'.;, lit&d States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-92/142
March 1992
®EPA Superfund
Record of Decision:
U.S. Defense General Supply
Center (Operable Unit 5), VA
-------
.. '.,
. ~,
NOTICE'
The appendiceS listed in ~ index 1hat are not found in this document haVe been rernav8d at the request of
the issuing agency. They Contain material which supplement. but adds no further" applicable information to "
the content of the documenL All supplemen1al material is, howeVer, con1ained in the administratiVe recoro
for this site.
-------
50272-101
REPORT DOCUMENTA11ON It. REPOATNO.
PAGE EPA/ROD/R03-92/142
I ~
3. Rec:lpi8nt'8 --- ND.
4. 11IIe end SubtIle
SUPERFUND RECORD OF DECISION
U.S. Defense General ~ly Center
First Remedial Action - Interim
7. AuIhor(8)
s. A8port Ode
03/25/92
(Operable Unit 5), VA
6.
a. "-fonaIooQo._,'_~..Il~ND.
9. P8rfonIS,g o."..,1z8tI ft"-end ~
10. Prajec:n88li1Work UnIt NIL
11. Con1r8ct(C) or Gnnt(G) NIL
(C)
(G)
12. Spon8OI'tng OrpnIz8tlon N8me and Addr88
U.S. Environmental Protection Agency
401 M Street, S.W.
washington, D.C. 20460
13. Tn- of Report & PerIod Cowwwd
800/000
14.
15. Suppl__.....,.....
PB93-963901
16. Ab8Ir8c:t (\JIIIJt: 2DD-*)
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 light industrial and residential with
surrounding woodlands. Although the site lies above a shallow aquifer, most
residences in the area are served by a municipal drinking water system. From the
1940's to the 1970's, DGSC provided multiple support functions for the U.S. Armed
Forces and several federal civilian agencies. Operation areas consist of indoor and
outdoor material storage areas, a motor pool facility, a National Guard training area,
a fire fighting training area, and two acid neutralization pits. Studies conducted by
the Army in 1984 led to initiating site clean-up activities. Results of remedial
investigations revealed VOCs, other organics, and metal contamination in soil and
ground water samples at sites throughout the facility. As a result, remediation of
DGSC has been divided into eight operable units to address site contamination issues.
These include an open storage source area, National Guard source area, a fire training
source area, Area #50 source area, an acid neutralization pit source area, a fire
fighting training ground water area, an acid neutralization pit ground water area,
(See Attached Page)
17. ~A/ui1r8i8 & D ; ~6
Record of Decision - U.S. Defense General Supply Center (Operable Unit S), VA
First Remedial Action - Interim
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylene), other organics
(solvents, pe~ticides), metals (arsenic)
b. 1den8li8r8lOpen-Enc T-
. c. COSATI RelcVGraup
18. Availlblllty S18I8ID8It
19. SeaIrIt1 a.. (Thi8 RepoI1)
None
20. Securtty a.. (TNe P8g8)
"T........""
21. No. 01 P8g88
66
22. Price
(See AfS-Z39.18)
See~CIft~
272(4077)
(Fom8fJ NT1S45)
~ofCom-
-------
EPA/ROD/R03-92/142
u.s. Defense General supply Center (Operable Unit 5), VA
First Remediai Action - Interim
Abstract (continued)
and Area iSO/open storage area/National Guard ground water area. The acid neutralization
pit (ANP) area, located in the northern section of DGSC, was in operation from 1958 to
the early 1980s. During the time of operation, caustic and acid wastes were collected
from onsite metal-cleaning operations in large outdoor 14,000- and 3,OOO-gallon capacity
concrete-lined basins. Periodically, spent cleaning solutions were discharged to the
settling pits where they were neutralized and suspended solids were allowed to settle
out. The neutralized wastewater was then discharged offsite in either a sanitary or
storm sewer. Sludges were also disposed of off-site in a nearby landfill. In 1985, the
pits were closed and remedial actions began. After cleaning the pits and prior to
filling them with clean fill, cracks in the sides and bottom of the pits were observed,
indicating possible routes of contamination of the surrounding soil and ground water.
Ground water monitoring around the ANP revealed ground water contamination in the
uppermost aquifer. A previous ROD has addressed the mitigation of the open storage area
where institutional controls were applied to reduce exposure to the public. This ROD
addresses the interim remediation of contaminated soil surrounding the ANP as OUS. A
future ROD will address the remediation of ground water associated with the acid
neutralization pits. Other RODs will address remediation activities for the remaining
contamination areas at the site. The primary contaminants affecting the soil are vocs,
including PeE, TeE, benzene, toluene, and xylenes; other organics, including pesticides
and solvents; and arsenic.
The selected remedial action for this site includes installing a Soil Vapor Extraction
(SVE) system, including extraction and vent wells, a manifold system, a utility building,
and a vapor containment system; constructing covers over the pits to prevent their
further use and infiltrating of rainwater; continued operation and maintenance of the
vapor extraction system for approximately 4 years until tests indicate that contaminants
are no longer present at levels that threaten ground water; and ana.lytical sampling of
the soil at the end of the clean-up period to evaluate the effectiveness of contaminate
removal. The estimated present worth cost for this remedial action is $115,607, which
includes an annual O&M cost of $ 16,000 for 4 years.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific soil action levels are based on
health-based criteria and include MCSI established for arsenic S.7 mg/kg, benzene
0.001 mg/kg, PeE 1.S mg/kg, DeE .01S mg/kg, TeE 0.036 mg/kg, toluene 2,400 mg/kg, and
xylenes 24,000 mg/kg. Soil action levels will protect ground water at the site from
further contamination.
-------
RECORD OF DECISION.
FOR
OU5 . ACID NEUTRALIZATION PITS SOURCE AREA
DEFENSE GENERAL SUPPLY CENTER
RICHMOND, VIRGINIA
PREPARED FOA
J !leN'" 08pet" till' U.
.ttJafft~.a tra.ac~oPP8
ot 'b. opt 11na! . 0".
IUe. tll 'Ja18 ..t~.r.
~~..
.~.,o t. ~Otl..~ '3J /7;
DEFENSE LOGISTICS AGENCY
AND THE
-II
u.s. ARMY CORPS OF ENGINEERS
. HUNTSVillE DIVISION
PREPARED BY:
A LAW ENVIRONMENTAL
~
CONTRACT No. DACW87.90-D0023 .
JOB No. 11.1519
MARCH 1992
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LO
2.0
1519.39
TABLE OF CONTENTS
DEClARATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1.1
1.2
SI'IE N~ AN'D lOCATION. . . . . . . . . . . . . . . . . . . . . . . . .
STATEMENT OF BASIS AND PURPOSE. . . . . . . . . . . . . . . . .
1.3
.ASSESSMENT OF TIm SI'IE ..........................
1.4
DESCRIP110N OF TIm SELECTED REMEDY. . . . . . . . . . .
STATUTORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . .
1.5
DECISION S'UMltlAR.Y . . . . . . . . . . . . . . . -. . . . . . . . . . . . . . . . . . . . . .
2.1
2.2
SITE NAME, LOCA110N AND DESCRIP110N ... . . . . . . . . .
SITE HISTORY AND ENFORCEMENT ACI1VITIES .......
2.3
2.4
SUMMARY OF COMMUNITY PARTICIPATION..........
SCOPE AND ROLE OF OPERABLE UNIT ........'.......
2.S . SUMMARY OF SI'IE CHARACTERISTICS. . . . . . . . . . . . . . .
2.6
2.7
SUMMARY OF SI'IE RISKS ...........................
DESCRIFI10N OF AL1ERNA11VES ....................
2.7.1 Altemative 1 (Surface Containment/Capping) ..........
. 2.72 Altemative 4 (Excavation and Solid Phase Biotreatment) ..
2.7.3 Alternative 7 (Vacuum Vapor Extraction) . . . . . . . . . . . . . .
2.7.4 Altemative 8 (Institutional Controls) .................
2.7.s Altemative 9 (No Action Alternative. . . . . . . . . . . . . . . . .
2.8
COMPARA11VE ANALYSIS SUMMARY.................
2.8.1 0ve'f81l Pr'otectiOD ...............................
-i-
bp
1-1
1-1
1-1
1-1
1-2
1-3
2-1
2-1
2-5
2-7
2-8
2-8
2-15
2-20
2-21 .
2-21
2-23
2-T1
2-28
2-28
2-30
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TABLE OF CONTENTS
(Continued)
2.8.2 Compliau.ce 'With ARARs . . . . . . . . . . . . . . . . . . . . . . . . . .
2.8.3 Long. Term Effectiveness and Permanence. . . . . . . . . . . . .
2.8.4 Reduction of Mobility, Toxicity, and Volume. . . . . . . . . . .
2.8.5 Shon.term Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . .
2.8.6 Implementa.bility ....................... ~ . . . . . . . .
2.8.7 Cost....................... ~ . . . . . . . . . . . . . . . . . .
2.8.8 Sta.te Acc:eptaD.ce ................................
2.8.9 Com'm1.1nity AcceptaD.ee ................."...........
2.9
SEI..E\.;lC1J RE.MEDY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.9.1 ~t SIJmmA'Y ..................................
2.10 STAnrI'ORY DETERMINATIONS. . . . . . . . . . . . . . . . . . . . .
1519.39
2.10.1 Protective of Human Health and the Environment. . . . . .
2.10.2 Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) .. . . . . . . . . . . . . . . . . . . . . . .
2.10.3 . Cost Effectiveness. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2.10.4 Utilization of Permanent Solutions and
Alternative Treatment Technologies. . . . . . . . . . . . . . .
2.10.5 Preference for Treatment wbich Reduces
Toxicity, Mobility, or Volume. . . . . . . . . . . . . . . . . . . .
2.10.6 Documentation of Significant Changes .... ~ . . . . . . . . .
2.10.7 Responsiveness SUlf'me.ry .........................
..
-n.
.fw
2-31
2-33
2-33
2-34
2-34
2-35
2-36
2-36
2-36
2-37
2-39
2-39
2-W
2-40
2-40
2-41
2-41
2-41
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filum
2-1
2-2
2-3
2-4
2-5
Table
2-1
2-2
2-3
2-4
2-5
2-6
~19.39
UST OF FIGURES
.
DEFENSE GENERAL SUPPLY CENTER AND
S'UR,R,OUNDIN'G AR.EA . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
ACID NEUI'RALIZA TION PIT AREA ............ . . . . . . .
CONCENTRATION (UGfL) OF IclKACHLOROETHENE
IN' UPPER AQUIF'ER ...............................
CROS5-SECI10N VIEW OF VACUUM VAPOR EXTRACI10N
WEU.., ......................... ~ . . : . . . . . . . . . . ... . .
VACUUM VAPOR EXTRAcnON SYSTEM COMPONENT
I.A Yom. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
UST OF TABLES
CONSTITUENTS DETECI'ED IN SOn.S
.................
CONSTITUENTS DETECI'ED IN' GROUND WATER. . . . . . .
RISK-BASED son.. AC110N LEVELS ...................
son. ACI10N LEVELS FOR 1HE PR01ECI10N OF
. GRO"UN'D : WATER. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
..-
POTE.N11AL APPUCABLE OR REI.EV ANT AND
APPROPRIATE REQUIREMENTS (ARARs) . . . . . . . . . . . . .
cosr SUMMARY FOR SELECI'ED AL1ERNATIVE ....... .
-iii-
~
2-2
2-3.
2-10
2-24
2-25
.EIp
2-11
2-13
2-16
2-17
2-32
2-38
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1.0 DECLARATION
1.1 SITE NAME AND LOCATION
Acid Neutralization Pits (ANP) Source Area - Operable Unit 5
Defense General Supply Center: (DGSC)
Chesterfield County, V1rginia
L2 STATEMENT OF BASIS AND PTJRPOSE
1.2.0.1 'Ibis decision document presents the selected interim remediA1 aCtion for the
Acid Neutralization Pits (ANP) Source Area - Operable Unit 5 (OU5) ("the ANP site") at
the Defense General Supply Center (DGSC), in Ric:hmond, VugiDia, which was chosen in
accordance with the Comprehensive Environmental Response Compensation, and Liability
act (CERClA) 42 U.S.e. SS 960l,~JIiL, and to th~ extent practicable, the National Oil
and HazardoUs Substances Pollution Contingency Plan (NCP), 40 c.F.R. Part 300. This
decision is based on the admini~tive record for this site. This remedy was chosen by the
Defense Logistics Agency (DlA) in consultation with the United States Environmental
Protection Agency, Region m (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 at this site, if not
addressed by implementing the response action selected in this Record of Decision (ROD),
Diay present an imminent and substantial endangerment to public: health, welfare, or the
environment.
1519.39
1-1
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1.4
.
1.4.0.1 This operable unit is the fifth of eight operable units that are currently
planned for the site. Operable Unit 5 addresses the soils impacted by the Acid
Neutralization Pits (ANP). The other operable units, and the portions of the site that they
address are as follows:
.
OUI . Open Storage Area (OSA) Source Area
.
OU2 . Area 50 Source Area
.
OU3. National Guard Area Source Area
.
OU4 . Fire Tr-aining Source Area
.
OU6 . Area SO/Open Storage Area/National Guard Area Ground Water
.
OU7 . Fire Tl2ining Area Ground Water
.
. OU8. Add Neutralization Pits Ground Water
L4.o.2 This action addresses the. contaminated soils at the ANP site by treating the
soils in place ut11i7-i"l vacuum extraction. After treatment is complete, no further
remediation for soils at the ANP site will be necessary. Operable Unit 8 will address the
remediation of ground water at the ANP site.
lA.O.3
The major components of the selected remedy include:
.
Installation of a vapor extraction system, including extraction and vent wells,
a manifold system, a utility building, and a vapor containment system;
1-2
1519.39
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-, -
.
CoDStruCtion of covers over the pits to prevent their further use and the
iDfiltration of rainwater,
.
Continued operation and maintenance of the vapor extraction system for
appr~mAtely four (4) years until tests indicate the COntAminAnts are no
longer present at levels that threaten ground water, and
.
Analytical sampling of the affected media (soil) at the end of the clean-up
period to evaluate the effectiveness of contAminAnt removal.
1.5
u.o.l The selected remedy is protective of human health and the eDYironment,
complies with Federal and State requirements that are legally applicable or relevant and
appropriate to the remMiAI adiou, and is cost-effective. 'Ibis remedy utilizes permanent
solutions and alternative treatment (or resource recovery) tedmologiesto the mnimnm
extent practicable and satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element. IJe(ause this remedy will
DOt result in hazardous substaDceS remAini"l on-site above health-based leve~ the five-year
review wiD DOt apply to this actiOlL
~/9z
CoI James B. Je UDited States Army
De Lopd A--
cs ~--I .
Staff Director, Office of IDstaJIation Services and
EnviroDmeDIal ProtedioD
..~~£?~
Edwin B. Erickson
Regicmal Administrator
U.s. Environmental Protection Agency. Region m
~ 11~ l'1/
itfr-
.'
1519.39
1-3
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2.0 DECISION SUMMARY
2.1 SITE NAME. LOCA110N AND DESCJUPI'ION
Acid Neutralization Pits (ANP) Source Area. Operable Unit 5
Defense General Supply Center (DOSC)
Chesterfield County, VugiDia
2.1.0.1 The DOSe is located in Chesterfield County, Virginia, appr~mAtely 11 miles
south of the city of Richmond, VugiDia. The ANP area is located in the northern section
of DOSe at the end of warehouse 6S (Figure 2-1). 'Ibis area is the site of two former
concrete settling tanks which received wastewater from metal cl~n;ng operations conducted
at warehouse 65. The two tanks were located in a fenced area appro~mAtely twenty-five
(25) feet northwest of the warehouse. The primary pit bad a capacity of 14,600 gallons; the
secondary pit bad a capacity of 3,000 gallons. The primary and secondary pits were e~
appro~mAtely 6.5 feet in depth. Both pits, and their location relative to warehouse 65, are
shown in rJgUre 2-2.
2.LCU . The facility was originally constructed in 1941 as two separate facilities: the
Richmond General Depo~ and Richmond Holding and Reconsipment Point. In 1962 the
installation became known as the OOse.
2.LO.3 The Defense Logistics Agency (DlA), an agency of the Department of
Defense (OOD), provides logistics suppon to the military services including procUrement
and supply support, contract adm;n;~tration and other services. Since 1942, DOSC's mission
has been the mSln~ng and furnish;"g of milltal)' genefal supplies to the Armed Forces and
several Federal Civilian Agencies. Today DOSC mAftS\ges more than 300,000 general supply
items at a fadlity encompassi'1g 640 acres. DGSe has more than 16 million square feet ,of
covered storage space in Zllarge brick warehouses and a million square feet of office space.
1519.39
2-1
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RGURE 2-1
DEFENSE GENERAL SUPPLY CENTER
AND SURROUNDING AREA
RICHMOND, VIRGINIA
BOUNDARIES
AGIO
NEUTRALIZATION
SEABOARD
COASTLINE
SCALE IN MILES
S LAW ENVIRONMENTAL, INC.
J GOVERNMENT SERVICES BRANCH
1519.39
2-2
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FIGURE 2-2
ACID NEUTRALIZATION PIT AREA
DGSC
RICHMOND, VIRGINIA
ACID
tNEUTRALOATON
60
100
SCALE M FEET
_ -LAW ENVIRONMENTAL, INC.
f* J GOVERNMENT SERVICES DIVISION
1519.39
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2.LOA Land use in Chesterfield County. in the vicinity of DGSC is primarily single
.
family residentia], intermixed with retail stores and light industry. Th~ DOSC is the major
indusuy in the area. The area to the northeast and east of DGSC has been developed as
both single family and multi-family housing. Bensley Village, a major subdivision of
Richmond, is located northeast of the ANP site in the area considered to be downgradient
of the upper aquifer flow at 005C. There are apprMim~tely 600 houses, 60 multi-family
apartment buildings, and 30 mobile homes located downgradient and within one mile of the
ANP area. The on-base population at DOSC includes 119 permanent resident and 3,682
employees. The estimated number of people living within one nUle downgradient of the
ANP area is 4,100. The total population living within a one mile radius of the site is
estimated to be 14,400.
2.LG.5 The DOSC is located within the modified continental climatic zone, an area
characterized by extreme variations in temperature and precipitation during the course of
a year. 'JYpicaJly, the area experiences warm summers, relatively mild winters and normally
adequate rainfsll1 ne 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.
Wmd direction in the vicinity of DOSC is variable most of the time although the prevailing
wind direction is southerly.
2.LO.' The land surface at DGSC has been extensively altered by grading and filling
operations. Generally, the topography is essentially flat with a slight slope. towards the
northeast. The ~mml1m difference in the local topographic relief is app1Wim~tely 30 feet.
Elevations range from 135 feet above mean sea level (msl) at the southwest comer of the
facility to 108 feet above ms1 near the northeastern portion. Surface drainage in the ANP
area is generally to the southwest towards a storm sewer system that drains south and to the
east and disch,"Ies to an l1nn~med creek along the eastem boundary of the facility.
2.LO.7 The unconsolidated soils below the DOSC have been divided into four
formations by the U.s. Geological Swvey. The Eastover Formation is present immediately
below the land surface and consists of up to 25 feet of interlayered beds of sand, silt, and
1519.39
2-4
-------
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. Tbe Potomac Formation, which underlies the Aquia Formation,
extends to the bedrock. The Potomac consists of approximately 40 feet of interbedded sand
and gravel with occasioual sn~ and clayey seams. Bedrock in the region consists of the
Petersburg Granite.
2.1.o.s SoDs and geologic conditions at the ANP site 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 CODtAminAtion origiDating from
the ANPs. Vertical migration of conmminants from the Upper Aquifer would be iDhibited
by the uDderIyiDg Calvert and Aquia Formations. These two formations, which have lower
pemieabilities than the overlying and underlying formations, are refemd to as the Confinittg
Unit.
2.LU . Ground.water flow in the Upper Aquifer is generally 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, discbarge or precipitation.
2.2 SITE HISTORY AND ENFORCEMENT AC'I'IVITIES
.. 1.2.0.1 The ANPs received wasteWater from metal deAning operations conducted at
warehouse 65. The metal cl~ni'1g operations in warehouse 6S included cleAnittg (paint and
~ removal) and repainting steel combat helmets and compressed gas c:y1inders. These
1519.39
2-5
"Y
-------
activities- were in operation from 1958 to the early 1980's. The metal cleaning system
consisted of a boiling caustic bath of sodium hydroxide (NaOH) to rem~e the paint,
fonowed by a hot water ~ dip to remove residual caustic solution :and paint resid~es.
The items were then immersed in a twenty percent hydrochloric acid (HC) solution to .
remove rust and treated with a neutralization solution consisting of sodium hydroxide,
surfac:tant and sodium bicarbonate.
1.2.0.2 The spent cl~ning solutions were discharged to the settliilg pits every one to
two months. The intervals varied depending on frequency and duration of use. In the
settling pits, the solids separated and collected in the bottom of the pits as sludge. The pH
of the wasteWater was adjusted by manual addition of time prior to itS discharge. From 1958
to the late 1970'5 wastewater was discharged from the primary pit to the storm sewer. With
the addition of the secondary pit in the late 1970's, wastewater discharge was connected to
the sanitary sewer.
2.2.0.3 While the pits were in operation, sludges were periodically removed and
disposed of at the Chesterfield County Landfill. The U.s. Army Environmental Hygiene
Agency aDaIyzed leachate from the sludge in 1979 using the TOxic Extraction Procedure (EP
Tax) method. Based on the analysis of the EP Tax results, the sludges were not
characterized as hazardous waste. The pits were closed in 1985. The remAini1'8g sludges
were removed for off-site disposal, the bottoms of the pits were washed dean of residual
sludges. and the pits were filled with dean soil. During the dosure activities. the concrete
sides and bottoms of the pits were observed to be broken and cracked. These cracks and
holes may have served as migration routes for contaminants in the pits to the surrounding
soils.
2.2.0.4 In 1984, the DOSC was recommended for placement on the CERCLA
National Priority List (NPL), and was promulgated to the NPL in 1987. This action was a
result of a Hazard Ranlnng System (HRS) scoring performed for the DOSe that was based
on the conclusions of preYious studies done at the site by the United States Army
Environmental Hygiene Agency (USAEHA). The DOSC received a hazardous fSlnlnng
1519.39
2-6
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score of 33.35, with 28.5 being the minimum necessary to be promulgated to the NPL. In
August 1986, the EP A issued a Corrective Action Permit to DGSC pursuant to the "Resource
Conservation and Recovery Act (RCRA), 42 U.S.e. 55 6901 ~aQ.. As part of RCRA
activities conducted at the site, Dames and Moore, a contractor of 005C, submitted three
Remedial Investigation Reports pert~ining to sites investigated. at DOSC in 1989. In
September 1990, the DLA, OOse, EPA, and the Commonwealth of VIrginia entered into
a CERCLA Interagency Agreement (lAO) pursuant to Section 120 of CERCLA, 42 U.S.c.
5 9620, which guides remediation activities.
2.3 SUMMARY OF COMMUNI'IY PARTICIPATION
2.3.0.1 On Febnwy 23, 1984, the DOSC orpn17ed an Interagency Task Force
comprised of State regulatory agencies, U.S. Environmental Protection Agency (EPA),
County agencies, VIrginia National Guard, Rayon Park Representatives, and DOSC
personneL 1be purpose of this group was to ensure that actions carried out at the site were"
done with input and review from the affected parties. This group was actiVe in the mid
198Os, but beMlme less active after county water supply lines were installed to service
residents located near the DOSC east boundary.
2.3.0.2 The proposed plan for Operable Unit 5 . Acid Neutr:l-1i7-,tion Pits was released
to the public on January 20, 1992. 'Ibis document was made available to the public in the
admini~tive record mAinmined at the Chesterfield Public Library at the Ch~rfield
County Courthouse in Chesterfield, VqiDia. The notice of availability for this document
was published in the Ri~1nnftnd TUDe Dispatch on Jamwy 20, 1992. The public comment
period was held from. January 20 through March 6, 1992. In addition, a public meeting was
held on February 20, 1992. At this meeting, representatives from the DLA, EP A, and
Commonwealth of VIrginia 8DSWer:ed questions conceming the remedial alternatives
evaluated for this site. A response to the comments received during this period is included
in the Responsiveness SummAry, which is part of this Record of Decision. 'Ibis decision
dnl"l1ment presmts the selected interim remedial action for Operable Unit FIVe (OU5) .
1519.39
2-7
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I' --- - - - .-
Acid Neutralization Pits source area at the DOSe in Chesterfield County, Virginia, chosen
in accordance with CERCLA, as amended by SARA and, to the extent practical, the
National Contingency Plan.
2.4 SCOPE AND ROLE OF OPERABLE..1lliII
2.4.0.1 As with many Superfund sites, the problems at DOSC. are complex. As a
result, the work at the site has been Olpni7'-ed into eight operable units. These are:
OU One:
OU Two:
OU Three:
OU Four:
OU rIVe:
OU Six:
OU Seven:
OU Eight:
Open Storage Area Source Area
Area SO Source Area
National Guard Area Source Area
Fire TrsaimngSource Area
Acid Neutrsa1i7j!ltion Pits Source Area
Area SO/Open Storage AreajNational Guard Area Ground Water.
rU'e Trsaininl Area Ground Water
Acid Neutralization Pits Ground'Water
2.4.G.2 The scope of this action addresses the fifth operable unit (OUS) at the site,
the Add N~utralization Pits (ANP) source area. There are no principal threats for OUS.
The ~ of this interim response action is to remove CODunmnants of a:mcem from the
soDs to prevent current or future lea,.1'IinB of conta.minSints from the soDs into the ground
water. GrOUDd water at the site is addressed as part of a separate Operable Unit (OU8).
2.5 SUMMARY 0" SITE CHARACTERISTICS
2.5.0.1 Several sampling and analysis programs have been performed ~ the ANP area
in order to evaluate the m2gJ1itude and extent of cont"mination. The locations of the soil
and ground-water samples were selected to identify sources of conmminsants, potential
1519.39
2-8
-------
1-
pathways of contAminant migration as well as the magJ1itude and extent of contamination.
A total of six son samples an~ 15 ground-water samples were collec:ted !o.r chemical analysis
during the period from November 1986 to November 1988. Figure 2-3 shows sample
locations at the ANP area. In addition, additional sampling will be conducted in the ANP
area in conjunction with OU8, Acid Neutralization Pits Ground Water.
2.5.0.2 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 (TeL) and Target
Analyte List (TAL) constituents. The complete analytical results are presented in the Draft
Remedial Investigation Report, Acid Neutralization Pit Area - Dames & Moore, Bethesda,
MD (4/27/89).
2.5.0.3 Samples from the soil borings in the pits had the greatest number of
. .,
constituents present. The constituents detected were primarily low levels of volatile organics
and semi-volatiles inc:ludiDg phthalates, naphthalene and phenanthrene. In addition, one
soil sample taken from a depth of fifteen feet had arsenic present at a conc:enttation higher
than the local background levels.
2.5.0.4 The primary constituents of concern detected in the ground water samples
were volatile organic compounds (V0Cs). The predomin3nt VOCs detected in the ground
water were tetrachloroethylene and trichloroethylene (detected in 10 out of 14 samples).
Other VOCs which were detected in more than one sample inc:luded acetone, methylene
chloride, l,2-dichloroethylene, and 1,2-dic:h1oroethane. Table 2-2 provides a snmmary of
constituents detected in the ground water at this site. rlgUI'e 2-3 shows the ground water
plume in the Upper Aquifer using tetrachloroethylene as the marker constituent.
2.5.0.5 As there are no promulgated chemical-specific ARARs for constituents in
soils, risk-based soil action levels were derived for the constituents of concern
(tetrachloroethylene and trichloroethylene) at the ANP site. The risk-based levels were
developed to be protective of workers at the facility, who may be exposed to contaminated
1519.39
2-9
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RGURE 2-3
CONCENTRATION (UG/L) OF TETRACHLOROETHENE IN UPPER AQUIFER
(BASED ON NOVEMBER 1988 SAMPLING RESULTS)
ANP AREA, DGSC
RICHMOND, VIRGIN
CONCENTRATION
MFERRED
100
BORING
MONITORING WELL
- PIEZOMETER
— mm PLUME CONTOUR
lOppb CONCENTRATION OF
TETRACHLOROETHENE
= LAW ENVIRONMENTAL, INC.
~ GOVERNMENT SERVICES DIVISION
1519.39
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"-
to
. ".
ne.1eaI
IU
I
-
-
An88k
.....
~..
1,2-Diddoroef".-
Tclr8dllorocdarlcae
ToIUCDO
Tridalaroc:daJlcae
XJIcao
Bia(1-cdaJ1baJ1)
,.....~...,
~
t>DidIIarah...
....,.,...,..."
~"....o
2-~"-"."~
-- Below Oded- Uad8a
1519.39 .
TABLE 2-1
CONS'ITI'UENTS DBTI!CTI!D IN SOILS
Add No8InIada8 ... Sa8rco Ala
OpcnIIIeUIIiI5
o.aenda8 .. SoUI...,..
DOSC DMS-8J DMHI DMW-2M DMW-JAA DMW-JM DMW-3tA
.....
1.z.7J.O 5.9 7.7 1.3 81 0.71 o.za
0.001 -
08
0.015
1.5 08 . -
0Am
0.0:J6
0.00:1 . -
O.U 0.81 0.G69 0.048
03A
0.14 .
0.11 -- 0
0.41
0.58
-------
t.)
I
.....
~
TABL&Z-1
. (~;'uc4)
OONS'l1'l1JENrS DI!TECI'ED IN SOILS
AdcI NcII8nIiu8ia8 Pia Saurce Ana
Opel'" U.. S
..~
u.r.w
DOSC
....
"~-~""Il.IU
.....~ .
~
Pyrcac
DMS-m
0.11
0...
o.m
CGMeII8r.... .. SoiI8. ~
DMS-81 DMW-DA DMW-Z4A
DMW-3QA
DMW-31A
0.064
- Below Dclcdioa UmiII
1519.39
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TABLE 2.2
CONSTITUENTS DETECTED IN GROUND WATEJt
Acid NeutraJizatioD Pit
Operable Unit 5
CbeIP~ Deccctioa Raage of Detected Loeatioa of Higbest
frequcacy . CoDCCauuioas CoaceauatioD
(milL)
..hllllnm- 10/14 0.03.S-0.16 DMW-23A
Anaic 4/14 0.Q0200.Q04 DMW-24A
Bariaaa 14/14 0.024-0.12 DMW-31A
C.~ 14/14 0.73-3.0 DMW-3QA
Cobalt 7/14 0.004-0.013 DMW-23A
C4ppcr 3/14 0.002.0.012 DMW-31A
Iraa 12/14 0.007.0.48 . DMW.23A
Lad 3/14 0 002-0 005 DMW.23A
~'IIM ,;u... 14/14 0.16-L4 DMW-31A
~"~T 14/14 0.Q20.0.84 DMW-23A
MercaIy 1/14 o.ooD2 DMW.23A
N"1CbI 1/14 om DMW.3OA
Jt
-------
TABLE 2-2 (continued)
CONSTITUENTS DETECTED IN GROUND WATER
Acid Neutralization Pit
Operable Unit S
CbemiCII
Detec:tioa
Frequency
T~
ToIaeao
TricbIaroedayIea
1.2-DicbIan1bcliftae
10/14
1114
10/14
1/14
1/14
2/14
Ilaage of Dececwt
ConceauaUou
. (milL)
0.QOS.3.7
0.24
0.Q07.L4
0.002
0.002
O.Q02.o.GQ3 8
Lca&iOD of Higbcst
Conc:emradoa .
l.4-DicbIarobeDzeDc
8i1(2.cday11aayphtlr.lato
DMW.3OA
DMW.24A
DMW.24A
DMW.24A
DMW.24A
DMW.24A
8
ec.dtueaI wu detecled ill the metbod blanks ,.soc;ated with samples from this site..
c:aaceDInIioas iD samples are suspected to be the result of laboratory CODtalDi".. .
-
0,.. -atradoaa exceed MCLs (01 some samples.
1519.39
2-14
-------
soils, via incidental ingestion, dermal contact and itWalation of fugi~ dusts. The ris~.based
soil action levels are presented in Table 2-3. The only constituent detected in soils in excess
of the risk.based soil action level was arsenic at a depth of 15 feet below the ground surface.
2.5.0.6 The soils are the apparent source of VOCs in the ground water at the ANP
area. Low levels of VOCs, including tetrachloroethylene and trichloroethylene, were
detected in the soil boring from the secondary settling tank at the site. Although VOCs
were not known to have been used in the metal clesaning operations in warehouse 65, the
ANPs were not covered during the time they were in operation and therefore could have
been used for undocumented disposal of chemicals and solvents used in a variety of
industrial operations at OOse.
2.5.0.7 Risk.based soD action levels for protection of ground water were also
calculated in the Focused Feasibility Report for OUS . Acid Neutralization Pits Source
Area, Law Environmental, ICennesaw, Georgia, November, 1991. The action levels are
shown in Table 2-4. As may be seen, only tetrachloroethylene exceeded its risk.based soil
action leveL
2.6 SUMMARY OF SITE RISKS
2.6.0.1 A baseline risk assessment was conducted for the ANP area as documented
in the Remedial Imestiption Report for OUS . Acid Neutr:lli7jluon Pits Area, Dames &
Moore, Bethesda, MaIyIaDd, April Xl, 1989. When this repon was being prepared, the ANP .
Area had DOt been broken into two separate operable units -(of eight total operable units
now present at the site). The purpose of the baseline risk8SSeSSl"-nt was to evaluate the
potential human health and eDYironmental risks posed by soD and ground water
COn~minAtiOn detected at the ANP area. The results of the baseline risk ~C1ftent as they
pertain to the ANP Source Area (i&., contaminAted soils) are summarized briefly below.
1519.39
2-15
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TABLE 2.3
DG-SC PO 1'.1
"~iid!
A' ~ttt:.
. RlSK.BASED SOn. AcrtON LEVELS
Acid Neutralization Pit Source Area
Operable Unit 5
C1n~lIIicaI
Risk.Based
DetectioD Soil Ac:bon
frequeac:y Level (mg/kg)
5/6 5.7
1/6 0.001 360
1/6 0.Q03 1.700
1/6 0.015 110
2/6 U 200
1/6 0.Q02 2.400
1/6 0.036 16,000
1/6 0.003 24,(D)
4/6 0.81 740
1/6 0.24 1200
1/6 0.14 1100
1/6 0.12 9'700
1/6 0.41 240
1/6 0.58 600
1/6 o.U 480
1/6 o.U 48
1/6 0.Q'73 as
1/6 0.Q6i6 11
Anaic
~1IY8~
Cabolorm
1.2.DicbIoroedwIe
Tdr8dIIoredayIeD
TaIaeDo
TricIdarocdIyIeD
Xyleae
B~phth.'.te
Di-b4;t1 phtlHa'.te
1.2-DidalarcJbeIlZlIUl
DiedIJI phth.I.M
Di . DCIJI pht..I....-
2-~
4-~
N.,....""
PIIeaadIreDe
Pyrae
. 0alJ C88 ..... ~~;-.d ~ It c:oaceauuions greater thu the Ac:cioD LeYeL .
m ~~.. =---- """118 c:oDCeDtraboD which exceea the Aaiaa LeYeL
1519'»
2-16
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[ .
N
,
....
...a
lS1~ "'..
TABLE 2-4
SOIL ACI10N LEVELS FOR mE PROTECI10N OF GROUND WATER
Add NcuanlizatiOD Pit Sourec Area
Operable Uail S
Chemical
Deteclioa Muimum MCL'I Oaemieal- CaIcuIaIed Calculated SoU
PrequeDq CoaccDtrIlioa (maIL) Specific "-a Value Amc. Level(b)
(mslka> K..: Value (ms/ka)
1/6 0.015 o.oos 14 0.. O.on
0/6 NA om 59 0.34 1.3
'1./6 II o.oos 364 '1..1 0.58
1/6 0.036 0.005 126 o.n 0.20
I,'l-DicbIor"'.~
I,'l-DichIoroetbJIeao
TetracbbOC8hyleao
Triddorocahyleae
m
(a)
(b)
Shaded area iDclicatca muimum aJIICCDtrIlioa wbida eJaeCla calculated SoU ActioD Level.
K.. . K..: . (OM/1.'71A)/1001
Assumes orpoic carboD CODtcot o.f IIOiI is 1 perceot
Soil ActioD Level ... MCL . rc.. . DP
DUUtiOD Fador (DF) estimated to be S5 based OD Summcr's EquatiOD.
-------
.., '
2.6.0.% 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
Tnhsa1~tion of vapors and dusts
Ingestion and dermal contact with surface water'
Ingestion of crops and other plants
.
.
.
.
2.6.G.3 Each of these pathways were evaluated for both on-site and off-site receptors,
under both current and future conditions. A complete exposure pathway includes a source,
release mechsani~1TIJ environmental transport route, receptor, and exposure route. Of the
forty-four (44) exposure pathways considered in the baseline risk as,seccment, only Dine were
considered to be complete.
2.6.0A There were no current exposure pathways considered to be complete at this
site due to the depth at which contaminAtiOn has been' found (greater than S feet in depth).
Therefore, direct contact with the soils is DOt possible unless they are disturbed by intrusive
activities (i&. excavation. drilJing).
2.6.0.5
The potential future son exposure pathways which were considered to be
. .
complete are summarized below: .
1519.39
.
Future inhSl1etion of dust and dermal contact with soils during excavation
activities by on-site workers .
.
,
Future inhaJation of dust, ingestion of soil and dermal contact with soils from
excavation activities by off-site residents, due to dust from the excavation
activities blowing offsite.
2-18
-------
2.6.0.6 Excess lifetime cancer risks are determined by multiplying the intake level with
the canc:er. potency factor. These risks are probabilities that are generally expressed in
scientific notation (w.l x 1~ or lE-6). An excess lifetime cancer rfst:of 1 x 1~ indicates
that, as a plausible upper bound, an individual has a one in one million additional chance
of developing cancer as a result of site-related exposure to a carcinogen over a 7o.year .
lifetime under the specific exposure conditions at a site.
2.6.0.7 The potential carcinogenic risks from future on-site exposure to soils were
calculated to be 2 x 10"'. 'Ibis falls within the standard risk range EP A uses for evaluating
carcinogenic risks which is 1 x 10-- to 1 x 1~. The elevated concentration of anonic
detected in one soil boring sample comprises 99 percent of the total estimated risk at the
site. It should be noted that this sample was collected at a depth of appro:rimately 15 feet.
It is 11n1i1r~ly that on-site workers would be exposed to constituents at this depth during
excavation activities.
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 CODfjlminant's
reference dose). By adding the HQs for all contaminants within a medium or across all
media to which a given population may reasonably be exposed, the Hazard Index (HI) can
be generated. The HI provides a useful reference point for gaugj'1g the potential
dgrtificance of multiple contAminAnt exposures within a siDgle medium or across media.
2.U.9 The potential non-carcinogenic hazard index from future on-site exposure to
soils via the inhA1A~mi of fugitive dusts was calculated to be 6 x 10"13. This value is far
below the threshold value of 1.0 which represents a potentially 11nAcceptable risk to human
health from systemic toIicants. .
2.6.0.10 If excavation activities were to take place at the ANP site, current carcinogenic
and noncarcinogenic risks would be equal to those calculated for future activities assuminB
the same exposure pathways.
1519.39
2-19
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2.6.0.11 The potential risks involved from ground water at the ~te are addressed in a
separate operable unit for ground water at the DGSC.
2.6.0.12
ANP site.
No critical habitats or endangered species were identified in the vicinity of the
2.6.0.13 Ac:tual 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 end~n'8erment to public health, welfare, or the environment.
2.7
2.7.0.1 CERClA requires that each selected site 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 msaYimum extent practicable, and be c:ost effective.
2.7.0.2 During the Focused Feasibility studies (Focused Feasibility Report for OUS'.
Acid Neutralization Pits Source Area, Law Environmental, Kennesaw, Georgia, 1991) for
the ANP site, nine remedial action alternatives were initially identified. As a result of
screening process, five out of Dine remedial action alternatives were selected for detailed
analysis. These five altematives are described in the following paragraphs. For easy
reference, the same alternative numbers as in the Fe8SlbiJity Study Report are assigned to .
these altematives. The five alternatives' are as follows: .
.
Alternative 1 (Surface Containment/Capping)
Alternative 4 (Excavation and Solid Phase Biotreatment)
Alternative 7 (Vacuum Vapor Extraction)
Alternative 5 (Institutional Controls)
Alternative 9 (No Action)
.
.
.
.
1519.39
2-20
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2.7.1
Estimated Capital Cost S 33,165
Estimated ~nnllal O&M Cost: S 800
Estimated Present Worth Cost: S 43,135
Estimated Tune to Implement: 1 to 3 months
%.7.Ll 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-flooded non-woven
geotextile fabric sandwiched between the asphalt layers. Cap surface area would be
approximately 6,750 sq. ft. Construction of concrete or gravel lined perimeter drains should
not be necessary since a storm drainage system exists and transects the site. Sloping of the
cap towards the sides or towards the street to the east and using simple curbs to direct flow
in that direction should be sufficient in handling storm water runoff. If this is determined
not to be the case, one or more storm grates and coUection/disebarge structures could be
installed and connected to the storm sewer line that traDSects the site. The site soils are
generally of sufficient quality such that settlement under the cap should not be a problem.
2.7.2 Altern.the 4 ~tlOD .n4..Salld.Phase BlotreatmeDt)
Estimated Capital Cost. S 194,208
EstimAted AnmJ-.J O&M Cost: S 0
EstimAted Present Worth Cost: S 194,208
EstimAted TUDe to Implement: 3 to 6 months
2.7.%.1 The use of excavation and ex-situ solid phase biotreatment bas been found to
be very effective in ~cing the mass of most organic conmmlnants in contaminated soils.
1519.39
2-21
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2.7.2.1, . . Surface preparation prior to excavation should
be limited to obstacle removaL The site will need to be segregated into zones and staging
areas prior to mobilization or construction of the treatment equipin~nt.' Site zones will
include the ezcIusion zone, suppon zone, and decontsamination zone as wen 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. The
general work area including all zones and staging areas will be fenced to delineate
boundaries and prevent uncontrolled access.
2.7.%.3 ~ent Tes~ Testing of equipment will 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 oD-site
performance of the equipment.
2.7.2.4 .EIsiIDtim1: Excavation will be accomplished using either a front-end loader
or a backhoe. Either a sloped or shored excavation could be used based on safety and
adjacent structures ~nsiderations. Vertical excavation utl1i'1ing soldier-pile and lagging
construction would minimi7.e the amount of spoil generated which would potentially require
treatment along with the contaminated soil For this reason, vertical-walled excavation was
found to be approximately 16% less expensive to implement than traditional sloped-walled
excavation. : The excavation would be coordinated with removal of the pits themselves. .It
is assumed that the concrete from the tanks is contAmina,ted and will be demolished, crushed
and treated along with the CO!ltAmina.ted soil. Reinforcing steel would be scrapped and
decontaminated.
.
2.7.2.5 ]'resatment Particle ~ separation may be necessary to screen out large
particles from the son prior to feeding into the treatment unit. Tr~.atment generally consists
of miYi"l the COntAmin'ted soil with a mixture of nutrients and surfactants. Water may also
be added to increase the soil moisture content. After miYin& the soil is stored in small piles
open to air on lined stAging areas where it is allowed to cure. During curing, the indigenous
soil microbes metabolize the organics present, aided by the surfactant/nutrient mixture, and
aeration induced by mixing.
1519.39
2-22
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2.7.2.6 ~ Excavation of the pits themselves would allow further
QA..mftAtion aDd testing of the underlying soils. Depending on the ~ location and extent
of cracks in the concrete, soil contamination may be localized to certain areas under the
tank. Additional testing would allow a more complete evaluation of the extent of
contamination than is currently available. The testing would allow a focusing of the
excavation effort and a better evaluation of contaminated soil quantities. Air monitoring
would be necessary at the ANP Area if the contaminant quantity is found to be much higher
than presently estimated
2.7.2.7 Oosure: After the soil has been treated and re-emp1aced into the excavation,
no special security or site restrictions will need to be constructed or enforced
2.7.3 Altematl.D..LLVaeuum Vapor Extraction)
Estimated Capital Cost: S S8,872
Estimated Aftfttl~" O&M Cost: S 16,000
Estimated Present Worth Cost: S 115,607
EstimAted Tune to Implement: 3 to 6 months
Estimated Years to Remediate: 4 years
2.7.3.1 VaCP11m extraction of Soil gas bas been shown to be effective at reducing the
mass of volatile orgauic constituents in soils. Various system COnfiguratiODS are potentially
applicable. However, the vertical extrad:ion system described is considered appropriate for
this site (F1pM 2-4 & 2-5).
2.7.3.Z . . Surface preparation prior to weD installation
is DOt necessary. A small drill rig will be mobilized for weD and vent instal1ation.
1519.39
2-23
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FIGURE 2-4
CROSS-SECTION VIEW OF VACUUM VAPOR EXTRACTION WELL
DGSC
RICHMOND, VA
VENT
TO
BLOWER
ASSEIIBL Y
.J
--
--
--
--
--
== ~
r "
~
LAW ENVIRONMENTAL, INC.
GOVERNMENTSERV~ESBRANCH
1519.39
-------
FIGURE 2-5
VACUUM VAPOR EXTRACTION SYSTEM COMPONENT LAYOUT
DGSC
RICHMOND, VA
MANHOLE
SECONDARY
SETTLING
TANK
EMISSIONS
CONTROL
SYSTEM
WAREHOUSE 66
3 = LAW ENVIRONMENTAL, INC.
7 ~ GOVERNMENT SERVICES DIVISION
LECEMD
VAPOR HEADER OR MANFOLD
EXTRACTION WELL
VENT WELL
1510.39
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2.7.3.3 . ~ Six extraction wells and two venting wells have been
assumed for development of a cost estimate. A significant consideniti~ in the design and
iDstallation of the vacuum wells is the proper seal to elimin:.te -short circuiting" of air
directly down the well bore. . The actual number of both extraction welIs and venting wells
may be different in actual application.
,
2.7.3.4 ~ One 'blower capable of maintaini11g an appropriate
vacuum (estimated at apprommately 20 inches mercury of continuous vacuum) would be
required. The blower would be installed o~ a concrete pad and housed in a ~tility building
to protect the equipment from weather extremes, etc. The blower would be connected to
the well collection materials and incorporate one or more flame arresters, since the
extracted vapors are potentially explosive. Emissions from the blower would require control
by use of carbon absorption.
2.7.3.5 lit Covers: To prevent rain water from collecting in the pit bottoms and to
prevent possible furtJ;ler usage of the pits for liquid disposal, a 6- concrete cover would be
constructed over each pit.
2.7.3.6 Oosure: As soil vapor and VQCs are removed, the total mass of the residual
cout:.min:.uon is gradually reduced. Tune required to achieve the remedial goals or action
levels varies and is both chemical and soil dependent. For this alternative and site, a time
of 4 yearS was projected. Soil samples will be collected from the affected area after shut-
down of the system, and will be analyzed to confirm whether cont:.min:'lIts have been
reduced to cleanup levels.
1519.39
2-26
-------
2.7.4
. D
Estimated Capital Cost: S 15,000
Estim'te4 Annual o&M Cost S 0
Estimated Present Worth Cost: S 15,000
Estimated 11D1e to Implement: 2 to 6 months
2.7.4.1 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.
2.7.4.Z Access Restrictions: These generally consist of fencing, warning signs, and
sometimes active security measures. Since the DOSe is a secured federal facility, site access
is already restricted.
2.7.4.3 ~ Since there is both the posstbility that contAminAnts
are still learhi"l from soDs to ground water, and also that some natural attenuation is
oc:c:urring. continued monitoring of ground water downgradient of the son source area can
provide some level of assurance that further and continued environmental dAm'ge is not
occurring. The ground-water monitoring at this site wiD, however, be done as part of
Operable Unit aU8 at the DOSC and, therefore, no ground-water monitoring will be
required under this Operable Unit 5.
2.7.4.4 . Administrative and legal mec"Anian~ such
as deed restrictioDS and ground-water access prolubitions will be implemented so that the
potential future users of the site recOgnize the risks of the contaminAted soil and ground
. water present there.
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------ --'- ,.--
. .
2..7.5 Attematlve 9 (No Action AItematiBl
Esrim~ted Capital Cost S 0
Estimated AmmaJ O&M Cost: S 0
Estimated Present Wonh Cost: S 0
Estimated Tune to Implement: NA
2..7.5.1 The No Action alternative, as its name implies, involves absolutely no action
at the site. The site is left in its present condition. 1be risks to human health and the
environment remain at the levels established' in the baseline risk assessmenL
2.1 COMPARATIVE ANALYSIS SUMMARY
ao.l For the comparative analysis presented below, the alternatives from the
detailed analysis were evaluated utili7-ing the EPA's nine evaluation criteria as set fonh in
the NCP, 40 c.F.R. S 300.430 (e) (a) (ill) and (f). These nine criteria are as follows:
.
- Overall
Protection of Human Health and Environment addresses whether a remedy
. provides adequate protection and describes bow risks posed through each
pathway are elimin~ted, reduced, or controlled through treatment engineering
controls or iDstitutional controls.
.
Comp1iance 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 statues and/or provide grounds for the invocation of a waiver.
1519.39
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. .
1519.39
.
~..term ~eness anQ...,Pennanence - Long-term Effectiveness and
Permanence refers to the magnitude of residual risk and the ability of a
remedy to maintain reliable protection of human health and the environment
over time once cleanup goals have been met.
.
. Reduction
of Toxicity, Mobility, or Volume Through Treatment refers to the objective
of the treatment technologies that may be employed to remedy site concerns.
Short-term Effectiveness - 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.
.
~ . Implementabillty is the technical and 8dmini~trative
feasibility of a remedy, including the availability of materials and services
needed to implement the chosen solution.
.
.Qm . Cost includes capital and operation and maintenance costs.
.
State/Sqp,pon AleD~ A~t~nce - State Acceptance indicates whether,
based on its review of the RIfFS and Proposed Plan, the State concurs with,
opposes, or has no comment on the preferred alternative.
.
r.mm"nni~ A~nce . Community Acceptance will be asRSSed in the
Record of "e<;sion following a review of the public comments received on the
RIfFS report and the Proposed Plan.
2-29
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2.8.1 ~
1519.39
'.
.
Altemative 4 (Excavation and Solid Phase Biotreatment) is effective at
protecting human health and the environment.as it removes the contSlminSlnts
of concern, and reduces them to safe by-products. It also achieves this result
relatively quickly.
.
Alternative 7 (Vacuum Extraction) is effective at protectiDg human health and
the environment. Vacuum extraCtion will remove the contAminAnts of concern
from the soils. Venting of VOCs to the atmosphere is minimi7.ed through an
emission control system using vapor phase activated carbon. Absorbed VOCs
are destroyed when the carbon is regenerated.
.
Alternative 1 (Capping) will not reduce the volume or toxicity of the
contAminAnts, but will reduce their mobility by restricting rsainfal1 and other
moisture perculation through the soils.
.
Alternative 8 (Institutional Controls) does not reduce the toxicity, volume, or
mobility of the contaminAnts, although Alternative 8 will restrict access to the .
conmminSlnts.
.
Alternative 9 No Action) does not reduce the toxicity, volume, or mobility of
the contAminants. It is not protective of the ground water. Therefore, this
altemative wiJl no longer be considered
2-30
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2.8.2
~ -
2.8.2.1 ARARs and the To Be Considered (TBCs)l requirements for the ANP site'
are identified in Table 2-5. Chemical-specific ARARs were not identified for the ANP soils.
Risk-based soil action levels for both exposure to workers and protection of ground water
were identified as TBCs. The single elevated occurrences of tetrachloroethylene and arsenic
were the only significant exceedances of the TBCs. No location specific ARARs or TBCs
were identified. Action specific ARARs and TBCs are disc:ussed below.
.
Alternative 4 (Excavation and Solid Phase Biotreatment) satisfies TBCs by
destroying organic contaminants present in the soils. This alternative will not
satisfy VtrgiDia Solid Waste or Hazardous Waste Management Regulations for
replacement of treated soil. Other action-specific ARARsfI'BCs can be
saUsfied. Therefore, this alternative will no longer be considered.
.
Alternative 7 (Vacuum Extraction) satisfies TBCs by physically removing most
organic contaminAnts from the soil. All ac:non-spec:ific ARARs can be
saUsfied.
.
Alternative 1 (Capping) does not satisfy the cbemical-spec:ific TBCs for soil,
since contAminAnt substances would remain at their current levels. Action.
specific..ARARs would be satisfied.
1 In ad4i~ion ~o applicable or rel.van~ and appropria~e
requiremen~s, the lead and suppo~ aqencies ..y, as appropriate,
iden~ify other advisories, criteria, or quidance ~o be considered
for a particular release. The "to be considered" (TBC) ca~eqory
consis~s of advisories, criteria, or quidance tha~ were developed
by EPA, or other ~ federal aqencies, or sta~es tha~ may be useful in
developinq CERCLA remedies. 40 C.F.R. S 300.400 (9) (3).
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TABL8 2-5
POI1!NI1AL APPUCABL8 OIlIlBLBVANI' AND APPIlOPIUATII REQUIRBMBNI'S (ARAIlS)
AND TO BB CONSIDBRBD ('1'801) RBQU'1lI!NiWIs
Add Ncutralll88i08 Pit Soun8 Area
OpcI1IbIoUaIIS
TYPe 0' AltAR
. Dt.a..LSpedAc
ARAR8
1BC ReqIlilaacal8
Ri*~ IDiI 8d108 IcwII for """818. IOiII bucd .. ......
.......
w_.... wWda will 808 ..... Ie Ie8daaIc or paad....,
_lnIiaaIpu.. .... Na...
. Noao Idcalificd
Noao Idc8II11ed . .
LocaIicJD.SpccUlc
Adloe-Spedflc
No Acdo8
Noao Ide.tlfted
""'lde8d~
Noao idcGlificd
I8II1ludoaaI c.o.arc.
..... Ide8tlfted
OSHA SI8Dd8Jda for AIr CoD""""'.. (29 aIlI910.10ID)
ACOIH 11uaboId UaI8 VIha (R.VI) .
OSHA Pcllllillible I!IpoIuI'8IJ111iu (PI!LI)
NAAQI for Puticulale ho....
Bacavallon aDd TrutlMlll/DiIpouI
llellA l8Dd DiIpoIaI Ratricliou
(40 all_)
VA HawdouI Wilt. Maapmenl acplaliou (Vil
6'noi0-1)
Nalloul Ambient AIr QuaD., SCududI (NMQS) for PutlculalC
I!mIIIionI .
ACOIH 11uahoId Umb VIIuca (R.VI)
OSHA Pcmlllibie BIpoIuIe UmitI (PBla)
tU
~
...,
VA Solid Wilt. ~."'-DI acplllloDl (V1l6'no
»10)
oar IluIc8 for TnMpocIadoa 01 HawdouI
M81cdIII (49 (1IR 107)
VA CoatraI lid Abalcmeal of AIr PaI1u8i08
(Va ... 4-2. 4-!, U) .
Coal8lament/C8ppIaa
IlCIlA 0DIuI'8 RequiRlDCD"
(40 (JlIt ...111)
Noao kk8l16ocl
Nooc IdeDdOed
.
BiotIabDeDt
Noae IdeDIIfled
,...5.... VecuuDl Bm8dJoa
NatJoaal f'-I-I- ~ for Hu.udouI AIr
PaIIutaaII (NI!SHAPS)
S88tc ....,............. ..... (51"')
VA Caatrol ad Abate"" AIr Pollution
(VIl1lulc8 4-2, 4-3, ~3)
Notte identified
1519.39
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.
Alternative 8 (Institutional Conttols) provides for institutional monitoring and
some exposure control of the site, but otherwise d~ not seek to limit
migration. or decrease contaminant volume or toxicity. There are no
promulgated ARARs for institutional controls.
2.8.3 Lonl-Term Effectiveness and Permanence
2.8A
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.
. Alternative 7 (Vacuum Extraction) is most effective for VOCS and semi-
volatile organics, with the long-term effectiveness for these constituents
equivalent to Alternative 4. Non-volatiles would presumably remain, although
the increased ventilation of deeper soils has in some simi1ar instances caused
an increase in natural biological attenuation of non-volatile organic residuals.
.
Alternative 1 (Capping) is assumed to be effective for as long as the cap
material maintains its integrity. However, the complete reduction of
migration of all constituents is not assured. Assuming that the capped area
is not heavily trafficked, and that periodic maintenance is performed to
maintain and repair ~e cap materials, this type of cap can be expected to last
anywhere from 20 to SO years before requiring a complete reinstallation.
.
Altemative 8 (IDstitutional Controls) is only effective in preventing surface
exposure at the site.
~
.
Alternative 7 (Vacuum Extraction) reduces mobility, toxicity, and volume of
VOCS. and semi-volatiles in son by rem~ them in the gas phase and using
vapor phase activated carbon to minimi7.e the venting of VOCS into the
atmosphere.
2-33
-------
.
Alternative 1 (Capping) is primarily aimed at re~uc:ing the mobility of
cmrtAminsints and does nothing to decrease their toxicity and/or volume.
.
Alte~e 8 (InstitUtional Controls) seeks to limit exposure at the site.
Alternative 8 does not affect contAminAnt mobility, toxicity, or volume.
2.8.5 Short.tenn Errediveness
.
Alternative 8 (Institutional Controls) offers relatively short.term exposure
potential since this alternative does not involve 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.
.
Alternative 7 (Vacuum Extraction) likewise involves little site disturbance;
only that associated with drilling and well installation. Therefore, a low or
moderate exposure potential exists from the movement of CODtamin'ted soil
in the drilling spoils to the surface.
2.8., ImplemeatabUiv
1519.39
.
Alternatives 8 is the easiest to implement in that DO direct physical actions are
to take place at the site as part of its "implementation.
2-34
-------
2.8.7 i:aI&
.
Alternative 7 (Vacuum Extraction) requires a mini~um of materials and
equipment to install and operate. Drilling beneath the pit bottoms for well
iDstallation is the only invasive activity involved This alternative is relatively
easy to implement. Coordination with the VirgiDia Department of Air
Pollution Control will be achieved.
.
Alternative 1 (Capping) is relatively easy to implement, hOwever, the site must
be prepared and graded, and the cap must be carefully constructed under
stringent quality control guidelines and supervision to maintain that the cap
will perform as designed and intended
.
Alternative 4 (Excavation and Solid Phase Biotreatment) is the most difficult
alternative to implement since it involves excavation of contJlminAted media,
treatment on-site, and re-emplacement of the dean soil. As previously
mentioned, this involves the potential for ~ip'ificant human eXposure to
. .
contAminAnts for which preventive measures must be undertaken.
. 2.8.7.1 The cost comparison among the alternatives is based both on the present
worth computed using the initial capital construction costs and anm.JaI operation and
maintenance costs. The cost comparisons are alSo based on assumptions about the volume
of contamination present. Based on previous discussions, the alternatives are ranked .
according to cost as fonows:
1519.39
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~
Alternative 8
(Institutional Controls)
Alternative 1 (Capping)
Alternative 7
(Vacuum Extraction)
Present Worth
Cost
$ 15,000
BaokiDa
1
S 43,135
$115,607
2
3
2.8.8 State Aeeeptanee
2.8.8.1 The Commonwealth of Vlrginia, upon review of the Proposed Plan, concurs
with the preferred alternative.
2.8.9 CommunitY A......ntanc:e
2.8.9.1 ColDD1\lDity acceptance of the preferred alternative was evaluated after the
public comment period on the Proposed plan for OU5. The comm11nity acceptance is
described in the Responsiveness Snmmsny of this ROD.
2.t~
2.9.0.1 Based on the precetting aualysis of alternatives, the DLA bas determined that
Alternative 7 (V&m11m &traction) is the most effective and appropriate option at the site.
The EP A aDd VDWM concur with this determination. As discussed previously, VOCs were
identified as the primary constituents of concern with soils at the ANP site. However,
, elevated levels of VOCs, particularly tetrachloroethylene (PCB) were detec:ted in only one
soil sample directly below the secondary setting pit. These CODStituents are of primary
concem bealuse they were also detected in the ground-water plume apparently originating
1519.39
2-36
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at this site. Only one bore hole was drilled through each of the two pits. There is,
therefore, some degree of U:Dcertainty associated with the concentration and extent of
contaminants present in the soil beneath the pits. Ground-water sampling and teSting
performance in November. 1988 indicated that PCE concentration in the plume had
increased as compared to those observed in July, 1988. It is possible that soil beneath the
pits could exhibit higher concentration of constituents.
23.0.2 Vacuum extraction requires the installation of extraction and venting wells,
a blower and manifold system, a utility building, and a carbon adsorption system to retain
vapors extracted by the system. The soil vapor extractor system shall be operated for a time
period sufficient to reduce present concentrations of CODtaminSints of concern in soils to
levels below the "Calculated Soil Action Levels" listed in Table 2-4 of this ROD. The
estimated time necessary for this system to remove the contaminAnts from the soils is four
years. In addition, tWo six (6) inch thick by 240 sq. ft. (Pit 2) and 780 (Pit 1) sq. ft.
reinforced concrete covers will be constructed over each of the pits to prevent infiltration
and unauthorized dumping of waste liquids. Minimal disturbance of soils would take place
as the wells would be installed uti1i7.ing a small drill rig. Samples shall be collected from
the wells to further delineate the amount and extent of subsurface soil contaminAtion. The
spent activated carbon from ~e emissioDS control system will be handled as hazardous waste
from the point of generation until it is regenerated or disposed of at a facility that operates
in compliance with the Resource Conservation and Recovery Act (RCRA), Subtitle C.
23.0.3 In addition to removing contaminants from the affected soDs, this alternative
will remove the soils as a possible source for ground-water contaminAtion.
2.9.1 Cost SDDlm.~
2.9.Ll
A cost summary for this alternative is detailed on Table 2-6.
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TABLE 2-6
:
COST SUMMARY fOR SELECI'ED ALTERNA11VE :"
ALTERNATIVE 7: VACUUM EXTRAcnON
(OPERABLE UNIT S)
a.pital CACh
Cost Elemea!l Unit Cost Uaits Cost
Ccmcrete TaDk Cap S115/~ 9.2 $1,100
WeDs $1,000 each 8 S8,OOO
Pipe ad FdIiDp S20/If 200 If S4,OOO
Stack SSO/v{ 30vf $1,SOO
Blower AsIe1IIbIy $15,000 $15,000
Vapor Pbue C8IbaD Adsorber $10,000 $10,000
Security BaiJdiag 15,000 15,000
Subtotal $44,600
:It 1.20 (desip, c:oatractia& etc.) S53,S2O
:It L10 (~."..,) SS8,B72
O&:M
~.i"ten.~ $ S,ooo/yr
CarbaD RepI-e-_t $ 8,QOO/yr
.
Power Usap S 1.000/vr
Ammal Total SU,QOO1Yr
IDterest Rare - S'5
Duratic8 - 4,...
Uaiform Series Preseat Work Factor P / A . 3.54595
PreseDt Worth SUS,607
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2-38'
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1.10
1.10.0.1 To meet the statutory requirements of CERCLA Section 121, the selected
remedy must:
.
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
m8~mum extent practicable; and
.
Satisfy the preference for treatment that reduces tOxicity, mobility, or volume
as a principal element, or provide an exploration as to why this preference is
not satisfied.
1.10.0.2 How the selected remedy complies with each of these requirements is
summarized below.
1.10.1 Protective of Haman Health and the Environment
1.10.Ll Alternative 7 (Vacuum Extraction) protects human health and the
environment through the treatment of contamina.ted soils. This remedy will also mitigate
the threat of contaminam;s le~bing from the soils into the underlying ground water.
1519.39
2-39
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2.10.2
m.
wi
2.UU.l 'The ARAR requirements identified for vacuum extraction at the site include
the National JO:mission StSI""ards for Hazardous Air Pollutants (NESHAPS), State
Implementation P1ans (SIPs), and Vuginia Control and Abatement Air Pollution (VR Rules
4-2, 4-3, 5-3). These requirements will be satisfied.
2.10.2.2 Alternative 7 (Vacuum Extraction) meets chemical-specific TBC requirements
at the site by treating C:OD~minants at the site to levels well below the proposed risk-based
soil action levels determined for constituents in the soils. The soil action levels are risk-
based levels which will protect ground water at the site.
2.10.3 Cost Effectiveness
Alternative 7 (Vacuum Extraction) is the least costly of the alternatives identified that', .
employ treatment as a principal method of remediation. By removing the contSlminants of
conc:em from the soils at the site, this option will effectively return the site to its original
condition, and is therefore considered the most cost-effective of the alternatives.
2.10.4
2.10.4.1 The DLA has determined that the selected alternative (Vacuum Extraction)
represents the m~~ml1m extent to which permanent solutions and treatment-technologies
can be uh1i7.ed.. The EPA and VDWM have concurred in the DLA's determination.
2.10.4.2 Of the five balancing criteria, Long Term Effectiveness and Permanence and
Reduction of Toxicity, Mobility, and Volume Through Treatment were considered the most
decisive factors in the selection of Alternative 7 (Vacuum Extraction). This was because by
1519.39
2-40
-------
removing the contaminants of concern, human health and the environment are protected
both in the present and the futUre.
2.10.5 Preference for Treatment which Reduces Toxicity. Mobility. or Volume.
2.10.5.1 This alternative also address the statutory preference of selecting a remedy
that utilizes treatment, which reduces toxicity, mobility or volume, as a principal element.
2.10.6 Documentation of SlplfleaR. Chances
The Proposed Plan for OUS -),. :1 Neutralization Pits Source Area was released to the
public on January 20th, 1992. The Proposed Plan identified Alternative 7, vapor vacuum
extraction as the preferred alternative. DLA reviewed all written and verbal comments
submitted during the public comment period. Upon review of these comments, it was
determined ~ no significant changes to the remedy, as it was origiDal1y identified in the
Proposed Plan, were necessary.
2.10.7 Resuonsiveness Samma~
The purpose of this responsiveness Stlmm9.ry 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 (DOse) in Chesterfield County, Virginia. The Area of Concem
specifically addressed by this responsiveness summary is:
.
Operable Unit Five (OUS) - Acid Neutralization Pits Source Soils
1519.39
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The responsiveness SlJmm~ny details the Defense Logistics Agenci~'s (DLA) 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 DOSC concerning the tWo operable units.
These comments and calls are addressed as part of this responsiveness summary. In
addition, a public meeting was held on February 20, 1992 at the Chesterfield Elementary
School by the DLA. At this meeting, the Proposed Plans for OUI and OUS were
presented, and the public was given a opportunity to comment on and ask questions
concerning the plaDs. Several technical questions perta;ni~g to OU1 and OUS were
answered during the public meeting. The responsiveness summaty for OUS is divided into
the following sections:
L
Summary of questions and replies.
n.
Public meeting attendance roster.
m.
Panel of Experts
IV.. Selected newspaper notices announcing dates of the public comment period
and location and time of public meeting.
All comments and conc:ems summarized in this document have been considered by the DLA
in msa1ring a decision reprdiDg the selection of the Vapor Vacuum Extraction Alternative
for OUS . Add NeuttRliftltiOD Pits Source Soils as the ChoseD alternative. Those questions
that do not pertain to OUS are preceded by an asteria (8).
1519.39
2-42
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L
.
.
1519.39
Summ~ otMajor Ouestions and Comments
1.
Comment: A resident sent a letter comment to DOSe stating that be 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 uri1i7'ecl the main threat
at the ANP area (chlorinated solvents) in the soils are being remediated. Tbe
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 DIA feels that institutional controls will not be
necessary if chemical sampling of soils confirms that the cb10rinated solvents
have been removed after treatment.
2
Comment: A resident sent a letter comment to DOSe requesting that the
public comment period for OUt be started over as one of the referenced
docum~nts in the OUI Proposed Plan was not available in the admini~trative
record. He also questioned whether concerned citizens could get Technical
Assistance Grant (TAG) money to help them with the process of
underst~nding the remedial actions taJring place at the site.
DlA Response: An additional time period is being allowed for public
comment on OUI as the missing reference document is now present in the
admini~trative record. The EP A 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. DOSe. .
3.
Comment A former resident of the area sent a letter comment to DOSe
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
documentation as to whether or not her mother's property bas contAmina.tion
present be sent to her as they plan to sell the property.
2-43
-------
DLA Response: The former resident was contacted ~o let her know that all
of the aclmini!;trative record would remain available.. for review at the
Chesterfield Public Library, and that this adll'1ini!;trative 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 mo01er's address to help determine whether
any contaminBtion is present at the property. .
The foUcnriDg comments were received during the pubUc meeting on Febnwy 20, tm.
.
.
1519.39
4.
Comment: A resident asked that the public comment period for OUI be
started over as the administrative record was mi~ing a memorandum
referenced in the OUt Proposed Plan.
DLA Response: Refer to Comment #2 response.
s.
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 CODmm;n~tion
whether evetyOne was hooked up to the county water supply system.
DLA Response: DGSe 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.
2-44
-------
.
7.
.
8.
.
9.
.
10.
.
11.
1519.39
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.
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 DOSC 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.
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 OUI & OUS.
Comment: A resident requested that additional people be put on DGSe's
informational mam"8 list for remedial activities at the site.
DLA Response: Everyo~ who signed in to the register tonight will be put
on the mai1i"8 list, unless they request otherwise. Also, residents can contact
George DelliDger (DGSC Public Relations Officer) to be put on the U)ai1ing
list also.
Comment: A resident asked for clarification as to who was and who wasn't
hooked up to the county water system years earlier.
2-45
-------
.
14.
15.
.
t6.
1519.39
DLA Response: DOSC 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 DOSC 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 DOSC will look into what possible impact ANP
ac:tivities may have had on the county sanital)' sewer system.
'Comment: The county supervisor asked that a reply also be sent to the
county admini~trator.
DLA Response: A response will also be sent to the county atlmini~trator.
Comment A resident asked if either OUt or OUS drain into }Cinp1and
Creek.
DLA Response: Neither.OUt or OUS drain into Kinptaod Creek.
Comment: A resident asked if any other sites drain into KinptaDd Creek.
DLA Response: There are other sites that drain into ICi'1pt;J.nd Creek, but
they are not being addressed tonight. as only OUt and OUS are being
discussed.
2-46
-------
.
17.
.
18.
.
19.
.
20.
2L
1519.39
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.
Comment: A resident asked how long it would be until tesults 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 a this meeting, there are no specific dates that can
be given to the residenL
Comment: A resident asked whether the DLA had a time frame for reporting
on the other sites not being addressed toDighL
DLA Response: Updates as to progress at the other sites will be provided as
they become available.
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.
Comment: A resident questioned whether contaminAtion that got into the
ground water at DOSC could come out at the surface of a site away from
DOSC if the site was lower in elevation than OOse, and what the effects of
that contAminltion would be.
2-47
-------
22.
23.
24.
.
25.
1519.39
DLA Response: During studies at the site, the vari~us ways in which the
contaminants could move offsite were investigated. The studies looked at .
different ways that people away from the site could be affected, including the
COJJtAminants being moved in the ground water. Tbe studies showed that if
the recommended alternatives are used, human health and the environment
would be sufficiently protected from contamin~nts at the sites.
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 OUS, the contaminants will essentially
be "vacuumed8 from the soils, and the contaminants will be captured in a
carbon adsorption unit.
Comment: A resident questioned whether these coutaminants 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.
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 Ouestion #2 for the DLA response.
Comment: A resident asked bow long it would take for a steel drum to rust
through if it was buried in the ground.
2-48
-------
.
.
151939
DIA 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.
26.
Comment: A resident asked if vacuum extraction would work if there were
buried drums.
. DLA Response: At OUS, there is no record of buried dnuns being present,
nor were any found during investigative work at OUS.
27.
Comment: A resident asked. about possible conta.minsation 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 wbat
types of metals and organics are present in the ground water. The remedies
proposed at OUI and OUS are designed to be protective of ground water.
The remedies for the ground water ~ deal specificaJly with contsaminants
and the problems they may pose in ground water itself. The remedies will
also take into consideration the posSlble affect ground water contsamination
could have on residents affected by the situation.
28.
Comments: A resident asked whether old wells ~at had been filled up
previously could cause the contsaminants to bypass the closed wells and move
on to open weDs.
DLA Response: Due to the way ground-water flows, the dosed weDs would
not have an effect on the way the contsaminsants move through the ground
water.
2-49
-------
n.
PUBUC MEETING ATTENDANCE ROSTER
1519.39
-------
Mf=lR
9 '92
8:47
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m
PANEL OF EXPERTS
The following list represents the panel members who participated in the public meeting held
on February 20,1992. .
J2d'ense General SQWly Center
Colonel John E. Dawley, Jr., U.S. Army
George Dellinger
William SaddingtOD
Art WellS
Kent Baldwen
William Walker
Major Keny 1. Burke, U.S. Army
.l1.S.....Em?mnmentatJ»rotecnon Aien~ - RepoD m
Jack Potosnak
Hank Sokolowski
David Sternberg
~artmeDt of Waste M':.In~eement
Steve MiUual1rn
Jamie Walters
Ii
Roger Fitzpatrick
Roger Young
Sn'nlnne Murdock
Law Envirnnmental. IDe:.
Thomas Richardson
Lynden Peters
1519.39
-------
IV.
SELECI'ED NEWSPAPER NOTICES ANNOUNCING DATES OF PUBUC
COMMENT AND LOCATION OF PUBUC MEETING
~
~
~19.39
-------
PUBLIC NOTICE
Proposed Remedial Action Plana
for the
Defense General Supply Center (DGSC) Superfund Site
In acc:ord8nC8 with the requirements of the Comprehensive Response, Compensation and Uability
AI;t (CERCLA) , the Defense General Supply Center (DGSC), th8 U.S. Environmental Protection
Agency (EPA), and the Virginia Department 01 Waste Management (VDWM) invite public comment
on the Proposed Plana for two 01 the eight Superfund operable units: the Open Starage 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 wiD be held to discuss the specifics of the proposed cleanup actions at 7:30
PM on February 20, 1892 at the Bellwood Elementary School, 9538 Dawnshire Road, Chesterfield,
VIrginia.
A foci IS8d feulbDIty study (FFS) has been prepared by DGSC for the contIIIninated soils at the
OSA. The FFS evalU8t8d the following remedial action attematives:
AIt8m8INe 1: Surface ContaInment/Capping
AIt8madve 2: SoIldlftcation/StabilizaUon
AIt8mative 3: SoIl Washing .
AIt8matMt 4: Evacuation with Off Site TreatmentlDisposaJ
AIt8matMt 5: InstttutionaI Controls
AIt8m8INe 8: No Action
Baed on an evalUIIIon of the aIt8matiY8s, the Pfefemld cleanup option for the OSA is Institutional
Controls consisting of erMrorimentaI reviews prior to performing rnaInt8nance, an environmental
lI88I.ment far military construction projects in acc:ord8nC8 with the Defense LOgIstics Agency policy .
memorandum dated %7 December 1989 and any deed restrictions required under Part 120 (H) of
CERCLA. .- .
A foci - feuibility study (FFS) has been prepared by DGSC for the contaminat8d soils at the
N4P. The FFS 8V8Iuat8d the following remedtaI action attematives:
AIt8matMt 1: SurfIIC8 ~
AIt8m8INe 2: Exc8Yation with SoIidificationIlization
AIt8mative 3: Excavation with Soil W88hing
AIt8m8INe 4: Excavation with Solid Phase BiObvatl.1$M
AIt8m8INe 5: Excaltion with Bulk IncinenItion
AII8matIv8 8: Excavation with Off SIte Tr68lh*1t/Dilpolal
AIt8m8INe 7: V8CUUII'I Vapor Extraction
AIt8madve 8: InIIIIuttanaI Controls
AIt8madve 8: No Actian . . ---.'
Buec:t on In 8V8JuItion of the 8It8mativea. the pi ,fined c:Iearq) option for the ANP is Vacuum
Vapor ExtractIan. Vecuum Vapor ExInIction COIISists of drawing vapcn from the 8OiI8 using extraction
..... COI.18d8d to . rrl8l1ifoId 1yIbIm. The system is connect8d to . bkMer to draw vapors from the .
8011. The ~dblQ of volatile organic cOmpounds (V0Cs) to the atn~ wiD be controlled through
an emi88ioI. (X)."01 8yIt8m using vapor.phase 8CtivaI8c:t carbon. au.. can I'I8Ir presentations
on these proposed tllc:hi1Ologies, and Ilk questions. at the February 20. 1992 public meeting.
Although .... are the prefelr8c:t remedial options at this time. DGSC. In consuIIation with EPA
and VDWM. may modify the preferred aIt8maIMt or 88I8ct anoItw option b88ecI on new information
pre.ented CUIng the public comment period; therefore the public 18 encouraged to review and
comment on. the Proposed Plan for site cleanup prior to tie cIo8e of tie comment period.
CI~II may nM8w and photDcopy documents pertaining to tie DGSC Superfund site studies
end IWTI8dy lellctb. In the lite Administrative Fi~. located at the Chesterfield Public Ubrary, 9501
Lori Road. Chest8rfieId. VA 23232. Ubrary hours are 10:00 Lm. to 5:30 p.m., on Wednesday, Friday
end Saturday: end 10:00 Lm. 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 tie upcomllig public meetilig or to be
added to the mailing list to receive updates on the site, interested atizens may contact:
Mr. George Dellinger .
Defense General Suppty Center, oosc.oa
Richmond. VA 23297.5000
(804) 275-3139
-------
.
. - .,... -....
DGSC
begins'
. 'clean!8up
; .
Journey
.'
By DAVID BREIDENBACH
Staff Writer. .
.. CHESTERFtELD~ Twe c:on-
taminaled sites AI the DefenseQen-
end,Supply Center have started II
long. road to being cleaned up.
About 26 :na residentS. :and
officials from die DOSC :and die
Environmental Prorection Apnt:Y
. discussed me sita ;and ctan-up
plans at i1 public harin. Thunday
nigbt at Sellwood Elemenwy
School. .
The tWO conwnilUWld sites
IIddr'esMd were :III opea storII&e
area and :III acid neunJiDtioa
facility. The Virginia Depllnment
ofWasae Management is also tak-
i. DGft in the cleanup apenWon. "
~ The Progress-Index. P.t.~rg. VL. Friday. February 21. 1992
I -Marked as It Superfund sile. the
t DGSC cleanup is different than II
I. typical cleanup. said Jack PoIas-
I n:&k of the EP A. which is oversee-
I ing the DOSe 5 cle:mup oper.uion.
: ,he said.
: Uiually. sites are abandoned
! before the EPA ever gets involved. .
I In this ca.w. DOSC i5 Slill II wort-
in, operation. .
The entire DOSe sitc'- which .
. has II total of eight contaminated
I areas - i5 c:on.oddered a Superfund
! site. said David Sternberg.:III EPA
public affain !IpeCiAli.'U. The conta-
mination sires were broken down
I to smaller areas to make it asier to
: clan up. he said. .
"'Of the tWO tonipt. neither are
, the most severe. but everythin, ii
I reviewed and die projects should
, ,go ahad." he said.
Five of die sites we called
r source areas. or places where con- .
~ auninatiOD is known to .ve
" .~ The other three involve
, See DGSC. P8&8 AS
I -
DG.SC: Has cleanup .he~g
ContInued from P8I8 A1.
",
8fOUIIdwItir, C'<)"bI-ri-'o- ...
areconsidaed themcndiflic:ulllD
clem. be 1IIicL' .
CoIttmnituYiiIB . ... DOSe
sites occurred........ ~ nannaI
oper'IIin, prac;edurel8I'" DOSC
over line ...., said Gearp ,
Dellinpr. . DOSe spaIccsman.
. --n.ere were' many prICCic:es in
die '40s. '501 and '60s .. were'
co..ide- ecS nGI'IDII openIIina ...
cedUra. Nabady thoqIR uydIiaJ
abauI the environment." he IIIid.
1beopen stamp Ira. a43-acre
fenced site in die middle of die
DOSC is used to IIOI'e peaaIeum
producIL Hiper IbID normal
levels of tWO meaaJs. ancniI: and
antimony. were found in soil s;un.
pies tbere. The conauninated soil is
not caasidered to be a Iaipif8CaDI
"
risk. said WilliIID Slddinpm ~
. tile DOSe. .
"'R die site pcIIIia lime risk.
SaddiIlJlOD. said tile PNf',"~ .
IIIIIbod of IraIIDeaI is to camioI
tile ... A fence will be put up
IraIIDd Ibnra aDd tIIe.DCiSC win
coati... to moai- it.
The s&icond sire. 1ft acid aeutrD-.
liDIioa.fadlity. poses a dif&f~
problem. he 5iIid. Hi'" tbIn nor-
mal IneIs of anaic 8Dd ..
orpnic eotominn were fauad.
, The':naaic level .. DO ..'
canc:em. but the orpnicconaanm.
am. ten:bIorethane. whicb is used
in claning nweriaIs. is of can-
~.'ern. bellid. The DOSC intendl to
v.:aum the c:ontUDillilDl out of the
. pouad. he said.
MOlt of the c:it~ whp 5pOke
at the meeting were co,1Cerned
"ith the effec:t5 the site ~ '111 ,~
..-MI...,.
In the 1llid-198OI. water WID
u""-' to a number' ~ h0use-
holds in narby Rayan PIIrt sutx1i-
YiIioa. About the ....... of the
subdiYision. wbo In DOt tied into
tile CGUIIIy WII8' ayReIII. c0m-
plained of warer, p.
-------
THE RICHMOND NEWS L.EADSt FridIIy, February 21, 1992 f f
..
Federal officials
plan cleanup amid
ground-water fears-
8r IIJtctt Z8mII roc* die mV*.",' DIIDeS ad ad- .
81ft... dresaellDd aid cbey would COIUICt
Federal oft;M... bI\Ie ~ted. rbem later.
.. to claD up twO of ciPt Super- 0IiciaII from tbe Defeate OeD-
luad buaJdaus' ... sites II die cra1 Supply Ceaser bave stated Ibat
DefaIe GeDeral Supply Cader ill . public "1IIIety aDd bea1tb lie DOt
Clesle:rfield Coumy.-&Ut "-uuuldi- Ibmte-d by tbe lites, bat EPA
ilia resideIda lie men ~ ....11 IIid ... ili8bt tbey wa'CQ't
about llvuDd-wIIc ftmt8IIIitt8tiftQ. l1li8 wbetber ~ 8I'C beiDa If-
.~~ 01 the military. t=cecI by tbe eoablftli..8tN1 pouad
die ~ Ea¥iroIIIDeDta1 ProtediaD Water.' .
ApttJ:y, tbe u.s. Army 0.1» of ; Moll ~IS ill tbe IIIpply c:a-
1:-"I'-..1Dd the II8Ie Depanmeat . 8Ia were eoDDeaed CD caamy
01 Ware )of8fJ8p-nt CODducted a -- IiDII ill tbe IDid-l$t801 ad
public bIariDa lilt ai8bt CD dIIc:ua .... .. wen--.
prapasaIs to IiIDd1c tWO of the IiIa. ~~~_~II laid tbe twO si1a
loch CICIIII8iD IOil ~itt8tM willa lilt DiPt are DOt tbe ..
: aneaic, ad cae also -m. a biz- ~. GDeL
: 8Idoas arpIIic ~., t'lvvI . 1b reIDDVe tbe CIIpIIic CXMd:IIDi-
I 8a& tile ....... ~.-.t'" 30 rai- fraaI die daulDe oldie siIa,
. deaD wIlD 'I'e~ die be8riDa II a' called ~ .... a-
f BeUwood &--~IM" Sc:IIaaI re- . waaId be I8Cd CD ..,. air
peaIedIy .... ~ Iboat two die IaiL 1be bazarc:b.a
0Cber IDa ol-n..-f pIIIIDd ~ waaJd be picRd up by
. WIler. . air, wbiI:Ia ... would be fi1tcreCI
. 1be "'''1Iid ICIIdieI 01 *- IeIIIIR8 tbe 0I--'_lftiIl8"" 1181
. twO ... IIId faar o8bcn lie DOt . waaId taDlbaat fDaryan.
. ~..,..v"1ID ad cbey .~tipll!l!l CD aM 1h ... willa die ocber lire, of&.
die rclWtn.. 8IIJ iIIf'anDaJkxa Ibaat pIaD limply to raaict IIXeII CD
dIeaL 0&:iIII 8dded dIIr dIey did ...'
: IIDt -- wbeD dIIDIe ... would be 1he..""'W ~ wD1 DOt
. IIIIdied GI' __II 11..' . till dedliDa aD die deulap
I SevaaI r-8d-.t.. &¥ 11111 II COD- 1IIdi11ftcr die pubtie COlD-
~ call - die CtJIr,I.._i..8tM --'- 'period eadI Mardl6-.
WIler .. bid deaed ....;;ii EPA ~ Slid tba'e is DO
ODe ..... IIid IIIII1tb* W8Ier II- far de"~1Ip of die ocber
I... .... failed to ... her WIler wbic:b weIe pat aD die SapR-
: driw"'''' AaadIer JaideDt said ber lilt ill 1987. Malt of die COD-
~ -- pipes ~lud5 ~. . are from pc"'" plOd-
; Alter "-1M"" to di8c:8I die ad were cSiIccMnd ill die azty
pooaad WIler, die fedcnl offit"i...
]
-------
. "
....
~
. .
. . ~ :: -.. :-."
" . . ~ ~!: .
:-&4..."""'" 'n--D' t ~ frWa,. fea.n.r, 21.1992
--.. ---
It ,.
Answers .
on cleanup
are few
,t~!t..
.-
Bellwood waste
,sit~' ~ question
., ........ P. s.tdt
....~
F~26 ~ Jo AlIa 0IrdIe.. .
CIIried waIer from . well 500 feet
from bet borDe ~ berGWllweU
water is "'IIiaIy" ad -- ......
_tWO WIler &hen aD't:s:
Mn.~ to ~ ar driak
weD ~ lUlU bet .......
$be if berwell .........
po1lllll' water coatalDiDatecl bj
cbcIiiiOIi Jcab It die DefIDIe QeD.
eraI Supply ea.. wbidI baldeD
bet J"'uty.. ,
S6W8I of MIl. CaIdIe'l .....
MIl ill .. BeIlwaod .. of. QD.
'.tedieJd 0Iaat1 ... - ....
~ po.l~JIlrA"-4 pI1IIIId .....
~ ..weI& SeiDI...- if
~c:,~~="
-'..Ma Ode ... abaat 30
. aeipbGJs5U1l as_aipt
It'- aiubIic tor....,....
o! c&.:'eJelllllP, ...... .-
.liteS 81 DGSC. . .
; ~"t'&~oI.lt"'.
:daIe8 -¥t 1M 1 ..tivel fn8 DOSe.
"".Jt8Ie - die EIMf.a l!tD"atll
.F~~ AfpI:J, die ... CIDID-
:aa~... 80 re8Jea'" .--
:.... "'We1l" '** to JfI&."
'. 0tDdaIa laid me, weraa"t ....
'pued 10 d Iboat por-etial p'GIIIId
.:water ~"'-tWt .
,,_.
, . ~ caenu, w8med to rearict'
.dIe d;~1ioa ,to die fine Cwo of
;c~:~ projeas OD tbe 639-
. ~ -Iital)' ..II... whidI iI
'r;;, ,m major IaPDIJ cIepoCa for .
....'>JmOPI arouad -alai woiId.
: ~ of.. ~ de&,!1II' dforII
%oaas' OD CIODtMItift-ted clift.
I . ODe'" . 43cn .... area
, wberc ill --...UMt 80,000 drams
DaW Ii~ waII't eva be de~
J-ecIvac jt..doeI"",-,.. '.
~ riIt," said WiDiIm~
~sc eIItiJoom"DtII eaaiDeer.
at die - wbidI ... beeD .
't:C'
ItDrIp uea-1iDce 1942. baa
~ o-a to~ abc.- DOnD8l
; :1ewJI. 8f tWO 1DeI8IL' ,
i ..,
., 'J1Ie""" dt-lIIup dart is 81
.' die lite .cI'tWO acid aeatnIizaIioD
I .
! . pi1I. ilW"
I ~ 1IIed to cIe8D "",:
i Sowed GIlt 01. ..... ... iiIto ,.
I :tWO QWae~ 8tdiD8 pitI. wbae it
~ tI8IIIr8Ii8cI bcfDN beiDa IIiDcd
, :.... ICOUIIt)' ..... .,...: 11Ie
, :~........ froID 1955 10 1-
~..(~:: ill willa deaD
:. ;---..: . C" . .
~"'I".IIL......~ .. faaIIIIlD ICIiI
. UDder ODe oldie pill'" die ~
ic tIpGII will be ftriL"aW oat of
; die ..... - . ..... dial ooaId
; tUe...to four,an. .
. Tbe.pJarid '--aDder dIe-1Cid
.~-~ ,.,.." eo-
. bat dIey diciD't ... 80
~ diII:a8 ill deIaD lilt ....... .
i 11& ~
:.~QIW-" ... tbat IIIidI8r die
~-",.. die ~ "r~'
=.... dlrealllO DGSC. em- .
. :~ or to 8cIIwQod ~u...
. ,- .. \
i '. 'Biat.1IftI8I JaIl .. die federal
&Ow---" paid 10 CIt8Dd CIDIIIIty '"
Water.to.1IIOIC of !be bameI ill die
BeDwood 11'18 liter CCJI8CWII were
: niIed Iboat coat-"'-'ed paaad
watcr~ otr die .. "
. ;,.
, .. . .;
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