EPA/ROD/R03-95/199
1995
EPA Superfund
Record of Decision:
ATLANTIC WOOD INDUSTRIES, INC.
EPA ID: VAD990710410
OU01
PORTSMOUTH, VA
09/29/1995
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ATLANTIC WOOD INDUSTRIES, INC., SUPERFUND SITE
CITY OF PORTSMOUTH, VIRGINIA
RECORD OF DECISION
OPERABLE UNIT 1 (SOIL, SEDIMENT, DNAPL)
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PREPARED BY
THE U.S. ENVIRONMENTAL PROTECTION AGENCY
SEPTEMBER 1995
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TABLE OF CONTENTS
PART I - DECLARATION
I. SITE NAME AND LOCATION 1-1
II. STATEMENT OF BASIS AND PURPOSE 1-1
III. ASSESSMENT OF THE SITE 1-1
IV. DESCRIPTION OF THE SELECTED REMEDY 1-1
V. STATUTORY DETERMINATIONS 1-3
PART II - DECISION SUMMARY
I. SITE NAME, LOCATION, AND DESCRIPTION 2-1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2-1
A. Initial Cleanup Actions 2-3
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 2-4
IV. SCOPE AND ROLE OF THERESPONSE ACTION 2-5
V. SUMMARY OF SITE CHARACTERISTICS 2-8
A. General 2-8
B. Surface Water Hydrology 2-8
C. Hydrogeology/Geology 2-10
D. Wetlands 2-14
E. Extent of Contamination 2-14
1. Soils Quality 2-14
2. Sediment Quality 2-21
3. DNAPL Occurrence 2-21
4. Ground Water 2-22
5. Surface Water 2-29
6. Air 2-30
VI. SUMMARY OF SITE RISKS 2-31
A. Data Collection and Evaluation 2-31
B. Exposure Assessment 2-32
C. Toxicity Assessment 2-44
D. Human Health Effect Summary 2-47
E. Risk Characterization 2-48
VII. SUMMARY OF SITE ECOLOGICAL RISKS 2-50
VIII. DESCRIPTION OF ALTERNATIVES 2-55
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IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . 2-69
A. Overall Protection of Human Health and the
Environment 2-71
B. Compliance with Applicable or Relevant and
Appropriate Requirements 2-72
C. Long-Term Effectiveness 2-76
D. Short-Term Effectiveness 2-76
E. Reduction of Toxicity, Mobility, or Volume
Through Treatment 2-77
F. Implementability 2-78
G. Cost Effectiveness 2-79
H. State Acceptance 2-80
I. Community Acceptance 2-80
X. SELECTED REMEDY AND PERFORMANCE STANDARDS 2-80
A. Treatability Study/ContingencyTrigger 2-82
B. Soil/Sediment Excavation and Backfill 2-83
C. Engineered Land Treatment of Soil/Sediment . . . 2-85
D. Contingent Treatment Technology for RRU1 and
RRU2: Low Temperature Thermal Desorption of
Soil/Sediment 2-86
E. Soil/Sediment Disposal 2-87
F. DNAPL Recovery 2-87
G. Site Monitoring 2-88
H. Miscellaneous Performance Standards/Institutional
Controls 2-89
XI. STATUTORY DETERMINATIONS 2-89
A. Overall Protection of Human Health and the
Environment 2-89
B. Compliance with Applicable or Relevant and
Appropriate Requirements 2-89
C. Cost Effectiveness 2-93
D. Utilization of Permanent Soluntions and Alternative
Treatment Technologies to the Maximum Extent
Possible 2-94
E. Preference for Treatment as a Principal Element . 2-94
X. DOCUMENTATION OF SIGNIFICANT CHANGES 2-95
PART III- RESPONSIVENESS SUMMARY
I. ORAL COMMENTS FROM JUNE 27, 1995 PUBLIC MEETING .... 3-1
II. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD 3-7
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LIST OF MAJOR TABLES
Table 2-1 - Total Equivalent 2,3,7,8-TCDD Concentrations 2-17
Table 2-2 - Results of TCLP Testing 2-24
Table 2-3 - DNAPL Distribution on Soils 2-25
Table 2-4 - Summary of DNAPL composition at MW-117 . . . 2-27
Table 2-5 - Reasonable Maximum Exposure Point
Concentrations, Wood Treatment East 2-33
Table 2-6 - Reasonable Maximum Exposure Point
Concentrations, Wood Treatment West 2-34
Table 2-7 - Reasonable Maximum Exposure Point
Concentrations, Historic Disposal Area . . . 2-36
Table 2-8 - Reasonable Maximum Exposure Point
Concentrations, Wood Storage Area 2-38
Table 2-9 - Reasonable Maximum Exposure Point
Concentrations, Waste Lime Area 2-40
Table 2-10 - Reasonable Maximum Exposure Assessment
Factors 2-43
Table 2-11 - Slope Factors and Reference Doses 2-45
Table 2-12 - Summary of Carcinogenic Risks 2-49
Table 2-13 - Summary of Hazard Indices 2-50
Table 2-14 - Physical Characteristics of RRUs 2-58
Table 2-15 - Performance Standards: Soil and Sediment
Cleanup Levels 2-82
LIST OF FIGURES
Figure 2-1 - Site Location Map 2-1
Figure 2-2 - Site Plan and Area Locations 2-7
Figure 2-3 - Wetland and Surface Water Outfalls Locations . 2-9
Figure 2-4 - Potentiometric Surface Map 2-13
Figure 2-5 - Maximum Concentrations in Surface Soil . . . 2-18
Figure 2-6 - Carcinogenic PAH Concentrations in Surface Soil
(Western Section) 2-19
Figure 2-7 - Carcinogenic PAH Concentrations in Surface Soil
(Eastern Section) 2-20
Figure 2-8 - Concentrations in Sediment 2-23
Figure 2-9 - Flood Plain Locations 2-54
Figure 2-10 - Estimated Excavation Areas 2-57
APPENDICES
Appendix A - Administrative Record Index
Appendix B - Glossary of Superfund Terms
Appendix C - Cross Reference of ROD Alternative Numbers with
Feasibility Report Alternative Numbers
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RECORD OF DECISION
ATLANTIC WOOD INDUSTRIES, INC., SUPERFUND SITE
OPERABLE UNIT I (SOIL, SEDIMENT, DNAPL)
PART I - DECLARATION
I. SITE NAME AND LOCATION
Atlantic Wood Industries, Inc., Superfund Site
City of Portsmouth, Virginia
II. STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the remedial action selected for Operable Unit 1, which addresses
soil, sediment, and Dense Non-Aqueous Phase Liquid (DNAPL) contamination at the Atlantic Wood Industries,
Inc., Superfund Site, located in Portsmouth, Virginia (Site). This remedial action was chosen in accordance
with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (CERCLA) ,
42 U.S.C. §§ 9601 et seq., and 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 selecting the remedial
action and is based on the Administrative Record for this Site. An index of documents included in the
Administrative Record may be found at Appendix A of the ROD. Appendix B provides a glossary of commonly used
Superfund terms.
The Virginia Department of Environmental Quality (VDEQ) has commented on the selected remedy and the
State's comments have been incorporated into this ROD to the extent possible.
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 VI
(Summary of Site Risks) of this ROD, if not addressed by implementing the remedial action selected in this
ROD, may present an imminent and substantial endangerment to public health, welfare, or the environment.
IV. DESCRIPTION OF THE SELECTED REMEDY
The Environmental Protection Agency (EPA) , in consultation with VDEQ, has selected the following
remedial action for the Atlantic Wood Industries, Inc., Superfund Site. This remedy addresses soil,
sediment, and DNAPL contamination (Operable unit 1 or oul) at the Site. Subsequent operable unit RODs will
address potential ground water and river cleanup. As environmental conditions vary throughout the Site, the
evaluation of the various cleanup alternatives for OU1 was performed for five separate Site units which are
called Remedial Response Units. The selected remedy is comprised of the following major
components as broken down into these Remedial Response Units:
Remedial Response Units 1 and 2 (soil/sediment):
! Excavation of an estimated 20,000 cubic yards of
contaminated soil and 564 cubic yards of sediment
existing above the water table (i.e., above the depth
of one to ten feet) in order to achieve the cleanup
levels provided in Part II, Section X, of this ROD.
! Treatment of the excavated soil and sediment, including
sediments already stored on-site, using engineered land
treatment (ex situ bioremediation) subject to
successful treatability results; otherwise, treatment
using low temperature thermal desorption.
Appropriately treated materials would be backfilled to
the general areas from which they were originally excavated.
Remedial Response Unit 3 (DNAPL):
! Recovery of DNAPL through the use of pumping or bailing
of new and existing wells for off-site reuse or disposal.
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Remedial Response Units 4 and 5 (high pH/elevated metal soil/sediment):
! Excavation of an estimated 2,370 cubic yards of
contaminated soil and 250 cubic yards of sediment
existing above the water table (i.e., above the depth
of one to ten feet) in order to achieve the cleanup
levels listed in Part II, Section X, of this ROD.
Backfilling of these excavation areas with clean soil
or sediment.
! Disposal of excavated soils and sediments from Remedial
Response Units 4 and 5 in an off-site landfill
permitted in accordance with the Resource Conservation
and Recovery Act (RCRA) Subtitle C reguirements;
Common Remedial Elements for all Remedial Response Units:
! Implementation of a sediment, ground water and surface
water monitoring program to verify the effectiveness of
the remedial action.
! Institutional controls including restrictions on title,
use, and access will be placed on the Site.
Restrictions on title shall prohibit the following:
1) residential development; 2) agricultural
development; and 3) the use of ground water for
domestic or drinking purposes.
V. STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal and State
reguirements 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.
Because this remedy will result in contaminants remaining on-site above levels that allow for unlimited
use or unrestricted exposure, a review will be conducted within five years after initiation of the remedial
action to ensure that the remedy continues to provide adeguate protection of human health and the
environment.
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Thomas C. Voltaggio Date
Director
Hazardous Waste Management Division
Region III
Environmental Protection Agency
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RECORD OF DECISION
ATLANTIC WOOD INDUSTRIES, INC., SUPERFUND SITE
OPERABLE UNIT 1 (SOIL, SEDIMENT, DNAPL)
PART II - DECISION SUMMARY
I. SITE NAME, LOCATION, AND DESCRIPTION
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The Atlantic Wood Industries, Inc., Site (Site) currently occupies approximately 47.5 acres of land on
the industrialized waterfront area of Portsmouth, Virginia (Figure 2-1). The States Norfolk Naval Shipyard
facilities, and on the west by a Virginia Electric Power Company right-of-way. To the south of the Site is
the south annex of the U.S. Norfolk Naval Shipyard and land occupied by the Portsmouth City School Board.
The Site is bounded on the east by the Southern Branch of the Elizabeth River. The Site is split into
eastern and western portions by the Norfolk and Portsmouth Beltline Railroad and Burtons Point
Road. The eastern portion of the Site contains the currently inactive wood processing facilities, and wood
storage areas. The western portion of the Site has been used for the storage of treated and untreated wood.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The original plant was constructed in 1926 by the Savannah Creosoting Company. The Site has been used
for various purposes during its history including a possible coal tar refinery, creosote wood treating plant,
pentachlorophenol (PCP) wood treating plant, and a storage yard for treated lumber. According to Site
records, wood was never treated with chromated copper arsenate (CCA) , a common wood treating chemical,
although some CCA-treated wood is stored on-site. A review of aerial photographs showing the historic
shoreline of the west bank of the Elizabeth River suggests that at least a portion of the Site has been
elevated with filling materials. Between 1978 and 1986, a significant amount of fill material was added to
the eastern boundary, and filling activity occurred south of this area from 1944 to approximately 1971 in an
inlet located along the southeastern boundary of the Site.
From 1926 until 1944, the Site was operated as the Savannah Creosoting Company and was owned by the
Savannah Creosoting Company, Inc., a Maryland corporation. On December 28, 1944, the name of Savannah
Creosoting was changed to Atlantic Creosoting Company, Inc. On September 1, 1978, the name of the
corporation was changed to Atlantic Wood Industries, Inc (AWI). Finally, on October 25, 1985, the name of
corporation was changed to Atlantic Wood Assets, Inc. On June 19, 1985, a Georgia corporation named
Atlantic Interim Inc. was incorporated. Its name was changed on November 21, 1985, to Atlantic Wood
Industries, Inc. On November 30, 1985, the operating assets of Atlantic Wood Assets, Inc., including the
wood preserving plant referred to above, were sold to Atlantic Wood Industries, Inc., the Georgia
Corporation. Since that time, Atlantic Wood Industries, Inc., the Georgia Corporation, has owned and operated
the plant.
The original Savannah Creosoting Company facility consisted of two of the existing four wood treatment
retorts (pressurized cylinders), the existing office building, several existing maintenance and storage
buildings, and the above-ground tank farm that was located adjacent to Elm Avenue. The above-ground tank
farm consisted of four storage tanks, installed around 1940, and were of open-top steel construction. These
tanks were originally used to store wood preserving chemicals, including creosote. In the past, two of the
four tanks were used occasionally to store process water which may have contained PCP. Two of these tanks
were removed in 1985, and the last two were removed by June 1986.
The four tanks west of the retorts were previously associated with a tar distillation unit that was
located east of the office building. There was also a shallow concrete basin associated with the tar
distillation unit. The tar distillation unit was disassembled in the 1940s. The basin was filled in and
the four tanks were moved to their present location. Portions of the retaining wall around the basin are
currently exposed and can be examined. Additionally, from about 1940 until October 1985, there was a
concrete process water recycling basin located immediately north of the retort building. This unit was used
to recover preservative from process water and until 1972 some excess process water was discharged to an area
immediately south of the railroad spur that juts out into the Southern Branch of the Elizabeth River. AWI
continued to use the unit to recover preservative and to recycle process water until it was removed in August
1985.
Retorts I and II, the original wood treatment units at the Site, were in use from 1926. Both retorts
were primarily used for creosote treatments, but from the late 1950s through the early to mid 1960s a
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PCP-related product known as creo-penta may also have been used. Retort III was constructed in 1959 and was
used for creosote treatment only. PCP was first used at the Site in about 1972 in Retort I. For
approximately two years, the plant operator used Retort I at times for PCP and other times for creosote
treatments. In 1974, Retort IV was constructed and dedicated to PCP treatments. At that time, Retort I was
used for creosote treatment only. The use of PCP as a preservative was discontinued in 1985.
Until about 1985, the plant used a concrete closed-loop recovery system located just north of the retort
building. This unit was used to recover creosote preservative and process conditioning water for reuse.
This system was removed in 1985, and the process then used a closed-loop recovery system located
in the retort building. All wood treating operations ceased by 1992.
When the Clean Water Act was implemented in the early 1970s, the plant was reguired to stop discharging
effluent from the oil/water separator directly into the Elizabeth River. At that time, a liguid incineration
unit known as a "Liguidator" was constructed. This unit was fired with No. 6 fuel oil and incinerated excess
process water that was previously discharged through the oil/water separator into the river. AWI stopped
using the Liguidator unit in 1984.
From approximately 1966 until 1982, an area of the property was used as a disposal area. This area is
located in the southwest corner of the property and west of Burtons Point Road. This area, termed the
historical disposal area, may contain up to 740 cubic yards of general debris, steel bands, untreated and
treated wood waste, and cylinder and tank clean out material, which may contain creosote and PCP.
On July 23, 1987, AWI entered into an Administrative Order by Consent (Consent Order) with EPA (Docket
No. III-87-24-DC) whereby AWI would perform initial cleanup actions and perform a Remedial Investigation and
Feasibility Study for the Site.
Sampling data collected during a preliminary site assessment were used to evaluate the relative hazards
posed by the Site using EPA's Hazard 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 may be placed on the National Priorities List (NPL), making it eligible to
receive Superfund monies for remedial cleanup. In 1985, an HRS score of 40.77 was calculated for the AWI
Site. On February 15, 1990, the Site was listed on the NPL.
A. Initial Cleanup Actions
Based on the results of sampling taken during the Remedial Investigation at the Site, it became evident
that hazardous substances associated with wood treatment had migrated into the soil surrounding the storm
sewer system which is located on Elm Avenue and to the inlet sediments where this sewer discharges. The Elm
Avenue storm sewer runs along the northern border of the Site. As this sewer pipeline contained small
cracks, surrounding contaminants seeped into it and were transported to the Elizabeth
River and its sediments. AWI, under the Consent Order with EPA, has undertaken an action to correct this
problem. Under EPA oversight, AWI hired a contractor to clean and install a new liner within all affected
manholes, catch basins, and sewer pipelines. The liner is made of polyethylene and various resins. This work
was completed by March 25, 1995.
As part of this same action, AWI excavated approximately 660 cubic yards of contaminated sediments that
existed in the intertidal drainage ditch and in the inlet that exists in the northeastern section of the
Site. This work was accomplished under EPA oversight and field work was completed by May 18, 1995.
The excavated sediments were stockpiled on-site in a secure storage tank and will be addressed as part of the
selected alternative provided in Part II, Section X, of this Record of Decision (ROD) for Remedial Response
Unit 2.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
The documents which EPA used to develop, evaluate, and select a remedial alternative for the Site have
been maintained at the Portsmouth Municipal Library, 601 Court Street, Portsmouth, VA 23704; Kirn Memorial
Library, City Hall Avenue, Norfolk, VA 23501; Chesapeake Public Library, 200 Feeder Street,
Chesapeake, VA 23320; and at the EPA Region III, Philadelphia Office.
Although many local residents, community groups, and officials are aware of work being done at the Site,
community involvement has been limited. In April 1995, EPA interviewed local residents and officials to
determine the community's awareness of, and concerns about, the Atlantic Wood Site. Many
community members were interested in meeting with EPA and learning more about the Superfund process. Most of
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those interviewed believe that frequent updates from EPA will create greater community interest and
involvement in Site activities. Some of the concerns voiced during the community interviews included: a lack
of knowledge about the Site and contamination; affects of contamination on the Elizabeth River and
surrounding waterways; the impact of the Site on the local community; and the length of time required to
conduct the cleanup.
The Feasibility Study Report, Proposed Plan, and other documents for the Atlantic Wood Industries, Inc.,
Site were released to the public on June 9, 1995. The notice of availability for these documents was
published in the Virginian-Pilot and the Ledger-Star on June 9, 1995. A public comment period was held from
June 9, 1995, to July 8, 1995. By request, the public comment period was extended until August 7, 1995. A
notice announcing this extension appeared in the Virginian-Pilot and the Ledger-Star on July 12, 1995.
A public meeting was held during the public comment period on June 27, 1995. At this meeting,
representatives from EPA answered questions about the Site and the remedial alternatives under consideration.
Approximately 35 people, including residents from the impacted area, attended the meeting. EPA responses to
the comments received during the public comment period are included in the Responsiveness Summary found at
Part III of this ROD.
IV. SCOPE AND ROLE OP THE RESPONSE ACTION
The remedial action selected in this Record of Decision is intended to remediate contamination in soils
and sediments, and to recover DNAPLs that are located in the subsurface. As with many Superfund sites, the
problems at the Atlantic Wood Industries, Inc., Site are complex. As a result, EPA has
organized the overall remedial work into Operable Units (ous). These are:
! OUI: Surface Soils, Sediments, and Dense Non-Aqueous Phase Liquid (DNAPL) located in subsoils;
! OU2: Site Ground Water;
! OUS: Impact to the River/Off-site areas (Note: this unit may be combined with OU2 Ground Water).
This ROD addresses the cleanup of OUI only. Operable Units 2 and 3 will be handled separately. EPA has
chosen this strategy for Site cleanup for two specific reasons: 1) OUI contamination represents a continuing
source of further releases of contaminants to the environment and therefore needs to be cleaned
up first; 2) OU2 and OUS require further investigation and study to determine feasible cleanup solutions.
Operable Unit 1, which this ROD addresses, is further broken down into five Remedial Response Units
(RRUs) including associated areas, as described below. Figure 2-2 provides a Site plan which shows the
general locations of these areas.
! RRU1: On-site soils in the former Wood Treatment East
(Area 1), Wood Treatment West (Area 2), Historic
Disposal (Area 3), and Wood Storage Yard (Area 4)
! RRU2: On-site sediments from the Inlet (Area 5), Storm
Water Runoff Ditch (Area 6), and Western Runoff Ditch (Area 7)
! RRUS: Dense Non-Aqueous Phase Liquid located in subsurface
! RRU4: On-site sediment in Southeast Ditch (Area 8)
! RRUS: On-site soil in Waste Lime Area (Area 9)
The above designations will be used throughout this ROD to identify response units and areas that have
been studied or are specifically planned for cleanup. The main difference between RRU1 and RRU2 is that RRU1
deals with soils, whereas RRU2 deals with sediments which generally have different cleanup levels than soils.
These cleanup levels are provided in Part II, Section X of this ROD. RRU4 and RRUS differ from RRU1 and RRU2
as the former units were found to contain elevated metal concentrations and high pH.
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A. General
The Site is located on the industrialized banks of the South Branch of the Elizabeth River. The
Elizabeth River is the dominant aquatic habitat impacted by the Site. The river system has three branches
that empty into the southern end of the Chesapeake Bay which contains highly-valued wetland areas. National
Pollution Discharge Elimination System (NPDES) monitoring at the Site is performed at Outfalls 001, 002, and
003 which are shown on Figure 2-3. NPDES monitoring is a provision of the Clean Water Act for regulating
pollutant discharges into navigable waters of the United States through a permitting system
administered by EPA or an authorized state. AWI has obtained such a permit for the Site (Permit #VA0004189;
effective 3-21-91 to 3-21-96). Outfall 003 at the Site impacts Paradise Creek which exists to the west and
south of, but not immediately adjacent to, the Site. This creek empties into the South Branch of the
Elizabeth River.
The closest human residences are located approximately one mile southwest of the Site in a section of
Portsmouth called Cradock. Drinking water for Portsmouth residents is supplied by a pipeline operated by the
City of Portsmouth; however, some residents use ground water for filling swimming pools and to water their
gardens and lawns. Approximately 13 people work at the Site and 77,000 people live within a 4-mile radius of
the Site. The Norfolk Naval Shipyard and its annexes, which are located within 1/2 mile of the Site, employ
up to 14,000 people.
B. Surface Water Ry4rology
The Site is a relatively flat area with ground surface elevations ranging from less than one foot above
mean sea level adjacent to the Southern Branch of the Elizabeth River to greater than ten feet above mean sea
level near the southern property boundary west of Barton's Point Road. Stormwater runoff at the
Site drains through the facility's three NPDES Outfalls (001, 002, and 003) and the Elm Avenue storm sewer.
Surface water runoff from the southeast half of the property located east of Burton's Point Road flows to a
collection ditch and Outfall 001, and then enters the Southern Branch of the Elizabeth River.
Surface water runoff from the northeast half of the property located to the east of Barton's Point Road, and
from off-site areas, drains to the South Branch of the Elizabeth River via Outfall 002 and the Elm Avenue
storm sewer. Surface water runoff from the portion of the Site to the west of Burton's Point Road
discharges through Outfall 003 into a ditch that flows north and eventually discharges into Paradise Creek.
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The Elizabeth River System is a tidal basin encompassing the Southern, Western, and Eastern Branches.
The Lafayette River converges with the three branches forming a main stem which empties into Hampton Roads.
The Southern Branch forms the eastern boundary of the Site and, in that location, flows from
south to north. The Southern Branch is connected via the Dismal Swamp Canal to the Intercoastal Waterway
which leads to Abetmarie Sound, and the Virginia Cut connects the Southern Branch to the Intercoastal
Waterway which leads to Pamlico Sound.
The Elizabeth River has a drainage area of approximately 300 sguare miles which is intensely urbanized
and includes portions of Norfolk, Portsmouth, Chesapeake, and Virginia Beach. There is very little
topographic relief in the basin and freshwater inflow to the system is minimal, composed principally of
drainage from the Dismal Swamp and stormwater runoff.
C. Hydrogeology/Geology
Based on the results from the various borings and monitoring wells drilled as part of the Remedial
Investigation and prior investigations, three hydrostratigraphic units have been identified beneath the Site.
These units are termed as follows:
Upper Water-Bearing Sone (Columbia Aguifer) - the uppermost
soil is a brown to gray, organic-rich mixture of clayey silt
and fine to medium sand, with a thickness ranging between 18
to 23 feet. This layer is continuous throughout the Site,
and contains ground water under unconfined conditions; the
water table is approximately 0.6 to 10 feet below grade.
The Columbia Aguifer is not known to be a drinking water source.
Semi-Confining Unit (Yorktown Clay) - immediately underlying
the Columbia Aguifer is a layer of gray clay, which acts as
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a semi-confiningunit. This layer may be silty and may
contain shell fragments. This lower semi-confining clay
layer is thought to be continuous beneath the majority of
the Site. The thickness (as determined by three borings)
was found to range between eight and 27 feet.
Lower Water-Bearing Zone (Torktown-Bastover Aguifer) - the
clay unit overlies a fine to medium to coarse grained sand
layer. Based on the data collected, as well as regional
geologic reports, this unit is the Yorktown-Eastover
Aguifer. Ground water occurs in this unit under semi-
confined to confined conditions.
Evaluation of the hydrogeology for the AWI Site was developed primarily from installation of monitoring
wells at varied depths across the Site, and from stratigraphic information obtained during the soil boring
program. Observations of water levels in wells installed as part of the Remedial Investigation and the
existing well network, provided data relative to the position of the potentiometric surface(s), water level
fluctuations, and ground water gradients across the Site. Soil boring data were utilized to characterize the
lithology and geometry of the units.
An assessment of the local hydrogeologic characteristics was made possible by the evaluation of ground
water data collected during the period between January 1989 and February 1990. Water levels measured at each
of the wells during the various Remedial Investigation sampling events or Site visits were used to calculate
ground water elevations.
Monitoring wells completed in the Columbia Aguifer indicate a range in water levels from elevations of
approximately 0.18 feet to 10.07 feet above mean sea level (msl). Ground water elevation data for the
shallow monitoring wells ("100"-series) screened in the upper silt, clay, and sand zone indicate a varied
flow system, with several directions of ground water flow. As indicated by the ground water potentiometric
contour maps presented in the Remedial Investigation Report, there are two prominent flow systems present at
the Site. Within the eastern portion of the Site, ground water flow is mainly to the east, toward the
Southern Branch of the Elizabeth River. Within the western portion of the Site, a ground water mound is
present, such that ground water flow in this area is radial. The variation in flow directions or presence of
two flow systems was attributed to: 1) the discontinuous nature of the deposits, which results in materials
of varying hydraulic conductivity and interconnection, and 2) recharge of the ground water system by the
introduction of water from Site drainage features. The
influence of the surface configuration of the Yorktown Clay on shallow ground water flow patterns has not yet
been defined, but will be further evaluated following completion of proposed additional subsurface
investigation activities. Supplemental remedial investigation activities pertaining to further definition of
the Yorktown Clay and shallow ground water flow characteristics are listed in Section 1.2.4.6 of the
Feasibility Study Report.
Due to the presence of the ground water mound in the western portion of the Site, a wide range of ground
water elevations was obtained. In general, the ground water potentiometric surface was the highest in wells
MW-33 and MW-34, which are located centrally within this area. Monitoring wells along the periphery of the
western Site were found to be an average of two to three feet lower than wells MW-33 and MW-34. Ground water
movement in the shallow aguifer does not appear to be controlled or affected
appreciably by the nearby shallow surface drainage features, since the ground water elevations are typically
below the base of the nearby drainageways. Contours of the potentiometric surface in the eastern portion of
the Site show that the overall direction of ground water flow across the Site is to the east. The hydraulic
gradient measured during each of the sampling dates is extremely low, and ranges from 0.0059 ft/ft to 0.0068
ft/ft. In the western portion of the Site, the hydraulic gradient was found to vary between 0.010 ft/ft and
0.0094 ft/ft. Figure 2-4 provides a map depicting the potentiometric surface at the Site.
Due to the presence of only three monitoring wells completed within the lower water-bearing zone
("200"-series wells), no detailed potentiometric surface map could be developed; however, regional geologic
data indicates that flow within this system would be toward the east, discharging into the South Branch of
the Elizabeth River. Ground water flow patterns within the lower aguifer will be further evaluated during
the proposed supplemental remedial investigation, as outlined in Section 1.2.4.6 of the Feasibility Study
Report.
In situ rising- and falling-head hydraulic conductivity tests were performed at ten well locations
across the Site. Horizontal hydraulic conductivities were determined only for those monitoring wells screened
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within the shallow water-bearing zone (Columbia Aquifer). Horizontal hydraulic conductivity
ranged from 1.3 x 10-2 cm/sec to 1.9 x 10-4 cm/sec. Average horizontal hydraulic conductivity value for the
shallow zone was calculated to be 4.3 x 103 cm/sec using the Hvorslev method and 3.3 x 10-3 cm/sec using the
method of Bouwer and Rice.
Based on water level measurements obtained during previous monitoring efforts, the direction and rate of
ground water movement can be approximated. Ground water velocity calculations for the shallow Columbia
Aguifer were based on an average hydraulic conductivity value Qf 4.3 x 10-4 cm/sec and an estimated
effective porosity of 30 percent. Using a mean hydraulic gradient of 0.0062 ft/ft, an average linear
velocity calculated for flow beneath the Site in the eastern area is 0.25 ft/day (91 ft/year). This
calculation represents a conservatively high estimate of the rate of ground water migration of constituents
dissolved in ground water.
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D. Wetlands
Five wetland areas have been identified at the Site. All the wetlands identified are in a disturbed
condition and are of low functional value based upon their small size, low vegetation diversity, scattered
vegetation, disturbed soils, and minimal wildlife usage. The five areas contain basically two types of
wetlands. The first type is a reed grass (Phragmites australis) community and the second a saltbush
(groundsel tree) community. Reed grass is an aggressive, less desirable species with little-known value to
wildlife. It typically invades disturbed marshes and competes with species considered more desirable for
their habitat value. Groundsel communities are considered of moderate value for the diversity and bird
nesting area they add to the marsh ecosystem.
The Site is located between two large riparian/estuarine wetland habitats of high value—Chesapeake Bay,
7 km to the north, and great Dismal Swamp National Wildlife Refuge, 12 km to the south. The Elizabeth River
connects these two large habitats, acting as an arian migratory route. Figure 2-3 depicts
the general locations of the wetland areas and surface water Outfalls 001, 002, and 003 at the Site.
E. Extent of Contamination
The primary objective of the Remedial Investigation was to characterize the nature and extent of
hazardous substances present at the Atlantic Wood Industries, Inc., site. As part of this effort, the
Remedial Investigation identified and evaluated potential migration routes for contaminants and exposure
pathways for human and ecological receptors.
1. Soils Quality
In general, polynuclear aromatic hydrocarbons (PAHs) and pentachlorophenol (PCP) were detected in the
nine areas of the Site in surface and subsurface soils. PCP, and PAHs (which are constituents of creosote),
were used in the wood treating processes at the Site. The highest levels of PAHs were detected
in the wood treatment and historic disposal areas. The highest levels of PCP at the Site were detected in
the historic disposal area. PAHs detected in the wood storage area are most likely associated with the wood
treatment processes conducted in this area. PAHs and PCP detected in the historic disposal area are
probably associated with the historical disposal activities.
Concentrations of metals were highest in the wood storage yard, where chromated copper arsenate (CCA)
treated wood was stored, and along the southeastern boundary of the Site, adjacent to Navy property.
Elevated levels of zinc and copper concentrations, and high pH, in the southeastern area may be related to
acetylene sludge that was discharged on the surface by a pipeline that was allegedly operated by the U.S.
Navy. Blasting grit and debris that the U.S. Navy may have disposed near this area may also be a possible
source for the elevated metals.
Analyses for polychlorinated dibenzodioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs) were
performed on 43 soil samples collected during the Site investigations. Twenty-five of the samples were
collected in the vicinity of the storm sewer line and eighteen samples were collected in other areas of the
Site. The samples were collected to represent worst case conditions. EPA adopted a procedure based on
toxicity equivalence factors (TEFs) to estimate the potential risks posed by complex mixtures of PCDDs and
PCDFs. TEFs are based on research which shows a strong structure-activity relationship between the chemical
structure of a particular PCDD/PCDF congener and its ability to elicit a biological response in various
i~vivo and in vitro test systems. The TEFs were used to calculate toxicity equivalent concentrations (TECs)
-------
for the soil samples analyzed for dioxins/furans which are presented in Table 2-1.
Figure 2-5 provides maximum concentrations of total PAHs, PCP, 2,3,7,8-TCDD (TEFs), arsenic, copper, and
zinc, in surface soils and their general locations. Figure 2-6 provides the concentration and location of
carcinogenic PAHs in surface soils located in the western section of the Site, and Figure 2-7
provides similar data for the eastern section of the Site.
The toxicity of carcinogenic PAHs can be defined in terms of the toxicity of a specific PAH compound
named benzo[a]pyrene. Benzo[a]pyrene is considered to be one of the most potent of the carcinogenic PAHs.
Therefore, benzo[a]pyrene was used as a surrogate to derive the cleanup level for carcinogenic PAHs
provided in Part II, Section X of this ROD. Relative potency factors are available for each carcinogenic
PAH: the carcinogenic potency for each PAH was derived by assuming that the carcinogenic PAH and
benzo[a]pyrene have similar dose-response curves, but takes proportionately larger concentrations of
carcinogenic PAH to induce the same responses as benzo[a]pyrene. For example, benzo[a]anthracene which is
another carcinogenic PAH, has a relative potency factor of 0.1; therefore, a benzola]anthracene concentration
of 5 mg/Kg is eguivalent to 0.5 mg benzo[a]pyrene/Kg. This concentration in terms of benzo[a]pyrene is
referred to as benzo[a]pyrene eguivalents (BaPEg). Relative potency factors for carcinogenic PAHs are:
PAR Constituent Factor
Benzo[a]pyrene 1.0
Benzo[a]anthracene 0.1
Benzo[b]fluoranthene 0.1
Benzo[k]fluoranthene 0.01
Chrysene 0.001
Dibenzo[a,h]anthracene 1.0
Indeno[1,2,3-cd]pyrene 0.1
The number of BaPEg can be related to total carcinogenic PAH concentrations at this Site by generating a
regression eguation between the total carcinogenic PAH (cPAH) concentration and the corresponding BaPEg
concentrations at each soil sample. The relationship is linear with a statistically significant correlation
coefficient (r) of 0.97. The linear relationship is defined as:
BaPEg = 0.19 cPAH
Cleanup levels for carcinogenic PAHs can be derived in terms of BaPEg. The BaPEg concentration can
easily be translated into a carcinogenic PAH concentration using the above eguation. This conversion
facilitates the delineation of areas that reguire remediation because the areas are defined by cPAH
concentrations which are shown in Figures 2-6 and 2-7.
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TABLE 2-1
ATLANTIC WOOD INDUSTRIES, INC.,
TOTAL EQUIVALENT 2,3,7,8-TCDD CONCENTRATIONS, • g/kg
Sample
Location
Treatment
Areas
Old Disposal
Area
Sample
BI-S
S9-S
S13-A
T1-4A
T1-4PD
T1-4F
7-2A
7-11
R-4
S-25
6-2A
7-6A
7-1A
5-7A
5-3A
7-12A
7-10A
Rll-A
Sl-A
S4-A
S15-A
Tl-A
T1-3A
7-9B
4-5A
9C
9E
Depth
(ft)
0-0.5
0-0.5
0
0-2
0-2
0-0.5
0-0.5
0-0.5
0-4
—
0-0.5
0-0.5
0-0.5
0-0.5
0-0.5
0-0.5
0-0.5
1-2
3-4
4-6
1-2
2-4
1-2
1.5
0-0.5
2-8
0-4
Surfac
Soils
0.02
0.22
0.77
0.00
0.00
0.02
7.10
8.04
0.06
0.28
2.05
2.54
0.75
1.27
9.31
6.06
11.64
—
—
—
—
—
—
—
1.03
--
12.77
Total Equivalent
2,3,7,8-TCDD
Subsurface
Soils
0.60
0.00
0.01
0.55
0.03
0.72
0.50
25.12
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In June of 1990, after the field work for the Remedial Investigation had been completed, EPA requested
that AWI collect a representative sample from each study area and conduct Toxicity Characteristic Leaching
Procedure (TCLP) and analysis to ascertain whether the soils were characteristically hazardous. Based on the
TCLP testing, the soils are not hazardous by characteristic. Table 2-2 provides the results for the TCLP
analysis.
2. Sediment Quality
Sediment samples were collected from five locations at the Site to characterize the extent of impact on
these areas from wood treating operations. The areas that were characterized include a storm-water runoff
ditch in the treated wood storage area, a ditch along the western boundary of the Site, a ditch at
the southeast edge of the Site which discharges into the Elizabeth River, the inlet receiving discharge from
Outfall 002 and the Elm Avenue storm sewer, and the Elizabeth River.
The highest concentrations of total detected PAH were present in the inlet sediment, increasing as the
samples were collected closer to the river. The PAH concentrations in the inlet ranged from 511 mg/kg to
38,437 mg/kg. The highest concentrations of PCP and chromium were detected in the storm-water runoff ditch
flowing out of the CCA and PCP treated wood storage area, with concentrations ranging from 7.2 mg/kg to 12.0
mg/kg and 53 mg/kg to 54 mg/kg, respectively. The concentrations of arsenic, copper, and zinc were highest
in the southeast ditch area, which is just north of the Navy property and passes through the acetylene sludge
disposal area (a.k.a. waste lime area), with maximum concentrations of 364 mg/kg, 1,350 mg/kg, and 1,890
mg/kg, respectively. Analysis for metals was not performed on samples collected from the inlet. Figure 2-8
provides concentrations of total PAHs and PCP at the various sediment sampling locations.
3. DNAPL Occurrence
Dense Non-Aqueous Phase Liquid (DNAPL) can be described as heavy liquids that exist below the surface in
certain areas of the Site, or can also be thought of as creosote-soaked subsoils. DNAPL exists at the Site
because of past releases of chemicals used in the wood-treatment processes. Available information
suggests that DNAPL has not penetrated into the Yorktown Clay zone in any significant manner and is thus
predominantly confined to the Columbia aquifer which is the upper water-bearing zone. The Yorktown Clay zone
is located at the bottom of the Columbia aquifer and acts as a semi-confining unit which in general
prevents DNAPL contamination from spreading into the lower aquifer known as the Yorktown-Eastover aquifer.
Although predominant areas of DNAPL occurrence in the Columbia aquifer is determined, the full extent of
DNAPL occurrence is not defined. The two main areas in which potentially recoverable DNAPL occurs are within
the former process area of the plant (Area 1—see Figure 2-2 for area locations) and the historical disposal
area (Area 3) at levels below approximately six feet.
The surface mound in the historical disposal area may indicate a likely area in which DNAPL may exist.
According to the Remedial Investigation, the wells that closely encircle the historical disposal area have
not had DNAPL accumulate within them, though some product presence was noted in soils located
just south of the historic disposal area (in wells marked MW-30 and MW-102). No wells have been centrally
installed within the historical disposal area itself, but soil samples were collected there. Based on
examination of the soil sampling logs, it seems likely that sufficient DNAPL is present and would thus
accumulate in wells centrally installed in the historic disposal area.
DNAPL has also accumulated in monitoring well MW-34 located in the wood storage area (Area 4), and
monitoring well MW-117, located east of the former process area and near the inlet (Area 5), where apparent
thicknesses of less than one foot and 1.5 feet, respectively, have been measured. These well locations are
remote from the two main areas of DNAPL occurrence.
Table 2-3 provides the distribution of DNAPLs in soils at the Site based on borings taken during the
Remedial Investigation. Table 2-4 provides a summary of DNAPL composition for Site monitoring well 117 (MW
117) for organic and inorganic constituents.
4. Ground Water
Only minimal information is provided on ground water quality in this ROD, as a subsequent operable unit
will address the potential remediation of ground water at the Site. Further ground water quality information
can be found in Section 4.3 of the Remedial Investigation Report (March 1992).
A total of 27 monitoring wells were used to generate ground water quality information for the Site. A
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total of 23 wells monitor the upper-most water-bearing zone (Columbia Aquifer), while four wells are screened
within the lower water-bearing zone (Yorktown-Eastover Aguifer).
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TABLE 2-2
ATLANTIC WOOD INDUSTRIES, INC., SITE
RESULTS OF TCLP TESTING
JUNE 28, 1990
Location
Grid Location(*)
Depth
Metals, ug/L
Arsenic
Barium
Cadmium
Chromium
Mercury
Lead
Selenium
Silver
Volatile Organic Compounds,
Benzene
Carbon Tetrachloride
Chlorobenzene
Chloroform
1,2-Dichloroethane
1,1-Dichloroethylene
Methyl ethyl ketone
Tetrachloroethylene
Trichloroethylene
Vinyl chloride
Semi-Volatile Organic Compounds,
o-Cresol
m-Cresol
p-CresoL
1,4-Dichlorobenxene
2,4-Dinitroluene
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Nitrobenzene
Pentachlorophenol
Pyridine
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Note: U indicates that the compound was not detected.
*Grid location corresponds to RI sampling grid.
Wood
Storage
Area
1C
0-0.5 ft
100 U
930
12.3
10.0 U
0.200 U
100 U
100 U
10.0 U
g/L
25 U
25 U
25 U
25 U
25 U
25 U
50 U
25 U
25 U
50 U
ds, • g/L
20 U
20 U
20 U
20 U
20 U
20 U
20 U
20 U
20 U
100 U
20 U
100 U
20 U
Wood
Storage
Area
2-3
0-0.5 ft
100 U
774
9.73
10.0 U
0.200 U
117
100 U
10.0 U
25 U
25 U
25 U
25 U
25 U
25 U
50 U
25 U
25 U
50 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
50 U
10 U
50 U
10 U
Wood
Storage
Area
3-2
0-0.5 ft
100 U
1140
10.1
10.0 U
0.200 U
100 U
100 U
10.0 U
25 U
25 U
25 U
25 U
25 U
25 U
50 U
25 U
25 U
50 U
20 U
20 U
20 U
20 U
20 U
20 U
20 U
20 U
20 U
100 U
20 U
100 U
20 U
Wood
Treating
Area West
4
0-0.5
100
-3
ft
U
2080
5.00
10.0
0.200
U
U
U
9460
100
10.0
25
25
25
25
25
25
50
25
25
50
10
10
10
10
10
10
10
10
10
50
10
50
10
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
Wood
Treating
Area East
5
0-0.5
100
-8
ft
U
540
5.00
10.0
0.200
100
100
10.0
25
25
25
25
25
25
50
25
25
50
10
10
10
10
10
10
10
10
10
50
10
50
10
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
Wood
Treating
Area East
6-6
0-0.5 ft
100 U
960
8.31
10.0 U
0.200 U
282
100 U
10.0 U
25 U
25 U
25 U
25 U
25 U
25 U
50 U
25 U
25 U
50 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
50 U
10 U
50 U
10 U
Wood
Treating
Area East
7-7
0-0.5
100
ft
U
1510
5.00
10.0
0.200
U
U
U
1360
100
10.0
25
25
25
25
25
25
50
25
25
50
10
10
10
10
10
10
10
10
10
50
10
50
10
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
Acetylene
Sludge
Area
8-8
0-0.5 ft
100 U
1670
7.74
10.0 U
0.200 U
1470
100 U
10.0 U
25 U
25 U
25 U
25 U
25 U
25 U
50 U
25 U
25 U
50 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
50 U
10 U
50 U
10 U
Historic
Disposal
Area
9E
0-0.5 ft
100 U
1500
5.00 U
10.0 U
0.200 U
1460
100 U
10.0 U
25 U
25 U
25 U
25 U
25 U
25 U
50 U
25 U
25 U
50 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
10 U
642
10 U
50 U
10 U
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TABLE 2-3
ATLANTIC WOOD INDUSTRIES, INC., SITE
DNAPL DISTRIBUTION IN SOILS
BASED ON RI/FS SOIL BORING AND WELL LOGS
BORING/
WELL
2-E
3-E
4-C
5 -A
5-C
5-D
5-E
6 -A
6-B
6-D
6-E
7 -A
7-B
7-C
7-G
9 -A
9-B
9-C
9-D
9-E
9-F
DNAPL
OCCURRANCE
(FT BGS)
3-6
2-4
1.5-4
5.5-19
0-2
4-11
0-2.5
5.8-6
2-3
5.5-8
0-4
4-8
8-10
5-12
8-9
8.5-11
14.5-17
2-5.5
8-10
3.8-6.5
1-1.5
0-1
2.3-3.5
6-8
1.5-2
5-5.5
5.5-20
20.5-22
4-4.5
6-6.5
3.5-7.5
10-10.5
17-18.5
18.5-20
20-21
25-25.5
28-33.8
5-15
16-19
19-22
0-22
1.8-6
9.3-11.1
11.5-18
18-20
TOP OF
YORKTOWN CLAY
(FT BGS)
20
(1)
19
19
17.5
17.5
19
16
16
(1)
17
18.5
19.5
18.5
17
(1)
18
(1)
(1)
(1)
18
NATURE OF DNAPL OCCURRANCE
Product occurs as isolated droplets; sheen
Some product saturation in noted interval
Product saturated coarse lenses above finer laminae
Product saturated coarse lenses above finer laminae
Product stained zones throughout noted interval
Product stained zones throughout noted interval
Product saturation
Thin product layer
Product staining
Product staining in thin clay laminae
Product saturation
Product saturated zones throughout
Zones of product shen throughout
Product occurs as isolated droplets
Light product sheen
Product saturation
Product saturation
Product saturation
Product saturation
Product saturation
Product saturation
Product saturation
Product saturation
Product saturation
Product saturation
Product saturation
Zones of product staining and saturation throughout
Product saturation
Product saturation
Product saturation
Product saturation
Product saturation
Product saturation
Thin sand seams with product saturation
Product saturation
Product saturation
Product saturation laminae
Product saturation seams
Product saturation
Product saturated sand seams
Product saturated zonesand laminae throughout
Product saturation
Product occurs as isolated droplets
Zones of product staining and saturation throughout
Product saturated sand laminae
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TABLE 2-3 (cont'd)
ATLANTIC WOOD INDUSTRIES, INC., SITE
DNAPL DISTRIBUTION IN SOILS
BASED ON RI/FS SOIL BORING AND WELL LOGS
BORING/
WELL
9-G
9-H
9-1
MW-102
MW-105
MW-106
MW-113
MW-114
MW-115
throughout
MW-116
MW-117
MW-118
DNAPL
OCCURRANCE
(FT BGS)
7.3-8
11-17.5
12-17.5
17.5-20
3-5.6
5.6-17.5
15-16
1.5
4-6
6-9.5
7.9-8
5-7
1-2
2.4-4
5-16
0-4.5
8-16
1.5-10.5
TOP OF
YORKTOWN CLAY
(FT BGS)
17.5
17.5
(1)
17
16
16.5
18
15
16
13
16
15.5
NATURE OF DNAPL OCCURRANCE
Product staining and saturation
Product saturated lenses and laminae throughout
Clay laminae with product saturated lenses
Clay with product sheen
Product saturation
Product saturated lenses and laminae throughout
Product saturation
Product staining
Product staining
Product sheen
Thin product saturated lens
Product staining
Product saturation
Product saturation
Product saturated sand lenses above clay lamination
Product saturation
Product occurs as isolated droplets
Product staining and sheen
NOTE: (1) CLAY NOT NOTED ON LOG; SANDS OR INTERBEDDED SANDS AND CLAYS OBSERVED AT BASE OF BORI
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TABLE 2-4
ATLANTIC WOOD INDUSTRIES, INC., SITE
SUMMARY OF DNAPL COMPOSITION
WELL MW-117 - ORGANIC AND INORGANIC CONSTITUENTS
Parameters
Naphthalene
2-Methylnaphthalene
Acenaphthylene
Acenaphthene
Dibenzofuran
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Bix(2-Ethylhexyl)phthalate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno (1,2,3-c,d)pyrene
Dibenzo(a,h)anthracene
Benzo(g,h,i)perylene
Pentachlorophenol
Arsenic
Estimated
Concentrations (• g/L)
64000000
12000000
1000000
17000000
11000000
13000000
36000000
4000000
18000000
12000000
29000000
32000000
3900
2600000
2600000
1900000
3600000
140000
310000
960000
1.2
Chromium
Copper
Zinc
1.2
2.6
9
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In general, PCP was the most dominant acid extractable compound present in ground water. PCP was
detected in seven of the 22 shallow wells. Generally, these wells are located in the area of the
wood-treating plant, the former tank farm, and the historic disposal area. PCP was not detected in any of
the deep wells monitoring the Site.
PAHs were detected in several of the monitoring wells at the Site. Concentrations of total PAHs were
highest near the wood-treating plant and the historic disposal area. PAH concentration ranged up to 12,212
•g/1. The wells located downgradient from the wood-treating plant showed the most elevated levels of PAH in
the shallow ground water zone. PAHs were not detected in any of the deep wells monitoring the
Yorktown-Eastover aguifer.
Several volatile organic compounds (VOCs), including benzene, toluene, ethylbenzene, and xylenes (BTEX),
and styrene were detected in 11 of the 22 shallow ground water monitoring wells. The majority of detections
were found within the eastern half of the Site. VOCs were also detected in two of the deep
wells.
Inorganic constituents, including arsenic, copper, and zinc, were detected in ground water samples
throughout the Site area. Arsenic concentrations ranged up to 876 • g/1 which exceeds the Maximum Contaminant
Level (MCL) of 50 • g/1 for this element. The MCL represents the maximum permissible level of a contaminant
in water delivered to any user of a public water system. MCLs are established under the Safe Drinking Water
Act, 42 U.S.C. §§ 300f et seg., codified at 40 C.F.R. Part 141, and are enforceable
standards that are used as a reference level when analyzing sampling data. Samples taken from three other
wells were found to exceed the arsenic MCL. An arsenic concentration of 12.8 • g/1 was detected in a sample
from one of the four deep wells monitoring the Yorktown-Eastover aguifer.
Total copper concentrations in the shallow aguifer ranged up to 1990 *g/l. The current MCL Goal (MCLG)
for copper is 1300 • g/1. The MCLG is an unenforceable health goal egual to the maximum level of a
contaminant which is not expected to cause any adverse health effects over a lifetime exposure and includes a
margin of safety. In general, copper concentrations were found to be more elevated in those wells in the
western portion of the Site. Copper (dissolved) was not detected in any of the deep wells monitoring the
Yorktown-Eastover aguifer.
The concentration of zinc within the shallow aguifer is fairly consistent throughout the Site. Zinc
concentrations ranged up to 9500 • g/1 in the shallow aguifer and was detected in one of the four deep wells.
Based on the analytical results of PCP sampling and based on their downgradient location from the
wood-treating plant, seven shallow wells were selected and sampled for the presence of dioxin/furans.
Concentrations of 2,3,7,8-TCDD eguivalents ranged from non-detects to 0.00054 •g/l. The current MCL for
2,3,7,8-TCDD is 0.00003 ~g/l.
5. Surface Water
Surface water was not investigated as part of the Remedial Investigation; however, NPDES monitoring is
performed at Outfalls 001, 002, and 003. The Outfalls are shown on Figure 2-3. During the period from
October 1985 through March 1990, the permit maximum for total phenol (1 mg/L monthly average; 2.0 mg/L daily
maximum) was exceeded one time at Outfall 001 during July 1986 with a concentration of 7.65 mg/L. Likewise,
the permitted monthly average for oil and grease (10.0 mg/L monthly average; 15.0 mg/L daily maximum) was
exceeded three times; twice at Outfall 001 (12.5 mg/L and 12.6 mg/L during July and December
1986, respectively), and once at Outfall 003 (10.9 mg/L during December 1986). The permitted maximum oil and
grease concentration was exceeded four times at Outfall 001 (17 mg/L, 20 mg/L, 35.7 mg/L, and 20.47 mg/L
during July, August, December 1986 and March 1989, respectively), once at Outfall 002 (20.8 mg/L during
December 1986), and once at Outfall 003 (28.4 mg/L during December 1986). The permitted maximum oil and
grease concentration was exceeded in May 1989 at each Outfall and in June 1989 at Outfall 001.
In August 1986, and October 1989, rainfall samples from each of the Outfalls were collected and analyzed
for all priority and non-priority pollutant extractable and volatile organics, and various metals. These
parameters were not subject to permit limitations. During the August 1986 event, 2,4-Dimethylphenol, phenol,
and total recoverable phenolics were detected, as well as arsenic, lead, and zinc. In October 1989, only
metals were detected - arsenic, copper, lead, nickel, and zinc.
During each of the first eight months of the permit which was effective beginning March 21, 1991, one
grab rainfall runoff sample was collected from each of the Outfalls, and analyzed for base neutral acids and
selected metals. These parameters were not subject to permit limitations, but were performed as part of the
-------
Virginia Toxics Monitoring Program. Pentachlorophenol, total recoverable phenolics, fluoranthene, total
recoverable zinc, and ferrous iron were most of the compounds that were detected.
Annual toxicity testing was performed by Savannah Laboratories and Environmental Services, Inc., a
representative of AWI. A 48-hour static bioassay was conducted using 5-day old Mysidopsis bahia (grass
shrimp). Results of the bioassay showed 95% or better survival rate for all test and control groups, with
the exception of the tests conducted on August 13, 1986, and October 3, 1989. On August 13, 1986, the
bioassay results showed survival rates ranging from 0% (Outfall 002 discharge, 100% effluent concentration)
to 100% (Outfalls 001 and 002 discharge, 6.25% effluent concentration) which indicate that the stormwater
samples were moderately toxic to Mysidopsis bahia. The August 1986 results may have been due to constituents
that were allowed to accumulate during the abnormally dry months in Spring and
Summer of 1986 and which were washed through the Outfalls with the stormwater. The results of the October
1989 bioassay using water from Outfall 002 showed survival rates between 65% and 85%; the reason for this is
not known, but it was noted in the laboratory report that the survival rate was 65% in the 25% concentration
and then increased to 85% in the 100% concentration. This testing concluded that the stormwater runoff from
the Site was not toxic to the MvsidoDsis bahia, and no additional toxicity testing was reguired by the
Surface Water Control Board.
6. Air
Air was not investigated as part of the Remedial Investigation; however, previous air sampling events
were conducted by EPA and Risk Service International (RSI), a representative of AWI. A total of 58 samples
were collected from eleven stations. EPA identified two on-site naphthalene emission sources: the northeast
drainage ditch area and the wood treatment area east. There was reasonable agreement between naphthalene
measurements made by EPA and RSI for the northeast drainage area, but RSI measurements for the area adjacent
to wood treatment area east were five-fold higher than the related EPA sample.
Based on EPA air sampling data, naphthalene levels at the south boundary fence were shown to be
sufficiently elevated above those of Elm Avenue which is an indication of possible off-site migration.
However, the RSI naphthalene air sampling data did not show similar sampling results. Considering the
collected data from both EPA and RSI, it appears that there is not enough data to conclusively determine if
off-site migration has occurred.
VI. SUMMARY OF SITE HEALTH RISKS
As part of the Remedial Investigation/Feasibility Study (RI/FS) process, an analysis was conducted by
AWI, under the oversight of EPA in consultation with the Virginia Department of Environmental Quality (VDEQ),
to identify human health and environmental risks that could exist if no action were taken at
the Site. This analysis, completed in accordance with the NCP, is referred to as a baseline risk assessment.
This assessment provides the basis for taking action and indicates the exposure pathways that need to be
addressed by the remedial action.
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 section of the
ROD will summarize the result of each of these steps.
A. Data Collection and Evaluation
The data collected and described in the previous section were evaluated for use in the baseline risk
assessment. This evaluation involves reviewing the guality of the data and determining which data are
appropriate to use to guantitatively estimate the risks associated with Site soil, sediment, surface
water, and ground water. Note, ground water data will not be presented within this summary as a subseguent
ROD will address potential ground water remediation.
Based on the soil sampling data, areas of high soil contamination exist in the Wood Treatment Area West
and East, Historic Disposal Area, Wood Storage Area, and the Waste Lime Area. The analytical results from
samples collected in these areas were used to estimate the soil exposure point concentrations for use in the
baseline risk assessment. The exposure point concentrations are upper 95th percentile confidence limits of
the arithmetic average concentrations of this data set. The values for surface and subsurface soils are
presented in Tables 2-5 through 2-9. The tables are divided into the five soil areas that were evaluated in
the baseline risk assessment. The table headings reference the general Site location from which the data
were generated. Scientific notation, a shorthand means of expressing numerical values, is
used within the tables to deal with particularly large or small numbers. For example, the value 0.000011 can
-------
be written as 1.1E-05 or 1.1 x 10-5.
Data from sediment sampling were not quantitatively evaluated for human risk assessment purposes since
exposure to sediments by human receptors is unlikely to occur at a frequency that would pose a significant
risk.
Surface water was not investigated as part of the Remedial Investigation; however, NPDES monitoring was
performed by AWI at Outfalls 001 through 003. Surface water was not quantitatively evaluated for human risk
assessment purposes since exposure to surface water by human receptors is unlikely to occur at a frequency
that would pose a significant risk.
B. Exposure Assessment
There are three basic steps involved in an exposure assessment: 1) identifying the potentially exposed
populations, both current and future, 2) determining the pathways by which these populations could be
exposed, and 3) quantifying the exposure. Under current Site conditions, the populations that could
potentially be exposed to contaminants in soil and sediment are current on-site workers, future on-site
workers, and off-site individuals on adjacent properties. Ground water users are also potentially exposed,
although ground water at the Site is not expected to be used for residential consumption purposes. According
to the Remedial Investigation, the City of Portsmouth requires all new residences to use city sewerage, and
any residence on the city sewer system must use city water. Note, potential ground water remediation will be
handled by a ROD for a subsequent operable unit, and is not addressed in this ROD.
The potential pathways for current exposure include: 1) incidental ingestion of soils (usually
resulting from placing hands or objects contaminated with soil into the mouth), 2) dermal contact with the
soils, and 3) inhalation (i.e. breathing) of fugitive dust.
EPA does not believe that residential development is a potential future use of the Site. The land use
currently on and within the vicinity of the Site is industrial, and thus, an industrial use scenario was used
in assessing risk. According to City records, the actual zoning designation at the Site is M2 -
Heavy Industrial.
-------
Table 2-5: Reasonable Maximum Exposure Point Concentrations
WOOD TREATMENT AREA EAST (AREA 1)
Surface Soil
Contaminants
Arsenic
Copper
Zinc
Benzene
Toluene
Ethylbenzene
Styrene
Xylenes
2-Methylnaphthalene
Dibenzofuran
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fiuoranthene
Benzo(g,h,i)perylene
Benzo (k)fIuoranthene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Subsurface Soil
Ingestion/
Dermal
Contact
(mg/kg)
36
184
458
n/a
n/a
n/a
n/a
n/a
49
72
114
10
280
167
83
1716
26
154
2058
9
733
Inhalation of
(mg/m3)
via Wind
Erosion
3.6E-07
1.9E-06
4.6E-06
n/a
n/a
n/a
n/a
n/a
5.0E-07
7.3E-07
1.2E-06
l.OE-07
2.8E-06
1.7E-06
8.4E-07
1.7E-06
2.6E-07
1.6E-06
2.1E-06
8.7E-08
7.4E-6
Dust
via
Construction
Activities
4.1 E-e6
2.1 E-e5
5.2E-05
n/a
n/a
n/a
n/a
n/a
5.6E-06
8.3E-06
1.3E-05
1.2E-06
3.2E-05
1.9E-05
9.5E-06
1.9E-05
3.0E-06
1.8E-05
2.3E-05
9.8E-07
8.4E-05
Ingestion/
Dermal
Contact
(mg/kg)
445
715
2, 670
0.140
0.2.04
0.243
0.173
1.005
220
484
707
20
2,710
391
156
228
60
205
505
22
2,631
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
5.1E-05
8.2E-05
3.0E-04
1.6E-08
2.3E-08
2.8E-08
2.0E-08
1.1E-07
2.5E-05
5.5E-05
8.1E-05
2.3E-06
3.1E-04
4.5E-05
1.8E-05
2.8E-05
6.8E-06
2.3E-05
5.8E-05
2.5E-06
3.0E-04
-------
Table 2-5: Reasonable Maximum Exposure Point Concentrations
WOOD TREATMENT AREA EAST (AREA 1)
Surface Soil
Contaminants
Fluorene
Indeno(1,2,3-cd) pyrene
Naphthalene
Phenanthrene
Pyrene
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol
2,4-Dimethyphenol
2-Methylphenol
4-Methylphenol
Subsurface Soil
Ingestion/
Dermal
Contact
(mg/kg)
136
27
150
432
456
10
6
n/a
n/a
n/a
n/a
Inhalation of
(mg/m3)
via Wind
Erosion
1.4E-06
2.7E-07
1.5E-06
4.4E-06
4.8E-06
1.1E-07
5.9E-08
n/a
n/a
n/a
n/a
Dust
via
Construction
Activities
1.5E-05
3.0E-06
1.7E-05
4.9E-05
5.2E-05
1.2E-06
1.2E-06
n/a
n/a
n/a
n/a
Ingestion/
Dermal
Contact
(mg/kg)
1,101
68
233
3,766
1,603
53
14
n/a
11
10
9
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
1.3E-04
7.7E-06
2.7E-05
4.3E-04
1.8E-04
6.1E-06
1.6E-06
n/a
1.2E-06
1.1E-06
l.OE-06
-------
Table 2-6: Reasonable Maximum Exposure Point Concentrations
WOOD TREATMENT AREA EAST (AREA 2)
Surface Soil
Contaminants
Arsenic
Copper
Subsurface Soil
Ingestion/
Dermal
Contact
(mg/kg)
93
313
Inhalation of
(mg/m3)
via Wind
Erosion
n/a
n/a
Dust
via
Construction
Activities
1.1E-05
3.6E-05
Ingestion/
Dermal
Contact
(mg/kg)
n/a
n/a
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
n/a
n/a
Table 2-6: Reasonable Maximum Exposure Point Concentrations
WOOD TREATMENT AREA EAST (AREA 2)
Surface Soil
Contaminants
Zinc
Benzene
Toluene
Ethylbenzene
Styrene
Xylenes
2-Methylnaphthalene
Dibenzofuran
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo (a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
Naphthalene
Subsurface Soil
Ingestion/
Dermal
Contact
(mg/kg)
947
n/a
n/a
n/a
n/a
n/a
1.2
1.9
1.8
3.8
14.9
23.4
27.5
66.6
14.9
66.6
35.8
6.0
58.1
2.8
15.5
1.8
Inhalation of
(mg/m3)
via Wind
Erosion
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Dust
via
Construction
Activities
1.1E-04
n/a
n/a
n/a
n/a
n/a
1.4E-07
2.2E-07
2.1E-07
4.4E-07
1.7E-06
2.7E-06
3.1E-06
7.6E-06
1.7E-06
7.8E-06
4.1E-06
8.8E-07
6.8E-06
3.0E-07
1.8E-06
2.1E-07
Ingestion/
Dermal
Contact
(mg/kg)
1,452
n/a
0.002
0.003
0.005
0.030
359
602
802
10
434
182
57
141
15
137
233
5
1,259
802
16
507
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
1.7E-04
0.0
2.3E-10
3.4E-10
5.7E-10
3.4E-09
4.1E-05
8.9E-05
9.1E-05
1.1E-06
5.0E-05
2.1E-05
6.5E-06
1.6E-05
1.8E-06
1.6E-05
2.7E-05
6.2E-07
1.4E-04
9.1E-05
1.8E-06
5.8E-05
-------
Table 2-6: Reasonable Maximum Exposure Point Concentrations
WOOD TREATMENT AREA EAST (AREA 2)
Contaminants
Phenanthrene
Pyrene
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol
2,4-Dimethyphenol
2-Methylphenol
4-Methylphenol
Surface Soil
Subsurface Soil
Ingestion/
Dermal
Contact
(mg/kg)
12.5
63.6
60.8
n/a
n/a
n/a
n/a
n/a
Inhalation of
(mg/m3)
via Wind
Erosion
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Dust
via
Construction
Activities
1.4E-06
7.2E-06
6.9E-06
n/a
n/a
n/a
n/a
n/a
Ingestion/
Dermal
Contact
(mg/kg)
2,359
1,057
23
2
n/a
7
2
3
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
2.7E-04
1.2E-04
2.6E-06
1.9E-07
n/a
8.2E-07
2.5E-07
3.8E-07
Table 2-7: Reasonable Maximum Exposure Point Concentrations
HISTORIC DISPOSAL AREA (AREA 3)
Contaminants
Arsenic
Copper
Zinc
Benzene
Ingestion/
Dermal
Contact
(mg/kg)
n/a
n/a
577
0.015
Surface Soil
Inhalation of Dust
(mg/m3)
Subsurface Soil
via Wind
Erosion
n/a
n/a
n/a
n/a
via
Construction
Activities
0.0
0.0
6.6E-05
1.7E-09
Ingestion/
Dermal
Contact
(mg/kg)
n/a
n/a
209
0.009
Inhalation of
Dust
via
Construction
Activities
(mg/m3)
0.0
0.0
2.4E-05
l.OE-09
-------
Table 2-7: Reasonable Maximum Exposure Point Concentrations
HISTORIC DISPOSAL AREA (AREA 3)
Surface Soil
Contaminants
Toluene
Ethylbenzene
Styrene
Xylenes
2- Methylnaphthalene
Dibenzofuran
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fiuoranthene
Benzo(g,h,i)perylene
Benzo(k)fIuoranthene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
Naphthalene
Phenanthrene
Pyrene
Subsurface Soil
Ingestion/
Dermal
Contact
(mg/kg)
0.062
0.096
0.052
1.4
390
400
560
42
650
1804
110
110
28
99
190
10
890
490
30
610
1,400
560
Inhalation of
(mg/m3)
via Wind
Erosion
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Dust
via
Construction
Activities
7.1E-09
1.1E-08
5.9E-09
1.6E-07
4.4E-05
4.6E-05
6.4E-05
4.8E-06
7.4E-05
2.1E-05
1.3E-05
1.3E-05
3.0E-06
1.1E-05
2.2E-05
1.1E-06
l.OE-04
5.6E-05
3.4E-00
7.0E-05
1.6E-04
6.4E-05
Ingestion/
Dermal
Contact
(mg/kg)
0.061
0.047
0.004
0.045
15
14
13
0.8
7.7
8
3.8
5.8
2.5
5.2
1.1
0.58
37
20
2.9
18
49
29
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
7.01-09
5.4E-09
4.6E-10
5.2E-09
1.7E-06
1.6E-06
1.5E-06
9. IE-OS
8.8E-07
9.1E-07
4.3E-07
6.8E-07
2.9E-07
5.9E-07
1.3E-07
6.6E-08
4.2E-06
2.3E-06
3.3E-07
2.1E-06
5.6E-06
3.3E-06
-------
Table 2-7: Reasonable Maximum Exposure Point Concentrations
HISTORIC DISPOSAL AREA (AREA 3)
Surface Soil
Subsurface Soil
Contaminants
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol
2,4-Dimethyphenol
2-Methylphenol
4-Methylphenol
Ingestion/
Dermal
Contact
(mg/kg)
970
0.46
n/a
n/a
n/a
n/a
Inhalation of
(mg/m3)
via Wind
Erosion
n/a
n/a
n/a
n/a
n/a
n/a
Dust
via
Construction
Activities
1.1E-04
5.2E-08
n/a
n/a
n/a
n/a
Ingestion/
Dermal
Contact
(mg/kg)
43
2.8
n/a
2.8
2.6
2.8
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
4.9E-06
3.0E-07
n/a
3.0E-07
3.0E-07
3.0E-07
Table 2-8: Reasonable Maximum Exposure Point Concentrations
WOOD STORAGE AREA (AREA 4)
Contaminants
Arsenic
Copper
Zinc
Benzene
Toluene
Ethylbenzene
Styrene
Ingestion/
Dermal
Contact
(mg/kg)
183
528
775
0.03
0.097
0.08
0.085
Surface Soil
Inhalation of Dust
Subsurface Soil
(mg/m3)
via Wind
Erosion
1.8E-06
5.3E-06
7.8E-06
3.0E-10
9.8E-10
8.1E-10
8.8E-10
via
Construction
Activities
2.1E-05
8.0E-05
8.8E-05
3.4E-09
1.1E-08
9.1E-09
9.7E-09
Ingestion/
Dermal
Contact
(mg/kg)
34
535
424
n/a
0.004
n/a
n/a
Inhalation of
Dust
via
Construction
Activities
(mg/m3)
3.9E-06
8.1E-05
4.8E-05
0.0
4.3E-10
0.0
0.0
-------
Table 2-8: Reasonable Maximum Exposure Point Concentrations
WOOD STORAGE AREA (AREA 4)
Surface Soil
Subsurface Soil
Contaminants
Xylenes
2-Methylnaphthalene
Dibenzofuran
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fiuoranthene
Benzo(g,h,i)perylene
Benzo(k)fIuoranthene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
Naphthalene
Phenanthrene
Pyrene
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol
Ingestion/ Inhalation of Dust Ingestion/ Inhalation of
Dermal (mg/m3) Dermal Dust
Contact Contact via
(mg/kg) via Wind via (mg/kg) Construction
Erosion Construction Activities
0.65
36
56
32
2
177
70
53
65
18
68
71
6.0
185
119
20
33
259
128
61
2
n/a
6.6E-09
3.7E-07
5.7E-07
3.2E-07
2.3E-08
1.8E-68
7.1E-07
5.4E-07
6.5E-07
1.9E-07
6.8E-07
7.2E-07
6.4E-08
1.7E-06
1.2E-06
2.0E-07
3.4E-07
2.6E-06
1.3E-06
6.2E-07
1.8E-08
n/a
Activities
7.4E-08
4.1 E-68
6.4E-06
3.7E-06
2.6E-07
2.0E-05
8.0E-06
6.0E-06
7.4E-68
2.1E-06
7.7E-06
8.1E-06
7.2E-07
1.9E-05
1.4E-05
2.3E-06
3.8E-06
3.0E-05
1.5E-05
7.0E-68
2.1E-07
n/a
n/a
1
4
8
2
12
45
43
69
12
69
43
6
86
7
13
11
48
66
39
n/a
n/a
(mg/m3 )
0.0
9.2E-08
4.9E-07
9.0E-07
2.5E-07
1.3E-06
5.2E-06
4.9E-06
7.9E-06
1.3E-06
7.9E-06
4.9E-06
6.6E-07
9.8E.06
8.2E-07
1.5E-06
1.2E-07
5.5E-68
7.5E-06
4.5E-68
0.0
n/a
-------
Table 2-8: Reasonable Maximum Exposure Point Concentrations
WOOD STORAGE AREA (AREA 4)
Contaminants
2,4-Dimethyphenol
2-Methylphenol
4-Methylphenol
Surface Soil
Subsurface Soil
Ingestion/
Dermal
Contact
(mg/kg)
n/a
n/a
n/a
Inhalation of
(mg/m3)
via Wind
Erosion
n/a
n/a
n/a
Dust
via
Construction
Activities
n/a
n/a
n/a
Ingestion/
Dermal
Contact
(mg/kg)
n/a
n/a
n/a
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
0.0
0.0
0.0
Table 2-9: Reasonable Maximum Exposure Point Concentrations
WASTE LIME AREA (AREA 9)
Surface Soil
Subsurface Soil
Contaminants
Arsenic
Copper
Zinc
Benzene
Toluene
Ethylbenzene
Styrene
Xylenes
2-Methylnaphthalene
Ingestion/
Dermal
Contact
(mg/kg)
328
6,140
12,552
0.001
0.003
0.002
0.007
0.015
6
Inhalation of
(mg/m3)
via Wind
Erosion
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Dust
via
Construction
Activities
3.7E-05
7.0E-04
1.4E-03
1.1E-10
3.4E-10
2.3E-10
8.0E-10
1.7E-09
6.9E-07
Ingestion/
Dermal
Contact
(mg/kg)
43
1,259
1,675
0.004
0.015
0.004
0.008
0.021
38
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
4.9E-06
1.4E-04
1.9E-04
4.6E-10
1.7E-09
4.6E-10
9.1E-10
2.4E-09
4.3E-06
-------
Table 2-9: Reasonable Maximum Exposure Point Concentrations
WASTE LIME AREA (AREA 9)
Surface Soil
Subsurface Soil
Contaminants
Dibenzofuran
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fiuoranthene
Benzo(g,h,i)perylene
Benzo(k)fIuoranthene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
Indeno(1,2,3-cd)pyrene
Naphthalene
Phenanthrene
Pyrene
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol
2,4-Dimethyphenol
2-Methylphenol
Ingestion/
Dermal
Contact
(mg/kg)
18
29
7
95
283
290
553
107
555
276
45
664
24
132
10
322
387
10
7
n/a
n/a
n/a
Inhalation of
(mg/m3)
via Wind
Erosion
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Dust
via
Construction
Activities
2.0E-06
3.4E-06
8.2E-07
1.1E-05
3.2E-05
3.3E-05
6.3E-05
1.2E-05
8.3E-05
3.1E-05
5.1E-06
7.6E-05
2.8E-06
1.5E-05
1.2E-03
3.7E-05
4.4E-05
1.1E-06
8.1E-07
n/a
n/a
n/a
Ingestion/
Dermal
Contact
(mg/kg)
203
415
1
741
293
2,563
1,777
80
1,777
2,860
394
4,096
311
1,281
49
3,453
4,585
0.95
0.29
n/a
0.25
n/a
Inhalation of
Dust
via
Construction
Activities
(mg/m3 )
2.3E-05
4.7E-05
5.7E-08
8.4E-05
3.3E-05
2.9E-04
2.0E-04
9.1E-06
2.0E-04
3.3E-04
4.5E-05
4.7E-04
3.5E-05
1.5E-04
5.6E-06
3.9E-04
5.2E-04
1.1E-07
3.3E-08
n/a
2.9E-08
n/a
-------
Table 2-9: Reasonable Maximum Exposure Point Concentrations
WASTE LIME AREA (AREA 9)
Surface Soil Subsurface Soil
Contaminants
Ingestion/ Inhalation of Dust Ingestion/ Inhalation of
Dermal (mg/m3) Dermal Dust
Contact Contact via
(mg/kg) via Wind via (mg/kg) Construction
Erosion Construction Activities
Activities (mg/m3)
4-Methylphenol n/a n/a n/a 0.36 4.1E-08
Note: For all previous tables, ambient air concentrations are based on a total particulate PM10
concentration of 114 • g/m3 for construction activities, and 10.1 • g/m3 for wind erosion.
In order to guantify the potential exposure associated with each pathway, assumptions must be made with
respect to the various factors used in the calculations. Table 2-10 summarizes the values used in the
baseline risk assessment.
-------
Table 2-10: Reasonable Maximum Exposure Assessment Factors
Exposure Factors
Future
Construction
Worker
INGESTION EXPOSURE PATHWAY
Ingestion Rate:
Soil 100 mg/day
Exposure Frequency:
Soil 250 days/year
DERMAL CONTACT EXPOSURE PATHWAY
Skin Surface Area
Available for
Contact:
Soil
Soil to Skin
Adherence Factor
2,000 cm2
1.45 mg/cm2
Exposure Frequency:
Soil 250 days/year
INHALATION EXPOSURE PATHWAY
Inhalation Rate:
Soil Vapor 1.8 m3/hour
Exposure Time:
Soil Vapor 8 hour/day
Exposure Frequency:
Soil Vapor 250 days/year
EXPOSURE ASSESSMENT CONSTANTS
Exposure Duration 0.5 years
Body Weight 70 kg
Averaging Time:
Carcinogens 70 years
Noncarcinogens 0.5 years
On-site Worker Off-site
Individuals
(Adults)
100 mg/day n/a
250 days/year n/a
2,000 cm2
1.45 mg/cm2
1.8 m3/hour
hours/day
n/a
n/a
250 days/year 250 days/year
1.8 m3/hour
hours/day
250 days/year 250 days/year
25
70
70
25
years
kg
years
years
25
70
70
25
years
kg
years
years
-------
C. Toxicity Assessment
The purpose of the toxicity assessment is to weigh available evidence regarding the potential for
particular contaminants to cause adverse effects in exposed individuals. Where possible, the assessment
provides a guantitative estimate of the relationship between the extent of exposure to a contaminant and
the increased likelihood and/or severity of adverse effects.
A toxicity assessment for contaminants found at a Superfund site is generally accomplished in two steps:
1) hazard identification, and 2) dose-response assessment. Hazard identification is the process of
determining whether exposure to an agent can cause an increase in the incidence of a particular adverse
health effect (e.g., cancer or birth defects) and whether the adverse health effect is likely to occur in
humans. It involves characterizing the nature and strength of the evidence of causation.
Dose-response evaluation is the process of guantitatively evaluating the toxicity information and
characterizing the relationship between the dose of the contaminant administered or received and the
incidence of adverse health effects in the administered population. From this guantitative dose-response
relationship, toxicity values (e.g., reference doses and slope factors) are derived that can be used to
estimate the incidence or potential for adverse effects as a function of human exposure to the agent. These
toxicity values are used in the risk characterization step to estimate the likelihood of adverse
effects occurring in humans at different exposure levels. For the purpose of the risk assessment,
contaminants were classified into two groups: potential carcinogens and noncarcinogens. The risks posed by
these two types of compounds are assessed differently because noncarcinogens generally exhibit a threshold
dose below which no adverse effects occur, while no such threshold can be proven to exist for carcinogens.
As used here, the term carcinogen means any chemical for which there is sufficient evidence that exposure may
result in continuing uncontrolled cell division (cancer) in humans and/or animals.
Conversely, the term noncarcinoaen means any chemical for which the carcinogenic evidence is negative or
insufficient.
Slope factors have been developed by EPA' s Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic contaminants of concern. Slope factors,
which are expressed in units of (mg/kg/day)-1, are multiplied by the estimated intake of a potential
carcinogen, in mg/kg/day, to provide an upper-bound estimate of the excess lifetime cancer risk associated
with exposure at that intake level. The term "upper-bound" reflects the conservative estimate of the risks
calculated from the slope factor. Use of this approach makes underestimation of the actual cancer risk
highly unlikely. Slope factors are derived from the results of human epidemiological studies or chronic
animal bioassays to which animal-to-human extrapolation and uncertainty factors have been applied (e.g., to
account for the use of animal data to predict effects on humans). Slope factors used in the baseline risk
assessment are presented in Table 2-11.
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse health
effects from exposure to contaminants of concern exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg/day, are estimates of lifetime daily exposure levels for humans, including
sensitive individuals. Estimated intakes of contaminants of concern from human epidemiological studies or
animal studies to which uncertainty factors have been applied account for the use of animal data to predict
effects on humans. Reference doses used in the baseline risk assessment are presented in
Table 2-11.
-------
Chemical
Table 2-11 Slope Factors and Reference Doses
Slope Factors (mg/kg-day)-1 Reference Doses (mg/kg-day)
Oral Inhalation Class Oral Inhalation
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chrysene
Dibenzo(a,h)anthracene
Indeno(1,2,3-cd)pyrene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(g,h,i)perylene
Fluoroanthene
Fluorene
Naphthalene
Phenanthrene
Pyrene
1.67
11.5
1.61
0.759
0.051
12.8
2.67
ND
ND
ND
0.253
ND
ND
ND
ND
0.932
0.884
6.1
0.854
0.403
0.027
6.77
1.42
ND
ND
ND
0.134
ND
ND
ND
ND
0.494
B2
B2
B2
B2
B2
B2
B2
D
D
D
D
D
D
D
D
D
ND
ND
ND
ND
ND
ND
ND
0.06
0.004
0.3
0.004
0.04
0.04
0.004
0.004
0.03
ND
ND
ND
ND
ND
ND
ND
0.06
0.004
0.3
0.004
0.04
0.04
0.004
0.004
0.03
-------
Chemical
Table 2-11 Slope Factors and Reference Doses
Slope Factors (mg/kg-day)-1 Reference Doses (mg/kg-day)
Oral Inhalation Class Oral Inhalation
Pentachlorophenol 0.12 0.12 E2 0.03 0.03
Phenol ND ND D 0.6 0.6
2-Methylphenol ND ND C 0.05 0.05
4-Met~ylphenol ND ND C 0.05 0.05
2,4-Dimethylphenol ND ND - 0.02 0.02
2,4,6-Trichlorophenol 0.011 0.011 B2 ND ND
Benzene 0.029 0.029 A ND ND
Toluene ND ND D 0.2 0.57
Ethylbenzene ND ND D 0.1 0.1
Styrene 0.03 0.03 - 0.2 0.2
Xylenes (Total) ND ND D 2.0 0.4
2-Methylnaphthalene ND ND - ND ND
Dibenzofuran ND ND D ND ND
Arsenic 1.75 50.0 A 0.001 0.001
Chromium VI ND 41.0 A 0.005 0.00000571
Copper ND ND D 0.037 0.037
Zinc ND ND D 0.2 0.2
Key: ND - Not determined
Class = EPA Weight-Of-Evidence Class for Carcinogenicity
A Human Carcinogen - sufficient evidence from epidemiological studies to support a causal
association between exposure and
B Probable Human Carcinogen -
Bl ! At least limited evidence of carcinogenicity to humans from epidemiological studies
132 ! Usually a combination of sufficient evidence of carcinogenicity in animals and
inadeguate evidence of carcinogenicity in humans
C Possible Human Carcinogen - limited evidence of carcinogenicity in animals in the absence
of human data
D Not Classified - inadeguate evidence of carcinogenicity in animals
-------
D. Human Health Effects
The health effects of the Site contaminants that are most associated with the unacceptable risk levels
are summarized below. In most cases, the information in the summaries is drawn from the Public Health
Statement in the Agency for Toxic Substances and Disease Registry's (ATSDR) toxicological profile
for that particular chemical.
Polynuclear Aromatic Hydrocarbons (PAHs): PAHs are a group of chemicals that are formed by the incomplete
burning of coal, oil, gas, garbage, tobacco, or almost any other organic substance. Natural sources include
forest fires and volcanoes. Conseguently, PAHs occur naturally throughout the environment in the soil and
other environmental media. Reproductive effects have occurred in animals that were fed certain PAHs.
Long-term ingestion of PAHs in food has resulted in adverse effects on the liver and blood in mice. Those
effects may also occur in humans, but there is no experimental evidence to substantiate that adverse impacts
in humans have, in fact, occurred. No information is available from human studies to determine what
non-cancerous adverse health effects, if any, may result from exposure to specific levels of the individual
PAHs, although inhalation and skin exposures to mixtures containing PAHs have been associated with cancer in
humans. The levels and lengths of exposure to the individual PAHs that effect human health cannot be
determined from the human studies available. Therefore, evaluation of non-cancer adverse health effects that
may result from exposure is somewhat uncertain.
EPA classifies a small group of PAHs as B2 (probable) carcinogens. Benzo(a)pyrene is the most potent of the
carcinogenic PAHs. Several PAHs, those listed as present in surface soils at the Site, have caused cancer in
laboratory animals through ingestion, skin contact, and inhalation. Reports from human studies show that
individuals exposed to mixtures of other compounds and PAHs by breathing or through skin contact for a long
period of time can also develop cancer. Human exposure to the PAHs found in existing surface soils at the
Site may result in a moderately increased risk of developing cancer if personal protective equipment is not
used.
Pentachlorophenol (PCP) s The major target organs impacted by PCP for both humans and animals are the liver
and the kidney. The central nervous system and the immune system also appear to be affected by PCP exposure.
Absorption is predominantly through the skin and/or respiratory system, although ingestion is also possible.
People are generally exposed to technical grade PCP, which usually contains such toxic impurities as
polychlorinated dibenzo-p-dioxins and dibenzofurans. Animal studies with both technical and purified PCP
have demonstrated that many, but not all, of the toxic effects attributed to PCP are actually due to the
impurities.
EPA classifies PCP as a Class B2 (probable) carcinogen. An increased incidence of liver and spleen cancer
has been shown in laboratory animals exposed to large concentrations of PCP. Workers who are exposed daily to
PCP at the maximum levels detected on the Site may have a slightly increased risk of developing cancer if
personal protective equipment is not used.
Arsenic: Direct skin contact with arsenic compounds can cause mild-to-severe skin irritation. Because the
levels of arsenic that can cause skin irritations are not known, constant contact with the maximum detected
level of arsenic at the Site may result in some skin irritation in sensitive individuals. However, workers
are not likely to be in constant contact with maximum levels.
EPA has determined that arsenic is a Class A human carcinogen because enough human data are available to
indicate oral and inhalation exposures do cause cancer. Dermal exposure to arsenic has been shown to cause
cancer. Also, the National Toxicology Program has classified arsenic as known carcinogen through the oral
and inhalation routes. Workers exposed to the highest amount of arsenic detected on-site through incidental
ingestion and inhalation are at a moderately increased risk of developing cancer if personal protective
equipment is not used.
E. Risk Characterization
The risk characterization process integrates the toxicity and exposure assessments into a quantitative
expression of risk. For carcinogens, the exposure point concentrations and exposure factors discussed earlier
are mathematically combined to generate a chronic daily intake value that is averaged over a lifetime (i.e.,
70 years). This intake value is then multiplied by the toxicity value for the contaminant (i.e., the slope
factor) to generate the incremental probability of an individual developing
cancer over a life-time as a result of exposure to the contaminant. These probabilities are generally
expressed in scientific notation (e.g., 1x10-6, otherwise expressed as 1E-6). An excess lifetime cancer risk
of 1x10-6 indicates that, as a reasonable maximum estimate, an individual has a 1 in 1,000,000
-------
chance of developing cancer as a result of site-related exposure to a carcinogen over a 70-year lifetime
under the specific exposure conditions at the Site. The generally acceptable excess cancer risk range, as
defined by Section 300.430 (e) (2) (i) (A) (2) of the NCP, is between 1.0 x 10-4 to 1.0 x 10-6.
The potential for noncarcinogenic effects is evaluated by comparing an exposure level over a specified
time period (i.e., the chronic daily intake) with the toxicity of the contaminant for a similar time period
(i.e., the reference dose). The ratio of exposure to toxicity is called the hazard quotient. A Hazard Index
(HI) is generated by adding the appropriate hazard guotients for contaminants to which a given population may
reasonably be exposed. Any media with an HI greater than 1.0 has the potential to adversely affect health.
The baseline risk assessment estimates the reasonable maximum total lifetime cancer risks for current
on-site workers to range from 4.5 x 10-3 to 5.1 x 10-4 in the evaluated areas of the Site, and 4.6 x 10-4 for
future on-site workers in the Waste Lime Area of the Site. These risks exceed the acceptable risk
range of 1 x 10-4 to 1 x 10-6 established in Section 300.430 (e) (2) (i) (A) of the NCP. Table 2-12 summarizes
the baseline risk assessment calculations for carcinogenic risk to individuals who would experience a
reasonable maximum exposure to Site contaminants.
The baseline risk assessment estimates the hazard index for noncarcinogenic effects for on-site workers
to be 1.22 in the historic disposal area, and 1.88, 1.04, 1.93 for future on-site workers in the wood
treatment east, wood treatment west, and waste lime area of the Site respectively. These risks exceed 1.0,
which is the acceptable hazard index level. Table 2-13 summarizes the hazard indices for noncarcinogenic
risk to individuals who would experience a reasonable maximum exposure to Site contaminants.
Exposure
Scenario
on-site
workers
Exposure
Media
surface
soils
Table 2-12: Summary of Carcinogenic Risks
Potential Risks by Area
Wood
Waste
Treatment Lime
Area West Area
Historic Wood Wood
Disposal Storage Treatment
Area Area Area East
Area
5.1x10-4 4.5x10-3 1.9x10-3 8.5x10-4 1.6x10-3
Predominant
Exposure
Pathway
Dermal
Contact
air via 2.3x10-7 1.8x10-5 4.4x10-5 3.9x10-7 9.1x10-7
construction
activities
Inhalation
future surface & 2.9x10-5 4.6X10-4 2.5x10-5 1.9x10-5 6.6x10-5 Dermal
workers subsurface Contact
soils
off-site air via wind n/a
workers erosion
n/a
n/a
2.8x10-5
1.1x10-6
Inhalation
air via 2.3x10-7 1.8x10-6 4.4x10-3 3.9x10-7
construction
activities
9.1x10-7
Inhalation
-------
Table 2-13: Summary of Hazard Indices (Noncarcinogenic Risks)
Exposure
Scenario
on-site
workers
Exposure
Media
surface
soils
Wood
Waste
Treatment Lime
Area West Area
0.09
0.57
Hazard Indices by Area
Historic Wood
Disposal Storage
Area
1.22
Area
0.29
Wood
Treatment
Area East
0.40
Predominant
Exposure
Pathway
Dermal
Contact
air via
construction
activities
0.029
0.260
0.003
0.031
0.055
Inhalation
future
workers
surface &
subsurface
soils
1.04
1.93
0.76
0.28
l.i
Dermal
Contact
off-site air via wind n/a
workers erosion
n/a
n/a
0.004
0.004
Inhalation
air via 0.029
construction
activities
0.260
0.003
0.031
0.055
Inhalation
VII. SUMMARY OF SITE ECOLOGICAL RISKS
A guantitative analysis of the potential environmental impacts was not performed during the Remedial
Investigation of the Site. Using gualitative information, the National Oceanic and Atmospheric
Administration (NOAA) , through an agreement with EPA, prepared an Ecological Risk Assessment, dated April
1992, for the Site. The primary objective of this assessment was to determine whether contaminants released
to the environment at the Site have impacted aguatic and terrestrial habitats. The impact of Site
contaminants on the two habitats is summarized below:
Aguatic Habitats: The primary contaminants for this habitat
are PAHs, PCP, and dioxin/furans, arsenic, copper, and zinc.
The South Branch of the Elizabeth River, located immediately
adjacent to the Site, is of particular concern since it has
received contamination through direct releases of creosote
to the river. Since contamination is present in soil,
ground water, and sediment, there is the continued potential
for Site-related contaminants to be transported to the river
and other nearby areas through surface water runoff, ground
water discharge, and fugitive dust from wind erosion.
Since many of the contaminants at the Site adsorb to
sediments, benthic (bottom feeding or dwelling) organisms
that have freguent contact with sediments will be most at
risk. These include benthic fish and invertebrates as well
as those species that feed on benthic prey such as blue
crab, weakfish, spot, and croaker. Given the levels of
contamination, many biological organisms that live near the
Site may be at potential risk.
Terrestrial Habitats: The Ecological Risk Assessment found
that animal, bird, and amphibian (e.g. frog) species on-site
are at risk. Animal species could suffer short- and long-
term effects from eating soil contaminated with PAHs, PCP,
dioxin/furans, and arsenic. Concentrations of copper and
zinc are high enough so that animals could suffer long-term
effects from continued exposure to these substances.
-------
Bird species could potentially suffer both short- and long-
term effects from exposures to the soil contaminated with
PCP, PAHs, dioxin/furans, and arsenic. No data were
available at the time of the Remedial Investigation
describing the toxicity of copper and zinc to bird species,
so the risk associated with these substances was not evaluated.
Amphibian species could experience both short- and long-term
effects from exposure to PAHs. No data were found
describing the toxicity of the other contaminants to either
amphibians or reptiles, so the risk to these species
associated with exposure to the other chemicals will not be
addressed.
Waterfowl are considered the predominant users of the areas near or on the Site. Common species are
dabblers, black duck, mallard, and ruddy duck. Wading birds include great blue heron, black-crowned night
heron, yellow-crowned night heron, clapper rail, snowy and great egret. Blue crab, eastern oysters, and
numerous anadromous, catadromous, and estuarine fish species also occur near the Site. Muskrat, raccoon,
opossum, meadow vole, marsh rabbit, and Norway rat are likely to live near or on the Site along with various
reptile and amphibian species.
The contaminants of primary ecological concern at the Atlantic Wood Site are the PAHs agsociated with
creosote, PCF, PCDDs and PCDFs, arsenic, copper, and zinc. Substantial data demonstrate that PAHs are
persistent compounds that can accumulate to high levels in many invertebrate organisms and are toxic to most
species at low concentrations. PCP and the associated chlorinated dioxins and furans also have been shown to
be toxic to most biological species. Because creosote (PAHs), PCP, PCDDs, and certain metals are all known
to be acutely toxic to aguatic and terrestrial species and because most of the toxicologic information
available describes acute toxicity, mortality was the primary endpoint of concern in the risk
assessment.
PGP's primary mode of action is the cellular uncoupling of oxidative phosphorylation (Ecobichon, 1991)1.
In aguatic organisms, this leads to a reduction in the availability of energy needed for maintenance and
growth, and thereby reduces their survival (Eisler, 1989)2. Adverse effects on growth,
survival, and reproduction have been demonstrated in algae and macrophytes; mollusc; and fishes at 7.5 to 80
ppb; 2.5 to 100 ppb; and less than 1.0 to 68 ppb, respectively. The American oyster (Crassostrea viginica),
is very sensitive to the effects of PCP, and abnormal development in 50% larvae was shown
following exposure to 40 ppb PCP. Adverse effects have been demonstrated in birds fed on a 1 ppm PCP diet.
Terrestrial plants and soil invertebrates were adversely affected at 0.3 ppm (Eisler 1989).
In performing the aguatic exposure assessment for the Atlantic Wood Site, uncertainties arose from two
main sources. First, those uncertainties associated with the distribution, import, and fate of compounds in
the environment. Second, those uncertainties associated in the estimated chemical intakes
resulting from contact by a receptor with a particular medium.
Without an ecological site-specific guantitative risk assessment, toxicity to ecological receptors
provided by literature values (ER-M)3 was evaluated to determine the potential need to cleanup Site
sediments. These values were also used in evaluating the need to clean up Site soils since most of
the Site is within the 100-year flood plain (Figure 2-9). The literature values from Long and MacDonald
(1992)4 and Long and Morgan (1990)5 which were used to evaluate the potential risk to ecological receptors
are presented below.
Compound ER-M
total PAH 44.79 ppm
pentachlorophenol 0.360 ppm6
arsenic 70 ppm
copper 270 ppm
zinc 410 ppm
1 Ecobichon, D.J. 1991. Toxic effects of Pesticides. In Casarett and Doull's Toxicology. (Eds.
M.O. Amdur, J. Doull, C.D. Klaassen) Pergamon Press, Inc. NY.
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2 Eisler, R. 1989. Pentachlorophenol hazards to fish, wildlife, and invertebrates: a synoptic
review. U.S. Fish and Wildlife Service. Biological Report No. 85(1.7), April 1989
3 The Effects Range-Median (ER-M) value for a specific contaminant is the median concentration, or
50th percentile, from a range of sediment concentrations determined by bioassessment studies to
cause adverse environmental impact.
4 Long, E.R. and D.D. MacDonald. 1992. National Status and Trends Program Approach. In: Sediment
Classification Methods Compendium. EPA 823-R-92-006. EPA office of Water (WH-556).
Washington, B.C.
5 Long and Morgan, E.R. and L.G. Morgan. 1990. The Potential for Biological Effects of
Sediment-sorbed Contaminants Tested in the National Status and Trends Program. NOAA Technical
Memo NOS OMA 52. Seattle WA. National Oceanic and Atmospheric Administration.
6 There is no ER-M value for this compound. The value listed is the lowest among the 4 apparent
effects threshold (AET) tests.
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VIII. DESCRIPTION OF ALTERNATIVE B
The Feasibility Study (FS) Report for the Site, dated April 1995, was prepared by a consultant hired by
AWI. EPA, in consultation with VDEQ, reviewed the FS Report and approved it subject to certain technical
reservations that can be found in the Administrative Record for the Site. In the FS Report,
technologies applicable to remediating the contaminated media were screened according to their effectiveness
and implementability. Those technologies remaining after the screening process were then developed into
remedial alternatives. The specific remedial alternatives were developed utilizing
information and data from the FS Report. An independent set of alternatives was developed as part the FS for
each of the five Remedial Response Units (RRU) at the Site. The remedial alternatives were carried through a
detailed analysis in the FS for the purpose of providing comparative and evaluative information on the
alternatives.
Common Elements of All Alternatives:
All alternatives evaluated in the FS include monitoring of
ground water and DNAPL occurrence to track the migration and
persistence of the contaminants for a period of 30 years or
an alternate period selected by EPA in consultation with
VDEQ. If applicable, ground water monitoring for a new
on-site landfill would also be reguired. Institutional
controls, including restrictions on title, use, and access
would be placed on the Site. Title restrictions prohibit
residential/agricultural development and restrict the use of
ground water at the Site because an industrial-use scenario
was used to derive the cleanup levels. Long-term surface
water monitoring would also be included in accordance with
State and federal reguirements to monitor the guality of
surface water run-off at the Site and to monitor the
potential migration of contamination from the Site. Semi-
annual chemical and annual bioassay monitoring of on-site
sediments would be reguired for a minimum period of five
years to determine the effectiveness and durability of the
cleanupl. Alternatives that involve on-site landfilling
would also reguire that the Site title be modified and
recorded to indicate appropriate restrictions against the
disturbance or development of the impacted Site areas.
Several wetland areas were identified at the Site.
Excavation and backfilling operations that would impact
these areas would be conducted to be protective of wetlands.
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1 This monitoring would be required for any alternatives
that yield concentrations of PCP greater than 0.4 mg/kg in Site soils.
Common Elements of Excavation Alternatives:
For alternatives that involve excavation, certain impacted
soils are anticipated to be located beneath portions of the
wood-treating plant and associated railroad tracks. Limited
demolition of surface tanks, buildings, railroad tracks, and
associated piping may be required to gain access to the
impacted surface soils. Any existing piping associated with
the former tank storage yard along Elm Avenue would be
removed. The shaded portions of Figure 2-10 provide a
general estimate of the surface areas of the Site that are
expected to require excavation. Table 2-14 provides a
listing of the estimated physical characteristics of the
five remedial response units.
Contaminated soils would be excavated to a depth where
contamination is no longer present, but the excavation would
generally not extend beyond the water table which varies
from 1 to 10 feet below grade across the Site. Most of the
excavations would be expected to occur within the top three
feet of surface soils. The excavation areas would be
scattered throughout the Site. Due to the shallow depth and
limited size of the excavation areas, only standard
construction equipment, such as an excavator or backhoe,
would be required for excavating the soils or sediments.
Surface soils are not expected to contain excess amounts of
moisture. Surface water run-off would be diverted away from
the excavation areas, and appropriate erosion and sediment
control measures would be implemented. In the event of rain
or potential Site flooding during excavation, any partially
excavated areas would be covered to minimize water
infiltration.
Excavation can generate dust under dry and windy conditions.
Measures would be taken to prevent dispersion of the
materials during excavation and transportation. Controlled
amounts of water would be sprayed onto the soils and tarps
would be placed over the loaded trucks. If dust emission
problems persist despite implementation of these dust
controls, excavation would be suspended until conditions improve.
Common Elements of Treatment Alternatives:
For all alternatives that involve treatment, a bench-scale
and/or pilot-scale treatability study would be required prior
to implementation of the alternative to ensure that cleanup
levels can be obtained given Site-specific conditions.
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Unit
Remedial Response Unit One (RRU1)
Wood Treating Area East (Area 1)
Wood Treating Area West (Area 2)
Historical Disposal Area (Area 3)
Wood Storage Area (Area 4)
Remedial Responses Unit Two (RRU2)
Inlet Area (Area 5)
Storm Water Run-off Ditch (Area 6)
Western Ditch (Area 7)
Remedial Response Unit Four (RRU4)
Southeastern Ditch
Remedial Response Unit Five (RRU5)
Acetylene Sludge Area
TABLE 2-14
ATLANTIC WOOD INDUSTRIES INC., SITE
PHYSICAL CHARACTERISTICS OF REMEDIAL RESPONSE UNITS
Area
(sq. feet)
224,620
42,710
28,800
107,140
403,270
9,404
750
420
Depth Volume For
Interval Excavation
(feet) (cu. yards)
0-1 8,320
1 - 1.4 ! ! 3,264
0-1 1,580
1 - 1.4 !! 576
0-1 1,070
0-1 3,965
1 - 1.3! ! 1,365
20,140
0 - 1.5 523
0-1 25
0-1 16
Volume For Concenration Ranges
Treatment cPAHs PCP Arsenic
(cu. yards)
7,980
3,264
1,320
576
1,070
3,435
1,365
19,010
523
25
16
(ing/Kg)
BDL -
4 -
BDL -
14 -
21 -
BDL -
BDL -
3,260
6,384
328
1,418
729
1,703
1,170
171-7,650
26 -
34 -
- 80
175
(ing/Kg)
0.3 - 22
0.7 - 290
BDL - 120
1.5 42
25 - 970
0.1 - 290
0.06-170
BDL
7.2 - 12.0
1.5 - 25
(ing/Kg)
8-36
4 - 445
59 - 93
NA
NA
24 - 369
1 -89
NA
109-136
82 - 135
6710
42,620
0-1
0-1
1 - 1.5
250
1580
790
250
97 - 3,118
1580 6.41 - 6110
790 3.41 - 22,190
.42 - 5.7
0.130 - 21.5
0.270 - 0.950
31 - 364
4 - 495
1-43
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Unit
Remedial Response Unit One (RRU3)
TABLE 2-14 (Cont'd)
ATLANTIC WOOD INDUSTRIES INC., SITE
PHYSICAL CHARACTERISTICS OF REMEDIAL RESPONSE UNITS
Depth Volume For Volume For
Area Interval Excavation Treatment
(sq. feet) (feet) (cu. yards) (cu. yards)
Concenration Ranges
cPAHs PCP Arsenic
(mg/Kg) (mg/Kg) (mg/Kg)
Wood Treating Area DNAPL
Historical Disposal Area DNAPL
Western Area (MW-34 Area) DNAPL
East of Process Area DNAPL
Eastern Area (MW-117 Area) DNAPL
<20
<35
<6 !
<5 !
<20
! - Depth estimates based on available descriptions of original boring logs only.
! ! - Measured avernge depth to groundwater table.
BDL - Below detection limits.
NA - Not Analyzed.
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NOTE: The alternatives described below are not numbered to directly correspond with the alternatives
described in the Feasibility Study Report. Appendix C of this ROD provides a table which cross-references
the alternatives identified in this ROD with those found in the Feasibility Study.
Alternative 1 - No Action
Section 300.430 (e) (6) of the NCP requires that EPA consider a "No Action" alternative for every
Superfund site to establish a baseline or reference point against which each of the remedial action
alternatives are compared. This alternative leaves the Site undisturbed and all current and potential future
risks would remain. This alternative includes long-term ground water monitoring as well as chemical and
biological monitoring of sediments. Presented below are the estimated costs and
implementation times of the No Action Alternative for each remedial response unit:
Alternative 1 Remedial Response Unit
Estimate of:
12345
Capital Costs2 $ 0$ 0$ 0$ 0$ 0
Annual O&M Costs3 $ 27,550 $ 23,800 $ 27,500 $ 16,900 $ 27,500
to 112,900 to 86,600 to 86,600
Present Worth Costs4 $ 698,000 $ 368,000 $ 584,000 $ 260,000 $ 584,000
Time to Implement Immediate Immediate Immediate Immediate Immediate
Alternative 2 - Excavation and On-site Landfilling of Soil/Sediment
This alternative provides for the excavation of approximately 20,000 cubic yards of soil for RRU1 and
564 cubic yards of sediment for RRU2 followed by disposal in an on-site landfill. The soils and sediments
would be excavated using conventional earth-moving equipment and then transported to a new on-site
landfill that would be constructed to meet the substantive requirements of a RCRA Subtitle C landfill. For
purposes of determining cost and engineering estimates, this alternative assumes that soils and sediments
would not require treatment prior to disposal because appropriate Land Disposal Restrictions have not yet
been established for RCRA waste listings F032 and F034 wood-treating wastes. The estimated size of the
landfill would be about 200' x 240' and would include a bottom liner, low-permeability cap, and would be
protected from inundation or washout caused by local flooding. Clean soils would be placed
2 Estimated Capital Costs represent the present worth of all capital costs.
3 Estimated Annual Operation and Maintenance ("O&M") Costs represent the total present worth of
annual costs divided by the life of the project (generally 30 years). Ranges are provided if
annual costs would vary over time.
4 Estimated Present Worth Costs represent the present worth of all capital costs and the total
present worth of O&M costs for a project life of 30 years. Present worth analysis is used to
evaluate expenditures that occur over different time periods by discounting all future costs to a
common base year. This allows the cost of remedial action alternatives to be compared on the
basis of a single figure representing the amount of money that, if invested in the base year and
disbursed as needed, would be sufficient to cover all costs associated with the remedial action
over its planned life. The planned life of each alternative is generally 30 years.
into the excavated areas to restore them to the original grade. This alternative only applies to RRU1 and
RRU2. Estimated costs and implementation times are presented below:
Alternative 2 Remedial Response Unit
Estimate of:
1 2
Capital Costs $ 2,930,000 $ 412,000
Annual O&M Costs $ 47,100 $ 45,000
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to 132,400
Present Worth Costs $ 3,928,000 $ 1,104,000
Time to Implement 7 months 6 months
Alternative 3 - Excavation and Off-site Landfilling of Soil/Sediment
This alternative entails the removal of soil or sediment (approximately 20,000 cubic yards for RRU1, 564
cubic yards for RRU2, 250 cubic yards for RRU4, and 2,370 cubic yards for RRUS) and transporting it to an
off-site RCRA Subtitle C landfill for disposal. For purposes of determining costs and engineering
estimates, it is assumed that treatment of the soil/sediment is not reguired prior to placing it in the
off-site landfill because appropriate Land Disposal Restrictions have not yet been established for RCRA waste
listings F032 and F034 wood-treating wastes. Clean soils would be placed into the excavated areas to restore
them to original grades. This alternative applies to RRU1, RRU2, RRU4, and RRUS. Estimated costs and times
for implementation are presented below:
Alternative 3 Remedial Response Unit
Estimate of
1 245
Capital Costs $ 9,379,000 $ 291,000 $ 162,000 $1,403,000
Annual O&M Costs $ 31,900 $ 28,000 $ 15,600 $ 31,900
to 117,300
Present Worth Costs $ 9.654,000 $ 721,000 $ 402,000 $1,893,000
Time to Implement 4 months 2 months 2 months 1 year
Alternative 4 - Soil Capping
A low permeability surface cap constructed in accordance with the substantive reguirements of applicable
RCRA regulations would be installed to cover the impacted soil. This alternative only applies to RRUS (soils
in the waste lime area). The purpose of this cap would be to eliminate any direct contact with contaminated
soil and to keep surface water from draining through the impacted soils in this area. A cap of approximately
one acre in size would be reguired to cover the waste lime area. The capped area would then be fenced to
restrict access and would no longer be available for use.
Cap construction would include grading and compacting the surface soils, placing soil to establish
drainage from the area to be capped, and installing a low permeability barrier layer. The barrier layer
would consist of a synthetic membrane placed on a six-inch thick layer of clayey soil. The synthetic
membrane would be covered with a drainage layer, then a layer of filter fabric, and finally, a one-foot soil
cover. Erosion resistant stone would be placed along the edges of the cap as a flood protection
measure. Additionally, an erosion protection mat would be placed along the shoulder edge of the cap to
ensure establishment of the vegetative cover. The surface of the cap areas would be seeded and mulched to
establish a permanent erosion resistant vegetative cover. Estimated costs and implementation time are listed
below:
Alternative 4 Remedial Response
Estimate of: Unit 5
Capital Costs $ 383,400
Annual O&M Costs $ 81,900
Present Worth Costs $ 1,622,000
Time to Implement 1 year
Alternative 5 - In Situ Bioremediation of Soil
This alternative which applies to RRU1 provides for the treatment of contaminated soils in situ (in
place without excavation) using bioremediation with naturally occurring microorganisms. The treatment
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process would be performed in accordance with the substantive requirements of applicable Federal and State
regulations. Excavation or dredgingwould not be required. Bioremediation uses microorganisms such as yeast,
fungi and/or bacteria to break down hazardous substances into less toxic or nontoxic substances.
Microorganisms, just like humans, eat and digest organic substances for nutrition and energy. Certain
microorganisms can digest organic substances that are hazardous to humans. The organic contaminants at the
Site, such as PAHs and PCP, would degrade into harmless products consisting mainly of carbon dioxide and
water.
Approximately 20,000 cubic yards of soils in RRU1 would be treated in this alternative. The major
elements of this alternative include the construction of a nutrient application system to promote the
bioremediation process, installation of run-on/run-off controls, and periodic sampling, analysis, and
inspection. In addition, an on-site water treatment plant that meets the substantive requirements of the
NPDES program established pursuant to Section 402 of the Clean Water Act is planned to address possible
run-off from the in situ areas due to precipitation. This alternative would only apply to RRU1. Estimated
costs and implementation time are presented below:
Alternative 5 Remedial Response
Estimate of: Unit 1
Capital Costs $ 2,369,000
Annual O&M Costs $ 27,500 to
$185,100
Present Worth Costs $ 3,673,000
Time to Implement 10 years
Alternative 6 - Excavation and On-site Biological Slurry Treatment of Soil/sediment
This alternative involves excavation of impacted soil/sediment (approximately 20,000 cubic yards for
RRU1, and 564 cubic yards for RRU2), and biologically treating the excavated soil in an on-site biological
slurry reactor. Biological slurry remediation mixes excavated soils with water in a tank to create a slurry
which is then mechanically agitated. Appropriate nutrients are added and the levels of oxygen, pH, and
temperature are controlled to promote the bioremediation process. Organic contaminant levels would be
reduced as microorganisms would degrade the contaminants into less toxic or nontoxic substances such as
carbon dioxide and water. A water treatment plant, consisting of filtration, pumps and tanks, would be
constructed to handle the water from the biological slurry process and its effluent would be discharged in
accordance with applicable State and Federal requirements. Access restrictions would be applied during the
construction and implementation of this alternative.
Following treatment, the soil/sediment would be disposed of using one of the following options:
On-Site Landfill Option: The appropriately treated soil/sediment
would be placed in a new on-site landfill constructed to meet the
requirements of RCRA Subtitle D landfill. This landfill would
include a bottom liner, low-permeability cap, and would be
protected from local flooding. Clean soils would be placed into
the excavated areas to restore them to the original grade.
Off-Site Landfill Option: The appropriately treated soil/sediment
would be transported to an off-site RCRA-permitted landfill.
Clean soils would be placed into the excavated areas to restore
them to the original grade.
Backfilling Option: The appropriately treated soil/sediment would
be placed back into the general areas from which it was excavated
using conventional earth-moving equipment.
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Estimated costs and implementation times are presented below:
Off-Site landfill Option
RRU2
Alternative 6 On-Site landfill Option
Estimate of:
RRU1 RRU2
Capital Costs
Annual O&M
Costs
Present
Worth Costs
$5,276,000 $ 374,000
$ 46,300 $ 42,500
to 511,800
$7,747,000 $1,027,000
RRU1
$12,719,000
$ 33,800
to 436,800
$14,378,000
$ 588,000
$ 30,000
$ 1,049,000
Backfilling Option
RRU1 RRU2
$4,511,000 $ 343,000
$ 33,800 $ 30,000
to 429,300
$5,120,000 $ 804,000
Time to
Implement
3 years
1 year
3 years
1 year
3 years
1 year
Alternative 7 - Excavation and Engineered Land Treatment of Soil/sediment
This alternative involves excavation of impacted soil/sediment (approximately 20,000 cubic yards for
RRU1, and 564 cubic yards for RRU2), and biologically land-treating the excavated soil/sediment in a
treatment plot that would be constructed with a landfill-type liner system. On-site treatment in a plot
would be in compliance with Virginia Hazardous Waste Management Regulations § 10.11, and RCRA reguirements
defined in 40 C.F.R. 264, Subpart L, Waste piles. Generally, engineered land treatment is a bioremediation
process that is similar to biological slurry (Alternative 6) except that the method for
introducing the microorganisms to the organic contaminants involves a plot system rather than a tank.
For cost estimating purposes, it was assumed that about 4,000 cubic yards of contaminated soils would be
excavated at a time and placed in a 180' x 810' treatment plot. Actual specifications would be determined
during the remedial design. The excavation would be repeated until all contaminated soils were treated. The
soils would be tilled and aerobically treated for periods up to a year. Water and nutrients would be added
to promote the bioremediation process. Excavated areas would be backfilled with clean or appropriately
treated soils (i.e., soils that have been treated to achieve site-specific environmental and health-based
cleanup levels). Organic contaminant levels would be reduced as microorganisms would degrade the
contaminants into less toxic or nontoxic substances such as carbon dioxide and water. Site access would be
restricted during the construction and implementation of this alternative.
Treated soil/sediment would be disposed of using one of the options described previously under
Alternative 6. Estimated costs and implementation times are presented below:
Alternative 6
Estimate of:
On-Site landfill Option
Off-Site landfill Option
RRU1
RRU2
RRU1
RRU2
Backfilling Option
RRU1 RRU2
Capital Costs $3,441,000 $ 294,000 $10,500,000 $ 527,000 $2,442,000 $ 283,000
Annual O&M $ 46,300 $ 30,400 $ 33,800 $ 30,000 $ 33,800 $ 30,000
Costs to 281,200 to 45,400 to 202,700 to 45,000 to 276,800 to 45,000
Present $4,564,000 $ 789,000 $11,701,000 $1,016,000 $3,839,000 $ 772,000
Worth Costs
Time to
Implement
4 years
2 year
4 years
2 years
6 years
2 years
Alternative 8 - Excavation and On-site Incineration of Soil/Sediment
This alternative provides for the excavation of RRU1 soils and RRU2 sediments followed by treatment in a
mobile on-site incinerator, and disposal in an on-site landfill. Contaminated soil/sediment (approximately
20,000 cubic yards for RRU1 and 564 cubic yards for RRU2) would be excavated using conventional excavating
eguipment. Erosion and sediment control measures would be implemented during excavation. The contaminated
soils would be incinerated in a mobile on-site rotary kiln incinerator outfitted with appropriate air
abatement eguipment and operated in accordance with the substantive reguirements defined in Virginia
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Hazardous Waste Management Regulations § 10.15, and RCRA reguirements defined in 40 C.F.R. 264, Subpart 0,
Incinerators. Organic contaminants would be burned by heating the soils to a temperature of 1400° C. Waste
solids would be discharged directly from the kiln, while the off-gases would be discharged to a secondary
combustion unit where complete destruction of the organic contaminants would occur. Clean soils would be
placed into the excavated areas to restore them to original grades.
Following incineration, the ash would be disposed of using one of the options described under
Alternative 6. Estimated costs and implementation times are presented below:
Alternative 6 On-Site landfill Option Off-Site landfill Option
Estimate of:
RRU1 RRU2 RRU1 RRU2
Capital $17,355,000 $ 589,000 $21,977,000 $ 750,000
Costs
Annual O&M $ 46,300 $ 42,500 $ 33,800 $ 30,000
Costs to 131,600 to 119,100
Present $18,341,000 $1,251,000 $22,771,000 $1,211,000
Worth Costs
Time to 1 year 1 year 6 months 1 year
Implement
Backfilling Option
RRU1 RRU2
$15,957,000 $ 580,000
$ 33,800 $ 30,000
to 119,100
$18,822,000 $ 1,041,000
6 months 6 months
Alternative 9 - Excavation and On-site Low Temperature Thermal Desorption of Soil/Sediment
This alternative involves the excavation of contaminated soil/sediment (approximately 20,000 cubic yards
for RRU1 and 564 cubic yards for RRU2), and treating it through an on-site low temperature thermal desorption
system (LTTD) operated in accordance with the substantive reguirements of 40 C.F.R. 264 Subpart X, and VHWMR
§ 10.15, Miscellaneous Units. LTTD treats contaminated soil/sediment by heating it at relatively low
temperatures (200-1000°F) so t~at contaminants with low boiling points will vaporize (turn into gas) and,
conseguently, separate from the soil/sediment. The vaporized contaminants are then
collected and removed, typically by an air emissions treatment system. LTTD is a different treatment process
than incineration. LTTD uses heat to physically separate the contaminants from the soil/sediment. These
contaminants then reguire further treatment. Incineration uses heat to actually destroy the
contaminants.
The treated soil/sediment would be disposed of using one of the options described in Alternative 6.
Estimated costs and implementation times are presented below:
Alternative 6 On-Site landfill Option Off-Site landfill Option Backfilling Option
Estimate of:
RRU1 RRU2 RRU1 RRU2 RRU1 RRU2
Capital $ 7,787,000 $ 383,000 $13,058,000
Costs
Annual O&M $ 46,300 $ 42,500 $ 33,800
Costs to 131,600 to 119,100
Present $ 8,822,000 $1,038,000 $13,852,000
Worth Costs
Time to 1.5 years 1 year 8 months
Implement
$ 535,000 $ 7,018,000 $ 364,000
$ 30,000 $ 33,800 $ 30,000
to 119,100
$ 996,000 $ 7,294,000 $ 825,000
1 year 1 . 5 years 8 months
Alternative 10 - Excavation and Off-sits Incineration of Soil/Sediment
This alternative would involve the excavation of contaminated soil/sediment (approximately 20,000 cubic
yards from RRU1 and 564 cubic yards from RRU2), loading it into trucks, and hauling it to a RCRA-permitted
off-site incineration facility for destruction. Clean soils would be placed into the excavated areas to
restore them to original grades. Estimated costs and implementation times are presented below:
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Alternative 10 Remedial Response Unit
Estimate of:
1 2
Capital Costs $ 53,064,000 $ 1,590,000
Annual O&M Costs $ 31,900 $ 30,000
to 117,300
Present Worth Costs $ 53,829,000 $ 2,051,000
Time to Implement 4 months 4 months
Alternative 11 - Extracting DNAPL for Off-Site Reuse
This alternative would involve monitoring and removing DNAPL (e.g., creosote) in existing monitoring
wells and would also involve the installation of several new recovery wells in areas where DNAPL has been
demonstrated to significantly accumulate in wells. Permanent DNAPL recovery pumps would be used in the new
recovery wells. DNAPL would be periodically bailed or pumped from existing monitoring wells in areas where
DNAPL does not rapidly accumulate. Any water collected during DNAPL recovery, or any recovered DNAPL that
can not be reused/recycled, will be disposed of in accordance with applicable local, state, and
Federal regulations.
Prior to the actual implementation of this alternative, relative rates of DNAPL accumulation in Site
wells would be measured. For costing purposes, it has been assumed that seven new recovery wells will be
installed; three in the historic disposal area and four in the former process area. Additional wells may be
installed if determined to be necessary by EPA.
The two main areas where potentially recoverable DNAPL exists at levels below approximately six feet are
in the former process area (Area 1) and the historic disposal area (Area 3). All of the DNAPL cannot be
practically removed from the subsurface. Residual DNAPL at areas in which recovery is not possible will be
left behind, and will continue to dissolve in the future. Further study will be reguired to determine if
additional cleanup measures will be needed to address ground water contamination. These additional measures
would be documented in a subseguent Proposed Plan and Record of Decision. Estimated costs and implementation
time are presented below:
Alternative 11 Estimate of: Remedial Response Unit 3
Capital Costs $ 537,850
Annual O&M Costs $ 214,775
Present Worth Costs $ 2,196,000
Time to Implement 10+ years
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The remedial action alternatives described above were evaluated using the following criteria, as
reguired under the NCP, 40 C.F.R. 300.430(e) (9) (iii) :
Threshold Criteria: Statutory reguirements that each alternative must satisfy in order to be eligible for
selection
1) Overall Protection of Human Health and the Environment.
Evaluation of the ability of each alternative to provide
adeguate 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.
2) Compliance with Applicable or Relevant and Appropriate Reguirements (ARARs)
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Evaluation of the ability of each alternative to attain
applicable or relevant and appropriate requirements under
federal environmental laws and state environmental or
facility siting laws or provide grounds for invoking a
waiver established under CERCLA.
Primary Balancing Criteria: Technical criteria upon which the detailed analysis is primarily based.
3) Long-Term Effectiveness and Permanence
Evaluation of expected residual risk and the ability of each
alternative to maintain reliable protection of human health
and the environment over time after cleanup requirements
have been met.
4) 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.
5) Reduction of Toxicity, Mobility, or Volume through Treatment
Evaluation of the degree to which an alternative employs
treatment methods to reduce the toxicity, mobility, or
volume of hazardous substances at the Site.
6) Implementability
Evaluation of the technical and administrative feasibility
of each alternative, including the availability of materials
and services.
7) Cost
Section 121 of CERCLA, 42 U.S.C. § 9621, requires selection
of a cost-effective remedy that protects human health and
the environment and meets the other requirements of the
statute. Alternatives are compared using present worth
cost, which includes all capital costs and the operation and
maintenance cost incurred over the life of the project.
Capital costs include expenditures necessary to implement a
remedial action (e.g., construction costs). All costs
presented are estimates computed for comparison purposes only.
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.
8) State Acceptance
Assessment of technical and administrative issues and
concerns that the State may have regarding each alternative.
9) 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.
A. Overall Protection of Human Health and the Environment
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RRU1 (Soils) and RRU2 (Sediments) Each of the alternatives, with the exception of Alternative 1 (No Action),
provide protection of human health and the environment. The greatest overall protection would be provided
from alternatives that use incineration as the treatment process (Alternatives 8 and 10). The contaminant
destruction efficiency of incineration is about 99.9999 percent. Among the three disposal options for the
incineration ash, on-site or off-site landfilling would provide slightly greater protection than the backfill
option because the ash would be in a controlled unit.
The alternatives that provide the next highest level of protection include Alternative 5 (In Situ
Bioremediation), Alternative 6 (Excavation and Biological Slurry Treatment) Alternative 7 (Excavation and
Engineered Land Treatment), and Alternative 9 (Excavation and On-Site LTTD). These alternatives reduce the
contaminant concentrations through treatment and cause a significant reduction in the toxicity, mobility and
volume of Site contamination.
Alternative 2 (Excavation and On-Site Landfilling), Alternative 3 (Excavation and Off-Site Landfilling),
and Alternative 4 (Soil Capping) provide lower overall protection because these alternatives rely on
effective long-term operation and maintenance and institutional controls, rather than actual treatment, to
contain and isolate the contamination and prevent future exposure.
RRU3 (DNAPLs) Alternative 11 (Extracting DNAPL for Off-Site Reuse) provides for protection of human health
and the environment by removing a concentrated source of contamination and thereby reducing further migration
of the contamination into the ground water. Since not all of the DNAPL can be removed from
the subsurface, the residual DNAPL left behind will continue to dissolve into the ground water. By reducing
the amount of DNAPL present to dissolve into the ground water, the overall time reguired to control movement
of the contamination will be reduced.
Alternative 1 (No Action) contains no provision for reducing or eliminating the migration and potential
exposure to DNAPL contamination, and is not protective of human health and the environment.
RRU4 (Southeast Ditch Sediments) and RRU5 (Waste Lime Area Soils) Alternative 1 (No Action) would not provide
protection of human health and the environment. Alternative 3 (Excavation and Off-Site Landfilling) provides
adeguate overall protection. The treatment alternatives considered for soils and sediments may not be
effective for the Southeast Ditch sediments and Waste Lime Area soils because of elevated metal
concentrations and high pH. Off-site landfilling provides protection by containing and
isolating the contaminated soils and sediments to prevent future exposure.
Alternative 1 (No Action) will not be considered further in this analysis since it does not meet the
threshold criterion of providing protection to human health and the environment.
B. Compliance with ARARs
This criterion addresses whether a remedy wiii meet all of the applicable or relevant and appropriate
reguirements (ARARs) of federal and state environmental laws and/or provide grounds for invoking a waiver
under the NCP at 40 C.F.R. § 300.430(f)(1)(ii)(c). All alternatives that are protective of human health and
the environment would be in compliance with existing federal and state ARARs.
1. Excavation/Storage ARARs For alternatives reguiring excavation of soil (Alternatives 2, 3, 6, 7, 8, 9 &
10), limited demolition of surface tanks, portions of the wood-treating plant, railroad tracks, and
associated piping may be necessary. Any debris contaminated with a listed hazardous waste (40 C.F.R. Part
261, Subpart D) such as F032 or F034, or debris exhibiting a characteristic of hazardous waste (40 C.F.R.
261, Subpart C) would be managed in accordance with the land disposal restrictions at 40 C.F.R. Part 268,
and Part XV of the Virginia Hazardous Waste Management Regulations (VHWHR) (VR 672-10-00). Debris that does
not contain or exhibit characteristics of hazardous waste would be managed in accordance with Virginia Solid
Waste Management Regulations (VSWMR) (VR 672-20-10).
Excavated soil and sediment would be temporarily staged on-site in accordance with 40 C.F.R. Part
264, Subpart L, and VHWMR § 10.11, Waste Piles, prior to treatment and/or transportation to an off-site
disposal facility. To the extent practicable, excavated soil and sediment would be staged in areas of
existing contamination. Erosion and sediment control measures would be installed in accordance with the
substantive reguirements of the Virginia Erosion and Sediment Control Law (Code of Va. §§ 10.1-560 et seg.)
and the Virginia Erosion and Sediment Regulations (VR 625-02-00). These measures would be sufficient to
provide protection in the event of flooding in accordance with Executive Order 11988 (Flood Plain
Management). When final areas of contamination are being addressed, excavated soil and sediment may need to
be staged in an area where cleanup has previously occurred. In such instances, soil and sediment would be
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staged in containers in accordance with 40 C.F.R. Part 264, Subpart I and VHWMR § 10.8 Use and Management of
Containers , and 40 C.F.R. 268, Subpart E, Prohibitions on Storage.
Air monitoring for site-related contaminants would be performed in accordance with 40 C.F.R. Part
50, to ensure air emissions conform with the National Primary and Secondary Ambient Air Quality Standards.
Fugitive dust emissions would be controlled in accordance with Virginia Air Pollution Control Law (Code of
Va. § 10.1-1300 et seg.)and the Virginia Regulations for the Control and Abatement of Air Pollution (VR
120-01) .
2. Soil and Sediment Treatment/Disppsal ARARs The soil and sediment at the Site are primarily contaminated
with drippage from the wood treatment processes which used PCP and creosote. This drippage is a RCRA-listed
hazardous waste (F032 or F034) and, therefore, any excavated soil and sediment containing this waste is also
regulated as a hazardous waste. The Hazardous and Solid Waste Amendments of 1984 prohibited the land
disposal of untreated hazardous wastes. EPA has promulgated regulations (40 C.F.R. Part 268) that establish
the constituent concentrations that can be present in the waste in order to allow for land disposal. However,
for F032 and F034 wastes, such concentrations have not yet been set. Therefore, untreated soil and sediment
can currently be disposed of in a hazardous waste landfill that is permitted in accordance with RCRA Subtitle
C. Alternatives 2 and 3 would comply with this reguirement.
An EPA and VDEQ interpretation of the RCRA regulations, referred to as the "Contained-In Policy"
states that any mixture of environmental media (e.g., ground water, soil, sediment) and a RCRA listed
hazardous waste (e.g., F032, F034) is not a solid waste itself, but must be managed as if it were a hazardous
waste. Consistent with this approach, the Agency further interprets the RCRA Subtitle C regulations to
mean that environmental media contaminated with listed hazardous waste must be managed as if it were
hazardous waste until the media no longer contains the listed hazardous waste (i.e., until decontaminated).
Related to making a determination as to when contaminated media no longer contains listed hazardous waste, a
site-specific risk assessment approach has been used that addresses the public health and environmental
impacts of hazardous constituents remaining in the treated media. Media treated so that the concentration of
hazardous constituents is below a level which would result in an unacceptable risk to human health and the
environment would not contain hazardous waste and, therefore, will no longer be reguired to be managed as if
it were a hazardous waste (EPA OSWER Directive 9347.3-05FS). For alternatives that reguire treatment of soil
and sediment (Alternatives 5 through 10), the treatment processes would be expected to achieve the cleanup
levels set forth in Part II, Section X of this ROD. These cleanup levels have been derived from
site-specific information and would be protective of human health and the environment. Therefore, soil
and sediment treated to these cleanup levels would no longer have to be managed as hazardous waste. The
treated soil and sediment could be backfilled on-site or disposed in a landfill (either on- or off-site)
permitted in accordance with RCRA Subtitle D.
Any off-site disposal of hazardous substances would comply with CERCLA § 121(d)(3) which prohibits
the disposal of Superfund Site waste at a facility not in compliance with §§3004 and 3005 of RCRA, 40 C.F.R.
§ 300.440.
3. Other ARARs Alternative 4 does not involve excavation; therefore, the RCRA regulations are not
applicable, but are considered relevant and appropriate, for the design of the surface cap.
Under Alternatives 2, 3, 6, 7, 8, 9, and 10, any transportation of hazardous waste from the Site
would be performed in accordance with Part VII of VHWMR, and Virginia Regulations Governing the Transport of
Hazardous Materials (VR 672-30-1), and RCRA reguirements defined in 40 C.F.R. Parts 262 and 263, and 49
C.F.R. Parts 107, and 171-179.
For Alternatives 8 and 9, the on-site treatment units would be eguipped with air pollution control
eguipment that can meet federal and Virginia air emission standards and eliminate any unacceptable risks to
human health of the environment. Air emissions would be in compliance with National Ambient Air Quality
Standards (NAAQS) (40 C.F.R. Part 50), National Emissions Standards for Hazardous Air Pollutants (NESHAP) (40
C.F.R. Part 61), and Virginia Regulations for Control and Abatement of Air Pollution (VR 120-01).
For Alternative 6, the water from the biological slurry process would be treated on-site and
discharged in accordance with the substantive reguirements of the Virginia State Water Control Law (Code of
Va., §§ 62.1-44.2 et seg.) and the Virginia Pollution Discharge Elimination System regulations (VPDES) (VR
680-14-01) . Also, the on-site treatment of soils and sediments in tanks would be in compliance with VHWMR §
10.9, and RCRA reguirements defined in 40 C.F.R. 264, Subpart J, Tank Systems.
For Alternative 7, on-site treatment in a plot would be in compliance with Virginia Hazardous Waste
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Management Regulations § 10.11, and RCRA reguirements defined in 40 C.F.R. 264, Subpart L, Waste Piles.
For Alternative 10, soil and sediment would be transported to an off-site incinerator in compliance
with RCRA regulations for incinerators (40 C.F.R. 264, Part o).
For Alternative 11, any water collected during the DNAPL recovery or any recovered DNAPL that can
not be reused or recycled would be managed as a hazardous waste and transported off-site for treatment and/or
disposal at a permitted RCRA Subtitle C facility.
Chemical and biological monitoring would be reguired under all alternatives to monitor the impact
of surface water run-off from the Site and evaluate the effectiveness of the cleanups. The monitoring
reguirements would be developed in accordance with Virginia State Water Control Law (Code of Virginia §§
62.1-44.2 et seg.), VPDES regulations (VR 680-14-01), and 40 C.F.R. Part 141, Subparts
C and E.
Other ARARs that are associated with various alternatives include the Chesapeake Bay Preservation
Area Designation and Management Regulations (VR 173-02-01), Virginia Water Protection Permit Regulations (VR
680-15-01), the Coastal Zone Management Act (40 C.F.R. 930), and Virginia Wetlands Regulations (VR
450-1-0051) .
5 his monitoring would be reguired for any alternatives that yield concentrations of PCP greater than
0.4 mg/kg in Site soils.
C. Long-Term Effectiveness and Permanence
RRU1 (Soils) For those alternatives where the impacted soil would be excavated and treated, the long-term
effectiveness would be very high. The Site soils and sediments would be reguired to achieve the Site cleanup
levels. Alternatives 6, 7, and 9 involve non-incineration forms of treatment. Alternatives 8, and 10
include incineration which is the most effective technology for destroying the contaminants.
Alternative 5 (In Situ Bioremediation) could potentially reduce concentrations of contaminants to below
cleanup levels and, thus, could provide long-term protection of on-site workers and the environment.
However, significant residual concentrations of contaminants would remain on-site for the longest period of
time when compared to all the other alternatives except No Action.
For those alternatives that solely involve landfill disposal of the untreated soil (Alternatives 2 and
3), long-term effectiveness would rely on effective and continuing operation and maintenance of the landfill.
RRU3 (DNAPLs) Because the total volume of DNAPL beneath the site will be reduced as a result of implementing
Alternative 11, the amount of time over which DNAPL dissolution occurs will decrease.
Overall ground water guality should begin to improve in terms of chemical loading, as less DNAPL will be
available for dissolution.
RRU4 (Southeast Ditch Sediments) and RRU5 (Waste Lime Area Soils) Alternative 3 (Excavation and Off-Site
Landfilling) would provide long-term effectiveness by reguiring disposal at a RCRA-permitted off-site
landfill facility. The long-term effectiveness would rely on effective and continuing operation and
maintenance of the landfill facility. Alternative 4 (Surface Capping) was also considered for the Waste Lime
Area and would be effective over the long term provided that the integrity of the cap is maintained.
D. Short-Term Effectiveness
RRU1 (Soils) and RRU2 (Sediments) Alternative 4 (In Situ Bioremediation) would result in the least short-term
risks to workers because soil would not be excavated. The other alternatives, except No Action, all have
potential for some short-term risk because excavation of impacted soil/sediment is reguired. However, in all
cases, short-term risks would be minimized by conducting operations in accordance with acceptable health and
safety procedures. The overall potential short-term exposure risks to on-site workers would be minimal.
Alternatives 6 and 7 provide a similar level of short-term effectiveness in that cleanup may take three
to six years to complete. Cleanup under Alternatives 8, 9, and 10 would be accomplished in approximately 16
months. Additional short-term risks may be associated with those alternatives that call for off-site
transportation of untreated soil, such as Alternative 10 (Excavation and Off-Site Incineration) and
Alternative 3 (Excavation and Off-Site Landfilling) due to the risk resulting from a spill or accident during
transportation.
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RRU3 (DNAPLs) Alternative 11 has the potential to increase the risk to on-site workers during implementation
due to worker interaction with impacted materials; however, these risks would be minimized by use of proper
health and safety procedures. There may also be a slight risk of exposure to residents along the
transportation route in the event of a spill or accidental release. Every effort would be made to identify
measures that would minimize the chance of an accident or spill. In addition, contingency plans for
responding to such an event would be developed.
RRU4 (Southeast Ditch Sediments) and RRU5 (Waste Lime Area Soils) Alternative 3 reguires the excavation of
impacted sediments. The excavation process would potentially increase exposures to workers; however, in all
cases, risks would be minimized by conducting operations in accordance with acceptable health and
safety procedures. In addition to excavation, Alternative 3 reguires the transportation of tuntreated
soil/sediment to a landfill facility. The potential risk resulting from a spill or accident during
transportation is minimal. The soil/sediment could be readily contained if such an incident were to occur.
Alternative 4 (Surface Capping) of the Waste Lime Area would result in the least short-term risks
because soil would not be excavated.
E. Reduction of Toxicity, Mobility, or Volume through Treatment
RRU1 (Soils) and RRU2 (Sediments) Alternatives 2 and 3 would significantly reduce the mobility of the
contaminants on-site; however, this reduction is not achieved through treatment and would not likely result
in a permanent reduction of the toxicity and volume of contaminants except for the natural biodegradation
over time. Alternative 5 (In Situ Bioremediation) would eventually reduce the toxicity, mobility, and volume
of contaminants through biological treatment of the impacted soils.
Among the alternatives that provide treatment, Alternatives $ and 10 would achieve the greatest
reduction (over 99.9999 percent) of contaminant concentrations. The percent reduction expected from LTTD
(Alternative 9) is in excess of 95 percent for both carcinogenic PAHs and PCP. The percent reduction
expected from the Biological Slurry Treatment (Alternative 6) and Engineered Land Treatment (Alternative 7)
range from 85 percent to 95 percent within the projected time frame.
RRU3 (DNAPLs) Alternative 11 will reduce the toxicity and mobility of DNAPL at the Site by reducing the level
of saturation in the soil and by removing a portion of the mobile DNAPL in the impacted areas. The volume of
mobile DNAPL remaining in the subsurface will be reduced, leaving less to be eventually
dissolved.
RRU4 (Southeast Ditch Sediments) and RRU5 (Waste Lime Area Soils) Alternative 3 does not provide treatment of
the impacted material; thus, there would not be any reduction of toxicity or volume of the contaminants.
This alternative does contribute to reducing the mobility of the contaminants in the soil by placing the
soil/sediment in a secure off-site landfill. Alternative 4 (Soil Capping) for the Waste Lime Area does not
provide for treatment, but would reduce the mobility of contaminants by limiting surface water infiltration
into the impacted area.
F. Implementability
RRU1 (Soils) and RRU2 (Sediments) Alternatives 2 and 3 can be readily implemented. Conventional earth-moving
eguipment would be used for the excavation activities and construction of the on-site landfill in Alternative
2. Excavated material would be transported to an off-site landfill under Alternative 3.
Alternative 5 (In Situ Bioremediation) would reguire minimal excavation and construction compared with
the other alternatives. Eguipment and materials which would be reguired to implement this alternative are
readily obtainable. However, because of the shallow ground water table and hydraulic gradient at the Site, a
significant engineering effort is warranted to design an effective treatment system.
The treatment alternatives (5, 6, 7, 8, 9, and 10) would reguire bench-scale and/or pilot-scale studies,
as appropriate, prior to full-scale implementation. Alternative 6 (Biological Slurry Treatment) would
involve extensive materials handling. The backfilling and off-site landfilling disposal option for
treated soil/sediment would be relatively easy to implement. The on-site landfilling disposal option would
reguire additional construction activity, but could also be readily implemented.
RRU3 (DNAPLs) Alternative 11 would also be easily implemented because the eguipment and materials are
readily available and adeguately demonstrated for similar applications.
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RRU4 (Southeast Ditch Sediments) and RRU5 (Waste Lime Area Soils) Technically, Alternative 3 is easily
implementable. The excavation and landfill techniques are commonly practiced and could be implemented in a
relatively short period of time. Surface capping (Alternative 4) of the Waste Lime Area could also
be easily implemented. Earth-moving equipment is readily available and the area of the Site to be capped may
be easily accessed.
G. Cost: Effectiveness
RRU1, 2, 4, and 5 (DNAPL) The costs of the alternatives for RRU1, 2, 4, and 5 are shown in the table below.
(Note: For convenience, costs for the selected alternatives are shown in bolded print in the table below.)
Present Worth Cost for Soil/Sediment Remedial Response Units
Alternative
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Alternative 5
Alternative 6 with
On-Site Landfill
Alternative 6 with
Off-Site Landfill
Alternative 6 with
Backfilling
Alternative 7 with
On-Site landfill
Alternative 7 with
Off-Site Landfill
Alternative 7 with
Backfilling
Alternative 8 with
On-Site landfill
Alternative 8 with
Off-Site Landfill
Alternative 8 with
Backfilling
Alternative 9 with
On-Site Landfill
Alternative 9 with
Off-Site Landfill
Alternative 9 with
1
$698,000
$3,928,000
$9,654,000
n/a
$3,673,000
$7,747,000
$14,378,000
$6,120,000
$4,564,000
$11,701,000
$3,839,000
$18,341,000
$22,771,000
$16,822,000
$8,822,000
$13,852,000
$7,294,000
2
$366,000
$1,104,000
$721,000
n/a
n/a
$1,027,000
$1,049,000
$804,000
$789,000
$1,016,000
$772,000
$1,251,000
$1 211,000
$1,041,000
$1,036,000
$996,000
$825,000
4
$260,000
n/a
$402,000
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
5
$584,000
n/a
$1,893,000
$1,622,000
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
Backfilling
Alternative 10 $53,829,000 $2,051,000 n/a n/a
RRU3 (DNAPL) The No Action alternative present worth cost is $584,000. Alternative 11 (Extracting DNAPL for
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Off-site Reuse) has a present worth cost of $2,196,000.
H. State Acceptance
VDEQ has had the opportunity to review and comment on all the documents in the Administrative Record and
has had the opportunity to comment on the draft ROD. The Commonwealth has not concurred with this ROD;
however, the Commonwealth's comments have been incorporated into this ROD.
I. Community Acceptance
The community has not indicated objections to the alternatives selected in this Record of Decision.
Atlantic Wood Industries, Inc., has, however, stated opposition to some components of the chosen
alternatives. Oral and written comments on the remedial alternatives evaluated by EPA for implementation
at the Site are included in Part III of this ROD.
X. SELECTED REMEDY AND PERFORMANCE STANDARDS
Based upon consideration of the requirements of CERCLA, the detailed analysis of the alternatives
presented in the Proposed Remedial Action Plan using the nine criteria, and public comments, EPA has selected
Alternative 7 (Engineered Land Treatment) with a contingency of Alternative 9 (Low Temperature
Thermal Desorption) as the remedy for RRU1 (soil) and RRU2 (sediment); Alternative 11 (DNAPL Extraction for
Off-Site Use) for RRU3; and Alternative 3 (Off-Site Landfilling) for RRU4 (Southeast Ditch Sediments) and
RRU5 (Waste Lime Area). The major components of the remedy include:
! Excavation of an estimated 20,000 cubic yards of soil
(RRU1) and 564 cubic yards of sediment (RRU2)6,
treatment of soil/sediment biologically using the
engineered land treatment process in order to achieve
the cleanup levels in Table 2-15 of this ROD, and
backfilling of appropriately treated soil/sediment on-site;
! A contingency treatment process using on-site low
temperature thermal desorption if treatability studies
conducted during the remedial design indicate that
biological treatment will not be effective in achieving
the Site cleanup levels listed in Table 2-15 of this ROD;
! Excavation of an estimated 250 cubic yards of sediment
(RRU4) and 2,370 cubic yards of soil (RRUS) in order to
achieve the cleanup levels in Table 2-15 of this ROD,
and disposal off-site in a RCRA-permitted Subtitle C landfill;
! Recovery of DNAPL from new and existing wells for off-
site reuse or disposal;
! Monitoring and institutional controls.
Table 2-15 immediately below sets forth the clean-up levels for RRU1, RRU2, RRU4, and RRUS.
6 The majority of contaminated sediment from the inlet portion of RRU2 have already Been removed ag Dart
of a ramOval action conducted at the Site in May of 1995. The excavated sediment is being stored on-site
awaiting treatment during the remedial action. Therefore, the amount of sediment to actually
excavate during the remedial action should be lower.
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Table 2-15: Performance Standards: Soil and Sediment Cleanup Levels?
(ppm)
Soils by Area: Total Dioxin/
BaPEqS PAH PCP Arsenic Copper Zinc Furans
RRUl-Area 1 11 100 3 150 390 410 0.001
Wood Treating East
RRUl-Area 2 10 100 2 76 390 410 0.001
Wood Treating West
RRUl-Area 3 8 100 3 150 390 410 0.001
Historic Disposal
RRUl-Area 4 8 100 3 131 390 410 0.001
Wood Storage Yard
RRU5-Area 9 8 100 3 150 390 410 0.001
Waste Lime Area
Sediments by Area: n/a 25 0.4 85 390 270 0.001
RRU2-Arees 5, 6, 7
RRU4-Area 8
(All Sediment arees)
The specific elements of the remedy and the associated performance standards are presented below.
A. Treatability Study/Contingent Trigger
1. An on-site pilot-scale treatability study using engineered land treatment shall be conducted in general
accordance with EPA/540/R-93/519a, August 1993, Guide for Conductina Treatability Studies Under CERCLA:
Biodegradation Remedy Selection.
2. A detailed Treatability Study Work Plan to test the effectiveness of the engineered land treatment
methods shall be approved by SPA prior to commencing the study. The Work Plan shall include, at a minimum, a
study description, testing goals, sampling and analysis methods, guality assurance/control methods, treatment
level derivations that support achieving the Table 2-15 cleanup levels for respective Site areas, and an
expeditious schedule for the study.
7 Cleanup concentrations are arithmetic means. Compliance will be determined in accordance with
Section X.B.8 of this ROD. Cleanup levels are based on the more conservative of the 1 x 10-5
target risk level for human health, or ecological literature values adjusted to accommodate
site-specific characteristics.
8 BaPEg stands for benzo[a]pyrene eguivalents. Benzo[a]pyrene is a specific compound in PAH and is
used as a surrogate to define PAH cleanup.
3. Pilot-scale studies performed shall clearly demonstrate the technical feasibility of engineered land
treatment in achieving the cleanup levels listed in Table 2-15 within a reasonable period of time (i.e.
approximately 12 months per lift).9 If EPA determines that the pilot-scale studies demonstrate the technical
feasibility of engineered land treatment, this technology shall be implemented in accordance with Section
X.C.
4. If EPA determines that engineered land treatment is not technically feasible based on the pilot-scale
studies, low temperature thermal desorption shall be triggered as the treatment technology to be implemented
for RRU1 and RRU2 in accordance with Section X.D.
B. Soil/Sediment Excavation and Backfill
1. All soil/sediment in the unsaturated zone above the water table (which varies from 1 to 10 feet below
grade) that reguire treatment or disposal in order to achieve the cleanup levels in Table 2-15, shall be
excavated. To the extent practicable, excavation shall be performed when the water table is at the
seasonally low elevation. The volume of soil to be excavated is estimated to be 20,000 yd3 for RRU1 and
2,370 yd3 for RRUS. The volume of sediments to be excavated is estimated to be 564 yd3 for RRU2 and 250 yd5
for RRU4. The full extent of excavation shall be finalized during the remedial design.
2. Surface tanks, buildings, railroad tracks, and associated piping shall be demolished as necessary to
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remediate contaminated soils beneath the wood-treating plant and associated railroad. Any existing piping
associated with the former tank storage yard along Elm Avenue shall be removed as necessary during
excavation. The demolition plans shall be finalized during the remedial design and will reguire approval by
EPA.
9 The sediment cleanup level for PCP (0.4 ppm) shown in Table 2-15 is not expected to be achievable
through the use of engineered land treatment; therefore, excavated areas shall be backfilled with
clean sediments. However, the Table 2-15 soil cleanup levels for PCP and other contaminants are
expected to be achievable at the Site; therefore, sediments treated to achieve the soil cleanup
levels shall be backfilled at the Site as soils.
3. Excavation activities shall be conducted in a manner that minimizes damage to the ecosystem and
surrounding wetlands in accordance with Executive Order 11990 on Wetlands Protection (40 C.F.R. Part 6,
Appendix A), Chesapeake Bay Preservation Area Designation and Management Regulations (VR 173-02-01), Virginia
Water Protection Permit Regulations (VR 680-15-01), and Virginia Wetlands Regulations (VR 450-01- 0051). To
the extent practicable, wildlife present in the areas to be excavated shall be moved to comparable natural
areas prior to commencement of excavation activities. Any impacts to wetlands shall be mitigated in
accordance with applicable regulations and EPA approved methods.
4. Air monitoring for site-related contaminants shall be performed in accordance with 40 C.F.R. Part 50, to
ensure air emissions conform with the National Primary and Secondary ambient Air Quality Standards. Fugitive
dust emissions shall be controlled in accordance with Virginia Air Pollution Control Law (Code of Va. §
10.1-1300 et seg.) and the Virginia Regulations for the Control and Abatement of Air Pollution (VR 120-01).
Measures shall be taken to prevent dispersion of the materials during excavation and transportation.
Controlled amounts of water shall be sprayed onto the soils and tarps shall be placed over the loaded trucks.
If dust emission problems persist, excavation shall be suspended until conditions improve.
5. Erosion and sediment control measures shall be installed in accordance with the substantive reguirements
of the Virginia Erosion and Sediment Control Law (Code of Va. §§ 10.1-560 et seg.) and the Virginia Erosion
and Sediment Regulations (VR 625-02-00). To the extent possible, these measures shall be sufficient to
provide protection in the event of flooding in accordance with Executive Order 11988 (Flood Plain
Management). An erosion and sediment control plan shall be prepared and submitted to EPA and the locality
for review. Surface water run-off shall be diverted away from the excavation areas, and appropriate erosion
and sediment control measures shall be implemented. In the event of rain or potential Site flooding during
excavation, appropriate measures shall be taken to prevent contaminant migration. Stormwater runoff from
the Site that discharges to surface water shall be in compliance with the stormwater reguirements included in
VPDES regulations (VR 680-14-01).
6. All eguipment used during excavation of contaminated soil shall be decontaminated before entering
uncontaminated areas. The design and specifications for the decontamination facilities shall be approved by
EPA as part of the remedial design. Any discharge of water generated from Site decontamination activities
shall be in compliance with Virginia State Water Control Law, Code of Virginia §§ 62.1-44.2 et seg., and
VPDES regulations (VR 680-14-01) .
7. Excavated areas shall be backfilled with appropriately treated soil/sediment or clean fill and
revegetated.
8. Sampling and analysis of soil and sediment shall be performed prior to excavation to delineate the
complete extent of contamination for excavation purposes. Sampling and analysis shall also be performed
after excavation, and after backfilling, to confirm that cleanup levels set forth in Table 2-15 have been
achieved. Methods for determining compliance with the cleanup levels shall be finalized and approved by EPA
during the remedial design and will be based upon EPA 230/02-89-042, February 1989, Methods for
Evaluating the Attainment 9f CleaDup Standards, Vol 1: Soils and Solid Media.
9. Excavated soil and sediment shall be temporarily staged on-site in accordance with 40 C.F.R. Part 264,
Subpart L, and VR § 10.11, Waste Piles, or alternate methods approved by EPA in consultation with VDEQ, prior
to treatment and/or transportation to an off-site disposal facility. To the extent practicable, excavated
soil and sediment shall be staged in areas of existing contamination. If soil and sediment will be staged
in a clean area, the waste material and soil shall be temporarily staged in containers in accordance with
RCRA regulations contained in 40 C.F.R. Part 268, Subpart E, or alternate methods approved by EPA in
consultation with VDEQ; containers shall be in compliance with 40 C.F.R. Part 264, Subpart I and VHWMR §
10.8, Use and Management of Containers.
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10. Any debris contaminated with a listed hazardous waste (40 C.F.R. Part 261, Subpart D) such as F032 or
F034, or debris exhibiting a characteristic of hazardous waste (40 C.F.R. 261, Subpart c) shall be managed An
accordance with the federal land disposal restrictions (40 C.F.R. Part 268). Debris that does not contain or
exhibit characteristics of hazardous waste shall be managed in accordance with VSWMR
(VR 672-20-10).
C. Engineered Land Treatment of Soil/Sediment
1. Engineered land treatment for RRU1 and RRU2 shall be implemented if EPA determines that this technology
can be utilized to achieve the cleanup levels in Table 2-15 based on the pilot-scale treatability studies
reguired in Section X.A. On-site treatment in a plot would be in compliance
with Virginia Hazardous Waste Management Regulations § 10.11, and RCRA reguirements defined in 40 C.F.R.
264, Subpart L, Waste Piles.
2. The engineered land treatment system shall be designed and constructed in general accordance with
EPA/600/R-93/164, August 1993, Bioremediation Using the Land Treatment concept, in order to achieve the
cleanup levels listed in Table 2-15. The system design reguires EPA approval prior to commencing
implementation.
3. Run-on and run-off controls shall be installed to prevent over-saturation of the treatment beds and to
prevent migration of contaminants.
4. The treatment unit soil/sediment shall be monitored routinely to determine the rate of degradation of
the contaminants. The appropriately treated materials shall be backfilled to the general areas from which
they were excavated.
5. Any air emissions from any on-site treatment system shall comply with Virginia Air Pollution Control
Law, Code of Virginia §§ 10.1-1300 et. seg.; the Virginia Department of Air Pollution Control Regulations for
the Control and Abatement of Air Pollution (VR 120-01); and the federal Clean Air Act, 42 U.S.C. § 7401 et
seg.; and 40 C.F.R. Part 50.
D. Contingent Treatment Technology for RRU1 and RRU2: Low Temperature Thermal Desorption of Soil/Sediment
1. Low temperature thermal desorption shall be used to treat the soil/sediment in RRU1 and RRU2 if EPA
determines that engineered land treatment cannot be implemented to achieve the cleanup levels in Table 2-15
based on the pilot-scale treatability study reguired in Section X.A.
2. A treatability study for low temperature thermal desorption shall be conducted in general accordance
with EPA/540/R-92/074A, September 1992, Guide for Conducting Treatability Studies Under CERCLA: Thermal
Desorption Remedy Selection. A detailed Treatability Study Work Plan to test the effectiveness of low
temperature thermal desorption shall be approved by EPA prior to commencing the study. The Work Plan shall
include, at a minimum, a study description, testing goals, sampling and analysis methods, guality
assurance/control methods, treatment level derivations that support achieving the Table 2-15 cleanup levels
for respective Site areas, and an expeditious schedule for the study.
3. If EPA determines, based on treatability studies, that low temperature thermal desorption cannot achieve
the cleanup levels listed in Table 2-15, the soils and sediments in RRU1 and RRU2 shall be disposed of in
accordance with Section X.E. If low temperature thermal desorption can achieve the cleanup levels listed
in Table 2-15, proceed with Section X.D.4.
4. Low temperature thermal desorption shall be used to treat excavated soil/sediment in order to achieve
the cleanup levels in Table 2-15.
5. Air emissions shall be in compliance with National Ambient Air Quality Standards (NAAQS) (40 C.F.R. Part
50), National Emissions Standards for Hazardous Air Pollutants (NESHAP) (40 C.F.R. Part 61), and Virginia
Regulations for Control and Abatement of Air Pollution (VR 120-01) . On-site treatment units shall be
eguipped with air pollution control eguipment that can meet federal and Virginia air emission standards
and eliminate any unacceptable risks to human health of the environment.
6. 40 C.F.R. Part 264, Subpart X, and VHWMR § 10.15, Miscellaneous Units, regulate the use of miscellaneous
units for storing and/or treating hazardous wastes during the cleanup.
E. Soil/Sediment Disposal
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1. Soil and sediment excavated for off-site disposal (RRU4 and RRU5) shall be sent to a permitted RCRA
Subtitle C facility. Excavated areas shall be backfilled with clean fill in order to restore original grades.
Off-site disposal shall comply with all applicable statutes and regulations including, but not limited
to, CERCLA § 121(d)(3) which prohibits the disposal of Superfund Site waste at a facility not in compliance
with §§ 3004 and 3005 of RCRA, 40 C.F.R. § 300.440.
2. Transportation of hazardous waste from the Site shall be performed in accordance with Part VII of VHWMR,
and Virginia Regulations Governing the Transport of Hazardous Materials (VR 672-30-1), and RCRA reguirements
defined in 40 C.F.R. Parts 262 and 263, and 49 C.F.R. Parts 107, and 171-179.
F. DNAPL Recovery
1. During the remedial design phase, relative rates of DNAPL accumulation shall be measured at the Site to
determine the appropriate location and number of additional wells and the most effective DRAPL removal method
as approved by EPA. An estimated number of eight existing and seven new wells shall be utilized for DNAPL
recovery. Additional new, and/or existing, wells shall also be installed if determined to be reguired by
EPA.
2. DNAPL shall be recovered to the extent practicable and reused or recycled in accordance with all
applicable local, state, and Federal reguirements.
3. Any water collected during DNAPL recovery or any recovered DNAPL that can not be reused or recycled
shall be managed as a hazardous waste and transported off-site for treatment and/or disposal at a permitted
RCRA Subtitle C facility.
G. Site Monitoring
1. Ground water monitoring shall begin upon the initiation of DNAPL recovery and shall continue until a
final ground water remedy is implemented in accordance with a subseguent ROD. Ground water and DNAPL beneath
the Site shall be monitored for PAHs, PCP, arsenic, and DNAPL thickness on a guarterly basis. Wells shall
also be sampled and analyzed for the full EPA Contract LaD Program Target Analyte List and Target Compound
List, and for dioxins/furans on an annual basis. The appropriate number and location of wells to be sampled,
the duration of sampling, and the parameters and methods for analysis shall be approved by EPA during the
remedial design phase.
2. Long-term surface water monitoring shall be performed in accordance with State and federal reguirements
to monitor the guality of surface water run-off at the Site and to monitor for the potential migration of
contamination from the Site. The monitoring reguirements shall be developed in accordance with Virginia
State Water Control Law (Code of Virginia §§ 62.1-44.2 et seg.), VPDES regulations
(VR 680- 14-01), and 40 C.F.R. Part 141, Subparts C and E.
3. Chemical and biological monitoring of sediments shall be reguired if post-remedial concentrations of PCP
are greater than 0.4 mg/kg in Site soils. Semi-annual chemical and annual bioassay monitoring of on-site
sediments shall be reguired for a minimum period of five years from the time of remedial construction
completion to determine the effectiveness and durability of the cleanup. Sediments shall be analyzed for
PCP, total PAH, arsenic, copper, zinc, total organic carbon, grain size, pH and soil type.
H. Miscellaneous Performance Standards/Institutional Controls
1. As soon as practicable, institutional controls, including restrictions on title, use, and access will be
placed on the site. Restrictions on title shall prohibit the following: 1) residential development; 2)
agricultural development; and 3) the use of ground water for domestic or drinking purposes.
2. Appropriate measures shall be taken during any field activities to prevent exposure to off-site
individuals and/or pedestrians. Security fencing shall be installed to prevent unauthorized access in areas
set for ongoing remedial activities.
XI. STATUTORY DETERMINATIONS
This remedy satisfies the remedy selection reguirements of CERCLA and the NCP. The remedy is expected
to be protective of human health and the environment, complies with ARARs, is cost-effective, utilizes
permanent solutions and alternative treatment technologies to the maximum extent practicable, and meets the
preference for treatment as a principal element of the remedy. The following is a discussion of how the
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selected remedial action addresses these statutory requirements.
A. Overall Protection of Human Health and the Environment
The selected remedy will provide adequate protection of human health and the environment throuqh the
removal of soil and sediments contaminated with PAHs, PCP, arsenic, copper, zinc, and dioxin/furan, and the
recovery of DNAPL in the subsurface. These actions will reduce the carcinoqenic risk to within the
acceptable EPA risk ranqe of 1 x 10-4 to 1 x 10-6 and achieve a Hazard Index of less than one for
noncarcinoqenic risks.
No unacceptable short-term risks or cross-media impacts are anticipated by implementation of the
selected remedy.
B. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Under Section 121(d) of CERCLA, 42 U.S.C. § 9621(d), and EPA quidance, remedial actions at Superfund
sites must attain legally applicable or relevant and appropriate Federal and state environmental standards,
requirements, criteria, and limitations (collectively referred to as ARARs). Applicable requirements are
those substantive environmental protection requirements, criteria, or limitations promulqated under Federal
or state law that specifically address hazardous material found at the Site,
the remedial action to be implemented at the Site, the location of the Site, or other circumstances at the
Site. Relevant and appropriate requirements are those which, while not applicable to the Site, nevertheless
address problems or situations sufficiently similar to those encountered at the Site that their use is well
suited to that Site.
The selected remedy will comply with all ARARs. The site-specific ARARs and the To Be Considered (TBC)
criteria for the selected remedies are presented below.
1. Chemical Specific ARARs
! Off-site disposal will comply with RCRA requlations and standards for owners and operators of
hazardous waste treatment, storaqe and disposal facilities, 40 C.F.R. Part 264, VHWMR (VR 672-10-1); VSWMR
(VR 672-20-10); RCRA land disposal requlations, 40 C.F.R. Part 268, Subpart C and D, and §§ 15.3 and 15.4 of
VHWMR (VR 672-10-1).
! Any debris contaminated with a listed hazardous waste (40 C.F.R. Part 261, Subpart D) such as F032 or
F034, or debris exhibitinq a characteristic of hazardous waste (40 C.F.R. 261, Subpart c) shall be manaqed in
accordance with the RCRA land disposal requlations (40 C.F.R. Part 268 and VHWHR Part XV). Debris that does
not contain or exhibit characteristics of hazardous waste shall be manaqed in accordance with VSWHR (VR
672-20-10) .
2. Action-Specific ARARs
! Any off-site disposal of hazardous substances will comply with CERCLA § 121(d)(3) which prohibits the
disposal of Superfund site waste at a facility not in compliance with §§ 3004 and 3005 of RCRA, 40 C.F.R. §
300.440.
! 40 C.F.R. Parts 262, 263, and 268, 49 C.F.R. Parts 107, 171-179, Part VII of VHWMR (VR 672-10-1), and
the Virqinia Requlations Governinq the Transportation of Hazardous Materials (VR 672-30-1) requlate the
off-site transportation of solid and hazardous wastes in the Commonwealth of Virqinia.
! 40 C.F.R. Part 268, Subpart E, Prohibitions on Storaqe, and VHWMR Part XV, provide land disposal
restrictions for hazardous waste.
! Virqinia Solid Waste Manaqement Requlations (VSWHR 672-20-10) requlate the manaqement of solid waste
manaqement facilities in the Commonwealth of Virqinia.
! 40 C.F.R Part 261, and VHWMR Part III provide for the identification and listinq of hazardous waste.
! 40 C.F.R. Part 264, Subpart I, and VHWMR § 10.8, Use and Manaqement of Containers requlates the use
and manaqement of containers of hazardous wastes durinq the cleanup.
! 40 C.F.R. Part 264, Subpart J, and VHWMR § 10.9, Tanks, requlate the use of tanks for storinq and/or
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treating hazardous wastes during the cleanup.
! 40 C.F.R. Part 264, Subpart L, and VHWMR § 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 264, Subpart X, and VHWMR § 10.15, Miscellaneous Units, regulates the use of
miscellaneous units for storing and/or treating hazardous wastes during the cleanup.
! Any land-disturbing activities associated with the selected remedy will comply with the Virginia
Erosion and Sediment Control Law, Code of Virginia §§ 10.1-560 et seg., and Virginia Erosion and Sediment
Control Regulations (VR 625-02-00) to prevent erosion and transport of sediments in surface water runoff
during earth moving activities.
! The excavation associated with the selected remedy shall cause no violation of NAAQS due to fugitive
dust generated during construction activities as set forth in 40 C.F.R. § 50.6 and 40 CFR ) 52.21(j) and VR
120-04-0101 of the Virginia Regulations for the Control and Abatement of Air Pollution.
! 40 C.F.R. Part 50, Appendix G establish protocols for air monitoring to be conducted during the
cleanup.
! Air emissions shall be in compliance with National Ambient Air Quality Standards (NAAQS) (40 C.F.R.
Part 50), National Emissions Standards for Hazardous Air Pollutants (NESHAP) (40 C.F.R. Part 61), and
Virginia Regulations for Control and Abatement of Air Pollution (VR 120-01) .
! The Site monitoring reguirements shall be developed in accordance with Virginia State Water Control
Law (Code of Virginia §§ 62.1-44.2 et seg.), VPDES regulations (VR 680-14-01), and 40 C.F.R. Part 141,
Subparts C and E.
! Virginia Stormwater Management Regulations (VR 215-02-00) reguire that all land-disturbing activities
be in compliance with local stormwater management 9rograms.
! The federal National Pollutant Discharge Elimination System (NPDES) under the Clean Water Act 33
U.S.C. §§ 1251 et seg., and the Virginia Pollution Discharge Elimination System (VPDES) under the Virginia
Water Control law, Code of VA § 62.1-44.2 et seg., establish discharge limitations for point source
discharges to surface water based on designated use of the receiving stream. NPDES reguirements set forth in
40 C.F.R. Part 122, 129, and 131 and VPDES reguirements set forth in VR 680-14-00 and 680-21-00 shall be met.
3. Location-Specific ARARs
! The Fish and Wildlife Coordination Act (16 U.S.C. 661-667e) coordinates Federal, State, public and
private organizations in protecting fish, wildlife and their habitats. The Migratory Bird Treaty Act (16
U.S.C. 701-708) is an international treaty protecting migratory birds.
! The Endangered Species Act of 1973 (16 U.S.C. § 1651 et. seg.,), the Virginia Board of Game and Inland
Fisheries (Code of Virginia §§ 29.1-100 et seg.), and Virginia Endangered Species Act, Code of Virginia §§
29.1-563, provide a means for conserving various species of fish, wildlife, and plants that are threatened
with extinction. These ARARs will be applicable if EPA determines that endangered species are present or will
be affected by the remedial action*
! Executive Order 11988, Floodplain Management (42 U.S.C. 4001); the National Flood Insurance Act of
1968; the Flood Disaster Act of 1973; and Procedures for Implementing the Reguirements of the Council on
Environmental Quality on the National Environmental Policy Act. These provisions regulate cleanup activities
that take place in a floodplain.
! Coastal Zone Management Act (16 U.S.C. §§ 1451 et. seg., 40 C.F.R. Part 930); 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 that take place in a coastal area.
! Virginia's Chesapeake Bay Preservation Act (Code of Va,. § 10.1-2100 et seg) and Chesapeake Bay
Preservation Area Designation and Management Regulations (VR 173-02-01) regulate cleanup activities that take
place in resource management and/or research protected areas as designated in the Chesapeake Bay Preservation
Act.
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! Excavation activities in wetland areas shall be conducted in accordance with Executive Order 11990 on
Wetlands Protection (40 C.F.R. Part 6, Appendix A), and Virginia Wetlands Regulations (VR 450-01-0051), and
the Virginia Water Protection Permit Regulations (VR 680-15-01).
4. Criteria, Advisories, or Guidance To Be Considered (TBCs)
! Contained-in Policy (EPA OSWER Directire 9347.3-05FS) states that environmental media mixed with a RCRA
listed hazardous waste must, upon collection, be managed as if it were a hazardous waste until it no longer
contains the listed hazardous waste.
! Methods for Evaluating the Attainment of Cleanup Standards - Volume 1 (Soils add Solid Media), EPA
230/02-89-042, provides statistical methods to confirm compliance with soil/solid media clean-up levels.
! Guide for Conducting Treatability Studies Under CERCLA: Biodegradation Remedy Selection,
EPA/540/R-93/519a, August 1993, provides guidance for the on-site pilot-scale treatability study using
engineered land treatment.
! Guide for Conducting Treatability Studies Under CERCLA: Thermal Desorption Remedy Selection,
EPA/540/R-92/074A, September 1992, provides guidance for a treatability study using low temperature thermal
desorption
! Bioremediation Using the Land Treatment Concept, EPA/600/R-93/164, August 1993, provides guidance on
designing the engineered land treatment system.
C. Cost Effectiveness
EPA has determined that the selected remedy is cost-effective in that it mitigates the risks posed by
the contaminants associated with the Site, meets all other reguirements of CERCLA, and affords overall
effectiveness proportionate to the cost. Based on the Feasibility Study Report, the total estimated present
worth cost of the selected remedy is $9,102,000 and is summarized in the table below.
Total Estimated Costs of Selected Alternatives
RRU1 RRU2 RRU3 RRU4 RRU5 TOTALS 10
Capital $2,442,000 $283.000 $537,850 $162.000 $1,403,000 $4,827,850
Costs
Annual O&M $33,800 to $30,000 to $214,775 $15,600 $31,900 $326,075 to
Costs $276,800 $45,000 $584,075
Present $3,839,000 $772.000 $2,196,000 $402,000 $1,893,000 $9,102,000
Worth Costs
D. Utilization of Permanent Solutions and Alternative Treatment
(or Resource Recovery) Technologies to the Maximum Extent Practicable
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 at the Site. Soils and sediments from
RRU1 and RRU2 will be treated by either engineered land treatment or by low temperature thermal desorption
processes. Soils and sediments from RRU4 and RRU5 can not be treated similarly due to the presence of
elevated metals, organics, and high pH. Soils and sediments from RRU4 and RRU5 will be sent off-site for
disposals therefore, this portion of the remedy does not employ a permanent solution. DNAPLs will be
extracted from new and existing recovery wells and will be re-used or disposed of off-site.
E. Preference for Treatment as a Principal Element
In keeping with the statutory preference for treatment as a principle element of the remedy, the
selected remedy utilizes treatment as a principal element for RRU1 and RRU2. The soil and sediment from RRU1
and RRU2 account for an estimated 87% of the total soil/sediment reguiring remediation at the Site. The
remaining soil/sediment will be disposed of off-site. Site soil and sediment will be treated to the extent
necessary to meet the cleanup levels provided in Table 2-15 of this ROD.
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10 Total estimated costs assume that engineered land treatment will be the treatment technology
implemented for soil/sediment in RRU1 and RRU2. Total estimated costs are $12.6M if low temperature thermal
desorption is the required technology to be implemented.
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes from the Proposed Remedial Action Plan appear in this Record of Decision.
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RECORD OF DECISION
ATLANTIC WOOD INDUSTRIES, INC., SUPERFUND SITE
PART III- RESPONSIVENESS SUMMARY
Comments raised during the public comment period on the Proposed Plan for the Atlantic Wood Industries,
Inc., Superfund Site (Site) are summarized in this Responsiveness Summary. The comment period was initially
held from June 9, 1995, to July 8, 1995, to address the Proposed Plan. Upon request, the public comment
period was extended to August 7, 1995.
Oral comments were presented at the Proposed Plan Public Meeting held on June 27, 1995. These comments
and EPA's responses are presented in Section I of this Responsiveness Summary. A transcript of the first
public meeting has been included in the Administrative Record for the Site.
EPA received three letters from concerned parties on the cleanup alternatives or other aspects of Site
activity during the public comment period. One letter was from a citizen. The other two letters contained
comments submitted by potentially responsible parties. The comments presented in these letters and EPA's
responses are found in Section II of the Responsiveness Summary. These letters have been included in the
Administrative Record for the Site.
I. ORAL COMMENTS FROM JUNE 27, 1995, PUBLIC MEETING
1. A community member asked how Alternative 6 and Alternative 7
in the Proposed Plan are different.
EPA RESPONSE: Both Alternative 6 and Alternative 7 are bioremediation technologies which involve
excavating contaminated soils and sediments and mixing in water and nutrients to enhance the break down of
the contaminants. However, Alternative 6 would involve placing excavated soils and sediments into an on-site
tank, and Alternative 7 involves placing the soil and sediments into an on-site treatment plot.
2. A community member asked if the proposed excavation of soils
and sediments would change the present surface
characteristics of the Site and induce mosguito breeding grounds.
SPA RESPONSE: The surface of the Site will not be changed as a result of excavation; therefore, new
mosguito breeding areas will not be created. Any areas that are excavated will be backfilled with clean or
treated soil.
3. A community member asked who will pay for the cost of the clean-up actions.
EPA RESPONSE: EPA will negotiate with the responsible parties to pay for the costs of the cleanup. If
EPA is unsuccessful in coming to an agreement with the responsible parties, then EPA can unilaterally order
these parties to do the work or use money from the Superfund trust to pay for the cleanup. If money is used
from the trust fund, EPA will continue to pursue the PRPs to recover the money spent on the cleanup.
4. A resident asked why the Site continued to operate until
1992 if it was placed on the National Priorities List in 1990.
EPA RESPONSE: The placing of a site on the National Priorities List (NPL) does not necessarily mean
that its operations must stop. The Site was placed on the National Priorities List in 1990 because of
contamination problems resulting from past operational practices.
5. A resident asked how sediments were prevented from entering
the river during the removal action.
EPA RESPONSE: EPA required that necessary precautions be taken during excavation of sediments from the
inlet to minimize the transport of sediments to the river. These precautions involved the use of
silt-curtains, booms, and the removal of sediments from the inlet only during low tide conditions.
6. A local resident commented that well water in the community
is often used to water yards and gardens and fill swimming
pools. The resident asked how Site contamination has
affected the ground water in these wells.
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EPA RESPONSE: Additional investigation will be conducted under Operable Unit 2 of the Site to
characterize the impact of contamination on the ground water in the area. Residents who live in the
immediate Site area and use well water for domestic purposes should contact EPA so that a determination
can be made as to the potential impact of the Site on the well water.
7. A community member asked if any controls were going to be
implemented to prevent rodents from migrating from the Site
during clean-up work.
EPS RESPONSE: EPA has not seen any indications that rodents will present a problem to the surrounding
neighborhood during the cleanup, but this issue may be considered during the remedial design.
8. A community member asked how dust from the trucks hauling
contaminated material off-site would be controlled.
EPA RESPONSE: EPA will ensure that all necessary safety precautions and regulations are followed during
the hauling of contaminated wastes off-site. Materials being transported from the Site by truck will be
covered with tarps. In addition, the truck drivers will have proper training for the transportation of
hazardous material.
9. A community member asked if EPA's goal for bioremediation is
to achieve the minimum permissible exposure level.
EPA RESPONSE: EPA's clean-up levels are designed to be protective of human health and the environment.
The cleanup levels are based on the more conservative of the human health or environmental risk factors for
the Site. The specific clean-up levels for Site contaminants are provided in Table 2-15 of this ROD.
10. A community member commented that, although there are bans
on fishing in the Elizabeth River, people continue to crab
and fish. The community member asked if river contamination
would be addressed as part of this Site.
EPA RESPONSE: Because there are many industries located on the Elizabeth River, the source of
contamination and how best to address it are difficult to determine. This ROD addresses the cleanup of
Operable Unit 1 (OU1) only. Subseguent OUs will be handled separately. EPA has chosen this strategy for Site
cleanup for two specific reasons: 1) OU1 contamination represents a continuing source of further
releases of contaminants to the environment and therefore needs to be cleaned up first; 2) subseguent OUs
reguire further investigation and study to determine feasible cleanup solutions. If cleanup actions are
reguired as a result of Site-related contamination, those actions will be documented in a subseguent ROD.
11. A resident asked about the time frame for initiating cleanup activities.
EPA RESPONSE: EPA will attempt to negotiate an agreement with the potentially responsible parties for
implementation of the cleanup. This can take six to eight months, sometimes longer. Upon completion of this
negotiation process, the design phase begins. As part of the design, treatability studies will be performed
to ensure that biological treatment can work effectively at the Site. The design phase usually reguires 15
to 20 months. Actual on-site cleanup action will begin following EPA approval of the design standards and
specifications.
12. A resident asked why EPA sought the community's comments
before selecting a final clean-up method.
EPA RESPONSE: EPA is reguired by law to solicit public input before selecting a remedy at a Superfund
site. EPA relies on public input to ensure that the cleanup meets the needs and concerns of the local
community.
13. A community member asked who was paying for the studies and
investigations that have been completed to date and who will
Day for the eventual clean-up work.
EPA RESPONSE: Atlantic Wood Industries, Inc. (AWI), has conducted all of the investigations and studies
at the Site under oversight from EPA and the Virginia Department of Environmental Quality. EPA anticipates
negotiating a consent decree with the potentially responsible parties (PRPs) for the AWI Superfund Site who
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under the terms of such decree, would pay for Site cleanup. If a decree is not successfully negotiated,
EPA has the option of ordering one or more of the PRPs to perform Site cleanup or EPA may use Superfund
monies to pay for Site cleanup and thereafter seek reimbursement of cleanup costs from the PRPs.
14. A Community member asked if drums buried on-site will be removed.
EPA RESPONSE: This ROD reguires excavation of contaminated materials in the area known as the historic
disposal area where drums may have been buried. Excavation is reguired to the depth of the water table, and
if drums are found, they will be removed and disposed of properly.
15. A community member asked EPA to identify the responsible
parties for Site contamination.
EPA RESPONSE: At this time, EPA has not made a legal determination as to which parties are responsible
for Site contamination. What EPA has done, however, is to inform those parties who are potentially
responsible for contamination at the AWI Site of their potential liability. The parties who have been so
informed by EPA are Atlantic Wood Industries, Inc., and the U.S. Norfolk Naval Shipyard.
16. A resident commented that many people in the community
expressed an interest in the public meeting but could not
attend because they only received a few days notice in the mail.
EPA RESPONSE: EPA mailed a fact sheet to the community and placed a public notice announcing the public
meeting in the Virginian-Pilot & Ledger-Star on June 9, 1995. EPA is available to schedule a teleconference
or availability session with any community members who could not attend the meeting. In the future, EPA will
attempt to provide the community with earlier notice of Site meetings and activities.
A community member asked if Site contamination impacting
Paradise Creek will be addressed.
EPA RESPONSE: This ROD does not address Paradise Creek. If investigations under subseguent Operable
Units for the Site determine that the Creek is contaminated by Site-related contamination, appropriate
cleanup actions would be documented in a subseguent ROD.
A resident asked if EPA could place a copy of the
Administrative Record in the Cradock Library.
EPA RESPONSE: EPA has been told there is not adeguate space at the Cradock Library for the
Administrative Record. However, EPA will attempt to have either a hard copy or a microfilm version placed
there as soon as possible.
A community member asked if Alternative 7 in the Proposed
Plan would be constructed on-site.
EPA RESPONSE: Alternative 7, which involves excavation and engineered land treatment of soils, would be
conducted on-site. Excavated soils will be placed in treatment plots at the Site and tilled to promote
biological degradation of the contaminants. Nutrient will be added as appropriate to enhance the biological
process.
20. A community member asked if EPA knew the volume of DNAPLs
present beneath the surface of the Site.
EPA RESPONSE: Areas have been identified where DNAPLs are known or suspected to exist. This
information is sufficient to identify the need for action to remove DNAPL contamination, however, an accurate
estimate of the total volume could not be made.
21. A community member asked if EPA is going to monitor the
effectiveness of the clean-up actions.
EPA RESPONSE: EPA will oversee implementation of the cleanup actions reguired in this ROD. In
addition, EPA will continue to oversee investigation activities for subseguent operable units at the Site.
After actual cleanup begins, a formal review of the Site is reguired by law in five years to ensure that the
cleanup remains protective of human health and the environment.
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22. A community member asked if creosote was still used in industry today.
EPA RESPONSE: Creosote is still used in industry today. When stored, handled, and disposed of properly,
creosote can be put to beneficial use. Health and environmental hazards arise when creosote is used, stored,
or disposed of improperly.
23. A community member asked if EPA will inform the community of
the results of the treatability studies prior to beginning
actual clean-up work.
EPA RESPONSE: EPA plans to issue fact sheets during the design of the cleanup remedy to update the
community on the progress of treatability studies and other work. In addition, EPA plans to hold another
public meeting prior to beginning the actual cleanup action at the Site.
24. A resident asked if Atlantic Wood has future industrial
plans for this Site once it is cleaned up.
EPA RESPONSE: Currently, the Site is used for storage and shipping purposes. Atlantic Wood has not
identified any future plans for the Site to EPA following its cleanup. Note, however, that this ROD reguires
that the Site title be modified to show restrictions to prevent: 1) residential development; 2) agricultural
development, and 3) the use of ground water for domestic or drinking purposes.
25. A community member asked if there have been studies, other
than plant and animal studies, on the contaminants at this Site.
EPA RESPONSE: Table 2-11 (Slope Factors and Reference Doses) in this ROD indicates the nature of the
evidence that EPA has relied upon in evaluating the health hazards associated with chemicals found at the
Site. The column labeled "Class" refers to this evidence and is explained in the notes at the end of the
table.
26. A community member asked what creo-penta was and where the wood that is on-site is coming from.
EPA RESPONSE: Creo-penta is a mixture of creosote and pentachlorophenol, the two elements commonly used
during wood treating operations at the Site. The wood that is currently stored on-site is being treated and
shipped from another facility. No active wood treatment is occurring at the Site at this time.
II. WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
Comments from Atlantic Wood Industries, Inc.
1. The company states that U.S. EPA's primary stated objective
to "eliminate the potential for human or ecological exposure
to soils or sediments that contain contaminants" (emphasis
added) is inconsistent with CERCLA and the NCP. Rather, the
objective should be to reduce the potential for adverse
human or ecological exposures to the constituents of
interest at the Site, as "adverse" is defined by the NCP.
EPA RESPONSE: The NCP at §300.430(a) states "The purpose of the remedy selection process is to
implement remedies that eliminate, reduce, or control risks to human health and the environment." This ROD
is consistent with that reguirement.
2. The company contends that the RI/FS soil data for the Site
more closely reflects a lognormal distribution than a normal
distribution, prior to and after remediation. The company
believes that a geometric mean is the statistic that best
describes this distribution and that EPA should concur with
what is statistically appropriate and sound scientific
practice.
EPA RESPONSE: EPA agrees that the distribution of data prior to remediation most often tends to be
lognormal and that the appropriate statistic to measure the central tendency of a lognormal data set is the
geometric mean. Following remediation, however, the objective of sampling is not simply to determine the
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central tendency of the data set. Rather, the objective is also to ensure that contamination "hot spots,"
which could pose an unacceptable risk to human health and the environment, do not exist. By using a
geometric mean to evaluate the success of the cleanup, areas with contaminant concentrations several orders
of magnitude above the cleanup level could remain. The use of the arithmetic mean, on the other hand, avoids
this problem and ensures that the cleanup is truly protective.
EPA expresses cleanup levels in terms of average
concentrations, as provided in "Methods for Evaluating the
Attainment of Cleanup Standards" (EPA 230/02-89-042) and
other similar statistical guidance documents. The average
concentration in post-remedial samples must be less than or
egual to these goals for the cleanup to be judged acceptable.
For physiological and biochemical reasons, EPA's model
of toxic effects (including cancer) reguires that exposures
and risk be based on arithmetic rather than geometric means
("Risk Assessment Guidance for Superfund", IA, EPA/540/1-
89/002) . For this reason, EPA also sets cleanup levels
based on arithmetic rather than geometric means. For data
that are lognormally distributed, special methods are used
to calculate the unbiased arithmetic mean.
It would be possible to convert the arithmetic mean
cleanup levels to eguivalent geometric means. However,
these geometric means would be substantially lower (and
would describe exactly the same set of post-remedial
conditions). Furthermore, in order to calculate residual
risk the geometric means would have to be converted back to
arithmetic means, a pointless and unnecessary exercise.
3. The company contends that the cleanup levels in Table 2-15
of this ROD are not appropriate for use as goals for the
biological treatment itself since achievement of the cleanup
levels will be determined as the statistical average
concentration throughout the remediated area.
EPA RESPONSE: In general, two basic approaches can be used to determine if reguired cleanup levels are
achieved for treated soils (or sediments) at a site. In the first method, statistically representative
sampling of the site soils is conducted prior to excavation to determine the areas where the cleanup levels
are exceeded. These soils are excavated and treated. As the soils exit the treatment unit, samples are
collected and analyzed to determine if the cleanup levels have been achieved. If the cleanup levels have
been achieved, the treated soils are backfilled and no further sampling is reguired. Otherwise, the soil is
returned to the treatment unit for further treatment and the process is repeated. This is a conservative
approach that generally guarantees that cleanup levels have been achieved. This method may, however, result
in more soil being treated than needed to achieve the reguired cleanup level.
The second method relies on statistical calculations based on the initial distribution of
contaminants to project interim concentrations that can be used as a basis for identifying what soils need to
be excavated and what treatment must be achieved in order to attain the cleanup levels. With this approach,
the cleanup levels do not need to be used to determine which soils should be excavated or to determine when
treatment is completed and backfilling can occur. However, statistically representative sampling will be
needed in remediated areas after backfilling to determine if the cleanup levels have been achieved. This
method may reduce the amount of soil that is treated, but the risk that some areas may have to be excavated
and treated again is greater.
The company's comment reflects a desire to use the second approach. EPA agrees that this approach
can be used, however, the company would be responsible for establishing the excavation and treatment levels
at its own risk. EPA's main interest under the second approach would be in evaluating the sampling plan used
and analytical results generated following backfilling to ensure that the cleanup levels have been
achieved.
4. The company states that the exposure model used in the
Ecological Risk Assessment prepared for the Site does not
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consider the home range of a species and, therefore, results
in an overestimation of the low dose exposures. The company
further contends that the exposure model incorrectly assumes
that the plants and animals consumed by ecological receptors
(e.g., other animals and birds) will bioaccumulate
contaminants to levels egual to those found in the
contaminated soil and sediment.
EPA RESPONSE: The purpose of the Ecological Risk Assessment was to conduct a screening of ecological
risk to determine if further consideration is warranted. Conservative assumptions are used so that if a
decision is made based upon the screening that no further consideration is needed, EPA can be confident that
this determination is appropriate. EPA agrees that if a site-specific guantitative ecological risk assessment
were to be conducted for the Site, factors such as home range and bioconcentration factors should be
considered in the exposure mode.
The company contends that any contribution from the Site to the Elizabeth River is the result of
historical discharges and/or infiltration and not from stormwater run-off. The company contends that outfall
grab samples and bioassays conducted since 1985 confirm that the Site has not significantly impacted aguatic
life.
EPA RESPONSE: While the outfall samplingdata summarized by the company may show compliance with the
State discharge permit reguirements, this data does not confirm the company's statement that stormwater
run-off from the Site is not contributing contamination to the Elizabeth River. In all instances where the
PCP data reported was above the analytical detection level (24 of 42 samples), all the concentrations
exceeded either the acute or marine chronic water guality standard for PCP. In the remaining instances,
the analytical detection limit exceeds the chronic water guality standard (and the acute in five samples) so
the data is inconclusive.
The discharge limit in the permit allows for a dilution factor of 50 to be applied to the outfall
data to estimate the river concentration. By using this dilution factor, the resulting river PCP
concentrations do not exceed the acute water guality standard and only exceed the chronic standard in one
sample from 1986. In addition, the bioassay results have shown instances were the Site run-off has been
toxic.
The outfall data and the associated water guality
standards do not apply to sediments and do not characterize
the mass of existing contamination within the sediments.
Therefore, the outfall data does not address risk from
exposure to these contaminated sediments. Site outfall data
show that PCP was still entering the river (1993 levels at
370 and 330 • g/L) two years after treatment with PCP ceased
at the Site. With PGP's affinity for soil (log K. of 5.86),
PCP would be expected to concentrate in sediment and not
remain in the water. Sediment data presented in the
Ecological Risk Assessment show a gradient of decreasing
levels of PCP with increasing distance from the Site.
A much more detailed study would be reguired to
determine if the concentrations of contaminants leaving the
Site through stormwater run-off or other means are
significantly impacting aguatic life in the Elizabeth River.
6. The company contends that EPA's PCP soil cleanup level of 3
mg/kg is more stringent than levels established in many
states (eight state cleanup levels were cited) and other EPA
Records of Decision (two were cited).
EPA RESPONSE: The Commonwealth of Virginia has not established soil cleanup levels and the soil cleanup
levels established by other states do not apply to this Site. Even if these state cleanup levels were
considered relevant, they would not have direct application to the Site. The PCP cleanup level for the Site
is based not only on potential risk from direct exposure to soil, but is also based on the potential risk
from exposure to sediments since Site soil can erode and migrate to nearby drainageways and the river.
Because aguatic organisms are more sensitive to PCP in sediment than terrestrial organisms may be to PCP in
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soil, the soil cleanup level was biased low in order to protect the aquatic organisms as well.
The determination of cleanup levels at Superfund sites is highly dependant on site-specific
factors. Therefore, the cleanup levels derived for one site cannot be applied to another.
7. The company contends that EPA's concern about potential
flooding of the Site fails to take into account the
hydrology of the Elizabeth River and the fact that past
floods have not been erosional-type floods.
EPA RESPONSE: Site-specific studies to indicate whether erosion occurs during heavy precipitation or
during flood events have not been conducted. However, drainageways on the Site, the inlet to the river, and
the river in the vicinity of the Site all have elevated levels of Site-related contaminants. While this
contamination could have resulted solely from surface and ground water migration, transport of soil with
surface water run-off almost always occurs to some extent.
8. The company contends that EPA did not consider the use of
engineering controls that could be used to mitigate the
potential for adverse erosional activities at the Site.
EPA RESPONSE: Engineering controls can be used to reduce the transport of soil through erosion;
however, as with any engineering control, these measures would have to be properly designed and constructed,
and permanently maintained to eliminate this transport pathway. EPA did not increase the PCP cleanup level
and allow the use of engineering controls to prevent the transport of soil because the long-term
effectiveness and permanence of the remedy would be difficult to achieve under these circumstances.
9. The company contends that recent plant studies indicate that
uptake of PCP is not significant, PCP accumulated in plants
in readily metabolized, and bioaccumulation in animal eating
plants is minimal. Therefore, the company does not believe
that biomonitoring of the Site is necessary.
EPA RESPONSE: PCP readily breaks down in the environment by chemical, microbial, and photochemical
processes. PCP is most toxic, yet rapidly metabolized, in aquatic environments at elevated temperatures and
reduced pH. A review of the related literature, however, indicates that although bioaccumulation may not be
significant (it does bioconcentrate, depending upon pH), PeP at low level exposure is still toxic to plants,
and causes uncoupling oxidative phosphorylation in mitochondrial. Studies indicate that root growth in
terrestrial plants is adversely affected at 0.3 mg/kg PCP. PCP applied at the rate of 1.0 g/m2 to beech
forest soils reduced populations of soil organisms, and at a rate of 5.0 g/m2, PCP reduced most of the soil
microflora and invertebrates. Little data is available on the toxic effects of PCP on terrestrial wildlife.
However, PCP has been shown to cause adverse sublethal effects in birds fed dietary levels as low as one
mg/kg.
The related Canadian study2 indicates that lettuce (Lactuca sativa) seed germination and root
elongation tests were used to assess the toxicity of PCP in soils. Seed germination tests measure toxicity
associated with soils directly, while root elongation tests evaluate the indirect effects of water soluble
constituents that may be present in Site samples. The no observable effects concentration for seedling
emergence in Lactuca sativa was calculated as 7 mg/kg dry soil, and the mean no observable effects
concentration for root elongation was calculated as 0.25 mg/kg dry soil.
The remedy selected in this ROD requires that Site soils be remediated to achieve the cleanup level
of 3 mg/kg for PCP. However, other data, such as the apparent effects thresholds concentration of 0.4 mg/kg
suggest that the 3 mg/kg cleanup level may not be conservative enough. Absent a site-specific quantitative
risk assessment to clearly define the most appropriate ecological cleanup level, chemical and biological
monitoring of sediments shall be conducted at the Site if post-remedial soil concentrations of PCP are
greater than 0.4 mg/kg. 10. The company recommends that EPA use 25 mg/kg as the cleanup level as recommended
by the recent comprehensive Canadian study2 because of the industrial nature of the Site.
1 Eisler, R. 1989 Pentachlorophenol Hazards to Fish, Wildlife, and Invertebrates: A Synoptic Review.
U.S. Fish and Wildlife Service Biological Report 10. 72 pp.
2 National Contaminated Site Remediation Program. Draft Report, September 1994. Canadian Soil
Quality Criteria for Contaminated Sites. Ecological and Human Health Effects: Pentachlorophenol.
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3 Preliminary Literature Review of the Aquatic Transport, Fate, and Effects of Creosote; and
Recommendations for Chemical and Biological Studies. Tech Memo 88-4. Seattle, Washington:
National Oceanic and Atmospheric Administration
EPA RESPONSE: The Canadian Soil Quality Criteria document referenced in the comment supports a soil
cleanup concentration of 25 mg/kg at industrial/commercial sites where a ground water check is not necessary
(i.e., where ground water is not used as a drinking source or if ground water will not discharge to surface
water). Contaminated ground water at the Site discharges to the Elizabeth River and contaminated soils are a
likely source of contamination to the aguifer. According to the soil guality document, a soil clean-up
concentration of 1.4 mg/kg is recommended for the protection of drinking water and 0.12 mg/kg is recommended
for the protection of aguatic life. The threshold effects concentrations for soils in agricultural, or
residential/parkland uses (calculated to be protective of ecological resources) is 3 mg/kg.
11. The company contends that EPA should eliminate the
requirement for backfilling of treated material and allow a
decision on management of the treated soil to be made during
the remedial design based upon the treatability study results.
EPA RESPONSE: The purpose of the treatability study to be conducted during the remedial design is to
establish whether engineered land treatment can be used to effectively achieve the cleanup levels established
for the Site in Table 2-15 of this ROD. If successful implementation of this technology cannot be
demonstrated, low temperature thermal desorption will be used to treat appropriate Site soils and sediments.
If engineered land treatment can be successfully implemented at the Site, backfilling provides the most
cost-effective disposal option for treated soils. The possibility exists that the treatability study results
for engineered land treatment may be positive, but for some reason, the full- scale implementation may
fail to produce appropriate results for a particular treatment plot. Under these circumstances, EPA will
need to review the specific facts available at that time and make a determination as to the appropriate
action.
12. The company contends that the Corrective Action Management
Unit (CAMU) regulations in 40 C.F.R. § 264.552 are ARARs for
the Site and, therefore, excavation, staging, treatment,
containment, and/or disposal of soils can occur at the Site
without triggering current or future RCRA Land Disposal Restrictions.
EPA RESPONSE: Excavation, staging, treatment, and disposal of soils at the Site, as required in the
selected remedy, will not trigger RCRA Land Disposal Restrictions. Therefore, the CAMU Rule does not need to
be considered.
Although the use of a CAMU as an ARAR may relieve a site from meeting specific federal LDR
requirements and/or needing a RCRA permit, the CAMU does not relieve a site from providing many other
protective measures. The preamble of the CAMU Rule (58 FR 8659) states, "EPA does not intend for this rule
to replace existing state and federal requirements, guidelines, and standards that define the necessary
level of protectiveness for remedies and the factors to be considered in selecting site-specific remedies."
AWI has stated that placing remediation wastes into or within a CAMU does not constitute land
disposal. This is only correct in that the LDRs do not apply. The CAMU rule revised the LDR Land Disposal
definition at 40 CFR § 268.2 to state "except in a corrective action management unit". The CAMU rule did not
change the base RCRA definition of "Disposal" at 40 CFR 260.10. It should be clear from the CAMU
regulations at 40 CFR § 264.552 that include ground water monitoring, closure and potential post-closure
requirements, that using a CAMU does not avoid the need for protective measures. Also as is stated in the
regulation at 40 CFR § 264.552 (h), "The designation of a CAMU does not change EPA's existing authority to
address clean-up levels, media-specific points of compliance to be applied to remediation at a facility
or other remedy selection decisions", which clearly indicates that a CAMU designation does not relieve the
facility/site from these site-specific decisions.
Even if a CAMU is designated as an ARAR for remediation actions at the Site, such designation may
not substantially change the remediation design requirements or clean-up levels. The designation of a CAMU
may also require long term environmental controls at the Site that may not be needed if a CAMU designation is
not applied.
13. The company contends that the RCRA minimum technical
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requirements for waste piles and surface impoundments should
not apply to staging and treating soils at the Site. The
company further contends that even if these requirements did
apply, the RCRA Corrective Action Management Unit concept
and/or the Temporary Unit concept should be used to waive
these requirements.
EPA RESPONSE: As identified in this ROD, EPA had determined that the RCRA regulations for waste piles
(40 C.F.R. Part 264, Subpart L) are ARARs for soil staged in waste piles at the Site; and RCRA regulations
for containers (40 C.F.R. Part 264, Subpart I) are ARARs for soil staged in containers. EPA does not
consider RCRA regulations for surface impoundments to be ARARs for the land treatment process. EPA believes
the waste pile and container regulations are appropriate for the cleanup activities to be performed at
the Site and does not consider it appropriate to attempt to waive these requirements by applying the CAMU
Rule.
14. The company contends that the remedial alternatives
development, screening, and detailed analysis performed in
the Feasibility Study for the Site did not assume that RCRA
Land Disposal Restrictions or RCRA Minimum Technical
Requirements would apply. Therefore, the company believes
that if these requirements do apply, the basis for making a
remedy selection will be flawed.
EPA RESPONSE: Treatment standards for RCRA listed wastes F032 and F034 have not been established under
the RCRA Land Disposal Restrictions. Therefore, the application of Land Disposal Restrictions to the
alternatives evaluated in the Feasibility Study would not have changed the analysis. As for the RCRA Minimum
Technical Requirements, consideration of the specific RCRA requirements for waste piles, containers, and land
treatment do not alter the discussion and analysis provided in the Feasibility Study needed to make a remedy
selection.
15. The company contends that several non-treatment alternatives
were either screened out or not rated as highly as treatment
alternatives because of CERCLA' s statutory preference for
treatment. The company further contends that, in light of
the general movement away from the preference for treatment,
EPA should reconsider the use of the surface capping and on-
site landfill alternatives for all Site soils and sediments.
EPA RESPONSE: EPA believes that an appropriate range of treatment and non-treatment alternatives were
evaluated in the Feasibility Study and the Proposed Remedial Action Plan. EPA, in fact, selected
non-treatment alternatives for two of the remedial response units being addressed under this ROD. The reasons
for not selecting a non-treatment remedy for the RRU1 and RRU2 soils is based on the limitations of the Site
itself and cost-effectiveness, not simply a preference for treatment. Even without a statutory preference
for treatment, the remedy selected in this ROD would likely have been the same due to cost effectiveness.
Estimates in the FS Report provided that the costs to excavate and on-site landfill ($3.928M RRU1) were
higher than the costs to excavate, land treat, and backfill ($3.839M RRU1).
16. The company does not believe that EPA should select a
contingency alternative for use if the primary alternative
fails. Specifically, the company contends that low
temperature thermal desorption is not well-demonstrated for
use with coal tar creosote and pentachlorophenol
constituents or with fine-grained soils such as those at the
Site. The company believes that a focused Feasibility Study
should be required in the event that the treatability
studies for engineered land treatment fail.
EPA RESPONSE: The Feasibility Study Report provided an evaluation of the all alternatives that could
potentially remediate Site soil and sediment. The report contained sufficient information on the contingency
alternative, low temperature thermal desorption (LTTD), for EPA to determine that this technology would be an
appropriate alternative should engineered land treatment fail to perform adequately. LTTD has been proposed
for use at several other Region III wood-treating sites including Saunders Supply, Rentokil, and Southern
Maryland Wood. Successful LTTD treatability studies have already been performed at Saunders and Rentokil.
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EPA has used a contingency alternative for several reasons. EPA hopes to promote the use of
innovative technologies, such as engineered land treatment, which appears to be the most appropriate remedy.
If the provision for a contingency was eliminated, LTTD would be the selected remedy—not engineered land
treatment. LTTD is considered to be a more reliable technology than engineered land treatment; however,
LTTD is not as cost effective. Also, selecting a contingent alternative now has the effect of reducing the
amount time needed before actual cleanup work can begin.
17. The company contends that neither CERCLA nor the NCP
reguires that existing, usable structures be demolished in
order to access soils beneath the structures. The company
recommends that structures which have an intended future use
be allowed to remain and that decisions regarding the need
for potential demolition activities should be finalized
during the Remedial Design process.
EPA RESPONSE: The company has not provided EPA with its specific plans for buildings and tanks at the
Site. The process area buildings and tanks have been idle since 1992. Substantial soil contamination may be
present beneath some of the process buildings and tanks. Unless a compelling reason is provided by the
company, EPA recommends that above ground structures at the Site be removed to the greatest extent possible
to facilitate soil remediation. EPA willmake a final decision regarding the demolition activities during the
remedial design process.
18. The company recommends that EPA clarify that excavation
activities will not extend below the water table.
EPA RESPONSE: This ROD specifies that the vertical limit of excavation is the water table and, to the
extent practicable, that excavation should occur when the water table is at the seasonally low elevation.
EPA recommends, however, that if significant pockets of contaminated soils are encountered below the water
table during excavation, and if field conditions permit, excavation of these materials should be
performed to lower the burden of residual contamination to ground water.
19. The company guestioned the purpose of inclusion of technical
details in the Proposed Plan. The company recommends that
this ROD not include technical details regarding the
remedial action and that these details be developed during
the Remedial Design process for the Site.
EPA RESPONSE: The specific performance standards for the selected remedy are listed in Part II, Section
X of this ROD. These standards provide the reguirements that must be met in implementing the remedy, but do
not include the design details for implementation. EPA agrees that the detailed standards and specifications
for implementing the remedy are best determined during the remedial design process. Details found in the
other portions of this ROD are provided for estimating or evaluative purposes.
20. The company has reguested that all of the documents,
including correspondence, draft reports, and status reports,
that were exchanged between the company and EPA be
incorporated into the Administrative Record for the Site
because they are important to the selection of the
appropriate remedy, cleanup goals, and statistical methods
for the Site.
EPA RESPONSE: Appendix A provides the current index to the Administrative Record. The documents in the
Administrative Record are those upon which EPA has relied in making the remedy selection decision documented
in this ROD. To the extent appropriate, the reguested documents have been added to the Administrative
Record.
COMMENTS FROM THE US DEPARTMENT OF THE NAVY ON THE FEASIBILITY STUDY (FS) REPORT.
21. The Navy guestioned whether there was, in general, detection
of either copper napthenate or zinc napthenate in any media analyzed.
EPA RESPONSE: The AWI Remedial Investigation (RI) Report, March 1992, provides concentrations of zinc
and copper for Site soil, sediment, and ground water. Concentrations of specific compounds for these metals
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do not appear to be included. Note also that AWI maintains that copper napthenate and zinc napthenate were
not used at the Portsmouth facility.
22. The Navy questions where CCA-treated wood at the Site came
from, where it was stored and for how long, how soon after
it was treated elsewhere did it arrive at the Site, and what
type of protection from the elements did it receive.
EPA RESPONSE: According to AWI, CCA-treated wood came from several off-site facilities beginning in
1970. The wood was shipped by rail or truck to the AWI Portsmouth Site. Wood that was shipped by rail would
have at least 10-days of drying/standing time before storage at the Site. Wood shipped by truck would have
had at least several days of drying/standing time before storage at the Site. CCA-treated wood was stored in
the western section of the Site. The RI/FS reports provide additional information regarding the storage
areas used for treated wood.
23. The Navy questioned whether the process water managed prior
to the early 1970s was conveyed via copper and/or galvanized
piping.
EPA RESPONSE: According to AWI, copper piping was not used for process water. Steel piping was mainly
used in addition to a small amount of galvanized piping.
24. The Navy contends there is not evidence to support EPA's
statement that inorganic concentrations in the Waste Lime
Area may be related to the acetylene sludge generated by the
Navy. The Navy further questions how this "contamination"
could have migrated upgradient, let alone to the Wood
Storage Area. The Navy contends that the locations of the
highest detections of arsenic, copper and zinc in the
Acetylene Sludge Area (495 mg/kg, 9780 mg/kg and 20,400
mg/kg respectively) do not correspond to suspected lime
(acetylene production byproduct) discharge locations. The
Navy indicates that aerial photographs from 1949, 1958,
1964, and 1972 suggest the discharge point may have been
several hundred feet east.
EPA RESPONSE: The Remedial Investigation Report provides data on the concentrations of contaminants in
Site soils. Statistically on a Site wide basis, the highest surface soil concentrations of metals,
specifically zinc and copper, occur in the area designated in the EPA Proposed Remedial Action Plan (June
1995) as the Waste Lime Area (Area 9) of the AWI Site. Concentrations of zinc in this area range from 87 to
20,400 mg/kg. Concentrations of copper in this area range from 78 to 9,780 mg/kg. South of this area, and
on the south side of the fence which divides the AWI property from the Norfolk Naval Shipyard's annex, is the
Navy's Site 9 (Waste Lime Pit). Comparing these AWI Site concentrations with data provided in the Final
Remedial Investigation/Risk Assessment/Feasibility Study (RI/RA/FS) Report, Norfolk Naval Shipyard, March
1995. for the Navy's Site 9, reveals a correlation of elevated metals among the properties that when
combined with historical information suggests that the Navy may have caused contamination on the AWI
property.
The Navy's RI/RA/FS Report lists concentrations of metals in Site 9. Concentrations of zinc in
Site 9 range from 3,770 to 28,500 mg/kg. Concentrations of copper in Site 9 range from 931 to 6,470 mg/kg.
These levels correspond with levels found at the AWI Site. The Navy RI/RA/FS Report states that "ballast
stones, silty sand, Black Beauty (trade name for abrasive blasting material used at NNSY), and other mixed
debris were used to construct the berm". This berm surrounds the Navy's waste lime pit at Site 9.
Section 4.5 of the AWI RI Report states that zinc was present in a sample from the acetylene waste sludge,
sand blasting grit, and in the red ballast stones collected on AWI property.
A letter dated July 23, 1951, from C. H. Slingluff, Vice-President for Atlantic Creosoting
Company, Inc., to Commander Van Liew, Public Works Officer for the Norfolk Naval Shipyard (NNSY) stated that
for several years NNSY discharged acetylene waste into the creek that separated the AWI Site from NNSY and
requested that NNSY review and correct the problem. A reply letter from Commander Van Liew, dated August 16,
1951, stated NNSY was "considering several proposals for a more adequate disposal of sludge from the
Acetylene Plantm. This correspondence confirms past NNSY disposal practices and the possibility that
contamination of AWI's property may have been in part caused by NNSY. Also, aerial photographs from 1944,
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1949, and 1952 analyzed by the EPA's Environmental Monitoring Systems Laboratory, suggest that a light-toned
material appears to radiate from a possible pipeline that may be associated with the Navy's acetylene
production. This material eventually accumulated within the inlet.
EPA recognizes that it was not unusual in the past for an industrial facility such as NNSY to
combine sludge, blasting grit, and other waste materials. If the blasting grit was of the spent variety,
which is likely, it would not be unusual for that grit to contain inorganic contaminants from the paint or
metal blasting operations. This could partly explain the source for elevated metals on both sides of the
fence. The preceding information coupled with AWI's assertions that it has never used zinc, copper, or
arsenic in its operations provided the justification that EPA needed to consider the Navy as a potentially
responsible party.
Regarding contaminant migration issues, EPA has not made any determinations with respect to
off-site contributions of contamination existing in the AWI Site Wood Storage Area located on the western
portion of the Site. However, EPA has contemplated that localized migration of contaminants in the AWI Site
Waste Lime Area could have occurred even if it appears to currently be upgradient. As operations at both the
AWI Site and NNSY date at least back to the early part of this century, and due to much of the impacted
area being fill, it is possible that contaminants could have been inadvertently spread to currently
upgradient areas.
25. The Navy guestioned what the ecological cleanup levels for
the Site were and from where they were derived.
EPA RESPONSE: The ecological cleanup levels for the Site are:
Ecological Cleanup Levels (ppm); AWI Site
Soil
Sediment
BaPEg
n/a
n/a
total
PAH
100
25
PCP
3.0
0.4
arsenic
150
85
copper
3.0
390
zinc
410
270
dioxin/
furans
0.001
0.001
The Site is mostly located on the floodplain of the Elizabeth River in the ecologically sensitive
Chesapeake Bay Drainage area. Because of the potential for Site soils to erode and migrate into drainageways
and the river, EPA factored in potential risks associated with sediment for the purposes of determining
ecological risk and cleanup levels.
The cleanup levels listed above were developed during the RI/FS for the Site. These levels
generally originate from effect range-median (ER-M) values provided by Long and Morgan (1990) as referenced
in the Ecoloaical Risk Assessment for Atlantic Wood Industries. APril 1992. which is a report prepared by
NOAA providing a gualitative risk assessment for the Site. During the RI/FS, these values were adjusted
to accommodate site-specific characteristics.
26. The Navy guestioned how alternatives could be considered to
eliminate exposure to soil in the Feasibility Study when
inorganic compounds are naturally occurring and will be
present in background concentrations.
EPA RESPONSE: The zero value applied to "an alternative that would eliminate exposure to soil" as
stated in the FS Report did not mean that a concentration of "0" would be achieved. These alternatives with
the zero value would involve capping or replacement of contaminated soils with clean soil--not treated soils,
as would be the case with bioremediation and backfill. Application of a zero value would therefore be
appropriate.
The background values from literature of metals were considered during the RI/FS. Table 4-2 of the
RI Report provides the related ranges of concentrations. As the background values are generally below the
cleanup levels selected for the Site, they are not considered to be a factor.
27. The Navy guestioned on what data the copper and zinc
geometric mean concentrations presented in the Feasibility
Study were based and how they were derived.
EPA RESPONSE: The tables in Section 4 of the RI Report provide the basis for the concentrations. This
-------
information was derived from sampling and analysis conducted at the Site.
28. The Navy stated that the assumption in the Feasibility Study
that soils in the Waste Lime Area cannot be treated
biologically eliminates other feasible options, as may be
learned during the remedial design. The Navy further states
that only the sludge itself, due to its high pH, may not be
easily bioremediated. The Navy contends that the inclusion
of the contaminated media (soil) originating from AWI with
that which has been alleged to have originated from the
Norfolk Naval Shipyard may prohibit or preclude EPA from
taking the most appropriate remedial action for the soil.
EPA RESPONSE: Based on the available RI/FS information, biologically treatment does not appear to be a
feasible alternative for the Waste Lime Area. However, if new information becomes available to indicate that
treatment of these soils is possible, EPA would be willing to consider this information.
29. The Navy guestion why cleanup levels presented in the
Feasibility Study for the Acetylene Sludge Area do not
correlate with the Remedial Action objectives presented in
Table 2-6 of the Feasibility Study.
EPA RESPONSE: A discrepancy does exist between the two tables. Table 2-5 provides cleanup levels that
were derived on the basis of protectiveness of human health. Table 2-6 provides objectives that were
intended to consider protectiveness to human health as well as the environment; however, the objectives are
not totally consistent. In any event, the cleanup levels provided in this ROD will govern during the
remedial design and action.
30. The Navy contends that EPA eliminated a numher of
alternatives in the Feasibility Study due to cost (4A, B,
and C; 5A, B and C, 6 and 7) and/or lack of vendor interest
(5A, B and C) when they may, in fact be feasible if combined
with other RRUs. The Navy further contends that the
Feasibility Study does not take into consideration
consolidation and/or treatment of like wastes to realize any
economy or efficiency.
EPA RESPONSE: Similarities between the various response units was considered during the development of
the Feasibility Study and during the evaluations conducted by EPA for the purposes of proposing and selecting
remedies. For example, this ROD provides for land treatment for both Remedial Response Units 1 and 2. EPA
does recognize that further consolidations could have been presented in the Feasibility Study. EPA
determined, however, that sufficient information was contained in the Feasibility Study for EPA, in
consultation with the Virginia Department of Environmental Quality, to make remedial decisions.
31. The Navy guestioned whether EPA has been able to demonstrate
if there has been or is likely to be migration of
constituents from the soil to the groundwater.
EPA RESPONSE: A Multimed model was performed in an effort to derive soil concentrations that would be
protective of ground water. Based on this model, there appears to be a potential for migration of
constituents to ground water at the Site. For example, Table 7-1 of the Final Report Interim Soil Cleanup
Goals, AWI, March 1992, which is the report providing the Multimed model results, provides arsenic
concentrations for soils ranging from 0.181 to 6.24 mg/kg which would be protective of ground water and the
Elizabeth River. These concentrations are generally more conservative than the levels existing at the Site.
Also, existing ground water data does show elevated levels of Site contaminants in various
monitoring wells. Additional data may be collected during a supplementary investigation planned for the Site.
32. The Navy noted that Fig. 2-6 of the Feasibility Study
indicates only two soil sample locations with arsenic
detection. The Navy guestioned if this was because these
were the only two analyzed for inorganic compounds. If so,
the Navy guestioned if this is a sufficient number to assert
-------
the "maximum concentration of 93 mg/Kg" is valid for the
entire area.
EPA RESPONSE: Only two locations were sampled in the Waste Lime Area for arsenic. The focus of the
Remedial Investigation was not on inorganic contaminants as the facility allegedly never used inorganics in
their processes. Also, it was apparent from Site investigations and plant history that the significant
contamination would have been caused by creosote and pentachlorophenol operations. Absent additional data,
which may become available through supplementary investigations, EPA believes that the use of data from the
two sample locations is valid.
33. The Navy states that for EPA to achieve a 10-5 cumulative
risk, soils in the Acetylene Sludge Area only need to be
treated for PCP contamination since elimination of PCP
exposure yields cleanup levels well below the EPA acceptable
risk range of 10-4 to 10-6. The Navy guestions why there is
the need then to consider arsenic as a Potential Contaminant
of Concern since it appears cleanup in this area is driven
by PCP and/or cPAHs with arsenic remediation a benefit.
BPA RESPONSE: Both the arithmetic average for arsenic in this area of 155 mg/kg and its 95% Upper
Confidence Limit of 376 mg/kg exceed the area cleanup level of 150 mg/kg for arsenic. Note that the
governing cleanup level is derived for both human health and ecological risk. Even if remediation of arsenic
was not needed for human health purposes in this area, the ecological cleanup level of 150 mg/kg does
necessitate a need for arsenic remediation.
OTHER COMMENTS
34. A written comment from a citizen recommended the use of the
most cost effective methods for Site cleanup. The citizen
believes that the problems are overstated—as long as the
contamination is not washed into streams or aguifers.
EPA RESPONSE: EPA considered cost effectiveness as one of the balancing criteria in the selection of
Site remedies. Also, the selected remedies will eliminate source contamination and will thereby reduce the
potential of contaminating streams and aguifers.
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ATLANTIC WOOD INDUSTRIES
ADMINISTRATIVE RECORD FILE *
INDEX OF DOCUMENTS
SITE IDENTIFICATION
1. Report: Final Preliminary Assessment for Atlantic Wood
Industries, Inc., prepared by NUS Corporation, 6/8/83.
P. 100001-100027.
2. Report: Site Inspection of Atlantic Wood Industries,
Inc., prepared by NUS Corporation, 3/28/86. P. 100028-100229.
Administrative Record File available 10/22/93, updated
10/17/94, 12/06/94, 1/31/95, 2/16/95, 3/23/95, 6/9/95,
8/10/95, and / / .
II. REMEDIAL ENFORCEMENT PLANNING
1. Administrative Order by Consent, In The Matter Of:
Atlantic Wood Industries, Inc. (a Georgia corporation),
Portsmouth, Virginia, Respondent, U.S. EPA Docket No.
III-87-24-DC, 7/23/87. P. 200001-200044.
2. First Amendment to the Administrative Order by Consent
In The Matter Of: Atlantic Wood Industries, Inc.,
Superfund Site, Portsmouth, Virginia, Respondent,
Docket No. III-87-24-DC, 8/5/94. P. 200045-200063.
3. Letter to Mr. Jeffrey A. Smigel, Atlantic Wood
Industries, Inc., from Mr. Bruce P. Smith and Mr
Stephen R. Wassersug, U.S. EPA, re: Notification of
potentially responsible party status and scope of
response activities for the site, 6/30/86. P. 200064-
200068.
4. Letter to Mr. James K. Strickland, Norfolk Naval Ship
Yard, from Mr. David lacono, U.S. EPA, re: General
notice of potential liability for the site, 5/18/94.
P. 200069-200076.
III. REMEDIAL RESPONSE PLANNING
1. Report: Remedial Investigation/Feasibility Study Work
Plan for the Atlantic Wood Industries, Inc. Site in
Portsmouth, Virginia, prepared by Environmental
Strategies Corporation, 3/1/88. P. 300001-300116.
2. Report: Supplemental Remedial Investigation Work Plan,
Atlantic Wood Industries, Inc. Portsmouth Virginia
Site, prepared by Keystone Environmental Resources,
Inc., 9/91. P. 300117-300158.
3. Report: Remedial Investigation Report of Atlantic Wood
Industries, Inc., Portsmouth, Virginia, Volume I,
prepared by Keystone Environmental Resources, Inc.,
3/92. P. 300159-300563.
4. Report: Ecological Risk Assessment for Atlantic Wood
Industries, prepared by National Oceanic and
Atmospheric Administration (NOAA) and E.V.S.
Consultants, Inc., 4/92. P. 300564-300617.
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5. Memorandum to Mr. Abraham Ferdas, U.S. EPA, from Mr.
Vance A. Evans, U.S. EPA, re: Determination that a
release at the site could present a threat to public
health or the welfare of the environment, 9/9/93.
P. 300618-300621.
6. Report: Public Health Assessment for Atlantic Wood
Industries Inc., Portsmouth, Portsmouth County,
Virginia, prepared by U.S. Department of Health and
Human Services, Public Health Service, Agency for Toxic
Substances and Disease Registry, 2/15/94. P. 300622-300678.
7. Memorandum to Mr. Drew Lausch, II, U.S. EPA, from Mr.
Roy L. Smith, U.S. EPA, re: Certification of human
health risk assessment for the site, 2/27/92.
P. 300679-300679.
8. Memorandum to Mr. David lacono, U.S. EPA, from Mr. Roy
L. Smith, U.S. EPA, re: Performance of Monte Carlo
analysis to determine if proposed soil clean-up levels
are consistent with risk reduction goals, 1/6/95.
P. 300680-300682. The analysis is attached.
9. Report: Feasibility Study Report for Atlantic Wood
Industries, Inc., Portsmouth, Virginia Site, prepared
by Groundwater Technology, Inc., 4/95.
P. 300683-301293.
10. Letter to Mr. Jeffrey A. Smigel, Atlantic Wood
Industries, Inc., from Mr. David J. lacono, U.S. EPA,
re: EPA's approval, with technical reservations, of
the April 1995 Feasibility Study Report, 6/8/95.
P. 301294-301300. The technical reservations of the
Feasibility Study are attached.
11. Proposed Plan, Atlantic Wood Industries Inc., 6/95.
P. 301301-301333.
12. Report: Remedial Investigation Report of Atlantic Wood
Industries, Inc., Portsmouth, Virginia Site, Volume IT,
prepared by Keystone Environmental Resources, Inc.,
1/92. P. 301334-301958.
13. Report: Remedial Investigation Report of Atlantic Wood
Industries, Inc., Portsmouth, Virginia Site, Volume
III, prepared by Keystone Environmental Resources,
Inc., 1/92. P. 301959-302563.
14. Letter to Mr. Timothy A. Longe, Virginia Department of
Environmental Quality, from Mr. David lacono, U.S. EPA,
re: Reguest for applicable or relevant and appropriate
reguirements (ARARs) for the Atlantic Wood Industries,
Inc. Site, 1/26/95. P. 302564-302565.
15. Letter to Mr. David lacono, U.S. EPA, from Mr. Paul L.
Spaulding, Virginia Department of Environmental
Quality, re: Notification that the Virginia ARARs were
previously provided to EPA in the February 1994,
Feasibility Study, 3/2/95. P. 302566-302566.
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16. Letter to Mr. David lacono, U.S. EPA, from Mr. Ross F.
Worsham, Atlantic Wood, Inc., re: Request for a 30-day
extension of the public comment period for the Proposed
Remedial Action Plan, 6/22/95. P. 302567-302567.
17. Memorandum to Mr. David lacono, U.S. EPA, from Mr. Roy
L. Smith, U.S. EPA, re: Documentation of EPA's
reasoning in determining the acceptability of post-
remedial human health risks, 7/26/95. P. 302568-
302582.
18. Letter to Mr. Harry S. Harbold, U.S. EPA, from Mr.
Robert J. Anderson, Keystone Environmental Resources,
Inc., re: Response to regulatory comments on the May
2, 1990, draft Remedial Investigation Report, 6/29/90.
P. The comments of the EPA, Virginia Department of
Environmental Quality, and the National Oceanic and
Atmospheric Administration (NOAA) are attached.
19. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Mr. Drew Lausch, U.S. EPA, re: Transmittal
of regulatory comments on the draft Remedial
Investigation Report and disapproval of the report,
6/21/91. P. The following are attached:
a) comments on the Remedial Investigation Report;
b) a list of environmental areas of concern;
c) the scope of additional remedial
investigation work required at the site;
d) a set of calculations and methodology for
estimating shower air concentrations and
inhalation exposures at the site.
20. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Mr. Drew Lausch, U.S. EPA, re: EPA's
approval of Atlantic Wood Industry, Inc.'s request for
time extensions for the submittal of the revised
Remedial Investigation Report and additional remedial
investigation tasks, 7/23/91. P.
21. Letter to Mr. Drew Lausch, U.S. EPA, from Mr. Jeffrey
Smigel, Atlantic Wood Industries, Inc., re:
Notification that Atlantic Wood Industry, Inc. is
ceasing operations at its Portsmouth, Virginia plant,
8/2/91. P.
22. Letter to Mr. Drew Lausch, U.S. EPA, from Mr. Jeffrey
Smigel, Atlantic Wood Industries, Inc., re:
Notification that Atlantic Wood Industry, Inc. agrees
to perform additionaltasks related to the remedial
investigation as requested by EPA, and that the tasks
will be defined in an addendum to the work plan,
8/23/91. P.
23. Letter to Mr. Drew Lausch, U.S. EPA, from Ms. Diane E.
McCausland, Keystone Environmental Resources, Inc., re:
Transmittal of the Supplemental Remedial Investigation
Work Plan, 9/20/91. P.
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24. Letter to Mr. Drew Lausch, U.S. EPA, from Ms. Diane E.
McCausland, Keystone Environmental Resources, Inc., re:
Transmittal of the draft Interim Soil Clean Up Goals
Report, 10/22/91. P.
25. Letter to Ms. Diane E. McCausland, Keystone
Environmental Resources, Inc., from Mr. Drew Lausch,
U.S. EPA, re: Discussion of preparation of the draft
Feasibility Study Report, 11/8/91. P. A summary of
the findings from a request for technical assistance
support and a copy of a journal of applied technologies
for remediation are attached.
Letter to Mr. Ross F. Worsham, Atlantic Wood Industry,
Inc., from Mr. Drew Lausch, U.S. EPA, re: Transmittal
of regulatory comments concerning the revised Remedial
Investigation Report, 12/12/91. P. The comments and a
table of ambient marine water quality criteria are attached.
27. Letter to Mr. Ross F. Worsham, Atlantic Wood Industry,
Inc., from Mr. Drew Lausch, U.S. EPA, re: Comments
concerning the Interim Clean Up Goals Report, 12/23/91.
P. A list of references is attached.
28. Letter to Mr. Drew Lausch, U.S. EPA, from Ms. Diane E.
McCausland, Keystone Environmental Resources, Inc., re:
Transmittal of the Remedial Investigation Report and a
response to specific EPA comments in a letter, dated
December 16, 1991, 1/14/92. P.
29. Letter to Mr. Drew Lausch, U.S. EPA, from Ms. Diane E.
McCausland, Keystone Environmental Resources, Inc., re:
Transmittal of the Risk-Based Soil Clean Up Levels
Study, 3/3/92. P. A title page to the report is attached.
30. Letter to Mr. Ross F. Worsham, Atlantic Wood Industry,
Inc., from Mr. Drew Lausch, U.S. EPA, re: Notification
that some regulatory comments concerning the second and
third revisions of the Remedial Investigation Report
still need to be addressed, 3/12/92. P. A summary of
Keystone Environmental Resources, Inc.'s responses to
regulatory comments and a list of regulatory comments
that still need to be addressed are attached.
31. Letter to Mr. Ross F. Worsham, Atlantic Wood Industry,
Inc., from Mr. Drew Lausch, U.S. EPA, re: Request for
a revised schedule for submission of the Feasibility
Study, 3/12/92. P.
32. Letter to Mr. Drew Lausch, U.S. EPA, from Ms. Diane E.
McCausland, Keystone Environmental Resources, Inc., re:
Transmittal of the final Interim Soil Clean Up Goals
Report, 3/13/92. P. The report is attached.
33. Letter to Mr. Drew Lausch, U.S. EPA, from Ms. Diane E.
McCausland, Keystone Environmental Resources, Inc., re:
Transmittal of a schedule for the Feasibility Study,
3/19/92. P.
-------
34. Letter to Mr. Drew Lausch, U.S. EPA, from Ms. Diane E.
McCausland, Keystone Environmental Resources, Inc., re:
Transmittal of revised pages for the Remedial
Investigation Report and specific responses to EPA's
additional comments, 3/23/92. P.
35. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Ms. Kimberly A. Hummel, U.S. EPA, re: EPA's
displeasure with the progress of the Feasibility Study
and the required removal action at the site, and
transmittal of a set of deadlines to complete this
work, 4/5/92. P.
36. Letter to Mr. Ross F. Worsham, Atlantic Wood Industry,
Inc., from Mr. Drew Lausch, U.S. EPA, re: Transmittal
of the final Ecological Risk Assessment, 4/13/92. P.
The title page to the report is attached.
37. Letter to Mr. Ross F. Worsham, Atlantic Wood Industry,
Inc., from Mr. Drew Lausch, U.S. EPA, re: Final
approval of the Remedial Investigation Report, 4/16/92. P.
38. Letter to Ms. Kimberly A. Hummel, U.S. EPA, from Mr.
Jeffrey Smigel, Atlantic Wood Industries, Inc., re:
Response to EPA's letter of April 5, 1992, concerning
Atlantic Wood Industry, Inc.'s compliance with
established time schedules, 4/16/92. P.
39. Letter to Ms. Kimberly A. Hummel, U.S. EPA, from Ms.
Diane E. McCausland, Keystone Environmental Resources,
Inc., re: Transmittal of an outline for the
Feasibility Study, 4/29/92. P. The outline is attached.
40. Memorandum to Mr. Robert Davis, Biological Technical
Assistance Group (BTAG), from Mr. Peter Knight, NOAA,
re: Review and comments on the Feasibility Study,
6/23/92. P.
41. Memorandum to Mr. Robert Davis, BTAG, from Mr. Peter
Knight, NOAA, re: Additional comments concerning the
Feasibility Study, 7/9/92. P.
42. Letter to Ms. Kimberly Hummel, U.S. EPA, from Mr.
Jeffrey Smigel, Atlantic Wood Industries, Inc., re:
Transmittal of responses to regulatory comments to the
Feasibility Study and a rationale for Atlantic Wood
Industry, Inc.'s approach to the Feasibility Study,
11/22/93. P. The comments are attached.
43. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Ms. Kimberly Hummel, U.S. EPA, re: EPA's
disapproval of the Feasibility Study, 11/23/93. P.
The regulatory comments on the Feasibility Study and
EPA Region Ill's risk-based concentration table are attached.
44. Letter to Mr. David J. lacono, U.S. EPA, from Mr. D.
Randolph Grubbs, Gannett Fleming, Inc., re:
Transmittal of notes summarizing a December 17, 1993,
meeting with representatives of Atlantic Wood Industry,
Inc., EPA, and the Virginia Department of Environmental
Quality, 12/29/93. P. The notes and a list of
attendees to the meeting are attached.
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45. Letter to Mr. David J. lacono, U.S. EPA, from Ms. Diane
E. McCausland, Chester Environmental, re: Summary of a
December 17/ 1993 meeting between the representatives
of Atlantic Wood Industry, Inc., EPA, and the Virginia
Department of Environmental Quality, 1/3/94. P.
46. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Mr. David J. lacono, U.S. EPA, re:
Notification that EPA may impose previously stipulated
penalties on Atlantic Wood Industry, Inc. for the late
submission of the Feasibility Study, 1/25/94. P.
47. Letter to Mr. David J. lacono, U.S. EPA, from Ms. Diane
E. McCausland, Chester Environmental, re: Transmittal
of a response to regulatory comments concerning the
Feasibility Study Report, 2/16/94. P. The responses
are attached.
48. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Mr. David J. lacono, U.S. EPA, re: EPA's
disapproval of the revised Feasibility Study, 5/13/94.
P. The regulatory comments on the Feasibility Study
are attached.
49. Letter to Mr. David J. lacono, U.S. EPA, from Mr.
Jeffrey Smigel, Atlantic Wood Industries, Inc., re:
Initiation of dispute resolution procedures with regard
to EPA's disapproval of the Feasibility Study and a
request for the extension of the period of dispute
resolution, 5/24/94. P.
50. Letter to Mr. David J. lacono, U.S. EPA, from Mr.
Jeffrey Smigel, Atlantic Wood Industries, Inc., re:
Transmittal of responses to regulatory comments
concerning the Feasibility Study, 6/3/94. P. The
responses are attached.
51. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Mr. David J. lacono, U.S. EPA, re:
Notification that EPA will expand the period for the
dispute resolution, 6/16/94. P.
52. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Mr. David J. lacono, U.S. EPA, re:
Notification of an August 8, 1994, deadline to re-
submit the Feasibility Study, conditions for the
resubmission, and transmittal of the regulatory
comments to Atlantic Wood Industry, Inc.'s June 3,
1994, responses, 7/8/94. P. The comments are attached.
53. Letter to Mr. David J. lacono, U.S. EPA, from Mr. David
L. King and Mr. Anthony Collins, Chester Environmental,
re: Response to regulatory comments of July 8, 1994,
and the rationale for Chester Environmental's
disagreement with the regulatory agencies concerning
ecological issues, 8/24/94. P.
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54. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Mr. David J. lacono, U.S. EPA, re:
Transmittal of EPA's comments concerning the
Feasibility Study and notification of a March 6, 1995
deadline for submission of the revised and final
Feasibility Study along with guidelines for that
submittal, 2/3/95. P.
55. Letter to Mr. David J. lacono, U.S. EPA, from Mr.
Jeffrey Smigel, Atlantic Wood Industries, Inc., re:
Notification that Atlantic Wood Industry, Inc. is
initiating dispute resolution regarding EPA' s February
3, 1995, disapproval of the Feasibility Study, 2/17/95. P.
56. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Ms. Kathryn A. Hodgkiss, U.S. EPA, re:
Transmittal of EPA's decision resolving ecological
issues brought up in the dispute resolution process and
notification that the deadline for submission of the
Feasibility Study is extended to March 20, 1995,
3/3/95. P.
57. Letter to Ms. Kathryn A. Hodgkiss, U.S. EPA, from Mr.
Jeffrey Smigel, Atlantic Wood Industries, Inc., re:
Atlantic wood Industry, Inc.'s response to EPA's
resolution of the disputed ecological issues, 3/9/95.
P. A limited review of clean-up levels from the Record
of Decision (ROD) database, and a report on sediment
guality and the sedimentation process are attached.
58. Letter to Mr. David J. lacono, U.S. EPA, from Mr. David
L. King, Groundwater Technology, Inc., re: Transmittal
of responses to EPA's February 3, 1995, comments on the
Feasibility Study, 3/17/95. P. The comments are attached.
59. Letter to Mr. Jeffrey Smigel, Atlantic Wood Industries,
Inc., from Ms. Kathryn A. Hodgkiss, U.S. EPA, re:
Notification that EPA will extend the deadline for
submission of the Feasibility Study to April 3, 1995,
and EPA's rationale in developing clean-up goals,
3/29/95. P.
60. Letter to Mr. David J. lacono, U.S. EPA, from Mr.
Thomas D. Modena, Virginia Department of Environmental
Quality, re: Review and comments for the Proposed
Remedial Action Plan, 5/23/95. P.
61. Letter to Mr. David J. lacono, U.S. EPA, from P. A.
Rakowski, Department of the Navy, re: Transmittal of
comments concerning the Proposed Remedial Action Plan,
8/4/95. P. The comments are attached.
62. Letter to Mr. David J. lacono, U.S. EPA, from Mr.
Jeffrey Smigel, Atlantic Wood Industries, Inc., re:
Transmittal of Atlantic Wood Industry, Inc.'s comments
concerning the Proposed Remedial Action Plan, 8/7/95.
P. The comments are attached.
63. Letter to Mr. David J. lacono, U.S. EPA, from Mr. David
L. King, Groundwater Technology, Inc., re: Transmittal
of Atlantic Wood Industry, Inc.'s response to EPA's
technical reservation concerning the Feasibility Study,
8/7/95. P. The response is attached.
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IV. REMOVAL RESPONSE PROJECTS
1. Report: Erosion and Sediment Control Plan, prepared by
Chester Environmental, 9/94. P. 400001-400019.
2. Report: Health and Safety Plan, Storm Drain
Sealing/Lining and Sediment Response Action,
Portsmouth, Virginia, prepared by Chester
Environmental, 10/94. P. 400020-400131.
3. Report: Response Action Plan, Elm Avenue Storm Drain
Portsmouth, Virginia Site, prepared by Chester
Environmental, 10/94. P. 400132-400168.
4. Report: Alternatives Screening Document for Sediment
Response Action, Portsmouth, Virginia Site, prepared by
Chester Environmental, 9/94. P. 400169-400208.
5. Letter to Mr. Jeffrey A. Smigel, Atlantic Wood
Industries, from Mr. David J. lacono, U.S. EPA, re:
EPA comments on the Alternative Screening Document for
Sediment Response Action and conditional acceptance of
the Erosion and Sediment Control Plan, 10/27/94.
P. 400209-400214. Comments of the Virginia Superfund
Remedial Program on the Sediment Response Action Plan
are attached.
6. Report: Sediment Response Action Plan, Portsmouth,
Virginia Site, prepared by Chester Environmental, 1/95.
P. 400215-400250.
7. Report: Site Activities Report/Response Action Plan
for Elm Avenue Storm Drain, prepared by Groundwater
Technology, Inc., 4/95. P.
V. COMMUNITY INVOLVEMENT/CONGRESSIONAL CORRESPONDENCE/IMAGERY
1. Final Community Relations Plan, Atlantic Wood
Industries Site, Portsmouth, Virginia, 2/18/88.
P. 500001-500026.
2. U.S. EPA Quick Reference Fact Sheet: Superfund
Technical Assistance Grants, 9/93. P. 500027-500032.
3. Letter to Mr. Chuck Anderson, Chesapeake Public
Library, from Ms. Lisa M. Brown, U.S. EPA, re:
Information on the Technical Assistance Grants,
2/10/95. P. 500033-500033.
4. Letter to Mr. Dean Burgess, Portsmouth Municipal
Library, from Ms. Lisa M. Brown, U.S. EPA, re:
Information on the Technical Assistance Grants,
2/10/95. P. 500034-500034.
5. Letter to Mr. Jerry Drye, Kirn Memorial Library, from
Ms. Lisa M. Brown, U.S. EPA, re: Information on the
Technical Assistance Grants, 2/10/95. P. 500035-500035.
6. EPA Public Information Sheet, re: Establishment of an
(800) number for information on Superfund sites,
(undated). P. 500036-500036.
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7. U.S. EPA Public Notice, re: The availability of the
Administrative Record, The Virginian-Pilot and The
Ledger Star, 2/5/95. P. 500037-500037.
8. U.S. EPA Fact Sheet, re: Removal action to begin at
the site, 3/95. P. 500038-500041.
9. U.S. EPA Fact sheet, re: EPA's release of the Proposed
Plan for the Atlantic Wood Industries, Inc. Site, 6/95.
P. 500042-500047.
10. Transcript of public meeting, Atlantic Wood Industries,
Inc. Site, 6/27/95. P. 500048-500110.
11. U.S. EPA Public Notice, re: EPA extension of the
comment period for the site, The Virginian-Pilot and
The Ledger Star, 7/12/95. P. 500111-500111.
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APPENDIX B
GLOSSARY
Administrative Order on Consent (AOC) - A legal agreement signed by EPA and an individual, business, or other
entity through which the violator agrees to pay for correction of violations, take the reguired corrective or
cleanup actions, or refrain from an activity. It describes the actions to be taken, may be subject to a
comment period, applies to civil actions, and can be enforced in court.
Administrative Record - EPA's official compilation of documents, data, reports, and other information
supporting selection of a response action. The record is placed in the information repository to allow
public access to the material.
Anadromous - Fish that migrate from the sea up a river to spawn.
Aguatic - Living or growing in the water.
Aguifer - An underground geologic formation, or group of formations, containing useable amounts of ground
water that can supply wells and springs.
ARARS - Applicable, Relevant and Appropriate Reguirements:
Applicable reguirements are those cleanup standards, standards of control, and other substantive
environmental protection reguirements, criteria, or limitations promulgated under Federal or State law that
specifically address a hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site.
Relevant and Appropriate reguirements are those same standards mentioned above that while not "applicable" at
the CERCLA site, address problems or situations sufficiently similar to those encountered at the site that
their use is well suited to the particular site.
Background - The average concentration of a contaminant in the Site area either naturally occurring or from
external sources unrelated from the Site.
Bioremediation, or Biological Treatment - Generally refers to the breakdown of organic compounds
(contaminants) by micro-organisms.
Carcinogenic - The ability to cause cancer.
Catadromous - Fish that migrate down a river to the sea to spawn. The opposite of anadromous.
CERCLA - See SUPERFUND below.
Creosote - A dark oily liguid having a penetrating tarry odor, obtained by the distillation of wood tar and
commonly used as a wood-treating preservative.
Dense Non-Agueous Phase Liguid (DNAPLs) - Chemical compounds that are heavier than water in their pure form.
DNAPL can be described as a heavy liguid that exists in certain areas below the ground at a site and can also
be thought of as creosote-soaked subsoils.
Feasibility Study - See RI/FS.
Ground water - Water found beneath the earth's surface that fills pores between soil, sand, and gravel
particles to the point of saturation. Groundwater often flows more slowly than surface water. When it
occurs in sufficient guantity, groundwater can be used as a water supply.
Hazard Index (HI) - The HI is the measurement expressing the overall potential for non-carcinogenic effects
posed by contaminants. An HI greater than 1 is characterized as presenting an unacceptable non-carcinogenic
risk.
Information Repository - A location where documents and data related to the Superfund project are placed by
EPA to allow access to the material by the public.
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In situ Bioremediation - The process of enhancing the microbial degradation of contaminants in subsurface
soil and water without excavation of the contaminated soil. Nutrients and microorganisms may be added to
stimulate biodegradation.
Low Temperature Thermal Desorption (LTTD) - Contaminated soils/sediments are heated at low temperatures to
volatilize water and organic contaminants. A carrier gas or vacuum system transports volatilized water and
organics to a gas treatment system. The contaminants are not destroyed, rather they are physically separated
from the soils and concentrated in a vapor treatment system before being disposed of.
MCL - The Maximum Contaminant Level or MCL is the maximum permissible level of a contaminant in water which
is delivered to any user of a public water system.
Micrograms per liter (• g/1) - Parts per Billion. For example, 5 ppb would be 5 parts in 1 billion parts.
For liguids (groundwater and surface water) ppb is based on volume. Example: 5 tablespoons of a contaminant
in a billion tablespoons (3,906,250 gallons) of water.
National Oil and Hazardous Substances Pollution Contingency plan (NCP) - The federal regulation that guides
determination of the sites to be corrected under the Superfund program and the program to prevent or control
spills into surface waters or other portions of the environment.
National Pollutant Discharge Elimination System (NPDRS) - A provision of the Clean Water Act which prohibits
discharge of pollutants into waters of the United States unless a special permit is issued by EPA, a state,
or (where delegated) a tribal government on an Indian reservation.
National Priorities List {NPL) - EPA's list of the most serious uncontrolled or abandoned hazardous waste
sites identified for possible long-term remedial action under Superfund. A site must be on the NPL to
receive money from the Trust Fund for remedial action. The list is based primarily on the score a site
receives from the Hazard Ranking System. EPA is reguired to update the NPL at least once a year.
Organic Compounds - Animal or plant-produced substances containing mainly carbon, hydrogen, and oxygen.
PAHs, pentachlorophenol, and dioxins are all organic compounds. Some organic compounds can cause cancer.
Pentachlorophenol (PCP) - An organic compound commonly used as a wood preservative.
Polynuclear Aromatic Hydrocarbons (PAR) - A class of organic compounds originating from creosote and commonly
used as a wood preservative.
ppb - Parts per billion. For example, five parts per billion is a fractional representation of five parts in
one billion parts. For solids, ppb is a fraction based on weight, for example five pounds of a contaminant in
a billion pounds (500,000 tons) of soil. For liguids ppb is based on volume, for example five tablespoons of
a contaminant in a billion tablespoons (3,906,250 gallons) of water.
ppm - Parts per Million. One ppm is a fractional representation of one part in one million parts.
RCRA (Resource Conservation and Recovery Act) - A statute at 42 U.S.C. §§ 6901 et. seg. under which EPA
regulates the management of hazardous waste.
Record of Decision (ROD) - A legal decision document that describes the remedial actions selected for a
Superfund site, why certain remedial action(s) were chosen as opposed to others, how much they will cost, and
how the public's comments about the Proposed Plan were incorporated into the final decisional
document.
Recovery Well - A well used to extract contaminated ground water or product from an aguifer for subseguent
treatment or disposal.
Remedial Investigation and Feasibility Study (RI/PS) - An in-depth study designed to gather the data
necessary to determine the nature and extent of contamination at a Superfund site; establish criteria for
cleaning up the site; identify preliminary alternatives for remedial actions; and support the technical and
cost analyses of the alternatives. The remedial investigation is usually done with the feasibility study.
Together they are usually referred to as the "RI/FS".
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Risk Assessment (RA) - The qualitative and quantitative evaluation performed in an effort to define the risk
posed to human health and/or the environment by the presence or potential presence and/or use of specific
pollutants.
Scientific Notation - In dealinq with particularly larqe or small numbers, scientists and enqineers have
developed a "short hand" means of expressinq numerical values. For example: 1,000,000 can be written as 1 x
106 and 1/1,000,000 can be written as 1 x 10-6.
SUPERFUND (Comprehensive Environmental Response, Compensation, and Liability Act) - The proqram operated
under the leqislative authority of CERCLA and SARA that funds and carries out the EPA solid waste emerqency
and lonq-term removal remedial activities. These activities include establishinq the National Priorities
List, investiqatinq sites for inclusion on the list, determininq their priority level on the list, and
conductinq and/or supervisinq the ultimately determined cleanup and other remedial activities.
Surface Water - All water naturally open to the atmosphere (rivers, lakes, reservoirs, streams, impoundments,
seas, estuaries, etc.) and all sprinq wells, or other collectors which are directly influenced by surface
water.
Terrestrial - Growinq or livinq on the qround.
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APPENDIX C
CROSS REFERENCE BETWEEN PROPOSED PLAN ALTERNATIVE NUMBERS AND FEASIBILITY
STUDY REPORT ALTERNATIVE NUMBERS FOR REMEDIAL RESPONSE UNITS 1 THROUGH 5
Proposed Plan
Alternative Number
1: No Action
Feasibility Study Report Alternative Number
RRU 1
1
RRU 2
1
RRU 3
1
RRU 4 RRU 5
1 1
2: Excavation and On- 11
Site Landfilling
3: Excavation and Off- 12
Site Landfill
10
n/a
n/a
n/a
n/a
4: Soil Capping
5: In Situ Bioremediation
6: Excavation and On-
Site Biological Slurry
Treatment of
Soil/S ediment
7: Excavation and
Engineering Land
Treatment of
Soil/S ediment
8: Excavation and On-
Site Incineration of
Soil/S ediment
9: Excavation and On-
Site Low Temperature
Thermal Desorption of
Soil/S ediment
10: Excavation and Off-
Site Incineration of
Soil/S ediment
11: Extracting DNAPL for
Reuse
n/a
4
5A (for On-Site
Landfill)
5B (for Off-Site
Landfill)
5C (for Backfill)
7A (for On-Site
Landfill)
7B (for Off-Site
Landfill)
7C (for Backfill)
8A (for On-Site
Landfill)
8B (for Off-Site
Landfill)
8C (for Backfill)
9A (for On-Site
Landfill)
9B (for Off-Site
Landfill)
9C (for Backfill)
10
n/a
n/a n/a n/a 3
n/a n/a n/a n/a
3A (for On-Site n/a n/a n/a
Landfill)
3B (for Off-Site
Landfill)
3C (for Backfill)
3A (for On-Site
Landfill)
3B (for Off-Site
Landfill)
3C (for Backfill)
3A (for On-Site
Landfill)
3B (for Off-Site
Landfill)
3C (for Backfill)
3A (for On-Site
Landfill)
3B (for Off-Site
Landfill)
3C (for Backfill)
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
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