UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
FINAL DECISION
VIRGINIA POLYTECHNIC INSTITUTE AND STATE UNIVERSITY
BLACKSBURG, VIRGINIA
PURPOSE
The United States Environmental Protection Agency (EPA) is issuing this Final Decision and
Response to Comments (FDRTC or Final Decision) selecting the Final Remedy for the Virginia
Polytechnic Institute and State University facility located in Blacksburg, VA (hereinafter referred
to as the Facility). The Final Decision is issued pursuant to the Solid Waste Disposal Act, as
amended by the Resource Conservation and Recovery Act (RCRA) of 1976, and the Hazardous
and Solid Waste Amendments (HSWA) of 1984, 42 U.S.C. Sections 6901, et seq. On January 5,
2015, EPA issued a Statement of Basis (SB) in which it described the information gathered
during environmental investigations at the Facility and proposed a Final Remedy for the Facility.
The SB is hereby incorporated into this Final Decision by reference and made a part hereof as
Attachment A.
This FDRTC selects the remedy that EPA evaluated in the SB. Consistent with the public
participation provisions under RCRA, EPA solicited public comment on its proposed Final
Remedy. On January 15, 2015, notice of the SB was published on the EPA website:
[http://www.epa.gov/reg3wcmd/publicnotice_vatech.html] and in the Roanoke Times
newspaper. The comment period ended on March 27, 2015.
EPA did not receive any comments on the SB; thus, the remedy proposed in the SB is the Final
Remedy selected by EPA for the Facility.
FINAL DECISION
EPA's Final Remedy for Solid Waste Management Units 1 and 2 at the Facility includes the
following:
• Monitored natural attenuation until drinking water standards are met;
• Continuing groundwater monitoring according to Post Closure Permit and
• Compliance with and maintenance of land and groundwater use restrictions.
EPA's Final Remedy also includes No Further Action for 19 SWMUs and 9 Areas of Concern at
the Facility.
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DECLARATION
Based on the Administrative Record compiled for the corrective action at the Virginia
Polytechnic Institute and State University facility, I have determined that the remedy selected in
this Final Decision and Response to Comments, which incorporates the January 5, 2015
Statement of Basis, is protective of human health and the environment.
John
Land and Chemicals Division
U.S. Environmental Protection Agency, Region III
Attachment A: Statement of Basis (January 5, 2015)
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Attachment A
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OF BASIS
VIRGINA POLYTECHNIC INSTITUTE AND STATE UNIVERSITY
BLACKSBURG, VIRGINIA
EPA ID No. VAD074747908
Prepared by
Office of Remediation
Land and Chemicals Division
January 2015
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Table of Contents
Section 1: Introduction
Section 2: Facility Background
Section 3: Summary of Environmental Investigation
Section 4: Summary of Facility Risks
Section 5: Corrective Action Objectives
Section 6: Proposed Remedy
Section 7: Evaluation of Proposed Remedy
Section 8: Financial Assurance
Section 9: Public Participation
Section 10: Index to Administrative Records
19
18
17
12
12
12
15
6
4
5
Figures
Figure 1 - Site Location Map
Figure 2 - Aerial Photograph of Site
Figure 3 - SWMU 1
Figure 4 - SWMU 2
Attachments
Attachment A - No Further Action Determinations
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List of Commonly Used Acronyms
ACL Alternate Concentration Limit
AOC Area of Concern
AR Administrative Record
AST Aboveground Storage Tank
CAMP Corrective Action Monitoring Plan
COC Constituent of Concern
EI Environmental Indicator
EPA Environmental Protection Agency
FDRTC Final Decision and Response to Comments
GPS Groundwater Protection Standard
HASP Health and Safety Plan
HSWA Hazardous and Solid Waste Amendments
MCL Maximum Contaminant Level
MNA Monitored Natural Attenuation
NFA No Further Action
PAH Polynuclear Aromatic Hydrocarbons
PR Presumptive Remedy
RCRA Resource Conservation and Recovery Act
RSL Regional Screening Level
SB Statement of Basis
SL Screening Level
SSL Soil Screening Level
SVOC Semi-Volatile Organic Compound
SWDA Solid Waste Disposal Act
SWMU Solid Waste Management Unit
UST Underground Storage Tank
VADEQ Virginia Department of Environmental Quality
VHWMR Virginia Hazardous Waste Management Regulations
VOC Volatile Organic Compound
VRP Voluntary Remediation Program
VSWMR Virginia Solid Waste Management Regulations
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Section 1: Introduction
The U.S. Environmental Protection Agency (EPA) has prepared this Statement of Basis
(SB) under the Corrective Action Program to solicit public comment on its proposed
remedy for the Virginia Polytechnic Institute and State University (Virginia Tech or the
University) facility located at 459 Tech Center Drive in Blacksburg, Virginia 24061
(Facility or Site).
The Facility is subject to EPA's Corrective Action Program under the Solid Waste
Disposal Act (SWDA), as amended by the Resource Conservation and Recovery Act
(RCRA) of 1976, and the Hazardous and Solid Waste Amendments (HSWA) of 1984, 42
U.S.C. §§ 6901 et seq. (Corrective Action Program). The Corrective Action Program is
designed to ensure that certain owners/operators of facilities subject to RCRA have
investigated and cleaned up any releases of hazardous waste and hazardous constituents
that have occurred at their property. The Commonwealth of Virginia (Commonwealth)
was authorized for the Corrective Action Program under Section 3006 of RCRA on July
31, 2000 (65 Federal Register 46606).
The Commonwealth requested that EPA, in consultation with the Virginia Department of
Environmental Quality (VADEQ), take the lead in overseeing Virginia Tech's
completion of its corrective action obligations at the Facility. In October 2010, EPA and
Virginia Tech entered into an Administrative Order on Consent, Docket No. RCRA-3-
2010-0396CA, (Order) under Section 3008(h) of RCRA, 42 U.S.C. § 6928(h). Under the
Order, Virginia Tech agreed to conduct a RCRA Facility Investigation (RFI) and
Corrective Measures Study (CMS) at the Facility. Virginia Tech has completed the RFI
and CMS for each of the Solid Waste Management Units (SWMUs) and Areas of
Concern (AOCs) at the Facility, with the exception of AOC 5 (Power Plant Underground
Storage Tanks). Based on that information, EPA has prepared this SB.
This SB highlights key information relied upon by EPA in selecting its proposed remedy
for each of the SWMUs and AOCs at the Facility, with the exception of AOC 5. EPA
will issue a separate SB for AOC 5 to solicit public comment once that AOC has been
further evaluated under the Corrective Action Program.
A detailed description of EPA's proposed remedy for the SWMUs and AOCs being
addressed by this SB may be found in Section 6. For additional information, please refer
to the Administrative Record (AR) for the Facility, which contains all documents,
including data and quality assurance information, on which EPA's proposed remedy is
based. The Index to the AR may be found in Section 10 of this SB. See Section 9,
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Public Participation, for information on how you may review the documents contained in
the AR and submit any comments you may have concerning this SB.
Section 2: Facility Background
2.1 Facility Description and History
The Facility is located at 459 Tech Center Drive in Blacksburg, Montgomery County,
Virginia. The Site is bordered to the north and east by residential properties, to the west
by residential and agricultural properties, and to the south by wooded areas and a
research park. The Site covers approximately 4,420 acres. A Site Location Map and
aerial photograph depicting the location and boundaries of the Site are attached to this SB
as Figures 1 and 2, respectively.
Virginia Tech was founded in 1872 as a land-grant college named Virginia Agricultural
and Mechanical College. Virginia Tech is now a comprehensive, innovative research
university. In addition to the 2,600-acre main campus, which has more than 100 campus
buildings, the Facility also includes a 1,700-acre agriculture research farm near the main
campus, and a 120-acre area covered by the Virginia Tech Montgomery Executive
Airport (formerly the Virginia Tech Airport) and the Virginia Tech Corporate Research
Center.
2.2 Environmental Setting
The Town of Blacksburg is located in the Valley and Ridge physiographic province,
which is a belt of folded and faulted clastic and carbonate sedimentary rocks situated
west of the Blue Ridge crystalline rocks and east of the Appalachian Plateaus. The Ridge
is held up by Silurian-age sandstone and quartzite. Virginia Tech is located on structural
block called the Blacksburg Synform created by late Paleozoic movement. The Site is
underlain by Cambrian age carbonate and shale bedrock of the Rome and Elbrook
formations comprised primarily of phyllitic siliciclastics dolomite.
Depth to groundwater in the uppermost aquifer varies from less than 10 feet below
ground surface (bgs) to more than 65 feet bgs. The uppermost aquifer resides in
secondary porosity features including fractures, joints, and bedding planes in the
underlying dolomite and shale bedrock. Groundwater levels and the local topography
both indicate that groundwater in the uppermost aquifer discharges into Stroubles Creek
and groundwater flow direction is generally to the north or west across the Site.
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Section 3: Summary of Environmental Investigation
3.1 Environmental Investigations
EPA has identified a total of 21 SWMUs and 9 AOCs at the Site. Based on a review of
all available information, EPA and the Virginia Department of Environmental Quality
(VADEQ) Site visits on November 8, 2006 and September 23, 2010, and discussions
with Facility representatives, EPA has determined that the only known soil and/or
groundwater impacts relating to the SWMUs and AOCs addressed in this SB are at
SWMUs 1 and 2, described below.
3.1.A SWMU 1 - Former Physical Plant/Quarry Area
Unit Description
SWMU 1 is located in the area between Cowgill Hall and the Perry Street Parking Lot
near Whittemore Hall and contains the area where the Bishop-Favro Building currently
stands. Please refer to Figure 3. From 1935 to 1968, the former Physical Plant was
located in this area and provided maintenance for university buildings and equipment.
The former Physical Plant was comprised of various buildings along with material
storage. In addition, a former quarry that supplied building stone used on campus during
the early part of the 20th century was located adjacent to the former Physical Plant in the
area behind Derring and Cowgill Halls. The former quarry is believed to have operated
from 1899 to 1935. From 1935 until the late 1940s, the former quarry was reportedly
filled with water, and then, subsequently, filled with soil and other fill material from the
late 1940s until 1952. The area of the former quarry is currently covered by asphalt,
various buildings, and grassy areas.
SWMU 1 was discovered on April 21, 1988, during construction of a storm sewer line
from Cowgill Hall toward Perry Street when a number of buried containers were
encountered during the excavation of a trench. Virginia Tech determined that the
containers held metal-bearing paints, tars and oils. The containers and contaminated soil
were excavated and stockpiled adjacent to the trench (north of Cowgill Hall) pending
disposal. VADEQ required Virginia Tech to prepare a Closure Plan under Virginia's
Hazardous Waste Management Regulations (VHWMR) because the stockpiled materials,
referred to as the "contaminated dirt pile," exhibited high levels of lead and arsenic and
were determined to be a hazardous waste. Following removal of the contaminated dirt
pile, sampling and analysis of soil beneath the pile area indicated that an additional 6-
inches of soil needed to be removed. Approximately 380 tons of impacted soil were
removed and transported for off-site for disposal. The excavated area was backfilled with
clean fill. On February 24, 1993, Virginia Tech submitted a Certification of Clean
Closure to VADEQ for review and approval. On April 26, 1993, VADEQ approved the
certification.
Environmental Investigations
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Due to uncertainty regarding the methods by which the former quarry was filled, as well
as the waste handling procedures that were used at the former Physical Plant, Virginia
Tech conducted extensive soil and groundwater investigations of these areas within
SWMU 1 in 1993. In 2002, prior to construction of the Bishop-Favro Hall, Virginia Tech
conducted additional characterization of SWMU 1. The findings of the additional Site
characterization were consistent with the 1993 investigation.
Soil:
Subsurface soil investigations found that fill materials in the former quarry consisted of
soil, organic soils, gravel, rock fragments, coal, ash, cinders, and various debris (i.e.,
bricks, wood, concrete, glass, and metal). The analytical results for soil samples
collected in 1993 and 2002 detected 9 metals, 17 volatile organic compounds (VOCs),
and 18 semi-volatile organic compounds (SVOCs). As part of the 2002 investigation, the
sampling results were compared to VADEQs Tier II and Tier III Voluntary Remediation
Program (VRP) screening levels (SLs).
Tier II SLs are used to evaluate a site for potential residential exposures and are
applicable for unrestricted use of the Site (e.g., residential use). Tier II SLs for soil are
based on the lower (more stringent) screening values of either the EPA Region 3 Risk-
Screening Levels (RSLs) for residential use or the values derived from the EPA Soil
Screening Level (SSL) guidance for migration from soil to air or groundwater assuming
residential use.
Tier III SLs are used to evaluate sites that are or will be restricted to a specified non-
residential use (e.g., industrial use). Tier III SLs for soils are the lower of either the EPA
Region III industrial soil RSLs or the SSL for migration to air or groundwater assuming
commercial or industrial use.
The results for the 2002 soil analyses and screening are discussed below:
• Metals
Arsenic concentrations ranged from 5.55 milligrams per kilogram (mg/kg) to 10.4
mg/kg, which exceeded both the Tier II SL of 0.439 mg/kg and the Tier III SL of
1.60 mg/kg. However, the levels of arsenic detected are representative of
background levels (6.68 to 10.3 mg/kg) based on a statistical comparison of on-
Site arsenic levels to background.
Chromium concentrations ranged from 6.3 mg/kg to 24.7 mg/kg, which exceeded
the Tier II SL of 3 mg/kg but not exceeding the Tier III SL of 63 mg/kg.
Lead concentrations ranged from 5.8 mg/kg to 648 mg/kg, with two samples
exceeding the Tier II SL of 270 mg/kg (EPA RSL 400 mg/kg), but not exceeding
the Tier III SL of 800 mg/kg.
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Barium, cadmium, mercury, selenium, silver, and zinc concentrations did not
exceed their respective Tier II or Tier III SLs.
• VOCs
VOCs were generally detected in soils at very low concentrations. Only two
VOCs, methylene chloride and 1,1,2,2-tetrachloroethane, exceeded their
respective Tier II SLs. Both exceedances were from samples taken near an area
where hazardous materials were removed in 1988 during the installation of a
storm water line. Methylene chloride was found at a concentration of 0.19 mg/kg,
which exceeded the Tier II SL of 0.0187 mg/kg (EPA RSL 56 mg/kg), but not the
Tier III SL of 960 mg/kg. 1,1,2,2-tetrachloroethane was found at a concentration
of 0.01 mg/kg, which exceeded the Tier II SL of 0.000876 mg/kg (EPA RSL
0.056 mg/kg), but not the Tier III SL of 2.8 mg/kg.
• SVOCs
Polynuclear aromatic hydrocarbons (PAHs), a category of SVOCs, were detected
in borings and are likely associated with cinders and ash. Out of the 18 SVOCs
detected, five exceeded their respective Tier II SLs.
Benzo(a)anthracene concentrations ranged from less than 0.204 mg/kg to 0.812
mg/kg which exceed the Tier II SL of 0.15 mg/kg, but not the Tier III SL of 210
mg/kg.
Benzo(b)fluoranthene concentrations ranged from less than 0.204 mg/kg to 0.895
mg/kg, which exceeded the Tier II SL of 0.015 mg/kg, but not the Tier III SL of
2.10 mg/kg.
Benzo(a)pyrene concentrations ranged from less than 0.204 mg/kg to 0.685 mg/kg
with samples exceeding the Tier II SL of 0.15 mg/kg but not exceeding the Tier
III SL of 2.9 mg/kg.
Indeno(l,2,3-cd)pyrene concentrations ranged from less than 0.204 mg/kg to
0.380, which exceeded the Tier II SL of 0.15 mg/kg, but not the Tier III SL of
2.10 mg/kg.
Naphthalene concentrations ranged from less than 0.200 mg/kg to 0.531 mg/kg,
which exceeded the Tier II SL of 0.0298 mg/kg (EPA RSL 3.60 mg/kg), but not
the Tier III SL of 18 mg/kg.
Groundwater:
The Tier II SLs for groundwater are based on federal Maximum Contaminant Levels
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(MCLs) promulgated at 40 C.F.R. Part 141 pursuant to Section 1412 of the Safe Drinking
Water Act, 42 U.S.C. Section 300g-l. For contaminants that do not have an MCL, the
results were screened against the EPA Region 3 RSLs for Tap Water.
The analytical results for groundwater samples collected in 1993 and 2002 detected 11
metals and one VOC. The results of the 1993 and 2002 groundwater analyses are
discussed below:
• Metals
Barium was detected in one monitoring well (MW-5) at a concentration of 3.75
mg/L, above its Tier II SL of 2.0 mg/L. EPA determined that the barium
concentrations from well MW-5 are not representative because MW-5 is located
in a parking lot and the well cap was loose at the time of sampling. Therefore, the
well may have been impacted by run-off. In addition, the groundwater purged
from well MW-5 was grayish and turbid. Based on these circumstances and the
sampling method used, the sporadic detections of metals are most likely related to
high turbidity (suspended solids) in the water samples.
Chromium concentrations ranged from less than 0.001 mg/L to 0.185 mg/L, with
one sample exceeding the Tier II SL of 0.100 mg/L. The sample exceeding the
Tier II SL was collected in 1993 from monitoring well MW-7, which was
reported to be turbid. As with MW-5, EPA determined that the chromium
concentrations from well MW-7 are not representative due to the high turbidity in
the water samples. MW-7 could not be located for resampling in 2002.
Lead concentrations in 1993 ranged from less than 0.001 mg/L to 0.263 mg/L,
and samples from three monitoring wells (MW-1, MW-2, MW-7) and one
Geoprobe boring (CC-1) exceeded the Tier II SL of 0.015 mg/L. The
concentrations of lead detected in MW-1 in 2002 were below the Tier II SL.
Wells MW-2 and MW-7 could not be located for resampling in 2002.
Nickel concentrations ranged from 0.00175 mg/L to 0.25 mg/L, with one sample
exceeding the Tier II SL of 0.030 mg/L. The sample exceeding the Tier II SL was
taken from well MW-7 in 1993. As previously stated, that well was reported to
be turbid in 1993 and could not be located for resampling in 2002.
Arsenic, beryllium, cadmium, copper, selenium, silver, and zinc concentrations
did not exceed their respective Tier II SLs.
• VOCs
Chloroform was the only VOC detected in the 1993 or 2002 groundwater
sampling events: it was detected in the hydraulicly upgradient wells MW-1 and
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MW-6. Chloroform concentrations ranged from 0.004 mg/L to 0.027 mg/L,
which are below the Tier II SL of 0.080 mg/L.
Additional Groundwater Investigation:
Of the seven monitoring wells that were part of the 1993 Site investigation, only two
monitoring wells remain: MW-1 and MW-61. Wells MW-1 and MW-6 are hydraulically
upgradient of SWMU 1. The other five wells were inadvertently destroyed or paved over
during construction activities. In November 2010, Virginia Tech sampled and analyzed
the groundwater from MW-1 and MW-6 for the presence of metals, VOCs and SVOCs
(including PAHs). All of the constituents detected in MW-1 and MW-6 were at
extremely low concentrations, and none of the constituents were detected above their
respective Tier II SLs.
3.1.B SWMU 2 - Closed Sanitary Landfill (Solid Waste Facility Permit No. 109)
Unit Description
SWMU 2 is a closed, solid waste landfill located to the west of Route 460 Bypass and to
the north of Prices Fork Road. Please refer to Figure 4. The landfill was approximately
4.5 acres in size, was unlined and received general University solid waste. On May 30,
1973, the Virginia Department of Health, subsequently renamed VADEQ, issued Solid
Waste Permit No. 109 (Permit No. 109) to Virginia Tech for this landfill. Waste was last
placed in the landfill on June 30, 1989. The University's solid waste is now shipped off-
site for disposal to a local permitted sanitary landfill.
During operation of SWMU 2, Virginia Tech constructed eight trenches which received
waste without a base liner or leachate collection system. Additionally, asbestos was
placed in one section of the landfill. In accordance with applicable regulations, trenches
1 through 6 were closed prior to December 1988 and capped with a soil cover. Trenches
7 and 8 were closed in October 1994 and capped with a soil cap in accordance with a
January 1994 VADEQ-approved Closure Plan. On October 7, 1994, Virginia Tech
submitted a certification of closure for SWMU 2 to the VADEQ for approval.
Constituents of Concern, Post-Closure Care & Groundwater Monitoring
Permit No. 109 was amended on June 14, 2002 to establish Groundwater Protection
Standards (GPSs) and to update the Groundwater Monitoring Program for SWMU 2.
GPSs are based on MCLs or VADEQ-approved, site-specific, background concentration
levels, when applicable. For a contaminant that does not have an MCL and a site-
specific, background concentration has not been established, the Virginia Solid Waste
Management Regulations (VSWMR) requires landfill owners/operators to adopt risk-
based Alternative Concentration Limits.
1 During early investigations of the Facility, well MW-6 had been identified as a separate area of concern
and referred to as AOC 6. Upon further evaluation, EPA has included MW-6 in SWMU 1.
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On July 7, 2005, VADEQ issued a second amendment to Permit 109 to establish a
groundwater Corrective Action - Presumptive Remedy (PR) Program due to the
detection of VOCs (i.e., chloroethane and vinyl chloride) hydraulically downgradient of
SWMU 2 at concentrations greater than the GPSs.
The groundwater Corrective Action - PR for SWMU 2 includes the following passive
and active engineering controls to prevent exposure to solid waste, reduce source
concentrations and limit migration impact: closing and covering of the waste unit to limit
the source of impact; restricting Site access to authorized personnel; managing landfill
gas to remove VOCs from the waste and reduce saturation to limit leachate production;
and, monitoring natural attenuation of VOCs to evaluate migration of impacted
groundwater. In addition, under Permit No. 109, VADEQ requires Virginia Tech to
maintain the landfill cap in accordance with the provisions for post-closure care in the
VSWMR.
In October 2005, Virginia Tech began implementing a VADEQ-approved Corrective
Action Monitoring Plan (CAMP) as part of the groundwater Corrective Action - PR.
The current contaminants of concern (COCs) which exceed their applicable GPSs for
SWMU 2 and are actively being monitored under the CAMP include:
• 1,1-Dichloroethane - 11 gram per liter (ug/1) (MW-3) compared to GPS (1.878 ug/1)
• Arsenic - 13.9 ug/1 (MW-2) compared to GPS (10 ug/1)
• Cobalt - 21.2 ug/1 (MW-4) compared to GPS (4.695 ug/1)
• Vinyl Chloride - 11 ug/1 (MW-3) compared to GPS (2.0 ug/1)
Every three years Virginia Tech prepares and submits to VADEQ for approval, a
Corrective Action Evaluation Report (Evaluation Report) in which it assesses how
effective monitored natural attenuation is preforming. On July 8, 2014, Virginia Tech
submitted an Evaluation Report which shows that 1,1 -dichloroethane and vinyl chloride
concentrations in groundwater are decreasing. Cobalt and arsenic groundwater
concentrations are stable. All COC groundwater concentrations are below ten times their
GPS.
The Evaluation Report also shows that the natural attenuation processes are limiting COC
migration to approximately 150 feet downgradient of the waste unit. Groundwater flow
and constituent migration appear to be at a steady-state. The predicted maximum extent
of COC migration will remain within the Facility property, and does not threaten off-site
groundwater sources. In addition, there are no complete exposure-pathways for
contaminated groundwater within the Facility property. Therefore, under the current use
scenario, there is no threat to human health or the environment presented by Facility-
related contaminated groundwater.
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Section 4: Summary of Facility Risks
EPA has determined that soils and groundwater associated with SWMUs 1 and 2 do not
pose a threat to human health or the environment under the current and anticipated non-
residential use EPA sets national goals to measure progress toward meeting the nation's
major environmental goals. For Corrective Action, EPA evaluates two key
environmental indicators for each facility: (1) current human exposures under control and
(2) migration of contaminated groundwater under control. EPA has determined that the
Facility met these indicators on March 21, 2011 and December 27, 2011, respectively.
Section 5: Corrective Action Objectives
5.1 Soil
EPA's Corrective Action Objective for Facility soils is to control exposure to the
hazardous constituents remaining in soils.
5.2 Groundwater
EPA's Corrective Action Objectives for Facility groundwater is to restore the
' groundwater to drinking water standards (MCLs) or site specific background levels as
applicable and until such time as those standards are achieved, to control exposure to the
hazardous constituents remaining in the groundwater through engineering and/or
groundwater use restrictions.
Section 6: Proposed Remedy
6.1 Soils
The proposed remedy for soils in SWMUs 1 and 2 consists of land-use restrictions to be
implemented through use restrictions (See Section 6.3) which will restrict those areas to
non-residential uses. EPA has determined that VADEQ's VRP Tier III SLs (based on
EPA Region 3's RSLs for Industrial Soils) for direct contact with soils are protective of
human health and the environment for individual contaminants at this Facility, provided
that the Facility is not used for residential purposes at SWMUs 1 and 2. Based on the
available information, there are currently no unacceptable risks to human health and the
environment via the soil or vapor intrusion pathways for the present and anticipated non-
residential use of SWMUs 1 and 2.
6.2 Groundwater
SWMU1
The proposed remedy for the groundwater associated with SWMU 1 is no further action.
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SWMU2
The proposed remedy for the groundwater associated with SWMU 2 is natural
attenuation with continuation of the groundwater monitoring program already in place for
SWMU 2 until drinking water standards are met and, until those standards are met, the
implementation of groundwater use restrictions (See Section 6.3).
Monitoring at the Facility for groundwater has shown that the contaminants are
effectively being addressed by natural attenuation. The groundwater plume associated
with SWMU 2 appears to be stable (not migrating), and concentrations of COCs are
either stable or declining over time. The most contaminated groundwater is less than ten
times levels appropriate for use as drinking water. While groundwater is not used on the
Facility for drinking water, and no downgradient users of off-site groundwater have been
identified, EPA is requiring groundwater use restrictions be implemented to prohibit use
of the groundwater.
In accordance with Permit No. 109, Virginia Tech is required to conduct post-closure
care activities including maintaining the landfill cap, addressing leachate issues, and
monitoring groundwater and landfill gas in accordance with the CAMP. Therefore, EPA
has determined that the operation and maintenance and monitoring actions necessary to
assure continued protection of human health and the environment at SWMU 2 are already
in place and required by Permit No. 109 issued in accordance with the provisions of §
10.1-1408.l.A, Chapter 14, Title 10.1, Code of Virginia (1950), as amended.
6.3 Use Restrictions and Other Requirements
Under this proposed remedy, some contaminants remain in the soil and groundwater at
the subject SWMUs above levels appropriate for residential uses. Because some
contaminants remain in the soil and groundwater at the Facility at levels which exceed
residential use, EPA's proposed decision requires the compliance with and maintenance
of land and groundwater use restrictions at SWMUs 1 and 2.
The restrictions shall include, but not be limited to, the following land and groundwater
use restrictions:
1. Groundwater at the Facility shall not be used for any purpose other than the
operation, maintenance, and monitoring activities required by VADEQ in consultation
with EPA, unless it is demonstrated to EPA, in consultation with VADEQ, that such use
will not pose a threat to human health or the environment or adversely affect or interfere
with the selected remedy and EPA, in consultation with VADEQ, provides prior written
approval for such use;
2. The property within SWMU 1 and SWMU 2 shall not be used for residential
purposes unless it is demonstrated to EPA, in consultation with VADEQ, that such use
will not pose a threat to human health or the environment or adversely affect or interfere
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with the final remedy, and EPA, in consultation with VADEQ, provides prior written
approval for such use;
3. All earth moving activities, including excavation, drilling and construction
activities, in the areas at SWMUs 1 and 2 at the Facility where any contaminants remain
in soils above EPA's Screening levels for non-residential use or in groundwater above
MCLs, or Tap Water RBCs, if applicable, shall be prohibited unless it is demonstrated to
EPA, in consultation with VADEQ, that such activity will not pose a threat to human
health or the environment or adversely affect or interfere with the final remedy, and EPA,
in consultation with VADEQ, provides prior written approval for such use;
4. The Facility property will not be used in a way that will adversely affect or
interfere with the integrity and protectiveness of the final remedy;
5. No new wells will be installed on Facility property unless it is demonstrated to
EPA, in consultation with VADEQ, that such wells will not pose a threat to human health
or the environment or adversely affect or interfere with the final remedy, and EPA, in
consultation with VADEQ, provides prior written approval to install such wells.
In addition to the above use restrictions, the following obligations and requirements shall
also be met. Owner agrees to allow the EPA, VADEQ, and/or their authorized agents and
representatives, access to the Property to inspect and evaluate the continued effectiveness
of the final remedy and, if necessary, to conduct additional remediation to ensure the
protection of the public health and safety and the environment based upon the final
remedy to be selected by EPA in the Final Decision and Response to Comments
(FDRTC). In addition, the Facility shall provide EPA with a coordinate survey as well as
a metes and bounds survey, of the Facility boundary. Mapping the extent of the land use
restrictions will allow for presentation in a publicly accessible mapping program such as
Google Earth or Google Maps.
If EPA or VADEQ determines that additional use restrictions or other corrective actions
are necessary to protect human health or the environment, EPA and VADEQ have the
authority to require and enforce such additional corrective actions, provided any
necessary public participation requirements are met.
6.4 No Further Action
EPA is proposing No Further Action (NFA) for 19 SWMUs and 9 AOCs at the Facility
that have been investigated and remediated or that have been investigated and determined
to pose no unacceptable risk to human health and the environment. For a detailed
description and environmental summary of the NFA SWMUs and AOCs, please refer to
Attachment A.
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January 2015
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Section 7: Evaluation of Proposed Remedy
This section provides a description of the criteria EPA used to evaluate the proposed
remedy consistent with EPA guidance. The criteria are applied in two phases. In the first
phase, EPA evaluates three decision threshold criteria as general goals. In the second
phase, for those remedies which meet the threshold criteria, EPA then evaluates seven
balancing criteria.
Threshold
Criteria
Evaluation
1) Protective of
Human Health and
the Environment
With respect to soils, contaminated soil is below the surface
and contained within Facility property. To prevent or control
the exposure to impacted soil where contamination above
residential screening levels remains in place, EPA has
proposed land-use restrictions in order to minimize the
potential for human exposure to that contamination.
With respect to groundwater, while low levels of contaminants
are present in the groundwater hydraulically downgradient of
SWMU 2, the migration of such contaminants has stabilized
and the contaminants have not migrated beyond the Facility
property (see Exhibit 17). For this reason, the area of
contaminated groundwater associated with SWMU 2 is
contained. The groundwater monitoring program already in
place for SWMU 2 will continue MCLs or background levels
are met. In addition, the implementation of groundwater use
restrictions will prevent the use of impacted groundwater at
SWMU 2.
2) Achieve Media
Cleanup Objectives
EPA's proposed remedy meets the appropriate cleanup
objectives based on assumptions regarding current and
reasonably anticipated land and groundwater use(s). The
anticipated future land use for SWMUs 1 and 2 is non-
residential. The majority of impacted soils contain
contaminant concentrations that are below the Tier II SLs for
residential use. For those areas where contaminant
concentrations are above the Tier II SLs, use restrictions will
be implemented to control potential risks and eliminate
exposure pathways.
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January 2015
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3) Remediating the
Source of Releases
In all remedy decisions, EPA seeks to eliminate or reduce
further releases of hazardous wastes or hazardous constituents
that may pose a threat to human health and the environment.
There are no remaining large, discrete sources of waste at the
Facility from which hazardous constituents would be released
to the environment. Wherever possible and practical,
contaminated soils from SWMU 1 were excavated and
disposed off-site. The Facility has remediated the source of
releases from SWMU 2 through closure and post-closure
activities as required by the VSWMR. In addition, the
groundwater beneath SWMU 2 is actively monitored to ensure
that contaminated groundwater is not migrating off-site. For
both SWMUs 1 and 2, use restrictions will be established to
control earth moving activities and restrict residential use at
these units. Therefore, EPA has determined that this criterion
has been met.
Balancing
Criteria
Evaluation
4) Long-term
effectiveness
The proposed remedy will remain protective of human health
and the environment over time by controlling exposure to the
hazardous constituents remaining in soils and groundwater.
EPA's proposed remedy requires the compliance with and
maintenance of land and groundwater use restrictions at the
Facility. In addition, a groundwater monitoring program
already in place for SWMU 2 will continue until groundwater
clean-up standards are met.
5) Reduction of
toxicity, mobility, or
volume of the
Hazardous
Constituents
Contaminated soils were removed from SWMU 1 eliminating
the known source of contamination and greatly reducing the
toxicity, mobility and volume of hazardous constituents
remaining in the soils. With respect to SWMU 2, the
groundwater monitoring system confirms that contamination
from SWMU 2 is not migrating off-site and the plume has
stabilized. In addition, the Facility is required to monitor the
groundwater annually to ensure that COCs are not being
released and/or migrating from SWMU 2 above clean-up
standards.
6) Short-term
effectiveness
EPA's proposed remedy does not involve any activities, such
as construction or excavation, which would pose short-term
risks to workers, residents, and the environment.
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January 2015
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7) Implementability
EPA does not anticipate any regulatory constraints in
implementing its proposed remedy. EPA proposes to
implement the use restrictions through an enforceable
mechanism such as an order, environmental covenant and/or
state regulations.
With respect to SWMU 2, all necessary components for post-
closure care and groundwater monitoring activities are being
implemented under Permit No. 109 issued pursuant to the
VSWMR.
8) Cost
EPA's proposed remedy is cost effective. The cost of the post-
closure activities and groundwater monitoring of SWMU 2 is
approximately $80,000 per year.
9) Community
Acceptance
EPA will evaluate community acceptance of the proposed
remedy during the public comment period and it will be
described in the Final Decision and Response to Comments.
10) State/Support
Agency Acceptance
VADEQ has reviewed and concurred with the proposed
remedy for the Facility during November 2014. Furthermore,
EPA has solicited VADEQ input and involvement throughout
the investigation process at the Facility.
Section 8: Financial Assurance
EPA has evaluated whether financial assurance for corrective action is necessary to
implement EPA's proposed remedy at the Facility. Given that EPA's proposed remedy
does not require any further engineering actions to remediate soil, groundwater or indoor
air contamination at this time and given that the post-closure activities and groundwater
monitoring of SWMU 2 is approximately $80,000 per year, EPA is proposing that no
financial assurance be required.
Virginia Polytechnic Institute & State University
January 2015
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Section 9: Public Participation
Before EPA makes a final decision on its proposed remedy for the Facility, the public
may participate in the decision selection process by reviewing this SB and documents
contained in the Administrative Record (AR) for the Facility. The Index to the AR may
be found in Section 10 of this SB. The AR contains all information considered by EPA
in reaching this proposed remedy. It is available for public review during normal
business hours at:
Interested parties are encouraged to review the AR and comment on EPA's proposed
remedy. The public comment period will last thirty (30) calendar days from the date that
notice is published in a local newspaper. You may submit comments by mail, fax, or e-
mail to Mr. Ed Hotham. EPA will hold a public meeting to discuss this proposed remedy
upon request. Requests for a public meeting should be made to Mr. Ed Hotham.
EPA will respond to all relevant comments received during the comment period. If EPA
determines that new information warrants a modification to the proposed remedy, EPA
will modify the proposed remedy or select other alternatives based on such new
information and/or public comments. EPA will announce its final remedy and explain
the rationale for any changes in a document entitled the Final Decision and Response to
Comments (FDRTC). All persons who comment on this proposed remedy will receive a
copy of the FDRTC. Others may obtain a copy by contacting Ed Hotham at the address
listed above.
U.S. EPA Region III
1650 Arch Street
Philadelphia, PA 19103
Contact: Ed Hotham
Phone: (215) 814-2820
Fax: (215)814-3113
Email: hotham.leonard@epa.gov
J<
L
US EPA, Region III
Virginia Polytechnic Institute & State University
January 2015
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Section 10: Index to Administrative Record
1. Draft RCRA Site Visit Report for Virginia Tech, prepared by Tetra Tech, Inc. for
VADEQ and USEPA, April 2007.
2. Site Visit Memo to File, prepared by Jeanna R. Henry, USEPA Project Manager,
September 28, 2010
3. 3008(h) Administrative Order on Consent, Docket No. RCRA-03-2010-0396CA,
entered into by Virginia Tech and USEPA, September 29, 2010
4. Description of Current Conditions for Virginia Polytechnic Institute and State
University, prepared by Environmental Health and Safety Services Virginia Tech and
Draper Aden Associates for USEPA, December 20, 2010
5. Supplemental Information associated with December 2010 Description of Current
Conditions prepared by Virginia Tech for USEPA, July 1, 2011
6- Hazardous Materials Survey Report for Davidson Hall Virginia Polytechnic Institute
and State University, prepared by Professional Service Industries, Inc. for Einhorn
Yaffee Prescott Architecture & Engineering, P.C., September 25, 2008
7. Elizabeth Lohman, Environmental Program Planner, VADEQ, e-mail dated
5/14/2012 to Jeanna R. Henry, Project Manager, USEPA - addresses potential soil
contamination discovered at Davidson Hall during renovation activities.
8. Elizabeth Lohman, Environmental Program Planner, VADEQ, e-mail dated 5/4/2012
to Rob Lowe, Project Manager, Virginia Tech, - addresses soil contamination
discovered at Davidson Hall during renovation activities.
9. Closure of Davidson Hall Hazardous Waste Accumulation Area, Memo from Frank
Imperatore to File, February 2, 2012
10. Correspondence from Draper Aden Associates to Elizabeth Lohman, VADEQ,
Environmental Program Planner, regarding Davidson Hall Renovations and Soil
Sampling Results and Recommendations, DAA Job No. B10131B-05, May 16, 2012
11. Correspondence from Virginia Tech to Jeanna Henry, USEPA, Project Coordinator,
regarding Davidson Hall Soils Management, June 14, 2012
12. Quarterly Progress Report for Virginia Polytechnic Institute and State University,
prepared by Environmental, Health and Safety Virginia Tech and Draper Aden
Associates for USEPA, September 1, 2012
Virginia Polytechnic Institute & State University
January 2015
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13. Davidson Hall Soil Sampling, prepared by Draper Aden Associates for USEPA, July
8,2014
14. Quarterly Progress Report for Virginia Polytechnic Institute, prepared by
Environmental, Health and Safety Virginia Tech and Draper Aden Associates for
USEPA, December 1, 2012
15. Documentation of Environmental Indicator Determination, Current Human Exposures
Under Control, completed by Jeanna Henry, EPA Project Manager, 3/21/2011
16. Documentation of Environmental Indicator Determination. Migration of
Contaminated Groundwater Under Control, completed by Jeanna Henry, EPA Project
Manager, 12/22/2011
17. Corrective Action Status Evaluation, prepared by Environmental, Health and Safety
Virginia Tech and Draper Aden Associates, July 8, 2014
Virginia Polytechnic Institute & State University
January 2015
Page 20
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ATTACHMENT A
NO FUTHER ACTION DETERMINATION
VIRGINA POLYTECHNIC INSTITUTE AND STATE UNIVERSITY
BLACKSBURG, VIRGINIA
EPA ID No. VAD074747908
-------
Supporting Information for
No Further Action Determination
Based on a review of all available information, EPA and VADEQ November 8, 2006 and
September 23, 2010 Site visits, and discussions with Facility representatives, EPA has concluded
that there are no unaddressed releases of hazardous waste or hazardous constituents from the
SWMUs and AOCs described below. All documents on which EPA's proposed decision is based
are contained in the Administrative Record (AR) and available upon request.
1. SWMU 3 - Closed Pathological Incinerator
SWMU 3 is located to the west of the Route 460 Bypass and to the north of Prices Fork Road,
adjacent to SWMU 2. VADEQ issued Virginia Tech a solid waste permit (Permit No. 185) on
April 30, 1975 for the operation of this unit (ECP Model 1000-T Oil-Fired Pathological
Incinerator), which was used to incinerate pathological waste. The incinerator accepted animal
wastes generated by various Virginia Tech animal research and production facilities and typically
operated one day per week. Wastes were delivered to the incinerator facility by the individual
generators where they were immediately loaded into the charging chute of the incinerator and
incinerated.
On January 7, 2003, Virginia Tech submitted a Closure Plan for the incinerator which was
subsequently approved by VADEQ on April 17, 2003. Closure activities included the removal of
all waste residuals (ash), decontamination of all interior building surfaces that may have come into
contact with pathogens, and dismantling and removal of incinerator equipment. All waste
residuals were shipped off-site for disposal to a permitted sanitary landfill, and the dismantled
incinerator equipment was either shipped off-site for recycle or disposed. On February 24, 2004,
Virginia Tech submitted a Certification of Closure to VADEQ for SWMU 3. In correspondence
dated April 5, 2004, VADEQ confirmed closure of SWMU 3 in accordance with the approved
Closure Plan.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment taking into consideration there are no known or documented releases or
environmental impacts associated with SWMU 3; the incinerator was housed within a brick
building constructed with a concrete floor ensuring any spills would have been contained; and,
staining was not observed in the area of the building that housed the unit. Moreover, the wastes
handled by this unit did not contain hazardous constituents.
2. SWMU 4 - Closed Sanitary Landfill (Permit No. 248)
On June 16, 1978, Virginia Tech was issued Solid Waste Permit No. 248 by the Virginia
Department of Health for the operation of a sanitary landfill (SWMU 4). The landfill was only
Virginia Polytechnic Institute & State University
No Further Action Determination
April 2013
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permitted to receive institutional fly ash, presumably from Virginia Tech's coal-fired Power Plant
(SWMU 14). According to the Permit, SWMU 4 is located at the western end of the east-west
runway at the Virginia Tech Airport (now known as the Virginia Tech Montgomery Executive
Airport) located on Ramble Road. The landfill was closed by the Virginia Department of Waste
Management prior to 1988.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 4.
3. SWMU 5 - Asbestos Waste Storage Trailer
During university maintenance and renovation projects, small amounts of asbestos wastes are
generated (e.g., pipe insulation, floor tiles). These wastes are contained and stored in a designated,
locked storage trailer (SWMU 5) located on Tech Center Drive. Once the trailer contains a
sufficient amount of material, the asbestos waste is shipped off-site in accordance with applicable
regulations to a permitted asbestos landfill (i.e., H.A.M. Sanitary Landfill in Peterstown, WV).
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 5.
4. SWMU 6 - Dairy Science Lagoons
The Virginia Tech Dairy Science Center (Center) is located at the intersection of Southgate Drive
and the Route 460 Bypass. The Dairy Science Center maintains the university's dairy herd and
includes feed lot, feed storage, milking center, barn, offices and other associated buildings.
Manure generated from the feed lot and barn is conveyed by water to manure lagoons located at
the Center under General Permit No. VPG100013. SWMU 6 includes three concrete-lined lagoons
used by the Center to manage animal waste and an unlined lagoon used to manage stormwater.
Historically, the unlined lagoon, currently used to manage the Center's stormwater, was used to
manage a mixture of manure and water. In February 1994, the unlined lagoon was filled to the
point of overflowing during a period of wet weather. A Virginia Tech employee siphoned the
excess manure and water to prevent an overflow and possible breaching of the lagoon. VADEQ
was notified regarding the discharge and it was discovered during an inspection that the discharge
manure/water mixture was being directed to a tributary of Stroubles Creek, resulting in the
issuance of a Notice of Violation (NOV) by VADEQ on April 8, 1994.
Immediately following the VADEQ inspection, Virginia Tech partially emptied the lagoon and
shipped the effluent to the local publically owned treatment works (POTW) for treatment.
Analysis of the material that was siphoned from the lagoon indicated that human waste was present
Virginia Polytechnic Institute & State University
No Further Action Determination
April 2013
Page 2
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in the manure/water mixture. A subsequent investigation of the restrooms and sinks at the Center
revealed they discharged to the manure lagoon. The restrooms were immediately closed and
portable toilets were installed on-site until a new sanitary sewer line could be constructed and
connected to the restrooms. Following the 1994 release, Virginia Tech also developed a University
Nutrient Management Plan which specifies how manure is managed and land applied under the its
Virginia Pollution Abatement (VPA) Permit, issued by VADEQ on March 10, 1995.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment taking into consideration there are no known environmental impacts associated with
SWMU 6 and the wastes handled by this unit did not contain hazardous constituents. The Center's
lagoons are managed under VADEQ oversight.
5. SWMU 7 - Sterrett Center Maintenance Complex Former Hazardous Waste
Accumulation Area
The former hazardous waste accumulation area located at the Sterrett Center Maintenance
Building was a less than 90-day accumulation unit used to store hazardous lead and paint related
wastes generated from maintenance activities. This unit consisted of an exterior concrete pad
surrounded by a wire fence with a capacity of approximately twenty 55-gallon drums.
In correspondence dated April 26, 1993, Virginia Tech notified VADEQ of its intent to close
SWMU 7 and transfer hazardous waste from this accumulation area to another hazardous waste
accumulation area (SWMU 8) located at the Virginia Tech Airport. All wastes would be removed
from SWMU 7 and transferred to SWMU No. 8 by April 29, 1993. The concrete pad and wire
fence associated with SWMU No. 7 were removed and shipped off-site for disposal. The adjacent
maintenance facility was expanded and now covers the area where SWMU 7 was previously
located.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 7. This former hazardous waste accumulation area was used to accumulate hazardous
wastes in containers on a concrete pad. In the event of a spill, the concrete would ensure
containment of the spilled material avoiding a release of hazardous waste or hazardous constituents
into the environment. In addition, access to the accumulation area was restricted to protect against
improper management of the hazardous wastes. All materials of construction associated with this
unit have been removed from the Facility and properly disposed off-site.
6. SWMU 8 - Virginia Tech Airport Former Hazardous Waste Accumulation Area
SWMU 8, located on Ramble Road, was Virginia Tech's main less than 90-day hazardous waste
accumulation area used to store hazardous and non-hazardous waste. This unit, commonly referred
to as "the Hill," was in operation between 1995 and 2010. SWMU 8 consists of a covered concrete
Virginia Polytechnic Institute & State University
No Further Action Determination
April 2013
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pad, two waste storage buildings, and various storage areas for supplies all surrounded by a locked,
barbed wire fence. Hazardous and non-hazardous wastes generated by the University were
transported to SWMU 8 from various waste accumulation areas and shipped off-site for disposal.
Hazardous wastes were segregated by class and stored in the waste storage buildings. Non-
regulated, petroleum and electronic wastes were stored on the covered pad.
In October 2010, Virginia Tech opened its newly constructed Materials Management Facility
(MMF); as a result, all wastes were removed from SWMU 8 and either shipped off-site or
transferred to the MMF, and all hazardous and non-hazardous wastes are now stored at the new
MMF.
EPA has concluded that SWMU 8 does not pose an unacceptable risk to human health and/or the
environment. To safe guard against vandalism and/or improper management of hazardous waste,
access to the accumulation area was restricted to selected Virginia Tech employees. No major
spills, leaks or releases have occurred at SWMU 8 and there are no known environmental impacts
associated with this unit. Minor releases of petroleum at the site have been contained and
immediately cleaned up. EPA did not observe any staining or signs of releases for this area during
its November 2006 and September 2010 Site visits.
7. SWMU 9 - Former Davidson Hall Hazardous Waste Accumulation Area
SWMU 9 was a less than 90-day hazardous waste accumulation area located in Room 15 of the
former Davidson Hall located at Drillfield Drive. This unit was equipped with secondary
containment. Containers of hazardous waste were accumulated in metal cabinets, on open metal
shelves, the floor, and in covered bins. The wastes were transferred from SWMU 9 to SWMU 8
up until October 2010, at which time SWMU 8 was taken out of operation and all hazardous wastes
were transferred to Virginia Tech's new MMF. SWMU 9 underwent closure on February 2, 2012
which is documented in a Virginia Tech Memo from Frank Imperatore to File.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 9. This former hazardous waste accumulation area was used to accumulate hazardous
wastes in containers on a concrete pad. In the event of a spill, the concrete would ensure
containment of the spilled material avoiding a release of hazardous waste or hazardous constituents
into the environment. In addition, access to the accumulation area was restricted to protect against
improper management of the hazardous wastes. All materials of construction associated with this
unit were removed and disposed following demolition of the section of Davidson Hall that housed
SWMU 9.
8. SWMU 10 - Former Hazardous Waste Accumulation Areas; HWMU 1, HWMU 2,
HWMU 3 and HWMU 4
Virginia Polytechnic Institute & State University
No Further Action Determination
April 2013
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SWMU 10 includes four former less than 90-day hazardous waste accumulation areas in the
following locations:
• Room 13-A located in the Health and Safety Building. This former hazardous waste
accumulation area, formerly referred to as Hazardous Waste Management Unit (HWMU)
1 consisted of a flammable storage cabinet used to store mercury and flammable materials.
This unit was in operation from pre-January 1992 until January 1994.
• Room 15 located in the basement of Davidson Hall. This former hazardous waste
accumulation area, formerly referred to as HWMU 2, consisted of three metal cabinets,
one set of open-face metal shelves, and an area of concrete floor under a 4'x4' wooden
table. This unit was used to accumulate ignitable, corrosive and toxic characteristic wastes,
in addition to listed spent halogenated and non-halogenated solvents between November
1991 and 1996.
• Room 4 located in the basement of Randolph Hall. This former hazardous waste
accumulation area, formerly referred to as HWMU 3, consisted of a 14'xl8' section of
cement floor and was used to accumulate ignitable, corrosive and toxic characteristic
wastes, in addition to listed spent halogenated and non-halogenated solvents. The dates of
operation for this unit are unknown.
• Section of the Insecticide and Fungicide Storage Building located at the Glade Road Plant
Pathology Facility. This former hazardous waste accumulation area, formerly referred to
as HWMU 4, consisted of six metal shelves used to store various pesticides. In 1991, a 5-
gallon container holding a mixture of kerosene/crude oil, water, sand, and sodium dodecyl
butane sulfonate (surfactant) was found to be leaking. The leaked material was
immediately cleaned up by Virginia Tech personnel. This unit was in operation for six
years; however, the exact dates of operation are unknown.
During VADEQ compliance inspections conducted in 1991, 1992, 1993, and 1994, it was
discovered that several containers of hazardous waste in each of the areas identified above had
been stored on-site for greater than 90-days. As a result, the Facility was found to be in violation
of VHWMR and operating without a permit. Virginia Tech was issued an Enforcement Order by
VADEQ on March 8, 1995, which required the Facility to develop a Closure Plan for each of the
areas. The Closure Plan included sampling and analysis to determine whether contamination
existed at either of these units. In correspondence dated June 8,1999, VADEQ confirmed closure
of HWMUs 1-4 (SWMU 10) in accordance with the approved Closure Plan.
EPA has concluded that SWMU 10 does not pose an unacceptable risk to human health and/or the
environment. All potential hazards posed by this unit have been addressed by VADEQ.
Virginia Polytechnic Institute & State University
No Further Action Determination
April 2013
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9. SWMU 11 - Satellite Hazardous Waste Accumulation Areas
Virginia Tech operates over 1,000 research laboratories throughout its campus. Each laboratory
has the potential to generate hazardous waste, which would be initially accumulated in a satellite
accumulation area (SAA) within the laboratory. The following bullets provide examples of SAAs
that are included as part of SWMU 11:
• Former Davidson Hall Chemistry Laboratories, formerly referred to as HWMU 7;
• Derring Hall Chemistry and Biology Laboratories, formerly referred to as HWMU 8;
• Hahn Hall Chemistry Laboratories, formerly referred to as HWMU 9;
• Norris Hall Environmental Engineer Laboratory, formerly referred to as HWMU 10; and,
• Randolph Hall Chemical Engineering Laboratories, formerly referred to as HWMU 11.
EPA has concluded that the SAAs operated by Virginia Tech do not pose an unacceptable risk to
human health and/or the environment. All laboratories, or other areas that use chemicals, are
governed by the University's Chemical Safety Program which covers the proper management of
hazardous materials. The hazardous wastes are managed in containers within buildings. In the
event a spill or leak did occur at one of these areas, the hazardous wastes or hazardous constituents
would be contained within the generating laboratory. In addition, each laboratory is regularly
inspected by Virginia Tech's Environmental Health and Safety (EHS) personnel for safety and
compliance. There are no known or documented releases or environmental impacts associated
with these units.
10. SWMU 12 - Sterrett Facilities Complex Bay 3 Hazardous Waste Accumulation Area
SWMU 12 consists of a flammable storage cabinet that is used to accumulate hazardous paint and
solvent waste generated by the Sterrett Facilities Complex (referred to as Bay 3) paint shop. The
wastes are accumulated in containers and placed in the flammable storage cabinet that is situated
on asphalt. In the event of a spill, the asphalt would ensure containment of the spilled material
avoiding a release of hazardous waste or hazardous constituents to the environment SWMU 12 is
inspected weekly to ensure the proper management of hazardous waste.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 12.
11. SWMU 13 - Former Sterrett Facilities Complex Buildings and Grounds Former
Hazardous Waste Accumulation Area
This former SWMU was a less than 90-day hazardous waste accumulation area located in the
Sterrett Facilities Complex and was used to accumulate paint and paint thinner wastes. EPA has
Virginia Polytechnic Institute & State University
No Further Action Determination
April 2013
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concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 13. Wastes accumulated in this area were in containers on a concrete pad. In the
event of a spill, the concrete would ensure containment of the spilled material avoiding a release
of hazardous waste or hazardous constituents into the environment.
12. SWMU 14 - Power Plant
Virginia Tech operates a Title V permitted Power Plant that generates steam for heating the
majority of the buildings on campus. The Power Plant was constructed in the 1920s, and consists
of two coal fired boilers and three natural gas boilers, with fuel oil as a backup fuel source. Ash
from the Power Plant is sent to a local sanitary landfill for use as alternate daily cover.
The coal at the Power Plant is stored in a coal yard adjacent to the facility. Storm water run-off
from the coal pile is directed to a drop inlet which leads to a sedimentation tank (SWMU 15).
Virginia Tech monitors and addresses storm water discharge in accordance with the facility
Virginia Pollutant Discharge Elimination System (VPDES) storm water discharge permit and in
accordance with the Virginia State Water Control Law.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 14.
13. SWMU 15 - Sedimentation Tank at Coal Yard
Storm water runoff from the Power Plant (SWMU 14) coal yard is directed to a drop inlet which
leads to a sedimentation tank, SWMU 15. Coal fines settle out of the storm water into the
sedimentation tank and are periodically removed and transported off-site for disposal at a local
sanitary landfill. The water is discharged to the Blacksburg Virginia Polytechnic Institute (VPI)
Sanitary Authority's Wastewater Treatment Plant.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 15.
14. SWMU 16 - Maintenance Shop Parts Washers
The Facility operates 9 parts washers in various maintenance shops, including the Motor Pool
Building. EPA has concluded that SWMU 16 does not pose an unacceptable risk to human health
and/or the environment. There are no known or documented releases or environmental impacts
associated with the parts washers which are managed on a concrete pad. In the event of a spill,
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the concrete would ensure containment of the spilled material avoiding a release of hazardous
waste or hazardous constituents into the environment.
15. SWMU 17 - Former Universal Waste Accumulation Area
Virginia Tech collects universal waste, such as spent fluorescent bulbs and ballasts, generated
throughout the Facility. These wastes are managed in containers, typically cardboard boxes. Prior
to 2011, the Facility's universal wastes were stored in a box trailer located behind the closed
incinerator building (SWMU 3) for accumulation prior to off-site shipment. In early 2011, the
Facility ceased using SWMU 17 for the accumulation of universal wastes. These wastes are now
stored at the Facility's MMF prior to off-site shipment.
EPA has concluded that SWMU 17 does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 17.
16. SWMU 18 - Hydraulic Trash Compactors
The Facility utilizes six hydraulic trash compactors, including one at the West End Dining Hall as
observed during the November 2006 Site visit. These units are situated on top of impermeable
surfaces, such as concrete or asphalt. Two known small releases of hydraulic oil have occurred
from the hydraulic lines associated with the compactors being accidentally broken. Both releases
were immediately contained and cleaned up by the Facility. EPA has concluded that SWMU 18
does not pose an unacceptable risk to human health and/or the environment. There are no known
or documented environmental impacts associated with these units. The wastes handled by this unit
do not contain hazardous waste or hazardous constituents.
17. SWMU 19 - Former Animal Carcass Rendering Unit
Virginia Tech formerly operated an animal carcass rendering unit at the Veterinary Hospital that
was used to render animal carcasses from the hospital or other animal related areas on campus.
The liquids from the unit were discharged to the sanitary sewer and the rendered solid material
was transported off-site for disposal in a local sanitary landfill. The carcasses formerly processed
by this unit are now transported off-site for disposal in a local sanitary landfill.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented environmental impacts associated with this unit.
The unit is located inside a building constructed with a concrete floor ensuring any spills would
have been contained. The wastes handled by this unit did not contain hazardous waste or
hazardous constituents.
18. SWMU 20 - Medical Waste Storage Shed
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SWMU 20 is located behind the Veterinary Hospital and is used to accumulate animal and human
medical waste (blood, fluids, etc.), medical devices and sharps. These wastes are generated
primarily from the Veterinary Medicine Complex, in addition to various other locations throughout
the Facility. From SWMU 20, the medical waste is shipped off-site to a regulated medical waste
treatment and disposal facility. There are no known or documented environmental impacts
associated with these units.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented environmental impacts associated with these
units. The wastes handled by this unit do not contain hazardous waste or hazardous constituents.
19. SWMU 21 - Former Mass Burn Facility
Prior to operation of SWMU 2, the Facility's closed sanitary landfill (Permit No. 109), Virginia
Tech operated a mass burn incinerator (SWMU 21) which was located in the same building as the
former closed pathological incinerator (SWMU 3). Solid waste generated by the Facility was
transported to the unit to be incinerated. This unit was taken out-of-service and dismantled prior
to 1980 as a result of changes in air pollution regulations to cover these types of units. Therefore,
due to the time period of operation, no records of operation for the former Mass Burn Facility
exist. The location and operation of this unit is based on an examination of the remaining building
that housed the unit.
EPA has concluded that this unit does not pose an unacceptable risk to human health and/or the
environment. There are no known or documented releases or environmental impacts associated
with SWMU 3, as evidenced by active groundwater monitoring of SWMU 2 located hydraulically
downgradient. In addition, the incinerator was housed within a brick building constructed with a
concrete floor ensuring any spills would have been contained.
20. AOC 1 - Virginia Tech Airport Aviation Fuel Release
On May 3, 1994, a leak of aviation fuel was discovered coming from one of the manholes used to
enter the 12,000-gallon aboveground aviation fuel tank at the Virginia Tech Airport.
Approximately 2,400-gallons of aviation fuel was released due to an improperly installed gasket
on the manhole. VADEQ issued Pollution Complaint Number 1994-3737 in response to the
release. The release was remediated through free product recovery trenches, soil vapor extraction
and air sparging, excavation of contaminated soil, and groundwater monitoring.
The success of the remediation and potential impacts of the release were evaluated in an Initial
Abatement Measures and Site Characterization Report dated August 25, 1994. Characterization
of the site indicated successful remediation of the release and no significant risk to human health
of the environment was identified. Following VADEQs review of the information presented in
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the August 1994 report, VADEQ notified Virginia Tech on November 18, 1994 that no further
action was required for the release of aviation fuel.
EPA has concluded that AOC 1 does not pose an unacceptable risk to human health and/or the
environment. All potential hazards posed by AOC 1 have been addressed by VADEQ.
21. AOC 2 - Fuel Release from Power Plant
On June 18, 1995, a sheen was discovered on the Duck Pond (AOC 3), a man-made pond located
on the Virginia Tech campus fed by two major branches of Stroubles Creek. The source of the
sheen was determined to be a release of No. 6 Fuel Oil from a leaking supply line at the Power
Plant (SWMU 14) which was entering a storm water drain. An estimated 1,400-gallons of fuel oil
was spilled; however, the majority of the fuel was contained in a coal elevator pit at the Power
Plant. VADEQ was immediately notified and Pollution Complaint No. 95-0682 was issued. A
Pollution Complaint Initial Abatement Measures Report dated July 1995 detailing the action taken
to contain, abate, and clean up the release was provided to VADEQ on July 11, 1995.
Subsequently, VADEQ closed this Pollution Complaint with no further action required on July 14,
1995.
EPA has concluded that AOC 2 does not pose an unacceptable risk to human health and/or the
environment. All potential hazards posed by this unit have been addressed by VADEQ.
22. AOC 3 - Duck Pond/Stroubles Creek
The Duck Pond is located on the Virginia Tech campus and was created in the 1930s by erecting
a dam along Stroubles Creek and is fed by two major branches of Stroubles Creek, a tributary of
the New River which flows north into the Kanawha River. Due to the topography of the Town of
Blacksburg, the Duck Pond also receives storm water and runoff from streets and properties
throughout the town, in addition to the Virginia Tech campus.
EPA has concluded that AOC 3 does not pose an unacceptable risk to human health and/or the
environment. There is no known risk to human health or impacts to the environment associated
with past releases to the Duck Pond. To ensure the water quality of the Duck Pond and Stroubles
Creek, VADEQ monitors these surface water bodies under the Total Maximum Daily Load
(TMDL) Program. In addition, Virginia Tech installed a boom attachment system at the Duck
Pond so that booms can be deployed quickly to contain a release at the pond.
23. AOC 4 - Hydraulic Fluid Release from Wind Tunnel
In February 1994, approximately 600-gallons of hydraulic fluid was released from the Wind
Tunnel located on Barger Street due to a mechanical failure. The release occurred during a
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significant storm. Most of the hydraulic fluid was contained at the source; however, a small
amount was released into the storm sewer and eventually to the Duck Pond. VADEQ was
immediately notified and Pollution Control No. 1994-1796 was issued. A Pollution Complaint
Initial Abatement Measures Report dated February 1994 detailing the action taken to contain,
abate, and clean up the release was provided to VADEQ. Subsequently, VADEQ closed this
Pollution Complaint with no further action required on October 25, 1994.
EPA has concluded that AOC 4 does not pose an unacceptable risk to human health and/or the
environment. All potential hazards posed by this unit have been addressed by VADEQ.
24. AOC 6 - MW-6 - Up gradient Well at SWMU 1
AOC 6 is associated with SWMU 1 and is addressed under Section 3.1 .A of the Statement of Basis
to which this No Further Action determination is attached.
25. AOC 7 - Former Virginia Tech Airport
The former Virginia Tech Airport was formerly operated by Virginia Tech. The airport is now
known as the Virginia Tech Montgomery Executive Airport and is operated by an authority
comprised of Virginia Tech, the Town of Blacksburg, and Montgomery County. Virginia Tech
owns the airport property and assists with the management of wastes generated by airport
activities.
With the exception of the aviation fuel release in 1994 that was remediated under the direction of
VADEQ (AOC 1), there are no other known or documented releases for the airport. Therefore,
EPA has concluded that AOC 7 does not pose an unacceptable risk to human health and/or the
environment.
26. AOC 8 - Remote Detonation Site
In February 1987, an emergency permit was issued to Virginia Tech for the detonation of old
peroxides and ethers that were discovered in laboratories at the university. The materials were
deemed too dangerous to transport to a waste disposal facility. Instead the Virginia State Police
transported the waste to an off-site location and detonated the materials.
EPA has concluded that AOC 8 does not pose an unacceptable risk to human health and/or the
environment. There are no known or anticipated environmental impacts associated with the
management of these materials, which were ultimately removed from the Facility.
27. AOC 9 - Davidson Hall Soil Contamination
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Davidson Hall is a chemistry building located at Drill field Drive undergoing renovation and
reconstruction. Davidson Hall was first constructed in 1926 with additions in 1932 and 1937. Part
of the original 1926 structure is being renovated and the remaining building has been demolished.
In preparation for the demolition work, Professional Service Industries, Inc. (PSI) was contracted
in 2008 to complete a Hazardous Materials Survey (Survey) of the building. The September 2008
Survey included the collection and analysis of composite soil samples (CS-1 and CS-2) from the
east and west side of the building (outside of the building footprint).
EPA compared the sampling results to the EPA Region 3 Risk-Screening Levels (RSLs) for
residential soil and industrial soil use or the values derived from the EPA Soil Screening Level
(SSL) guidance for migration from soil to air or groundwater assuming residential use.
The Survey identified the presence of benzo(a)anthracene and benzo(b)fluoranthene above their
respective EPA Region 3 RSLs for residential soil. Arsenic, chromium, mercury, and
benzo(a)pyrene were detected at concentrations above their respective EPA Region 3 RSLs for
industrial soil in one or both samples. Please refer to the tables below for a summary of the COCs
detected in samples CS-1 and CS-2.
Sample CS-1
Constituent
Concentration
VRP Tier II SL
VRP Tier III SL
Arsenic*^
4.4 mg/kg
0.390 mg/kg
1.60 mg/kg
Chromium^
19 nig/kg
0.290 mg/kg
5.60 mg/kg
Mercury
5.2 mg/kg
1.000 mg/kg
4.30 mg/kg
Selenium
10 mg/kg
390 mg/kg
5,100 mg/kg
Sample CS-2
Constituent
Concentration
EPA Residential
Soil Screening
Level
EPA Industrial
Soil Screening
Level
Antimony
5.1 mg/kg
31 mg/kg
410 mg/kg
Arsenic(b)
3.6 mg/kg
0.390 mg/kg
1.60 mg/kg
Chromium(c)
19 mg/kg
0.290 mg/kg
5.60 mg/kg
Mercury
52 mg/kg
10 mg/kg
43 mg/kg
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Benzo(a)anthracene
1.6 mg/kg
0.150 mg/kg
2.10 mg/kg
Benzo(b)fluoranthene
1.7 mg/kg
0.150 mg/kg
2.10 mg/kg
Benzo(a)pyrene
1.3 mg/kg
0.015 mg/kg
0.21 mg/kg
(a) VRP Tier II SLs revised on 7/19/12.
(b) The risk-based SL for arsenic is usually below the naturally occurring background concentration. The levels of
arsenic detected are representative of background levels (6.68 to 10.3 mg/kg) based on a statistical comparison of
on-site arsenic levels to background levels.
(c) Results compared to Carcinogenic SL for Chromium (VI).
(d) VRP Tier III SLs revised on 6/26/12.
As part of the Davidson Hall construction project, soils were excavated from the Site. On May 9,
2012, on behalf of Virginia Tech, Draper Aden Associates (DAA) collected composite soil
samples from three stockpiles of soil (samples SP-1 through SP-3) excavated from within the
footprint of Davidson Hall, in addition to six grab soil samples (SMP-4 through SMP-9) from areas
where excavation was to occur. The soil sample locations, analytical results and a discussion on
sampling procedures and interpretation are documented in a May 16,2012 letter/report from DAA
to Virginia Tech.
The soil samples were analyzed for total mercury, TCLP (toxicity characteristic leaching
procedure) mercury and benzo(a)pyrene. The soil samples were analyzed for TCLP mercury to
determine if the soils would be characterized as a hazardous waste. Total mercury concentrations
from all samples were below the Region 3 RSLs for residential soil, and TCLP mercury results for
all samples were below the laboratory detection limit. Benzo(a)pyrene concentrations reported in
samples collected from the three soil stockpiles (SP-1 through SP-3), and the subgrade soil sample
SMP-8 exceeded the EPA Region 3 Industrial Soil Screening Level of 0.21 mg/kg, and soil sample
SMP-4 exceeded the EPA Region 3 Residential Soil Screening Level of 0.015 mg/kg for
benzo(a)pyrene.
With respect to the presence of benzo(a)pyrene in facility soils, this constituent is a poly-nuclear
aromatic hydrocarbon (PAH) that is ubiquitous in urban environments and is found in asphalt, coal
combustion products, automobile exhaust fumes (especially from diesel engines), and smoke from
the combustion of organic material (e.g., cigarette smoke). The benzo(a)pyrene detected in the
2008 and 2012 sample results is most likely influenced by normal activities in an urban, high traffic
area and do not indicate a specific point source derived impact nor a significant threat to human
health or the environment from exposure to these soils.
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Virginia Tech, under the direction of VADEQ, is managing the excavated soils (approx. 5,500
cubic yards) from within the footprint of the former building as solid waste. The excavated soils
are being sent to the New River Source Authority (municipal landfill) to be used as daily cover.
The results from the April 3, 2014 Soil Sampling Event at Davidson Hall show that mercury
concentrations in the soil, reported on an "as-received" basis, in the Davidson Hall area do not
exceed the RSLs for elemental mercury and the RSLs for mercuric salts in both residential or
industrial scenarios. The results show that the soil surrounding Davidson Hall does not pose
unacceptable risks to humans or the environment. No further action was recommended, in the
report.
EPA has concluded that AOC 9 does not pose an unacceptable risk to human health and/or the
environment.
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