EPA/ROD/R03-98/081
                                   1998
EPA Superfund
     Record of Decision:
     NORFOLK NAVAL BASE (SEWELLS POINT NAVAL
     COMPLEX)
     EPA ID: VA6170061463
     OU07
     NORFOLK, VA
     09/30/1998

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EPA 541-R98-081

                      FINAL
           RECORD OF DECISION  -  OU 2
                CD LANDFILL SITE
         NAVAL  BASE, NORFOLK,  VIRGINIA

            CONTRACT TASK ORDER 0138

               SEPTEMBER 28,  1998

                  Prepared for:

             DEPARTMENT  OF THE NAVY
                ATLANTIC DIVISION
                NAVAL FACILITIES
              ENGINEERING COMMAND
                Norfolk,  Virginia
                     Under:

              LANTDIV CLEAN Program
           Contract N62470-89-D-4814

                  Prepared by:

           BAKER ENVIRONMENTAL,  INC.
            Coraopolis,  Pennsylvania

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                                 TABLE OF  CONTENTS


                                                                                 Page

ACRONYMS AND ABBREVIATIONS 	    iv

1.0   DECLARATION 	   1-1
      1.1 Site Name and Location 	   1-1
      1.2 Statement of Basis and Purpose 	   1-1
      1.3 Description of the Selected Remedy 	   1-1
      1.4 Statutory Determinations 	   1-2

2.0   DECISION SUMMARY 	   2-1
      2.1 Site Name, Location and Description 	   2-1
      2.2 Site History and Enforcement Activities 	   2-1
          2.2 1 Site History 	   2-1
          2.2.2 Previous Investigations 	   2-2
          2.2.3 Enforcement Actions 	   2-3
          2.2.4 Highlights of Community Participation 	   2-4
      2.3 Scope and Role of Response Action at OU 2 	   2-4
      2 . 4 Summary of Site Characteristics 	   2-5
          2.4.1 Sources of Contamination 	   2-7
          2.4.2 Description of Contamination 	   2-8
          2.4.3 Contaminant Migration 	   2-9
      2.5 Summary Of Site Risks 	  2-10
          2.5.1 Summary of Human Health Risks 	  2-10
          2.5.2 Summary of Ecological Evaluation  	  2-13
      2. 6 Description of Alternatives 	  2-16
          2.6.1 Soil Remedial Alternatives	  2-17
          2.6.2 Groundwater Remedial Alternatives 	  2-24
      2.7 Summary of Comparative Analysis of Alternatives 	  2-27
          2.7.1 Comparison of Soil Alternatives 	  2-28
          2.7.2 Comparison of Groundwater Alternatives 	  2-31
      2.8 The Selected Remedy 	  2-33
          2.8.1 Selected Soil Alternative 	  2-33
          2.8.2 Selected Groundwater/Surface Water Alternative 	  2-37
          2.8.3 Performance Standards 	  2-39
      2.9 Statutory Determinations 	  2-41
          2.9.1 Protection of Human Health and the Environment 	  2-42
          2.9.2 Compliance with Applicable or Relevant and
                Appropriate Reguirements 	  2-42
          2.9.3 Cost-Effectiveness 	  2-42
          2.9.4 Utilization of Permanent Solutions and Alternative Treatment
                Technologies to the Maximum Extent Practicable 	  2-43
          2.9.5 Preference for Treatment as a Principal Element 	  2-43

 3.0  RESPONSIVENESS SUMMARY 	  3-1
      3.1 Background on Community Involvement 	  3-1
      3.2 Summary of Public Comments 	  3-1

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                               APPENDICES

 A   VADEQ Concurrence Letter
 B   ARAR Tables
     B-la Federal Chemical-Specific ARARs by Media
     B-lb Federal Location-Specific ARARs
     B-2a Virginia Chemical-Specific ARARs by Media
     B-2b Virginia Location-Specific ARARs
     B-2c Virginia Action-Specific ARARs
 C   RI Sampling Results
     C-l  Surface Soil Data and COPC Selection Summary
     C-2  Subsurface Soil Data and COPC Selection Summary
     C-3  Shallow Groundwater Data and COPC Selection Summary
     C-4  Deep Groundwater Data and COPC Selection Summary
     C-5  Surface Water Data and COPC Selection Summary
                             LIST OF TABLES

2-1  Summary of COPCs
2-2  Incremental Lifetime Cancer Risks (ILCRs)  and Hazard Indices (His)  for Current
     Military Personnel
2-3  Incremental Lifetime Cancer Risks (ILCRs)  and Hazard Indices (His)  for Current/Future
     Adult and Child Trespassers
2-4  Incremental Lifetime Cancer Risks (ILCRs)  and Hazard Indices (His)  for Future Civilian
     Workers (Groundskeepers)  - Shallow Aguifer used as Non-Potable Source
2-5  Incremental Lifetime Cancer Risks (ILCRs)  and Hazard Indices (His)  for Future Civilian
     Workers (Groundskeepers)  - Deep Aguifer (Well Location GW-05C)  used as
     Non-Potable Source
2-6  Incremental Lifetime Cancer Risks (ILCRs)  and Hazard Indices (His)  for Future
     Construction Workers
2-7  Incremental Lifetime Cancer Risks (ILCRs)  and Hazard Indices (His)  for Future Adult
     and Young Child On-Site Residents - Shallow Aguifer used as Potable Source
2-8  Incremental Lifetime Cancer Risks (ILCRs)  and Hazard Indices (His)  for Future Adult
     and Young Child On-Site Residents - Deep Aguifer (Well Location (GW-05C)  used as
     Potable Source
2-9  Summary of Evaluation Criteria
                             LIST OF FIGURES

2-1  Site Location Map
2-2  Site Map
2-3  Preferred Soil Alternative SO-3
2-4  Alternative SO-4: Composite Cap Cross-Section

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                       ACRONYMS AND ABBREVIATIONS
ARARs      applicable, or relevant and appropriate requirements
AWQC       Ambient Water Quality Criteria
bgs        below ground surface
CERCLA     Comprehensive Environmental Response, Compensation and Liability Act
COPCs      contaminants of potential concern
CRDL       Contract Required Detection Limit
DoD        Department of Defense
DoN        Department of the Navy
ER-L       Effects Range-Low
ER-M       Effects Range-Median
ESI        Expanded Site Investigation
FS         Feasibility Study
GAG        granular activated carbon
HI         hazard index
IAS        Initial Assessment Study
ILCRs      incremental lifetime cancer risks
IDL        Instrument Detection Limit
IRP        Installation Restoration Program
LANTDIV    Atlantic Division, Naval Facilities Engineering Command
MCLs       Maximum Contaminant Levels
NAS        Naval Air Station
NCP        National Oil and Hazardous Substances Pollution Contingency Plan
NEX        Naval Exchange Complex
NOAA       National Oceanic and Atmospheric Administration
OU         Operable Unit
PAHs       polynuclear aromatic hydrocarbons
PCBs       polychlorinated biphenyls
PRAP       Proposed Remedial Action Plan
QIs        Quotient Indices
RA          Risk Assessment
RAOs        remedial action objectives
RCRA        Resource Conservation and Recovery Act
RI          Remedial Investigation
ROD         Record of Decision
SSLs        sediment screening levels
SSSLs       surface soil screening levels
SVOCS       semivolatile organic compounds
SWSLs       surface water screening levels
TBC         to be considered
TCLP        toxicity characteristic leaching procedure
TOX         total organic halogens
USEPA       United States Environmental Protection Agency
VADEQ       Virginia Department of Environmental Quality
VDWM        Virginia Department of Waste Management
VHWMR       Virginia Hazardous Waste Management Regulations
VOCS        volatile organic compounds
VSWMR       Virginia Solid Waste Management Regulations
WQS         water quality standard

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1.0   DECLARATION

1.1    Site Name and Location

Site 6,  CD Landfill  Site, Operable Unit 2 - Soil and Groundwater
Naval Base Norfolk
Norfolk, Virginia

1.2    Statement of  Basis  and  Purpose

This Decision Document presents the selected remedy for Site  6, CD Landfill Site, Operable
Unit 2 (OU 2)  - Soil and Groundwater, Naval Base,  Norfolk,  Virginia  (i.e., the "site"). The
selected remedy was  chosen  in accordance with the Comprehensive Environmental Response,
Compensation,  and Liability Act of 1980  (CERCLA),  as amended  by the  Superfund Amendments and
Reauthorization Act  of 1986 (SARA), and the National Oil and  Hazardous Substances Pollution
Contingency Plan.  (NCP). This decision is based on the Administrative Record for the CD
Landfill Site.

The United States Department of the Navy  (Navy)  and the United States Environmental
Protection Agency (USEPA) Region  III issue this decision document jointly. The Commonwealth
of Virginia concurs  with the selected remedy for OU 2 at the  CD Landfill  (See Appendix A).

Assessment of the Site

Actual or  threatened releases of  hazardous substances from OU 2, if  not addressed by
implementing the response actions selected in this Record of  Decision  (ROD), may present an
imminent and substantial endangerment to public health,  welfare, or  the environment.

1.3   Description   of  the  Selected  Remedy

The selected remedy  in this ROD is the permanent remedy for controlling contaminated soil,
groundwater,  and surface water for the CD Landfill site. The  major components of the selected
remedy for OU 2 include the following:

     •     Installation of a composite cap over  the  entire 22-acre landfill designed in
          accordance with the reguirements of the Virginia Solid Waste Management Regulations
          for an industrial waste landfill,  Part E  of  9  VAC 20-80-270;

     •     Land  use restrictions to prevent future residential development, public access, and
          use of shallow groundwater for any purpose  except monitoring;

     •     Post-closure guarterly shallow groundwater monitoring for one year that meets the
          reguirements of the Virginia Solid Waste  Management Regulations, Part  D of 9
          VAC 20-80-270.  After an analysis of the first  year of groundwater monitoring data,
          the sampling freguency shall change to annual  sampling for the groundwater guality
          parameters, and semi-annually for the  groundwater contamination indicator
          parameters. Post-closure shallow groundwater monitoring shall be conducted for ten
          years;

     •     Implementation of a guarterly groundwater monitoring program of the deep aguifer if
          organic contaminants are detected in  the  shall groundwater at the site.  Monitoring
          reguirements will be evaluated after  a period  of two years.

     •     Quarterly  surface water sampling at three locations at the site boundary for a
          period of  two years.

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1. 4    Statutory-Determinations

This selected remedy for OU 2, is protective of human health  and the environment, complies
with Federal and State  requirements that are legally applicable or relevant and appropriate
to this action,  and is  cost effective.

The selected remedy for OU 2 addresses the containment of  surface soils and landfill wastes
at the site. The selected remedy will provided for the long-term reduction of leachate
generation and possible contamination of the groundwater beneath the landfill, and surface
water in perimeter  drainage ditches.

This remedy fulfills the State of Virginia solid waste regulations for closure of an
industrial waste landfill by using a cap design and post-closure monitoring that meets state
requirements.  The installation of an engineered landfill cap  will eliminate direct contact,
ingestion, and inhalation threats from the contaminated soils, and will reduce the leaching
of contaminants to  groundwater by controlling precipitation entering the landfill and
minimizing leachate generation. Capping is a permanent solution and is a common remedy for
landfilled wastes.

This remedy uses permanent solutions and alternative treatment  (or resource recovery)
technologies to the maximum extent practicable for this Operable Unit. However, because
treatment of the principal threats of the Operable Unit was not found to be practicable,  the
remedy does not satisfy the statutory preference for treatment as a principal element.
Because the remedy  for  OU 2 will result in potentially hazardous substances remaining on-site
above health-based  levels, a review will be conducted,  at  a minimum, every five years,
consistent with Section 121(c) of CERCLA, 42 U.S.C.  °9621(c), after commencement of the
remedial action to  ensure that the remedy continues to provide adequate protection of human
health and the environment.



2.0   DECISION SUMMARY

2.1    Site  Name, Location and  Description

This Record of Decision (ROD) presents the Department of the  Navy's  (Navy) selected remedial
actions for Operable Unit 2 - Soil and Groundwater,  at CD  Landfill  (Site 6) ,  Naval Base,
Norfolk, Virginia (OU 2) .

OU 2 is located on  the  Naval Base, Norfolk, south of Admiral  Taussig Boulevard. The site  is
bordered by the Naval Exchange area to the north,  Naval Air Station  (NAS) to the east, a
long-term parking facility to the south and Hampton Boulevard to the west  (see Figure 2-1).
Seabee Road cuts across the western portion of the site (See  Figure 2-2).

The site was formerly used for the disposal of construction debris and other material. At
present the majority of the 22 acre landfill is vegetated  due in part to roadway construction
restoration activities.

Seabee Road has been landscaped with trees and shrubbery and  a fence has been installed on
either side to eliminate public access from the right-of-way  to the landfill area. Two
drainage ditches border the site to the north and south. These drainage ditches flow eastward
into culverts beneath the NAS which then convey surface water runoff to Willoughby Bay.

2.2    Site  History and  Enforcement  Activities

The history of the  site, previous site investigations,  and highlights of community
participation are summarized below.

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2.2.1  Site  History

Originally, the CD Landfill was part of the historic Bousch Creek drainage system.  The Navy
purchased the land in 1974. Prior to that time the land was owned and operated as a rail yard
by the Western Railway Company.

The site, shown in detail in Figure 2-2,  incorporates two areas of landfilling operations:
the easternmost (unpermitted)  section and the western (permitted)  section. The unpermitted
portion of the landfill was filled first and was used for demolition debris and inert solid
waste, fly ash, and incinerator residue.  From 1974 to 1979, ash residues,  sandblasting grit
and spent rice hulls were deposited in the landfill.

In 1979, soil and fill material from a portion of the southeast corner of the site was
removed and regraded to allow for runway expansion at the Naval Air Station (NAS).  The runway
expansion design specified that excess material was to be spread over the landfill and not
removed from the site.

In October 1979, the Naval Facilities Engineering Command received a permit from the Virginia
Department of Health to use the landfill (western portion)  for disposal of demolition debris
and other non-putrescible wastes. The permit excluded the disposal of fly ash, incinerator
residues, chemicals, and asbestos. Blasting grit used for sandblasting cadmium-plated
aircraft parts was deposited at the landfill until 1981 when the blasting grit was tested and
found to exceed the EP toxicity limit for cadmium. The grit was classified as a hazardous
waste and on-site disposal of the material ceased.

Landfilling operations continued in the western portion of the site until 1987.

In April 1993, construction began on a new roadway  (Seabee Road)  across the CD Landfill to
link Hampton Boulevard at the Base Pass Office to the Naval Exchange Complex  (NEX)  located
just north of the site. Construction plans reguired only the addition of fill material; no
cutting or grading into the existing landfill occurred.  Seabee Road was completed and opened
to the public on August 6, 1993. The road remains accessible to pedestrian and vehicular
traffic.

In late September 1993, most of the existing debris mounds situated in the north central
portion of the landfill were leveled and spread around the site to reduce the amount of
standing water which accumulated after rain events. A small area of debris remains in the
north central part of the site.

2.2.2  Previous Investigations

The following studies of the CD Landfill Site have been conducted:

     •    Initial Assessment Study (IAS)
     •    Confirmation Study
     •    Expanded Site Investigation (ESI)
     •    Limited Soils Study
     •    Remedial Investigation/Risk Assessment  (RI/RA)  and  Feasibility Study (FS)

In April 1982, an IAS was conducted at the Sewell's Point Naval Complex, Norfolk Naval Base.
The IAS identified 18 sites of concern with regard to potential contamination. The CD
Landfill  (Site 6)  was included as a potential area of concern. The IAS report, completed in
February 1983, documented the disposal of ash and spent blasting grit at the site.  Based on
the IAS findings,  surface water and sediment were sampled guarterly and then semi-annually
from 1983 to 1985.

In 1987, a Confirmation Study identified erosion from the landfill surface and/or chemical
precipitation as two potential sources of cadmium contamination in the sediment.

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An ESI, conducted from February 1990 to June 1991,  detected  concentrations of cadmium, iron,
lead, and total organic halogens (TOX)  in subsurface  soils and  sediment. Cadmium and lead
were not detected in surface water.

In 1992 a Limited Soils Study was conducted in the  northwestern portion of the landfill in
the vicinity of the proposed Seabee  Road.  Analytical  results of the  study indicated total
lead and cadmium concentrations in soils;  however,  no samples exceeded the Virginia
Department of Waste Management (VDWM)  action levels for  TCLP-lead  or TCLP-cadmium.

The results of the previous investigations guided the scoping of the RI, performed in
1993/1994.

The RI was completed in three separate rounds of sampling. Soil, sediment, groundwater, and
surface water samples were collected.  The results of  the RI  are presented later in this
document, and this information was used as the basis  for the FS, completed in 1996, that
identified and evaluated potential remedial alternatives for the site.

2.2.3  Enforcement Actions

Based on reviews of the ESI, the Virginia Depart of Environmental  Quality  (VADEQ) notified
the Navy on June 5, 1992 of a proposed Enforcement  Order addressing  concerns that hazardous
waste had been disposed at the site. VADEQ was concerned that the  site was not in compliance
with the Virginia Hazardous Waste Management Regulations (VHWMR).  The Navy and VADEQ met on
August 4, 1992 to discuss the proposed enforcement  action. The  Navy  responded to the proposed
enforcement action on August 18,  1992 stating the Navy's position  to address the entire site
as part of the Naval Bases' Installation Restoration  program (IRP) ,  and provided supporting
rationale and documentation. The VADEQ rescinded the  enforcement action on December 9, 1992
based on the August meeting and the  Navy's position to study the entire site under the IRP.

The Naval Base Norfolk was placed on the National Priorities List  (NPL) on April 1, 1997.

2.2.4  Highlights  of Community  Participation

The Final RURA (December, 1995),  Final FS (July 1996), as well  as  the Final Proposed Remedial
Action Plan (PRAP) (June 1998) for OU 2 at the CD Landfill Site have been released and made
available to the public in the Administrative Record  at  the  Kirn Memorial Branch of the
Norfolk Public Library in Norfolk, Virginia and at  information  repositories maintained at the
Larchmont and Mary Pretlow Branches  of the Norfolk  Public Library  and the Naval Station
Library.

The notice of availability of the RI/RA and FS was  published in the  Virginian Pilot on July
15, 1996.

A public comment period for these documents was held  from July  15, 1996 to August 15, 1996.

A notice of availability of the Final PRAP was published in  the Virginian Pilot on June 5, 6,
and 7, 1998. No written comments were received during the comment  period. A public meeting
was conducted on Wednesday, June 24, 1998 at the Naval Base  Environmental Offices  (Building
N-26). No one from the local community attended the meeting  and no comments or guestions were
raised.

2.3   Scope  and  Role  of  Response Action  at  OU 2

Previous waste disposal practices at the CD Landfill  have impacted soil, groundwater, and
surface water at the site. The selected remedy identified in this  ROD addresses all
contaminated media of concern at the site as identified  in the  RI  and FS Reports, and
comprises the overall cleanup strategy for the site.  The selected  remedy for these media are
identified and the rationale for their selection is described in Section 2.7.

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The selected remedy will reduce the potential risk to human health and the environment
associated with the surface/subsurface soils, groundwater,  and surface water.  The remedy will
provide effective source control and substantially reduce the potential for migration of
contamination. The remedy includes the installation of an impermeable cap that meets the
reguirements of the Virginia Solid Waste Regulations for industrial waste landfills. The cap
will reduce exposure to contaminants at the site and will reduce infiltration into the
landfill. A groundwater/surface water monitoring program will track migration of groundwater
contamination to ensure that the contamination is not migrating past the site boundary.

The remedy is consistent with the long-term remedial goals  for soil and groundwater at the CD
Landfill. The remedial action will reduce the threat of human exposure to potential
contamination in soils and groundwater. The action will also minimize the movement of
potential contaminants from soils to the groundwater and surface water. The cap will prevent
the exposure of surface soils to ecological receptors. Groundwater monitoring will track the
migration of shallow groundwater toward site boundaries. Institutional controls will prevent
the future use of the Yorktown Aguifer as a potable water source at the site.

The selected remedy is expected to comply with applicable,  or relevant and appropriate
reguirements  (ARARs) and "to be considered"  (TBC) reguirements.  ARARs and TBC reguirements
are federal and state environmental statutes that are either directly applicable or are
considered in the development and evaluation of remedial Alternatives at a particular site.
(See Appendix B for a listing of ARARs.)

2.4   Summary  of  Site  Characteristics

This section provides a summary of the features of the site,  and of the nature and extent of
soil, groundwater, and surface water contamination at the site.

The fill materials encountered at the CD Landfill consist of metal, plastic,  glass,  wood and
concrete debris, blast furnace cinders, wiring and miscellaneous construction rubble with a
primary soil matrix of silt or sand. Distinguishing soil cover from surficially deposited
fill material was difficult as each consisted of silt and sand.  Fill material was generally
encountered at or near ground surface to depths of between  3.5 and 12.0 feet below ground
surface  (bgs) and tends to increase in thickness from west  to east, indicating a gradual
topographic low existed in the eastern portion of the site  prior to landfilling operations.
In addition, shallow fill was encountered north of the northern drainage ditch possibly due
to past rail yard activities.

Surface Water - Surface water at CD Landfill is primarily accommodated by two drainage
ditches located at the northern and southern boundaries which merge at the eastern end of the
site. Both ditches, (unlined and heavily sedimented) were constructed to facilitate runoff of
surface water from the landfill area. Surface water in the  ditches is conveyed to the Bousch
Creek drainage channel which eventually empties into Willoughby Bay. Due to the proximity of
this area to Willoughby Bay and the low relief of the land  surface, the remnant tributaries
of Bousch Creek are tidal throughout the Base. However, the drainage ditches bordering the CD
Landfill are not tidal except in the immediate vicinity of  the confluence with the Bousch
Creek drainage channel. Surface water from the Naval Exchange parking area (located just
northwest of the site)  is directed via a storm sewer to the northern drainage ditch.

Groundwater - The Columbia (watertable) Aguifer and, to some extent, the underlying Yorktown
Aguifer are the primary aguifer systems of concern at the CD Landfill Site. The Columbia
Aguifer in the vicinity of the site is generally not suitable for potable  (drinking water)
use because of high concentrations of iron, manganese, and  total dissolved solids,  as well as
low pH (less than 6).  The deeper Yorktown Aguifer is generally suitable for potable uses,
except near tidal waters, where the water can be brackish in guality.

Shallow groundwater is present as an unconfined aguifer with a water level ranging from
approximately four to six feet bgs within the fill material.  The aguifer extends about 25 to
30 feet to a confining clay unit (if present). Shallow groundwater within the fill tends to

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follow the historical (now subsurface)  land contours. Groundwater movement across the site,
in general, appears to be to the northeast, but tends toward the direction of flow in the
drainage ditches bordering the northern and eastern portions of the site in the immediate
vicinity of the ditches. The maximum estimated groundwater flow velocity for the central
portion of the site was calculated to be 3.5 feet per year. The maximum estimated groundwater
flow velocity for the northeastern/eastern portion of the site was calculated to be 17.5 feet
per year. The difference in groundwater flow velocity is based on the inconsistency of
groundwater gradients throughout the site.

Based on regional information, it is believed that deeper groundwater in the Yorktown Aguifer
flows in a more northerly direction towards the Elizabeth River and Willoughby Bay. Because
the primary concern of the RI was to characterize groundwater conditions in the Columbia
Aguifer, site-specific data was not generated to confirm deep groundwater flow direction, as
only one well was installed into the Yorktown Aguifer. However, based on information
generated during the RI for the Camp Allen Landfill site, located approximately 4,500 feet to
the southeast, the Yorktown Aguifer is separated from the water table aguifer by a
semi-confining clay unit. This leaky condition primarily is due to the presence of a breach
and/or ineffective (poorly developed) portions of the confining clay unit at the base of the
Columbia Group. The breached or ineffective portions allow for the downward migration of
constituents. Average groundwater flow velocities in the Yorktown Aguifer range from
approximately 0.001 to 0.08 feet/day.

The Yorktown Formation underlies the Columbia Group, and is characterized by coarse sand,
gravel, and abundant shell fragments. Regionally, the Yorktown Formation ranges in thickness
from 300 to 400 feet. In the vicinity of the site, the Yorktown was encountered at depths of
40 and 60 feet below ground surface  (bgs). However, thickness of the Yorktown was not
determined during the remedial investigation.

Wetlands - No federal or state regulated wetlands have been identified at the site.

Ecology - The area around the CD Landfill is largely urban, and few natural resources are
present. Areas of underbrush, narrow wooded strips, and opportunistic wetlands (established
along the ditches) are located adjacent to the landfill.

2.4.1  Sources of  Contamination

Based on the available information and analytical data, the major disposal area for the CD
Landfill appears to be the central and eastern portions of the site, probably extending
southeastward into the NAS glide path (See Figure 2-2). The geophysical investigation
completed during the RI indicated metal disposal in the eastern portion of the landfill and
isolated areas in the northern, northwestern and southwestern sections of the site. However,
no "hot spots" (discrete areas of contaminated soil) were identified.

2.4.2  Description of Contamination

Based on site history, previous investigations and RI findings, contamination from prior
disposal practices at the CD Landfill Site has impacted surface soil, subsurface soil,
sediment, surface water, and groundwater (water table and potentially the Yorktown Aguifer
systems). In general, the primary contaminants of potential concern  (COPCs) are several
inorganic constituents,  and to a lesser extent, specific volatile organic compounds (VOCs),
semivolatile organic compounds (SVOCs),  pesticides, and polychlorinated biphenyls  (PCBs).

As part of the RI chemicals detected in OU 2 soil, groundwater and surface water were
compared to applicable Federal and Commonwealth of Virginia criteria and/or standards, and a
preliminary list of COPCs was identified.  The following brief summary of the nature and
extent of contamination focuses on the primary COPCs associated with site soil and
groundwater and is not intended to address all results in detail. A gualitative summary of
the COPCs for each medium is presented in Table 2-1.

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Specific summary tables for each medium: surface soil,  subsurface soil,  surface water,  and
groundwater, are presented in Appendix C.

Surface Soil - Analytical results indicate surficial soil to be nominally impacted by
disposal activities. Inorganics and organics were detected site-wide; however,  the
concentrations were low and, with the exception of several inorganics, generally do not
exceed risk-based concentrations for human health. The exceptions include lead and arsenic,
which were detected in one surface soil sample at 1,040 milligrams per kilogram (mg/kg) and
34.9 mg/kg, respectively.

Subsurface Soil - Analytical results indicate subsurface soils to be impacted by disposal
activities.

As anticipated, based on the site disposal history,  inorganic contamination is widely
distributed over the site, and at least to the water table. In general,  concentrations  do not
exceed risk-based concentrations except at specific locations.

Surface Water - Results indicate various inorganic and pesticide constituent concentrations
exceeding Federal Ambient Water Quality Criteria and Virginia Water Quality Standards,
referred to in the ecological risk assessment as surface water screening levels (SWSLs).

Shallow Groundwater (water table) Aquifer - At some locations, inorganics were detected in
shallow groundwater at levels exceeding Maximum Contaminant Levels (MCLs),  Virginia
Groundwater Quality Standards, and Virginia Drinking Water Standards. Water quality data were
also observed at levels in excess of MCLs and Virginia Water Quality Standards. Elevated
metals concentrations in unfiltered samples from shallow monitoring wells may be the result
of turbidity (i.e., suspended solids)  in the wells rather than actual leaching of
contaminants from the soils to groundwater. No clear trends or plumes associated with
inorganics are evident. Radionuclides were also observed at levels in excess of the MCL and
Virginia Water Quality Standards. However, the presence of radionuclides appears to be
indicative of natural origin. Chlorobenzene was detected in one shallow well at a
concentration significantly above the MCL, but appears to be of relatively limited extent in
the extreme eastern portion of the site. While shallow groundwater contamination does not
appear to be impacting surface water leaving the site,  the SVOC 1,4-dichlorobenzene was also
detected in MW 05A, and in two surface water samples (SW 08 and SW 12) collected from areas
near MW 05A. This may indicate that, at certain times,  groundwater may be discharged to the
drainage ditches along the eastern portion of the site.

Deep Groundwater (Yorktown) Aquifer - Monitoring wells MW 03B and MW 05C at the site
provide data concerning the quality of groundwater in the Yorktown Aquifer. RI sampling
results from these two wells indicate that the Yorktown Aquifer has been marginally impacted
by the landfill. No organic contaminants were detected in these wells during two sampling
rounds. During Round 1, lead was detected in an unfiltered sample at 16.9 micrograms per
liter  (Ig/L), which slightly exceeds the MCL of 15 Ig/L. However, the Round 2 total lead
concentration was only 1.4 Ig/L, and no lead was detected in the filtered samples collected
from either sampling round. Iron and manganese concentrations exceeded secondary MCLs;
however, these constituents may not be site-related and may be a result of turbidity in the
wells caused by well bailing during sampling.

2.4.3  Contaminant  Migration

The COPCs identified at the CD Landfill consist of inorganics in surface and subsurface soil,
and groundwater. VOCs and SVOCs were also detected in groundwater and surface water. These
COPCs may present risks to human and ecological receptors. These contaminants are expected to
migrate via surface runoff or through the soils by dissolution to groundwater,  and transport
by groundwater to receptors in surface water and sediment. Installation of a landfill capping
system will minimize the potential for surface water runoff of contaminants, and the
infiltration and transport of contaminants into the underlying groundwater. Although
groundwater at the site is currently not used for any purpose, contaminated groundwater could

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pose a human health risk if utilized as a drinking water source under a future  residential
use scenario. By implementing institutional controls and long-term monitoring,  an evaluation
of groundwater guality and migration can be developed over time to ensure  protection of  human
health.

2.5   Summary  Of  Site  Risks

The public health and ecological risks associated with exposure to contaminated media within
the CD Landfill Site were evaluated in the RI/RA Report.  The public health baseline  risk
assessment evaluated and assessed the potential public health risks which  might result under
current and potential future land use scenarios.  It should be noted that the  Navy has no
plans for changing the land use of the site from its present status as landfill area. An
ecological evaluation also was performed and addressed the ecological integrity at the CD
Landfill Site. A summary of the public health and ecological risks associated with the site
are summarized below.

2.5.1  Summary of  Human Health Risks

The National Oil and Hazardous Substances Pollution Contingency Plan ("NCP")  established
acceptable levels of carcinogenic risk for Superfund sites ranging from one excess cancer
case per 10,000 people exposed to one excess cancer case per one million people exposed. This
translates to a risk range of between one in 10,000 and one in one million additional cancer
cases. Expressed as scientific notation,  this risk range is between 10 -4  and 10 -6.  Remedial
action is warranted at a site when the calculated cancer risk level exceeds 10  -4. However,
since EPA's cleanup goal is generally to reduce the risk to 10 -6 or less,  EPA  also
recommends action where tile risk is within the range between 10 -4 and 10 -6.

The NCP also states that sites should not pose a health threat due to a non-carcinogenic, but
otherwise hazardous,  chemical. EPA defines a non-carcinogenic threat by the ratio of the
contaminant concentration at the site that a person may encounter to the established safe
concentration. If the ratio,  called the Hazard Index (HI),  exceeds one (1.0), there  may  be
concern for the potential non-carcinogenic health effects associated with  exposure to the
contaminants. The HI identifies the potential for the most sensitive individuals to  be
adversely affected by the non carcinogenic effects of contaminants. As a rule,  the greater
the value of the HI above 1.0, the greater the level of concern.

Incremental lifetime cancer risks (ILCRs)  and the potential to experience  non-carcinogenic
adverse effects (i.e.,  central nervous system effects,  kidney effects,  etc.), as measured by
a hazard index (HI),  were evaluated in the RI/RA. Estimated incremental cancer  risks were
compared to the acceptable risk range of 10 -4 to 10 -6.  The calculated HI was  compared  to
the threshold value of one. The baseline risk assessment evaluated potential  risks which
might result under the following land use scenarios:

     •    Current Military Personnel
     •    Current/Future  Adult and Child Trespassers
     •    Future Civilian Workers  using Shallow Groundwater  for  Nonpotable Use
     •    Future Civilian Workers  using Deep  Groundwater  for Nonpotable Use
     •    Future Construction  Workers
     •    Future On-site  Residents using Shallow  Groundwater for Potable Use
     •    Future On-site  Residents using Deep Groundwater for  Potable Use

The risk assessment indicates that past practices at the CD Landfill Site  have  contaminated
certain media to the extent that they pose a potential threat to human health only under
certain potential future land use scenarios.  Although future residential use  scenarios are
unlikely at the site, they have been incorporated into the baseline comparisons.  The results
of the human health risk assessment for the various exposure scenarios are summarized below.

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Current Military Personnel

The current military personnel risk scenario was evaluated for military personnel stationed
at the Naval Base who may contact surface soil and surface water at the site. The scenario
was based on an exposure duration of 4 years, which is the typical assignment period for the
military. Table 2-2 shows the results of this scenario. Results indicate that there are no
unacceptable risks to current military personnel posed by any of the contaminated media
(i.e., surface soils and surface water)  at the CD Landfill Site.

Current/Future Adult and Child Trespassers

For the current/future adult and child trespasser scenario, it was conservatively assumed
that adults and older children (ages 7-15 years old),  who live in the vicinity of the site,
may trespass onto the site and become exposed to site surface soil and surface water. This
scenario is considered conservative since the trespasser access is restricted by a chain-link
fence that encloses the CD Landfill area. As shown on Table 2-3, results indicate that cancer
risks are within the acceptable range of 10 -4 to 10 -6 and the Hazard Index is less than
1.0.

Future Civilian Workers using Shallow Groundwater for Nonpotable Use

This exposure scenario was evaluated for potential future civilian workers using shallow
groundwater for nonpotable uses such as lawn watering and vehicle washing. Each of the
shallow groundwater COPCs was detected in only one monitoring well; therefore, all evaluation
of dermal contact with these constituents represents an extremely conservative exposure
scenario. As shown in Table 2-4,  shallow groundwater poses a potential unacceptable risk to
human health through dermal contact, for which the total ILCR is 9.1 x 10 -4 and HI is 3.8.
PCB Aroclor 1260, detected in the shallow groundwater is the greatest contributor to the
cancer risk, and chlorobenzene is the primary non-carcinogen responsible for the elevated HI
value. It should be noted that Aroclor 1260 was only detected in one monitoring well at a
concentration of 0.12 Ig/L in sampling round 2.

Future Civilian Workers using Deep Groundwater for Nonpotable Use

This exposure scenario was evaluated for potential future civilian workers using deep
groundwater (i.e., Yorktown Aguifer) for nonpotable uses such as lawn watering and vehicle
washing. As shown in Table 2-5, the total ILCR is only slightly above the acceptable risk
range at 1.2 x 10 -4, and the Hazard Index is 0.43.

Future Construction Workers

This exposure scenario was evaluated for potential construction workers who may contact
surface and subsurface soils during any future excavation and construction activities
performed at the site.

As shown in Table 2-6, the ILCR is within the acceptable risk range of 10 -4 to 10 -6 and the
Hazard Index is 5.8, which exceeds the acceptable level of 1.

Future On-site Residents using Shallow Groundwater for Potable Use

This exposure scenario was evaluated based on the unlikely scenario that tile landfill would
be used as a residential area in the future and that shallow groundwater would be used as a
potable water source. As shown in Table 2-7, the total ILCR exceeds the acceptable range at
1.6 x 10 -3 (adults) and 7.9 x 10 -4 (children), and the HI is 17 for adults and 51 for
children.

Considering a potable groundwater use scenario, shallow groundwater contributes the majority
of the risk presented, including a carcinogenic risk of 1.2 x 10 -3 for adults and 5.2 x 10
-4 for children and a HI of 12 for adults and 30 for children through dermal contact and
ingestion. Manganese was the greatest contributor to the risk associated with groundwater

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ingestion, and Aroclor 1260 was the greatest risk driver for dermal contact.

Future On-site Residents using Deep Groundwater for Potable Use

This exposure scenario is identical to the previously described residential scenario with the
exception that deep groundwater (Yorktown Aguifer)  would be used as a potable water source.
Although the total risk from soil, surface water, and groundwater exceeds EPA's acceptable
levels under a potable use scenario,  deep groundwater would not pose a carcinogenic risk (no
carcinogens identified in groundwater) and the HI would be less than 1.0 (See Table 2-8).

2.5.2  Summary of Ecological Evaluation

In addition to the human health risks identified for the CD Landfill, an ecological risk
assessment (ERA)  was also completed as part of the RI/RA Report. The ERA considered the same
media as the human health risk assessment: soils, surface water (from site drainage ditches),
sediments, and groundwater. The Decision Document for OU 1 summarized the ecological risks
presented by the site sediments, and a separate remedial action is in process for site
sediments. Therefore,  site sediments are not included in this section.

The ERA evaluated and analyzed the results from the RI, including sampling and chemical
analysis of the media of concern.  Potential ecological receptors were determined from
observations during the RI, and from a habitat evaluation that was conducted to identify
potential aguatic and terrestrial ecological receptors. Contaminants detected in these media
were evaluated to determine if they posed a risk to either aguatic or terrestrial receptors.

Quantifying an ecological risk for all contaminants identified can distract from the dominant
risk driving contaminants at the site. Therefore, the overall list of identified contaminants
was reduced to a list of COPCs. The COPCs are site-related contaminants used to estimate
ecological exposures and potential adverse effects on the site receptors. The following
criteria were used in selecting COPCS:

     •    Historical Information - contaminants  that  were  not  related to the site,  such as
          calcium, magnesium,  potassium,  and sodium were not  retained as COPCs.

     •    Prevalence  (freguency of positive  detections)  -  contaminants that  were  detected in
          five  percent  or less of  the  samples  were  not  retained as  COPCs.

     •    Toxicity - several  of the contaminants detected  were prevalent, but  their inherent
          toxicity to  ecological receptors was low, therefore,  they were not retained  as
          COPCs.

     •    Comparison to Federal  and State criteria  -  this  includes  State Water Quality
          Standards  (WQS)  for surface  water; USEPA  Region  III  Surface Water  Screening  Levels
          (SWSLs), and  Surface Soils  Screening Levels (SSSLs).  These standards or criteria are
          also  based on the toxicity  of  the  contaminant.

     •    Comparison to Field and  Laboratory Blank  Data -  common laboratory  contaminants were
          not retained  as COPCs.

Summaries of the ecological risks to aguatic or terrestrial receptors are presented on the
following page.

Aquatic Risks - Potential ecological risks to aguatic receptors were evaluated based on
analytical data from both surface water and groundwater samples. For both media,  a list of
COPCs was determined by comparing the concentration of the COPC to the SWSLs  (SWSLs have been
developed for both acute and chronic toxicity). A contaminant with a concentration that
exceeded the SWSL was retained as a COPC. When evaluating the inorganic contaminant data,
both total and dissolved concentrations were considered. However,  it is generally accepted
that only the dissolved fraction of an inorganic is bioavailable to aguatic receptors.

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After a COPC was identified, the risk characterization of that contaminant was estimated.  The
risk characterization evaluated the likelihood of adverse effects that may occur as a result
of exposure to a contaminant. This evaluation was based on a calculated Quotient Indices
(QI), which is the ratio of the actual contaminant concentration in the surface water or
groundwater sample to the respective SWSL. A QI that exceeded a value of 1 indicates that
exposure to a contaminant could potentially cause adverse effects to the receptor.

A summary of the aquatic risks indicates that the QI for total dieldrin, 4,4'-DDD,  and 13  of
the inorganics exceeded the recommended level of "1". However, only five of tile dissolved
inorganics had QIs that exceeded "1" (copper, cobalt, iron,  manganese,  and nickel) , and the
concentrations of these were several orders of magnitude less than the total concentrations
for most of the contaminants. This is significant in that,  primarily, it is only the
dissolved fraction of inorganics that is bioavailable to aguatic receptors.

Dieldrin and 4,4'-DDD may cause a moderate risk to aguatic receptors via toxicity.  The source
of the pesticides at this site was most likely from years of surface applications of
pesticides for the control of pests/vermin during landfilling operations.

Cobalt, copper, and nickel only slightly exceeded their respective SWSLs;  therefore, there is
a slight potential risk to aguatic receptors from these contaminants. Potential risks to
aguatic life from iron are expected to be high, and iron increases in concentration in the
downstream samples. Iron may be site-related.

Some of the contaminants detected in the surface water have a high potential for
bioaccumulating in biota (i.e., pesticides, PCBs, and some inorganics). Therefore,  there is
the potential for some aguatic and terrestrial receptors to become exposed to contaminants
that have bioaccumulated in the biota.

Terrestrial Risks - Several inorganics, and a few organics,  were detected at concentrations
in the surface soils above the SSSLs. There are some small areas of underbrush, narrow wooded
strips, and wetlands located on site. Therefore, potential adverse impacts to terrestrial
flora and fauna may be possible. However, the terrestrial environment appeared to be
unaffected by site contaminants based on visual observations. Gross effects of contamination
(i.e., death or illness of wildlife, vegetative stress)  were not observed. Although the
terrestrial study was gualitative only, habitats appeared to be diverse and included species
to be expected, particularly in an urban environment.

Threatened and Endangered Species - No federal or state endangered or threatened species are
expected to be present at the CD Landfill Site. The peregrine falcon has been sighted near
Camp Allen, which is located southeast of the CD Landfill site. There is a low potential that
the falcon will be feeding on fish in the drainage ditches at the site, since the ditches  are
not large enough to support a significant fish population.  Therefore, the risk of potential
impacts to threatened or endangered species from contaminants associated with the CD Landfill
is very small.

Wetlands - No federal or state regulated wetlands were identified at the site.

2.6   Description of  Alternatives

A detailed analysis of the possible remedial alternatives for tile soil, sediment and
groundwater at the CD Landfill Site was conducted as part of the FS Report. The detailed
analysis was conducted in accordance with the USEPA document entitled "Guidance for
Conducting Remedial Investigations and Feasibility Studies under CERCLA" and the NCP. Based
on the results of this analysis, the Navy is proceeding with a remedial action for sediments
at the site which was presented in a separate decision document for sediments, which was
categorized as OU 1. A summary of the remedial alternatives evaluated for OU 2, soil and
groundwater, is presented below.

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2.6.1  Soil  Remedial Alternatives

The primary contaminants of concern in soils are benzo[a]pyrene,  dieldrin,  and various
inorganics.

The following four remedial alternatives were considered for site soils:

          Alternative  SO-1:  No Action

          Alternative  SO-2:  Institutional Controls

     •    Alternative  SO-3:  Solid Waste  Landfill  Cap with Institutional Controls and Post
          Closure  Groundwater Monitoring

     •    Alternative  SO-4:  Hazardous Waste  Landfill Cap with Institutional Controls

Descriptions of these remedial alternatives, as well as estimated alternative costs,  are
provided below.

Alternative SO-1:  No Action

Description: No action would be taken to remediate soils or to  restrict site  access.

Cost: The estimated costs of Alternative SO-1 are as follows:

          Capital:                                        $     0
     •    Annual operation  and maintenance:               $  5,000
          Net  present  worth (30-year):                    $15,400

Alternative SO—2:  Institutional Controls

Description: Under this alternative,  the Navy would implement several institutional controls
to limit site access and restrict site use.  Controls would be implemented on  the landfill
site itself and drainage ditches located on and adjacent to the landfill  and  within any
fenced area.

The Navy would commit to the following land use restrictions to protect the integrity of the
landfill cover and to limit exposure due to the continuing presence of solid  waste at the
site:

     •    The  Navy would allow no future residential development  on the site;

     •    The  Navy would allow no use of shallow  groundwater, potable  or nonpotable,
          underlying the site for any purpose  except for monitoring;

     •    The  Navy would allow no public access to  the  site;

     •    The  Navy would not take or allow any other action  that would disturb  the  integrity
          of the landfill cover  or  disturb the function  of the monitoring systems.

     •    The  Navy would implement  the following  institutional controls to  ensure that  the
          above limitations are  properly and effectively carried  out:

     •    The  Navy would maintain the existing fences and gates at the site to  limit access to
          the  former landfill. The  Navy  also would  install warning signs at each gate entrance
          to indicate  that  solid waste is buried  at the  site.

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     •     The  Navy would  note  the  changes  and  restrictions  associated with the  site in the
          next revision to  the Naval  Base  Norfolk Master  Plan. The Master Plan  is a
          comprehensive planning document  consulted by both Naval Base personnel and the
          Atlantic Division, Naval Facilities  Engineering Command when making on-base
          planning,  development and construction decisions. The Master Plan would identify a
          land use category for the site that  would prohibit  residential use of the area as
          well as any  invasive construction  activities. The Master Plan would reflect the
          location and dimensions  of  the site,  the location of any fencing, signs and
          monitoring wells,  and would incorporate the land  use restrictions stated above.

     •     The  Naval  Base  Norfolk real property file and any base planning maps  or other
          documents  maintained at  the base and the Atlantic Division, Naval Facilities
          Engineering  Command  also would be  revised to note the land use restrictions
          established  for land comprising  the  site and to cross reference these restrictions
          in the Naval Base Norfolk Master Plan.

     •     The  Navy would  provide the  general public with  notice of the past use of the site
          and  information on land  use restrictions to be  implemented by taking  the following
          actions:

               •    Preparing a survey plat that indicates the location and dimensions of the
                   site and the location of all monitoring wells.  The survey plat also would
                   state that use of the site is limited as stated above.  The Navy would submit
                   the survey plat to the local recording authority.

               •    Recording a notation on real property documents evidencing the United
                   States'  ownership of the property on which the site is located that will
                   notify interested parties that the site was previously used to manage solid
                   waste.

               •    The Navy would conduct an annual inspections to insure that land use at the
                   site has remained consistent with the restrictions imposed.  Based oil these
                   inspections,  the Navy would certify to USEPA Region III and to the
                   Commonwealth of Virginia that institutional controls are in place and
                   operational.

Note that Federal government entities are  subject to extensive reguirements  under CERCLA
120(h)  regarding cleanup of real  property to be transferred out of Federal hands.  In addition
to complying with statutory reguirements,  to insure that the  above land use  restrictions are
adhered to if the Navy or the United States  relinguishes control  or disposes  of the  property
on which the site is situated, the Navy commits to taking the following future  actions:

     •     If the property on which the site  is  located is transferred to another Federal
          government entity, the Navy would  insure that the institutional controls described
          above will remain in effect after  the transfer. Transfer documents would
          specifically reguire continued implementation of  land use restrictions and would
          impose upon  the transferee  Federal government entity the obligation to maintain the
          fencing, warning  signs and  monitoring well heads. The Navy would prepare a site map
          that would be marked with the location and dimensions of the former landfill on the
          site and the location of fencing, warning signs and monitoring wells, and include
          this site  map as  an  attachment to  the appropriate transfer documents. As between the
          Navy and the Federal government  transferee, any Navy obligations to the transferee
          for  continued responsibility for the  transferred  site would be made contingent on
          the  transferee's  adherence  to the  limitations on  the use of the site  spelled out in
          tile transfer documents  and site map.

     •     If the property on which the site  is  located is conveyed to a non-Federal government
          entity, and  the Navy is  empowered  to  dispose of the property directly, The Navy
          would insure that the deed  effecting such action  contains an casement or covenant in
          favor of the U.S.  Government that will impose the land use restrictions. The Navy

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          also would prepare a survey plat,  similar to the site map described above,  that
          reflects  the existence of this  deed and land use restrictions  that have been imposed
          on the site therein.  Upon conveyance of the property,  both the deed and the survey
          plat would be recorded,  and the Navy would make arrangements  to insure that the
          integrity of the fencing,  warning signs and monitoring well heads  are maintained,  as
          well as insuring that the land  use restrictions are complied with  by the grantee.  As
          between the Navy and its transferee,  any Navy obligation to the transferee
          non-Federal entity for continued responsibility for the site would be made
          contingent on the transferee non-Federal entity's adherence to the limitations  on
          the use of the site indicated in the site map and transfer documents.

     •     If the property on which the site is located is conveyed to a  non-Federal entity,
          and the Navy is not empowered to dispose of the property,  the  Navy would take all
          steps necessary and permissible to ensure that the Federal entity  disposing of  the
          property  takes the steps outlined above,  unless the property  is remediated  to
          residential standards prior to  such transfer.

Cost: The estimated costs of Alternative SO-2 are as follows:

          Capital:                                         $ 1,000
     •     Annual operation and maintenance:                $ 4,400
          Net present worth (30-year):                     $69,000

Alternative SO-3: Solid Waste Landfill Cap with Institutional Controls and Post-Closure
Gro'uiid.wa.ter MOPT torincr

Description: This alternative would include the construction of a capping system that meets
the closure reguirements of the Virginia Solid Waste Management Regulations  (VSWMR) for an
Industrial Waste Landfill  (9 VAC 20-80-270E). This alternative would include:

     •     Construction of a capping system over the entire 22 acre site  (inclusive of the
          permitted and un-permitted landfill areas).  The capping system would be divided into
          three sections or areas,  with Seabee Road dividing the western portion of the cap,
          and a drainage ditch along the  southeast corner separating the portion of the cap
          constructed over the landfill area within the airfield runway  approach from the
          remainder of the landfill.  Seabee Road would remain intact along with its right-of-
          way,  and  the capping system shall be extended to the edge of  the roadway. Access to
          the site  would be accommodated  via improved gravel roadways along  the perimeter
          fencing,  as shown in Figure 2-3.

     •     Implementation of institutional controls,  as described under Alternative SO-2,  to
          restrict  access to the entire landfill and limit the site to non-residential use.
          Existing  fencing and new fencing to be constructed (as shown  on Figure 2-3)  would
          limit site access.

     •     Initiating a shallow groundwater monitoring program that meets the reguirements of
          Part D of 9 VAC 20-80-270.  The  groundwater monitoring program  will meet the Phase  I
          monitoring reguirements  specified in Part D.5,  which includes  groundwater guality
          parameters and indicator parameters.  (Note that a separate groundwater monitoring
          program,  that is not related to the VSWMR reguirements,  is proposed for groundwater
          remedial  alternative GW-2).  The monitoring program would start after the cap is
          constructed,  and would include:

               •     Quarterly sampling  for one year  (four  consecutive guarterly  sampling
                    events), for the groundwater guality parameters  and groundwater
                    contamination indicator parameters.

               •     Samples would be collected from the following  six existing groundwater
                    monitoring wells: MW01B, MW02B, MW03A, MW04A, MW05B, and MW06B  (shown on
                    Figure 2-2); plus one additional monitoring well  to be installed between

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                   MW02B and MW03A.
               •    After an analysis of the first year of groundwater monitoring data, the
                   sampling freguency would change to annual sampling for the groundwater
                   guality parameters, and semi-annually for the groundwater contamination
                   indicator parameters.

                   In accordance with Part F of 9 VAC 20-80-270, the post-closure shallow
                   groundwater monitoring shall be conducted for 10 years.

As allowed by Part E of 9 VAC 20-80-270, two options would be considered for this capping
alternative for the site. These options are as follows:

Alternative SO-3A: Soil/Clay Capping System

This alternative would meet the reguirements of Part E.I.,  which includes:

     •     Construction  of a  final  cover  system that  includes  an  infiltration layer that
          contains a minimum of 18  inches  of  earthen material, and  with  a  hydraulic
          conductivity  less  than or egual  to  the hydraulic  conductivity  of the  subsoils
          present,  or a hydraulic  conductivity no  greater than 1 x  10  -5 cm per second,
          whichever is  less.

     •     Installation  of an erosion control  layer (topsoil)  that contains a minimum of  6
          inches  of earthen  material that  is  capable of  sustaining  native  plant growth.

Alternative SO-3B: Soil/Synthetic Flexible Liner Capping System

This alternative would meet the reguirements of Part E.l.c.,  which includes:

     •     Installation  of an infiltration  layer that achieves an eguivalent  reduction in
          Infiltration  as that  provided  by the 18  inches of earthen material. This criteria
          would most likely  be  met  with  the use of a synthetic flexible  liner system.

     •     Installation  of an erosion control  layer (topsoil)  that provides eguivalent
          protection from wind  and  water as that provided by  24  inches of  earthen material,
          and  is  capable of  sustaining plant  growth.

Cost: The estimated costs of this  alternative are as follows:

Alternative SO-3A:

          Capital:                                        $3,857,000
     •     Annual  operation and  maintenance:               $    6,400
          Net  present worth  (30-year):                    $3,981,000


Alternative SO-3B:

          Capital:                                        $2,532,000
     •     Annual  operation and  maintenance:               $    6,400
          Net  present worth  (30-year):                    $2,656,000


Alternative SO-4: Hazardous Waste Landfill Cap with Institutional Controls

Description: This alternative would include the construction of a cover system over the
entire landfill in accordance with 9 VAC 20-60-870.  The capping system would be divided into
three sections or areas, with Seabee Road dividing the western portion of the cap,  and a
drainage ditch along the southeast corner separating the portion of the cap constructed over
the landfill area within the airfield runway approach from the remainder of the landfill.

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Seabee Road would remain intact along with its right-of-way;  and the capping system shall be
extended to the edge of the roadway.

Site access would be accommodated via improved gravel roadways along the perimeter fencing.

Institutional controls, as described under Alternative SO-2,  would also be implemented under
this alternative to restrict access to the landfill and limit the site to non-residential
use. Existing fencing and new fencing to be constructed would limit site access.

The estimated costs of this alternative are as follows:

          Capital:                                         $5,916,500
     •     Annual  operation and  maintenance:                $     4,000
          Net  present  worth (30-year):                     $5,978,000

2.6.2     Groundwater Remedial Alternatives

Three groundwater remedial alternatives were developed and evaluated for the CD Landfill
Site. As noted previously, surface water has also been included under the groundwater
category for purpose of alternative development and evaluation. The three groundwater
remedial alternatives include:

     •     No Action

     •     Institutional Controls  with Monitoring

     •     Limited Groundwater Extraction/Treatment  with Institutional  Controls  and
          Monitoring.

A brief description of each groundwater alternative,  as well  as the estimated cost,  is
provided below:

Alternative GW-1: No Action

Description: Under the No Action Alternative,  no remedial action for groundwater would be
performed at the CD Landfill Site.

Cost: The estimated costs of Alternative GW-1 are as  follows:

          Capital:                                         $      0
     •     Annual  operation and  maintenance:                $ 1,000
          Net  present  worth (30-year):                     $15,400
Alternative GW—2:  Institutional Controls with Monitoring*

Description: Under this alternative,  institutional controls would be implemented to restrict
access to the site and the use of groundwater at the site.  These controls would be similar to
those presented in Alternative SO-2 for soil, and would include prohibiting the installation
of water supply wells  (for either potable or nonpotable use)  on site.  As stated in
Alternative SO-2,  documents would be recorded in the City of Norfolk property records
indicating that the site has been used to manage solid wastes,  and would include notations
that would identify any use restrictions which apply to the site,  as a result of closure of
the site.

A focused groundwater and surface water monitoring program would be implemented to track
trends in contamination at the site boundary. The program would focus on monitoring the
migration of specific volatile and semi-volatile organic contamination from shallow
groundwater to points outside the site boundary, downgradient of MW 05A or in the drainage

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ditch near this point. In addition, this monitoring program would include the contingent
reguirement to sample the deeper  (Yorktown) aguifer, if contaminants are detected in the
shallow aguifer. This monitoring would be performed in addition to the post-closure
groundwater monitoring to be implemented for the soil remedy, and would be limited to the
scope presented below. The monitoring program would be structured to meet the overall intent
of 9 VAC 20-80-270, Part D, and would include the following:

     •     Quarterly sampling and analysis  for  chlorobenzene  and 1,4-dichlorobenzene  from the
          down-gradient  well MW 05B.

     •     If  chlorobenzene  or 1,4-dichlorobenzene is detected in MW 05B,  then a  deep
          groundwater  sample shall be  collected from MW 05C,  and from a new monitoring well to
          be  installed into the Yorktown aguifer,  hydraulic  down-gradient of  the landfill.
          These deep groundwater samples shall be analyzed for the same contaminants.

     •     Three surface  water samples  will be  collected (down-gradient of MW  05A) , on a
          guarterly basis.

     •     Quarterly sampling shall be  conducted for  two consecutive years. After this period,
          if  two consecutive sampling  events  show that  the concentrations of  chlorobenzene and
          1,4-dichlorobenzene are below USEPA Region III  Risk Based Concentrations RBCs)  of 39
          Ig/L and 0.44  I/L,  respectively,  the Navy  shall reguest approval to eliminate this
          sampling from  the site post-closure  monitoring.

Cost: The estimated costs of this alternative are as follows:

          Capital:                                         $       0
     •     Annual monitoring:                               $   8,100
          Net present  worth (30-year):                     $125,000

Alternative GW-3: Limited Groundwater Extraction with Institutional Controls and Monitoring

Description:  The objective of this alternative is to use groundwater extraction and treatment
technology, also referred to as "pump and treat", over a limited area near monitoring well MW
05A to contain shallow groundwater, and to render it suitable for its most likely potential
beneficial use  (i.e.,  nonpotable use such as lawn watering and vehicle washing).

Under this alternative,  groundwater would be pumped using three shallow  (approximately 25
feet deep) pumping wells, located near MW 05A, connected to a common treatment system. Each
well would pump water at approximately 5 gallons per minute, for a total pumping rate of
about 15 gallons per minute.

The conceptual treatment system design is based on a granular activated carbon  (GAG) system
for removal of organic contaminants (primarily chlorobenzene). Sand and cartridge filters
were included in the treatment system for removal of suspended solids and inorganics to
minimize clogging of the GAG units. Treated groundwater would be discharged into the existing
on-site drainage ditch in accordance with effluent standards established in accordance with
the Virginia Pollutant Discharge Elimination System.

This alternative would also include the implementation of institutional controls at the site.
As with Alternative GW-2, controls would be implemented to restrict access to the site, and
the use of groundwater at the site. These controls would be similar to those presented in
Alternative SO-2 for soil,  and would include prohibiting the installation of water supply
wells (for either potable or nonpotable use)  on site. With respect to surface water at the
site, the institutional controls and fencing would prevent potential future exposure to
potential contaminants in the surface water.

A groundwater and surface water monitoring program,  as presented in Alternative GW-2, would
be implemented to track trends in contamination at the site near MW 05A, and at locations
hydrauli cal1y downgradi ent.

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Cost: The estimated costs of this alternative  are  as  follows:
          Capital:                                             $   954,900
     •     Annual  operation, maintenance and monitoring: $   97,600
          Net  present worth  (30-year):                         $2,455,000

2.7     Summary  of Comparative  Analysis  of  Alternatives

In order to determine the preferred alternatives,  the  remedial alternatives for soil and
groundwater (including surface water)  presented in Section  2.6 were evaluated against nine
evaluation criteria identified in the NCP at  40 C.F.R.  Section 300.430(e) (9) and discussed in
the USEPA publication entitled "Guidance  for  Conducting Remedial  Investigations and
Feasibility Studies under CERCLA."

A summary of the nine evaluation criteria is  presented in Table 2-9.

Two of the nine evaluation criteria are  state acceptance and  community acceptance. With
respect to state acceptance,  the VADEQ concurs with the preferred alternatives. However,
based on new information and/or public comments,  the Navy,  in consultation with USEPA and
VADEQ,  may modify the preferred alternatives  or select other  remedial alternatives than those
presented in the FS Report and this PRAP.  The community acceptance criteria is assessed in
the Responsiveness Summary (Section 3.0  of this document).

The following information summarizes and  compares  the  remedial alternatives developed for
soil and groundwater (including surface water)  using the remaining seven  evaluation criteria.

2.7.1     Comparison  of Soil Alternatives

Overall Protection of Human Health and the Environment: With  respect to surface soils,
Alternatives SO-3 and SO-4 would provide  the  greatest  amount  of overall protection. Although
the institutional controls noted in Alternative SO-2,  would help  to minimize the chance for
exposure to potential contaminants,  the  solid waste or hazardous  waste capping systems would
provide added protection.  The No Action Alternative, Alternative  SO-1, is not protective of
human health and the environment and therefore is  not  considered  in the remainder of the
analysis.

With respect to potential contamination  in subsurface  soils,  Alternative  SO-3 and 4 would
provide the highest level of protection  through formal institutional controls and
installation of a capping system.  Alternative SO-2 would provide  protection through formal
institutional controls, including land use restrictions, and  maintenance  of the existing
landfill soil cover and fencing.

With respect to groundwater protection, Alternatives SO-3 and SO-4, which include an
impermeable cover, would provide the greatest levels of protection. These alternatives should
reduce infiltration and thus reduce the  amount of  contaminant leaching to groundwater.
However, the overall effectiveness of either  cap would be limited because the landfill is not
lined with a low-permeability material,  and the groundwater is very shallow. Alternative SO-2
would not minimize leaching of potential  contaminants  from  soil to groundwater. However, as
previously indicated,  the threat of contaminants leaching to  groundwater may be minimal.

Compliance with ARARs:  Since the environmental investigation  and  remediation of the CD
Landfill is being performed in accordance with CERCLA,  ARARs  (applicable, or relevant and
appropriate reguirements)  were identified and considered for  the  soil alternatives. Summaries
of all the ARARs identified in the Final  FS report are included in Appendix B to this
document. The purpose of identifying ARARs is to make  a CERCLA response action consistent
with other pertinent federal and state environmental reguirements. A summary of how the
remedial alternatives for soil comply with the identified ARARs is presented below.

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Alternatives SO-3 and SO-4 would meet all their respective federal and state ARARs:

     •     Alternatives  SO-3  and SO-4  would meet all  federal  and state  location-specific ARARs,
          including  protection of floodplains,  consideration of endangered species habitats,
          natural preserve areas,  and endangered plant  and insect  species.

     •     SO-3  and SO-4  would meet all state  action-specific ARARs for the proper disposal  of
          solid or hazardous wastes generated during the  construction  of  the  landfill  cap.

     •     Alternative SO-3 would meet state action-specific  ARARs  for  the design,
          construction,  monitoring,  and closure reguirements for a capping system for  an
          industrial waste landfill as reguired by the  VSWMRs (9 VAC 20-80-270).

     •     SO-3  would meet the state chemical-specific ARAR addressing  the presence,  and
          control of methane gas from the landfill (9 VAC 20-80-280) .  An  evaluation  of methane
          gas  reguirements would be addressed during the  design of the capping system.

     •     SO-3  and SO-4  would meet state action-specific  ARARs  for the proper disposal of
          solid or hazardous wastes generated during the  construction  of  the  landfill  cap.

The remedy is expected to comply with all ARARS. There are no chemical, location, or action-
specific ARARs associated with Alternative SO-2.

Long-term Effectiveness and Permanence: Estimated risk levels for exposure to surface soils
are currently within acceptable levels except that the hazard index for children is greater
than 1.0. Therefore, Alternatives SO-3 and SO-4 would reduce potential human health risks by
preventing dermal contact or ingestion of contaminated surface soil.

A number of Remedial Action Objectives  (RAOs) for OU 2 were identified in the PRAP.  With
respect to the first RAO for soils (prevent human exposure to potential contaminants within
subsurface soil and debris), Alternatives SO-3 and SO-4 would provide the greatest level of
long-term protection through both institutional controls and installation of a permanent cap.

With respect to the second RAO for soils  (minimize movement of potential contaminants from
soils and debris to groundwater and surface water),  installation of a cap under Alternative
SO-3 and Alternative SO-4 would help to reduce infiltration and thus leaching of potential
contaminants from soil  to groundwater. However, as previously indicated,  the effectiveness of
either the solid waste  or hazardous waste cap would be limited by the fact that the site is
not underlain by a low permeability liner and the depth to groundwater is very shallow.
Alternative SO-2 would not provide any actions to minimize leaching of potential contaminants
from soil to groundwater. However, as previously indicated,  the threat of contaminants
leaching to groundwater may be minimal.

With respect to the third RAO for soils, Alternatives SO-3 and SO-4 would minimize direct
ecological exposure to  the surface soils; Alternative SO-2 would not prevent ecological
exposure to surface soil.

Reduction of Toxicitv,  Mobility, or Volume:  None of the soil remedial alternatives would
actively reduce the toxicity or volume of contaminants through treatment. Some reduction may
be achieved under these alternatives through natural processes, such as volatilization and
biodegradation.

Installation of a cap under Alternatives SO-3 and SO-4 would help to reduce the mobility of
potential contaminants  in the soil, but the degree of reduction may be marginal because of
the absence of a confining layer and a very shallow groundwater depth.

Short-term Effectiveness: Alternative SO-2 would not pose potential risks to human health or
the environment during implementation. Construction of a cap under Alternatives SO-3 and SO-4
would reguire extensive clearing, grubbing,  and regrading activities that would disturb some
of the landfill contents and potentially pose a risk to workers, nearby Base personnel, and

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the environment.

Implementabilitv: There are no major implementability considerations under Alternative SO-2.
Alternatives SO-3 and SO-4 would be more difficult to implement because of the large area to
be capped  (approximately 21.6 acres); the extensive clearing,  grubbing, and regrading
reguired; and the necessary human health and environmental protection measures.  However,
landfill capping is a proven technology, and there should be no difficulty in obtaining the
reguired materials or a gualified construction contractor.

Cost: The 30-year net present worth costs for the four alternatives are summarized below.
Note that two capping options were considered for SO-3:

         Alternative  SO-1:            $        0

         Alternative  SO-2:            $   69,000

         Alternative  SO-3A:           $3,981,000

         Alternative  SO-3B:           $2,656,000

         Alternative  SO-4:            $5,978,000

2.7.2     Comparison of Groundwater Alternatives

Overall Protection: Alternative GW-3 would provide the highest level of protection since the
groundwater extraction and treatment system would contain and treat the chlorobenzene in the
shallow aguifer and prevent it from discharging into one or both of the perimeter drainage
ditches.

Alternative GW-2 would provide more overall protection than would Alternative GW- 1 through
the use of institutional controls and monitoring. Alternative GW-1, No Action, is not
protective of human health and the environment and therefore is not considered in the
remainder of this comparison.

Compliance with ARARs: Under Alternative GW-2, surface water runoff from the site may not
comply with Federal and Virginia Water Quality Standards, which are chemical-specific ARARs.
However, Alternative GW-2 would enable contaminant levels in surface water and groundwater to
be monitored and compared to federal and state water guality standards, federal  MCLs, and
state PMCLs. Both Alternatives GW-2 and GW-3 would prevent potential future consumption of
groundwater exceeding federal MCLs and state PMCLs through institutional controls.

There are no location-or action-specific ARARs associated with Alternative GW-2.

Alternative GW-3 would meet the chemical-specific ARARs covering the discharge of water from
a groundwater treatment plant to a surface water, (i.e., the more stringent or substantive
reguirements of the Clean Water Act NPDES discharge regulations [40CFR Sections
122.41-122.50] ; the Virginia Pollution Discharge Elimination System regulations  [9 VAC
25-31-10 to 940] and Virginia Water Protection Permit Regulations  [9 VAC 25-210-10 to 260];
and the Virginia Water Quality Standards [9 VAC 25-260-10 to 540]).

Long-term Effectiveness and Permanence:  Alternative GW-2 would provide a permanent solution
through use of institutional controls to prevent future potential exposure to shallow
groundwater and future potable use of the Yorktown Aguifer on site. Alternatives GW-2 and
GW-3 would include actively monitoring the migration of shallow groundwater toward site
boundaries, and would also include monitoring for any discharge of contaminated  shallow
groundwater to surface water.

Alternative GW-3 would be a permanent long-term remedy.

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Reduction of Toxicitv,  Mobility,  or Volume:  Alternative GW-2 would not actively reduce  the
toxicity, mobility, or volume of contaminants through remedial actions.  Some reduction  may  be
achieved under this alternative through natural processes,  such as dispersion,
volatilization, and biodegradation. Only Alternative GW-3 would reduce the toxicity,
mobility, and volume of contaminants through groundwater extraction and treatment.

Short-term Effectiveness: Alternative GW-2 would not pose potential risks  to human  health or
the environment during implementation.  Alternative GW-3 would pose a risk  to human  health and
the environment during installation of underground piping for the groundwater extraction
system and construction of the treatment building foundation. Proper personnel  health and
safety procedures and environmental protection measures (e.g.,  dust and erosion controls)
would be used to minimize these risks.

Implementabilitv: There are no major implementability considerations associated with
Alternative GW-2. Alternatives GW-2 and GW-3 would involve administrative  actions as  well as
long-term monitoring activities.  Alternative GW-3 would be the most difficult to implement
but should not pose any significant implementability concerns.

Cost: The 30-year net present worth costs for the three groundwater alternatives are
presented below:

         Alternative GW-1:            $        0

         Alternative GW-2:            $  125,000

         Alternative GW-3:            $2,455,000

2.8     The  Selected Remedy

The selected remedy for OU 2, contaminated soils, groundwater and surface  water at  the  CD
Landfill Site is identified below:

Soil: Alternative SO-3B - Solid Waste Landfill Cap with Institutional Controls  and
      Post-Closure Groundwater Monitoring

Groundwater: Alternative GW-2 - Institutional Controls with Monitoring

A description of the selected remedy is presented below.

2.8.1  Selected  Soil Alternative

The selected soil remedy for OU 2 at the CD Landfill Site is Alternative SO-3B,  the
construction of a solid waste landfill cap that meets the closure requirements  of the VSWMR
(9 VAC 20-80-270) for an industrial waste landfill,  and the implementation of institutional
controls.

The major components of the selected soil remedy are:

Landfill Capping System: The Navy shall construct a landfill cap over the  entire 22-acre
landfill, as shown on Figure 2-3. The capping system shall be divided into three sections or
areas, with Seabee Road dividing the western portion of the cap,  and a drainage ditch along
the southeast corner separating the portion of the cap constructed over the landfill  area
within the airfield runway approach from the eastern portion of the landfill cap. The capping
system shall include the installation of an infiltration layer that achieves an equivalent
reduction in infiltration as that provided by 18 inches of earthen material. These  criteria
shall most likely be met with the use of a synthetic flexible liner system,  the installation
of an erosion control layer  (topsoil)  that provides equivalent protection  from wind and water
as that provided by 24  inches of earthen material, and is capable of sustaining plant growth.
Seabee Road shall remain intact along with its right-of-way, and the capping system shall be

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extended to the edge of the roadway. Access to the site would be accommodated via improved
gravel roadways along the perimeter fencing. Figure 2-4 shows a preliminary cross-section of
the cap.

The design of the capping system shall include an evaluation to determine the need for a
methane gas collection system. The Navy shall also develop and implement an operating and
maintenance plan for the landfill site.

Groundwater Monitoring Program: The Navy shall initiate a groundwater monitoring program
that meets the reguirements of Part D of 9 VAC 20-80-270. The groundwater monitoring program
will meet the Phase I monitoring reguirements specified in Part D.5, which includes
groundwater guality parameters and indicator parameters. (Note that a separate groundwater
monitoring program, that is not related to the VSWMR reguirements,  will be included in the
selected groundwater remedy).  The monitoring program shall start after the cap is
constructed, and shall include:

     •     Quarterly sampling for  one year  (four  consecutive  guarterly  sampling events),  for
          the  groundwater guality parameters and groundwater contamination indicator
          parameters.

     •     Samples  shall  be collected from  the following six  existing groundwater  monitoring
          wells: MW01B,  MW02B,  MW03A,  MW04A,  MW05B,  and MW06B (shown on Figure 2-1);  plus  one
          additional monitoring well to be installed between MW02B  and MW03A.

     •     After an analysis  of the first year of groundwater monitoring data,  the sampling
          freguency shall change  to annual sampling for the  groundwater guality parameters,
          and  semi-annually  for the groundwater  contamination indicator parameters.

     •     In accordance  with Part F of 9 VAC 20-80-270,  the  post-closure shallow  groundwater
          monitoring shall be  conducted for ten  years.

Land Use Restrictions: The Navy shall implement the following land use restrictions to
protect the integrity of the landfill cover and to limit exposure due to the continuing
presence of solid waste at the site:

     •     The  Navy would allow no future residential development  on the site;

     •     The  Navy would allow no use of shallow groundwater,  potable  or nonpotable,
          underlying the site  for any purpose except for monitoring;

     •     The  Navy would allow no public access  to the  site;

     •     The  Navy would not take or allow any other action  that  would disturb the integrity
          of the landfill cover or disturb the function of the monitoring systems.

Institutional Controls:  The Navy shall implement the following institutional controls to
ensure that the above limitations are properly and effectively carried out:

     •     The  Navy shall maintain the existing fences and gates at  the site to limit  access to
          the  former landfill.  The Navy shall install warning signs at each entrance  gate  to
          indicate that  solid  waste is buried at the site.

     •     The  Navy shall note  the changes  and restrictions associated  with the site in the
          next revision  to the Naval Base  Norfolk Master Plan.  These changes  shall identify a
          land use category  for the site that prohibits residential use of the area as well as
          any  invasive construction activities.  The Master Plan shall  reflect  the location and
          dimensions of  the  site,  the location of any fencing,  signs and monitoring wells, and
          shall incorporate  the land use restrictions stated above.

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     •     The  Naval  Base  Norfolk  real property  file  and  any base planning maps  or other
          documents  maintained  at the base  and  the Atlantic Division, Naval  Facilities
          Engineering  Command shall be  revised  to note the land use  restrictions established
          for  land comprising the site  and  to cross  reference  these  restrictions in  the Naval
          Base Norfolk Master Plan.

     •     The  Navy shall  provide  the general public  with notice of the past  use of the site
          and  information on land use restrictions to be implemented by  taking  the following
          actions:

               •    Preparing a survey plat that indicates the location and dimensions of the
                    site  and the  location of all monitoring wells. The survey plat shall state
                    that  use of the site is limited  as stated above.  The Navy shall  submit the
                    survey plat to the local recording authority.

               •    Recording a notation on real property documents evidencing the United
                    States' ownership of the property on which the site is located that shall
                   notify interested parties that the site was previously used to manage solid
                   waste.

               •    The Navy shall conduct annual inspections to ensure that land use at the
                   site has remained consistent with the restrictions imposed.  Based on these
                   inspections,  the Navy shall certify to USEPA Region III and to the
                   Commonwealth  of Virginia that institutional controls are in place and
                   operational.

Future Actions is Case of Property Transfer:  In order to meet the extensive reguirements
under CERCLA 120(h)  regarding cleanup of real property to be transferred out of Federal
hands,  and in addition to complying with statutory reguirements,  the Navy commits  to taking
the following future actions if the Navy or the United States relinguishes control  or
disposes of the property on which the site is situated:

     •     If the property on which the  site is  located is transferred to another Federal
          government entity, the  Navy shall ensure that  the institutional controls described
          above remain in effect  after  the  transfer. Transfer  documents  shall specifically
          reguire  continued implementation  of land use restrictions  and would impose upon the
          transferee Federal government  entity  the obligation  to maintain the fencing, warning
          signs and  monitoring  well heads.  The  Navy  shall prepare a  site map that shall be
          marked with  the location and  dimensions of the former landfill on  the site and the
          location of  fencing,  warning  signs and monitoring wells, and include  this  site map
          as an attachment to the appropriate transfer documents. As between the Navy and the
          Federal  government transferee, any Navy obligations  to the transferee for  continued
          responsibility  for the  transferred site shall  be made contingent on the transferee's
          adherence  to the limitations  on the use of the site  spelled out in the transfer
          documents  and site map.

     •     If the property on which the  site is  located is conveyed to a non-Federal  government
          entity,  and  the Navy  is empowered to  dispose of the  property directly, the Navy
          shall ensure that the deed effecting  such  action contains  an easement or covenant in
          favor of the U.S. Government  that will impose  the land use restrictions. The Navy
          shall also prepare a  survey plat, similar  to the site map  described above,  that
          reflects the existence  of this deed and land use restrictions  that have been imposed
          on the  site  therein.  Upon conveyance  of the property, both the deed and the survey
          plat shall be recorded,  and the Navy  shall make arrangements to insure that the
          integrity  of the fencing, warning signs and monitoring well heads  are maintained, as
          well as  insuring that the land use restrictions are  complied with  by  the grantee. As
          between  the  Navy and  its transferee,  any Navy  obligation to the transferee
          non-Federal  entity for  continued  responsibility for  the site shall be made
          contingent on the transferee  non-Federal entity's adherence to the limitations on
          the  use  of the  site indicated in  the  site  map  and transfer documents.

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     •     If  the  property on which  the  site  is  located  is  conveyed to  a non-Federal entity,
          and the Navy  is not  empowered to dispose  of property,  the Navy  shall take all  steps
          necessary  and permissible to  ensure that  the  Federal  entity  disposing of the
          property takes the steps  outlined  above,  unless  the property is remediated to
          residential standards  prior to such transfer.

This selected soil remedy provides for the containment  of surface soil and waste  materials at
the CD Landfill site,  and provides a permanent  solution by preventing both human  and
ecological future exposure to potential contamination.  The selected remedy will provide for
long-term reduction of leachate generation and  will reduce potential  future contamination of
groundwater beneath the site.

2.8.2   Selected Groundwater/Surface Water Alternative

The selected groundwater remedy for OU 2 at the CD Landfill Site is Alternative GW-2,
institutional controls  with monitoring. The selected alternative shall include the
implementation of a groundwater and surface monitoring  program, land  use  restrictions,  and
institutional controls. The Navy shall implement the same institutional  controls  as  described
for the selected soil remedy  (SO-3B).  The major components of the selected soil remedy are:

Groundwater Monitoring Program:  A focused groundwater and surface water monitoring
program shall be implemented to track trends in contamination at the  site boundary.  The
program shall focus on monitoring the migration of specific volatile  and  semi-volatile
organic contamination from shallow groundwater  to points outside the  site boundary,
downgradient of MW 05A or in the drainage ditch near this point. In addition,  this monitoring
program shall include the contingent reguirement to sample the deeper (Yorktown)  aguifer,  if
contaminants are detected in the shallow aguifer. This  monitoring shall be performed in
addition to the post-closure groundwater monitoring to  be implemented for the soil remedy,
and will be limited to the scope presented below. The monitoring program  shall be structured
to meet the intent of 9 VAC 20-80-270,  Part D,  and shall include the  following:

     •     Quarterly  sampling and analysis for chlorobenzene  and 1,4-dichlorobenzene from the
          down-gradient well MW  05B.

     •     If  chlorobenzene or  1,4-dichlorobenzene is detected in MW 05B,  then  a deep
          groundwater sample shall  be collected from MW 05C, and from  a new monitoring well to
          be  installed  into the  Yorktown aguifer, hydraulically down-gradient  of  the landfill.
          These deep groundwater samples shall  be analyzed for  the same contaminants.

     •     Three surface water  samples shall  be  collected (down-gradient of MW  05A) , on a
          guarterly  basis.

     •     Quarterly  sampling shall  be conducted for two consecutive years. After  this period,
          if  two  consecutive sampling events show that  the concentrations of chlorobenzene and
          1,4-dichlorobenzene  are below USEPA Region III Risk Based Concentrations (RBCs)  of
          39  Ig/L and 0.44 Ig/L,  respectively,  the  Navy shall reguest  approval to eliminate
          this sampling from the site post-closure  monitoring.

Land Use Restrictions:  Implementation of the land use restrictions  for the selected  soil
remedy  (SO-3B) shall also apply to the groundwater remedy.

Institutional Controls: The institutional controls implemented for the selected soil remedy
(SO-3B) shall also apply to control of the groundwater  and surface  water.

The selected groundwater remedy shall include  institutional controls  to  restrict  groundwater
use (for either potable or nonpotable use)  at  the site, prohibit installation of  water supply
wells,  and the implementation of a sediment, surface water and groundwater monitoring
program. This preferred groundwater alternative shall provide overall protection  through
long-term monitoring of contaminant levels and  the prevention of potential future consumption

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of groundwater.

2.8.3  Performance Standards

The landfill cap shall be designed, constructed, operated, and maintained to meet the
performance reguirements of the VSWMR (9 VAC 20-80-270E and F)  for closure of an industrial
waste landfill.

Landfill Cap Design Criteria: The cap design shall minimize infiltration, and control surface
water run on/runoff. The landfill cap shall be constructed, at a minimum to the following
performance standards:

     •    Installation of an infiltration layer  that  achieves an eguivalent  reduction in
          infiltration as that  provided  by 18  inches  of earthen material,  with  a  hydraulic
          conductivity less  than or egual to the hydraulic conductivity  of the  subsoils
          present,  or a hydraulic conductivity no greater  than  1 x 10  -5  cm  per second,
          whichever is  less.  These criteria will be met with the use of  a synthetic  flexible
          liner  system,  and

     •    Installation of an erosion control layer (topsoil) that provides eguivalent
          protection from wind  and water as that provided  by 24 inches of compacted  earthen
          material,  and is capable of sustaining plant  growth.

     •    Surface water drainage controls shall  be constructed  to prevent erosion of the  cap.
          As  determined by the  final design, drainage channels  shall be  installed in certain
          areas  on  the  top and  perimeter of the  landfill cap to channel  runoff  away  from  the
          landfill.

     •    The landfill  cap design shall  evaluate the  presence of methane  gas, and if
          warranted,  the design will include a gas collection and monitoring system  that  meets
          VSWMR  reguirements.

Closure Plan: The Navy shall prepare a written closure plan that meets the reguirements of
9 VAC 220-80-270 for an industrial landfill.

Post-Closure Groundwater Monitoring: The Navy shall implement a groundwater monitoring
program that meets the reguirements of Part D of 9 VAC 20-80-270. The groundwater monitoring
program will meet the Phase I monitoring reguirements specified in Part  D.5, which includes
groundwater guality parameters and indicator parameters.  (Note that a separate  groundwater
monitoring program, that is not related to the VSWMR reguirements, is proposed  for
groundwater remedial alternative GW-2).  The monitoring program shall start after the cap is
constructed,  shall evaluate any future contaminant transport,  and shall  include:

     •    Quarterly sampling for one year (four  consecutive guarterly  sampling  events), for
          the groundwater guality parameters and groundwater contamination indicator
          parameters.

     •    Samples shall be collected from the  following six existing groundwater  monitoring
          wells: MW01B,  MW02B,  MW03A,  MW04A, MW05B, and MW06B  (shown on  Figure  2-2);  plus one
          additional monitoring well to  be installed  between MW02B and MW03A.

     •    After  an  analysis  of  the first year  of groundwater monitoring  data, the sampling
          freguency shall change to annual sampling for the groundwater  guality parameters,
          and semi-annually  for the groundwater  contamination indicator  parameters.

Institutional Controls: The Navy shall implement institutional controls, as described under
Alternative SO-2,  to restrict access to the entire landfill and limit the site  to
non-residential use. Fencing shall completely enclose the site and signs shall  be posted
indicating solid wastes are present. The next revision to the Base Master Plan  shall note

-------
that the CD Landfill is an area in which construction changes  are  prohibited,  residential
development is prohibited, shallow groundwater use is prohibited,  and site  access  shall be
limited. A notation shall be filed in the real property file maintained  by  the Navy  for this
site indicating the extent of the area and the fact that solid wastes are present.

Within 60 days of closure (capping),  the Navy shall produce a  survey plat indicating the
location and dimensions of the landfill with respect to permanently surveyed benchmarks. This
plat shall be prepared and certified by a professional land surveyor.  The plat shall contain
a note, prominently displayed, which states the owner's obligation to restrict disturbance of
the landfill; post-closure use shall prohibit residential use,  shall prohibit  access or use
of groundwater underlying the property for any purpose except  monitoring, and  shall  never be
allowed to disturb the integrity of the final cover,  liners, or any other components of the
containment system, or the function of the facility's monitoring systems. No later than 60
days after closure, the Navy shall to submit to the local property office a record of the
location of the facility.

If and when the property is transferred out of the federal government, the  deed  shall contain
the survey plat,  (the notation that the property was previously used to  manage solid wastes,
that its future use is restricted, and other deed restrictions as  appropriate  apply.

In a yearly Closure Report,  the Navy shall certify that the institutional controls as
outlined above are still in place and effective.  The Navy shall notify USEPA and VADEQ 60
days before changing any of the use restrictions in the Base Master Plan related to  the CD
Landfill.

2.9   Statutory Determinations

A selected remedy must satisfy the statutory reguirements of CERCLA Section 121, which
include:

     •     Protection of human health  and  the  environment

     •     Compliance with ARARs  (or justification  of  a waiver)

     •     Cost-effectiveness

     •     Utilization of permanent solutions  and alternative treatment or resource recovery
          technologies  to the maximum extent  practicable

     •     Preference for treatment that reduces toxicity, mobility,  or volume as a principal
          element,  or explanation as  to why this preference is not  satisfied

The evaluation of how the selected remedy for the CD Landfill  site satisfies these
reguirements is presented below.

2.9.1   Protection of Human Health and the Environment

The selected remedy will protect human health and the environment.  Installation  of a solid
waste landfill cap will eliminate direct contact,  inhalation,  and  ingestion threats  from
contaminated soils and will reduce the leaching of contaminants from the landfill  to
groundwater. Institutional controls will restrict future land  use,  further  mitigating the
potential for direct exposure and potential risks.

Groundwater monitoring in the vicinity of the landfill will provide a warning  mechanism for
potential groundwater contamination and ensure the landfill cap is effective in  protecting
human health. Since the remedy will leave contaminants at the  site,  a review will  be
performed within five years to ensure continued protection of  human health  and the
environment.

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2.9.2   Compliance with Applicable or Relevant and Appropriate Requirements

The selected  remedy will comply with  applicable or relevant  and appropriate requirements
(ARARS).  ARARs are identified in Appendix B.

2.9.3   Cost-Effectiveness

The selected  remedy provides overall  cost-effectiveness.  The total present worth cost of the
selected remedy in this ROD is $2,781,000.

2.9.4   Utilization of Permanent Solutions and Alternative Treatment Technologies
        to the Maximum Extent Practicable

The selected  remedy represents the  maximum extent to which permanent solutions  and  treatment
technologies  can be utilized while  providing the best  balance among the other evaluation
criteria.

The selected  landfill cap is a permanent solution and  is a common remedy for large  landfills
with high volumes of waste such as  CD Landfill.

2.9.5   Preference for Treatment as a Principal  Element

The selected  remedy does not utilize  permanent treatment technologies due to the large volume
of waste in the landfill requiring  treatment or disposal.

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3.0     RESPONSIVENESS  SUMMARY

3.1      Background  on  Community Involvement

Community  relations activities to date for the CD Landfill site include establishment of  an
Administrative Record, briefings to  the Restoration Advisory  Board regarding findings of  the
RI and FS, release of  the PRAP for public review and comment  on June 5, 1998, and a public
meeting conducted on June 24,  1998.

3.2      Summary of  Public Comments

No written comments were received during the comment period.  A public meeting was conducted
on Wednesday, June 24, 1998 at the Naval Base Environmental Offices  (Building N-26).  No one
from the local community attended the meeting and no comments or guestions were raised.

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     Media

Surface Water



Shallow Sediment



Deep Sediment



Surface Soil



Subsurface Soil
Groundwater
                            TABIiE 2-1
                  QUALITATIVE SUMMARY OF COPCs
                      CD LANDFILL - OU 2
                  NAVAL BASE NORFOLK, VIRGINIA

              Contaminants

SVOCs  (primarily 1,4-dichlorobenzene)
Pesticides  (primarily dieldrin)
Metals  (Sb, As, Ba, Cr, Cu, Mn, Ni, Th, V, Zn

SVOCs
Pesticides/PCBs
Metals  (As, Cr, Cu, Mn, Ni, V)

SVOC
Pesticides/PCBs
Metals  (As, Ba, Mn)

SVOCs  [primarily benzo(a)pyrene]
Pesticides  (primarily dieldrin)
Metals  (As, Be, Mn, V)

SVOCs  [primarily benzo(a)pyrene]
Metals  (Sb, As, Be, Cd, Cr, Cu, Mn, Ni, Zn)
                                                               Location

                                                Northern  and  eastern drainage area
                                                Northern  and  eastern drainage area
                                                Northern  and  eastern drainage area

                                                Southern  drainage  area and SD09
                                                Northern  and  southern drainage area
                                                Northern  and  southern drainage area

                                                Eastern drainage area
                                                Northern  and  southern drainage area
                                                Southern  drainage  area

                                                SB-09S
                                                SB-09S
                                                Site-wide

                                                SB-17 and SB-18
                                                Arsenic found site-wide.  Other
                                                metals primarily in East/Central to
                                                extreme eastern portion of site
                                                 SB/MW-05A
                                                 SB/MW-05A
                                                 Northern  length  of  site
                                                 MW-04A
VOCs  (primarily chlorobenzene)
SVOCs  (primarily 1,4-dichlorobenzene)
Pesticides  (primarily dieldrin)
PCBs  (primarily Aroclor 1260)
Metals  (Sb, As, Ba, Be, Cd, Cu, Mn, Ni, V,  Zn)  As,  Be, Mn, V -  Site  Wide
                                                Cd,  Cu, Ni, Zn - MW-03A,  04A,
                                                05 A,  10A
                                                Be  - MW03A and 10A
                                                Sb  - 04A  and  10A
Surface Water
Shallow Sediment
Deep Sediment
Surface Soil
Subsurface Soil
Groundwater
 SVOCs  (primarily 1,4-dichlorobenzene)
 Pesticides  (primarily dieldrin)
 Metals  (Sb, As, Ba, Cr, Cu, Mn, Ni, Th, V, Zn

 SVOCs
 Pesticides/PCBs
 Metals  (As, Cr, Cu, Mn, Ni, V)

 SVOC
 Pesticides/PCBs
 Metals  (As, Ba, Mn)

 SVOCs  [primarily benzo(a)pyrene]
 Pesticides  (primarily dieldrin)
 Metals  (As, Be, Mn, V)

 SVOCs  (primarily benzo(a)pyrene]
 Metals  (Sb, As, Be, Cd, Cr, Cu, Mn, Ni, Zn)
 VOCs  (primarily chlorobenzene)
 SVOCs  (primarily 1,4-dichlorobenzene)
 Pesticides  (primarily dieldrin)
 PCBs  (primarily Aroclor 1260)
                                                Northern  and  eastern drainage area
                                                Northern  and  eastern drainage area
                                                Northern  and  eastern drainage area

                                                Southern  drainage  area and SD09
                                                Northern  and  southern drainage area
                                                Northern  and  southern drainage area

                                                Eastern drainage area
                                                Northern  and  southern drainage area
                                                Southern  drainage  area

                                                SB-09S
                                                SB-09S
                                                Site-wide

                                                SB-17 and SB-18
                                                Arsenic found site-wide.  Other
                                                metals primarily in East/Central to
                                                extreme eastern portion of site

                                                SB/MW-05A
                                                SB/MW-05A
                                                Northern  length of site
                                                MW-04A
                   Metals  (Sb, As, Ba, Be, Cd, Cu, Mn, Ni, V,  Zn) As,  Be, Mn, V -  Site  Wide
                                                                  Cd,  Cu, Ni, Zn - MW-03A,  04A,
                                                                  05 A,  10A
                                                                  Be  - MW03A and 10A
                                                                  Sb  - 04A  and  10A

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                              TABIiE 2-2

              INCREMENTAL LIFETIME CANCER RISKS  (ILCRs)
                      AND HAZARD INDICES (His)
                  FOR CURRENT MILITARY PERSONNEL
                        CD LANDFILL SITE
                  NAVAL BASE, NORFOLK, VIRGINIA

                                    Receptor
                           Adult Military Personnel
  Medium/Pathway             ILCR             HI

  Surface Soil

   Ingestion              7.6 x 10 -7       3.4 x 10 -2

 Dermal Contact           4.8 x 10 -6       7.3 x 10 -2

  Inhalation  (1)          8.2 x 10 -10      7.8 x 10 -4

    Subtotal                    5.6 x 10 -6       1.1 x  10 -1

 Surface Water

  Ingestion               1.7 x 10 -7         1.7 x 10 -2

Dermal Contact            1.0 x 10 -6         9.9 x 10 -3

   Subtotal               1.2 x 10 -6         2.7 x 10 -2

    TOTAL                 6.8 x 10 -5         1.4 x 10 -1

Notes:

(1)  Inhalation of fugitive dusts.

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                                    TABIiE 2-3
      INCREMENTAL LIFETIME CANCER RISKS  (ILCRs) AND  HAZARD INDICES (His)
               FOR CURRENT/FUTURE ADULT AND CHILD  TRESPASSERS
                                CD LANDFILL SITE
                         NAVAL BASE, NORFOLK, VIRGINIA
 Medium/Pathway

  Surface Soil

   Ingestion

 Dermal Contact

   Subtotal

 Surface Water

  Ingestion

Dermal Contact

  Subtotal

  TOTAL
                                            Receptors
       Adults
ILCR            HI
                                                           Children (7-15 years)
                                      ILCR
                                                        HI
9.
5.
6.
3.
1.
1.
2.
2
8
7
9
5
9
6
X
X
X
X
X
X
X
10
10
10
10
10
10
10
-7
-6
-6
-6
-5
-5
-5
5.
1.
1.
4.
2.
6.
7.
4
2
7
0
0
0
7
x 10
x 10
x 10
x 10
x 10
x 10
x 10
-3
-2
-2
-2
-2
-2
-2
5,
2,
2,
2,
6,
9,
1,
.2
.4
.9
.2
.9
.1
.2
x
x
X
X
X
X
X
10
10
10
10
10
10
10
-7
-6
-6
-6
-6
-6
-5
1,
1,
2,
7,
3,
1,
1,
.0
.6
.6
.7
.0
.1
.3
x
x
X
X
X
X
X
10
10
10
10
10
10
10
-2
-2
-2
-2
-2
-1
-1

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                                      TABIiE 2-4

         INCREMENTAL LIFETIME CANCER RISKS  (ILCRs) AND  HAZARD  INDICES  (His)
                   FOR FUTURE CIVILIAN WORKERS  (GROUNDSKEEPERS)
                    SHALLOW AQUIFER USED AS NON-POTABLE SOURCE
                                  CD LANDFILL SITE
                           NAVAL BASE, NORFOLK, VIRGINIA

                                                Receptor
                                            Civilian Worker
          Medium/Pathway                ILCR                 HI

           Surface Soil

          Ingestion                  4.0 x 10 -6           2.8  x  10  -2
         Dermal Contact              4.1 x 10 -5           1.0  x  10  -1
         Inhalation (1)              1.0 x 10 -8           1.6  x  10  -3

            Subtotal                 4.5 x 10 -5           1.3  x  10  -1

       Shallow Groundwater

          Ingestion                  2.2 x 10 -5           4.5  x  10  -1
        Dermal Contact               7.7 x 10 -4           2.9  x  10  +0

          Subtotal                   7.9 x 10 -4           3.4  x  10  +0

       Surface Water
ngestion
irmal Contact
Subtotal
TOTAL
1.6 x 10 -5
6.4 x 10 -5
8.0 x 10 -5
9.1 x 10 -4
2.0 x 10 -1
1.0 x 10 -1
3.0 x 10 -1
3.8 x 10 +0
Notes:

(1) Inhalation of fugitive dusts.

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                                 TABLE 2-5

     INCREMENTAL LIFETIME CANCER RISKS  (ILCRs) AND HAZARD  INDICES  (His)
              FOR FUTURE CIVILIAN WORKERS  (GROUNDSKEEPERS)
       DEEP AQUIFER  (WELL LOCATION GW-05C) USED AS NON-POTABLE  SOURCE
                              CD LANDFILL SITE
                       NAVAL BASE, NORFOLK, VIRGINIA
                                             Receptor
                                          Civilian Worker
    Medium/Pathway                   ILCR                 HI

    Surface Soil

    Ingestion                    4.0 x 10 -6           2.8 x  10  -2
   Dermal Contact                4.1 x 10 -5           1.0 x  10  -1
   Inhalation  (1)                1.0 x 10 -1           1.6 x  10  -3

    Subtotal                     4.5 x 10 -5           1.3 x  10  -1

  Deep Groundwater

    Ingestion                       --                 5.5 x  10  -4
  Dermal Contact                    —                 4.4 x  10  -3

    Subtotal                                           5.0 x  10  -3

  Surface Water

   Ingestion                     1.6 x 10 -5           2.0 x  10  -1
  Dermal Contact                 6.4 x 10 -5           1.0 x  10  -1

    Subtotal                     8.0 x 10 -5           3.0 x  10  -1

    TOTAL                        1.2 x 10 -4           4.3 x  10  -1

Notes:

(1)   Inhalation of fugitive dusts.
     No COPCs identified for evaluation.

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                                TABIiE 2-6

  INCREMENTAL LIFETIME CANCER RISKS  (ILCRs) AND HAZARD  INDICES  (His)
                    FOR FUTURE CONSTRUCTION WORKERS
                            CD LANDFILL SITE
                     NAVAL BASE, NORFOLK, VIRGINIA

                                                Receptor
                                       Adult Construction Worker
    Medium/Pathway                       ILCR                HI

    Surface Soil

     Ingestion                         1.5 x 10 -6        2.7 x 10  -2
   Dermal Contact                      1.7 x 10 -6        1.0 x 10  -1
    Inhalation  (1)                     4.1 x 10 -10       1.6 x 10  -3

      Subtotal                         3.2 x 10 -6        3.7 x 10  -1

   Subsurface Soil

     Ingestion                         1.8 x 10 -6        3.1 x 10  +0
   Dermal Contact                      5.6 x 10 -6        2.3 x 10  +0
   Inhalation (1)                      9.5 x 10 -9        1.9 x 10  -2

    Subtotal                           7.4 x 10 -6        5.4 x 10  +0

     Total                             1.1 x 10 -5        5.8 x 10  +0


Note:

(1)  Inhalation of fugitive dusts.

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                                        TABIiE 2-7

             INCREMENTAL LIFETIME CANCER RISKS  (ILCRs) AND HAZARD INDICES  (His)
                   FOR FUTURE ADULT AND YOUNG CHILD ON-SITE RESIDENTS
                         SHALLOW AQUIFER USED AS POTABLE SOURCE
                                     CD LANDFILL SITE
                               NAVAL BASE, NORFOLK, VIRGINIA
                                                Receptors
                                   Adults               Young Children  (1-6 years)
  Medium/Pathway            ILCR               HI       ILCR               HI

   Surface Soil

    Ingestion             1.3 x 10 -5     7.8 x 10 -2   2.5 x 10 -5    7.3 x 10 -1
  Dermal Contact          8.5 x 10 -5     1.7 x 10 -1   4.8 x 10 -5    4.8 x 10 -1
   Inhalation  (1)         1.4 x 10 -9     1.8 x 10 -4   2.7 x 10 -9    1.7 x 10 -3

     Subtotal             9.8 x 10 -5     2.5 x 10 -1   7.3 x 10 -5    1.2 x 10 +0

  Subsurface Soil

   Ingestion              1.6 x 10 -5     9.1 x 10 -1   3.0 x 10 -5    8.5 x 10 +0
  Dermal Contact          2.9 x 10 -4     3.9 x 10 +0   1.6 x 10 -4    1.1 x 10 +1
  Inhalation (1)          3.3 x 10 -8     2.2 x 10 -3   6.2 x 10 -8    2.1 x 10 -2

   Subtotal               3.1 x 10 -4     4.8 x 10 +0   1.9 x 10 -4    2.0 x 10 +1

  Shallow Groundwater (2)

    Ingestion             7.6 x 10 -4     9.9 x 10 +0   3.6 x 10 -4    2.3 x 10 +1
  Dermal Contact          4.3 x 10 -4     1.3 x 10 +0   1.6 x 10 -4    2.4 x 10 +0
   Inhalation  (3)         4.3 x 10 -7     9.2 x 10 -1   4.0 x 10 -7    4.3 x 10 +0

    Subtotal              1.2 x 10 -3     1.2 x 10 +1   5.2 x 10 -4    3.0 x 10 +1

  Surface Water

    Ingestion             3.9 x 10 -6     4.0 x 10 -2   3.7 x 10 -6    1.9 x 10 -1
  Dermal Contact          1.5 x 10 -5     2.0 x 10 -2   8.0 x 10 -6    5.3 x 10 -2

    Subtotal              1.9 x 10 -5     6.0 x 10 -2   1.2 x 10 -5    2.4 x 10 -1

     TOTAL                1.6 x 10 -3     1.7 x 10 +1   7.9 x 10 -4    5.1 x 10 +1
Notes:

(1)  Inhalation of fugitive dusts.
(2)  Risk levels presented are associated with potential exposures to organic and dissolved
     inorganic COPCs.
(3)  Inhalation of volatilized organic COPC concentrations in shower air as determined by
     the Foster and Chrostowski Shower Model.

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                                  TABIiE 2-8

       INCREMENTAL LIFETIME CANCER RISKS  (ILCRs) AND HAZARD INDICES  (His)
             FOR FUTURE ADULT AND YOUNG CHILD ON-SITE RESIDENTS
          DEEP AQUIFER (WELL LOCATION GW-05C) USED AS POTABLE SOURCE
                              CD LANDFILL SITE
                       NAVAL BASE, NORFOLK, VIRGINIA
   Medium/Pathway
                         ILCR
                                            Receptors
          Adults
                                          HI
                    Young Children  (1-6 years)
                    ILCR                HI
  Surface Soil
   Ingestion
 Dermal Contact
  Inhalation (1)
1.3 x 10 -5
8.5 x 10 -5
1.4 x 10 -9
7.8 x 10 -2
1.7 x 10 -1
1.8 x 10 -4
 2.5 x 10 -5
 4.8 x 10 -5
 2.7 x 10 -9
7.3 x 10 -1
4.8 x 10 -1
1.7 x 10 -3
    Subtotal
                       9.8 x 10 -5
                                      2.5 x 10 -1
                                                        7.3 x 10 -5
                                                                         1.2 x 10 +0
  Subsurface Soil
    Ingestion
  Dermal Contact
  Inhalation (1)
1.6 x 10 -5
2.9 x 10 -4
3.3 x 10 -8
9.1 x 10 -1
3.9 x 10 +0
2.2 x 10 -3
 3.0 x 10 -5
 1.6 x 10 -4
 6.2 x 10 -8
8.5 x 10 +0
1.1 x 10 +1
2.1 x 10 -2
    Subtotal
                       3.1 x 10 -4
                                      4.8 x 10 +0
                                                        1.9 x 10 -4
                                                                         2.0 x 10 +1
 Deep Groundwater (2)
   Ingestion
  Dermal Contact
  Inhalation (3)
               2.7 x 10 -2
               1.1 x 10 -3
                                   6.3 x 10 -2
                                   2.0 x 10 -3
   Subtotal
                                      2.8 x 10 -2
                                                                          6.5 x 10 -2
 Surface Water
  Ingestion
Dermal Contact
  Subtotal
3.9 x 10 -6
1.5 x 10 -5
1.9 x 10 -1
4.0 x 10 -2
2.0 x 10 -2
6.0 x 10 -2
3.7 x 10 -6
8.0 x 10 -6
1.2 x 10 -5
1.9 x 10 -1
5.3 x 10 -2
2.4 x 10 -1
   TOTAL
                       4.3 x 10 -4
                                      5.1 x 10 +0
                                                       2.7 x 10 -4
                                                                         2.1 x 10 +1
Notes:
(1)    Inhalation of fugitive dusts.
(2)    Risk levels presented are associated with potential exposures to organic and
      dissolved inorganic COPCs.
(3)    Inhalation of volatilized organic COPC concentrations in shower air as determined by
         the Foster and Chrostowski Shower Model.
      No COPCs identified for evaluation.

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                                    TABLE 2-9

                        SUMMARY OF EVALUATION CRITERIA

     Overall  Protection of Human Health and Environment -  addresses  whether or not an
     alternative provides  adequate protection and describes  how risks  posed through each
     pathway  are eliminated,  reduced,  or controlled through  treatment,  engineering controls,
     or institutional  controls.

     Compliance with ARARs -  addresses whether or not  an alternative will  meet all of the
     applicable or relevant and appropriate requirements (ARARs)  prescribed in federal and
     state environmental statutes and/or provide grounds for invoking  a waiver.

     Long-Term Effectiveness  and Permanence - refers to the  magnitude  of residual  risk and
     the ability of an alternative to  maintain reliable protection of  human health and the
     environment over  time once cleanup goals have been met.

     Reduction of Toxicity, Mobility,  or Volume through Treatment -  refers to the  anticipated
     performance of the treatment options that may be  employed in an alternative.

     Short-Term Effectiveness - refers to the speed with which the alternative achieves
     protection,  as well as the remedy's potential to  create adverse impacts on human health
     and the  environment during the construction and implementation  period.

     Implementability  - refers to the  technical and administrative feasibility of  an
     alternative,  including the availability of materials  and services needed to implement
     the chosen solution.

     Cost - includes capital  and operation and maintenance costs,  and  for  comparative
     purposes,  net present worth values.

     State Acceptance  - indicates whether,  based on review of the RI and FS Reports and the
     PRAP,  the State concurs  with,  opposes,  or has no  comments on the  preferred alternative.

     Community Acceptance  - will be addressed in the Record  of Decision following  a review
     of the public comments received on the RI and FS  Reports and the  PRAP.




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                                           APPENDIX A
                                       VADEQ CONCURRENCE IiETTER


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                                               APPENDIX B
                                              ARAR TABIiES

                                                 TABIiE B-la
Requirement
 FEDERAL CHEMICAL-SPECIFIC ARARS BY MEDIA
CD LANDFILL SITE - OU 2 SOIL AND GROUNDWATER
      NAVAL BASE, NORFOLK, VIRGINIA
               (Sheet 1 of 2)

                         Prerequisite
                                                                          GROUNDWATER
Safe Drinkinq Water Act  (SDWA) , 42 USC 300*
National primary drinkinq water standards are
health-based standards for public water
systems  (maximum contaminant levels
[MCLs]) .
                      Public water system.
  Citation
40 CFR Part 141
Subparts B & G
Maximum contaminant level qoals  [MCLGs]
pertain to known or anticipated adverse health
effects (also known as recommended
maximum contaminant levels).
                       Public water system.
40 CFR Part 141
Subpart F
                         ARAR
                    Determination
Not  relevant
 and appropriate
for  the  shallow
water  table
 aquifer, which
is a Class  III
 aquifer, and is
 not  a  potential
 drinkinq water
 source.
 Relevant and
 appropriate to
 the  Yorktown
Aquifer.
 Relevant and
 appropriate for
Yorktown
Aquifer only,
which  is a
Class  II
aquifer. The
water table
aquifer  is a
Class III
aquifer.
                                                     Comments
MCLs are relevant and appropriate for
 qroundwater determined to be a current or
potential source of drinkinq water in cases
where MCLGs are not ARARs. MCLs are
relevant and appropriate  for  Yorktown
aquifer. However, no contaminants
detected in Yorktown Aquifer  in excess  of
MCLs.
 MCLGs  that have non-zero values are
 relevant and appropriate for qroundwater
determined to be a current or potential
 source of  drinkinq water (40 CFR
300.430[e][2][i][B]  throuqh  [D]).
Relevant and appropriate at the unit boundary.

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                                                                      TABIiE B-la

                                                        FEDERAL CHEMICAL-SPECIFIC ARARS BY MEDIA
                                                       CD LANDFILL SITE - OU 2 SOIL AND GROUNDWATER
                                                              NAVAL BASE, NORFOLK, VIRGINIA
                                                                      (Sheet 2 of 2)
            Requirement
      Prerequisite
  Citation
                             ARAR
                      Determination
                                                         Comments
National secondary drinkinq water requlations
are standards for the aesthetic qualities of
public water systems  (secondary MCLs
[SMCLs]) .
Public water system.
40 CFR Part 143,
excludinq 143.5(b)
TBC for
Yorktown
Aquifer only.
                                                                                                                                    SMCLs are nonenforceable federal
                                                                                                                                   contaminant levels intended as quidelines
                                                                                                                                   for the  states.  Because  they  are
                                                                                                                                   nonenforceable, federal SMCLs are not
                                                                                                                                  ARARs. However,  they  may  be  TBCs  at  the
                                                                                                                                  unit boundary.  Iron and manqanese
                                                                                                                                  detected  above  SMCLs  in two  Yorktown
                                                                                                                                  Aquifer wells  (may not  be site-related).
                                                                                                                                  Iron SMCL =  300  Iq/L, Manqanese SMCL
                                                                                                                                   =  50  Iq/L.
                                                                                 SURFACE WATER
Water quality criteria.
Discharqes to waters of
the United States and
qroundwater.
 33 USC 1314(a) and 42
 USC 9621(d)(2)
                    Federal water quality criteria may be
                     relevant and appropriate for any discharqes
                    to surface water  (from contaminated
                    qroundwater or surface runoff).
                                                                                                             Relevant and
                                                                                                              appropriate
                                                                                                             (NPDES
                                                                                                             requlations
                                                                                                             would be
                                                                                                             Relevant and
                                                                                                             appropriate).

*     Statutes and policies, and their citations, are provided as headinqs to identify qeneral cateqories of potential ARARs for the convenience  of  the  reader.  Listinq
      the statutes and policies does not indicate that DON accepts the entire statutes or policies as potential ARARs. Specific potential ARARs are  addressed  in the
      table below each qeneral headinq; only substantive requirements of the specific citations are considered potential ARARs.

ARARs - Applicable or relevant and appropriate requirements.
CFR - Code of Federal Requlations.
USC - United States Code.
TBC - To be considered.

-------
                                                                                     TABIiE B-lb

                                                                          FEDERAL LOCATION-SPECIFIC ARARS
                                                                   CD LANDFILL SITE  - OU 2 SOIL AND GROUNDTCATER
                                                                           NAVAL BASE, NORFOLK, VIRGINIA
                                                                                    (Sheet 1 of 1)
           Location

Executive Order 11988,
Within floodplain
     Requirement

 Protection of Floodplains*
Actions taken should avoid
adverse effects, minimize
potential harm, restore and
preserve natural and
 beneficial values,
      Prerequisite
 Action that will occur in a
 floodplain, i.e.,  lowlands,
 and relatively flat areas
 adjoininq inland and
coastal waters and other
flood-prone areas.
     Citation
40 CFR Part 6,
Appendix A; excludinq
Sections 6 (a)  (2),
6(a)(4),  6(a)(6);  40 CFR
6.302
   ARAR
Determination

 Applicable.
                                                 Comments
Reqradinq activities may require
compliance with this order.
 *   Statutes  and policies,  and their citations,  are provided as headinqs to identify qeneral cateqories of potential ARARs for the convenience of the reader. Listinq the statutes
   and policies does not indicate that DON accepts the entire  statues or policies as potential ARARs.  Specific potential ARARs  are  addressed in  the table below each qeneral
   headinq; only substantive requirements of the specific citations are considered potential ARARs.

ARARs - Applicable or relevant and appropriate requirements.
CFR - Code of Federal Requlations.
USC - United States Code.

-------
                                                                                                   TABLE B-2a

                                                                                    VIRGINIA CHEMICAL-SPECIFIC ARARS BY MEDIA
                                                                                   CD LANDFILL SITE - OU 2 SOIL AND GROUNDTCATER
                                                                                           NAVAL BASE, NORFOLK, VIRGINIA
                                                                                                   (Sheet 1 of 2)
              Requirement
Virginia Drinking Water Standards*
Primary drinking water standards are health-
based standards for public water supplies
(primary maximum contaminant levels
[PMCLs]) .
      Prerequisite
 Public water system.
         Citation

      GROUNDWATER

12 VAC 5-590-10
VR 355-18-001.02
Secondary drinking water regulations are
chemical based standards for qualities of
public water supplies  (secondary MCLs
[SMCLs]) .
Virginia Groundwater Standards*
Establishes groundwater standards for State
Antidegradation Policy.
 Public water system.
  12 VAC 5-590-390
  VR 355-18-004.06
Standards are used when
 no  MCL is  available.
   9 VAC 25-260-190 to
    220
   VR 680-21-04.1
      ARAR
  Determination
Relevant and
appropriate for
Yorktown
Aquifer only.
Not relevant
and appropriate
for shallow,
non-potable
water table
aquifer, which
is not  a
potential
drinking water
source.
 Relevant and
 appropriate for
 Yorktown
 Aquifer only.
 Relevant and
  appropriate
 when MCLs
 not  available,
 or when
 standards are
 more stringent
 than MCLs.
                               Comments
 Virginia PMCLs are similar to federal
 MCLs. PMCLs are relevant and
 appropriate for groundwater determined to
 Be a current or potential source of drinking
 water. However, the shallow water table is
not a potential drinking water source, and
no contaminants detected in Yorktown
Aquifer in excess of MCLs. Standards to be
applied at unit boundary.
  Virginia SMCLs are similar to federal
  SMCLs.  In Virginia,  SMCLs are
  enforceable for potable water supplies.
  and manganese detected above SMCLs in
  two Yorktown Aquifer wells (may not be
  site-related). Iron SMCL = 300 Ig/L,
  Manganese SMCL =50 Ig/L.

  MCLs available for all contaminants of
  concern.
                                                                                                               Iron

-------
                                                                                                           TABLE B-2a

                                                                                           VIRGINIA CHEMICAL-SPECIFIC ARARS BY MEDIA
                                                                                          CD LANDFILL SITE - OU 2 SOIL AND GROUNDTCATER
                                                                                                 NAVAL BASE, NORFOLK, VIRGINIA
                                                                                                         (Sheet 2 of 2)
            Requirement
Virginia Water Quality Standards*

Water quality standards based on water use
and class of surface water.
Virginia Air Pollution Control Regulations

Ambient Air Quality Standards: primary and
secondary standards for ambient air quality to
protect public health and welfare  (including
standards for particulate matter and lead).
 Prerequisite
Citation
                                                                    SURFACE WATER
Discharges to surface    9 VAC 25-260-10 to
waters.                  540
                         VR 680-21-01.1, et al.
                                                                            AIR
                             ARAR
                              Determination
                              Applicable.
Contamination of air
affecting public health
and welfare.
    9 VAC  5-30-20  and
    9  VAC  5-30-60
    VR 123-03
Applicable.
                                                     Comments
                    Water quality standards would be applicable
                    for any discharges to surface water  (from
                    contaminated groundwater or  surface
                    runoff).
Applicable to all activities at the site that
may generate regulated pollutants.
*      Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing
       the statutes and policies does not indicate that Navy accepts the entire statutes or policies as potential ARARs, Specific potential ARARs are addressed in the
       table below each general heading; only substantive requirements of the specific citations are considered potential ARARs.

ARARs - Applicable or relevant and appropriate requirements.
CFR - Code of Federal Regulations.
USC - United States Code.
TBC - To be considered criterion, not an ARAR

-------
                                                                            TABIiE B-2b

                                                               VIRGINIA LOCATION-SPECIFIC ARftRS
                                                         CD LANDFILL SITE - OU 2 SOIL AND GROUNDTCATER
                                                                  NAVAL BASE, NORFOLK, VIRGINIA
                                                                          (Sheet 1 of 2)
               Location          Requirement                         Prerequisite

Virqinia State Water Control Laws and Virqinia Wetlands Requlations*
                                                                Citation
                                                                                     ARAR
                                                                                    Determination
Wetland
 Action to minimize the             Wetland as defined by   Virqinia Code Sections   Not applicable.
 destruction, loss, or deqradation  Virqinia statutory      62.1-44.15:5
 of wetlands.                       provision.
                                                                                                              Comments
                                                                                                                                        No federal or state requlated wetlands are
                                                                                                                                        present on and adjacent to the site which
                                                                                                                                        could be impacted by the response action
                                                                                                                                        for the site.
Chesapeake Bay Preservation Act and Chesapeake Bay Preservation Area Desiqnation and Manaqement Requlations*
Chesapeake Bay areas
                                    Federally owned area
                                    desiqnated as a
                                    Chesapeake Bay
                                    Preservation area.
                           Code of Virqinia
                           Section 10.1-2100 et
                           seq. and 9 VAC 10-20-
                           10
                                Under these requirements,          Federally owned area    Code of Virqinia           TBC
                                certain locally desiqnated tidal
                                and nontidal wetlands, as well as
                                other sensitive land areas,  may
                                be subject to limitations
                                reqardinq land-disturbinq
                                activities,  removal of veqetation,
                                use of impervious cover,  erosion
                                and sediment control,
                                stormwater manaqement, and
                                other aspects of land use that
                                may have effects on water
                                quality.

Coastal Zone Manaqement Act*; Coastal Manaqement Plan, City of Norfolk, NOAA Requlations on Federal Consistency with approved State Coastal Zone
Manaqement Proqrams
This requirement is not an ARAR since the
area affected by the response action is not a
federally owned Chesapeake Bay
Preservation area.  Also,  City of Norfolk
does not have jurisdiction over the Naval
Base, Compliance is on a voluntary basis.
Within coastal zone
Conduct activities within a
coastal Manaqement Zone in a
manner consistent with local
requirements.
Activities affectinq the
coastal zone includinq
lands thereunder and
adjacent shore land.
                                                                                          Section 307 (c) of  16
                                                                                          USC 1456 (c); also see
                                                                                          15 CFR 930 and 923.45
                                                                                                                         TBC
This requirement is not an ARAR since the
City of Norfolk does not have jurisdiction
Over the Naval Base. Compliance is on a
 voluntary basis.

-------
                                                                            TABIiE B-2b

                                                                 VIRGINIA LOCATION-SPECIFIC ARARs
                                                            CD LANDFILL SITE - OU 2 SOIL AND GROUNDTCATER
                                                                   NAVAL BASE, NORFOLK, VIRGINIA
                                                                           (Sheet 2 of 2)
             Location            Requirement

Virginia Endangered Species Act*
Critical habitat upon
which endangered
species or threatened
species depend
  Action to conserve endangered
  species or threatened species,
  including consultation with the
  Virginia Board of Game and
  Inland Fisheries.
Virginia Natural Areas Preserves Act*
Natural preserves area
 Action to conserve natural
 preserve areas and restrict
 certain activities in these areas
                                          Prerequisite
 Determination of effect
 upon endangered or
threatened species or its
 habitat.
                                  Citation
 Code  of Virginia
 Sections  29.1-563
through 568
4 VAC 15-20-130
   Applicable to sites that
   meet natural preserve
   area criteria as
   determined by the
   Virginia Department of
   Conservation and
   Recreation
  Code of Virginia
  Sections 10.1-209
   through 217
                                                         ARAR
                                                     Determination
Applicable
because
peregrine
falcons  have
been seen near
the site.
   Relevant and
   Appropriate
                                                                           Comments
Virginia  Board of  Game  and  Inland
Fisheries will be  notified  of  this  project,
The Navy will request determination if
proposed  activities  will  threaten endangered
species or habitats.
 Virginia Department of Conservation and
 Recreation will be notified of this project.
 The Navy will request a determination if
 proposed activities will threaten natural
 heritage resources.
Virginia Endangered Plant and Insect Species Act; Virginia Board of Game and Inland Fisheries*
Endangered plant and
insect species
Action to conserve endangered
or protected plant and insect
species
 Applies to actions that
affect  endangered or
protected plant and
insect species.
 Code  of Virginia
Sections 29.1-100 and
29.1-565
 2 VAC 5-320-10
   Relevant  and
  Appropriate
Virginia  Department  of Agriculture  and
Consumer Services will be notified of this
project. The Navy requests determination if
proposed  activities  will affect endangered
 plants or insects.
*      Statutes and policies, and their citations, are provided as headings to identify general categories of potential ARARs for the convenience of the reader. Listing the
statutes and policies does not indicate that Navy accepts the entire statues or policies as potential ARARs. Specific potential ARARs are addressed in the table below each
general heading; only substantive requirements of the specific citations are considered potential ARARs.
ARARs - Applicable or relevant and appropriate requirements.

-------
                                                                            TABIiE B-2c

                                                                 VIRGINIA ACTION-SPECIFIC ARftRS
                                                         CD LANDFILL SITE - OU 2 SOIL AND GROUNDTCATER
                                                                 NAVAL BASE, NORFOLK, VIRGINIA
                                                                            (Sheet 1 of 2)
       Action
  Requirement
 Prerequisites
                                                                              ARAR Determination**
                                                                                           Citation
                                                                                                                 A
                                                                                                                     RA
                                                                                                                          TBC
                                                                                                                                         Comments
Virqinia Air Pollution Control Requlations*
Discharqe to air
  Virqinia Ambient Air Quality
  Standards - standards for ambient air
  quality to protect public health and
  welfare  (includinq standards for
  particulate matter and lead).
Discharqe of visible   Fuqitive dust/emissions may not be
emissions and fuqitive discharqed to the atmosphere at
dust                    amounts in excess  of standards.
  Contamination of air affectinq
  public health and welfare.
                                          Any source of fuqitive dust/
                                          emissions.
VR 120-03-02,
VR-120-030-06 &
9 VAC 5-30-10
                                    VR 120-05-01 &
                                    VAC  5-50-60  to
                                    120
Applicable for all site remediation
 Activities that may qenerate air
 discharqes.
                                   Applicable for any site remediation
                                   activities that qenerate fuqitive dust.
Discharqe of toxic
pollutants
   Toxic pollutants  may not  be  discharqed
   to the atmosphere at amounts in excess
   of standards.
   Any emission from the disturbance
  of soil, or treatment of soil or
   water,  that  do not qualify
   for the exemption under Rule 4-3.
  VR 120-05-01&
  VAC 5-50-160 to
   230
  Applicable for any site remediation
 activities that qenerate toxic air
  pollutants.
Virqinia Stormwater Manaqement Requlations and Virqinia Erosion and Sediment Control Requlations
Stormwater
Manaqement
  Requlates Stormwater manaqement and     Land disturbinq activities
  erosion/sedimentation control practice.
Virqinia Solid Waste Requlations
Closure of
Construction/
Demolition Debris
Landfills and
Industrial Waste
Landfills
 Closure  and post-closure  care
 requirements for
 construction/demolition debris
and for industrial waste landfills.
Landfill used to dispose
construction/demolition
debris and/or landfills
industrial waste
                                     VR 215-02-00 &
                                     VR 625-02-00 &
                                     4 VAC 50-30-10
 VR 672-20-10,
 Section 5.2;
 9 VAC 20-80-260;
 VR  672-20-10,
 Section 5.3;
 9 VAC 20-80-270
                                   Applicable for any site remediation
                                   activities involvinq surface water
                                   runoff and erosion.
 Industrial waste landfill requirements
 of 9 VAC 20-80-270 are applicable
 for the entire landfill.

-------
                                                              TABIiE B-2c
                                                    VIRGINIA ACTION-SPECIFIC ARARS
                                             CD LANDFILL SITE - OU 2 SOIL AND GROUNDTSATER
                                                     NAVAL BASE, NORFOLK, VIRGINIA
                                                              (Sheet 2 of 2)

       Action         Requirement                        Prerequisites
Virqinia Pollutant Discharqe Elimination System  (VPDES))  Permit Requlations*
                                                                                    Citation
                                                             ARAR Determination**
                                                             A   RA  TBC
                                                                                                                                 Comments
Discharqe of Treated
Water to Surface
Waters, and certain
storm water
discharqes
                                       Applicable to discharqe of treated water to
                                        surface water,  and to storm water discharqes
                                       from certain facilities, includinq landfills.
                                              VR 680-14-01,
                                               VR 680-15-01;
                                              9 VAC 25-31-10
                                               940
                 to
 Substantive requirements of VPDES
  permit will be used to determine the
 discharqe limits for the  discharqe of
  the treated water to surface water on
  site.
                       Requlated point-source discharqes
                       throuqh VPDES permittinq proqram.
                       Permit requirements include
                       compliance with correspondinq water
                       quality  standards, establishment of  a
                       discharqe monitorinq system,  and
                       completion of reqular discharqe
                       monitorinq records.

Virqinia Solid Waste Manaqement Requlations, Requlations Applicable to Generators and Transporters of Hazardous Waste; and Requlations Governinq the Transportation of Hazardous
Materials
Hazardous Materials
Preparation and
Transportation
Hazardous materials must be packaqed,
marked, labeled, placarded, loaded, and
transported in  the manner required.
Intrastate carriers transportinq hazardous
waste and substances by motor vehicle.
VR 672-10-01 Parts
 VI  and VII,
 9 VAC  20-60-420
 to 500;
 VR 672-30-1,
 9 VAC 20-110-10
 to 130, 9 VAC 20-
 60-330  to  410, and
 9VAC 20-60-600
Applicable to the qeneration, storaqe,
 preparation and off-site transportation
 of materials classified  as hazardous.
Solid Waste Manaqement Requlations, Solid Waste Disposal Facility Standards  (9 VAC 20-80-240 to 310 and 9 VAC 20-80-60); Virqinia Waste Manaqement Act*
Solid Waste Staqinq
Transport, and
Disposal
  These requlations and laws define the
  requirements for the staqinq,
  transportation, and disposal of solid
  wastes. The disposal facility must be
  properly permitted and in compliance
   with all operational and monitorinq
  requirements of the permit and
  requlations.
   Wastes must meet definition of solid waste.
                                                VR 672-20-10, Part
                                                 V;
                                                 9 VAC 20-80-240
                                                 to 310  (disposal
                                                 facility) ;
                                                 9 VAC 20-80-60
                                                 (staqinq of solid
                                                  wastes)
                                   Applicable to staqinq, transportation,
                                   and off-site disposal of any soil,
                                   debris, sludqe, or other material
                                   classified as a solid waste.
* Statutes and policies, and their citations, are provided as headinqs to identify qeneral cateqories of potential ARARs. Specific potential ARARs are addressed in the table below
each qeneral headinq.
** A - Applicable, RA - Relevant and appropriate, TBC - To be considered
ARAR - Applicable or relevant and appropriate requirement.
CFR - Code of Federal Requlations USC - United States Code.

-------
                                                       APPENDIX C
                                                  RI SAMPLING RESULTS

                                                           TABLE C-l

                                            SURFACE SOIL DATA AND COPC  SELECTION  SUMMARY  (1)
                                                             CD LANDFILL
                                                    NAVAL BASE, NORFOLK, VIRGINIA
                                             Detection Range/Frequency
                                                            Comparison to Criteria
                      Parameter
      Range of
Positive Detections
      (mg/kg)
No. of Positive
   Detects/
No. of Samples
USEPA Region III
Residential COPC
Screening Value
   (mg/kg)
                                                                                                                         No.  of Positive
                                                                                                                         Detects Above
                                                                                                                         Residential
                                                                                                                         COPC Screening
                                                                                                                             Value
                                                                        COPC
                                                                      Selection
Selected
  as a
  COPC?
Volatile Organic
Compounds:
   Tetrachloroethene
                                                      0.002J
                            1/6
                                                                                                         12
                                                                                                                                                No
Semivolatile Organic
Compounds:

   Phenanthrene
   Fluoranthene
   Pyrene
   Benzo(a)anthracene
   Chrysene
   Bis(2-ethylhexyl)phthalate
   Benzo(b)fluoranthene
   Benzo(k)fluoranthene
   Benzo(a)pyrene
   Indeno(1,2,3-cd)pyrene
   Dibenzo(a,h)anthracene
   Benzo(g,h,i)perylene
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.

0.
,052J
,034J
,042J
,046J
, 031J
,038J
,028J
,028J
, 019J
, 039J
0.
, 023 J
- 0.092J
- 0.170J
- 0.160J
- 0.094J
- 0.150J
- 10
- 0.210J
- 0.081J
- 0.093J
- 0.048J
017J
- 0.061J
4/6
5/6
5/6
3/6
5/6
3/6
5/6
4/6
5/6
2/6
1/6
3/6
                                                         310  (2)
                                                          310
                                                          230
                                                         0.88
                                                          88
                                                          46
                                                         0.88
                                                          8.8
                                                         0.088
                                                          0.88
                                                         0.088
                                                         310  (2)
0
0
0
0
0
0
0
0
1
0
0
0
No
No
No
No
No
No
No
No
Yes
No
No
No

-------
                                          TABIiE C-l (Continued)

                            SURFACE SOIL DATA AND COPC SEIiECTION SUMMARY (1)
                                               CD LANDFILL
                                      NAVAL BASE, NORFOLK, VIRGINIA
                                  Detection Range/Frequency
     Parameter

Pesticides/PCBs:

   Aldrin
   Dieldrin
   4,4'-DDD
   Endosulfan II
   4,4'-DDE
   4,4'-DDT
   Endrin Aldehyde
   alpha-Chlordane
   gamma-chlordane
   Aroclor-1260

Inorganics and Cyanide:

   Aluminum
   Antimony
   Arsenic (6)
   Barium
   Beryllium
      Range of
Positive Detections
     (mg/kg)
0.00051J - 0.00052J
 0.0024J - 0.051J
 0.0007J - 0.0007J
      0.00095J
  0.001J - 0.0031J
 0.0025J - 0.0078L
      0.00029J
 0.0003J - 0.0005J
      0.000097J
  0.012J - 0.027J
  1,690J - 11,100
   0.73J - 2.5J
     2.6 - 34.9
   16.8B - 106
   0.22B - 0.79B
No. of Positive
   Detects/
No. of Samples
     2/6
     3/6
     1/6
     1/6
     3/6
     3/6
     1/6
     2/6
     1/6
     2/6
    20/20
    2/20
    20/20
    20/20
    13/20
       Comparison to Criteria
                      No. of Positive
USEPA Region III       Detects Above
Residential COPC        Residential
Screening Value       COPC Screening
     (mg/kg)                Value
     0.038
     0.04
     2.7
     47  (3)
     1.9
     1.9
    2.3  (4)
    0.49  (5)
    0.49  (5)
    0.083
     7800
     3.1
     0.37
     550
     0.15
1
0
20
0
13
                                                                                          COPC
                                                                                        Selection
                                                                                                                   Selected
                                                                                                                    as  a
                                                                                                                     COPC?
                    No
                    Yes
                    No
                    No
                    No
                    No
                    No
                    No
                    No
                    No
Yes
No
Yes
No
Yes

-------
     Parameter

Inorganics and Cyanide
(Continued):
                                          TABIiE C-l  (Continued)

                            SURFACE SOIL DATA AND COPC SELECTION SUMMARY  (1)
                                               CD LANDFILL
                                      NAVAL BASE, NORFOLK, VIRGINIA
                                  Detection Range/Frequency
      Range of
Positive Detections
     (mg/kg)
No. of Positive
   Detects/
No. of Samples
       Comparison to Criteria
                      No. of Positive
USEPA Region III       Detects Above
Residential COPC        Residential
Screening Value       COPC Screening
     (mg/kg)                Value
                                                                                          COPC
                                                                                        Selection
                                                                                                                    Selected
                                                                                                                    as a
                                                                                                                     COPC?
Cadmium
Calcium
Chromium (7)
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
0.33B
2,600J
7.8
1.3B
4.6
5,010
9
455
26. U
0.09
3.3B
375
0.28
0.
83. 3B
- 2.3
- 155,OOOJ
- 31.8
- 6B
- 208
- 18,700
- 1,040L
- 33,600
- 264J
- 0.56
- 40.7
- 1,610
- 0.64
69B
- 1,730
7/20
20/20
20/20
18/20
20/20
20/20
20/20
20/20
20/20
8/20
20/20
20/20
9/20
1/20
20/20
                                                                          3.9

                                                                           39
                                                                          470
                                                                          290

                                                                          400  (8)
                                                                       39
                                                                           2.3
                                                                          160

                                                                           39
                                                                           39
                                                                                               18
                                                                                                                   Yes
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            Yes
                                                                                            No

                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No
                                                                                            No

-------
                                          TABIiE C-l  (Continued)

                            SURFACE SOIL DATA AND COPC SEIiECTION SUMMARY  (1)
                                               CD LANDFILL
                                      NAVAL BASE, NORFOLK, VIRGINIA
                                  Detection Range/Frequency
     Parameter

Inorganics and Cyanide
(Continued):

   Thallium
   Vanadium
   Zinc
   Cyanide (total)
      Range of
Positive Detections
     (mg/kg)
    0.23 - 0.54
    12.2 - 78
    12.3 - 982
       0.98L
No. of Positive
   Detects/
No. of Samples
     13/20
     20/20
     20/20
      1/16
       Comparison to Criteria
                      No. of Positive
USEPA Region III       Detects Above
Residential COPC        Residential
Screening Value       COPC Screening
     (mg/kg)                Value
     0.63
      55
     2,300
      160
(9)
                                                                                          COPC
                                                                                        Selection
                                                                                                                    Selected
                                                                                                                    as a
                                                                                                                      COPC?
No
Yes
No
No
Notes:
(1)   Surface soils include soil samples collected from the 0 - 0.25 foot depth interval during  Rounds  1,  2  and 3  of the  Remedial  Investigation.
(2)   COPC screening value for naphthalene used as a surrogate.
(3)   COPC screening value for endosulfan used as a surrogate.
(4)   COPC screening value for endrin used as a surrogate.
(5)   COPC screening value for chlordane used as a surrogate.
(6)   Arsenic evaluated as a carcinogen.
(7)   Chromium evaluated as chromium  (VI).
(8)   Action level for residential soils (USEPA, 1994c)
(9)   COPC screening value for thallium carbonate, thallium chloride and thallium  sulfate.
J     Analyte was positively identified, value is estimated.
B     Analyte was detected in a blank, inorganic value is estimated.
      No criteria published

-------
                                         TABLE C-2

                     SUBSURFACE SOIL DATA AND COPC SELECTION SUMMARY (1)
                                        CD LANDFILL
                              NAVAL BASE, NORFOLK, VIRGINIA
                                  Detection Range/Frequency
     Parameter

Volatile Organic
Compounds:

   Acetone
   Carbon disulfide
   2-Butanone
   Xylenes, Total

Semivolatile Organic
Compounds:

   Phenol
   2-Methylphenol
   Naphthalene
   2-Methylnaphthalene
   Acenaphthene
   Dibenzofuran
   Fluorene
   Phenanthrene
   Anthracene
      Range of
Positive Detections
     (mg/kg)
    0.015 - 0.033
       0.009J
   0.002J - 0.006J
       0.008J
   0.018J - 0.034J
       0.040J
   0.042J - 0.310J
   0.068J - 0.170J
       0.040J
       0.049J
    0.040J - 0.053J
    0.038J - 0.300J
    0.042J - 0.075J
No. of Positive
   Detects/
No. of Samples
     3/6
     1/6
     4/6
     1/6
     2/6
     1/6
     3/6
     2/6
     1/6
     1/6
     2/6
     4/6
     2/6
       Comparison to Criteria
                      No. of Positive
USEPA Region III       Detects Above
Residential COPC        Residential
Screening Value       COPC Screening
     (mg/kg)                Value
      780
      780
     4,700
    16,000
     4,700
      390
      310
      310  (2)
      470
      31
      310
      310  (2)
      2300
                                                                                          COPC
                                                                                        Selection
                                                                                                                   Selected
                                                                                                                    as  a
                                                                                                                     COPC?
No
No
No
No
No
No
No
No
No
No
No
No
No

-------
                                     TABIiE C-2  (Continued)

                     SUBSURFACE SOIL DATA AND COPC SELECTION SUMMARY  (1)
                                        CD LANDFILL
                              NAVAL BASE, NORFOLK, VIRGINIA
                                       Detection Range/Frequency
                                                   Comparison to Criteria
     Parameter

Semivolatile Organic
Compounds (Continued):

   Di-n-butylphthalate
   Fluoranthene
   Pyrene
   Benzo(a)anthracene
   Chrysene
   Bis(2-ethythexyl)phthalate
   Benzo(b)fluoranthene
   Benzo(k)fluoranthene
   Benzo(a)pyrene
   Indeno(1,2,3-cd)pyrene
   Benzo(g,h,i)perylene

Pesticides/PCBs:
      Range of
Positive Detections
     (mg/kg)
No. of Positive
  Detects/
No. of Samples
0.
0.084J
0.064J
0.086J
0.048J
0.052J
0.053J
0.020J
0.035J
0.023J
0.023J
044J
- 0.
- 0.
- 0.
- 0.
- 0.
- 0.
- 0.
- 0.
- 0.
- 0.

360J
300J
180J
190J
089J
170J
130J
160J
056J
048J
1/6
4/6
4/6
2/6
4/6
3/6
3/6
3/6
3/6
3/6
3/6
 USEPA Region III
 Residential COPC
Screening Value
      (mg/kg)
                                                 780
                                                 310
                                                 230
                                                 0.88
                                                  88
                                                  46
                                                 0.88
                                                  8.8
                                                0.088
                                                 0.88
                                                310  (2)
                                                                                                   No. of Positive
                                                                                                   Detects Above
                                                                                                   Residential
                                                                                                  COPC Screening
                                                                                                    Value
                                                                 COPC
                                                                 Selection
 Selected
as a
 COPC?
                                                                    No
                                                                    No
                                                                    No
                                                                    No
                                                                    No
                                                                    No
                                                                    No
                                                                    No
                                                                    Yes
                                                                    No
                                                                    No
   Heptachlor
   Dieldrin
   4,4 '-ODD
       0.00052J
  0.0012J - 0.0056J
   0.0027 - 0.021J
     1/6
     4/6
     4/6
       0.14
       0.04
       2.7
  No
  No
  No

-------
                                     TABIiE C-2  (Continued)

                     SUBSURFACE SOIL DATA AND COPC SELECTION SUMMARY  (1)
                                        CD LANDFILL
                              NAVAL BASE, NORFOLK, VIRGINIA
     Parameter

Pesticides/PCBs
(Continued):
                                       Detection Range/Frequency
                                                   Comparison to Criteria
      Range of
Positive Detections
     (mg/kg)
No. of Positive
  Detects/
No. of Samples
 USEPA Region III
 Residential COPC
Screening Value
      (mg/kg)
                                                                                                   No. of Positive
                                                                                                   Detects Above
                                                                                                   Residential
                                                                                                  COPC Screening
                                                                                                    Value
                                                                 COPC
                                                                 Selection
                   Selected
                  as  a
                   COPC?
   Endrin
   Endrin ketone
   4,4'-DDE
   4,4'-DDT
   Methoxychlor
   alpha-Chlordane
   gamma-Chlordane
   Aroclor-1260
0.0048J
0.0078J
0.0021J -
0.0013J -
0.0012J -
0.0012J -
0.00075J -
0.012J -
0.035J
0.010J
0.039
0.0035J
0.0045L
0.018J
1/6
1/6
4/6
3/6
2/6
3/6
4/6
2/6
                                                 2.3
                                                 2.3  (3)
                                                  1.9
                                                  1.9
                                                   39
                                                 0.49
                                                 0.49
                               (4)
                               (4)
                                                                                0.083
                                                  No
                                                  No
                                                  No
                                                  No
                                                  No
                                                  No
                                                  No
                                                  No
Inorganics and Cyanide:

   Aluminum
   Antimony
   Arsenic (5)
   Barium
   Beryllium
   Cadmium
 1,660 - 41,000
 0.35J - 103L
   1.2 - 21.7J
  6.IB - 688J
 0.22B - 2.IB
   1.3 - 50.4
    17/17
     4/17
    17/17
    17/17
     9/17
     6/17
        7,800
         3.1
         0.37
         550
         0.15
          3.9
7
3
17
1
9
3
Yes
Yes
Yes
Yes
Yes
Yes

-------
                                         TABLE C-2 (Continued)

                     SUBSURFACE SOIL DATA AND COPC SELECTION SUMMARY (1)
                                        CD LANDFILL
                              NAVAL BASE, NORFOLK, VIRGINIA
                                       Detection Range/Frequency
     Parameter

Inorganics and Cyanide
(Continued):

   Calcium
   Chromium (6)
   Cobalt
   Copper
   Iron
   Lead
   Magnesium
   Manganese
   Mercury
   Nickel
   Potassium
   Selenium
   Silver
   Sodium
   Thallium
      Range of
Positive Detections
     (mg/kg)
No. of Positive
  Detects/
No. of Samples
         Comparison to Criteria
                           No. of Positive
 USEPA Region III          Detects Above
 Residential COPC          Residential
Screening Value           COPC Screening
      (mg/kg)                Value
168B -
3.5 -
1.2B -
0.92 -
2,OOOJ -
2 -
268J -
7.2J -
0.12 -
1.9 -
204 -
0.27B -
1.5 -
45. 3B -
0.24 -
108,OOOJ
226
17.3
3,090
96,300J
3,220J
5,070
1,850J
0.92
521
1,760J
0.68B
182
4,340
0.53
17/17
17/17
11/17
17/17
17/17
17/17
17/17
17/17
6/17
14/17
16/17
2/17
4/17
17/17
6/17
                                                 39
                                                 470
                                                 290

                                                 400 (7)

                                                  39
                                                  2.3
                                                  160

                                                  39
                                                  39

                                                 0.63  (8)
                                                                                         COPC
                                                                                         Selection
                                                                                                                         Selected
                                                                                                                        as a
                                                                                                                         COPC?
                                                                    No
                                                                    Yes
                                                                    No
                                                                    Yes
                                                                    No
                                                                    Yes
                                                                    No
                                                                    Yes
                                                                    No
                                                                    Yes
                                                                    No
                                                                    No
                                                                    Yes
                                                                    No
                                                                    No

-------
                                    TABIiE C-2  (Continued)

                     SUBSURFACE SOIL DATA AND COPC SELECTION SUMMARY  (1)
                                        CD LANDFILL
                              NAVAL BASE, NORFOLK, VIRGINIA
                                       Detection Range/Frequency
     Parameter

Inorganics and Cyanide
(Continued):

   Vanadium
   Zinc
   Cyanide (total)

Notes:
      Range of
Positive Detections
     (mg/kg)
      5 - 349J
    2.IE - 6,220J
     1.1 - 1.4
No. of Positive
  Detects/
No. of Samples
     17/17
     17/17
      2/12
         Comparison to Criteria
                           No. of Positive
 USEPA Region III          Detects Above
 Residential COPC          Residential
Screening Value           COPC Screening
      (mg/kg)                Value
       55
     2,300
      160
                                                                                         COPC
                                                                                         Selection
                                                                                                                          Selected
                                                                                                                        as a
                                                                                                                          COPC?
Yes
Yes
No
(1)   Subsurface soils include soil samples collected from the 0.25 - 12 foot depth interval during Rounds  1,  2  and  3  of  the  Remedial  Investigation.
(2)   COPC screening value for naphthalene used as a surrogate.
(3)   COPC screening value for endrin used as a surrogate.
(4)   COPC screening value for chlordane used as a surrogate.
(5)   Arsenic evaluated as a carcinogen.
(6)   Chromium evaluated as chromium  (VI).
(7)   Action level for residential soils (USEPA, 1994c)
(8)   COPC screening value for thallium carbonate, thallium chloride and thallium sulfate.
J     Analyte was positively identified, value is estimated.
B     Analyte was detected in a blank, inorganic value is estimated.
      No criteria published

-------
                                                     TABIiE C-3

                                 SHAIiOW GROUNDWATER DATA AND COPC  SEIiECTION SUMMARY
                                            GROUNDTCATER  - ROUNDS  2  AND  3
                                            CD LANDFILL  SITE, NAVAL BASE
                                                  NORFOLK, VIRGINIA
                                                 Groundwater  Criteria
                                              Contaminant
                                           Frequency/Range  (3)
Comparison to Criteria
Volatile Organic Compounds:

   Methylene Chloride
   Chloroform
   Chlorobenzene

Semivolatile Organic Compounds:

   Phenol
   2-Chlorophenol
   1,3-Dichlorobenzene
   1, 4-Dichlorobenzene
   1, 2-Dichlorobenzene
   4-Methylphenol
   Naphthalene
   2-Methylnaphthalene
   Acenaphthene
   Dibenzofuran
   Diethyl phthalate
                                        Federal
                                          MCL
                                       (Ig/L)  (1)
100
100
600
600
 75
600




Virginia
PMCLs
(Ig/L) (2)

--


—
—
75
—
—
--
--
--
—
--
USEPA
Region III
Tapwater
COPC
Screening
Level
(Ig/L)
4.1
0.15
3.9
2,200
18
54
0.44
27
18
150
150 (4)
220
15
2,900



No. of
Positive
Detects/No.
of Samples
1/25
2/25
4/25
3/25
2/25
2/25
2/25
2/25
3/25
5/25
5/25
4/25
2/25
7/25




Concentration
Range ( 3 )
(Ig/L)
2J
3J-5J
3J-2, OOOJ
2J-5J
10-16
4J-5J
9J-12
8J-10
0.7J-2J
1J-3J
0.5J-1J
1J-6J
1J-1J
0.5J-6J
                                                                No. of
                                                                Detects
                                                                Above
                                                                  MCL
      No. of
      Detects
       Above
      Virginia
        PMCL

:ria
No. of
Detects
Above
COPC
Screening
Value
0
2
3
0
0
0
2
0
0
0
0
0
0
0
COPC
Selection



Retained
as a
COPC?
No
Yes
Yes
No
No
No
Yes
No
No
No
No
No
No
No

-------
                                                             TABIiE C-3 (Continued)

                                             SHALLOW GROUNDWATER DATA AND COPC SELECTION SUMMARY
                                                         GROUNDWATER - ROUNDS 2 AND 3
                                                         CD LANDFILL SITE, NAVAL BASE
                                                              NORFOLK, VIRGINIA
           Contaminant
Seinivolatile Organic
Compounds: (Continued)

  Fluorene
  N-Nitrosodiphenylamine
  Phenanthrene
  Anthracene
  Carbazole
  Di-n-butyl phthalate
  Fluoranthene
  Pyrene
  Butyl benzyl phthalate
  Bis(2-ethylhexyl)phthalate
Groundwater Criteria
US EPA
Region III


Federal
MCL
(Ig/L) (1)

—
—
—
—
—
—
—
—
6
Tapwater
COPC
Virginia Screening
PMCLs Level
(Ig/L) (2) (Ig/L)
150
1.4
150 (4)
1,100
3.4
370
150
110
730
4.8
Contaminant
Freguency/Range (3) Comparison to Criteria
No. of

No. of
Positive
Detects/No.
of Samples
4/25
1/25
6/25
2/25
4/25
7/25
5/25
3/25
1/25
14/25

No. of
Concentration Detects
Range (3) Above
(Ig/L) MCL
0.6J-1J
1J
0.5J-2J
0.6J-1J
0.5J-1J
0.5J-2J
0.5J-2J
0.5L-2J
0.6J
1.5J-9J
No. of Detects
Detects Above
Above COPC
Virginia Screening
PMCL Value
0
0
0
0
0
0
0
0
0
1
COPC
Selection


Retained
as a
COPC?
No
No
No
No
No
No
No
No
No
Yes

-------
                                                                         TABLE C-3  (Continued)
                                                         SHALLOW GROUNDWATER DATA AND COPC SELECTION SUMMARY
                                                                     GROUNDWATER - ROUNDS 2 AND 3
                                                                     CD LANDFILL SITE, NAVAL BASE
                                                                          NORFOLK, VIRGINIA
            Contaminant
Pesticides/PCBs:

  beta-BHC
  Heptachlor epoxide
  Dieldrin
  4,4-DDD
  4,4DDT
  Endrin aldehyde
  gamma-Chlordane
  Aroclor-1260

Unfiltered Inorganics:

  Aluminum
  Antimony
  Arsenic
  Barium
  Beryllium
  Cadmium
  Calcium+
  Chromium (7)
  Cobalt
  Copper
  Iron+
  Lead
  Magnesium+
  Manganese
  Mercury
 Federal
   MCL
 (Ig/L)  (1)
   0.2
Groundwater Criteria
                      US EPA
                   Region III
                    Tapwater

       Virginia
         PMCLs
        (Ig/L) (2)
                                                                                  Contaminant
                                                                               Freguency/Range
                                                                   (3)
   6
   50
  2000
   4
   5

  100

1,300 (8)

  15 (8)
        50
      1,000

        10

        50
        50
COPC
creening
Level
(Ig/L)
0.037
0.0012
0.0042
0.28
0.2
1.1 (1)
0.052 (6)
0.0087
3,700
1.5
0.038
260
0.016
1.8
--
18
220
140
--
—
—
18
1.1
No. of
Positive
Detects/No.
of Samples
1/23
1/23
6/23
3/23
2/23
1/23
1/23
1/23
25/25
7/17
22/25
25/25
7/25
8/25
25/25
21/25
17/25
25/25
25/25
24/25
25/25
25/25
6/25

Concentration
Range ( 3 )
(Ig/L)
0.034J
0.032J
0.006J-0.04J
0.015J-0.02J
0.016J-0.02J
0.017J
0.0051
0.12J
83.66-208,000
1.2J-33.6
2.8L-65.6
34.4-1,940
1.1B-6.4B
4.7-21.8B
34,500-335,000
7.5B-309
6.7-55.6
2.9B-534
1,240-177,000
1.2B-864J
5,540-77,900
158-6,560
0.26-1.1
   Comparison to Criteria
No. of
Detects
 Above
 MCL
No. of
Detects
 Above
Virginia
 PMCL
  No.  of
 Detects
  Above
  COPC
Screening
Value
                                                                                                                     COPC
                                                                                                                   Selection
Retained
  as a
 COPC?
0
1
6
0
0
0
0
1
No
Yes
Yes
No
No
No
No
Yes
—
6
2
0
2
7
—
7
—
0
—
16
—
—
0
—
—
2
1
—
3
—
12
—
—
—
9
—
—
0
21
6
22
5
7
8
—
18
0
3
—
--
—
25
0
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No

-------
                                                              TABIiE C-3  (Continued)
                                              SHALLOW GROUNDWATER DATA AND COPC SELECTION SUMMARY
                                                          GROUNDWATER - ROUNDS 2 AND 3
                                                          CD LANDFILL SITE, NAVAL BASE
                                                                NORFOLK, VIRGINIA
Groundwater Criteria
           Contaminant
Unfiltered Inorganics:
(Continued)

  Nickel
  Potassium+
  Selenium
  Silver
  Sodium+
  Thallium
  Vanadium
  Zinc

Filtered Inorganics:

  Aluminum
  Antimony
  Arsenic
  Barium
  Calcium+
  Chromium
  Cobalt
  Copper
  Iron+
  Lead
  Magnesium+
  Manganese
  Nickel
  Potassium+
  Selenium
 100

  50
  6
  50
 2000

 100

1,300

  15


 100

  50
                                                   Contaminant
                                                Freguency/Range
                                                                                              (3)
Comparison to Criteria




Virginia
PMCLs
(Ig/L) (2)

--
10
50
--
--
—


—
50
1,000
--
50
—
—
—
50
--
--
—
—
10
USEPA
Region III
Tapwater
COPC
Screening
Level
(Ig/L)
73
—
18
18
—
0.29 (9)
26
1,100
3,700
1.5
0.038
260
—
18
220
140
—
—
--
--
73
—
18



No. of
Positive
Detects/No.
of Samples
19/25
25/25
2/12
2/25
25/25
1/25
24/25
25/25
14/25
5/25
13/25
25/25
25/25
2/25
10/25
14/25
24/25
1/25
25/25
25/25
10/25
25/25
2/25




Concentration
Range ( 3 )
(Ig/L)
10.2B-138
2,530-56,300
2.6B-5.6
2.9B-8.6B
11, 600-539,000
1.1B
5.9-504
8-3,780
16-144B
4.9B-18.8B
2.5B-41.8
26.6-835
33,000-352,000
69.6-106
3.5B-31
2B-17.7B
75.46-28,800
2.3B
5,170-60,000
106-5,790
5B-52.9
2, 020-54, 500J
5.6-6.3



No. of
Detects
Above
MCL
2
--
0
—
--
0
—


3
0
0
--
1
—
0
-
0
--
--
0
—
0

:ria
No. of
Detects
Above
COPC
Screening
Value
5
—
0
0
—
1
17
3
0
5
13
1
-
2
0
0
—
--
—
25
0
—
0
COPC
Selection



Retained
as a
COPC?
Yes
No
No
No
No
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
No
No
No
No
No
Yes
No
No
No

-------
                                                                 TABLE C-3  (Continued)
                                                 SHALLOW GROUNDWATER DATA AND COPC SELECTION SUMMARY
                                                           GROUNDWATER - ROUNDS 2 AND 3
                                                           CD LANDFILL SITE, NAVAL BASE
                                                                NORFOLK, VIRGINIA
                                                                                             Contaminant
                                             Groundwater Criteria                         Frequency/Range  (3)
                                                                         Comparison to Criteria
                                                                                            COPC
                                                                                          Selection
           Contaminant
Filtered Inorganics:  (Continued)
  Silver
  Sodium+
  Thallium                      2
  Vanadium
  Zinc


Federal
MCL
(Ig/L) (1)


Virginia
PMCLs
(Ig/L) (2)
USEPA
Region III
Tapwater
COPC
Screening
Level
(Ig/L)

No. of
Positive
Detects/No.
of Samples


Concentration
Range ( 3 )
(Ig/L)

No. of
Detects
Above
MCL
No. of
Detects
Above
Virginia
PMCL
Detects
Above
COPC
Screening
Value


Retained
as a
COPC?
50
               18

             0.29
               26
             1,100
(9)
 1/25
25/25
 1/25
 3/25
18/25
     2.3B
11,000-775,000
     1.5K
  1.2B-7.5B
   4.1B-577
 No
No
 Yes
 No
 No
Notes:
 (1) Federal MCL - Federal Safe Drinking Water Act Maximum Contaminant Level  (USEPA, 1994a)
 (2) Virginia Primary Maximum Contaminant Levels  (Bureau of National Affairs  - December,  1993)
 (3) B (organics) = Not detected substantially above the level reported in laboratory or  field blanks.
     B (inorganics) = Less than CRDL but greater than or egual to the IDL.
     J = Analyte was positively identified, value is estimated.
     L = Value estimated; biased low.
     K = Value estimated; biased high.
 (4) COPC screening value for naphthalene used as a surrogate.
 (5) COPC screening value for endrin used as a surrogate.
 (6) COPC screening value for chlordane used as a surrogate.
 (7) Chromium was evaluated as chromium  (VI).
 (8) Action level.
 (9) COPC screening value for thallium carbonate, thallium chloride and thallium sulfate.

     -- = No criteria published
     + = Essential Nutrient

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                                                                TABIiE C-4
Unfiltered Inorganics:

   Aluminum
   Barium
   Calcium
   Copper
   Iron
   Lead
   Magnesium
   Manganese
   Potassium
   Sodium
   Vanadium
   Zinc
                                                DEEP GROUNDWATER DATA AND COPC  SEIiECTION SUMMARY
                                                                CD LANDFILL
                                                       NAVAL BASE, NORFOLK, VIRGINIA
                              Detection Range/Freguency
Concentration
    Range
   (Ig/L)

    543B
    41J
  182,000
    2.2B
   4, 630
    1.4B
   5,200
    156
  1,620J
  28,900
    5.9
  11.413
 No. of Positive
    Detects/
No. of Samples

      1/1
      1/1
      1/1
      1/1
      1/1
      1/1
      1/1
      1/1
      1/1
      1/1
      1/1
      1/1
                                                 Groundwater Criteria  (2)
                                                                        Comparison  to  Criteria
                                                                                COPC
                                                                               Selection


Federal
MCL
(Ig/L)
50 - 200 (3)
2.000
1,300 (4)
300 (3)
15 (4)
USEPA
Region III
Tapwater
COPC Value
(Ig/L)
3,700
260
140
—
—


Virginia
PMCLs
(Ig/L)
—
1,000
1,000 (3)
300 (3)
50

No. of
Detects
Above
MCL
1
0
0
1
0
No. of
Detects
Above
COPC
Value
0
0
0
—
—
50 (3)
                                                                    5,0000  (3)
                18
                26
              1,100
50 (3)
                                                                      5,000  (3)
                                                                 No. of
                                                                 Detects
                                                                  Above      Retained
                                                                 Virginia       as  a
                                                             Criteria     COPC  ?
—
0
—
0
1
0
—
1
--
—
—
0
No
No
No
No
No
No
No
Yes
No
No
No
No

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                                                                     TABIiE C4  (Continued)

                                                      DEEP GROUNDWATER DATA AND COPC SEIiECTION  SUMMARY  (1)
                                                                         CD LANDFILL
                                                                 NAVAL BASE, NORFOLK, VIRGINIA
                            Detection Range/Frequency
                                                          Groundwater Criteria  (2)
                                                                      Comparison to Criteria
                                                                                 COPC
                                                                               Selection
        Parameter

Dissolved Inorganics:

  Barium
  Calcium
  Iron
  Magnesium
  Manganese
  Potassium
  Sodium
           Concentration
               Range
                (Ig/L)
                33.7
              171,000
                 734
               5,260J
                 138
               1,630J
               29,200
No. of Positive
    Detects/
No. of Samples
      1/1
      1/1
      1/1
      1/1
      1/1
      1/1
      1/1


Federal
MCL
(Ig/L)
US EPA
Region III
Tapwater
COPC Value
(Ig/L)


Virginia
PMCLs
(Ig/L)g/L)

No. of
Detects
Above
MCL
No. of
Detects
Above
COPC
Value
No. of
Detects
Above
Virginia
Criteria


Retained
as a
COPC?
                                                     2000
50 (3)
                                                                     260
                                1,000
50 (3)
 No
 No
 No
No
 Yes
 No
 No
Notes:
(1)
(2)
(3)
(4)
B
J
Data and COPC Summary is for groundwater samples collected during Round  2  of  the  Remedial  Investigation.
Federal MCL - Federal Safe Drinking Water Act Maximum Contaminant Level  (USEPA, 1994a;  Drinking Water  Regulations  and Health Advisories)
Virginia Drinking Water Standards - PMCLs - Primary Maximum Contaminant  Levels  (Bureau  of  National Affairs  -  December,  1994)
COPC values - USEPA Region III COPC screening value  (USEPA, 1993a)
Secondary MCL.
Action level
Analyte was also detected in an associated blank.
Analyte was positively identified, value is estimated.
No criteria published

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                                                                         TABLE C-5

                                                       SURFACE WATER DATA AND COPC  SELECTION SUMMARY
                                                                         CD LANDFILL
                                                                 NAVAL BASE, NORFOLK, VIRGINIA
        Parameter
Seinivolatile Organic
Compounds:

  1,4-Dichlorobenzene
  1,2-Dichlorobenzene
  4-Methylphenol

Pesticides:

  Dieldrin
  4,4-DDD

Inorganics and Cyanide:

  Aluminum
  Antimony
  Arsenic
  Barium
  Beryllium
  Calcium
  Chromium
  Cobalt
 Copper
  Iron                 ;
  Lead
  Magnesium
         Manganese
  Mercury
  Nickel
  Potassium
  Silver
  Sodium
        Detection Range/Freguency
                            No. of
                           Positive
     Concentration         Detects/
         Range              No. of
         (Ig/L)             Samples
       0.7J - 1J
        2J - 2J
          0.8J
    0.013J - 0.035J
     0.01J - 0.016J
    345J - 176,OOOJ
          22.5
        4.7-40.1
       50.8-1,420
      4.9B - 9.IB
   76,200 - 197,000
     10.9 - 299
      9.4 - 128
         425
2,100K - 1,470,OOOK
     7.5 - 712
 9,170 - 324,000
          136 - 6,760
   0.51 - 0.74
    9.2 - 253
4,540J - 129,OOOJ
     5.2 - 7.2
12,100 - 3,150,000
2/7
2/7
1/7
4/7
3/7
7/7
1/7
6/7
7/7
2/7
7/7
4/7
3/7
7/7
7/7
6/7
7/7
7/7
2/7
5/7
7/7
3/7
7/7
   400 (2)
  2,700 (3)
 0.00014 (3)
 0.00083 (3)
   14 (3)
 0.018 (3)
 1,000 (4)
0.0076 (5)

 170 (5)

 1,300 (5)
   300 (4)
    50 (4)

   50 (4)
  0.14 (2)
   610 (3)

   91 (5)

Organisms
Only
(Ig/L)
2,600 (2)
17,000 (3)
0.00014 (3)
0.00084 (3)
4,300 (1)
0.14 (3)
0.131 (5)
3,400 (5)
--
100 (4)
0.15 (2)
4,600 (3)
Public
Water
Supplies
(Ig/L)
400
2,700
0.0014
50
2,000
170
300 (7)
15
50 (7)
0.144
607
All Other
Surface
Waters
(Ig/L)
2, 600
17,000
0.0014
--
3,400
--
0.146
4,583
0
0
NA
NA
1
6
1
2
NA
2
 NA
 0
 7
 2
 NA
 7
 2
 0
 NA
 0
 NA
0
0
NA
NA
0
6
NA
2
NA
0
 NA
 NA
 NA
 NA
 NA
 7
 2
 0
 NA
 NA
 NA
;rations Exceeding COPC
riterion
Virginia
Public
Water
Supplies
0
0
NA
4
NA
NA
NA
0
0
NA
NA
2
NA
NA
7
3
NA
7
2
0
NA
NA
NA
Selection
Virginia
All Other Retained
Surface as a
Waters COPC?
0 No
0 No
NA No
4 Yes
NA Yes
NA No
NA Yes
NA Yes
NA Yes
NA Yes
NA No
0 Yes
NA No
NA No
NA No
NA Yes
NA No
NA Yes
2 Yes
0 No
NA No
NA No
NA No

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                                                                         TABLE C-5
Inorganics and Cyanide  (continued):
  Thallium
  Vanadium
  Zinc
  Cyanide, Total
   1.9 - 5L
   6-1,180
15.813 - 2,640
    5B - 25.1
                                                       SURFACE WATER DATA AND COPC SELECTION SUMMARY
                                                                         CD LANDFILL
                                                                 NAVAL BASE, NORFOLK, VIRGINIA
3/7
6/7
7/7
2/7
1.7 (3)
                                        700 (3)
6.3 (3)
                 220,000 (3)
                                5,000 (7)
                                  700
                      215,000
3
NA
NA
 0
0
NA
NA
 0
NA
NA
0
 0
NA
NA
NA
 0
Yes
No
No
No
Notes:
(1)  All concentrations reported in Ig/L
(2)  USEPA, 1992. Water Quality Standards: Establishment of Numeric Criteria for Priority Toxic Pollutants,
(3)  USEPA, 1992. Water Quality Standards: Establishment of Numeric Criteria for Priority Toxic Pollutants,
     agency g 1* or RfD, as con Integrated Risk Information System  (MIS).
(4)  USEPA, 1991. Water Quality Criteria Summary Published Criteria.
(5)  USEPA, 1991. Water Quality Criteria Summary Recalculated values from IRIS  (as of 9/90), based on a risk level
(6)  Chromium evaluated as the hexavalent state.
(7)  To maintain acceptable taste, odor or aesthetic guality of drinking water.
J    =    Analyte was positively identified, value is estimated.
B    =    Detected in associated blank(s).
L    =    Value is estimated; biased low.
K    =    Value is estimated, biased high.
     =    No criteria published.
NA   =    Not Applicable.
                                                                                   States Compliance: Final
                                                                                   States Compliance: Final
                                                                                          of 1 x 10 1)
                                                                                 Rule.
                                                                                 Rule.
                                                                           Criteria revised to reflect current

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