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"~\ O^t&t^AL^ SDMS DocID 2122438 EXPLANATION OF SIGNBFICANT DIFFERENCES FOR ACID NEUTRIUZATION PIT SOILS (OPERABLE UNIT 5) DEFENSE GENERAL SUPPLY CENTER CHESTERFIELD COUNTY, VIRGINIA Prepared By U.S. Army Corps of Engineers ' Huntsville Division 4820 University Square HuntsvUle, AL 35816

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Page 1: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

"~\ O ^ t & t ^ A L ^

SDMS DocID 2122438

EXPLANATION OF SIGNBFICANT DIFFERENCES

FOR

ACID NEUTRIUZATION PIT SOILS

(OPERABLE UNIT 5)

DEFENSE GENERAL SUPPLY CENTER

CHESTERFIELD COUNTY, VIRGINIA

Prepared By

U.S. Army Corps of Engineers '

Huntsville Division

4820 University Square

HuntsvUle, AL 35816

Page 2: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

TABLE OF CONTENTS

Page

I. INTRODUCTION 1

n . SUMMARY OF SITE HISTORY, CONTAMINATION PROBLEMS AND SELECTED REMEDY 3

A. Site History • • • • 3

B. Contamination Problems 6

C. Selected Remedy 10

m . DESCRIPTION OF SIGNIFICANT DIFFERENCES AND THE BASIS FOR

THOSE DIFFERENCES 11

rv. SUPPORT AGENCY REVIEW 15

V, AFFIRMATION OF THE STATUTORY DETERMINATIONS 15

VI. PUBLIC PARTICIPATION ACTIVniES 16

Vn. ADMINISTRATIVE RECORD 16

1538-3104.04

Page 3: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

EXPLANATION OF SIGNIFICANT DIFFERENCES

OPERABLE UNIT FIVE

Defense General Supply Center Chesterfield County, Virginia

Septeinber 1995

I. E^TRODUCTION

This Explanation of Significant Differences (ESD) is issued in accordance with Section 117(c)

of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as

amended (CERCLA), 42 U.S.C. § 9617(c), and Section 300.435(c)(2) of the National OU and

Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R. § 300.435(c)(2), which

requires the Defense Logistics Agency (DLA) to publish an explanation of significant differences

where a remedial action is taken that will differ in any significant respect from the fmal remedial

action selected and described in the Record of Decision with respect to the scope, performance,

or cost.

The Defense General Supply Center (DGSC) is located in Chesterfield County, Virginia,

approximately 11 miles south of the city of Richmond and 16 miles north of the city of

Petersburg (Figure 1.1).

DLA has served as the Lead Agency for both the Remedial Investigation/Feasibility Study

(RI/FS) and the Remedial Design/Remedial Action (RD/RA). The United States Environmental

Protection Agency (EPA) Region HI and the Virginia Department of Environmental (Quality

(VDEQ) have been the support agencies. This ESD relates to remedial action specified in a

Record of Decision (ROD) between EPA and the DLA signed in March 1992 and concurred

with by the Commonwealth of Virginia. Remedial design for the remedy began in September

1992 and was completed in March 1993.

Page 4: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

FIGURE 1.1-DEFENSE GENERAL SUPPLY CENTER

AND SURROUNDING AREA RICHMOND, VIRGINIA

SCALE IN M i l ES

TftODUCED FflOM: LAW ENVJROMMEKTAL, WC, OCTOBER 1t91

Page 5: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

This ESD is issued as a result of information generated during pilot plant operations and pre-

design field explorations performed as part of the remedial design of 0U5. The results support

the recommendation to eliminate the installation of the full-scale vapor vacuum extraction

system. This document is issued by the DLA to disseminate information concerning superfund

remedial activities to the public. The public is encouraged to review all documents contained

in the DGSC Administrative Record to obtain a more comprehensive understanding of the DGSC

site and the ESD contained herein.

n . SUMMARY OF SITE HISTORY, CONTAMINATION PROBLEMS AND SELECTED REMEDY

A. Site History

The Bellwood Estate was purchased by the United States Department of the Army. DGSC was

constructed in 1941 and 1942, and has on-going construction to date. The installation formerly

consisted of two separate facilities: the Richmond General Depot and Richmond Holding and

Reconsignment Point. In 1962, the installation became known as the Defense General Supply

Center. At the time, the mission of DGSC was to organize, direct and accomplish the

management of supplies in assigned federal supply groups; to operate a Defense Supply Agency

storage facility; to account for and coordinate receipt to store and distribute designated civil

defense materials; to accomplish the management and supply support for overseas requirements

for decentralized and non catalogued items identifiable to material assignments of DGSC; to

provide supply support to civil agencies on a basis that would not adversely affect the

performance of the primaiy mission; and to direct and accomplish other supply and

miscellaneous missions as assigned.

Since that time the mission of DGSC has continued to expand, with its main assignment being

to manage and fiimish military general supplies to the Armed Forces and several federal civilian

agencies. Today DGSC manages more than 300,000 general supply items at a facility valued

at $100 million and encompassing 640 acres.

1538-3104.04 3

Page 6: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

Based on the Hazard Ranking System evaluation and in accordance with EPA policy, in October

1984, EPA proposed DGSC for inclusion on the National Priorities List (NPL). DGSC was

promulgated to the NPL in August 1987. In September 1990, DGSC entered into a Federal

Facilities Agreement (FFA) with the U.S. EPA and the Commonwealth of Virginia.

Subsequently, it was decided that in order to expedite the implementation of remedial action, the

DGSC was divided into nine operable units. This document pertains only to operable unit five

(0U5), the Acid Neutralization Pits (ANP) source area.

The ANP area is located in the northern section of DGSC at the end of warehouse 65 (Figure

1.2). This area is the site of two former concrete settling tanks which received wastewater from

metal cleaning operations conducted at warehouse 65. The two tanks were located in a fenced

area approximately 25 feet northwest of the warehouse. The primary pit had a capacity of

14,600 gallons; the secondary pit had a capacity of 3,000 gallons. The primary and secondary

pits were each approximately 6.5 feet in depth.

The metal cleaning operations in Warehouse 65 included cleaning (paint and rust removal) and

repainting steel combat helmets and compressed gas cylinders. These activities were in

operation from 1958 to the early 1980's. The metal cleaning system consisted of first immersing

the items in a boiling caustic bath of sodium hydroxide (NaOH) to remove paint followed by a

hot-water rinse dip to remove residual caustic solution and paint residues. The items were then

immersed in a 20 percent hydrochloric acid (HCL) solution to remove rust and treated with a

neutralization solution consisting of sodium hydroxide, surfactant and sodium bicarbonate.

During the 1960's and until the mid-1970's, these dip tanks were also used to remove paint and

rust from various other metal items such as 55-gallon drums and 5-gallon metal cans.

Spent cleaning solutions were discharged to the settling tanks every 1-2 months. The intervals

varied depending on frequency and duration of use. In the settling tanks, the solids separated

and collected in the bottom of the tanks as sludge. The pH of the wastewater was adjusted by

manually adding lime prior to discharge. From 1958 to the late 1970's, wastewater was

1538-3104.04 4

Page 7: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

FIGURE 1.2 ACID NEUTRALIZATION PITS AREA

DGSC. RICHMOND. VIRGINIA

M r i n

U \

I ^ \

V

WARCMMAC M

ACIO NCWTMAUIAIIOM

Pits

"¥•

I 1 • M l •oou

J L

0

r\

««acNO«nc • )

riKXHiCCO raoMi u « I I M » O N W C H I « L INC. O C I O M I I « « I r i } noo«

ENCINEERINC-^riENCE

Page 8: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

discharged from the primary pit to the storm sewer. With the addition of the secondary pit in

the late 1970's, wastewater discharge was connected to the sanitary sewer.

While the pits were in operation, sludges were jjeriodically removed and disposed at the

Chesterfield County Landfill. The U.S. Army Environmental Hygiene Agency analyzed leachate

from the sludge in 1979 using the Extraction Procedure Toxicity (EP Tox) method. Based on

the analysis of the EP Tox results, the sludges were not characterized as hazardous waste. The

pits were closed in 1985. The remaining sludges were removed for off-site disposal, the bottoms

of the pits were washed clean of residual sludges, and the pits were filled with clean soil.

During closure activities, the concrete sides and bottoms of the pits were observed to be broken

and cracked. These cracks and holes may have served as migration routes for contaminants in

the pits to the surrounding soils.

B. Contamlliatinn Prnhlemy

Previous remedial investigations performed in November 1988 consisting of borings, monitoring

wells, and piezometers (Figure 1.3) revealed volatile organic contamination in the soil and

ground water surrounding the pits. The soils were the apparent source of VOCs in the ground

water at the ANP area. Low levels of VOCs, including tetrachloroethylene (PCE) and

trichloroethylene (TCE), were detected in the soil boring from the secondary settling tank at

the site. Although VOCs were not known to have been used in the metal cleaning operations

in warehouse 65, the ANPs were not covered during the time they were in operation and

therefore could have been used for undocumented disposal of chemicals and solvents used in a

variety of industrial operations at DGSC.

A baseline risk assessment was conducted for the ANP area as documented in the RI Report.

The purpose of the assessment was to evaluate the potential human health and environmental

risks posed by soil and ground-water contamination detected at the ANP area. The results of

the baseline risk assessment as they pertain to the ANP Source Area (i.e., contaminated soils)

are briefly summarized below.

1538-3104.04 6

Page 9: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

FIGURE 1.3 SOIL BORING/WELL LOCATIONS ACID NEUTRALIZATION PIT AREA

DGSC RICHMOND. VA

WAREHOUSE 65

SANO BLAST I ROOM

t

OMW-30A

LAW ENVIRONMENTAL, INC. GOVERNMENT SERVICES DIVISION

OMS-ao a ^ 0 M W - 2 } a

1 \ri OMSSI I

0MW-24a

l>> AGIO

> NEUTRALIZATION PITS

O WAREHOUSE 64

0MS-7S

LEGEND

# BORINQ

© MONITORINO WELL

A PIEZOMETER

M 100

SCALE INf tET

TH

Page 10: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

The potential exposure pathways which were considered in the baseline risk assessment included

the following:

Ingestion and dermal contact with ground water.

Ingestion and dermal contact with contaminated soils.

Inhalation of vapors and dusts.

Ingestion and dermal contact with surface water.

Ingestion of fish and game.

Ingestion of crops and other plants.

Each of these pathways were evaluated for both on-site and off-site receptors, under both current

and future conditions. A complete exposure pathway includes a source, release mechanism,

environmental transport route, recqptor, and exposure route. Of the 44 exposure pathways

considered in the baseline risk assessment, only nine were considered to be complete. There

were no current exposure pathways considered to be complete at this site. The potential future

exposure pathways which were considered to be complete are summarized below:

• Future inhalation of dust and dermal contact with soils during excavation activities by on-site workers.

• Future ingestion and dermal contact with ground water by off-site residents.

• Future inhalation of dust, ingestion of soil and dermal contact with soUs from excavation activities by off-site residents.

• Future ingestion and dermal contact with surface water recharged by contaminated ground water by off-site residents.

The potential carcinogenic risks from all future on-site exposures to soils were estimated to be

2 X 10"*. This is approximately equivalent to the standard point of departure for evaluating

1538-3104.04 8

Page 11: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

carcinogenic risks which is 1 x 10̂ or one excess cancer in a million people exposed to the site

contaminants.

The potential noncarcinogenic hazard index from all future on-site exposures to soils was

estimated to be 6 x 10'\ This value is far below the threshold value of 1.0 which represents

a potentially unacceptable risk to human health from systemic toxicants

Risk-based soil action levels for protection of ground water were calculated in the Focused

Feasibility Report for 0U5 - Acid Neutralization Pits Source Area, November 1991. The action

levels are shown in Table 1. As may be seen, only tetrachloroethylene exceeded its risk-based

soil action level. This occurred in only one isolated sample at one location.

TABLE 1

Soil Action Levels for the Protection of Ground Water Acid Neutralization Pit Source Area

Operable Unit 5

- -

Chemical

Tetrachloroethylene

Trichloroethylene

1,2-Dichloroethane

1,2-Dichloroethylene

Maximum Concentration (mg/kg)

November 1988 March 1993

1.5

0.036

0.015

NA

0.18

0.11

••.

Ground-Water MCLs (mg/L)

0.005

0.005

0.005

0.07

Calculated Soil Action Level

(mg/kg)

0.58

0.20

0.022

1/3

1538-3104.04

Page 12: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

C. Selected Remedy

At issue herein is OUS and the 0U5 ROD issued by DLA in March 1992. The remedial

objectives as identified in the Focused Feasibility Study for 0U5 are:

• Prevent ingestion/direct contact with soil having constiments in excess of risk-based Soil Action Levels.

• Prevent inhalation of dusts having constituents posing excess cancer risk levels of lE-06.

Prevent inhalation of dusts having constituents at levels resulting in intakes greater than Reference Doses.

Prevent migration of constituents that would result in ground-water contamination in excess of MCLs.

The major components of the selected remedy specified in the ROD include:

• Installation of a vapor extraction system, including extraction and vent wells, a manifold system, a utility building, and vapor phase emission control;

• Construction of covers over the pits to prevent their further use and the infiltration of rainwater;

Continued operation and maintenance of the vapor extraction system for approximately four (4) years until tests indicate the contaminants are no

longer present at levels that threaten ground water; and

Analytical sampling of the affected media (soil) at the end of the clean-up period to evaluate the effectiveness of contaminant removal.

1538-3104.04 10

Page 13: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

m. DESCRIPTION OF SIGNDICANT DIFFERENCES AND THE BASIS FOR THOSE DIFFERENCES

A remedial design was initiated in September 1992 for the selected remedy of the ROD. In

order to develop an effective remedial design, a pilot test was necessary to obtain additional

design parameters. The vapor extraction pilot study consisted of two separate tests: a hydraulic

influence test and a hydrocartwn removal test. The hydraulic influence test was run over a 24-

hour period followed by the 10-day hydrocarbon removal test. During the 10-day test, the gas

stream from the well contained no BTEX constituents, with the exception of toluene

concentrations which appeared during the furst day's samples at relatively high levels. ES and

Tracer Research personnel determined that the source of the toluene was a sealant used to make

the connections with the wellhead airtight. Subsequently, all components of the flow system

having contact with the sealant were replaced, and flexible rubber couplings were used to

provide an air-tight seal. As a result, toluene concentrations dropped immediately and were

below detection limits by the fourth day of sampling, where they remained for the duration of

the test. This is indicated by the Total Volatile Hydrocarbon Concentrations (TVHC) m Table

2. Detectable levels of PCE, TCE, and TVHC were present throughout the test. Concentrations

of these constituents detected during the test are presented in Table 2. The maximum removal

rate calculated was 2.1 x 10^ Ib/hr.-

Based on the very low hydrocarbon removal rates and to substantiate pilot test results, 19

additional soil samples were collected and analyzed from beneath the pits. The samples from

beneath the pits were obtained from locations. Pit 1 to 6 (Figure 1.4). The samples from the

three borings in the smaller pits (Pit 1, Pit 2, Pit 3) had results below method detection limits.

The highest contaminant concentrations of 0.11 mg/kg for TCE and 0.18 mg/kg for PCE were

found in the deepest samples from location. Pit 6. Those concentrations are below the "soil

action levels" for TCE and PCE presented in Table 1 and excerpted from the ROD for 0U5.

Based upon the vapor extraction pilot study and the subsequent additional soil sampling results,

1538-3104.04 11

Page 14: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

TABLE 2 AIR SAMPLE R£SULTS FROM T H E HYDROCARBON REMOVAL TES ••'

WELLHEAD SAMPUNO-fORT

I DATE

pi-Doc-^2

p2-D€e-92

p3-D«:-92

W-Doc-92

1

p5-D«e-92

p6-D«:-92

TIME

02:52 PM

02:5« PM 03:03 PM

03:35 PM

04:07 PM

.05.02 PM

-05:20 PM

'05:56 PM

09:56 AM

02:00 PM

02:43 PM

04:09 PM

05 01 PM

. 05:49 PM

01:4SPM

02:16 PM

04:54 PM

12:58 PM

01:51 PM

02:42 PM

03:51 PM

04:53 PM

05:45 PM

0S:42 AM

09:38 AM

10:25 A M

11:15 AM

12:13 PM

0 l :0«PM

02:29 PM

03:55 PM

109:01 AM

09:59 A M

12:21 PM

01:59 PM

02:33 PM

03>*8 PM

05:19 PM

(36:53 PM

SAMPLE

NAME

I - l - l

1-2-1

l ->- l I-4-I

1-5-1

»-«-l I-7-I

I-8-1

2-1-1

2-2-1

2-3-1 2-4-1

2-5- !

2-6-1

3-1-1

3-2-1

3-3-1

4-1-1

4-2-1

i - 3 - l 4-4- !

4-5-1

4-6-1

5-1-1

5-2-1

, 5-3-1 1 5-4-1

5-5-1

5-6-1

J-7-1

S-l-1

^ l - I

fr-2-J

6-3-1 6-4-1

6-5-1

6-6-1

6-7-1

6-8-1

VACUUM

•H20

70

70

70

&S 44

35

3S

.35

35

70

M 50

50

50

90

90

70

90

90

90

90

90

90

88

88

1 " ' 8»

88

88

90

90

90

90

90

90

90

90

90

90

TEMP

F

50

50

50

- ^ 50

50

50

50

52

55

61

53

50

50

46

49

47

56

61

61

56

52

50

43

43

43

49

SI

45 48

37

'27

29

40

43 4«

40

40

40

TVHC

PP»»

322670.9

46934.0

52800.7

63590.1 43570.4

20195.0

31886.8

23915.1

5602.1

2073.5 1164.1

557.0

830.7

553.8

2165.9

622.5

262.5

63.1

31.9

31.9

31.6

31.3

31.2

< 61.1

< 61.1

< 61.1

< 61.9

< 62.1 < 61.4

< ' 62.1

< 60.8

89.3

89.7

< 91.7

92.3

92.8

91.7

91.7

91.7

TCA

PP*>

NA

NA

NA '

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

1.4

0.7

0.9

0.7

0.9

0.7

0.4

0.4

0.4

0.4

0.4

0.4

0.4

0.4

0.1

0.2

O.i

0.1

0.0

0.0

0.1

0.1

TCE

Pf*

< t . l

< O.I

< O.I

< O.I

< O.I

< 0.1

< O.I

< 0.1

< O.I

• 0.4

0.4

0.6

0 6

0 6

0.2

0.1

0.2

4.6

2.3

2.3

4 6

• 4.6

4 5

4.4

4.4

6.7

< 4.5

6.8

, *-5 6.8

6.6

< lO.S

10.9

15.6

15.7

13.5

15.6

15.6

20.0

PCE

pr*>

1.2

15.2 1.7

3.3

< 3.1

4.6

4.6

4.6

7.7

10.2 S 4

11.2

U.2

11.2

5.4

3.6

5.0

54.6

36.7

36.7

54.6

54.1

36.0

70,5

70.5

70.5

71.3

71.6

1 ' ° ' 89.5

70.1

120.2

120.7

176.3

177.3

124.9

158.6

158.6

176.3

NOTE: High eoneeaiiatjoai of TVHC during (b« fifJi three dayi w« likely due to (be «cal«nt which mu uaed.

12

Page 15: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

TABLE 2 (CONT) AIR SAMPLE RESULTS FROM THE HYDROCARBON REMOVAL TEST

WELLHEAD SAMPLING PORT

DATE

07-D«c-92

08-D«c-92

D9-D<»:-92

IO-Dce-92

II-D«e-92

TIME

10:55 AM

12:00 PM

01:01 PM

02:09 PM

02.46 PM

04:05 PM

04:55 PM

(}5:55 PM

08:32 AM

09:36 AM

11:44 AM

12:31 PM

01:15 PM

02:19 PM

03:15 PM

04:13 PM

08:28 AM

10:00 AM

11:01 A M

12:35 PM

01:39 PM

02:39 PM

03:29 PM

04:14 PM

08:03 AM

09:03 AM

10:31 A M

11:34 A M

12:25 PM

01:47 PM

02:47 PM

03:33 PM

08:37 A M

10:44 A M

11:31 A M

12:15 PM

01:08 PM

02:04 PM

02:57 PM

04:02 PM

SAMPLE

NAME

7-1-1

7-2-1

7-3-1 7-4-1

7-5-1

7 - * - !

7-7-1

7-8-1

8-1-1

8-2-1

8-3-1 8-4-1

8-5-1

8-6-1

8-7-1

8-8-1

9-1-1

9-2-1

9-3-1 9-4-1

9-5-1

9-6-1 9-7-1

9-8-1

l O - M

10-2-1

I0-3- I

10-»-l

I0-5- I

10-6-1 I0-7- I

I0-8- I

1 1 - M

11-2-1

11-3-1

11-4-1

n-5-i 11-6-1

n-7-i 11-8-1

VACUUM

•H20

88

88

88

88

88

88

88

88

90

90

88

90

90

90

90

90

90

90

90

90

90

90

90

90

71

85

90

90

90

90

90

90

90

90

90

90

90

90

90

TEMP

F

53

52

53 54

53

50

43 41

37

37

42

43

41

41

40

38

29

32 47

45

45

48

44

43

38

37

39

46

50

52 54

•53

42 44

44

a a 45

41

40

TVHC

P I *

623.4

1556

623.4

156.2

155.9

154.9

152.8

152.2

243.1

152.0

152.5

2IS.3 214.4

153.2

152.9

152.3

299.0

300.8

310.0

308.8

308.8

310.6

308.2

307.6

288.1

299.2

152.6

< 92.8

< 93.6

< 93.9

< 94.3 < 94.1

, 276.3 277.4

216.6

155.3

155.3 154.4

153.2

152.9

TCA

PJ*

0.9

0.7

0.7

0.7

0.9

1.6

0.9

0.9

0.7

1.3

1.3

0.9

1.5

1.3

0.9

0.7

1.7

I.I

l . I

1.6

1.1

I.i

2.2

1.8

I.O

0.9 0.4

0.2 0.4

0.7

0.5

0.5

0.7

0.9

0.7

1.3

0.9

< 0.2

0.4

0.9

TCE

P I *

45.4

22.6 22.7

22.7

45.4

45.1

22.2

22.2

22.1

44.2 44.4

22.4

44.6

44.6

< 445

44.3

65.3

43.8

90.2 67.4

44.9

45.2

44.9

895

41.9

43.5 44.4

15.8

6.8

2.3

2.1

1.8

22.3 22.4

22J

45.2

45.2

13.5

22.3

44.5

PCE

P I *

3594

3587

3594

180.1

3594

357.3

176.2

175.5

175.2 350.4

351.7

IT7.3

3532

3532

352.5

351.1

517.2

346.9

536.2 534.1

356.0

358.2

355.3

3546

332.2

3*5.0

175.9

53J

360

18.0

18.1

18.1

177.0

IT7.7

178.4

358.2

358.2

89.0

176.6

352.5

13

Page 16: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

TlGURE 1.4

WELL & BORING LOCATIONS DGSC VACUUM EXTRACTION SYSTEM

AGIO NEUTRAUZATION PITS

© NORTH 4TH STREET

I. i : II

I I !

S 5 - ;

s

PIT (

11

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A S P H A L "

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3

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VICUUU EXTSACTIOH WEU.

S SOIL BORINC

I <0S VAPOR PROBC I

14

Page 17: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

it appears that the contaminant levels in the soil have decreased, probably due to the effects of

natural attenuation and the vapor extraction pilot smdy-r-^Fhusrthe"soils^f'OU5'cio not pose a >\

:Tiskr:to:zhuman—health~or'~the~environmeht,_are„lioIIlg^ —v

^contain in^on-above-MGI^levels--and-do-nQt-need-to-be—remediated~base^ —^

ipresejited-in-the^ROiljniis-document-proposes-the-elimination-of-the-vapGr-vaGuum-extraetion

-syjtem detailed'̂ in thejOD. The permanent cohcrete_pit covers have been installed in

<-accordance-with'the-requirements of the ROD. " ^

IV. SUPPORT AGENCY REVIEW

In accordance with NCP § 300.435 (c) (2), the U.S. EPA and the Commonwealth of Virginia

have been consulted regarding the above described change in the scope of the remedy selected

for 0U5. The Commonwealth of Virginia will indicate its concurrence or nonconcurrence

following the public conunent period for this ESD. The U.S. EPA Remedial Project Manager

assigned to DGSC witnessed the confirmatory sampling that was performed on 15 and 16 March

1993. In addition, U.S. EPA's oversight contractor was also present and collected split samples

that were analyzed and found to confirm the conclusions reached by DGSCs sampling program.

V. AFFIRMATION OF THE STATUTORY DETERMINATIONS

DLA believes that the remedy selected for 0U5, including the changes documented in this ESD,

remains protective of human health and the environment, complies with federal and state

requirements that are applicable or relevant and appropriate to this remedial action, and is cost-

effective. In addition, the remedy utilizes permanent solutions to the maximum extent

practicable for this site. As originally stated in the ROD, because the selected remedy including

these changes will not result in hazardous substances remaining on site above health-based

levels, the five-year review will not apply.

1538-3104.04 15

Page 18: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

VI. PUBLIC PARTICIPATION ACTIVITIES

The Proposed ESD was released for public comment as part of the Administrative Record File

on July 24, 1995. The Proposed ESD and other related documents were made available to the

public in the Administrative Record file located at the Chesterfield Public Library in

Chesterfield , Virginia. The notice of availability of these documents was published in the

Richmond Times-Dispatch on July 24, 1995. The public was allowed forty-five days from the

notice date to submit comments to DGSC. No public comments were received.

v n . 7.0 ADMINISTRATTVE RECORD

A copy of this ESD, together with documentation supporting the changes described herein, has

been included in the Administrative Record file for DGSC. The Administrative Record file for

DGSC is available at the following location:

Chesterfield Public Library

County Courthouse

9501 Lori Road

Chesterfield, Virginia 23832

Hours: 10:00 a.m. - 5:30 p.m. (Wednesday, Friday and Saturday)

10:00 a.m. - 8:00 p.m (Monday, Tuesday and Thursday)

Closed Sunday

Phone: (804)748-1602

1538-3104.04 16

Page 19: EXPLANATION OF SIGNIFICANT DIFFERENCES (ESD) - ACID

JANE\^TMAN

Staff Director, Environmental and Safety Office

Defense Logistics Agency

Date DEC 1 0 :^:h

THOMAS C. VOLTAG'

Date j/f/f^

Director, Hazardous Waste Management Division

United States Environmental Protection Agency Region HI

1538-3104.04 17