United States        Office of
Environmental Protection   Emergency and
Agency          Remedial Response
                                     EPA/ROD/R03-92/141
                                     May 1992.
&EPA   Superfund
         Record of Decision:

         U. S. Defense General
         Supply Center (Operable Unit
         1),VA

-------
                                          NOTICE

The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the adiniiuatiative record
for this site.

-------
50272-101
I REPORT DOCUMENTATION
'         PAGE
1. REPORT NO.
    EPA/ROD/R03-92/141
                                           3. Recipient11 Accession No.
 4. TrHe and Subtitle
   SUPERFUND  RECORD OF  DECISION
   U.S. Defense General Supply Center  (Operable Unit  1),  VA
   First Remedial Action - Subsequent  to follow	
                                           5. Report Data
                                            05/15/92
                                           6.
  7. Authors)
                                                                     8. Performing Organization Rept No.
 9. Performing Orgainization Name and Address
                                           10. Project/Taskwork Unit No.
                                                                     11. Contract C) or Grant(G) No.

                                                                     (C)

                                                                     (C)
 12. Sponsoring Organization Name and Address
   U.S.  Environmental Protection Agency
   401 M Street,  S.W.
   Washington, D.C.   20460
                                           13. Type of Report ft Period Covered

                                             800/000
 15. Supplementary Notes

   PB93-963923
 16. Abstract (Umit: 200 words)


   The 640-acre  U.S. Defense  General Supply Center  (DGSC)  is a military support,  service,
   and storage facility located approximately 11 miles  south of the  City of Richmond,
   Virginia.  Land use in  the area is predominantly  residential and  wooded, with  the James
   River located approximately 1 mile east  of the site.   Although  the site overlies a
   shallow aquifer,  residences in the area  are serviced by a municipal drinking water
   facility.  From the 1940's to 1970's,  DGSC provided  multiple support functions for the
   U.S.  Army.  Operational areas consisted  of indoor and outdoor material storage areas, a
   motor pool facility, a  National Guard  training area,  fire training areas, and  various
   acid neutralization pits.   Materials that were stored in Open Storage Areas  (OSA)
   consisted mainly of petroleum, oils, and lubricants  although, in  the past, there were
   reported pesticide and  herbicide spills.   Soil contamination at the OSA source area
   resulted from improper  chemical handling and storage activities conducted during this
   time.  In 1986,  as part of a RCRA Corrective Action  permit for  the facility, remedial
   investigations  revealed contamination  by VOCs, other organics,  metals,  and inorganics


   (See  Attached Page)
 17. Document Analysis a. Descriptors
   Record of Decision - U.S. Defense General  Supply Center (Operable  Unit 1), VA
   First Remedial  Action - Subsequent to follow
   Contaminated Medium: soil
   Key  Contaminants: VOCs  (benzene,  PCE, TCE,  toluene,  xylenes), other organics  (PAHs,
                       pesticides,  phenols), metals (arsenic,  chromium,  lead), acids,  oils
   b. Identifiera/Open-Ended Terms
   c. COSATI Reid/Group
 18. Availability Statement
                                                      19. Security Class (This Report)
                                                             None
                                                      20. Security Class (This Page)
                                                             None
                                                      21. No. of Pages
                                                         82
                                                                                22. Price
(See ANSW3S.18)
                                      See Instructions on Reverse
                                                      OPTIONAL FORM 272 (4-77)
                                                      (Formerly MTIS-35)
                                                      Department of Commerce

-------
EPA/ROD/R03-92/141
U.S. Defense General Supply Center  (Operable Unit 1), VA
First Remedial Action - Subsequent to follow

Abstract  (Continued)

in both the soil and ground water throughout the facility.  As a result, remediation of
DGSC has been divided into eight OUs.  This ROD addresses the interim remediation of OU1,
the contaminated soil at OSA.  Future RODs will address onsite contaminated media at the
remaining seven areas as OU2 through OUS.  The primary contaminants of concern affecting
the soil are VOCs, including benzene, PCE, TCE, toluene, and xylenes; other organics,
including PAHs, pesticides, and phenols; metals, including arsenic, chromium, and lead;
acids; and oils.

The selected remedial action for this site includes implementing institutional controls
and site access restrictions, including fencing of the storage area.  The present worth
cost for this remedial action is $15,000.  No O&M costs are applicable to this remedial
action.

PERFORMANCE STANDARDS OR GOALS:

Not applicable.

-------
. araa^'i
r
                     FIMAI
                     I IIN/~VL.      7—— - jji
                              Attorney for
            RECORD OF DECISION
                      FOR
             OU1- OPEN STORAGE AREA
         DEFENSE GENERAL SUPPLY CENTER
              RICHMOND, VIRGINIA

                    PREPARED FOR
        DEFENSE LOGISTICS AGENCY
                    AND THE
        U.S. ARMY CORPS OF ENGINEERS
             HUNTSVILLE DIVISION

                   PREPARED BY:
             ~ ^  LAW ENVIRONMENTAL
               CONTRACT No. DACW87-90-D0023
                   JOB No. 11-1519
                   APRIL 1992    :

-------
                        TABLE OF CONTENTS


                                                              Page

1.0   DECLARATION 	   1-1

     1.1   SITE NAME AND LOCATION	   1-1

     1.2   STATEMENT OF BASIS AND PURPOSE	   1-1

     1.3   ASSESSMENT OF THE SITE 	   1-1

     1.4   DESCRIPTION OF THE SELECTED REMEDY  	   1-2

     1.5   STATUTORY DETERMINATIONS  	   1-3

2.0   DECISION SUMMARY	   2-1

     2.1   SITE NAME, LOCATION AND DESCRIPTION	   2-1

     2.2   SITE HISTORY AND ENFORCEMENT ACnVITIES	   2-4

     2.3   SUMMARY OF COMMUNITY PARTICIPATION 	   2-7

     2.4   SCOPE AND ROLE OF OPERABLE UNIT	   2-8

     2.5   SUMMARY OF SITE CHARACTERISTICS	   2-9

     2.6   SUMMARY OF SITE RISKS	   2-14

     2.7   DESCRIPTION OF ALTERNATIVES	   2-20

     2.8   COMPARATIVE ANALYSIS SUMMARY	   2-25

     2.9   SELECTED REMEDY	   2-31

     2.10  STATUTORY DETERMINATIONS  	   2-32

          2.10.1  Protection of Human Health and Environment	   2-33
          2.10.2  Compliance with ARARs	   2-33
          2.10.3  Cost-Effectiveness	   2-34
          2.10.4  Utilization of Permanent Solutions and Alternative
                Treatment Technologies	   2-34
          2.10.5  Documentation of Significant Changes 	   2-34
          2.10.6  Responsiveness Summary	   2-35


1519.42                            -i-

-------
                               LIST OF FIGURES

Figure                                                                  Page
2-1   Defense General Supply Center and Surrounding Area  	   2-2
2-2   Open Storage Area  	   2-6
                               LIST OF TABLES

Table                                                                   Page
2-1   Constituents Detected in Soils	   2-11
2-2   Constituents Detected in Ground Water	   2-12
2-3   Risk-Based Soil Action Levels	   2-15
2-4   Potential Applicable or Relevant and Appropriate
       Requirements (ARARs) And To be Considered
       (TBC) Requirements	   2-28
1519.42                                -ii-

-------
                              1.0 DECLARATION
1.1 SITE NAME AND LOCATION

Open Storage Area (OSA) Source Area - Operable Unit 1, Contaminated Soils
Defense General Supply Center (DGSC)
Chesterfield County, Virginia


12 STATEMENT OF BASIS AND PURPOSE

1.2.0.1      This decision document presents the selected interim remedial action for the
Open Storage Area source area (OSA source area), Operable Unit (OU1) at the Defense
General Supply Center  (DGSC) in Richmond, Virginia, which was chosen in accordance
with Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),
42 U.S.C. §§ 9601 et seq.. and to the extent practicable, the National Oil and Hazardous
Substance Pollution Contingency Plan (NCP) 40 C.F.R. Part 300. This decision is based on
the administrative record for this site.  This interim remedy was chosen by the Defense
Logistics  Agency (DLA) in consultation with the United States Environmental Protection
Agency, Region HI (EPA). Both the EPA and the Commonwealth of Virginia concur with
the selected remedy.


1.3 ASSESSMENT OF  THE SITE

1.3.0.1      Actual or  threatened releases of hazardous substances from this site, if not
addressed by implementing the response action selected in this Record of Decision (ROD),
may present an imminent and substantial endangerment to public health,  welfare, or the
environment.
                                                      I hereby certify that -;.
                                                 within is a true and correct ccr
           '                                      0^ the QT'1eHinft1(C
-------
1.4 DESCRIPTION OF THE SELECTED REMEDY

1.4.0.1       This operable unit is the first of eight operable units that are currently
proposed for the DGSC site. Operable Unit 1 addresses the contaminated soils at the Open
Storage Area (OSA).  The other Operable Units, and the portions of the site that they
address are  as follows:

       •    OU2 - Area 50 Source Area
       •    OU3 - National Guard Area Source Area
       •    OU4 - Fire Training Source Area
       •    OU5 - Acid Neutralization Pits Source Area
       •    OU6 - Open Storage Area/Area 50/National Guard Area Ground Water
       •    OU7 - Fire Training Area Ground Water
       •    OU8 - Acid Neutralization Pits Ground Water

1.4.0.2      This action addresses the contaminated soils at the Open Storage Area source
area by establishing physical and institutional controls to  limit access to the soils.

1.4.0.3      The major components of the selected remedy include:

       •    Continued operation of the site as a restricted area in which access to the site
            is controlled  by a dual system of fences and gates.  Security  personnel also
            restrict access to the fenced area.

       •    Institutional Controls including deed restrictions to restrict future development
            of the area. Restrictions which will limit future development include limitations
            on  the  transfer of  the property,  maintenance protocol, and  which require
            environmental sampling prior to the start of any construction at the area, and
           ambient air testing and personnel monitoring during the construction phase.
1519.42                                  1-2

-------
1.5 STATUTORY DETERMINATIONS

1.5.0.1       The selected remedy is protective of human health and the environment,
complies with Federal and State requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost effective. However, because treatment was
not found  to be  practicable, this  remedy does not satisfy the  statutory preference  for
treatment as a principal element.

1.5.0.2       Because this remedy will result in hazardous substances remaining on-site
above health-based levels, a review will be conducted within five years after commencement
of remedial action in accordance with CERCLA Section 121  (c), 42 U.S.C. § 9621 (c) to
ensure that the remedy continues to provide adequate protection of human health and  the
environment.
Colonel James E. Jerkins, United States Army              Date
Deferae Logistics Agency
Staff Director, Office of Installation Services
and Environmental Protection
Edwin B. Erickson                                       Date
Regional Administrator
U.S. Environmental Protection Agency - Region in
1519.42                                1-3

-------
                            2.0  DECISION SUMMARY
2.1  SITE NAME. LOCATION AND DESCRIPTION

Open Storage Area (OSA) Source Area - Operable Unit 1, Contaminated Soils
Defense General Supply Center (DGSC)
Chesterfield County, Virginia

2.1.0.1       The DGSC is located in Chesterfield County, Virginia approximately 11 miles
south of the City of Richmond (see Figure 2-1). The OSA is a 43-acre fenced area located
along the western boundary in the central portion of the DGSC.  The OSA is used for the
storage of drummed and containerized chemicals. The majority of the chemicals stored at
the OSA are  petroleum, oil and lubricant (POL)  products.

2.1.0.2       The DGSC was originally constructed in 1941 as two separate facilities: i.e,
the Richmond General Depot and Richmond Holding and Reconsignment Point. In 1962
the installation became known as the DGSC.

2.1.03       The Defense  Logistics Agency (DLA),  an agency of the Department of
Defense (DOD), provides logistics support to the military services including procurement
and supply support, contract administration and other services.  Since 1942, the DGSC's
mission has been the managing and  furnishing of military general supplies to the Armed
Forces and several Federal Civilian Agencies.  Today DGSC manages more than 300,000
general supply items at a facility valued at $100 million and encompassing 640 acres. The
DGSC has more than 16 million square  feet of  covered storage space in 27 large brick
warehouses and a million square feet of office  space.

2.1.0.4       Land use in Chesterfield County in the vicinity of the DGSC is primarily single
family residential, intermixed with retail stores and light industry.

1519.42 .                               2-1

-------
                   FIGURE 2-1

     DEFENSE GENERAL SUPPLY CENTER

          AND SURROUNDING AREA
               RICHMOND, VIRGINIA
        SEABOARD
        COAST LINE
   SCALE IN MILES
LAW ENVIRONMENTAL, INC.
GOVERNMENT SERVICES BRANCH
                                               1519.38
                       2-2

-------
2.1.0.5       The DGSC is the major industry in the area.  The area to the northeast and
east of the DGSC has been developed as both single family and multi-family housing. Area
50 and the National Guard Area (NGA) are located immediately downgradient of the OSA.
A wooded area and apartment complex is located east of the NGA. Rayon Park, a sparsely
populated housing subdivision consisting of 83 houses, is  located east of the DGSC and
south of the wooded area.  Municipal water is supplied to the residents of the downgradient
apartment complex and Rayon Park.

2.1.0.6       The DGSC is located within the modified continental climatic zone, an area
characterized by extreme variations in temperature and precipitation during the course of
a year. Typically, the area experiences warm summers, relatively  mild winters and normally
adequate  rainfall.  The mean annual temperature is between 55°F and 60°F.  The average
annual precipitation is 44.2 inches.  The mean annual pan evaporation rate for the  area is
between 48 and 64 inches. Precipitation and pan evaporation are generally greatest during
July and August.  Wind direction in the vicinity of the DGSC is variable most of the time,
although the prevailing wind direction is southerly.

2.1.0.7       The land surface at the DGSC has been extensively altered by grading and
filling operations.  Generally, the topography is essentially flat with a slight slope towards
the northeast.  The maximum difference in the local topographic relief is approximately  30
feet.  Elevations range from 135  feet above  mean sea level (msl) at the southwest  corner
of the facility to 108 feet above msl near the  northeastern portion.  Surface drainage in the
OSA area is presently directed towards a storm sewer system that drains northeastward and
discharges into the unnamed creek at the northeast corner of NGA. The unnamed creek
flows  north-to-south along the eastern edge of the NGA, turns to the east, and ultimately
discharges into the James River.

2.1.0.8       The  unconsolidated soils below  the DGSC have been divided into  four
formations by the U.S. Geological Survey.  The Eastover Formation is present  immediately
below the land surface and consists of up to 25 feet of interlayered beds of sand, silt and
1519.42                                2-3

-------
clay with occasional gravel.  The predominantly gray clay and silt of the Calvert Formation
underlies the Eastover throughout the area.  The Calvert Formation is typically 11 feet
thick. The Aquia Formation, approximately 7 feet of gray sand, gravel and clay, underlies
the Calvert Formation.  The  Potomac Formation, which underlies the Aquia Formation,
extends to the bedrock. The Potomac consists of approximately 40 feet of interbedded sand
and gravel with occasional silt and clay seams.   Bedrock in the  region consists of  the
Petersburg Granite.

2.1.0.9       Soils and geologic conditions at the OS A area were characterized during the
Remedial Investigation (RI) at the site. An unconfined water table aquifer is present within
the Eastover Formation.  This aquifer, referred to in this document as the Upper Aquifer,
would be the first water bearing unit to be impacted by any contamination originating from
the OSA.  Vertical migration  of contaminants from the Upper Aquifer would be inhibited
by the underlying Calvert and Aquia Formations. These two formations, which have lower
permeabilities than the overlying and underlying formations, are referred to as the Confining
Unit.   The confined  Lower Aquifer underlying these two formations is located in  the
Potomac Formation.

2.1.0.10      Ground-water flow in the  Upper Aquifer  is generally towards the north-
northeast.  The  average depth to ground water varies with season but typically ranges from
13 to  16 feet below ground surface. The hydraulic gradient has been calculated to range
from 0.05 percent to 0.12 percent. The low hydraulic gradient in the ground water indicates
that the potentiometric surface and ground-water flow direction are susceptible to seasonal
changes in  recharge, discharge or precipitation. Flow direction of ground water within the
Lower Aquifer  is generally  east to northeast.
22 SITE HISTORY AND ENFORCEMENT ACTIVITIES

2 J.O.I       Past industrial operations at the DGSC have included parachute manufacture
and repair, mess kit and canteen repair, refrigerator repair, material handling, equipment

1519.42                                 2-4

-------
overhaul, and engine rebuilding. Current industrial operations include the refurbishing of
steel combat helmets and compressed gas cylinders using both wet (acid and caustic) and
dry (ball blasting) processes, and tent and fabric repair.

2.2.0.2       The DGSC motor pool operations include minor vehicle repairs, fluid changes,
and vehicle lubrication.  These activities take place at the motor pool facility located in the
southern portion of the DGSC.  There are underground gasoline and fuel storage tanks
located throughout the installation.

22.0.3       Chemical  operations  at the  DGSC have included storing  and shipping
flammable, toxic, corrosive and oxidizer chemicals for DLA. The majority of the chemicals
are stored in warehouses at the DGSC. Chemicals stored at the DGSC have also included
pesticides and herbicides for use at DGSC and as part of the chemical stock mission of the
DGSC. The open storage areas at the facility are utilized primarily for open storage of 55-
gallon drums of petroleum, oils, and lubricants.

2.2.0.4       The Open Storage Area source  area (OSA source area), Operable Unit 1,
consists of Open Storage Areas 38 through 47 (see Figure 2-2). The OSA source area has
been used for the storage of drummed and containerized chemicals since the opening of the
facility in 1942.  The OSA source area is not paved, and drums in storage are stored directly
on the ground or on wooden skids.   Pathways between the drums are paved.  Spills and
leaks have been reported to have occurred within this area.

2.2.0.5       The northern end of Storage Areas 39 and 40 was the site of former drum
recoupment activities carried out between the early 1960s and the late 1970s. Recoupment
activities involve transferring the contents of leaking or damaged containers into new or
reclaimed drums. The soils in the vicinity of the former recoupment area are reportedly
stained from past spills, as  are the soils  in other locations around the OSA source area.
Three documented spills of malathion occurred at the OSA source area between 1977 and
1980, though no resulting ground-water contamination has been identified in the area. All
three spills  occurred from 55-gallon  drums awaiting recoupment.
1519.42                                2-5

-------
           FIGURE 2-2
   OPEN STORAGE AREA
DEFENSE GENERAL SUPPLY CENTER
          RICHMOND, VA
  FORMER
   DRUM
 RECOUPMENT
   AREA
OPEN STORAGE AREA
                 E NATIONAL
                 =  GUARD
                 E  AREA
      500
1000
   SCALE IN FEET
                                         1519.42

-------
2.2.0.6      In  1984, the DGSC was recommended for placement on the CERCLA
National Priority List (NPLj, and was promulgated to the NPL in 1987.  This action was a
result of a Hazard Ranking System (HRS) scoring performed for the DGSC that was based
on  the  conclusions  of  previous studies done at the site by  the United States  Army
Environmental Hygiene Agency (USAEHA).  The DGSC received a hazardous ranking
score of 33.85, with 28.5 being the minimum necessary to be promulgated to the NPL  In
August, 1986 the United States Environmental Protection Agency, Region III (EPA), issued
a Corrective Action Permit to DGSC pursuant to the Resource Conservation and Recovery
Act (RCRA), 42 U.S.C. §§ 6901 £l.se_a,. As part of RCRA activities conducted at the site,
Dames and Moore, a contractor of DGSC, submitted three Remedial Investigation Reports
pertaining to sites investigated at DGSC in 1989. The three reports submitted by Dames
and Moore, Bethesda, Maryland were as follows:

      •    Remedial Investigation for the Fire Training Area, May 1989;

      •    Remedial Investigation for the Acid Neutralization Pits
            Area, April 27, 1989; and

      •    Remedial Investigation for the Open Storage Area/Area 50/
            National Guard Area, July 1989.

In September, 1990, the DLA, DGSC, EPA, and the Commonwealth of Virginia entered
into a CERCLA Interagency Agreement (IAG) pursuant to Section 120 of CERCLA, 42
U.S.C. § 9620, which contains the requirements for the implementation of remediation
activities.
2.3  SUMMARY OF COMMUNITY PARTICIPATION

2J.O.I       On February 23,  1984, the DGSC organized an Interagency Task Force
comprised of .State regulatory agencies, EPA, County agencies, Virginia National Guard,

1519.42                               2-7

-------
Rayon Park Representatives, and DGSC personnel.  The purpose of this group was to
ensure that actions carried" Out at the site were done with input and review from affected
parties. This group was active in the mid 1980s, but became less active after county water
supply lines were installed to service residents located near DGSC boundaries.

2.3.0.2      The proposed plan for Operable Unit 1 - Open Storage Area was released to
the public on January 20,  1992. This document was made available to the public in the
administrative  record  maintained at the Chesterfield Public Library at the Chesterfield
County Courthouse in Chesterfield, Virginia. The notice of availability for this document
was published in the Richmond Times Dispatch on January 20, 1992. The public comment
period was held through March 6,1992.  In addition, a public meeting was held on February
20, 1992.  At this meeting, representatives  from the DLA, EPA, and Commonwealth of
Virginia answered  questions  concerning the remedial alternatives evaluated for this site.
The thirty day public comment period was  extended until April  6, 1992 due to a request
made by a member of the public. A response to the comments received during this period
is included in the Responsiveness Summary, which  is part of this Record of Decision.  This
decision document presents the selected remedial action for Operable Unit One - Open
Storage Area at the DGSC in Chesterfield County, Virginia, chosen in accordance with
CERCLA and to the extent practical, the National Contingency Plan.


2.4 SCOPE AND ROLE OF OPERABLE UNIT

2.4.0.1      As with  many Superfund sites, the problems at DGSC are complex.  As a
result, the work at the site has been organized into eight operable units. These are:

       OU 1        -      Open Storage Area Source Area

       OU 2        -      Area 50 Source  Area


1519.42      /'                         2-8

-------
       OU 3 -      National Guard Area Source Area

       OU 4 -      Fire Training Area Source Area

       OU 5 -      Acid Neutralization Pits Source Area

       OU 6 -      Area 50/Open Storage Area/National Guard
                   Area Ground Water

       OU 7 -      Fire Training Area Ground Water

       OU 8 -      Acid Neutralization Pits Ground Water

2.4.0.2       The scope of this action addresses the first operable unit (OU1) at the site,
the OSA source area (see Figures 2-1 and  2-2).  OU1 addresses the contaminated soils
present at the OSA. The purpose of this action is to prevent current or future exposure to
contaminated soils at the site by restricting access to the OSA source area and insuring that
any onsite construction activities conform to DLA and DGSC policies regarding military
construction. Ground water at the OSA source area has not been shown to be impacted by
contaminants leaching from the soils at the OSA source area.


2.5 SUMMARY OF SITE CHARACTERISTICS

2.5.0.1       Contamination of the soil at the OSA source area results from the chemical
handling and storage activities conducted between  the late 1950s and the present.  Based
on a review of past activities, the types of contamination that are present includes petroleum
products, chlorinated  and non-chlorinated solvents, pesticides, and herbicides.  Elevated
levels of some metals may also be identified as a result of their potential presence in the
POL products at the site.

1519.42 .                               2-9

-------
2.5.02       Several sampling and analysis programs have been performed at the OSA in
order to evaluate the magnitude and extent of contamination. The complete analysis results
are detailed in the Draft Remedial Investigation Report, Area 50/OSA/NGA - Dames and
Moore, Bethesda, Maryland, July 1989.  The locations of the soil samples were selected to
identify sources of contaminants, potential pathways of contaminant migration as well as the
magnitude and extent of contamination.

2.5.0.3       The results of the chemical analysis on the soil samples are presented in Table
2-1.  The soil samples were analyzed for the full Target Compound List (TCL) and Target
Analyte List (TAL) constituents. Table 2-1 provides a summary of those constituents which
were detected in at least one sample at concentrations above  background.  As  shown in
Table 2-1, the most frequently detected constituents in the  soils at the OSA were semi-
volatile organics including primarily polycyclic aromatic hydrocarbons  (PAHs).  Other
constituents detected in soils from this site included four metals (antimony, arsenic,
cadmium, chromium (VI)), volatile organics and pesticides. Constituents present in the soils
in the OSA were primarily limited to the surface soils. The highest concentrations of PAHs
and pesticides were found in samples from 0 to 4 feet deep. The only constituents detected
at depth were antimony, arsenic, acetone, carbon disulfide, toluene, and xylene.

2.5.0.4       The primary constituents detected in the surficial (upper) aquifer ground water
at OSA were volatile organics, phthalates, and inorganics (Table 2-2).

2.5.0.5       As shown in Table 2-2, two inorganic constituents and six volatile organics
were present in the  shallow ground water  at concentrations greater than  MCLs.  A
comparison to Table 2-1 shows that none of the constituents detected in the Upper Aquifer
were detected in soil samples from the OSA. Therefore, there appears to be no correlation
between the constituents detected in the soils at the OSA source area and in the Upper
Aquifer at this site.  In addition, a separate operable unit - OU6 (Area 50/OSA/NG Area
ground water) will address contaminated ground water in the vicinity of the OSA and other
adjacent sites.
1519.42  .                              2-10

-------
                                         TABLE 2-1
                            CONSTITUENTS DETECTED IN SOILS
                                     Open Storage Area
                                       Operable Unit 1
Chemical
Antimony
Arsenic
Cadmium
Chromium (VI)
Acetone
Carbon disulfide
Chloroform
Methylene chloride*
Toluene
Xylene
Benzoic acid
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluroanthene
Bis(2-ethylhexyl)phthalate
Chrysene
Dibenzo(aji)anthracene
Di-n-octyl phthalate
Di-n-butyl phthalate
Fluoranthene
Indeno(lA3-cd)pyrene
4-Nltrophenol
Phenanthrene
Pyrene
2,4-D
4,4'-DDD
4,4'DDE
4,4'-DDT
Detection
Frequency
3/54
51/54
4/54
4/22
53/54
2/54
6/54
54/54
1/54
1/54
1/54
1/54
3/54
3/54
4/54
12/54
5/54
1/54
8/54
1/54
6/54
3/54
1/54
4/54
6/54
2/29
1/54
1/54
5/54
Maximum
Concentration
(mg/kg)
6.6
88
5
0.71
0.27
0.033
0.013
0.063
0.0064
0.0028
0.055
0.062
0.35
0.3
0.5
0.87
0.98
0.046
1.4
0.23
1
0.2
0.05
0.17
1
0.13
0.0042
0.04
0.22
Location of
Highest
Concentration
DMS-90
DMS-55
DMS-52
DMS-58
DMS-54
DMW-16B
DMS-89
DMW-16C
DMS-61
DMS-58
DMS-83
DMW-15A
DMS-54
DMS-54
DMS-103
DMS-59
DMS-54
DMW-15A
DMS-59
DMS-56
DMS-54
DMS-54
DMS-83
DMS-103
DMS-54
DMS-57
DMS-61
DMS-98
DMS-98
Depth of
Highest
Concentration
15-65'
5-6'
0-4'
0-4'
15-65'
15-65'
0-4'
15-65'
15-65'
15-65'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
0-4'
  Methylene chloride attributed to laboratory blank contamination.
1519.42
2-11

-------
                                    TABLE 2-2
                   CONSTITUENTS DETECTED IN GROUND WATER
                                 Open Storage Area
                                  Operable Unit 1
Chemical
Aluminum
Arsenic
Barium
Calcium
Chromium, Total
Chromium, Hexavalent
Cobalt
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Vanadium
Zinc
Acetone
Benzene
Carbon Tetrachloride
2-Chlorovinyl Ether
1,1-Dichloroethylene
1,2-Dichloroethylene
Range of Concentrations
(mg/L)
BDL-1.7
BDL-0.005
0.009-0.18
0.73-19
0.010
0.058
BDL-0.013
BbL-0.032
BDL-0.010
BDL-14.3
BmXMJl*
BDL-44
0.002-0.16
BDL-0.0025
BDL-0.041
BDL-85
BDL-0.019
BDL-0.86
BDL-55
BDL-0.006
0.012-0.51
BDL-0.18
BDL-0.001
0.004
BDL-0.002
BDL-0.18 ^
'"; ' BDL-0.lt \
Location of Highest
Concentration
DMW-16A
DMW-17A
DMW-14A
DMW-16B
DMW-7A
DMW-7A
DMW-8A
DMW-15A
K2
DMW-15A
DMW-7A
12
12
DMW-8A
K2
DMW-16B
K2
K2
DMW-16C
DMW-7A
B2
DMW-7A
62
DMW-8A
DMW-7A
DMW-7A
B2
1519.42
                                     2-12

-------
                                  TABLE 2-2 (continued)
                     CONSTITUENTS DETECTED IN GROUND WATER
                                    Open Storage Area
                                     Operable Unit 1
Chemical
Methylene Chloride
Tetrachloroethylene
Toluene
Trichloroethylene
1,1,1-Trichloroe thane
Di-n-butyl Phthalate
Bis(2-Ethylhexyl)Phthalate
Isophorone
Phenol
2,4,5-TP (Silvex)
2A5-T
Range of Concentrations
(mg/L)
0404-&56
BDL4.5
BDL-0.009
BDL-I.5
BDL-1,4
BDL-0.027
BDL-0.035
BDL-0.003
BDL-0.022
BDL-0.00002
BDL-0.59
Location of Highest
Concentration
DMW-7A
DMW-7A; B2
12
DMW-7A; B2
DMW-7A
B2
N2
16B
DMW-7A
DMW-7A
DMW-16B
       Maximum detected concentration in OSA exceeds MCL.
1519.42
2-13

-------
2.5.0.6       The only compounds detected in more than one sample in the Lower Aquifer
at the OSA  source  area during the Remedial Investigation were methylene chloride,
acetone, and bis(2-Ethylhexyl)phthalate.  These  compounds  were determined to be
laboratory contaminants. No correlation was established between compounds detected in
the Lower Aquifer and compounds in the soils at the OSA.

2.5.0.7       As there are no  promulgated chemical-specific ARARs for constituents in
soils,  risk-based soil  action levels were derived for the constituents in soils at the OSA
source area. The risk-based soil action levels are presented in Table 2-3.  Risk-based action
levels or maximum background levels for antimony and arsenic were exceeded in only one
sample each from depths greater than 5 feet. There was no standard available to use for
a background level for antimony. It was determined in the Draft Remedial Investigation
Report, Area 50/Open Storage Area/National Guard Area, Dames and Moore, Bethesda,
MD, July, 1989, that  the maximum  background level for arsenic was 73.0 ppm.

2.5.0.8       Risk-based soil  action levels were developed in  accordance with EPA
guidelines to  be protective of workers at the facility who may be exposed to contaminated
soils,  via incidental  ingestion, dermal contact,  and inhalation of fugitive  dusts  during
excavation activities.   The risk-based soil action  levels for carcinogenic constituents are
based on a total risk, via all pathways of 1 x 10"6.  The action levels for noncarcinogenic
constituents are based on a total hazard index, via all pathways of less than 1.
2.6 SUMMARY OF SITE RISKS

2.6.0.1       A  baseline risk  assessment was conducted for the OSA source  area  as
documented  in  the  Draft  Remedial Investigation Report,  Area  SO/Open  Storage
Area/National Guard Area,  Dames and Moore, Bethesda, MD, July, 1989.  The  purpose
of the assessment was to evaluate the potential human health and environmental risks posed

1519.42    ,-"                          2-14

-------
                                       TABLE 2-3
                           RISK-BASED SOIL ACTION LEVELS
                                   Open Storage Area
                                     Operable Unit 1
Chemical
Antimony
Arsenic
Cadmium
Chromium (VI)
Acetone
Carbon Disulfide
Chloroform
Methylene Chloride
Toluene
Xylene
Benzoic Acid
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluroanthene
Benzo(g, h, i)perylene
Benzo(k)fluoranthene
Bis(2-Ethylhexyl)phthalate
Chrysene
Dibenzo(a, h)anthracene
Di-n-octyl phthalate
Di-n-butyl phthalate
Fluoranthene
Indeno(l,23-cd)pyrene
4-Nitrophenol
Phenanthrene
Detection
Frequency
3/54
51/54
4/54
4/22
53/54
2/54 '
6/54
54/54
1/54
1/54
1/54
1/54
3/54
3/54
5/54
3/54
4/54
12/54
5/54
1/54
8/54
1/54
6/54
3/54
1/54
4/54
Maximum
Concentration
(mg/kg)
$4*
88
5
0.71
0.27
0.033
0.013
0.063
0.0064
0.0028
0.055
0.062
035
03
1.5
0.22
0.5
0.87
0.98
0.046
1.4
0.23
1
02
0.05
0.17
Risk-Based Soil
Action Level
(mg/kg)
4.8
5.7
6.0
60
1200
1200
1700
1400 .
2400
24,000
48,000
3600
6.1
0.86
65
41
14
740
200
0.79
240
1200
480
3.8
48
85
1519.42
                                        2-15

-------
                                     TABLE 2-3 (continued)
                              RISK-BASED SOIL ACTION LEVELS
                                       Open Storage Area
                                        Operable Unit 1
Chemical
Pyrene
2,4-D
4,4'-DDD
4,4'-DDE
4,4'-DDT
Detection
Frequency
6/54
2/29
1/54
1/54
5/54
Maximum
Concentration
(mg/kg)
1
0.13
0.0042
0.04
0.22
Risk-Based Soil
Action Level
(mg/kg)
11
120
43
30
30
       Shaded area indicates maximum concentration which exceeds Action Level.
       Only one sample contained constituent at concentrations greater than the Action Level.
1519.42
                                         2-16

-------
by soil and ground-water contamination detected at the OSA.  This risk assessment did not
distinguish between source area and ground-water based risks.  The results of the baseline
risk assessment as they pertain to the OSA source  area (i.e., contaminated soils) are
summarized briefly below.

2.6.02       The potential exposure pathways which were considered in the baseline risk
assessment included the following:

       •     Ingestion and dermal contact with ground water
       •     Ingestion and dermal contact with contaminated soils
       •     Inhalation of vapors  and dusts
       •     Ingestion and dermal contact with surface water
       •     Ingestion of fish and game
       •     Ingestion of crops and other plants

2.6.0.3       Each of these pathways were evaluated for both on-site and off-site receptors,
under both current and future conditions. On-site workers could be exposed during both
current and proposed (future) warehouse construction.  A complete exposure  pathway
includes a source, release mechanism, environmental transport route, receptor, and exposure
route.  Of the 44 exposure pathways considered in the baseline risk assessment, only 20 were
considered to be complete.

2.6.0.4       The potential current exposure pathways considered to be complete at this site
are summarized below:

       •   Current ingestion of soils, inhalation of dust and dermal contact with soils
           during excavation activities by on-site workers.

       •   Current  inhalation of vapors  and particulates by on-site workers.

       •   Current  ingestion and  dermal contact with surface water by off-site residents.
1519.42                                 2-17

-------
2.6.0.5      The potential future exposure pathways which were considered to be complete
are summarized below:

       •    Future inhalation of dust and dermal contact with soils during construction and
            excavation activities by on-site workers.

       •    Future ingestion and dermal contact with ground water by off-site residents.

       •    Future inhalation of dust, ingestion of soil and dermal contact with soils from
            construction and excavation activities by off-site residents.

       •    Future  ingestion  and  dermal  contact  with  surface water  recharged  by
            contaminated ground water by off-site residents.

2.6.0.6       Excess lifetime cancer risks are determined by multiplying the intake level with
the cancer potency factor.  These risks are  probabilities that are generally expressed in
scientific notation (e.g., 1 x 10"6 or 1E-6). An  excess lifetime cancer risk of 1 x 10"6 indicates
that, as a plausible upper bound, an individual has one  in a million additional 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.

2.6.0.7       The potential carcinogenic risks from all current and future on-site exposures
to soils were calculated to be 4 x 10"8. This is less than the standard risk range EPA uses
for evaluating carcinogenic risks which is 1 x 10"4 to 1 x 10"6. Because on-site risks were less
than 10*6, potential carcinogenic risks from current and future off-site exposures to soils were
not calculated, but were assumed to be less than 4 x 10"8.

2.6.0.8       Potential concern for non-carcinogenic effects of a single contaminant in a
single medium 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
1519.42     '                            2-18

-------
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.

2.6.0.9       The potential non-carcinogenic hazard index from all current and future on-
site exposure to soils was estimated to be 1 x  10"6.  This value is far below the threshold
value of 1.0 which represents a potentially unacceptable risk to human health from systemic
toxicants (non-carcinogenic effects).

2.6.0.10      The potential risks involved from ground water at the site will be addressed
in a separate operable unit (OU6) for  ground water at the DGSC.  This operable unit
addresses the entire ground-water contaminant "plume" encompassing the Area 50/OSA/NG
Area, as well as any other affected area.

2.6.0.11      Risks posed by the site to the environment were considered very slight during
the RL This was mainly because of the low levels of contaminants present.  The primary
exposure pathway which was considered in the environmental pathway was surface run-off
to the  stream near the site.  Also, in assessing the environmental transport routes present
at the site, no critical habitats or endangered species were identified that would be affected.

2.6.0.12     The primary contaminants addressed by remedial alternatives are semi-volatile
organics. Although some metals are present, their concentration and extent are very limited.
Minimal risk is associated through exposure to these metals as they are at a depth greater
than 5 feet, and would not be disturbed by  any excavation activities.

2.6.0.13     Actual or threatened releases of hazardous substances from  this site, if not
addressed by implementing the response  action selected in this ROD, may present  an
imminent and substantial endangerment to  public health, welfare, or the environment.

1519.42                                2-19

-------
2.7 DESCRIPTION OF ALTERNATIVES

2.7.0.1       CERCLA requires that each selected remedy be protective of human health
and the environment, comply with applicable or relevant and appropriate requirements
(ARARs), utilize permanent solutions  and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable, and be cost effective.

2.7.0 2       During the Focused Feasibility Study for the OS A source area site (Focused
Feasibility Study Report - OLJ1 Open Storage Area, Law Environmental, Kennesaw, GA,
November, 1991), six remedial action alternatives were initially identified. As a result of
screening process, four out of six remedial action alternatives were selected for detailed
analysis. The four alternatives that were retained were:

       •  Alternative  1 - Surface Contaminant/Capping
       •  Alternative 3 - Excavation and Soil Washing
       •  Alternative 5 - Institutional Controls
       •  Alternative 6 - No Action Alternative

2.7.0.3       These four alternatives  are described in the following  paragraphs.   For
reference, the same alternative numbers as in the Feasibility Study Report are assigned to
these  alternatives.

Alternative 1 (Surface Containment/Capping)

Capital Cost:                   $576,105
Annual O&M Costs:            $ 20,000
Present Worth Cost:            $825,300
Months to Implement:           6 to 9 months


1519.42    -'"                          2-20

-------
2.7.0.4       Surface Containment/Capping: The proposed design is for a multi-layer cap
that includes an asphaltic concrete upper surface  underlain by a layer of gravel with a
bitumen-saturated non-woven geotextile fabric sandwiched between the asphalt layers. Cap
surface area would be approximately 31,218 sq. yd. Existing drainage structures would be
utilized. The site soils are generally well compacted and settlement under the cap should
not be a problem.

2.7.0.5       We have assumed that approximately 15% of the total OSA source area would
need to be capped.  The cap would extend to suitable  distances beyond the areas with
detectable contamination.

Alternative 3 (Excavation and Soil Washing)

Capital Cost:                    $6,067,578
Annual O&M Costs:             $      0
Present Worth Cost:             $6,067,578
Months to Implement:           12 to  18 months

2.7.0.6       The use of soil washing has been found to be effective in reducing the mass
of both organic and inorganic contaminants in contaminated soils. However, every site is
unique in both soil and contamination, therefore the process must be designed and tested
for each site prior to its approval and application. For costing purposes, we have assumed
a volume comprising 10% of the soils in the  OSA source area to a depth  of four feet.

       •     Soil Testing:  Additional soil testing would be  required  to provide better
             delineation of areas requiring treatment. A considerable number of samples
             could be required.  The cost of analysis could be reduced  considerably by
             using a field screening method backed up with laboratory results. The cost
             of additional soil testing has not been considered in this detailed analysis.

1519.42   .-•"                          2-21

-------
       •      Site Preparation/Mobilization: Surface preparation prior to excavation would
             require the relocation of the numerous drums stored at the site. The site will
             need to be segregated into zones and staging areas prior  to mobilization or
             construction of the treatment equipment. Site zones will include the exclusion
             zone, support zone, and decontamination zone as well as  a staging area for
             temporary storage of excavated soil prior to treatment.  Another staging area
             will be required for temporary storage of treated soil for  curing prior to re-
             emplacement.  Staging requirements will depend on the allowable throughput
             rates of treatment equipment relative to excavation, estimated contact times,
             and re-emplacement rates. The general work  area including all zones and
             staging areas will be fenced to delineate boundaries and prevent uncontrolled
             access.

       •      Equipment  Testing:  Prior to adoption of this alternative, bench-scale
             treatability tests  may be necessary to  ensure  that remedial goals will be
             achieved.  Testing will also be necessary at the site, just after the treatment
             units have been erected and prior to full implementation of remedial activity,
             to provide for air emissions permitting requirements  and to verify on-site
             performance of the equipment.

       •      Excavation: Excavation will be  accomplished using front-end loaders where
             site conditions permit. For the shallow (4 feet) excavation depth at the OSA
             source area, this will not present a problem.

Alternative 5 (Institutional Controls)

Capital Cost:                    $ 15,000
Annual O&M Costs:             $ 0
Present Worth Cost:             $  15,000
Months to Implement:           2 to 6 months

1519.42                                 2-22

-------
2.7.0.7       The  Institutional Controls  alternative  involves instituting  various  access
restrictions and institutional  controls to prevent current and future human exposure to
contaminated media  at the  site.  No measures are  taken which address or constitute
remediation of the site.

       •     Access Restrictions:  These generally consist  of fencing, warning signs, and
             sometimes, active security measures such as guards and patrols.  Since the
             DGSC is a secure federal facility, site access is already restricted and further
             access restrictions would not be required. Access control to the OSA source
             area itself is provided by a separate security system in addition to that of the
             main post. Therefore, a dual security system is in effect and will continue to
             be provided  at the OSA site.

       •     Long-Term Institutional Controls:  Institutional controls will include deed
             restrictions which will limit future development as follows:

1.     Transfer of Property:

       •     The transfer of the property known as the Defense General Supply Center
             shall be in accordance with Section 120 (h) of CERCLA, 42 U.S.C. § 9620 (h)
             and any regulations promulgated pursuant to Section 120 (h); (see 40 C.F.R.
             § 373 [1990]). See Attachment A.

2.     Maintenance and Construction within the physical boundaries of the Open Storage
       Area:

             •     Maintenance:   The DGSC's  regulation,  DGSCR 4150.1, shall be
                   modified to require an environmental review in section HI which is a
                   statement of policy.  The ROD shall be incorporated in the section I,
                   which is a list  of the references.  See Attachment B.
1519.42    '                             2-23

-------
                   Military Construction Projects: An environmental site assessment shall
                   be performed in accordance with the guidance provided in the DLA-W
                   Policy Memorandum dated 27 December 1989 (see Attachment C),
                   and shall be completed prior to project design within the OSA; and
3.    Monitoring
             •     Any monitoring that is required as a result of the environmental site
                   assessment described above will include soil gas sampling prior to the
                   start of the project, and soil analysis, ambient air testing, and personnel
                   monitoring during the construction phase of the project.

2.7.0.8       No further site restrictions (such as fences or signs) are required because the
site is already operated as a restricted area.  No measures are taken which constitute
remediation of the site.  If activities include new construction regrading or reworking of
soils, measures will be taken to insure that workers and the public are adequately protected
during site activities. These measures will include  environmental sampling and personnel
monitoring.  Should hazardous waste be encountered during any construction or excavation
activities, a prearranged plan, which shall be approved by the EPA and Commonwealth of
Virginia, will be available and will be invoked. This alternative would require a five-year
review in accordance with Section 121  (c) of CERCLA, 42  U.S.C. S9621 (c).

      Alternative 6 (No Action Alternative)

      Capital Cost:                    $      0
      Annual O&M Costs:             $      0
      Present Worth Cost:             $      0
      Months to Implement:           N/A


1519.42    /                           2-24

-------
2.7.0.9       The No Action alternative, as its name implies, involves absolutely no action
at the site.  The site is left in its present condition. The risks to human health and the
environment remain at the levels established in the baseline risk assessment.

2.7.0.10      The No Action alternative is carried through the screening process as required
by the NCP. It is used as a baseline for comparison with the other alternatives that are
developed.
2.8 COMPARATIVE ANALYSIS SUMMARY

2.8.0.1       For the comparative analysis presented below, the alternatives from the
detailed analysis were evaluated utilizing the EPA's nine evaluation criteria as laid forth in
the EPA's document, "Guidance on Preparing Superfund Decision Documents, July 1989".
These nine criteria are as follows:

      1.     Overall protection of Human Health and the Environment addresses whether
             a remedy provides adequate protection and describes how risks posed through
             each pathway are  eliminated,  reduced,  or  controlled  through treatment,
             engineering controls or institutional controls.

      2.     Compliance with  Applicable or Relevant and Appropriate Requirements
             (ARARs)  addresses whether  a remedy will  meet  all of the applicable or
             relevant  and  appropriate  requirements  of  other Federal  and  State
             environmental statutes and/or provide grounds for the invocation of a waiver.

      3.     Long-Term Effectiveness and Permanence refers to the magnitude of residual
             risk and ability of a remedy to maintain reliable protection of human health
             and the environment over time once cleanup goals have been met.


1519.42      -•"                         2-25

-------
      4.     Reduction of Toricity, Mobility, or Volume Through Treatment refers to the
             objective of the treatment technologies that may be employed to remedy site
             concerns.

      5.     Short-Term Effectiveness refers to the speed with which the remedy achieves
             protection, as well as the remedy's potential to create adverse impacts  on
             human health and the environment as a result of the construction and
             implementation activities.

      6.     Implementability is the technical and administrative feasibility of a remedy,
             including the availability of materials and services needed to implement the
             chosen solution.

      7.     Cost includes capital  and operation and maintenance costs.

      8.     State/Support Agency Acceptance indicates whether, based on its review of
             the RI/FS and Proposed Plan, the State and/or the Support Agency concurs
             with, opposes, or has  no comment to the preferred alternative.

      9.     Community Acceptance will be assessed in the Record of Decision following
             a review of the public comments received on the RI/FS report and the
             Proposed Plan.

2.8.0.2       Overall protection of human health and the environment:

      •      Alternative 3 (Excavation and Soil Washing). This alternative is effective at
             protecting human health and the environment as it employs treatment as the
             principal remediation effort at the site. This alternative would be effective at
             removing the semi-volatile and volatile organic compounds from the soils.
             Metals in the soils would not be affected by the treatment.
1519.42                                 2-26

-------
             Alternative 1 (Capping).  This alternative does not reduce the  toxicity or
             volume of the contaminants in the soil, but reduces their mobility. As the risk
             posed by  the site is  low and primarily associated with excavation,  this
             alternative is effective at protecting human health and the environment.

             Alternative 5  (Institutional Controls).  This alternative restricts access to the
             site to reduce the principal threat of exposure through ingestion  or dermal
             contact with the contaminated soils, therefore it is protective of human health
             and the environment.

             Alternative 6 (No Action). Nothing is done to affect the current situation at
             the site.   This  alternative  is  not protective  of human health and  the
             environment.
2.8.0.3       Compliance with ARARs:
             ARARs and To Be Considered (TBC) requirements for the OSA source area
             are identified in Table 2-4.  Chemical specific ARARs were not identified for
             the OSA soils.  Thus, compliance with chemical specific ARARs are not an
             issue at the OSA Risk-based soil action levels were determined as To Be
             Considered (TBC) requirements. However, these action levels or background
             levels were not exceeded  except for single concentration of arsenic and
             antimony.  Because these concentrations occurred at a depth of greater than
             5 feet,  they were not considered significant.   This alternative will comply
             with the chemical-specific TBCs identified on Table 2-4 (risk-based soil action
             levels), with the  exception of the  single  concentrations of  arsenic and
             antimony discussed  above.  No  location specific  ARARs or TBCs were
             identified.  Action specific ARARs and TBCs are discussed below.
1519.42     /                         2-27

-------
                                                                    TABLE 2-4

                              POTENTIAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
                                                AND TO BE CONSIDERED (TBC) REQUIREMENTS
                                                                Open Storage Area
                                                                  Operable Unit 1
                     TYPEOFARAR
                                                     ARARs
               TBC Requirements
           Chemical-Specific
N>
Location-Specific

Action-Specific


 Institutional Controls
            Excavation and Treatment/Disposal
            Containment/Capping
                                      None identified
                                                None identified
                                                None identified
                                      VA Solid Waste Management Regulations
                                      (VR 672-20-10)
                                      VA Hazardous Waste Management
                                      Regulations (VR 672-10-1)
                                      VA Control and Abatement of Air
                                      Pollution (VR Rules 4-2, 4-3, 5-3)
                                      RCRA Land Disposal Restrictions
                                      (40 CFR 268)

                                      RCRA Closure Requirements
                                      (40 CFR 264 Subpart G)
Risk-based action levels for constituents in soils based
on worker exposure.
Soil concentrations which will not result in leachate or ;,
ground water concentrations greater than the MCLs for
constituents in ground water

None identified
Occupational Safety and Health Standards for Air
Contaminants (29 CFR 1910.1000)
ACGIH Threshold Limit Values (TLVs)
OSHA Permissible Exposure Limits (PELs)

Occupational Safety and Health Standards for Air
Contaminants (29 CFR 1910.1000)
ACGIH Threshold Limit Values (TLVs)
OSHA Permissible Exposure Limits (PELs)
National Ambient Air Quality Standards (NAAQS)
(CAA 40 CFR Part 50)
None identified
          1519.42

-------
       •     Alternative .3 (Excavation and Soil Washing) will not satisfy Virginia Solid
             Waste or Hazardous  Waste Management Regulations for replacement of
             treated soil, and therefore is not being considered further.

       •     Alternative 1 (Capping) would satisfy the RCRA Closure Requirements.

       •     Alternative 5 (Institutional Controls) would  satisfy appropriate  OSHA and
             American  Conference  of Government Industrial  Hygienists  (ACGIH)
             requirements. In addition, Alternative 5 will meet the chemical-specific TBCs
             identified on Table 2-4 (risk-based soil action levels).

       •     Alternative  6 (No Action).   There  are no ARARs  for a  No  Action
             Alternative.

2.8.0.4       Long-Term Effectiveness and Permanence:

       •     Alternative 1 (Capping) is assumed to be  generally effective for as long as the
             cap material maintains its integrity. Assuming that the area that is capped is
             not heavily trafficked, and that periodic maintenance is performed to maintain
             and repair the cap materials, this type of cap can be expected to last anywhere
             from 20 to 50 years before requiring a complete reinstallation.  Effectiveness
             of Alternative 1 also  relies heavily on the assumption that the limiting of
             infiltration  through  the contaminated  media  will  also limit  continued
             contaminant migration.

       •     Alternative 5 (Institutional Controls) is only effective in preventing surface
             exposure  at the site.

       •     Alternative 6 (No Action) leaves the site as  it is and, like Alternative 5, is
            .effective  only if contaminant  substances  are   already  immobile or are
             significantly degraded by natural attenuation.
1519.42                                2-29

-------
2.8.0.5       Redaction of Mobility, Toxicity, and Volume Through Treatment:

       •     Alternative  1 (Capping)  is primarily  aimed  at  reducing the mobility  of
             contaminants and does nothing to decrease their toxicity and/or volume.

       •     Alternative  5  (Institutional Controls) seeks to limit exposure  at the site.
             Alternative 5 does not affect contaminant mobility, toxicity, or volume.

       •     Alternative 6 (No Action) also does nothing to reduce contaminant mobility,
             toxicity, or volume.

2.8.0.6       Short-Term  Effectiveness:

       •     Both Alternative 5 (Institutional Controls) and Alternative 6 (No Action)
             offer  relatively  equivalent  short-term exposure potential  since neither
             alternative involves disturbance of site materials, and  since there was no
             excess risk from exposure to surface materials as determined in the baseline
             risk assessment.

       •     Alternative  1  (Capping)  has a  potential  for  short-term  exposure  to
             contaminated  materials since grading of the site prior to installation of the
             surface cap may be required.

2.8.0.7       Implementability:

       •     Alternatives 5 (Institutional Controls) and 6 (No  Action)  are the easiest to
             implement in that no direct physical actions are to take place at the site as
             part of alternative implementation.

       •    .Alternative 1 (Capping) is relatively moderately difficult to  implement in that
             the site  must be prepared and  graded, and the  cap must be  carefully
1519.42                                 2-30

-------
             constructed.under stringent quality control  guidelines and supervision to
             maintain that the  cap will  perform as  designed and  intended.   Both
             Alternatives 1 and 3 could significantly impact operations at the OSA

2.8.0.8       Cost:  The cost comparison  among the alternatives is based both on the
initial capital construction costs and the annual operation and maintenance costs. Based on
the relative present worth costs, the alternatives are ranked as follows:

Approach                                   Present Worth Cost      Ranking

Alternative 6 (No Action)                    $ 0                        1
Alternative 5 (Institutional  Controls)          $ 15,000                   2
Alternative 1 (Capping)                      $825,300                   3

2.8.0.9       State Acceptance:   The Commonwealth of  Virginia, upon review of the
Proposed Plan, concurs with the preferred alternative.

2.8.0.10      Community Acceptance: Community acceptance of the preferred alternative
was evaluated after the  public comment period on the Proposed Plan for OU1.  The
community acceptance is described in the Responsiveness Summary of this ROD.
2.9 SELECTED REMEDY

2.9.0.1       Based on the preceding analyses of alternatives, the DLA has determined that
Alternative 5 (Institutional Controls) is the most appropriate option at the site.

2.9.0.2       Although risk-based soil  action levels (TBC requirements) or background
concentrations for arsenic and antimony were exceeded in one sample each, none of the
constituents found in the soils at the OSA are present in the ground water at concentrations

1519.42                                2-31

-------
greater  than MCLs.    Additionally, the  samples  containing  arsenic and antimony
concentrations greater than the risk-based action or background levels were collected at
depths greater than 5 feet. Therefore, exposure to these constituents would not be expected
to occur unless excavation activities take place at this site.  Therefore, with respect to the
soils at the OSA site, the institutional control approach has been determined to be the most
effective and appropriate option.

2.9.0.3       The institutional control at the OSA site should include continued operation
of the site as a restricted area.  Specific deed restrictions are detailed in Section 2.7.0.7 of
this ROD document. Future development of the OSA site,  including excavation and other
site grading, are  not precluded by the site contamination or by the institutional controls
recommended in this Record of Decision. As construction and excavation will be required
as part  of the site  development by the base (construction is currently  taking place, and
additional construction is planned), formal safety measures will be instituted to protect both
workers and the public.  A soil sampling, analysis and remedial action plan will be done with
concurrence from the regulatory agencies and instituted during excavation activities at the
site.   Although the  site soils do not  represent a significant threat to the ground water,
continued monitoring of ground-water quality will be carried out as part of the ground-
water operable unit (OU6) for  the OSA  and  adjacent areas.

2.9.0.4       The estimated cost of the system is estimated to be approximately $15,000.
The majority of the controls are already in place at the site, thereby negating many of the
costs that could be  associated with this alternative.
2.10 STATUTORY DETERMINATIONS

2.10.0.1      To meet the statutory requirements of CERCLA Section 121, the selected
remedy must:


1519.42                                 2-32

-------
       •      Be protective of human health and the environment;

       •      Comply with ARARs (or justify an ARAR waiver);

       •.      Be cost effective;

       •      Utilize permanent solutions and  alternative treatment technologies to the
             maximum extent practicable; and

       •      Satisfy the preference for treatment that reduces toxicity, mobility, or volume
             as a principal element, or provide an explanation as to why this preference is
             not satisfied.

2.10.02      How the selected  remedy  complies  with  each of  these requirements is
summarized below.


2.10.1  Protection of Human Health and Environment

2.10.1.1      The institutional controls alternative is primarily aimed  at  reducing  or
eliminating human contact and preventing the inappropriate future  usage of the site or
contaminated soil. Ground-water monitoring would be conducted at this area as part of the
ground-water operable unit (OU6). Due to the low levels of contamination present at OU1
and the existing restrictive access, this alternative is effective at protecting human health and
the environment.


2.10.2  Compliance with ARARs

2.10.2.1      No ARARs were identified for this alternative.  This alternative will comply
with the  chemical-specific TBC requirements (risk-based soil action levels)  identified in

1519.42                                2-33

-------
Table 2-4, with the exception of single concentrations of arsenic and antimony which were
encountered at a depth of greater than 5 feet. By requiring formal Health and Safety Plans
and environmental and personnel monitoring for all future excavation and construction
activities  at the site, this alternative will  also  comply with  the action-specific  TBC
requirements.


2.10.3 Cost-EfTectiveness:

2.103.1      The alternative is cost effective.   The cost  for this alternative primarily
involves costs that already are assumed as part of the DGSC operations.  Additional cost
of $15,000 is estimated for legal and other miscellaneous costs required for deed restrictions
and establishing institutional arrangements and procedures.


2.10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies;

2.10.4.1      This alternative does not treat the soils at the OS A, but does have the
potential for treatment if necessary during excavation activities at the site.  The alternative
does not therefore satisfy the preference for treatment technologies that reduce contaminant
toxicity, mobility, or volume.

2.10.4.2      However, as the risk posed by the contaminants at the site is low, and due to
their nature and extent, the DLA has determined that the selected alternative (Institutional
Controls)  represents the most effective option for OU1 at the DGSC.


2.10.5 Documentation of Significant Changes

The Proposed Plan for OUl-Open Storage Area Source Soils was released to the public on
January 20,1992. The Proposed Plan identified Alternative 5, Institutional Controls as the
preferred alternative. The DLA reviewed all written and verbal comments submitted during
1519.42                                 2-34

-------
the public comment period.  Upon review of the comments, it was determined that no
significant changes to.the alternative, as it was originally identified in the Proposed Plan,
were necessary.


2.10.6  Responsiveness Summary

The purpose of this responsiveness summary is to provide the public with a summary of
citizen comments, concerns, and questions relating to two areas of concern at the Defense
General Supply Center (DGSC) in Chesterfield County, Virginia.  The area of concern
specifically addressed by this responsiveness summary is:

       •      Operable Unit One (OU1) - Open Storage Area Source Soils

The responsiveness summary details the DLA's responses to these comments, concerns and
questions.

During the public comment period from January 20 through March 6, 1992, both written
comments and phone calls were received by DGSC concerning the two operable units. In
addition, for OU1, the comment period was extended from March 9, 1992, to April 6, 1992.
Comments and calls received during these public comment periods are addressed as part
of this responsiveness summary.  As part of its efforts to inform the public of environmental
activities at  DGSC, the DLA held  a  public  meeting on February  20,  1992, at the
Chesterfield  Elementary School. At this meeting,  the Proposed Plans for OU1 and OU5
were presented, and the public was given an opportunity to comment on and ask questions
concerning the plans.  Several technical questions pertaining to OU1 and OU5 were
answered during the public meeting. The responsiveness summary for OU1 is divided into
the following sections:
1519.42                               2-35

-------
      I.     Summary of questions and replies

      II.     Public meeting attendance roster.

      III.    Panel of experts.

      IV.    Selected newspaper notices announcing dates of the public
             comment period and location and time of public meeting.

All comments and concerns summarized in this document have been considered by the DLA
in making a decision regarding the selection of the Institutional Controls Alternative for
OU1 - Open Storage Area Source Soils as the chosen alternative. Those questions that do
not pertain to OU1 are preceded by an asterisk (*).
1519.42                                2-36

-------
I.     SUMMARY OF MAJOR QUESTIONS AND COMMENTS

  *    1.    Comment: A resident sent a letter comment to DGSC stating that he agreed
            with vapor vacuum extraction for the Acid Neutralization Pit Soils (OU5) as
            long as institutional controls were included as part of the final solution.

            DLA Response: With the preferred alternative being utilized, the main threat
            at the ANP area (chlorinated solvents) in the soils are being remediated. The
            single elevated occurrence of arsenic was encountered at significant depth (15
            feet) and is considered unlikely to be encountered by reasonably anticipated
            site activities. Therefore, the DLA feels that institutional controls will not be
            necessary if chemical sampling of soils confirms that the chlorinated solvents
            have been removed after treatment.

      2.    Comment:  A resident sent a letter comment to DGSC requesting that the
            public comment period  for OU1 be started over as one of the referenced
            documents in the OU1 Proposed Plan was not available in the administrative
            record.  He also questioned whether concerned citizens could get Technical
            Assistance  Grant  (TAG)  money to  help them with  the  process  of
            understanding the  remedial actions taking place at the site.

            DLA Response:   An additional time period is  being  allowed for public
            comment on  OU1  as the missing reference document is now present in the
            administrative record. The EPA is willing to work with any group of citizens
            that is interested in obtaining TAG money to help their review of past and
            ongoing remedial activities at DGSC.

  *    3.    Comment:  A former resident of the area sent a letter comment to DGSC
            asking that documentation relating to remedial work and laboratory testing
            of water be sent to her or kept available for viewing. She also requested that
1519.42.                               2-37

-------
             documentation-as to whether or not her mother's property has contamination
             present be sent to her as they plan to sell the property.

             DLA Response: The former resident was contacted to let her know that all
             of  the  administrative  record  would remain  available  for  review at  the
             Chesterfield Public Library, and that  this administrative record contained
             information on all  of the remedial  work  done  at  the  site.   DGSC
             representatives will also send  any information pertaining to water well or
             other sampling done  at her mother's address to help determine whether  any
             contamination is present at the property.

The following comments were received during the public meeting on February 20, 1992.

      4.     Comment: A resident asked that the public comment period for OU1 be
             started  over  as the administrative record was  missing a memorandum
             referenced in the OU1 Proposed Plan.

             DLA Response: Refer to Comment #2 response.

 *    5.     Comment: A resident stated that he felt that institutional controls should be
             applied to the ANP area after  treatment is complete.

             DLA Response: Refer to Comment #1 response.

 *    6.     Comment: A resident asked that in the area of ground-water contamination
            whether everyone was hooked up to the county water supply system.

             DLA Response: DGSC will look into the situation with anyone who leaves
             their name and phone number, and the location of the property in question,
           .  after the meeting.
1519.42                                2-38

-------
  "    7.     Comment:  A resident asked whether the  DLA was aware that not all
             properties had county water run to them.

             DLA Response: Refer to Comment #6 response.

  *    8.     Comment: A resident questioned whether anyone present was aware of a site
             not  currently  under investigation that the resident  had pointed out to a
             general's aide a number of years earlier.

             DLA Response: The DGSC will send  out a representative with the resident
             to investigate the site, and will also forward any testing results concerning the
             site that they may have to the resident.

  *    9.     Comment: A resident questioned why some  of the area residents were not
             on the committee.

             DLA Response: The reason that public meeting is being held is to bring all
             of the concerned residents up to date on clean-up  activities for OU1 & OU5.

  *    10.    Comment: A resident requested that  additional  people be put on DGSC's
             informational mailing list for remedial activities at the site.

             DLA Response: Everyone who signed in to the register tonight will be put
             on the mailing list, unless they request otherwise.  Also, residents can contact
             George Dellinger (DGSC Public Relations Officer) to be put on the mailing
             list also.

  *    11.    Comment: A resident asked for clarification as to who was and who wasn't
             hooked up to the county water system years earlier.

1519.42.                               2-39

-------
             DLA Response:  DGSC will  look  into the situation  and respond to the
             resident.

  *    12.    Comment: A resident that lives along Kingsland Creek asked if the slime that
             she had on her well filter was normal.

             DLA Response:  The DGSC will  have someone come to the resident's
             property to see about testing the water.

  *    13.    Comment: A county supervisor asked if material that went into the sanitary
             sewer at the ANP area eventually went into the county sewer system, and
             whether downstream hazards had been assessed.

             DLA Response:  The DGSC will  look into what  possible impact ANP
             activities may have had on the  county sanitary sewer system.

  *    14.    Comment:  The county supervisor asked that a reply  also be sent to the
             county administrator.

             DLA Response: A response will also be sent to the county administrator.

       15.    Comment:  A resident asked if either OU1 or OU5 drain into Kingsland
             Creek.

             DLA Response: Neither OU1  or OU5 drain into Kingsland Creek.

  *    16.    Comment: A resident asked if any other sites drain into Kingsland Creek.

             DLA Response: There are other sites that drain into Kingsland Creek, but
             they are not being  addressed  tonight, as  only OU1 and OU5 are being
          '   discussed.
1519.42                               2-40

-------
  *    17.   Comment: A resident asked when the other sites will be addressed.

            DLA Response: Updates as to progress at the other sites will be provided as
            they become available.

  *    18.   Comment:  A resident asked how long it would be until results would be
            available from studies being done on Kingsland Creek.

            DLA Response: As Kingsland Creek is addressed as part of other operable
            units not being addressed at this meeting, there are no specific dates that can
            be given to the resident.

  *    19.   Comment: A resident asked whether the DLA had a time frame for reporting
            on the other sites not being addressed tonight.

            DLA Response: Updates as to progress at the other sites will be provided as
            they become available.

  *    20.   Comment: A resident asked whether proposed plans for the other sites would
            be provided when they are done.

            DLA Response: Proposed plans for all of the sites will be made available as
            soon as they are done.

      21.   Comment: A resident questioned whether contamination that got into the
            ground water at DGSC could come out at the surface of a site away from
            DGSC if the site was lower in elevation than DGSC, and what the effects of
            that contamination would be.

            DLA Response:  During studies at the site, the various ways in which the
           'Contaminants could move offsite were  investigated.  The studies looked at
1519.42                                2-41

-------
             different ways that people away from the site could be affected, including the
             contaminants being moved in the ground water.  The studies showed that if
             the .recommended alternatives are used, human health and the environment
             would be sufficiently protected from contaminants at the sites.

  *    22.    Comment:   A  resident questioned  whether excavation involved with the
             remediation would cause additional migration of the contaminants.

             DLA Response: The DLA has recommended a remediation alternative that
             does not involve excavation.  Rather, at OU5, the contaminants will essentially
             be "vacuumed"  from the soils,  and the contaminants will be captured  in a
             carbon adsorption unit.

  *    23.    Comment:  A resident questioned whether these contaminants would be put
             in the county sewer line after they are removed from the ground.

             DLA Response: The contaminants would not be put in the county sewer line.
             Instead, the carbon adsorption unit would be sent away for proper disposal.

      24.    Comment:  A resident asked whether the whole process could be started over
             so that some of the community groups can try for a EPA Tag (money grant).

             DLA Response: Refer to Question #2 for the DLA response.

  *    25.    Comment:  A resident asked how long it would take for a steel drum to rust
             through if it was buried in the ground.

             DLA Response: Although the exact number of years it can take depends on
             the condition of the drum originally, and the type of soil it is buried in, a
             buried drum can rust through in approximately a decade.

1519.42                                2-42

-------
      26.    Comment: A resident asked if vacuum extraction would work if there were
             buried drums.

             DLA Response: At OU5, there is no record of buried drums being present,
             nor were any found during investigative work at OU5.

      27.    Comment: A resident asked about possible contamination at his property,
             and whether metals in the ground water could affect his pipes as he is not
             hooked up to the county system.

             DLA Response: As part of the investigative activities at the other sites, which
             are not being addressed tonight, work is being done  to try to determine what
             types of metals and organics are present in the ground water.  The remedies
             proposed  at OU1 and OU5 are designed to be protective of ground water.
             The remedies for the ground water will deal specifically with contaminants
             and the problems they may pose in ground water itself.  The remedies will
             also take into consideration the possible affect ground-water  contamination
             could have on residents affected by the situation.

      28.    Comments:  A resident asked whether  old wells that  had been filled up
             previously could cause the contaminants to bypass the closed wells and move
             on to open wells.

             DLA Response: Due to the way ground-water flows, the closed wells would
             not have an effect on the way the contaminants move through the ground
             water.
1519.42                                2-43

-------
II.   PUBLIC MEETING ATTENDANCE ROSTER
1519.42

-------
NAME
           Piuur
       OBFBH8B OBNBBAL SUPPLY CBBTBB



PUBLIC MBBTIHG f BBLLWOOD SLBMBHTARY SCHOOL



            FBBBUARY 20, 1992



       ADDRESS
                                                              MAILING US'

                                                             i
                                                            •W^*
//LL>
                     "rt
                           Sf&L
.  H.iL. U. Vi».%i'.w

-------
            a : -a
NAMB
       DBPBN8B OBNBBAL SUPPLY CBRTBB
PUBLIC MBBTXHG • BBLLWOOD BLBMBKTABY SCHOOL
             FEBRUARY 20, 1992
       ADDRESS	'	   	
                                                              MAILING LIST
               4frMk£
                                            IS*^.  IVWTMM
                                  $
11- rtut
//
      y  '
                        &&Z&Z-

-------
NAME
       DIFBH8B QBXSRAL SUPPLY CMITBB



PUBLIC MBBTIHQ • BBLLWOOD KLBMBHTARY SCHOOL



             FEBRUARY 20, 1992



       ADDRESS  	
MAILING LIST
                                                                   7-
            I

-------
m.   PANEL OF EXPERTS

The following list represents the panel members who participated in the public meeting held
on February 20,1992.

Defense General Supply Center
Colonel John E. Dawley, Jr., U.S. Army
George Dellinger
William Saddington
Art Wells
Kent Baldwen
William Walker
Major Kerry L. Burke, U.S. Army

y.S. Environmental Protection Agency - Region III
Jack Potosnak
Hank Sokolowski
David Sternberg

Virginia Department of Waste Management
Steve Milhalko
Jamie Walters

U.S. Army Corps of Engineers
Roger Fitzpatrick
Roger Young
Suzanne Murdock

Law Environmental. Inc.
Thomas Richardson
Lynden Peters
1519.42

-------
 IV.   SELECTED NEWSPAPER NOTICES  ANNOUNCING DATES OF PUBLIC
      COMMENT AND LOCATION OF PUBLIC MEETING
1519.42

-------
                                 PUBLIC NOTICE
                      Proposed  Remedial Action Plans
                                       for the
        Defense General Supply Center (DGSC)  Superfund Site
 In accordance with the requirements of the Comprehensive Response, Compensation and Liability
 Act (CERCLA), the Defense Genera! Supply Center (DGSC), the U.S. Environmental Protection
 Agency (EPA), and the Virginia Department of Waste Management (VDWM) invite public comment
 on the Proposed Plans for two of the eight Superfund operable units: the Open Storage Area (OSA)
 and tbe Former Acid Neutralization Pits (ANP). The Superfund public comment period will begin on
 January 21,1992 and close on March 2,1992.
    A public meeting will be held to discuss the specifics of the proposed cleanup actions at 7:30
 PM on February 20,1992 at the Bellwood Elementary School, 9536 Dawnshire Road, Chesterfield,
 Virginia.
    A focused feasibility study (FFS) has been prepared by DGSC for the contaminated soils at the
 OSA. The FFS evaluated the following remedial action alternatives:
    Alternative 1: Surface Containment/Capping
    Alternative 2: Solidification/Stabilization
    Alternative 3: Soil Washing
    Alternative 4: Evacuation with Off Site Treatment/Disposal
    Alternative 5: Institutional Controls
    Alternative 6: No Action
    Based on an evaluation of the alternatives, the preferred cleanup option for the OSA is Institutional
 Controls consisting of environmental  reviews prior to performing maintenance,  an environmental
 assessment for military construction projects in accordance with the Defense Logistics Agency policy
 memorandum dated 27 December 1989 and  any deed restrictions required under Part 120 (H) of
 CERCLA.
    A focused feasibility study (FFS) has been prepared by DGSC for the contaminated soils at the
 ANP. The FFS evaluated the following remedial action alternatives:
    Alternative 1: Surface Containment/Capping
    Alternative 2: Excavation with Solidification/Stabilization
    Alternative 3: Excavation with Soil Washing
    Alternative 4: Excavation with Solid Phase Biotreatment
    Alternative 5: Excavation with Bulk Incineration
    Alternative 6: Excavation with Off Site Treatment/Disposal
    Alternative 7: Vacuum Vapor Extraction
    Alternative 8: Institutional Controls
    Alternative 9: No Action
    Based on an evaluation of the alternatives, the preferred cleanup option for the ANP is Vacuum
Vapor Extraction. Vacuum Vapor Extraction consists of drawing vapors from the soils using extraction
wells connected to a manifold system. The system is connected to a blower to draw vapors from the
soil. The venting of volatile organic compounds (VOCs) to the atmosphere will be controlled through
an emissions control system using vapor phase -  *;vated carbon. Citizens can hear presentations
on these proposed technologies,  and ask ques. jns, at the February  20, 1992 public meeting.
   Although these are the preferred remedial options at this time, DGSC, in consultation with EPA
and VDWM, may modify the preferred alternative or select another option based on new information
presented during the public comment period; therefore the public is encouraged to review and
comment on the  Proposed Plan for  site cleanup  prior to  the dose of the  comment period.
    Citizens may review and photocopy documents pertaining to the DGSC Superfund site studies
and remedy selections in the site Administrative File, located at the Chesterfield Public Library, 9501
Lori Road, Chesterfield, VA 23232. Library hours are 10:00 a.m. to 5:30 p.m., on Wednesday, Friday
and Saturday; and 10:00 am. to 8:00 p.m. on Monday, Tuesday and Thursday. The library is closed
on Sunday,'
    For more information on the site, the comment period, or the upcoming public meeting or to be
added to  the mailing  list to receive  updates  on  the site, interested citizens  may  contact:
                                  Mr. George Dellinger
                        Defense General Supply Center, DGSC-DB
                               Richmond. VA 23297-5000   •
                                     (804) 275-3139

-------
                                             "Progress-Index, Petersburg, Va., Friday, February 21,  1992
  DGSC

  begins

  clean-up

  journey

  By DAVID BREIDENBACH
  Staff Writer
  . CHESTERFIELD^- Two con-
  taminated sites at the Defense Gen-
  eral Supply Center have started a
  long road to  being cleaned  up.
    About 26 area  residents,  and
  officials from the DGSC and the
  Environmental Protection Agency
  discussed the sites and clean-up
  plans at a public hearing Thursday
  night at  Bel I wood  Elementary
  School.
    The two contaminated sites
  addressed were an open storage
  area and  an  acid neutralization
  facility. The Virginia Department
  of Waste Management is also tak-
  inc pan in the cleanup operation.
    Marked as a Superfund site, the
  DGSC cleanup is different than a
  typical cleanup, said Jack  Potas-
  nak of the EPA, which is oversee-
  ing the DGSC's cleanup operation,
  he said.
    Usually, sites are abandoned
  before the EPA ever gets involved.
  In this case. DGSC is still u work-
  ing operation.
    The entire DGSC site — which
  has a total of eight contaminated
  areas — is considered a Superfund
  site, said David Steinberg, an EPA
  public affairs specialist. The conta-
  mination sites were broken down
  to smaller areas to make it easier to
  clean up, he said.
    "Of the two tonight, neither are
  the most severe, but everything is
  reviewed and the projects should
  go ahead." he said.
    Five of the sites are  called
  source ureas, or places where con-
  tamination  is known  to  have
  occurred. The other three involve

  See DGSC,  page A6
DGSC:   Has  cleanup  hearing
  Continued from  page Al


 groundwater'contamination and
 are considered the more difficult to
 clean, he said.
   Contamination  at the  DGSC
 sites occurred as a result of normal
 operating procedures at the DGSC
 over three decades, said George
 Dellinger.  a DGSC spokesman.
   "There were many practices in
 the '40s. '50s and '60s that were
 considered normal operating pro-
 cedures. Nobody thought anything
 about the environment," he said.
   The open storage area, a 43-acre
 fenced site in the middle of the
 DGSC is used to store petroleum
 products.  Higher than  normal
 levels of two metals, arsenic and
 antimony, were found in soil sam-
 ples there. The contaminated soil is
 not considered to be a .significant
risk, said William Saddington of
the DGSC.
  Because the site poses little risk.
Saddington said the  preferred
method of treatment is to control
the area. A fence will be put up
around theurea and the DGSC will
continue to monitor it.
  The second site, an acid neutra*.
lization facility, poses a different
problem, he said. Higher than nor-
mal levels of arsenic  and  an
organic contaminant were found.

  The arsenic level was no great
concern, but the organic contamin-
ant, terchlorethane. which is used
in cleaning materials,  is of con-
cern, he said. The DGSC i mends to
vacuum the contaminant out of the
ground, he said.
  Most of the citizens who spoke
at the meeting were  concerned
"•?th the effects the site has ->n the
groundwater.
  In  the mid-1980s, water was
extended to a number of house-
holds in nearby Rayon Park subdi-
vision. About five residents of the
subdivision, who are not tied into
the county  water system, com-
plained of water problems at the
meeting.
  DGSC representatives  took
names and addresses and promised
to address the questions. A public
comment period closes March 6. at
which time a final decision will be
made on how to clean up each of
the two sites, said Stemberg.
  It will probably take about four
years for the two sites to  be
cleaned. The groundwater sites ore
even more difficult to fix. he said.
  "The EPA wonts this done in a
fast and thorough manner. (But)
the site is difficult: it is a long-time
process.** he said.

-------
      THE RICHMOND NEWS LEADER, Friday, February 21,1992 11
 Federal  officials
 plan  cleanup  amid
 ground-water fears
By Mitch Ztnwl
Stiff writ*
  Federal officials have presented
plans to clean up two of eight Super-
fund hazardous waste sites at the
Defense General Supply Center in
Chesterfield County, but surround-
ing  residents are  more  concerned
about ground-water contamination.
  Representatives of  the military,
the  U.S. Environmental  Protection
Agency,  the  U.S. Army Corps of
Engineers and the state Department
of Waste Management conducted a
public hearing last night to discuss
proposals to handle two of the sites.
Both contain soil contaminated with
arsenic, and one also contains a haz-
ardous organic compound.
  But the approximately 30 resi-
dents who attended the  hearing at
Bellwood Elementary  School re-
peatedly asked questions about two
other sites of contaminated ground
water.
  The officials said studies of those
two sites and four others  are not
complete and they declined to give
the residents any information about
them. Officials added that they did
not know when those sites would be
studied or discussed.
  Several residents expressed con-
cern that the contaminated ground-
water sites had affected their wells.
One woman said multiple water fil-
ters have failed to make her water
drinkable. Another resident said her
water pipes corrode rapidly.
  After  declining  to discuss the
ground water, the  federal  officials
took the residents' names and ad-
dresses and said they would contact
them later.
  Officials from the Defense Gen-
eral Supply Center have stated that
public  safety and health are  not
threatened by the sites, but  EPA
officials said last night they weren't
sure whether residents are being af-
fected by the contaminated ground
vater.
•  Most residents in the supply cen-
er area were connected to county
vater  lines in the mid-1980s and
ton't use well water.
[  EPA officials said the two  sites
f soused last night are not the most
crious ones.
I  To remove  the organic contami-
ijant from the soil at one of the sites,
a process called "vacuum vapor ex-
naction" would be used to blow air
through  the  soil The  hazardous
(impound would be picked up by
t ie air, which then would be filtered
ti  remove the  contaminant.  The
process would take about four years.
I To deal with the other site,  offi-
c als plan simply to restrict access to
t e area.
 The agencies involved will not
t ake a final decision on the cleanup
p oposals until after the public com-
i ent period ends March 6.
 EPA officials said there is no
t netable for cleanup of the other
s es, which were put on the Super-
f nd list in 1987. Most of the con-
t minants are from petroleum prod-
t ts and were discovered in the early
180s.

-------
-JB-4 Hichmond Tlme^Dt^H t  Friday. February 21, 1992
             .•?  f

         Answers


         on cleanup


         are few


         Bellwood waste

         sites in question

         By Randolph P. Smith
         Staff writer
           For. 26 years, Jo Ann Cordle has
         carried water from a well 500 feet
         from her home because her own well
         water  is "slimy" and "tastes bad"
           Even two water filters can't tempt
         Mrs.'/Cordle  to cook or  drink the
         well water piped into her home.
           She wonders if her well is drawing
         ground water contaminated by
         chemical leaks at the Defense Gen-
         eral Supply Center, which  borders
         her property.
           SeV&al of Mrs.  Cordle's neigh-
         bors in the Bellwood area of Ches-
         •terfield County also are  worried
         f-abojtf* contaminated ground water
         jfeeofng their wells. Some wonder if
         •"thVtiancer death rate in the neigh-
         borhood is higher than normal
           But, Mrs. Cordle and  about 30
         neighbors got few answers last night

         of the cleanup of hazardous waste
         sites at DGSC.
         ,  Despite the presence of at least a
         .dozen representatives from DGSC,
         ;the .state  and  the  Environmental
         'Protection Agency, the most  com-
         •molr'fcnswer to residents' questions
         Jwas, "We'll get back to you."
         •!  Officials said they weren't  ore-
         •pared to talk about potential ground
         water contamination.
 * ^fSey generally wanted to restrict
 Jhe discussion fto the  first two of
 Jeight cleanup projects on the 639-
             installation, which is
        six major supply depots for
            around the world.
    oth of the initial cleanup efforts
 locus on contaminated dirt
   One  site, a 43-acre storage area
 where an estimated 80,000 drums
 now sit, won't even be cleaned up
 because it "does not present a signii-
 •jcant risk," said William Saddington,
 39 DGSC  environmental  engineer.
 jSoil at  the site, which has been a
 jidrung storage area -since  1942, has
 Cbeen found to contain above-normal
 levels of two metals.

   The second  cleanup effort  is at
 the site of two acid neutralization
   Chemicals  used  to dean  metal
 flowed out of a warehouse and into
 two concrete settling pits, where it
 was neutralized before being piped
[•into the -county sewer system. The
;ipits were used from 1955 to 1985,
;>hen they were filled in with dean
<$oii,.Saddington said.

'  'Contamination was found in soil
 under one of the pits and the organ-
 ic vapors will be vacuumed out of
 the ground — a process that could
 take up to four yean.
   The .ground water under the add
 pits -is contaminated, officials ac-
. knowiedged, but they didn't want to
< discuss that in detail last night.
•^.Officials stress that neither the
• soil .nor the ground water poses
'• health threats to DGSCs 3^200 em-
'. ployees or to Bellwood residents.
   But several years ago, the federal
 government paid to extend county
 water to most of the homes in the
 Bellwood area after concerns were
 raised about  contaminated ground
 water flowing off the base.

-------
ATTACHMENT A

-------
          EPA HAZARDOUS SUBSTANCES REPORTING REQUIREMENTS FOR SELLING OR
                                TRANSFERRING FEDERAL REAL PROPERTY

                                   (40 CFR 373; 55 FR 14212, April 16, 1990)
 PART 373—REPORTING HAZARDOUS
 SUBSTANCE ACTIVITY WHEN
 SELLING OR TRANSFERRING
 FEDERAL REAL PROPERTY

 Sec.
 373.1  General requirement.
 373.2  Applicability.
 373.3  Content of notice.
 373.4  Definitions.
  Authority: Section 120(h) of the
 Comprehensive Environmental Respon:e.
 Compensation, and Liability Act of 1980. as
 amended. 42 U.S.C. 9601 6t seq.

 §373.1  General requirement.
  After the last day of the six month
 period beginning on April 16.1990,
 whenever any d?partment, agency, or
 instrumentality of the United States
 enters into any contract for the sale or
 ether transfer of real property which is
 owned by the United Stales and at
 which, during the time the property was
 owr.ed by the United States, any
 hazardous substance was stored for one
 year or more, known to have been
 released, or disposed of. the head of
 such department, agency, or
 instrumentality must include in such
 contract notice of the type and quantity
of such hazardous substance and notice
of the time at which such storage,
release, or disposal took place, to the
extent such information is available on
the basis of a complete search of agency
files.
537X2  Applicability.
  (a) Except as otherwise provided in
this section, the notice required by 40
CFR 373.1 applies whenevet the United
States enters into any contract for the
sale or other transfer of real property
which is owned by the United States
and on which any hazardous substance
was stored for one year or more, known
to have been released, or disposed of.
  (b) The notice required by 40 CFR
373.1 for the storage for one year or
more of hazardous substances applies
only when hazardous substances are or
have been stored in quantities greater
than or equal to 1000 kilograms or the
hazardous substance's CERCLA
reportable quantity found at 40 CFR
302.4. whichever is greater. Hazardous
substances that are also listed under 40
CFR 261.30 as acutely hazardous wastes.
and that are stored for one year or more.
are subject to the notice requirement
when stored in quantities greater than or
equal to one kilogram.
  (c) The notice required by 40 CFR
373.1 for the known release of hazardous
substances applies only when
hazardous substances are or have been
released in quantities greater than or
equal to the substance's CERCLA
reportable quantity found at 40 CFR
302.4.

6 373.3 Content of notice.
  The notice required by 40 CFR 373.1
must contain the following information:
  (a) The name of the hazardous
substance: the Chemical Abstracts
Services Registry Number (CASRN)
where applicable: the regulatory
synonym  for the hazardous substance.
u listed In 40 CFR 302.4. where
applicable: the RCRA hazardous waste
number specified in 40 CFR 261.30.
where applicable: the quantity in
kilograms and pounds of the hazardous
substance that has been stored for one
year or more, or known to have been
released, or disposed of. on the property.
and the date(s) that such storage,
release, or disposal took place.
  (b) The following statement.
prominently displayed: "The
information contained in this notice is
required under the authority of
regulations promulgated under section
120(h) of the Comprehensive
Environmental Response, Liability, and
Compensation Act {CERCLA or
"Superfund") 42 U.S.C. section 9620(h)."

9 373.4  Definition*.
  For the purposes of implementing this
regulation, the following definitions
apply:
  (a) Hazardous substances means that
group of substances defined as
hazardous under CERCLA  101(14!, and
that appear at 40 CFR ,302.4.
  (b) Storage means the holding of
hazardous substances for a temporary
period, at the end of which the
hazardous substance is either used.
neutralized, disposed of. or stored
elsewhere.
  (c) Release is defined as specified by
CERCLA 101(22).
  (d) Disposal means the discharge.
deposit,  injection, damping spilling.
leaking or placing of any hazardous
substance into or on any land or water
so that such hazardous substance or any
constituent thereof may enter the
environment or be emitted  into the air cr
discharged into any waters, including
groundwatcr.
                                                                                         [Sec. 373.4
-------
ATTACHMENT B

-------
                          DEFENSE  SUPPLY  AGENCY
                          DEFENSE GENERAL SUPPLY CENTER
                            RICHMOND. VIRGINIA 23297
                                                                    4150.1
   DGSC REGULATION
   WO.      4150.1
                                                       31 Jan 77
DGSC-W
               MAINTENANCE AJTO REPAIR OF BUILDUP AID GROUTCS

   I.  REFERENCES
     A.  AR 420-70, Repairs and Utilities Buildi.ngs and Structures.
     B.  AR 420-74, Repairs and Utilities Natural Resources - Land,
   Forest and Wildlife Management.
     C.  DSAR 4270.3, Maintenance and Repair of Real Property Facilities
   (Excepting Family Housing).

   II.  PURPOSE AND SCOPS.  To define responsibilities and establish
   policies for the upkeep and maintenance of buildings and grounds.
   This regulation is applicable to all elements of the Defense
   General Supply Center (DGSC) and tenant activities.

   IH.  POLICY
     A. -Construction of new buildings,  alterations or additions to
   existing buildings will not be undertaken by any individual without
   the prior approval of the Chief.. Facilities Engineering Division,
   Dir/Installation Services (D/IS).              .
     B.  The Chief, Facilities Engineering Division, D/IS, is
   authorized to approve all requests within available operation
   and maintenance (O&M) funds, for work classified as maintenance
   (excepting Family Housing). •
     C.  The Chief, Facilities Engineering Division, D/IS, is
   authorized to approve all requests for repair within available operation
   and maintenance (O&M) funds at a funded cost of $5,000 or less,
   except when the cost is more than 50  percent of the facility
   replacement cost,  for work classified as repair (excepting Family
   Housing).   The Director of Installation Services  is authorized to
   approve all requests within available operating and maintenance
   (O&M)  funds at a funded cost of $5,000 to $100,000,  except when
   the cost is more than 50 percent of the facility  replacement cost,
   for work classified as repair  (excepting Family Housing).
     D.  No painting will be undertaken  by any individual without
   prior  approval of the Chief, Facilities Engineering Division.
     E.  Items showing indications of abuse or daaage,  other than
   that due to fair wear and tear,  will  be called  to the attention of
   the responsible office and an  explanation will be required.   Unwar-
   ranted damage or abuse together with  an estimate  of the cost of
This DGSCR supersedes D3SCR 4150.1, 1 Sep 71.

-------
DGSCR 4150.1


 repairs, will be brought to the attention of the Deputy Cozzander
 by the Director of Installation Services for appropriate action.
   F.  Cutting of trees on the Center vill not be accomplished T..dth-
 out approval of Chief, Facilities Engineering Division.
   G.  Cigarettes, ezpty cups, paper bags, etc.  vili not be scattered
 about the Center.  Building occupants are responsible for the police
 cf the area surrounding their building.  Drink cans containing steel
 vill be placed in trash receptacles provided unless they are aluai-
 nua drink cans, vhich will be placed in recycling container.
 .  H.  Care vill be exercised by each person -using the restrooas to
 ensure that papers,  cigarettes, and ashes are not throvn on the
 floor, in the lavatories,  or in the washstar.ds.
   !•  Only emergency type work will be performed in the Family
 Housing areas without prior approval of  the Family Housing Officer.

 IV.   RESPONSIBILITIES
   A.   The Chief,  Facilities  Engineering Division is responsible
 for the budgeting of adequate funds to  provide  for  the maintenance
 and repair for all facilities located on the. Defense. .General Supply
 Center.
   B.   The Chief,  Facilities  Engineering Division (Center Engineer),
 Sir/Installation  Services will upkeep and maintain  all building
 and grounds.
   C.   Directors/Major Office Chiefs will ensure  proper policing
 and control abuse or damage  to buildings, structures,  facilities,
 or portions thereof,  occupied or used by their activities.
   D.   The Director of Installation Services  will maintain this
 regulation in a current  status and review it annually.

 V.   PROCEDURES
   A.  The  Chief, Facilities Engineering  Division  will monitor all
 activities located on the Defense  General Supply Center  for  compli-
 ance  with policies stated in paragraph  III,  violations will  be
 reported  to the Director of  Installation  Services.
   B.   All requests for construction or  alterations  to buildings
 will  be processed IAW DGSCR  4150.1,  Maintenance  and  Repair of
 Buildings  and Grounds.
   C.   All requests for work  in the Family Housing Area,  other than
 trouble calls, will be approved by the  Family Housing Officer on DA
 Form 2701 prior to accomplishment.
   D.   Trouble calls received  from  Family  Housing will be accomplished
 on a  monthly work  order approved by the Family Housing Officer.
   E.   All requests for maintenance  and  repair, except trouble calls,
 will be requested on DA Form 2701.

-------
                                                           DGSCR 4150.1

  F.  All  trouble "calls will be received by phone by the Facilities
Engineering Division on extension 3560.

BY ORDER OF TOE COMMANDER
                                       A. J. POLUBIXSKI
                                       Ch, Admin Services  Division
                                       Dir/Installation Services
DISTRIBUTION:  E & S
  S - 50 cys DGSC-WO

-------
DGSC REGULATION                           DGSC-W
NO. 4150.1

          MAINTENANCE AND REPAIR OP BUILDINGS AND GROUNDS
I.  REFERENCES: (See current DGSCR 4150.1 for refs A thru C)
    D.  Record of Decision - Operative Unit 1 - Date  	
II.  PURPOSE AND SCOPE: (See current DGSCR 4150.1 for policy and
scope - no change contemplated)

III.  POLICY: (See current DGSCR 4150.1 for policy items A through
I)
      J.  An environmental review shall be performed prior to any
excavation below 6 inches in the Open Storage Area for routine
maintenance.  The review shall consist of evaluating the proposed
area of excavation through an on site inspection of the area and
evaluation of analytical results from the remedial investigation
and any other results that have been collected.

IV.  RESPONSIBILITIES;  (See current DGSCR 4150.1 for items A
through D

     E.  The Environmental section of the Facilities Engineering
Section shall be responsible for conducting the on-site review in
the Open Storage Area.

V.  PROCEDURES;   (See current DGSCR 4150.1 for procedures - no
change contemplated)

-------
                            DEFENSE LOGISTICS AGENCY
                                    HEADQUARTERS
                                   CAMERON STATION
                             ALEXANDRIA. VIRGINIA 22304-6IOO



                                                                   2 7 OSC jggg

  DLA-W/DEPO (Mr. Stumpf/(AV)284-7275/gk)



  SUBJECT:  Installation Characterization and Clearance



  TO:        SEE DISTRIBUTION
  1.   Enclosed for  your  information  is  a copy  of  the  "Interim  Guidance for
  Construction Site Clearance at  U.S.  Army Installations"  prepared by the U.S.
  Army Toxic  and  Hazardous Materials Agency.  Also enclosed is  an excerpt frcm
  draft AR 415-15 which accompanied the guidance.

  2.  We are  initiating  our own  project in FY 90 through the Huntsville Division
 of  the  U.S.  Anny Ccrps cf Engineers  (CoE)  to characterize  all DLA-managed
 installations based on  site  contamination criteria.  The purpose of the project
 is  to  evaluate each  installation to ensure safe conditions  for construction
 site personnel  as well  as  for its occupants. This  project will  result  in  an
 installation  map with  all  areas  labeled as either  Category  I,  II or III.
 Basically,  a Category I area  is one for which  there is  no reason to believe
 that contamination  has  occurred as  a result  of past  or present operations
 in  the  area; construction  may  proceed  without  any environmental cleanup.  A
 Category II  area  is  one for  which  there  is potential  for  the presence  of
 contamination frcm  past or  present operations  in  or near the area; a more
 extensive survey, including  field investigations, is  required  before  the area
 can be characterized and before  construction may proceed. A Category  III area
 is one which is  known to be contaminated; remediation of a Category  III area
 may be prohibitively e:
-------
                                                                          osctgag
 DLA-W/DEPO  PAGE 2
 SUBJECT:   Installation Characterization and Clearance
 5.   Please provide us with a point of  contact  for this project by 15 January
 1990.  You will be notified by the CoE  or its contractor to arrange a schedule
 for your installation's  evaluation.

 6.   PCC  for this matter  at DLA-W/DEPO is Mr. Harry Sttnpf, AV 284-7275.

 FDR THE  DIRECTOR:
2Encl                                •Tjjtfj a. AND3EWS, JR.'
DISTRIBUTION:                         •>••:•.*.*!  ,:^
  DGSC-W                              .,•/  .:•:•'•..•
  DCSC-W
  DESC-W                                :"\  ..'...
  DPSC-W                               "	*"
  DDMT-W
  DDTC-W
  DDOU-W
  DFSC-F
  DNSC-N
  CoE, Huntsville
       (CEHND-ED-PM (Boswell))

-------
                            INTERIM GUIDANCE

                                  KR

                                   SITE CLEARANCE

                                  AT

                       U. S. ARMY INSTALLATIONS
PREPARED BY:     DARRYL D. BORRELLT

                 U. S. ARMY
                TOXIC AND HA2ARDOOS
                 MATERIALS AGENCY
                 (USMHRMA)

-------
                                      PURPOSE
      The  purpose of this  interim document is to  provide immediate guidance  to
 Major  Conmands   (MACCMS)  and  Engineering  and Construction  Project  Managers
 responsible  for  Military  Construction,  Anny  (MCA),  minor MCA,  Army  Family
 Housing (APH) construction projects, and all other construction projects en Army
 installations,   regarding  proper   techniques   for  preconstruction  site
 investigation  and  clearance procedures.    Information contained  herein will
 improve the safety of such projects and decrease the risk of injury to military,
 civilian,  and contractor personnel involved in their construction.

      Final guidance which  specifically details procedures presented  in this
 interim document  is currently being developed and  will be distributed upon its
 ccnEleticn.   Questions on the information provided in this interim guidance can
 be addressed  to Mr.  carsyl Sorrel 1 i,  CEffiA-lRrR, at (301) 671-2828/3921.


                               AUTHORITY

     The authority  for this guidance  is contained  in memorandums  from  Major
Generals Robertson  and Offringa,  Subject:  Environmental  Survey Guidance for
Potential  Construction  Sites.    These memorandums  contain  an  excerpt  from
proposed Arny Regulation  415-15 which  specifically  tasks U5ATKAMA  to  provide
guidance concerning the clearance of sites proposed for MCA, Minor  MCA,  and AFH
construct ion projects at Army installations worldwide.

-------
                        CLEARANCE OF CATEGORY I STIES
       Category I  sites,  by  definition,  are sites  located  in  a traditionally
  ncnhazardous  location,  such as an  administrative,  recreation,  or housing area"
  The  installation  therefore  has  no reason to  suspect  that contamination  has
  occurred through  past installation  operations in the area.   It must be realized
  that clearance procedures  for Category I  sites  entail only  visual inspections,
  thereby inherently limiting  their value.   Prudent  classification  of  sites  into
  Category I must be practiced to ensure worker safety.  If there is any potential
  for a  site to contain contamination,  or any doubt as to the site's  historical
  usage,   it  must be upgraded  to  a  Category  II  site, and investigated by  the
  required procedures.

       Procedures  for sites classified as Category I are as  follows:

       1.   Feview of the  installation historical  records  is  required.  P.ecords
  regarding past construction at a site and  its vicinity can normally be obtained
  frcm  the Directorate of  Engineering and Housing; while records regarding past
  installation  activities  in an area  nay  be contained in  the installation's
  library  or  museum.  Emphasis should be placed not only en historical text,  but
  also on archived photographs.   Discussions  with long-time installation personnel
 may prove beneficial for determining the historical usage of an area.

      2.   Review of the  Initial  Installation Assessment  (HA)  and the update
 thereof, if one exists,  is required.  This document can usually be obtained from
 the Environmental  office of  the  Directorate of  Engineering and. Housing, and
 contains  an assessment  of  environmental  contamination  that  was potentially
 caused by past operations of  the installation.   Environmental personnel may be
 of help in interpreting the information contained in this document.

      3.    Installation Restoration  Program  documents, if  any,  should also  be
 reviewed.   Specifically  these  would  be the Preliminary  Assessment  and  site
 Inspection report  and any  resulting  reports.   These reports  can usually  be
 obtained from  the  Environmental Office  of the Directorate of Engineering and
 Housing.

     4.    Review  of  aerial   photography   contained  in  EPA's  Environmental
 Photographic Interpretation  Center  (EPIC)  report, and associated narrative  is
 required.  This  report  can ^l«q  usually  be found in the Environmental  Office of
 the Directorate of  Engineering and Housing.   Photographs should be reviewed  with
 environmental  personnel or  someone  knowledgeable in  discerning natural  land
disturbances from aerial photographs  to ensure that the interpretation  provided
in the  narrative  is accurate.   These photographs can provide some of  the  most
conclusive information for the proper categorization of a site  and its vicinity.

-------
      5.    Surface reconnaissance  or physical inspection of the surface of the
          site and its vicinity to obtain evidence of potential  contamination is
 required.    This reconnaissance  should be  conducted under the supervision of
 environmental personnel who  are  experienced in field notation of factors which
 indicate possible  environmental  damage,  such  as  stressed  vegetation,  or other
 unnatural  land  features which may be related to anthropogenic sources.   The
 surface  of the  proposed site should  be  walked by personnel  spaced no further
 than twenty feet apart.  Care should  be  taken to ensure that all  areas of the
 proposed sites are  covered.

     Unnatural  surface  features  and  man-made structures or  debris should  be
narked in  the  field by flags.   Locations  should be recorded  on  a site nap.
Features which are  indicative of prior hazardous or industrial  usage of the site
and  its  vicinity  will elevate  the  site  to  Category rr, requiring  further
investigation.  Hie clearance program  for  Category I  sites  should entail  no
longer than 2 weeks.

-------
                       CLEARANCE OF CATEGOR* H SITES
       Category II  sites  are sites for which sane degree of doubt exists as to the
  historical  usage  of  the  site  and its  vicinity,  and  therefore  there is  a
  potential for the presence of contamination.   If doubt exists, a more extensive
  survey than that  performed for  a  Category I site must  be performed prior  to
  construction to ensure worker safety.  This will  involve ail  of the procedures
  reccKxnended for a Category  I site as well as the use of several ncnintrusive
  subsurface field investigative techniques.  Specifically, the use of geophysical
  and soil  vapor extraction techniques are required.   A lead time of approximately
  4 to 8 weeks,  depending  en a site  size, will be required to accomplish field
  work and review of results for a Category H site.  USA1HAMA will be available
  to  assist  the    installation   cccmander  in  interpreting   results  of  the
  gecphysical/soil gas studies.

      The  five procedures outlined for category I sites should be conducted prior
  to planning  the ensuing ncnintrusive field procedures.  Review of the  historical
  documents and a   reconnaissance  of  the  site surface  will  aid in  the  Fr=psr
 placement of field sarrcling devices.

  1.  GEOEKYSICAL TECHNIQUES

      Surface geophysical  investigation of the proposed site and  its vicinity
 should occur next.   Geophysical tools use  natural physical properties of the
 earth to  provide a "picture" of  subsurface conditions.  Geophysics can be used
 for  an  assessment  of  natural  hydrogeologic conditions,   an  assessment  of
 contaminants within the  natural system, and most inportantly, for the detection
 of buried wastes or unexplcded ordnance (UXD).

      A number of  surface  geophysical methods  are available,  including, ground
 penetrating radar (GJR), electromagnetics (EM), resistivity, seismic refraction,
 seismic  reflection,  gravity, and magnetometry.     Host successful   and  cost
 effective  for use  in characterizing construction  site conditions are  magnetic,
 electromagnetic,  and GSR techniques.   These  methods  offer  the benefit  of
 continuous measurements  along a  profile line,  thereby  providing  real  time
 results  which can  be interpreted  in  the  field.   Choice of the proper methods
 will be site  specific, and will require some knowledge of the geologic  and
 hydrogeologic conditions at the site and its vicinity.

     Final guidance on this subject will address the strengths and weaknesses of
 each available geophysical method, and will provide  direction for choosing the
proper method based on site conditions; however, for the purpose of this interim
guidance,  a  general overview of  the three most applicable methods will be
provided.

-------
       a.  GROUND FBOTRAriNG RADAR (GER)

       Ground penetrating radar uses high  frequency radio waves to .elicit  radar
  wave  reflections  from  interfaces  of  material  having  different  electrical
  properties.   This technique is highly effective for the evaluation  of  natural
  soil and rock conditions, and for the  delineation  of subsurface burial pits and
  trenches.   It can also be used for the location of  buried.pipes and  tanks.

       Depth of penetration for GJR  is  highly specific and  varies according to
  properties of the soil and rock.  Better overall penetration is achieved in dry,
  sand or rocky areas; poorer results are obtained in moist, clayey or conductive
  soils.   Penetration from one to 10 meters  is connon.

      Advantages offered by GTB are its  acquisition of continuous data,  providing
  highly  detailed  readouts, and the picture-like  quality of results.  Because of
  the  high  speed  of  data acquisition,  site coverage with  G?R is economically
  attractive.    As  with  all geophysical techniques,  experienced  personnel are
  required for the correct  interpretation of radar data.

      b.   zrzcnfcHAGNEncs (EM)

      Zlectrcnagnetics  (EM)  uses  low  frequency electromagnetic  induction to
 measure  electric  conductivity of  subsurface  soil,  rock,  and  grcundwater.
 Electrical conductivity is a function of the type of soil and rock, its porosity
 and permeability,  and the fluids which fill the pore spaces.  EM can be used for
 the  assessment of natural  geonydrolcgic  conditions, delineation  of  trench
 boundaries, buried wastes, and utility lines, and potentially for the mapping of
 contaminant plumes.

      Instruments and field procedures have been recently developed which make it
 possible to  obtain  continuous  EM profiling  data  to a  depth of 15  meters.
 Continuous  profiling  data can  provide  excellent lateral resolution  for  the
 mapping  of  even small electromagnetic anomalies.   EM works well in a  variety of
 geologic settings; however, surroundings with  a high percentage of  conducting
 fluids or high moisture content will provide the optima EM results.

     Advantages of EM  are again the  ability to provide  continuous profiling
results  of  high  resolution,  and  cost effectiveness  haseri on  the ease  and
quickness  of data  collection.   This techniques offers  a good  "second best"
alternative at sites where GPR is not viable based on geologic conditions.

-------
        C.

        A magnetometer measures the intensity of  the earth's magnetic field, and
   detects changes  in that field caused  by the presence of  ferrous *"*»*•* i <=   Tj-e
   magnetometer's response is proportional to the mass of the  ferrous target. This
   quality makes magnetometry very useful  for the detection  of buried drums and
   unexploded ordnance (UXO)  or ferrous utility conduits.

       Penetration  depths for the magnetometer vary  depending on the mass of the
  buried  ferrous object.   Detection of a single buried drum or UXO rarely exceeds
  10  feet.   Clearance  of the site  surface  of any  ferrous  metallic debris  is
  required  prior to  conducting  the  survey to  eliminate the potential for  its
  interference.   Eesults  may be adversely affected by  soils containing  higher
  percentages of ferrous minerals.  Natural changes in the  earth's magnetic field
  lost also be taken  into  account by the  field operating  crew.  Interpretation by
  experienced geophysical personnel is extremely important for data validation.

       Magnetometry should be used in conjunction with either GPR or EM to provide
  a ccnplete picture  of  the subsurface environment.   Specifically, it can alert
  trained personnel  to the possibility of  the existence of UXO,  a  common hazard at
  military installations.   Magnetonetry,  like G?R and EM,  has the advantage of
  providing continuous real time results,  which increases its applicability to
  construction site  clearance while  reducing cost.

      d.  GENERAL GEOPHYSICAL SURVEY GUIDANCE

      The  boundaries for  the geophysical  survey  should  entirely  encompass  the
 area proposed for construction, with a  20 to  30  foot  overlap on  all sides  to
 negate edge effects.  Areas proposed for the placement of underground  utility
 lines should  be included in the survey  as veil.   Survey lines should be spaced
 at 10  foot intervals with alternating geophysical methods run at each spacing.
 For' example, a magnetcnster  survey would, be conducted at even interval spacings
 of 0, 20, 40, etc., feet; while electromagnetics would be conducted at the
 odd intervals  of  10, 30,  50, etc.,  feet until the site  and its vicinity was
 covered.

      Use of an experienced  geophysical  contractor  is extremely important for
 obtaining valid results.   The installation Environmental Office may be of help
 in identifying reputable geophysical  firms  in  your area.

     Results 'can  usually  be  interpreted  at the construction  'site to  alert
personnel to areas  of interest.  Areas containing anomalous readings indicating
buried  metal   (possibly  UXO),  buried  utility   lines,   pits,   trenches,   or
contaminant plumes, should be marked on the site map.  At this point, a decision
may be made to abandon  the site  based  on these  results; or the  decision  to
further   investigate  the   anomalous   readings  nay  be  reached.    It  is  not
recommended  to propose construction  activities  at any site  that shows a past
usage for the burial of hazardous waste materials.

-------
        Metallic  debris,   indicated  by  the  geophysics,  should  be  carefully
   excavated by personnel  experienced at  the retrieval  of UXD.   The  Explosive
   Ordnance Disposal Uhit may provide guidance  for such  field activity.   After the
   clearance of metallic debris from the site,  the field investigation  may proceed
   to its second stage, placement of soil vapor extraction devices.

   2.  SOIL GAS SURVEY

       Soil gas sampling is used to detect volatile organic vapors which may be
  present in the pore spaces of  near surface or vadose  zone soils,  and which may
  be  released  during construction excavation.   If released  in quantity,  these
  vapors could be harmful to the health of on-site workers.

       Soil  gas  sanpling  techniques are  of  two  varieties.    Hie  passive or
  intacrative  technique utilizes a static trapping device implanted  in  the grcund
  for a  period from 7 to  30 days at depths up to 2 feet.  The sample collector
  consists of a ferromagnetic wire coated with an activated adsorbent encased in a
  glass  protective  tube.    Upon  retrieval,  the  device is transported  to  the
  laboratory where  it is analyzed by desorptive ***« SDectrosccpy.   While this
  technique allows for the  identification of a broad rawe of organic compounds,
  its application to construction  site clearance is limited by the relatively
  long period of time required for sample collection and analysis.

      Of mere use for site clearance  is the real-tine soil gas technique.  This
  technique can provide instantaneous results in the field  to allow the detection
  of potentially hazardous vapors.  A sampling device consisting of a hollow metal
  tube is  driven  into the  grcund to  depths up to 20 feet.  A vacuum  is then
  applied to the tube  and  a sample of the  soil gas is extracted via a syringe.
 This sample is then injected immediately into an on-site gas chronatograph (GC),
 usually truck-mounted,  equipped  with a flame ionization and photo  ionization
 detectors capable of identifying the compounds of interest. Results from the GC
 are instantaneous.

      Placement and  spacing of   the sampling devices are critical.    Areas
 identified  in the prior phases of the clearance investigation as having a high
 likelihood  for contamination,  such  as areas of  stressed  vegetation,  low areas
 where  contaminants  would accumulate,   areas  of  anomalous  electromagnetic
 readings, etc., should be  targeted  for soil gas investigation,  in the absence
 of  such  indications,  and to guide the  placement  of devices  In areas  not
 suspected.of contamination, the use  of a grid pattern should be employed.

      In areas  where the construction of the proposed project  will  require the
 excavation of soils, sampling devices should be located on 20 foot centers, or;
 one  probe should be placed In  every  400 square feet of area proposed for
 excavation.    Bus  applies as  well  to  areas proposed  for excavation for the
placement  of  underground  utilities.    For  areas  considered part  of the
construction site,  but  which  will not  be  excavated,  the coverage of  sampling
devices  can be reduced  to  probes on 50 foot  centers.   This, would require one
probe  for every 2,500 square feet  of area.   These guidelines can be used to
estimate the total required number of sampling points which can be placed on a
random grid, or targeted to areas of suspected contamination.

-------
      Use  of a  reputable soil gas  survey firm is important.   Personnel should
 have  knowledge  of  health and  safety  requirements  for  hazardous waste  site
 operations.   Hie  QTvironmental  Office at  the installation should provide  the
 names of reputable soil gas .finis in your area.

 3.  POST SURVEY 'GUHANCE
            on the results of the soil gas survey in conjunction with the results
 of the  geophysical  survey,  a  decision to  abandon the  site or proceed with
 construction will  be required.   USA2HW-JA,  with the help of medical personnel
 from AEHA,  will be  available to aid  in reviewing  and  interpreting survey
 results;  however, the decision to proceed or abandon a site will lie ultimately
 with the  installation Germander.

     If it is decided that construction can safely proceed at the site,  results
 of  the geophysical survey, any  clearance procedures performed,  and soil gas
 survey results should be provided in the design/construction documents.  This
will ensure  that proper protective equipment, if required, will be provided  to
en-site workers.  In some cases,  the services of an industrial hygienist nay  be
required curing excavation to assure proper personnel monitoring and protection.

-------
                     CLEARANCE OF CAIEGCRY HI SITES
      Category  in sites  have been  defined as those sites  currently known  or
 suspected  of having  been contaminated with hayardmis  substances by  past  or
 current  installation  operations.  This will include sites  in bombing ranges,
 landfills, burn sites, etc.  Proposals for construction at these sites are to  be
 avoided if at an feasible.

      Guidance  for clearance  of  a  Category HI  site  oust  be obtained  from
 USAIHAMA on a case-fay-case basis.  A fonnal request for such guidance from the
 major conmand will be required.   Investigation  and clearance of such sites nay
 require  extensive  field  surveys,  to  include,  geophysics,  soil sampling  and
 analysis, groundwater sanpling and analysis,  and the associated requirements for
 coordination with federal  and state environmental  agencies.   The  remediation of
 Category  III  sites prior to  construction  will  require compliance  with  all
 applicable federal and state environmental regulations.   Lead  times  for the
 completion of the preconstructien survey and remediation of a category ITT  site
and  its vicinity could easily encompass a nun-ber of years.   Investigations of
this sort would cost likely render the proposed project economically infeasible.

-------
           TBO4 IPAFT AR 415-15
      a.  All proposed sites will be evaluated for potential site
   contamination and categorized as  one of the following:

           (1)  Category I.  Tnis site  is  located in a traditional non-
   hazardous location, such as in an administrative,  recreation,  or housing
   area.  Ihe installation has no reason to suspect contamination.

           (2)   Category II.  Current and fanner industrial sites or other
   hazard-producing activity sites will fit into this category,   This site
   category consists of a perceived clean location, which, due to former
   industrial or other activities within or near the site, have the potential
   for contamination.  Site survey will  be accoiplished IAW OSAffiAMA
   guidance.  Assistance may be requested  from:  OR, USA Toxic and Hazardous
   Materials Agency, ATIN:  CETHA-1R, Aberdeen Proving Ground,  MD 21010-5401,
   ccrzercial phone, 301-671-3921/2828,  autovon  534-3921/2828.

          (3)  Category IH.  Sites located in areas currently known or
  suspected to be contaminated are included within this category.
  Ccntaninaticn will vary; i.e.,  known disposal site as identified  in
  previous studies; unexploded ordnance at former range,  etc.  Site survey
  will be accomplished IAW USAIKAMA guidance.

     b.    Actions required for evaluation,  mitigation, and verification of
  site contamination are  below.   The  statement  following each action will be
  inserted as a  separate  sub-paragraph in paragraph D9, Summary of
  environmental  consequences, in  the  DO  Form 1391 Processor,  to highlight
  this issue.

          (1)  Category I sites require  surface and records survey as shown
 below.  A physical inspection (walk of the site IAW USAIHAMA guidance)
 will be conducted for evidence of possible contamination and the results
 will be recorded in Detailed Justification Paragraph D9.  A  review of the
 following documents will be conducted and the findings recorded  in Block
 D9:                   .     '

              (a)   Aerial photography from the  Environmental Protection
 Agency, Environmental Photographic Interpretation Center  (EPIC) , P. O. Box
 1587,   Vint Kill Taxas Station,  Warrenton, VA  22186, ComprciaJ phone 703-
 349-8970, F1S 557-3110.
              (b)   Initial Installation Asyvmipnt and any updates
available prepared by USAIHAMA.

              (c)   Installation historical records.

              (d)   If a Category I site investigation discovers
contaminated conditions '(or the possibility thereof) the site will be
reclassified as Category II or III as appropriate and those procedure
followed.

-------
              (2)  Category n sites are to be reviewed by MAGOG/MSCs and
   installation safety and environmental offices to determine the nature of
   potential contamination.   Ciey will  be surveyed IAW USA2HAMA guidance,  site
   surveys determined  to be necessary will be performed prior to project
   design, and funded  with installation operating funds.  When investigation of
   a Category H site  reveals contamination  (other than minor limited
   contamination which will be cleared prior to design using installation
   operating funds)  the site will be reclassified as category HI and those
   procedures followed.  If the site remains a Category  H site,  add  the
   following statement to paragraph D9 of DO Fora 1391 — "The proposed
   construction site is a current/former industrial/test/other— (state what)
   site that is perceived to be clean and free of contamination.  Safety and
   environmental evaluations of the  site and available data do not show any
   need for  further  site surveys.'

             (3)  Category  HI sites are to be avoided if at all feasible.
  They also require a  survey  IAW USA1HAMA, guidance.  Clean-up should  be
  acconplished prior to construction using installation operating funds.  MCA
  funds may be prograinned  for clean-up as part of the total  project,  however,
  it is not encouraged due to funding constraints that will  adversely affect
  the project's competition for funding.  Add the following  statement to
  paragraph Dl of DO Form 1391 — *The proposed construction site is  a
  current/former industrial/test/other—(state what) site, with a potential
  for contamination.  Safety and environmental evaluations of the site and
  available  data indicated a detailed site survey was  advisable and such a
  survey has been accomplished.   Add one of the following:

            (a)  No  contamination was found and there  is no reason to believe
  contamination will be encountered  during construction;

            (b)  No  contamination was found but there is some potential that
  contamination may  be  encountered during construction.  Potential
  contamination is identified  to the designer in SPP 4 of the DO Form  1391 and
 must be reflected  in  construction contract documents. A separate line item
 providing for potential clean-up actions is included under  the primary
 facilities.  Detailed back-up environmental documentation is included in
 paragraphs 09, Summary of Environmental Consequences, and in SRP-4."

           (c)  All  contamination found has been cleared and there is no
 reason to expect further contamination will be encountered during
 construction or;

        •  (d)  All  contamination found has been cleared.  Additional
 contamination nay be encountered during construction  and a separate line
 item providing for  potential  clean-up actions is included in the primary
 facility.   Detailed back-up environmental documentation is included in
 paragraphs  D9, Summary of  Environmental Consequences, and in S5P-4."

     c.  Contracting officers will  insure that construction contracts
 include a clause specifying the category of the construction site, the
Government's analysis  of the  current site conditions and the contractual
responsibilities of all parties in the event of encounter with
contamination.

-------