PB99-963919
EPA541-R99-062
1999
EPA Superfund
Record of Decision:
Naval Surface Warfare Dahlgren
Site 25 OU9
Dahlgren, VA
9/27/1999
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SITE 25 - PESTICIDE RINSE AREA
NAVAL SURFACE WARFARE CENTER
DAHLGREN SITE
DAHLGREN, VIRGINIA
RECORD OF DECISION
SEPTEMBER 1999
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TABLE OF CONTENTS
PAGE NO
1.0 THE DECLARATION .................................... 11
1.1 SITE NAME AND LOCATION ............. [[[ /\
1.2 STATEMENT OF BASIS AND PURPOSE... ........... ' .............................. /«
1.3 DESCRIPTION OF THE SELECTED REMEDY ............................................ 1%
1.4 STATUTORY DETERMINATIONS .................. [[[ « 2
1.5 ROD DATA CERTIFICATION CHECKLIST .................. '"-".'ZZZZZZZZZZ 1-3
2.0 DECISION SUMMARY ............................. . ........................ - 1
2. 1 SITE NAME, LOCATION. AND DESCRIPTION [[[ 21
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES .. ............................................. 21
2.2.1 History of Site Activities .............................................. ........................................... 21
2.2.2 Previous Investigations ................................................ !Z!!^Z!!Z!~! ....................... 2-5
2.2.3 Enforcement Actions [[[ ' ...................................... 2-6
2.2.4 Highlights of Community Participation ......... [[[ 2-6
2.3 SCOPE AND ROLE OF RESPONSE ACTION SITE 25 ........................................... 2%
2.4 SITE CHARACTERISTICS ................................................. ZZZ ............................... £?
2.4.1 Sources of Contamination [[[ L'Z.'Z"! ....................... 2-8
2.4.2 Description of Contamination ......................................... "."".'.""" ................................ 2-8
2.4.3 Contaminant Migration ..................... ........................................... 2 12
2.5 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE" USES .................. 2-12
2.6 SUMMARY OF SITE RISKS ..................... .................. Il3
2.6.1 Human Health Risks ....................... ................................... 2 13
2.6.2 Ecological Risks ........ . [[[ !!""'.'".'.'"."".""".'." .................. 2-19
2.6.3 Summary, Conclusions, and Recommendations ......... ZZZZZ" ....... ............... 2-21
2.6.4 Development of Preliminary Remediation Goals (PRGs) ........ ................. 2-21
2.6.5 Remedial Action Objectives RAOs) ........... ................ 2 22
2.7 DESCRIPTION OF ALTERNATIVES ............... "" ....... ' ............................ 2-23
2.8 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES .................. 2-29
2.8.1 Threshold Criteria .............................. . ........................... ....... 2-29
2.8.2 Primary Balancing Criteria .................................... ZZZ"Z" .................................. 2-30
2.8.3 Modifying Criteria .................................. ......................... 231
2.9 THE SELECTED REMEDY ................................................ ZZZZZZZ". ......... 2-32
2.9.1 Performance Standards [[[ ................ 2-33
2.9.2 Summary of the Estimated Remedy Costs ......................... Z " ................................. 2-37
2.9.3 Expected Outcomes of the Selected Remedy .................... ...................... 2-38
2.10 STATUTORY DETERMINATIONS ................................................ .'.'.'Z'ZZZZ ..... 2-38
2.10.1 Protection of Human Health and the Environment .................. 2-41
2.10.2 Compliance with ARARs .................... . .............................. ............ 2-41
2.10.3 Cost-Effectiveness [[[ ZZZZZZZZ"!!!." 2-42
2.10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable .............. 2-42
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APPENDICES
B fSSuSoSSSStl? V"*3'N'A CONCURR6NCE LETTER
§ WS£
E TOXICITY PROFILES
in
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TABLES
NUMBER
PAGE NO.
2-1 Human Health Chemicals Of Potential Concern And Exposure Point Concentrations 2-11
2-2 Dose-Response Parameters ^ \l
2-3 Cost Estimates for Selected Remedy 2 39
FIGURES
NUMBER
PAGE NO.
2-1 NSWCDL Location Map 2 2
2-2 Site Location Map " 23
2-3 Site 25 Site Map ' '"" £4
2-4 Sampling Location Map ZZZZZZiZZZ 2-9
2-5 Areas of Contamination Exceeding Human Health and Ecological PRGs in Soils 2-25
2-6 Site Plan for Remedial Action. Alternative 3.... ZZZ"Z!! 2-35
IV
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1.0 THE DECLARATION
1.1 SITE NAME AND LOCATION
Site 25 Pesticide Rinse Area
Naval Surface Warfare Center
Dahlgren, Virginia
1.2 STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for Site 25 Pesticide Rinse 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 this site.
The Commonwealth of Virginia concurs with the selected remedy (see Appendix A).
ASSESSMENT OF THE SITE
The response action selected in this Record of Decision (ROD) is necessary to protect the public health,
welfare, or the environment from actual or threatened releases of hazardous substances into the
environment.
1.3 DESCRIPTION OF THE SELECTED REMEDY
Site 25 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).
For Site 25, the selected remedy, Alternative 3, consists of excavation and off-site disposal of
contaminated soils and fits the Navy strategy to reduce risks at all NSWCDL sites with minimal long-term
care. The remedial action selected in this ROD addresses contamination associated with Site 25
pesticide rinse contents, surface soils, subsurface soils and sediments. The selected remedy for Site 25
is: excavation and off-site disposal of all soil contaminated with pesticides and inorganics at levels
exceeding Remedial Action Objectives (RAOs), in order to protect potential ecological and human
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receptors. The excavated areas will be backfilled and revegetated and the wetlands restored The RAOs
tor the Chemicals of Concerns (COCs) are as follows:
Human Health
COC
uieldrin
Antimony
Concentration
u.B7 mg/kg
18.0mg/kg
Ecological
COC
4,4'-DDT-R
uieidrin-R
Antimony
Lead
Mercury
Silver
Concentration
1.0 mg/kg
1.0 mg/kg
5.0 mg/kg
50 mg/kg
0.10 mg/kg
2.0 mg/kg
The major components of the selected remedy are as follows:
French Drain and Contaminated Soil Removal: Excavation of approximately 370 cubic
yards of soil covering an area of approximately 2,500 square feet to a depth of 4 feet
below ground surface (bgs) in and around the French Drain at Site 25.
Excavation of Contaminated Soil in the Source Area Exceeding the RAOs: Excavation
of approximately 9.200 cubic yards of soil covering an area of approximately 122,000
square feet to a depth varying from 2 to 4.5 feet bgs.
Off-site Disposal of the contaminated soil: Disposal of approximately 9.570 cubic yards
of soil by direct landfilling at an offsrte facility.
Site Restoration: The excavated area in and around the French Drain will be backfilled to
previous grade and a vegetative cover will be placed on the surface. The excavated area
in the wetland where soil exceeding RAOs were present, will be regraded, backfilled, and
revegetated to the extent necessary to reestablish and. if possible, enhance the wetland
area. Additional wetlands mitigation may be required.
1.4 STATUTORY DETERMINATIONS
The selected remedy for Site 25 is protective of human health and the environment, complies with
Federal and Commonwealth of Virginia requirements that are applicable or relevant and appropriate to
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the remedial action, is cost effective, and utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable.
Based on the nature of the contamination at Site 25, the Navy concluded that it was impracticable to treat
the chemicals of concern (COCs) in a cost effective manner. Thus, the selected remedy for this site does
not satisfy the statutory preference for treatment as a principal element of the remedy.
A 5-year review will not be required because constituents remaining onsite after remedy implementation
are at levels that do not require use restrictions.
1.5 ROD DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record for Site 25.
• Chemicals of concern (COCs) and their respective concentrations
• Baseline risk represented by the COCs
• Cleanup levels established for COCs and the basis for the levels
• Current and reasonably anticipated future land use assumptions and current and
potential future beneficial uses of groundwater used in the baseline risk assessment and
ROD
• Potential land and groundwater use that will be available at the site as a result of the
selected remedy.
• Estimated capital, operation and maintenance (O&M), and total present worth costs;
discount rate; and the number of years over which the remedy cost estimates are
projected
• Decisive factors that led to selecting the remedy (i.e., how the Selected Remedy provides
the best balance of tradeoffs with respect to the balancing and modifying criteria)
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Vaughn E.
. . «c- ™- D
Commanding Officer / ' f re
Naval Surface Warfare CenteV
Dahfgren, Virginia
v^
Abraham Ferdas, Director
Hazardous Site Cleanup Division
U.S. EPA - Region III
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2.0 DECISION SUMMARY
2.1 SITE NAME, LOCATION, AND DESCRIPTION
This ROD is issued to describe the Department of the Navy's (NAVY) selected remedial action for Site 25,
Pesticide Rinse Area, at the NSWCDL, Dahlgren. Virginia (Figure 2-1). Site 25 is one of several
Installation Restoration (IR) sites (Figure 2-2) located at the NSWCDL facility.
Site 25, the Pesticide Rinse Area, is an inactive site located in the southern portion of NSWCDL,
approximately 700 feet northwest of Upper Machodoc Creek (Figure 2-3). Access to the site is from
Tisdale Road, which lines the western boundary of the site in conjunction with the northeast-southwest
trending railroad tracks. A cooling pond is located to the northwest of the site. Several buildings located
to the north of Site 25 are occupied by the Public Works Department, and the NSWCDL treatment plant is
located in the northeastern portion of the site. Site 25 is bounded on the east and south by Upper
Machodoc Creek.
The ground surface at Site 25 includes pavement gravel cover, and grass. A broad swale downstope of
the former location of Building 946 is located in the southern portion of the site. The swale is covered in
tall grass, reeds, and related marsh-type plants. The center of the swale is less than 5 feet in elevation
and slopes are gentle in the area, typically less than 5 percent Surface drainage at Site 25 is toward the
swale, which flows eastward into Upper Machodoc Creek.
Historic information indicates that past practices at Site 25, which included the rinsing of pesticide
containers with wash water, resulted in two areas of concern: (1) the surface drainage swale in the
southern portion of the site that received surface runoff from the gravel area near the former location of
Building 946; and (2) an area west of Building 134, the location of the former French Drain. The French
Drain consisted of a pipe, placed 18 inches bgs. that transported rinse waters from a slop sink in Building
134 to a dry well outside of the building. The dry well was constructed by excavating and gravel filling a
4-foot-square area to a depth of 4 feet
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.2.1 Htetorv of Stte Activities
The Pesticide Rinse Area, Site 25, was used during the 1960's and 1970's for calibration of pesticide
application equipment and rinsing of empty pesticide containers. The french drain area received
washwater from a slop sink located inside Building 134, the former Pesticide Shop. Discharges included
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NSWCDL
OAHLGREN, VIRGINIA
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pesticide residuals resulting from mixing of pesticides in the sink. Operations ceased during the late
1970-s.
According to an U.S. Environmental Protection Agency (U.S. EPA) study of aerial photographs, a former
inlet located in the vicinity of the present swale location was filled during the late 1930s to mid-1940s, and
buildings, roads, and yard areas were constructed. Additional fill operations were also taking place in the
inlets east of the site and along a drainage route southeast of the site. Linear ground scars were
identified south of Building 134 with one scar leading to an east-flowing channel. A dark-toned plume,
located where the east-flowing channel met the Upper Machodoc Creek, was noted in the 1943 imagery.
By 1952 a delta had developed in the river below the inlets. Aerial photographs between 1952 and 1974
indicated that the ground surface at Site 25 had been modified several times: the area south of Building
134 was graded in 1953; disturbed ground, located along an access road that led through the southern
drainage area, was identified in the 1958 imagery; and a channel leading from the southwest comer of
Building 134 to the disturbed area was observed in the 1962 imagery. Ground stains were noted on the
south side of Building 134 in both the 1952 and 1962 imagery.
The channel leading from the southwest comer of Building 134 was no longer visible in the 1983 imagery;
however, evidence of an area of standing liquid and a trench were identified near its former location.
Evidence of a stain on the south side of Building 134 was also noted. In 1990 photographs, rectangular
objects, and equipment were being stored sou* of Building 134. A liquid discharge was noted where the
stain was identified in 1983. The trench evident in the 1983 imagery was still visible in the 1990 imagery.
2.2.2 Previous Investigations
The first investigation at Site 25 was the Initial Assessment Study (IAS) that began in 1981. The IAS
included an on-site records review, site visit and personnel interviews. The IAS concluded that, although
the amounts of rinse water used at Site 25 were relatively small and dilute, the hazardous nature of some
pesticides warranted a Confirmation Study of soil in the suspect area
The objective of the Site 25 Confirmation Study, which was conducted in 1983 and 1984, was to
determine pesticide concentrations in the soil and any lateral or downward migration of contaminants at
the site. This study determined that two distinct areas of concern were at this site. One area was near
the French Drain west of Building 134 into which a slop sink in Building 134 drained. The second area
was in the vicinity of the swale, which occupies the former inlet/marsh area south of Building 946, where
facility personnel indicated that pesticide containers had been drained. The Confirmation Study consisted
of soil sampling at the areas of concern in 1983 and an expanded soil sampling effort the following year.
The installation and sampling of four groundwater monitoring wells also took place in 1984. In summary,
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the soil analyses from this study confirmed the presence of pesticides west and south of Building 134 and
near Building 946. The pesticides included 4,4'-DDT, 4,4'-DDD, 4,4'-DDE. dieldrin. aldrin, and endrin.
One of the four groundwater wells sampled was also found to contain 4.4'-DDT, 4,4'-DDD, and 4,4'-DDE.
2.2.3 Enforcement Actions
No enforcement actions have been taken at Site 25. The Navy has owned the property since the early
1900s and is identified as the responsible party. NSWCDL was added to the National Priorities List (NPL)
in 1992. The NPL is a list of the most contaminated hazardous waste sites in the United States.
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 described in the Feasibility Study
(FS) and the Proposed Plan for Site 25.
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 detailed in Section 3.1.
2.3 SCOPE AND ROLE OF RESPONSE ACTION FOR SITE 25
Site 25 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).
Past pesticide rinsing operations at Site 25 have contaminated the soil and sediment with pesticides
including aldrin, DDT. and dieldrin. The remedial actions identified in this ROD address contamination
associated with Site 25. Pesticide Rinse Area, as identified in the Draft Final Remedial Investigation (Rl)
Report, the Addendum Rl Report, and the FS Report for Site 25. Several alternatives for response
actions for contaminated media are described in Section 2.6. The rationale for selecting one of those
alternatives as the remedy for Site 25 is described in Section 2.7.
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The selected remedy is to excavate contaminated surface and subsurface soils at Site 25 in both the
French Drain area and the area south of the former location of Building 946. The excavated materials
would then be disposed off site at an appropriate RCRA disposal facility. The selected remedy will
reduce the potential risk to ecological receptors associated with pesticides (4,4'-DDT, dieldrin) and metals
(antimony, lead, mercury, silver) present in surface soils and wetland sediments at the site. The selected
remedy will also reduce the potential risk to human receptors from pesticides (dieldrin) and metals
(antimony) in surface soil and metals in subsurface soil at the site. Finally, the selected remedy will
reduce the risks from metals in surface and subsurface soils migrating to the groundwater and the nearby
Upper Machodoc Creek.
The remedy is consistent with long-term remedial goals for Site 25. The remedial action will reduce risks
to human and ecological receptors in the wetland and Upper Machodoc Creek from soil and sediment
contamination.
2.4 SITE CHARACTERISTICS
The Pesticide Rinse Area is located in the southern portion of the Mainside, approximately 700 feet
northwest of the Upper Machodoc Creek, Access to the site is from Tisdale Road, which lines the
western boundary of the site in conjunction with the railroad tracks. The cooling pond is located to the
northwest of the site. The NSWCDL sewage treatment plant is located to the northeast of the site. Site
25 is bounded on the east and south by Upper Machodoc Creek. The ground surface at Site 25 includes
pavement gravel cover, and grass. A broad swale is located in the southern portion of the site. The
swate is covered in tall grass, reeds, and related marsh-type plants. Maximum elevations of 15 feet occur
near the railroad tracks, a portion of which is on an embankment The center of the swale is less than 5
feet in elevation. Slopes are gentle in the area, typically less than 5 percent Surface drainage at the site
is toward the swale, which flows eastward into Upper Machodoc Creek and eventually to the Potomac
River.
The Rl at Site 25 was completed in phases and included a contamination assessment and a risk
assessment. The initial Rl field investigation, performed in 1994, was developed as a result of earlier
investigations to determine the limits of contamination (both areal and vertical) at the site. To accomplish
this many of the surface soil and subsurface soil samples collected during this investigation were outside
the main areas of known contamination where the confirmation study samples had been previously
collected. Groundwater samples were also collected from six shallow wells in the vicinity of the site to
determine the potential for site contaminants to migrate into the surficial aquifer. Finally, three surface
water and associated sediment samples were collected from the drainage swale to evaluate potential
contaminant transport and environmental impacts. In addition to the organochtorine pesticides analyzed
in previous studies, all samples that were collected during the Rl field investigation were analyzed for
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dioxins and furans. TAL metals, TCL volatile and semivolatile organics, and other pesticides/herbicides
previously used at NSWCDL. Additional sampling of one groundwater monitoring weir was completed in
1996 to verify that the presence of pesticides in previously tested groundwater was attributable to
particulates present in the sample. In 1998, additional surface and subsurface soil samples were
collected at the site. Sampling efforts concentrated on the areas of heaviest suspected contamination as
well as those outlying areas for which no data was previously available. Another round of groundwater
sampling was also performed at four wells.
2-4.1 Source* of Contamination
The only known source of contamination at the site is the past practice of disposal of pesticide rinse water
to the subsurface through the French Drain or directly to the surface.
2.4.2 Description of Contamination
Soil, sediment, and groundwater samples were collected and analyzed at the locations shown on Figure
2-4. Sediment samples were collected from areas of the drainage swale where localized ponding of
water was observed, Because the presence of surface water at these locations is temporary and does
not support aquatic biota, the data from the sediment samples were included with the surface soil data.
Surface and Subsurfac* Soil
The Chemicals of Potential Concern (COPCs) in the surface soil (0 to 2 feet bgs) that contributed the
most to the overall risk included pesticides (4,4'-DDT and its breakdown products 4,4'-DDD and 4,4'-DDE,
dieWrin, and aldrin.). one inorganic metal (arsenic), one semivolatile compound (benzo(a)pyrene) and
four dioxins/furans (1.2,3,4,6,7.8 HPCDF, 1,2,3.4.7,8-HXCDF. 1.2,3, ,6,7,8 HXCDF, and OCDF). 4.4'.
DDT and dieldrin were the pesticides found in the highest concentrations in the surface soils at Site 25
(190,000 pg/kg and 260,000 ug/kg. respectively). Occurring in 90 percent of the samples, 4.4'-DDE and
4.4-DDT were the most prevalent pesticides found in the surface soils at the site. Metals were detected
at concentrations higher than background levels, although no pattern of contamination that could be
associated with the potential source area shown in Figure 2-3 was evident Dtoxin and furan detections
were scattered and infrequent Tabte 2-1 summarizes the COPCs for surface soil and presents their
maximum exposure point concentration.
Combining the COPCs for surface and subsurface soil (deeper than 2 feet bgs) adds only one inorganic
metal (antimony) to the list of COPCs generated for surface soils. Antimony occurred at a somewhat
higher frequency (in approximately 20 percent of the samples) and concentration in the subsurface soil
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TABLE 2-1
HUMAN HEALTH
CHEMICALS OF POTENTIAL CONCERN AND EXPOSURE POINT CONCENTRATIONS™
SITE 25, PESTICIDE RINSE AREA
NSWCDL, DAHLGREN, VIRGINIA
Medium
Surface Soil
Surface/
Subsurface Soil
Fish Tissue
Sediment
Groundwater
Organic*
Chemical
Benzo(a)pyrene
4,4'-DDD
4.4--DDE
4,4'-DDT
Aldrin
Dieldrin
1,2,3,4,6,7,8-HPCDF
1,2,3,4,7,8-HXCDF
1,2,3,6.7,8-HXCDF
OCDF
Benzo(a)pyrene
4,4'-DDD
4,4'-DOE
4.4--DDT
Aldrin
Dieldrin
1.2,3,4,6,7,8-HPCDF
1,2,3,4,7,8-HXCDF
1,2,3,6.7,8-HXCDF
OCDF
Not Evaluated*3'
Not Evaluated'4)
Apha-BHC
Dieldrin
Exposure
Point
Concentration
(mB/kg)W
0.27
7.4
1.3
13
0.18
48
0.00060
0.00014
0.00013
0.0026
0.27
7.4
1.3
13
0.18
48
0.00060
0.00014
0.00013
0.0026
NA
NA
0.019
0.027
Inort
Chemical
Arsenic
Antimony
Arsenic
Not Evaluated'3'
Not Evaluated'4'
Arsenic
Barium
Iron
Manganese
isnics
Exposure Point
Concentration
(mg/ka)<2>
8.1
19.6
9.0
NA
NA
4.2
443
33,000
5,415
2
3
4
95 Percent Upper Confidence Limits (UCLs) on the arithmetic mean were used as exposure point
concentrations for the Reasonable Maximum Exposure (RME), and Central Tendency Exposure
(CTE) except for groundwater where maximum concentrations were used because the groundwater
database contained ten or fewer samples.
Exposure point concentrations for groundwater are in ug/L
The small wetland at the site is not large enough to support a population of edible game fish.
Human exposure is expected to be minimal because of current/anticipated land use and because of
the relatively small size of the wetland area.
NA Not Applicable
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compared to the surface soil at the site. However, no pattern of subsurface soil contamination could be
associated with a potential source. Table 2-1 summarizes the COPCs for subsurface soil and presents
their maximum exposure point concentration.
The presence of pesticides in the surface and subsurface soil at the site is indicative of the previous
practice of pesticide rinsewater disposal at the site. The presence of inorganics is expected to be
associated with fill material used at Site 25 . The main area of soil contamination associated with the
pesticide rinsewater disposal is considered to be within the source area which is outlined in Figure 2-3.
Groundwater
The COPCs identified for groundwater that contributed the most to the overall risk include two pesticides
(alpha-BHC and dieldrin) and four inorganic metals (arsenic, barium, iron, and manganese). None of the
COPCs exceeded Federal Maximum Contaminant Levels (MCLs) in the 1998 sampling event. The most
recent round of groundwater samples (from the 1998 sampling event) is used as the basis for the
exposure point concentrations presented in Table 2-1.
2<4>3 Contaminant Migration
The presence of a surface water body (Upper Machodoc Creek) approximately 1,000 feet from the source
area soil and the potential for migration of pesticides and inorganics via groundwater that eventually
discharges to the creek was considered a potential concern. Also, the potential for groundwater to
emerge to the surface and carry contaminants to the surface in the vicinity of the source area was also
considered a potential concern. To address these two concerns, contaminant fate and transport
modeling was performed. The results of the modeling study indicated that because of the low mobility of
pesticides and the high attenuation in concentration afforded by mixing with the creek water, none of the
pesticides or inorganic contaminants of potential concern would adversely impact either the surface water
or sediments in Upper Machodoc Creek. The results of the modeling study also indicated that in the
drainage swale area immediately downgradient of the source area soil, there would be minimal potential
for contaminants in the groundwater to emerge to the surface and adversely impact ponded water.
Details of the modeling were presented in the FS.
2.5 CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
Site 25 is located in the southern portion of the Mainside, approximately 700 feet northwest of Upper
Machodoc Creek. The ground surface at Site 25 includes pavement, gravel cover, and grass. A broad
swale downslope of the former location of Building 946 is located in the southern portion of the site. The
swale, consisting of about 10 naturally vegetated acres, is covered in tall grass, reeds, and related marsh-
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type plants. Wetlands on Site 25 comprise a roughly lOCMoot wide swath of land in the center of the
swa.e. T,sdale Road and a set of railroad tracks line the western boundary of the site. A cooling pond is
located to the northwest of the site on the other side of Tisdale Road. Several buildings located to the
north of Srte 25 are occupied by the Public Works Department and the NSWCDL treatment plant is
located ,n the northeastern portion of the site. Site 25 is bounded on the east and south by Upper
Machodoc Creek.
Site 25 is within an industrial use area and is anticipated to remain an industrial use area in the future
The roads.de adjacent to Site 25 is mowed and maintained on a regular basis and all activity at the site is
l.m,ted to the activities in adjacent buildings and roadsides. Recreational activity in this area is limited to
joggmg along Tisdale Road. Fishing occurs in the cooling pond; however, the pond is not considered to
be part of the site. The industrial use 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 25 is a thin water bearing zone underlain by a laterally
perststent clay confining layer (or Upper Confining Unit). Shallow groundwater at the Base is known to
discharge to adjacent shallow water bodies, in this case Upper Machodoc Creek. 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, during the risk evaluation for Site 25. the
watertable aquifer is considered to be a potential source of potable water.
2.6 SUMMARY OF SITE RISKS
The human health and ecological risks associated with exposure to contaminated media at Site 25 were
evaluated in the Addendum Rl Report Although the site will remain in industrial use, a human health risk
assessment was also performed on a hypothetical residential use scenario for informational purposes only.
Groundwater in the shallow aquifer is not a current source of drinking water and is not expected to be used
as one in the future.
2.6.1 Human Health Risks
The baseline human health risk assessment estimates what risks the site poses if no action were taken.
It provides the basis for taking action and identifies the contaminants and exposure pathways that need to
be addressed by the remedial action. This section of the ROD summarizes the results of the baseline risk
assessment for this site.
2-13
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Exposure Pathways and Potentially Exposed Population
Base workers, construction workers, and on-site residents {children and adults) were evaluated in the
quantitative risk assessment Base workers were evaluated for current and future conditions.
Construction workers and on-site residents were evaluated for future conditions only. Although the
potential for the site to be converted to residential land use is minimal, potential risks to future on-site
residents were quantified for purposes of completeness. Construction workers were evaluated for
exposure to surface/subsurface soil (0 to 12 feet) while only surface soil (0 to 2 feet) exposure was
considered for all other potentially exposed populations. Under the current and future land use scenarios
considered at Site 25, the exposure routes were incidental ingestion of soil and dermal contact with soil.
Inhalation of volatile emissions and dust was evaluated qualitatively via a comparison of site data with
USEPA Generic Soil Screening Levels (SSLs) for transfers from soil to air. The observed SSL
exceedance for dieldrin was not considered to be significant because this chemical was only detected in a
few soil samples at concentrations greater than the corresponding SSL.
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.
Exposure Assessment
The COPCs that were evaluated and their maximum exposure point concentrations are presented in
Table 2-1. 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
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
Table 2-2.
2-14
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TABLE 2-2
to
.A
at
DOSE-RESPONSE PARAMETERS
NAVAL SURFACE WARFARE CENTER, DAHLGREN, VIRGINIA
01 USEPA, 19948
» ATSDR, 19878
m Not appropriate to consider dermal toxfcity (USEPA 1994b)
•» ATSDR. 1991J '
m ATSDR, 1992a
« Based on toxicity equivalence factors for 2,3,7.8-TCDD (USEPA 1989c)
m ATSDR, 1987c '
<" Assumed default value (USEPA, 1989a)
<* ATSDR. 19918
(IG| USEPA, 1984
"" ATSDR, 1991f
«"> NA - Not available/applicable
Chemical
Benzo(a)pyrene
AWrin
alpha-BHC
4,4'-DDD
4.4'-DOE
4,4'-DDT
DtcWrin
npdUr
HaCDF
OCDF
Antimony
Arsenic
Barium
Iron
Manganese
RfDOrar1"
(mg/kg/day)
NA
3E-5
NA
NA
NA
5E-4
SE-S
NA
NA
NA
4E-4
3E-4
7E-2
3E-1<">
6E-3 (water)
1 4E-1 (food)
RfD
InhalaOoni"
(mgAcg/day)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.43E-4
NA<"
1.43E-5
CSFOraJi"
(mg/day/k0) '
7.3E+0
1.7E+1
6.3E+0
24E-1
3.4E-1
3.4E-1
1.6E+1
1.5E+3"
1.5E*4«
1.5E+2»
NA
1.75E+0
NA
NA<">
NA
CSF Inhalation")
(mo/kg/day)'
6.1E+0
1.7E*1
6.3E+0
NA
NA
3.4E-1
1.61E+1
1.5E+3"
1.5E+4»
1.5E+2*
NA
1.51E+1
NA
NA<">
NA
Gastolntattln
al Absorption
factor
0.75W
0.50<4>
NA
0.80")
0.80*1'
0.80<«
0.50"»
0.90P
o.yp
NA
0.05»
0.95«
0.05m
NA'">
0.03"°»
RfD Dermal
(mg/kg/day)
NA°»
1.5E-5
NA
NA
NA
4E-4
2.5E-5
NA
NA
NA
2E-5
2.85E-4
3.5E-3
3E-1
1.5E-4
CSF Dermal
(mo/kg/day)'
NA"1
3.4E+1
6.3E+0
3.0E-1
4.25E-1
4.25E-1
3.2E+1
1.67E*3
1.67E*4
1.5E+2
NA
184E+0
NA
NA<">
NA
Weight of
Evidence
B2
B2
D
B2
—
B2
B2
B2
B2
82
82
D
A - Inhal.
D
NA<12>
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, I992b) recommends that oral
toxicrty 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 2-2. 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.
Chromium Toxicity
Chromium was identified as a COPC in subsurface soil at Site 29. 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 mixtures, is the most toxic form of
chromium. No analyses were performed to distinguish among the specific chromium oxidation states
present at the site. For purposes of risk assessment, it is assumed conservatively that chromium is
present in the hexavalent state.
Lead Toxicity
The equations and methodology used for the other COPCs cannot be used to evaluate exposure to lead
because of the absence of published dose-response parameters for this hazardous substance. Lead was
identified as a COPC for groundwater because the maximum detected concentration of lead. 113 ng/L in
sample GW-29-2(94), exceeded the 15 >ig/L Federal Safe Drinking Water Act (SDWA) Action Level
(USEPA, October 1996b).
Exposure to lead in water is typically addressed using the USEPA Integrated Exposure Uptake Biokinetic
(IEUBK) Model for lead (USEPA, 1994a) for exposure to small 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.
2-16
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Risk Characterization
Excess lifetime cancer risks are determined by multiplying the intake level and the Cancer Slope Factor
(CSF). 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., soil, water,
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 reference dose). 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.
Current and Future Base Worker. The cumulative noncancer HI for ingestion of and dermal contact
with soils at Site 25 under industrial land use conditions is 4.9. which exceeds unity and indicates
potential for adverse health effects. The cumulative ingestion and dermal contact cancer risk is 1.0 x 10"3,
under a "reasonable maximum exposure" (RME) scenario. This exceeds the USEPA's acceptable target
risk range of 1 x 10* to 1 x 1
-------
The cumulative noncancer HI for exposure to groundwater at Site 25 under the hypothetical residential
land use conditions is 26 under the RME scenario. The HI for the RME exceeds 1.0 primarily as a result
of the ingestion of arsenic, iron, and manganese in groundwater. The RfD for iron is not based on health
effects, but rather on recommended daily allowances for human nutrition. In addition, it is likely that
arsenic and manganese concentrations are from naturally occurring conditions that are not site related.
The total residential incremental lifetime cancer risk based on exposure to groundwater at Site 25 is 1.2 x
10*. which slightly exceeds the USEPA's target risk range. The risk estimate is primarily influenced by
the ingestion of arsenic in groundwater. Once again, the arsenic concentrations are likely from naturally
occurring conditions that are not site related.
Uncertainty Analysis. The major sources of uncertainty specific to conditions at Site 25 include:
• The assumed dermal absorption rates from soil are a significant contributor to the
uncertainties at this site because dermal absorption is the only exposure route that
results in risks greater than 1x10*. Without firm default guidance from the USEPA,
general ranges presented in the dermal exposure guidance document, default guidance
from other regions, and general literature values were used in an attempt to differentiate
between the average and RME cases. This adds considerable uncertainty to the risk
characterization for dieldrin.
• The evaluation of arsenic as an oral carcinogen is a conservative approach. There is no
USEPA approved CSF for arsenic upon oral exposure. Arsenic is not known to cause
cancer upon oral exposure, and therefore the risks associated with arsenic may be
overstated.
• Some uncertainty is associated with the use of base background concentrations in the
COC selection process since site concentrations less than the maximum background
concentration were not considered to be attributable to site-related activities.
Background samples were collected from USEPA approved locations that are not
considered to be affiected by base activities. Analytical results for arsenic in surface soil
sample SSOO-5 (88.9 mg/kg) and for manganese in surface soil sample SSOO-3 (629
mg/kg) were eliminated from the background data set because they were considered to
be outside the normal range for background.
• An evaluation of a hypothetical future residential land use scenario was added to the
baseline human health risk assessment for Site 25 to aid in future risk management
2-18
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decisions. The evaluation of this scenario does not imply that the site is expected to be
used for residential development in the foreseeable future. The likelihood of this scenario
is minimal because the mission of the base is currently expanding and Site 25 is located
within the restricted area at NSWCDL.
2.6.2 Ecological Risks
The intent of the baseline ecological risk assessment (ERA) was to characterize potential hazard or risk to
plant and animal populations and habitats (ecological receptors). . Wetland identifications, terrestrial
habitat/wildlife characterization, and habitat mapping were performed in order to characterize the biota
and habitats associated with Site 25. Samples for the ERA were collected from surface soils (0 to 2 feet)
at the site as well as from surface waters and sediments from areas of the drainage ditch where standing
water was present.
Identification of Ecological COCs
Ecological effects quotients (EEQs) were derived for each COPC in all media. An EEQ represents the
ratio of the maximum concentration of a contaminant to a conservative or published cleanup criterion that
is applicable to a wide variety of ecological receptors. An EEQ equal to or greater than 1.0 indicates a
potential risk to ecological receptors. Based on EEQs, 4,4'-DDD, 4,4<-DDE, 4,4t-DDT, aldrin. dieldrin.
endrin. endrin ketone, endrin aldehyde, HPCDD. HPCDF, antimony, arsenic, lead, mercury, silver, and
zinc in surface soil and sediments, and dieldrin and zinc in surface waters, were identified as COCs for
ecological receptors.
Exposure Assessment
Potential ecological receptors at Site 25 are terrestrial receptors such as rabbits, meadow voles, mice,
earthworms, ground insects, and a variety of birds. Direct contact with contaminated soil, incidental
ingestion of contaminated food, and incidental ingestion of contaminated soil are the primary pathways of
exposure to terrestrial receptors at this site. Exposure to contaminated subsurface soil is unlikely under
current or reasonably anticipated future site conditions. Exposure to surface water or sediment is a less
likely pathway of exposure because of the intermittent nature of the presence of surface water and
associated sediment.
Ecological Effects Assessment
The toxicity of the Site 25 soil to earthworms was studied by observing the mortality rate of earthworms
and loss of lipids from earthworm bodies. The results of the study provided information on the
bioavailability, i.e., the accumulation of pesticides in earthworms exposed to DDT- and dieldrin-
2-19
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contaminated soil. The bioavailability information was used to develop levels protective of receptors via
the food chain model, as discussed further in Section 2.6.4.
Ecological Risk Characterization
Among the ecological COCs identified above, only the following were retained for development of levels
for protection of potential ecological receptors: 4,4'-DDD, 4,4'-DDE, 4.4'-DDT, aldrin, dieldrin, endrin,
endrin ketone, endrin aldehyde, antimony, lead, mercury and silver. Among the remaining COCs.'
HPCDD and HPCDF were infrequently detected and not expected to be related to site operations; and
arsenic and zinc were detected at levels that were found at levels similar to fill material over much of
NSWCDL outside the site, and also were not considered to be related to previous site operations.
Therefore. HPCDD, HPCDF. arsenic and zinc were not considered further for development of levels for
protection of ecological receptors. Section 2.6.3 presents the development of levels protective of
potential ecological receptors for the COCs retained above..
Uncertainty Analysis
The major sources of uncertainty specific to conditions at Site 25 include:
• Uncertainty in problem definition can arise from ambiguities in characterization of
contaminant sources and migration pathways, as well as in the exposure pathway
analysis. Data gaps and incomplete or vague information regarding contaminant fate and
transport and the environmental receptors present and their ecology may lead to
uncertainty in determining complete exposure pathways.
• Uncertainty in exposure assessment includes the methods and assumptions made in the
determination of the exposure point concentrations. Except for surface soils, limited
numbers of samples were collected from each media, resulting in uncertainty as to how
accurately the data represents the site. In addition, the use of maximum detected values
to represent site-specific contaminant concentrations is conservative and overestimates
risk.
• Uncertainty in ecological effects characterization can result from the quality of existing
data used to support the determination of potential adverse impacts to ecological
receptors. The comparison of site data to conservative, published screening values.
although necessary, will introduce error into the results of the assessment In addition,
the uncertainties associated with extrapolations from results based on laboratory test
2-20
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conditions to field situations have long been acknowledged, but remain difficult to
quantify.
• Uncertainty in risk characterization includes that associated with the potential effects of
exposure to multiple chemicals and the cumulative uncertainty from combining
conservative assumptions in earlier activities. Often conservative conclusions rather than
reasonable and appropriate ones are drawn that tend to overestimate risk.
2-6-3 Summary. Conclusions, and Recommendations
In summary, dieldrin and antimony in surface soil and subsurface soil at Site 25 can present human
health risks for a potential future resident No unacceptable human health risks are expected for the
current or future base worker or the future construction worker. Ecological receptors at the site are at risk
based on concentrations of 4,4'-DDD, 4.4'-DDE. 4,4'-DDT, dieldrin, aldrin, endrin. endrin aldehyde, endrin
ketone, antimony, lead, mercury, and silver in the surface soils at Site 25. Risks to ecological receptors
from exposure to subsurface soils, and sediments, and intermittently present surface waters outside the
source area, are considered to be minimal.
Previous releases of hazardous substances from Site 25, if not addressed by implementing the response
action selected in this ROD, may present a threat to public health, welfare, or the environment
2.6.4 Development of Preliminary Remediation Goals f PRGal
The COCs for surface and subsurface soils were evaluated using contaminant transport modeling to
verify the protection of groundwater from contaminants in the surface and subsurface soils, and of nearby
surface waters and associated sediments from soil contaminants via the groundwater pathway. Details of
the contaminant transport modeling effort are provided in Appendix C of the Site 25 FS.
Human Health PRO*
Human health PRGs were calculated from the major human health risk-based COCs for surface and
subsurface soils for the protection of the future resident. Based on these calculations and modeling
efforts, PRGs were developed for surface and subsurface soils. The human health PRGs for both
surface and subsurface soils at Site 25 include dieldrin (0.67mg/kg) and antimony (18 mg/kg).
Ecological PRGs
The pesticide PRGs were derived using food chain models because concentrations of these compounds
tend to increase at higher levels of the food chain. Also, higher animals are more sensitive than soil
2-21
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organisms to most of the DDT- and dieldrin-related compounds. For simplicity, the sums of 4.4'-DDT-R
(concentration of 4,4'-DDD, 4,4'-DDE, plus 4.4--DDT) and dieldrin-R (concentration of aldrin. dieldrin,
endrin. endrin aldehyde, plus endrin ketone) were used for developing the pesticide PRGs. PRGs were
developed only for soil because that is the predominant contaminated medium on the site. The drainage
ditch in the site contains water only intermittently. A description of the PRG derivation process is
provided in Appendix B of the Site 25 FS.
Although pesticides are the main concern at Site 25, a dioxin, a furan, and several metals were
characterized in the Rl as potential risks to ecological receptors. These analytes have been assigned
PRGs from published sources. The dioxin and furan. like the pesticides, are of most concern to higher
animals; however, their occurrences at Site 25 were both infrequent and scattered. The metals may harm
wildlife, soil organisms, or plants, depending on the relative sensitivity of each type of receptor and, for
wildlife, the likelihood of exposure. Ecological PRGs for surface soil at Site 25 include 4,4'-DDT-R
(1.0mg/kg), dieldrin-R (1.0 mg/kg). antimony (5.0 mg/kg). lead (50 mg/kg), mercury (0.10 mg/kg). and
silver (2.0 mg/kg).
2.6.5 Remedial Action Objectives (RAO*)
Based on human health and ecological risks at Site 25. and specific site conditions, the following remedial
action objectives (RAOs) were developed for site surface and subsurface soils to address the primary
exposure pathways. The concentrations indicated below represent levels protective of human health and
the environment.
Prevent potential future resident receptors from being exposed to dieldrin and antimony in surface soils
and subsurface soils.
Human Health
COC
Dieldrin
Antimony
Concentration
0.67 mg/kg
18.0 mg/kg
Prevent ecological receptors from being exposed to 4,4'-DDT-R, dieldrin-R, antimony, lead, mercury, and
silver present in surface soils (0 to 2 feet bgs).
Ecological
COC
4.4'-DDT-R
Dieldrin-R
Antimony
Lead
Mercury
Silver
Concentration
1.0 mg/kg
1.0 mg/kg
5.0 mg/kg
50 mg/kg
0.10 mg/kg
2.0 mg/kg
2-22
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2.7 DESCRIPTION OF ALTERNATIVES
A detailed analysis of the possible remedial alternatives for Site 25 is included in the Site 25 Feasibility
Study report. The detailed analysis was conducted in accordance with the U.S. EPA document entitled
Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA and the
National Oil Hazardous Substances Pollution Contingency Plan.
Alternative 1: No Action
Under Alternative 1 the site is essentially abandoned. No further evaluation of conditions would occur.
Alternative 1 serves as a baseline against which the ability of other alternatives to meet remedial action
objectives is evaluated.
The following are the cost and duration associated with Alternative 1:
• Present Worth: $15,550 is the estimated administrative cost of 5-year reviews over a 30-
year period.
• Time to Implement . 0 months
Alternative 2: French Drain Removal: Soil Cover with Impermeable Liner fSoil Exceeding Remedial
Action Objectives (RAOs)l: Institutional Controls (Soil and Groundwatert: and Wetlands Restoration
- Option A: Excavation, Consolidation of Soil "Hot Spots" under Soil Cover, and Backfill or
- Option B: Excavation, Off-site Disposal of Soil "Hot Spots", and Backfill
Under Alternative 2. the following actions would be performed
• French Drain Removal: An area of approximately 2500 square feet of contaminated
material down to a depth of 4 feet below ground surface (bgs) would be excavated. A
total volume of approximately 370 cubic yards of contaminated material would be
excavated and disposed off-site. The disposal facility is expected to be a RCRA Subtitle
D facility where the material would be directly landfilled. The French Drain removal area
is delineated in Figure 2-5. The calculations supporting the volume estimate are
presented in Appendix D of the FS.
• Option A: Excavation, Consolidation of Soil "Hot Spots" under Soil Cover, and Backfill:
Hot spots 1 and 2, located outside the soil cover area (Figure 2-5), would be excavated
2-23
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and consolidated within the area of soil exceeding RAOs. Approximately 6075 square
feet of area at hot spots 1 and 2 would be excavated to a depth of 1.5 feet.
Approximately 338 cubic yards of contaminated soil would be spread over an area of
approximately 142,000 square feet Hot spot areas 1 and 2 would be backfilled to grade
with clean borrow (common fill) from an off-site location and revegetated. The
calculations supporting the area and hot spot volume estimates are presented in
Appendix D of the FS.
Option B: Excavation, Off-site Disposal of Soil "Hot Spots" and Backfill. Hot spots 1, 2, 3,
4 and 5, would be excavated and disposed off-site, as shown on Figure 2-5.
Approximately 19.800 square feet of contaminated soil at the five hot spots, would be
excavated to a depth of 1.5 feet. The excavated soil corresponds to a volume of 1,100
cubic yards. The excavated area outside the proposed soil cover area (hot spots 1 and
2), would be backfilled to grade with clean borrow soil from an off-site location. The
remaining hot spot excavated areas (hot spots 3,4, and 5) would be regraded. Hot spots
1, 2, 3, 4 and 5, and other onsite areas identified from previous investigations and
confirmatory sampling, would be tested for TCLP characteristic waste prior to transport
off-site for disposal. Should the soils fail for TCLP. these corresponding areas will be
handled as RCRA hazardous waste. Should the soils pass TCLP, then a health-based
level shall be used to determine whether the soils are disposed in a Subtitle C or D facility
as a non-regulated waste. The health-based level for dieldrin was calculated to be 5.4
mg/kg as provided in Appendix D. Should TCLP and the health-based level pass, the
soils would be disposed in a Subtitle 0 facility.
Soil Cover with Impermeable Liner A soil cover with an impermeable liner would be
placed over an area of 142,000 square feet Under Option A, this area would include
consolidated hot spot soils. Under Option B, no hot spot soil consolidation would be
required and the excavated areas in the swale area would be regraded. A minimum area
of 142,000 square feet would be cleared/grubbed/graded for a liner to be placed. This
area would exceed the area of surface soil where contamination levels exceed RAOs by
approximately 26,000 square feet to meet cap grading requirements. A soil cover
approximately 2 feet in thickness consisting of soil that is similar in geological properties
to the existing uncontaminated soil at the site would be placed over the entire area that
would be covered by the liner. In particular, siltfclay/loam type soil would be placed in the
areas where wetland restoration is required. The final slope of the surface of the soil
layer would be similar to the existing slope of the area under the proposed cover which is
approximately 4 percent
2-24
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-------
This page intentionally left blank
2-26
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Wetlands Restoration: Vegetation similar to the existing plants and shrubs in the
wetland areas of the site would be planted in the soil cover in areas where
wetlands would have been cleared. The use of a liner (preferably of
geocomposite clay material) is expected to aid moisture retention in the soil
cover and wetland re-establishment. Vegetation similar to upland plants and
shrubs would be planted in all remaining areas of soil cover. The edges of the
soil cover would be provided with erosion protection (gravel or gabion baskets) in
the event of storms. Additional wetlands mitigation may be required.
Institutional Controls: A Land Use Control Assurance Plan (LUCAP) and Land Use Control
Implementation Plan (LUCIP) would be developed to assure implementation of the following measures.
Records of the contamination would be placed in the NSWCDL Master Plan to prevent site development
for residential use. Access to the site would be restricted to prevent human intrusion into the soil cover.
Deed notation would be required to limit future disturbances to the site and establish other appropriate
site use limitations. In the event of sale of this property , the deed would carry a restriction preventing the
potable use of groundwater, and allowing only industrial use of the land. Groundwater at the site is not
currently used and is unlikely to be used within the foreseeable future under the Navy's ownership.
Groundwater samples would be taken from 4 monitoring wells (including a background well) and
analyzed for pesticides and inorganics. A report on the site conditions would be issued at each five-year
review event.
The costs associated with Alternative 2 are shown in the following table. Details of the cost estimate are
presented in Appendix E of the FS.
ALTERNATIVE 2
COST
Capital:
Operating and Maintenance
(O&M)
Present Worth
(30-year @ 7% discount rate)
OPTION A
$1,495,000n' or $1,599,000 or $2,053,000W
$5,600/yr + $9,000/5 yr
$1 ,696,OOOlJ> or $2,142,000'*'
1
2
3
4
Assumes French-Drain material disposal at Subtitle D landfill.
Assumes French-Drain material disposal at Subtitle C landfill.
Assumes French-Drain material and hot spot soil disposal at Subtitle D landfill.
Assumes French-Drain material and hot spot soil disposal at Subtitle C Landfill.
Time to Implement: 4 months
2-27
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Alternative 3: French Drain Removal- Exertion *nH n*.5ite nisnnga, fM Exceedjng RAfw
BackfiH: and Wetlands
Under Alternative 3 the following actions would be performed:
• French Drain Removal: This component would be identical to that of Alternative 2.
Excavation. Off-site Disposal {Soil Exceeding RAOs), and Backfill: Soil contaminated with
concentrations greater than the RAOs in Section 2.6.5 (area shown on Figure 2-5)
covering an area of approximately 122,000 square feet (including approximately 19,800
square feet from the five hot spots) would be excavated to a depth of 2 feet bgs to meet
ecological RAOs. An additional volume of 139 cubic yards would be excavated from
subsurface soils (to an average depth of 4.5 feet bgs) at Hot spots 6 and 7 (also shown
on Figure 2-5) to meet human health RAOs. Approximately 9,200 cubic yards of soil '
would be disposed off-site. Hot spots 1. 2, 3, 4 and 5, and other onsite areas identified
from previous investigations and confirmatory sampling, would be tested for TCLP
characteristic waste prior to transport off-site for disposal. Should the soils fail for TCLP.
these corresponding areas will be handled as RCRA hazardous waste. Should the soils
pass TCLP. then a health-based level shall be used to determine whether the soils are
disposed in a Subtitle C or D facility as a non-regulated waste. The health-based level for
dieldrin was calculated to be 5.4 mg/kg as provided in Appendix D. Should TCLP and the
health-based level pass, the soils would be disposed in a Subtitle D facility.
Backfill: Fill material approximately 2 feet in thickness consisting of soil that is similar to
the existing soil at the site would be backfilled in the excavated areas within the swale. In
particular, silt/clay/loam type of soil would be backfilled in the areas where wetland
restoration is required. As before, hot spots excavated outside the soil cover area would
be backfilled with common fill soil. The final grade and elevations of the surface of the
backfilled soil would be similar to the existing grade and elevations of the existing
contaminated area.
• Wetlands Restoration: The excavated areas would be revegetated after backfilling to
grade. Vegetation similar to the existing plants and shrubs in the wetland areas of the site
would be re-established. Vegetation similar to the existing upland plants and shrubs
would be planted in remaining area affected by excavation. No additional erosion
protection is expected to be required. Additional wetlands mitigation may be required.
2-28
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implementation of Alternative 3 wou«d make the site available for unrestricted land and groundwater use
However, certam metals in groundwater are found at levels that wou.d be of concern in drinking water
These metals (,ron and manganese) were found to be naturally occurring in the area and therefore are
not attributable to the site.
The costs associated with Alternative 3 are as follows:
ALTERNATIVES'
Capital Cost
Operating and Maintenance
Present - Worth (30-year @ 7%
discount rate)
* " W
$1 ,51 7.000* "or $2.049. 1QO
$0
$1,517,000'" or $2,049,000I
T2T
1 Assumes all soil/material disposal at Subtitle D landfill.
2 Assumes French-Drain material and hotspot soil disposal at Subtitle C
landfill and remaining soil disposal at Subtitle D landfill.
Details of the cost estimate are presented in Appendix E of the FS.
• Time to Implement 6 months
2.8 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial alternatives described in Section 2.6 were evaluated in the Feasibility Study against nine
criteria identified in the NCR, as presented below.
2.8.1 Threshold Criteria
Overall Protection of Human Health and the Environment
Alternative 3 would be the most protective of all alternatives because the contaminated soil would be
removed from the site. Alternative 2 would also be protective, although less reliable than Alternative 3 in
the long term because the contaminated soil would remain on site and only the exposure pathway of
incidental ingestion or dermal contact would be blocked using a soil cover. Under Alternative 2, Option B
would be more protective than Option A because the most highly contaminated soil (hot spots) would be
removed from the site in the former option, whereas, they would only be consolidated under the cover in
the latter option. Alternative 1 would not be protective since the potential for receptors to be exposed to
contaminants remains. Because Alternative 1 does not meet the threshold criteria of protecting human
health and the environment, it will not be considered further in this analysis.
2-29
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Compliance with ARARs and TBCs
Alternatives 2 and 3 would comply with chemical-specific, location-specific and action-specific ARARs.
2.8.2 Primary Balancing Criteria
Reduction of Toxicity, Mobility or Volume through Treatment
There would be no reduction in toxicity, mobility or volume through treatment in any of the alternatives.
Long-term Effectiveness
Alternative 3 would be permanent and most effective in the long-term because the contaminated soil
would be removed from the site and disposed of under regulated and controlled conditions offsite
Alternative 2 would also be permanent, but less effective in the long-term than Alternative 3 because the
soil cover would have to be maintained. Under Alternative 2. Option B would be more reliable than
Option A because the most highly contaminated soil would be removed from the site whereas the
potential for exposure to receptors would remain under Option A.
Short-term Effectiveness
Option A under Alternative 2 would be the most effective in the short-term because the smallest volume
of contaminated material would be excavated and therefore, the potential for workers on site to be
exposed to contaminants would be the least. Option B under Alternative 2 would be somewhat less
effective than Option A and Alternative 3 would be the least effective because of greater potential for
exposure to contaminants and the longer time (6 months vs. 4 months) to reach RAOs. However, in both
alternatives with proper use of personal protective equipment engineering controls, etc., all exposure can
be adequately minimized and therefore both alternatives would be effective in the short term. Durations
of remedial action under the options for Alternative 2 (approximately 4 months) are expected to be shorter
than the duration of remedial action under Alternative 3, which is estimated to be 6 months.
implementabillty
Wetland restoration under Alternative 3 is likely to be easier to implement than under Alternative 2.
Under Alternative 2, Option B would be somewhat easier to implement with regard to wetland restoration
than Option A because the surface elevation would be tower and consequently more conducive to
saturation.
2-30
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Cost
The following table compares the costs of the alternatives.
ALTERNATIVE 2
OPTION A
Capital:
$i,495,ooo
$1,599,000(2)
O&M: $5,600/yr +
$9,000/5yrs
Present-Worth:
$1.584,000<1>or
$1,687,000(2)
OPTION B
Capital:
$i,608,ooo<1>or
$2,053,000<2>
O&M: $5,600/yr +
$9,000/5 yrs.
Present-Worth:
$1,696,000<1> or
$2,142,000(2)
ALTERNATIVE 3
Capital:
$1,517.000<1>or
$2,049,000<2>
O&M: $0
Present-Worth:
$1,517.000<1>or
$2,049,000(2)
1 Assumes a Subtitle D landfill for disposal of all
soil/French Drain material.
2 Assumes a Subtitle C landfill for disoosal of hot soot sr»is
— — —,_ __» •_• .v. .v,,., iwt *«itf p^w^ui wi 1IWL 9UWI W
and French Drain material and a Subtitle D landfill for
disposal of all remaining soil.
Administrative Costs of 5-year reviews over 30-year duration.
2.8.3
Modifying Criteria
State Acceptance
The Virginia Department of Environmental Quality, on behalf of the Commonwealth of Virginia, has
reviewed the information available for this site and has concurred with this ROD and the selected remedy
identified below. A copy of the letter of concurrence from the Commonwealth of Virginia is attached as
Appendix A.
Community Acceptance
The selected remedy was presented to the public in a public meeting along with the Proposed Plan.
Minutes of the public meeting are presented in Appendix B. Questions raised by members of the
community are addressed in the Responsiveness Summary presented in Section 3.0. Based upon the
outcome of the public meeting, participants at the meeting did not disagree with the selected remedy.
2.9
THE SELECTED REMEDY
The selected remedy, Alternative 3, consists of excavation and off-site disposal of contaminated soils and
fits the Navy strategy to reduce risks at all NSWCDL sites with minimal long-term_care. The remedial
2-31
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action selected in this ROD addresses contamination associated with Site 25 pesticide rinse contents
surface soils, subsurface soils and sediments. The selected remedy for Site 25 is excavation and off-site
disposal of all soil contaminated with pesticides and inorganics at levels exceeding Remedial Action
Objectives (RAOs) for protection of potential ecological and human receptors. The excavated areas will
be backfilled and revegetated and the wetlands restored. The RAOs for the Chemicals of Concerns
(COCs) are as follows:
Human Health
COG
Oieldrin
Antimony
Concentration
0.67 frig/kg
18.0 mg/kg
Ecological
coc
4,4'-DDT-R
Dieldrin-R
Antimony
Lead
Mercury
Silver
Concentration
1.0 mg/kg
1.0 mg/kg
5.0 mg/kg
50 mg/kg
0.10 mg/kg
2.0 mg/kg
Based on available information and the current understanding of site conditions, Alternative 3 appears to
provide the best balance of the nine NCP evaluation criteria. In addition, the selected alternative is
anticipated to meet the following statutory requirements:
• Protection of human health and the environment
• Compliance with ARARs
• Cost effectiveness
• Use of a permanent solution to eliminate site risks by removing contaminated soil from
the site and disposing of the soil at an offsrte landfill. The soil could be used as a daily
cover at the selected landfill, thereby providing resource recovery to the maximum extent
possible.
The selected remedy does not achieve the preference for the reduction of toxicity, mobility, and volume
through treatment because potential treatment technologies were not effective and were too costly.
2-32
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The major components of the selected remedy are as follows:
French Drain and Contaminated Soil Removal: Excavation of approximately 370 cubic
yards of soil covering an area of approximately 2,500 square feet to a depth of 4 feet
below ground surface (bgs) in and around the French Drain at Site 25..
Excavation of Contaminated Soil in the Source Area Exceeding the RAOs: Excavation
of approximately 9.200 cubic yards of soil covering an area of approximately 122,000
square feet to a depth varying from 2 to 4.5 feet bgs
Off-site Disposal of the contaminated soil: Disposal of approximately 9,570 cubic yards
of soil by direct landfilling at an offsite facility. The excavated soil will be tested using the
Toxicity Characteristic Leaching Procedure (TCLP) to determine if it is hazardous or
nonhazardous waste for off-site disposal, as appropriate. If the soil passes the TCLP, it is '
not a hazardous waste and Land Disposal Restrictions (LDRs) do not apply. If the
concentration of dieldrin exceeds the health-based risk level of 5.4 mg/kg. however, the
soil will be manifested and disposed of in a RCRA Subtitle C landfill. Specifically, hot
spots 1, 2, 3. 4 and 5, and other onsite areas identified from previous investigations and
confirmatory sampling, would be tested for TCLP characteristic waste prior to transport
off-site for disposal. Should the soils fail for TCLP, these corresponding areas will be
handled as RCRA hazardous waste. Should the soils pass TCLP, then a health-based
level shall be used to determine whether the soils are disposed in a Subtitle C or D facility
as a non-regulated waste. The health-based level for dieldrin was calculated to be 5.4
mg/kg as provided in Appendix D. Should TCLP and the hearth-based level pass, the
soils would be disposed in a Subtitle D facility.
• Site Restoration: The excavated area in and around the French Drain will be backfilled to
previous grade and a vegetative cover will be placed on the surface. The excavated area
in the wetland where soil exceeding RAOs were present will be regraded, backfilled, and
revegetated to the extent necessary to reestablish and, if possible, enhance the wetland
area. Additional wetlands mitigation may be required.
2.9.1 Performance Standards
Excavation and Off-site Disposal
The proposed areas of excavation are shown on Figure 2-6. These areas have been delineated based
on data indicating concentrations of pesticides and inorganics greater than RAOs in Section 2.6.5.
2-33
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Ftibung excavation to a depth of 2 feet, confirmatory samp.ing of the bottom (for human health RAOs
on*) and s,de walls (for both ecological and human hea,th RAOs) shall be conducted to ensure that the
mean of the residua, levels of each of the COPCs does not exceed its respective RAO at a 95 percent
upper confidence limit. percent
Approximate^ 2.500 square feet of area in and around the French Drain wi,, be cleared and excavated to
a depth of approximates 4 feet be,ow ground surface. The resultant volume of soi, and French Drain
matenal (includmg any gravel or brick lining) corresponding to a total in-situ volume of 370 cubic yards wil.
be loaded onto trucks for offsite disposal.
Approximately 122.000 square feet of surface soi. in the pesticide nnse area wi.l be cleared of vegetal
and excavated to a depth of 2 feet below ground surface. Within this area, approximately 19.800 square
feet of soi, is expected to contain pesticide hotspots. i.e.. soil with DDT-R or dieldrin-R levels exceeding
5.0 m,ll,grams per kilogram, that are labeled as H.S. 1. H.S. 2. H.S. 3. H.S. 4, and H.S. 5. A.so within this
area, two hotspots containing inorganic contaminants at concentrations greater than the RAOs shall be
excavated. The excavation area is anticipated to be approximately 1.500 square feet (total) to a depth of
4.5 feet below ground surface. A total in-situ volume of approximately 9.300 cubic yards of soi. will be
excavated and loaded onto trucks for offsite disposal.
Excavated material shall be disposed at a permitted RCRA Subtitle D landfill offsite. Hot
spots 1. 2. 3. 4 and 5, and other onsite areas identified from previous investigations and
confirmatory sampling, would be tested for TCLP characteristic waste prior to transport
off-site for disposal. Should the soils fail for TCLP. these corresponding areas will be
handled as RCRA hazardous waste. Should the soils pass TCLP. then a health-based
level shall be used to determine whether the soils are disposed in a Subtitle C or D facility
as a non-regulated waste. The health-based level for dieldrin was calculated to be 5.4
mg/kg as provided in Appendix D. Should TCLP and the health-based level pass, the
soils would be disposed in a Subtitle D facility, approximately 2 feet in thickness
consisting of soil that is similar in geological properties to the existing uncontaminated
soil at the site would be placed over the entire area that would be covered by the liner. In
particular, silt/clay/loam type soil would be placed in the areas where wetland restoration
is required. The final slope of the surface of the soil layer would be similar to the existing
slope of the area under the proposed cover which is approximates 4 percent
2-34
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EXCAVATE CONTAMINATED
AREA ASSOCIATED WITH
EXCAVATEf IOFFSITE DISPOSAL!
IOFFSITE DISPOSAL}
^""^~~^~~J
EXCAVATE AREA
CONTAMINATED>PRGs
AREA REQUIRING •
WETLAND RESTORATION!!
150
150 F*tt
Legend:
Contaminated Area Associated wrth French Drain
Hot Spot 5
} Surface Soil Hot Spot (H.S.)
Subsurface Soil Hot Spot (H.S.)
• Sampled in 1994 0.. Sampled in 1998 (Pesticides and
• Sampled in 1998 Metals)-No Exceedances
• Sediment Sample ® Sampled in 1998 (Pesticides only)
-No Exceedances
T«tra T*ch NU8, Inc.
CONTRACT NUMBER
0291
OWNS* NO
COSTI9CHEDULE-ORE*
1 1 1
SCALE
AS NOTED
SITE PLAN FOR REMEDIAL ACTION. ALTERNATIVE 3
SITE 25 - PESTICIDE RINSE AREA
NSWC DAHLGREN
DAMLGREN. VIRGINIA
FIGURE 2-6
E PLAN . ALT51NATIVE 3 LAYOUT p.«|
2-35
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This page intentionally left blank
2-36
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During excavation and backfilling operations, erosion and sedimentation controls shall be established to
minimize impacts to downgradient areas of the site, especially Upper Machodoc Creek. Erosion and
Sediment Control Regulations (4VAC 50-30-10 to 110) shall be complied with during these activities.
Backfill
Backfilled material in the French Drain area will consist of common fill with a vegetative topsoil cover.
However, backfilled material in the remaining areas, especially within the swale shall be silty/clay/loam
type of soil similar in geological characteristics to those currently existing at the site. Backfilling shall be
to the extent necessary to maintain or even enhance the area of wetlands reestablishment. The minimum
volume of excavation requiring backfilling is expected to be approximately 139 cubic yards corresponding
to the deeper excavation in the Hot Spot areas H.S. 6 and H.S. 7. Additional backfilling may be used as
required to meet grading requirements and to the extent necessary to prevent excessive ponding of
water. A vegetative cover shall be similar to those currently existing at the site.
Wetlands Restoration
A minimum area of approximately 72.000 square feet shall be planted with wetland species of plants and
shrubs that are similar to those currently existing at the site. The restoration of wetlands at the site shall
be conducted in accordance with the applicable portions of Erosion and Sediment Control Regulations
(4VAC 50-30-10 to 110), Protection of Wetlands and Floodplains (E.O. 11990, 11998), Virginia Water
Protection Permit Regulation (9 VAC 25-210-10 to 260), Wetlands Mitigation Compensation Policy (4
VAC 20-390-10 to 50) and relevant portions of the Clean Water Act (Sections 404 and 401). Additional
wetlands mitigation may be required.
Details of the excavation, backfilling and restoration will be addressed in the detailed design. The actual
quantities of excavated material as determined during remedial design and as a result of implementaton
of the remedy could vary from the estimates presented above.
2.9.2 Summary of the Estimated Remedy Co«t«
The estimated cost of the selected remedy is as follows:
• $ 1,517,000 assuming all of the material will be disposed of at a RCRA Subtitle D landfill
2-37
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The estimated alternative (contingency) cost of the selected remedy is as follows:
$ 2,049,000 assuming that approximately 1.470 cubic yards (consisting of 1,100 cubic
yards from Hot Spots 1, 2, 3, 4 and 5 •«• 370 cubic yards from the French Drain area) will
be disposed of at a RCRA Subtitle C landfill and the remainder of the soil will be disposed
of at a RCRA Subtitle D landfill.
The costs also assume conservatively, that the excavated areas will be backfilled to previous ground
surface elevations. However, as discussed earlier, the excavated areas may need to be backfilled only
partially, depending on the final design requirements for wetlands restoration. Table 2-3 presents a
breakdown of estimated capital costs associated with the remedy and the alternative contingency
remedy, respectively. There are no operating and maintenance costs associated with the selected
remedy, therefore, the 30-year present worth cost is identical to the capital cost.
2-9-3 Expected Outcomes of tha S«l«ctad Rnm«dY
The expected outcomes of implementing the selected remedy in terms of land and resource uses and risk
reduction are as follows:
.-.—, - _ ,,MHWl aw€11Ui U1B aire snail ^
returned to unrestricted use.
• Groundwater currently meets federal primary drinking-water standards (MCLs) for
contaminants associated with the site, and it is anticipated to continue to meet these
standards following the remedial action.
The basis and rationale for the cleanup levels that will allow the selected remedy to meet ecological
protection and human health risk reduction have been described in Section 2.6.2.
2.10 STATUTORY DETERMINATIONS
Remedial actions must meet the statutory requirements of Section 121 of CERCLA 42 U.S.C. 9621 as
discussed below. Remedial actions undertaken at NPL sites must achieve adequate protection of human
health and the environment, comply with ARARs of both Federal and state laws and regulations, be cost-
effective, and utilize, to the maximum extent practicable, permanent solutions and alternative treatment or
2-38
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TABLE 2-3
CAPITAL COST ESTIMATE FOR SELECTED REMEDY
SITE 25-PESTICIDE RINSE AREA
NSWCDL, DAHLGREN, VIRGINIA
PAGE 1 OF 2
Item
#
1.
3.
4.
5.
Cost Item/Components
Mobilization/Demobilization (includes
trailer rental and utilities for 6 months)
Decontamination Facilities (includes
water storage, personnel protective
equipment and wastewater disposal)
Excavation, Disposal, Restoration
(French Drain Area)
Clear and Grub
Excavation
Haul for Disposal
Disposal
Disposal TCLP testing
Confirmatory sampling of excavation
Purchase/haul/place/spread/compact fill
Purchase/haul/place/spread top soil
Revegetate
Excavation, Disposal, Restoration
(Area>Action Levels)
Clear and Grub
Excavation
Haul for Disposal (690 trips® 85 mi/trip)
Disposal
Disposal TCLP testing
Confirmatory sampling of excavation
Purchase/haul/place/spread/compact fill
Purchase/haul/place/spread top soil
Revegetate
Wetlands Restoration
Purchase/haul/place/spread/compact
silty clay fill
Purchase/haul/place/spread loam
Selection/purchase/planting of wetland
species of vegetation
Quantity
1
1
0.1
370
2,380
555
2
5
320
50
333
3.4
9,181
58,650
12,395
4
20
2782
927
5,564
4,139
1,380
1.7
Unit
Is
Is
ac
cy
mile
ton
ea
ea
cy
cy
sy
ac
cy
mi
ton
ea
ea
cy
cy
sy
cy
cy
ac
Unit
Cost
30,000
87,000
1833
1.76
4
25
358
278
8
23
1.60
1833
1.76
4
25
358
278
8
23
1.60
8
23
10,000
Total Cost
30,000
87,000
183
651
9,520
13,875
716
1,390
2,560
1.150
533
6232
16,159
234,600
309,875
1,432
5,560
22,256
21,321
8902
33.112
31,740
17,000
2-39
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TABLE 2-3
CAPITAL COST ESTIMATE FOR SELECTED REMEDY
SITE 25-PESTICIDE RINSE AREA
NSWCDL, DAHLGREN, VIRGINIA
PAGE 2 OF 2
Item
*
KHVBIH^BHMB
6.
Cost Item/Components
otnsr costs
Overheads and G&A Costs
Indirects on labor cost and profit
Health and Safety monitoring
Contingency
Engineering
Total
Quantity
Unit
Unit
Cost
Total Cost
99,344
108,217
55.560
233,351
116,675
1,516,780
or 2,048,832(1>
2-40
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resource recovery technologies. Also, remedial alternatives that reduce the volume, toxicity, and/or
mobility of hazardous waste as the principal element are preferred. The following discussion summarizes
the statutory requirements that are met by the selected remedy.
2-10-1 Protection of Human Haatth and the Environment
The selected remedy will be protective of human health and the environment because the contaminated
soil that could pose a potential risk will be removed from the site.
2.10.2 Compliance wfth ARARs
The selected remedy will meet all identified ARARs as provided in Appendix C. The remedy will comply
with Safe Drinking Water MCLs that are applicable to groundwater at the site since current groundwater
concentrations are already in compliance with these standards and the potential for future impact to the
groundwater by leaching of soil contaminants will be minimized by removal of the contaminated soil. The
selected remedy will comply with Virginia Water Quality Standards because the potential for future impact
to surface water by erosion of contaminated surface soil will be minimized by the removal of
contaminated soil. The selected remedy will also be conducted in compliance with the following action-
specific ARARs:
• Commonwealth of Virginia Erosion and Sediment Control Regulations (4VAC 50-30-10 to
110) applicable to minimizing erosion of surface soil during excavation as well as during
restoration
• Commonwealth of Virginia Ambient Air Quality Standards (9VAC 5-30-260) applicable to
control of dust emissions during excavation/backfilling of contaminated soil
• Executive Order on Wetlands and Ftoodplains (E.O. 11990 and E.O. 11998). Virginia
Water Protection Permit Regulation (9 VAC 25-210-10 to 260) applicable to wetlands
restoration, and Wetlands Mitigation Compensation Policy (4 VAC 20-390-10 to 50)
• Clean Water Act (Sections 404 and 401) relevant portions that address placement of fill
in wetlands
A more detailed evaluation of ARARs is provided in Appendix C.
2-41
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2.10.3 Cost-EffectivanflM
The selected remedy is cost effective because it would provide overall effectiveness proportional to the
cost The selected remedy is very similar in cost to the other alternatives (less than 21 percent higher
than Alternative 2), but removes the contaminated media from the site.
2'10'4 Utilization of Permanent Solution* ind Alternative Treatment Technologic or
Resource Recovery Technologies to the Maximum Extent Practicable
The selected remedy uses a permanent solution that effectively removes the contaminated soil from the
site and disposes of the soil at a permitted landfill offsite. Assuming that a majority, if not all of the soil will
be considered nonhazardous, the soil could potentially be incorporated within daily cover material at the
selected RCRA Subtitle D landfill off site. Therefore, the remedy offers resource recovery to the
maximum extent practicable by reusing the soil under controlled conditions.
2.10.5 Preference for Treatment as « Principal Element
The selected remedy does not utilize treatment as a principal element The evaluation of treatment
technologies has shown that there are no practical and cost effective processes that can remove both
pesticide and inorganic contaminants from the soil while maintaining suitable geological characteristics for
reuse for this site.
2.10.6 Five-Year Ravlew Requirement*
Because this remedy will not result in hazardous substances remaining onstte above levels that allow for
unlimited use and unrestricted exposure, a five-year review will not be required for this remedial action.
2.10.7 Documentation of Significant Change*
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.
No significant changes were made to the recommended remedial action alternative in the Proposed Plan.
2-42
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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 25 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 questions were addressed. A summary of questions and answers of the public
meeting are attached 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 Board (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 25 were
discussed at the RAB meetings.
Community relations activities for the final selected remedy include the items below:
• The documents concerning the investigation and analysis at Site 25, 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.
3-1
-------
A Public Meeting was held July 28. 1999 to answer any questions concerning the Site 25
Proposed Plan. Approximately 10 people, including Federal, state, and local government
representatives attended the meeting.
3-2
-------
APPENDIX A
COMMONWEALTH OF VIRGINIA CONCURRENCE LETTER
-------
-------
SEP.-23'99(THU) 13 = 17 DEQ TEL: 8046984234
P. 002
COMMONWEALTH of VIRQINIA
DEPARTMENT OF ENVIRONMENTAL QUALITY Dt.HH.Twey
Sevtoddrta: 639 EM Una Sin*; Udunond. VUiink 33JI9 Direclor
UdltntoJ+tu: P.O. Box 10009, KfcfaniBd, Vbgfaii 23240
*taP«lW<>odl*y.Jr. F«c(I04)«9«-tttO TOD (KM) 69*^021
September 23, 1999
Mr.-Abraham Ferdjis, Division Director
Hazardous Site Cleanup Division (3HSOO)
U.S. Environmental Protection Agency, Region HI
1650 Arch Street
Philadelphia, PA 19103-2029
Re: Concurrence with Record of Decision for Site 25. NSWC Dahlgran, Virginia
Dear Mr. Ferdas:
The Virginia Department of Environmental Quality staff has reviewed the Record
of Decision ("ROD") for Site 25, the Pesticide Rinse Area at the Naval Surfece Warfare
Center, Dahlgren, Virginia. On behalf of the Commonwealth of Virginia, we concur with
the selected remedial alternative as outlined in the ROD dated September 1 999.
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 Beach, EPA Region m
Has*anVak3li,VDEQ
Durwood Willis, VDEQ
Dave Cillisp-ie, VDEQ
-------
-------
APPENDIX B
PUBLIC COMMENTS
-------
-------
APPENDIX B
SUMMARY OF QUESTIONS FROM 28 JULY 99 PUBLIC MEETING
How do you determine If you've removed all of the contaminated «oll?
°S,£%(Cavation' a Veiification Sampling Plan is reviewed and approved by U.S. EPA Region
VDEQ and the Navy. The Plan outlines an approach for sampling (i.e., grid or random) Once
the excavation is performed, sampling and analysis is performed at these locations This
information is reviewed by the regulators and the Navy fora decision on the remaining soils.
Will there be problems during excavation due to wet conditions?
Site 25 may contain wet areas, however, we will minimize construction during wet times of the
year by performing this operation toward the end of summer, during dryer periods Should we
encounter wet soils, they will be stabilized prior to offsite transportation and disposal
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O8/20/9B
07 -. O7
'9340 083 2339
SAFETY * ETTV C28 -•*- EFA Cbas Code IS
®002
1
2
3
4
5
6
O 7
R •
I *
G 10
I 11
Nl2
A 13
L 14
15
is
17
16
19
20
21
NAVAL SEA SYSTEMS COMMAND
NAVAL SURFACE WARFARE CENTER
DAHLGREN DIVISION
PUBLIC MEETING
THURSDAY, JULY 28, 1999, 7:00 P.M.
KINO OEORGE 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 Regz.cn III
Hazardous Site Cleanup Division
Federal Facilities Section
Mr. Bruce Beach
1650 Arch Street. Philadelphia, Pennsylvania 18107
Virginia Department of Environmental Quality
Mr. David Gilliarpie
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 fc ASSOCIATES, Court Reporterm
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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 propoaad remedial action* for three
sites at the Naval Surface Warfare Center, that the
Navy, the Commonwealth of Virginia and the
Bnvironmental Protection Agency have chosen as the
proposed plane 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 Dahlgran 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 fc ASSOCIATES, Court Reporters
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that does all our investigations for u» and moat of
the design work, all of hie Tetratech teams. So,
Dave, I'll let you take it away.
MR. MISENHIMER: Okay.
MS. SWOFE: Oh, one more thing. I'm
sorry. Just so you know, this is -- we have a court
reporter here. We're recording everything tonight.
Your comments are welcome, but we want to document-
thoee commentB 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'a reversed.
MR. MXSSNKXMZR: I don't know what
PRANCES K. HALEY & ASSOCIATES, Court Reportera
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happened here. Let•• cry this again.
MS. SWOPE: It was working
beautifully, too.
MR. MISENHXMER: Yeah, it was
working.
MR. FUSCALDO: You got a discount
because it's upside down.
MS. SWOPE: Exactly. You can show
the location on the map.
MR. MISBNHIMBR: Yeah. The three
sites that we're dealing with — Site 19, is located
right here. Thie is main side, here's 301, the
Potomac River, Upper Machodoc 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
start out with Site 29 -- Site 19. And both, Site
19 and 29, are grouped together because these are
FRANCES K. HALEY 6 ASSOCIATES, Court Reporters
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two Bites 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 this 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 4O, which is another site that
is currently undar investigation in the Installation
Restoration Program at Dahlgren. And there's some
FRANCES K. HALEY fc ASSOCIATES, Court Reporters
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concrete pad*, here, where they stored the
transformers and this is generally the area where
transformer oil waa dumped. This area, in general,
ig 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 the 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 is over in this area and
this is the area where, in 1994, the contaminated
soil was removed. The 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
PRANCES K. HALEY fc ASSOCIATES, Court Reporters
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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 successful in getting all
the contaminated soil out of there and verification
sampling verified that we did reach thac 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 h«re. In terms of groundwater,
because wa have Site 40 very close by and that eite
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. MISBNHIMER: Right.
MR. FTJSCALDO: The clinic is there
someplace now, isn't it? The temporary clinic.
MS. SWOPB: Yes.
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MR. PUSCALDO: 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. hez-e.
MR. FUSCALDO: 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 1594 wae sufficient and that no further
action ±m required for the soils in that area, and
the groundwater, again, as I said, be evaluated with
an adjacent site. And that's pretty much all I was
going to oay about Site 19. Are there any
questions?
MR. FUSCALDO•. And Site 40, what was
that again?
MS. SWOPE: That's a atoraga lot,
•crap metal.
FRANCES 1C. HAUSY 6 ASSOCIATES, Court Reporters
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MR. MISENHIM2R: Now, let's aee if I
can pull it up. Okay. Site 29 is the second site
we want to talk about today. This Lm 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. Thie area in red, within this area
here is where the neutralization pit was located and
it'e --
MS. SWOPB: (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. Juat 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-
FFANCES K. HALEY fc ASSOCIATES, Court Reporters
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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 -- ao. we had to dig
that up to find the neutralization put and remove
any contaminated soil that surrounded it.
MR. FUSCALDO: Now, I remember
this — I don't know how many -- how many meetings
ago it was that -- when this thing wae 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,
haa 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 6 ASSOCIATES, Court Reporters
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PHONE; C540)898-1527 FAX: (540)898-6154
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that encompassed about twenty-two feet by about
thirty-eight feet. We went down seven feet. Before
we got started, we had some preliminary goals in
terma 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
site.
MS. SWOPS: When we removed that, we
removed a couple of oil separators that were old, an
old oil tank.
MR. MISENHIMER; Right, right. Yes.
MS. SWOPS: There was a lot of things
in the area, so we got rid of it all together.
MR. FUSCALDO: I remember it was a
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real bad site.
MS. SWOPE: Right.
MR. FUSCALDO: Like most of that old
•tuff is.
MR. MISENHIMER: Okay. So, the
contaminants that we were concerned about are listed
up here; antimony, arsenic, iron, lead and mercury.
So. ae I said, when the soil was removed, we took
samples and these were the things that we were
cheeking on. And then, when we did the risk
assessment, we did it based on these contaminants.
So, in summary, we £•«! that
there's no need for any further action on the soils
at Sits 29 and that, baaed 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, ok«y.
MS. VAN DE WEERT: Landfills?
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MR. MISENHIMER: Yes. 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 PCS -- the PCS
•oil -- this soil went to a cemant kiln, brick kiln,
I think. And then, the PCS soil went to one of very
few PCS facilities that either landfill it or burn
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 juat doesn't get
moved somewhere else to be 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 ef times, mo you get some
valuable uee out of it.
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MR. MISBNH1MER: Any more questions?
Okay. Our next sit* ic Site 25, known as the
pesticide rinse area. And this is an area where
pesticide containers were rinsed outside and the
containers were then -- whatever was left was
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
shove 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 containers were rinsed was out in this
area, here, and whatever was left 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 fe ASSOCIATES, Court Reporters
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1 the pesticides that may be present there. And then.
2 this area, here, where we know things were dumped on
3 the ground.
4 The other thing I gueea I wanted
5 to point out on this slide is that this is a
6 drainage through here. It's kind of an intermittent
7 drainage way and it ia -- 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 29 is
somewhere over in this direction. The cooling ponds
12 are over here. And this ia Site 25. So,
ultimately, any overland flow drains down in this
14 direction and into the Upper Machodoc Creek.
15 This is a site photo. Looking
16 towards the Potomac River and Upper Machodoc Creek
17 over in this direction. This is part of the wetland
18 area in here and this is a monitoring well.
19 Now, this diagram shows what the
20 preferred alternative is and it may be difficult to
21 see this in the back there, but on the handout, thie
PRANCES K. HALEY & ASSOCIATES, Court Reporters
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little handout here, it might be easier to follow.
There's a green line here that outlinea 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-aite 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
ease, the material that would be hauled off would go
to landfill and Used as a daily cover at a landfill.
The level* of contaminants are not that high that it
would require any treatment prior to going to a
landfill.
After this araa, 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 down as far as
four -- four or five feet. This area would then be
regraded to -- back to the existing ar*a and the
FRANCES K. HALEY fc ASSOCIATES, Court Reporters
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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 -- 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, ian't it?
MR. MISENHIMBR: 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 nnd take samples. So.
as you're excavating this, we will typically grid
this area off and then take samples at different
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point:* and baaed on those sampling results, we'll
decide, okay, is it okay or do we need to remove
some more coil.
MR. FUSCALDO: How do you work that
aite when it's 00 wet in there.
MS. SWOPS: We could it right now.
MR. FUSCALDO: Okay.
MR. MISENHIMSR: That's a good point.
MR. FUSCALDO: That gives mm 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.
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MR. PUSCALDO: 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 as wetland and not replace -- you know,
not have to haul in clean dirt, just regrade and
make it a better wetlands.
MR. FDSCALDO: Good idea. Good idea.
MR. MISENHIMER: Any other questions?
okay.
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 some more
questions that you'd rather not be recorded.
MR. FUSCALiDO: I'm personally
finished.
MS. SWOPE: Okay. Patty, do you have
any more questions?
MS. VAN DE WEERT: Mo.
PRANCES K. HALEY fc ASSOCIATES, Court Reporters
10500 Waketnan Drive. Suite 300, Fredericksburg, VA 22407
PHONE: (540)896-1527 FAX: (540)898-6154
8T
BTOi CC» Z02 TVd TC:fiO
86/Ot/«0
-------
08/20/99
853
•AFETY
..... SFA
12)021
2.0
MS. SWOFE: Anyone? Captain?
MR. MISENHIMER: one thing that I
guess should be mentioned i, that the cOnun.nt p.riod
•tarted l«»t Wednesday.
MS. SWOPB: It waa announced in the
Free Lane*.
MR. MISENHIMER: Right. And it goes
for thirty day, and the comment p«riod «mdB
August --
MS. SWOPE: 19th.
MR. MISENHIMER: Augu«t 19th.
MS. SWOPE: so, you are welcome to
Bubmit written comments to the location, on the back
anytime before August lath. if you think of
aomething else or you pa8B the information to
someone who ha» question*, we welcome any gue8tione
or comments. Anybody else? We'll officially close
the comment period then.
MEETING CONCLUDED AT 7:32 P.M.
FRANCES K. HALEY ft ASSOCIATES, Court Reporter,
Wakeman Drive. Suite 300, Predericjcaburg, VA 22*07
PHONE: (540)898-1527 PAX-. (540)898-6154
epoo
•m m zoz ivj TC:«OHJ ee/o
-------
09/20/98 07:13
SArtTV * ENV CSS -.--. HFA CJjec Code II
CERTIFICATE OP COURT REPORTER
I, Lola Gail Serrett, hereby certify that I waB tin
Court Reporter at the Public Meeting held at King Oeorge
Courthouse, King George, Virginia, on July 28, 1999, at the
time of the meeting herein.
I further certify that the foregoing transcript is
true and accurate record of the proceeding herein.
Given under my hand this 3let day of July, 1999.
SERRETT
Reporter
PILE: P072899L.HRS
FRANCES K. HALEY fe ASSOCIATES, Court Reporter*
10500 Wakeman Drive. Suits 300, Fredericksburg, VA 22407
PHONE: (540)898-1527 FAX: (540)898-6154
ST
CC» ZOZ IVd ZC:80 IHd 66/02/80
-------
-------
APPENDIX C
APPLICABLE OR REVELANT AND APPROPRIATE REQUIREMENTS
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APPENDIX C
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
SITE 25 PESTICIDE RINSE AREA
NSWCDL, DAHLGREN, VIRGINIA
ARARorTBC
Statut
Reguli
1. LOCATION SPECIFIC
Endangered Species
Act of 1978
Virginia Endangered
Species Regulations
Rules and
Regulations for the
Enforcement of the
Endangered Plant
And Insect Species
Act
The Archaeological
and Historical
Preservation Act of
1974
Virginia Natural Area
Preserves Act
Migratory Bird Area
16 USC §15
SOCFRParl
4 VAC 15-2C
to 140
2 VAC 5-32C
16 USC §46
Va. Code An
10.1-209 to 2
16 USC §702
Classification
Applicable
Applicable
Applicable
Applicable
To Be
Considered
Applicable
Requirement Synopsis
Act requires federal agencies to ensure that
any action authorized by an agency is not likely
to jeopardize the continued existence of any
endangered or threatened species or adversely
affect its critical habitat.
Similar Virginia requirements for submittal and
review of environmental assessments.
Applicability to Remedial
Alternatives
Requires actions to avoid potential loss or
destruction of significant scientific, historical, or
archaeological data.
Allows for preservation of certain significant
ecological systems.
Protects almost all species of native birds in the
U.S. from unregulated "take" which can include
poisoning at hazardous waste sites.
Potentially affected endangered
species have not been identified
The remedial action will be
implemented so resources are not
adversely affected should any be
identified in the future.
Site is not known to be within a
historically significant area. If
future resources are identified
actions will be taken to ensure
compliance.
If specific species are found,
actions will be taken to eliminate
or minimize degradation to these
resources.
Remedy will be implemented to
ensure that wastes have no
mpacts to native birds.
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APPENDIX C
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
SITE 25 PESTICIDE RINSE AREA
NSWCDL, DAHLGREN, VIRGINIA
ARARorTBC
Chesapeake Bay
Preservation Area
Designation and
Management
Regulations
Standards for
Owners and
Operators of
Hazardous Waste
Treatment, Storage,
and Disposal
Facilities
Virginia Water
Protection Permit
Regulation
Executive Order
11988, Protection of
Fkxxfplains
Statute or
Regulation
9 VAC 10-20-10 to
280
40 CFR 264.18 (b)
9 VAC 25-210-10 to
260
40 CFR 6. Appendix
A; excluding Sections
6(a)(2), 6(a)(4).
6(a)(6); 40 CFR 6.302
Classification
Relevant and
Appropriate
Applicable
Applicable
Applicable
Requirement Synopsis
Requires that certain locally designated tidal
and non-tidal wetlands and other sensitive
areas be subject to limitations regarding land-
disturbing activities, removal of vegetation, use
of impervious cover, erosion and sediment
control, and stormwater management.
Applies to treatment, storage, or disposal of
hazardous waste within a 100 year floodplain
area.
Facility or activity design must adequately
address the issues arising from locating
facilities in wetlands and delineated wellhead
protection areas (determined vulnerable).
Federal agencies should avoid to the extent
possible adverse impacts associated with the
destruction or modification of floodplains.
Applicability to Remedial
Alternatives
Remedy implementation will
require construction activities.
Actions will address the regulatory
requirements.
Remedy implementation may
produce hazardous wastes within
the 100 year floodplain area.
Hazardous wastes, if
encountered, will be managed
consistent with Federal and
Virginia requirements.
Remedy implementation will
impact a wetland area. The
remedy will minimize impacts to
the wetlands and will restore
wetlands areas on the facility.
Site is partially in the 100 year
floodplain. Remedy will be
installed in the floodplain and will
be designed and constructed to
minimize impacts to floodplain
resources.
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APPENDIX C
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
SITE 25 PESTICIDE RINSE AREA
NSWCDL, DAHL6REN, VIRGINIA
ARARorTBC
Executive Order
11990. Protection of
Wetlands
Clean Water Act of
1972 (CWA) Section
404
Wetlands Mitigation
Compensation Policy
Statute or
Regulation
40 CFR 6.
Appendix A
33 USC §§1344
4 VAC 20-390-10 to
50
Classification
Applicable
Applicable
Requirement Synopsis
Federal agencies should avoid to the extent
possible adverse impacts associated with the
destruction or modification of wetlands.
The Federal agencies should request Va.
Marine Resources Commission (VMRC)
determine jurisdiction of the wetlands and
applicable regulatory requirements.
Applicability to Remedial
Alternatives
Portions of the site are
characterized as wetlands.
Remedy implementation will be
designed and constructed to
restore wetland impacts.
The Navy will contact the VMRC
concerning this project.
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APPENDIX C
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
SITE 25 PESTICIDE RINSE AREA
NSWCDL, DAHLGREN, VIRGINIA
ARARorTBC
Statute or
Regulation
Classification
Requirement Synopsis
Applicability to Remedial
Alternatives
II. ACTION SPECIFIC
Virginia Solid Waste
Management
Regulations
9 VAC 20-80-10 to
790
Part IV. Management
of Open Dumps and
Unpermitted Facilities
Applicable
Applicable
Prescribes the requirements for cleanup and
corrective action for remediation of releases
that have occurred as the result of improper
management of solid wastes.
Requires the remedy to alleviate the conditions
that may cause the facility to be classified as an
open dump.
Solid wastes at Site 25, shall be
handled under these regulations.
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APPENDIX C
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
SITE 25 PESTICIDE RINSE AREA
NSWCDL, DAHL6REN, VIRGINIA
ARARorTBC
Statute or
Regulation
Classification
Requirement Synopsis
Applicability to Remedial
Alternatives
Virginia Hazardous
Waste Management
Regulations
EPA's Area of
Contamination (AOC)
Policy
EPA's Contained-in
Policy
9 VAC 20-60-12 to
1505
9 VAC 20-60-261
Policy
Policy
Applicable
Applicable
To Be
Considered
To Be
Considered
Applies to treatment, storage, or disposal of
hazardous waste.
Provides that certain hazardous waste
remaining in "empty" containers are not
regulated as hazardous waste.
Allows hazardous waste to be managed within
discrete areas without triggering hazardous
waste regulatory requirements.
Allows the choice of appropriate health-based
levels (for diekJrin) above which contaminated
media must be handled as if it were a
hazardous waste.
Hazardous wastes encountered
will be managed consistent with
Federal and Virginia requirements.
Rinseate from empty non-acutely
toxic pesticide (such as DDT)
containers are exempt.
Waste generated on-site may be
stored temporarily on-site prior to
off-site disposal.
Contaminated soils at Site 25 do
not contain listed hazardous waste
and therefore are not
automatically subject to LDRs.
This policy applies to
contaminated soils containing
dieldrin.
Regulations
Governing the
Transportation of
Hazardous Materials
9 VAC 20-110-10 to
130
Applicable
Applies to transportation of hazardous waste.
Hazardous wastes, if
encountered, will be managed.
consistent with Federal and
Virginia requirements.
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APPENDIX C
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
SITE 25 PESTICIDE RINSE AREA
NSWCDL, DAHLGREN, VIRGINIA
ARARorTBC
Military Munitions
Rules
DoD Guidance on
Property
Contaminated with
Ammunition,
Explosives or
Chemical Agents
Erosion and
Sediment Control
Regulations
Statute or
Regulation
(40 CFR 260-266 and
270)
DoD 6055.9-STD
4 VAC 50-30-10 to
110
Classification
To Be
Considered
To Be
Considered
Applicable
Requirement Synopsis
Recently promulgated regulations in response
to Section 107 of the Federal Facilities
Compliance Act of 1992, identifying when
conventional and chemical military munitions
become hazardous waste. Applications of the
rules are a TBC' until adopted by states
authorized to administer RCRA.
Dod guidance document stipulating policy and
procedure to provide protection of personnel
resulting from DoD ammunition, explosives or
chemical agent contamination. Includes
property currently or formerly owned, leased or
used by DoD, and calls for identification and
control at active installations, and provides
guidance for potential land disposal.
Erosion and sediment control plans are to be
submitted for land-disturbing activities, and be
in compliance with of the locality and/or local
soil and water conservation district.
Applicability to Remedial
Alternatives
Ordnance-related wastes
potentially buried at Site 25 will be
managed in compliance with the
rules.
Excavation of Site 25 will be
completed to be consistent with
DoD policy and procedures to
address safety issues should UXO
issues arise.
Construction activities will disturb
the land in the vicinity of the site.
Activities will address Virginia
erosion and sediment control
requirements.
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APPENDIX C
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
SITE 25 PESTICIDE RINSE AREA
NSWCDL, DAHLGREN, VIRGINIA
ARARorTBC
1C
Statute or
Regulation
(
AIR
Ambient Air Qualtiy
Standards
Visible and Fugitive
Dust Emissions
Standards of
Performance for
Toxic Pollutants
9 VAC 5-30-10 to 80
9 VAC 5-30-20
9 VAC 5-30-60
9 VAC 5-50^0 to 120
9 VAC 5-50-160 to
230
WATER
Criteria for
Classification of Solid
Waste Disposal
Facilities and
Practices
Water Quality
Standards
49 CFR 257.3-3(a)
33 USC §§1288 &
1342
Requirement Synopsis
Applicable
Applicable
Applicable
Applicable
9 VAC 25-260-5 to
550
Potentially
Applicable
Applicable
Control of Paniculate Matter (TSP)
Control of Particulate Matter (PM10)
Standards for visible and/or fugitive dust
emissions.
Standards of performance for toxic pollutants.
A facility shall not cause a discharge of
pollutants into the waters of the U. S. that is in
violation of the substantive requirements of the
NPDES under CWA Section 402, as amended.
Standards and criteria for State waters,
including wetlands.
Applicability to Remedial
Alternatives
Visible and Fugitive Dust
emissions from remedial actions
shall be controlled, as necessary.
Toxic pollutants are not expected
during remedial actions; however,
corrective action will be performed
if problems arise.
No discharges under the remedy
are planned. In addition. NPDES
program is delegated to Virginia
(VPDES). Potentially applicable
for situations potentially not
covered by VPDES.
Provides standards for evaluating
State waters and wetlands at Site
25.
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APPENDIX C
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
SITE 25 PESTICIDE RINSE AREA
NSWCDL, DAHLGREN, VIRGINIA
ARARorTBC
Virginia Pollutant
Discharge
Elimination System
(VPDES)
Virginia Pollution
Abatement (VPA)
Permit Regulation
Stormwater
Management
Regulations
Statute or
Regulation
9 VAC 25-31-10 to
940
9 VAC 25-32-10 to
300
4 VAC 3-20-10 to 251
Classification
Applicable
Applicable
Applicable
Requirement Synopsis
Procedures and requirements for discharging
pollutants into surface waters, or any activity
which impacts physical, chemical or biological
properties of surface waters.
Criteria for Stormwater Management.
Applicability to Remedial
Alternatives
Excavation, backfilling and
regrading Site 25 not expected to
produce waste liquids that would
be discharged to surface waters.
Excavation, backfilling, and
regrading of Site 25 will include
applicable Stormwater
management requirements.
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APPENDIX D
CALCULATION WORKSHEETS
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APPENDIX D
CALCULATION WORKSHEET
Page 1 of 2
CLIENT:
DAHLGREN, SITE 25
JOB NUMBER:
0291
SUBJECT: — —
CALCULATION OF SOIL HEALTH-BASED LEVELS FOR THE CONSTRUCTION WORKER
SCENARIO
BASED ON:
USEPA, DEC. 1989
BY:
T. Jackman
CHECKED BY:
/to
-------
CALCULATION WORKSHEET
Page 2 of 2
CLIENT:
DAHLGREN. SITE 25
JOB NUMBER:
0291
SUBJECT:
CALCULATION OF SOIL HEALTH-BASED LEVELS FOR THE CONSTRUCTION WORKER
SCENARIO
BASED ON:
USEPA, DEC. 1989
BY:
T. Jackman
CHECKED BY:
/fi«n tf/toni
DATE:
Calculation of Soil Health-Based Level for Dieldrin- Carcinogenic Effects
Cs = 48 mg/kg
TCR = 1.0E-4
Risk2S - 5E-5 (Ingestion) + 5.2E-5 (Dermal) = 1.0E-4
SRG=
48xl.O£-4
l.QE-4
SRG (Dieldrin) » 48 mg/kg
Since the health-based level calculated for noncarcinogenic effects is lower, i.e., more
conservative, this value, 5.4 mg/kg, is the level chosen for construction worker exposure to
dieldrin.
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APPENDIX E
TOXICITY PROFILES
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TOXICITY PROFILES - DAHLGREN, SITE 25
ALDRIN AND DIELDRIN
Aldrin and dieldrin mainly affect the central nervous system. Accidental or intentional ingestlon of
high levels of aldrin and dieldrin result in convulsions and death. Ingesting moderate levels of
aldrin or dieldrin over a longer period may also cause convulsions. This occurs because aldrin
and dieldrin build up in our bodies.
The effects of exposure to low levels of aldrin or dieldrin over a long time are not known. Some
workers who made or applied the insecticides had nervous system effects with excitation leading
to convulsions. Lesser effects in some workers included headaches, dizziness, vomiting
irritability, and uncontrolled muscle movements. Workers removed from the source of exposure
rapidly recovered from most of these effects. Studies in animals indicate that aldrin or dieldrin
may reduce the body's ability to resist infection.
The International Agency for Research on Cancer has determined that aldrin and dieldrin are not
classifiable as to their carcinogenicity to humans. There is no direct evidence that aldrin or
dieldrin causes cancer in humans. Studies on workers generally show no increase in cancer or
deaths due to cancer. Mice given high amounts of dieldrin, however, did develop liver cancers.
Aldrin and dieldrin are classified as Class B2 carcinogens by the EPA.
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 EPA 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.
ANTIMONY
Ingested antimony is absorbed slowly and incompletely from the gastrointestinal (Gl) tract Within
a few days of acute exposure, highest tissue concentrations are found in the liver, kidney, and
thyroid. Organs of storage include skin, bone, and teeth. Highest concentrations in deceased
smelter workers (inhalation exposure) occurred in the lungs and skeleton.
Acute intoxication from ingestion of large doses of antimony induces Gl disturbances,
dehydration, and cardiac effects in humans. Chronic effects from occupational exposure include
irritation of the respiratory tract pneumoconiosis, pustular eruptions of the skin called "antimony
spots," allergic contact dermatitis, and cardiac effects, including abnormalities of the
electrocardiograph (ECG) and myocardial changes. Cardiac effects were also observed in rats
and rabbits exposed by inhalation for six weeks and in animals (dogs, and possibly other species)
treated by intravenous injection.
Chronic oral exposure resulted in reduced longevity in both species and in reduced mean heart
weight in the rats. The EPA verified an RfD of 0.0004 mg/kg/day for chronic oral exposure to
antimony from the LOAEL of 5 ppm potassium antimony tartrate (0.35 mg antimony/kg body
weight-day) in the lifetime study in rats. The heart is considered a likely target organ for chronic
oral exposure of humans.
Antimony is classified in EPA cancer weight-of-evidenos Group D (not classifiable as to
carcinogenicity to humans).
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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.
BARIUM
The soluble salts of barium, an alkaline earth metal, are toxic in mammalian systems. They are
absorbed rapidly from the gastrointestinal tract and are deposited in the muscles, lungs, and
bone. Barium is excreted primarily in the feces. At low doses, barium acts as a muscle stimulant
and at higher doses affects the nervous system eventually leading to paralysis. Acute and
subchronic oral doses of barium cause vomiting and diarrhea, followed by decreased heart rate
and elevated blood pressure. Higher doses result in cardiac irregularities, weakness, tremors
anxiety, and dyspnea.
Subchronic and chronic oral or inhalation exposure primarily affects the cardiovascular system
resulting in elevated blood pressure. Human data were used by the EPA to calculate a chronic
and subchronic oral reference dose (RfD) of 0.07 mg/kg/day. Subchronic and chronic inhalation
exposure of human populations to barium-containing dust can result in a benign pneumoconiosis
called "baritosis." This condition is often accompanied by an elevated blood pressure but does
not result in a change in pulmonary function. However, Reproductive and developmental effects
and increased fetal mortality in rats were also observed after inhalation exposures. An inhalation
reference concentration (RfC) of 0.005 mg/m3 for subchronic and 0.0005 mg/m3 for chronic
exposure was calculated by the EPA based on the NOAEL for developmental effects which have
not been substantiated in humans.
BENZOFA1PYRENE (BAP1
In the risk assessment for Site 25, PAHs are evaluated as benzo(a)pyrene equivalents, where:
Benz[a]anthracene =0.1 BAP
Benzo[b]fluoranthene = 0.1 BAP
Dibenz[a,h]anthracene = BAP
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.
-------
PAHs are ubiquitous, being released to the environment from anthropogenic as well as from
natural sources. Benzo (a)pyrene is the most extensively studied member of the class inducing
tumors in multiple tissues of virtually all laboratory species tested by all routes of exposure.
Because of the lack of human cancer data, assignment of individual PAHs to EPA cancer weight-
of-evidence groups was based largely on the results of animal studies with large doses of purified
compound. Benzo (a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene
chrysene, dibenzo(a,h)anthracene, and indeno(1,2,3-cd)pyrene were classified in Group B2
(probable human carcinogens).
The EPA (1998) 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. Largely because of this precedent,
the quantitative risk estimates for benzo(a)pyrene were adopted for the other carcinogenic PAHs
when quantitative estimates were needed.
Human data specifically linking benzojajpyrene (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 was sufficient The animal data consist of dietary, gavage
inhalation, intratracheal instillation, dermal and subcutaneous studies in numerous strains of at
least four species of rodents and several primates. 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 EPA publishes 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 are available for the other PAHs. Largely because of this precedent, the
quantitative risk estimates for benzo(a)pyrene were adopted for the other carcinogenic PAHs
when quantitative estimates were needed.
BIS(2-ETHYLHEXYL)PHTHALATE
Bis(2-ethylhexyl)phthalate is a colorless oily liquid that is extensively used as a plasticizer in a
wide variety of industrial, domestic and medical products. It is an environmental contaminant and
has been detected in ground water, surface water, drinking water, air, soil, plants, fish and
animals. It is rapidly absorbed from the gastrointestinal tract primarily and can be absorbed
through the skin and from the lungs.
Animal studies have indicated that the primary target organs are the liver and kidneys. However,
higher doses are reported to result in testicular effects and decreased hemoglobin and packed
cell volume. Studies on occupational exposures to mixtures of phthalate esters containing bis(2-
ethylhexyOphthalate have reported sensory-motor effects and decreased leukocytes and
hemoglobin in some exposed workers. Developmental toxicity studies with rats and mice have
shown that bis(2-ethylhexyl)phthalate is fetotoxic and teratogenic when given orally during
gestation. Oral exposure has also been shown to result in decreased sperm count in rats. A
Reference Dose (RfD) for both subchronic and chronic oral exposure was calculated from a
lowest-observed-adverse-effect level (LOAEL) based on increased relative liver weight in guinea
pigs.
Bis(2-ethylhexyl)phthalate was assigned to weight-of-evidence Group B2, probable human
carcinogen, on the basis of an increased incidence of liver tumors in rats and mice.
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CHROMIUM
In nature, chromium (111) 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
DDT. DDE, and ODD
DDT affects the nervous system. People who accidentally swallowed large amounts of DDT
became excitable and had tremors and seizures. These effects went away after the exposure
stopped. No effects were seen in people who took small daily doses of DDT by capsule for 18
months. People who worked with DDT for a long time had some reversible changes in the levels
of liver enzymes.
In animals, short-term exposure to large amounts of DDT in food affected the nervous system. In
animals, long-term exposure to DDT affected the liver. Animal studies suggest that short-term
exposure to DDT in food may have a harmful effect on reproduction.
The Department of Health and Human Services (DHHS) has determined that DDT may
reasonably be anticipated to be a human carcinogen. DHHS has not classified DDE and DDD,
but the Environmental Protection Agency (EPA) has determined that they are probable human
carcinogens. Liver cancer has been seen in animals that were fed DDT. Studies in DDT-
exposed workers did not show increases in cancer.
DIELDRIN
Dieldrin is an insecticide which from 1950-1970 was a popular pesticide for crops like corn and
cotton. Because of concerns about damage to the environment and the potential harm to human
health, EPA banned all uses of diekjrin in 1974 except to control termites. In 1987, EPA banned
all uses. Exposure to dieldrin happens mostly from eating contaminated foods, such as root
crops, fish, or seafood. Dieldrin build up in the body after years of exposure and can damage the
nervous system.
Exposure to dieldrin mainly affect the central nervous system. Ingestion of high levels of dieldrin
result in convulsions and death. These levels are many thousands of times higher than the
average exposure. Ingesting moderate levels of dieldrin over a longer period may also cause
convulsions. We don't know the effects of exposure to low levels of dieldrin over a long time.
Some workers who made or applied dieldrin had nervous system effects with excitation leading to
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convulsions. Lesser effects in some workers included headaches, dizziness, vomiting, irritability,
and uncontrolled muscle movements. Workers removed from the source of exposure rapidly
recovered from most of these effects. The EPA had established an oral RfD of 5E-5 mg/kg-day
for dieldrin based on liver lesions in rats from a 2-year study.
There is no direct evidence that dieldrin causes cancer in humans. Studies on workers generally
show no increase in cancer or deaths due to cancer. Mice given high amounts of dieldrin,
however, did develop liver cancers. Dieldrin has been classified as a probable human carcinogen
(B2) by the EPA because it caused tumors in rodents when administered orally.
CHLORINATED DIBENZO-P-DIOXINS fCDDSl
The most noted health effect in people exposed to large amounts of 2,3.7,8-TCDD is chloracne.
Chloracne is a severe skin disease with acne-like lesions that occur mainly on the face and upper
body. Changes in blood and urine that may indicate liver damage also are seen in people.
Exposure to high concentrations of CDDs may induce long-term alterations in glucose
metabolism and subtle changes in hormona llevels.
Exposure to lower levels can cause a variety of effects in animals, such as weight loss, liver
damage, and disruption of the endocrine system. In many species of animals, 2,3,7,8-TCDD
weakens the immune system and causes a decrease in the system's ability to fight bacteria and
viruses. In other animal studies, exposure to 2,3,7,8-TCDD has caused reproductive damage
and birth defects. Some animal species exposed to CDDs during pregnancy had miscarriages
and the offspring of animals exposed to 2,3,7,8-TCDD during pregnancy often had severe birth
defects including skeletal deformities, kidney defects, and weakened immune responses.
Several studies suggest that exposure to 2,3,7,8-TCDD increases the risk of several types of
cancer in people. Animal studies have also shown an increased risk of cancer from exposure to
2,3,7,8-TCDD. The EPA and the World Health Organization (WHO) has determined that 2,3,7,8-
TCDD is a human carcinogen.
ENDRIN
Endrin is a solid, white, almost odorless substance that was used as a pesticide to control
insects, rodents, and birds. Endrin has not been produced or sold for general use in the United
States since 1986. Littte is known about the properties of endrin aldehyde (an impurity and
breakdown product of endrin} or endrin ketone (a product of endrin when it is exposed to light).
Endrin does not dissolve very well in water. It has been found in groundwater and surface water,
but only at very low levels. It is more likely to cling to the bottom sediments of rivers, lakes, and
other bodies of water. The persistence of endrin in the environment depends highly on local
conditions. Some estimates indicate that endrin can stay in soil for over 10 years.
Exposure to endrin can cause various harmful effects including death and severe central nervous
system (brain and spinal cord) injury. Swallowing large amounts of endrin may cause
convulsions and kill you in a few minutes or hours. Symptoms that may result from endrin
poisoning are headaches, dizziness, nervousness, confusion, nausea, vomiting, and convulsions.
No long-term health effects have been noted in workers who have been exposed to endrin by
breathing or touching it Studies in animals confirm that endrin's main target is the nervous
system. Birth defects, especially abnormal bone formation, have been seen in some animal
studies.
In studies using rats, mice, and dogs, endrin did not produce cancer. However, most of these
studies did not accurately evaluate the ability of endrin to cause cancer. No significant excess of
cancer has been found in exposed factory workers. The EPA has determined that endrin is not
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classifiable as to its human carcinogenicity because there is not enough information to allow
classification.
HEPTACHLOR AND HEPTACHLOR EPOXIDE
Heptachlor is a manufactured chemical and doesn't occur naturally. Pure heptachlor is a white
powder that smells like camphor (mothballs). The less pure grade is tan. Heptachlor was used
extensively in the past for killing insects in homes, buildings, and on food crops especially com
Use slowed in the 1970s and stopped in 1988. Heptachlor epoxide is also a white powder and is
a breakdown product of heptachlor. The epoxide is more likely to be found in the environment
than heptachlor. Heptachlor doesn't dissolve easily in water heptachlor epoxide dissolves more
easily. They stick strongly to soil particles and evaporate slowly to air. Heptachlor epoxide can
stay in the soil and water for many years.
Heptachlor and heptachlor epoxide are toxic to humans and animals and can damage the
nervous system. There are some human data on brief exposures to high levels. A few human
case reports showed that people who accidentally swallowed pesticide that contained heptachlor,
or who spilled pesticide on their clothes became dizzy, confused, or had convulsions.
Very high levels for short periods produce serious liver problems. Mice had trouble walking and
rats developed tremors. High levels of heptachlor in the feed for several weeks damaged the
livers of rats and the livers and adrenal glands of mice. Animals that ate food containing
heptachlor before and/or during pregnancy had smaller litters or were unable to reproduce.
Some of the offspring had cataracts and some didn't live long after birth.
The EPA has classified heptachlor expoxide as a Class B2, probable human carcinogen, on the
basis of rodent studies in which liver carcinomas were induced in two strains of mice and in
female rats.
alpha-HEXACHLOROCYCLOHEXANEfalDhi-HCHl
Alpha-HCH has been classified as a B2, probable human carcinogen, by the EPA based on an
increased incidence of liver tumors in mice and rats. There is inadequate evidence of alpha-HCH
causing cancer in humans.
In animals, dietary alpha-HCH has been shown to cause increased incidences of liver tumors in
five mouse strains and in VWstar rats. No data on the genetic toxicology of alpha-HCH are
available. The oral slope factor (CSF for alpha-HCH is 6.3E+0 (mg/kg-day)'1 and the inhalation
unit risk is 1.8E-3 (ug/m3)'1.
b«ta-HEXACHLOROCYCLOHEXANE (beto-HCHl
Alpha-HCH has been classified as a C; possible human carcinogen by the EPA based on an
increased incidence of liver tumors in mice. There is inadequate evidence of alpha-HCH causing
cancer in humans.
Positive or marginally positive tumorigenic responses, characterized as benign hepatomas or
hepatocellular carcinomas, have been observed in two strains of mice. The studies are limited in
that small numbers of animals were used.
No data on the genetic toxicology of alpha-HCH are available. The oral slope factor (CSF for
alpha-HCH is 1.8E+0 (mg/kg-day)*1 and the inhalation unit risk is 5.3E-4 (ug/m3)"1.
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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 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 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 ug/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 neurobehavtoral function from an epidemiological study.
MERCURY
Toxicity resulting from subchronic and chronic exposure to mercury and mercury compounds
usually involves the kidneys and/or nervous system. The specific target and effect being
dependent on the form of mercury.
A subchronic and chronic oral RfD of 0.0001 mg/kg/day for methyl mercury is based on
neurologic developmental abnormalities in human infants. A subchronic and chronic oral RfD of
0.0003 mg/kg/day for mercuric chloride is based on immunologic glomerulonephritis. A Lowest
Observed Adverse Effect Level (LOAEL) of 0.63 mg Hg/kg/day for mercuric chloride was
identified. A subchronic and chronic inhalation RfC of 0.0003 mg Hg/m3 for inorganic mercury is
based on neurological disorders.
No data were available regarding the carcinogenicity of mercury in humans or animals. EPA has
placed inorganic mercury in weight-of-evidence classification D, not classifiable as to human
carcinogenicity.
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.
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Inhalation exposure to some nickel compounds will cause toxic effects in the respiratory tract and
immune system. Inhalation LC50 values for animals range from 0.97 mg nickel/m3 for rats (6-
hour exposure) to 15 mg nickel/m3 for guinea pigs (time not specified). 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. Soluble nickel
compounds tend to be more toxic than insoluble compounds. 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
(0.13-0.2 mg nickel/m3) 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
(5 mg/kg/day) 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.
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