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
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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.
-------
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
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
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.
-------
APPENDIX A
VADEQ CONCURRENCE IiETTER
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
------- |