future resident using the groundwater as a
                domestic water supply. The HI for the RME resident exposed to COPCs in groundwater
                was 16.5.   The primary risk drivers  were aluminum, arsenic, manganese,  and iron.
                However,  concentrations  of  arsenic,  iron,  and manganese appear  to be  naturally
                occurring. The  RfDs for aluminum and  iron are not based on any health effects but rather
                on recommended daily allowances for human nutrition. The manganese concentration
                reported for the monitoring well located at the source area is less than  the RBC for tap
                water and is less than the concentration reported for a well located downgradient of the
                source area. If aluminum, arsenic, iron, and manganese are eliminated as COPCs,  the HI
                calculated for the hypothetical resident  using the groundwater is less than 1.0.  A HI less
                than 1.0 indicates that there are so significant hazards.

        5.       Cancer risk estimates developed for the hypothetical future resident using groundwater
               were  1.4x10"* for  the RME.   However,  arsenic,  the major carcinogenic  COPC in
               groundwater, was detected at concentrations that appear to be naturally occurring.

        6.      The COPC concentrations reported for the Site 29 monitoring wells do not exceed current
               Federal Safe Drinking Water Act (SDWA)  primary (health-based) MCLs.  Secondary
               (aesthetic-based) standards  for  aluminum,  iron,   and   manganese  are exceeded.
               Additionally, the maximum lead concentration  in  an unfiltered  groundwater sample
               exceeds the current SDWA Action Level  for lead  in  drinking  water.  However, lead
               concentrations in filtered groundwater samples do not exceed the current  SDWA Action
               Level for lead in drinking water, suggesting that turbidity is influencing lead concentrations
               in the unfiltered  sample.  Lead concentrations reported for the unfiltered sample collected
               from the upgradient monitoring well also exceed the SDWA Action Level.  Lead is not a
               pervasive contaminant in soils at Site 29.

The cancer risk estimates for the human  receptors evaluated are within or less than USEPA's target risk
range of 1 X 10"* to 1 X 10"6 and reflect, in part, background or naturally occurring conditions for the site.
The His calculated for receptor exposure to soil are less than one indicating that adverse noncarcinogenic
health effects are not anticipated. The analytical results do indicate that the groundwater quality in the
vicinity of the site may not be suitable for domestic purposes. For the metals that drive the risk estimates,
the pattern of contamination and the aforementioned studies regarding manganese suggest that Site 29 is
not the source of these metal concentrations.  Consequently, site-specific actions may be ineffective in
improving water quality or protecting future potential users.
                                         2-34

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SOILS

The Draft Final Rl for Site 29 indicated metals concentrations in soil were the only contaminant that
warranted remedial action.  Subsequently,  the neutralization pit and adjacent soils were excavated and
disposed of offsite. Sampling data was collected to verify the removal action had achieved its objectives.
This data was re-evaluated in a revised risk assessment.  The revised risk assessment for soil indicated
remaining risks are acceptable. It is recommended that no further action be taken for soils at Site 29.

GROUNDWATER

The risk assessment for groundwater indicates risks are acceptable even though they are at the upper
end of  the acceptable limit.  Site 29  is not the source of the metals that are driving the risk.   It  is
recommended that no further action be taken for groundwater at Site 29 for the following reasons:


        1.     The pattern of groundwater contamination indicates that the Site 29 neutralization pit is not a
              source of the contaminants.

        2.     Arsenic concentrations in downgradient wells (filtered and unfiltered) were slightly less than
              concentrations detected in  the   upgradient well (filtered  and  unfiltered).   Arsenic
              concentrations appear to be naturally occurring.

        3.     Iron concentrations in  downgradient wells  were similar to or less than concentrations
              detected in the upgradient well. Based on this, downgradient iron concentrations are not
              considered significantly different from background  concentrations.  Furthermore, the iron
              concentrations downgradient of Site 29 are considerably less than the maximum basewide
              concentration reported by the USGS.

        4.     Lead concentrations detected in the upgradient well and in GW29-2, which is located at the
              source area, exceeded the SOWA Action Level (15 ng/L) in unfiltered samples. However,
              lead was not detected in filtered groundwater samples from either well and results of the
              IEUBK Model suggest that no action is necessary to protect human health.

        5.     Manganese concentrations detected in GW29-2 (141 ng/l), which is located at the source
              area, were  less than the upgradient concentration (272 ng/l).   It should be noted the
              downgradient concentration (2,600 ng/l) were  higher than the site-specific  background
              concentration.  However, all Site 29 manganese values  are well below the maximum
              basewide concentration reported by USGS (7,000 ng/l).

The pattern of metals detected in shallow groundwater at Site 29 indicates the metals concentrations are
attributable to naturally occurring conditions and not attributable to Site 29.  Based on this, the selected
remedy  for Site 29 is no further action.

2.14          DOCUMENTATION OF SIGNIFICANT CHANGES

The selected remedy is the same alternative identified as the recommended alternative in the Proposed
Remedial Action Plan and that was presented to the public at the public meeting held July 28,1999.

There were no significant changes to the recommended remedial action alternative in the Proposed Plan.
                                          2-35

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        2-36

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                          3.0  RESPONSIVENESS SUMMARY
No written comments, concerns, or questions were received by the Navy, USEPA, or the Commonwealth
of Virginia during the public comment period from July 21, 1999 to August 19, 1999. A public meeting was
held on July 28, 1999 to present the Proposed Plan for Site 19 and Site 29 soils and groundwater and to
answer any questions on the Proposed Plan and on the documents in the information repositories. A 30-
minute presentation was provided during which informal questions were addressed.

A summary of the questions (and responses) that were asked  at the public meeting is provided in
Appendix B.

3.1            BACKGROUND ON COMMUNITY INVOLVEMENT

The Navy and NSWCDL have had a comprehensive public involvement program  for several years.
Starting in 1993, a Technical Review Committee (TRC) met, on average, twice a year to discuss issues
related to investigative  activities at NSWCDL.   The TRC was composed of mostly  governmental
personnel; however, a few private citizens attended the meetings.

In early 1996 the Navy  converted the TRC into a Restoration Advisory Broad (RAB) and eight to ten
community  representatives  joined.  The RAB is co-chaired by  a community member and has held
meetings  approximately  every 4 to 6 months. The RI/FS and the Proposed Plan for Site 19 soils and
Site 29 soils and groundwater were both discussed at the RAB meetings.

Community relations activities for the final selected remedy include:

       •       The documents concerning the investigation and analysis at Site 19 and 29, as well as a
              copy of  the Proposed Plan, were placed in the information repository at the NSWCDL
              General  Library and the Smoot Memorial Library.

       •       Newspaper announcements on the availability of the documents and the public comment
              period/meeting date was placed in The Journal on July 14, 1999 and the Freelance Star
              newspaper on July 19,1999.

       •       The Navy established a 30-day public comment period starting July 21, 1999 and ending
              August 19, 1999 to present the Proposed Remedial Action Plan. No written comments
              were received during the 30-day public comment period.

       •       A Public Meeting was held July 28, 1999 to answer any questions concerning the Site 19
              and 29  Proposed Plan.  Approximately  10 people,  including Federal, state, and local
              government representatives attended the meeting.
                                            3-1

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            3-2

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        APPENDIX A




VIRGINIA CONCURRENCE LETTER

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SEP,-23'99fT}JU)  13:17   DEQ                              TEL:8046984234                    P.003
                        COMMONWEALTH of VIRQINIA
                          DEPARTMENT OF ENVIRONMENTAL QUALITY
        Governor               S*r««f***wfi29 Butt Miin Sntei, Riciunood. Virginia 23219
                             Mailing aUna: P.O. Box 10009. Richmond, Vfaginim 23240                  (104) 60MOOO
    Joh«P-Wcxxfcy J,                  Ftt(W4)69W50fl  TDD (104) 69*^021                        1-IOO.S9M4C
  ScacttyorNaunlRi^urcci                     taQ»rf/www.dcq.«ie.vttts


                                         September 23,1999

           Mr. Abraham Ferdas, Division Director
           Hazardous Site Cle;inup Division (3HSOO)
           U.S. Environmental Protection Agency, Region m
           1650 Arch Street
           Philadelphia, PA 19103-2029


           Re:   Record of Decision for Site 19 (Soil) and Site 29, NSWC Dahlgren, Virginia

           Dear Mr. Ferdas:

                 The Virginia Department of Environmental Quality staff has reviewed the Record
           of Decision ("ROD'1) for Site 19 - Transformer Draining Area (Soils), and Site 29 -
           Battery Service Area (Soils and Groundwater), at the Naval Surface Warfare Center,
           Dahlgren, Virginia. On behalf of the Commonwealth of Virginia, we concur with the
           selected remedial alternatives as outlined in the ROD dated September 1999.

                 Should you have any questions concerning this letter, please feel free to contact
           Dave Gillispie at (804) 698-4209.

                                                 Very truly yours,
                                                 Erica S. Dameron
                                                 Director, Office of Remediation Programs
           cc:    Ryan Mayer, ChesDiv
                  Ann Swope. NSWC Dahlgren
                  Bruce Beacli, EPA Region m
                  Hassan Vakili,VDEQ
                  Durwood Willis, VDEQ
                  Dave Gillispie, VDEQ
                               An Agency of the Natural Resources Secretariat

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   APPENDIX B




PUBLIC COMMENTS

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                                      APPENDIX B

          SUMMARY OF QUESTIONS FROM 28 JULY 99 PUBLIC MEETING

Site 19

Have we found any contaminants in the groundwater?

Polychlorinated Biphenyl's were not found in groundwater sampling; however, groundwater investigations
have indicated several metals  which have  exceeded U.S. EPA Region  III  screening criteria (i.e..
aluminum, arsenic, barium,  beryllium and vanadium),  and  maximum contaminant levels (MCLs)  for
beryllium and lead.  Organic compounds, specifically phthalates were detected,  however, none were
above MCL's and one (dibenz(a.h)anthracene) was above a screening level.  The final assessment for
groundwater will be done in conjunction with a nearby adjacent site (Site 40) in the near future.

Where is Site 19  relative to other buildings?

Site 19 is located in the south-central portion of the NSWCDL property, approximately 150 feet east of
Caskey Road.  Building 120B Defense Reutilization and Marketing Office (DRMO) lot is located nearby
on the northeast portion of the site. The outside storage area of the DRMO lot is designated as Site 40.
Site 40 is planned for investigation as outlined in the Site Management Plan.  A temporary clinic is located
southeast of the site approximately 200 feet away.

Site 29

Has there been any indications of heavy metal contamination at this site?

Soil samples collected indicated the  following contaminants;  antimony, arsenic,  iron, lead, mercury and
total petroleum hydrocarbons. These contaminants were excavated during a Removal Action conducted
in 1997.  These  contaminants were removed  to the target cleanup levels, except for arsenic.  It was
determined that remaining arsenic levels were safe and similar to background levels.

Where were excavated soils taken during the Removal Action of the site?

Soil from Site 29  was excavated and transported to the permitted King & Queen Landfill located in Little
Plymouth,  Virginia for disposal.
                                            B-1

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                             NAVAL SEA SYSTEMS COMMAND

                           NAVAL  SURFACE WARFARE CENTER
                                 DAHLGREN DIVISION
                                   PUBLIC MEETING
              THURSDAY, JULY  28,  1999,  7:00 P.M.
                 KING GEORGE COUNTY COURTHOUSE
                     KING GEORGE, VIRGINIA

                 PROPOSED REMEDIAL ACTION PLAN
              Site  19, Transformer Draining Area
                 Site 29,  Battery Service Area
                 Site 25,  Pesticide Rinse Area
USEPA Reg:.on  III
Hazardous Site  Cleanup Division
Federal Facilities Section
Mr. Bruce Beach
1650 Arch.Street.  Philadelphia, Pennsylvania 18107

Virginia Department of Environmental Quality
Mr. David Gillispie
629 East Main Street.  Richmond. Virginia 23219

Public Affairs  Office
Commander,  Naval  Surface Warfare Center
Ms- Jennifer  Wilkins
17320 Dahlgren  Road, Mail Code CD06 Dahlgren, Virginia  22448
                         Reported by:  Lola Gail  Serrett
                   FRANCES K. HALEY & ASSOCIATES, Court Reporters
              10500 Wakeman Drive,  Suite 300, Fredericksburg. VA 22407
                     PHONE:  (540)898-1527    FAX:  (540)898-6154
                          8T
                                        CCt ZOZ IVd €2:SO IHJ  66/02/80

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July 28, :.999:

                         MS. SWOPE:  Good evening. everyone.

          I want to welcome you tonight to our public meeting

          that we're having for the public comment period

          which announces proposed remedial actions for three

          sites at the Naval Surface Warfare Center, that the

          Navy, the Commonwealth of Virginia and the

          Environmental Protection Agency have choaen as the

          proposed plans that we would like to remediate these

          sites with.   We're going to present a brief synopsis

          of that action to you tonight.   You have -- some of

         .you have seen copies of the documents.   They went

          down to the  RAB members.   They're also in the Smoot

          Library and  the Dahlgren Library and we have copies

          on base,  if  you'd like to  see it.   The information

          is on the back on how to contact us with more

          questions.   Yeah,  they're  in the back o£ the room.

                              Also,  I want to introduce to

          Dave Misenhimer.  He works  for  Tetratech,  NUS.   He's

          going to do  the presentations tonight.   He is

          probably the chief  member of  our contracting team
             FRANCES K.  HALEY & ASSOCIATES,  Court Reporters
       10500 Wakeman Drive,  Suite  300,  Predericksburg,  VA 22407
               PHONE: (540)898-1527   FAX:  (540)898-6154
               «T
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that does all our investigations  for us and most of

the design work, all of his Tetratech teams.  So,

Dave, I'll let you take it away.

               MR. MXSENHIMER:  Okay.

               MS. SWQPE:  Oh,  one  more thing.  I'm

sorry.  Just so you know, this  is -- we have a court

reporter here.  We're recording everything tonighfc.

Your comments are welcome, but  we want to document

those comments BO we properly respond to your

comments since this is a public comment period.  So.

feel free to interject whenever you have a question,

concern or need clarification.

               MR. MISENHIMER:  Thank you.  Okay.

This machine is just beginning  to warm up.  But as

Ann just said, there's two documents that are in the

back of the room there.  The  first  one deals with

two sites; Site 19 and Site 29.   And I'm going to go

through Site 19 first, followed by  Site 29.  The

second document deals with Site 25  entirely.

               MS. SWOPE:  That'B reversed.

               MR. MISBNHIMER:  I don't know what
                  PRANCES  K.  HALEY & ASSOCIATES,  Court Reporters
             10500 Wakeman Drive,  Suite 300,  Fredericksburg, VA 22407
                     PHONE: (540)898-1527   FAX;  (540)898-6154
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    happened here.  Let•a try this again.

                   MS. SWOPEi  It was working

    beautifully, too.

                   MR. MISENHIMER:  Yeah,  it was

    working.

                   MR. FUSCAXiDO:  You got  a  discount

    because it's upside down.

                   MS. SWOPS:  Exactly.  You can ahow

    the location on the map.

                   MR. MISENHIMER:  Yeah.  The three

    sites that we're dealing with -- Site  19, is located

    right here.   This is main aide,  here's 301.  the

    Potomac River,  Upper Maohodoc Creek.  So, Site 19  is

    kind of on the  south aide of main side.  Site 29 is

    a little further south,  over here.   And Site 25  is

    located on the  drain  swell here  that feeds into

    Upper Machodoc  Creek.

                       Now.  it's working.   Okay.  I

    don't know what happened.  Anyway,  so we're going to

    staz-t out  with  Site 29 -- Site 19.   And both, Site

    19  and 29, are  grouped together because these are
                 FRANCES K. HALEY £ ASSOCIATES, Court Reporters
            10500 Hakeman Drive, Suite 300, Fredericksburg,  VA 22407
           	  PHONE:  (540J898-1527    FAX: (540)898-6154
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    two sites where we did some remedial action in the

    past and we're proposing that no  further action be

    taken upon those two sites; whereas.  Site 25. we

    have not done any remedial action to date and we are

    proposing to do some remedial action.   That's what

    we'll be focusing on today.

                        So. at Site 19,  this was a

    transformer draining area.  Transformers were

    drained on the ground and transformer oil typically,

    in the days when thie occurred, had  PCB oil in the

    transformers.  PCBs were found to be  a human health

    risk and they were present in the soil where the

    transformers were drained.  So, in 1994,  the PCB

    contaminated soil was removed.

                   MS.  SWOPE;   This site is right south

    of the sea plane hangar.

                   MR.  MISENHIMER:  Here's an aerial

    photo of the site.   This area in red is Site 19.

    It's adjacent to Site 40,  which is another site  that

    is currently under investigation in the Installation

    Restoration Program at Dmhlgircn.   And  there's some
                 PRANCES K. HALEY  & ASSOCIATES,  Court Reporters
            10500 Wakeman Drive, Suite  300,  Frederickuburg,  VA 22407
            	   PHONE:  (540)698-1527   FAX:  (540)893-6154
                         «T
                                             STOi CE* SO! XVd 52=80 IHJ  66/02/80

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    concrete pads, here, where they stored the


    transformers and this is generally  the area where


    transformer oil was dumped.  This area,  in general,


    is fairly flat, so anything that was  dumped out here


    didn't really move too far.  Groundwater generally
                                                   \

    flows in this direction, to the east.  And


    approximately a thousand gallons of transformer oil


    were dumped there in th« past -- drained there in


    the past.


                        Here's a site photo.   In fact,


    the concrete pad I pointed out to you is  right here.


    Here's  a monitoring well.   The area where


    transformer oil was drained ie over in this  area  and


    this is the area where,  in 1994, the contaminated


    soil was removed.   Th« area that was -- where  the


    removal occurred was about twenty-five feet by


    seventy feet, in length  and width.   And the soil was


    removed down to a depth  of approximately two feet.


    So,  there were  about a hundred and seventy-seven


    cubic yards  of  soil that were  removed, in total,


    from the site.  The target  cleanup level for the PCB
                 FRANCES K.  HMJSY & ASSOCIATES, Court Reporters
           10500 Wafceman Drive,  Suite 300,  Fredericksburg,  VA 22407
                   PHONE; (540)898-1527   FAX:  (540)898-6154
                        8T apoo saqo yjg
                             8TOi ECt ZOZ IVd
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contaminated soil was a residential land use value

that US EPA has established,  which is one part per

million.  And cleanup was  sueeeaaful in getting all

the contaminated soil out  of  there and verification

sampling verified that we  did reach that level.

               MR.  FUSCALDO;   I mean, have the

monitoring wells picked up anything?

               MR.  MISENHIMER:  No, there's

really -- well, one thing  I  should -- this is what I

want to point out here.  In terras of groundwater,

because we have Site 40 very close by and that site

is being investigated. we  decided to address

groundwater with that adjacent site when we look at

that site.  It didn't make a lot of sense to try and

break one area up from the other.  So --

               MS.  SWOPE:   (interjecting) But we

have not found PCBs in the groundwater.

               MR.  MISENHIMBR:  Right.

               MR.  FXJSCALDO-.  The clinic is there

someplace now,  isn't it?   The temporary clinic.

               MS.  SWOPB:   Yes.
                  FRANCES K.  HALEY & ASSOCIATES,  Court Reporters
             10SOO Wakeman Drive,  Suite 300,  Fredericksburg, VA 22407
                     PHONE: (540)696-1527   PAX:  (540)898-6154	
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                   MR.  FUSCAiDO:   Where is that on

    this  --in relation to --

                   MS.  SWOPE:   You go back to the --

    hang  on. I'll show  him.  Qo back to the aerial

    photo,  it is right -- right  in here.

                   MR.  FCSCALDO:   Okay.   All right.

                   CAPTAIN MAHAFFEY:   That's a new

    building.

                   MS,  SWOPS:   Yeah.

                   MR.  MISENHIMER:   So.  what we're

    proposing today ia  that the removal  or cleanup that

    occurred in 1994 wae sufficient  and  that no further

    action is required  for the  soils  in  that area,  and

   .the groundwater,  again, ae  I  said, be  evaluated with

    an adjacent site.  And that's pretty much all I waa

    going to say about Site 19.  Are  there any

    quostione?

                   MR. FUSCALDO:  And Site 40.  what  was

    that again?

                   MS. SWOPS:  That's  a  storage lot,

    scrap metal.
                 PRANCES  K.  HALEY & ASSOCIATES,  Court Reporters
            10500 Wakeman Drive,  Suite 300,  Predericksburg, VA 22407
           	PHONE; <540) 898-1527   PAX:  (540)898-6154
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                MR. MISENHIMER:  Now,  let's see if I

 can pull it up.  Okay.  Site 29 is the  second site

 we want to talk about today.  This is an  area where

 an unlined neutralization pit received  battery acid

 from an area about where batteries were drained.

 And in 1995,  our remedial investigation suggested

 that there were human health risks, potential risks

 with heavy metals in the soils,  so in 1997, the

 neutralization pit and all the soil that surrounded

 that neutralization pit  was removed.   Here's  an

 aerial photo.   This area in red,  within this  area

 here is where  the  neutralization pit  was located and

 it's —

                MS.  SWOPfi:   (interjecting)  It's the

 corner between  the  heavy duty  shop  and the battery

 shop, behind it, toward  the  community house.

               MR. MISENHIMER:  And the  surrounding

soil, which was removed.  Just south  of  the site is

a cooling pond.  The cooling pond, which is also

known as Site 55, is another installation

restoration site which is currently under  investi-
                FRANCES K. HALEY  & ASSOCIATES,  Court  Reporters
           10500 Wakeman Drive, Suite  300,  Frederieksburg,  VA 22407
                   PHONE;  (540)896-1527   FAX;  (540)898-6154
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    gation.  These buildings are  in  the transportation

    area and there's a lot of activity that goes on

    around there related to transportation,  and public

    works.

                        Here's a  site  photo.  The area

    that we have highlighted in red  is essentially this

    area in here.  The neutralization  pit  is under-

    ground.  It was covered over  some  years ago and

    covered with asphalt paving and  -- so.  we had to dig

    that up to find the neutralization put  and remove

    any contaminated soil that surrounded  it.

                   MR. FUSCAUJO:  Now,  I remember

    this -- I don't know how many -- how many meetings

    ago it was that -- when this  thing waa  detailed.

                   MS. SWOPE:  When  we did  the work?

                   MR. FUSCALDO:  And  I'm  just kind of

    wondering how -- how that's turned out,  you know,

    has there been any other indications of heavy metal

    contamination in there?

                   MR. MISENHIMER:   Well, what we did

    was the area that was excavated  here was an area
                  FRANCES K. HALEY fc ASSOCIATES, Court Reporters
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                     that  encompassed about twenty-two feet by about

                     thirty-eight feet.   Me went down seven feet.   Before

                     we  got started,  we had some preliminary goals  in

                     terms of what kinds of levels were acceptable  for

                     metals in the soils.  So,  as we went along, we

                     sampled the soil.  If we weren't meeting our goal,

                     we  dug some more out until we got. to the point where

                     we  felt we were okay.  After that was completed and

                     the sampling data came back, then we looked at the

                     human health risks.  We'd run the numbers  that you

                     typically do to evaluate human health risks and

                     based on that analysis, it was determined  that the

                     soil was fine, as well as the groundwater  on  this



                                    MS. SWOPE:  When we removed that, we

                     removed a couple of oil separators that were  old, an

                     old oil tank.

                                    MR. MISENHIMERs  Right,  right.   Yes.

                                    MS. SWOPE:  There was  a  lot of things

                     in th« ar*a,  so  w« got rid of it all  together.

                                    MR. FOSCALBO:  I remember it was a
                   FFANCES K. HALEY & ASSOCIATES, Court Reporters
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    real bad eite.

                   MS. SWOPE:  Right.

                   MR. FUSCALDO:  Like meet  of that old

    stuff is.

                   MR. MISENHIMER:  Okay.  So,  the

    contaminants that we were concerned about  are  listed

    up here;  antimony, arsenic, iron, lead and mercury.

    So,  as I  said,  when the soil was removed,  we took

    samples and these were the things that we  were

    checking-  on.  And then,  when we did the risk

    assessment, we  did it  baaed on these contaminants.

                        So,  in summary,  we feel that

    there's no  need for any  further action on the soils

    at Site 29  and  that, based on our evaluation of

  .groundwater, there's no  need  for any action with

   groundwater.  The  groundwater is fine  and we believe

   that we're done with this  site,  essentially.  Yes?

                  MS. VAN DB WBERT:   you  keep saying

   the soils were removed.  Where are they taken  to?

                  MR. MISENHIMER:   Oh, okay.

                  MS. VAN DE WEERT-.  Landfills?
                FRANCES K.  HALEY & ASSOCIATES,  Court Reporters
           10500 Wakeman Drive,  Suite  300,  Predericksburg, VA 22407
                   PHONE;  (540)898-1527   FAX:  (540)898-6154
                        8T
                                            8TOI CC» 202 Tfd 82=80 IHd  66/02/80

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               MR. MISEKHIMER:   Yea.   They're taken

off-site to a landfill.

               MS. SWOPE;   Actually --

               MR. FUSCALDO:   (interjecting) Well.

it's an incinerator,  isn't  it?

               MS. SWOPE;   The  PCB -- the PCS

soil -- this soil went to a. cement kiln, brick kiln,

I think.  And then,  the  PCB soil went to one of very

few PCB facilities that  either  landfill it or bum

it, depending on the concentration of PCBs.  And

they verify that when they  get  it there.  There are

very few that will accept that.   It went out west by

train.

               MR- FUSCALDO:  It just doesn't get

moved sonwwher* «lsa to  ba  somebody else's problem?

               MR. MISENHIMER:   No.

               MS. SWOPE:   Right.  But the primary

thing here were -- essentially,  any time you've got

petroleum type products, it ends up being burned in

a brick kiln a lot of times,  BO you get some

valuable use out of  it.
                  FRANCES  K. HALEY & ASSOCIATES,  Court Reporters
             10500 waketnan Drive,  Suite 300,  Frederieksburg, VA 22407
                     PHONE: (540)898-1527   FAX:  (540)B9B-6154	
      «T
                                     VdH
                                               8TIH CE* ZOZ IVd 82:80 IHd 66/02/80

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                MR.  MISENHIMER:  Any more questions?

 Okay.   Our next site is Site 25, known as the

 pesticide rinse area.  And this ie an area where

 pesticide containers were rinsed outside and the

 containers were then -- whatever was left waa

 spilled on the ground.   And also,  inside a building,

 there  was a slop sink where containers were rinsed

 and  thie slop sink  drained into a freneh drain.  Our

 remedial investigation  suggested there were human

 health and ecological concerns from pesticides and

 heavy  metals in the soil and in the sediment.

                     This is an aerial photo and it

 showB  you building  134,  right here.  This is the

building where  the  slop sink was located and this is

 the  freneh drain, so material would drain out  here

and  infiltrate  into the ground.  The other area

where  the container* were  rinsed was out in this

area,  here,  and whatever was  lefc  in the container

was  then dumped on  the  ground out  here,   So, in our

investigation,  we were  concerned about the  freneh

drain  and any movement  of  any of the contaminants.
                 FRANCES K. HALEY  & ASSOCIATES, Court Reporters
            10500 Wakeman Drive, Suite 300, Fredericfcsburg,  VA 22407
                    PHONE:  (540)898-1527   FAX: (540)898-6154
                         ST apoo sstp
                          8TOZ CC» ZOZ Tfd 62=80 IHH  66/02/80

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the pesticides that may be present  there.   And then,

this area, here, where we know things  were dumped or.

the ground.

                    The other thing I  guess 1 wanted

to point out on this slide is that  this  is a

drainage through here .  It' a kind of an  intermittent

drainage way and it is -- a good portion of this has

been delineated as a wetland area.

                    Upgrade, here,  is  the cooling

pond, just to relate back to Site 29.  Site 25 is

somewhere over in this direction.   The cooling ponds

are over here.  And this is Site 25.   So,

ultimately, any overland flow drains down in this

direction and into the Upper Machodoc  Creek.

                    This is a site  photo.   Looking

towards the Potomac River and Upper Machodoc Creek

over in this direction.  This is part  of the wetland

area in here and this is a monitoring  well.

                    Now, this diagram  shows what the

preferred alternative is and it may be difficult to

see this in the back there, but on  the handout, this
                  FRANCES K. HALEY  & ASSOCIATES,  Court  Reporters
             10500 Wakeman Drive, Suite  300,  Fredericksburg,  VA 22407
                     PHONE:  (540)898-1527   FAXi  (540)898-615*	
                          8T
                              m zoz rvd 62:90 IHJ es/oz/so

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    little handout here,  it might  be easier to follow.

    There's a green, line  here  that outlines the wetland

    area and then, this solid  line,  here,  outlines the

    area where we're proposing to  excavate the

    contaminated soil and haul that  off-site for

    disposal at a landfill.

                        There  are  also  some hot spot

    areas identified.  Here's  one.   Here's another one.

    And then, the french  drain area,  which would also be

    excavated and hauled  off-site  for disposal.  In this

    case, the material that would be hauled off would go

    to landfill and Used  as a  daily  cover  at a landfill.

    The levels of contaminants are not  that high that it

    would require any creatment prior to going to a

    landfill.

                        After  this area, here,  is

    excavated,  we're talking about going down to a depth

    of about two feet.  In some hot  spot areas

    identified here,  we might be going  dawn as  far as

    four -- four or fiv« f««t.   This  area  would then be

    regradad to -- back to the •scisting area and the
                    FRANCES X. HALEY & ASSOCIATES, Court Reporters
               10500 wakeman Drive, Suite 300, Fredericksburg, VA 22407
                      PHONE:  (540)898-1527    FAX:  (540)898-6154
•56
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wetland area would be reestablished.

                    So. the preferred alternative is

that we remove all the contaminated  soil.

reestablish the wetland, we're going to send the

contaminated soil to an off-site  landfill.   And

because of this, we would have a  situation where no

long term monitoring of the site  would be necessary

because we're removing all the contaminated soil.

                    Any questions on Site 25?

               MR. FUSCALDO:   I guess r-- yeah, how

do you -- how do you determine that  you removed all

the contaminated soil?  That's a  hard thing to do at

a site like that, isn't it?

               MR. MISENHIMER:  Okay.  That's a good

question.  Whenever we do any excavation like this,

part of the project is to verify  what you have left

after you've taken this out,  the  soil that's left is

clean.  And so. a verification sampling plan ia

prepared  and then we go ahead and take samples.  So.

as you're excavating this, we will typically grid

thia  area off  and then take  camplee at different
                   FRANCES K. HALEY t ASSOCIATES, Court Reporters
              10500 wakeman Drive, Suite 300, Fredericksburg, VA 22407
                     PHONE;  (540)898-1527    PAX:  (540)898-6154	
                           8T
                                               9102. CC» ZOZ Tfd 06 = 80 IHH 66/OZ/80

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point* and based on, those sampling results,  we'll
decide, okay, is it okay or  do we  need to remove
some more soil.
               MR. FUSCALDO:  How  do you work that
site when it's so wet in there.
               MS. SWOPB:  We could it right now.
               MR. FUSCALDO:  Okay.
               MR. MISENHIMBR:   That's a good point.
               MR. FUSCALDO:  That gives me an
indication.  Okay,
               MR. MISENHIMER;   But one of the
things that we take into consideration is really the
time of year in which we're  trying to work.  We'll
try to make sure it's during a  dry period.  You
know, there's no guarantees  on  that, as you well
know.  But apparently --
               MR. FUSCALDO:   (interjecting) August
is supposed to be pretty wet.
               MS. SWOPE:  These are all proposed
that we would do the work  next  fiscal year, so it
will happen  in  2000.
             FRANCES K. HALEY & ASSOCIATES, Court  Reporters
        10500 Wakeman Drive, Suite 300, Predericksburg,  VA 22407
                PHONE:  (540)898-1527   FAX: (540)698-6154
                     8i apoo saqo
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                                     MR.  FUSCALDO:  Okay.  All right.

                                     MS.  SWOPE:   And the other thing is

                      that when we remove that,  we'd like to increase the

                      wetland capacity there and make it even more

                      beneficial aa wetland and not replace -- you know,

                      not have to haul in clean dirt, just regrade and

                      make it a better wetlands.

                                     MR.  FUSCALDO:  Good idea.  Good idea.

                                     MR.  MISENHIMER:  Any other questions?



                                     MS.  SWOPE:   Do we want to have a

                      formal comment period.  You know,  I'll take another

                     .minute for you to ask more questions that will be

                      recorded and after that,  we'll cut off the recorder.

                      We have refreshments and you can ask us eome more

                      questions that you'd rather not be recorded.

                                     MR.  FUSCALDO:  I'm personally

                      finished.

                                     MS.  SWOPE:   Okay.  Patty, do you have

                      any more questions?

                                     MS.  VAN DE WEERT:  No.
                   PRANCES X.  HALEY & ASSOCIATES,  Court Reporters
               10500 Wakeman Drive.  Suite 300,  Fredericksburg,  VA 22407
                      PHONE: (540)898-1527   FAX:  (540)898-6154	
:OIB
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                MS. SWOPE:  Anyone?   Captain?

                MR. MISENHIMER:  One  thing that I

 guess should be mentioned is that the  comment

 started last Wednesday.

                MS. SWOPE:  It was announced in the

 Free Lance.

                MR. MISENHIMERt   Right.  And it goes

 for thirty daya and the comment period ends

 August  --

                MS. SWOPE:  19th.

                MR. MISENHIMBR:   August 19th.

                MS. SWOPEs  So,  you are welcome  to

 submit written comments Co the  locations on the back

 anytime before August  19th.   If you think of

 something elBO or  you  pass the  information to

 someone who has questions,  we welcome any questions

or comments.   Anybody  else?  We'll  officially close

the comment period then.
                                       MEETING CONCLUDED AT 7:32 P.M.
                FRANCES K. HALEY & ASSOCIATES, Court Reporters
           10500 Wakeman Drive, Suite 300, Predericksburg,  VA 22407
          	    PHONE:  (540)898-1527    PAX:  (540)898-6154
                       8T epoo
                         8TOZ CC* ZOZ
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08/20/99   07:13
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                            CERTIFICATE OP COURT REPORTER



                     I,  Lola Gail Searrett, hereby certify that  I  was the

          Court  Reporter at the Public Meeting held at King George

          Courthouse,  King George, Virginia,  on July 2S,  1999, at  the

          time of the meeting herein.

                     I further certify that  the foregoing transcript is J

          true and accurate record of the proceeding herein.

                     Given under my hand  this  3lst day of July, 1399.
                                                    I OLA GXL SERRETT
                                                    /Court Reporter
           PILE:   PO'.'2899L.HRG
                   FRANCES K. HALEY & ASSOCIATES,  Court Reporters
              10500 Wakeman Drive, Suite  300,  Fredericksburg, VA 22407
                      PHONE:  (540)898-1527   FAX:  (540)898-6154
                     8T
                                     Vdta
                                          8TOZ CC» ZOZ TVi Ze:«0  IHd  66/02/80

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   APPENDIX C




TOXICITY PROFILES

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                                       APPENDIX C

                      TOXICITY PROFILES - DAHLGREN, SITE 19
ALUMINUM

Aluminum is not generally regarded as an industrial poison. Inhalation of finely divided powder has been
reported as a cause of pulmonary fibrosis.  Aluminum in aerosols has been  implicated in Alzheimer's
disease. As with other metals, the powder and dust are the most dangerous forms. Most hazardous
exposures to aluminum occur in refining and smelting processes. Aluminum dust is a respiratory and eye
irritant.  The USEPA has published an oral RfD of 1.00 mg/kg/day (IRIS) and an inhalation reference dose
of 0.001 mg/kg/day (HEAST, 1997) for aluminum.

AROCLOR 1260

Hepatotoxicity is a prominent effect of PCBs, including Aroclor 1260, that has been well characterized.
Effects include hepatic microsomal enzyme induction, increased serum levels of liver-related enzymes
(indicative  of  hepatocellular damage), liver  enlargement,  lipid  deposition,  fibrosis, and  necrosis.'
Chloracne and Immune function disorders have been observed in humans and several animal species
after PCB exposure.  Reproductive and developmental effects,  including low-birth weight, and decreased
gestational  time,  and decreased reproductive  capacity, have been observed  in human  and animal
species.

Data  are  suggestive  but  not  conclusive concerning  the  carcinogenicity  of PCBs  in  humans.
Heptatocellular carcinomas in three strains of rats and two strains of mice have led the EPA to classify
PCBs as group 62, probable human carcinogen.

ARSENIC

The toxicity of inorganic arsenic (As) depends on its valence state (-3, +3, or +5), and also on the physical
and chemical properties of the compound in which it occurs. Trivalent (As+3) compounds are generally
more toxic than pentavalent (As+5) compounds, and the more water soluble compounds are usually more
toxic and more likely to have systemic effects than the less soluble compounds, which  are. more likely to
cause chronic pulmonary effects if inhaled.

The Reference Dose for chronic  oral exposures,  0.0003 mg/kg/day, is based on a NOAEL of 0.0008
mg/kg/day and a LOAEL  of 0.014 mg/kg/day  for hyperpigmentation, keratosis, and possible vascular
complications in  a human population  consuming arsenic-contaminated drinking water.  Because of
uncertainties in the data,  U.S. EPA states that "strong scientific arguments can be made for various
values within a factor of 2 or 3 of the currently recommended RfD value."  The subchronic Reference
Dose is the same as the chronic RfD, 0.0003 mg/kg/day.

Epidemiological studies have revealed an association between arsenic concentrations in drinking  water
and increased incidences  of skin  cancers (including  squamous cell carcinomas and multiple basal cell
Carcinomas), as well as cancers of the liver, bladder, respiratory and gastrointestinal tracts. Occupational
exposure studies have shown a clear correlation between exposure to arsenic and lung cancer mortality.
U.S. EPA has placed  inorganic arsenic in weight-of-evidence group A, human carcinogen.

CHROMIUM
                                                          *
In nature, chromium  (III)  predominates  over chromium (VI).   Little chromium  (VI) exists  in biological
materials, except shortly after exposure, because reduction to chromium (III) occurs rapidly. Chromium
(III) is considered a nutritionally essential trace element and is considerably less toxic than chromium (VI).
                                             C-1

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 Acute  oral exposure of humans to high doses  of chromium  (VI) induced  neurological  effects  Gl
 hemorrhage and fluid loss, and kidney and liver effects. An NOAEL of 2.5 mg chromium (VI) /kg/day'in a
 one-year drinking water study in rats and  an uncertainty factor of 300 was the basis of a verified RfD of
 0.003 mg/kg/day for chronic oral exposure. An NOAEL (No effects were observed in rats consuming  5%
 chromium (lll)/kg/day in the diet  for over two years) of 1,468  mg/kg-day for chromium (III)  and  an
 uncertainty factor of 100 was the basis of the RfD of 1.5 mg/kg/day for chronic oral exposure.

 Occupational (inhalation and dermal) exposure to chromium (III) compounds induced dermatitis.  Similar
 exposure to chromium  (VI) induced ulcerative and allergic contact dermatitis, irritation of the upper
 respiratory  tract including ulceration of the mucosa and perforation of the nasal septum and possibly
 kidney effects.

 A target organ was not identified for chromium (III).  The kidney appears to be the principal target organ
 for repeated oral dosing with chromium (VI).  Additional target organs for dermal and inhalation exposure
 include the skin and respiratory tract.

 IRON

 No toxicity information available.  The RfD for iron "(0.3 mg/kg/day is based on allowable  intakes rather
 than adverse effect levels.

 MANGANESE

 Manganese is an essential trace element  in humans that can  elicit a variety of serious toxic  responses
 upon prolonged exposure to elevated concentrations either orally  or by inhalation.  The central nervous
 system is the  primary target. Initial symptoms are headache, insomnia, disorientation,  anxiety, lethargy,
 and memory loss.  These symptoms progress with  continued exposure and eventually include motor
 disturbances,  tremors, and  difficulty in walking, symptoms similar to those seen with Parkinsonis.m.
 These motor difficulties are often irreversible.

 Effects  on reproduction (decreased fertility, impotence) have been observed in humans with inhalation
 exposure and in animals with oral exposure at the same or similar doses that initiate the central nervous
 system effects.  An increased incidence  of coughs,  colds, dyspnea during exercise, bronchitis, and
 altered lung  ventilatory parameters have also been seen in humans and animals with inhalation  exposure.

 A chronic and subchronic RfD for drinking water has been calculated by EPA from a human no observed
 adverse-effect level (NOAEL).   The NOAEL was determined from an epidemiological study  of  human
 populations exposed for a lifetime to manganese concentrations in drinking water ranging from 3.6-2300
 pg/L A chronic and subchronic RfD for dietary exposure has been calculated  by  EPA from a  human
 NOAEL which was determined  from a series of epidemiological studies. A reference concentration (RfC)
 for chronic inhalation exposure was calculated from a human LOAEL for impairment of neurobehavioral
 function from an epidemiological study.

VANADIUM

Vanadium is a metallic element that occurs in  six oxidation states  and numerous inorganic compounds.
Vanadium is used primarily as an alloying agent in steels and non-ferrous metals. Vanadium compounds
are also used as catalysts and in chemical,  ceramic or specialty applications. Vanadium compounds are
poorly absorbed through the gastrointestinal system but slightly more readily absorbed through the lungs.
Absorbed vanadium is widely distributed in  the body, but short-term localization occurs primarily in bone,
kidneys, and liver.

The  toxicity  of vanadium depends  on' its physico-chemical state  particularly on its valence state and
solubility. In animals,-acutely toxic oral doses cause vasoconstriction, congestion and fatty degeneration
of the liver, congestion and focal hemorrhages in the lungs and adrenal cortex. Minimal effects seen after
subchronic  oral  exposures  to animals  include diarrhea, altered  renal  function,  and decreases   in
                                             C-2

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erythrocyte counts, hemogloblin, and hematocrit . In humans, intestinal cramps and diarrhea may occur
following subchronic oral  exposures.   the£e studies  indicate  that  for subchronic and chronic oral
exposures the primary targets are the digestive system, kidneys, and blood.

The reference dose (RfD) for chronic oral  exposures to vanadium is  0.007  mg/kg/day.   Inhalation
exposures to vanadium and vanadium compounds result primarily in adverse effects to the respiratory
system.  There is little evidence that vanadium or vanadium compounds are reproductive toxins  or
teratogens.  There is also no evidence that any vanadium compound  is carcinogenic; however, very few
adequate studies are available for evaluation. Vanadium has not been classified as to carcinogenicity  by
the U.S. EPA.
                                              C-3

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                        TOXICITY PROFILES - DAHLGREN, SITE 29
  ALUMINUM
  Aluminum is not generally regarded as an industrial poison. Inhalation of finely divided powder has been
  reported as a cause of pulmonary fibrosis.  Aluminum in aerosols has been implicated  in Alzheimer's
  disease. As with other metals, the powder and dust are the most dangerous forms. Most hazardous
  exposures to aluminum occur in refining and smelting processes.  Aluminum dust is a respiratory and eye
  n"S mltfJ   /SLffX£.a.n °rf Rf° °f 10° m9/k9/day  and an inhalation reference dose of
  0.001 mg/kg/day (HEAST, 1997) for aluminum.

  ARSENIC

  The toxicity of inorganic arsenic (As) depends on its valence state (-3. +3, or +5), and also on the physical
  and chemical properties of the compound in which it occurs. Trivalent (As+3) compounds are generally
  more toxic than pentavalent (As+5) compounds, and the more water soluble compounds are usually more
  toxic and more likely to have systemic effects than the less soluble compounds, which are more likely to
  cause chronic pulmonary effects if inhaled.

 The Reference  Dose for chronic oral exposures, 0.0003 mg/kg/day,  is based on a  NOAEL of 0 0008
 mg/kg/day and  a LOAEL of 0.014  mg/kg/day for hyperpigmentation,  keratosis,  and possible vascular
 complications in a human population consuming arsenic-contaminated drinking water   Because of
 uncertainties in the data, U.S.  EPA states that "strong scientific arguments  can be made for various
 values within a  factor of 2  or 3 of the currently  recommended RfD value." The subchronic  Reference
 Dose is the same as the chronic RfD, 0.0003 mg/kg/day.

 Epidemiological studies have revealed an association between arsenic concentrations in drinking water
 and increased incidences of skin cancers (including squamous cell carcinomas and multiple basal  cell
 Carcinomas), as well as cancers of the liver, bladder, respiratory and gastrointestinal tracts.  Occupational
 f,XS°lUr,r! !tud'e,s have shown a clear conation  between exposure to arsenic  and lung cancer mortality
 U.S. EPA has placed inorganic arsenic in weight-of-evidence group A, human carcinogen.

 BENZENE

 Benzene is absorbed via ingestion, inhalation, and skin application. Humans may absorb benzene vapors
 through the skin as well as the lungs; of the total dose absorbed by the two routes, an estimated 22-36%
 enters the body through the skin.

 Limited  data  show that  nonlethal oral doses of  benzene can impact  the nervous, hematological  and
 immunological systems.  As with orally administered benzene, the targets for nonlethal concentrations of
 inhaled  benzene include the nervous, hematological,  and  immunological systems.   Subchronic  and
 chronic exposures to benzene vapors induce a progressive depletion of the bone marrow and dysfunction
 of the hematopoietic system.  Benzene may also have long-term effects on the central  nervous system
 Workers exposed to benzene for 0.5 to 4 years exhibited EEG changes and atypical sleep  activity
 consistent with neurotoxicity.  Others exposed to benzene concentrations of 210 ppm for 6-8 years had
 peripheral nerve damage.    Benzene does produce  developmental  effects (fetal  toxicity  but  not
 malformations) in the offspring of treated animals.

 Benzene is carcinogenic in humans and  animals  by inhalation  and  in animals by the oral route of
 exposure. Occupational exposure to benzene has been associated mainly with increased incidences of
various leukemias among workers.

Based  on "several studies of  increased incidence of nonlymphocytic  leukemia from  occupational
exposure, increased incidence of neoplasia in rats and mice exposed by inhalation and gavage benzene
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 has been placed in the EPA weight-of-evidence classification  A,  human carcinogen.   The oral  and
 inhalation slope factors for benzene are 0.029 (mg/kg/day)"1

 BENZO FA1PYRENE fBAPl

 Benzo (a)pyrene is the most extensively studied member of polynuclear aromatic hydrocarbons (PAHs)
 inducing tumors in multiple tissues of virtually all laboratory species tested by all routes of exposure.

 Benzo (a)pyrene is readily absorbed  across the Gl  and respiratory  epithelia.   Benzo  (a)pyrene was
 distributed widely in the tissues of treated rats and mice,  but primarily  to tissues  high  in fat such as
 adipose tissue and mammary gland.

 Human data specifically linking benzo[a]pyrene (BAP) to a carcinogenic effect are  lacking.  There are
 however, multiple animal  studies in  many species demonstrating  BAP to be carcinogenic following
 administration  by numerous routes.   In addition,  BAP has  produced positive results in  numerous
 genotoxicity assays.

 The data for animal carcinogenicity is sufficient.  Repeated BAP administration has been associated with
 increased incidences of total tumors and of tumors  at the site  of exposure. Benzo [ajpyrene has been
 shown to cause genotoxic effects in a broad range of prokaryotic and mammalian cell assay systems.

 The verified a slope factor for oral exposure to benzo(a)pyrene of 7.3  per mg/kg/day, based on several
 dietary studies in mice and  rats. Neither verified nor  provisional  quantitative  risk estimates  were available
 for the other PAHs in Group B2.

 CHROMIUM

 In nature,  chromium  (III) predominates over chromium  (VI).   Little  chromium (VI) exists in biological
 materials, except shortly after exposure, because reduction to chromium (III) occurs rapidly.  Chromium
 (III) is considered a nutritionally essential trace element and is considerably less toxic than chromium (VI).

 Acute oral exposure of humans to high  doses of chromium (VI)  induced neurological effects,  Gl
 hemorrhage and fluid loss, and kidney and liver effects. An NOAEL of 2.5 mg chromium (VI) /kg/day in a
 one-year drinking water study in rats and an uncertainty factor of 300 was the basis of a verified RfD of
 0.003 mg/kg/day for chronic oral exposure.  An NOAEL (No effects were observed in rats consuming 5%
 chromium (lll)/kg/day in the diet  for over  two years) of 1,468 mg/kg-day for chromium (III) and  an
 uncertainty factor of 100 was the basis of the RfD of 1.5 mg/kg/day for chronic oral  exposure.

 Occupational (inhalation and dermal) exposure to chromium (III) compounds induced dermatitis.  Similar
 exposure  to chromium  (VI) induced ulcerative  and allergic contact dermatitis,  irritation  of the  upper
 respiratory tract including ulceration of the mucosa  and  perforation of the  nasal septum  and possibly
 kidney effects.

 A target organ was not identified for chromium (III).  The kidney appears to be the principal target organ
 for repeated oral dosing with chromium  (VI). Additional target organs for dermal and inhalation exposure
 include the skin and respiratory tract.

 IRON

 No toxicity information is available for iron. The RfD for iron (0.3  mg/kg/day is based on allowable intakes
 rather than adverse effect levels.

 MANGANESE

Manganese is an essential  trace element in humans that can elicit a variety of serious toxic responses
upon prolonged exposure to elevated concentrations either orally or by inhalation. The central nervous



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 system is the primary target. Initial symptoms are headache, insomnia, disorientation, anxiety, lethargy,
 and memory  loss.  These symptoms progress with continued exposure and eventually include  motor
 disturbances, tremors, and difficulty in walking, symptoms similar to those seen with Parkinsonism
 These motor difficulties are often irreversible.

 Effects on reproduction (decreased fertility, impotence) have been observed in  humans with inhalation
 exposure and in animals with oral exposure at the same or similar doses that initiate the central nervous
 system effects.  An  increased incidence  of coughs,  colds,  dyspnea during exercise,  bronchitis, and
 altered lung ventilatory parameters have also been seen in humans and animals with inhalation exposure.

 A chronic and subchronic RfD for drinking water has been calculated by USEPA from a human no
 observed adverse-effect level (NOAEL). The NOAEL was determined from an epidemiological study of
 human populations exposed for a lifetime  to manganese concentrations in drinking water ranging from
 3.6-2300 ug/L. A chronic  and subchronic RfD for dietary exposure has been calculated by USEPA from
 a human NOAEL which was determined from a  series  of  epidemiological  studies.   A reference
 concentration  (RfC) for chronic inhalation exposure was calculated from a human LOAEL for impairment
 of neurobehavioral function from an epidemiological study.

 NICKEL

 Nickel is a naturally occurring element that may exist in various mineral forms. It is used in a wide variety
 of applications including metallurgical processes and electrical  components, such as batteries.  Some
 evidence suggests that nickel may be an essential trace element for mammals. The absorption of nickel
 is dependent on its physicochemical form,  with watersoluble forms  being more readily absorbed.   Toxic
 effects of oral exposure to nickel usually involve the kidneys with  some evidence from animal studies
 showing a possible developmental/reproductive toxicity effect.

 Inhalation exposure to some nickel compounds will cause toxic effects in the respiratory tract and immune
 system.  Acute inhalation exposure of humans to nickel may produce headache, nausea.respiratory
 disorders, and death.  Asthmatic conditions have also been documented for inhalation exposure to nickel.
 No clinical evidence of developmental  or reproductive toxicity were reported for women working in a
 nickel  refinery, but possible reproductive and developmental effects in humans of occupational exposure
 to nickel have been reported.  Furthermore, sensitivity reactions  to nickel are well documented and
 usually involve contact dermatitis reactions resulting  from contact with nickel-containing items such  as
 cooking utensils, jewelry, coins, etc.

 A chronic and subchronic oral reference  dose (RfD) of 0.02 mg/kg/day for soluble  nickel salts is based  on
 changes in organ and body weights of rats receiving dietary nickel sulfate hexahydrate for 2 years.  The
 primary target organs for nickel-induced systemic toxicity are the lungs and upper respiratory tract  for
 inhalation  exposure and the kidneys for oral exposure.  Other target organs include the cardiovascular
 system, immune system, and the blood.

ZINC AND ZINC COMPOUNDS

Zinc is an  essential element with recommended  daily allowances ranging from 5 mg for infants to 15 mg
for adult males. Zinc is present in all tissues with the highest concentrations in the prostate, kidney,  liver,
 heart, and pancreas.

 In humans, acutely toxic oral doses of zinc cause nausea, vomiting, diarrhea, and  abdominal cramps and
in some cases gastric bleeding.  Gastrointestinal upset has also been reported in  individuals taking  daily
dietary zinc supplements for up to 6 weeks. There is also limited evidence that the human immune
system may be impaired by subchronic exposures.

Chronic oral  exposures to zinc have  resulted  in hypochromic microcytic anemia  associated  with
hypoceruloplasminemia, hypocupremia,  and neutropenia in some individuals. Anemia and pancreatitis
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were the major adverse effects observed in chronic animal studies.  Teratogenic effects have not been
seen in animals exposed to zinc; however, high oral doses can affect reproduction and fetal growth.

The reference dose for chronic oral exposure to zinc is under review by USEPA; the currently accepted
RfD for both  subchronic and chronic exposures is 0.3 mg/kg/day based on a  decrease in erythrocyte
superoxide dismutase (ESOD) in adult women after 10 weeks of zinc exposure. Zinc is placed in weight-
of-evidence Group D, not classifiable as to human carcinogenicity due to inadequate evidence in humans
and animals.
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