PB98-963910
                              EPA 541-R98-066
                              October 1998
EPA Supei fund
      Record of Decision:
      Langley AFB/NASA Langley Center
      Area E Warehouse OU
      Hampton, VA
      9/28/1998

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     RECORD OF DECISION




NASA LANGLEY RESEARCH CENTER






    AREA E WAREHOUSE OU
        September 1998

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                                      RECORD OF DECISION
                              NASA LANGLEY RESEARCH CENTER

                                         DECLARATION

 SITE NAME AND LOCATION

 NASA Langley Research Center (NASA LaRC)
 Area E Warehouse Operable Unit
 Hampton. Virginia

 STATEMENT OF BASIS AND PURPOSE

 This Record of Decision (ROD) presents the selected remedial action for the Area E Warehouse Operable Unit
 (OU) at the NASA Langley Research Center (LaRC) in Hampton, Virginia (the "Site"), chosen in accordance
 with the Comprehensive Environmental Response. Compensation, and Liability Act (CERCLA) of 1980. 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. Pan 300.  This decision is based on the Administrative Record for
 this Site.

 The Virginia Department of Environmental Quality (VDEQ) concurs with the selected remedy.

 ASSESSMENT OF THE SITE

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

 DESCRIPTION OF THE SELECTED REMEDY

The Area E Warehouse OU cleanup is part of a comprehensive environmental investigation and cleanup currently
being performed at the NASA LaRC under the CERCLA program.  NASA LaRC is currently addressing five
OUs under its environmental  remediation program. The remaining four OUs will be addressed in future RODs.

This action addresses the principle threat at the OU by imposing land use restrictions that will prevent any non-
industrial activities to take place on the OU.

The selected remedy is the implementation of institutional controls, which include:
        1)  the prohibition of use of the property for purposes other than industrial (e.g., residential,  child care
       or recreational use);
       2)  inputting these restrictions in the NASA LaRC Master Plan;
       3)  within 90 days of ROD signature. NASA shall produce a survey plat prepared by a professional land
       surveyor registered by the Commonwealth of Virginia indicating the location and dimensions of the Area
       E Warehouse Operable Unit and the extent of the soil contamination. The plat shall contain a note.
       prominently displayed, which states the owner's future obligation to restrict the land use of the property.
       The plat shall be submitted to the local recording authority;
       4)  NASA shall incorporate these restrictions and supply a copy of the plat into any real property
       documents necessary for transferring ownership  from NASA, in the unlikely event that NASA sells the
       property.  The real property document would also include a discussion of the National Priorities List
       (NPL) status of this Site, as well as a description of the soil contamination;
       5)  The NASA LaRC Environmental Engineering Office Head will certify to USEPA on an annual basis
       that there have been  no violations of these prohibitions.  If a violation has occurred, a description of the
       violation and corrective actions to be taken will be provided.

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  DECLARATION OF 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
 for this OU.

 Because this remedy may result in hazardous substances remaining onsite, a review will be conducted within 5
 years after the commencement of the remedial action to ensure that the remedy continues to provide adequate
 protection of human health and the environment.
Or. Jertfiiah F. Creedon                                Date
Director
NASA Langley Research Center
Abraham Ferdas                                       Date
Director
Hazardous Site Cleanup Division
U.S. Environmental Protection Agency, Region III

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                              TABLE OF CONTENTS




 SECTION                                                               PAGE




 I.      SITE NAME, LOCATION AND DESCRIPTION                                1




 II.     SITE HISTORY                                                      2




 III.     HIGHLIGHTS OF COMMUNITY PARTICIPATION                             3




 IV.     SCOPE AND ROLE OF THIS REMEDIAL ACTION                             4




 V.     SUMMARY OF SITE CHARACTERISTICS/EXTENT OF CONTAMINATION            4




 VI.     SUMMARY OF SITE RISKS                                             7




 VII.    DESCRIPTION OF ALTERNATIVES                                       9




 VIII.    SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES                   10




 IX.     SELECTED REMEDY                                                  12




X.     STATUTORY DETERMINATIONS                                         13




XI.    DOCUMENTATION OF SIGNIFICANT CHANGES                             14




XII.   RESPONSIVENESS SUMMARY                                          14




XIII.   REFERENCES                                                       16

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                                 LIST OF TABLES AND FIGURES


 TABLE             ~~       DESCRIPTION                                             PAGE

 1                            Summary of Operable Units under CERCLA Investigation          2

 2                            Exposure and Intake Assumptions for Dermal Contact and Ingestion   A-1

 3                            Area E Warehouse Hazard Index and Excess Cancer Risk, NASA     A-2
                             Langley Research Center

 4                            Clean-up Soil Concentration Area E Warehouse/Surface Soil, NASA  A-4
                             Langley Research Center

 5                            Screening of Soil Remedial Technologies, Area E Warehouse Site,    A-5
                             NASA Langley Research Center

 6                            Summary of Alternative Screening Soil Remedial Technologies,      A-11
                             NASA Area E Warehouse


 FIGURE                      DESCRIPTION                                             PAGE

 1                            Site Location Map                                            IA

 2                            Area E Warehouse Layout                                     IB

 3                            Soil Sampling Locations, NASA LaRC Site Assessment            6A

4                            Soil Sampling Locations, Contamination Assessment               6B

5                            Monitoring Well Locations for Area E Warehouse                 1A

6                            Area E Warehouse Sediment Sampling Locations                  7B

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                                       RECORD OF DECISION

                                NASA LANGLEY RESEARCH CENTER
                              AREA E WAREHOUSE OPERABLE UNIT

                                        DECISION SUMMARY

 I.      SITE NAME. LOCATION. AND DESCRIPTION

 NASA LaRC is a 787-acre NASA research center located in southeastern Virginia in the Hampton Roads area.
 NASA LaRC is bounded by State  Route  172 on die West, by Brick Kiln Creek to the North and byLangley Air
 Force Base to the South and East (Figure 1).  NASA LaRC together with Langley Air Force Base  was proposed
 to the National Priorities List (NPL) in 1993 and finalized in 1994.

 The Area E Warehouse OU is located along the eastern boundary between NASA LaRC and Langley Air Force
 Base.  The  Area E Warehouse OU is approximately 4.5 acres in size (Figure 2).  The area  houses several
 structures which encompass approximately * of die OU.  The site includes  the area immediately surrounding
 Buildings  1170 to  1174 as shown in Figure 2.  Storm sewers located on the site discharge into a small ditch
 approximately 120 feet long located immediately adjacent to the Area E Warehouse OU. The ditch discharges
 into the site-wide drainage system which ultimately discharges into theTabbs Creek estuary.  The  distance from
 the drainage ditch to Tabbs Creek is approximately 14 of a mile.

 The Area E Warehouse OU serves as a storage and distribution center for all supplies and materials for the NASA
 LaRC facility.  The area includes mainly asphalt and gravel road surfaces and warehouse structures.  Drums,
 which are stored on  pallets, containing  raw  products (lubricating oils,  solvents, etc.) to be issued for use
 throughout the Center, rolls of electrical conduit,  and miscellaneous equipment occupy approximately 40 percent
 of the warehouse area.  Approximately 10 percent of the area is covered with grass.

 The OU is in close proximity to Tabbs Creek and widiin die tidal zone of the Chesapeake Bay (Figure 1).  Marine
 wetlands are common in the  surrounding area, and the Plum Tree Island National Wildlife  Refuge is  located
 approximately four miles northeast of the OU. The northeast portion of the OU is located within the 100-year
 flood plain, coinciding approximately with die 8.5-foot elevation contour.

 The site is located within the Atlantic Coastal Plain physiographic province. The geology of the area, primarily
 flat lying marine sediments, consists of die Norfolk Formation and the Yorfctown Formation.  The uppermost soil
 unit at the site consists of varying sequences of silt, clay, and silty to clayey sands belonging to the  Norfolk
 Formation. In the boring drilled for the Site Inspection, this unit occurs from 0 to 9 feet in depth  and consists of
 brown, mottled orange and gray soils. They are typically dry to moist and slightly to moderately plastic.  The
 underlying Yorktown  Formation  consists of  gray silty clay  and clayey silt with abundant  shells  and  shell
 fragments.  It is typically wet to saturated, moderately to highly plastic and  occasionally mottled.  Local sand
 lenses are common, as are partially  indurated shelly layers  (coquina).  The Yorktown  Formation extends to
approximately 400 feet below grade at the site.

Groundwater in the area can be found at a depth of 5 to 50 feet below the land surface.  This aquifer, known as
the  Columbia aquifer,  is brackish and is limited to lawn and garden watering.   Both the Yorktown  and the
Yorktown-Eastover aquifers underlie the Columbia aquifer. The Yorktown-Eastover aquifer is confined and is
used as a source of domestic potable water.

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                       FIGURE 1
                  SITE LOCATION MAP
                  NASA LARC AREA E

           Prepared by Ebasco Services incorporated
1A

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                     ^
                       AREA  E  WAREHOUSE
•2519100

     LEGEND
26I99SO
-••"•AREA BOUNDARIES i
— — » SITE BOUNDARY j\
	 	 PROPERTY LINE ^ n , tn
	 ROADS -"- ° 'V0
' ' FENCES A Sco'«"m F-tti
' i BUILDINGS II
• CATCH BASIN (4
•


FIGURE 2
AREA E WAREHOUSE LAYOUT
Prepared by: Ebasco Services Inc.

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  II.     SITE HISTORY

  This section describes the history of waste disposal, and CERCLA investigations response actions at the Site.

  A.     HISTORY OF WASTE DISPOSAL

  The primary function of NASA LaRC is the research and development of advanced technologies for aircraft and
  spacecraft.   Specific studies center on instrumentation, materials fatigue, acoustics, aerodynamics, and guidance
  control.  In conducting  its research and development mission. NASA LaRC requires many  support facilities
  including Underground Storage Tanks (USTs) for fuel and  other raw products,  power plants,  wind tunnels.
  laboratories  and administrative buildings.  All of these facilities have the potential to impact the environment
  through disposal activities, transfer operations and inadvertent releases such as spills or mechanical malfunctions.

 There are currently 5  Operable Units being  investigated under CERCLA at  NASA LaRC.  They include: the
 Construction Debris Landfill, the Chemical Waste Pit, Tabbs Creek. Stratum Substation and Area E Warehouse.
 A  brief summary of these areas is provided on Table 1.  Figure 1  provides the location of these areas.  The 4
 remaining Operable Units will be addressed in future Records of Decision.

                   Table 1.  Summary of Operable Units Under CERCLA Investigations
OUName
Construction Debris Landfill
Chemical Waste Pit
Tabbs Creek
Stratton Substation
Findings
Organic and inorganic
contaminants found in
groundwater. surface water,
sediment, and soil.
Chemical wastes reportedly buried
at the site.
PCB/PCT contamination in
sediments.
PCB contaminated soil.
Current Status
Draft Remedial
Investigation/Feasibility Study
(RI/FS) under regulatory review
Chemical Waste Pit was found to
be located within the boundaries of
the Construction Debris Landfill
(CDL) OU and is addressed in the
CDL RI/FS.
Final RI/FS completed.
Draft Final Focused RI/FS
currently under regulatory review.
The Area E Warehouse serves as a storage distribution center for all supplies and materials for the NASA LaRC
facility.  The Area E Warehouse is used by LaRC to store raw products under cover and in original packing for
use in day-to-day operational activities and as a staging area and  temporary storage for outgoing construction
wastes prior to off-site disposal. From the 1960's to 1990. a small outdoor staging area was used for the storage
of both hazardous and non-hazardous waste materials.  In addition, polychlorinated biphenyl transformers were
stored within the Area E Warehouse OU.  Past activities have included some on-site spills within the warehouse
area.
B.
CERCLA INVESTIGATIONS
NASA completed CERCLA Preliminary Assessment (PA) and Site Inspection (SI) Reports  in 1988  and 1989.
respectively.  In 1993, NASA LaRC. together with Langley Air Force Base (LAFB), was proposed for inclusion
on the National Priorities List (NPL) and finalized in 1994.  A Federal Facilities Agreement (FFA) was signed by
EPA. NASA and the Virginia Department of Environmental Quality (VDEQ) in  1994.  The FFA establishes a
procedural framework and schedule for implementing site cleanups at NASA LaRC (the Site).

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 NASA has investigated hazardous releases at the Site in multiple investigations.  Previous investigations at the
 Area E Warehouse OU include a Preliminary Assessment (PA) completed in April 1988, a Site Inspection in May
 1989 (Ebasco, 1989), a Site Assessment in November.  1990 (Ebasco.  1990),  and a Contamination Assessment in
 October 1992 (Ebasco,-1992).  The Comprehensive Environmental Response, Compensation, and Liability Act
 (CERCLA), as  amended, mandates that the Environmental Protection Agency (USEPA) establish  a docket of
 federal facilities where hazardous waste has been generated, stored, treated, or disposed in the past.  The PA
 identified  the Area  E Warehouse  as  requiring  further investigation  of past waste handling  activities  through
 completion of a Site  Inspection (SI).

 The SI identified the contaminants of concern at the Area E Warehouse OU as mercury, lead, manganese, and
 polychlorinated biphenyls (PCBs).  Because of the presence of mercury, lead, manganese, and PCBs in Area E
 Warehouse soil. NASA proceeded with a Site Assessment (SA) to establish the risk posed from the contaminants
 and to develop a course of action to remove the contaminants from the OU, if necessary.

 Consequently,  a Contamination Assessment (CA)  was conducted  to  further delineate die extent  of  PCB
 contamination at the  OU  as well as conducting a focused sediment sampling effort in a nearby drainage ditch.  In
 addition an Addendum to die SA was prepared in August of 1995 to clarify  die data presentation in the original
 SA Report.

 ffl.     HIGHLIGHTS  OF COMMUNITY PARTICIPATION

 In accordance with Sections 113 and 117 of CERCLA. 42 U.S.C. Sections 9613 and 9617, NASA, in conjunction
 with EPA. issued a Proposed Plan on January 26, 1998, presenting the preferred remedial alternative for the Area
 E Warehouse OU. The Proposed Plan and the supporting documentation became available for review at that time
 and are among the documents which comprise the CERCLA Administrative Record for NASA LaRC.

 The Administrative Record is available for review by the public at the following information repositories:

 •        Poquoson Public Library
         800 City Hall Avenue
         Poquoson. Virginia.

 • •       Royd L. Thompson Library
         NASA LaRC
         Hampton. Virginia

 An announcement for an availability  session, the comment period,  and the  availability of the Administrative
 Record for the remedy for the Area E Warehouse OU was published in the Daily Press on January 25. 1998.
 Additionally, the Notice of Availability was mailed to local municipal and government agencies and residents in
 the vicinity of the Site.

 The public comment period for the Proposed Plan was from January 26, 1998 to March  11, 1998.   A public
 availability session was held at the Virginia Air and Space museum in Hampton, Virginia on February 5, 1998 to
 inform the public of all the remedial alternatives and to seek public comments. At this meeting, representatives
 from  NASA.  USEPA, VDEQ, and  Foster  Wheeler (an environmental consultant) were  available to answer
 questions about conditions at the  site and  the  remedial alternatives under consideration.   Responses to  the
 comments received during this period are included in the Responsiveness Summary section of this ROD.

 This Record of Decision  presents the selected remedial action for the Area E Warehouse OU in accordance with
CERCLA and. to the extent practicable, the National Contingency Plan (NCP).

 All  documents considered or relied upon in reaching the remedy selection  decision contained in this  ROD are
 included in the Administrative Record for the Site and can be reviewed at the  information repositories.

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 IV.      «jfDPE AND ROI.F QF THIS REMEDIAL ACTION

 Discrete  portions of an NPL site are often managed more effectively as Operable Units.   NASA has organized
 work to date into five operable units. This ROD addresses the Area E Warehouse OU.  The remaining Operable
 Units are:

                 Construction Debris Landfill
                 Chemical Waste Pit
                 Tabbs Creek
                 Stratum Substation

 These four remaining Operable Units are currently being independently  investigated under CERCLA and will be
 addressed in future Records of Decision.

 V.      SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF CONTAMINATION

 Summarized below are the relevant findings of the work to date with regard to contaminated soil located within
 the boundaries of the Area E Warehouse OU.

 A.     SITE CHARACTERISTICS

 1.      Geology

 LaRC is  situated within  the Atlantic Coastal Plain physiographic province, which  consists  of  an eastward
 thickening sedimentary wedge composed  of unconsolidatedgravels, sands, silti. and clays, with variable amounts
 of marine fossils. LaRC is underlain by approximately 2.000 feet of unconsolidatfd sediments.

 The uppermost soil units  (excluding fill material)  are  Holocene  age deposits and Pleistocene deposits of the
 Norfolk Formation.  Holocene deposits, consisting of organic clays, silts, and silty clays,  are encountered in
 proximity to the margins of tidal estuaries that border LaRC.  These deposits are up to 30 feet thick along the
 northern border of the facility. Away from the tidal estuaries, surface soils consist of the Norfolk  Formation, a
 member of the Pleistocene Age Columbia Group.   Soils of the  Norfolk Formation consist of sequences of silt.
 clay,  and silty to clayey sands that are typically dry to moist and slightly to moderately  plastic.   Anerosional
 surface separates this unit from the underlying Bacons Castle Formation.

 The Pliocene Age Bacon Castle Formation,  composed of the Moore House Member, occurs at depths of 50 to 60
 feet at LaRC.  The Moore House Member  consists of sequences  of silty sands containing marl and shell  hash
 lenses. These marl and hash lenses are absent at some locations.  The Mogarts Beach Member of the Yorktown
 Formation is encountered at depths of 70 to 80 feet.  The Mogarts Beach Member is a distinctive hydrologtc unit
 consisting of blue clay of up to IS feet in  thickness; however, it is absent at some locations.

2.      Hydrogeoiofj

Groundwater in the area can be found at  a depth of 5 to 50 feet below the land surface.  This aquifer, known as
the Columbia aquifer, is brackish and. its use is limited to lawn and garden watering. Both the Yorktown and the
Yorktown-Eastover aquifers  underlie the Columbia  aquifer.  The Yorktown-Eastover aquifer is confined and is
used as a source of domestic potable water.

3.      Meteorology

The climate at the Site is characterized by mild winters and warm and humid summers.  The climate is  affected
by the Chesapeake Bay and Atlantic Ocean  to the east and mountains to the west.   During  the  winter.
temperatures reach a high of near SO with lows in the 30s.  In the summer, the highs are generally in the  80s with
lows around 70.

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 The mean annual precipitation at the Site is 44.15 inches.  Maximum precipitation occurs in July and  August.
 while the minimum occurs in November  and April.  However, precipitation is distributed throughout the year.
 The average number of days with precipitation ranges from 7 to 11  days  per month and 110 days per year.
 Snowfall in the winter averages 10 inches per year, however, it is extremely variable, ranging annually from 0 to
 45 inches.

 The prevailing wind direction is south-southwest in April and May, southwest in June to September, and  north in
 October to March.  The average wind speed is 5 to 8 knots.

 4.      Ecology

 Open land, woodland, wetland and aquatic habitats are all found within or near NASA LaRC.  These  include
 mowed fields and lawns, nonforested overgrown land, wooded areas,  forested wetlands, scrub/shrub wetlands.
 creeks, tributaries and steams.  While the majority of the Area E Warehouse OU is paved/graveled, runoff from
 the OU flows to a small drainage ditch  approximately 120 feet in length and located  immediately adjacent to the
 Area E Warehouse OU. The ditch discharges into the site-wide drainage system which ultimately discharges into
 the Tabbs Creek estuary. The distance from the drainage ditch  to Tabbs Creek is approximately K of a mile.

 5.      Soils

 Soil at the Area E Warehouse OU has generally been graded and/or filled to support buildings and road surfaces.
 Coarse sand and gravel is  found within the upper two feet of the ground surface.   Grass covered areas were
 graded with topsoil and some subsurface soil samples encountered the Norfolk Formation.

 6.      Groundwater Use

 Groundwater in the area can be found at a depth of 5 to SO feet below  the land surface.  This aquifer, known as
 the Columbia aquifer, is brackish and, its use is limited to lawn and garden watering.  It is currently not used or
 usable as a source of potable water.  Both the Yorktown and the Yorktown-Eastover aquifers underlie  the
 Columbia aquifer.  The Yorktown-Eastover aquifer is confined and is used at other locations as a source of
 domestic potable water.

 B. NATURE AND EXTENT OF CONTAMINATION

 In April of  1988 a Preliminary Assessment (PA) was  completed for NASA LaRC which included the  Area E
 Warehouse OU.  Based on the results of this study a Site Inspection (SI) was completed in May of 1989.  The SI
 recommended that additional sampling  and investigation be conducted at the Area  E Warehouse OU.   NASA
 proceeded with a Site Assessment (SA) in  1990 to establish the potential risk posed from OU contaminants.

 The  SA involved the identification and detailed  evaluation of potential remedial alternatives and concluded with a
 recommendation of the preferred remedial alternative.

 A  Contamination Assessment (CA) was  conducted in October 1992 to further delineate the extent of contaminated
 soil at the OU. A focused sediment sampling effort in the nearby drainage ditch was also conducted  in 1994.  In
 addition, an Addendum to the SA was prepared in August of 1995 to clarify the data presentation in the original
 SA report.

The following is a summary of the sampling results of these investigations.

SOIL

Mrtah
A  total of 47 soil samples [(35 surface soil (0-6  inches) and 12  subsurface soil (6-24")J were collected at the Area
E  Warehouse for  metal analysis during the SA (Figure 3).  The metals were characterized using two analytical

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 approaches: the total concentration of inorganic constituents of concern ("Total Metals") in the samples: and the
 metals concentration in leachate produced by the Toxic Characteristic Leaching Procedure (TCLP).

 Lead was detected in ail-soil samples ranging from 3.1 to 63 mg/Kg.  Lead was not detected above twice the
 background reasonable maximum exposure (RME) (20.7 mg/Kg) level in any of the subsurface soil samples.  The
 RME is the 95% upper confidence limit of the arithmetic mean.  In surface soil samples, lead  was detected
 slightly above twice the background in one warehouse area (44 mg/Kg) and two north storage area samples (47
 and 63 mg/Kg) obtained from the site. TCLP results  for lead were reported in three samples with a range from
 0.085 to 0.434 mg/L.  The regulatory TCLP limit for lead is 5 mg/Kg.

 Trace amounts of mercury were detected above twice  the background soil values at the  site. The concentrations
 ranged from non-detected to 2 mg/Kg.  No mercury was detected in the TCLP leachate.

 Manganese was detected above twice die background soil sample values.  Concentrations were reported at 1.100
 mg/Kg and 913 mg/Kg in warehouse area surface soil  samples, and 1,220 mg/Kg in one subsurface soil collected
 in the west area  of the site.  The mean value for manganese concentrations was the highest for  the warehouse
 surface soil samples which was  statistically  significant.  Manganese was not detected above twice the RME in
 subsurface or surface soil samples collected from the north storage area of the site.

 PCBs

 Surface and subsurface soil samples  were obtained from Area E and analyzed for PCBs during the SI. SA and CA
 (Figure 4).  The  result of surface soil samples collected from 2 to 7 inches below grade showed that PCBs  were
 detected in 41 of the 53 surface soil samples. A frequency distribution of these detections includes:

                                > 1,000 Mg/Kg  -        10 samples
                        200 Mg/Kg- 1,000 Mg/Kg-        11 samples
                                < 200 Mg/Kg    -       20 samples

 The highest PCB concentration (4.800 Mg/Kg) was detected at S-SS-17-01. at the southeast corner of Building
 1170. Soil sample SS03-01, which  exhibited a PCB concentration of 4,300 Mg/Kg. was collected approximately
 15  feet west of  S-SS-17-01.  Soil  samples S-SS-02-01 and S-SS-03-01.  located northeast of Building  1206,
 contained PCBs at a concentration of 2.500 Mg/Kg and 3.100 Mg/Kg, respectively. The geometric mean of  PCBs
 detected in the surface soil is 324 Mg/Kg.

 A total of 25 subsurface soil samples were obtained from 8 to 55 inches; most samples were between  10 inches
 and  22 inches.   PCBs were detected in 10 of the 25 samples.  A  frequency  distribution of these detections
 includes:

                                > 1.000 Mg/Kg  -       2 samples
                        200 Mg/Kg - 1.000 Mg/Kg -       4 samples
                                < 200 Mg/Kg    -       4 samples

 The  highest PCB concentration (3,800 Mg/Kg) was detected at SB37-01, east of Building 1173, at a depth  of 10
 inches below grade.  The geometric mean of PCBs detected in subsurface soil is 226 Mg/Kg.

GROUNDWATER

Metals

One  groundwater sample was collected from the Columbia aquifer at the west area of the site and was reported
with concentrations at 56 and 1,280  Mg/L for lead and  manganese, respectively. These concentrations,  however.
are consistent with naturally occurring background levels of these constituents in the area of Area E Warehouse
OU and are not attributable to present or past  activities at this OU.  The mercury result was rejected; however.

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       •2619)00
             LEGEND
         	PROPERTY LINE
         	ROADS
         	 FENCES
               BUILDINGS
               CATCH BASIN
A soMrAcs/tuMtmrACS son. SAMTU 
• tOltFACX SOU, SAMTLB (19M.90)
0 soMtmrACS sou. SAMPLS d»«t)
Q 
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       "2619:00
             LEGEND

        - — — — PROPERTY LINC
        	ROADS
               FENCES
               BUIUOINGS
          t    CATCH  BASIN
A SURfACf/SUBSURfACC SOU. SAXFUC (1990)

• SUMAC! SOIL SAJ0LB (19S9,90)

9 SUISU1VACS SOIL SAKTLI (19t9)

O SURFACX SOIL SAHTLC (1992)

• SU8SUIVACE SOIL SAJtfU (1992)
          '1.30
Scai« in Feet
NOTE:  Prefix B and S  Cor 1989 staple locations
       Prefix SS and BK  Cor 1990 sample  locations!
       PreCix SS and SB  Cor 1992 saaple  locations
                       FIGURE 4
                       AREAS ABOVE 90 ug/Vg RISK-BASED LEVEL
                       NASA LARC AREA E SITE
                       Prepared by: Ebasco Services incorporated
                                                6B

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 the reported value was below the detection limit.

 PCBs

 Two groundwater samples were collected in the west area of the site (Figure 5). No PCBs were detected.

 SEDIMENT

 Two surface sediment samples were collected at  a depth from 0 to  1 foot from the drainage ditch that drains the
 stormwater  runoff from the  Area E  Warehouse site (Figure 6).   Both locations  showed extremely  low
 concentrations of PCBs.  10. 1 and 143 pg/Kg. respectively.  The results revealed that the migration of PCBs from
 the site was insignificant.

 Contaminant Fate and Transport

 The environmental fate and transport of the contaminants  present at the Area E Warehouse Site was studied  to
 determine the potential for continued on-site and off-site migration of the contaminants of concern.  The results of
 the study concluded that metals and PCBs exhibit relatively high persistence in the environment of the site.  Due
 to the low solubility of these contaminants in water, low vapor pressure, and strong adsorption to soils, sediments.
 and organic matter, adsorption is the predominant fate process for the metals and PCBs at the site.

 Since the terrain of the  site area is flat with a shallow groundwater table below the ground surface,  the most
 probable path of migration for contaminants is into the groundwater. The potential migration of the contaminants
 was predicted by using the Rapid Assessment Groundwater Model  (Donnigian, et al., 198S). The results of the
 model showed there would be insignificant metal leachate concentrations (approximately 1.6x10*" mg/L) reaching
 the 3 foot depth in ten years.  No Aroclor 1260 would migrate to the depth even when the analysis was extended
 to 30 years.  Aroclor 1260 is one of the major PCB compounds detected in soil .of the site.  Therefore, the
 potential migration of the site contaminants to the groundwater system is minimal.

 VI.  SUMMARY OF STTF BISKS

 A risk  assessment  was conducted in the SA  in accordance with  the latest EPA policy on Risk  Assessments
 (USEPA. 1989). The results are summarized below.
Health risks are based on a conservative estimate of the potential carcinogenic risk or potential to cause other
health effects not related to cancer.  Carcinogenic risks and noncarcinogenic risks were evaluated as pan of the
risk assessment; three factors were considered:

I.  nature and extent of contaminants at the OU,
2.  the pathways through which human and ecological receptors are or may be exposed to those contaminants at
    the OU, and
3.  potential toxic effects of those contaminants.

For this OU, the human health risk assessment was based on exposure to soil under industrial land use scenarios.
Surface water was not evaluated because human health receptors are  not exposed to this medium at this OU.  In
addition, neither organic compounds nor PCBs were detected in groundwater.  Only metals were detected in the
Columbia aquifer.  The detected concentrations, however, are consistent with naturally occurring background
levels in  the area of this OU and are not attributable to present or past activities at this OU. Even if water from
the Columbia aquifer were used for drinking, unacceptable risks would not be expected and. therefore, no action
is required for addressing groundwater.

Cancer risks are expressed as  a number reflecting the increased chance that  a person will develop cancer, if

-------
TABBS  CREEK
                                     PAVED DITCH  DRAINS TO TABBS  CREEK
                                                                               **»-«.   - ..PEP,,.,.
                                              AREA E WAREHOUSE
STORM DRAIN         0
MONITORING WELL     1
                                       (APPROX   OCATION)
                                                             Sco" "» r«««
                                                                      ISO
       FIGURE 5
MONITORING WELL LOCATIONS
  FOR AREA E WAREHOUSE
                                     EBASCO SERVICES INC    ORATED

-------
               ^ >.*  \ >
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                 v-.*1*   turn jr
                  V.'.«*
                    ^	--{
                    L»Mi
                         U.I
= 2«;s-.oo
    LEGEND
- - - - ASS,* eOUNCA«!ES
•——• Si"£ SOUNOAfiY
- - - - Fsc*::=Tf LINE
	F.OACS
      rENC£S  •
                         • SEDIMENT SAMPLE LOCATION
                                                                     t:o
      CATCH EAS:N
a
                                                              Ses>« in ."§«'.
                                     HGURE6

                                     AREA E WAREHOUSE SAMPLING LOCATIONS

                                     Prepared by: Ebasco Services Inc.     	
                                 7B

-------
  he/she is directly exposed (i.e., through working at the OU) to the contaminants found in the groundwater. surface
  water, soil and sediment at the OU for 30 years.  For example, EPA's acceptable risk range for cancer is I * 10~*
  to 1 x 10"*, meaning there is one additional chance in ten thousand (1 x  10" ) to one additional chance in one
  million (1 x 10"4 ) that a" person will develop cancer if exposed to a hazardous waste site. The risk associated with
  developing other health effects is expressed as a hazard index. A hazard index of one or less means that a person
  exposed to a hazardous waste site is unlikely to experience adverse health effects. A hazard index is also used to
  evaluate ecological risks.

  Direct contact, including oral and dermal exposures  of contaminated soils, forLaRC workers was calculated for
  the Risk Assessment.  The assumptions and results are presented in Tables  1 and 2. The lifetime cancer risk from
  PCB exposure for the workers at the Area E Warehouse site is calculated at 4.9 x  10 J. This lifetime risk is within
  the EPA's acceptable risk range of 1 x  10* to I x 10". The  HI for the non-carcinogenic risk due to exposure to
  metals in contaminated soils was estimated to be 0.2,  which is below the target of 1.0.

  Potential exposures to site-related contamination under future use were also considered.  However, it is  unlikely
 that the use of this area will change in the succeeding years as it is a pan of a large government-owned research
 center.

 The major uncertainties in the Risk Assessment are  the exposure factors (duration and magnitude).  Since daily
 occupation of the warehouse area does not presently  occur, the exposure assumption that a worker will be on site
 each working date and exposed to soil under the exposure conditions each day is conservative.  The uncertainty in
 the risk assessment, based on the given soil concentrations and exposure factors, is estimated to be a factor of ten
 on the high side.
 The two potential pathways for ecological impact identified were through sediment transport of contaminated soils
 to  the  estuary and/or  groundwater infiltration.   Sediment transport is through surface runoff which  carries
 contaminated soil into the storm drain, and ultimately into the estuary.  Because of the flat profile of the area,
 sediment transport is very unlikely.  The sediment samples collected from die storm drain adjacent to  the site
 reveal only extremely low levels of PCBs.

 Both metals and PCBs  exceeded ecological  screening levels  for  soils which suggests potential risk  to the
 environment. Soil screening levels which are exceeded include:

 Manganese:      330 ppm
 Lead:            10 ppm
 Mercury:        0. IS ppm
 PCBs:           0.10 ppm

 Although soil screening levels have been exceeded in the soil at the Area E Warehouse OU, there is no indication
 from samples taken in the storm drain or in the estuary that there exists an ecological risk as a result of  surface
 runoff from the site. In addition, because of the current industrial setting of the Area E Warehouse OU it is a very
 unlikely location  for a terrestrial habitat.

 CONCLUSIONS

 The remedial objective for the  Area E Warehouse is to  protect human health and the environment.  Because the
 current and  anticipated  future land  use is  non-residential, soils  were evaluated only for construction  worker
 exposure. As indicated above,  the risk posed to the construction worker is within EPA's acceptable risk range,
 however,  actual or threatened releases  from hazardous substances may present an imminent and  substantial
endangerment to  public  health or  welfare under a  non-industrial  exposure scenario.   The specific remedial
objective for this  operable unit, therefore, is to assure that the property use does not allow non-industrial exposure
to the soils.

-------
 VII.    DESCRIPTION OF ALTERNATIVES

 The Site Assessment for the Area E Warehouse OU presents three alternatives that address risks posed by PCBs
 and metals contaminated-soil.  The soil remediation technologies were identified and screened using effectiveness
 and implementability as the criteria.  The screening process is described in Table 5.   Table 6 summarizes the
 process options that were screened,  including  the  no-action alternative.   Three process  options (no- action.
 gravel/asphalt cap, and off-site landfill) were retained to form alternatives,  with two process options retained as
 support technologies.  Using these retained process options, three alternatives:  1) no-action: 2) excavauon/off-sue
 disposal: and 3) capping were developed for detailed analysis as follows.   In addition, a fourth alternative was
 developed and  discussed in a letter from NASA to  EPA and VDEQ.   This alternative is a hybrid alternative
 referred to as institutional controls and was also retained.

 Alternative I - No Action

 The NCP requires that a "no action" alternative be considered to provide a baseline for comparison with action
 alternatives.  Under this alternative, no remedial action would be undertaken at this time to address contaminated
 soil at the Area E Warehouse OU.                                         •>

 •   Capital Cost: SO
 •   Operations and maintenance (O&M) cost: $0
 •   Net present worth: SO

 Alternative 2 - Excavation fnA Off-Site Disposal

 This alternative involves excavating approximately  3,700 cubic yards  of  contaminated  soil and disposing the
 material in an approved -off-site facility.  Upon completion of the excavation, clean material would be used to
 backfill  the excavated areas.  The site would  be restored back to the original level and condition  including
 regrading to promote drainage and revegetation as appropriate to prevent  soil erosion.

 Long-term monitoring would not be included with this alternative.  Aconfirmatory sampling program, however.
 would be undertaken during the remedial action to  ensure contaminated soil above  the cleanup level has been
 removed.

 •        Capital Costs:  SI. 500,000
 •        Operations and maintenance (O&M) cost: SO
 •        Net present worth: $1 .500,000

 Alternative 3 - Containment

 This alternative consists of covering the contaminated areas with clean soil or gravel.  If the existing contaminated
 area is a grassy area, then a 10" top soil cap would be installed.  If the existing area is covered  with gravel, then
 the existing gravel should be removed prior to the placement of new gravel or top soil, or alternatively, a 6" layer
 of asphalt mix shall be placed on top of the contaminated gravel.  In addition, this alternative would incorporate
 institutional controls and  a long-term  monitoring  plan.   Also,  a confirmatory sampling  program  would  be
 undertaken during the  remedial action  to  delineate the PCB-contaminated areas to be covered to ensure  the
 effectiveness of the remedy.

 •        Capital Costs:  $168.000
 •        Operations and maintenance (O&M) cost: SO
 •        Net present worth: SI 68.000

 AJteTPftt'v* ** •  Institution
This alternative consists of a use restriction on die property to prevent non-industrial activities (e.g..  residential.

-------
 child care,  or recreational uses).  These   restrictions include: 1)  the prohibition  of use of the property  for
 purposes other than industrial (e.g.. residential, child care, or recreational use); 2) inputting these restrictions in
 the NASA LaRC Master Plan; 3) within 90 days of ROD signature, NASA shall produce a survey plat prepared
 by  a professional  land-surveyor registered  by  the  Commonwealth of  Virginia  indicating  the  location and
 dimensions of the  Area E Warehouse Operable Unit and the extent of the  soil contamination.  The plat shall
 contain a note, prominently displayed, which states the owner's future obligation to restrict the  land use of  the
 property.   The plat shall be  submitted  to the local recording  authority;  4) NASA shall  incorporate  these
 restrictions and supply a copy  of the plat into any real property documents necessary for transferring ownership
 from NASA, in the unlikely event that NASA sells the property. The real  property document would also include
 a discussion of the National  Priorities  List  (NPL) status of this Site, as well  as a description of the soil
 contamination: 5) The NASA LaRC Environmental Engineering Office Head will certify to USEPA on an annual
 basis that there have been no violations  of these prohibitions.  If a violation has occurred, a  description of the
 violation and corrective  actions to be taken will be provided.

 In addition, the presence of the existing security fence around the OU serves to  limit access to the OU. Although
 the purpose of the fence around the OU is for providing security (its presence and maintenance is not pan of  this
 alternative) it also limits the individuals who may be exposed to the contaminated soils by preventing unauthorized
 access.
         Capital Costs: $2,000
         Operations and maintenance (O&M) cost: $500
         Net present worth: $16,500
 The cost figures included here are  estimates  which reflect a reeavluation of the cost since the release of the
 Proposed Plan.   This difference results  from adding extra components to the alternative. „ See Section XI.
 Documentation of Significant Changes, below.
        SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

 During the detailed evaluation of remedial alternatives,  each alternative is  assessed against the following nine
 evaluation criteria:  overall protection of human health  and the environment;  compliance  with applicable  and
 relevant and appropriate requirements (ARARs); long-term effectiveness and permanence; reduction of toxiciry,
 mobility and/or  volume  (TMV);  short-term  effectiveness;  implementability; cost,  state  acceptance;  and
 community acceptance.

 A comparative analysis for the four alternatives based on  these evaluation criteria is presented in  the  following
 sections.

 A.  OVERALL PROTECTION OF HUMAN HEALTH  AND THE ENVIRONMENT

 Alternative 1,  No Action, provides no reduction in risk to humans and the  environment.  Alternatives 2 and 3
 would provide adequate protection of human health and  the environment by  eliminating, reducing  or controlling
 risk through removal,  engineering controls, or institutional controls.  Alternative 4  would prevent exposure
 through access restrictions and other institutional controls.

 B.  COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

 Under Alternatives 2. 3 and 4, all applicable or relevant and appropriate requirements (ARARs), would be met.
 (Specific ARARs for the remedy in this case are identified in Section X.B. of  this ROD).

C.  LONG-TERM EFFECTIVENESS AND PERMANENCE

Alternative 2 would be the most  effective since it would permanently remove the contaminated media from the
site. Alternative 3, the installation of a cover, although less permanent than alternative 2, effectively mitigates the


                                                  10

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 risk associated with direct contact or ingestion of the contaminated media.  The long-term effectiveness will
 depend on maintenance of the cover and the adherence to imposed land-use restrictions.  Since the contaminants
 would remain on-site.  Alternative 3 would provide less protection then Alternative 2.   Alternative  1  would not
 provide added protection Trom the contaminated soil. Alternative 4 will continue to prevent exposure and prevent
 unacceptable risk by, among other things, prohibiting a non-industrial use of the property.

 D.  REDUCTION OF TOHCITY, MOBILITY, OR VOLUME BY TREATMENT

 Alternatives 1  and 4 provide no reduction in the contaminant toxicity, mobility or volume of contaminated soil.
 Alternative 2, excavation and off-site disposal, would effectively reduce the contaminant levels on-site.  However.
 Alternative 2 achieves this goal by moving the contaminated media to another location (off-site landfill) where its
 mobility is reduced but its toxiciry  and volume  are unchanged.   Alternative 3 would reduce the contaminant
 mobility somewhat through the use of a soil cover, but toxicity and volume would remain the same.

 E.  SHORT-TERM EFFECTIVENESS

 No  short-term  impacts to human health and  the environment  are associated  with the  implementation  of
 Alternatives 1  or 4, no action and institutional controls respectively, because physical  remedial actions are not
 undertaken.  For Alternatives 2 and 3. which require excavation or containment,  the potential short term risks are
 those associated with dermal contact with and ingestion of the contaminated soil by workers.  NASA, however,
 would minimize these short-term risks by implementing controls and procedures to ensure, to the greatest extent
 possible, that such dermal contact and ingestion did not occur.   In the cases of these alternatives,  workers would
 be required to  wear protective equipment during activities where they may be exposed to hazardous  materials.
 The short-term risk  associated with Alternative  2 would be potentially greater than Alternative 3  because of the
 additional handling of the contaminated soil.

 F. IMPLEMENTABELITY

 Alternative 1,  no action, can be easily implemented because there are no construction,  storage, equipment or
 disposal considerations.  Alternatives 2 and 3 (excavation/off-site disposal and containment) each are relatively
 easy  to  implement  because the required  labor, equipment  and  materials  are readily  available.    However,
 Alternative 3 may be less implementable because of the change of existing OU topographic features.  In addition.
 Alternative 3 would  require a long-term monitoring plan. Alternative 4 involves the restriction of future uses of
 the OU to industrial activities. Implementation of Alternative 4 is relatively easy.

 G. COST

 Alternatives 1 has no costs associated with it.  Alternative 4. institutional controls, is estimated to cost $16.500.
 Alternative 3, containment, costs are estimated to be S 168,000.  Alternative 2. excavation/off-site disposal, costs
 are estimated to be SI.500,000 and is the most expensive.

 H. STATE ACCEPTANCE

The Virginia Department of Environmental Quality concurs with the selection of Alternative 4.
 institutional controls, as the selected remedy for this OU.

I.  COMMUNITY ACCEPTANCE

An availability  session on the Proposed Plan was held  on-February 3, 1998 in Hampton. Virginia.  Comments
received orally and/or  in writing   at  the availability session are referenced in the Responsiveness Summary
(Section  XII of this ROD).  No written or oral comments were received outside  of the availability session during
the public comment period.
                                                   11

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 IX. fiFiIiFif^D REMEDY

 Following review and  consideration  of the  information  in the Administrative Record  Tile,  requirements of
 CERCLA and the NCR.-and public comments received on the Proposed Remedial Action Plan. NASA and EPA.
 in consultation with VDEQ.  have selected Alternative 4:  Institutional Controls as  the remedy for the Area E
 Warehouse Operable Unit.  This remedy would prevent unacceptable exposure to contaminated soils.

 Based on available information. NASA and EPA believe that the selected remedy would be protective of human
 health and the environment, would be cost effective, and would provide the best balance of trade-offs among the
 alternatives with respect to the evaluation criteria.

 The selected remedy for the Area E Warehouse OU includes the following major components:

 1) the prohibition of use of the  property  for purposes other than industrial (e.g..  residential,  child care, or
 recreational use),

 2) inputting these restrictions in the NASA LaRC Master Plan ,

 3) within 90 days of ROD signature, NASA shall produce a survey plat prepared by a professional land surveyor
 registered by the Commonwealth  of Virginia indicating the location and dimensions  of the Area E Warehouse
 Operable Unit and the extent of the soil contamination.  The plat  shall contain  a note, prominently displayed.
 which states the owner's future obligation to restrict the land use of the property. The plat shall be submitted to
 the local recording authority,

 4) NASA shall incorporate these restrictions and supply a copy of the plat into any real  property documents
 necessary for transferring ownership from NASA, in the unlikely event that NASA sells the property.  The real
 property document would also include  a discussion of the National Priorities List (NPL) status of this Site, as well
 as a description of the soil contamination.

 5)  The NASA LaRC Environmental Engineering Office Head will certify to USEPA on an  annual  basis that  there
 have been no  violations of these  prohibitions.  If a violation has  occurred, a  description  of the violation and
 corrective actions to be taken will be provided.

 The present worth of this remedy is $16,500.

 PERFORMANCE STANDARDS

 A prohibition of use of the property for purposes other than industrial (e.g.. residential, child care, or recreational
 use) will be imposed.  All use restrictions will be inputted into the NASA LaRC Master Plan. Within 90 days of
 ROD signature,  NASA shall  produce  a  survey plat prepared by a  professional land  surveyor registered by the
 Commonwealth of Virginia inHir«ri«ig the location and dimensions of die Area E Warehouse Operable Unit and
 the extent of the soil contamination.   The plat shall contain  a note, prominently displayed, which  states the
owner's  future obligation to  restrict the land use of the property.  The plat  shall be submitted to the local
 recording authority.   NASA shall  incorporate these restrictions and supply a copy of the plat into  any real
property documents necessary for transfering ownership from NASA, in the unlikely event that NASA sells the
property.  The real property document would also include a discussion of the National Priorities List (NPL)  status
of this Site, as well as  a description  of the soil contamination. In  addition,  the  NASA LaRC  Environmental
 Engineering Office Head will certify to USEPA on an annual basis that mere have been no violations of these
prohibitions.  If a violation has occurred, a description of the violation and corrective actions to be taken will be
provided.

A 5-year review will be  conducted in order to evaluate continuing protectiveness  of human  health and  the
environment.   Each required 5-year  review  will culminate in the preparation  of a report.  Specifically, the
effectiveness of the selected remedy will be reviewed, and a determination will  be made as to whether adverse


                                                   12

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 changes in risk have occurred at the Area E Warehouse OU.   The  effectiveness of use  restrictions  will be
 evaluated and changes may be recommended at that time.

 X. STATUTORY DETERMINATIONS

 A. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

 The selected remedy. Alternative 4. would protect human health and  the environment by preventing exposure
 through (he use restrictions and other institutional controls.

 B. COMPLIANCE WITH ARARS

 The selected remedy will comply with all ARARs

 1.  Chemical-Specific ARARs

 There are no chemical-specific ARARs for the selected remedy.

 2.  Location-Specific ARARs

 There are no location-specific ARARs for the selected remedy at this OU.

 3.  Action-Specific ARARs

 There are no action-specific ARARs for the selected remedy.

 C. COST EFFECTIVENESS

 The selected remedy is cost-effective.  The present worth cost of Alternative 4 is SI6,500.

 D.     UTILIZATION  OF  PERMANENT   SOLUTIONS   AND   ALTERNATIVE   TREATMENT
 TECHNOLOGIES  OR RESOURCE RECOVERY TECHNOLOGIES TO THE MAXIMUM  EXTENT
 PRACTICABLE

 The selected remedy represents the maximum extent to which permanent solutions and treatment technologies can
 be utilized in a cost-effective and timely manner. Of those alternatives that are protective of human health and the
 environment and comply with ARARs, the  selected remedy provides the best balance of trade-offs in terms of
 long-term effectiveness and permanence, reduction of toxicity, mobility, or volume achieved through treatment.
 short-term effectiveness, iraplementability and cost, while also considering the statutory preference for treatment
 as a principal element and considering state and community acceptance: The selected remedy addresses the
 principal threats posed by contaminated soils given the reasonably anticipated future use of the site.

 E.  PREFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT

The selected remedy does not satisfy the statutory preference for treatment as a principal element of the remedy.
Treatment remedies were not considered because of low levels of contamination. Although no active treatment is
employed with the selected remedy, the selected alternative would limit exposure to contaminated soils.

XL DOCUMENTATION OF SIGNIFICANT CHANGES

The preferred  alternative in the Proposed  Plan was  Alternative 4: Institutional Controls.  The only significant
changes to the proposed alternative described in the Proposed Plan is the addition of the survey plat requirement.
incorporation  of these restrictions into the NASA LaRC Master Plan and the annual reporting on the continued
application of the institutional controls.


                                               13

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     . RESPONSIVENESS SUMMARY

 A.  OVERVIEW

 In a Proposed Plan released for public comment on January 26, 1998, NASA, with the support of EPA, identified
 Alternative 4 as the preferred remedial alternative for the Area E Warehouse OU at the Site.  Alternative 4 in the
 Proposed Plan was as described in Section VIII, with the additions discussed in Section XI.

 There were no written comments received  as  a result of the  public comment period.   There were written
 comments submitted during the February  5,  1998 availability session.  After evaluating and  addressing these
 comments, NASA and EPA have decided to select Alternative 4 as the remedy for the Area E Warehouse OU.
 Comments and the  associated responses of  NASA and EPA are described below after  a brief discussion of
 community involvement to date.

 B. COMMUNITY INVOLVEMENT TO DATE

 NASA and EPA established a public comment period from January 26, 1998 to March 11, 1998 for interested
 panics to comment on the Proposed Plan, the  Site Assessment. Contamination Assessment, focused sediment
 sampling reports and other documents pertaining  to the Area E Warehouse OU.  These and all other documents
 considered or relied  upon during the remedy selection process for the Area E Warehouse OU are  included in the
 Administrative Record, which has been in two information repositories accessible to the public since the beginning
 of the public comment period for the Area E Warehouse OU. An availability session was held at the Virginia Air
 and Space Museum.  Hampton. Virginia on February 3. 1998, to present the Proposed Plan, answer questions, and
 accept both oral and written comments on the  Area E Warehouse OU remedial alternatives.  One person attended
 this session.

 This Responsiveness Summary, required by CERCLA. provides a summary of citizens' comments identified and
 received during the public comment period and the responses of NASA and EPA in selecting the remedy for the
 Area E Warehouse OU.  Responses to these comments are included in the section below.

 C. SUMMARY OF COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD AND
 COMMENT RESPONSES

 Comment #1:

 My particular question was about the plan to test Tabbs Creek over the yean in the future. I was told that this
 testing of biota would occur 2-4 times per year over the next five years.  I agree this is good, but 5 years may be
 too short - term; should be a long range plan  as well.

 Response #1:

The Tabbs Creek OU will be addressed in a future Proposed Plan and ROD.  A monitoring plan will be included
in  any remediation that may take place in Tabbs Creek.  The details of the monitoring have yet to be developed.
This concern will be considered at that time.

Comment #2:

Groundwater may be contaminated in the future, so the suggestion to preclude the use of groundwater in the
future should be implemented.

Response #2:

Groundwater at the Area E Warehouse OU does not currently pose a threat to human health or the environment.
Upon completion of the studies at the remaining OUs. a determination will be made on what actions  if any are


                                                 14

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necessary to address groundwater.
                                                  15

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 REFERENCES

 Anderson. E.N., S. Browne, Dulctslcy, and T. Warn (1984).  Development of Statistical Distribution or Ranges
    of Standard Factors Used in Exposure Assessments.  Draft Final Report prepared for USEPA, Office of
    Health Environmental Assessment under Contract No. 68-02-3510.

 Donnigian Jr.. Anthony S.. T.Y. Richard Lo. and W. Shanahan (1985).  "Rapid Assessment of Potential Ground
    Water Contaminations.  EPA Report.  Contract No. 68-03-3116.

 Ebasco. 1988. "Preliminary Assessment Report For Langley Resource Center."

 Ebasco. 1989. "Report of Site Inspection. NASA,  Langley Resource Center."

 Ebasco. 1990. "Area E Warehouse Site Assessment, LaRC. Hampton, VA."

 Ebasco. 1992. "Final Contamination Assessment Report, Area E Warehouse, LaRC. Hampton. VA."

 U.S. Environmental Protection Agency. 1990.  "Guidance on Remedial Actions for Superfund Sites with PCB
    Contamination."  EPA 540 G-90-007. August.

U.S. Environmental Protection Agency, 1989.  "Risk Assessment Guidance for Superfund. Volume
    I:  Human Health Evaluation Manual."  OSWER Directive 9285.7-Ola. Office of Emergency and Remedial
    Response, Washington, D.C.

U.S. Environmental Protection Agency, 1988.  "Guidance for Conducting Remedial Investigations and Feasibility
    Studies Under CERCLA."  Interim Final.
                                                16

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APPENDIX A




  TABLES

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                                    TABLE 2
                    EXPOSURE AND INTAKE ASSUMPTIONS FOR
                       DERMAL CONTACT AND INGESTION
                       NASA LANGLEY RESEARCH CENTER
                                                                        Workers

 Age Group                                                                18-70

 Dermal Exposure to Soil (day/year)                                                78

 Duration of Exposure (yean)                                                     44

 Frequency of Exposures (Dayj/yr)                                                244

 Dermal Soil Deposition (mg/crrf)                                                 1.4

 Skin Surface Area Exposed (cm2)                                               3,600

 Dermal Absorption Factors:

        PCBs                                                               12%
        Metals                                                             1.0%

 Gut Absorption Factors:

       PCBs                                                               50%
       Metals                                                              50%

Soil Ingestion (mg/day)                                                         100
Sources: Skin surface areas exposed are from Anderson, et al., (1984); other parameter values
        were derived as described in the SA report.
                                     A-l

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                                                                     TABLES
                                                                AREA E WAREHOUSE
                                                      HAZARD INDEX AND EXCESS CANCER RISK
                                                            LANGUEY RESEARCH CENTER
Non-Carcinogenic Effects:

CD) = CDRD) + CDKD
           CDl(DXmg/kg/day) - C(mg/kg) • DR(mg/cm*2) • ARI * SA(cm*2) • DE/36S(days/days) • l(T-6(kg/mg) / BW(kg)
           CDKIMmg/kg/day> • C(in|/k|) • le      3.IE-02                74E-02                I.OE-OI

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                                                               TABLE 3 (Continued)
                                                              AREA E WAREHOUSE
                                                    HAZARD INDEX AND EXCESS CANCER RISK
                                                          LANGLEY RESEARCH CENTER
Area E Warehouse/Surface Soil

Exposure Roue: Soil (Denial Contact A Acrirknul Ingeaion)


Scenario: Long-Term Representative Exposure
Source: Surface Soil (Present and Funire)
Receptor: LARC Workers

Area of Exposure ==»=» = = >
Exposure Factors:
% Time Exposed per area
Days Exposed (per year)
Fractional days per year
Yean Expand (per 70 year life)
Body Weight (kg)
Soil Ingeflioa (me/day)
Surface Area Exposed (cm~2)

West

20*
220
44
42
70
100
3.800

Warehouse

40%
220
88
42
70
200
3.800

1 North

40%
220
88
42
70
100
3.800
Carcinogenic Effects:
CDI ~ CDI(D) •»• CDI (1)
                       CDKDXmg/kg/day) - C(inf/kg) * DR(mg/cro'7) * AFd * SA(cmA2) • DE/36S(days/days) • YE/70(years/yean) • I0*-6(kg/mg) / BW(kg)
                       CDKIXmg/k) CDKIXmf/kt/day) - COng/kg) • Mmf/day) • AF1 • DE/365(days/aayj) • YEAXKyean/years) • l(T-«(kt/nij) / BW(kg)
Compound
AF$
                                  Denial
                                  Dep.
                                             CPF
Chronic Daily Intake and Cancer Risk for Age Group (years):
PCBs
AFd     AFt        (mg/cm*2)
   Soil Cone (mg/kg) = = « = •
12%     50%       1.4E+00
                   Total Risk
                                             12E+OI
                                                           	Warehouse	
                                               CDI        Risk      CDI          Risk
                                               1.2E+00              I.2E+00
                                               8.4E-07     9.7E46   I.8E-06       2. IE-OS
                                                          9.7E-06                2. IE-OS
                                                                                                          	North	
                                                                                                          CDI        Risk
                                                                                                          I IE+00
                                                                                                          I6E46     I9E43
                                                                                                                     I9E-05
                                                                                                                         Lifetime
                                                                                                                         Ruk
                                                                                                                                      49E-05

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                                                                               TABLE 4
                                                                   CLEAN-UP SOIL CONCENTRATION
                                                                  AREA E WAREHOUSE/SURFACE SOIL
                                                                  NASA LANGLEY RESEARCH CENTER


Scenario: Long-Term Representative Exposure
Source: Surface Soil (Present and Future)
Receptor: LaRC Workers


% Time exposed per area
Days Exposed (per year)
Fractional days per year
Yean Exposed (per 70 year life)
Body Weight (k|)
Sod Ingestion (rag/day)
Surface Area Exposed (cm~2)
U/«c*

20%
220
44
42
70
100
3.800

warcnouse
40%
220
88
42
70
200
3.800

Nonn
, 40%
1 220
88
42
70
100
3.800
I
Carcinogenic Effects: CDI« CDIfD) + CDI(I|
CDI|DKmg/kg/day) = Qmg/kg) • DR(mg/cm*2) • AFd • SA(cnT2) • DE/363(days/days) • YE/70(years/years) *
CDI|IKmg/kg/day) - Qmg/kg) * ls(mg/day) • AFi • DE/36S(days/days) * YE/70(years/yean) * l
Chronic Dail;

CDt Risk
90E-02
7-v^'^v*
6.4E-08 4.9E-07
4.9E-07
                                                                                Chronic Daily Intake and Cancer Risk for Age Group (yean):
                                                                                     	Warehouse	
                                                                                     CDt          Risk
                                                                                     9.0E-02
                                                                                     1.4E-07       I 1E-06
                                                                                                  I.IE-06
	North	
CD!         Risk
9.0E-02
I.3E-07      9.9E-07
            9.9E-07
                                                                                                                                           Lifetime
                                                                                                                                           Risk
25E-06
2.SE46

-------
               TABLES
SCREENING OF SOIL REMEDIAL TECHNOLOGIES
        AREA E WAREHOUSE SITE
    NASA LANGLEY RESEARCH CENTER
Technology Type:
Process Opdon(s)
No-Acaon
Limited Action:
Monitoring
Capping:
Gravel/Asphalt Cap
RCRA Cap
Removal:
Eicavaoon
Description
The MR a not irmrrtiainrl IB any way.
Low level 01 COfltJBanBntS VeflBVD OB
Ste.
Perform periodic analysis of ate toib to
nmiaminatinn
Cover contaminated toil with a single
layer of asphalt or f mvcl.
Cover contaminated sod wife a multi-
layer cap consisting of top soil, syndteoc
membranes, impenneabk soil, and
drainage layer.
Contaminated tot) would be removed

Eflcoivcnesi
Carcinogenic risk is witun EPA's acceptable
fcfcume risk ranfc U10* •> UIO4.
Eflecbve for monitonnt levcb of soil
conbuninaBon and «HfMi"" However, due
ID te tow levels of aoi caattninaoa. • a
unlikely dial PCBi would na|nae »
imindwaier or surface water at levels posinj
litairkaal ducats.
"^•*^™^*^*^ 	
Reduces mobiiJiy of conimnaVitt tnd risk of
OO-SNC and nay be eiposcd from
en>sioii/ruain|.
• ftf^ufttt cnobiliiy of cootuMfttitt md risk
icnuun on-siie.
• Meets RCRA m|aiiftfntno

ni In iniia • il
miliBuBOB*
• RCRA sysvot is icbaUe for reducini
ten a mvRCRA synem for ndudm
contact risks.
* Effective at fctnovnf cocttniisQaiod SOM.
• Reqyifts Auter ocaBncot/dttposaU.
• Wil not reduce volutne or toxiciiy of
contunvttMDd soil.
•t^MU^H^MMaVy
C««ik* In | 	 *
cASiy •»»yitjncasto.
Cott Low
C*«iKj MIWkkvi^Ffl^hfVl
CM»: Low/Moderaic
Construction is relatively easy.
Change in elevation due to installation of cap
may change fte dnunage pattern of te area.
Cost: Low/Moderate
• Construction requires multiple steps and is
Ome Cffinmntng.
wife ooo-RCRA layer cap.
advene cffcct on RCRA cap.
• Change h elevation due to imallarion of cap
would bnMcumnl use of pnptny.
Cost H%h
• TcchnkaOy fcasMe.
• Can be done usini common constiucoon
OttUDIDBfat.
• i"T *™ *"•
Cgsr. Low
SBUUS
I
Retained for ftmtier
consvleration

BuninMed as long u die
ste use is kept (he same.
Retained (01 funhcr
yiynii^yQji^iY
Eliminated due 10 HKCU!
site conuninu.
Retained for (unher
considerabon at a tuppon
technotofy.

-------
                                                                    TABLES (Continued)
                                                     SCREENING OF SOIL REMEDIAL TECHNOLOGIES
                                                                AREA E WAREHOUSE SITE
                                                           NASA LANGLEY RESEARCH CENTER
Technoiofy Type:
Process OpoonU)
DetCnpBOe)
Effectiveness

                                                                                                                 Satis
Physical Treatment:
Sold Processing
Conan of pfayaofty sonnf and/or
modsfying we size tnl dMribunon of
ne toil oti my be eicavaied.
  Does not itduce uuciiy or mobility at
  coaarninana. but my reduce vohune of


  teicnm te specsnc surface area of ne
  toil.
  More of a putiuunett nan a treatment.
Ropoica Hgnifkaot maieriab I
b required at a pnacaunen toe many
                                                                            Etiminaied. |Ticaaneniof
                                                                            toil
                                                                                                Coy  Low
PhyikalTi
Process 10 tcraovc cicess (ftw) Ikyiid
faun sMuttcd OMNcnals pnof b
•  Effe
                                                            Snynrt By hnnlnay .
                                                            Don am nducc noMiy or ttuciry of
                                                                         . May itauk in sapiiAcani
Imnkmrnabiliry of dtwaierint. roohodt may
be djfficuk  aomt tuauiifnt
                                                            or d^Mual Hcnnolofics.
                                                                          •  Ticatmeni of dnined water, if required.
                                                                             woUht MBMC off-Mt htodUnf and disposal.
                                                                          Cost Low
Solver* Etmcoon:
la-Sin Soil Fhuhinf
Couaminanu are removed from «oib
via in-iiai «oJveni nMnaoo.
Contaaiiniagd tgrvcnB are recovered for
wbtequeni ocaonen and/or dqposal.
Organic solvent used for PCB extraction
may be considered banidous.

sepaiMt torrents.
Reduces volume of cooaminants in toils;
however, produces tup vohjotes of
cotMnmiad solvents whicfe nquin
                                       •  Typically compki proccsies. diflkuh »

                                       •  tacaatJ far toa of solvents durinj
                                     Biminued due lu
                                     potenul for advene
                                     cnviionmeMil effecu anl
                                     amicipajed diflicuHy m
                                     implcneiMabon.
                                                                                                   Requires special provisions (i.e.. sheet
                                                                                                            vure ^fnrtrit coUecoon of
                                                            _M_^_
                                                            Rdiabiiiy ofefloptecaoMi widiaD

                                                            Actuevtble level of conftraDtnl removal
                                                            may not be adequate ID attain necessary
                                                            acaonkvcfa.
                                                                          •  Cofacooei of U faisMnf sorveni may be
                                                                             euemdy dMioilL
                                                                          •  Cofiecfed sorfcnts require ottmunt to
                                                                          Con: Modeme

-------
           TABLE 5 (Continued)
SCREENING OF SOIL REMEDIAL TECHNOLOGIES
        AREA E WAREHOUSE SITE
     NASA LANGLEY RESEARCH CENTER
Technology Type:
Process Opooofft)
TEA Exmcuoo






Fiufkn'*riitbttTTtfiOfi *
SoMifirtiinn

DdcnpttM
EnmrtoaflfonMir from cimviitri
ioib a achieved by canaani fee toil
(TEA) totvctt •> CUM cacnfcak



Piccext wed in bboniofy and iadutay
ID move PCBi Aon (nuforaKf oil.

AdMmt «rf p«T»«J««c HagMM M UCMB
a omHeaclaMe nMtral wbkb it cukr
K»h*nlle.

Elbctiveneu

conceaoiooft loitel for doponl.
* Pito itn dm far I\*P muinK is
ftvftiUbic foe tffih. HdiflBMttt ind dudccs.
•dioo levcb lo|y to
mcb tcaoo level* for
PCB*

.

Rich Kboa levels lor
PCBs

Fliminiinl duf 10
inpfovea cflccavencvt m
«nmotMlii«n PCBt *i te
sac.


-------
                                                                                   TABLE 5 (Continued)
                                                                  SCREENING OF SOIL REMEDIAL TECHNOLOGIES
                                                                              AREA E WAREHOUSE SITE
                                                                         NASA LANGLEY RESEARCH CENTER
           Tccbnotofy Type:
           Process OpQMft)
DcacnptiM
Eflimwcncss
Impletncntaibiuiy
                                                                                  Sous
           Biological Treatment:
           Liquid totals CogOKt
           In Sun Treatment Land
           AuolicaikMi
           *'i i '' •""••
Bacteria are used 10 degrade specific
organic ooaMMMB. May be
performed aVjiit, of in • batch IUUM
after eicavaom.
•  Laboratory dcmomoioom have shown
   KB compound! u be btodcgndabie.
   Mercury my be auk and inhibit (town.
   Treatment of <|*[*a|ar* only.
                                                                          pemnt may be achievable.
                                                                          Bench icak eating and pMot saidy
                                                                          required.
                                                                          Biological oeatmcnt has resuhed reduction
                                                                          of PCBs 10 ten ten 1 ppn in tome bench
   Specific woit widi biolo|icil degmbiion of
   PCBi b »• experimental.
   May produce waae icsiduali ieojuino(
   (uitftef Btaoum and/or dupoial.
   Piuteu bas BDC bom developed mfficiefidy
   k> pennii tccume pmtioion of
                                                                                  Eliminated «ue u
                                                                                  eiDenmcaoJ DMIK. Uck
                                                                                  of piot teak data, ml
                                                                                  pmbaHiiy of OEM mtcoi«
                                                                                  the action levcta for PCB
                                                                                  contuninMcd tod
                                                                                   Modeme
>
oo
                                                                        •  Reaction product! have OM been
                                                                          chincieiaed and 
-------
                                                                    TABLE 5 (Continued)
                                                    SCREENING OF SOIL REMEDIAL TECHNOLOGIES
                                                                AREA E WAREHOUSE SITE
                                                           NASA LANGLEY RESEARCH CENTER
Technology Type:
Process Opdontt)
                                   Effectiveness
                                       linpfctneniabiliiy
                                                                                                                 Sodus
Thermal Treatment:
Off-siie Incinemim
TWo types of ott-tm incineiMon tie
avertable:  rotsiy kite and Whued
system. Roiuy kito nroduccs wise
                             of • pflfBvy
                       •Dd lined wik hycn ofl%lM-we%h(
                       cerate fiber blanket Thenfand
                       energy a provided by abcoBcaroide-
•  Ptifonmace dan for incinemoa ue we8-
   demaraoued wtti h%h eflkieocy far
   destroy iaj oipak warn.
•  WiU Ktiieve tttn^d fioum> levels.
•  Peifonmnce dea ue leUebte.
•  Places* win gcaente ck*o soil end only s
   i~fvnal i"*ntr* of •*** icsidue. whicn
   would be  tandtod by to incincnaan
• Oincady sppi
ady four operating
         Alfour
                                                                               Eumimied due 10 cou
                                                                               ineHecove!
                                                                                                   baton in nmaiRj si capsciiy.  Cspiciy b
                                                                                                 •  Ei
                                                                             nnsponsttw we necessiiy.
                                                                          Cog: H«h
                       ID be prac*sted b conveyed teoufb Ae
                                   • ReducesTMV.
                                   • Is not eflbciive lor nonjsnics oesflncn.
                                   * OewMennj of soils msy be ivojuind.
On Sue Incmenoon
Seme u off-sisc. cicqM diM • noMr
incinenior would be locassd « te Ana
E Wvchousc site.
             data for tafecnoon ate wdl-
  demonsoiiBd widi high elfkieiicy foe
  destroying organic wstscs.
• Win achieve augtt cleanup fcveb.
• Rdkeiuty in te field has oat been wen-
  UunumuMad. Cuneody k§s been used si
  ontyafcwwajes
• ReducesTMV.
• bnotcffecovefori
• IYe-ats«nMofsain*ybem|uind.
                                       •  Mobile sod mnsporablc urau ue avwtable
                                          for on-ske incinendoa.
                                       •  On-siss ipcinen be buik.  Amobik
                                          iocioeraBr decs not require pcnninnj if • is
                                        Eluninaiod due » high
                                        cost.
                                                                                                   Air poJudoa tuaiul eyipaeni is typicslly
                                                                                                 • Adiftt
                                                                                                   detaedorptacediisRCftAfkil«y.

                                                                                                          isnlcicavsionsBOuldbe
                                                                                                 Con: H«h
Thermal TitamttM:
Viinncsuon
Ekcutxki imened into soil (n-wu)
conumm sijnificani levels of silkMes.
GnpniK is placed on die soil suifacc »
connect die deorades. The beat
IcncnMt hum 
-------
                                                                       TABLE 5 (Continued)
                                                       SCREENING OF SOIL REMEDIAL TECHNOLOGIES
                                                                   AREA E WAREHOUSE SITE
                                                             NASA LANGLEY RESEARCH CENTER
Tcchnok>(y Type:
Process Opoon(»)
Descnpoon
Effectiveness
ImpkmentabiUry
Thermal Treatment:
Low-Teinpcraain:
Thermal Extraction
Organic waste* are removed from soil
by introducing heated tit into • reactor
widi die soil to strip oottuniotOM from
soil.  Excavation is nrjuind for
   Hat been demonstrated to remove certain
   organic* from solid*.
   Not proven and not likely to remove PCBs
   and otter noo-vobnk comarainanu.
   Anoter tBcteoloiy would be required to
   defray organic* removal.
   Reduces volume* of WUK.
•  Imptcmcnabk. Could be constructed on-
   site or preassanbfed mobtk units could be
   transported to die site.
•  Site space consninu «««™-j««««f wMh
   cicavaboB riffldit be cnnudrred.
•  May be mad in aimfiannn wift odier

Con:  H«h-
                                                                                  Elimimied due w
                                                                                  iraMvy iJ cnecovely
                                                                                  uiai PCB* ant
                                                                                  inotianics.
On SMC Disposal:
On SMC Landfill
Soil from contaminated aica* are
eacavated and dHpmnd of in an
approved tacikiy constnicted oo-ute.
   Rdiabte meted » oonain wufes.
   VokMne or louciiy of was* b DM reduced.
   Protective by reducinf direct exposure to
•  Water-saMMtd matrnalt would require
   cater sotidifiuMiuo or dewaatrinf prior u
                                                                                                                                             Eliminated due to MIC
                                                                             •  Co
                                                                                                                          and lanj-tenn
                                         indudmt lack of
                                         sufficient space.
                                                                                                    •  Potential long-acrm liability for waste

                                                                                                    Cost Moderate
Off-Site Disposal:
Off-Site Landfill
Waaes with PCBs <» pproare
excavated, transported, and disposed of
at a Virginia Department of Want
Management approved off-sac tandfiB.
•  Effective in reducing direct contact risk.
•  Volumeorioxicityof wasKisnM
   decreased.
•  Exposure to soil during excavation and
   nmporaoon could pose a heaat hazard.
                                        •  Potential for long-lean liability tot waste
                                           placed in bniM.
                                        •  OfT-sia: hndtii capacity is Unwed.
                                        •  Increased risk of exposure during
                                         Retained for further
                                         consideration.
                                                                                                    Con: Moderate

-------
                                             TABLE 6
                             SUMMARY OF ALTERNATIVE SCREENING
                                 SOIL REMEDIAL TECHNOLOGIES
                          NASA AREA E WAREHOUSE SITE ASSESSMENT
 General
 Response Actions

 No-Action

 Limited Action

 Containment Actions


 Removal Actions

 Treatment Actions
 Remedial
 Technology T
Monitoring

Capping


Excavation

Physical Treatment


Solvent Extraction



Fixation/Stabilization

Biological Treatment
                           Thermal Treatment
Disposal Actions
On-Site Disposal

Off-Site Disposal
No-Action

Monitoring

Gravel/Asphalt Cap
RCRAType

Excavation

Solids Processing
Dewatering

In-SiOi Soil Rushing
TEA Extraction
Critical Fluid Extraction

Solidification

Liquid-Solids Contact
ln-Situ Treatment
Land Application
UV/Oxidation

Dechlorination KPEG

Off-Site Incineration
On-Site Incineration
Vitrification
Low Temperature Thermal
Extraction

On-Site Landfill

Off-Site Landfill
Status

Retained

Eliminated

Retained
Eliminated

Retained*

Eliminated
Eliminated

Eliminated
Eliminated
Eliminated

Eliminated

Eliminated
Eliminated
Eliminated
Eliminated

Eliminated

Eliminated
Eliminated
Eliminated
Eliminated


Eliminated

Retained
Note: * * As support technology
                                                A-ll

-------