EPA 542-R-13-006
January 2013
United States Office of Solid Waste and Emergency Response
Environmental Protection Office of Superfund Remediation and
Agency ^
Technology Innovation
Optimization Review
Peck Iron and Metal Superfund Site
Portsmouth, Virginia
www.epa.gov/superfund/remedytech | www.clu-in.org/optimization | www.epa.gov/superfund/cleanup/posteonstruction
-------
OPTIMIZATION REVIEW
PECK IRON AND METAL SUPERFUND SITE
PORTSMOUTH, VIRGINIA
Report of the Optimization Review and
Site Visit Conducted at the Peck Iron and Metal Superfund Site on
February 22, 2012
January 18,2013
-------
EXECUTIVE SUMMARY
The purpose of this optimization review was to evaluate site conditions and identify optimal approaches
for conducting the remedial investigation (RI) of the Peck Iron and Metal (PIM) Superfund Site (the Site).
It is expected that this report may form the basis for additional systematic project planning among the
optimization review team, project technical team and stakeholders to develop, review and finalize RI-
specific work planning and implementation documents.
The U.S. Environmental Protection Agency (EPA)'s Office of Solid Waste and Emergency Response
(OSWER) and the Office of Superfund Remediation and Technology Innovation (OSRTI) define
optimization as follows:
"Efforts at any phase of the removal or remedial response to identify and implement
actions that improve the action's effectiveness and cost-efficiency. Such actions may also
improve the remedy's protectiveness and long-term implementation which may facilitate
progress towards site completion. To identify these opportunities, regions may use a
systematic site review by a team of independent technical experts, apply techniques or
principles from Green Remediation or Triad, or apply some other approach to identify
opportunities for greater efficiency and effectiveness. Contractors, states, tribes, the
public and PRPs are also encouraged to put forth opportunities for the Agency to
consider."
Optimization reviews include a "systematic site review," whereby the site as a whole is often considered.
However, optimization can focus on a specific aspect of a given cleanup phase (or a particular operable
unit [OU]), with other phases and site areas considered to the degree that they affect the focus of the
optimization effort. For optimization reviews conducted before a Record of Decision (ROD) is issued, the
focus is on developing the conceptual site model (CSM) by leveraging existing data and exploring
potentially applicable sampling and analysis tools and strategies that facilitate a comprehensive
systematic planning process.
The recommendations in this report are intended to help the site team identify opportunities for an
optimized RI approach. Where noted in this report, further analysis of a recommendation may be needed
before the recommendation can be implemented. The recommendations are based on an independent
evaluation and represent the opinions of the optimization review team. These recommendations do not
constitute requirements for future action, but rather are provided for consideration by the Region and
other site stakeholders. While the recommendations may provide some details to consider during
implementation, the recommendations are not meant to replace other, more comprehensive, planning
documents such as work plans, sampling plans and quality assurance project plans (QAPP).
Site-Specific Background
The Site is a 3 3-acre property located in Norfolk County, Portsmouth, Virginia. PIM (Figure 1) is the site
of a former scrap metal storage and recycling facility that began operation in the 1940s. The Site borders
Paradise Creek, a tidal tributary to the Elizabeth River. As a result of Site operations, elevated
concentrations of lead, poly-chlorinated biphenyls (PCBs), arsenic and other contaminants are present in
site environmental media, particularly surface soil. In accordance with a January 11, 2007 EPA, Region 3
(Region 3) Administrative Order for Removal Response Action, the site owner conducted an investigation
to determine the extent of contamination. Based on a review of this and previous investigations,
-------
Hydrogeologic, Inc. (HGL), on behalf of Region 3, prepared a Response Action Contract (RAC) RI Work
Plan (HGL Plan) to address identified data gaps in the existing Site characterization and to generate the
data necessary to support the assessment of remedial options. The purpose of this optimization review is
to evaluate Site conditions and identify opportunities, if any, to optimize the planned RI of the PIM site.
Summary of Conceptual Site Model
Based on review of available documents and a site visit conducted on February 22, 2012, a preliminary
conceptual site model (PCSM) has been developed to describe the optimization team's interpretation of
dominant processes responsible for the release and transport of site constituents to the environment.
As a result of approximately 50 years of scrap metal processing and recycling operations, contaminants,
primarily PCBs and metals, were released over broad areas to surface soil at the Site. In addition, a
secondary source of potential subsurface soil contamination is the large amount of fill material of various
forms (construction rubble, debris, etc.) used to raise land surface elevations, particularly in the southern
central portion of the Site. Contact of precipitation with contaminated soil potentially resulted in the
transport of contaminated soil through surface runoff. Surface water transport of contaminated soil has
potentially resulted in elevated levels of site constituents in Paradise Creek. As a result of the downward
migration of contaminated groundwater recharge, the potential also exists for offsite migration of
contaminated groundwater.
Summary of Findings
The following are the primary findings from this optimization review.
Although mostly vacant, portions of the Site are being used for various ad hoc purposes that may
contribute to, or result in human exposure from, Site contamination. For example, a construction
contractor appears to use a portion of the Site as an operations base and materials used for
automotive painting and maintenance were identified during the site visit.
Most of the Site is blanketed by a fill layer that locally can attain thicknesses approaching 10 feet
(ft). The fill appears to consist of soil mixed with various forms of rubble (wood, concrete,
asphalt, glass) and metal scraps. Previous investigations have indicated that the fill may contain
minor amounts of munitions and explosives of concern/munitions debris (MEC/MD).
Historic processing of decommissioned electrical transformers for scrap metal recovery at the Site
is the likely source for elevated PCB concentrations observed over much of the Site. Results from
the extensive amount of soil sampling conducted at the Site indicate that PCB concentrations
exceeding 5.4 milligrams per kilogram (mg/kg) or 10 times the most stringent EPA Regional
Screening Level (RSL) for PCBs in industrial soil (0.54 mg/kg for Aroclor1 1221 and 1232) are
common. Additionally, concentrations exceeding 100 times the Aroclor 1221 and 1232 RSL have
been identified in many areas.
Elevated concentrations of metals and PCBs are present in Site soils over broad areas. Although
somewhat limited, Site groundwater data suggest that Site related metals and PCBs are either
present at relatively low concentration levels or are non-detect.
1 Aroclor is a registered trademark of the Monsanto Chemical Company.
-------
As a result of previous investigations, the level of characterization of Site media attained to date
is significant. However, the following data issues were identified by the optimization review
team:
o Surface soils characterization data are based on composite samples taken from the top 18
inches of soil, an interval that is inconsistent with Region 3 procedures for risk
assessment.
o Polychlorinated dibenzodioxins (PCDD) and polychlorinated dibenzofurans (PCDFs) are
compounds that are released into the environment from several industrial processes
including combustion and metal processing (EPA, 2012). PCDDs and PCDFs were
detected at relatively low levels (less than 0.664 ppb, screening level for industrial or
commercial property, www.epa.gov/superfund/health/contaminants/dioxin/
dioxinsoil.html) in soil samples collected in three areas where combustion-based
processing of decommissioned electrical transformers occurred. The available data,
however, are insufficient for determining overall concentration levels and extent of these
constituents.
o With few exceptions, sampling of Site media has been limited to PCBs and seven metals
(arsenic, cadmium, total chromium, lead, mercury, nickel and silver). To ensure that the
list of Site constituents is complete, selected environmental samples from the Site areas
with elevated concentrations for the existing constituent list should be analyzed for a
more comprehensive constituent list.
A total maximum daily load (TMDL) for PCBs is in development by the Virginia Department of
Environmental Quality (VDEQ) for the Elizabeth River Watershed and is scheduled to be issued
in 2014. A TMDL is the maximum amount of a pollutant that a water body can receive and still
meet water quality standards. The Elizabeth River PCB TMDL could potentially be identified as
a future applicable or relevant and appropriate requirement (ARAR) for the Site.
Summary of Recommendations
The HGL Plan describes an extremely thorough and well-reasoned approach for closing data gaps
identified in the Site CSM. This optimization review team, however, identified some potential
opportunities for expediting the RI while maximizing its effectiveness. The following recommendations
are offered:
Access to the Site should be limited to authorized individuals and entities only. Any currently
existing unauthorized use of Site buildings or grounds should be evaluated and potentially
terminated.
In recognition of the hazards posed by MEC/MD, a trained unexploded ordinance (UXO)
technician should be present during drilling operations. A protocol should be developed by UXO
technicians for conducting down-hole magnetometer screening incrementally during borehole
advancement through the fill layer.
The RI should be structured so that data collection for each environmental media follows an
adaptive sampling strategy. Low cost, rapid turnaround field analyses can be more fully
employed in the RI to identify priority sampling locations for fixed-base laboratory analyses.
DMAs are recommended to be conducted for each of the selected field technologies planned for
use in the field investigation. Information on the design and performance of DMAs is provided in
www.brownfieldstsc.org/pdfs/Demonstrations of Methods Applicability.pdf (EPA. 2008). In
in
-------
addition, OSRTI is available upon request to provide technical assistance in the design and
implementation of a DMA for X-ray fluorescence (XRF) or any other real time, field screening
technology that Region 3 might consider for the PIM Site.
Prior to conducting extensive analyses for PCDD and PCDFs in Site soil, groundwater and
sediment samples, preliminary surface soil sampling for these constituents should be conducted in
the Site areas most likely to be contaminated with PCDD and PCDFs. It is recommended that the
sampling be performed early in the RI, possibly during the MEC/ MD avoidance and utility
clearance sampling task. Based on the results of this initial sampling, the extent and scale of
follow-up PCDD and PCDF characterization sampling can be defined. If elevated concentrations
are observed in the initial sampling, more extensive sampling for PCDD and PCDF constituents
is warranted. If concentrations are below applicable regional screening levels (RSLs), more
limited sampling for these constituents may be sufficient.
For the characterization of Paradise Creek sediments, a key task objective should be to directly
evaluate the Site's impact on the benthic environment in Paradise Creek. Consistent with this
objective, consideration should be given to performing benthic enumeration, sediment pore water
sampling and sediment sampling at selected locations adjacent to and up-stream from the Site.
As a recommended precursor activity to conducting benthic enumeration, pore water sampling
and sediment sampling, a groundwater discharge survey of the Paradise Creek channel offshore
from the Site should be performed. It is recommended that the aforementioned sediment
characterization activities include any identified zones of preferential groundwater discharge
identified by the survey.
For the characterization of surface soil, incremental composite sampling (ICS) methods can be
considered to provide better spatial coverage, help control matrix heterogeneity, lower analytical
costs and if acceptable to Region 3, meet risk assessment needs.
PCB congener (a PCB congener is any single, unique compound in the PCB category of
compounds; there are 209 unique PCB congeners [Narquis et al., 2007]) analyses can be
performed on a limited number of soil, on-Site sediment and groundwater samples for
comparison to PCB congener data from Paradise Creek sediments. The results of these analyses
will help to assess potential attribution of Site constituents to observed contamination in the creek
sediments. For general characterization and for the purpose of risk assessment, analysis of PCB
Aroclors is necessary to compare with RSLs.
A review of municipal and/or state-maintained well permit databases should be performed to
identify, to the extent possible, the extraction wells located in the vicinity of the Site. The results
of the permit database review may help to understand the cause of low groundwater levels
observed in a portion of the Site.
Selected soil, groundwater, surface water and sediment samples (onsite drainages and Paradise
Creek sediments) targeted for PCB congener analyses should use an analytical method (such as
EPA 1668A) with a method detection level sufficiently low to demonstrate compliance with the
PCB TMDL requirement currently in preparation by VDEQ.
IV
-------
NOTICE
Work described herein was performed by Tetra Tech EMI for the U.S. Environmental Protection Agency
(EPA). Work conducted by Tetra Tech EMI, including preparation of this report, was performed under
Work Assignment 2-58 of EPA contract EP-W-07-078. Mention of trade names or commercial products
does not constitute endorsement or recommendation for use.
-------
PREFACE
This report was prepared as part of a national strategy to expand Superfund optimization practices from
remedial investigation to site completion implemented by the United States Environmental Protection
Agency (EPA) Office of Superfund Remediation and Technology Innovation (OSRTI). The project
contacts are as follows:
Organization
Key Contact
Contact Information
EPA Office of Superfund
Remediation and Technology
Innovation
(OSRTI)
Stephen Dyment
EPA
Technology Innovation and Field Services
Division
1200 Pennsylvania Ave., NW (5203P)
Washington, DC 20460
dyment.stephen@epa.gov
Phone: 703-603-9903
Tetra Tech EM, Inc.
(Contractor to EPA)
Jody Edwards, P.G.
Tetra Tech EM Inc.
21 Juniper Ridge Road
Essex Junction, VT 05452
iody.edwards@tetratech.com
phone: 802-288-9485
Tetra Tech EM, Inc.
(Contractor to EPA)
Mark Shupe, P.G.
Tetra Tech EM Inc.
1881 Campus Commons Drive, Suite 200
Reston,VA20191
mark. shupe @tetratech. com
phone: 703-390-0653
VI
-------
LIST OF ACRONYMS
ATSDR
bgs
CIP
CLP
cm
coc
CSM
DAA
DMA
DO
DU
EOD
ERP
ESC
eV
FS
ft
GPS
HGL
HGLTW
HHRA
HRS
IA
1C
MCL
MD
MECmg/kg
MPI
msl
ng/kg
NOAA
NPL
ORP
OSRTI
OSWER
OTW
OU
P&T
PAH
Peck
PIM
PCBs
PCSM
PCDD
PCDF
PID
Agency for Toxic Substances and Disease Registry
below ground surface
Community Involvement Plan
Contract Laboratory Program
centimeter
contaminant of concern
conceptual site model
Draper Aden Associates
demonstration of method applicability
dissolved oxygen
decision unit
explosive ordnance disposal
Elizabeth River Project
Environmental Science Connector
electron-volt
feasibility study
foot
global positioning system
Hydrogeologic, Inc.
Hydrogeologic, Inc. Temporary Well
Human Health Risk Assessment
Hazard Ranking Score
immunoassay analyses
institutional controls
maximum contaminant level
munitions debris
munitions and explosives of concern milligrams per kilogram
Malcolm Pirnie, Inc.
mean sea level
nanogram per kilogram
National Oceanic and Atmospheric Administration
National Priorities List
oxidation-reduction potential
Office of Superfund Remediation and Technology Innovation
Office of Solid Waste and Emergency Response
Optimization Temporary Well
operable unit
pump and treat
polycyclic aromatic hydrocarbons
The Peck Company, Inc.
Peck Iron and Metal Superfund Site
polychlorinated biphenyls
preliminary conceptual site model
polychlorinated dibenzodioxins
polychlorinated dibenzofurans
photo ionization detector
vn
-------
ppb
QAPP
RA
RAC
RAP
RCRA
RI
RI/FS
RPM
ROD
RSLs
RSE
SOP
SPP
SPS-RDF
SQuiRTs
SVOC
TAL
TCE
TCL
TDS
TEL
TMDL
TOC
TPH
TSCA
TSS
USAGE
EPA
UST
UXO
VC
VDEQ
VDOT
VOC
VRP
XRF
parts per billion
quality assurance project plan
Remedial Action
Response Action Contract
Response action plan
Resource Conservation and Recovery Act
Remedial investigation
Remedial investigation/feasibility study
Remedial Project Manager
Record of Decision
Regional Screening Levels
Remediation System Evaluation
Standard operating procedure
Systematic project planning
Southeastern Public Service Authority's Refuse Derived Fuel
Screening Quick Reference Tables
semi-volatile organic compound
target analyte list
trichloroethene
Target compound list
Total dissolved solids
Threshold effects level
Total Maximum Daily Load
total organic carbon
total petroleum hydrocarbon
Toxic Substances Control Act
Total suspended solids
microgram per kilogram
microgram per liter
United States Army Corps of Engineers
United States Environmental Protection Agency
underground storage tank
unexploded ordnance
vinyl chloride
Virginia Department of Environmental Quality
Virginia Department of Transportation
volatile organic compound
VDEQ Voluntary Remediation Program
X-Ray Fluorescence
Vlll
-------
TABLE OF CONTENTS
EXECUTIVE SUMMARY i
NOTICE v
PREFACE vi
LIST OF ACRONYMS vii
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 3
1.3 DOCUMENTS REVIEWED 3
1.4 QUALITY ASSURANCE 4
1.5 PERSONS CONTACTED 4
2.0 SITE BACKGROUND 6
2.1 LOCATION 6
2.2 SITE HISTORY 7
2.2.1 HISTORIC LAND USE AND OPERATIONS 7
2.2.2 CHRONOLOGY OF ENFORCEMENT AND REMEDIAL ACTIVITIES 7
2.3 POTENTIAL HUMAN AND ECOLOGICAL RECEPTORS 8
2.4 EXISTING DATA AND INFORMATION 9
2.4.1 SOURCES OF CONTAMINATION 9
2.4.2 GEOLOGY SETTING AND HYDROGEOLOGY 10
2.4.3 MUNITIONS AND EXPLOSIVES 12
2.4.4 SOIL CONTAMINATION 12
2.4.5 SOIL VAPOR/INDOOR AIR CONTAMINATION 15
2.4.6 GROUNDWATER CONTAMINATION 15
2.4.7 SURFACE WATER CONTAMINATION 16
2.4.8 SEDIMENT CONTAMINATION 17
3.0 DESCRIPTION OF PLANNED OR EXISTING REMEDIES 19
4.0 CONCEPTUAL SITE MODEL 20
4.1 CSM OVERVIEW 20
4.2 DATA GAPS 20
4.2.1 GENERAL CHARACTERIZATION 21
4.2.2 ENVIRONMENTAL MEDIA 22
4.3 IMPLICATIONS FOR THE REMEDIAL INVESTIGATION 24
4.3.1 MEC/MD AVOIDANCE AND UTILITY CLEARANCE 24
4.3.2 SOIL INVESTIGATION 26
4.3.3 GROUNDWATER INVESTIGATION 30
4.3.4 SEDIMENT INVESTIGATION 33
4.3.5 SURFACE WATER INVESTIGATION 36
4.3.6 SEQUENCING OF FIELD ACTIVITIES 37
5.0 FINDINGS 39
6.0 RECOMMENDATIONS 41
-------
List of Tables
Table 1. Soil Sampling Analytical Parameters and Potential Screening Values
Table 2. Groundwater Sampling Analytical Parameters and Potential Screening Values
Table 3. Surface Water Sampling Analytical Parameters and Potential Screening Values
Table 4. Sediment Sampling Analytical Parameters and Potential Screening Values
Table 5. Summary of Optimization Recommendations for Each of the Field Sampling Tasks Presented in
the Hydrogeologic, Inc. (HGL) Work Plan (Plan)
List of Figures
Figure 1. Peck Iron and Metal Site Layout
Figure 2. 1937 to 2009 Impoundments and Drainages
Figure 3. Generic Pathway Receptor-Network Diagram for Human Health Risk Assessment
Figure 4. Schematic Representation of Potential Ecological Exposure Pathways for the PIM Site
Figure 5. Representative Hydrogeologic Cross-Section for the Atlantic Coastal Plain in Virginia
Figure 6. Geologic Cross Section
Figure 7. October 2008 Groundwater Potentiometric Surface
Figure 8. PCB Concentrations in Soils (0 to 18 inches bgs)
Figure 9. Arsenic Concentrations in Soils (0 to 18 inches bgs)
Figure 10. Cadmium Concentrations in Soils (0 to 18 inches bgs)
Figure 11. Chromium Concentrations in Soils (0 to 18 inches bgs)
Figure 12. Lead Concentrations in Soils (0 to 18 inches bgs)
Figure 13. Mercury Concentrations in Soils (0 to 18 inches bgs)
Figure 14. Nickel Concentrations in Soils (0 to 18 inches bgs)
Figure 15. Silver Concentrations in Soils (0 to 18 inches bgs)
Figure 16. Groundwater Contaminant Concentrations
Figure 17. PCB Homologue Detections in Paradise Creek Sediment Samples
Figure 18. Site Soil and Groundwater Sample Locations
Figure 19. Soil Investigation Decision Logic (Offsite Contamination and Hotspot Assessment)
Figure 20. Groundwater Investigation Decision Logic
Figure 21. Site Drainage and Wetland Sample Locations
Figure 22. Paradise Creek Sample Locations
Figure 23. Sediment Investigation Decision Logic (Western Drainage)
Appendix A: References
Attachments
A: Trip Log Memorandum for February 22, 2012 Site Visit
B: Photographic Log for February 22, 2012 Site Visit
-------
1.0 INTRODUCTION
1.1 PURPOSE
The Peck Iron and Metal (PIM) Superfund Site (the Site) is a 33-acre property located in Norfolk County,
Portsmouth, Virginia. PIM (Figure 1) is a former scrap metal storage and recycling facility that began
operation in the 1940s.
As a result of Site operations, elevated concentrations of lead, polychlorinated biphenyls (PCBs), arsenic
and other contaminants are present in Site environmental media, particularly soil. In accordance with a
January 11, 2007 U.S. Environmental Protection Agency (EPA), Region 3 (Region 3) Administrative
Order for Removal Response Action, the site owner conducted an investigation to determine the extent of
contamination. Based on a review of this and previous investigations, Hydrogeologic, Inc. (HGL), on
behalf of Region 3, prepared a Response Action Contract (RAC) Remedial Investigation (RI) Work Plan
(HGL Plan) to address identified data gaps in the existing Site characterization and to generate the data
necessary to support the assessment of remedial options
The purpose of this review is to evaluate Site conditions and identify optimal approaches for conducting
the planned RI of the PIM site. EPA's emphasis on the optimization of site investigation on this project is
based on the on-going program of evaluating operating remedies at Fund-lead sites. During fiscal years
2000 and 2001 independent Remediation System Evaluations (RSEs) were conducted at 20 operating
pump and treat (P&T) sites (i.e., those sites with P&T systems funded and managed under Superfund by
EPA, other federal agencies and by the States). Due to the opportunities for system optimization that
arose from those RSEs, the EPA Office of Superfund Remediation and Technology Innovation (OSRTI)
has incorporated RSEs into a larger post-construction complete strategy for Fund-lead remedies as
documented in the Office of Solid Waste and Emergency Response (OSWER) Directive No. 9283.1-25,
Action Plan for Ground Water Remedy Optimization. Concurrently, the EPA developed and applied the
Triad Approach to optimize site characterization strategies, methods and technologies, including the
increased use of conceptual site models (CSMs) as the basis for identifying project data gaps and using
those gaps to guide the development of site characterization objectives and work plans. The EPA has
since expanded the reach of optimization to encompass reviews at the investigation stage of projects (such
as for the PIM Site).
EPA OSWER and OSRTI define optimization as follows:
"Efforts at any phase of the removal or remedial response to identify and implement
actions that improve the action's effectiveness and cost-efficiency. Such actions may also
improve the remedy's protectiveness and long-term implementation which may facilitate
progress towards site completion. To identify these opportunities, regions may use a
systematic site review by a team of independent technical experts, apply techniques or
principles from Green Remediation or Triad, or apply some other approach to identify
opportunities for greater efficiency and effectiveness. Contractors, states, tribes, the
public andPRPs are also encouraged to put forth opportunities for the Agency to
consider. "
-------
Optimization reviews include a "systematic site review," whereby the site as a whole is often considered.
However, optimization can focus on a specific aspect of a given cleanup phase (or a particular operable
unit [OU]), with other phases and site areas considered to the degree that they affect the focus of the
optimization effort. For optimization reviews conducted before a Record of Decision (ROD) is issued, the
focus is on developing the CSM by leveraging existing data and exploring potentially applicable sampling
and analysis tools and strategies that facilitate a comprehensive systematic planning process.
A strong interest in green remediation and sustainability has also developed in the private sector and
within Federal, State and Municipal governments. Consistent with this interest, OSRTI has developed a
methodology for environmental footprint evaluation (www.cluin.org/greenremediation/methodology/
index.cfm) and now routinely considers environmental footprint reduction during optimization reviews.
For a site in the investigation stage, the optimization review process includes reviewing site documents,
potentially visiting the site for one day and compiling a report that includes recommendations for design
and execution of a comprehensive, efficient and cost-effective investigation strategy.
The recommendations in this report are intended to help the site team identify opportunities for an
optimized RI approach. Where noted in this report, further analysis of a recommendation may be needed
before the recommendation can be implemented. The recommendations are based on an independent
evaluation and represent the opinions of the optimization review team. These recommendations do not
constitute requirements for future action, but rather are provided for consideration by the Region and
other site stakeholders. While the recommendations may provide some details to consider during
implementation, the recommendations are not meant to replace other, more comprehensive, planning
documents such as work plans, sampling plans and quality assurance project plans (QAPP).
The national optimization strategy includes a system for tracking consideration and implementation of
optimization recommendations and includes a provision for follow-up technical assistance from the
optimization team as mutually agreed on by the site management team and EPA OSRTI.
The optimization review and site technical teams participated in a site visit and early systematic project
planning (SPP) on February 22, 2012. This optimization review report provides findings and
recommendations resulting from review of site documentation and data in conjunction with the site visit
and SPP efforts. Suggestions provided for sample quantities, collection/analytical methods, locations and
other parameters may be adjusted to meet project-specific schedule, budget and logistical considerations.
This document reviews the PIM Site CSM and identifies data gaps in the existing Site characterization as
a means to focus and streamline the sequence of RI activities. It is recognized that sampling for multiple
parameters will be necessary to assess total risk and that sampling to assess exposure routes and areas for
human and ecological risk assessment are integral components of any RI. Where appropriate and timely,
suggestions include these considerations, however, it is expected that this report will form the basis for
additional SPP efforts among the optimization review team, project technical team and stakeholders to
develop, review and finalize RI specific QAPP and implementation documents.
-------
1.2 TEAM COMPOSITION
The optimization review team consisted of the following individuals:
Name
Steve Dyment
Mark Shupe, PG
Affiliation
EPA OSRTI
Tetra Tech EMI
Phone
703-603-9903
703-390-0653
Email
dyment . stephen@epa. gov
mark . shupe @tetratech . com
1.3 DOCUMENTS REVIEWED
The key documents that provided significant basis for the formulation of the preliminary conceptual site
model (CSM) components included:
Letter Report to Mr. B. Webber (Chesterfield Auto Parts) and B. D. Peck (Peck Co.) from
Messrs. T.A. LaMaskin andR.F. Hatcher, Hatcher-Sayre, Inc., Subject: Site Investigation
Results, The Peck Company, Portsmouth, VA, (Hatcher-Sayre, Inc., 1999). This report
documents the results of a field investigation conducted during 1999, the year that the facility
ceased operations. The investigation included the sampling of surface soil, subsurface soil and
groundwater. Surface soil samples were collected on a 250 x 250 foot (ft) grid. Subsurface soils
were collected in the interval just above the observed depth of the water table.
Letter report to J. Bernard /Virginia Department of Environmental Quality (VDEQ)l from S.
Werner [Draper Aden Associates (DAA)], Subject: Site Characterization Report, Proposed
Pull-A-Part Site, 3500 and 3850 Elm Ave., Portsmouth, VA, (Draper Aden Associates, 2003a).
In this site characterization report, DAA discussed the collection of additional groundwater
data; presented the existing environmental data collected at the site, including the 1999 Hatcher-
Sayre (Hatcher-Sayre, Inc., 1999) investigation results; presented re-use plans for the Site as a
self-service auto parts salvage yard; performed a human health risk assessment based on the
available data; and proposed remedial design consisting of soil capping and deed restrictions.
Based on results obtained using VDEQ's Risk Exposure Analysis Modeling System, DAA
determined that remedial measures to address arsenic and lead contamination in soil would be
necessary to support future development of the Site. DAA observed that Site constituent
concentrations (metals and PCBs) are not elevated in Site monitoring wells and that public
water supply in the area is provided by the City of Portsmouth. Since groundwater is not
consumed in the area and human contact with Site groundwater is unlikely, DAA concluded
that human health risk associated with the Site groundwater was not a concern.
Letter report to J. Bernard (VDEQ) from S. Werner (DAA), Subject: Site Characterization
Addendum, Peck Recycling/Pull-A-P'art, Inc., 3850 Elm Ave., Portsmouth, VA. (Draper Aden
Associates, 2003b). In response to the VDEQ's and the EPA's comments on the site
characterization report, DAA conducted additional investigations to better characterize lead and
PCBs in soil, screen soil for dioxin compounds and sample sediments from the two western
drainage ways and the discharge points of these drainage ways to Paradise Creek. Soil sampling
was conducted by random selection of sampling locations from a 150 by 150ft grid covering
the Site. Soil and sediment samples were collected at depths ranging from the ground surface to
a depth of 2 ft below ground surface (bgs).
Sheet A-1: PCB Soil Sampling Results, February-May 2005, 50 x 50 ft Grid, 0-18-inch Depth,
Pull-A-P art, Inc. VRP Site, Elm Ave., Portsmouth, VA (Stand-alone map ofPCB concentrations
-------
for 0-18 inch depth; a second stand-alone map [Sheet BJpresented PCB concentrations
distributed over the same grid for the 18-36-inch depth). (Draper Aden Associates, 2005). DAA
conducted additional sampling for PCBs in early 2005. Samples were collected from selected
locations based on a 50 x 50 ft sampling grid covering the site. Samples from both the surface
(0-18 inch bgs depth interval) and subsurface (18-36 inch bgs depth interval) were collected.
Concentrations ofPolychlorinatedBiphenyls (PCB) and Polycyclic Aromatic Hydrocarbons
(PAH) in Sediment Samples from Paradise Creek, a Tributary to the Elizabeth River in
Virginia, January 2005, (Unger, M.A., Vadas, G.G., Harvey, E. and Reiger, J., 2005). In 2005,
sediment sampling of Paradise Creek in the area adjacent to the Site was conducted. A total of
19 surface sediment samples and one core sample (divided into three depths) were collected
from the creek.
Draft Extent of Contamination Study Report, Peck Iron Metal Site, 3850 Elm Avenue,
Portsmouth VA, 23704. October 24, 2008. (Malcolm Pirnie, Inc., 2008). On behalf of the Peck
Company, Malcolm Pirnie, Inc. (MPI) prepared this report in accordance with a 2007 EPA
Administrative Order for Removal Response Action for The Peck Company, Inc. The report
documented soil, sediment and groundwater sampling conducted to address data gaps identified
in the available characterization data.
Site Management Plan, Remedial Investigation/Feasibility Study, Peck Iron and Metal,
Portsmouth, Norfolk County, Virginia, December 2011, (Hydrogeologic, Inc., 2011). HGL
prepared this Remedial Investigation/Feasibility Study (RI/FS) work plan as a task under the
EPA Region 3 RAC. The objectives of the RI were to refine the CSM, address identified data
gaps, define the nature and extent of contamination at the Site and assess the potential risk to
human health and ecological receptors from identified site contaminants.
1.4 QUALITY ASSURANCE
This optimization review utilizes existing environmental data to interpret the CSM, evaluate principle
study questions, identify data gaps and support SPP efforts to make recommendations for streamlined
sequencing, sampling and analytical strategies. The quality of the existing data was evaluated by the
optimization review team prior to using the data for these purposes. The evaluation for data quality
includes a brief review of how the data were collected and managed, the consistency of the data with
other site data and the use of the data in the optimization review. Data that are of suspect quality were
either not used as part of the optimization review or are used with the quality concerns noted. Where
appropriate, this report provides recommendations made to improve data quality.
1.5 PERSONS CONTACTED
A kickoff meeting with stakeholders was held on February 22, 2012, at the U.S. Army Corps of Engineers
(USAGE) field office at the former Atlantic Wood Treating Superfund Site (Atlantic Wood) located
adjacent to the Site. In addition to the optimization review team, the following persons were present for
the stakeholders meeting, including members of the project technical team:
Name
Debra Rossi
Bill Hagel
Bruce Pluta
Affiliation
Region 3
Region 3
Region 3
Telephone
215-814-3228
215-814-2380
215-814-2380
-------
Name
Jeff Turtle
Ryan Bower
Stephen Dyment
Durwood Willis
Kevin Green
Kyle Newman
Michelle Hollis
Brett Brodersen
Mark Shupe
Affiliation
Region 3
Region 3
OSRTI
VDEQ
VDEQ
VDEQ
VDEQ
HGL
Tetra Tech
Telephone
215-814-3236
215-814-3389
703-402-1857
804-698-4192
804-698-4236
804-698-4452
804-698-4014
703-736-4526
703-390-0653
Following the kickoff meeting, the team toured the Site. Tetra Tech, Inc. (Tetra Tech) prepared atrip log
memorandum and photographic log of the site walk. Both were posted to the EPA Environmental Science
Connector (ESC) web site (https://ssoprod.epa.gov/sso/isp/oblogin.jsp). Note that access to the ESC
requires EPA authorization. For access support, contact Stephen Dyment. The trip log memorandum is
included as Attachment A to this report; a photo log from the site visit (photos by Stephen Dyment) is
provided as Attachment B.
-------
2.0 SITE BACKGROUND
2.1 LOCATION
The PIM Superfund Site (the Site) is a 3 3-acre property located in Norfolk County, Portsmouth, Virginia.
PIM (Figure 1) is the site of a former scrap metal storage and recycling facility that began operation in the
1940s. As a result of Site operations, elevated concentrations of lead, PCBs, arsenic and other
contaminants are present in site environmental media, particularly soil.
The Site is bordered by Paradise Creek to the south, Elm Avenue to the north and east and Victory
Boulevard to the east. An ARREFF Terminals, Inc. facility, a trans loading and bagging facility
specializing in agricultural commodities, borders to the north. The Southeastern Public Service
Authority's Refuse Derived Fuel (SPS-RDF) facility borders the Site to the southeast and the Norfolk
Naval Shipyard partially borders the Site to the west, southeast and northeast. The Atlantic Wood
Preserves Superfund Site is also located east of the Site, across Victory Boulevard. A Sherwin-Williams
paint facility is located to the west of the Site. Paradise Creek is a tributary of the Southern Branch of the
Elizabeth River. In 2003, a 6-acre parcel of the Site bordering Paradise Creek was donated to the
Elizabeth River Project (ERP) for permanent conservation as a wetland buffer (HGL 2011). In the spring
of 2003, ERP completed a wetland restoration of this 6-acre area. Currently, only a small segment of the
Site borders Paradise Creek.
General Site conditions were assessed during the February 22, 2012 site visit. The primary site structures
observed included cinderblock and brick slab-on-grade buildings located in the northwestern portion and
eastern portion of the Site. The buildings present in the eastern portion of the Site include a former
maintenance building, former locker/change room facility and former office; all of which appeared
abandoned and unused at the time of the site visit. In addition, the former maintenance building was
flooded by several inches of water. Although the buildings in the northwestern portion of the Site are in a
dilapidated state, they are subject to ad hoc usage by various unidentified parties. Such uses include but
are not limited to: antique vehicle storage, hydraulic equipment and vehicle servicing and storage of
miscellaneous materials including children's bicycles, material storage drums and various equipment.
A construction contractor is currently using a portion of the property adjacent to the buildings located in
the northwestern portion of the Site as a lay down yard and for material and heavy equipment staging.
Also present in this area are numerous abandoned roll off containers, shipping containers and construction
vehicles and equipment. During the site visit, several apparent employees of the contractor were
performing tasks in an outdoor work area located adjacent to the buildings in the northwestern portion of
the Site.
Miscellaneous surficial debris is present on the surface of much of the Site. The debris typically consists
of brick, glass, wood, broken asphalt and concrete and scrap metal. The majority of the Site is unpaved.
Shallow standing water was present in intermittent puddles throughout much of the Site, particularly in
areas south of the contractor occupied portion of the Site. The standing water was presumed to be the
result of a winter storm that moved through the area three days prior to the site visit. During the site visit,
however, a number of areas with phragmites (perennial grasses found in wetlands) vegetation were
identified on the east and west portions of the Site indicating more consistently wet conditions,
particularly along drainages in these areas (Figure 2).
-------
2.2 SITE HISTORY
This section discusses historic land use and former operations conducted at the Site. In addition, the
enforcement actions and the chronology of remedial activities are described. This section is based
primarily on the information provided in the RI/FS Site Management Report (HGL, 2011).
2.2.1 HISTORIC LAND USE AND OPERATIONS
PIM operated as a scrap metal processing facility from approximately 1945 to 1999. Operations at the
Site included metals processing, storage and shipping. Sources of metals handled at the Site included
local businesses, the federal government and the state of Virginia. Scrap metal reportedly came from old
equipment and parts, naval vessels, military bases and PCB-containing transformers (HGL, 2011).
Prior to 1980, operational activities took place primarily in buildings located in the central portion of the
Site. Uses of these buildings were as a locker room building, a machine shop building, a metal storage
and sorting building that contained a small aluminum scrap metal furnace and a building that contained a
hydraulic guillotine for shearing steel (HGL, 2011).
An analysis of historic aerial photographs of the Site was conducted by the EPA (HGL, 2011), from
which it was inferred that solid waste management and scrap metal storage at the Site started in the
northeastern portion of the Site in 1937. Until 1990, these activities were conducted over the entire Site.
Two former surface water impoundments and associated drainage ditches were also identified on aerial
photographs (Figure 2). By the late 1990's, solid waste management activities were limited to the
southwestern and west-central portions of the Site.
Aerial photographs also showed locations of brick fill areas, a burn pit, debris and ground scarring dating
back to 1937. The majority of ground scarring and presence of debris was observed in the years 1998 and
2009. Potential release areas onsite were also identified from aerial photographs. The potential release
areas are numerous and widely distributed across the central, south-central and eastern portions of the Site
and generally correspond with the fill/ground scar areas. The potential release areas include drum storage
areas, staining and possible underground storage tank (UST) areas, mostly observed in the years 1998 and
2009 (HGL, 2011). These areas were primarily located in the central, south-central and eastern portions of
the Site. In addition, a potential release area, identified by EPA as an area with soil staining, is located
along the northwestern boundary of the Site, west of the block of masonry buildings and near the front
gate.
The Site is currently owned by The Peck Company, Inc. (Peck). The adjacent property, upon which the
Sherwin-Williams facility is currently located, was historically a part of the Site (EPA Hazardous
Ranking Score [HRS], 2009). The year in which the property was transferred from Peck to Sherwin-
Williams is not documented in the Site information reviewed.
2.2.2 CHRONOLOGY OF ENFORCEMENT AND REMEDIAL ACTIVITIES
Enforcement and remedial actions at the Site were initiated in approximately 2003 and are ongoing. To
facilitate redevelopment plans for the Site, Peck entered the Site in the VDEQ Voluntary Remediation
Program (VRP) in 2003. In August 2003, Peck and a prospective buyer of the property (Pull-A-Part, Inc.)
submitted an initial remedial design based on data generated during the 1999 Hatcher-Sayre investigation
(DAA, 2003a). In response to VDEQ requests for additional data, Peck performed several field
investigations under the supervision of VDEQ and EPA (DAA, 2003b and DAA, 2005). The
investigations included soil sampling to improve the delineation of PCB contamination.
-------
In January 2004, VDEQ received written guidance from the EPA that the Toxic Substance Control Act
(TSCA) is the regulatory authority regarding PCBs. The EPA instructed Peck in April 2004 to prepare a
Self-Implementing PCB Cleanup Plan to the EPA Region 3 Regional Administrator. EPA reviewed the
plan in November 2004 and requested the collection of an additional 2,500 samples for the analysis of
PCBs and dioxin. This sampling was not performed. As an alternative, a revised soil characterization
sampling grid (50 ft by 50 ft) was established for the Site. In January 2005, the EPA approved the revised
Self-Implementing PCB Cleanup Plan upon the condition that the sampling results based on the new grid
be submitted to the EPA for review and approval prior to the initiation of any remediation activities.
In 2007, the EPA implemented an Administrative Order for Removal Response Action (AO) requiring
Peck to complete a response action plan (RAP) for the delineation of extent of contamination at the Site.
The objective of the RAP was to characterize the distribution of Site concentrations of arsenic, cadmium,
chromium, lead, mercury, nickel, silver and PCBs. The results of the RAP field investigation are
presented in the Extent of Contamination Report (MPI, 2008). The EPA added the Site to the National
Priorities List (NPL) in November 4, 2009. In May 2010, both the EPA and the Agency for Toxic
Substances and Disease Registry (ATSDR) conducted interviews with local residents to gain their input
on the development of a Community Involvement Plan (CIP). The EPA initiated a Fund-lead RI/FS at the
Site in September 2011.
2.3 POTENTIAL HUMAN AND ECOLOGICAL RECEPTORS
Previous Site investigations indicate that, compared to the EPA Regional Screening Levels (RSLs) for
industrial soil, Site soils exhibit elevated concentrations of PCBs and metals, including arsenic, cadmium,
total chromium, lead, mercury and nickel. Sediments contain elevated concentrations of these same
constituents relative to National Oceanic and Atmospheric Administration (NOAA) Screening Quick
Reference Tables (SQuiRTs) threshold effects levels (TELs) for sediment. PCBs and metals (arsenic, total
chromium, nickel, lead and mercury) were detected in Site groundwater. Constituents exceeding criteria
included arsenic and nickel (tap water RSL), lead (EPA lead action level and mercury (maximum
contaminant level [MCL]). With the exception of Paradise Creek surface water sampling conducted by
CH2M Hill (CH2M Hill, 2001) on behalf of the Navy, previous Site investigations have not included the
characterization of Site surface water. Data from the CH2M Hill sampling event were unavailable for this
optimization review. Site sediments are presumed to contain detectable concentrations of PCBs and
metals through storm water erosion and surface water transport of contaminated fine-grained soils. Based
on the results of the optimization review, concentration data from Site surface water and sediment
analyses have not historically been compared to EPA Region 3 Biological Technical Assistance Group
(BTAG) ecological screening levels. The concentration data for Site media are summarized in the
Sections 2.4.3 through 2.4.8.
The RI will evaluate human health and ecological risks associated with these media. Generic pathway-
receptor network diagrams for human health and ecological risk are shown in Figures 3 and 4,
respectively. The primary media and associated potential receptors at the Site include:
Groundwater: Human health risk is likely low because groundwater is not used as a source of
drinking water supply and existing data suggest that groundwater is relatively unimpacted by Site
operations. An ecological risk, however, may exist to indigenous fauna as a result of the
contamination of surface water and sediments from the discharge of potentially contaminated
groundwater.
Soil: Human health risk likely exists due to potential ingestion, inhalation and dermal adsorption
through direct contact of contaminated soil by site workers, construction workers and trespassers.
-------
Ecological risks that are likely posed by the soil include foraging animal direct contact of soil and
food chain exposure and plant uptake.
Surface water: Human health risk may exist due to potential dermal adsorption through direct
contact and ingestion through consumption of contaminated fish and/or waterfowl. Ecological
risks posed by surface water include direct exposure / contact and food chain exposure.
Sediment: Human health risk exists due to potential dermal adsorption through direct
contact/ingestion through consumption of contaminated finfish and shellfish. Ecological risks
posed by sediment include direct exposure / contact, food chain exposure and ingestion by
indigenous fauna.
On behalf of Peck, DAA (DAA, 2003a) completed a human health risk assessment (HHRA) based on the
results of the 1999 Site investigation conducted by Hatcher-Sayre (Hatcher-Sayre 1999). DAA used the
Risk Analysis module of the Risk Exposure Analysis Modeling System (REAMS) developed by VDEQ.
The HHRA examined residential and industrial exposure risks associated with the minimum and
maximum concentration of each inorganic constituent. DAA determined that the exposure risk for each of
the scenarios exceeded the target allowable risk level of 1 x 10~6 for one carcinogen (arsenic) and one
non-carcinogen (lead). In addition, DAA determined that the total hazard indices for the remaining
constituents (all considered non-carcinogenic) were greater for each scenario than the target level of 1.0.
Based on the results of the risk assessment, DAA concluded that arsenic and lead are the primary
constituents of concern and will require further consideration for the development of the Site. Although
considered, PCBs were not identified as primary constituents driving site risk.
2.4 EXISTING DATA AND INFORMATION
The information provided in this section is summarized from existing site documents reviewed as part of
the optimization review effort. Interpretations included in this section are generally taken from the
documents from which the relevant information was obtained. Particular attention was paid to CSM
elements and conclusions that may warrant consideration during the RI/ FS.
2.4.1 SOURCES OF CONTAMINATION
Sources of contamination at the Site are attributable to various operations associated with scrap metal
salvaging, processing and storage. As reported by HGL (2011), EPA conducted a study of historical aerial
photographs to identify potential Site constituent release areas. As a result of this study, EPA delineated
historic drum storage, ground stained (classified as light, medium and dark toned) and possible
underground storage areas. Potential contamination release areas were identified in the central, south-
central, eastern and northwestern portions of the Site.
In discussions with EPA and VDEQ, Mr. R.D. Peck, a former principal of Peck Co., stated that PCB-
containing transformers were disassembled and their wiring burned at the Site as a method for removing
the wiring insulation and recovering the copper wire. Although PCB contamination in Site soil exists over
broad areas, the specific location(s) of transformer processing operations is unknown. In 2003 discussions
between the EPA and Mr. David B. Peck (owner of Peck), Mr. Peck indicated that any burning conducted
at the facility was performed at the rear of the property, not in the front where scrap metals operations
were ongoing on a daily basis (DAA, 2003b). Available literature (EPA, 2012) also indicates that
industrial combustion activities can potentially create dioxin or furan compounds.
-------
Potential offsite sources of contamination to groundwater, surface water and sediment include each of the
properties (Norfolk Naval Shipyard, Sherwin-Williams, ARREFF Terminals and the SPS-RDF facility)
that border the Site. The Norfolk Naval Shipyard borders to the west, the Sherwin Williams facility
borders to the north and west, the ARREFF facility borders to the north and the SPS-RDF facility borders
to the east of the Site. Monitoring wells are sparsely distributed at the Site, resulting in a relatively poor
understanding of hydrogeologic conditions that influence groundwater flow direction. Based on the
available groundwater elevation data (discussed further in Section 4.2.1), portions of the Sherwin-
Williams, ARREFF and SPS-RDF facilities are potentially located hydraulically up gradient from
portions of the Site. For example, based on measured groundwater levels (as opposed to a specific contour
interpretation), the Sherwin Williams property is located up gradient of the block of buildings and front
gate area in the northwestern portion of the Site. The RDF and ARREFF sites are located up gradient of
the east-northeastern portions of the Site. The four adjacent properties are all situated at a higher
topographic elevation relative to the Site. Surface water features were also identified at each location
during the site visit including a 10-inch pipe extending from the Sherwin Williams facility that appears to
introduce surface or facility run-off to the PIM property and a concrete lined vault/channel extending
along the property boundaries of the PIM Site and the ARREFF facility.
2.4.2 GEOLOGY SETTING AND HYDROGEOLOGY
The Site is located on relatively low-lying land adjacent to Paradise Creek, a tributary of the Southern
Branch of the Elizabeth River. Topographic elevations range from sea level along the Site's southern
boundary to approximately 10 ft above mean sea level (msl) near the northern Site boundary. A northeast
to southwest-trending, approximately 25-ft-high berm is located along the southeastern Site boundary.
The Site is situated on the Atlantic Coastal Plain physiographic province and is underlain by
unconsolidated formations. Figure 5 shows a representative cross section for the Atlantic Coastal Plain in
Virginia. Beginning at ground surface, the uppermost of these units consists of interbedded sand, silt and
clay units of Holocene and Pleistocene age. Tertiary formations, consisting predominantly of interlayered
sands and clays, underlie these deposits and are, in turn, underlain by the Cretaceous-age Potomac Group.
The Potomac Group, comprised primarily of thick, interbedded clay, silt, sand and gravel units, overlies
the basement rock complex, which consists of massive igneous and highly deformed metamorphic rocks
of Precambrian and Lower Paleozoic age. The aggregate thickness of the unconsolidated formations in
the general area is approximately 2,500 ft (Meng and Harsh, 1988).
The Columbia aquifer is the uppermost water bearing zone in the Site vicinity. The Columbia outcrops at
land surface and occurs within the Holocene and Pleistocene deposits. The aquifer is underlain by the
Yorktown confining unit. Based on hydrogeologic unit correlations provided in Meng and Harsh (1988),
the top of the Yorktown confining unit in the Portsmouth, Virginia vicinity is encountered at depths
ranging from 25 to 44 ft bgs. The Yorktown-Eastover aquifer underlies the Yorktown confining unit
(Meng and Harsh, 1988). At the Atlantic Wood Treating Site, adjacent to the eastern boundary of the Site,
the Yorktown confining unit ranges up to 44 ft in thickness (HGL, 2011).
Figure 6 shows a geologic cross section oriented from the southwest to northeast across the Site. As stated
by HGL (2011) lithologic characterization conducted previously at the PIM site is limited to a depth of 15
to 20 ft bgs. The following description of the Site geology is summarized from MPI (2008). Lithologic
conditions are highly variable across the site. The Site is underlain by fill ranging in thickness from 1.5 ft
of sandy-clay fill in the northwestern portion of the Site to 12 ft in the central portion of the Site. As is
generally true of the eastern and southern portions of the Site, the fill in this area consists of varying
proportions of building demolition rubble, miscellaneous debris and scrap metal. In the northwestern
portion of the Site and southward toward Paradise Creek, the fill layer is underlain by stiff clay to soft
sandy clay. In the west-central and central portion of the Site, the fill is underlain by fine to medium
10
-------
grained sand that becomes slightly clayey toward the east. In the eastern portion of the Site, fill is
underlain by clay grading downward to interbedded clay and sand. In the north-eastern Site area, fill is
underlain by clayey sand overlying clay.
Figure 7 shows the water table elevation at the Site based on groundwater level data collected on July 24,
2008 (MPI, 2008). The water table ranged in elevation from -5.37 ft msl to 7.46 ft msl. To avoid an
unaccounted for tidal influence in the measured groundwater levels, the data shown on Figure 7 were
collected synchronously and thus are consistent with the ambient tidal level (MPI, 2008). The highest
groundwater elevation was measured in monitoring well MW-4, located in the central portion of the Site
where an apparent groundwater mound is present. From the apparent groundwater mound area, flow is
generally southwestward toward Paradise Creek or northeastward toward the intersection of Elm Avenue
and Williams Avenue. City utility maps indicate the presence of a storm drainage ditch paralleling Elm
Avenue along the northern Site boundary and northern boundary of the ARREFF property. Near the
northeastern corner of the Site, at the intersection of Elm and Williams Avenues, the ditch discharges to a
southward flowing drainage pipe that parallels the eastern boundary of the Site. Drainage to the ditch and
drain pipe may act to passively lower water levels in the eastern portion of the Site. Passive drainage
alone, however, would only account for the lowering of groundwater to levels slightly greater than msl
datum. The below sea level datum water levels consistently observed in MW-6 (-5.37 ft), if accurate2,
suggest off-site influences on groundwater, such as pumping.
For the surficial unconsolidated deposits, MPI derived an average hydraulic conductivity of 0.9 ft/day
based on slug tests conducted in the Site monitoring wells. Given an assumed porosity for fine-medium
sand of 20 percent and a hydraulic gradient of 0.012 ft/ft (measured from the October 2008 potentiometric
surface map from MPI [2008]), the average linear groundwater flow velocity is approximately 20 ft/year
toward the southwest. The above velocity calculation is representative of native shallow formation
material; given that the observed fill includes zones containing large fragments of rubble and debris, the
groundwater flow velocity may be higher in some areas where coarse fill is saturated.
Based on a comparison of the Site's typical topographic elevation with the October 2008 potentiometric
surface map (MPI, 2008), the depth to the water table ranges from approximately 2 to 3 ft bgs in the west
central portion of the site to 5 ft bgs in the east central portion of the Site and declines to 0 ft bgs along the
Paradise Creek shoreline. During the February 22, 2012 site visit, saturated ground and frequent surface
water puddles were observed throughout the western-central, central and eastern portions of the Site. The
ponded surface water likely reflected the effects of a winter storm that had passed through the area three
days prior to the field visit and likely represented locally perched water conditions. The presence of
phragmites in the western drainage and in the swale at the toe of the berm separating the Site from the
SPS-RDF facility suggests the prolonged recurring presence of surface water or persistent shallow
groundwater conditions in these areas, unrelated to storm events.
Figure 2 shows the locations of existing and former drainage features at the Site. As reported by HGL
(2011) the EPA's review of historical aerial photographs revealed the presence of two former surface
water impoundments. One surface water impoundment was located in the central portion of the Site and
appears to have been active from 1937 to 1963. A drainage channel leading to this impoundment
potentially received water from an on-site clarifier located immediately south of the Sherwin-Williams
property. The second impoundment was located in the central portion of the Site and extended from the
northern property boundary to the southern property boundary. This impoundment was active primarily
between 1947 and 1963, with small surface water ponds present within or near the impoundment footprint
A surveyed reference point elevation could not be identified in the available documents for MW-06 thus
preventing independent verification of the reported groundwater elevation in this well.
11
-------
in 1998. Linear drainage patterns from the ARREFF property abutting the Site were observed in 1980 and
in 1998. Based on these patterns, surface drainage flowed to two surface water impoundments and then
ultimately to Paradise Creek.
HGL (2011) identified two main surface water drainage channels at the Site. The western drainage is
approximately 600 ft in length and extends along the western Site boundary from the Sherwin Williams
property south through the ERP wetland area at the southwest corner of the Site to Paradise Creek. It
receives drainage from the western portion of the Site and the Sherwin Williams facility. The northern,
approximately 150 ft of the western drainage, consists of a shallow, open ditch. Along the remaining
portion of the western drainage, the ditch is lined with an approximately 24-inch diameter terra cotta
surface drainage pipe. During the Site visit, the northern portion of the pipe appeared discontinuous and
broken in many places and contained several junction boxes. The southern portion appeared to be in
better condition and to terminate at Paradise Creek.
The second channel is an approximately 3 to 4 ft wide concrete trough that appears to originate at the
northern boundary of the Site and continue northward, first on the ARREFF property then on the Site,
parallel to the boundary between the northwestern portion of the Site and the ARREFF property. At the
time of the site visit, the western drainage ditch appeared to be partially filled with water to within
approximately 1 to 2 ft of ground surface. The water was turbid and appeared to flowing northward
toward Elm Avenue.
Paradise Creek in the Site vicinity is tidally influenced. NOAA maintains a water level gauging station at
Money Point, located on the Southern Branch of the Elizabeth River, approximately 2 miles south of the
Site. Surface water levels at Money Point typically vary by approximately 3 ft over a typical tidal cycle.
2.4.3 MUNITIONS AND EXPLOSIVES
During the 2008 MPI investigation, unexploded ordnance (UXO) was discovered during the collection of
soil samples. Following UXO discovery, an MPI UXO specialist surveyed all new intrusive sampling
locations for UXO and was present onsite on each day that soil sampling and soil boring construction for
monitoring well installation activities were conducted. All munitions and explosives of concern and
munitions debris (MEC/MD) were logged and photographed. The types of MEC/MD discovered included
a 3-inch naval round fused, inert/training 0.50 caliber bullets, a machine gun and shell casings. Upon
discovery, all MEC/MD were removed by local Navy explosive ordnance disposal (EOD) technicians for
appropriate disposal.
2.4.4 SOIL CONTAMINATION
Extensive PCB (DAA, 2005 and MPI, 2008) and metals (MPI, 2008) characterization sampling of soils
has been conducted at the Site. The sampling performed has been for PCB Aroclors and for a limited list
of metals (arsenic, cadmium, total chromium, lead, mercury, nickel and silver). Based on a 50 by 50 ft
sampling grid covering the Site, DAA sampled 524 sample grids for PCB Aroclor analyses. Prior to
performing the extent of contamination field investigation, MPI subjected the DAA sampling results to
independent data validation in accordance with EPA Region III Modifications to the Laboratory Data
Validation Functional Guidelines for Inorganics and the EPA Region III Modifications to the National
functional Guidelines for Organic Data Review. A minimum of Level II data quality and the correct
analytical method were required for existing data to pass validation. For the extent of contamination
investigation, MPI collected an additional 569 soil samples for PCB Aroclor and metals analyses and
validated these data to the same standards noted above for the DAA data.
12
-------
Environmental investigations conducted at the Site identified PCBs and metals contamination in surface
and subsurface soils at the Site. For the DAA and MPI Site investigations, surface soil was defined as soil
from a depth of 0 to 18 inches bgs. Subsurface soil was defined as soil from a depth of 18 inches bgs to
the water table. Surface soil characterization results for Site contaminants of concern (COCs) from the
DAA and MPI investigations are discussed below. Screening levels for soil are shown in Table 1.
Although some correlation exists between elevated lead and elevated PCBs in Site soils, inspection of
Site metal and PCB concentration trends do not suggest a specific source of the metals and PCB
contamination. In addition, no direct link of metals and PCB concentrations above screening criteria was
observed to former USTs, tank fields, solid waste disposal areas, surface water impoundments, or ground
scarred areas.
2.4.4.1 SOIL CONCENTRATIONS COMPARED TO RSLs
Figures 8 through 15 show the surface soil concentrations for PCB total Aroclors, arsenic, cadmium, total
chromium, lead, mercury, nickel and silver, respectively. The figures depict color-flood contours based on
the MPI 50 x 50 ft sampling grid with the MPI-measured concentration posted at the center of each grid
cell. In the following discussion, the term "elevated" denotes concentrations that exceed the April 2012
RSL for residential soil. For total chromium, concentrations are screened against the hexavalent
chromium RSL. It should be noted that specific residential RSLs for each COC as noted on the figures are
from an earlier RSL table (June 2011) and, therefore, may not match the RSLs noted in this section's text
and Table 1. Additionally, the term "hotspot" refers to relatively isolated areas (red shaded sampling grid
blocks on the figures) with elevated concentrations that exceed a specific elevated screening threshold
defined for each COC (typically the industrial soil RSL or the industrial soil RSL multiplied by 10 or
100).
Figure 8 indicates that PCB concentrations in soils exceed 10 times the minimum PCB RSL (5.4
milligram per kilogram [mg/kg]) across most of the Site. In addition, arsenic, lead, mercury and nickel
concentrations in soil are elevated Site-wide (Figures 9, 12, 13 and 14, respectively). Hotspots for these
COCs exceed the industrial soil RSL by one or more orders of magnitude. PCB hotspots (>100 mg/kg)
and lead hotspots (>8,000 mg/kg, 10 times the industrial soil RSL) occur in the central, eastern and
northeastern portions of the Site. Arsenic hotspots (>160 mg/kg, 100 x industrial soil RSL) are distributed
Site-wide. Mercury and nickel each exhibit one hotspot. The nickel hotspot (>20,000 mg/kg, 10 x
industrial RSL) is located on the Site's western boundary, at a point along the western drainage. The
mercury hotspot (>43 mg/kg, 10 x industrial RSL) is located adjacent to the Paradise Creek shoreline.
Total chromium exhibits elevated concentrations in soils across the Site (Figure 11) while cadmium
concentrations are elevated Site-wide with the exception of the northwestern portion of the Site (Figure
10). Silver concentrations are generally below the residential RSL Site-wide (Figure 15). The total
chromium hotspots (>20,000 mg/kg, the industrial soil RSL) are observed along the Site's western
boundary, one of which is in close proximity to the above-noted nickel hotspot. Cadmium exhibits
hotspots (>80 mg/kg) in the central, eastern and northeastern portions of the Site.
In October 2003, DAA (DAA, 2003b) sampled soils for PCDDs and PCDFs (also referred to herein as
"dioxins and furans") at three areas on site where cables were burned for copper wire recovery. The
documents available for this optimization review did not include information regarding the locations of
these samples. The soil samples were analyzed for dioxins and furans and the results for all three areas
(maximum of 0.42 parts per billion [ppb] equivalent total 2,3,7,8-tetrachlorodibenzo-p-dioxin [2,3,7,8-
TCDD]) were below the latest threshold screening level of 0.664 ppb for industrial/commercial property
(www.epa.gov/superfund/health/contaminants/dioxin/dioxinsoil.html). However, the observed equivalent
2,3,7,8-TCDD concentrations at two of the three areas exceeded the latest threshold screening level of
0.050 ppb.
13
-------
2.4.4.2 SOIL CONCENTRATIONS COMPARED TO SOIL ECOLOGICAL SCREENING LEVELS
The surface soil concentrations data shown on Figures 8 through 15 were compared to soil ecological
screening levels. For screening PCBs, the EPA Region 3 Draft BTAG level of 0.1 mg/kg was used (EPA,
undated reference). The EPA Office of Solid Waste and Emergency Response (OSWER) defined separate
ecological screening levels for plants, invertebrates, birds and mammals for arsenic (EPA, 2005),
cadmium (EPA, 2005), chromium (EPA, 2008), lead (EPA, 2005), nickel (EPA, 2007) and silver (EPA,
2006). To maximize protectiveness of the screening, the lowest of the four ecological levels was selected
for the screening of these constituents. The selected levels therefore were 18 mg/kg for arsenic (plants),
0.36 mg/kg for cadmium (mammal), 26 mg/kg for chromium III (birds), 11 mg/kg for lead (birds), 38
mg/kg for nickel, (plants) and 4.2 for silver mg/kg (birds). For screening mercury, the EPA Region 3
Draft BTAG Screening level of 0.058 mg/kg was used (EPA, undated reference).
Figure 8 shows PCB concentrations measured in surface soil. Because the minimum contour defines PCB
concentrations of 1 mg/kg or greater (compared to a screening level of 0.1 mg/kg), all shaded areas shown
on the figure exceed the PCB screening level. Review of the non-shaded areas (PCB concentrations below
1 mg/kg) reveals that, with only a few exceptions, all non-shaded grid blocks with a posted concentration
also exceed the lead screening level. Two or more contiguous grid cells with less than screening level
posted concentrations include several areas in the northwest portion of the Site (Y40-AA40 and Y38-
Z38) and the south-southwestern portion of the Site (Y24-Z24, FF14-HH14, Y16-Z15 and T10-U10).
Figure 9 shows arsenic concentrations measured in surface soil The gold/red-shaded areas, encompassing
most of the northeastern, eastern, central and northwestern portions of the site, denote areas where the
arsenic concentration exceeds 16 mg/kg. Although some of the gold-shaded grid cell concentrations are
less than the 18 mg/kg arsenic screening level, the posted concentrations for most exceed this level.
Figure 10 shows cadmium surface soil concentrations. Because the minimum contour defines cadmium
concentrations of 7 mg/kg or greater (compared to a screening level of 0.36 mg/kg), all shaded areas
(northeastern, eastern and central portions of the Site) shown on the figure exceed the cadmium screening
level. Review of the posted concentrations in the non-shaded grid cells shows that only in a very small
number of the cells are concentrations less than screening level.
Figure 11 shows chromium surface soil concentrations. Yellow, gold and red shaded grid cells indicate
Site areas that exceed 56 mg/kg and thus define areas in which chromium concentrations exceed the
screening level of 26 mg/kg. The remaining grid cells are all shaded green denoting chromium
concentrations ranging from 5.6 to 56 mg/kg in surface soil. With the exception of single cell
occurrences, green-shaded grid cells with posted concentrations less than the screening level are
concentrated in the extreme northwestern portion of the Site (cells Y38-Y41, Z38-Z49 and AA39), the
cells just south of the Sherwin Williams property (EE27 and FF27), cells in the southern wetland area
(DD7, DD4, DD5, EE4, EE8) and cells in the extreme northeastern corner (C34-C37).
Figure 12 shows surface soil concentrations for lead. Because the minimum contour defines lead
concentrations of 400 mg/kg or greater (compared to a screening level of 11 mg/kg), all shaded areas
shown on the figure exceed the lead screening level. Review of the non-shaded areas (lead concentrations
below 400 mg/kg) reveals that with only a small number of exceptions, all non-shaded grid blocks also
exceed the lead screening level. Contiguous cells with posted concentrations less than the screening level
include cells Y38-Y39 in the northwestern portion of the Site.
Figure 13 shows the surface soil concentrations for mercury. Because the minimum contour defines
mercury concentrations of 1 mg/kg or greater (compared to a screening level of 0.058 mg/kg), all shaded
14
-------
areas shown on the figure exceed the mercury screening level. Review of the non-shaded areas (mercury
concentrations below 0.058 mg/kg) reveals that with only a small number of exceptions, all non-shaded
grid blocks also exceed the mercury screening level. Contiguous cells with posted concentrations less
than the screening level include the following cells: FF14-GG13, BB3-CC4, Z20-AA20 and Y38-Z38.
Figure 14 shows surface soil concentrations for nickel. Yellow, gold and red shaded grid cells encompass
Site areas that exceed 150 mg/kg and thus define areas in which nickel concentrations exceed the
screening level of 38 mg/kg. Review of the non-shaded areas (mercury concentrations below 0.1 mg/kg)
reveals that with some exceptions, most non-shaded grid blocks also exceed the nickel screening level.
The principal areas of non-exceedance include the southwestern portion of the Site (between rows 3-8
and columns DD-FF), south of the block of masonry buildings in the northwestern portion of the Site
(between rows 26-31 and columns Y-BB) and in the northwestern corner of the Site (between rows 38-
42 and columns Y-AA).
Figure 15 shows surface soil concentrations for silver. Because the minimum contour defines silver
concentrations of 39 mg/kg or greater (compared to a screening level of 4.2 mg/kg), all shaded areas
shown on the figure exceed the silver screening level. In addition, large areas of unshaded cells also
exceed the screening level including cells in the northeastern portion of the Site (between rows 25 to 33
and columns B-E), in the central and eastern portion of the Site (between rows 13 and 22 and columns A
through V) and in the southern portion of the Site (between rows 2 and 13 and columns X through EE).
2.4.5 SOIL VAPOR / INDOOR AIR CONTAMINATION
The previous site investigations did not include the collection of soil vapor or indoor air data. Previous
site activities have potentially resulted in the release of constituents that may contribute to soil vapor
contamination and potentially contamination of indoor air. It should be noted however, that all site
buildings and structures identified during the site visit appeared to have limited current use and were
observed to be open to the elements via missing bay doors, entry doors and windows (see photo log in
Attachment B). The potential risks associated with soil vapors at the Site, therefore, are dependent on the
extent of volatile organic compound (VOC) contamination encountered in shallow soil and groundwater
and the spatial relationship of the locations of any detections or screening level exceedances to buildings
that are used on site.
2.4.6 GROUNDWATER CONTAMINATION
Site groundwater sampling has been conducted at nine existing monitoring wells (MW-1R through 7, 9
and 10), one historic monitoring well (MW-1) (HGL, 2011) and four direct push locations (Hatcher-
Sayre, 1999). For the previous investigations, groundwater was analyzed for three to four rounds of PCBs
and metals analyses. The metals analyses included arsenic, cadmium, total chromium, lead, mercury,
nickel and silver. One round of groundwater samples collected in 1999 was also analyzed for VOCs
(Hatcher-Sayre, 1999). VOC sampling locations included six monitoring wells (MW-1 through MW-6)
and four direct push sample locations (B-l through B-4). In total, 24 VOC analytes were detected at
relatively low concentrations with three compounds exceeding tap water RSLs (benzene, trichloroethene
[TCE] and vinyl chloride [VC]). With the exception of B-4, detections and screening level exceedances
were isolated. At B-4, located in southwest of the former maintenance building in the east-central portion
of the Site, 18 VOC detections and two exceedances were observed. The two B-4 exceedances included
benzene (15 micrograms per liter [|ig/L]) and VC (13 (ig/L). The benzene and VC tap water RSLs are
0.39 and 0.015 (ig/L, respectively. The other VOC exceedance was TCE at 20 (ig/L in MW-2 (versus the
tap water RSL of 0.44 (ig/L).
15
-------
Figure 16 shows the PCB and metals results for the constituents detected in three Site-wide groundwater
sampling events (July 1999, July 2003 and July 2008). Applicable screening levels for groundwater are
shown in Table 2. PCB homologues were detected in July 2008 in three monitoring wells MW-7, MW-9
and MW-10 all of which are located down gradient from the areas with maximum PCB concentrations in
shallow soils. Detected concentrations ranged from 0.007 to 0.1944 (ig/L, which are below the EPA MCL
of 0.5 (ig/L (source: EPA Consumer Factsheet on PCBs available at the web address
www.epa.gov/ogwdw/pdfs/factsheets/soc/pcbs.pdf).
The metals detected in Site monitoring wells include arsenic, total chromium, nickel, lead and mercury.
Considering the elevated metals concentrations observed in Site soil, metals screening level (tap water
RSL) exceedances are at relatively low concentrations and exhibit no obvious trends or patterns. Arsenic
was detected in all monitoring wells with the exception of MW-2. The maximum arsenic and chromium
concentrations (28 and 93 (ig/L unfiltered) were observed at MW-7. The corresponding tap water RSLs
are 0.045 (ig/L (arsenic) and 0.031 (ig/L (hexavalent chromium), respectively. The maximum nickel
concentration was observed at MW-2 (800 (ig/L, unfiltered) which exceeds the tap water RSL (30(ig/L).
The maximum lead and mercury concentrations (50 (ig/L and 0.24 (ig/L, both unfiltered) were observed
at MW-7. No tap water RSL exists for lead; the MCL is 15 (ig/L. The tap water RSL for elemental
mercury is 0.063 (ig/L.
As discussed in Section 4.0, the City of Portsmouth provides potable water service to the Site vicinity and
discourages the installation of private wells for the purpose of water supply. A search for potential private
wells in the vicinity of the Site was not conducted for this optimization review and an inventory of water
supply wells in the Site vicinity was not identified in the Site documents used for the optimization review.
These activities are recommended for consideration during RI activities to understand potential exposure
pathways for groundwater.
2.4.7 SURFACE WATER CONTAMINATION
With the exception of Paradise Creek surface water sampling conducted by CH2M Hill (CH2M Hill,
2001) on behalf of the Navy, previous Site investigations have not included the characterization of Site
surface water. Data from the CH2M Hill sampling event were unavailable for this optimization review. In
accordance with the state requirements under the Clean Water Act, the VDEQ has identified the water
bodies in the state that do not meet water quality standards and, therefore, are declared to be impaired.
Paradise Creek, located to the south and southeast of the Site, has been identified in Virginia's Draft 2012
305(b)/303(d) Water Quality Assessment Integrated Report (VDEQ, 2012) as an impaired water body due
to the following:
2009 advisory for dioxin contamination in Blue Crab tissue
2004 advisory for PCB contamination in fish tissue
2006 declaration for recreational use impairment due to elevated bacterium levels of
Enterococcus
2006 declaration of dissolved oxygen (DO) concentrations below acceptable criteria for open
water
A total maximum daily load (TMDL) for PCBs is currently under development for the Elizabeth River
watershed to address fish tissue impairment. A TMDL is the maximum amount of a pollutant that a water
body can receive and still meet water quality standards. The TMDL must account for loading among the
various sources of the given pollutant. In order to characterize PCB loadings for TMDL development,
VDEQ is implementing low-level PCB monitoring (VDEQ, 2009) at permitted point source discharge
facilities (municipal and industrial waste water facilities and industrial storm water facilities) within the
16
-------
state. The Elizabeth River PCB TMDL could potentially be identified as a future ARAR for the Site. The
target date for PCB TMDL implementation is 2014. Screening Levels for surface water are shown in
TableS.
2.4.8 SEDIMENT CONTAMINATION
Sediments from the western drainage and from Paradise Creek adjacent to the Site have been sampled to
date. Four sampling events have been conducted including a 2001 event performed by CH2M Hill for the
Navy (CH2M Hill, 2001), a 2003 event performed by DAA and VDEQ, a 2004 event conducted by Unger
et al. (2005) and a 2007 event conducted by MPI (MPI, 2008). Screening Levels for sediment are shown
in Table 4. The screening levels are generally derived from NOAA SQuiRT TELs for freshwater which
are equivalent or lower than the Region 3 Ecological Screening Benchmarks available at the web address:
www.epa.gov/reg3hscd/risk/eco/index.htm.
As a result of discussions at a 2003 meeting between Peck, VDEQ, Elizabeth River Project (ERP) and
EPA; DAA and VDEQ jointly collected three sediment samples from the Site in 2003 (DAA, 2003b).
One sediment sample was collected from the open ditch portion of the western drainage, at a location
approximately 500 ft upstream from the drainage discharge point to Paradise Creek. A second sample was
collected from the western drainage channel at the downstream end of the drain pipe, approximately 65 ft
upstream of Paradise Creek. A third sample was collected at the confluence of the western drainage
channel and Paradise Creek. The samples were collected from the surface to a depth of approximately 6
inches. The objective of the sampling effort was to confirm the 17.7 mg/kg PCB concentration obtained
by CH2M Hill from a sediment sample collected from Paradise Creek near the southeast corner of the Site
(DAA, 2003b). CH2M Hill (CH2M Hill, 2001) conducted the sampling for an ecological risk assessment
performed on behalf of the Navy. The location of the CH2M Hill sediment sample is unknown because
the associated documentation was unavailable for this optimization review. The DAA/VDEQ samples
were analyzed for PCBs (Aroclors) only. The open ditch western drainage sample and the sample from
the western drainage channel below the drain pipe were both non-detect at the method detection level of
0.033 mg/kg. A PCB concentration of 0.044 mg/kg was obtained from the sample collected from the
confluence of the western drainage and Paradise Creek (DAA, 2003b).
On behalf of ERP, Unger et al (2005) collected 19 surface sediment samples and one 60-centimeter (cm)
sediment core. The samples were collected in June, 2004 from Paradise Creek adjacent to the Site. A petit
ponar sampler was used to collect the surface sediment samples; samples were collected to an
approximate depth of 16 cm. A subset of eight samples was submitted for grain size analyses, total
organic carbon (TOC), PCB (congeners) and PAH analyses. PCB analyses were performed to a method
detection level approaching 0.1 nanogram/gram (ng/g). The analyses included over 100 individual
congeners. Total PCB concentrations, calculated as the sum of all congeners at each location, ranged from
0.001 to 1.5 mg/kg. Total PAH concentrations ranged from 11 to 52 mg/kg. Concentrations of both
constituent groups decreased with depth. The maximum concentrations were measured in samples
collected near the confluence of the western drainage and Paradise Creek. The results of this investigation
also indicated that total PCB and PAH concentrations were only marginally correlated (R square = 0.57)
and that no correlation exists between either constituent group and TOC.
For the extent of contamination study performed for Peck, MPI conducted a 2007 sediment sampling
event in Paradise Creek adjacent to the Site (Figure 17). The sample domain was partitioned into 50 ft by
50 ft grids resulting in the collection of 37 samples which were analyzed for PCB homologues and seven
metals (arsenic, cadmium, total chromium, nickel, lead, mercury and silver). The samples were collected
from the surface to a depth of 6 inches. PCBs were non-detect at all sampling locations with the exception
of two samples (0.075 mg/kg for both) near the western drainage channel/Paradise Creek confluence and
one sample located near the southeastern corner of the Site (0.14 mg/kg). All detected concentrations
17
-------
exceeded the NOAA SQuiRTs freshwater TEL of 0.0216 mg/kg for total PCBs. The homologue analyses,
however, are reported at detection levels that are elevated relative to the screening level (>0.075 mg/kg
compared to the 0.0216 mg/kg NOAA SQuiRT TEL). The elevated detection levels, therefore, may mask
other potential exceedances. With regard to metals analyses for the 37 samples, all 37 exceeded SQuiRT
TELs for six of the seven metals. Silver exceeded the SQuiRT TEL at just six of the 37 locations.
18
-------
3.0 DESCRIPTION OF PLANNED OR EXISTING REMEDIES
To date, no remedial actions have been taken to address Site conditions. However, several remedies have
been proposed by the Site owner in effort to achieve Site reuse objectives. To facilitate redevelopment of
the Site as a self-service auto parts salvage yard, Peck entered the Site in the VDEQ VRP in 2003. In May
2003, on behalf of Peck, DAA proposed a remedial design (DAA, 2003a) consisting of the installation of
a fill barrier and implementation of institutional controls (1C) including deed restrictions and excavation
prohibitions. The remedy design called for compaction of the existing ground surface followed by
placement of at least 3 inches of granular material (Virginia Department of Transportation [VDOT] #3
aggregate or equivalent), 3 inches of compacted clayey sand to sandy clay fill, a 2- to 3-inch layer of
crushed stone in areas of proposed automobile staging and access areas and 2 inches of topsoil in lieu of
crushed stone in areas of planned landscaping (DAA, 2003a). The minimum combined thickness of the
proposed cap would be 8 inches.
VDEQ issued a response to the remedy proposal in June 2003, noting that although additional
characterization sampling was needed, it agreed in principal with the concept of capping as a remedial
approach for the Site. VDEQ also requested additional sampling to better delineate the extent of PCB
contamination, evaluate potential dioxin contamination and characterize PCB concentrations in on- and
off-Site sediments. Other actions requested included the installation of a perimeter security fence and a
removal action to address localized areas of soil with elevated lead concentrations. VDEQ indicated areas
with lead concentrations in excess of 10,000 mg/kg or PCB concentrations in excess of 100 mg/kg would
require a soil cap with minimum thickness of 10 inches.
In October 2004, Peck submitted a revised Self-Implementing PCB Cleanup Plan to the EPA Region 3
Regional Administrator (DAA, 2004a). The plan called for the excavation of areas with PCB
concentrations exceeding 10 mg/kg; backfilling of the excavations with clean fill; appropriate disposal of
the excavated PCB-contaminated soil; engineered regrading; and placement of a 10-inch thick soil cap
over the Site. Areas to be overlain by concrete floor slabs or pavement would not require capping. Areas
requiring excavation were based on sampling conducted onal50ftbyl50ft sampling grid with a single
discrete sample collected from within each grid cell.
In January 2007, EPA Region 3 issued an Administrative Order (AO) for the Site. Consistent with the
terms of the AO, Peck completed the extent of contamination investigation which included soil PCBs and
metals concentration characterization on a 50 ft by 50 ft grid (MPI2008). Again, a single discrete sample
was collected from within each grid cell. In subsequent discussions with Peck, the EPA indicated that all
soil with PCB concentrations greater than 25 mg/kg or lead concentrations greater than 1,000 mg/kg
would need to be removed from the Site. Peck maintained that since the Site was considered a Low-
Occupancy property, TSCA PCB regulations allowed soil with PCB concentrations between 25 mg/kg
and 100 mg/kg to be left on Site provided they were capped. MPFs site remedy recommendation included
removal and off-site disposal of PCB contaminated soils with concentrations greater than 500 mg/kg.
Soils identified at PCB concentrations less than 500 mg/kg would be excavated and consolidated. These
consolidated materials would then be capped on Site (MPI, 2008).
Selection of a final Site remedy design must await the completion of the Site characterization activities
that will be performed for the RI and the completion of the associated FS.
19
-------
4.0 CONCEPTUAL SITE MODEL
This section discusses the optimization review team's interpretation of historical information and existing
characterization data to explain how historic events and site characteristics have led to current conditions.
Section 4.1 provides a brief summary of the optimization review team's interpretation of the CSM.
Identified data gaps are discussed in Section 4.2. Section 4.3 reviews the existing investigation as
documented in the HGL Plan and provides potential strategies for optimizing the investigation.
4.1 CSM OVERVIEW
In accordance with the information obtained from the document review and from discussions with Region
3 and VDEQ, the optimization review team developed a CSM for the release and migration of
constituents from the Site. The CSM states that as a result of approximately 50 years of scrap metal
processing and recycling operations, contaminants, primarily PCBs and metals, were released over broad
areas to surface soil at the Site. A source of potential subsurface soil contamination is the large amount of
fill material of various forms (construction rubble, debris, etc.) used to raise land surface elevations,
particularly in the southern central portion of the Site. Contact of precipitation with contaminated soil
likely resulted in the transport of contaminated soil through surface runoff and the potential migration of
Site constituents with recharging water to shallow groundwater. Surface water transport of contaminated
soil has potentially resulted in elevated levels of Site constituents in Paradise Creek sediments. As a result
of the downward migration of contaminated groundwater recharge, the potential also exists for offsite
migration of contaminated groundwater.
Water levels in Paradise Creek exhibit diurnal tidal fluctuation with a typical amplitude of approximately
3 ft. Groundwater levels near a tidal shoreline typically exhibit some fluctuation corresponding to tide
changes with the tidal influence dissipating with distance from the shoreline. Based on the relatively small
amount of tidal fluctuation in comparison to the higher groundwater level at MW-4 (location of maximum
groundwater elevation observed on Site [Figure 7]), groundwater is expected to move a greater distance
down gradient over each tidal cycle.
4.2 DATA GAPS
The CSM is the primary tool for identifying significant data gaps in the existing characterization data. In
the discussion that follows, general site condition data gaps are discussed, followed by discussions of the
data gaps for each environmental media. Strategies to address the data gaps are then discussed at the end
of this section.
Ideally optimization reviews are conducted prior to the development of any draft work plans as a means
to inform the development of planned site activities. In the case of the PIM optimization review, EPA
Region 3 did receive a draft work plan from HGL prior to soliciting an optimization review for the site.
At the request of the RPM, the optimization team has included Table 5 which provides a crosswalk
highlighting differences between site activities proposed by HGL in the draft RI work plan and suggested
RI activities from the optimization review.
20
-------
4.2.2 GENERAL SITE CONDITIONS
Data gaps exist with regard to the understanding general site conditions. Specifically, additional data is
needed with respect to fill thickness, extent and thickness of the uppermost aquifer, Site surface water
drainage structures, Site groundwater flow directions and potential contamination in the vicinity of the
Site buildings.
Fill Thickness. As indicated in the background discussion presented in Section 2, extensive portions of
the Site are underlain by various types of fill that are present in apparent thicknesses exceeding 10 ft. Fill
present below the water table can impact groundwater flow directions, velocity and groundwater quality.
From a sampling access perspective, fill containing a high percentage of concrete, wood, metal and other
non-native materials can restrict the use of hand auguring, drive point methods and other of the more cost-
effective drilling technologies.
Site Surface Water Drainage Structures. HGL (2011) identified two main surface water drainage
channels at the Site. The western drainage ditch is located along the western boundary of the Site and
receives drainage from the western portion of the Site and the neighboring Sherwin Williams facility. The
second channel (the northwestern drainage ditch) is a concrete trough-like structure that appears to
originate at the northern boundary of the Site and continues northward, first on the ARREFF property
then on the Site, parallel to the boundary between the northwestern portion of the Site and the ARREFF
property. Potential impacts to western drainage ditch surface water and sediment quality from the
upstream Sherwin Williams facility are unknown. Upstream sediment and surface water contributions to
the western drainage ditch have not been characterized. With respect to the northwestern drainage ditch,
confirmation of the direction of flow is necessary. Associated with this data gap is the determination of
the source and fate of water to this ditch and what, if any, buried Site sewer lines, drain tiles, or other
structures drain to this structure. Addressing these data gaps is necessary for designing a meaningful
sampling strategy for the northwestern drainage ditch.
Extent of Uppermost Aquifer and Site Groundwater Flow Directions. Groundwater level data
collected from the existing monitoring well network consistently result in water table elevation maps
depicting a groundwater mound located in the central portion of the Site in the vicinity of MW-4.
Additional soil borings may be useful in delineating the extent and saturated thickness of the uppermost
aquifer. Flow directions based on the map show that a portion of site groundwater flow is toward the
northeast, toward MW-6 near the intersection of Elm and Williams Avenue. City utility maps indicate the
presence of a storm drainage ditch paralleling Elm Avenue along the northern Site boundary and northern
boundary of the ARREFF property. Near the northeastern corner of the Site, at the intersection of Elm
and Williams Avenues, the ditch discharges to a southward flowing drainage pipe that parallels the
eastern boundary of the Site. Drainage to the ditch and drain pipe may act to passively lower water levels
in the eastern portion of the Site. In addition, as noted in the previous section, passive drainage alone
would only account for the lowering of groundwater levels to levels slightly greater than mean sea level
datum. The water levels consistently observed in MW-6 in recent monitoring events are below sea level
datum suggesting the presence of some form of off-site influences on groundwater, such as pumping.
These uncertainties, suggest that additional characterization of the extent of the groundwater mound and
confirmation of the groundwater low near Elm and Williams Avenues is warranted. Existing groundwater
contour interpretations project the local high at MW-04 as a northwest-trending groundwater high
resulting in a divergent flow pattern across the central and northwestern portions of the Site. Because
manually constructed groundwater contours can be subject to the personal bias of the interpreter (Kresic
2007), contouring results can vary between different analysts. For example, due to data scarcity, a
plausible alternative contour interpretation places the groundwater high in a more westerly orientation,
cresting at MW-2 rather than trending to the northeast of MW-2 as shown in Figure 7. Based on this
interpretation, groundwater flow in the northwestern portion of the Site would be more northerly instead
21
-------
of toward the northeast, as shown on Figure 7. An improved understanding of groundwater flow direction
is essential for accurate evaluation of the fate and transport of Site constituents in groundwater.
Preferential Groundwater Discharge Zones in Paradise Creek. A data gap exists regarding the
location of preferential groundwater discharge zones in Paradise Creek offshore from the Site. In addition,
the extent of the medium to fine-grained sand zone (Figure 6), which may structurally affect flow
directions, has not been fully characterized. Although groundwater discharge to the creek is expected to
occur along the full length of Site's shoreline and adjacent creek bottom, the presence of discrete areas
with convergent groundwater flow and relatively higher groundwater discharge rates are also expected.
Such zones of preferential discharge likely reflect the presence of zones of higher hydraulic conductivity
in the adjacent aquifer sediments and associated preferential groundwater flow paths. Preferential
groundwater discharge zones, therefore, should be considered in the selection of locations for the
characterization of Site sediments as sediment contamination levels may be related to the discharge of
contaminated groundwater.
Potential Contamination near Existing Structures. A number of buildings are present on Site and
numerous others existed historically. Buildings and other structures are centers of manufacturing and
material processing operations and thus are potential locations for the release of Site contaminants. The
following specific data gaps were identified:
A small catchment basin was observed during the site visit at the northeastern corner of the block
of masonry buildings located near the entrance gate at the northwestern portion of the Site.
Several below grade pipes enter the basin from the direction of the buildings. Any standing water
and sediment in the basin can be easily sampled.
As reported by HGL (2011), a vent pipe, possibly associated with an UST is located adjacent to
the former maintenance garage in the eastern-central portion of the Site. The presence of an UST
at this location should be confirmed. If confirmed, the UST should be removed and the potential
for contamination (soil and groundwater) should be evaluated in accordance with Virginia UST
regulations.
Staining was noted on the floor slabs of the buildings and materials indicative of automotive
repair/detailing were identified in the largest building in the northwestern portion of the Site. The
potential for sub-slab contamination or contamination from recent activities should be considered.
Munitions and Explosives of Concern and Munitions Debris (MEC/MD) Identification and
Clearance. MEC/MD has been discovered at the Site during soil sampling and soil boring construction
operations performed in previous Site investigations. Site operational data regarding the extent of
historical processing operations involving MEC/MD are unavailable. In addition, Site data characterizing
the occurrence of MEC/MD at the Site are nonexistent and will need to be generated at each proposed
intrusive sampling location.
4.2.3 ENVIRONMENTAL MEDIA
Environmental media of concern include soil, soil vapor, groundwater, sediment and surface water. With
the exception of the 1997 and 1999 Hatcher-Sayre investigations, chemical analysis of Site samples have
been restricted to eight Resource Conservation and Recovery Act (RCRA) metals and PCBs (Aroclors in
soil; homologues and congeners in sediment). Across all media, therefore, a significant data gap to be
addressed is the need for a more complete analytical scan to ensure that all Site COCs are identified. At
selected locations for each media, samples may be analyzed for target compound list (TCL) and target
22
-------
analyte list (TAL) analyses. In addition to those identified above in the general characterization
discussion, analytical data gaps for each media are discussed below. Input from the project risk assessors
and BTAG group can be used to further focus analytical options on human health or ecological risk
drivers.
Soil. In addition to sampling for a more complete analytical scan, soil data gaps include surface soil
quality data collected at the appropriate depth for use in risk assessments, the expansion of the soil sample
coverage to include the previously unsampled areas and limited sampling to identify specific PCB,
PCDD, and PCDF congeners in Site soil. Surface soil characterization data are available for the top 18
inches. For human health and ecological risk assessment purposes, however, surface soil data is required
for the top 6 inches. Sampling consistent with risk assessment data requirements should be conducted.
With regard to soil data coverage, samples should be collected from the areas not covered by the DAA
and MPI sample grids. These areas include the western Site boundary and the berm located along the
Site's southeastern border with the SPS-RDF facility. To provide a basis for comparing specific PCB
compounds in Site soils to those identified in Paradise Creek sediment, PCB congeners may be analyzed
in samples from Site areas with the most elevated PCB concentrations. High PCB concentration areas
may more completely represent the diversity of PCB congeners at the Site.
Soil Vapor. Previous investigations have not included the collection of soil vapor samples. If reuse
scenarios include the construction of new buildings or the reuse of existing structures, a soil gas sampling
event may be conducted to evaluate the potential presence of elevated VOCs in soil vapor. The necessity
of a soil vapor sampling event is contingent on initial findings for any areas that exhibit elevated VOCs in
soil or groundwater. Guidance for evaluating vapor intrusion (VI) potential given Site VOC soil and
groundwater concentration data is provided in the EPA Subsurface Vapor Intrusion Guidance (EPA,
2002).
Groundwater. The primary groundwater data gaps are the need to improve the characterization of the
variability of groundwater flow directions at the Site. The groundwater divide in the vicinity of MW-04
may be the result of deeper pumping east of the Site. Additional deeper monitoring wells may be useful to
examine groundwater flow paths in this direction. Groundwater quality along the Site's up gradient
boundaries should also be examined. Following confirmation of Site groundwater flow, groundwater
sampling is recommended to belter characterize potential impacts to groundwater quality from adjacent
properties. Specifically, sampling is recommended in the northeastern and eastern portions of the Site
adjacent to the ARREFF property and SPS-RDF properties, respectively (Figure 7).
Sediment. Sediment samples have been collected from the western drainage ditch and from Paradise
Creek. Data for the western drainage ditch is limited to three samples, two of which were non-detect for
PCBs (Aroclors). In a sample collected at the confluence of the western drainage ditch and Paradise
Creek, PCBs were detected at a concentration of 0.044 mg/kg which exceeds the SQuiRT TEL of 0.0216
mg/kg for total PCBs. Additional sampling of the western drainage should be conducted for full TCL and
TAL analysis and to confirm the PCB results from the previous sampling event. Paradise Creek sediment
PCB data consist of one sample analyzed for Aroclors at the discharge point of the western drainage ditch
and relatively broad sample coverage for PCB congeners and homologues. The homologue analyses,
however, are reported at detection levels that are elevated relative to the screening level (>0.075 mg/kg
compared to 0.0216 mg/kg NOAA SQuiRT TEL) thus potentially masking exceedances. Data gaps
include the need to analyze sediment samples for PCB Aroclors. The Aroclor data are needed for
comparison to risk-based standards. A subset of samples (the highest detected values) can be analyzed for
PCB congeners for comparison to congener analysis for shallow soil on site. In addition, consideration
should be given to conducting limited sampling and analysis for PCDD and PCDF compounds in the
western and northwestern drainage ditches to evaluate the potential for contaminated sediment transport
from the former transformer burn areas.
23
-------
Surface Water. Previous investigations for this Site did not include the sampling of surface water.
Surface water is present onsite in ponds and puddles, in the western drainage ditch and in the northwest
drainage ditch located at the boundary of the Site and the ARREFF property. To address this data gap,
surface water samples should be collected from these features and from Paradise Creek. It is
recommended that this sampling be timed to coincide with the collection of sediment samples and include
the same suite of analyses for site COCs.
4.3 IMPLICATIONS FOR THE REMEDIAL INVESTIGATION
As a task under the EPA Region 3 RAC, HGL prepared the RI/FS work plan (HGL Plan [HGL, 2011])
for the Site. The HGL Plan documents an effective investigation to address site data gaps. The HGL
investigation will include an MEC/MD avoidance and utility clearance task and soil, groundwater, surface
water and sediment sampling. After a brief summary of the HGL-planned sampling approach, potential
strategies for optimization are identified. Table 5 summarizes the optimization recommendations for each
of the field sampling tasks presented in the HGL Plan. The strategies are offered to the RI Team (Region
3 staff and its supporting contractors) for consideration for the implementation of a potentially more
expedited and effective RI.
4.3.1 MEC/MD AVOIDANCE AND UTILITY CLEARANCE
This section describes currently planned MEC/MD avoidance and utility clearance activities contained in
the HGL Plan. Section 4.3.1.1 summarizes the HGL-planned activities. Section 4.3.1.2 provides
suggested changes as a result of the optimization review team's site visit, preliminary CSM development
and site data/report reviews.
4.3.1.1 HGL Planned Field Activity
Prior to the start of the RI field events, trained MEC/MD technicians will perform a visual survey and will
construct boreholes for MEC/MD avoidance in areas of planned investigative work. The survey will
include a 34-acre area including the entire Site (with the exception of the northern half of the
northwestern portion of the Site) and a portion of the ARREFF property. Any MEC/MD identified will be
visually inspected, photographed, surveyed using a hand-held global positioning system (GPS), its
location marked in the field and mapped.
During the visual survey, locations of boreholes for MEC/MD avoidance will be sited in each of the
planned boring locations in the areas of future investigation. Using a hand auger, a UXO technician will
advance a boring to a depth range of 2 to 6 ft bgs. A magnetometer will be used to determine the presence
of magnetic and/or magnetically susceptible items in the soil. If a magnetic or magnetically susceptible
item is detected in a boring, the boring will be abandoned and a new boring will be drilled within 5 to 10
ft of the abandoned boring. All MEC/MD and potential MEC/MD locations will be avoided during the
RI.
4.3.1.2 Recommended Strategies for Optimization
The MEC/MD visual survey by trained UXO technicians is important for identifying areas where the field
investigation can safely proceed. The thick, metal-laden fill layer that blankets a large portion of the Site,
however, may limit the effectiveness of the MEC/MD avoidance borehole installation task. Frequent hand
auger refusal should be expected. Since MEC/MD might be encountered at any depth in the fill and
24
-------
drilling for soil sampling will be accomplished using sonic methods, preliminary screening of drilling
locations using hand auguring will likely be challenging.
The RI Team should consider modifying the proposed MEC/MD avoidance activities. To achieve the
objective of avoiding MEC/MD, a UXO technician should be present during drilling operations. A
protocol should be developed by UXO technical staff for conducting down hole magnetometer screening
incrementally during borehole advancement through the fill layer. Initial, pre-intrusive RI activities
should focus on the location and mapping of buried utilities with UXO surveying provided to the extent
necessary for support of utility clearance.
PCDD and PCDF Sampling Strategy. The MEC/MD avoidance and utility locating task provides an
opportunity for preliminary soil screening sampling for PCDD and PCDF compounds. The HGL plan
specifies that extensive sampling for PCDD and PCDF compounds will be performed for soil,
groundwater, surface water and sediment. PCDD and PCDF analyses are relatively expensive
(approximately $800-$ 1,000 per sample); the optimization of the prescribed number of these analyses can
lead to significant project cost savings while ensuring that the PCDD and PCDF data generated by the
investigation meet the requirements for risk characterization. Given that PCDD and PCDF compounds are
relatively immobile in soil and are likely introduced at ground level through direct release or airborne
deposition, they are most likely to occur in surface soil as a result of their tendency to strongly sorb to soil
particles. The results from a preliminary sampling of Site surface soil, therefore, can provide critical input
for refining the sampling design for other media. For example, if the observed PCDD and PCDF
concentrations in surface soil are not a significant environmental concern, lower density sampling can be
considered for the other media (groundwater, surface water and sediments) since contaminated soil is the
likely dominant source for any observed PCDD and PCDF contamination in these media.
A significant source of PCDDs and PCDF compounds is the incomplete combustion of chlorine
containing wastes. Previous sampling (conducted in 2003 and discussed in Section 2.4.4) for these
compounds in electrical transformer burn areas at the Site yielded concentrations that were below the
PCDD and PCDF industrial/commercial property threshold screening level. The locations of the burn
areas, however, were not included in the available Site documentation reviewed. The working assumption
of the CSM is, therefore, that the highest PCDD/PCDF concentrations at the Site occur in shallow soil in
the burn areas and that the burn areas correspond to the locations with the highest observed PCB
concentration.
The recommended approach for resampling the burn areas is based on the incremental composite
sampling (ICS) soil characterization method. The ICS methodology is a composite sampling approach
that statistically reduces data variability associated with discrete sampling and provides mean
concentrations of contaminants within a specified area or volume of soil referred to as a decision unit
(DU). As a result of "short-scale heterogeneity" (the existence of large differences in soil concentrations
over short distances), a strong likelihood exists that any discrete sampling approach for the preliminary
PCDD and PCDF soil sampling can result in a false positive or false negative conclusion (e.g., concluding
that elevated PCDD and PCDF concentrations are more pervasive or less pervasive, respectively, than is
the true situation). The ICS approach reduces the chances for a false conclusion by collecting incremental
samples from each DU that are comprised of a statistically determined number of increments (typically
30-60) to provide an estimate of the mean concentration for that DU. ICS samples can also be collected in
triplicate to allow other statistical analyses such as development of an upper confidence level (UCL) for
the mean. Additional resources including a QAPP template and user guide for employing ICS techniques
when sampling dioxin/furan compounds in soil can be found at www.epa.gov/superfund/health/
contaminants/dioxin/dioxinsoil .html.
25
-------
Using the ICS sampling approach, soil increments of equal mass are collected from multiple, un-biased
locations across the DU. The sampling locations within the DU must be evenly distributed to ensure
representativeness. The soil increments are then mixed together and homogenized to produce one uniform
sample. A sub-sample is collected from the homogenized soil increments and submitted to a fixed-base
laboratory for analysis. The analytical results of the sample are referred to as average or mean
concentrations for the DU.
Since the locations of the 2003 PCDD and PCDF sampling are unavailable in the report documenting this
sampling, the preliminary PCDD and PCDF sampling, as noted above, is proposed for Site areas where
the maximum PCB concentrations are observed in surface and subsurface soil. Using the established 50 x
50 ft grid system at the Site, a minimum of eight3 to 10 of the highest PCB concentration grid cells may
be selected as ICS DUs for the preliminary PCDD and PCDF sampling task. To evaluate the CSM
assumption that the highest PCDD and PCDF concentration locations correspond to the locations with the
highest observed PCB concentrations, sampling should also include a subset of grid blocks with low and
non-detect PCB concentrations. Based on the results of this initial sampling, the extent and scale of
follow-up characterization sampling in the RI tasks for soil, groundwater, surface water and sediment
characterization can be defined.
4.3.2 SOIL INVESTIGATION
This section describes soil sampling activities and recommended strategies for optimizing the
characterization of Site soil. Section 4.3.2.1 summarizes the HGL-planned activities (HGL, 2011).
Section 4.3.2.2 provides suggested changes as a result of the optimization review team's site visit,
preliminary CSM development and site data/report reviews.
4.3.2.1 HGL Planned Field Activities
The HGL-planned investigation of Site soils includes three phases: (1) the assessment of potential offsite
contamination, (2) hotspot evaluation and (3) sampling to confirm the results of the 2008 MPI
investigation. Figure 18 shows the proposed soil sampling locations.
Assessment of Potential Offsite Contamination. A total of 23 off-site delineation soil borings
(designated XRF-01 through XRF-23 on Figure 18) will be completed utilizing a sonic drill rig for x-ray
fluorescence (XRF) lead screening. Seventeen of these borings (XRF-01 through XRF 17) will be
advanced to 8 ft bgs on the ARREFF property. These 17 borings will be located approximately 25 ft north
of the fence line and be spaced approximately 100 ft apart along the fence line where lead concentrations
were previously identified at 400 mg/kg or higher. The remaining six off-site delineation borings (XRF-
18 through XRF-23) will be advanced to 8 ft bgs every 100 ft along the Site/SPS-RDF property boundary.
During borehole advancement, soil samples will be collected continuously for lithologic logging, field
screening with an 11.7-electron-volt (eV) photoionization detector (PID) and visual inspection. In
addition, a total of 92 soil samples will be collected from the following soil depth intervals bgs for XRF
screening: 0 to 6 inches, 6 inches to 2 ft, 3 to 5 ft and 6 to 8 ft bgs. Ten percent of the 92 screened soil
samples will be submitted as confirmatory samples to an EPA off-site laboratory for TAL metals analysis.
A soil sample will be collected from the depth interval of 0 to 6 inches bgs and 6 inches to 2 ft bgs from
each of the 23 borings for offsite analysis at an EPA-approved laboratory for TCL PCB analysis.
3 Eight samples are the minimum number recommended for quantifying the variance in a background data set (EPA
2009). On this basis, the eight sample minimum is adopted in this document as the minimum number of required
samples for statistical characterization of non-background data sets.
26
-------
Hotspot Evaluation. A total of 13 hot spot soil borings, designated SB-01 through SB-13, will be
completed utilizing a sonic drill rig (Figure 18). Eleven of the soil borings will be completed in areas of
known potential impacts on site (SB-01 through SB-11) while the remaining two hot spot soil borings
(SB-12 and SB-13) will be completed on the ARREFF property. The locations of the 13 hot spot soil
borings are depicted on Figure 18. To assist with the hot spot investigation, soil samples will also be
collected from 18 of 24 planned temporary well locations (introduced in Section 4.3.3.1). A continuous
soil core will be collected from each of the 13 soil borings and the 18 temporary wells to 10 ft bgs. Each
core will be visually inspected, lithologically logged and field screened with an 11.7-eV PID. Upon
completion of the visual inspection and PID field screening, soil samples will be collected from the
following soil intervals for laboratory analysis: 0 to 6 inches, 6 inches to 2 ft, 4 to 6 ft and 8 to 10 ft bgs.
Hotspot soil samples will be analyzed for TCL VOCs, TCL semivolatile organic compounds (SVOCs),
TCL pesticides and PCBs, TAL metals and total organic carbon (TOC). In addition, 50 percent of the
samples collected will be analyzed for dioxins and furans, explosives, hexavalent chromium, grain size
and asbestos.
Malcolm Pirnie Confirmatory Sampling. Ten percent of the 555 soil borings completed during the
2008 MPI soil investigation will be re-sampled for the collection of soil samples at specific sample depths
(Figure 18). The MPI confirmatory sampling event will involve completing a soil boring at 55 of the
former MPI 50-by-50 ft sampling grid locations. The re-sampled grid locations were randomly selected to
represent the full range of lead concentrations (non-detect to 10,000 mg/kg). One soil boring per re-
sample grid will be completed using a sonic drill rig. The soil boring within each grid selected for re-
sampling will be biased toward areas of potential contamination (e.g., stained areas, areas of known pits,
or mounds of debris). Without identifiable areas of potential contamination, the soil boring will be
collected from the center of the 50- by 50-ft sampling grid location. A continuous soil core will be
collected from each boring. Each core will be visually inspected, lithologically logged and field screened
with an 11.7-eV PID. Soil samples will be collected at the following interval from each of the 55 soil
borings for laboratory analysis: 0 to 6 inches, 6 inches to 2 ft, 4 to 6 ft and 8 to 10 ft bgs. MPI
confirmation soil samples will be analyzed for TCL VOCs, TCL SVOCs, TCL pesticides and PCBs, TAL
metals and TOC. In addition, 50 percent of the samples will be analyzed for dioxins and furans,
explosives, hexavalent chromium, grain size and asbestos.
4.3.2.2 Recommended Strategies for Optimization
The soil sampling described in the HGL plan is designed to address three characterization objectives: (1)
assess the potential for offsite contamination, (2) evaluate potential hotspots and (3) verify the previous
sampling conducted by MPI. To address the first two objectives, a more adaptive approach is
recommended. For the third objective, the ICS sampling procedure is recommended.
Optimization of HGL Plan Soil Sampling Objectives 1 and 2: Assessment of the Potential for
Offsite Contamination and the Evaluation of Potential Hotspots. An adaptive approach for the offsite
and hotspot soil characterization tasks is recommended. Adaptive sampling consists of the collection of a
relatively large number of field-analyzed samples and the use of the results of the field analyses to select
locations for confirmatory fixed-base laboratory analyses. Follow-up sampling decisions are made in the
field following decision logic defined in the work plan. Field analysis methods are screened for
applicability/effectiveness through the performance of a demonstration of method applicability (DMA). A
typical DMA involves the collection of paired samples for analysis by the field method and by fixed-base
laboratory methods. The general applicability of a field method is based on the quality of the correlation
between the results from the field and laboratory-analyzed samples.
The HGL plan provides for the collection of laboratory verification samples in which paired samples over
the range of observed concentrations are submitted for field XRF analysis of lead and fixed-based
27
-------
laboratory analyses for TAL metals. A goal of 10 to 20 percent fixed-base laboratory collaborative
samples can also be maintained by targeting samples where the field XRF results indicate one or more
metals are near the RSLs. It should be noted that XRF analyses for metals and immunoassay analyses
(IA) for PCBs have both been subjected to collaborative analyses with a fixed-base laboratory (Hatcher-
Sayre, 1999 and DAA, 2003a, respectively). Somewhat reasonable correlations were obtained by
Hatcher-Sayre (1999) for XRF; results of the DAA comparison of PCB IA results with fixed-base
laboratory results were unavailable for this review (i.e., results were not included in the documents
provided).
For the assessment of potential offsite contamination, the HGL plan is not truly adaptive because the
selection of step-out sampling locations depends in part on laboratory-based PCB analyses results from
the set of initially defined locations with the results reported within the standard turnaround time for the
laboratory. The decision to step out, therefore, may be delayed until fixed-base laboratory results are
available, which, assuming normal turnaround time would require approximately 10 business days. For
the same amount of time spent in the field, a greater number of samples can be collected if the step-out
decision is fully field-based compared to a sampling effort based on a non-field step-out decision.
To increase flexibility of the soil characterization, it is recommended that soil sampling be conducted in
two phases within a single field event. In the first phase, samples from the prescribed depths at each
boring are field analyzed and a percentage of the samples are submitted for fixed-base laboratory analysis.
In addition, all first phase soil samples are archived for potential future PCDD and PCDF analysis. In the
second phase, based on the field-based analyses results generated from the first phase borings, a subset of
the borings are selected for further characterization using step-out borings and field analytics. Using
defined logic, a percentage of the samples from the step-out locations can then be selected for fixed-based
laboratory analysis.
The specific approach is described below and shown on Figure 19 in flow-diagram format. At the HGL
plan-prescribed 23 offsite and 31 hotspot locations, install soil borings and collect soil samples at the
plan-defined depth intervals. Each of the soil samples collected is then analyzed via PID, XRF, PAH IA
and PCB IA and is archived. Based on an evaluation of the field analysis data from the initial borings,
select a percentage (20 percent) of the soil samples for fixed-base laboratory analysis and a subset of the
initial boring locations (3 to 5) for follow-up step out boring installation. Identify the optimal number of
adaptive step out borings that can be installed given project budgetary constraints. Install the step out
borings with the goal of placing at least one boring per each of the 3 to 5 follow-up locations. Screen
cores and field analyze over the required sampling intervals used for the initial borings. Archive all
samples from the prescribed sampling depths. Select for submission for fixed-base laboratory analysis all
samples from the final step out boring associated with each initial phase boring.
Based on a review of field analyses and associated fixed based laboratory analyses results, the project
team may select from the archived soil samples (from both the initial and step out soil borings) the
appropriate samples for laboratory analyses of PCDD and PCDF compounds. In addition to PCDD and
PCDF compounds, it is also recommended that selected samples also be analyzed for PCB congener
concentrations via EPA Method 1668B (EPA, 2008) which is capable of achieving PCB detection levels
to the low ng/kg (nanogram per kilogram) range. The resulting data in Site soil can be used for
comparison to PCB congener composition data for Paradise Creek sediments. Determining the relative
similarity or dissimilarity between the congener mix in the soil versus the sediment will assist in source
attribution efforts. Archive sample selection for the analyses of PCDD and PCDF compounds and PCB
congeners should occur in accordance with the laboratory-specified holding time for these constituents.
The above approach requires that the project team specify several specific quantities during the project
planning phase, as follows:
28
-------
The percentage of samples from the initial phase borings that are to be submitted for fixed-base
laboratory analyses and the selection criteria for these samples
The number of initial phase locations that can be investigated in the adaptive phase
The maximum number of adaptive phase step out borings that will be used to investigate the
selected initial phase locations
The percentage of samples from the adaptive phase borings that are to be submitted for fixed-base
laboratory analyses and the selection criteria for these samples
The number and selection criteria for soil samples that will be submitted for PCDD and PCDF
analysis and PCB congener analyses via EPA 1668B
Final quantifications of these parameters are dependent on data quality objectives (DQOs) as defined in
consultation with the project risk assessment team and project financial constraints.
Optimization of HGL Soil Sampling Objective 3: MPI Sample Verification Sampling. The objective
of the MPI sample verification sampling appears to be the generation of a leveraged soil data set
appropriate for FIHRA and ecological risk assessment. The apparent operating assumption is that, if the
verification samples collected from a depth of 6 inches closely correlate with the MPI sampling results
from 18 inches, the larger MPI data set can be leveraged for risk calculations. However, a discussion of
methods or criteria for assessing sufficiency of the correlation are absent from the HGL plan. Given that
soil data typically exhibit pronounced short scale variability (as noted previously, large changes in
concentration occurring over small distances), the probable conclusion of the sampling event, as
structured, will be that the 6-inch depth soil data collected in accordance with the HGL plan differs
significantly from the MPI data.
Given that the existing MPI surface soil data set reflects composited soil for the top 18 inches and that
any comparison with data representative of the top 6 inches will be confounded by the variability inherent
to soil concentration data, the MPI data, while informative, are essentially unusable for risk assessment
calculations. Provided that it would be acceptable to EPA Region 3 risk assessment staff, the
recommended approach for generating 6-inch-depth soil data for the HHRA and ecological risk
assessments is the ICS approach (discussed in Section 4.3.1.2). Generally, the collection of three replicate
ICS samples per DU is recommended so that reliability of the sampling methodology can be assessed.
Appropriate DU delineation is critical to the ICS approach. DUs should be defined via the SPP process
such that risk characterization objectives are achieved with the optimal number of required samples. Final
DU size determination should be based on the CSM and will require input and consideration by all
stakeholders in the SPP process.
ICS has been successfully used for a variety of constituents of interest including VOCs. After field
sampling, VOC increments are typically shipped to the analytical laboratory for compositing, collection
of the composite sample and analysis. Guidance on the application of this approach, including
recommended sample processing procedures for VOCs, is provided in a document prepared by The
Interstate Technology and Regulatory Council (ITRC) (ITRC, 2012). The document may be downloaded
from www.itrcweb.org/ism-l/pdfs/ISM-l 021512 Final.pdf).
The mean concentrations are used for comparison to regulatory threshold values and action levels or are
used in risk assessment calculations. In contrast, the conventional approach for soil characterization is to
collect and analyze discrete soil samples and calculate the appropriate statistics for risk characterization
from the analyses results. In comparison to the more conventional sampling approaches involving the
29
-------
collection of discrete samples, results from ICS applications have shown concentration data to be more
consistent, less variable and reproducible.
As was discussed for the offsite and hotspot soil characterization tasks, it is recommended that the field
team archive the ICS composite samples from selected DUs. The archived DU samples can then be
selected for PCDD and PCDF and PCB congener analyses after the ICS sample results are received and
evaluated for other constituents. Depending on the conclusions from the preliminary PCDD and PCDF
sampling (conducted during utility/MEC/MD clearance as discussed in Section 4.3.1), the appropriate
level of ICS sampling archiving (all samples versus a portion of the samples) and numbers of samples to
be submitted for PCDD and PCDF and PCB congener analyses can be determined. Specific decisions on
the numbers and selection of samples to be archived should be based on the results of the preliminary
PCDD and PCDF sampling task.
The optimization team also recommends development of decision logic or decision rules (consistent with
results of preliminary PCDD and PCDF sampling conducted as per Section 4.3.1) that can assist field
crews in determining appropriate sample numbers and locations that will be analyzed for PCDDs and
PCDFs, explosives, hexavalent chromium, grain size and asbestos.
4.3.3 GROUNDWATER INVESTIGATION
This section describes groundwater sampling activities and recommended strategies for optimizing the
characterization of Site groundwater. Section 4.3.3.1 summarizes the HGL-planned activities (HGL,
2011). Section 4.3.3.2 provides suggested changes as a result of the optimization review team's site visit,
preliminary CSM development and site data/report reviews.
4.3.3.1 HGL Planned Field Activities
The HGL planned investigation of Site groundwater includes the installation of temporary monitoring
wells, the installation of follow-up permanent monitoring wells, redevelopment of existing monitoring
wells and the collection of groundwater samples. Figure 18 shows the proposed groundwater sampling
locations.
Temporary Well InstallationMain Site Area. A total of 24 pre-pack temporary wells designated TW-
01 through TW-24 will be installed in areas where Site activities may have resulted in releases of
contamination. The locations of the 24 temporary wells are shown on Figure 18. The temporary wells will
be used to assess the overall groundwater quality and inform the placement of permanent groundwater
monitoring wells.
The temporary wells will be installed using a sonic drill rig to a depth of 8 ft below the top of the water
table. Once the desired depth is achieved, a 10-ft-long, 0.010-slotted, 2-inch diameter pre-pack
monitoring well will be installed. The well screen will be positioned across the water table with
approximately 8 ft of the well screen located below the water table.
Temporary well groundwater samples will be analyzed for TCL VOCs, TCL SVOCs, TCL pesticides and
PCBs and TAL metals. In addition, 50 percent of the samples will be analyzed for PCDDs and PCDFs,
explosives and hexavalent chromium.
Temporary Well InstallationSite Wetland Area. Four 10-ft-long, 0.010-slotted, 2-inch-diameter
temporary pre-pack monitoring wells will be installed in the Site wetlands using either a sonic drill rig or
by using a stainless steel hand auger. Samples collected from the wells will be analyzed for TCL VOCs,
TCL SVOCs, TCL pesticides and PCBs, TAL metals, explosives, hexavalent chromium, alkalinity,
30
-------
hardness, chloride, sulfide, sulfate, nitrate, nitrite, TOC, total suspended solids (TSS), total dissolved
solids (TDS), methane, ethane and ethene.
Installation of Permanent Wells. Based on the results of the temporary well groundwater contamination
screening, up to six new groundwater monitoring wells will be installed and developed. Prior to well
drilling, a UXO technician will conduct down hole clearances for MEC. A sonic drill rig will be used to
drill and install the groundwater monitoring wells.
Groundwater Sampling. All nine existing wells, six new wells and four temporary wells installed in the
Site wetlands will be sampled during the groundwater sampling event. Groundwater purging and
sampling activities will be conducted via the low-flow sampling method. A bladder pump with a
dedicated bladder will be used to pump each well. An in-line water quality meter and separate turbidity
meter will be used to collect field water quality parameter data.
Permanent well groundwater samples will be analyzed for TCL VOCs, TCL SVOCs, TCL pesticides and
PCBs, TAL metals, hexavalent chromium, alkalinity, hardness, chloride, sulfide, sulfate, nitrate, nitrite,
TOC, TSS, TDS, methane, ethane and ethene.
Well Redevelopment. The existing nine site monitoring wells (MW-1R, MW-2, MW-4, MW-5, MW-6,
MW-7, MW-8, MW-9 and MW-10) will be redeveloped. The locations of the nine wells are depicted on
Figure 18. Wells not located or determined to be compromised will not be redeveloped. If a well is
compromised or cannot be located, the EPA Remedial Project Manager (RPM) will be notified. Wells
determined to be compromised will be properly abandoned by a Commonwealth of Virginia-licensed well
driller.
4.3.3.2 Recommended Optimization Strategies
The groundwater sampling described in the HGL plan is designed to address characterization objectives
which include (1) assess groundwater quality in the potential hotspot areas identified from historical air
photo analyses (discussed in Section 2), (2) assess groundwater quality in the wetland area between the
Site and Paradise Creek, (3) generate site analytical data for an expanded analyte list and (4) expand, as
necessary, the Site groundwater monitoring well network with up to six new monitoring wells.
Consistent with the adaptive approach defined for soils, the groundwater characterization should also
consider employment of an adaptive approach, to the extent possible given the drilling/sampling
challenges presented by the ubiquitous fill layer. Also, in addition to the above objectives, as stated
previously, a significant Site characterization data gap to be addressed is the development of a more
complete understanding of Site groundwater elevations and flow directions.
The groundwater characterization approach defined in the work plan is non-adaptive in that it consists of
the installation of a select number of monitoring wells at prescribed locations. Any decision to install
follow-up wells must await the receipt of fixed base laboratory analyses results provided within the
standard turnaround time for the laboratory.
To increase the flexibility of the groundwater characterization, the following adaptive approach is
recommended. The associated field logic is shown on Figure 20. Based on discussions with EPA (Rossi
2012), EPA Region 3 may reduce the final number of temporary wells from 24 to a total of 12. Given that
12 wells will be installed, the recommended approach consists of the installation of an initial subset of
these wells (8 are proposed) with the remaining wells (four) installed based on the field data generated
from the initial wells.
31
-------
Given the 24 temporary well locations proposed in the HGL plan and an initial subset of eight wells, the
recommended adaptive approach can be implemented as follows. The proposed 24 temporary well
locations should first be prioritized based on existing information. A subset should then be selected
consisting of the eight locations judged most likely to be impacted by Site operations and to provide
information on groundwater flow directions. Consistent with the HGL plan (e.g., co-location of
subsurface soil hotspot borings with onsite temporary wells), the eight locations can be defined to
coincide with eight of the soil borings specified for hotspot soil assessment (discussed in the previous
section). The drilling program may then be structured to first investigate these initial eight locations and
then, based on the field analysis results, up to four follow-up wells can be used to step out from the initial
locations. The groundwater field analytics can include PCB IA, PAH IA, metals via Lumex (with water
attachment) and field parameters plus any supporting data from the field analysis of the soil samples
collected during the hotspot subsurface soil investigation. Based in part on an assessment of the
preliminary PCDD and PCDF surface soil sampling results obtained in accordance with Section 4.3.1, the
project team can determine the number and locations of groundwater samples that should be analyzed for
PCDD and PCDF compounds and PCB congeners via EPA Method 1668B.
The above approach requires that the project team address several specific issues during the project
planning phase, as follows:
Prioritization of the HGL-proposed 24 well locations with regard to the relative potential for Site
impact
Determination of the overall number of wells (assumed to be 12) that can be installed given
available project resources
Selection of the initial number of wells to be installed (assumed to be eight)
Selection of the wells for the collection of samples for the analysis of PCDD and PCDF
compounds and analysis of PCB congeners via EPA 1668B
Final quantification of these parameters is dependent on DQOs as defined in consultation with the project
risk assessment team and project financial constraints.
Other recommendations for the groundwater characterization include:
The depth of sample collection within the screened interval of each monitoring well should be
included in the routine field documentation for each groundwater sample. This data will be
important in general, but critically so if subsequent use of 3-D visualization and analysis
technology is ever warranted.
If temporary monitoring wells are installed, each temporary well should be constructed such that
it can be readily converted to a permanent well. The construction of each temporary well should
include the installation of filter sand and fine filter sand above the top of the well screen and the
installation of a bentonite grout seal. Conversion of a temporary well to permanent status would
then only require the addition of the appropriate surface completion.
The HGL plan calls for the installation of the four temporary wells in the Site wetland area. The
apparent objective of these wells is to characterize groundwater quality in the wetland area in
close proximity to the shoreline of Paradise Creek. It is recommended that groundwater sampling
at these locations be eliminated or considered in combination with the locations specified by HGL
for onsite temporary well installation. As discussed in the optimization evaluation of the proposed
Paradise sediment characterization, the performance of sediment pore water sampling in Paradise
32
-------
Creek is recommended to assess the groundwater to surface water pathway. It is expected that the
proposed temporary and new wells in combination with the existing monitoring well network will
likely sufficiently characterize groundwater quality near the creek shoreline as well as inform
sediment and pore water sampling locations adjacent to the Site.
Recommendations regarding the proposed analyte lists include:
The current temporary well analyte list calls for half of the wells (12) to be analyzed for dioxins
and furans. If the results obtained from the preliminary sampling for PCDD and PCDF
compounds in the initial field task (utility/MEC/MD clearance discussed in Section 4.3.1) suggest
that these compounds are not a significant concern, a further reduced groundwater sampling
scope may be considered. Dioxin and furan samples should be biased toward locations with the
highest observed soil dioxin/furan concentrations and/or along any suspected potential primary
transport pathways.
To provide data comparable to the Elizabeth River TMDL currently under development and to
develop PCB congener concentration data in groundwater for comparison to congener
composition data for Paradise Creek pore water/surface water, groundwater samples from
monitoring wells installed down gradient from the areas with elevated PCB concentrations may
be analyzed to a low method detection level via EPA Method 1668B (EPA, 2008). The PCB
congener analysis is beneficial for comparing Site PCB congeners to sediment PCB congeners for
fingerprinting purposes. For example, if the Site congener suite of PCBs poorly matches the
sediment congener suite, offsite PCB source attribution may be considered.
The permanent well analyte list includes several constituents (sulfide, nitrite, methane, ethane and
ethane) normally used to evaluate natural attenuation of chlorinated ethene compounds. It is
suggested that the analysis of these compounds only be performed if elevated concentrations of
chlorinated hydrocarbons are detected in the temporary well sampling task.
The optimization team recommends development of decision logic or decision rules (consistent
with results of preliminary PCDD and PCDF sampling conducted as per Section 4.3.1) that can
assist field crews in determining appropriate sample numbers and locations that will be analyzed
for PCDDs and PCDFs, explosives and hexavalent chromium.
4.3.4 SEDIMENT INVESTIGATION
This section describes soil sampling activities and recommended strategies for optimizing the
characterization of Site sediment. Section 4.3.4.1 summarizes the HGL-planned activities (HGL, 2011).
Section 4.3.4.2 provides suggested changes as a result of the optimization review team's site visit,
preliminary CSM development and site data/report reviews.
4.3.4.1 HGL Planned Field Activities
Western Drainage and Concrete Channel. Eight sediment samples are planned for collection from four
locations along the western drainage and two samples will be collected from one location at the outlet of
the drainage. Four sediment samples will be collected from two locations within the concrete-lined
drainage channel. The collected sediment samples will be visually inspected, field screened with a PID
and lithologically characterized. The samples will be collected from the top 0-6 inches and from the
interval from 6 inches to 2 ft below the top. All samples will be analyzed for TCL VOCs, TCL SVOCs,
TCL pesticides and PCBs, TAL metals, TOC, grain size, oxidation-reduction potential (ORP) and pH. In
33
-------
addition, 50 percent of the samples will be analyzed for hexavalent chromium, explosives, and PCDD and
PCDFs. A field instrument will be utilized to measure the sediment sample's ORP.
Site Wetlands. Eighteen sediment samples designated WLSD-01 through WLSD-18 will be collected
from the wetlands bordering Paradise Creek. The locations of the wetland sediment samples are depicted
on Figure 21. Sediment samples from the wetlands will be collected from the top 6 inches and from 6
inches to 2 ft below the top of the sediment. A decontaminated stainless steel hand auger will be used for
sample collection. The sediment samples will be visually inspected, field screened with a PID and
lithologically characterized. The sediment samples will be submitted through the Contract Laboratory
Program (CLP) to an EPA-approved laboratory for TCL VOCs, TCL SVOCs, TCL pesticides and PCBs,
TAL metals, TOC, grain size and pH analyses. In addition, 50 percent of the samples will be analyzed for
hexavalent chromium, explosives and dioxins. A field instrument will be utilized to measure the sediment
sample's oxidation-reduction potential ORP.
Paradise Creek. Twelve sediment samples designated PCSD-01 through PCSD-12 will be collected from
Paradise Creek. In general, the sediment sample locations will be dependent on areas of deposition
bordering the Site (eight locations), as well as upstream locations of the Site (two locations) and
downstream locations of the Site (two locations). The locations of the Paradise Creek sediment samples
are shown on Figure 22; however, the exact locations will be determined in the field after collecting
channel bottom depths and surface water flow measurements in order to assess flow regimes within the
creek. Samples will be collected using core samplers, hand augers, or ponar dredges from a depth of 0-6
inches below the top of the sediment. All samples will be analyzed for TCL VOCs, TCL SVOCs, TCL
pesticides and PCBs, TAL metals and TOC. Half of the samples will also be analyzed for hexavalent
chromium, explosives, PCDDs and PCDFs and grain size.
4.3.4.2 Recommended Optimization Strategies
Opportunities for optimization of the Site drainage and wetlands investigations are discussed first
followed by a discussion of optimization strategies for Paradise Creek. The drainages include the western
drainage and the northwestern (concrete-lined channel) drainage located along the boundary of the
ARREFF property and the northwestern portion of the Site.
Northwestern Drainage. Based on observations made during the February site visit, sample collection
from the concrete-lined drainage channel may be hindered by the presence of deep, standing water and
limited access, as portions of the channel are covered by concrete or pavement. Prior to sampling, a
survey of the accessible portions of the channel is recommended to identify locations of sufficient
sediment accumulation for sample collection. Up to three locations are recommended. If standing water is
present, a petit Ponar dredge may be necessary to collect samples. To provide data comparable to the
Elizabeth River TMDL currently under development and to develop PCB congener concentration data for
northwestern drainage sediment, PCB analyses of selected sediment samples can be performed at a low
method detection level using EPA Method 1668B. An approach for converting congener concentration
data to an equivalent Aroclor concentration given specific assumptions is provided in Narquis et al.
(2007). Selected samples should also be analyzed for PCDD and PCDF compounds.
The selection of sediment samples for congener analyses may be based on Aroclor analyses results. It is
recommended that all fixed-base laboratory samples be analyzed for PCB Aroclors and a portion of each
sample archived. Based on the results of the Aroclor analyses, the most elevated Aroclor samples can be
submitted for congener analysis by Method 1668B (a minimum of 3 samples is recommended).
Regarding the collection of northwestern drainage sediment samples for PCDD and PCDF analyses, the
scope of this sampling may be driven largely by the results of the preliminary PCDD and PCDF sampling
in surface soil conducted in accordance with Section 4.3.1.
34
-------
Western Drainage. To efficiently identify potential localized areas with elevated concentrations of COCs
and minimize the need for follow-up sampling rounds in the western drainage and in the site wetlands, an
adaptive sampling approach is recommended. Suggested decision logic is shown on Figure 23. An initial
field sampling and analysis event that includes the length of the western drainage and Site wetland area
would establish the optimal locations for the collection of the eight proposed fixed-base laboratory
samples to meet or exceed project DQOs for collaborative sample data. Consistent with the HGL draft
WP, two samples should be collected at the outlet of the western drainage to Paradise Creek. Field-based
analyses accomplished using XRF and, potentially, IA screening methods for PCBs and PAHs are
suggested for the field characterization of the western drainage and wetland area. To provide data
comparable to the Elizabeth River TMDL currently under development and to develop PCB congener
concentration data for western drainage sediment for comparison to congener composition data for
Paradise Creek sediments, PCB analyses of selected sediment samples should be performed at a low
method detection level using EPA Method 1668B. Selected samples should also be analyzed for PCDD
and PCDF compounds.
As was also indicated for the northwestern drainage, the selection of sediment samples for congener
analyses may be based on Aroclor analyses results. It is recommended that all fixed-base laboratory
samples be analyzed for PCB Aroclors and a portion of each sample archived. Based on the results of the
Aroclor analyses, the most elevated Aroclor samples can be submitted for analysis by Method 1668B (a
minimum of 3 samples is recommended). Regarding the collection of western drainage sediment samples
for PCDD and PCDF analyses, the scope of this sampling may be driven largely by the results of the
preliminary PCDD and PCDF sampling in surface soil conducted in accordance with Section 4.3.1.
Site Wetlands. To optimize the wetlands sediment sampling activity, it is recommended that this
sampling be conducted using ICS methodology rather than conducting the sampling at the 18 prescribed
locations in the HGL Plan. As discussed in previous sections, ICS provides an effective strategy for
estimating the mean concentration of soil constituents within a defined DU. As a result of short scale
heterogeneity in sediment, prescribed sampling results are often subject to misinterpretation. DU
boundaries and the appropriate number of soil increments will require project team and stakeholder input.
Paradise Creek. The proposed collection of 12 sediment samples from Paradise Creek is intended to
address the data gaps summarized in the HGL plan. Specifically, these data gaps include the
characterization of background sediment and surface water quality, the characterization of surface water
quality, the selection of sample locations based on local flow regime and the assessment of contaminant
bioavailability and sediment toxicity. It is suggested that the proposed sampling approach be re-evaluated
with respect to ecological risk assessment objectives. Since sediment quality in Paradise Creek is at least
partially influenced by conditions offsite, a key objective of the sediment sampling task should be the
evaluation of potential impacts of the Site on the benthic environment adjacent to the Site. The
recommended approach (consistent with elements of the Triad Approach to sediment quality assessment
[EPA, 2002a]) would, therefore, include in addition to sediment sampling, enumeration of the benthic
macroinvertebrate community and characterization of sediment pore water. This approach will provide
context for interpretation of the Paradise Creek sediment data collected near the Site and help define
potential sediment impairment directly attributable to the Site.
In summary, it is suggested that the sediment characterization approach include three components: (1) the
collection of sediment samples, (2) the enumeration of macroinvertebrate fauna and (3) the collection of
sediment pore water samples. Sediment and sediment pore water are key to determining the overall
quality of the benthic environment. Enumeration of macroinvertebrates measures species populations and
diversity as a general in situ indicator of the quality of the benthic environment. Co-location of
enumeration sampling areas with sediment and pore water sampling locations enables the evaluation of
35
-------
spatial variability of benthic quality at multiple locations along the Site's Paradise Creek shoreline. The
optimization review team recommends 8 to 10 such sampling points as a means to sufficiently
characterize the Site's shoreline using the proposed three component approach. For control purposes, two
offsite sampling points, located upstream from the Site would provide baseline conditions for comparison
to Site results. The similarity/dissimilarity of benthic enumeration and sediment and pore water quality at
the upstream control points would indicate the relative significance of Site contributions to Paradise
Creek sediment quality adjacent to the Site.
It is further recommended that a survey of the Paradise Creek channel offshore from the Site be
conducted to identify zones of preferential groundwater discharge to surface water. The results of the
survey may be useful in identifying potential groundwater contaminant migration pathways. Aerial or
camera-based thermal infrared imagery alone or in combination with a survey of temperature and specific
conductivity differentials in pore water can be used to identify preferential groundwater discharge zones.
Examples of the application of thermal imaging to identify groundwater discharge zones in surface water
are provided on the EPA Clu-In site at www.clu-in.org/download/contaminantfocus/sediments/GW-to-
SW.pdf The optimization team is aware of least one other Superfund site in Region 3 where application
of infrared imagery is planned to assist the project team in locating and evaluating groundwater discharge
zones in surface water bodies. Additional information is available upon request.
Additional sediment characterization concerns include the characterization of PCB concentrations at
sufficiently low method detection levels for comparison to the Elizabeth River TMDL under
development, the identification of specific PCB congeners for comparison to PCB congener analyses
from onsite environmental media samples and the characterization of PCDD and PCDF compounds.
Although homologue (MPI, 2008) and congener (Unger et al., 2005) data exist for the sediments, the
homologue results are mostly non-detect and are reported at elevated detection levels. In addition,
laboratory QC data are unavailable for the congener results. A subset of the sediment samples
(approximately 20 percent), therefore, should be analyzed using EPA Method 1668B at a low detection
level for PCB congeners in sediment samples for TMDL comparison purposes. In addition, in a limited
subset of these samples, analyses of PCB congeners should also be performed to assist in potential
"fingerprinting" of Paradise Creek PCB contamination to Site sources. As noted above, an approach for
converting congener concentration data to an equivalent Aroclor concentration given specific assumptions
is provided in by Narquis et al. (2007). Regarding the collection of Paradise Creek sediment samples for
PCDD and PCDF analyses, the scope of this sampling may be driven largely by the results of the
preliminary PCDD and PCDF sampling in surface soil conducted in accordance with Section 4.3.1.
4.3.5 SURFACE WATER INVESTIGATION
This section describes soil sampling activities and recommended strategies for optimizing the
characterization of Site surface water. Section 4.3.5.1 summarizes the HGL-planned activities (HGL,
2011). Section 4.3.5.2 provides suggested changes as a result of the optimization review team's site visit,
preliminary CSM development and site data/report reviews.
4.3.5.1 HGL Planned Field Activities
Western and Northwestern Drainages. The HGL draft sampling plan includes collection of five surface
water samples. The samples will be co-located with the five sediment samples planned for Western and
Northwestern drainages (Figure 21). The surface water samples will be collected if surface water is
present during the field investigation. The samples will be collected utilizing hand dipping techniques if
the drainage is accessible and shallow or utilizing a remote sampling devise such as a dipper or discrete
water sampler if access to the drainage channel is a health and safety concern and/or the surface water
body is deeper than 1 ft. Site drainage surface water samples will be analyzed for TCL VOCs, TCL
36
-------
SVOCs, TCL pesticides and PCBs and TAL metals. Approximately half of the samples will also be
analyzed for PCDDs and PCDFs, hexavalent chromium and explosives.
Site Wetlands. Ten surface water samples designated WLSW-01 through WLSW-10 will be collected
from the Site wetlands. Four of the wetland surface water samples will be collected from four of the
wetland sediment sample locations. The remaining six surface water wetland samples will be collected
from seep locations along the Paradise Creek shoreline during low tide. Surface water samples will only
be collected if surface water is present. Hand dipping techniques will be employed if the drainage is
accessible and shallow; otherwise, a remote sampling device such as a dipper or discrete water sampler
will be utilized. Site wetlands surface water samples will be analyzed for TCL VOCs, TCL SVOCs, TCL
pesticides and PCBs and TAL metals. Approximately half of the samples will also be analyzed for
PCDDs and PCDFs, hexavalent chromium and explosives.
Paradise Creek. Twelve surface water samples designated PCSW-01 through PCSW-12 will be collected
from Paradise Creek. The locations of the surface water samples are shown on Figure 22; however, the
exact locations of the samples will be determined in the field and based on observed surface
water/groundwater discharges and primary surface water flow paths through Paradise Creek. Paradise
Creek surface water samples will be analyzed for TCL VOCs, TCL SVOCs, TCL pesticides and PCBs,
TAL metals, alkalinity, hardness, chloride, sulfide, sulfate, nitrite and nitrate. Approximately half of the
samples will also be analyzed for PCDDs and PCDFs, hexavalent chromium and explosives.
4.3.5.2 Recommended Optimization Strategies
It is recommended that surface water sample collection efforts be coordinated with the collection of
sediment samples and collection locations should coincide with the sediment characterization locations.
With regard to sample quantities and placement, the same recommended strategies apply as are provided
for sediments (see Section 4.3.4). With regard to surface water sample analyses, the following suggestions
are offered:
As discussed previously, since PCDDs and PCDFs are relatively immobile, sampling of these
constituents in surface water should be contingent on the results obtained from the preliminary
PCDD and PCDF soil sampling event conducted in accordance with Section 4.3.1.
EPA Method 1668B should be used for PCB analyses to ensure that results are reported to the
lowest possible method detection level. In addition, since an aggregate PCB concentration is
necessary for comparison to the RSL, analyses results can be reported as the sum of individual
PCB homologue concentrations. As noted previously, an approach for converting congener
concentration data to an equivalent Aroclor concentration given specific assumptions is provided
in by Narquis et al. (2007).
4.3.6 SEQUENCING OF FIELD ACTIVITIES
Sequencing of field activities is a critical element of any dynamic or adaptive sampling approach as each
activity can greatly inform subsequent sampling locations and frequencies. The field investigation will
include the identification and mapping of buried utilities at the Site and the collection of soil,
groundwater, sediment and surface water data. Following utility identification, the progression of major
field tasks is recommended as follows:
37
-------
Preliminary ICS Surface Soil sampling for PCDD and PCDF Compounds. This sampling is
proposed to occur as early as possible during the field effort, preferably during the buried utility
delineation task (Section 4.3.1). Results of the sampling will provide the opportunity to optimize
selected locations for a subset of sample analyses for PCB congener and PCDD/PCDF analyses
as well as inform planned sampling in other media (subsurface soil, groundwater, surface water,
sediments)
Survey for off-site extraction wells. A review of municipal and/or state-maintained well permit
databases should be performed to identify, to the extent possible, the extraction wells located in
the vicinity of the Site. The results of the permit database review should be field verified with
specific attention given to identifying the cause of the low groundwater levels observed in the
northeastern portion of the Site. This survey will assist in the identification of locations for
permanent monitoring well installation.
Comprehensive Site wide ICS Surface Soil Sampling for Risk Assessment. This soil sampling
will be conducted to support site human health and ecological risk determinations. The
preliminary ICS surface soil sampling for PCDD and PCDF compounds will be used to calibrate
the level of sampling for these constituents that is appropriate for the comprehensive site wide
ICS sampling event.
Soil sampling to evaluate potential offsite contamination and to characterize hotspots;
groundwater characterization through the installation of temporary monitoring wells. These
tasks involve boring construction via sonic methods and will require the services of a licensed
drilling subcontractor. Conducting these tasks simultaneously will allow efficient staging of
drilling operations to avoid drilling rig idle time. These results will be used to characterize
subsurface soil and fill material on site as well as inform placement of permanent wells.
Installation of permanent monitoring wells. This task will require the services of a licensed
drilling subcontractor and should be coordinated to coincide with the soil boring and temporary
well installation tasks discussed in the previous bullet.
Northwestern and western drainage ditch sediment and surface water sampling. Sampling
from the northwestern drainage and adaptive sampling from the western drainage will be
conducted. These tasks can be coordinated with the other non-drilling tasks.
ICS Wetland Sediment Sampling. ICS sampling of Site surface soil and ICS sampling of
Paradise Creek wetland sediments can be coordinated with the other non-drilling tasks.
Paradise Creek groundwater discharge survey. A survey to identify groundwater seeps and
zones of preferential groundwater discharge to Paradise Creek channel offshore from the Site
should be conducted prior to performing sediment characterization sampling in the creek.
Paradise Creek sediment and surface water sampling. The sediment and sediment pore water
and benthic enumeration sampling can be conducted independent of the other tasks.
38
-------
5.0 FINDINGS
The observations provided below are the interpretations of the optimization review team based on
historical information and data review, a site visit conducted February 22, 2012 and SPP conducted with
project technical team members and stakeholders in a meeting prior to the site visit. The observations are
not intended to imply a deficiency in any previous characterization work or the draft HGL RI work plan
but are offered as observations that provide context for constructive suggestions provided in Sections 4
and 6 of this document. The optimization review team believes the suggestions offered are in the best
interest of EPA Region 3 and project stakeholders including the public.
Findings regarding the Site include the following:
The Site is bordered by active industrial facilities all situated up-slope topographically from the
Site. Surface water and sediment runoff from the adjacent upslope portions of the U.S. Navy,
Sherwin Williams, ARREFF and the SPS-RDF facility properties drain on to the PIM Site
property. Site surface water, soil and sediment therefore, may be impacted by these potential
offsite contamination sources. In addition to recognizing the potential for contaminant migration
from the PIM site to nearby properties, the recommended sampling also seeks to evaluate the
potential for off-site contaminants to be transported to the PIM site via surface water features and
topographically up gradient properties.
During the February site visit, the optimization review team observed continued human use of the
Site for various ad hoc purposes that may result in the release of additional contamination and/or
expose individuals to known contamination at the Site. A portion of the Site appears to be
currently used by a contractor for equipment/material staging and equipment repair. The contents
of the buildings present in the northwestern portion of the Site include various personal vehicles,
tools, material storage drums and children's bicycles.
Extensive portions of the Site are underlain by various types of fill that can attain apparent
thicknesses exceeding 10 ft. The fill appears to consist of soil mixed with various forms of rubble
(wood, concrete, asphalt, glass) and metal scraps. Fill materials observed across much of the
southern portions of the Site can present challenges for not only drilling technologies, but sample
collection and homogenization strategies. Proposed standard operating procedures (SOP) should
provide clear direction to the project team as to how sample collection and homogenization will
address this unique matrix.
Based on groundwater level data from the previous site investigations, groundwater flows to the
northeast and to the southwest from a local high groundwater elevation measured at MW-4 (7.46
ft above msl), located in the central portion of the Site. Southwestward groundwater flow from
the mound is toward Paradise Creek at an average rate of 20 ft/year (MPI, 2008). It should be
noted that this apparent groundwater mound is visually correlated with historical impoundment
and surface features identified in the EPA aerial photography review (HGL 2011) and identified
in Figure 2. Lower groundwater elevations in the eastern portion of the Site may partially result
from groundwater drainage to City storm drainage ditches and piping that border the northern and
eastern boundaries of the Site. The presence of water levels below mean sea level (NAVD88)
suggests the existence of offsite groundwater pumping that may influence site groundwater
transport. Water and sewer services are readily accessible to the properties bordering Elm Avenue
39
-------
in the Site vicinity. The City of Portsmouth indicates that if such service is available, private
wells are not typically used as sources for potable water supply. An inventory of wells in the Site
vicinity was not identified in the documents reviewed or performed for this study. It is
recommended that the project team develop a groundwater supply well inventory for the PIM Site
vicinity.
Elevated PCB concentrations are present in Site soil. Several areas, particularly in the central and
east-central portion of the Site, exceed 1000 xthe RSL for Aroclor 1221 and 1232 (540 mg/kg).
In the available Site characterization data, PCB analyses of onsite soil and Paradise Creek
sediments have been inconsistent in that Aroclors have been analyzed in Site soils while
homologues and congeners have been analyzed in Paradise Creek sediments. PCBs expressed as
equivalent Aroclor concentrations are required for Region 3 risk evaluations while PCBs
expressed as congener concentrations are required for fate and transport considerations. To the
extent possible, suggestions provided in this document seek to leverage both types of PCB data to
meet DQOs for risk evaluations as well as provide data for fingerprinting and fate/transport
evaluations.
Elevated metals concentrations are present in Site soil. Lead concentrations exceed 800 mg/kg
(lead RSL for industrial soil) over broad areas and in isolated areas distributed in the east and
central portions of the Site, lead exceeds 8,000 mg/kg. The available monitoring wells installed
near and down gradient from the elevated metals areas, however, exhibit relatively low metals
concentrations. The contrast between metals concentrations in Site soil and subjacent
groundwater suggests that a low capacity exists for soils to leach metals to groundwater.
A TMDL for PCBs is in development for the Elizabeth River Watershed and is scheduled to be
issued in 2014. Evaluation of Site PCB concentrations will require analyses at a method of
detection level that is less than the TMDL. The Elizabeth River PCB TMDL could potentially be
identified as a future ARAR or influence future PCB analytical technique considerations for the
Site.
40
-------
6.0 RECOMMENDATIONS
The purpose of this review is to evaluate Site conditions and identify opportunities to optimize the
planned RI at the Site. Recommendations for specific RI tasks were presented in Section 4.3. This section
lists the recommendations that transcend individual tasks and are applicable to the RI in general. Note that
while the recommendations provide some details to consider during implementation, they are not meant
to replace the HGL plan or other more comprehensive planning documents.
Access to the Site should be limited to authorized individuals and entities only. Any currently
existing unauthorized use of Site buildings or grounds should be curtailed. As a result of
structural integrity issues and potential contamination concerns, all use of the Site buildings
should also be terminated and each building should be secured such that any future unauthorized
entry is prevented.
Development of a fill isopach map showing the estimated distribution, thickness and general
composition of fill at the PIM Site is recommended. Information sources for preparation of the
map can include site boring logs, surface mapping and historical aerial photographs.
In recognition of the hazards posed by MEC/MD, a trained UXO technician should be present
during drilling operations. A protocol should be developed by UXO staff for conducting down-
hole magnetometer screening incrementally during borehole advancement through the fill layer.
It is recommended that the RI be structured so that data collection for each environmental media
follows an adaptive sampling strategy. Low cost, rapid turnaround field analyses can be more
fully employed to identify the priority sampling locations for fixed-base laboratory analyses. An
adaptive framework utilizing decision logic or decision rules should drive the selection of
sampling locations for fixed-base laboratory soil, groundwater and sediment sample collection.
It is also recommended that DMAs be conducted for field-based analysis technologies under
consideration for deployment in the field investigation. A discussion of DMA design
fundamentals and associated case studies are available in the EPA publication: Demonstrations
of Method Applicability under a Triad Approach for Site Assessment and CleanupTechnology
Bulletin, August 2008, available from www.clu-in.org/download/char/
demonstrations of methods applicability.pdf. Additionally, OSRTI is available upon request to
provide technical assistance in the design and implementation of a DMA for XRF or any other
real time, field screening technology that might be considered by Region 3 for the PIM Site RI.
It is suggested that temporary well installation and permanent well installation tasks be merged by
constructing each temporary well in a manner that will allow it to be finished as a permanent
well. Doing this will avoid redundancy between the well installation tasks and reduce the number
of attempts to achieve effective monitoring well placement in thick, irregular fill terrain.
A preliminary, ICS-based soil sampling event (coinciding with the MEC/MD survey) should be
considered for sampling the Site areas with the most elevated PCB concentrations for PCDDs and
PCDFs. The decision to carry these constituents forward for additional soil investigation and in
the investigation of other media can be based on the results of this initial sampling.
41
-------
Given that two, fairly extensive sediment sampling events have been conducted in Paradise Creek
adjacent to the Site, one that included the analyses of PCB congeners and PAHs and the other that
included the analysis of PCB homologues and seven metals, consideration should be given to
defining the Paradise Creek sediment characterization task objective to be the estimation of
specific impacts to the benthic environment directly attributable to the Site. Toward this end, the
RI Team should consider the performance of benthic enumeration, sediment pore water sampling
and sediment sampling at several locations both adjacent to and upstream from the Site.
As a recommended precursor activity to conducting benthic enumeration, pore water sampling
and sediment sampling, a groundwater discharge survey of the Paradise Creek channel offshore
from the Site should be performed. It is recommended that aforementioned sediment
characterization activities include any identified zones of preferential groundwater discharge
identified by the survey. Thermal infrared or forward looking infrared imagery (FLIR) alone or in
combination with a survey of temperature, specific conductivity differentials and water quality in
pore water, and groundwater/surface water head elevations within the stream channel, can be
used to identify preferential groundwater discharge zones. In addition, three dimensional
visualization analysis of hydrogeologic parameters such as relative hydraulic conductivity and
porosity is also a tool that can greatly inform any evaluation of the presence or absence and
location of potential groundwater discharge zones in Paradise creek adjacent to the PIM site.
A review of municipal and/or state-maintained well permit databases should be performed to
identify, to the extent possible, the extraction wells located in the vicinity of the Site. The results
of the permit database review may help to understand groundwater flow directions and the cause
of the low groundwater levels observed in the northeastern portion of the Site.
Selected soil, groundwater, surface water and sediment samples (onsite drainages and Paradise
Creek sediments) should be targeted for low level PCB congener analyses via EPA Method
1668B. The congener analyses will allow comparison of the PCB congeners present in Site soil to
those present in Paradise Creek, thus providing an indication of the potential significance of the
Site as a contributing source of PCB contamination in Paradise Creek sediment. In addition,
Method 1668B will yield Paradise Creek sediment concentration results with detection levels
comparable with the upcoming TMDL.
42
-------
APPENDIX A
References
CH2MHILL, Baker, Inc. and CDM Inc., Phase II Remedial Investigation and Human Health Risk
Assessment Operable Unit 1, Scott Center Landfill, Norfolk Naval Shipyard, Portsmouth,
Virginia. October 2001. Excerpt. 12pp.
Draper Aden Associates, May 28, 2003 letter from Stephen G. Werner (Draper Aden Associates) to Mr.
James Bernard (VDEQ), Subject: Site CharacterizationRisk Assessment Report.
Draper Aden Associates, November 7, 2003 letter from Stephen G. Werner (Draper Aden Associates) to
Mr. James Bernard (VDEQ), Subject: Site Characterization Addendum.
Draper Aden Associates, May 11, 2004 letter from Stephen G. Werner (Draper Aden Associates) to Mr.
Donald S. Welsh (EPA), Subject: Self-Implementing PCB Cleanup Plan.
Draper Aden Associates, October 22, 2004 letter from Stephen G. Werner (Draper Aden Associates) to
Mr. Donald S. Welsh (EPA), Subject: Self-Implementing PCB Cleanup Plan.
Draper Aden Associates, 2005, Sheet A-l: PCB Soil Sampling Results, February-May 2005, 50 x 50 ft
Grid, 0-18-inch Depth, Pull-A-Part, Inc. VRP Site, Elm Ave., Portsmouth, VA (Stand-alone map
of PCB concentrations for 0-18-inch depth; a second stand-alone map [Sheet B] presented PCB
concentrations distributed over the same grid for the 18-36-inch depth).
Harsh, J.F. and Laczniak, R.J., 1990, conceptualization and analysis of ground-water flow system in the
Coastal Plain of Virginia and adjacent parts of Maryland and North Carolina: U.S. Geological
Survey Professional Paper 1404-F, 100 pp.
Hatcher-Sayre, Inc., July 29, 1999 letter from Todd A. LaMaskin (Hatcher-Sayre, Inc.) and Roger F.
Hatcher (Hatcher-Sayre, Inc.) to Mr. Butch Webber and Mr. B. David Peck, Subject: Site
Investigation Results.
Hydrogeologic, Inc. 2011. Site Management Plan, Remedial Investigation/Feasibility Study, Peck Iron
and Metal, Portsmouth, Norfolk County, Virginia, Prepared for U.S. Environmental Protection
Agency Region 3, December 2011.
Interstate Technology & Regulatory Council, 2012. Technical and Regulatory Guidance, Incremental
Composite Sampling, February 2012.
Kresic, N. 2008. Hydrogeology and Groundwater Modeling, CRC Press, 807 pp.
Malcolm Pirnie, Inc., 2007. Final Response Action Plan, Peck Iron and Metal Site, 3850 Elm Avenue,
Portsmouth, Virginia, prepared for the Peck Company, Inc., March 23, 2007.
Malcolm Pirnie, Inc., 2007. Quality Assurance Project Plan, prepared for the Peck Iron and Metal Site,
March 2007.
Malcolm Pirnie, Inc., 2007. Field Sampling Plan, prepared for Peck Iron and Metal Site, March 2007.
43
-------
Malcolm Pirnie, Inc., 2008. Draft Extent of Contamination Study Report, Pursuant to January 2007
Administrative Order for Removal Response Action, Docket No. CERC-03-2007-0075DC, Peck
Iron and Metal Site, 3850 Elm Avenue, Portsmouth, Virginia. Prepared for the Peck Company,
Inc., JSP Land Company, Inc., Peck-Portsmouth Recycling Company, Inc. and ELM Leasing
Company, Inc., October 24, 2008.
McFarland, E.R., 1998. Design, Revisions and Considerations for Continued Use of a Ground-Water-
Flow Model of the Coastal Plain Aquifer System in Virginia, WRIR 98-4085
http://va. water .usgs.gov/online jubs/WRIR/98-4085/g-wfmcpasys_va.html
Meng, A. A., Ill and Harsh, J.F., 1988, Hydrogeologic framework of the Virginia Coastal Plain: U.S.
Geological Survey Professional Paper 1404-C, 32 p.
Narquis, C.T., Hyatt, J.E. and Prignano, A.L., 2007. Generating the Right Data: Determination of
Aroclors Versus PCB Congeners, Fluor Government Group. Prepared for the U.S. Department of
Energy, November 2007.
Rossi, D., 2012. Verbal communication, US EPA Region 3 Remedial Project Manager, June 27, 2012.
Unger, M.A., Vadas, G.G., Harvey, E., Rieger, J., 2005. Concentrations of Polychlorinated Biphenyls
(PCB) and Polycyclic Aromatic Hydrocarbons (PAH) in Sediment Samples from Paradise Creek,
a Tributary to the Elizabeth River in Virginia. Department of Environmental and Aquatic Health,
the College of William and Mary, January 2005.
U.S. Environmental Protection Agency, undated. Region III BTAG Draft Screening Level Tables
available at the following web address:
http://nepis.epa.gov/Exe/ZyNET.exe/910087UH.TXT?ZyActionD=ZyDocument&Client=EPA&I
ndex= 1995+Thru+1999&Docs=&Query=FNAME%3D910087UH.TXT%20or%20(%20BTAG%
20or%20flora%20and%20fauna%20or%20values)&Time=&EndTime=&SearchMethod=l&Toc
Restrict=n&Toc=&TocEntrv=&OField=&OFieldYear=&OFieldMonth=&OFieldDav=&UseOFi
eld=&IntQFieldOp=l&ExtQFieldOp=l&XmlQuerv=&File=D%3A%5Czvfiles%5CIndex%20Da
ta%5C95thru99%5CTxt%5C00000025%5C910087UH.txt&User=ANONYMOUS&Password=a
nonymous&SortMethod=h%7C-
&MaximumDocuments=10&FuzzvDegree=0&ImageOualitv=r75g8/r75g8/xl50yl50gl6/i425&
Displav=p%7Cf&DefSeekPage=x&SearchBack=ZvActionL&Back=ZyActionS&BackDesc=Res
ults%20page&MaximumPages= 1 &ZvEntrv= 1 &SeekPage=x&ZvPURL#
U.S. Environmental Protection Agency, 2002. Office of Solid Waste and Emergency Response Draft
Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils
(Subsurface Vapor Intrusion Guidance), EPA 530-D-02-0004, November 2002.
U.S. Environmental Protection Agency, 2002a. A Guidance Manual to Support the Assessment of
Contaminated Sediments in Freshwater Ecosystems, Volume IIIInterpretation of the Results of
Sediment Quality Investigations, EPA 905-802-001-C, December 2002.
U.S. Environmental Protection Agency, 2003. Guidance for Developing Ecological Soil Screening
Levels, OSWER Directive 9285.7-55, November 2003.
U.S. Environmental Protection Agency Region 3, 2009. HRS Documentation Record, Peck Iron and
Metal, Virginia.
44
-------
U.S. Environmental Protection Agency, 2008. Demonstrations of Method Applicability under a Triad
Approach for Site Assessment and CleanupTechnology Bulletin, August 2008, Office of Solid
Waste and Emergency Response, EPA 542-F-08-006.
U.S. Environmental Protection Agency, 2008a. Method 1668B Chlorinated Biphenyl Congeners in
Water, Soil, Sediment, Biosolids and Tissue by HRGC/HRMS, November 2008.
U.S. Environmental Protection Agency, 2009. Statistical Analysis of Groundwater Monitoring Data at
RCRA Facilities, Unified Guidance, March 2009. EPA 530-R-09-007.
U.S. Environmental Protection Agency, 2012. EPA's Reanalysis of Key Issues Related to Dioxin
Toxicity and Response to NAS Comments, Volume 1, EPA 600-R-10-038F
www.epa. gov/iris/supdocs/dioxinv 1 sup .pdf.
Virginia Department of Environmental Quality, 2009. Memorandum from Ellen Gilinsky to Regional
Directors. Subject: TMDL Guidance Memo No. 09-2001. Guidance for monitoring of point
sources for TMDL development using low-level PCB method 1668, March 6, 2009.
Virginia Department of Environmental Quality, 2012. Draft 2012 305(b)/303(d) Water Quality
Assessment Integrated Report (Integrated Report), March 26, 2012.
45
-------
TABLES
-------
Table 1. Soil Sampling Analytical Parameters and Potential Screening Values Reported in HGL (2011) and Recommended Updated Values Where Appropriate
(Shading denotes a value that could not be verified in USEPA-published tables)
Analyte
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Aroclor 1262
Aroclor 1268
Total PCBs
Arsenic
Cadmium
Chromium
Lead
Mercury
Nickel
Silver
EPA Residential RSL (mg/kg) June
2011(1)
HGL RI/FS Site Management Plan,
2011
0.39
0.14
0.14
0.22
0.22
0.11
0.22
0.22 (as PCBs)
0.22 (as PCBs)
-
0.39
7
0.29 (as Chromium VI)
400131
0.78 (methyl mercury)
150
39
EPA Residential RSL (mg/kg)
April 2012(1)
Values Identified during this
report
0.39
0.14
0.14
0.22
0.22
0.22
0.22
-
0.39
7
0.29 (as Chromium VI)
400131
0.78 (methyl mercury)
150
39
Region 3 Ecological SSL (mg/kg)(2)
-
-
-
-
-
-
-
-
-
0.1
18
0.36
26
11
0.058
38
4.2
(1) Noncarcinogenic RSLs based on hazard quotient of 0.1.
(2) The lowest value from the EPA Region 3 Ecological SSLs derived for plant, soil invertebrate, avian, or mammalian receptors;
where this value is not available, the lower of the Region 3 BTAG soil screening level for flora or fauna has been used.
(3) EPA recommended value for residential soils (www.epa.gov/reg3hwmd/risk/human/rb-concentration_table/Generic_Tables/index.htm)
PCB = polychlorinated biphenyl
RSL = Regional Screening Level
mg/kg = milligrams per kilogram
Updated April 2012 EPA RSLs are available.
This table was generated in part from December 2011 RI/FS Site Management Plan by HGL
-------
Table 2. Groundwater Sampling Analytical Parameters and Potential Screening Values Reported in HGL (2011) and Recommended Updated Values Where Appropriate
(Shading denotes a value that could not be verified in USEPA-published tables)
Analyte
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Aroclor 1262
Aroclor 1268
Total PCBs
Arsenic
Cadmium
Chromium
Lead
Mercury
Nickel
Silver
EPA MCL (ng/L) EPA MCL (ng/L)
HGL RI/FS Site Values Identified during
Management Plan, 2011 this report
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
NA
10 10
5 5
100 100
15 15
2 (mercury compounds) 2 (mercury compounds)
-
-
EPA Tap Water RSL (ng/L) June EPA Tap Water RSL (ng/L)
2011 (1) April 2012 (1)
HGL RI/FS Site Management Values Identified during this
Plan, 2011 report
0.26 0.96
0.0068 0.0043
0.0068 0.0043
0.034 0.034
0.034 0.034
0.034 0.034
0.034 0.034
0.17 (PCBs)
0.17 (PCBs)
-
0.045 0.045
1.8 0.69
0.043 (Chromium VI) 0.031 (Chromium VI)
-
0.37 (methyl mercury) 0.16 (methyl mercury)
73 30
510 7.1
Region 3 Ecological Region 3 Ecological
Freshwater SSL (ng/L) (2) Freshwater SSL (ng/L) (2)
HGL RI/FS Site Values Identified during this
Management Plan, 2011 report
0.00074 0.00074
0.00074 0.00074
0.00074 0.00074
0.00074 0.00074
0.00074 0.00074
0.00074 0.00074
0.00074 0.00074
0.00074 0.00074
31 (Arsenic V) 31 (Arsenic V)
2.5131 2.5131
110 (Chromium VI) |3' 110 (Chromium VI) |3'
25 (31 25(3)
0.04 (methyl mercury) 0.04 (methyl mercury)
52 (3) 520 (3)
32 (3) 32 (3)
(1) EPA Region 3 Tap Water Noncarcinogenic RBCs based on hazard quotient of 0.1.
(2) Region 3 Freshwater Screening Benchmark multiplied by a dilution factor of 10.
(3) Value corresponds to a hardness = 100 mg/L
MCL = Maximum Contaminant Level
PCB = polychlorinated biphenyl
RSL= Regional Screening Level
u.g/L = micrograms per liter
Updated April 2012 EPA Region 3 Tap Water RBCs are available.
This table was generated in part from December 2011 RI/FS Site Management Plan by HGL
-------
Tables. Surface Water Sampling Analytical Parameters and Potential Screening Values Reported in HGL (2011) and Recommended Updated Values Where Appropriate
(Shading denotes a value that could not be verified in USEPA-published tables)
Analyte
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Aroclor 1262
Aroclor 1268
Total PCBs
Arsenic
Cadmium
Chromium
Lead
Mercury
Nickel
Silver
EPA MCL (ug/L) EPA MCL (ug/L)
HGL RI/FS Site Values Identified during
Management Plan, 2011 this report
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
NA
10 10
5 5
100 100
15 15
2 (mercury compounds) 2 (mercury compounds)
EPA Tap Water RSL (ug/L) June 2011 EPA Tap Water RSL (ug/L)
(1) April 2012 (1)
HGL RI/FS Site Management Plan, Values Identified during this
2011 report
0.26 0.96
0.0068 0.0043
0.0068 0.0043
0.034 0.034
0.034 0.034
0.034 0.034
0.034 0.034
0.17 (PCBs)
0.17 (PCBs)
0.045 0.045
1.8 0.69
0.043 (Chromium VI) 0.031 (Chromium VI)
0.37 (methyl mercury) 0.16 (methyl mercury)
73 30
510 7.1
Region 3 Ecological Region 3 Ecological
Freshwater SSL (ug/L) (2) Freshwater SSL (ug/L) (2)
HGL RI/FS Site Values Identified during this
Management Plan, 2011 report
0.000074 0.000074
0.000074 0.000074
0.000074 0.000074
0.000074 0.000074
0.000074 0.000074
0.000074 0.000074
0.000074 0.000074
0.000074 0.000074
3. 1 (Arsenic V) 3. 1 (Arsenic V)
0.25 |31 0.25 |31
11 (Chromium VI) |3' 11 (Chromium VI) |3'
2.5 |3' 2.5 |3'
0.004 (methyl mercury) 0.004 (methyl mercury)
5 2 (3) 52(3)
3.2 |31 3.2 |31
(1) EPA Region 3 Tap Water Noncarcinogenic RBCs based on hazard quotient of 0.1.
(2) Region 3 Freshwater Screening Benchmark
(3) Value corresponds to a hardness = 100 mg/L
MCL = Maximum Contaminant Level
PCB = polychlorinated biphenyl
RSL = Regional Screening Level
u.g/L = micrograms per liter
Updated April 2012 EPA Region 3 Tap Water RBCs are available.
This table was generated in part from December 2011 RI/FS Site Management Plan by HGL
-------
Table 4. Sediment Sampling Analytical Parameters and Potential Screening Values Reported in HGL (2011) and Recommended Updated Values Where Appropriate
(Shading denotes a value that could not be verified in USEPA-published tables)
Analyte
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Aroclor 1262
Aroclor 1268
Total PCBs
Arsenic
Cadmium
Chromium
Lead
Mercury
Nickel
Silver
EPA Residential RSL (mg/kg) June
2011 (1)
HGL RI/FSSite Management
Plan, 2011
0.39
0.14
0.14
0.22
0.22
0.11
0.22
0.22 (as PCBs)
0.22 (as PCBs)
-
0.39
7
0.29 (Chromium VI)
400 |3>
0.78 (methyl mercury)
150
39
EPA Residential RSL (mg/kg) April
2012 (1)
Values Identified during this report
0.39
0.14
0.14
0.22
0.22
0.22
0.22
-
-
-
0.39
7
0.29 (as Chromium VI)
400131
0.78 (methyl mercury)
150
39
Region 3 Ecological SLL (mg/kg)
(2)
-
-
-
-
0.0598
9.8
0.99
43.4
35.8
0.18
22.7
1
(1) Noncarcinogenic RSLs based on hazard quotient of 0.1.
(2) EPA Region 3 freshwater sediment benchmarks dated August 2006
(3) EPA recommended value for residential soils (www.epa.gov/reg3hwmd/risk/human/rb-concentration_table/Generic_Tables/index.htm)
Updated April 2012 EPA RSLs are available.
This table was generated in part from December 2011 RI/FS Site Management Plan by HGL
-------
Tables
Summary of Optimization Recommendations for Each of the Field Sampling Tasks Presented in the Hydrogeologic, Inc. {HGL) Work Plan (Plan)
Page 1 of 4
Optimization Report
Section and Title
4.3.1
Munitions and Explosives
of Concern/Munitions
Debris (MEC/MD)
Avoi ancean Uti ity
4.3.2
Soil Investigation
HGL Plan Defined Task
Priorto remedial investigation (Rl) field events,
MEC/MD avoidance and utility clearance will be
conducted by trained MEC/MD technicians in areas
of planned investigative work. The planned
strategy for each drilling location (to be supervised
by a MEC/MD technician) is to perform visual
surveys, advancement of borings to 2 to 6 feet
below ground surface (BGS) by hand augering and
use of a magnetometer to detect buried metallic or
magnetically susceptible objects.
Assessment of potential offsite contamination will
be conducted by installing 23 soil borings offsite
using a sonic drill rig for field-based XRF lead
screening and sampling for fixed-base laboratory
analyses. Sampling will be performed atthe
following depths: Oto 6 inches, 6 inches to 2 ft, 3
to5ft, and 6to8ft BGS.
Hotspot evaluation will be conducted by installing
11 borings in areas of known potential impacts
onsite utilizing a sonic drill. Two borings will be
installed offsite on the ARREFF property. In
addition, hotspot soil sampling will be conducted in
18 of the temporary monitoring wells installed in
accordance with Section 4.3.3. Sampling will be
performed atthe following depths: Oto 6 inches, 6
inches to 2 ft, 4 to 6 ft, and 8 to 10ft BGS.
Malcolm Pirnie (MPI) confirmatory sampling will be
conducted by re-sampling ten percent (55) of the
555 soil borings completed during the 2008 MPI
investigation. Sampling will be performed atthe
following depths: Oto 6 inches, 6 inches to 2 ft, 4
to 6ft, and 8 to 10ft BGS.
Media Sampled and Numbers of
Samples
Soil
Soil - 92 samples
Soil - 52 samples
Soil -220 samples
Analytes for Each Media1
MEC/MD
All samples: field X ray
fluorescence (XRF) screening
laboratory target a nalyte list (TAL)
Zero to 0.5 ft and 0.5 to 2 ft
samples: fixed-base laboratory
target compound list (TCL) PCBs
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/ PCBs, TAL metals,
TOC.
50% of samples will be analyzed
for dioxins and furans, explosives,
chromium VI, grain size and
asbestos.
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/PCBs, TAL metals,
TOC.
50% of samples will be analyzed
for dioxins and furans, explosives,
chromium VI, grain size and
asbestos.
Optimization Report Recommendations
A MEC/MD technician should be present during all drilling operations in fill areas and a protocol should
be developed for conducting downhole magnetometer screening incrementally during borehole
advancement through the fill layer. Initial, pre-intrusive Rl activities should focus on the location and
mapping of buried utilities with UXO surveying provided to the extent necessary for support of utility
clearance.
An additional task recommended to be performed in conjunction with the MEC/MD avoidance and utility
clearance task is a preliminary screening sampling for polychlorinated dibenzo-p-dioxins/polychlorinated
dibenzofurans (PCDD/PCDF) in Site areas where the maximum PCB concentrations are observed in
surface and subsurface soil. Using the established grid system for the Site and an ICS sampling approach,
it is recommended that a minimum of 8 to 10 grid cells be selected for sampling. The PCB hotspots likely
coincide with maximum PCDD/PCDF concentration locations. The objective of the preliminary
PCDD/PCDF sampling is calibration of PCDD/PCDF sampling to a level appropriate for the occurrence and
concentration levels of these compounds.
For the offsite and hotspot soil characterization tasks, a more adaptive approach is recommended.
Sampling for these two tasks can be conducted in two phases within a single field event. Atthe 23
offsite and 31 hotspot (includes the 11 hotspot borings and the 18 temporary wells at which hotspot soil
sampling will also be conducted) locations, install soil borings and collect samples atthe HGL plan-
specified sampling depths. In the first phase, samples from the prescribed depths at each boring are
field analyzed and a percentage of the samples are submitted for fixed-base laboratory analysis. A goal
where the field XRF results indicate one or more metals are near the remedial screening levels (RSLs). All
first phase soil samples are archived for potential future PCDD/PCDF analysis. The field-based analyses
results generated from the first phase borings are then used to determine the appropriate locations for
the second phase. Specifically, second phase borings will be installed at step-out locations from a subset
of the first phase borings (3 to 5). Field analyses of the soil samples collected during the second phase
will be used for further (potentially final) characterization. The field team will select for submission for
fixed-base laboratory analysis all samples from the final step borings.
Recommended approach for generating 6-inch-depth soil data for the HHRA and ecological risk
assessments is the ICS approach. This rationale for this recommendation is the generation of appropriate
data (0-6 inch depth) for risk assessment purposes and avoidance of the need to statistically compare the
MPI data set (0-18 inch depth) with the MPI sample verification sampling data set (0-6 inches). Final DU
size determination should be based on the CSM and will require input and consideration by all
stakeholders in the SPP process. It is recommended that the field team archive the ICS composite
samples from selected DUs. The archived DU samples can then be selected for PCDD/PCDF and PCB
congener analyses after the ICS sample results are received and evaluated for other constituents.
Media Sampled and
Numbers of Samples
Soil -8-10 ICS samples
Phase 1
Field analysis: 216
Fixed-based-
laboratory: 44
Phase II
(assume 3 step out
borings at 5 locations)
Field analysis: 40
laborato 20
Soil - Specific decisions
on DU size and number
o samp e mcremen s
requires input from
of number of samples to
PCDD/PCDF analysis
preliminary sampling
task.
Analytes for Each Media1
PCDD/PCDF
Phase 1
Field (Offsite): metals by XRF,
PAH and PCBs by IA
Laboratory (Offsite): 20%forTAL
metals and PCBs
Field (Hot Spot): metals by XRF,
PAH and PCBs by IA
Laboratory (Hot Spot): TCL VOCs,
TCL SVOCs, TCL pesticide/PCBs,
TAL metals, TOC; 50% for
explosives, CR VI, grain size,
(determined based on Section
4.3.1 preliminary sampling)
Phase II
Field: metals by XRF and PCBs by
IA
Laboratory: TCL VOCs, TCL
SVOCs, TCL pesticide/PCBs, TAL
metals, TOC; 50% for explosives,
CR VI, grain size, asbestos,
PCDD/PCDF (determined based
on Section 4.3.1 preliminary
sampling)
TCL VOCs, TCL SVOCs, TCL
pesticide/PCBs, explosives, Cr VI,
grain size, asbestos, PCDD/PCDF
samples archived for analysis
based on Section 4.3.1
preliminary sampling task results
-------
Tables
Summary of Optimization Recommendations for Each of the Field Sampling Tasks Presented in the Hydrogeologic, Inc. {HGL) Work Plan (Plan)
Page 2 of 4
4.3.3
Groundwater Investi ation
24 pre-pack temporary wells will be installed via
sonic methods in areas where Site activities may
have resulted in releases of contamination (based
on the analysis of historical aerial photographs and
observed conditions). The wells will be installed
with 10-ft long well screens with the base of the
screen positioned at a depth of 8ft below the
watertable. Groundwater samples will be
collected.
4 pre-pack temporary wells will be installed in the
Site wetlands and groundwater samples will be
collected.
Installation of up to 6 new permanent groundwater
monitoring wells - well locations to be based on
temporary well sampling results.
All Site wells will be sampled in a Site-wide
ground water sampling task. All nine existing wells
pi us the six new wells and four temporary wells
installed in the Site wetlands will be sampled
during a site-wide groundwater sampling event.
The existing nine site monitoring wells (MW-1R,
MW-2, MW-4, MW-5, MW-6, MW-7, MW-8, MW-9,
and MW-10) will be redeveloped.
Northwestern Drainage (referred to in the HGL Plan
as "Concrete Channel")
Four sediment samples are planned for collection
from 2 locations within the concrete-lined
Northwest Drainage ditch. The samples will be
collected from 0 - 6 inches and from the interval 6
inches to 2 feet BGS.
Groundwater - 24 samples
Groundwater - 4 samples
Groundwaterto be sampled in
accordance with the site-wide
groundwater sampling task
described at part of Section 4.3.3.
Groundwater - 19 samples
Groundwater
Sediment - 4 samples via fixed-base
laboratory
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/PCBs, and TAL
metals.
50% of the samples will be
analyzed for PCDDs/PCDFs,
explosives, and chromium VI.
All samples: TCL VOCs, TCL
SVOCs, TCL pesticides/PCBs, TAL
metals, explosives, hexavalent
chromium, alkalinity, hardness,
' ' '
ethane, and ethene.
N/A
TCL VOCs, TCL SVOCs, TCL
pesticides/PCBs, TAL metals,
chromium VI, alkalinity, hardness,
chloride, sulfide, sulfate, nitrate,
nitrite, TOC, TSS, TDS, methane,
ethane, and ethene.
No fie Id analytical or fixed-base
laboratory sampling will be
conducted.
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/PCBs, TAL metals,
fieldORP.
50% of samples will be analyzed
for chromium VI, explosives, and
PCDD/PCDFs.
The number of temporary wells is likely reduced to 12 from the 24 indicated by the HGL Plan (issued in
December 2011), as per discussions with Region 3. An adaptive approach is recommended in which 8
wells will be installed initially and the remaining 4 will be installed based on field data generated from
the initial wells. The eight initial locations can coincide with the hotspot soil assessment borings. During
installation of the 8 initial wells, field groundwateranalyses including PCB immunoassay (IA), PAH IA,
metals via Lumex, and field parameters. Based on the results of the ground water data obtained in real
time, step-out, follow-up locations for the 4 remaining wells will be selected. As determined from the
preliminary PCDD/PCDF surface soil sampling results obtained in Section 4.3.1, the projectteam can
determine the number and locations of groundwater samples that should be analyzed for PCDD/PCDF
compounds and PCB congeners via EPA Method 1668B.
Considering that the sediment pore water sampling recommended for Paradise Creek may provide more
useful data regarding the impact of site groundwater on surface water. In addition, the existing wells
and the proposed onsite temporary wells will likely sufficiently characterize groundwater quality near
the creek shoreline. It is recommended, therefore, that ground water sampling at the four temporary
wells planned for the wetland area be eliminated or considered in combination with the locations
specified by HGL for onsite temporary well installation.
It is recommended that this task be eliminated by requiring that all temporary wells be installed in a
manor such that they could be completed as permanent wells. The decision to complete a temporary
well as permanent would be based on real time field sampling results obtained during temporary well
drilling. Accordingly, duplication of drilling tasks can be avoided.
Recommendations for the list of analytesforthe site wide ground water sampling event including the 6
new wells and the 9 existing wells are as follows. For permanent well sampling, it is suggested that the
analysis of sulfide, nitrite, methane, ethane, and ethane only be performed if elevated concentrations of
chlorinated hydrocarbons are detected in the temporary well sampling task. To provide data comparable
to the Elizabeth RiverTMDL currently under development, and to develop PCB congener concentration
data in ground water for comparison to congener composition data for Paradise Creek pore
water/surface water, groundwater samples from monitoring wells installed down gradient from the
areas with elevated PCB concentrations may be analyzed to a low method detection level via EPA
Method 1668B.
No changes recommended to this task.
Priorto sampling, a survey of the accessible portions of the channel is recommended to identify
locations of sufficient sediment accumulation for sample collection. Up to three areas should be
sampled. If standing water is present, a petit Ponar dredge may be necessary to collect samples. To
provide data com parable to the Elizabeth River total maximum daily load (TMDL) currently under
development and to develop PCB congener concentration data for northwestern drainage sediment, PCB
analyses of selected sediment samples can be performed at a low method detection level using EPA
Method 1668B. It is recommended that all fixed-base laboratory samples be analyzed for PCB Aroclors
and a portion of each sample archived. Based on the results of the Aroclor analyses, the three most
elevated Aroclor samples can be submitted for analysis by EPA Method 1668B
Groundwater: 12 field
analyzed samples
(including 8 during initial
temporary well
installation and 4 during
the installation of follow-
up temporary wells)
Sampling recommended
for elimination
N/A
Groundwater- 19
samples analyzed via
fixed-base laboratory
N/A
Sediment - up to 3
samples
Field analyses: PCB IA, PAH IA,
attachment), and field
parameters
Laboratory: Based on sampling
level determined from the initial
PCDD/PCDF sampling performed
as per Section 4.3.1, submit
appropriate number of samples
for PCDD/PCDF analyses is based
on preliminary surface soil
sampling results.
Sampling recommended for
elimination
N/A
Analyte list as indicated in the
HGL Plan with the following
sulfide, sulfate, nitrate, nitrite,
methane, ethane, and ethene
unless VOCs are detected in the
temporary wells. Also, add PCB
Congener analyses for selected
wells in PCB hotspot areas for
sediment sampling results for PCB
congeners.
N/A
Analyte list as indicated in the
HGL Plan with the addition of the
following:
Based on Aroclor analyses results
in archived samples, submit
samples for PCB Congener
analyses via EPA Method 1668B;
also, analyze for PCDD/PCDF in
accordance with findings of
preliminary PCDD/PCDF sampling
conducted via Task 4.3.1.
-------
Tables
Summary of Optimization Recommendations for Each of the Field Sampling Tasks Presented in the Hydrogeologic, Inc. {HGL) Work Plan (Plan)
Page 3 of 4
4.3.4
Sediment Investigation
4.3.5
Surface Water
Investigation
Western Drainage Ditch
Eight sediment samples are planned for col lection
from 4 locations within the Western Drainage
ditch. In addition, 2 samples will be collected atthe
outlet of the ditch to Paradise Creek. The samples
will be collected from 0 - 6 inches and from the
interval 6 inches to 2 feet BGS.
Site Wetlands
Eighteen sediment samples will be collected at pre-
defined locations. Using a hand auger, the samples
will be collected from 0 - 6 inches and from the
interval 6 inches to 2 feet BGS.
Paradise Creek
Twelve sediment samples will be collected at
locations determined in the field. The sampling
points will be located upstream (2 locations),
bordering the site (8 locations), and downstream (2
locations). The samples will be collected from the
top 6 inches of sediment.
Western and Northwestern Drainage surface water
samples will be collected atthe sediment sampling
locations defined forthese two drainages.
Surface water sampling in the Site wetlands
bordering Paradise Creek: collect 4 samples co-
located with wetland sediment sample locations
and 6 samples from seep locations a long the
Paradise Creek shoreline.
Sediment - 10 samples via fixed-
base laboratory
Sediment - 18 samples via fixed-
base laboratory
Sediment - 12 samples via fixed-
base laboratory
Surface Water - 5 samples
Surface Water - 10 samples
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/PCBs, TAL metals,
TOC, and grain size; field pH and
ORP.
50% of samples will be analyzed
for chromium VI, and explosives.
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/PCBs, TAL metals,
TOC, and grain size; field pH and
ORP.
50% of samples will be analyzed
for chromium VI, explosives, and
PCDD/PCDF.
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/PCBs, TAL metals,
and TOC.
50% of samples will also be
analyzed for chromium VI,
explosives, PCDDs/PCDFs, and
grain size.
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/PCBs, and TAL
metals.
50% of the samples will also be
analyzed for PCDDs/PCDFs,
chromium VI, and explosives.
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/PCBs, and TAL
metals.
50% of the samples will also be
analyzed for PCDDs/PCDFs,
chromium VI, and explosives.
An adaptive approach for sampling the Western Drainage is recommended. Sampling should include the
entire length of the Western Drainage and would provide data for the establishment of optimal locations
for the 8 proposed fixed-base laboratory samples. Consistent with the HGL WP, 2 samples should be
collected at the ditch outlet to Paradise Creek. During the initial sampling, field-based analyses
accomplished using XRF and, potentially, IA screening methods for PCBs and PAHs are suggested. To
provide data com parable to the Elizabeth River TMDL currently under development and to develop PCB
congener concentration data for western drainage sediment for comparison to congener composition
data for Paradise Creek sediments, PCB analyses of selected sediment samples should be performed at a
low method detection level using EPA Method 1668B. Selected samples should also be analyzed for
PCDD/PCDF compounds. It is recommended that all fixed-base laboratory samples be analyzed for PCB
Aroclors and a portion of each sample archived. Based on the results of the Aroclor analyses, the three
most elevated Aroclor samples can be submitted for ana lysis by Method 1668B. Regard ing the collection
of Western Drainage sediment samples for PCDD/PCDF analyses, the scope of this sampling may be
driven largely by the results of the preliminary PCDD/PCDF sampling in surface soil.
As a result of anticipated short scale heterogeneity in the wetland sediment, It is recommended that
sediments in the wetland area be characterized using ICS methodology. ICS is, therefore, recommended
rather than conducting the sampling atthe 18 prescribed locations as envisioned in the HGL Plan. DU
boundaries and the appropriate number of soil increments will require project team and stakeholder
input.
It is suggested that the proposed sampling approach be re-evaluated with respect to ecological risk
assessment objectives. It is recommended that evaluation of the relative impact of the site on Paradise
Creek sediment be established as the characterization objective. Accordingly, it is suggested that the
following sediment characterization sampling be conducted immediately offshore from the site and at
locations offsite (within Paradise Creek/Elizabeth River but hydraulically isolated from site): (1) the
collection of sediment samples, (2) the enumeration of macroinvertebrate fauna, and (3) the collection
of sediment pore water samples. Statistical comparison of the near site and offsite sampling results will
provide an indication of site impacts on the creek. It is recommended that a survey of the Paradise
Creek channel offshore from the Site be conducted to identify zones of preferential groundwater
discharge to surface water. The results of this sampling will help guide the selection of the sediment
characterization locations. For the Elizabeth River TMDL under development, a subset of the sediment
samples (approximately 20 percent), should be analyzed using EPA Method 1668B at a low detection
level for PCB congeners in sediment samples for TMDL comparison purposes.
It is recommended that surface water sample collection efforts be coordinated with the collection of
sediment samples and collection locations should coincide with the sediment characterization locations.
With regard to sample quantities and placement, surface water sampling should be coordinated with the
sediment sampling strategies discussed above for the Northwest Drainage, the Western Drainage, and
Paradise Creek. Sampling for PCDDs and PCDFs should be contingent on the results obtained from the
preliminary PCDD/PCDF sampling event discussed in Section 4.3.1. EPA Method 1668B should be used
for PCB analyses to ensure that results are reported to the lowest possible method detection level. In
Sediment -
Field: adaptively
defined sampling over
length of drainage
Laboratory: 10 samples
Sediment - Specific
decisions on DU size and
increments requires
input from stakeholders;
selection of number of
samples to be archived
for PCDD/PCDF analysis
. .
task.
Sediment and sediment
pore water- 8to 10
locations with analysis
via fixed-base laboratory
Benthic enumeration at
each of the above
locations
Surface Water u to 3
^
samples
One sample per ICS DU
Field: metals via XRF; PCBs and
PAHs via IA
b
Analyte list as indicated in the
HGL Plan with the addition of the
following:
Based on Aroclor analyses results
samples for PCB Congener
analyses via EPA Method 1668B;
also, analyze for PCDD/PCDF in
accordance with findings of
preliminary PCDD/PCDF sampling
conducted via Task 4.3.1.
Laboratory:
Analyte list as indicated in the
HGL Plan with the addition of the
following:
Based on Aroclor analyses results
in archived samples, submit
samples for PCB Congener
analyses via EPA Method 1668B;
also, analyze for PCDD/PCDF in
accordance with findings of
preliminary PCDD/PCDF sampling
conducted via Task 4.3.1.
Laboratory:
HGL Plan with the addition of the
following:
Based on Aroclor analyses results
in archived samples, submit
samples for PCB Congener
analyses via EPA Method 1668B;
also, analyze for PCDD/PCDF in
accordance with findings of
preliminary PCDD/PCDF sampling
Laboratory:
HGL Plan with the addition of the
Based on Aroclor analyses results
samples for PCB Congener
analyses via EPA Method 1668B;
-------
Tables
Summary of Optimization Recommendations for Each of the Field Sampling Tasks Presented in the Hydrogeologic, Inc. (HGL) Work Plan (Plan)
Page 4 of 4
Paradise Creek surface water samples: collected at
locations that will be determined in the field based
on observed surface water/groundwater discharges
and surface waterflow paths.
Surface Water - 12 samples
All samples: TCL VOCs, TCL SVOCs,
TCL pesticides/PCBs, and TAL
metals, alkalinity, hardness,
chloride, sulfide, sulfate, nitrite,
and nitrate.
50% of the samples will also be
analyzed for PCDDs/PCDFs,
chromium VI, and explosives.
addition, since an aggregate PCB concentration is necessary for comparison to the RSL, analyses results
can be reported as the sum of individual PCB homologue concentrations.
Surface Water- up to 10
samples
accordance with findings of
preliminary PCDD/PCDF sampling
conducted via Task 4.3.1.
1. Definition of chemical analyte acronyms
PCDD\PCDF: polychlorinated dibenzo-p-dioxins/polychlorinated dibenzofurans
VOC: volatile organic compound
SVOC: semi-volatile organic compound
TCL: target compound list
TAL: target analyte list
PCB: polychlorinated biphenyl
PAH: polycyclic aromatic hydrocarbon
TOC: total organic carbon
TSS: total suspended solids
TDS: total dissolved solids
ORP: oxidation/reduction potential
-------
FIGURES
-------
Atlantic Wood
Industries
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 1
Peck Iron and Metal
Site Layout
Legend
« Monitoring Well
Drainage
Road
ii- Railroad
| | Building
| | Parcel
03860026 Tax Parcel #
Peck Iron and Metal Site
Peck Iron and Metal
-I Remediation Investigation Area
Environmental Photographic Interpretation
Center Study Area
Wetland
\\gst-sn>-01\hglgis\Peck\_MSIHr\SAdP_RlFS\
(2-02)Site_Layout. mxd
11/2/2011 PD
Source: HGL, Malcolm Pirnie, EPA
ArcGIS Online BingMaps Aerial
v HGL
-------
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 2
1937 to 2009
Impoundments and Drainages
Legend
* Monitoring Well
MW-4 Well Identification
Malcolm Pirnie 50 foot x 50 foot Sample Grid
AA Grid Column or Row Identification
| | Parcel
0386002? Tax Parcel #
Peck Iron and Metal Site
i"~"~: Environmental Photographic Interpretation
!_._.' Center Study Area
Historical Liquid and Drainage features (by shape):
> >~ Drainage Channel
-< *~ Drainage Channel, Indeterminate Flow
> Breach
Berm/Dike
| | Liquid / Impoundment
Last Known Year Feature Applies (by color):
1937
1947
1954
1958
1963
1970
1980
1990
1998
2009
\\gst-srv-01\hglgis\Peck\JvlSIW\SMPJUFS\
(2-06)Impoundments. mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie, EPA
A rcGIS Online BingA!'^!^ Arrii-i.
v HGL
-------
Primary
Source
Primary Release
Mechanism
Secondary
Source
Secondary
Release
Mechanism
Pathway
Exposure
Route
Rece
Industrial
Worker
Mai ntenance
Worker
Construction
Worker
ptors
Recreational
User
Agriculture
Resident
Vapor Intrusion into
Buildings and Outdoor Air
Subsurface soil to Groundwater
Ingestion
Inhalation
Dermal
u
0
0
0
0
D
Ingestion
Inhalation
Dermal
Ingestion
Inhalation
Dermal
Ingestion
Inhalation
Dermal
0
0
Q
Figure 3. Generic Pathway Receptor-Network Diagram for Human Health Risk Assessment
-------
HYDRODYNAMICS & SEDIMENT DYNAMICS
HIOKKilOM IHANSPOWI AhAlh
Hoot
Tributary Zone ~"
Regional Ground'Aater Discnarge
Regional Groundwaler Drscfiarge
Figure 4. Schematic Representation of Potential Ecological Exposure Pathways for the PIM Site
(Modified from Geosyntec Consultants)
-------
SEA
LEVEL
500 -
-' '
FALL LINE
FALL ZONE
PORTSMOUTH
YORKTOWN EASTOVERAOUIFER
YORKTOWN CONFINING UNIT
COLUMBIA AQUIFER
EXPLANATION
AQUIFER
CONFINING UNIT
BEDROCK
10 20 KILCMEFERS
DIRECTION OF GROUND-WATER FLOW
:
V -f/s
1,000 -
.
.
Figure 5. Representative Hydrogeologic Cross-Section for the Atlantic Coastal Plain in Virginia
(Modified from Harsh and Laczniak (1990) (fide McFarland, 1998)
-------
Southwest
Northeast
i
| Cross-Section Location |
,000 - .__
:= i^v-:;.11!*
.';. ;:;..._:*:
CO
I
iS
1500
1600 1700 1800 1900 2000
\\gst-srv-01\hglgis\Peck\_MSIW\SMP_RIFS\
Geologic_Cross_Section.cdr
11/16/2011 CNL
Source: HGL, Malcolm Pimie
v HGL
Boring
MW-10 Boring / Well Identification
Lithology Boundary (dashed where inferred)
Legend
Fill
Clayey Sand
Notes:
Vertical Datum is NGVD 1988.
ft amsl = feet above mean sea level
Inset Features:
© Monitoring Well
^^ Geologic Cross Section
=, Peck Iron and Metal Site
Figure 6
Geologic Cross Section
-------
"*^> * \ ' sr fll
a?"1* > -
S-rC - - » o
X X % "T
^x v % \
N V
//GZ,S/fe Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 7
October 2008
Groundwater
Potentiometric Surface
Legend
Monitoring Well
MW-9 Monitoring Well Identification
6.37 2008 Groundwater Elevation (ft amsl)
2008 Groundwater Elevation Contour (ft amsl)
(dashed where inferred, 1 ft contour interval)
Peck Iron and Metal Site
Notes:
Water levels measured on July 24, 2008.
MW-6 and MW-8 were not screened in the water table aquifer.
Vertical datum is NGVD 1988.
ft amsl = feet above mean sea level
\\gst-siv-01\hglgis\Peck\_MSimSAdP_RIFS\
(2-09)pot_2008-l 0. mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
- i
$
I
~ 42
«t
40
39
38
36
35
34
33*
32
31
30
29
28i
fl
26
fl
25
r
24
0.08
0.12
2.04
0
20.6
7.8
19
41
0.39
0
1.6
3.5
0.98
0.9
2.11
3.38
2.78
-OL67
^
0.13
2.6
0.72
0.21
6.2
24.2
24.9
104
17.8
26.8
25.13
13.7
0.15
0.07
1.39
1.81
6.05
0.69
rs
1.381
*
z
£
0.02
3
2.28
3.5
1.23
20.9
5.97
1.57
0
2.9
1.01
0
1.6
6.8
1.24
0.08
0.9
2.02
'0.48
y
I
I
t
I
i
=»=,
0.91
3.8
1.49
4
4.5
8.7
1.34
2.38
340
3.3
3
2.39
1.41
11.3
9.01
49.3
0.3
0.59
\0.58
K. 97
'S.47
0.51,4
i. L'
*?
B
\
70.6
0.62
2.01
0.56
0.53
2.08
0.18
10.37
3.09
|0.34
0.26
0.14
0.02
0.35
0.82
1.2
6.4
3.85
0.37
14
2.53
1.45
1.81
25
27.5
8.6
16.8
6.7
9.5
3.06
0.59
0.47
0.64
0.42
0.39,
/T
»
0.74
0.92
0.28
0.84
1.15
0.17
0.23
0.16
1.55
0.29
1.37
3.5
3.48
0.99
1.94
1.03
5.6
4.9
4.3
15.2
4.2
3.9
27.6
26.62
1.69
10.1
27
4.4
0.82
7.5
8.9
3.15
5
0.92
1.25
I0791\
^7
1.0-10
>10-25
>25-50
>50-100
>100
Notes:
bgs=below ground surface
mg/kg=milligrams per kilogram
PCB=polychlorinated biphenyl
\\gst-stv-01\hglgis\Peck\JvlSIW\SMPJUFS\
(2-10)PCB_Suif.mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
Y X W V U I SRQPONMLKJ i HGFEDCBA
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 9
Arsenic Concentrations in Soils
(0 to 18 inches bgs)
AA
Legend
Malcolm Pirnie 50 foot x 50 foot Sample Grid
and PCB Concentration (mg/kg)
Grid Column or Row Identification
Peck Iron and Metal Site
Arsenic Concentration (mg/kg):
>0.39-1.6
>16-160
>160
Notes:
0.39 ppm=Residential June 2011 RSL (CR = 10'6)
1.6 ppm=Industrial June 2011 RSL (CR = 10'6)
16 ppm=10x Industrial June 2011 RSL
160 ppm=100x Industrial June 2011 RSL
bgs=below ground surface
mg/kg=milligrams per kilogram
CR=cancer risk
RSL=regional screening level
\\gst-srv-01\hglgistfeck\_MSIW\SMP_RIFS\
(2-12)As_Surfmxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
No/*,/*,
Y X W V U I SRQPONMLKJ
i HGFEDCBA
- i
$
I
X*'
/i
//GZ,S/fe Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 10
Cadmium Concentrations in Soils
(0 to 18 inches bgs)
AA
Legend
Malcolm Pirnie 50 foot x 50 foot Sample Grid
and PCB Concentration (mg/kg)
Grid Column or Row Identification
Peck Iron and Metal Site
Cadmium Concentration (mg/kg):
>7-80
>80
Notes:
7 ppm=Residential June 2011 RSL (adjusted for HI=0.1)
80 ppm=Industrial June 2011 RSL (adjusted for HI=0.1)
bgs=below ground surface
mg/kg=milligrams per kilogram
HI=hazard index
RSL=regional screening level
\\gst-stv-01\hglgis\Peck\JvlSIW\SMPJUFS\
(2-I4)Cd_Surf.mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 11
Chromium Concentrations in Soils
(0 to 18 inches bgs)
AA
Legend
Malcolm Pirnie 50 foot x 50 foot Sample Grid
and PCB Concentration (mg/kg)
Grid Column or Row Identification
Peck Iron and Metal Site
Chromium Concentration (mg/kg):
>0.29-5.6
>5.6-56
>56-560
>560-12,000
>12,000
Notes:
0.29 ppm=Hexavalent Chromium Residential June 2011 RSL
5.6 ppm=Hexavalent Chromium Industrial June 2011 RSL (CR = 10"6)
56 ppm=10x Hexavalent Chromium Industrial June 2011 RSL
560 ppm=100x Hexavalent Chromium Industrial June 2011 RSL
12,000 ppm=Trivalent Chromium Residential June 2011 RSL
(adjusted for HI=0.1)
bgs=below ground surface
mg/kg=milligrams per kilogram
CR=cancer risk
HI=hazard index
RSL=regional screening level
\\gst-srv-01\hglgistfeck\_MSIW\SMP_RIFS\
(2-I6)Cr_Surf.mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
~ 42
«t
40
39
38
36
35
34
33*
32
31
30
29
28i
26
fl
25
r
24
140
23
1500
200
2500
3400
110
2400
2700
1200
180
240
330
220
460
490J
290
^58
^
130
290
170
420
83
3100
350
130
21
13
350
140
470
43
*2°
25W
"
I
&
63
32,
150
340
120P,
770
230
110
140
74
7.9
280
1300
210
94
350
350
^37
U
J
|
I
1
r
=»=,
300
260
490
46
420
1100
1200
2800
870
21
820
2200
370
3200
2400
680
72
190
V 110
U40
^130
430,
*?
B
I
f660
200
2500
230
180
1300
950
11000
'l200
290
1100
1700
180
320
210
360
460
32
1100
970
1500
360
1800
1900
230
4900
4300
3600
510
130
9.6
130
72
100,
/T
»
310
4200
940
560
860
160
100
280
550
2300
660
210
290
230
260
330
360
570
390
3800
2900
570
4900
780
65
1200
1600
2400
4700
1800
530
590
220
210
[220\
jl
I
j
6300
6400
4400
24000
M=a
%
t
\
]
1
J
1
I
S
I
I
6000
1800
5900
590
4200
«
^
LS^
~1oo>
[280
420
U80
H
320
a
f
/900
8400
3700,
6500
5400
12000
3000
1600
1600
4900
4100
1700
17000
2900
~m~ i
£
f°
340
110
120\
460
220
2800
2200
2200
54000
3900
3900
6700
5300
7300
3700
580
11000
1600
CBE
>
I
«
1300
260
540
"
920
1700
970
220
28,a
1
2000
1
4501
11000
1
160'
2500
2700
7900
=
cn
CD
3
CD
No,
\
\
640
650ol
n
2500J
J
W V U I SRQPONMLKJ i HGFEDCBA
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 12
Lead Concentrations in Soils
(0 to 18 inches bgs)
AA
Legend
Malcolm Pirnie 50 foot x 50 foot Sample Grid
and PCB Concentration (mg/kg)
Grid Column or Row Identification
Peck Iron and Metal Site
Lead Concentration (mg/kg):
>400-800
>800-8,000
>8,000
Notes:
400 ppm=Lead Residential June 2011 RSL
800 ppm=Lead Industrial June 2011 RSL
8,000 ppm=10x Lead Industrial June 2011 RSL
bgs=below ground surface
mg/kg=milligrams per kilogram
RSL=regional screening level
\\gst-stv-01\hglgis\Peck\JvlSIW\SMPJUFS\
(2-18)Pb_Suif.mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
HHGGFFEEDDCCBBAAZYXWVUTSRQPONMLKJ I HGFEDCBA
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 13
Mercury Concentrations in Soils
(0 to 18 inches bgs)
AA
Legend
Malcolm Pirnie 50 foot x 50 foot Sample Grid
and PCB Concentration (mg/kg)
Grid Column or Row Identification
Peck Iron and Metal Site
Mercury Concentration (mg/kg):
> 1.0-4.3
^^ >4.3-43
>43
Notes:
1.0 ppm=Elemental Mercury Residential June 2011 RSL
(adjusted HI=0.1)
4.3 ppm=Elemental Mercury Industrial June 2011 RSL
(adjusted HI=0.1)
43 ppm=10x Elemental Mercury Industrial June 2011 RSL
(adjusted HI=0.1)
bgs=below ground surface
mg/kg=milligrams per kilogram
HI=hazard index
RSL=regional screening level
\\gst-srv-01\hglgisWeck\_MSIW\SMP_RIFS\
(2-20)Hg_Surf.mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
mil
" 42
«t
40
39
38
36
35
34
33*
32
31
30
29
28i
26
n
25
r
24
80.1
57.4
37
2400
5100
390
9300
2700
7400
28000
17000
6700
310
7400
7000
2100
**6
^
pel
240
190
410
1000
2700
3400
03
89.3
190
1800
91
37
*"
12W
"
I
&
8.1
150
320
40
230
590
270
120
180
390
9.9
1400
420
49
19
98.2
43
^33
U
I
t
I
I
i
=»=,
18
260
320
Py
210
310
550
690
570
29
590
300
62
320
500
146
14
46
\ 18
J55
717
22,
*?
B
1
7 66
250
690
45
68
1500
290j
1190
440
110
390
700
32
71
134
160
300
7.7
390
290
290
51
310
490
870
210
1800
1300
120
52
7
35
17
23>
f
i
89
890
380
160
^01
75
1400
41
190
836
280
78
59
73
72
40
130
300
130
430
130
130
180
70
57
95
150
210
1200
300
150
170
51
95
fis\
jl
76
H
I
/130
260
*180
330
680
450
150
110
110
140
330
170
830
340
mu
14
\
5
59
128
350
1300
440
230
490
330
400
350
750
620
95
450
150
cat
^
^
I
\
yao
n
3070
1200
150
170
200
«_
180
48i
cn
CD
3
CD
A/o,
85j
58501
690J
23 T\
190
160
2000
»^1
81
17o|
16oU
3
1'
I HGFEDCBA
V U I SRQPONML
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 14
Nickel Concentrations in Soils
(0 to 18 inches bgs)
AA
Legend
Malcolm Pirnie 50 foot x 50 foot Sample Grid
and PCB Concentration (mg/kg)
Grid Column or Row Identification
Peck Iron and Metal Site
Nickel Concentration (mg/kg):
>150-2,000
>2,000-20,000
>20,000
Notes:
150 ppm=Nickel Residential June 2011 RSL (adjusted HI=0.1)
2,000 ppm=Nickel Industrial June 2011 RSL (adjusted HI = 0.1)
20,000 ppm=10x Nickel Industrial June 2011 RSL (adjusted HI=0.1)
bgs=below ground surface
mg/kg=milligrams per kilogram
HI=hazard index
RSL=regional screening level
\\gst-srv-01\hglgistfeck\_MSIW\SMP_RIFS\
(2-22)Ni_Surf.mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
ElmA
venU(
^
i,'?tfpa
\ - -i b a
K" 3
f'
42
*'/,"/<
41
40
39
38
37
36
35
34
33*
32
31
M
30
29
28i
fl
23
26
fl
25
g
24
ft
23
U
22
n
21
U
20
n
19
U
18
n
»17^
u
16
n
15
5.07
4.8
4.2
0.49
5.9
66
0.91
5.5
11.7
3.2
3.3
5
0.56
0.84
0.41
2.4
1.1
-OL13
^
^^
^3
0.48
^3
0.51
Iscy
^3
0.98
^jj
5.43
0.19
0.51
^^
^^
fe16
^
0.54J
*
z
A
0
0.3
0.9
14
3
1.8
0.87
0.72
1.9
0.32
0
0.54
4.5
0.38
0.23
6.45
1.1
^
5
i
$
I
t
I
I
i
=»=,
0.29
^^
^3
0.13
^^
3.5
^M
^M
^^
El
^^
^^
1
^3
^^
7.54
0.37
0.67
V0.11
K. 19
£
1-
*?
B
J
f"
1.9
2.8
1.2
0.47
1.7
0.31
10.38
0.47
|0.13
0.53
| 2.5
' 0
0.54
5.43
0.34
0.98
*7l
2.3
1.9
4
0.44
4.5
5.4
1.1
3.7
3.5
5.1
1.7
0.3
0
0.18
0.1
^
S
i
Pal
^3
0.42
0.46
5.18
0.18
^^
[0.21
,0.37
'6.041
0.69
F^tl
0.67
^3
0.44
0.48
0.81
0.68
^^
T^M
^y
^y
^3
0.48
0.14
^3
^3
^3
^3
^3
^3
^y
0.68
^3
10744\
/
F
=-
1.1
1.4
0.26
0.6
0.69
0
0.44
0.24
0.2
\2
0.4
0.22
0.23
1.1
1
1.1
0.46
0.9
13
1.5
3.3
7.3
51
23
6
10
0.97
1.2
2.1
^^
0.13
IT1
0
0.85
0.13
0.14
1
0.26
0.96
0.59
1.1
0.75
0.1
1.3
1.4
3.1
7.1
2.6
0.6
1.6
7.6
0.31
4.3
77
37
1.5
4.3
0.32
1.1
2
13
6.6
rr
I
L
0^7
JH
0.38
0.25
j^J
0
0
0.26
l^l
^3
0.11
0.15
0.3
0.67
1
|
I^J
19
0.86
0.69
0.44
0.06
^^
^3
^3
120
^^
^3
20.9
^3
^^
1.1
^
^^
1
1
0."
1
°l
o'
°l
1
1
1
1
1
1
1
1
1
0.14
U
P
0.86j
1
1
0.95
f^B
0.43
0.67
1
^^
^3
^3
^J
^^
^^
^y
^j
f^
^y
5.63
9.29
^J
1.6
^^
1
1
1
1
1
1
0.07
0.55
1.7
16
2.7
5.9
2.9
3.5
3.8
8.4
0
13
1.5
1.4
0.77
5.1
2.1
5.6
3.7
2.9
2.5
1.8
2.6
3.4
8.2
0.09
6.1
4.3
1.5
1.3
4.3
0.47
^
_M__
^tf
^^
^3
m
^^
0.62
^M
^^
^W
^3
0.67
8.41
n:6B
20
0.35
4.9
8.6
3.5
2.5
6.5
9.2
0.75
3.4
7.2
:38~
56
7.5
0.59
5.7
2.9
1.2
6.8
6.2
1.5
4.4
0.97
4.4
I6.*1l
28
6
7.8
43
5.2
6.1
4.4
1.3
5.6
9.2
S
^3
^3
^3
^^
^3
^3
^^
0.
-1
4J*
6.3
20
8.1
2.3
0.97
3.2
CIM
^1!5~
1.8
3.7
2.3
8.3
1.3
15
11
1.6
-m^
>3:9l
4.6
21
7.1
0.89
6.7
6.8
A
7
9
-0:71"
12
^3
^n
^^
^3
/
f
"9J^
270
16
6.5
6.8
19,
t
-16-
29
15
19
32
^203
*40*
0.19
14
cm:
0.6
BiB
»n
5.34
12
ir«:
-n
LJ
^3
^^
21
^^
*n
%
!=
2.7
79
7.8
29
8.7
^f.
-
t~^
^
o^>
>
I
j
53
11
20
8.7
K=]
s
\1.2
\
\
I
J
|
f
y
f
f
9.9
1.6
6.7
1.2
5
»
<^
/
4^
^
0.62^
0.34
,0.58
*0.35
U
8,
n
1
L
^3
6.2
^^
^^
^3
^3
^3
^3
^3
^^
Ejl
El4l
Enl
=1
0.18
\
]
0.68
5.25
3.4
4.5
1.8
3.7
2.7
5.6
7.2
28
2.8
4.3
1.1
6.4
3.9
K»:
^
j?
f
I
4
1
fc
0.64
56
y
0.95
0.98
U
5
n
0.22
en
>
CD
3
CD
A/o,
1 3J
7.921
3.4H
°'3T\
4.8
1.6
7.6
j«a
0.9
"
"
J
J
FF EE DD CC
Y X W V U I SRQPONMLKJ i HGFEDCBA
0rt
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 15
Silver Concentrations in Soils
(0 to 18 inches bgs)
AA
Legend
Malcolm Pirnie 50 foot x 50 foot Sample Grid
and PCB Concentration (mg/kg)
Grid Column or Row Identification
Peck Iron and Metal Site
Silver Concentration (mg/kg):
>39
Notes:
39 ppm=Silver Residential June 2011 RSL (adjusted HI=0.1)
bgs=below ground surface
mg/kg=milligrams per kilogram
HI=hazard index
RSL=regional screening level
\\gst-srv-01\hglgis\Peck\JvlSIW\SMPJUFS\
(2-24)Ag_Suif.mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
Analyte
AROCLOR(ug/L)
MW-7
Jul-08
Result Qual
NA
PCBHOMOLOGUES(Mg/L)
Monochlorobiphenyl
Dichlorobiphenyl
Trichlorobiphenyl
TOTAL METALS (ug/L)
Arsenic
Ichromium
"JNickel
*|Lead
J Mercury
0.097 U
0.097 U
0.007 J
28
93
30 J
50 B
0.24
iJDISSOLVED METALS (ug/L)
|Arsenic
Ichromium
JNickel
I Lead
J| Mercury
10 U
ill
9.1 J
5 U
0.2 U
1 \
i
-ZB~
\ : "
. \ \ ' A
AROCLOR(ug/L)
MW-10
Jul-08
Result Qual
NA
PCB HOMOLOGUES (ug/L)
Monochlorobiphenyl
Dichlorobiphenyl
Trichlorobiphenyl
TOTAL METALS (ug/L)
Arsenic
Chromium
Nickel
Lead
Mercury
0.097 U
0.097 U
0.014 J
10 U
10 U
2 J
12 B
0.1 J
DISSOLVED METALS (ug/L)
Arsenic
Chromium
Nickel
Lead
Mercury
31
10 U
2.7 J
5 U
0.2 U
«r ^^*
4
£
.
AROCLOR{ng/L)
\
MW-9
Jul-08
Result Qual
NA
PCB HOMOLOGUES {[og/L)
Monochlorobiphenyl
D chlorobiphenyl
Trichlorobiphenyl
TOTAL METALS {[og/L)
Arsenic
Chromium
N ckel
Lead
Mercury
0.0084 J
0.17
0.016 J
6.9 J
LSI
40 U
6.9 B
0.2 U
DISSOLVED METALS (ng/L)
Arsenic
Chromium
Nckel
Lead
Mercury
61
10 U
40 U
2.6 J
0.2 U
Analyte
AROCLOR(ug/L)
MW-4
Jul-99
Result Qual
ND
Jul-03
Result Qual
ND
Jul-08
Result Qual
NA
PCB HOMOLOGUES (ug/L)
Monochlorobiphenyl
Dichlorobiphenyl
Trichlorobiphenyl
TOTAL METALS (ug/L)
Arsenic
Chromium
Nickel
Lead
Mercury
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.1 U
0.1 U
0.1 U
20
10 U
40 U
2.7 JB
0.2 U
DISSOLVED METALS (ug/L)
Arsenic
Chromium
Nickel
Lead
Mercury
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
21
2.6 J
2.2 J
5 U
0.2 U
Analyte
AROCLOR(ug/L)
Tap
Water
RSL
MCL
PCB HOMOLOGUES (ug/L)
Monochlorobiphenyl
Dichlorobiphenyl
Trichlorobiphenyl
TOTAL METALS (ug/L)
Arsenic
Chromium
Nickel
Lead
Mercury
-
0.045
0.043
73
-
0.063
0.5
0.5
0.5
10
100
-
15
2
DISSOLVED METALS (ug/L)
Arsenic
Chromium
Nickel
Lead
Mercury
0.045
0.043
73
0.063
10
100
15
2
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 16
Groundwater Contaminant
Concentrations
Legend
« Monitoring Well
MW-S Well Identification
4 2008 Groundwater Elevation Contour (ft amsl)
(dashed where inferred, 1 ft contour interval)
1 Peck Iron and Metal Site
Notes:
Bolded value: Analyte concentration exceedes EPAMCL
Underlined value: Analyte concentration exceeds EPA Tap water RSL
(adjusted)
=not applicable
|ig/L=micrograms per liter
B= positive detection, representative of laboratory blank contamination
CR=cancer risk
HI=hazard index
J=positive detection, considered an estimate
MCL=Maximum Contaminant Level
NA=not analyzed
ND=not detected
Qual=qualifier
RSL=Regional Screening Level (June 2011 value; adjusted for CR=10"6,
HI=0.1)
U=not detected
\\gst-srv-01\hglgis\Peck\_MSimSAdP_RlFS\
(2-26)GW_Contaminants. mxd
11/16/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
Analyte
Heptachlorobiphenyl
Hexachlorobi phenyl
EPA
Residential
RSLs (xlO)
1100
1100
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 17
PCB Homologue Detections
Paradise Creek Sediment Samples
Legend
Sediment Sample
SD-1 Sample Location Identification
Peck Iron and Metal Site Boundary
Malcolm Pirnie Sediment Sample Grid
Notes:
|ig/L=micrograms per liter
EPA=U.S. Environmental Protection Agency
HI=hazard index
J=positive detection, considered an estimate
PCB=polychlorinated biphenyl
Qual=qualilfier
RSL=Regional Screening Level (June 2011 value, residential soil xlO;
adjusted for HI=0.1)
U=not detected
\\gst-srv-01\hglgis\Peck\_MSimSAdP_RlFS\
(2-27)Sediment_Tags. mxd
11/10/2011 CNL
Source: HGL, Malcolm Pirnie
ArcGIS Online BingMaps Aerial
v HGL
-------
O-MP-51
:-iM
>-MP-50
tt IB
XRF-04
XRF-05
MP-42-O
<-TW-S
MW-4 ' '>MP-30 MP-34
OMP-20 OMP-21
, OMP-15
MP-11.-0 OMP-12 . T\AM6
MP-08-O
MR.-060 9
MP-07
MP-13 MP-14
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 18
Site Soil and Groundwater
Sample Locations
Legend
* Monitoring Well
^ Prepack Well
^ Soil Sampled Prepack Well
o Hotspot Soil Boring
© XRF Soil Boring
o Malcolm Pirnie Verification Boring
MW-1 R Well or Sample Location Identification
Malcolm Pirnie 50 foot x 50 foot Sample Grid
AA Grid Column or Row Identification
MEC Visual Inspection Area
Peck Iron and Metal Site
j T Peck Iron and Metal
i' Remedial Investigation Area
Notes:
MEC=munitions and explosives of concern
XRF=x-ray fluorescence
\\gst-srv-01\hglgis\Peck\_MSIHr\SMP_RlFS\
(3-01)Sample_Locs. mxd
11/21/2011 CNL
Source: HGL, Malcolm Pirnie, EPA
ArcGIS Online BingMaps Aerial
v HGL
-------
New Boring1 (Initial or Step Out)
Collect Rotary Sonic Soil Core to Prescribed Depth
(8 or 10 ft)
/Survey Core with PID\
Is There Visual Evidence of
Contamination/ Elevated
PID Readings? /
No
Field Analyze
Offsite Hotspot
0-0.5 ft 0-0.5 ft
0.5 - 2 ft 0.5-2 ft
3 - 5 ft 4 - 6 ft
6 - 8 ft 8 - 10 ft
forXRF, PAH IA, & PCB IA
Pb > 400 mg/kg,\
PCB > 1 mg/kg, or TPH
\ > background?
Yes
No
Submit Samples for
Fixed-Base
Laboratory
Analyses4
/ Should Samples Be N,
Submitted for Fixed-Base
\Laboratory Analyses5?/^
No
Yes
'/Is this an InitiaN^
Phase
Boring? /""^
No
Yes
Have The Budgeted
Number Borings
Been Installed?
Figure 19. Optimization Team-Proposed Soil Investigation Decision Logic
(Offsite Contamination and Hot Spot Assessment)
-------
Figure 19 Footnotes
New boring to be installed could be one of the 31 offsite borings (Offsite Soil Characterization Task),
23 hotspot borings (Hotspot Soil Characterization Task), or follow-up step out borings for either of
these tasks.
2. F.ntire soil core will be initially field screened with a PID in preparation of collecting a field sample
from the portion of each prescribed sample interval exhibits the highest VOC concentration. The
prescribed intervals are adjusted as necessary to reflect field characterization objectives. Each
sample is field-analyzed using XRF, PAH IA, and PCB IA. Note that XRF cannot differentiate between
the different oxidation states of a given species (i.e., Cr+3 vs. Cr+6).
3. Based on the results of the preliminary sampling for PCDD/PCDF compounds in the initial field task
(utility/MEC/MD clearance discussed in Section 4.3.1), an appropriate number of the archived
samples will be selected for PCDD/PCDF analyses in a fixed base laboratory.
4. ^Jisam^l^ from initial boringga/j^^^ottftborings for which all field anal^snesj^teare below
field detection levels will be submitted for fixed-base laboratory analyses.
5. Tj^ip^ejjitage of samples and selectij^ (p^a^ri^^ be submitted for
fixed-base laboratory analyses will be determined by the project team based on data quality
objectives and project financial constraints.
Figure 19 (Continued). Optimization Team-Proposed Soil Investigation Decision Logic
(Offsite Contamination and Hot Spot Assessment]
-------
Define Initial Well Group
Construct Borehole to 8 ft Below Water Table
Log Geology, Screen with PID
Construct/Sample Temporary Well with Screen
Bottom Set at Depth of 8 ft Below Water Table
Field Analyze: Lumex metals, PCB IA, PAH IA
Evaluate Results of
Field Analysis
Should a Step Out
Well be Installed or
Should Drilling Move
to Next Location?
No
T
Is the InstalledX Yes
Well a Step Out ^>
Well? /
//Is This theLast Step
Out Well?
Yes
No
-Is this the Last Well in thex
Initial
Well Group?
Yes
Select Wells for
PCDD/PCDF
Sampling
Figure 20. Optimization Team-Proposed Groundwater Investigation Decision Logic
-------
WDSD-01
WDSW-Oj
WDSD-02*
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 21
Site Drainage and
Wetland Sample Locations
Legend
« Monitoring Well
A Sediment Sample
O Surface Water Sample
O Surface Water Seep Sample
^ Wetland Pre-Pack Well
MW-1R Well or Sample Identification
Malcolm Pirnie 50 foot x 50 foot Sample Grid
Grid Column or Row Identification
Drainage
Road
ii- Railroad
| | Building
Peck Iron and Metal Site
j ~i Peck Iron and Metal
i! Remediation Investigation Area
Environmental Photographic Interpretation
Center Study Area
Wetland
Note:
Actual locations of surface water seep samples to be determined in field.
\\gst-srv-01\hglgis\Peck\_MSIHr\SMP_RlFS\
(3-02) Wetland_Samples. mxd
11/18/2011 CNL
Source: HGL, Malcolm Pirnie, EPA
ArcGIS Online BingMaps Aerial
v HGL
-------
P.CSD-5
PCSW-5
M*M
PCSD-6
RCSW-6=©
PCSD-8
rita
P.CSW-8
I
PCSD-9
PCSW-9
HGLSite Management Plan, RI/FS,
Peck Iron and MetalCity of Portsmouth, VA
Figure 22
Paradise Creek
Sample Locations
Legend
A Sediment Sample
O Surface Water Sample
PCSD-1 Well or Sample Identification
Peck Iron and Metal Site
Note:
Actual locations will be determined in field and based upon identified
flow patterns within Paradise Creek.
\\gst-srv-01\hglgis\Peck\_MSIHr\SMP_RlFS\
(3-03)Paradise_Samples. mxd
11/9/2011 CNL
Source: HGL, Malcolm Pirnie, EPA
ArcGIS Online BingMaps Aerial
v HGL
-------
/Start at North End of
V Drainage
Collect Surface Sediment Sample
Geologically Log &
Screen with PID
Yes
Move 100 ft
South to Next
Sampling
Point or to
Next Break in
Drainage Pipe
if < 100 ft
No
/ Pb > 400 mg/kg, \
PCB > 1 mg/kg, or TPH
\x > background? ^
No
^/Sample for^x
XPCDD/ PCDFJ/
No
Submit Samples for
Fixed-Base Laboratory
Analyses
T
South End of
Drainage?
Yes
End Western Drainage
Sediment Characterization
Task
W-
/Sample Needed for\
Characterzation or
Fixed Base Laboratory
^^Correlation Analysis?/
No
\
Yes
/^Sample for^x
\PCDD/ PCDF?/
No
Yes
Submit Samples for
Fixed-Base Laboratory
Analyses
Move 100 ft South
to Next Sampling
Point or to Next
Break in Drainage
Pipe if < 100ft
Figure 23. Optimization Team-Proposed Sediment Investigation Decision Logic
(Western Drainage)
-------
ATTACHMENT A
TRIP LOG MEMORANDUM FOR FEBRUARY 22, 2012 SITE VISIT
-------
MEMORANDUM
TETRATECH
Date: March 30, 2012
To: Steve Dyment, US EPA OSRTI
From: Mark Shupe, Senior Hydrogeologist, Tetra Tech EMI
Subject: DRAFT - Trip Log: Peck Iron Optimization Review Site Visit, Portsmouth, Virginia,
February 22, 2012
The purpose of this memorandum is to document the Wednesday, February 22, 2012 site visit conducted
at the Peck Iron and Metal Site (the Site) in Portsmouth, Virginia. The site visit was conducted as part of a
remedial investigation (Rl) optimization review.
Site visit attendees included representatives from the U.S. Environmental Protection Agency Region 3
(Region 3), the U.S. Environmental Protection Agency Office of Superfund Remediation & Technology
Innovation (OSRTI), Virginia Department of Environmental Quality (VDEQ), Hydrogeologic, Inc. (HGL),
and Tetra Tech EM Inc. (Tetra Tech); optimization support contractor to OSRTI. The attendees and their
contact information are provided in the following table.
Attendee
Debra Rossi
Bill Hagel
Bruce Pluta
JeffTuttle
Ryan Bower
Stephen Dyment
Durwood Willis
Kevin Green
Kyle Newman
Michelle Hollis
Brett Brodersen
Mark Shupe
Affiliation
Region 3
Region 3
Region 3
Region 3
Region 3
OSRTI
VDEQ
VDEQ
VDEQ
VDEQ
HGL
Tetra Tech
Phone
215-814-3228
215-814-2380
215-814-2380
215-814-3236
215-814-3389
703-402-1857
804-698-4192
804-698-4236
804-698-4452
804-698-4014
703-736-4526
703-390-0653
The site visit consisted of an initial orientation meeting followed by a site walk of the Peck Iron property.
The meeting was held from 9:30 to approximately 11:30 at the US Army Corps of Engineers (USAGE)
field office at the Atlantic Wood Treating Superfund Site located across Elm Avenue from the Site. Steve
Dyment and Mark Shupe facilitated the discussion in accordance with a prepared agenda (Attachment 1).
Major topics included:
General description of current conditions,
Review of key previous investigations,
Description of the preliminary conceptual site model (PCSM) and associated data gaps,
Questions developed from the document review, and
Summary of potential strategies for conducting the remedial investigation (Rl).
The meeting discussions resulted in a list of action items (Attachment 2).
Tetra Tech EM Inc.
1881 Campus Commons Drive, Suite 200, Reston, VA 20I9I
Tel 703.391.5875 Fax 703.391.5876 www.tetratech.com
-------
March 30, 2012
The site walk began at approximately 12:00 noon and was completed by 2:00 PM. The weather was
sunny and calm with temperatures in the 60s (Fahrenheit). The site walk began at the entrance gate and
proceeded from the group of Site buildings near the gate southward along the western boundary to the
southwestern corner of the Site in the vicinity of a recently-constructed wetland adjacent to Paradise
Creek. The walk then paralleled Paradise Creek to the eastern boundary and then northward to the
center of the main Site area. The eastern portion of the Site was visited, followed by a walk back to the
building area and completion at the entrance gate.
An annotated photograph log, available as a Microsoft PowerPoint file, has been uploaded to the EPA
Environmental Science Connector (ESC) web site (https://ssoprod.epa.gov/sso/isp/oblogin.isp)
[Note: Access to the ESC requires EPA authorization. For access support, contact Steve Dyment.]
Notable observations from the site walk included:
A block of masonry-on-slab buildings is located near the entrance gate. The buildings
(approximately six in number) are in poor condition and, because of missing doors and portions
of walls, are apparently opportunistically used for multiple purposes by unidentified individuals.
An unidentified party is using the building nearest the entrance gate for antique vehicle storage.
Within the three adjacent buildings were respectively observed a work bench and storage area, a
hydraulic equipment servicing area, and a drum storage area. Labeling on a group of drums in
the observed drum storage area indicated that the drums contained powdered magnesium. The
drums were staged on a wooden pallet, appeared generally in good condition, and were partially
covered by plastic sheeting.
A storm grate and catchment basin was observed adjacent to the northeastern corner of the
northernmost building. Visual assessment identified that two pipes discharged into the catchment
basin, both of which appeared to originate within the northernmost building.
A contractor is using an area to the south and west of the building area for material and
equipment staging. It is also likely that some of the observed activities (e.g., hydraulic equipment
servicing, work bench activities) in the buildings are attributable to this contractor.
A Sherwin Williams facility occupies the parcel bordering the western Site boundary. Standing
water was observed in a swale adjacent to the Sherwin Williams building. A 1-foot diameter
drainage pipe trending approximately north-south on the Site appears to originate on the Sherwin
Williams property. The pipe is approximately parallel to the western drainage ditch, observed to
be mostly a shallow swale marked by high phragmites. A thin strip of land exists between the
western drainage ditch and the chain-link fence located at the Site boundary.
At various locations, patches of barren soil and areas with stressed vegetation were evident. In
addition, areas of standing surface water were present throughout the Site. The observed
standing water was likely related to the winter storm that struck the area the previous weekend.
High phragmites were observed in the Elizabeth River Keepers-constructed wetland located at
the southwest corner of the site. Although obscured by high vegetation, the remains of a silt
fence were observed that possibly demarcated the wetland boundary.
A residential area borders the opposite side of Paradise Creek to the south of the Site.
In conducting initial sampling that coincided with the Site visit, Bruce Pluta with the Region 3
Biological Technical Assistance Group (BTAG) trapped a minnow from Paradise Creek at he
Site's southern boundary.
Much of the southeastern portion of the Site is underlain by apparent building demolition debris.
Large blocks of concrete, asphalt, wood and other materials daylight to ground surface in this
area.
-------
March 30, 2012
A north-south-trending wooded berm separates much of the Site's central area from the
Southeastern Public Service Authority Refuse Derived Fuel facility (incinerator) to the east. As
marked by high phragmites, a drainage swale parallels, and is located at the toe of, the berm.
Standing water was observed in this swale.
The remains of two former metal processing facilities were observed in the northern central
portion of the Site. A large electrical transformer was located adjacent to the easternmost facility.
Three one-story, cinderblock on-slab buildings are located in eastern portion of the Site. The
largest of these may have served as a maintenance building. A possible vent pipe for an
underground storage tank (UST) was observed at the southwest corner of this building. The
interior of the building was flooded by several inches of water. The two other buildings are
located on the eastern boundary of the site adjacent to Elm Avenue. One of the buildings
apparently was a restroom/change room facility; the other building was possibly an office.
An eastern drainage ditch is referenced in the HGL Rl work plan for the Site. As clarified by Brett
Brodersen (HGL), the eastern drainage ditch is actually located between the block of masonry
buildings near the main entrance gate and the Areff facility that borders the Site to the east. The
ditch is a north-south-trending, open cement tough that originates on the Areff property and is
apparently northward flowing. The southern portion of the ditch is open. The northern portion
located behind the block of masonry buildings is covered by a concrete driveway.
With the attendees' return to the main gate, the site walk was completed. The conclusion of the site walk
marked the end of the site visit.
cc:
Debra Rossi, Region 3
Bill Hagel, Region 3
Bruce Pluta, Region 3
JeffTuttle, Region 3
Ryan Bower, Region 3
Stephen Dyment, OSRTI
Durwood Willis, VDEQ
Kevin Green, VDEQ
Kyle Newman, VDEQ
Michelle Hollis, VDEQ
Brett Brodersen, HGL
-------
Site Log Attachment 1:
Draft Meeting Agenda
-------
Draft Meeting Agenda
Peck Iron & Metal RI Optimization Review
Site Visit (February 22, 2012)
I. Site Visit Objectives
Introduction of Team Members
Summary of Data Review Effort
Summarize Preliminary Conceptual Site Model (PCSM) and Associated Data Gaps /
Uncertainties
Address Outstanding Review Team Questions
Discuss Potential Investigation Strategies
Summary and Action Items
II. Site Description
a. Site History
The site consists of a 33 acre former scrap metal recycling facility which
received materials from Federal and State governments, as well as commercial,
industrial, and private sources.
Period of operation: late 1945 to 1999.
b. Adjacent Land Use
Bounded by industrial/commercial properties and Paradise Creek (tidal
tributary to the Southern Branch of the Elizabeth River)
III. Key Previous Investigations
Hatcher-Sayer, Inc., 1999
Draper Aden Associates, 2003a
Draper Aden Associates, 2003b
Draper Aden Associates, 2005: Sheets A-l and B
Unger, M.A., Vadas, G.G., Harvey, E., and Reiger, J., 2005
Malcolm Pirnie, Inc., 2008: Extent of Contamination Study Report
Hydrogeologic, Inc., 2011: Site Management Plan RI/FS Peck Iron & Metal
IV. Preliminary CSM
a. Topography and Surface Water Drainage
Ground surface elevations generally range from sea level to 10 feet msl
Two north-to-south trending surface water drainage ditches
Paradise Creek and associated wetlands are located along the site's southern
boundary
b. Geology/Hydrogeology
Characterization limited to upper 15 to 20 feet. Site lithology consists of from
1.5 to 12 feet of silty clay fill underlain by sand or clayey sand and locally by
clay. In some areas the fill consists of scrap metal and/or rubble.
Groundwater is encountered at depths ranging from 8 to 12 feet bgs.
Shallow groundwater flow is to the south toward Paradise Creek and to the
north toward the intersection of Elm and Williams avenues; a groundwater
mound is present in the central portion of the site.
-------
c. Constituents of Potential Concern
Soil
o Extensive areas with elevated concentrations of PCB and selected
metals (lead and other metals).
o Elevated TPH-DRO
Groundwater
o PCBs detected down-gradient of maximum concentration area in soils
o Arsenic, nickel, lead, and mercury exceeded screening levels
o Seven VOC compounds exceeded screening levels (benzene,
chlorobenzene, 1,4-dichlorobenzene, MTBE, TCE, 1,3,5-
trimethylbenzene, vinyl chloride)
Sediment
o PCBs detected
o Seven metals exceed screening levels (As, Cd, Cr, Pb, Hg, Ni, Ag)
d. Potential Contaminant Migration Pathways
o Erosion and surface water transport of contaminated soil
o Leaching of soil constituents to groundwater
o Discharge of contaminated groundwater to surface water
o Fugitive dust generation from contaminated soil
V. Currently Identified Data Gaps /Uncertainties
a. Soil
Data are only available for a limited list of analytes;
Lack of data for adjoining properties where potential contaminant releases may
have occurred.
Soil horizons characterized in previous investigations may not be appropriate
for risk assessment purposes.
Potential hotspots exist that have not been characterized.
b. Groundwater
No data available in areas of potential hotspots in soil
Limited analyte list used for previous investigation sampling.
c. Surface Water/Sediment (On/Off-Site)
Limited or no data available ;sampling needed for TAL/TCL
VI. Questions
What is the current plan for site re-use?
Are leaching analyses data available for site soils?
Does a fill thickness/fill type (i.e., soil fill versus rubble) map exist for the site?
Would a benthic macro-invertebrate community evaluation be appropriate for Paradise
Creek?
VII. Potential Strategies for Conducting the RI/FS
Leverage existing site data to the maximum extent possible
Use adaptive sampling approaches with associated field decision logic diagrams
Use field analytical methods for both organic and inorganic constituents
VIII. Summary and Action Items
-------
Site Log Attachment 2:
Draft Optimization Team Action Item List for Peck Iron & Metal Site
-------
DRAFT Optimization Team Action Item List for Peck Iron & Metal Site
3/30/12
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
Action Item
Prepare site visit trip report (including list of attendees and contact information)
Contact Elizabeth River Consortium
Identify stakeholders
Any information on historic dredge spoil disposal - locations on site
Provide VDEQ with Oregon contact (Bryn Thorns) regarding the ongoing Black Butte Mercury
Mine optimization
Upload site visit photograph log to EPA's Environmental Science Connector (ESC)
Determine the approach/assumptions/calculations/modeling performed by VDEQ to establish
the TMDLs for a surface water body like Paradise Creek
Obtain flow/tidal information for Paradise Creek
Approach site owner to assess availability of as-built drawings for buildings, structures, buried
utilities
Obtain from the City of Portsmouth maps showing locations of City sewers and water mains in
the area
Assess TSCA status
Determine status of any remaining site TSCA requirements (How was 2,500 sample
request resolved?)
What is TSCA's role moving forward?
Determine if the City of Portsmouth imposes restrictions on the installation of wells for
water supply purposes
Evaluate the charrette approach for reuse design options and potential input to the
appropriate remedial cleanup levels that should be used for the Rl
Contact Matt Mellon at Region 3 to discuss the following:
How will EPA preserve macro data (e.g. well construction information, boring logs, etc.)
from the Rl?
What format does Region 3 require for EQuiS?
How should a yet-to-be-defined TMDL be considered with regard to defining site ARARs? What
precedents exist for sites wherein a site remedial approach has been selected (and possibly
completed) and the state has re-opened the site because of a TMDL issuance? How has Region
3 handled this situation?
Responsible
Party
Tetra Tech
Tetra Tech
OSRTI
Tetra Tech
Tetra Tech
Tetra Tech
Region 3
Tetra Tech
Region 3
Tetra Tech
Region 3
OSRTI
OSRTI
Status
Completed
Contacting on 3-30-12
To Be Completed
Completed
In progress
Initiating on 3-30-12
To Be Completed
City contacted, direct
contact provided
TB Completed
Contacting on 3-30-12
To Be Completed
To Be Completed
In progress
-------
ATTACHMENT B
PHOTOGRAPHIC LOG FOR FEBRUARY 22, 2012 SITE VISIT
-------
View of front gate from inside the Peck Iron property. Facing north toward Elm Avenue.
-------
View of the main (largest) structure on the Peck Iron property. Looking south/southeast near
entry driveway and access gate. Building is decaying and contains a series of bays used for
various storage and auto restoration activities
-------
Car storage in the northern most bay of the main (largest) structure on the Peck Iron property.
Looking east/southeast, notice roof collapse and other structural issues.
-------
North side of main building on Peck Iron property. Looking west.
-------
Main structure at Peck Iron property. Northeast corner of building facing South. Vat or sump
containing liquid identified at the northeast corner of building.
-------
Close up #1 of vat/sump identified at the northeast corner of the main building on the Peck
Iron property. Sump was 2-3' deep with ~ 1.5' of standing water and had 2 pipes emanating
from the building emptying into this structure.
-------
Close up #2 of vat/sump identified at the northeast corner of the main building on the Peck
Iron property. Sump was 2-3' deep with ~ 1.5' of standing water and had 2 pipes emanating
from the building emptying into this structure.
-------
Middle bay of main building on Peck Iron property. Notice drum storage area and staining of
concrete areas.
-------
Middle bay of main building on Peck Iron property. Close up of drum storage area.
-------
Middle bay of main building on Peck Iron property. Close up of 1 of the drums (powdered
magnesium) contained in the storage area.
-------
Southern most bay of main building on Peck Iron property. Structural building issues,
construction/demolition debris, paint cans and other materials are visible.
-------
South side of main building on Peck Iron property, facing north/northwest. Demolition debris,
excavation equipment and other metals debris are located south of the building.
-------
View from the southeast corner of the main building on Peck Iron property, facing south.
Standing water, excavation equipment, demolition debris piles and other metals debris are
located south of the building. Also note the presence of the concrete structure on the left that
is associated with the surface water feature of the adjacent Areff property.
-------
View from south of the main building on Peck Iron property, facing north. Standing water,
excavation/trucking equipment, demolition debris piles and other metals debris are located south of the
building. On the left side of the photo in the distance to the North you can see the fence bordering the
railroad tracks and Elm Avenue property entrance as well as buildings on the north side of Elm Avenue.
-------
View from southwest of the main building on Peck Iron property, facing north. The Sherwin Williams facility
is the light blue structure to the north. An additional area of excavation/trucking equipment
storage/maintenance and metals debris extend south of the Sherwin Williams facility along the western
property boundary. A pipe appears to extend from the Sherwin Williams property/facility and discharges
surface water in the foreground.
-------
' «' '".-L-- -
1
'
Close up of the pipe extending from the Sherwin Williams facility to the north and discharging
surface water to the Peck Iron property near the excavation/trucking equipment
storage/maintenance and metals debris south of the Sherwin Williams facility along the
western property boundary.
-------
Western drainage feature extending from the Sherwin Williams facility north of the property
along the western property boundary to Paradise Creek in the south.
-------
View of the western drainage feature looking north towards the Sherwin Williams facility. Notice the
heavy vegetation and phragmites associated with this feature. The site is bordered by another industrial
facility (possibly Navy property) to the west. A review of existing data indicates that historical sampling on
the western most portions of the property along this feature may be limited.
-------
Series of pictures showing the 18"-24" pipe extending along much of the western drainage
feature. The pipe is discontinuous and contains a series of junction boxes, connects and
breaks along northern sections of the pipe.
-------
Series of pictures showing the 18"-24" pipe extending along much of the western drainage
feature. Facing south from the middle of the property the pipe appears more competent and
may extend all the way to an outfall in Paradise Creek which can be seen in the distance.
-------
Legend
* Monitoring Well
| £0' x EC' Sampling Cell
Approximate She Boundary
701 Town Center Driie
Suite 6DD
Newcon News. VA 238C6
Monitoring Well Lc-catons
Monitoring well believed to be MW-7 identified in the adjacent site map. View is facing south
towards Paradise Creek. Monitoring wells located were 2 inch diameter and stick up mounted
but they were locked so we could not confirm the well identity.
-------
Located southeast of the monitoring well believed to be MW-7 identified in the previous slide,
facing southwest. Bruce Pluta (R3 BTAG) and Jeff Tuttle (R3 Risk assessor) can be seen
collecting a minnow trap from Paradise creek. There is approximately 100 feet of mud and
wetlands before reaching the creek channel.
-------
Series of photos displaying the minnow/chub species collected in the minnow trap shown in
the previous slide. According to Mr. Pluta and Mr. Tuttle, the likely home range of this species
is less than 100 feet indicating that the species may be both representative of the Paradise
Creek food chain and has likely lived its entire existence along the Creek/Peck Iron property
boundary.
-------
Brett Broderson (HGL) in search of nearby monitoring wells along the southern edge
of the property. The Paradise Creek channel is clearly visible in background. There is
approximately 100 feet of mud and wetlands before reaching the creek channel.
-------
Suite 6DD
Newpor. News, VA 236C6
Monitoring Well
501 x 5D1 Samoling Call
Aoprox'mate She Bojndary
Monitoring Well Locations
The Peck Company
Monitoring well believed to be MW-10 identified in the adjacent site map. View is facing south
towards Paradise Creek which can be seen in the background. Monitoring wells located were 2
inch diameter and stick up mounted but they were locked so we could not confirm the well
identity.
-------
701 Town Ce-ier Ove
Suits 6DD
Newpor News, VA236C6
Monitoring Well
fu1 x 5C' SamDlirrg Cell
Appro* "nate Si:e Bojndary
Monitoring Well Locate is
The Peck Cc-moany
September 2ODS
View from monitoring well believed to be MW-10 identified in the adjacent site map. View is
facing southwest towards Paradise Creek. The structures and tall pine trees shown in the map
are visible in the distance of these photos.
-------
suite eaa
Newpor. Mews. VA 236G6
Legend
* Monitoring Well
| | EC1 x 5Cf Sampling Cell
1 , Approximate She Boundary
Monitoring Well L
The Peck Company
September 2ODS
Figure 2-3
Interface between demolition debris/fill material and the mud/marsh of Paradise Creek, facing
south/southeast. This is the most southern portion of the property and the section of the
Creek that runs north/south can be seen in the distance.
-------
Legend
* Monitoring Well
| | «0' x EC' Sampling Cell
Approximate Gi:e Boundary
Arref
Facility
... . jsi >
Southeastern Public Service
Authority Refuse Derived Fuel
facility (incinerator)
Series of pictures showing demolition debris and conduits (some deeper than 6') to the
subsurface. In addition to standing water, debris piles, and potential subsurface conduits, the
approximate area shown in the adjacent map contained some of the most expansive and
(potentially deepest) fill and construction/demolition debris identified during the site visit. The
bottom photo shows a view of the debris facing north from the area north of MW-10.
-------
Monitoring Well
EO' x 501 Samoling Cell
Appro* 'mate She Bojndarv
701 Town C=":er u>ve
Suite 6DO
Nevreor P,ev»5. VA 23806
Monitoring Well Locations
The Peck Company
September 20D8
Figure 2-3
Metals recycling/crushing facility
shown in later slides
Series of pictures showing demolition debris field.
A monitoring well believed to be MW-9 is
identified in the photos. In the distance of the
bottom photo you can see the small green
building believed to be a metals
recycling/crushing facility.
-------
Legend
* Monitoring Well
| | £0' x EC1 Sampling Cell
Approximate Sile Boundary
Monitoring Well Locations
Tie Fesk Co-npany
September 2QDS
Figure 2-3
Series of photos showing surface water features, debris, and the wooded berm along the eastern
property boundary. In some cases surface water appeared more prevalent (perhaps not solely due to a
winter storm several days before the site visit), due to the presence of phragmites.
-------
Series of photos taken near the metals recycling/crusher facility facing northeast towards the
Southeastern Public Service Authority Refuse Derived Fuel facility (incinerator). Standing water
in this area is believed to be due to a winter storm that struck the area several days before the
site visit.
-------
Series of photos taken near the metals recycling/crusher facility. The photo on the left shows
the operation facility and infrastructure for a claw/crusher as well as metals and other debris
on a concrete pad in the foreground. Behind the facility is a white building, believed to be a
maintenance shop shown in subsequent slides. Some of the highest historical hits of PCBs are
located near this facility. Photos on the left show a transformer likely used in powering the
facility located on east side (back) of the control facility and crushing pad.
-------
Close up inside
the sump
Maintenance facility located just northeast of the metals recycling/crusher facility. The
building and surrounding area was under several inches of standing water. In the foreground of
the photo on the upper left is the sump/piping possibly associated with a LIST.
-------
Legend
* Monitoring Well
SET x Sty Sampling Cell
Aopro* Ttate She Boundary
Suite 6DD
Newport News. VA 236Q6
Monitoring 'A'ell )_ooat:ans
The Peck Comoany
View looking north from the fence line north of maintenance facility. A monitoring well
believed to be MW-8 is identified.
-------
Legend
Monitoring Well
EO1 x EC1 SamDling Cell
Aopro* -nate She Boundary
fDi Town CenterDnve
Moniioring Well _oojtons
The Peck Company
Series of photos of the concrete surface
drainage feature located along the
property boundary with the Arref facility.
------- |