UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

SUBJECT: Request for Approval to Conduct an DATE: OCT 6 1995Engineering Evaluation/Cost Analysisfor Removal Action at the Potomac YardSite in the City of Alexandria, andArlington County, Virginia

moval Enforcemen

TO: w Thomas C. Voltaggio, DirectorHazardous Waste Management Division (3HWOO)

THRU:

I. PURPOSE

The purpose of this memorandum is to request approval toconduct an Engineering Evaluation/Cost Analysis for a removalaction at the Potomac Yard Site, located in the City ofAlexandria and Arlington County, Virginia.

An Extent of Contamination Study (ECS) and Baseline HumanHealth and On-Site Ecological Risk Assessment (BHERA) haverecently been completed pursuant to EPA's Administrative Order byConsent ("Order") [Docket No. III-92-61-DC] by RespondentRichmond, Fredericksburg & Potomac Railroad Company (RF&P).Based upon the results of the BHERA, elevated levels of risk tothe environment may be posed by the Site, primarily to thePotomac River, Four Mile Run and Potomac Greens areas of theSite. Specifically, the BHERA stated that "pesticides in surfacewaters and sediments in the Potomac Greens area of the site maycause a localized reduction in the abundance and diversity ofaquatic insects.91 In addition, the BHERA stated that "PotomacYards is a source of low concentrations of PAHs, metals andpesticides to Four Mile Run and the Potomac River. Measuredconcentrations at the property boundary exceed toxicity criteriafor sensitive species of aquatic life, possibly resulting inlocalized decreases in benthic species abundance and diversity."

Pursuant to Paragraph 8.3.c.iv of the Order, and inaccordance with 40 C.F.R. S 300.415(b)(4), EPA has determined,based upon the site evaluation conducted by RF&P as reported inthe ECS and BHERA, that further removal actions are appropriateat the Site and that the Respondent shall conduct an engineeringevaluation/cost analysis ("EE/CA") pursuant to 40 C.F.R.300.415(b)

II. SITE CONDITIONS AND BACKGROUND

A. Site Description

The Site is located in the northeastern portion of the Cityof Alexandria and the southeastern portion of Arlington County,Virginia. The Site is approximately 342 acres in size and isgenerally bordered by 27th Street to the north, Braddock Road tothe south, by U.S. Route 1 (Jefferson Davis Parkway) to the vestand the George Washington Memorial Parkway to the east. The Siteis approximately 2.7 miles in length and approximately 2,000 feetwide near the center of the Site. Crystal City, VA, an urbanarea of high-rise office and hotel buildings is located to thenorth of the Site, and Washington National Airport is located tothe northeast. Residential and light commercial developments,including the Arlington County Water Pollution Control Plantborder the Site to the west, south, and southeast. DaingerfieldIsland, a mixed-use recreational facility, and the Potomac Riverlie to the east of the Site. Four Mile Run, a perennial streamwhich flows east to the Potomac River, divides the northernportion of the Site.

The majority of the Site (approximately 300 acres) issimilar in nature and historical use and is characterized asgenerally flat in topography, and covered with a layer of largestone ballast material, which was used as a base for railroadtracks which once traversed the Site. Approximately 40 acres ofthe Site, referred to as Fotomac Greens, lies to the east of theformer active portion of the Site and is generally characterizedas being covered with vegetation and was the location of threeoil/water separator ponds which collected run-off from the Siteand is also the location of fly-ash and dredge spoils disposalareas. Wetland areas also currently exist in the Potomac Greensarea of the Site. No railroad activities actually took place onthe Potomac Greens area of the Site. Surf ace water drainage atthe Site, is generally controlled by topographic relief andurbanization. There are seven storm water sewer discharges fromthe Site into Four Mile Run from both the northern and southernportions of the Site. Other surface water drainage featuresinclude a large drainage ditch which traverses the length of thenorthern portion of the Site and which originates off-site in theCounty of Arlington, VA and discharges to Four Mile Run, severalother drainage ditches located on the southern portion of theSite which direct surface water towards Four Mile Run and PotomacGreens, and three drainage ditches located in the Potomac Greensportion of the Site which were part of the former oil/waterseparators. The oil/water separators were removed in 1993,however two of the drainage ditches located in the Potomac Greensportion of the Site continue to receive storm water runoff fromthe City of Alexandria via stormwater sewers which traverse theSite as well as stormwater drainage from the Potomac Greensportion of the Site. These two drainage ditches ultimatelydischarge to the Potomac River to the east of the Site.

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B. Site HistoryThe Potomac Yard Sita served as a major railroad switching

and maintenance yard for over 100 years* Railroad operationsbegan in the mid-13003 with development of the Site into a majorrail yard in the early 1900s. By 1937, the rail yard hadexpanded to approximately its maximum extent. Potomac Yardserviced several different railroad lines, and locomotiveclassification, switching, maintenance, servicing, and refueling(diesel-electric locomotives only) were carried out at the Site.Coal-fired, steam powered locomotives were serviced from 1906 tothe mid-1950s; electric locomotives were serviced from 1936 until1980; and diesel-electric locomotives were serviced from the mid-1950s until 1990 at the Site. Maintenance and servicingoperations also were carried out for other types of rail cars atthe Site. In 1939, a decommissioning process of the rail yardoperations began at the Site and continued through 1993. Duringthis period, all but two building structures, eight tracks, andthree stormwater retention ponds were removed. Currently,railroad activities at the Site are limited to two mainline(through) tracks on the western portion of the Site and sixtracks on the eastern portion of the Site which are used for thetemporary storage of trains.

9 • ''

The Site is proposed for future development on an interimand long-term, basis. Interim development of the Site began inJuly 1995 with the construction of the first phase of a warehousecomplex and may also include "big-box" retail stores, parking wlots, recreation or construction staging areas. Interimdevelopment of the yard is envisioned for a period of 15-20years* Long term development plans, which will ultimately resultin phasing out of the interim use developments, include a varietyof urban-density land uses, including a regional transportationhub, office, hotel, retail, and residential, as well as openspace uses.

C. Incident/Response History

In April 1983, a Preliminary Assessment (PA) of the Site wasperformed by the Virginia Department of Waste Management (VDWM)for EPA. Tha PA recommended that a Site Investigation: (SI) beperformed. The PA cited concerns regarding potential surfacewater contamination migrating from the Site and the possibilityof adverse effects in the food chain from consumption by waterlife of soluble fuel-oil/greasevconstituents in discharge waterfrom the Site.i - • • , „ ' ' " . . "

A SI was performed by VDWM in February 1989, which ;identified several metals present in soils at the Site above 1background soil concentrations. Specifically, arsenic, chromium,lead, barium and zinc with maximum concentrations of 123 mg/kg,30 mg/kg, 411 mg/kg, 463 mg/kg and 769 mg/kg respectively wereidentified as a result of the SI. Also found in the soil at the OSite were total xylanes, toluene and athylbenzene at

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concentrations of 87, 130 and 17 parts per billion (ppb)respectively. Polychlorinated biphenyls (fCBs) were found in twosamples at concentrations of 1.3 and 8.7 ppb,respectively.

r&. 'Jf~ ''i\f •*

In February 1990, RFfiP Corporation performed anenvironmental assessment (EA) of the northern portion of the Siteprior to considering future development of this portion of theSite. The EA evaluated approximately 50 of the northernmostacres of the site to determine if soil, sediments, surface waterand ground water contamination exists in this portion of the sitedue to past operations conducted there. Approximately 144surface water, subsurface soil, sediment samples and groundwatersamples from eight (8) monitoring wells were collected. The EAdocumented maximum metals concentrations in on-site soils forarsenic at 1,940 parts per million (ppm), chromium at 139 ppm,lead at 1,000 ppm, manganese at 3,460 ppm and zinc at 857 ppm.PCB contamination of 22.6 ppm was detected in one soil samplefound during on site screening, however, upon subsequentlaboratory verification, no concentrations of PCBs wereidentified. Analysis for total petroleum hydrocarbons ("TPH")revealed one soil sample containing 29,000 ppm for TPH* The EAalso reported TPH concentrations of up to 990,000 ppm in a sampleobtained from a Site monitoring well.

During: an .environmental assessment performed by RF&P in July1991, approximately 7 feet of fuel was observed in ground watermonitoring wells installed in the Central Operations area of theSite. The release was assumed to have occurred over many yearsdue to over-filling of locomotives and leaks in the fuel storageand distribution system* A recovery well was installed, howeverinitial recovery rates indicated that an extended period of timewould be needed to remove the product. Additional wells wereinstalled and weekly hand bailing of the product was conducted.In August 1993, an additional series of wells were installedin collection trenches located in and around the area of freeproduct for use as product recovery wells. Two product skimmer .pumps were installed in the trench wells in Hay 1994 for thepurpose of continued collection of product* The removal of theproduct from this area of the Site is currently still beingconducted by RF&F under the oversight and monitoring of theVirginia Department of Environmental Quality* As of August 1995,a total of approximately 2,374 gallons of free product have beenrecovered. . '

In Spring of 1992, development of the central portion of theSite, particularly as the location of a new football stadium forthe Washington Redskins was contemplated. In July 1992, RF&P, inanticipation of having to complete an environmental siteevaluation before development of the central portion of the sitecould begin, collected approximately 305 soil, 41 ground water,26 sediment and 26 surface water samples in the A-l area of theSite. The A-l area of the Site encompasses the area of the Sitebetween South Glebe Road to the north and the Monroe StreetBridge to the south.

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In September 1992, EPA and RF&P signed a Consent Order whichrequired RF&P to investigate the nature and extent ofcontamination which may be present at the Site. The Orderspecified the investigation in three phases which includeseparate extent of contamination studies (ECS) for the A-l areaand all other areas of the Site outside Area A-l and the conductof an EE/CA, if EPA determined further removal actions areappropriate. The Order acknowledged that RF&P has alreadyperformed an extensive sampling effort of the A-l area, andrequired a detailed work plan describing the sample collectioneffort to date, and the identification of further sampling, ifwarranted.

In April 1993f EPA approved RF&P's revised work plan for thecollection of samples in the A-l area of the Site with certainmodifications including collection of additional background soilsamples and installation of two additional groundwater monitoringwells, based in large part on comments received fromparticipating agencies.

In June 1993, EPA and RF&P collected background soil samplesnear the Site for use in the extent of contamination and riskassessment studies.

In January 1994, the Consent Order was modified such thatthe ECS was consolidated into two phases instead of three.Instead of developing 2 separate ECS reports for tha A-l area andall other areas of tha Site outside the A-l area, only one ECSreport and risk assessment was performed. RF&P was responsiblefor preparing the ECS report and baseline risk assessment.

In March 1994, RF&P collected approximately 108 soil, 36groundwater, 13 sediment and 23 surface water samples in theNorth Tail, South Tail, Potomac Greens and A-l areas of the Site.

in October 1994, EPA modified certain portions of the workplan addendum and granted conditional approval of the work planaddendum, after receiving comments from the participatingagencies; RF&P was required to collect additional samples at theSite and submit additional information with respect to the riskassessment.

In November 1994, RF&P collected additional samples at theSite and submitted additional information according toconditional approval of the work plan addendum.

" , ' ' " " " " " • " • • ' . . ! - • * ' . t ' •

The ECS Report was submitted by RF&P in February 1993,: ... *subsequently revised and resubmitted in May 1995 based upon EPA'sand participating agencies' comments and conditionally approvedby EPA in June 1995. The ECS report includes a description ofthe Site .history, summary of previous investigations and clean upactions, a Site description, all chemical concentration datacollected during the ECS and a summary of potentially exposedpopulations to assist in preparation of a baseline risk

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assessment*; Pertinent observations made irutfhe ECS reporti include the following: "*v":v'''^ • . -•••- , : •- , , ' , ':.. ' • " • . ' " •

• Some migration of metals is occurring through movementof sediments and, to a lesser degree, movement of dissolved-phase metals in storm runoff. The site wide meanconcentration in sediments for arsenic is 38 mg/kg. 'Themean concentration in sediments for lead and,copper are 96mg/kg and 65 mg/kg, respectively. The site wide meanconcentration in surface water for arsenic, lead, and copperare 62.2 ug/L(dissolved)/112 ug/L(total); 2 ug/L(dissolved)/6 ug/L(total); and 6 ug/L(dissolved)/8 ug/L (total),respectively.

• Polycyclic aromatic hydrocarbons (PAHs) have been foundin cinder ballast in the rail yard and in fly ash and dredgespoils on Potomac Greens. PAHs are found in coal and coal-combustion by-products, as well as petroleum hydrocarbons,such as diesel fuel. The PAH with the highest meanConcentration in rail yard cinder ballast is pyrene at 1,675ug/kg. The mean concentration of pyrene in rail yard soilsis 363 ug/kg. To the extent PAHs are found in nativesoil/fill, they are in areas where ballast has been mixedinto the soils or where petroleum hydrocarbons tyave beendetected. Migration of PAHs in ground .water and surfacewater/sediments also tends to be associated with petroleumhydrocarbons, although movement of cinder ballast as

V_x sediment in stormwater runoff may also be occurring.

• The PAH most frequently detected in site sediments isfluoranthene, detected in 77 percent of samples collected(23 of 30) at a site wide mean concentration of 2,528 ug/kg.Fluoranthene was also the PAH with highest detectedconcentration in Site surface water at 82 ug/L. PAHs weredetected infrequently in Site surface water, with mostdetected only in a drainage ditch that formerly drained aretention pond on Potomac Greens (North Pond drainageditch). Petroleum sheens are present periodically in thisditch, which receives stormwater runoff originating off sitein the City of Alexandria.

• Polychlorinated biphenyls (PCBs) have been detected insoils at the Site in low, concentrations (less than 1.0mg/kg), except in one sample, where PCBs were detected at1.05 tag/kg). PCBs are present in some of the free productfound in the Central Operations area of the Site atconcentrations £ 10.2 mg/L but have not been found to.bemigrating at detectable levels in ground water or surf acewater. Limited migration of PCBs in sediment appears to beoccurring along a drainage ditch that received dischargefrom a former oil/water separator.

i • Some pesticides that may have been used at the Site fortermite control, e.g., chlordane or other pest control

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purposes have been detected sporadically throughout theSite. The most frequently detected pesticide is DOT andassociated breakdown products (ODD and DDE). DOT has beenextensively used throughout the United States for mosquitocontrol and is widespread in the environment. Migration ofpesticides is not occurring through ground water, but somemigration of DOT and other pesticides appears to beoccurring via sediment in surface water runoff. Thepesticide detected most frequently in Site sediments wasbeta-BHC, detected in 17 percent of sediment samples at amaximum concentration of 90 ug/kg. Pesticides detected insurface waters in drainage ditches on Potomac Greens havebeen found in Site soils and in stormwater coining onto theSite via stormwater sewer pipes originating off site in theCity of Alexandria. These are commonly detected pesticides.The pesticide detected most frequently in surface watersamples was endosulfan sulfate, detected in 19 percent ofsamples at a maximum concentration of 0.33 ug/L.

The baseline human health and on-site ecological riskassessment was submitted by RF&P in June 1995, subsequentlyrevised and resubmitted in August 1995 based upon EPA's andparticipating agencies comments. EPA continued to have commentsand concerns about the ecological portion of the ris£ assessment.EPA met with RF&P and their contractors on September 26, 1995 toresolve the outstanding issues. EPA and RF&P agreed that theexisting risk assessment document would be revised according toEPA's comments and will focus only on the characterization of on-site risks to ecological receptors. Approval of the revisedhuman health and on-site ecological risk assessment isanticipated the first week of October 1995.

EPA has identified the need for the collection of additionaldata to complete the ecological characterization of risk to off-site receptors, primarily in the Potomac River and Four Mile Run.Additional data specified in order to complete the off-siteecological risk assessment for the Site include the collection ofsediment samples to assess impacts the Site may have, had or iscurrently having in the Potomac River and Four Mile Run. Althoughnot necessary for completion of the ecological risk assessment, agroundwater, sampling program downgradient of the CentralOperations Area of the Site (an area of the Site where a plume ofdiesel fuel containing levels of PCBs as high as 10.2 mg/L iscurrently being removed by RF&P) should be instituted to ensurethat migration of contaminants is not occurring, as well asmitigating the introduction of contaminants above ecologicallysensitive levels to Four Mile Run and the Potomac River andestablishing a monitoring program at all discharge points to FourMile Run and the Potomac River to monitor contaminants which maybe affecting off-site ecological receptors.

The pertinent findings of the human health and on-siteecological risk assessment are as follows:

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* The baseline human health risk assessment concludedthat the Site does.not pose elevated risks to human health.All of the upperbound excess cancer risks were within orbelow EPA's risk range (10~4 to 10~6)$Mr risk management atSuperfund Sites. The hazard indices;for noncancer healtheffects were predominately below EPA's guideline thresholdof 1. The hazard index for high-end occupational exposurewas slightly exceeded in only one localized area of theSite. However, all of the estimated air concentrationsassociated with this exposure were far below occupationalstandards and criteria.• Pesticides in surface waters and sediments in thePotomac Greens area of the site may cause a localizedreduction in the abundance and diversity of aquatic insects.

• Potomac Yards is a source of low concentrations ofPAHs, metals and pesticides to Four Mile Run and the PotomacRiver. :• _ Measured concentrations of some contaminants at theproperty boundary exceed toxicity criteria for sensitivespecies of aquatic life, possibly resulting in localizeddecreases in benthic species abundance and diversity.• The available sampling data cannot be used to evaluateecological risks associated with historical releases fromthe Site primarily to the Potomac River and Four Mile Run.Chemical concentrations in sediments are the most relevantdata for addressing historical releases. Chemicalspotentially associated with the site include PAHs, PCBs andarsenic.• The following contaminants exceeded toxicity screeninglevels in surface water at the Site indicating elevatedlevel of risk to ecological receptors:

Four Mile Run Storm Water/Drainage Ditches: Aluminum,arsenic, lead, and zinc.Potomac River Drainage Ditches: beta-chlordane, endosulfansulfate, heptachlor, and zinc.Potomac Greens Drainage Ditchess beta-chlordane, endosulfansulfate/ endrin, heptachlor epoxide anthracene, and zinc.

• The following contaminants exceeded toxicity screeninglevels in sediments at the Site indicating elevated level ofrisk to ecological receptors:Four Mile Run 6torn Water/Drainage Ditches: endrin ketone,dibenz(a,h)anthracene, fluorene, and copper.

Potomao River Drainage Ditchess anthracene,benzo(a)anthracene, fluorene, arsenic, copper, lead, andmercury.Potomao Greens Drainage Ditches: beta-chlordane, endrinketona, anthracene, benzo(a)anthracene, fluorene, arsenic,copper, lead, and mercury*

XXX. THREATS TO PUBLIC HEALTH OR WEL7ARE OR THB ENVIRONMENT

Section 300.415(b)(2) of the National Oil and HazardousSubstances Pollution Contingency Plan outlines the factors whichshould be considered in determining the appropriateness of aremoval action. Under Section 300.415(b) (2), five of the eightfactors are directly applicable to the situation at the Site.These are as follows:

A) 300.415(b)(2) (i) "Actual or potential exposure tonearby human populations, animals,or the food chain from hazardoussubstances or pollutants orcontaminants*1

Contaminants present in surface water and sediments from theSite are currently migrating to Four Mile Run'and the PotomacRiver as well as possibly affecting ecological receptors presentin the Potomac Greens area of the site. Concentrations ofaluminum, arsenic, lead, zinc, beta-chlordane, endosulfansulfate, heptachlor, endrin, heptachlor epoxide and anthracene insurface water and arsenic, copper, lead, mercury, endrin ketone,beta-chlordane, dibenz( a, h) anthracene, f luorene, anthracene andbenzo(a)anthracene in sediments have been identified as possiblyhaving potential adverse affects on ecological receptors in FourMile Run, Potomac River and Potomac Greens. The Potomac Riverand Four Mile Run are both used for fishing and recreationalactivities thereby causing possible exposure to human receptorsin the food chain.

B) 300.415(b)(2) (ii)

Contaminants are presently being released to Four Mile Runand the Potomac River via surf ace water drainage ditches andstormwater sewers from the Site. The Potomac River and itstributary, Four Mile Run, support a variety of fish and otherspecies of life which may be impacted by the contaminantsmigrating from the Site. The Potomac Greens area of the Sitealso supports a variety of insects, amphibians and otherwildlife. Portions of the Potomac Greens area of the site aredelineated as wetland areas.

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C) 300.415(b)(2)(iv) "High levels of hazardoussubstances or pollutants orcontaminants in soils largely at ornear the surface that may migrate*1

Elevated levels of several contaminants in surface water andsediments have the potential to migrate or are migrating from theSite to the Fotomac River and Four Mile Run., Concentrations ofaluminum, arsenic, lead, zinc, beta-chlordane, endosulfansulfate, heptachlor, endrin, heptachlor epoxide and anthracene in.surface water and arsenic, copper, lead, mercury, endrin ketone,beta-chlordane, dibenz(a,h)anthracene, fluorene, anthracene andbenzo(a)anthracene in sediments have been identified as possiblyhaving potential adverse affects on ecological receptors in FourNile Run, Potomac River and Potomac Greens.

(D) 300.415(b)(2)(v) "Weather conditions that may causehazardous substances or pollutantsor contaminants to migrate or bereleased"

Contaminants from the Site have the potential to or arecurrently migrating or being released to the Potomac River andFour Mile Run via drainage ditches and storm water severs presenton the Site. Rainfall and annual snowfall melt events increasethe likelihood of migration and release of contaminants insurface water and sediment discharge from the Site.

, • ' . ; . . - , . " " " •(E) 300.415(b)(2)(vii) "The availability of other

appropriate federal or state: . /. .response mechanisms to respond to

, the release"

The Virginia Department of Environmental Quality, City ofAlexandria and County of Arlington do not possess the resourcesto undertake a removal of this magnitude at this time.

IV. ENDANGERMENT DETERMINATION- - • . ; • • . - . (-T - - • - . - ' .

Actual or threatened releases of hazardous substances fromthis Site, if not addressed by implementing an appropriateresponse action, may present an imminent and substantialendangerment to public health, or welfare, or the environment.

V. ENFORCEMENT ACTIONS r

The Administrative Order by Consent [Docket No. 111-92-61-DC] ("Order"), between the EPA and Respondent, Richmond,Fredericksburg & Potomac Railroad Company (RF&P) was signed inSeptember 1992 and subsequently amended in January 1994. TheOrder requires the Respondent to conduct an EE/CA pursuant to 40CFR 300.415(b)(4)(i) if EPA determines that further removalactions are appropriate.

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VI. PROPOSED PROJECT DESCRIPTION/OVERSIGHT COSTS

The actions proposed for the development of the EE/CA forthe Potomac Yard Site are designed to eliminate the imminentthreat posed to human health, welfare, and the environment by thesite. The actions to be addressed by the EE/CA are as follows:

1. Evaluate, propose and review alternatives to mitigatethe release of contaminants from the Site which may bepotentially affecting the ecological receptors in thePotomac River, Four Mile Run and Potomac Greens areasof the Site.

Factors to be considered in the evaluation, proposaland review of alternatives to mitigate the release ofcontaminants at the Site which may be potentiallyaffecting the ecological receptors in the PotomacRiver, Four Mile Run and Potomac Greens areas of theSite should include, but not necessarily be limited tothe following:

• Mitigating the release of contaminant^ to EPAapproved limits, including, but not limited toAmbient Water Quality Criteria, or other criteriaprotective of ecological receptors in surfacewater and sediments from the Site.

• Establishing a quarterly monitoring program forcontaminants at all discharge points to thePotomac River and Four Mile Run to evaluate theeffectiveness of the measure (s) selected andapproved by the EPA to mitigate the release ofcontaminants to Four Mile Run, the Potomac Riverand Potomac Greens.

» Evaluation of the nature and extent ofcontamination in sediments from the Potomac Riverand Four Mile Run to evaluate ecological risksassociated with current and historical releasesfrom the Site.

Develop and submit an "off-site ecological riskassessment" based upon the additional data collectedfrom Four Mile Run and the Potomac River sedimentsampling as well as data collected as part of theExtent of Contamination Study already completed at theSite.

The alternatives proposed by the Respondent will be reviewedby EPA. EPA will select, or modify as necessary (prior to publiccomment as required by the NCF), alternatives to mitigate therelease of contaminants from the Site which may be potentiallyaffecting the ecological receptors in the Potomac River, FourMile Run and Fotomac Greens areas of the Site.

B. Oversight Costs

Oversight costs incurred by the U.S. Government with respectto Respondent's conduct of the EE/CA will be reimbursed by theRespondent to the Order in accordance with Paragraphs 21.1 and22.2 of the Order.

VIZ. RECOMMENDATIONS

Because conditions at the Potomac Yard Site meet thecriteria in NCF 40 C.F.R. S 300.415 for a non-time criticalremoval action, I recommend your approval of this request toconduct an Engineering Analysis/Cost Analysis at this site.

You may indicate your approyal or disapproval by signingbelow.

APPROVEDI X" ^ *""U f J Jv DATES,

DISAPPROVED I ____' •_________ DATE I

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