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
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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.
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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
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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.
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. 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 :
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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-
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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-
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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'
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DBPBN8B OBNBBAL SUPPLY CBRTBB
PUBLIC MBBTXHG BBLLWOOD BLBMBKTABY SCHOOL
FEBRUARY 20, 1992
ADDRESS '
MAILING LIST
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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 373REPORTING 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
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ATTACHMENT B
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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.
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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.
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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
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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)
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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:
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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))
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INTERIM GUIDANCE
KR
SITE CLEARANCE
AT
U. S. ARMY INSTALLATIONS
PREPARED BY: DARRYL D. BORRELLT
U. S. ARMY
TOXIC AND HA2ARDOOS
MATERIALS AGENCY
(USMHRMA)
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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(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.
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