Superfund Record of Decision Marine Corps Combat Development Command Site 4 Ou 4 Quantico VA


                                    EPA/ROD/R03-97/093
                                    1997
EPA Superfund
     Record of Decision:
     MARINE CORPS COMBAT DEVELOPMENT
     COMMAND
     EPA ID: VA1170024722
     OU04
     QUANTICO, VA
     09/30/1997

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EPA/541/R-97/093

                           RECORD OF DECISION

                                  FOR

                         OLD LANDFILL - SITE 4

                        INTERIM REMEDIAL ACTION



                 MARINE CORPS COMBAT DEVELOPMENT COMMAND
                           QUANTICO, VIRGINIA

                             SEPTEMBER 1997

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                        DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

     Old Landfill, Site 4, Operable Unit 4
     Marine Corps Combat Development Command  (MCCDC)
     Quantico, Virginia

STATEMENT OF BASIS AND PURPOSE

     This Record of Decision  (ROD) presents the selected Interim Remedial Action  (IRA) for the Old Landfill,
Installation Restoration  (IR) Site 4, Operable Unit 4 (OU4), MCCDC, Quantico, Virginia. For consistency, this
ROD will refer to the site as the Old Landfill,Site 4. The selected IRA was chosen in accordance with the
reguirements of the Comprehensive Environmental Response, Compensation, and Liability Act  (CERCLA) of 1980,
as amended by the Superfund Amendments and Reauthorization Act  (SARA)  of 1986, 42 U.S.C. Section 9601 et
seg.,  and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP,  40 CFR Part 300).  This ROD provides the factual basis for selecting the IRA for the Old Landfill and
the rationale for the decision. The information supporting this IRA decision is contained in the
Administrative
Record for this site.

     The Commonwealth of Virginia, Department of Environmental Quality (VDEQ) supports the selected IRA.

ASSESSMENT OF THE SITE

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

DESCRIPTION OF THE SELECTED REMEDY

     This action is the third for the Old Landfill. The first action,  a Removal Action  (RA),  was conducted in
1990 to remove polychlorinated biphenyl  (PCB) contaminated soil from the Defense Reutilization and Marketing
Office (DRMO) Scrapyard and DRMO Transformer Storage Area, located within the Old Landfill boundary.
Approximately 3,800 tons of contaminated soil and scrap were removed and disposed of off-site during that
action.

     The second action,  an erosion and sediment control Removal Action, was implemented in 1994 to reduce the
amount of PCB contaminated sediment and surface water runoff leaving the Old Landfill and entering the
Potomac River. That action included:

•       Installation of silt fence, hay bales, rip rap, and berms to prevent contaminated
       soils and sediments from migrating;

•       Scarifying the blacktop area on the west side of the Old Landfill to increase
       infiltration and reduce the runoff from entering the drainage swale; and

•       Collection of monthly surface water samples from the drainage swale outfall to
       monitor discharges to the Potomac River.

     The selected IRA addresses the known principal threats posed by the site, which are contaminated soils
and sediments in and surrounding the drainage swale. This IRA will: minimize direct contact,  inhalation, and
ingestion of contaminants posing a carcinogenic risk; reduce migration of contaminants to groundwater;
restrict migration of contaminants to the adjacent embayment; and comply with all Applicable or Relevant and
Appropriate Reguirements directly associated with this action. This selected IRA will be followed by further
investigations and a final remedy. It is anticipated that the IRA will be consistent
with the final remedy.

     The major components of the IRA include:

       •       Institutional controls,  to include no breaching of the barrier layer,  fencing around
              the entire site with locked gates, and restricting access by unauthorized personnel;

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       •      Consolidation of existing berms,  demolition and off-site disposal of scrapyard
              buildings,  and incorporation of scrapyard building foundations within the Old Landfill;

       •      Excavation and off-site disposal  of surface soil and drainage swale sediments
              contaminated with PCBs in excess  of 10 parts per million (ppm) ;

       •      Permeable soil barrier layer installation covering 23 acres,  and incorporation of
              flood control measures and shore  protection;

       •      Successful  replacement and restoration of wetlands destroyed/impacted by the
              implementation of the IRA (1.8 acres impacted vs. 2.1 acres replaced), including
              ensuring the replacement and restoration is successful,  through continued
              monitoring and other appropriate  measures;

       •      Operation and maintenance; and

       •      Five-year reviews as reguired by  CERCLA.

     Final-use restrictions will be addressed in the final remedy. Until that time, institutional controls,
to include no breaching of the barrier layer, fencing around the entire site with locked gates, and
restricting access by unauthorized personnel, will be employed by the Navy as protection. No invasive
development of the landfill area will be allowed.

     In addition, operations and maintenance (O&M) will be performed in accordance with the Virginia Solid
Waste Management Regulations  (VSWMR °5.0). This O&M will include an annual inspection of the cover, initiated
within one year of completion of the IRA.  O&M will include, at a minimum, the following items:

       •      Performance standards to assure integrity of the barrier layer;

       •      Erosion control;

       •      Wetland monitoring;  and

       •      Inspection and maintenance as applicable.

STATUTORY DETERMINATIONS

     This IRA is protective of human health and the environment in the short term and is intended to provide
adeguate protection until a final ROD is issued complies with Federal and State ARARS for this limited-scope
action, and is cost effective. This action is interim and is not intended to utilize permanent solutions and
alternative treatment technologies to the maximum extent practicable for this operable unit. Because this
action does not constitute the final remedy for the operable unit, the statutory preference for remedies that
employ treatment that reduces toxicity, mobility or volume as a principal element need not be satisfied and
will be addressed by the final response action. Subseguent actions are planned to address fully the threats
posed by the conditions at this operable unit.

     Because this remedy will result in hazardous substances remaining on site above health-based levels, a
review will be conducted to ensure that the remedy continues to provide adeguate protection of human health
and the environment within five years after commencement of the remedial action. Because this is an interim
action ROD, review of this site and of this interim remedy will be on-going as the Navy and USEPA continue to
develop final remedial alternatives for the operable unit.

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                                   TABLE OF CONTENTS

SECTION                                                                          PAGE

ACRONYMS                                                                           ix

1.0   SITE NAME, LOCATION AND DESCRIPTION                                         1-1

2.0   SITE HISTORY AND ENFORCEMENT ACTIVITIES                                     2-1

      2.1    History                                                              2-1
      2.2    Present Condition of the Old Landfill                                2-3
      2.3    Previous Investigations                                              2-4
      2.4    Enforcement Actions                                                  2-4

3.0   HIGHLIGHTS OF COMMUNITY PARTICIPATION                                       3-1

4.0   SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION                          4-1

5.0   SITE CHARACTERISTICS                                                        5-1

      5.1    Contaminants at the Old Landfill                                     5-1
      5.2    Potential Route of Contaminant Migration and Route of Exposure       5-1
      5.3    Population and environmental areas that could be affected by the     5-1
             contaminants at the site
      5.4    Site Specific Factors that may affect the Interim Remedial Action    5-3
      5.5    Shoreline Excavation                                                 5-3
      5.6    Shoreline Protection                                                 5-6

6.0   SUMMARY OF SITE RISKS                                                       6-1

      6.1    Human Health Risks                                                   6-1
      6.2    Risk Assessment Uncertainties                                        6-2
      6.3    Exposure Assessment                                                  6-3
      6.4    Risk Characterization                                                6-3
      6.5    Ecological Risk                                                      6-4

7.0   DESCRIPTION OF IRA ALTERNATIVES                                             7-1

      7.1    Alternative 1: Barrier Layer Implementation                          7-1
      7.2    Alternative 2: Clay Cap                                              7-2
      7.3    Alternative 3: Excavation/Off-site Incineration                      7-3
      7.4    Alternative 4: No Action                                             7-4

8.0   SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES                             8-1

      8.1    Overall Protection of Human Health and the Environment               8-1
      8.2    Compliance with Applicable and Relevant and Appropriate              8-2
             Reguirements
      8.3    Long-Term Effectiveness and Permanence                               8-2
      8.4    Reduction of Toxicity, Mobility or Volume through Treatment          8-2
      8.5    Short-term Effectiveness                                             8-2
      8.6    Implementability                                                     8-3
      8.7    Cost                                                                 8-4
      8.8    State Acceptance                                                     8-4
      8.9    Community Acceptance                                                 8-4
      8.10   Summary of Detailed Evaluation                                       8-4

9.0   SELECTED REMEDY                                                             9-1

      9.1    Remediation Reguirements                                             9-1
      9.2    Institutional Controls                                               9-2
      9.3    Operations and Maintenance                                           9-2

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      9.4    Performance Standards                                                9-3
      9.5    Cost of Selected Remedy                                              9-4

10.0      STATUTORY DETERMINATIONS                                               10-1

        10.1   Overall Protection of Human Health and the Environment            10-1
        10.2   Compliance with Applicable or Relevant and Appropriate            10-2
               Re qui rement s
        10.3   Cost Effectiveness                                                10-2
        10.4   Utilization of Permanent Solutions and Alternative Treatment      10-3
               Technologies  (or Resource Recovery Technologies) to the
               Maximum Extent Practicable
        10.5   Preference for Treatment as a Principal Element                   10-3

11.0      SIGNIFICANT CHANGES                                                    11-1

12.0      REFERENCES                                                             12-1

APPENDIX A: RESPONSIVENESS SUMMARY                                                A-l

                                       LIST OF FIGURES

FIGURE                                                                           PAGE

1-1    Location Map of MCCDC, Quantico and the Old Landfill                       1-2
1-2    Old Landfill Site Map                                                      1-3
5-1    Old Landfill Sediment Sample Locations                                     5-4

                                       LIST OF TABLES

TABLE                                                                            PAGE

5-1    Old Landfill Contaminants                                                  5-2
8-1    Cost Summary                                                               8-4
10-1   ARARs (Chemical, Location and Action Specific)                            10-4

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ACRONYMS

ARARs     Applicable or Relevant and Appropriate Regulations
AWQC      Ambient Water Quality Criteria
BTAG      Biological Technical Assistance Group
CERCLA    Comprehensive Environmental Response, Compensation, and Liability Act
CFR       Code of Federal Regulations
CLEAN     Comprehensive Long-Term Environmental Action Navy
COE       United States Corps of Engineers
DDD       Dichlorodiphenyldichloroethane
DDE       Dichlorodiphenylethane
DDT       Dichlorodiphenyltrichloroethane
DRMO      Defense Reutilization and Marketing Office
EFACHES   Engineering Field Activity Chesapeake
FFS       Focused Feasibility Study
FS        Feasibility Study
HNUS      Halliburton NUS Corporation
IAS       Initial Assessment Study
IR        Installation Restoration
IRA       Interim Remedial Action
IRP       Installation Restoration Program
MCCDC     Marine Corps Combat Development Command
NCP       National Oil and Hazardous Substances Pollution Contingency Plan
NPDES     National Pollutant Discharge Elimination System
NPL       National Priorities List
PCB       Polychlorinated Biphenyl
RA        Removal Action
RAA       Remedial Action Alternative
RAG       Remedial Action Contract
RCRA      Resource Conservation and Recovery Act
RI        Remedial Investigation
ROD       Record of Decision
SARA      Superfund Amendments and Reauthorization Act
TBC       To Be Considered
TPH       Total Petroleum Hydrocarbon
TSCA      Toxic Substance Control Act
USEPA     United States Environmental Protection Agency
USFWS     United States Fish and Wildlife Service
VDEQ      Commonwealth of Virginia, Department of Environmental Quality
VMRC      Virginia Marine Resources Commission
VPDES     Virginia Pollution Discharge Elimination System

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1.0 SITE NAME, LOCATION AND DESCRIPTION

The Marine Corps Combat Development Command (MCCDC), Quantico, Virginia is a 60,000 acre Marine Corps
installation located in southern Prince William, northern Stafford and eastern Fauquier Counties, Virginia
and is bordered on the east by the Potomac River. Figure 1 provides a location map for the Base and for the
Old Landfill. The installation has been in operation since 1917 and is currently bordered by residential,
park, farmland and commercial properties. The installation is located approximately 35 miles south of
Washington, DC and is divided by Interstate 95 into two areas: Mainside (east of 1-95) and Guadalcanal (west
of 1-95) .

The Old Landfill is located on the Mainside Area, adjacent to the Potomac River. The Old Landfill is
bordered on the north by the Mainside Sewage Treatment Plant, to the south by the Marine Corps Air Facility
and to the west by the Richmond, Fredericksburg and Potomac Railroad. The Town of Quantico is located
approximately 1/2 mile north of the Old Landfill.

The Old Landfill is 23 acres in size and was operated from 1920 to 1971. Concurrent to and after
landfill operations ceased, it was also used as a scrapyard operated by the Defense Property Disposal Office
and later the Defense Reutilization and Marketing Office (DRMO). In addition to the DRMO Scrapyard, there was
also an area designated as the DRMO Transformer Storage Area. Existing structures at the Old Landfill
included Buildings 671 and 672 (and associated concrete foundations) in the DRMO Scrapyard and Building 679,
680, and several concrete loading structures at the DRMO Transformer Storage Area. Presently, the Old
Landfill is partially covered with forest, open fields, paved and graveled areas, and is partially surrounded
by a chain link fence. Figure 2 provides a layout of the Old Landfill.

The Old Landfill is located adjacent to the Potomac River and within its floodplain. The ground surface
elevation at the Old Landfill ranges from 1 to 20 feet above mean sea level. The Potomac River water surface
elevation is tidally influenced and approximates mean sea level. Drainage from the area is channelized into
two primary paths: the drainage swale and the unnamed tributary. The entire Old Landfill site lies within the
Atlantic Coastal Plain Physiographic Province. The geology consists of an eastward
thickening wedge of sand, silt and clay sediments. The surface soil consists of artificial fill to a depth of
approximately eight feet below ground surface. River deposits are encountered beneath the fill material that
consist primarily of alluvium and river terrace deposits to a depth of 60 feet. The deposits are described as
gray to black sand, silt and organic clay, interlayered with peat in the southwestern portion of the site.

The Aguia Formation was partially encountered at 50 feet below ground surface and is described as a
distinct grayish green cohesive, dense sand with sift and clay. A layer of clay was encountered at 60 feet
below ground surface, however, the extent of this clay layer is unknown.

Groundwater at the Old Landfill is shallow and occurs at less than three feet to 13 feet below ground
surface. Shallow groundwater flows toward surface water to the east, south and southwest. However, the
overall general direction of the shallow groundwater flow is toward the east and to the Potomac River. The
estimated horizontal rate that shallow groundwater flows is 38 feet per day.

2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES

2.1 History

Waste disposal operations were initiated at the Old Landfill in the early 1920s and continued to expand
eastward, ceasing in 1971, when another municipal landfill was opened west of Interstate 95. Wastes were
typically burned prior to disposal in the landfill until the 1960s and included municipal refuse,
construction and demolition debris, and wastes from Base operations. The estimated volume of fill material at
the Old Landfill is 7.6 million cubic feet. Depth of the fill material is eight feet below ground surface.

As sections of the landfill were closed down, the area was taken over by DRMO to stage scrap prior to
disposal. Items stored included drums containing waste fuels and solvents, transformers, and out of service
military vehicles. Additionally, construction materials (road salt, sand, gravel and asphaft) were stockpiled
for as-needed uses. Concurrent to and after the landfill operations ceased, electrical transformers were
stored and opened at the DRMO Transformer Storage Area, Transformers were opened and
drained to recover the copper wire and steel casings. The dielectric fluid, containing PCBs, was drained
directly on to the ground. Transformer recovery operations were stopped in the 1970s, and DRMO stopped using

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the site in 1991.

In 1980, a pipeline, owned by Plantation Pipeline Company of Gastonia, North Carolina, running adjacent
to the railroad tracks at the northern end of the landfill ruptured. Approximately 100,000 gallons of diesel
fuel spilled from the pipeline adjacent to the Old Landfill. The pipeline was repaired and remains in use.

In 1982, a soil berm enclosure was constructed in the southeastern portion of the site for disposal of
Potomac River dredge spoils. Due to its location in the river's floodplain, the project was halted before any
spoils were placed in the enclosure.
A removal action was conducted at MCCDC Quantico from September 1990 through December 1990 to remove
PCB-contaminated soil from the DRMO Scrapyard and the adjoining Transformer Storage Area. The report,
entitled PCB Removal Action (Radian, 1991), provides additional details. The removal action also encompassed
the Old Batch Plant site, unrelated to the Old Landfill. U.S. Environmental Services, Inc.
(USESI) conducted the removal action, with Radian serving as the Architecture/Engineering (A/E) contractor
for the Navy. A total of 3,881 tons of soil and debris were disposed of at the Grayback Mountain Landfill
located in Utah. The areas were backfilled, graded, and seeded after completion of the removal activities.
Analytical testing confirmed that the borrow material was free of PCBs and other contaminants (i.e., only
clean fill was used).

PCBs were essentially present as PCB-1260. Although the removal action targeted soils with 10 milligrams
per kilogram (mg/kg) or greater total PCBs, the use of a 5-mg/kg level directed the activities to provide an
increased level of confidence that all sampling locations attained the target cleanup level of 10 mg/kg.

At the DRMO Transformer Storage Area, original PCB concentrations ranged from 0.55 mg/kg to 30 mg/kg
within the Transformer Storage Area. The removal action consisted of removal of the first foot of soil. At
the DRMO Scrapyard, original PCB concentrations ranged from 2 mg/kg to 1,820 mg/kg within the Scrapyard. For
the most part, PCB concentrations along the fence separating the Scrapyard from the Old Landfill
and the area farther east ranged from 2 mg/kg to 7.5 mg/kg. Two exceptions were the northern end of the fence
line, with maximum PCB concentrations of 32 mg/kg, and a drainage channel from the Scrapyard to the Potomac
River via the Old Landfill, with maximum PCB concentrations of 23 mg/kg; both of these areas were included in
the removal action. Generally, PCB contamination was limited to the top 18 inches of soil.
PCB-contaminated soils at 68 percent of the Scrapyard were excavated to a 1-foot depth, 25 percent reguired
excavation to a 2-foot depth, 5 percent reguired excavation to a 3-foot depth, and 2 percent reguired
excavation to a 4-foot depth. Approximately 3,800 tons of contaminated soil and scrap were removed and
disposed of off-site during that action.

Of note, higher PCB concentrations than expected were encountered in the DRMO Scrapyard drainage channel
leading to the Potomac River. The maximum PCB concentration in the drainage channel area (1,760 mg/kg at a
1-foot depth) was located at the edge of the area slated for the removal action. This indicates that
PCB-contaminated soils that were not addressed in the subject removal action were present further
downgradient in the drainage channel.

The Commonwealth of Virginia, Department of Environmental Quality, issued a Notice of Violation (NOV No.
93-06-NRO-075 dated June 24, 1993) for the Old Landfill site. The violation noted "Discharge of
polychlorinated biphenyls (PCBs), pesticides, petroleum hydrocarbons, and metals to state waters without
authority of a NPDES permit in violation of VR680-14-02, and violating water guality standards for surface
water and groundwater, VR 680-12-01, and VR-680-21-04, respectively, and causing environmental damage (PCBs
in fish tissue)."

In response to the NOV, the Navy initiated immediate measures to eliminate further contamination from
the Old Landfill site, as follows:

• Silt fences were installed to prevent contaminated sediment from migrating from
the western side of the site and further contaminating the drainage creek and the
river and to prevent sediment from continuing down the drainage creek.

• The blacktop area on the west side of the site was scarified by breaking up the
asphalt to make the area more permeable and thus decrease the amount of water
moving across the area. The blacktop area contributed greatly to the runoff going
into the drainage channel.

• Monthly filtered and unfiltered surface water samples were collected from a
location at the mouth of the drainage channel to monitor contaminants of concern

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in surface water in the drainage channel and to verify that PCBs are not currently
leaving the Old Landfill.

• The Focused Feasibility Study (FFS) was initiated to further study the area and
make recommendations for any additional actions deemed necessary and
consistent with the Installation Restoration Program.

• An ecological assessment with the U.S. Fish and Wildlife Service was initiated to
collect biota samples. The Agency for Toxics and Disease Registry (ATSDR)
evaluated this data to assess risks to human health from the consumption of fish
from the Potomac River embayment associated with the Old Landfill.

2.2 Present Condition of the Old Landfill

There are currently no scrapyard or landfill operations at the Old Landfill. Except for the scrapyard
area, the area is forested along the river and tributary banks and open overgrown grassy fields in the
vicinity of the former scrapyard. Access to the area is restricted and the site is partially fenced to deter
unauthorized access. Deer, groundhogs, rabbits, birds, as well as evidence of beaver activity have been
identified at the Old Landfill.

Drainage from the area is channelized into two primary drainage paths: the central drainage swale and
the unnamed tributary. The bermed area created in the early 1980s for river dredgings but never used, still
exists and is vegetated with trees and bushes. The Old Landfill is scattered with surface debris ranging from
various metal objects to concrete, plastics and wood.

2.3 Previous Investigations

The Department of the Navy issued guidance in the 1980's for all Navy and Marine Corps installations io
perform assessments to determine the extent of improper hazardous substance disposal. The Naval Energy and
Environment Support Activity (NEESA) completed the Initial Assessment Study (IAS) for MCCDC, Quantico in
1984. The study identified 17 sites of potential concern, including the Old Landfill. Because of the
potential to contaminate surface and groundwater, the Old Landfill was recommended for further study. In the
IAS, the Old Landfill was distinct from the DRMO Scrapyard, which was also recommended for further study.

A Confirmation Study (CS) of the Old Landfill and DRMO Scrapyard was completed in 1988. The CS found
high levels of PCBs in the surface soils of the Old Landfill and DRMO Scrapyard. The CS recommended a
Remedial Investigation for the Old Landfill. The Remedial Investigation began in 1991 and will be completed
after the IRA.

An Engineering Evaluation/Cost Analysis (EE/CA) was conducted in 1994 in preparation for a Removal
Action for the Old Landfill. In 1995, the EE/CA was transformed into a Focused Feasibility Study (FFS). The
FFS is the primary background document for this IRA.

2.4 Enforcement Actions

To date, no CERCLA or Resource Conservation and Recovery Act (RCRA) enforcement actions have occurred at
the Old Landfill. However, on June 23, 1993, VDEQ issued a Notice of Violation (No. 93-06-NRO-075) for the
unpermitted discharge of PCBs, pesticides, petroleum hydrocarbons, and metals to state waters from the Old
Landfill Drainage Swale. In conjunction with other response actions in 1993 to stop the discharge of
contaminants, the swale was brought into the Virginia Pollutant Discharge Elimination System (VPDES) as a
permitted discharge (VPDES No. 2151, Outfall 031) and subject to monthly monitoring reguirements.

3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION

Community participation reguirements in CERCLA Section 113(k) (2) (B) (i-v) and 117 have been met for this
IRA.

The Focused Feasibility Study Report and Proposed Plan for the Old Landfill IRA were released to the
public in July 1995. Both of these documents are available in the Administrative Record and the Information
Repositories maintained at the Chinn Park Regional Library, Prince William, Virginia; John Porter Memorial
Library, Stafford, Virginia; and Natural Resources and Environmental Affairs Branch, Building 3040, Quantico.
The notice of availability was published in the Quantico Sentry on July 21, 1995; the Free Lance-Star on July
15 and 21, 1995; and the Potomac News on July 15, 1995.

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The Public Comment Period occurred from July 15, 1995 to August 19, 1995 and was extended, at USEPA
Region III reguest, to August 28, 1995. A public availability session was held on August 9, 1995. At this
session, representatives from MCCDC, Quantico; Engineering Field Activity, Chesapeake; USEPA Region III; and
VDEQ hosted a display booth session and were available to answer or address citizen comments. The display
booths described the past site history, site characterization, and preferred remedial alternative. A summary
of the Availability Session is provided in Appendix A, Responsiveness Summary. No citizen comments were
received during the Availability Session or the Public Comment Period.

4.0 SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION

Past disposal operations at the Old Landfill have contaminated soil, groundwater, sediment, and surface
water. The Department of Navy is remediating the Old Landfill in several phases.

Currently there are seven Operable Units (OUs) under investigation/remediation at MCCDC. The current
list of OUs at MCCDC include:

OU1 Pesticide Burial Area, IR Site 1
OU2 Arsenic Burial Area, IR Site 17
OUS Former Rifle Range, IR Site 20
OU4 Old Landfill, IR Site 4
OUS Aero Club, IR Site 18
OU6 Old Batch Plant, IR Site 5
OU7 Former Fire Training Area, IR Site 19

The IRA, referred to as the "Barrier Layer, Groundwater Monitoring" alternative in the Proposed Plan, is
being performed at the Old Landfill, OU4, IR Site 4, and is being implemented to reduce potential risks to
human health and the environment associated with the Old Landfill. The IRA at the Old Landfill consists of
excavation and off-site treatment or disposal of surface soil and drainage swale sediments contaminated with
PCBs in excess of 10 parts per million, regrading the landfill surface, wetlands restoration, installation of
a soil barrier layer, and institutional controls. The IRA will be followed by additional Remedial
Investigation (RI) activities at the Old Landfill to evaluate groundwater, surface water, and sediment
contamination, and potential impacts to the Potomac River to determine if further remedial actions are
necessary. The barrier layer will be designed to:

1. reduce channelized flow and erosion by encouraging overland flow which will
prevent contaminated soil from being available at the surface;

2. prevent contaminant migration through surface water transport and soil erosion; and

3. eliminate the surface soil exposure pathways.

The IRA will be consistent with any planned future actions, to the extent possible, including the Final
Remedy selected for the Old Landfill.

5.0 SITE CHARACTERISTICS

This section provides a summary of the nature and extent of contamination at the Old Landfill, a
discussion of potential routes of contaminant migration and routes of exposure, the population and
environmental areas that could be affected by a release at the site, and site-specific factors that may
affect remedial actions at the site.

5.1 Contaminants at the Old Landfill

Contaminants of concern found in surface and subsurface soil at the Old Landfill site are listed in the
Table 5-1. Table 5-1 lists those chemicals that exceeded EPA Region III, Risk Based Concentrations (RBCs) for
residential soil and statistically determined background values. The background concentration was calculated
as the arithmetic mean concentration of two background surface soil samples. The Old Landfill,encompassing an
approximately 23 acre area, contains approximately 7.6 million cubic yards of waste, and is approximately 8
feet deep.

5.2 Potential Route of Contaminant Migration and Route of Exposure

The most likely human health exposure pathway at the Old Landfill is worker contact with the landfill

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contents or contaminated surface soil. Contaminants could be absorbed through the skin or ingested. The
drainage swale that flows through the central portion of the site may present a risk if individuals come in
contact with surface water or sediment. However, there have been no intrusive activities at the site for the
past 10 years with the exception of remediation work. Therefore, the likelihood of recent human exposures is
minimal. Other than the remediation workers currently on site,  no additional workers are
anticipated to come in contact with the landfill contents or contaminated surface soil in the future.

5.3 Population and Environmental Areas that could be affected by the contaminants at the site

     Civilians and Marine Corps personnel who work or trespass on the site could be exposed to contaminated
soils,  surface water runoff, and drainage swale sediments. Wildlife could also be exposed. However, as
mentioned previously, there are no anticipated future workers other than the remediation workers currently on
site. Potential population and environmental receptors of site groundwater will be fully evaluated in the
Remedial Investigation.

     The results of an endangered species survey was reported in the draft Phase I RI report and submitted to
the State and USEPA for review. No potentially affected endangered species have been identified.

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                          Table 5-1: Old Landfill Contaminants

                       Surface Soil  (0-2 feet) A           Surface/Subsurface  (0-10 feet) B
      Chemical
Representative
Concentration c
   Maximum
Concentration
Semivolatile Organic Compounds  (ug/kg)
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Dibenzo(a,h)anthracene
Indeno(1,2,3-d)pyrene

Pesticides/PCBs  (ug/kg)

Aroclor-1260
4,4' -DDD
4,4'-DDT
Dieldrin

Inorganics  (mg/kg)
516
501
521
383
221
388
4,800
2,400
3,400
2,900
340
3,000
Representative
Concentration c
                                           424
                                           384
                                           406
                                           305
                                           212
                                           303
6,600

2,200
224
130,000

2,700
1,700
3,400
2,100
2,200
89
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Cobalt
Copper
Lead
Manganese
Thallium
Vanadium

3.7

0.47
1.3
21.8
4.4
87.5
314
144
0.54
33.7

7.2

0.92
9.9
53.6
8.4
314
760
333
0.94
60.4
8,430
6.3
104
0.55
1.1
23.5
4.5
58.8
327
151
0.59
31.6
   Maximum
Concentration
                                           4,800
                                           4,700
                                           3,400
                                           2,900
                                             340
                                           3,000
                                                            130,000
                                                             33,000
                                                              2,700
                                                              1,700
                                                                                   27,500
                                                                                     52.3
                                                                                      825
                                                                                      2.1
                                                                                      9.9
                                                                                     65.7
                                                                                     16.2
                                                                                      568
                                                                                    1,530
                                                                                      904
                                                                                      1.9
                                                                                     60.4
Notes: A-Focused Feasibility Study, Table 2-11; B-Focused Feasibility Study, Table 2-12;
C-The 95% upper confidence limit  (UCL) of the mean

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5.4 Site Specific Factors that may affect the Interim Remedial Action

There are several wetlands located throughout the site. Several of these areas will be destroyed during
implementation of the IRA. The wetland area will be increased to approximately 2.1 acres around the Unnamed
Tributary in the southern end of the site to mitigate the loss of any wetlands impacted/destroyed (estimated
to be approximately 1.8 acres). Therefore, the size of the mitigation area will exceed the total acreage of
lost wetlands. Performance of the wetland restoration will be evaluated against a Wetland
Restoration Monitoring Plan, which will be reviewed by the USEPA, VDEQ, and the Biological Technical
Assistance Group (BTAG). Although a permit was not reguired by the United States Corps of Engineers (COE) for
this site, the COE was involved in preparation of the wetland mitigation plans and the mitigation activities
will achieve the COE permit program criteria.

The site is adjacent to the Potomac River, necessitating special measures to protect the river from
erosion impacts and storm water discharges. The selected shoreline stabilization includes the construction of
a stone, rip rap revetment (approximately 1,100 feet long). The revetment is fully described under Section
11.0, Significant Changes; Subsection 11.2, Shoreline Stabilization. Also, because of the high water table,
water will be generated during the excavation of contaminated soil and drainage swale sediment. Contaminated
water from the excavations will be treated using a bag filter and activated
carbon, tested to confirm treatment effectiveness, and discharged to the Potomac River. The discharged water
will meet the reguirements of the Virginia Pollution Discharge Elimination System (VPDES) permit for
discharge to the river.

Currently, no endangered species have been identified at the site. The remedial action shall be
implemented so as not to adversely affect such species should any be identified in the future. Also,
appropriate efforts shall be made to identify such species that may be present in the future.

5.5 Shoreline Excavation

During an extremely low tide in February 1997, a wash out of probable landfill material was observed in
the Chopawamsic embayment of the Potomac River. The exceptionally low tide conditions at the time of the site
visit afforded the opportunity to conduct a thorough assessment of the Old Landfill shoreline. A letter
documenting the site visit, dated February 25, 1997, was provided to the Navy from the VDEQ Office of Federal
Facilities Restoration Project Manager.

As a result of the discovery, the Navy, with input from the State and USEPA, proceeded to characterize
the approximate nature and extent of the landfill material on the shoreline. On March 17-19, 1997, a total of
17 test pits were excavated and 13 soil samples were collected for analysis (see Figure 5-1).

Test pits were spaced at approximately 50 ft. intervals from landfill baseline station 6+00 to 12+00.
Soil samples were shipped to Analytical Services Corp. (ASC) for DDT and PCB analysis on a seven day
turnaround time.

Results of the investigation indicated that the material consisted primarily of typical landfill
material with little to no evidence of PCB or DDT contamination. The landfill material was observed from
approximately station 6+00 to 12+00, extended to a maximum distance from the landfill berm of approximately
50 feet, and was identified at a maximum depth of 3 feet. The test pits excavated at approximate station 6+00
indicated the greatest depth and breadth of trash. Therefore, an additional seven test pits were excavated
and five soil samples were collected for laboratory analysis. The additional test pits were located southwest
of station 6+00. Results of the additional investigation
indicated that material of a similar character was present southwest of station 6+00 at a maximum depth of 8
feet. All the samples showed PCB results less than 3.32 mg/kg, and DDT results less than 0.332 mg/kg.

Due to the negative aesthetic impact of the landfill material on the shore of the Old Landfill, the
reguirements under the Open Dump provisions of °4.0 of the VSWMR, and the minimal contamination present in
the material, the Navy decided to selectively excavate the trash material and incorporate it back into the
landfill beneath the design barrier layer.

In late April 1997, landfill material was removed from the area along the shoreline a distance of
approximately 1,100 feet between Stations 6+00 to 12+00, from the shoreline to approximately 50 feet into the
river.

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An excavation depth of 1 to 3 feet was required across the entire area, except for a 25-foot area near
the mouth of the wetlands channel (Station 6+50), which required an excavation depth of 4 to 5 feet. The
material was removed, stockpiled near the shoreline, and later transported and placed in the interior of the
landfill. An approximate 3,500 cubic yards of landfill matedal was removed from the shoreline durinq the
excavation activities. The only area where restoration of the river bottom was performed was the deeper
excavation near Station 6+50. The excavation was backfilled with crushed qravel to the approximate surface of
the existinq river bottom.

The action resulted in the removal of a siqnificant quantity of sediment and landfill material from the
shoreline of the Old Landfill, an increase in the volume of material incorporated under the desiqn barrier
layer, and minor chanqes to the qradinq plan. The removal of landfill material from the shoreline of the
Potomac River was performed as part of the IRA, and as such is anticipated to be consistent with the final
remedy. The action should not, however, be viewed as the final remedy. Accordinqly, it should be noted that
the effectiveness of the current removal action, and the need for further remedial action within the
embayment, will be assessed durinq the upcominq RI investiqation.

5.6 Shoreline Stabilization

As a result of the potentially erodable condition observed alonq the Old Landfill berm, the project team
decided to incorporate shoreline stabilization features into the IRA. After completinq an alternatives
analysis, the selected shoreline stabilization included the construction of a stone, rip rap revetment
(approximately 1,100 feet lonq). The revetment was desiqned to remedy the potential erosion condition alonq
the shoreline and provide protection aqainst a desiqn wave of approximately 3 feet. The shoreline revetment
consists of three elements: a rip rap armor layer, a qeotextile filter layer, and a
rip rap toe. The revetment detail was developed based on a thorouqh review of available reference material
and consultation with Virqinia's Shoreline Protection Enqineer.

The action resulted in the excavation and removal of landfill material from the existinq berm, an
increased volume of material incorporated under the desiqn barrier layer, minor chanqes to the qradinq plan,
and an increase of construction materials brouqht onto the site. The shoreline stabilization will be
performed as part of the IRA, and as such is anticipated to be consistent with the final remedy. The action
should not, however, be viewed as the final remedy.

6.0 SUMMARY OF SITE RISKS

This section presents the risks associated with the Old Landfill and the rationale for conductinq an
IRA at the site,

6.1 Human Health Risks

Potential human health risks are cateqorized as carcinoqenic or noncarcinoqenic. Lifetime incremental
cancer risk. (LICR) estimates are evaluated by performinq a probabilistic calculation usinq estimated
exposure intakes and published Cancer Slope Factors (CSFs), and comparinq this to an acceptable risk ranqe (1
x 10 -4 to 1 x 10 -6). The resultinq risk is a unitless expression of an individual's likelihood of
developinq cancer from exposure to carcinoqenic chemicals. A LICR of 1 x 10 -6 indicates that the exposed
receptor has a one in one million chance of developinq cancer under the defined exposure scenario.
Alternatively, such a risk may be interpreted as representinq one additional case of cancer in an exposed
population of one million persons.

The calculated cancer risks should be recoqnized as upper-limit estimates. CSFs are upper bound
estimates of the probability of cancer incidence qenerally derived from animal studies. Actual human risk,
while not identifiable, is not expected to exceed the upper limit based on the CSFs, and, in fact, may be
lower.

Noncarcinoqenic risks are evaluated usinq a quantity called a Hazard Quotient (HQ) which is the ratio
of the site dose (the estimated exposure intake) to a dose not expected to cause adverse health effects (the
Reference Dose, RfD), as follows:

A Hazard Index (HI) is then calculated by summinq the individual HQs for the Contaminants of Concern
(COCs). If the value of the HI exceeds unity (1.0), there is a potential noncarcinoqenic health risk

-------
associated wfth exposure to that particular chemical mixture (USEPA, September 24, 1986). At that time,
particular attention should be paid to the target organs affected by each chemical. The HI is not a
mathematical prediction of the severity of toxic effects; it is simply a numerical indicator of the
possibility of the occurrence of noncarcinogenic (threshold) effects. If the ratio of the intake and the RfD
for any individual chemical exceeds unity, toxic effects would also be expected.

The media of concern for this IRA are soil and drainage swale sediments. Old Landfill soils and
drainage swale sediments contain semi-volatile organic compounds, volatile organic compounds, halogenated
organics, and metal contaminants. Environmental Protection Agency, Region 111, Risk Based Concentrations
(RBCs) were exceeded for many chemicals, including metals, polycyclic aromatic hydrocarbons, PCBs, 4,4-DDT
and Dieldrin in soil. These contaminants are found sporadically across the Old Landfill. Cumulative
carcinogenic risk from the soil contaminants was estimated to exceed 10 -4 only for the potential adult and
child resident exposure scenarios. This cancer risk was driven by Aroclor 1260 (PCBs), beryllium, and
polycyclic aromatic hydrocarbons, with PCBs contributing the most to risk. Total Hazard Indices did not
exceed unity when chemicals were properly separated by target organ.

The presence of PCBs in the Old Landfill soils and drainage swale sediments, particularly in hot
spots, have been determined to be additionally impacting the adjacent embayment of the Potomac River. Once in
the embayment, bioaccumulation of PCBs occurs in the aguatic receptors. The environmental impact is due to
bioaccumulation by aguatic receptors of PCBs and subseguent risk resulting from human ingestion of
contaminated fish. These environmental impacts are being investigated and guantified through ongoing studies,
including the RI and United States Fish and Wildlife Service (USFWS) studies. However, the impacts have
historically violated State Water Quality Standards and have been estimated to be creating risks associated
with fish consumption that exceed 10 -4.

6.2 Risk Assessment Uncertainties

There are a number of uncertainties with the current risk estimates due to the limited nature of the
Focused Feasibility Study. A significant uncertainty is in the actual selection of potential chemicals of
concern considered to be representative of site contamination. The use of background concentrations, water
guality standards, and toxicity information to screen for potential chemicals of concern may lead to the
underestimation of risks. Additionally, the chemical analytical database also has some limitations regarding
the representativeness of the laboratory results, the inclusion of nondetected data, data gaps, number of
samples collected, and heterogeneity of sample data. The effects of these limitations on the results of the
risk assessment are varied. However, every effort was made to collect and use samples that reflect actual
site conditions.

The toxicological data used as the basis for all risk assessments contain uncertainty such as the
extrapolation of carcinogenic exposure scenarios, the extrapolation of the results of laboratory animal
studies to human or environmental receptors, the interspecies variation in toxicological endpoints, the
variations in sensitivity among individuals of any particular species, and the use of short-term
toxicological studies to predict log-term effects. In addition, established RfDs themselves have an inherent
amount of uncertainty and the fact that toxicity information is not available for all chemicals of concern is
in itself is a major limitation of the toxicity assessment. Since completion of the preliminary risk
assessment in the FFS, the cancer slope factor for PCBs has been reassessed. For highly chlorinated,
persistent PCBs such as Aroclor 1260, the slope factor would decrease from 7.7 to 2 per mg/kg/day. Therefore,
all PCB cancer risks would decrease by a factor of 3.85, which would still result in an approximately 2 x 10
-4 cancer risk from PCBs in soil alone for the potential adult resident.

Some of the uncertainties related to the estimates of exposure include identification of land use and
activity patterns, receptor characteristics, such as age, body weight, and exposure duration, and models
and/or eguations to estimate exposure doses or contaminant concentrations.

In summary, carcinogenic and noncarcinogenic health risks are estimated using a number of different
assumptions. Conseguently, the values presented for the Old Landfill Site contain an inherent amount of
uncertainty. The extent to which health risks can be characterized is primarily dependent upon the accuracy
with which the toxicity of a chemical can be estimated and the accuracy of the exposure scenario assumptions.
For the purposes of the risk assessment performed for this site, a conservative approach was used to evaluate
the carcinogenicity and HI for chemicals of concern. Therefore, the estimated risks for this site should be
over estimated.

6.3 Exposure Assessment

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As part of a "no action" evaluation, receptors (potential future residents, hunters, trespassers,
workers, wildlife, etc.) at the site may be exposed to contaminants via groundwater, surface water, soil,
sediments, and landfill gases. Exposure to contaminants in groundwater, surface water, soil and sediment can
occur through ingestion, inhalation and dermal contact. Exposure to contaminants in fugitive dust emissions
from soil may occur through inhalation. Additional exposure may occur through ingestion of fish, wildlife,
and vegetation associated with the site.

While ingestion, inhalation, and/or dermal contact with contaminants in surface water and sediment
may present additional risks, the cumulative risk from these media have not been evaluated for the IRA.
Cumulative risks will be evaluated under the Remedial Investigation and addressed in the final Remedial
Action.

6.4 Risk Characterization

The media of concern for this IRA are soil and drainage swale sediments, which represent the highest
risk exposure pathways at the Old Landfill. Cumulative carcinogenic risk from the soil contaminants was
estimated to exceed 10 -4 only for adult and child resident exposure scenarios. Total Hazard Indices (HI)
were also estimated to exceed unity only for these exposure scenarios. Additionally, the presence of PCBs in
the Old Landfill soils and drainage swale sediments have been determined to be impacting the adjacent
embayment of the Potomac River.

The exceedance of USEPA's human health risk limits for potential receptors of site soils and the
potential for contaminant migration to groundwater and the Potomac River provide the basis for this IRA.

6.5 Ecological Risk

The preliminary risk assessment presented in the Focused Feasibility Study only assessed human health
risks. Ecological risks were not evaluated. Biological samples collected in the embayment indicated PCBs were
present in the food chain (fish fillets). Ecological risks will be evaluated in the Remedial Investigation
and addressed in the final Remedial Action. However, by implementing the IRA, the Navy will reduce future
loading and reduce additional impacts to fish.

Although the IRA has been designed to be consistent with the final remedy for the site, this IRA may be
aftered as a result of the data gathered dudng the RI and possible implementation of other OUs at the Old
Landfill.

7.0 DESCRIPTION OF INTERIM REMEDIAL ACTION ALTERNATIVES

This section describes the remedial action alternatives (RAAs) that were considered for the IRA and
presented in the Proposed Plan. During the conduct of the Focused Feasibility Study, applicable remedial
technologies were identified, evaluated and assembled into RAAs. This IRA addresses soil and drainage swale
sediment contamination at the Old Landfill. Groundwater, surface water, and embayment sediment contaminants
of concern at the Old Landfill will be deferred to and further evaluated in the Remedial Investigation.
The RAAs include:

• Barrier Layer Implementation;

• Clay Cap;

• Excavation/Offsite Incineration; and

• No Action

7.1 RAA 1: Barrier Layer Implementation

Capital Cost $5,241,000

Annual O&M Cost $69,000

Implementation Time 12 Months

The intent of this alternative is to provide a source-control remedy to minimize exposure to landfill
contents, infiltration of stormwater, and migration of contaminants off-site. PCB contaminated surface soil

-------
"hot spots" would be excavated and disposed of offsite in a TSCA-permitted facility,  followed by installation
of a soil barrier layer.  The key components of RAA 1 include:

       •       Institutional  controls  (e.g.,  locked fencing and access  restrictions)

       •       Consolidation  of existing berm,  demolition and off-silte disposal  of scrapyard buildings
             (Buildings 671  and 672 in the DRMO Scrapyard and  Building 679,  680,  and  several
             concrete loading structures at the DRMO Transformer Storage Area),  and disposal of
             associated building foundations within the Old Landfill.

       •       Excavation  and off-site  disposal at  a TSCA-permitted facility  of  surface  soil  and
              drainage swale sediments contaminated with PCBs  in excess of 10 parts per million.

       •       Installation of geotextile and 2-ft.  soil layer  covering 23 acres,  and  shoreline
              protection.

       •       Replacement  of wetlands  destroyed/impacted by the implementation  of the IRA
              (including long-term monitoring of the replacement wetlands to ensure mitigation is
              effective).

       •       Operation and  maintenance (as discussed in Section 9.3;  Operations  and
              Maintenance),  and 5-year review.

       •       Upon completion of the  "hot spot" removal and construction of  the  barrier layer,  any
              remaining PCBs will no longer be available to receptors  at the land surface,  but rather will
              become a subsurface contaminant. Therefore,  no PCBs will remain on the  land surface
              of the Old Landfill.

       •       Installation of the geotextile and 2-ft.  soil barrier layer, in conjunction with shoreline
              protection,  will reduce  potential for washout of landfill material from flood conditions  and
              prevent erosion of contaminated soil offsite.

    7.2 RAA 2: Clay Cap

                        Capital Cost             $10,854,000

                        Annual O&M Cost              $69,000

                        Implementation Time        15 Months

      The intent of this alternative is to provide a source-control remedy to minimize  exposure to landfill
contents, eliminate infiltration of stormwater, and prevent migration of contaminants off-site. PCB
contaminated surface soil "hot spots"  would be excavated and disposed of offsite at a TSCA-permitted
facility, followed by installation of a clay cap.  All components of RAA 2 are the same  as RAA 1 except  a
2-foot impermeable clay cap  is constructed instead of a 2-foot soil barrier layer.

    The clay cap would consist of the following layers, from top to bottom:

       •       Revegetation

       •       Soil (24 inches)  - barrier protection layer/soil cover

       •       Gravel (12  inches)  -  drainage layer

       •       Filter Fabric

       •       Clay (12 inches)  - low permeability  layer

       •       Filter Fabric

       •       Gravel (12  inches)  -  bedding and/or  gas venting  layer

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7.3 RAA 3: Excavation/Offsite Incineration

Capital Cost $383,225,000

Annual O&M Cost $646,000

Implementation Time 48 Months

The intent of this alternative is to provide a treatment alternative. All contaminated fill would be
remediated. Key components of RAA 3 include:

• Institutional controls (e.g., looked fencing and access restrictions)

• Excavation/off-site incineration at a TSCA-permitted incinerator of surface soil and
drainage swale sediments contaminated with PCBs in excess of 10 parts per million.

• Excavation/off-site incineration of approximately 279,000 cubic yards of potentially
contaminated additional material at a RCRA-permitted incinerator.

• Replacement of wetlands destroyed/impacted by the implementation of the IRA
(including monitoring of the replacement wetlands to ensure mitigation is effective).

• Demolition and oftite disposal of scrapyard buildings and associated foundations,
described in Section 1.0, in order to allow for excavation of potential waste beneath.

• Backfilling based upon state and local reguirements.

• Regrading, revegetation, shoreline protection upon completion of the excavation effort.

7.4 RAA 4: No Action

Capital Cost $0

Annual O&M Cost $0

Implementation Time 0 Months

An evaluation of the No Action alternative is reguired under CERCLA and conducted to provide a baseline
for comparison with the other remedial alternatives. Under this alternative, contaminants would remain in
site soils and continue to present human health risks and be released via surface water runoff and soil
erosion into surrounding surface water bodies. The removal of contaminants and barrier layer installation
would not be instituted. This alternative is not protective of human health and the environment.

8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

Section 300.430 (e) of the NCP lists nine criteria by which each remedial alternative must be
assessed. The acceptability or performance of each alternative against the criteria is evaluated individually
so that relative strengths and weaknesses may be identified. The nine criteria include: 1) Overall protection
of human health and the environment; 2) Compliance with applicable or relevant and appropriate reguirements
(ARARs); 3) Long-term effectiveness and permanence; 4) Reduction of toxicity, mobility, or volume through
treatment; 5) Short-term effectiveness; 6) Implementability; 7) Cost; 8) State acceptance; and 9) Community
acceptance.

The NCP (section 300.430(f)) states that the first two criteria, protection of human health and the
environment and compliance with ARARs, are the "threshold criteria" which must be met by the selected
remedial action. The next five criteria are the "primary balancing criteria", and the trade-offs within this
group must be weighed. The selected remedial alternative is that alternative which is most protective of
human health and the environment, is ARAR-compliant, and provides the best combination of primary balancing
criteria attributes. With respect to criteria 4), since this is interim action, the IRA is not intended to
utilize treatment to the maximum extent. The final two criteria, state and community acceptance, are
"modifying crtteria" which are evaluated following comments from the FS report and the Proposed Plan.

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8.1 Overall Protection of Human Health and the Environment

All of the RAAs developed are protective of public health and the environment, except RAA4 . RAA3
provides the greatest level of protectiveness, since this alternative includes full removal of all PCB
contaminated soil and landfill trash; however, risks to the environment associated with implementation of
RAA.3 include potential releases of contamination during removal.

RAAs 1 and 2 reduce exposure to landfill material and prevent erosion. RAA2, with an impermeable clay
cap, has the advantage of reducing infiltration from stormwater. Regardless of the cap material, leaching of
contaminants will occur from fill material coming in contact with groundwater.

During determination of the cleanup criteria for PCBs in surface soil/sediment, the project team (Navy,
USEPA, and VDEQ) evaluated both human health and environmental concerns. For human health, a level of 10 ppm
PCBs was agreed upon, which is in accordance with USEPA's "Guidance on Remedial Actions For Superfund Sites
With PCB Contamination." For environmental concerns, although BTAG recommended a cleanup level of 1 ppm PCBs,
the addition of the additional 2-foot barrier layer effectively eliminates exposure to surficial
contamination, thereby increasing protection of human health and the environment. The project team evaluated
both criteria and decided a cleanup level of 10 ppm PCBs for this IRA would be protective of human health and
the environment.

8.2 Compliance with Applicable or Relevant and Appropriate Reguirements

RAA 3 complies with all ARARs and guidance and is ranked first.

For RAAs 1, 2 and 3, removal of the PCB "hot spot" from the soil and drainage swale sediments to 10
ppm would comply with and exceed the Federal Toxic Substances Control Act (TSCA) regulations addressing
reguirements for PCB concentrations greater than 50 ppm. For RAAs 1, 2 and 3, air monitoring will be
conducted to ensure that air pollution control regulations are not violated, primarily for fugitive dust
emissions during construction. Venting is included in RAA 2.

RAAs 1, 2 and 3 would be implemented to comply with ARARS relating to the storage, treatment, and
disposal of hazardous substances, as well as, floodplains and wetlands regulations, erosion and sediment
control regulations, and NPDES ARARs.

8.3 Long-Term Effectiveness and Permanence

RAA 3 provides the greatest level of protectiveness since all contaminated material would be removed.
RAAs 1 and 2, provide varying levels of long-term effectiveness and permanence. The permeable barrier layer
of RAA1 appears to be less likely than the impermeable clay cap of RAA 2 to deteriorate from factors
associated with location in the 100-year flood plain. For RAAs 1 and 2, excavation and disposal of the PCB
surface soil is both effective and permanent.

8.4 Reduction of Toxicity, Mobility or Volume through Treatment

Although it is difficult to guantify the volume of contaminants in the Old Landfill, RAA3 would result
in the excavation and off-site incineration of PCB contaminated soils and approximately 279,000 additional
cubic yards of contaminated fill. Complete destruction of organic toxicity is anticipated with incineration.
Metals would reside in the ash produced, which may reguire solidification to decrease mobility prior to
disposal. None of the remaining RAAs would reduce toxicity, mobility or volume through treatment.

8.5 Short-Term Effectiveness

For RAAs 1 and 2, there will be little or no short-term effects on the community. Air monitoring will
be conducted to detect any unexpected release of contaminants from excavation and grading associated with
these alternatives as a precaution. In addition, permitted transporters will be employed to ensure compliance
with DOT regulations, with particular respect to air monitoring, for the transportation of hazardous waste to
ensure compliance with the Virginia Hazardous Waste Management Regulations
(VR 672-10-1 / 9VAC 20-60-10 et seg.). For RAA 3, there will be significant short-term effects to the
community due to transportation of contaminated material to the TSCA- or RCRA-permitted facility. This will
occur over an extended period of time, up to 48-months. Therefore, RAA 3 has more impacts than RAAs 1 and 2.

An environmental concern is runoff of contamination to the Potomac River during remediation. RAAs 1

-------
and 2 have similar rankings with respect to runoff control, since each of these RAAs involve cap or barrier
layer installation. Runoff controls are a major concern for RAA 3 which involves excavation and dredging
operations next to the Potomac River. Each RAA emphasizes conducting capping (or excavation) activities in
small sections to lessen potential adverse environmental impacts, considering the site location in the
100-year floodplain. Erosion and sedimentation controls will also lessen potential adverse environmental
impacts.

Although comprehensive wetland mitigation is planned under all options, a concern with respect to the
RAAs will be the short-term loss of wetlands. A significant environmental concern is the filling in of the
drainage channel, and more importantly, the unnamed tributary. RAAs 1, 2 and 3 impact the drainage channel
and unnamed tributary, either through filling in (RAAs 1 and 2) or removal via excavation (RAA 3), and
grading. However, for both RAAs 1 and 2 to be effective, these channels must be incorporated into the barrier
layer/cap. Due to the contamination present in the drainage channel sediments, the channel must be removed in
all options.

During implementation of the IRA, performance of the wetland restoration will be evaluated against a
Wetland Restoration Monitoring Plan, which will be reviewed by the USEPA, VDEQ, and BTAG.

8.6 Implementablillity

Each of the RAAs is technically and administratively feasible. In addition, materials and services are
available for each RAA, however, the appropriate clay material for RAA 2 would be more difficult to acguire
than the materials reguired for RAAs 1 and 3. RAA 3, although feasible, would be the most difficult to
implement without affecting the Potomac River during excavation and dredging operations. Under RAA 3, it
would also be difficult to segregate PCB contaminated fill, which is potentially present throughout the
landfill and reguires more stringent incineration considerations compared to other waste types.

The impermeable clay cap (RAA 2) is thicker than the permeable barrier layer (RAA1). As a result, the
clay cap necessitates additional effort to provide proper slopes for shore protection.

8.7 Cost

Table 8-1 summarizes the capital costs, annual O&M costs, and present worth of the four RAAs. A
discount rate of 5 percent was used in the present worth calculation.

Table 8-1: Cost Summary

Alternative Capital Costs Annual O&M Present Worth

RAAl-Barrier Layer $5,241,000 $69,000 $6,296,000

RAA2-Clay Cap $10,854,000 $69,000 $11,909,000

RAA3-Excavation/Oftite Incineration $383,225,000 $646,000 $352,439,000

RAA4-NO Action $0 $0 $0

8.8 State Acceptance

Based on its review of the Proposed Plan, the ROD, and support documents, the State supports the
selected RAA, which is RAA1.

8.9 Community Acceptance

Community Acceptance summarizes the publids general response to the alternatives described in the
Proposed Plan. A summary of the public meeting held August 9, 1995, and comments and responses from the
comment period and the public meeting are included in the Responsiveness Summary (Appendix A). Results of the
public meeting and community comment indicate that the community favors the selected RAA.

8.10 Summary of Detailed Evaluation

RAA 1 provides the best balance with respect to the nine evaluation criteria for protection of human
health and the environment. This alternative meets eight of the nine evaluation criteria in selecting an

-------
appropriate remedy, however, the reduction of toxicity, mobility, or volume through treatment criterion will
not be entirely met.

RAAs 2 and 3 are protective of human health and the environment. However, compared to RAA 1, they each
have significantly increased costs and implernentability problems.

RAA 4 is not protective of human health and the environment.

9.0 SELECTED REMEDY

Details of the barrier layer construction, including wetland mitigation, plant selection, planting
reguirements; and maintenance will be presented in the final Design Specifications and the IRA Work Plan.

The barrier layer is an interim remedy that may or may not meet the state closure reguirements. It is
intended as an interim action but is anticipated to be consistent with the final remedy. Upon completion of
the Remedial Investigation (RI) and Feasibility Study (FS), the final remedy will be selected which will meet
state closure reguirements. As an example, groundwater is an outstanding issue not addressed in this ROD, but
rather will be addressed during the upcoming RI. State reguirements for closure will be monitored during the
RI/FS process.

9.1 Remediation Reguirements

Based upon the consideration of the reguirements of CERCLA, the alternatives analysis, and public
comments, RAA 1 has been chosen as the IRA at the Old Landfill. The Department of the Navy, Virginia
Department of Environmental Quality and the Environmental Protection Agency, Region III, consider RAA 1, to
be the most appropriate interim remedial action for the Old Landfill. This IRA has been designed to be
consistent with the final remedy for the site. This IRA may be altered as a result of the data gathered
during the RI and possible implementation of other OUs at the Old Landfill.

The major components of the IRA include:

• Institutional controls, to assure that activities do not breach or compromise the
integrity ofthe barrier layer, fencing around the entire site with locked gates, and
restricting access by unauthorized personnel;

• Consolidation of existing berms, demolition and off-site disposal of scrapyard
buildings, and incorporation of scrapyard building foundations within the Old Landfill;

• Excavation and off-site disposal of surface soil and drainage swale sediments
contaminated with PCBs in excess of 10 parts per million (ppm);

• Permeable 2-foot soil barrier layer installation covering 23 acres with the
following layers: high guality vegetation, topsoil. barrier soil, and marking geotextile;

• Incorporation of flood control measures and shore protection;

• Successful replacement and restoration of wetlands destroyed/impacted by the
implementation of the IRA (1.8 acres impacted vs. 2.1 acres replaced), including
ensuring the replacement and restoration is successful, through continued
monitoring and other appropriate measures;

• Operation and maintenance; and

• Five year reviews, as reguired by the National Contingency Plan.

Additionally, the Remedial Investigation will determine additional remedial actions needed for the
site. Such actions will be addressed in a final ROD.

9.2 Institutional Controls

Final use restrictions will be addressed in the final remedy. A copy of this document will be
provided to the Navy's Planning Offices (at EFACHES and the Marine Corps Base) for their review in order to
eliminate performance of any project that might affect the integrity of the barrier layer. Until that time,

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institutional controls, to include no breaching of the barrier layer, fencing around the entire site with
locked gates, and restricting access by unauthorized personnel, will be employed by the Navy as protection.
No invasive development of the landfill area will be allowed.

Each year, the Natural Resources Environmental Affairs (NREA) Branch at the Marine Corps Base shall
be responsible for reviewing any on site activities and maintaining continued coordination with the Planning
Offices.

9.3 Operations and Maintenance

Operations and maintenance (O&M) will be perfon-ned in accordance with the Virginia Solid Waste
Management Regulations (VSWMR °5.0). This O&M will include an annual inspection of the cover, initiated
within one year of completion of the IRA. The remaining portions of the VSWMR O&M requirements will be
implemented as part of the final remedy for the Old Landfill. O&M for this IRA will include, at a minimum,
the following items:

• Performance standards to assure integrity of the barrier layer;

• Erosion control;

• Wetland monitoring, and

• Inspection and maintenance as applicable.

During implementation of the IRA, performance of the wetland restoration will be evaluated against a
Wetland Restoration Monitoring Plan, which will be reviewed by the USEPA, VDEQ, and BTAG.

9.4 Performance Standards

• Remove all PCB contaminated surface soil/sediment in the drainage channel to 10 ppm,

• Install silt fences along the river, 20 feet from the river's edge to control erosion
as required by Virginia Erosion and Sediment and Control Act.

• Construct 4-foot high temporary berms along the river's edge to minimize soil
loss during construction.

• Successfully replace and restore approximately 2.1 acres of wetlands in the
unnamed drainage channel.

• Excavate and place waste material and common fill to achieve design grade.

• Construct a barrier layer to prevent direct human contact with site contaminats.
The barrier layer will be constructed according to the following performance
standards:

• Install an 8-oz, non-woven geotextile, with a minimum thickness of 95-mil and a
minimum grab tensile strength of 225 pounds.

• All geotextile will overlap a minimum of 12 inches.

• Geotextile placed 25-percent slopes or steeper will be continuously sewn.

• Install the barrier layer (2 percent minimum grade) consisting of 18 inches of
common fill and 6 inches of topsoil.

• The barrier layer will have a maximum particle size of 3 inches and a maximum
of 25 percent by weight passing the No. 200 sieve.

• The top soil will contain 5 to 20 percent by weight organic matter and will have a
maximum particle size of 1 inch and a maximum of 5 percent by weight retained
on the 1/4-inch sieve.

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• All disturbed areas will be revegetated. Seed and mulch will be applied to
accomplish this.

• Install approximately 3,000 linear feet of chain-link fence with locked gates to
prevent unauthorized access to the Old Landfill area.

9.5 Cost of Selected Remedy

The cost to implement RAA 1 is $5,241,000 and the cost for operation and maintenance is $69,000 per
year. The present mrth is $6,296,000 over 20 years with 5% discount rate.

10.0 STATUTORY DETERMINATIONS

The goal of this IRA for the Old Landfill is to reduce dermal contact, ingestion, and inhalation
risks to human health and the environment, and to eliminate further erosion of contaminants into the
wetlands and adjacent Potomac River embayment. This IRA increases protection of human health and the
environment with a remedial alternative that is cost effective, consistent with a permanent solution, and
complies with Federal, State, and local ARARs specific to this IRA. Following this IRA, risks to human health
and the environment from contaminants left on site will be assessed in the Remedial Investigation and
addressed in the final Remedial Action.

10.1 Overall Protection of Human Health and the Environment

The selected RAA increases protection to human health and the environment by reducing exposure to, and
further release of, site contaminants. Removal of PCB contaminated soil and drainage swale sediments to 10
ppm, stabilization of site grades, and the installation of a soil barrier layer over the entire site will: 1)
reduce cumulative carcinogenic risk from contact with, and inhalation of, soil and drainage swale sediment
contaminants below 10 -4; and 2) prevent further escalation of risks associated with the
consumption of fish from water bodies adjacent to the Old Landfill. Hazard Indices were already below
unity (less than 1) as discussed in Section 6.1.

Short-term risks associated with the selected RAA could include increased erosion of site soils,
increased fugitive dust releases, and increased discharges of contaminated groundwater during dewatering
activities reguired for the drainage channel excavation. However, these short-term risks are to be minimized
through use of erosion, dust, and wastewater management plans, as addressed in Section 8.5. With
implementation of work plan controls, the short-term risks become acceptable as compared to the continued
risks associated with the No Action RAA.

Although comprehensive wetland mitigation is planned, a concern will be the short-term loss of
wetlands. An additional environmental concern is the filling in of the drainage channel, and more
importantly, the unnamed tributary. RAA 1 impacts the drainage channel and unnamed tributary through filling
in and regrading. However, for RAA 1 to be effective, these channels must be incorporated into the barrier
layer, and due to the contamination present in the drainage channel sediments, it must be removed in all
options.

10.2 Compliance with Applicable or Relevant and Appropriate Reguirements

The selected IRA will comply with the Federal, state, and local ARARs specific to this IRA. ARARs are
separated into three categories; Chemical-specific, Location-specific, and Action-specific.

Chemical-specific ARARs are usually health or risk-based numerical values or methodologies which, when
applied to site-specific conditions, result in the establishment of numerical values. These values establish
the acceptable amount or concentration of a chemical that may be found in, or discharged to, the ambient
environment. Location-specific ARARs are restrictions placed on the concentration of hazardous substances or
the conduct of activities solely because they are in specific locations (floodplains, wetlands, historic
places, etc.). Action-specific ARARs are usually technology or activity-base reguirements or limitations on
actions taken with respect to hazardous wastes. These reguirements are triggered by the particular remedial
activities that are selected to accomplish a remedy. These Actton-specific reguirements do not in themselves
determine the remedial alternative; rather, they indicate how a selected alternative must be achieved.

"Applicable reguirements" include those cleanup standards, standards of control, and other substantive

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environmental protection requirements, criteria, or limitations promulgated under Federal or state law that
directly and fully address a hazardous substance, pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site. "Relevant and appropriate requirements" means those cleanup standards,
standards of control, and other substantive environmental protection requirements, criteria, or limitations
promulgated under Federal or state law, while not "applicable", address problems or situations sufficiently
similar  (relevant) to those encountered at the CERCLA site, that their use is well suited (appropriate) to
the particular site. "To Be Considered (TBC)" criteria are nonpromulgated, non-enforceable guidelines or
criteria that may be useful for developing remedial action, or necessary for determining what is protective
to human health and/or the environment. Examples of TBC criteria include USEPA Drinking Water Health
Advisories, Carcinogenic Potency Factors, and Reference Doses.

       Several pertinent guidances were also identified and will be considered. Table 10-1  (included at the
end of this Section) provides a listing of the Chemical, Action, and Location-specific ARARs.

    10.3 Cost Effectiveness

    RAA 1 was determined to be the most cost effective option.

    10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies
         or Resource Recovery Technologies) to the Maximum Extent Practicable

       The IRA is not designed or expected to be final, but the selected IRA represents the best balance of
trade-offs among the RAAs. The selected IRA utilizes permanent solutions, alternative treatment technologies,
or resource recovery technologies to increase protection of human health and the environment while complying
with ARARs to the maximum extent practicable for interim source control of Old Landfill   contaminants.

    10.5 Preference for Treatment as a Principal Element

       Treatment options were determined to be impracticable for the limited scope of this IRA, since only a
small portion of the site is being excavated and would therefore become treatable. The small volume of soil
to be excavated does not favor treatment from a cost perspective. Because this IRA does not constitute the
final remedy, the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element (e.g., with respect to groundwater) will be addressed in the final ROD.

       Continued study of the Old Landfill may identify risks associated with other site media, such as
groundwater, that would have a greater potential to utilize treatment than media addressed in this IRA. The
inclusion of treatment based remedial technologies in the final remedy would achieve a balance between
treatment and non- treatment based remedies for the overall cleanup of the Old Landfill.

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TABLE 10-1: Applicable or Relevant and Appropriate Requirements
Old Landfill (Site 4)
Marine Corps Combat Development Command, Quantico, Virginia
ARAR or TBC

1. CHEMICAL-SPECIFIG
Legal Citation
Classification
Summary Requirement
Applicability to IRA
A. Polychlorinated Biphenyls
(PCBs)

1. Toxic Substance Control
Act(TSCA)

a. USEPA PCB Spill Policy
40 CFR 761
To Be Considered
b. Guidance on Remedial
Actions for Superfund Sites
with PCB Contamination
OSWER Dir.
9355.4-01,
August 1990
To Be Considered
Remediation of non-liquids (soil,
rags, debris) >50 ppm.
Comparison of site concentrations
with performance standards for
new spills is warranted although
the concentration of the original
spill(s) is unknown.

This document describes the
recommended approach for
evaluating and remediating
Superfund sites with PCB
contamination.
Soils or drainage swale sediments with
>10 ppm PCB will be removed/disposed
based on industrial use, continued
monitoring.
The Old Landfill qualifies as an industrial
area. Maximum site PCB soil
concentrations exceed both industrial and
residential recommended remediation
goals for soils. PCB contamination will
continue to be evaluated at each 5 year
review. PCB contaminated soils and
drainage swale sediment will be removed
to 10 ppm to achieve the remediation
goals.

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      ARAR or TBC

II. LOCATION-SPECIFIG

A. Wetlands

1. Clean Water Act




2. Wetlands Executive Order
Legal Citation
                                                       Classification
                                          Summary Requirement
                                                    Applicability to IRA
3. Coastal Zone
Management Act  (CZMA)
4.  Floodplain Executive
Order
5.  Virginia Wetlands Act
6. Virginia Wetlands
Regulations Act
 33 USC 1344;
 40 CFR 230.41
                               EO 11990
                               16 USC 1451
 EO 11988
 VA Code 62.1-
 13.1 et seg;

 VR A450-01
 0051 / 4 VAC
 20-390-10 et
 seg. Code
 62.1-13.1 et
 seg.
 Applicable
                         Applicable
                         Applicable
Applicable
Applicable


Applicable
Regulates dredge and fill activities.
No activity that adversely affects a
wetlands shall be permitted if there
is a practical alternative.

Federal Agencies are reguired to
minimize the destruction, loss, or
degradation of wetlands and to
preserve and enhance natural and
beneficial value of wetlands.

Protection of shorelines, wetlands
and runoff controls.
Federal Agencies are reguired to
reduce the risk of flood loss,
minimize impact of the floods, and
restore and preserve the natural
and beneftal value of floodplains.

Regulates activities in Tidal
Wetlands.

Any activity to take place in, or
impact on, a tidal wetland must
meet the provisions of the Virginia
Wetlands Act and regulations as
applicable. Regulates activities in
Tidal Wetlands.
  Actions along the Potomac or impacted
  wetlands will be coordinated with
  COE(Dumfries) and Virginia Marine
  Resources Commission  (VMRC).

  Wetlands will be impacted by the action.
  Wetlands impact assessment and
  restoration will be coordinated with COE,
  Dumfries and VMRC.
 Alternative will impact shoreline, wetlands
 and runoff controls. Alternative will
 comply with substantive reguirements of
 °404 and VPDES permit, and local CZMO
 and erosion control boards.

  Portions of the site are in the 100 year
  floodplain. Flood protection will include
  vegetative cover and riprap.
  Coordinate compliance through
  substantive regulations of °404.

Any activity to take place in,  or impact on,
the tidal wetland of the Old Landfill must
meet the provisions of the Act. Coordinate
compliance through substantive
regulations of °404.

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          ARAR or TBC
Legal Citation
                                                           Classification
                                         Summary Requirement
                                                        Applicability to IRA
7. Virginia Water Protection
Permit Regulations (VWPP)
8.  Virginia Waste
Management Act  (VWMA),
Siting of Hazardous Waste
Facilities
 VR-680-15-02
Applicable
 Ch.  14 VWMA
 Article 6,  10.1-
 1433
Applicable
Applies to activities that affect
dredge and fill of surface waters.
Commonwealth's certification
authority under °401 of the Clean
Water Act.

Protects wetlands from facility
siting.
Permit information will be coordinated with
VMRC regarding wetland disturbances
coordinated through VWPP at VDEQ.
Alternative includes restoration.
Restoration will be in accordance with this
standard.
B. Chesapeake Bay

1. Chesapeake Bay
Preservation Act;
Chesapeake Bay
Preservation Area
Designation and
Management Regulations
(Virginia)
III. ACTION-SPECIFIC
 VA Code Ch.21
 (°10.1-2100) ;
 VR 173-02-01
Applicable
Limits land disturbing activities
impacting state surface water
quality. Chesapeake Bay
Preservation Act and Regulations
administered by local C-BLAD.
 Requires that certain locally designated
 tidal and nontidal wetlands, as well as
 other sensitive land areas, be subject to
 limitations regarding land-disturbing
 activities, removal of vegetation, use of
 impervious cover, erosion and sediment
 control, stormwater management, and
 other aspects of land use that may have
 effects on water quality.
A. Hazardous Waste
Management

1. Virginia Hazardous Waste
Management Regulations
(VHWMR)/Resource
Conservation and Recovery
Act  (RCRA)
 VR 672-10-1
 9 VAC 20-60-
 10 et seq.;
 40 CFR 261-
 266,268,270-
 271
Applicable
Controls gereration, storage, and
disposal of solid and hazardous
waste. Regulations mirror those
developed by USEPA for
hazardous waste.
 If the remedial response involves storage,
 treatment or disposal of a VHWMR/RCRA
 hazardous waste, various VHWMR/RCRA
 requirements may need to be complied
 with as specified in VHWMR and/or the
 applicable 40 CFR Parts. Because
 Virginia administers an authorized state
 RCRA program, the VHWMR will serve as
 the governing ARAR in place of the
 RCRA regulations.

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           ARAR or TBC

2.  RCRA Corrective Action
for Solid Waste
Management Units at
Hazardous Waste
Management Facilities

3.  Virginia Solid Waste
Management Regulations
 (VSWMR)
B. Water

1. Clean Water Act

National Pollutant Discharge
Elimination System
Regulations (NPDES)

2. Federal Ambient Water
Quality Criteria  (AWQC)
3. Virginia Pollutant
Discharge Elimination
System Regulations
(VPDES)

4. Virginia Water Quality
Standards
           ARAR or TBC
Legal Citation

40 CFR 264,
265,270,271
VR 672-20-10 /
9 VAC 20-80-
10 et seg.
33 CFR °1342

40 CFR 122



40 CFR 131
VR 680-14-01 /
9 VAC 25-30-
10 et. seg.
VR 680-21-00
Classification

To be considered
             Summary Reguirement

Corrective Action procedures.
Applicable
Applicable
Applicable
Applicable
Applicable
Legal Citation
                                                            Classification
The disposal of any soil, debris,
sludge or any other solid waste
from a site must be done in
compliance with VSWMR
Controls discharge of
contaminants from point source to
surface waters.
AWQC may be considered for
actions that involve discharges to
state surface waters.

Establishes the mechanism for
permitting of discharges to state
waters through VPDES.
Provides water guality standards
for surface water.
                                          Summary Reguirement
           Applicability to IRA

 Will be used as guidance when
 developing remediation strategies.
The disposal of any soil, debris, sludge or
any other solid waste from the Old
Landfill site must be done in compliance
with the regulations.
Criteria will be followed in the design and
operation of any water
treatment/discharge system.
 Comply with substantive reguirements of
 VPDES, and Storm Water Regulation as
 identified by VDEQ NRO.

 Comply with the substantive
 reguirements of VPDES and Storm
 Water Regulations as identified by the
 VDEQ NRO.

 Standards are used for a basis to develop
 and comply with the substantive
 reguirements of VPDES discharge
 permits for PCB hot spots and excavation
 activities, and Storm Water Regulations
 as identified by VDEQ NRO.
           Applicability to IRA

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           ARAR or TBC

5.  Virginia Stormwater
Management Act Virginia
Stormwater Management
Regulations
C. Air

1. Clean Air Act

a. National Ambient Air
Quality Standards  (NAAQS)
2.  Virginia Regulation for
the Control and Abatement
of Air Pollution (VRCAAP)
D. Virginia Erosion and
Sediment Control
Regulations
Legal Citation

Code of
Virginia
Sections 10.1-
603.1 et seg.;

VR 215-02-00 /
4 VAC 3-20-10
et seg.
42 USC 7401

40 CFR 50
VR 120-01-1
through VR
120-08-065 /

9 VAC 5-10-10
through 9 VAC
5-80-350

VR 625-02-00
Classification

Applicable
Applicable
Applicable
Applicable
             Summary Reguirement

All land-disturbing activities must
be in compliance with local
Stormwater management
programs, where they exist
Control emission of unacceptable
levels of airborne particulates to
the atmosphere.  The primary and
secondary standards for
particulate matter, expressed as
PM-10 is 150 [24 hour, annual
arithmetic mean] and 50 [1 -year
annual arithmetic mean],
respectively.

Establishes ambient air guality
goals and regulates the discharge
of pollutants into the atmosphere.
Establishes minimum design and
implementation standards to
control erosion and sedimentation
from construction sites.
           Applicability to IRA

 Comply with substantive reguirements as
 identified by VDEQ.
Alternative may result in emission of
unacceptable levels of airborne
particulates to the atmosphere. Site
wetting will be used to control particulate
matter and fugitive dust in compliance
with VDEQ Air Regulations.
Particulates may be released into the
atmosphere during remediation. Site
wetting will be used to control particulate
matter and fugitive dist in compliance
with VDEQ Air Regulations.
 An erosion and sediment control plan will
 be prepared and submitted to the Virginia
 representative at the Navy for review
 before engaging in any land disturbing
 activity.

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11.0 SIGNIFICANT CHANGES

This section describes significant changes to the Old Landfill IRA that have occurred since the
Proposed Plan was submitted for public review. The changes are anticipated to be consistent with the final
remedy.

The IRA addresses soil and drainage swale sediment contamination at the Old Landfill. Groundwater
monitoring and/or remediation has been deferred to the final Remedial Action. Groundwater, surface water, and
embayment sediment contaminants of concern at the Old Landfill will be further evaluated during the Remedial
Investigation.

12.0 REFERENCES

A.T. Kearney, Inc., March 1989. Revised Phase II, RCRA Facilily Assessment
Report of the Marine Corps Develogment and Education Command. Alexandria, Virginia.

Engineering Field Activity, Chesapeake, July 1995. Proposed Plan for the Old
Landfill Interim Remedial Action. Washington, DC.

Halliburton NUS, June 1995. Supplemental Field Investigation Report for Site 4 - Old
Landfill at Marine Corps Combat Development Command, Quantico, Virginia, CTO
0198, Wayne, PA.

Halliburton NUS Corporation, April 1995. Focused Feasibilily Study Report for Old
Landfill, Quantico, Virginia. CTO 0149, Wayne, PA.

Naval Energy and Environmental Support Activity (NEESA) , March 1984. Initial
Assessment Study of Marine Corps Development and Education Command,
Quantico, VA. NEESA 13-043, Port Hueneme, CA.

Radian Corporation, August 1991. PCB Removal Action, Marine Corps Combat
Development Command, Quantico, Virginia. Herndon, VA.

U.S. Environmental Protection Agency, January 1992. Guidance on preparing
Superfund Decision Document (Preliminary Draft). Directive 9335.3-02, Washington,
DC.

U.S. Environmental Protection Agency, October 1991. Compendium of CERCLA
ARARs Fact Sheets and Directives. Washington DC.

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APPENDIX A
RESPONSIVENESS SUMMARY

I. SUMMARY OF PUBLIC AVAILABILITY SESSION

II. RESPONSES TO WRITTEN COMMENTS RECEIVED AT AVAILABILITY
SESSION, AUGUST 9,1995

III. RESPONSES TO WRITTEN COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD, JULY 15,1995 TO AUGUST 28,1995
I. SUMMARY OF PUBLIC AVAILABILITY SESSION
(Available to Public, September 15, 1995)

A Public Availability Session was held on August 9, 1995 from 4:00 to 9:00 PM on the Focused
Feasibility Study (FFS) and Proposed Plan for the Old Landfill Interim Remedial Action (IRA). The
Availability Session was located at the Dumfries District Community Cultural Arts Center and conducted in
accordance with requirements set forth in the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) and the National Oil and Hazardous Substances Contingency Plan (NCP). The purpose of
the Availability Session was to provide a forum to inform the community on the results of the FFS, the
alternatives presented in the Proposed Plan, and the preferred alternative for the IRA.

The Availability Session included four display booths featuring: the Old Landfill site history, site
investigation process, site characterization, and preferred IRA alternative. Administrative Record documents
were available.

Project representatives available to address citizen comments included: the Naval Facilities
Engineering Command, Engineering Field Activity Chesapeake (EFACHES); Environmental Protection Agency
(USEPA), Region III; Virginia Department of Environmental Quality (VDEQ); Halliburton NUS Corporation (HNUS)
and MCCDC, Quantico. Specifically, the representatives included:

Ms. Lisa M. Bradford USEPA Region III
Ms. Bernice Pasguini USEPA Region III
Ms. Jennifer Hubbard USEPA Region III
Mr. William Hudson USEPA Region III
Mr. David GrimesVDEQ
Mr. Tony Klimek HNUS
Mr. Heath Wells EFACHES
Ms. Angle Lower EFACHES
Maj. Fred Mock MCCDC, Quantico
Mr. Charles Grimm MCCDC, Quantico,
Mr. John Burleson MCCDC, Quantico,

During the five hour availability session, three citizens signed in, two of whom were briefed on the
project. Citizens were briefed on all display booths by Mr. Heath Wells, EFACHES. An additional information
exchange occurred with Mr. John Burleson regarding past practices at the Old Landfill.

One ciften from Dumfries, Virginia, provided information to Mr. Wells on objects previously
unidentifiable on aedal photographs of the scrapyard and said that they would contact Mr. Wells or Mr.
Burleson, MCCDC, at a later time to discuss additional information about past waste disposal practices on
board MCCDC, Quantico.

A second citizen from Triangle, Virginia, was interested in the contracting mechanisms and
possibilities for cleanup at MCCDC, Quantico, since they were interested in business potentials associated
with the Old Landfill cleanup earth moving aspects. Mr. Burleson explained that the Navy manages the
contracts for the Marine Corps through regional offices of the Naval Facilities Engineering Command.
Additionally, Mr. Burleson explained that the contracts were divided into investigatory and cleanup, the Navy
Comprehensive Long-term Environmental Action Navy (CLEAN) contracts and Remedial Action Contracts (RAG),
respectively. Mr. Burleson recommended contacting the RAG for the Old Landfill cleanup, Ohio Hazardous
Materials (OHM), Richmond Office, to get more information on becoming a potential subcontractor. The citizen
requested that their name be placed on the Interested Party Mailing List.

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      A third citizen from Triangle, Virginia came in briefly, took a copy of the Proposed Plan and left.
None of the three citizens submitted any written comments.

      Additional MCCDC,  Quantico affiliated personnel attended the Availability Session to find out more
about the project they were partially involved with and show support for the Availability Session concept.
Specifically, MCCDC affiliated personnel included:

      Ms. Kay Lyon              MCCDC, Counsels Office
      Ms. Penny Clark           MCCDC, Counsels Office
      Mr. Jim Yohn              MCCDC, Counsels Office
      Ms. Kelly Dreyer          HQ Marine Corps (LFL)
      Mr. William Fennel        MCCDC, NREAB Branch
      Mr. Mel MacDonald         OHM Corporation
      Mr. Charles Crenshaw      OHM Corporation

      The Availability Session concluded at 9:00 PM.


                   II. RESPONSES TO WRITTEN COMMENTS RECEIVED AT
                        AVAILABILITY SESSION, AUGUST 9,1995

    No written comments were received at the Public Availability Session.

                 III. RESPONSES TO WRITTEN COMMENTS RECEIVED DURING
             THE PUBLIC COMMENT PERIOD, JULY 16, 1995 TO AUGUST 28,1996

                        No citizen comments were received.

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