PB95-963108
EPA/AMD/R03-94/190
February 1995
EPA Superfund
Record of Decision Amendment:
Abex Corp., Superfund
Site, Portsmouth, VA
8/15/1994
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CORPORATION SUPERFUND SITE
PORTSMOUTH, VIRGINIA
RECORD OF DECISION AMENDMENT
PREPARED BY
THE U.S. ENVIRONMENTAL PROTECTION AGENCY
AUGUST 1994
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- - - RECORD OF DECISION AMENDMENT
ABEX CORPORATION SUPERFUND SITS
- PORTSMOUTH, VIRGINIA
TABLE OP CONTENTS
PART I - DECLARATION
Page
I. SITE NAME AND LOCATION 1
II. STATEMENT OF BASIS AND PURPOSE 1
III. ASSESSMENT OF THE SITE 1
IV. DESCRIPTION OF THE SELECTED REMEDY 1
V. STATUTORY DETERMINATIONS 7
PART II - DECISION SUMMARY
I. INTRODUCTION 9
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 12
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 14
IV. RATIONALE FOR CHANGING REMEDY SELECTED IN
SEPTEMBER, 1992 ROD 14
V. SCOPE AND ROLE OF RESPONSE ACTION 15
VI. SUMMARY OF SITE CHARACTERISTICS 15
A. General Overview 15
B. Summary of RI Findings 17
VII. SUMMARY OF SITE RISKS AND CLEANUP LEVELS 19
A. Identification of Contaminants of Concern 20
B. Human Health Exposure Assessment 20
C. Human Health Toxicity Assessment 25
D. Toxicity Profiles For Contaminants of Concern .... 27
E. Human Health Risk Characterization ,. 33
F. Future Risks Associated With Subsurface Soil 36
G. Ecological Risk 37
H. Lead Cleanup Levels 37
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- • TMLS OF CONTENTS (Cont.j
Page
VIII. C...3CRJPTION OF ALTERNATIVES 38
A. Elements Common to Alternatives 4&8 '. 33
1. Demolition of Former Foundry Facility
Buildings on Holland Property .. 38
2. Soil Excavation and Off-Site Disposal 38
3. Temporary Relocation 39
4. Soil Treatment By Stabilization
and/or Solidification 39
5. Discharge of Contaminated Water 40
6. • Air Emissions Monitoring During
Remedial Action 40
7. Transportation, Storage, Treatment
. and Disposal of Soil and Debris 40
B. Elements Specific to Alternative 4 or 8 41
1. Alternative 4 41
- • 2. Alternative 8 41
IX. COMPARISON OP ALTERNATIVES 43
•
A, General Overview of y^alu.iting Criteria ........... 43
1. Threshold Criteria 43
2. Primary Balancing Criteria 44
3. Modifying criteria 44
B. Application of Evaluation Criteria to
Alternatives 4 & 8 45
Threshold Criteria 45
1. Protection of suman Health and the
Environment 45
2. Compliance with Applicable or Relevant and
Appropriate Requirements. 46
Balancing Criteria ...*..... 48
3. Long-term Effectiveness and Permanence ........ 48
4. Reduction cf Tox^city, Mobility or
Volume Thrc 70. Treatner . 48
5. Sh. :-t-term £ffectivene 49
6. Inr lementability 50
7. Cost 51
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- ... TABLE 07 CONTENTS (Cont.)
Page
Modifying .Criteria 51
8. State Acceptance 51
9. Community Acceptance 51
X. SELECTED REMEDY AND PERFORMANCE STANDARDS 52
A. Soil Excavation 52
B. Soil Treatment And Disposal 55
C. Building Demolition 56
XI. STATUTORY DETERMINATIONS , 57
A. Protection of Human Health and the Environment . 57
B. Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) 58
1. Chemical-Specific ARARs 58
2. Location-Specific ARARs 59
3. Action-Specific ARARs 59
C. Criteria, advisories, or Guidance To Be
Considered (TBCs) 60
D. Cost Effectiveness 61
E. Utilization of Permanent Solutions and
Alternative Treatment Technologies to the
Maximum Extent Practicable 61
F. Preference for Treatment as Principal Element .. 61
XII. DOCUMENTATION OF SIGNIFICANT CHANGES 61
PART III - RESPONSIVENESS SUMMARY
I. INTRODUCTION 62
II. MIGRATION OF LEAD UNDER COVERED AREAS 62
III. EXCAVATION OF LEAD TO A DEPTH OF ONE FOOT 63
IV. HOMEOWNER'S CONCERN IF HOMES ARE NOT PURCHASED 64
V. FAIR COMPENSATION TO HOMEOWNERS 64
VI. COMMENTS RECEIVED PRIOR TO PUBLIC COMMENT PERIOD 65
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RECORD OF DECISION AMENDMENT
ABEX CORPORATION SOPERFUND SITE
PART I - DECLARATION
I. SITE NAME AND LOCATION
Abex Corporation Superfund Site
Portsmouth, Virginia
Operable Unit One
II. STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) Amendment revises the ROD
signed on September 29, 1992, for the Abex Corporation Site
(Site), in Portsmouth, Virginia. This ROD Amendment presents the
revised remedial action selected for Operable Unit One (OU1) at
the Site. This revised remedy was chosen in accordance with the
requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended,
42 U.S.C. §§ 9601 et seq. and, to the extent practicable, the
National oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 C.F.R. Part 300. This decision document explains the
factual and legal basis for revising the remedy for this Site.
An index of documents contained in the Administrative Record is
included in Appendix A.
III. ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. § 9606, that actual
or threatened releases of hazardous substances from this Site, as
discussed in Section VII (SUMMARY OF SITE RISKS AND CLEANUP
LEVELS) of this ROD Amendment, if not addressed by implementing
the remedial action selected in this ROD Amendment, may present
an imminent and substantial endangerment to public health,
welfare, or the environment.
IV. DESCRIPTION OF THE SELECTED
By this ROD Amendment, EPA is revising the remedy previously
selected to address OU1 for the Site. This operable unit
addresses contaminated soil and waste material present within an
approximately 700-foot radius.of the former Abex foundry facility
located at the Site. The former foundry buildings will also be
addressed as part of OU1. The selected remedial action for OU1
addresses the threat at the Site by excavating and treating the
contaminated soil and waste material, by demolishing the
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buildings associated with the former foundry operation, and by
implementing institutional controls in commercial/industrial
areas and under permanently covered areas where some contaminated
soil exceeding health-based levels will remain in place. Treated
material, soil containing low levels of contamination that do not
require treatment, and building debris will be disposed of off-
site in a permitted Resource Conservation and Recovery Act (RCRA)
landfill.
Response actions began at this Site in 1986 when EPA
identified high lead concentrations in the Abex foundry waste
within the Abex Lot bounded by Seventh, Green, and Brighton
Streets, in Portsmouth, Virginia and in soil of neighboring
residential lots. Pursuant to a Consent Order signed with EPA in
August of 1986, Abex excavated and removed contaminated soil at
varying depths (generally 6 to 12 inches) from residential areas
around the Abex Lot, primarily in portions of the Washington Park
housing development (hereafter Washington Park development), the
Effingham Playground, and around the Seventh Street row homes.
Additional high lead concentrations in soil in residential
areas were identified in the Remedial Investigation and
Feasibility Study (RI/FS) for OU1. The RI/FS was completed in
February of 1992. Pursuant to a unilateral administrative order
issued by EPA in March of 1992, Abex excavated and removed
additional contaminated soil to a depth of approximately twelve
inches in portions of the Washington Park development and the
Effingham Playground. Excavation and removal of surface soil
contamination in the Effingham residential areas as required
under the March, 1992 Order has not been completed because the
homeowners in the two-block residential area south of the
Effingham Playground chose to wait for the long-term remediation
involving both surface and subsurface excavation.
In April of 1992, EPA and the Commonwealth published for
public comment a Proposed Plan describing several proposed
remedial alternatives for the Site. Alternative 4 was selected
as the preferred alternative. Public comments were received on
the Proposed Plan and in September of 1992, EPA and the
Commonwealth published a ROD selecting a final remedy for the
Site. The preferred alternative selected in the September 1992
ROD (Alternative 4, with some minor modifications) required
excavation down to the water table of soil exceeding 500 mg/kg of
lead in residential areas and excavation down to the water table
of soil exceeding 1,000 mg/kg of lead in commercial/industrial
areas. Alternative 4 is described more fully below.
On October 19, 1993, Abex, one of the potentially
responsible parties (PRPs) for the Site, submitted proposed
changes to the ROD based on new information obtained from the
City of Portsmouth (the "City") on proposed zoning and land-use
plans and new institutional controls on future excavation within
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the Site area." EPA conducted public availability sessions from
November 8, 1993 to November 10, 1993 to solicit input from the
affected residents on the PRPs' proposed changes to the ROD.
Public availability sessions are small meetings that provide
individuals and small groups with an opportunity to meet with EPA
to voice their opinions about site issues. The private
homeowners responded favorably to the proposal. Some of the
Washington Park development residents were still interested in
permanent relocation, however, the majority of the residents were
generally supportive of the proposal. Both the City and the
Portsmouth Redevelopment and Housing Authority (PRHA) have
indicated their support for the 1993 Abex proposal as well.
After thoroughly evaluating the proposal and considering the
responses to the proposal received from the affected residents
during the November 8, 1993 public availability sessions, EPA
issued a Proposed Plan to amend the 1992 ROD with its revised
preferred remedy and published Notice of the Public Comment
Period on February 17, 1994 in the Virginian-Pilot/Ledaer-Star.
EPA held public availability sessions on February 23, 1994
in Portsmouth, VA, during the 30-day public comment period on the
Proposed Plan. EPA also held a public meeting on February 24,
1994 to formally discuss the Proposed Plan and to receive
comments.
The major components of the revised selected remedy
(Alternative 8 in the Proposed Plan to Amend the 1992 ROD) for
OUl are set forth below. The revised selected remedy is based on
the premise that: (l) the Effingham residential area, the
Effingham playground, and the Seventh Street row homes will be
rezoned commercial/industrial and will be occupied in a manner
not inconsistent with such zoning classification; and (2) the
institutional controls described in the remedy are in place no
later than the completion of the preliminary remedial design for
the remedy. If the proposed rezoning of residential areas to
commercial/industrial has not occurred by that time, the areas
specified above must be excavated to meet residential health-
based levels, i.e.. soil exceeding 500 mg/kg lead must be
excavated down to the water table. If all necessary
institutional controls are not approved by EPA and in place by
that time, soil exceeding 500 mg/kg lead in the first foot and
soil exceeding 1,000 mg/kg lead between twelve (12) inches and
the water table will be excavated in areas within the scope of
OUl which are zoned commercial/industrial (except the Abex Lot,
which will be addressed to the residential cleanup requirements).
• In areas zoned for residential use at the date of completion
of the preliminary remedial design, surface and subsurface
soils located between the surface and the water table which
contain greater than 500 mg/kg lead will be excavated.
Soils exceeding 500 mg/kg lead in the Abex Lot will also be
excavated to the depth of the water table.
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In areas -zoned for commercial/industrial or other non-
residential uses (except the Abex Lot) at the date of
completion of the preliminary remedial design, soil located
between the ground surface and one foot depth which contains
greater than 500 mg/kg lead will be excavated, and soil
between one foot and two feet which exceeds 1,000 mg/kg lead
in industrial areas will be excavated. Institutional land-
use controls will be implemented to control any future
excavation below two feet and to prevent exposure to
contaminated soil.
EPA will review, comment upon, and approve all institutional
controls to be implemented as part of the remedial action
for the Site. These institutional controls may include: an
ordinance or regulation requiring a permit for, and imposing
restrictions on, excavation in areas within OU1 and
requiring notice to EPA, the City, PRHA, and the public
prior to excavation in such areas; the inclusion of
provisions in deeds for properties within OU1 providing
notice of this CERCLA remedy and restricting excavation on
such properties; and the placement of underground "warning
sheets" in excavated commercial/industrial areas before
backfilling with clean soil. The institutional controls
must be sufficient to ensure (1) that soils below two feet
in areas of OU1 zoned commercial/industrial, as well as
soils beneath permanent covers in all areas, are not
disturbed after completion of this remedy without prior
notice to EPA, the City, PRHA, and the. public, and (2) if
such soils are to be disturbed, the soils are managed in a
manner which will not endanger public health or the
environment.
Excavated soil and waste materials from the Site will be
tested using the Toxicity Characteristic Leaching Procedure
(TCLP) to determine whether excavated soil is a RCRA
characteristic hazardous waste. Soil which is determined to
be a RCRA hazardous waste will be treated on-site prior to
off-site land disposal. Soil which is not a RCRA hazardous
waste will be treated to the extent and in the manner as may
be required by the state to which such soils will be
transported for off-site disposal. Conventional earth-
moving equipment will be used to excavate and load the
contaminated soil.
Excavated soil and waste materials that exhibit toxicity
using the TCLP will be treated by mixing such soil and waste
materials with chemicals/reagents. The mixing will be
contained in above-ground equipment on-site to create a
final product that encapsulates and immobilizes lead and
other metals. Specific chemicals to be used in the process
remedial design phase of the project. Treated material will
be tested using TCLP to ensure that it no longer exhibits
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toxic-characteristics. Soil/waste materials that no longer
exhibit toxicity using TCLP shall be disposed of off-site in
a permitted RCRA Subtitle D landfill. Soil/waste materials
that continues to exhibit toxicity shall either be subject
to additional treatment to further reduce toxicity, or be
disposed of off-site in an approved RCRA Subtitle C
landfill, after RCRA Land Disposal Restriction (LDR)
requirements have been met.
Soil beneath existing permanent covers such as buildings,
parking lots, sidewalks, and streets will not be removed.
These covers will be maintained and institutional land-use
controls will be used to prevent future exposure to
contaminated soil beneath such covers. The following
existing permanent covers are not included in this provision
and will be removed as part of the remedy: the asphalt
covers on the Abex Lot, the McCready Lot, and the Holland
Property, the former foundry buildings on the Holland
Property, and, if rezoning occurs, the Effingham and Seventh
Street residential homes1.
All excavated areas will be backfilled with clean fill.
Formerly vegetated areas will be graded and reestablished to
their.original condition, to the extent practicable.
Where excavation to the depth of the water table is
required, excavation will occur during the period when the
water table is at the seasonally low elevation, to the
extent practicable.
Prior to the excavation of contaminated soil on the Abex
Lot, the McCready Lot, and the Holland Property, existing
asphalt and concrete will be removed and tested using the
TCLP. Debris which is determined not to be RCRA hazardous
waste will be disposed of as construction and demolition
debris. Debris that tests as hazardous under TCLP will be
disposed of in accordance with RCRA Subtitle C requirements,
including LDR regulations.
The buildings associated with the former foundry operation
on the Holland property, the Effingham residences, and the
Seventh Street row homes will be demolished prior to the
1 For purposes .of this ROD Amendment, the term "permanent
cover" shall not include buildings with crawl spaces that have
dirt floors. Thus, if the Effingham and Seventh Street
residential areas are not rezoned for commercial/industrial use
by the completion of the preliminary remedial design and the
homes are not demolished, further geotechnical investigations
will be undertaken to determine an appropriate method of
remediating the crawl spaces.
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excavation of - contaminated soil on these properties.
Building debris resulting from such demolition will undergo
TCLP testing and, if the debris tests as hazardous waste, it
will be disposed of off-site in a landfill permitted in
accordance with the RCRA and in accordance with RCRA LDR
regulations. Equipment maintained by the current owner of
the Holland Property within the buildings will have to be
removed. Equipment which is contaminated with or
constitutes a RCRA hazardous waste will be disposed of off-
site in accordance with the requirements of RCRA Subtitle C,
including the LDR requirements. Equipment which is not
contaminated with or is not a RCRA hazardous waste, or which
is decontaminated so that it no longer is contaminated with
or constitutes a RCRA hazardous waste, may be used or
disposed of off-site in a manner not inconsistent with
applicable laws or regulations. Residuals generated as a
result of decontamination activities will be tested under
TCLP and disposed of as required by RCRA Subtitle C and any
other laws or regulations which may be applicable to such
wastes.
Temporary relocation will be provided to residents while
excavation is occurring around residential units. The
extent of soil to be removed around each residential unit
will be determined during the remedial design phase. The
specific arrangements for temporary housing will be based oh
the extent of soil to be removed and the needs of the
impacted residents. Efforts will be made to minimize
inconvenience to residents. To the extent practicable, the
U.S. Department of Transportation Uniform Relocation Act and
accompanying regulations will used as guidelines.
Discharge of decontamination water and any other water
generated during remedial activities will meet Virginia
Pollution Discharge Elimination System (VPDES)
requirements developed pursuant to the Federal Clean Water
Act, 31 U.S.C. §§ 1251 et sea.. and the Virginia State Water
Control Law, Code of Virginia §§ 62.1-44.2 et sea. It is
anticipated that most of the water generated by the Site
activities will be recycled or re-used in the treatment
process. The water that is not recycled will be treated,
tested and sent off-site either to a wastewater treatment
facility (if the water does not exceed the levels of lead
that the treatment facility is permitted to accept) or
treated on-site and discharged into the Elizabeth River. If
the water is to be discharged into the Elizabeth River, it
will have to meet all VPDES requirements.
Dust suppression measures will be used to ensure that
unacceptable releases of air-borne contamination do not
occur. Air will be monitored for both dust and lead levels
during remedial activities to protect the health of on-
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site workers and the community. Sampling of the interior of
homes in the vicinity of excavation will also be performed
before-,-during, and after excavation to assure that the
National Emission Standards for Hazardous Air Pollutants
(NESHAPs) developed under the Federal Clean Air Act, 40
C.F.R. SS 50.12 and 50.6, and the Virginia Regulations for
the Control and Abatement of Air Pollution (VRCAAP), VR §
0401-0101, are not exceeded.
Transportation, storage, treatment and disposal of soil and
debris will be in compliance with applicable provisions of
RCRA, federal regulations promulgated thereunder pursuant to
HSWA at 40 C.F.R. Parts 260-271; Department of
Transportation Report at 40 C.F.R. Part 171-177; the
Virginia Hazardous Waste Management Regulations (VHWMR) Part
VII, Regulations Applicable to Transporters of Hazardous
Waste (VR §§672-30-1), or Virginia Solid Waste Management
Regulations (VR §§672-20-10).
Excavated soil and waste materials shall be temporarily
staged on-site prior to treatment and/or transportation to
an off-site disposal facility; to the extent practicable,
excavated soil and waste material shall be staged in areas
of existing contamination, e.g.. the Abex Lot, the Holland
Property, McCready Lot, or the vacant lots; containment
measures such as berms and temporary covers shall be used in
areas with staged material to ensure that there are no
unacceptable air or water-borne releases of contamination
from these areas; these measures shall be sufficient to
provide protection in the event of flooding; areas that are
used to stage excavated material shall be secured with a
fence to prevent trespassing. In all instances where soil
and waste materials are staged in areas where cleanup has
previously occurred or are otherwise not contaminated above
levels requiring excavation, soil and waste material shall
be staged in containers in accordance with RCRA regulations
contained in 40 C.F.R. Part 268.50; containers used shall be
in compliance with VHWMR § 10.8 Use and Management of
containers.
V. STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action and is cost-effective. The remedy utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element.
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Because this remedy will result in hazardous substances
remaining on-site above health-based levels (i.e.. 500 mg/kg lead
under covered areas in Washington Park and above 1,000 mg/kg lead
in soil below two feet in commercial/industrial areas), a review
will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment. Such
reviews will be conducted every five years thereafter to
ascertain that the hazardous substances remaining at the Site are
properly contained and do not represent an exposure at the Site.
Peter H. Kostmayer . . Date
Regional Administrator
Region III, U.S. EPA
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RECORD OF DECISION AMENDMENT
ABEZ CORPORATION SOPERFUHD SITE
PART II - DECISION SUMMARY
I. INTRODUCTION
The Abex Site (the "Site") is located in the eastern section
of Portsmouth, Virginia, approximately 1.2 miles southwest of the
confluence of the southern and eastern branches of the Elizabeth
River (See Figure 1). Operable Unit One (OU1) of the Site
encompasses a several block area with numerous parcels of land
(See Figure 2). This operable unit contains the former Abex
brass and bronze foundry, which is comprised of five buildings
(hereinafter referred to as the Holland Property), and associated
former waste sand disposal areas (hereinafter referred to as the
Abex Lot and the McCready Lot). Other areas within the
approximately 700-foot OU1 radius found to have contamination
associated, at least in part, with the former foundry operation
will also be addressed in this remedial action.
The locations of the OU1 properties are as follows: the
Holland Property is located in the block bounded on the east by
Seventh Street, on the south by Randolph Street, on the west by
Green Street, and on the north by Brighton Street; the Abex Lot
is located immediately north of the Holland Property; the
Washington Park development is located both northeast of the
Holland Property and north of the Abex Lot; the Effingham
Playground is located west of the Holland Property; private
residential properties (hereafter referred to as the Effingham
residential area) are located south of the playground and south-
west of the Holland Property; a drug rehabilitation center and a
small shopping center are located south of the Holland Property;
the McCready Lot is located southeast of the Holland Property at
the northwest intersection of Randolph and Seventh Street;
several row homes located north of the McCready Lot and
immediately east of the Holland Property; and several vacant lots
located east of Seventh Street. The Washington Park development,
the Effingham Playground, and the Effingham residential area are
currently zoned for residential use. The remaining properties
are zoned for commercial/industrial use (see Figure 2).
The Remedial Investigation (RI) for OU1 identified lead as
the primary contaminant of concern at the Site. Lead was
detected in soil on the Holland Property, under the asphalt-
capped Abex and McCready Lots, and in surrounding residential and
commercial/industrial areas at levels that pose an actual or
potential threat to human health and the environment.
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FIGURE 1 - sTJf LOCATION MAP
FOUNDRY SAND DISPOSAL AREA
PORTSMOUTH
FORMER LOCATION OF ABEX FOUNDRY
SOURCE: USGS 7.6 MINUTE QUADRANGLE
FOR NORFOLK SOUTH. VIRGINIA
DATED 1966. AND PHOTOREVISB)
1866.
10b> 0 1000 2000 3000
SCALE IN FEET
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N
in
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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A brasVand bronze foundry was operated at the Site from
1928 to 1978. The foundry melted used railroad car journal
bearings which were over 80% bronze and poured the molten
material into sand molds to cast new railroad car bearings.
These sand casts eventually became laden with heavy metals, such
as lead, antimony, copper, tin, and zinc. During operation, the
foundry also produced stack emissions of fine particulate
material associated with facility processes.
The National Bearing Metal Corporation purchased the foundry
property in May of 1927 and operated the foundry at the Site from
1928 until December of 1944. American Brake Shoe Company bought
the foundry in December of 1944 and operated it until May of
1966. At that time, Abex purchased the facility and operated the
foundry until it closed in 1978. During Abex's operation of the
foundry, waste sand was disposed of in an approximately one-acre
area immediately north of the foundry building. When the foundry
operation closed, Abex graded this disposal area (which is
referred to as the Abex Lot) and secured it with a seven foot
cyclone fence. Pneumo Abex Corporation, the successor of Abex
Corporation, still owns most of the Abex Lot. In 1977, Runnymede
Corporation, a real estate investment company, purchased a small
parcel of the Abex Lot from Abex. Runnymede still owns this
parcel, but no further development has occurred on it.
In 1984, Holland Investment and Manufacturing Corporation
(hereinafter Holland Investment) purchased the portion of the
Site that contains the foundry building and several smaller
associated structures. Holland Investment allowed John C.
Holland Enterprises, Inc., a trash hauling business, to conduct
vehicle service and maintenance on the property.
During operation and following closure of the foundry, many
of the parcels located nearby changed ownership and were
redeveloped for other uses. These areas include the Washington
Park development, the drug rehabilitation center, the Effingham
Playground, and numerous private residences.
In January of 1983, an EPA contractor visited the Site to
observe the conditions at the Abex Lot. No sampling was
conducted during this preliminary assessment. EPA contractors
returned to the Site in June of 1984 to perform a site inspection
and collect several samples from the Abex Lot. Sample results
detected high levels of lead (up to 10,400 mg/kg), zinc, copper,
tin, and antimony. A sample which was to serve as an indication
of the background concentration of lead in the soiL, was
collected east of the Site and also had a lead concentration of
2,750 mg/kg.
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In April "of 1986, EPA collected additional soil samples from
the Washington Park development and other properties adjoining
the ex Si*f < The analytical res i ts found lead concentrations
of up to i2,800 mg/kg in the samples collected. Pursuant to tne
authority granted in Section 106 of CERCLA, 42 U.S.C. 9606, EPA
entered into a Consent Order with *bex in August of 1986 for the
excavat..-n and removal of contamir :ed soil at varying depths
(generally 6 to 12 inches) from certain residential areas around
the Abex Lot. The areas to be addressed included portions of the
Washington Park development, the Effingham Playground, and the
Seventh Street row homes. All excavated areas were filled with
clean soil and revegetated. Abex also paved and fenced the Abex
Lot and the McCready Lot.
The analytical data collected at the Site were used to
evaluate the relative hazards posed by the Abex Site using EPA's
Hazards Ranking System (HRS). EPA uses the HRS to calculate a .
score for hazardous waste sites based upon the presence of
potential and observed hazards. If the final HRS score exceeds
28.5, the site is placed on the National Priorities List (NPL),
making it eligible to receive Superfund monies for remedial
cleanup. An HRS score of 36.53 was calculated for the Abex Site.
As a result, EPA proposed the Abex Site for inclusion on the NPL
on June 24, 1988 (53 FR 23988). The Site was placed on the list
on August 28, 1990 (55 FR 35502).
On June 2, 1989, pursuant to Section 122 of CERCLA,
42 U.S.C, S 96*22, EPA issued special notice letters to Abex
Corporation and the Holland Investuent offering them the
opportunity to perform the Remedial Investigation/Feasibility
Study (RI/FS) for the Site. On October 10, 1989, the Virginia
Department of Environmental Quality (VDEQ), serving as the lead
agency, entered into an Administrative Order on Consent with Abex
pursuant to Section 106 of CERCLA, 42 U.S.C. S 9606. Under the
Order, Abex agreed to conduct the RI/FS at the .Site to determine
the nature and extent of Site contamination and to identify
remedial alternatives for Site-related contamination of concern.
Based on the findings of the draft RI/FS report submitted 1
October of 1991 and the final RI/FS report dated February of
1992, EPA determined that lead-contaminated surface soil
exceeding 500 mg/kg within the Effingham residential area, and at
a few additional locations in the Washington Park development and
the Effingham Playground, presented a short-term threat to human
health. As a result, pursuant to Section 106 of CERCLA, 42
U.S.C. S 9606, EPA issued a unilateral administrative order on
March 30, 1992 to Abex requiring Abex to remove such soil from
the Site. Abex agreed to perform 'he removal action and, to
date, has excavated and removed additional contaminated surface
soil in the Washington Park development and the Effingham
Playground. Plans to remove soil in the Effingham residential
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area have be«ri temporarily suspended because the impacted
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stated their''continued interest in being permanently relocated.
Both the City and the PRHA have indicated their support of the
Abex proposal". After thoroughly evaluating the proposal and
considering the responses to the proposal received from the
affected residents during the November 8, 1993 public
availability sessions, EPA published the Proposed Plan to Amend
the September, 1992 ROD with its revised preferred remedy.
V. SCOPE AMD ROLE OF THIS RESPONSE ACTION
As with many Superfund sites, the problems at the Abex
Corporation Site are complex. As a result, EPA has organized the
work into two operable units (OUs). These OUs are:
• OU1: Contamination in the soil and waste sands on the
Holland Property, the Abex Lot, the McCready Lot and in
the surrounding properties within an approximate 700-
foot radius of the Abex foundry facility.
• OU2: Potential contamination of the shallow and deep
aquifers, ecological impacts, including further
investigation and analysis of surface and sediment
quality, and additional soil contamination that may
exist beyond the approximate 700-foot radius being
addressed in OU1.
The subject of this ROD Amendment, OU1, is lead
contamination in soil within the 700-foot study radius around the
former Abex foundry. The primary exposure pathway of concern at
this Site is incidental ingestion of contaminated soil. Based on
results of EPA's Lead Uptake Biokinetic Model, children are
exposed to an unacceptable health risk when the average lead
concentrations in surface soil exceeds 400 mg/kg. The purpose of
this response is to protect human health and the environment by
preventing current or future exposure to the contaminated soil.
As part of OU2, additional RI/FS activities will be
performed to fully characterize the nature and extent of
groundwater contamination. The second operable unit will also
include an investigation of additional soil contamination at
distances greater than 700 feet from the foundry facility, as
well as off-site ecological impacts.
VI. SUMMARY OF SITE CHARACTERISTICS
A. General Overview
The Abex Site is located in the urban environment of
Portsmouth, Virginia, approximately one-half mile to the west of
the south branch of the Elizabeth River. The Site is relatively
15
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flat and is approximately five to ten feet above mean sea level.
A review of aerial photographs from 1937 reveal extensive
surficial drerinage surrounding the Site. However, by 1964,
drainage was largely confined to Gander Creek, a channelized
canal flowing from east to west just north of the Abex Lot. At
the present, most drainage occurs through a network of catch
basins and storm sewers.
The Site is located in one of the oldest sections of the
City of Portsmouth (hereinafter the City). The area was
incorporated into the City's limits in 1784. The U.S. Naval
Shipyard, located less than a mile to the southeast, commenced
operation in 1767 and presently encompasses about 800 acres. The
Portsmouth area experienced rapid growth during World War I and
II when the Navy expanded its shipyard, hospitals, and docking
facilities.
The population in the one-mile radius surrounding the Site
varied during the period when the foundry was operating. From
1930 to 1950, the population in this area grew from 27,470 to
30,930. Since 1950, the population has been declining. In 1960,
the population declined to 27,575; in 1970 it decreased to
19,940; and in 1980 it went down to 15,117.
The Elizabeth River Basin, which surrounds Norfolk,
Portsmouth, and Chesapeake, drains approximately 300 square
miles. The river basin is heavily industrialized and receives
wastewater discharges from U.S. Naval facilities, heavy industry,
major municipal treatment facilities, urban runoff, and boating
and docking facilities.
Annual rainfall in the Site area is between 45 and 50
inches. Wind direction for the Portsmouth and surrounding area
is predominantly north-northeast and south-southwest.
In general, the former foundry property and the surrounding
700-foot radius study area are underlain by a veneer of
undistinguished fill material, sand, and fine grained sediments.
Groundwater movement beneath the study area is largely confined
to the sand-dominated strata.
Portsmouth lies in the Coastal Plain physiographic province
and, in general, is underlain by a thick sequence of
unconsolidated sediments consisting primarily of sand, gravel,
silt, clay and some shell material. These sediments thicken from
west to east in a wedge-like form and are .immediately underlain
by igneous and metamorphic bedrock. The depositional history of
the unconsolidated sediments is complex and has resulted in what
is generally an alternating sequence of sand and fine grain
sediment layers.
16
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In the vicinity of Portsmouth, large-scale groundwater
movement occurs only within confined aquifers. Except for the
uppermost aquifer, the Columbia Group, each aquifer is separated
from the underlying aquifer by a confining unit. Most of the
groundwater used in the area for potable purposes, is withdrawn
from the confined aquifers. At the present time, very little
groundwater withdrawn from the unconfined Columbia Group Aquifer
is utilized for potable purposes. :
B. Summary of RZ Findings
The primary focus of the OU1 RI was to evaluate possible
lead contamination in soil on and around the foundry property.
In addition, the RI included a limited investigation of ground-
water, surface water, and sediments potentially impacted by the
Site. ..-..-•
Soil contamination was investigated by sampling and testing
over 1,000 samples for lead content. Of these samples, over 550
were also analyzed for fourteen other metals. Soil samples were
collected either using a hand auger or through soil borings. A
total of 206 locations were sampled using the hand auger. Sample
locations were established primarily through use of a 100-foot
grid system over the 700-foot radius study area. At each
location, a minimum of two samples were collected - one at the 0
to 0.5 foot depth and a second at the 1.5 to 2 foot depth.
Additional samples were collected to a maximum depth of 3 to 3.5
feet where elevated lead concentrations were observed.
Soil borings ranging in depth from 11 to 26 feet were
performed at 34 locations primarily in the Abex Lot and in and
around the Holland Property. A minimum of five samples were
collected at each location to characterize the stratigraphy of
the water table aquifer. The number of samples analyzed varied
depending on the location and the conditions encountered. Most
analyses were for lead or for the primary pollutant list of
fourteen metals.
Sweep samples for dust were also collected from the interior
of the foundry building and from the attics of two Seventh Street
row homes. A number of the dust and soil samples collected on
the Holland Property and in the Abex Lot were analyzed for the
complete list of priority pollutants.
The major finding of the RI was that both surface and
subsurface soils are contaminated with lead in residential and
non-residential areas. Soil ("floor dirt") and dust throughout
the interior of the foundry building on the Holland Property was
found to contain lead levels of up to 100,000 mg/kg. Outdoor
soil on the Holland Property contains lead levels of up to 58,000
mg/kg within the top two feet. Waste sand beneath the asphalt
cap on the Abex Lot has lead concentrations ranging up to 24,000
17
-------
mg/kg. Lead- levels of up to 4,750 mg/kg occur within the top two
feet of soil under the asphalt within the McCready Lot.
—. e--
Surrounding areas containing lead-contaminated soil
associated with the Site include portions of the Washington Park
development, the Effingham Playground, the Effingham residential
area, the Seventh Street row homes, the drug rehabilitation
center property, and vacant lots east of Seventh Street.
Lead levels of up to 46,500 mg/kg were detected in soil at
depths of one to four feet in portions of the Washington Park
Housing Project. Subsurface soil in the Effingham Playground
contains lead levels of up to 5,000 mg/kg. Contaminated surface
soil (generally 6 to 12 inches) in both Washington Park and the
Effingham Playground were previously excavated and removed by
Abex pursuant to a Consent Order signed with EPA in August, 1986.
A few additional areas in the Washington Park development and the
Effingham Playground were identified during the investigation as
.having surface soil contamination above 500 mg/kg. Soil in these
areas was excavated and removed by Abex pursuant to a. unilateral
order issued by EPA in March of 1992.
Surface and subsurface soil within the Effingham residential
areas have lead concentrations of up to 8,000 mg/kg. Additional
sampling performed as part of the 1992 removal action detected
elevated levels of lead ranging up to 3,739 mg/kg in crawl spaces
beneath eleven of sixteen homes sampled in this area.
Soil in lots associated with the Seventh Street row homes
contain lead at levels up to 7,000 mg/kg at 0 to 2 feet in depth.
Surface soil contamination in the row home lots was previously
addressed by Abex under the 1986 Consent Order. Attics of two
Seventh Street homes contain dust with lead levels of up to 7,030
mg/kg.
Surface soil within the drug rehabilitation center property
contains lead at levels of up to 9,300 mg/kg. Lead has also been
detected in surface soil of the vacant lots east of Seventh
Street at levels of up to 1,200 mg/kg, with subsurface soils
containing lead of up to 6,000 mg/kg.
A limited hydrogeologic investigation, was undertaken at the
Site to assess the impact of contamination on the surf iclal
aquifer. Four monitoring wells, three piezometers, and numerous
soil borings were installed to gain an understanding of the
materials and contaminant distribution in the upper aquifer. Two
monitoring wells were located in the Abex Lot; one well was
located in the McCready Lot; and one well was located immediately
north of the Seventh Street row homes. The wells were drilled to
approximately fourteen feet below ground surface; the piezometers
(wells about 2" to 4" in diameter that are used to measure
subsurface pressure and water levels) were drilled to fifteen
18
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feet below"surface; Ground water was encountered from three to
six feet below surface across the Site.
Groundwater data from the Abex property indicates that lead
has entered the surficial ground water in the source area either
through migration or through past disposal practices. Elevated
concentrations of lead were present in filtered samples collected
in one of the monitoring wells in the Abex Lot (MW-1). Lead
levels of 31 micrograms per liter (ug/1) and 24 ug/1 were
detected during two separate sampling events. EPA recommends a
cleanup level of 15 ug/1 for lead in groundwater. Filtered
samples collected in the other three wells did not exhibit
elevated concentrations of lead. The surficial aquifer and the
deeper aquifer are not currently used for drinking water supplies
in the area of the Site. Further investigation of contamination
in the deeper aquifer and the hydraulic relationship between the
surface and deeper aquifers will be undertaken as part of OU2.
Surface water and sediment samples were collected from four
catch basins within the 700-foot study area. Elevated metal
concentrations were observed in both surface water and sediment
samples. The significance of the metal concentrations to the
Abex Site is unclear. Further investigation and analysis of
surface water and sediment quality at the Site, including
potential ecological impacts, will be performed as part of OU2.
VIZ. SUMMARY OF SITE RISKS AMD CLEANUP LEVELS
This Section summarizes relevant portions of the baseline
risk assessment from the September, 1992 ROD. The following is an
excerpt from the Summary of Site Risks Section in the September,
1992 ROD.
An assessment of the potential risks posed to human health
and the environment was completed in accordance with the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP).
The baseline risk assessment provides the basis for taking action
and indicates the exposure pathways that need to be addressed by
the remedial action. It identifies the risks that could exist if
no action were taken at the Site. The baseline risk assessment
for the Abex Site was completed in February of 1992 and is part
of the Administrative Record.
In general, a baseline risk assessment is performed in four
steps: (1) data collection and evaluation; (2) the exposure
assessment; (3) the toxicity assessment and; (4) risk
characterization. This portion of the amended ROD will summarize
the findings during each of these steps of the baseline risks
assessment for the Abex Site.
19
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A. Identification of Contaminants of concern
Lead_is,_the principal contaminant of concern at this Site
due to its known health effects and its widespread presence in
surface and subsurface soil in the residential areas, as well as
the foundry properties. Other contaminants present in
residential areas in levels of concern, along with lead, include
antimony, nickel, tin, copper, and zinc. These contaminants are
all known to be present in waste sands from the foundry
operation. Other contaminants present at levels of concern at
the Holland Property, the Abex Lot, or the McCready Lot include
cadmium, chromium, silver, polynuclear aromatic hydrocarbons
(PAHs) and polychlorinated biphenyls (PCBs).
The two media of primary concern at this Site are soil and
groundwater. An overview of the extent of contamination in the
soil at the Site is presented in Table 1. The data is presented
for the three residential areas - the Washington Park
development, the Effingham residential area, and the Seventh
Street row homes; the Effingham Playground; the foundry
properties, including the Holland Property, the Abex Lot, and the
McCready Lot; and for the vacant lots. The number of samples
collected (designated as *n'), the mean (or average)
concentrations, and the upper 97.5 percentile confidence limit
concentrations are presented in Table 1 for both surface soil (0
- 12") and subsurface soil (> 12') data. The term "upper 97.5
percentile confidence limit" is a statistical term used in
describing how well the data collected reflect actual conditions.
There is a 97.5% probability (i.e.. 39 times out of 40) that the
actual mean concentration for the contaminant of concern listed
is below the upper confidence limit value.
Since lead is relatively immobile in the environment, the
OU1 groundwater investigation in the RI was limited to four wells
in the .surficial aquifer. Groundwater in the surficial aquifer
was found to exceed the EPA's recommended cleanup level for lead
in one well on the Abex Lot. The surficial aquifer and the
deeper confined aquifer are not currently used as drinking water
supplies. Further investigation of potential groundwater
contamination will be performed as part of OU2 to assess
potential future risks and the need for possible remediation.
The discussion of Site risks presented below will focus on
contamination in the soil media.
B. Hunan Health Exposure Assessment
The purpose of the exposure assessment in the baseline risk
assessment is to determine exposure pathways that exist at a site
and to quantify the exposure associated with each pathway. An
exposure pathway exists if there are: (1) contaminants at a site
at levels of concern; (2) individuals that may come in contact
20
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TABLB 1 -
AREAS
Contflnnwt
• EXTENT 07 SOIL CONTAMINATION AT THE ABBZ 8ITB
n
SUR7ACE SOIL
MEAN
(mg/kg)
97.5th
% UCL
(mg/kg)
SUBSURFACE SOIL
n
Bffinghaa Playground (Cont.)t
Tin
Zinc
5
5
63
381
132
754
32
32
MEAN
(mg/kg)
423
1,503
97.5th
% UCL .
(mg/kg)
2,117
6,836
Holland Property/Abes Lot/MeCready Lots
Lead
Antimony
Cadmium
Chromium
Copper
Nickel
Silver
Tin
Zinc
Total
PAHS
Total
PCBs
41
33
33
33
33
33
33
33
33
340
14
33,000
590
15
185
54,000
255
18
2/872
8,400
29
5
46,800
928
21
256
90,400
397
26
4,261
11,800
32
12
46
45
41
44
45
45
39
45
45
1
3
8,937
104
4
12
15,055
71
5
1,861
3,290
0.099
13.5
44,954
659
18
.38
87,866
395
26
12,720
14,658
45.4
vacant Lots/Drug Rehabilitation Centers .
Lead
Antimony
Copper
Nickel
Tin
Zinc
86
22
22
22
22
* 22
609
7
619
10
100
549
848
9
1072
14
154
743
101
30
30
30
30
30
849
18
852
16
298
962
7,345
141
5,803
67
1,738
5,286
KEYS
97.51 Utt •
th« tutor of M>plM collected •
the average concentration of the saaplea collected; vnlt* tr«
•Uligr«p«r kilegrw .
Upper Conffdmec Lfait; th« eoncantrstlon tt which th*r« i> •
97.5 X probability that th« Mtucl mm conc«ntr«t1on it b*loM
-------
TABLE 1 •
AREAS
ContMfrantL_. .«^-
• BXTBHT OF SOIL CONTAMINATION AT TEE ABBX SITE
n
SUR7ACE SOIL
MEAN
(ng/Jcg)
97.5th
% DCL
(mg/kg)
Washington Park Bousing Projects
Lead
Antimony
Copper
Nickel
"tin
Zinc
135
6
6
6
6
6
260
7
311
7
55
315
289
10
565
13
89
560
SUBSURFACE SOIL
n
93
77
77
77
77
77
MEAN
(mg/kg)
2,926
22
2,079
26
580
1,979
97.5th
% UCL
(mg/kg)
20,744
138
14,698
146
. 4,314
12,607
Eff inghaa Residential Areas
Lead
Antimony
Copper
Nickel
Tin
Zinc
48
25
25
25
25
25
Seventh street Rev
Lead
Antimony
Copper
Nickel
Tin
Zinc
0
0
0
0
0
0
1302
8
546
16
152
896
Homes s-
...
— "
—
...
...
... '
1,688
10
736
23
224
1,175
...
—
... '
...
...
' ...
38
15
15
15
15
15
29
29
29
29
29
29
1,545
14
411
28
490
1,482
8,632
54
1,541
103
1,872
4,503
974
9
902
• 14
200
500
8,834
41
9,452
90
1,962
4,852
Eff inghaa Playgrounds
Lead
Antimony
Copper
Nickel
36
• 5
5
5
267
6
407
6
326
6
1,200
12
34
32
32
32
1,869
12
803
3~3
8,526
53
4,279
186
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with those contaminants; and (3) mechanisms through which
contamination can enter the body.
The potentially exposed populations in OU1 consist
principally of residents (children and adults) within
approximately 700 feet of the foundry who could be exposed to
soil containing the contaminants of concern discussed above. The
risk assessment also considered the potential exposure to adults
working in the former foundry building, although the foundry is
no longer in operation and, therefore., :.this type of exposure is
not presently occurring.
Actions at Superfund sites are generally based on an
estimate of the reasonable maximum exposure expected to occur
under both the current and future land-use conditions. The
reasonable maximum exposure is defined as the highest exposure
that is reasonably expected to occur at a site. The risk
assessment for the Abex Site was based on the assumption that
current and future land-uses in the area are not expected to
change significantly2.
Current land-uses at the Site are a mixture of residential
and commercial/industrial. The Washington Park development, the
Effingham residential area, the Seventh Street row homes, and the
Effingham Playground are currently zoned for residential use.
The Abex Lot, Holland Property, and McCready Lot, the drug
rehabilitation center, and the vacant lots are zoned for use as
commercial/light-industrial purposes. The Washington Park
development is expected to continue to operate as residential
units. The City has proposed rezoning the Effingham Playground,
the Effingham residential area (i.e.. a three block area bounded
by Green, Lincoln, and Effingham Streets) and the Seventh Street
row home area to commercial/light-industrial, demolishing the
homes, and then building a police headquarters building and
parking lots at the Effingham Playground and Effingham
residential area. The Holland Property, the Abex Lot, and the
McCready Lot are expected to be used for commercial/industrial
purposes in the future. Future use of the vacant lots east of
Seventh Street has not been determined. Most of the vacant lot
area is located outside of the 700-foot study area for OU1.
Routes of exposure considered in the risk assessment
include: soil ingestion; dermal contact; food ingestion; dust
inhalation; and. inhalation of vapors. These pathways are
described briefly below:
2 The areas that the City plans to rezone from residential
to commercial/light industrial will not significantly affect the
results of the risk assessment for the Site.
23
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Soil ingestion - Eating soil and dust, usually
inadvertently and probably arising
.._. .—• mostly from the soil being transferred
from hand to mouth.
Dermal contact . Skin contact with soil and dust.
Food .ingestion Eating locally grown foods not
thoroughly washed to remove contaminated
soil.
Dust Inhalation Breathing dust. No industrial dusts are
currently being generated through active
operations, nor are any expected to be
generated in the future. Dust may come
from disturbed contaminated soil in the
area.- - ••" •• - -'
Inhalation of vapors Breathing vapors from groundwater and
soil. This route of exposure was found
to be negligible.
To quantitatively evaluate the exposure associated with
pathways identified at the Site, assumptions were made concerning
the reasonable maximum exposure for an individual living in the
impacted area. Table 2 presents the activity pattern for exposed
residents and the assumptions made as part of the risk
assessment* This table was designed to reflect potential
exposure to the contaminants of concern in soil. Different
activities were assigned reasonable average weekly times. All
activities were assumed to take place for 350 days per year.
As part of the process of quantifying exposure, standard
assumptions are made concerning factors such as the intake rate
for soil ingestion, the ability of soil to adhere to skin,
inhalation and consumption rates, the average lifetime, and
maximum periods of exposure. Table 3 summarizes the exposure
factors used in the risk assessment for the Abex Site.
The final consideration in quantifying exposure is the
concentration of the contaminant of concern to be used in the
calculation. The risk assessment for the Site used data from
soil samples collected in the top six inches to calculate
exposure concentrations. Surface soil data was used since
residents are exposed to these soils at a much greater frequency
than subsurface soil. The mean concentration and the upper 97.5%
confidence limit were calculated for each contaminant of concern
in each area of the Site, as presented in Table 1. The upper
confidence limit values were used to quantify individual
exposure.
24
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TABLE
ACTIVITY
At hone
indoors
At home
outdoors
Foundry site
At school
off-site
Activities
off-site
2 - ACTIVITY PATTERNS POR EXPOSED RESIDENTS
o-i
130
35
0
w
3
HOURS/WEEK (By Age Category)
1-4
130
35
0
3
4-7
131
33
1
3
7-11
102
33
1
29
3
11-15
102
33
1
29
3
15-18
102
33
1
29
3
18-70
131
33
1
3
Source: Baseline Risk Assessment for the Abex Site, Table 3.7
c. Human Health Toxicity Assessment
The purpose of the toxicity assessment is to weigh available
evidence regarding the potential for particular contaminants to
cause adverse effects in an exposed individual. Where possible,
the toxicity assessment provides an estimate of the relationship
between the extent of exposure to the contaminant and the
increased likelihood and/or severity of adverse effects. The
first step in the process is to determine whether exposure to the
contaminant can cause an increase in the incidence of either a
cancer-related (carcinogenic) or non-cancer-related (non-
carcinogenic) adverse health effect. EPA gathers evidence from a
variety of sources regarding these health effects, including
controlled epidemiologic investigations, clinical studies, and
experimental animal studies.
The second step in the toxicity assessment is to
quantitatively evaluate the health effects associated with the
contaminant of concern on the exposed population. For
contaminants that are known or suspected of causing cancer,
Cancer Slope Factors (CSFs) have been developed by EPA's
Carcinogenic Assessment Group in order to estimate the adverse
health effect. Carcinogenic effects are measured as the
additional risk of an individual contracting cancer as a result
of exposure to potentially carcinogenic chemicals. CSFs are
multiplied by the estimated exposure rates to provide an upper
bound estimate of the excess lifetime cancer risk associated with
that exposure. The term "upper bound" reflects the
25
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TABLE 3 - EXPOSURE FACTORS
Exposure pathway
Age Categories (e)
0-1 1-4 4-7 7-11 11-15 15-18 "-70
.
Xngestion of soil and dust ' • :i
Intake rate rag/day 100 200 200 100 100 100 100
Exposure frequency days/year 350 350 350 350 350 350 350
Dermal absorption of soil . ' .
Soil to skin adherence factoring/cm' (f) 0.51 0.51 0.51 0.51 0.51 0.51 0.51
1 Total limb area m1
-------
conservative-estimate of the risks and makes underestimation of
the actual cancer risk highly unlikely. Table 4 lists the CSFs
for the chemicals treated in this risk assessment.
For contaminants that are not known to cause cancer,
reference doses (RfDs) have been developed by EPA for quantifying
the potential for adverse health effects from exposure. RfDs are
estimates of lifetime daily exposure levels for humans, including
sensitive individuals, who are likely, to be without an
appreciable risk of adverse effects during a lifetime. Estimated
intakes of chemicals from environmental media (e.g.. the amount
of a chemical ingested from contaminated soil) can be compared
to the RfD. Table 5 lists values of RfD (for chronic exposure)
and RfD (for subchronic exposure), where they are available. The
toxicity profiles discussing the possible effects of the
contaminants of concern are included at the end of this section.
EPA does not currently recommend using the standard risk
assessment methods described thus far for evaluating lead
contamination. EPA recommends, and the Abex Site risk assessment
used, the Uptake/Biokinetic (UBK) Model to assess the hazards
associated with lead contamination at the Abex Site. The UBK
Model estimates a range of blood lead levels for children that
can result from the overall exposure to the variety of
leadsources in the environment. The Model considers possible
exposure from air, diet, drinking water, soil/dust, paint
chips/dust, and maternal blood lead sources. Table 6 presents
the standard assumptions used in the UBK model for the Abex risk
assessment. Lead exposure was evaluated for children up to four
years old, the group most sensitive to potential adverse health
effects from lead.
D. Tozieity Profiles For Contaminants of Concern
Lead is a heavy metal that exists in one of three oxidation
states, 0, +2, and +4. Primarily, lead is used in equipment
where pliability and corrosion resistance are required, in
solder, in paints and varnishes, in storage batteries, and in
alloys. Occupational exposure to lead dust and fumes can occur
during mining, refining, smelting, and welding. Children with
pica (placing non-food items in the mouth), as well as children
exhibiting normal hand-to-mouth activities, who are exposed to
lead-contaminated paint chips, dust, or soil can experience
elevated blood.lead levels, sometimes at elevations significant
enough to cause illness. Some of these effects, particularly
changes in the levels of certain blood enzymes and in aspects of
childrens' neurobehavioral development, may occur at low blood
lead levels. The fetus may also be impacted by blood lead levels
below 10 micrograms per deciliter (ug/dl). Lead has been
classified as a Group B2 probable human carcinogen. Oral
exposure to lead salts, primarily phosphates and acetates, has
caused kidney tumors in laboratory animals.
27
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TABLE 4 - CANCER SLOPE FACTORS
CHEMICAL _
Metals:
Antimony
Cadmium
Chromium (VI)
Copper
Nickel
Silver
Tin
Zinc
PAEss
Accnaphthena
Anthracene
Benzo
-------
CHEMICAL
Antimony
Cadmium
Chromium
(VI)
Copper
Nickel
Silver
Tin
Zinc
Acwupftthm
Anthracene
B«nzo(a)anthrac«m
B«nzo(a)pyr*ne
B«nzo(b)fluof
anthtrw
B*nxo(ght )p*ryl«ni
ChryMn*
0
-------
TABLE 6 - STANDARD ASSUMPTIONS FOR UBK MODEL
Parameters that vary with aoe
. 0-1 1-2 2-3 3-4
Exposure from air
Background concentration in air: 0.2 |ig/m3
Indoor air concentration {% of outdoors): 30%
Time spent outdoors (hours/day): 12 34
Ventilation rate (mVhr):- 2 355
. Percent absorption in lung: 32% ..
Exposure from diet
Background dietary exposure to lead (jig/day): 5.88 5.92 6.79 6.57
Percent absorption in gastrointestinal tract: 50%
Exposure from drinking water
Lead concentration in drinking water: 4 u.g/1
Daily ingestion rate of drinking water (I/day): 0.20 0.50 0.52 0.53
Percent absorption in gastrointestinal tract: 50%
Exposure from soil/dust
Rate of soil/dust exposure (rng/day): 100
Percentage exposure to soil: 45%
Percentage exposure to dust: 55%
Percent absorption in gastrointestinal traci: 30%
Exposure from paint chips
Rate of exposure to lead in paint (mg/day): 0
Source: Baseline Risk Assessment for the Abex Site," Table 4.4
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Antimony is a soft metal insoluble in water and organic
solvents. It is/widely used in the production of alloys. Oral
exposure t» -antimony has been shown to cause burning stomach
pains, cholic, nausea and vomiting in human. Long-term
occupational inhalation exposure is associated with heart disease
in both human and laboratory animals. Decreased longevity and
altered cholesterol levels have been observed in rats. Antimony
has not been tested for carcinogenicity.
Cadmium is a bluish-white metal. Small amounts of cadmium
are found in zinc, copper, and lead ores. Cadmium is insoluble
in water but is soluble in acids. Cadmium dust includes dust of
various cadmium compounds. Cadmium is used as a protective
coating for iron, steel, and copper because it is resistant to
corrosion. Cadmium alloys (copper, nickel) may be used as
coatings for other materials, welding electrodes, solders, and in
pigments and paints. Cadmium is used as an amalgam in dentistry.
Various cadmium compounds are used as fungicides and
insecticides. Exposure to cadmium can occur through inhalation
and ingestion. Short and long-term inhalation exposure to
cadmium dust or fumes is associated with swelling of the lung
tissue, pain in the chest, difficulty in breathing and emphysema.
Long-term ingestion of cadmium is associated with changes and
damages to the kidneys in laboratory animals. The EPA has
classified cadmium as a Group Bl probable human carcinogen.
Cadmium may be associated with an increased risk of prostate and
lung cancer in humans occupationally exposed to this contaminant.
Copper is a reddish-brown metal which occurs free or in
ores. It is insoluble in water but soluble in acid. Metallic
copper is used as a conductor of electricity and in all gauges of
wire for circuitry, coil, high conductivity tubes. Copper is
used in many important alloys, such as brass and bronze. Copper
is also used in insecticides, fungicides, catalysts, analytical
reagents and paints. Acute exposure to copper salts may cause
eye and skin irritation. Acute industrial exposure to copper may
occur during fumes generated during welding copper-containing
metals. This type of exposure may cause upper respiratory tract
and stomach irritation. Chronic exposure to copper rarely occurs
except in individuals with Wilson's disease. This is a genetic
condition where abnormal amounts of copper are absorbed and
stored by the body. Chronic exposure to copper may result in
anemia. Copper is not classifiable as to human carcinogenicity.
Chromium is a heavy metal that exists in either a trivalent
or hexavalent oxidation state. Hexavalent chromium is soluble
and mobile in ground water and surface water. Trivalent chromium
is in the reduced form and is. generally found absorbed to soil;
and therefore, it is less mobile. Hexavalent chromium is used in
chrome plating, copper photography, copper stripping, aluminum
anodizing, as a catalyst, in organic synthesis and photography.
Exposure to chromium compounds can occur through ingestion,
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inhalation and skin contact. Hexavalent chromium may have a
direct corrosive effect on the skin and may cause upper
respiratory -distress, headache, fever, and loss of weight. Long-
term occupational inhalation exposure to dust and fumes of
hexavalent chromium has been shown to cause lung cancer in
humans, especially those in the chrornate-producing industry. In
addition, a number of salts of hexavalent chromium are
carcinogenic in rats. The EPA has classified hexavalent chromium
as a Group A human carcinogen. Trivalent chromium is an
essential nutrient and have low toxicity; however, at high
levels, it may cause skin irritation.
Nickel is a white hard,, ferromagnetic metal that is a
naturally-occurring element in the earth's crust and is stable in
the atmosphere at ambient temperatures. Nickel forms alloys with
a variety of metals, including copper, manganese, zinc, chromium
and..iron. Elemental nickel is used in electroplating and casting
operations, magnetic tapes, surgical and dental instruments,
nickel-cadmium batteries, and colored ceramics. Occupational
exposure to nickel compounds has been associated with an
increased incidence of nasal cavity and lung cancers. For this
reason, nickel refinery dust has been classified by the EPA as a
Group A - Human Carcinogen via the inhalation route of exposure.
The most common reaction to nickel exposure is skin
sensitization. Nickel and its compounds also irritate the
conjunctiva of the eye and the mucous membranes of the upper
respiratory tract.
Polychlorinated biphenyls (PCBs) are complex mixtures of the
products of the chlorination of biphenyl. The mixtures contain
isomers of chlorobiphenyls with different chlorine content. PCBs
may contain other chlorinated mixtures (e.g., chlorinated
naphthalenes and chlorinated dibenzofurans). PCBs are stable and
nonflammable. They are used chiefly in insulation for electric
cables and wires. PCBs are persistent in the environment and
bioaccumulate in food chains, with possible adverse effects on
animals and man. Prolonged skin contact may cause the formation
of chloracne which is characterized by blackheads, fat containing
cyst and pustules. Irritation of eyes, nose and throat may also
occur. Systemic toxic effects are dependent upon the degree of
chlorination of the biphenyls. Short and long-term exposure may
cause liver damage. PCBs may cause embryo toxicity leading to
stillbirth. Some PCBs are carcinogenic in animals. The EPA has
classified PCBs as Group B2 probable human carcinogens. Oral
exposure to PCBs has been shown to cause liver tumors in
laboratory animals.
Polycyclic aromatic hydrocarbons (PAHs) constitute a class
of contaminants consisting of substituted and unsubstituted
polycyclic aromatic rings formed by the incomplete combustion of
organic materials. Their physical, chemical, and biological
properties vary with their size and shape. PAHs are persistent
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in the environment; Benzo (a) pyrene is one of the most common
and most hazardous PAHs. Some PAHs are classified by the EPA as
a Group B2-probable human carcinogens. Benzo (a) pyrene is the
most potent of the carcinogenic PAHs. Oral exposure to benzo (a)
pyrene has been shown to produce stomach tumors in mice and rats
and mammary tumors in rats. Dermal exposure to benzo (a) pyrene
has been shown to produce skin cancer in mice, rats and rabbits.
Oral and inhalation exposure to benzo (a) pyrene has been shown
to cause lung tumors in mice and rats. Long-term exposure to
PAHs may cause birth defects.
Silver is a white metal insoluble in water and soluble in
sulfuric and nitric acids. Alloys or silver (e.g., copper,
aluminum, cadmium, lead or antimony) are used in the manufacture
of silverware, jewelry, coins, films, mirrors, as a bactericide
for sterilizing water, fruit juices, etc. Some silver compounds
are also of medical importance as antiseptics or astringents.
Exposure to silver can occur through inhalation of fumes or dust,
ingestion of solutions or dust, or through eye and skin contact.
Eye and skin contact with metallic silver may .produce local
permanent discoloration of the skin similar to tattooing. This
process is referred to as argyria. Argyria is characterized by a
dark, slate-gray color .pigmentation of the skin. Generalized
argyria can develop through exposure to silver oxides or salts
through ingestion and inhalation of dust. Silver is not
classifiable as to carcinogenicity.
Tin is a soft, silvery white metal insoluble in water. It
is used as a protective coating for other metals such as in
household utensils, as soft solders, and in the packaging
industry. Exposure to tin may occur in mining, smelting, and
refining, and in the production and use of tin alloys and
solders. Inorganic tin salts are mild skin irritants. Exposure
to dust or fumes of inorganic tin is known to cause lung disease.
Tin is not classifiable as to human carcinogenicity.
Zino is a bluish-white metal that is stable in dry air, but
becomes covered with a white coating on exposure to moist air.
Zinc is present in abundance in the earth's crust. Zinc chloride
is used as a wood preservative, in dry battery cells, in oil
refining operations, and in the manufacture of dyes, activated
carbon, deodorants and disinfecting solutions. 2inc chromate and
zinc oxide are used primarily as pigments. Exposure to zinc
compounds can cause skin sensitizatibn, irritation of the nose
and throat, fever, and fatigue. Zinc is not classifiable as to
human carcinogenicity.
E. Human Health Risk Characterization
The risk characterization section in a risk assessment
summarizes the results of the exposure and toxicity assessments
to describe the baseline risk for the Site. In general, risk is
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characterized-as being unacceptable when: (l) existing levels of
contaminants present at a site may cause cancer or some other
adverse health effect; (2) there is a route or pathway through
which a receptor may be exposed (.e.g.. ingestion of contaminated
soil) and; (3) there is a, receptor which may be exposed (e.g., a
child ingesting soil). For cancer-causing contaminants, risk is
measured as the- number of additional incidences of cancer that
can be expected in a population exposed to that contaminant. For
example, one additional incident pf cancer estimated to occur in
a population of 10,000, as a result of.exposure to contamination
at a site, would quantitatively be described as a 1 x 10~4 cancer
risk. EPA recommends that remedial actions be taken to address
risk greater than a 1 x 10~4 cancer risk. EPA may recommend
action in situations where the risk is in the range of 1 x 10~4
to 1 x 10~6~(one additional incident of cancer in a population of
1,000,000). .
For non-carcinogenic contaminants, risk is considered
unacceptable when the concentration of the contaminant that an
individual is exposed to (i.e.. the intake rate) exceeds the RfD
concentration for that contaminant. The non-carcinogenic effects
of a single contaminant in a single medium is expressed as the
hazard quotient (HQ). To assess the overall potential for non-
carcinogenic effects posed by more than one contaminant, the HQs
are added to determine the Hazard Index (HI). The HI provides a
useful reference point for gauging the potential significance of
multiple contaminant exposure within a single medium or across
media. EPA may recommend action in situations where the HI
exceeds one. ."'.••
Table 7 summarizes the quantitative results of the risk
assessment for residents and workers exposed to contaminants of
concern other than lead at the Site. In the case of residential
exposure, risks to different age groups were determined.
EPA does not recommend characterizing the health effects
associated with lead using the risk assessment procedures
discussed above. EPA currently believes that the best available
approach for characterizing risks associated with lead in
residential areas is the UBK Model. The UBK Model was used at
the Abex Site to predict the percentage of highly exposed
children that would have a level of lead in their blood exceeding
10 ug/dL, the level recommended as safe by the Center for Disease
Control (CDC), at various levels of contamination. Based on the
exposure assumptions presented earlier, the Model predicts that
approximately 95% of children exposed to soil/dust with an
average lead concentration of 400 mg/kg would have blood lead
levels below 10 ug/dL. This is the average lead concentration
that should be achieved at the Site by implementation of the
remedy.
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-TABLB 7 - BASELINE RISKS FOR THB ABBX 8ITB
EXPOSED POPULATION
HAZARD INDEX
CANCER RISK
Residents* (by age group)
0-1
1-4
4-7
7-11
11-15
15-18 '
18-70
Total lifetime risk:
(for carcinogens)
Future Workers!
Inhalation
Ingestion
Dermal
Total lifetime risk:
(for carcinogens)
0.83
1.21
1.35
0.70
0.57
0.50
0.51
( chronic/ subchronic)
43.9/43.8
2.42/2.38
4.49/4.37
''——
1.20 X 10'*
1.29 X 10'8
3.34 X 10'*
2.36 X 10'*
1.59 X 10**
1.35 X 10'*
2.09 X 10'*
3.0 X 10's
4.10 X 10'4
1.46 X 10*4
3.41 X 10'4
8.97 X 10'4
At the time the baseline risk assessment was done, the
baseline risk assessment determined that surface soil
contamination at the Site presented a current unacceptable risk
to residents and would pose unacceptable risks to workers within
the former foundry building. The average lead concentration
exceeded 400 mg/kg in surface soil in the Effingham residential
area, on the Holland Property, .and in the vacant lots. The Site
would also pose an unacceptable future risk to residents as a
result of potential exposure to contaminated subsurface soils.
Average lead concentrations exceeded 400 mg/kg in subsurface soil
in the Washington Park development, the Effingham residential *
area, the Seventh Street row homes, the Holland Property, the
Abex Lot, the drug rehabilitation center, and the vacant lots.
At the present, the foundry buildings are not in use, and have
been secured to restrict access. One foundry building has been
dismantled due to its poor structural condition. In addition,
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CERCLA removal actions were performed in which lead-contaminated
surface soil" exceeding 500 mg/kg lead was excavated from the
Washington Park Development, the Effingham Playground, and the
Seventh Street Row Homes. The Effingham residents were informed
of the human health risks posed by exposure to lead-contaminated
surface soil on their property. They chose to wait for the long-
term Site remediation to have both the lead-contaminated surface
and subsurface soil excavation work done at the same time. The
removal actions alleviated the current risks to site residents
(except for Effingham homeowners) being exposed to lead-
contaminated surface soil, however, they did not eliminate the
future risks posed by subsurface lead-contaminated soils. This
remedy will address the future risk.
The baseline risk assessment also indicated that children
between the ages of one and seven and future workers at -t'r.a
former foundry building could be exposed to unacceptable .future
risk associated with other non-carcinogenic contaminants of
concern. This is indicated in Table 7 where the total HI values
are greater than one. It should be noted, however, that the HI
calculations may over estimate the potential for adverse health
effects at the Site since not all contaminants of concern induce
the same health effect by the same mechanism or action.
The total lifetime cancer risks associated with the areas
addressed by OU1 are 3.0 x 10~s for residents fi.e.. one
additional incident of cancer in an exposed population of 33,333)
and 8.97 x 10"4 for future workers at the former foundry facility
(i.e.. one additional incident of cancer in an exposed population
of 1,115). As noted earlier, EPA recommends that remedial
actions be taken to address risk greater than a 1 x 10"4 cancer
risk. EPA may recommend action in situations where the risk is
in the range of 1 x 10~4 to 1 x 10"6 (one additional incident of
cancer in a population of 1,000,000).
F. Future Risks Associated With Subsurface Soil
Because contaminated soil has been removed and/or necessary
precautions are being taken by residents to limit exposure,
residents are not currently being exposed to unacceptable health
risks. The potential for future exposure to unacceptable human
health risks may exist if contaminated subsurface soil is brought
to the surface by future activity. The risk assessment only
briefly discusses this subject in conjunction with current and
future land-use and states that highly contaminated subsurface
soils could be brought to the surface if large scale development
occurs.
In addition to large scale development, EPA has considered
other possible mechanisms for exposure to subsurface soils either
directly or by the transport of these soils to the surface.
Routine activities by property owners or their children include,
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but are not limited to, gardening of fruits, vegetables and other
plants, children playing in soil (e.g.f digging holes, making mud
pies, etc.-)-,—and installing fence posts, decks, and playground
equipment. Construction activities that could result in human
exposure to contaminated subsurface soil and the recontamination
of surface soil include, but are not limited to, construction of
housing additions, maintenance and addition/replacement of
subsurface utilities, demolition of existing
buildings/structures, construction of new buildings/structures,
and construction of in-ground pools.
EPA is unaware of any research or models that can be used as
a basis for estimating the potential future exposure of residents
to subsurface soil contamination. Since future activities in the
residential areas of OU1, unless restricted, could reasonably
result in either direct exposure to contaminated subsurface soil
or exposure to contaminated soil reintroduced to the surface, EPA
believes surface and subsurface soil are of equal concern. Since
this ROD Amendment identifies the final remedial action for
contaminated soil in OU1, EPA believes a conservative approach to
determining the extent of cleanup is appropriate.
6. Ecological Risk
The OU1 RI focused on the area within a 700-foot radius of
the foundry, which is a predominantly urban area. A formal
ecological risk assessment that qualitatively and/or
quantitatively appraises the actual or potential effects of the
Site on plants and animals was not performed as part of this OU.
An investigation of the ecological impacts that may be associated
with this Site, particularly with regard to the Elizabeth River
and off-site environmental receptors, will be evaluated in OU2.
H. Lead Cleanup Levels
After completion of the baseline risk assessment at a site,
appropriate cleanup levels are considered during the Feasibility
Study in order to evaluate the effectiveness of the remedial
alternatives. For sites dealing with lead contamination, EPA
recommends, as a matter of policy (OSWER Directive #9355.4-02),
that soil cleanup levels in the range of 500 to 1,000 mg/kg lead
be used to trigger a remedial action in residential areas. The
use of specific clean-up levels has proved to be an effective
method for implementing cleanup activities. After cleanup has
been completed, confirmatory sampling is performed to ensure that
unacceptable risks identified in the baseline risk assessment
have been addressed. Since other contaminants of concern
identified at the Abex Site are found in close association with
lead, actions taken to achieve the lead -cleanup levels will also
be effective in addressing unacceptable risks from these
contaminants.
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VTII. DESCRIPTION OP ALTERNATIVES
The remedial alternative selected in the September, 1992 ROD
(Alternative 4) and the alternative now preferred by EPA
(Alternative 8), are described below.
A. Elements. Common to Alternatives 4*8:
Both Alternatives 4 and 8 include the following elements:
1. Demolition of Former Foundry Facility Buildings on
Hoiland Property
All buildings associated with the former foundry operation
will be demolished. Demolition debris will be tested using TCLP
to determine if the material is RCRA hazardous waste. If the
demolition debris exhibits toxieity, it will be disposed of off-
site in a RCRA Subtitle C landfill, after RCRA land disposal
restriction requirements are met. If the construction debris
does not exhibit toxicity, it will be disposed of off-site in a
permitted RCRA Subtitle D landfill.
Equipment which is contaminated with or constitutes a RCRA
hazardous waste will be disposed of of f-site in accordance with
the requirements of RCRA Subtitle C, including the LDR
requirement. Equipment which is not contaminated with or is not
a RCRA hazardous waste, or which is decontaminated so that it no
longer is contaminated with or constitutes a RCRA hazardous
waste, may be used or disposed of off-site in a manner not
inconsistent with applicable laws or regulations. Residuals
generated as a result of decontamination activities will be
tested under TCLP and disposed of as required by RCRA Subtitle C
and any other laws or regulations which may be applicable to such
wastes.
2. Soil Excavation and Off-^Site Disposal
Soil excavation and off-site soil disposal is required to
various extents under both Alternatives. TCLP testing will be
conducted to determine whether excavated, soil is a RCRA
characteristic hazardous waste. Soil which is determined to be a
RCRA hazardous waste will be treated prior to land disposal.
Soil which is not a RCRA hazardous waste will be treated to the
extent and in the manner as may be required by the state to which
such soils will be transported for off-site disposal.
Conventional earth-moving equipment will be used to excavate and
load the contaminated soil. Dust suppression measures will be
used to ensure that unacceptable releases of air-borne
contamination do not occur. All excavated areas will be
backfilled with clean fill. Formerly vegetated areas will be
graded and reestablished to original condition, to the extent
38
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practicable.- Tttiere excavation to the depth of the water table is
required, excavation will occur during the period when the water
table is at-the seasonally low elevation, to the extent
practicable.
Prior to the excavation of contaminated soil on the Abex
Lot,.the McCready Lot, and the Holland Property, existing asphalt
and concrete will be removed and tested using the TCLP. Debris
which is determined not to be RCRA hazardous waste, will be
disposed of as construction and demolition debris. Debris that
tests as hazardous under TCLP will be disposed of in. accordance
with RCRA Subtitle C requirements, including LDR regulations.
Excavated soil and waste materials will be temporarily
staged on-site prior to treatment and/or transportation to an
off-site disposal facility; to the extent practicable, excavated
soil and waste material will be staged in areas of existing
contamination, e.g.. the Abex Lot, the Holland Property, McCready
Lot, or the vacant lots; containment measures such as berms and
temporary covers will be used in areas with staged material to
ensure that there are no unacceptable air or water-borne releases
of contamination from these areas; these measures will be
sufficient to provide protection in the event of flooding; areas
that are used to stage excavated material will be secured with a
fence to prevent trespassing. In all instances where soil and
waste materials are staged in areas where cleanup has previously
occurred or are otherwise not contaminated above levels requiring
excavation, soil and waste material will be staged in containers
in accordance with RCRA regulations contained in 40 C.F.R. Part
268.50; containers used.will be in compliance with VHWMR S 10.8
Use and Management of containers.
3. Temporary Relocation
Residents will be temporarily relocated while excavation is
occurring around residential units. The extent of soil to be
removed around each residential unit will be determined during
the remedial design phase. The specific arrangements for
temporary housing will be based on the extent of soil to be
removed and the needs of the impacted residents. Efforts will be
made to minimize inconvenience to the residents.
4. Soil Treatment By Stabilization and/or Solidification
Excavated soil and waste materials from the site that
exhibit toxicity (as determined by the TCLP test) will be treated
on-site via stabilization by mixing such soil and waste materials
with chemicals/reagents. The mixing will be contained in above-
ground equipment on-site to create a final product that
encapsulates and immobilizes lead and other metals. Specific
chemicals to be used in the process will be determined in a
treatability study during the remedial design phase of the
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project. -Treated material will be tested using TCLP to ensure it
no longer exhibits toxic characteristics. Further treatment will
be undertaken if the soil and waste material still exhibit
toxicity. If the soil or waste material still exhibits toxicity
after further treatment, it will be disposed of in a permitted
RCRA Subtitle C landfill, after meeting RCRA LDR requirements.
Soil and waste materials that no longer exhibit toxicity after
treatment will be disposed of off-site in a permitted RCRA
Subtitle D landfill.
5.i' . Discharge of Contaminated Water
-?.
Discharge of decontamination water and any other water
generated during remedial activities will meet Virginia Pollution
Discharge Elimination System (VPDES) requirements developed
pursuant to the Federal Clean Water Act, 31 U.S.C. §§ 1251 et
seq., and ths Virginia State Water Control Law, Code of Virginia
§§ 62.1-44.2 et seq. It is anticipated that most of the water
generated by the Site activities will be recycled or re-used in
the treatment process. The water that is not recycled will be
treated, tested and sent off-site either to a waste water
treatment facility (if the water does not exceed the levels of
lead that the treatment facility is permitted to accept) or
treated on-site and discharged into the Elizabeth River. If the
water is to be discharged into the Elizabeth River, it will have
to meet all VPDES requirements.
6.- Air Emissions Monitoring During Remedial Activities
Air will be monitored for both dust and lead levels during
the remedial activities to protect the health of on-site workers
and the community. Sampling of the interior of homes in the
vicinity of excavation will also be performed before, during, and
after excavation. Such monitoring and Sampling will be designed
to ensure compliance with the National Emission Standards for
Hazardous Air Pollutants (NESHAPs) developed under the Federal
Clean Air Act; 40 C.F.R. Part 60 ; National Primary and Secondary
Ambient Air Quality Standards for Particulates and Lead, 40
C.F.R. §§ 50.12 and 50.6, and the Virginia Regulations for the
Control and Abatement of Air Pollution (VRCAAP), VR § 120-04,
120-05 and 120-06.
7. Transportation. Storage. Treatment and Disposal of Soil
and Debris
Transportation, storage, treatment and disposal of soil and
debris will be in compliance with applicable provisions of RCRA,
the federal regulations promulgated thereunder pursuant to HSWA
at 40 C.F.R. Parts 260-271, the Virginia Hazardous Waste
Management Regulations (VHWMR) Part VII, Regulations Applicable
to Transporters of Hazardous Waste (VR SS 672-30-1) and Virginia
Solid Waste Management Regulations (VR § 672-20-10).
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B. Elements Specific to Alternative 4 or 8:
A description of additional elements and the estimated cost for
each Alternative is provided below. ••-•'•
1. Alternative 4;
Estimated Capital Cost: $31,962,9233/
Estimated O & M Cost: 0
Estimated Present Worth: $31,962,923
Estimated Time to .Construct: 55 weeks
In areas zoned for residential use, surface and subsurface
soil located between the ground surface and the water table which
contains greater than 500 ing/kg lead, including contaminated soil
adjacent to home foundations, would be excavated. Geotechnical
investigations would be performed during remedial design to
determine if remediation beneath homes would be technically
practicable and, if so, to determine the appropriate construction
techniques to be used to maintain the structural integrity of the
homes during such excavation.
In areas zoned for commercial/industrial use, surface soil
(0-12" in depth) exceeding 500 mg/kg lead and subsurface soil
(>12" in depth) exceeding 1,000 mg/kg lead would be excavated to
the depth of the water table.
2. Alternative 8:
Estimated Capital Cost: $31,484,1704
Estimated O & M cost: $23,500
Estimated Present Worth: $31,507,670
Estimated Time to Construct: 58 weeks
3 In preparing the cost estimate for Alternative 8, EPA
determined that the cost of excavation, treatment, and disposal
of contaminated soil on the Holland Property had inadvertently
been omitted from Alternative 4. This cost has been included in
Alternative 8 and has also been added to Alternative 4 so that an
appropriate comparison can be made.
4 For cost estimate purposes, EPA has assumed that the
areas where the Effingham and Seventh Street homes currently
exist will be rezoned by the City of Portsmouth to
commercial/light industrial use. The estimated cost to demolish
the Effingham and Seventh street homes and dispose of debris in a
RCRA permitted landfill has been included. If these residential
areas are not rezoned, these areas must be remediated in the
manner specified in this ROD Amendment for areas zoned
residential.
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In areas-zoned for residential use at the completion of the
preliminary remedial design, and in the Abex Lot, surface and
subsurface._s.oil located between the ground surface and the water
table which contains greater than 500 mg/kg lead would be
excavated.
If all necessary EPA-approved institutional controls5 are
in effect .by ~the completion of the preliminary remedial design,
soil from the ground surface to a depth of one foot in
commercial/industrial areas (except for the Abex Lot) which
exceeds 500 mg/kg lead will be excavated. Soil below one foot
which exceeds 1,000 mg/kg lead will be excavated to a depth of
two feet. The institutional controls will prevent excavation
activities that could allow human exposure of lead-contaminated
subsurface soils. If the institutional controls are not in place
by the completion of the preliminary remedial design, soil which
exceeds 1,000 mg/kg lead will be excavated down to the water
table. : ,-
Institutional land-use controls will be implemented to
control any future excavation below two feet and to prevent
exposure to contaminated soil. EPA will review, comment upon,
and approve all institutional controls to be implemented as part
of the remedial action for the Site. These institutional
controls may include?, an ordinance or regulation requiring a
permit for, and imposing restrictions on, excavation in areas
within OU1 and requiring notice to EPA, the City, PRHA, and the
public prior to excavation in such areas; the inclusion of
provisions in deeds for properties within OU1 providing notice of
this CERCLA remedy and restricting excavation on such properties;
and the placement of underground "warning sheets" in excavated
commercial/ industrial areas before backfilling with clean soil.
The institutional controls must be sufficient to ensure (1) that
soils below two feet are not disturbed in areas of OU1 zoned
commercial/industrial after completion of this remedy without
prior notice to EPA, the City, PRHA, and the public, and (2) if
such soils are to be disturbed, the soils are managed in a manner
which will not endanger public health or the environment.
Soil beneath existing permanent covers such as buildings
without crawl spaces, parking lots, sidewalks, and streets would
5 The PRP proposal of October, 1993 described several
potential institutional land-use controls to be employed to
prevent exposure to contaminated subsurface soils remaining on-
site. EPA will review, comment, and approve all institutional
controls to be implemented as part of the remedial action for the
site.
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not be removed6. These covers would be maintained and EPA-
approved institutional land-use controls would be used to prevent
future exposure to contaminated soil beneath such covers.
A five-year review pursuant to CERCLA S 121(c), 42 U.S.C.
§ 9621(c), will.be required under this Alternative.
IX. COMPARISON OF ALTERNATIVES
The Alternatives described above were evaluated in the
Proposed Plan to Amend the September, 1992 ROD using the
following criteria, as required under the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R.
§ 300.430(e)(9)(iii):
A. General Overview of Evaluating Criteria:
1. Threshold Criteria; (Relate to statutory requirements
that each alternative must satisfy in order to be
eligible for selection.)
Overall Protection of Human Health and the Environment
Evaluation of the ability of each alternative to
provide adequate protection of human health and the
environment in the long and short-term; description of
how risks posed through each exposure pathway are
eliminated, reduced, or controlled through treatment,
engineering controls, or institutional controls.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARS)
Evaluation of the ability of each alternative to meet
all ARARs of Federal and State environmental laws
and/or justification for invoking a waiver; assessment
of the ability of each alternative to comply with
advisories, criteria, and guidance that EPA
has agreed to follow.
6 The former foundry buildings, the Effingham and Seventh
Street homes, and the asphalt covers on the Abex Lot, the
McCready Lot and the Holland property would all be removed under
this Alternative and contaminated soil beneath these existing
permanent covers would be removed to the health-based levels
specified in this ROD Amendment for the area or zoning
classification at issue. The definition of "permanent cover"
does not include buildings that have crawl spaces with dirt
floors.
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2. -Primary Balancing Criteria: (Technical criteria upon
which the detailed analysis is primarily based)
Long-Term Effectiveness and Permanence
Evaluation of expected residual risk and the ability of
each remedy to maintain reliable protection of human
health and the environment over time after cleanup
goals have been met. .
Reduction of Toxicity. Mobility.or Volume Through
Treatment .
Evaluation of .the statutory preference for selecting
remedial actions that employ treatment technologies
that permanently and significantly reduce the toxicity,
mobility, or volume of hazardous substances.
Short-Term Effectiveness
Evaluation of the period of time needed to achieve
protection and any adverse impacts on human health and
the environment that may be posed during the
construction and implementation period, until cleanup
goals are achieved.
Implementabi1ity . ,
Evaluation of the technical and administrative
feasibility of each alternative, including the
. availability of materials and services.
Cost " ' " ' '..-:.-.'
Section 121 of CERCLA, 42 U.S.C. Section 9621, requires
selection of a cost-effective remedy that protects
human health and the environment and meets the other
requirements of the statute. The Alternatives are
compared with respect to present worth cost, which
includes all capital costs and the operation and
maintenance cost incurred over the life of the project.
Capital costs include those expenditures necessary to
implement a remedial action, including construction
costs. All of the costs indicated below are estimates.
3. Modifying Criteria; (Criteria considered throughout
the development of the preferred remedial alternative
and formally assessed after the public comment period,
which may modify the preferred alternative.)
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State Acceptance
Assessment of technical and administrative issues and
concerns that the State may have regarding each
alternative.
Community Acceptance
Assessment of issues and concerns the public may have
regarding each alternative based on a review of public
comments received on the Administrative Record and the
Proposed Plan.
B. EVALUATING CRITERIA APPLIED TO ALTERNATIVES 4 48:
Threshold Criteria:
1. overall Protection of Human Health and the Environment
Alternative 4 would require removal of soil that exceeds
residential or commercial/industrial health-based cleanup levels,
as appropriate, to the depth of the water table and is considered
fully protective of human health and the environment.
Alternative 8 will require removal of soil that exceeds the
residential health-based cleanup level (500 mg/kg lead) to the
depth of the water table in residential areas and the Abex Lot
and to a depth of one foot in the remaining commercial/ industrial
areas. An additional one foot of soil (i.e.. 12"-24H depth) will
be removed in commercial/industrial areas where lead
concentrations exceed 1,000 mg/kg. Exposure to contaminated soil
remaining below the depth of two feet in commercial/industrial
areas or below existing permanent covers such as buildings,
parking lots, sidewalks, and street would be prevented through
the use of institutional controls described in Section VIII.B.
As noted previously, failure to implement the institutional
controls by the completion of the preliminary remedial design
will result in commercial/industrial areas having to be excavated
to 500 mg/kg lead in the first foot and 1,000 mg/kg lead to the
depth of the water table. If the Effingham residential area, the
Effingham playground, and Seventh Street row homes are not
rezoned by the completion of the preliminary remedial design,
soil exceeding 500 mg/kg lead will be excavated in these areas to
the depth of the water table and further investigation into
appropriate remediation of soil beneath homes that have crawl
spaces with dirt floors will have to be undertaken. Alternative
8 is also considered fully protective of human health and the
environment.
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2. -Compliance with ARARs
Both,Alternatives 4 and 8 would meet the following
respective federal and state ARARs:
• The Resource Conservation and Recovery Act, (40 C.F.R.
Parts 261-270); the Virginia Hazardous Waste Management Act
(Code of Va. §§ 10.1-1400 e£ seq.l; the Virginia Waste
Management Regulations (VR §672-10-1); and the Virginia
Solid Waste Management Regulations (VR §672-20-10). These
provisions regulate the transportation, treatment, storage,
and disposal of hazardous and solid wastes that are
excavated or generated during the cleanup.
• Clean Water Act; National Pollution Discharge Elimination
System requirements, (40 C.F.R. Part 122); the Virginia
Water Control Law (Code of Va. § 62.1-44.2 et seq.); and the
Virginia State Water Control Board regulations (VR §680-21-
00). These regulate any discharge of wastewater generated
during the cleanup to the waters of the Commonwealth of
Virginia. . • ,
• National Primary and Secondary Ambient Air Quality Standards
for Lead (40 C.F.R. Part 50.12) and Particulate Matter (40
C.F.R. Part 50.6); and the Virginia Air Pollution Control
Law (Code of Va. §10.1-1300 et seq.l. and the Virginia
regulations for the Control and Abatement of Air Pollution
(VR § 120-04, 120-05, and 120-06) and the Virginia State
Implementation Plan, 40 C.F.R. Part 52, Subpart W regulate
air emissions and establish permissible levels of lead and
particulate matter that can be released into the environment
during the cleanup activities.
• Executive Order 11988, Floodplain Management; the National
Flood Insurance Act of 1968; the Flood Disaster Act of 1973;
and Procedures for Implementing the Requirements of the
Council on Environmental Quality on the National
Environmental Policy Act. These provisions regulate cleanup
activities because they take place in a floodplain.
• Coastal Zone Management Act, 16 U.S.C. §§1451 et.seq.; the
Coastal Management Plan for the City of Portsmouth; and the
National Oceanic and Atmospheric Administration (NOAA)
Regulations on Federal Consistency With Approved State
Coastal Zone Management Programs. These provisions regulate
cleanup activities because they take place in a cleanup
coastal area.
• Virginia's Chesapeake Bay Preservation Act (Code of Va.
§10.1-2100 et sea). and Chesapeake Bay Preservation Area
Designation and Management Regulations (VR §173-02-01)
regulate cleanup activities that take place in designated
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resource management areas and/or resource protection areas
as defined in the Chesapeake Bay Preservation Act.
• Virginia Erosion and Sediment Control Law (Code of Va.
§10.1-560 et seq.) and the Virginia Erosion and Sediment
Control Regulations (VR S625-02-00). These provisions
require control measures during earth-moving activities to
prevent erosion and transport of sediment in surface water
runoff.
• 40 C.F.R..Part 50, Appendix G establishes protocols for air
- monitoring to be conducted during the cleanup.
• 40 C.F.R. Part 264, Subpart I, and VR §10.8 Use and
Management of Containers regulate the use of containers for
storing and/or treating hazardous wastes during the cleanup.
• 40 C.F.R. Part 264, Subpart J, and VR $10.9, Tanks regulate
the use of tanks for storing and/or treating hazardous
wastes during the cleanup.
• 40 C.F.R. Part 264, Subpart L, and VR $10.11, Waste Piles
regulate the use of waste piles for storing and/or treating
hazardous wastes during the cleanup.
• 40 C.F.R. Part 268, Subpart E, Prohibitions on Storage
regulates the storage of hazardous waste restricted from
land disposal.
• 40 C.F.R. Part 262 and 263; 49 C.F.R. Parts 171-177; and'VR
Part VII, and the Virginia Regulations Governing the
Transportation of Hazardous Materials (VR $ 672-30-1) and
the Virginia Solid Waste Management Regualtions (VR $ 672-
20-1) regulate the transportation of solid and hazardous
wastes in the Commonwealth of Virginia.
• Virginia Solid Waste Management Regulations, Part VIII,
regulate the management of solid waste management facilities
in the Commonwealth of Virginia.
• Occupational Safety and Health Administration Act (OSHA), 29
C.F.R. Parts 1910, 1926, and 1904, regulate health and
safety requirements for workers during the cleanup.
Alternatives 4 and 8 would also both meet the following EPA
guidance considered to be relevant to this cleanup:
• Interim Guidance on Establishing Soil Lead Cleanup Levels at
Superfund Sites (EPA OSWER Directive 9355.4-02) recommends
use of the UBK Model and appropriate assumptions to develop
soil cleanup levels for lead.
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• Methods- for Evaluating the Attainment of Cleanup Standards,
Vol. I (EPA 230/02-89-042) recommends statistical methods to
confirm-cleanup levels have been achieved.
Balancing Criteria:
3. Long-Term Effectiveness and Permanence
Alternative 4 provides minimal residual risk and, therefore,
a high degree of long-term effectiveness since surface and
subsurface soil exceeding.health-based cleanup levels in OU1 are
excavated, treated as required on-site, and disposed of off-site
in a permitted RCRA landfill.
Under Alternative 8, contaminated soil would remain below
the depth of two feet in the commercial/industrial areas (except
the Abex Lot, which would be excavated down to the water table).
Contaminated soil beneath existing permanent covers such as
buildings, parking lots, sidewalks, and streets would also remain
in place (except beneath the following existing permanent covers:
asphalt on the Abex Lot, the McCready Lot, and the Holland
Property, the former foundry buildings on the Holland Property,
and the Effingham and Seventh Street homes). Therefore, the
residual risk associated with Alternative 8 would be higher than
that of Alternative 4 and Alternative 8 would be considered a
slightly less permanent; remedy than Alternative 4. By excavating
from the ground surface down to two feet in the
commercial/industrial areas, most of the contaminated soil will
be removed from the Holland Property and from the vacant lots,
according to the data that was obtained during the RI.
Institutional controls would be implemented to prevent future
exposure to contaminated soil that remains. Overall, Alternative
8 provides for a high degree of long-term effectiveness.
4. Reduction of Toxicitv. Mobility, or Volume through
Treatment
Lead, the primary contaminant of concern at the Site, is a
metallic element that cannot be destroyed to reduce its toxicity.
Therefore, remedies addressing lead contamination in soil
generally require either removal and/or stabilization by
immobiiiz ing the lead within the soil structure, thereby reducing
the mobility of the contaminant. Stabilization, however, results
in an increase in the volume of material to be addressed and will
not reduce the toxicity of the lead.
Under Alternative 4, surface and subsurface soil above the
water table, that is contaminated with lead above health-based
cleanup levels would be excavated, treated (as appropriate) to
reduce the. mobility of lead in the soil, and removed for off-site
disposal. For soil that is treated by stabilization, the
mobility of the lead will be reduced, but the volume of the lead-
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contaminated""soil will increase due to the addition of
stabilizing agents.
Under Alternative 8, soils which exceed health-based cleanup
levels would be excavated and treated, as appropriate, down to
the water table in residential areas and the Abex Lot, and to a
depth of two feet in remaining commercial/industrial areas to
reduce the mobility of the lead in the soil. The contaminated
soil will be moved for off-site disposal. Relatively small
quantities of contaminated soil are expected to remain below two
feet in commercial/industrial areas or beneath permanent covers
such as buildings, parking lots, sidewalks, and streets. In
addition, the mobility of lead in the soil is known to be low.
Therefore, Alternative 8 is considered to achieve the same
reduction in toxicity through treatment as Alternative 4.
5. Short-Term Effectiveness
The primary short-term effects associated with both
Alternatives are potential exposure to contaminated dust
generated during excavation and exposure to physical safety
hazards that exist around heavy equipment. Air-borne dust
containing elevated lead levels could be generated during soil
excavation required in Alternatives 4 and 8. The extent of soil
excavation is greater under Alternative 4 and, thus, the
potential for exposure to contaminated dust could be greater.
Additional dust could be generated during soil handling and
operation of soil treatment units on-site. However, measures
will be taken to control dust during implementation of either of
the Alternatives. These measures will be detailed in the
Remedial Action Work Plan and the associated Health and Safety
Plan which must be prepared and approved by EPA prior to
initiation of construction. Measures to be performed would
include: (1) dust suppression during excavation, handling, and
treatment activities; (2) sampling the interior of housing units
for contaminated dust before, during, and after remedial
activities to ensure dust suppression has been effectively
implemented; and (3) air monitoring for both lead and dust before
and during remedial activity.
Alternatives 4 and 8 would require temporary relocation of
residents during excavation and treatment of contaminated surface
and subsurface soil around their residential units. This action
would be taken to minimize the physical safety hazards associated
with heavy equipment operating in close proximity to residential
property. Details on the extent of excavation required for each
residential unit and the arrangement for temporary relocation
would be discussed with impacted residents during, the remedial
design process.
Both Alternatives require on-site treatment of excavated
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soils. The-Remedial Action Work Plan and Health and Safety Plan
would detail measures to be taken to secure the areas where soil
is stored .ptior to and during treatment to prevent air or water-
borne releases of contaminated soil and to prevent access by
local children. In addition, the -on-site soil treatment unit will
be housed in a temporary structure to minimize exposure to the
elements and the opportunity for any releases.
6. Implementability
Alternative 4, as proposed in the 1992 ROD, called for
extensive excavation of contaminated surface and subsurface soil,
including contaminated soil..that exists adjacent to foundations
and/or beneath homes or residential units. Due to the unstable
nature of soil or fill material around or under many of the
impacted residences and the proximity of the water table to the
ground surface (estimated at 3 to 6 feet), strict engineering
practices would need to be followed to prevent structural damage
to the homes during excavation. It was noted in the September,
1992 ROD that such excavation may in fact prove technically
impracticable upon further investigation.
For both Alternatives 4 and 8, implementation of on-site
treatment will require careful planning and additional
construction activities. In each case, treatability studies will
be necessary to determine the appropriate mixture of reagents
needed to effectively immobilize the lead in the soil.
Alternative 8 also requires extensive excavation of
contaminated surface and subsurface soil, although the depth of
excavation is reduced in commercial/industrial areas (except the
Abex Lot). Under Alternative 8, institutional controls would
have to be used to prevent future exposure to contaminated soil
that remains two feet or more below the surface, as well as
contaminated soil beneath existing permanent covers.
Neither Alternative would require excavation beneath
permanent covers such as buildings without crawl spaces, parking
lots, sidewalks, and streets.
Both Alternatives 4 and 8 are considered remedies that can
be readily implemented, although Alternative 4 may be more
technically difficult, depending upon the extent of contaminated
soil found under homes, and the engineering measures which would
be employed to excavate, if technically feasible.
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7. Cost"
The estimated present worth cost of Alternatives 4 and 8,
are $31,962,923 and $31,507,670, respectively.
Modifying Criteria:
8. State Acceptance
The Commonwealth has reviewed and commented oh the Proposed
ROD Amendment. The Commonwealth's comments have been
incorporated into the ROD Amendment.
9. Community Acceptance
During the public comment period, most of the community
expressed their approval of Alternative 8. However, some
residents living in Washington Park continue to express their
desire to be permanently relocated. The Portsmouth Redevelopment
and Housing Authority (PRHA) offered permanent relocation to
other public housing within the City to those residents who have
concerns about their health or the health of their families.
The residential homeowners are also in support of
Alternative 8, but have requested that EPA intervene if they do
not get what they consider to be fair market value for their
homes from the PRPs. As noted above, the City informed EPA of
its intention to rezone the Effingham Playground, Seventh Street
row home area, and the Effingham Residential area from
residential to light commercial/industrial and purchase the homes
for demolition. The decision to rezone, purchase, and demolish
the homes is a local governmental function and outside the
jurisdiction of EPA. During the public meeting and public
availability sessions on the Proposed Plan, EPA explained to the
residents and PRPs that the negotiations for purchasing homes
will be between the PRPs and the homeowner. EPA does not have
direct involvement in this process.
The City and the PRHA support Alternative 8, except that
they have requested that the areas that the City plans to rezone
to commercial/industrial, i.e.. the Effingham Playground and
Effingham residential area, Seventh Street row home area,
portions of Lincoln and Green Streets, be excavated down to a
depth of one foot instead of two feet. They have stated that
excavation to one foot in these areas is protective because the
area will be permanently covered by a police headquarters
building and parking lots to be built on these areas. EPA has
determined that since these areas are not currently permanently
covered and because they will be excavated for demolition and
construction activities anyway, excavation of contaminated soil
down to a maximum of two feet throughout the areas is appropriate
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and consistent with the standards established throughout this
Amended ROD.^Further, it is EPA's position that excavation of
lead-contaminated soil down to one foot is not protective of
human health in these areas due to the close proximity of
residents living in the Washington Park Housing Development.
X. SELECTED REMEDY AND PERFORMANCE STANDARDS
Based upon consideration of the requirements of CERCLA, the
detailed analysis of the Alternatives using the nine criteria and
public comments, EPA has determined that Alternative 8 is the
most appropriate remedy for the Abex Superfund Site. The major
components of the remedy and the required performance standards
are listed below.
A. Soil Excavation
1. Performance Standards;
• Soil exceeding 500 mg/kg lead in areas zoned for
residential use at the completion of the preliminary
remedial design and in the Abex Lot shall be excavated
to the water table. To the extent practicable, such
excavation shall be performed when the water table is
at the seasonally low elevation.
• Soil exceeding 500 mg/kg lead in the first foot and
1,000 mg/kg lead at depths between one and two feet
shall be excavated in areas zoned for commercial/light-
industrial use (except for the Abex Lot) as of the
completion of the preliminary remedial design; this
includes soil in the areas to be rezoned (i.e.. the
Effingham Playground, the Effingham residential area,
and the Seventh street row homes).
• Institutional land-use controls shall be implemented to
control any future excavation below the depth of two
feet in commercial/industrial areas to prevent exposure
to contaminated soil. EPA shall review, comment upon,
and approve all institutional controls to be
implemented as part of the remedial action for the
Site. These institutional controls may include: an
ordinance or regulation requiring a permit for, and
'imposing restrictions on, excavation in areas within
OU1 and requiring notice to EPA, the City, PRHA, and
the public prior to excavation in such areas; the
inclusion of provisions in deeds for properties within
OU1 providing notice of this CERCLA remedy and
restricting excavation on such properties; and the
placement of underground "warning sheets" in excavated
commercial/industrial areas before backfilling with
clean soil. The institutional controls shall be
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sufficient to ensure (l) that soils below two feet are
not disturbed in areas of OU1 zoned commercial/
-industrial after completion of this remedy without
prior notice to EPA, the City, PRHA, and the public,
and (2) if such soils are to be disturbed, the soils
shall be managed in a manner which will not endanger
public health or the environment.
• Soil beneath existing permanent covers (such as
buildings without crawl spaces, parking lots,
sidewalks, and streets), will not be removed. These
covers shall be maintained and EPA-approved
institutional land-use controls shall be used to
prevent future exposure to contaminated soil beneath
these covers. The following existing permanent covers
are not included in this provision and shall be removed
as part of the remedy: the asphalt covers on the Abex
Lot, the McCready Lot, and the Holland Property, the
former foundry buildings on the Holland Property, and,
if rezoning occurs, the Effingham and Seventh Street
residential homes. Contaminated soil beneath these
covers shall be excavated.
2. Additional Components;
• Temporary relocation shall be provided to residents
while excavation is occurring around residential units.
The extent of soil to be removed around each
residential unit under this ROD Amendment shall be
determined during the remedial design phase. The
specific arrangements for temporary housing shall be
based on the extent of soil to be removed and the needs
of the impacted residents. Efforts shall be made to
minimize inconvenience to residents. To the extent
practicable, the U.S. Department of Transportation
. Uniform Relocation Act and accompanying regulations
will be used as guidelines.
• Dust suppression measures shall be used to prevent
contaminated dust from rising into the air and from
entering homes or adjacent areas. Sampling of the
interior of nearby homes shall be performed before,
during, and after excavation to ensure that dust
control measures have been effective. Air monitoring
for lead and dust shall be performed in accordance with
40 C.F.R. Part 50, Appendix 6, to ensure air emissions
conform with the National Primary and Secondary Ambient
Air Quality Standards for lead (40 C.F.R. Part 50.12)
and particulate matter (40 C.F.R. Part 50.6); and the
Virginia Air Pollution Control Law (Code of Va. S10.1-
1300 et sea.), and the Virginia regulations for the
Control and Abatement of Air Pollution (VR S120-04,
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-12O-05 and 120-06) regulate air emmissions and
establish permissible levels of lead and particulate
jnajtter that can be released into the environment during
the cleanup activities.
Erosion and sediment control measures shall be
installed in accordance with the substantive
requirements of the Virginia Erosion and Sediment
Control Law, Code of Virginia §§ 10.1-560 et sea.. the
Virginia Erosion and Sediment Regulations, VR § 625-02-
00, and the City of Portsmouth's Erosion and Sediment
Control Ordinance.
All excavated areas shall be backfilled with clean
fill; areas vegetated prior to excavation shall be
restored to original conditions, to the extent
practicable.
Additional sampling and analysis of soil shall be
performed prior to excavation to determine the full
extent of contamination. Sampling and analysis shall
also be performed after excavation has been completed
to confirm that cleanup levels set forth in the
performance standards have been achieved. Methods for
determining that the cleanup goals have been reached
shall be finalized during remedial design and
approved by EPA based on EPA 230/02-89-042, Methods
for Evaluating the Attainment of Cleanup
Standards. Vol. I.
Excavated soil and waste materials shall be temporarily
staged on-site in accordance with 40 C.F.R. Part 264,
Subpart L., and VR §10.11, Waste Piles, prior to
treatment and/or transportation to an off-site disposal
facility. To the extent practicable, excavated soil
and waste material shall be staged in areas of existing
contamination, e.gf. the Abex Lot, the Holland
Property, McCready Lot, or the vacant lots.
Containment measures, such as berms and temporary
covers, shall be used in areas with staged material to
ensure that there are no unacceptable air or water-
borne releases of contamination from these areas.
These measures shall be sufficient to provide such
protection in the event of flooding. Areas that are
used to stage excavated material shall be secured with
a fence to prevent trespassing.
When the final areas of contamination are being
addressed, excavated* soil and wast9 materials may need
to be staged in an areas where cleanup has previously
occurred. In all instances where soil and waste
materials are staged in areas where cleanup has
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previously occurred, or are otherwise not contaminated
above levels requiring excavation, soil and waste
material shall be staged in containers in accordance
with RCRA regulations contained in 40 C.F.R. Part
268.50; containers used shall be in compliance with 40
C.F.R. Part 246f Subpart I and VR $10.8 Use and
Management of containers.
B. Soil Treatment And Disposal
1. Performance Standards;
• Excavated soil and waste materials shall be tested
using TCLP to determine if they exhibit toxicity, as
defined in 40 C.F.R. Part 261, Subpart C. Contaminated
soil and waste materials that do not exhibit toxicity
shall be disposed of off-site at a permitted RCRA
Subtitle D landfill.
• Soil and waste material that exhibits toxicity due to
the leaching of lead or other metals of concern shall
be handled as a RCRA hazardous waste, as defined in 40
C.F.R. Part 261, Subpart C. Such material shall be
treated prior to disposal using a stabilization process
that mixes the excavated soil and waste materials with
chemical/reagents to create a final product that
.encapsulates and immobilizes lead and other metals.
Specific chemicals to be used the process shall be
determined in a treatability study during the remedial
design phase of this project. Mixing shall be
contained in above-ground equipment on-site in
accordance with VHWMR SI0.9, Tanks.
• Treated material shall be tested using TCLP to ensure
that it no longer exhibits toxic characteristics.
Treated material that continues to exhibit toxicity
shall either be subject to additional treatment to
further reduce toxicity, or disposed of off-site in an
approved RCRA Subtitle C landfill, after RCRA land
disposal restriction requirements have been met.
Treated material that no longer exhibits toxicity using
TCLP shall be disposed of off-site in a permitted RCRA
Subtitle D landfill. If a disposal facility in
Virginia is used, the treated waste is considered a
"special waste" under Part VIII of VSWMR and specific
approval from VDEQ's Director shall be obtained prior
to disposal.
2. Additional Components;
• Air monitoring for lead and dust shall be performed in
accordance with 40 C.F.R. Part 50, Appendix 6, to
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-ensure air emissions conform with the National Primary
and Secondary Ambient Air Quality Standard for lead, 40
XJ'.R. § 50.12, and particulate matter, 40 C.F.R.
S 50.6. Air monitoring shall be done before, during and
after the remedial work. Fugitive dust emissions shall
also be controlled in accordance with Virginia Air
Pollution Control Board Regulations, VR S 04-0101.
• The on-site soil treatment unit shall be housed in a
temporary structure to minimize exposure to the
elements and the opportunity for air or water-borne
releases.
• Treated material that no longer exhibits tqxicity using
TCLP shall be staged on-site in containers in
preparation for transporation. Treated material that
continues to exhibit toxicity shall be staged in
accordance with the same requirements described above
for staging untreated excavated soil and waste
materials.
• Any transportation of hazardous waste from the Site
shall be performed in accordance with VHWMR Part VII,
Regulations applicable to Transporters of Hazardous
Waste (VR SS 672-30-10), the Virginia Solid Waste
Management Regulations (VR SS 672-20-10); 40 C.F.R.
Parts 262, 263, and 268; and 49 C.F.R. Parts 171-17.
Any local roads damaged by the increased truck traffic
associated with the remedial action shall be repaired
in a timely manner following the conclusion of the on-
site activity.
• Any off-site discharge of water generated from the
on-site soil treatment system or from Site
decontamination activities shall be in compliance with
the Virginia Surface Water Standards and the Virginia
Pollution Discharge Elimination System (VPDES)
requirements. Any disposal of wastewater at a local
Publicly-Owned Treatment Works (POTW) shall be in
compliance with the POTW's VPDES permit and pre-
treatment standards or requirements.
• Any treatment and/or storage units used during the
remedial action (i.e.f waste piles, tanks or containers
.for storage or treatment) that are regulated under
VHWHR/RCRA requirements shall meet .the closure and
post-closure care requirements of 40 C.F.R. Part 264,
Subpart G and VR 59.6, Closure and Post-Closure.
c. Building Demolition
1. Performance Standard;
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• AIT: "existing structures on the Holland Property
associated with the former foundry operations, the
*f*ingham. residential lots and the Seventh Street row
home lots shall be demolished. Debris resulting from
. such demolition which exhibits toxicity using TCLP
shall be decontaminated in accordance with RCRA land
disposal restriction requirements effective at the time
when demolition occurs. Debris which continues to
exhibit toxicity after decontamination shall be
disposed of in a permitted RCRA Subtitle C landfill.
Debris that does not exhibit toxicity shall be disposed
of in a permitted RCRA Subtitle D landfill.
2. Additional Components; . -.
• Equipment which is contaminated with or constitutes a
RCRA hazardous waste shall be disposed of off-site in
accordance with the.requirements of RCRA Subtitle C,
including the LDR requirement. Equipment which is not
contaminated with or is not a RCRA hazardous waste, or
which is decontaminated so that it no longer is
contaminated with or constitutes a RCRA hazardous
waste, may be used or disposed of off-site in a manner
.not inconsistent with applicable laws or regulations.
Residuals generated as a result of decontamination
activities shall be tested under TCLP and disposed of
as required by RCRA Subtitle C and any other laws or
regulations which may be applicable to such wastes.
XI. STATUTORY DETERMINATIONS
EPA's primary responsibility at Superfund sites is to
undertake remedial actions that achieve adequate protection of
human health and the environment. In addition, Section 121 of
CERCLA, 42 U.S.C. S 9621, establishes several other statutory
requirements and preferences. Under this Section, the selected
remedy for the Site, when completed, must comply with ARARs
established under Federal and State laws unless a statutory
waiver is justified. The selected remedy must also be cost-
effective and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable. Finally, CERCLA includes a
preference for remedies that employ treatment that permanently
and significantly reduce the volume, toxicity or -mobility of
contamination as their principle element. This Section discusses
how the selected remedy meets these statutory requirements.
A. Protection of Human Health and the Environment
At the time the baseline risk assessment was done, the
baseline risk assessment determined that surface soil
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contamination at the Site presented a current unacceptable risk
to residents and would pose unacceptable risks to workers within
the former foundry building. The average lead concentration
exceeded 400 mg/kg in surface soil in the Effingham residential
area, on the Holland Property, and in the vacant lots. JThe Site
would _also_ poge^an unaccepjtable^ future risk^tojnBsidentsT as a
jresu ItZaJL^BgEen^ia 1 exposurglgr oDntaminaed
Average lead concentrations exceeded 40
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The Resource Conservation and Recovery Act, (40 C.F.R. Parts
261-270); the Virginia Waste Management Act (Code of Va. SS
10.1--T4tro e£ sea.) ; the Virginia Waste Management -.-
Regulations (VR S672-10-1); and the Virginia Solid Waste
Management Regulations.. (VR S 672-20-10). These, provisions
regulate the transportation, treatment, storage, and
disposal of hazardous, wastes that occur during the cleanup.
Clean Water Act; National Pollution Discharge Elimination
System requirements, (40 C.F.R. Part 122); the Virginia
Water Control Lav (Code of Va. $62.1-44.2 et seq.) ; and the
Virginia State Water Control Board regulations (VR £680-21-
00). These regulate any discharge of wastewater generated
during the cleanup to the waters of the Commonwealth of
Virginia.
National Primary and Secondary Ambient Air Quality Standards
for Lead (40 C.F.R. Part 50.12) and for Particulate Matter
(40 C.F.R. Part 50.6); the Virginia Air Pollution Control
Law (Code of Va. S10.1-1300 et sea.1; the Virginia
regulations for. the Control and Abatement of Air Pollution
(VR §120-04, 120-05 and 120-06); and the Virginia State
Implemetation Plan, 40 C.F.R. Part 52, Subpart W regulate
air emissions and establish permissible levels of lead and
particulate matter that can be released into the environment
during the cleanup activities.
2. LOCATION-SPECIFIC ARARs
Executive Order 11988, Floodplain Management; the National
Flood Insurance Act of 1968; the Flood Disaster Act of 1973;
and Procedures for Implementing the Requirements of the
Council on:Environmental Quality on the National
Environmental Policy Act. These provisions regulate cleanup
activities because they take place in a floodplain.
Coastal Zone Management Act, 16 U.S.C. SS1451 et.sea.; the
Coastal .Management Plan for the City of Portsmouth; and the
National Oceanic and Atmospheric Administration (NOAA)
Regulations on Federal Consistency With Approved State
Coastal Zone Management Programs. These provisions regulate
cleanup activities because they take place in a cleanup
coastal area.
Virginia's Chesapeake Bay Preservation Act (Code of Va. S
10.1-2100 et seq.) and Chesapeake Bay Preservation Area
Designation and Management Regulations (VR S 173-02-01)
regulate cleanup activities that take place in resource
management and/or research protected areas as designated in
the the Chesapeake Bay Preservation Act.
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3. -ACTION-SPECIFIC ARARs
Virginia Erosion and Sediment Control Law (Code of Va.
§10.1-560 et sea.l and the Virginia Erosion and Sediment
Control Regulations (VR S625-02-00). These provisions
require control measures during earth-moving activities to
prevent erosion and transport of sediment in surface water
runoff.
40 C.F.R. Part 50, Appendix 6 establish protocols
for air monitoring to be conducted during the cleanup.
40 C.F.R. Part 264, Subpart I, and VHWMR Section 10.8 Use
and Management of Containers regulate the use of containers
for storing and/or treating hazardous wastes during the
cleanup.
40 C.F.R. Part 264, Subpart J, and VHMR Section 10.9, Tanks
regulate the use of tanks for storing and/or treating
hazardous wastes during the cleanup.
40 C.F.R. Part 264, Subpart L, and VHWMR Section 10.il,
Waste Piles regulate the use of waste piles for storing
and/or treating hazardous wastes during the cleanup.
40 C.F.R. Part 268, Subpart E, Prohibitions on Storage
regulates the storage of hazardous waste restricted from
land disposal.
40 C.F.R. Part 262, 263, and 268, 49 C.F.R. Parts 171-177,
and VHWMR Part VII, the Virginia Regulations Governing the
Transportation of Hazardous Materials (VR §672-30-1) and
the Virginia Solid Waste Management Regulations (VR §672-20-
1) regulate the off-site transportation of solid and
hazardous wastes in the Commonwealth of Virginia.
Virginia Solid Waste Management Regulations, Part VIII,
regulate the management of solid waste management facilities
in the Commonwealth of Virginia.
Occupational Safety and Health Administration Act (OSHA), 29
C.F.R. Parts 1910, 1926, and 1904, regulate health and
safety requirements for workers during the cleanup.
C. Criteria, Advisories, or Guidance To Be Considered
(TBCs):
Interim Guidance on establishing Soil Lead Clean-up Levels
at Superfund Sites (EPA OSWER Directive 9355.4-02)
recommends use of the UBK Model and appropriate assumptions
to develop soil clean-up levels for lead.
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• Methods" for Evaluating the Attainment of Cleanup Standards,
Vol. I (EPA 230/02-89-042) recommends statistical methods to
confirm- soil clean-up levels have been achieved;
D. Cost Effectiveness
Alternative 8 is less expensive than the remedy (Alternative
4) selected in the 1992 ROD. EPA believes that Alternative 8
will eliminate unacceptable risks to human health at the Site at
an estimated cost of $31,507,670 and, therefore, provides an
overall benefit proportionate to its costs;
B. Utilization of Permanent Solutions and Alternative
Treatment Technologies to the Maximum ExtentPraoticable
Section 121(b) of CERCLA, 42 U.S.C. S 9621(b), establishes a
preference for remedial actions that permanently and
significantly reduce toxicity, mobility, or volume of hazardous
substances over remedial actions which will not. EPA has
determined that the selected remedy represents the maximum extent
to which permanent solutions and treatment technologies can be
utilized in a cost-effective manner to control contamination at
the Abex Site. Of those alternatives that are protective of
human health and the environment and comply with the ARARs, EPA
has determined that Alternative 8 provides the best balance of
trade-offs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility, or volume through treatment,
short-term effectiveness, implementability, and cost, while also
considering the statutory preference for treatment as a principal
element, and state and community acceptance.
Alternative 8 also treats lead-contaminated soils that
exhibit toxicity, as determined using TCLP, thereby achieving
significant reduction of the mobility of lead in soil. The
selection of treatment of the contaminated soil is consistent
with program expectations that indicate that highly toxic wastes
are a priority for treatment and often necessary to ensure the
long-term effectiveness of a remedy.
7. Preference for Treatment as Principal Element
By treating the contaminated soil determined to exhibit
toxicity by TCLP testing, Alternative 8 addresses the principal
threats posed by the Site through the use of treatment
technologies and satisfies the statutory preference for remedies
that employ the treatment element.
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes have been made to the remedy since
its publication in the Proposed Plan to Amend the September 1992
ROD.
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RECORD OF DECISION AMENDMENT
ABEX CORPORATION SUPERFUND SITE
PART III - RESPONSIVENESS SUMMARY
I. INTRODUCTION
During the public comment period on the Proposed Plan to
Amend the September 1992 ROD fpr the Abex Site, EPA received
three letters commenting on the cleanup alternatives. In
addition, oral comments were recorded by a stenographer at the
public meeting held on February 23, 1994, and tape recorded at
the public availability sessions (meetings) held with local
residents on February 22, 1994. EPA has carefully reviewed these
comments and organized them into the following major categories:
• Migration of lead under covered areas
• Excavation of lead exceeding 500 mg/kg under buildings
and parking lots controlled by the local government to
a depth of one foot
• Assurance that the Effingham and Seventh Street Row
homeowners receive the same cleanup as provided in
the original ROD if the homes are not purchased
• Assurance that homeowners are fairly compensated for
their homes
EPA's responses to the public comments are presented below.
Copies of the letters submitted to EPA are included in the
Administrative Record and identified in the index of documents
for the Administrative Record in Appendix A.
II. MIGRATION OF LEAD UNDER COVERED AREAS
1) One resident questioned how lead can be prevented from
migrating from under covered areas, such as the drug
rehabilitation center parking lot, and what the lead
concentrations are at the drug rehabilitation center.
Responses The main concern regarding risks posed by lead
contamination is that of direct exposure through ingestion
(eating) and inhalation (breathing). Where areas are
covered or capped, such as the drug rehabilitation center
parking lot, there is an.impervious barrier preventing human
contact with soil at the ground surface and preventing rain
and surface water from infiltrating into the underlying
soil. In addition, transportation of contaminated soil by
wind and water erosion is prevented by the impervious
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covers." According to the results of groundwater samples
obtained from monitoring wells installed at the Site during
the R*,—lead has not migrated much either laterally or
vertically down to the underlying groundwater. This finding
is not surprising as lead tends to bind to fine-grained
materials in the soils and the contamination at this site is
due mainly from landfill ing of foundry-contaminated soils.
The well that was drilled directly into the highly
contaminated Abex Lot did exceed EPA's recommended 15 ug/1
cleanup level for lead in groundwater. The Abex Lot will be
excavated to the 500 mg/kg lead level down to the water
table. The covered areas will require maintenance to ensure
that the remedy remains protective of human health and the
environment. Results of samples obtained during the RI
indicate that the highest concentrations of lead under the
drug rehabilitation center parking lot are approximately
6,500 mg/kg lead.
III. EXCAVATION OF SOIL TO A DEPTH OF ONE FOOT
1) Letters from the City of Portsmouth (the City) and from the
Portsmouth Redevelopment and Housing Authority (PRHA)
requested that the revised ROD include language which
"recognizes that excavation of 24 inches of soil will not be
necessary at portions of the Site that will be under
governmental ownership and control and on which permanent,
non-residential structures, will be placed1*. The City
supported this request with its statement that the City
would be rezoning the three block area bounded by Green,
Lincoln, and Effingham Streets and the Effingham Playground,
from residential to industrial and imposing restrictions on
excavation, deed restrictions and building codes. The City
also stated that the City and/or the PRHA intends to take
title to properties located in the existing Effingham
residential area and build a police station and parking lot
at that location.
Response: Under Alternative 8, soil exceeding 500 mg/kg lead
in all areas zoned for commercial/industrial use, except the
Abex Lot, would be excavated from the surface to a depth of
one foot. Soil below one foot which exceeds 1,000 mg/kg
lead in these areas will be excavated to a depth of two
feet. Institutional land-use controls would be implemented
to control future excavation below two feet and to prevent
exposure to contaminated soil. EPA has determined that the
two foot depth is necessary to protect human health and the
environment in all commercial/industrial areas that do not
have existing covers or where existing covers will be
disturbed. The .City's plans do not involve merely leaving
these existing permanent covers in place. In fact, the
construction of a police headquarters and parking lot will
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[i
require demolition and excavation activities. In addition,
the close proximity of this area to residents living in the
Washington Park Housing Development warrants this two foot
level.
IV. HOMEOWNER'S CONCERN IF HOMES ARE NOT PURCHASED
1) Several residents voiced a desire to have the proposed ROD
drafted so that the September, 1992 ROD (Alternative 4.)
remedy would be performed if, for some reason, proposed
Alternative 8 is not implemented and their homes are to
remain at the Site. .
Response: EPA has selected Alternative 8 as the remedy for
OU1. The City has proposed the rezoning from residential to
commercial/industrial the Effingham residential area and the
area of the Seventh Street row homes, as well as the
Effingham playground. The PRPs plan to purchase the private
residential properties in independent, arms-length
transactions or acquisition by the City through eminent
domain. If, for any reason, the rezoning does not occur by
completion of the preliminary remedial design, then the
residential health-based levels specified in the ROD
Amendment must be met, .i.e., soil that contains lead in
excess of 500 ing/kg will be excavated down to the water
table. Homes.haying crawl spaces with dirt floors will
require further investigations during the remedial design to
determine an appropriate method to remediate the
contaminated soil. Institutional controls will be required
to prevent any future exposure to contaminated soil
remaining beneath existing permanent covers on residential
property.
V. FAIR COMPENSATION TO HOMEOWNERS
1) Several Effingham and Seventh Street row home residents
voiced a concern about being fairly compensated for their
homes.
Response: As explained to the residents during the
availability sessions held on November 8-10, 1993, in
; Portsmouth, EPA has no jurisdiction.regarding rezoning or
the proposed home acquisitions and, therefore, cannot
provide any assurances to residents in that regard. The
City's October 19, 1993 letter entitled, "Revision to the
Record of Decision" informed EPA that the city had begun to
take actions to rezone three city blocks bordered by
Effingham, Lincoln, Green Streets, and the Effingham
Playground. The City informed EPA that this area will be
rezoned from residential to industrial use, and that a
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police Headquarters building and associated parking lots
would be built in that location. In addition, the City
stated -*hat the privately-owned homes in the Effingham
residential area and the Seventh Street row hones would be
acquired through arm's length purchases or acquisition by
the City by eminent domain, if necessary.
As noted above, EPA conducted public availability
sessions from November 8, 1993 to November 10, 1993 to
solicit input from residents regarding the PRPs' proposed
changes to the ROD, one of which was to purchase and
demolish certain residences on Effingham and Seventh
Streets. The private homeowners responded favorably to the
proposal. During the public availability sessions and the
public meeting, EPA informed affected residents that the
rezoning and land-use issues, including any purchase of
homes, were solely vithin the jurisdiction of local
government and that EPA has no input into making these
decisions.
VI. COMMENTS RECEIVED PRIOR TO THE PUBLIC COMMENT PERIOD
A letter was submitted by counsel representing certain
individuals living in Washington Park in response to the
proposals by the City, Abex, and the PRHA prior to the issuance
of the Proposed Plan to Amend the September 1992 ROD and the
opening of the public comment period. This letter will be
addressed even though it was submitted prior to the statutory
public comment period and addresses the PRPs' proposal (not EPA's
Proposed Plan to Amend the September 1992 ROD).
1) The commentor acknowledges that no one is opposed to
rezoning portions of the Site and locating police facilities
in the rezoned area, but objects to the proposed excavation
to one foot in this area as non-protective of Washington
Park residents.
Responses As indicated above, EPA agrees with the commentor
and is requiring excavation to a depth of two feet, i.e..
soil exceeding 500 mg/kg lead will be excavated to one foot
and soil exceeding 1,000 mg/kg lead will be excavated to a
depth of two feet. EPA has determined that this additional
foot will ensure that residents will not be exposed to lead-
contaminated soil from normal activities such as planting in
this rezoned area. Also, the Amended ROD calls for the
implementation of institutional land use controls which will
control all construction, and excavation activities which
could possibly result in the disruption of contaminated soil
left below the two foot level.
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2) The eommentor suggests that the only solution to protect the
health and safety of the Washington Park residents is to
relocate all residents who live within or adjacent to the
Site and that such a proposal enjoys widespread support.
Response: EPA has determined that the measures to be
undertaken- in the Amended ROD will protect the Washington
Park residents from potential exposure to lead-contaminated
soils. As described in detail above, excavation of any
areas of the Washington Park development exceeding 500 mg/kg
of lead will be down to the water table. Also, lead does
not tend to migrate horizontally or vertically through
soils. The groundwater beneath the Site is not potable and
is, therefore, not a drinking source for Portsmouth
residents7. All commercial/industrial areas will be
excavated to a depth of two feet (except the Abex Lot, which
will be excavated to 500 mg/kg lead to the water table) and
all future construction activities within the Site will be
strictly controlled by various institutional land-use
controls. Further, at the various availability sessions and
the public meeting held by EPA following issuance of the
Proposed Plan to Amend the ROD, the majority of Site
residents that attended these meetings indicated support for
the Plan with a few Washington Park residents stating their
continued desire to relocate. There has also been an offer
made by the PRHA to relocate Washington Park residents to
other available public housing in the Portsmouth area if
they do not believe that Washington Park is safe for them or
their families due to the lead contamination.
3) The eommentor has also stated that EPA has not had any
experience with dismantling contaminated equipment and/or
buildings "right in the middle of a heavily populated area"
and that neither the ROD nor the PRPs' proposal require
adequate measures to protect Washington Park residents both
during and after the dismantling of the foundry.
Response: EPA has had experience with dismantling and/or
demolishing highly contaminated structures in residential
areas. At the Austin Avenue Site in Lansdowne,
Pennsylvania, EPA dismantled a warehouse that was highly
contaminated with radiation and located in a residential
neighborhood. EPA has already demolished one contaminated
building at the Site. The following stringent precautions
will be followed during demolition: dust suppression
measures will be used to ensure that unacceptable releases
of air-borne contamination do not occur; air will be
monitored for both dust and lead levels during remedial
7 Further groundwater studies will be undertaken in
Operable Unit 2.
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activities to protect the health of on-site workers and the
community. EPA and/or their representatives will be on-site
during -the demolition to ensure that activities proceed in
accordance with approved requirements. If at any time there
is an indication through visual observation or monitoring
data that there are releases of contaminants above safe
levels, immediate action will be taken to correct the
situation and protect the health and safety of the
residents.
4) The commentor suggests that the standard by which EPA
determines whether relocation of residents will occur is
"when [that] remedy is more cost-effective than cleanup
measures."
Response: There are nine criteria that EPA must evaluate in
making its selection of a Site remedy (see 40 C.F.R. S
300.430(e)(9)(iii). One of the nine criteria involves a
determination of the cost effectiveness of the remedy,
however, this provision also requires that the measure be
"... protective of human health and the environment and
meet[s] the other requirements of the statute." EPA
carefully evaluated all of the nine criteria in selecting
the preferred alternative selected in this Amended ROD.
While the cost of relocation was investigated by EPA as part
of the remedy selection process, permanent relocation is not
part of the remedy because the Site remedy will be
protective of human health and the environment and,
therefore, there is no justification for permanent
relocation. As a further protective measure designed
primarily to ensure against problems associated with the use
of heavy equipment in a residential setting, the Amended ROD
provides for the temporary relocation of Washington Park
residents during excavation activities near residents'
particular units.
5) The commentor suggests an inequitable treatment of
Washington Park residents versus independent homeowners at
the Site due to the proposal by the city to buy certain
homes located in the Lincoln, Green, Effingham, and Seventh
Street area.
Response: The Amended ROD calls for the excavation of all
soil exceeding 500 mg/kg lead to the water table in the
Washington Park development. Institutional controls will be
used to prevent excavation beneath the foundations of the
units. The Effingham and Seventh Street homes will be
demolished and the area cleared for the construction of a
police headquarters and associated parking lots. The
decision to rezone the Effingham and Seventh Street areas to
commercial/industrial and purchase the homes for demolition
was made by the City and not EPA. EPA, through this ROD
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Amendment, is merely establishing health-based lead levels
permitted in soils in areas based on a particular usage,
i.e.. "residential versus commercial/industrial. The
Washington Park residents will be fully protected by the
excavation of contaminated soils above 500 mg/kg lead to the
water table, coupled with the use of institutional controls
to prevent excavation beneath the housing units. If the
rezoning and demolition does not occur, the Effingham and
Seventh Street homes will be treated in the same fashion as
the Washington Park units.
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