work plan c&r battery site remedial investigation ...2.0 site background information...

IMUSCORPORATION

MINE ROAD, PA

WORK PLAN

C&R BATTERY SITECHESTERFIELD COUNTY, VIRGINIA

REMEDIAL INVESTIGATION/FEASIBILITY STUDY

EPA WORK ASSIGNMENTNUMBER37-01-3LP4

CONTRACT NUMBER 68-W8-0037

NUS PROJECT NUMBER 9851

JUNE 1988

SUBMITTED FOR NUS BY: APPROVED BY:

RICHARD M.NINESTEEUP.E. ARTHUR K. BOMBERGER,^PROJECT MANAGER PROGRAM MANAGER

TABLE OF CONTENTS

.. , .... . .... ........ . Qff/G/ft PAGE- - -- . - - - --- ,• , 'X

1.0 INTRODUCTION ..................................................... .'f?{ ......... 1-11.1 PURPOSE .,.-.-. ,.__,_-,.- .-:_:..-- .-.»..-.= ,..:. ..;...........„....... 1-11.2 .-- OBJECTIVES AND ORGANIZATION ...,...-.....-.,.,...,....,........_....... 1-1

2.0 SITE BACKGROUND INFORMATION ................................................. 2-12.1 SITE LOCATION AND DESCRIPTION ........................................ 2-12.2 ... . .SITE HISTORY ....,..-.,.,,.-,.......,_..,.......,......,....-.........,.,.... 2-12.3 GEOLOGY ....... „„_.„„,. .__.__.,,.;v; .™~ ..... .................. 2-42.4 . _ .__HYDROGEOLOGY ......,:..,...„ ._.__..-. „. ..../.„;........„..„..... 2-62.5 - SURFACE WATER HYDROLOGY ................. ..,_.....,._.........,....... 2-7

3.0 SCOPING OF REMEDIAL INVESTIGATION AND FEASIBILITY STUDY ..................... 3-13.1 SUMMARY OF EXISTING DATA .....,. ...,,,„................................ 3-13.1.1 Groundwaterand Surface Water Investigations (1976-1984) .............. 3-13.1..2. . .. State Water Control Board Surface Water Sampling (1980-1986) ........... 3-23.1.3 State Water Control Board Soil Sampling (1979) .......................... 3-23.1.4 : Soil Borings (198~3) .... r.TTV .....,:,. ;:rrr...V...:.-.....,.........,.... 3-103.1.5 :..:.Reside.ntial Well Survey (1979) ......................................... 3-103.1.6 "Field Investigation Teami(FlT) Site Inspection (1985) ..................... 3-103.2 - 'PRELIMINARY RISK ASSESSMENT . .....,.._..._. .......... ,...^,........... 3-133.2,1 . Hazard Assessment .............. CT.. ..... .,,....._,.................... 3-183.2,1.1 : Indicator Chemical Selection ................ ,......................... 3-183.2.1.2 Toxicological Profiles .,-..-.,,-„..........,....,..,....,..........,..,.. 3-183.2.2 " Dose-Response Evaluation ......,_._..,_._......,...,.,..-,.,.-..........._.. 3-193.2.3 --ExposureAssessment ........U,.~fc..... . ., I,.*......,............... 3-203.2.4 Risk Assessment ;:.............__„;.;..-.. ,.-,. ...................... 3-223.3 - , -.-APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs) .. 3-233.4 .. - PRELIMINARYSCOPINGOFREMEDIALTECHNOLOGIES ..................... 3-303.5 .,,=. . DATA LIMITATIONS AND REQUIREMENTS ................................. 3-303.6 - DATA QUALITY OBJECTIVES (DQOs) ..._....._._.._.,........,.......,,.... 3-37

4.0 WORK ASSIGNMENT TASK PLAN .................................................. 4-14.1 TASK 1-PROJECT PLANNING ....,.....,........".......................... 4-14.1.1 Site Reconnaissance ,...'~~....«... _,._............._.-........................ 4-24.1,2 .- Collectand Evaluate Data _........._.-_........ _.„..,„.,.......................... 4-24.1.3 Bralnstorming"Activities ".,.....,-.".».-_.... y~~..,........................ 4-24.1.4 .-:. Preparation of Work Plan .......,....._ ...,,~,,,........................ 4-24.1,5 .Preparation of Project Operations Plan (POP) ............................ 4-34.2 - ---TASK 2 - COMMUNITY RELATIONS '.._......................... „.......,.-,. .-4-34.2.1 Community Relations Plan ............_.__,_-., .-.-_=,............................. 4-34.2.2 Public Meetings ... ~. ,.~. .. .-, .-. ,. ,r.~~~.................... .^....... 4-34.2.3 "CommunTty Relations implementation. .....".......,............ ....=.......... 4-44.3 - - /TASK'S-FIELD INVESTIGATION ............,..-.-...-.,.-...-..--...,.......... 4-44.3.1 Procurement of Subcontractors ........-,....-..-. -,.!,,.................... 4-44.3.2 . Mobilization/Demobilization .... .V.................................... 4-54.3.3 ...-.- -Environmental Survey ............,..._,","..,._.....-.-.....,'.......................... .4-54.3.4 -.. Hydrogeoligic Investigation .".,,.. -.-_,,-... -. -.•,.-.. -^ ................... 4-64.3.5 - Media Sampling ... ..:.-;_..•,..._„.„, ..,_1.. -..................... 4-124.3.6 Site Survey/Topographic Mapping ...... .=.......,.-........................... 4-24

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TABLE OF CONTENTS (CONTINUED)(r.

SECTION .:/ 'r'- PAGE—————————————————— - - - -.———————————————— - - - ^ - -^ ^_. - .... ... -i'.fq,.

4.4 .„ TASK 4.-.SAMPLE ANALYSIS AND DATA VALIDATION. ....................... 4-254.4.1 Field Instrument Analysis ........... .-......„_„_.,.,.................... 4-254.4.2 . Laboratory Analysis ...._,........-.,.-.....;.,,...,. „.„................... 4-254.43 - .Quality Control and Data Validation ........--.,..:, ._......,..,..,,....,,. 4-254.5 . ...TASK 5 - DATA EVALUATION ............. _„,....,.,.-,,.... ™ .......... -4-264.6 TASK 6- RISK ASSESSMENT ......... ,....-.__. .1........... ,„,........... 4-274.7 TASK'7-TREATABILITY STUDY/PI LOT TESTING ............................ 4-274.8 TASK 8- REMEDIAL INVESTIGATION (Rl) REPORT ..-,-..............., ., 4-294.9 -- TASK9-REMEDIALALTERNATIVESSCREENING ......... . ................ 4-294.9.1 Development of Remedial Response Objectives and Response Actions .... 4-304.9.2 ., .Identification of Applicable Technologiesand Assembly of Alternatives .._. 4-304.9.3 .---.. -Screening of Remedial Technologies/Ai-ternatives ................., .... 4-304.10 .TASK TO- REMEDIALALTERNATIVES EVALUATION ..,,......,.......,....., 4-314.11 TASK11-FEASIBILITYSTUDYREPORT ...................................... 4-354.12 - TASK 12-POST-RI/FSSUPPORT ..;......... _.,._._..................... 4-354.13 TASK 13- ENFORCEMENT SUPPORT .......................................... 4-364.14 TASK 14-MISCELLANEOUS SUPPORT .................................... 4-354.15 TASK 15-ERA PLANNING ..........-.,.:,:....»......,........,.....,....,-.. 4-36

5.0 PROJECT MANAGEMENT APPROACH ............................................... 5-15.1 ORGANIZATION AND APPROACH .........,-.. ..„, ..._ ................... .-.-5-15.2 ... QUALITY ASSURANCE AND DATA MANAGEMENT ....... ...................... 5-15.3 . zJ PROJECT SCHEDULE .... .=,,_-. ... .r.-.. .;„,.;:"!„ ,....,..........„..,,.., 5-35.4 .^PROJECT COSTS . . ......._.. „_.__.,-.-_;r ................. .......... 5-3

REFERENCES ....... - ......-. ™- .™-.—— «-.... - .............................. R-1

APPENDICES

A APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs) .. A-1

B TRIP REPORT ......................................................... B-1

C BATTERY CHEMISTRY OVERVIEW ....................................... C-1

Ml 30000

TABLES

NUMBER _; --- - • ..••:• r. .._:_,. -~~..._.- _._._..-.---- -.-- : /^H _ _ PAGE

3-1 Groundwater "and Surface Water Analytical. Results ........ .„,"„................ 3-3Froehling and Robertson, Inc., 1976-1984

3-2 .. Surface Water Analytical R Aufts State .Water Control Board, 1980-1986 .......... 3-63-3 -;.T- .--: Soil and Jediment Analytical Results, State Water Control Board ..........,_.... 3-8

May ancTAugust 1979 . . ", ..3-4 Soil Sample Analytical Results, Froehling and Robertson, Inc. ..-.-....._............. 3-12

December 19833-5 Groundwater Analytical Results, Field Investigation Team, April 1985 ...............3-143-6 Surface Sdil and Sediment Analytical Results, Field Investigation Team, .......... 3-16

April 1985 --.- ....-__._„_ ..'I' - . . _ . - . , __-. =_-i ..... . .... .3-7 Applicable or Relevant and Appropriate RequirementsTor ...................... 3-21

Indicator Chemicals .3-8 Potential Risks from Exposure to Site Contaminants -.--,—...-,...,...,,.......... 3-243-9 Preliminary Federal Applicable or Relevant and Appropriate Requirements ........ .3-273-10 Preliminary State Applicable or Relevant and Appropriate Requirements ........ 3-293-11 Potential Remedial Technologies' ...._.,-....,....,,..,....,...._-,.................. 3-313-12 Summary of Rl/FS Scoping Process and Data Requirements ...................... 3-344-1 Criteria for Placement of Monitoring Wells, for C&R Battery Site .................. 4-94-2 - Proposed Groundwater Sampling and Analysis Program ......................... 4-134-3 Proposed Soil Sampling and Analysis Program. .._-.-.,............................ 4-184-4 Proposed Surface Water and Sedi'ment Sampling and Analysis Program ..,_._...... 4-224-5 Debris Pile Sampling and Analysis Program. .......,....,_:.........,_....... r...... 4-23

FIGURES

NUMBER ____.. PAGE

2-1 Site Loca~tioh~Map . , ™-_.........-,.,,._ „."...... _,...-....,...,..,......... _:2-22-2 - -General Arrangement ...,...,„_._....,....,,,................................ 2-33-1 State Water Control Board (SWCB) ............................................ 3-73-2 Froehling & Robertsorv, Inc. Sojj.Sampling Locations ............................ 3-113-3 ^ EPA Region III FIT Sampling Locations i...._.'....,."!".........,-,.....,........ 3-154-1 Proposed Sampling Locations ,..._. .'i. _.; .".".""...'.,....... ___ ............ 4-104-2 - - Proposed Residential Well ........... .„_.............._..__.._,................. .4-155-1 Project Organization ........................................",................. 5-25-2 Project Sche'dule ................ .,„....,........-.,-.......,.,.............. Back Pocket

300004IV

1.0 INTRODUCTION

1.1 PURPOSE -'— """-"-"•

NUS Corporation (NUS) is submitting' this Work Plan for a remedial investigation/feasibility study(Rl/FS) of the C&R Battery Site to the U.S. Environmental Protection Agency (EPA), in response toWork Assignment Number.37-01-3LP4 under.Contract.Numbe_r68-W8-p037. This Work Plan wasdeveloped from a review of historical data and information obtained from a site visit onApril 7,1988, as well as a brainstorming session held on April 15,1988.

This Work Plan presents the technical scope of work, the estimated cost, and a schedule forperforming the Rl/FS. The work described in this document draws upon the results from previoussampling activities and focuses_sampling and analytical efforts on issues needing a more thoroughexamination. This approach will define present and future risks to human health and theenvironment as well as evaluate potential remedial alternatives. It is the intent of this Work Plan toperform all Rl activities as a single-phase effort. Thus, this document, including the project scheduleand the associated estimates of cost and LOE hours, considers only one phase. If however, onsitecontamination is found to be more extensive than expected, a second phase may be required.

1.2 OBJECTIVES AND ORGANIZATION

The Work Plan is organised, into.fiye_sections'. This .Introduction is Section 1.0. -Section 2.0, SiteBackground Information, presents an overview of the site. Section 3.0 draws upon available siteinformation to discuss risk, engineering, atid regulatory-related issues; develops a list of data needsbased on those discussions;" formulates a list of Rl objectives based on the data needs; and presents aset of field activities,~orgahized by medium, to meet the Rl'objectives. Section 4.0 presents theRl/FS tasks necessary to implement the scope of work developed in Section 3,0. Finally, Section 5.0,Project Management Approach, presents the project organization, cost, and schedule. .

1-1

300007

2.0 SITE BACKGROUND INFORMATION

*ft'G/;Vto;

This section "provides a brief review of the site history and site description. The primary source of thisinformation is the site inspection report for the C&R Battery Site, prepared by NUS Corporationunderthe Field Investigation Team (FIT) contract in February 1986. ._

2.1 SITE LOCATION AND DESCRIPTION

The C&R Battery Site is located in Chesterfield County, Virginia, approximately Smiles southeast ofRichmond. The site is located on a 4.5-acre tract of land on the north side of Bellwood Road,approximately 3,800 feet east of Interstate 95. Map coordinates for the site are 37*25'04" northlatitude and 77°24' 56" west'longitude.on the Drewry's Bluff,_Virginia, 7.5-minute series quadranglemap, as shown in Figure 2-1. ." " . "

The site is rectangular irfshape, approximately 1260 feet in the north-south direction, and between100 and 190 feet wTde. "It is bordered on the north, south, and west by open fieids and woods. Asmall f^el oil distributor, Capitol Oil Company, borders the site on the.east. The James River islocated approximately 650 feet north of the site. Figure 2-2 depicts the general site layout.

The site is located on property that was leased from the Capitol Oil Company by Mr. Charles Guyton.The lease boundary is indicated on Figure 2-2, but processing activities extended beyond thedrainage ditch (east of the site) onto the Capitol Oil Company property.

2.2 - SITE HISTORY

The C&R Battery Site was a battery-sawing and shredding facility designed to recover lead fromdiscarded auto and truck batteries. .It operated from the early 1970s until 1985. The battery breakerwas mobile, and operations were moved throughout the site.

The site received bulk shipments of discarded batteries. The first step in recycling was to cut thebatteries open and drain the battery acids into onsite ponds. The batteries were then broken openand the lead and lead compounds were recovered and stockpiled for later shipment. The batterycasings were subsequently shredded and stockpiled on the site. Crushed battery casings wereobserved on site during the April 7, 1988 site visitT No "other activities that may have produced -additional contaminants are known to have occurred onsite (NUS, February 1986);

3000082-1

BASE MAP IS A PORTION OF THE USGS 7.5 MINUTE DREWRYS BLUFF,VIRGINIA QUADRANGLE, 1969 PHOTO-REVISED 1980. CONTOUR INTERVAL 1 0 FEET. _ . . . . _

FIGURE 2-1SITE LOCATION MAP IMUSC 8 R BATTERY SITE, CHESTERFIELD CO., VA

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The Virginia State Water Control Board began "monitoring the site in the late 1970s. Severalreclamation plans were proposed "and permit applications were made by the operator but stateapproval was never authorized. . -,....._. . ..._ ....__.

Virginia "OSHA first inspected the site in 1983 while the / TJj&y processing facility was still inoperation. Air. monitoring of the breathing zone at several work stations measured lead atconcentrations up to I12yg/m3, well above the existing OSHA standard of 50 pg/m3. Employeeswere found to have elevated levels of lead in their blood (NUS, February 1986).

In response to potential public health concerns, ERA conducted a removal action at the site in thesummer of 1986. ERA removed the acidic liquidTrom onsite lagoons, raised its pH and discharged theneutralized liquids into storm sewers. The lagoon sludge was blended with hydrated lime andreturned to the lagoon. ;Soiis were disked and mixed with lime to a depth of 2 feet. However, whenintact batteries were found in the northern portion of the site, the decision was made to apply limeonly to the soil surfaceTn this area. "At the same time, a large amount of shredded battery casingmaterial was found east erf the drainage ditch. Some of this debris was brought back onto the siteand remains on site iff the debris piles (refer to Figure 2-2), whereas the excavated area wassubsequently backfilled to reduce hazards to Capitol Oil Company employees. The dr.' inage ditchwas graded and riprap channels and dams were installed to reduce erosion. A six-foot tall chain linkfence was installed inside. the tree-line to minimize the potential for direct contact withcontaminated materials on site "(verbal discussion with EPA during April 15,1988 brainstormingmeeting). .. __ . ...____. ., ..r_ _._ = ....

2.3 GEOLOGY

Regionally, the C&R Battery Site is located at the western edge of the Atlantic Coastal PlainPhysiographic Province of Virginia: The Coastal Plain is described as an eastward thickening anddipping wedge of unconsplidated_s_ediments (e.g., gravel, sand, silt, and clays) which were depositedin both marine and nonmarine environments. The thickness of this sediment wedge varies fromnearly zero at the Fall Line, .which roughly runs in a nqrth-south_direction, approximately 70 milesinland from the Virginia coastline to over 6,000feet (to the northeast near Temperancevilie,Virginia). The age of this clastic wedge of sediments ranges from early Cretaceous to Holocene(Meng and Harsh, 1984). _._ . . _ . _ _ . . . . ..... .:_..._

It is reported (NUS, February 1986) that, based on available information from geologicalpublications, the sediments of the Lower Cretaceous age Poto.mac?ormation outcrop just east of the

2-4 300011

Gfr.

Fall Line in the James River.valley within the vicinity of the C&R Battery Site "study area. According toMeng and Harsh (1984), the Potomac. Formation consists of fluvial-deltaic continental and marginalmarine. deposits of "early to~ea"rly~-late Cretaceous age. The Potomac Formation forms the basallithostratigraphic unit of the coastal plain sediments, and rests unconformably upon the basementrock surface. This formation is separated by major regional unconformities from the overlying laterCretaceous "and various Tertiafy'cleposits. The paleoenvirohment consisted of a low gradient,subareal, fluvial flood plain (dominated by meandering streams), which is represented by sedimentscharacteristic of channel sands, point bars, levels, flood plains, and back swamps.

These deposits rest unconformably on_a rock surface (Basement Complex), composed generally ofPrecambrian-Paleozoic granite and metamorphic rocks, with local occurrences of Triassic semi-consolidated "red beds" in graben structures of the basement rock (Calver, 1973). The upper surfaceof the basement rock is highly weathered,, forming 'a cover of saprolite which slopes gently eastward(Meng and Harsh, 1984).

The C&R Battery Site" study area" lies, within the reworked flood plain area of the James River, which islocated approximately 1,000 feet north of the site boundary.

The local geology ..of. the. C&R_B_attery Site, as d_escribed_ in_a recent FIT site inspection report(NUS, February 1986), consists of alternating layers of clay, sand, and sand and gravel, that belong to

the Potomac Formation. This interpretation is based on data from 4exploratory soil borings drilledon the site during a geotechnical"stud_y"_(Sayre arid Associates, .1.983), The deepest of these 4boringspenetrated to a depth of 45 feet. . • . . .. .:

A more detailed review of the subsurface data, indicate, the presence of a 3 to 8 feet thick layer ofgray clay just beneath the surface cover material which contains thin discontinuous lenses of brownsand. This clay layerJs underlain by a brown to gray sandy clay to a depth ranging from 13 to 20 feet.Only 2 of 4 onsite" borings penetrated the entire thickness of the sandy clay. Beneath this sandy claylies an interval which is described as a 9-foot-thick interval of brown, fine-to-medium-graihed sandin 1 boring and as alternating zones of brown sand and gravel and brown silty sand in anotherboring. Only 1 of the 4 borings penetrated deep enough (45 feet) to observe a zone of alternatingsands and gravels. Thus, the C&R Battery Site is apparently underlain by fine-grained sedimentswhich coarsen with depth to sand and gravel. A log of a test well, located approximately 3,200 feetnorthwest. of the C&RBattery Site at "the Fort Darling National Park, indicates the presence ofalternating layers of sand and gravel,, sandy gravel and clay,. and clay (NUS, February 1986). In the FITSite InspectibTi report, "ft" "was ' reported" that" ! "bedrock was encountered at 176feet(NUS, February 1986). .. . . .:_.. .... . _ " _ .. ;._ '_

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An alternate interpretation of the test .well boring description is also presented below. Theoverburden sediments extend to a depth of 141 feet. Semi-consolidated Triassic "red-beds" orsaprolitic materiaTcomprise the interval from 141 to 176 feet. The Precambrian-Paleozoic basementcomplex occurs below 176 feet an'd is comprised of red and gray granite.

The Soil Subfflv'b'f ChestedLeiclCQyntv, Virginia (1978) indicates that .original soils throughout theC&R Battery Site and adjacent area are classified as Pamunkey loam, 0 to 6 percent slope. Based onthe Site Investigation (NUS, Feburary 1986), the surface soils were described as a light brown sandyclay. . L _ .__.._._:.

2.4 HYDROGEOLOGY

The Potomac Formation comprises the six lowermost, hydrogeologic units in the hydrogeologicframework of the Virginia. Coastal Plain, consisting. of'three aquifers and three confining beds.Therefore, these hydrogeologic units are referred to as.the.Lower, Middle, and Upper Potomacaquifers and the corresponding Lower, Middle, and Upper Potomac confining beds. In general, theaquifer units are wedge-shaped in cross section and consist of a series of interbedded sands andclays. The delineated confining" beds are highly variable in thickness and consist of a series ofinterlayered silty and clayey deposits. 5 . . •

FIT 111 recorded in their site ih"vestic]atiori"report'(NUS, February 1986) that, based on the report byMeng and Harsh (1984), the C&R Battery Site is "situated within the outcrop area of the MiddlePotomac Aquifer urii~t~The Middle Potomac Aquifer is the second lowest and thickest aquifer in thehydrogeologic frarne_work of Vjrgihla, and extends the furthest westward, compared to the upperand lower aquifer units.of the Potomac.Formation._the aquifer consists of interlensing medium-grained sands, silts, and clays of differing thickness. Drillers commonly refer to the Middle PotomacAquifer sediments as "medium or coarse gray sands" with "red, brown, or multicolored clays".

The thickness of the middle Potorrrac aquifer within.a 3-mile radius of the site (NUS, February 1986)ranges from Ofeet, where the base of the unit outcrops, dipping and thickening to 150 feet to theeast of the site. Generally, most industrial and municipal wells throughout the eastern half ofVirginia, between'the coast and the Fall Line, obtain water from the Middle Potomac Aquifer (Mengand Harsh, 1984). This aquifer is capable of producing large quantities of high quality waters, but itcontains increasingly higher amounts,of jchloride in the down dip direction, restricting its use as apotable water source,. Domestic.wells in the vicinity of the C&R Battery Site most likely are screenedin this Middle Potomac Aquifer. .".. . .;

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Based on the FIT Site Investigation Report (NUS, February 1986), the upper layers of the MiddlePotomac Aquifer "exte'nd north and eastward from the sites ..where they are truncated by the JamesRiver. The lower portion of this.aq.uifer unit extends beneath the river. Even so, it is unlikely thatgroundwater beneath the site could migrate beyond the drainage divide of the James River, butwould instead discharge into the James River. Thus, there is little chance for wells located north andeast of the James River to be potentially affected as a result of contaminated groundwater migrationfrom thesite. __ _.. ,._ ..,,,--:........_ .:.-_._......... _.._:._:_ :___.n.._._. . i

Groundwater flow within the water table aquifer beneath the site is probably controlled by the site'sproximity to the nearby James River to the north. There are no recorded data specific to theC&R Battery Site to indicate" the "local gr"oundwater"flow direction, althoughjt is probably to thenorth or northeast toward the James River. Two wells penetrate the water table at the_C&R BatterySite. The off ice. well, located at the southern portion "of thesite, is a 36-inch diameter concrete-casedwell which extends to a depth of 30 feet. The monitoring well (Well No. 2) consists of a 2-inchdiameter PVC riser "pipe with a 5-foot long screen to a depth of approximately 40 feet. An adjacentpiezometer (Well No. 1) consists of a 2-inch diameter PVC riser pipe with a 5-foot long screen to adepth of approximately 18 feet. These two wells are located east of the former acid ponds (refer toFigure 2-2). Depth to water from the ground surface, ranged from 26 feet (office well) to 38.5 feet(deep monitoring well)"based on one water level measurement collected from each well. Elevationscannot be reasonably determined since the wells have never been surveyed. The depth togroundwater at the site appears to be consistent with the elevation of the James River to the north.

2.5 SURFACE WATER HYDROLOGY

The Coastal Plain of Virginia is dr.ained by three types of streams and their tributaries: (1) the trans-Blue Ridge, (2) the Piedmont, and (3) the Coastal Plain. The James River is considered a trans-BlueRidge type stream and is described as follows. The headwaters of the James River are far to the westin the Appalachian Plateau and the Appalachian Valley provinces. Before reaching the Coastal Plain,the river crosses the Blue Ridge and Piedmont Plateau provinces. The general drainage pattern ofthe James River intheCbasta! Plain is dendritic.. - .

The C&R Battery Site is located within the drainacje basin of the. James River which is part of theGreat Chesapeake system. The James River flows north.and east of the C&R Battery Site. The river isclosest to the site (approximately 650 feet) to'the north and is approximately one mile away east ofthe site.. A ditch running parallel to the eastern boundary of the site runs directly north to the James

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River." This ditch provides stormwater runoff from the site and .adjacent areas. It is otherwise dry formost of the year. --- - - - - - - - -. — -. _

The average discharge of the James River is 7,543 cubic" feet per seconcras measured over a 51-yearperiod at river mile 116.6 'hear Richmond (Prugh, 1986). The channel of the James Riveraverages 1,000 to 1,500 feet wide, and it is generally. about 15 to 20 feet deep (Wentworth, 1930).Also, the_ James River is ticfally influenced and has a mean tide range of 3.7feet near Richmond(Wentworth, 1930). This tidal fluctuation should affect groundwater levels near the James River andmay possibly influence water levels in monitoring wells installed near the C&R Battery Site.

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3.0 SCOPING OF REMEDIAL INVESTIGATION AND FEASIBILITY STUDY

This Work Plan has been developed to present the technical scope of work for the C&R Battery Site.The scope of work must be adequate to meet the objectives of the Ri/FS, which are to define the risksto public health and the environment as well as collect the data required to evaluate potentialremedial alternatives. ... . . _ . .. ._..._ . . . . . . . .

The first part of this section presents a summary "of existing data for the site. These data are thenused to develop a preliminary risk assessment that briefly examines potential exposure pathways andevaluates the public health risks.__Applicable state and federal regulations and guidelines are used inconjuncfTofTwlth the results of the preliminary risk assessment to help determine appropriateremedial technologies. . . .. . . _ . . . - . _ . . _ . .

In the" evaluation of risks to public health and environment and of the remedial technologies, datagaps are. identified and further developed as specific investigatibn objectives. The quantity of datato be collected and the associated quality requirements (data quality objectives) are defined in thefinal portions of this section. ". " . '

3.1 SUMMARY OF EXISTING DATA

Previous investigations. at the C&R Battery. Site have.focused primarily on the presence of high leadand low pH levels found on site. These are the most significant environmental issues at this site. Thebattery crushing_operation and' storage of battery add are. the .only known or suspected operationsat the site. Therefore, it'Ts unlikely that there are other significant types of contamination on site. -

3.1.1 Groundwater and Surface Water Investigations (1976-1984)

The earliest site investrgatioTTfdr which data are available was initiated in early 1976 by Froehlingand Robertson, !nc,,-consuitants to C&R Battery. From January 1976 until January 1978, the onsiteoffice well was regularly sampled and analyzed for pH and lead since it was a water supply well.Other sample locations (e.g., the drainage ditch on site, the Safety-Kleen/Capital Oil Company well,and an upstream sample in the drainage ditch) were subsequently added. Sampling intervals rangedfrom monthly to biannually.

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fey, ""There are marked differences between the onsite and the offsite samples. The onsite office well hada pH of iess than 6.2rand on one occasion of 3.0. Lead .concentrations in the onsite office well wereas high as 6.5 mg/l. .Groundwater sampled .from the tap at the Capitol Oil Company adjacent to thesite had a pH greater than 5.3 during every sampling period, and lead levels of 0.05 mg/l or less.

A surface water sampling location upstream of the site had a pH between 5.1 and 7.1 and lead levelsbetween 0.10 and 5.97 mg/l. The onsite drainage ditch was sampled at the same time. Analysis ofthe samples revealed that the pH ranged from 1.1 to 6.5 and lead ranged from 0.08 to 4.64 mg/l. Thehigher lead values in the upstream surface water sampling location compared to onsite values maybe attributable to residual leaded gasoline runoff from the adjacent roadway. Table 3-1 summarizesthesedata. -~. =i-::rr.- =• •-.::.;.-._:::- -...-.- •-. ;; :. ..-: .. . . _ ... .:: ~'-- -• - .-• --

3.1.2 State Water Control Board Surface Water Sampling (1980-1986)

Between 1980. and 1986, the.State Water Control Board (SWCB) periodically collected surface watersamples from standing water in the.pnsite._drainage ditch and from an upstream location alongBellwood Road. Some samples were analyzed Tor lead, cadmium, acidity, and field pH, while othersamples were analyzed for several other heavy metals. ; _

There was a significanfdifference between the upstream samples and the samples collected on site.During concurrent sampling events, lead concentrations in" the onsite. drainage ditch were greaterthan those in.the upstream sample. Lead in the upstream samples ranged from 0.117 to 1.899 mg/l,with a pH range of 5.5 tcr6.2. .Lead in the onsite samples ranged from 1.0 to 3.5 mg/l, with a pHrange of.0.4 to 6.0.._TThe data are summarized in Table 3-2.

3.1.3 State Water Control Board Soil Sampling (1979)

In 1979, the State Water Control Board conducted a soil sampling program on site. Approximatesample locations are shown in Figure 3r1. Soli samples were collected at 18 locations throughout thesite. Sediment" samples were" collected at 2 locations in the drainage ditch adjacent to the site.Table 3-3 presents a summary of the analytical results.

The .data presented in Table3-3 indicated that lead was present at concentrations of up to1.6 percent (16,000 nig/kg). The pH of the soils ranged^ from 3.3 to 6.5. Most samples were alsoanalyzed for cadmium, manganese," and zinc. In August'1979, additional analytes.such as arsenic,chromium, copper, nickel, and mercury were reported. Concentrations of these metals were similar

' . _ . . . , - . . _ , _ . . . _ .to typical concentrations in soils of the'eastern United States (Shacklette and Boerngen, 1984).

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3.1.4 Soil Borings (1983)

In December 1983, Froehling and Robertson, Inc., conducted a shallow sol! boring program at thelocations shown in Figure" 3-2. :Lead concentrations and pH levels were measured in surficial samples(0 to 1 foot depth) an if,at many locations, in subsurface samples (1 to 2 foot depth). EP toxicity testswere also run on several of these soil samples. Results from this sampling program may not reflectcurrent contaminant values sihce.""a limited degree of surface and subsurface soil remediationoccurred after these data were collected and analyzed.

North of the active area, lead concentrations were generally an order of magnitude higher in thesurface samples than in the subsurface samples. The pH of these samples ranged from 3.5 to 6.0.Two sample locations had-pH values greater than 10--one near a lime pond in the active area andone just south of the active area. Other sample locations south of the active area had pH values from3.7 to 8.2 and widely ranging leacj_.concentrations..___Four ~o;f the .eight EP toxicity tests exceeded the5ppm maximum RCRA EP toxicity level for lead. The values ..ranged, from 175.. to less than 0.2 mg/l.Table 3-4 presents the analytical data for soils from the soil borings.

3.1.5 Residential Well Survey (1979)

In July 1979, the SWCB collected samples from the onsitepffice well, the Safety Kleen (Capitol OilCompany)" water well, and 3 local residential water wells (locations unknown). Samples wereanalyzed for general water quality parameters such as suspended solids, major anions (e.g., chloride,ammonia, nitrate, nitrite, and sulfafe), fecal coliform, and various metals, including lead. The onsiteoffice.well groundwater sample was the only one found to exceed the drinking water standard forlead (the U.S. drinking water standard for |ead_is_ £50 £cj/l),_with_ a. concentration of 230yg/l. Theother four water wells contained less than 11 ug/1 of lead.

3.1.6 Field. Investigation Team (FIT) Site Inspection (1985)

In April 1985, the EPA Region ill FIT conducted a site reconnaissance and collected environmentalsamples..The.samples were analyzed for the inorganic Target Analyte List (TAL), including cyanide..No organics were analyzed and rto.pH values were reported.

Analyses of groundwater were performed on both _filtered_ and unfiltered samples in order todetermine both dissolved and total metal levels. The onsite office well groundwater was found tobe of relatively.goocl.quality when compared to the monitoring well groundwater downgradient of

3-10 30002G

TABLE 3-4 o

SOIL SAMPLE ANALYTICALFROEHLING'AND ROBERT sw, INC'

DECEMBER 1983C&R BATTERY SITE, CHESTERFIELD COUNTY, VIRGINIA

Boring ~Number

1

1A

2

2A

3

45 .. -6 "

6A

7

8

9

9A

10

11

12

13

Boring Depth(ft)0-1..01.0-2.00-1.00-0.5 .....0-1.01.0-1,30-1.01.0-2.0 "0-0.50-0.80-1.01.0-2.0 "••"".,-1.01.0-2.0 . "0-1.01.0-2.0 .

0-1.01.0-2.00-1.01.0-2.00-1.01.0-2.00-1.01.0-2.00-1.01.0-2.00-1.01.0-2.0.0-1.01.0-2.0.

pH

6.95.76.77.07.28.25.2

3.711.87.610.61234.8

4.55.84.6

5.53,56.04.6

4.64.24.73.84.94.3 - .4.95.93.53.9

Lead(mg/kg)17,99722,0004,39643,5693,4313,2337,85791.725,75562,95813,36632,3914,589292

35,3796,03929,5951,114

25,583446

22,172

3,59842,344

2,63860,6359,331

EP Toxicity Lead(mg/l)

175

20.8

3.9

98

6.1<0.2<0.2<0.2

Blank spaces- Not analyzed.Approxiate sampling locations are shown on Figure 3-2.

3.12 300028

the former acid pond (Well No. 2). The groundwater collected from well No. 2 contained several

metals. ..However, because the well borehole was backfilled with site soil that may have beencontaminated, these groundwater data are of suspect

"

Offsite groundwater samples were collected from a home downgradient (north) of the site, a homeupgradient" (south) of the .site, and Capitol Oil Company; east~of the site. These groundwatersamples did not contain any heavy metals (such asjead or arsenic) at concentrations above theanalytical method detection limijsr which was. we) I below the respective MCLs.

Table 3-5 presents a" s~umm~afy~of the groundwater analytical data for the residential wells and theonsite off ice Well as reported by FIT. Data rejected during validation procedures are not included.

Sediment and surface soil samples were collected by the FIT from several locations, which are shownin Figure.3-3. The analytical results for the two sediment samples showed no significant differencesbetween the upstream and the downstream sample locations.

The analytical results for the soil samples were compared to the results for an offsite sample.Cadmium, copper, nickel, and cyanide were not detected in the background sample, but were foundin the onsite samples. Calcium, lead, mercury/and ^inc were found in at least one onsite sample atconcentrations three times the background concentrations. Finally, arsenic is present in site soils atconcentrations greater than those normally encountered in native soils in the eastern U.S.(Shacklette and Boerngen, 1984).

Table 3-6 presents the analytical results for surface soils and sediments. Data rejected duringvalidation a r e notincluded. . . . . . . . .

3.2 PRELIMINARY RISK ASSESSMENT

This section presents a" "preliminary risk~~assessm~ent to identify potential public health andenvironmental risks" associated with ihe~~C&R Battery Site, The assessment is based on the validatedFIT data from 1985.. Because sampling procedures, analytical methods, and quality assurance/qualitycontrol aspects of the Froehling and Robertson and SWCB investigations are not known, the data areof uncertain quality and, therefore, will not be used in the preliminary risk assessment.- However, theFIT data analytical results are generally of the same order of magnitude as the results from theearlier investigations. " "". : .(-~: ~~ - - .'.~~" : " r -

- . . . . . ' . - - 3000293-13

TABLE 3-5

GROUNDWATER ANALYTICAL RESULTSFIELD INVESTIGATION TEAM

APRIL 1985C&R BATTERY SITE

CHESTERFIELD COUNTY, VIRGINIA

Analyte

aluminum

antimony

arsenic "~

barium

beryllium

cadmium

calcium

chromium

cobalt . . .

copper

iron

lead

magnesium

manganese

mercury

nickel

potassium

selenium

silver

sodium

thallium

tin

vanadium

zinc . . •

cyanide

Off ice Well

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823

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2,020 : =

7,949

517

5,598" ~ .-

20,680 —

119

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122;300

314

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358

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21,980 "

139. ..

NA

Duplicate OfficeJWeil

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469 ..

116,400

2,743

7,746

478

5,837

19,860

117

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153

118,800

183

8,119

355

NA

5,373

21,200

89

Home #8Downgradient

123

15,840 _

65

6,017

51

8,738

211,600 .

17

Home #10Upgradient

89

8,544

28

166"

882.

2,654

10

9,239

50 :

11.0

Capital OilCompany

245

9,831

12

3,971

7,179

161

3,931

11

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68

All results reported in yg/I.NA- Notanalyzed. „__.Blank space - Not detected.

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TABLE 3-6

SURFACE SOIL AND S

FIELD INVESTIGATE!

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3-17 300033

The risk assessment process has.several components, .The first component is the selection of indicatorcompounds that adequately represent the site conditions and an evaluation of their toxicity, whichconstitute the Haza'rd Assessment. The next component is a dose-response evaluation whichpresents regulatory standards or ..guidelines, for the. indicator chemicals. The dose-responseevaluation is then foilowed by an assessment of potential exposure pathways. Doses can then beestimated by making assumptions about contaminant concentrations at the point of exposure andabout exposure duration. Finally, potential carcinogenic and noncarcinogenic risks can be estimatedby using published toxicologic information.

3.2.1 Hazard Assessment _ ,,"_"._ ._"_,—--"

3.2.1.1 Indicator Chemical Selection

An initial list of indicator chemicals is. selected after site monitoring data are evaluated. Theselection is based on thei'r chemical toxicity, environmental concentrations, and various physical andchemica! parameters related to environmental mobility and persistence. Indicator chemicals areintended to be representative of site conditions and potential health risks.

For this site, the most obviousTnolcator chemical is lead. However, several other metals were foundin onsite soils that are common components of lead-acid and nickel-cadmium batteries. Thesemetals are arsenic, cadmium, copper, nickel, and zinc. Other metals known to be components ofbatteries, such as antimony, were not found in the FIT samples. An overview of battery chemistry ispresented in Appendix C. Based on existing knowledge of previous site activities, there is no reasonto suspect that the battery processing operation wouldTiave introduced any organic contaminantsinto the environment! For this reason, only inorgariic'indicator compounds will be evaluated at thistime. .. ,~ - - " - - ." - - ,. ..:. .—_--- -

3.2.1.2 Toxicological Profiles

Of the identified indicator "compound's, only arsenic, •'cadmium, and nickel are known to be or aresuspected of being human carcinogens. All of_the indjcator.metals exhibit noncarcinogenic healtheffects. The following are brief toxfcologica! profiles for each indicator compound:

Lead - Data concerning the.cardnogenicity__of lead in_h_uman.$ are inconclusive. However, severallead salts have been shown to cause kidney tumors in'mice and rats. Ingestion or inhalation of leadmay cause toxic effects in the brain, central nervous, system, or the kidneys. Anemia is an early

3-18 S400034

manifestation of lead poisoning "in humans. Freshwater vertebrates and invertebrates are moresensitive to lead in soft water than in hard water.

Arsenic.- Upon ingeTtibri", arsenic has been shown to~cause skin cancer. There is also evidence thatarsenic causes lung cancer in^bccupationally-exposed individuals. Arsenic compounds also producenoncancerous skin changes and progressive polyneuropathy. Inorganic arsenic appears to be moretoxic to freshwater vertebrates than organic arsenic..

Cadmium - Cadmj_um has_been linked to prostate cancer in humans. Inhalational exposure tocadmium caused lung tumors in rats. Toxiceffects attributed to cadmium include renal dysfunction,anemia, pulmonary disease, and bone damage. Cadmium may have adverse effects on fishreproduction. Cadmium is taken up by plants and may thus be introduced, into the food chain.

Copper•-• Copper does not appear to have any carcinogenic, mutagenic, or teratogenic effects inanimals or humans. Copper salts act as skin irritants upon dermal contact. Inhalation of copper dustand fumes can cause short-term illness and respiratory tract irritation." Conjunctivitis may result fromdirect contact of "iontc copper with the eye. Acute toxicity of copper in aquatic animals tends todecrease with increasing hardness, alkalinity, and total organic carbon parameters. Sheep areparticularly sensitive to copper (Gough, Shacklette, and Case, 1979).

I Nickel - Nickel .is a known human carcinogen. Workers exposed to insoluble nickel in the workplaceexhibit lung and nasal cavity cancer. _Soluble nickel salts do not appear to be carcinogenic.

f Dermatitis, rhinitis," and nasal mucosal injury are the most frequent effects of exposure to nickel andnickel-containing compounds. For freshwater, organisms, nickel tends to be more toxic in soft waterthan in hard water.

Zinc"-The presence of zincTappears.to be necessary for tumor'growth, but zinc does not appear to becarcinogenic/mutagenic, or teratoge.nic in humans,.^ Zipc is"an^ essential dietary trace element.However, ingestfon of excessive arnouhts'of zinc may.cause a copper deficiency and result in anemiaas well as fever, vomiting, stoma;c"h"crarnps," and diarrhea. Zinc is less toxic to freshwater organisms inhard water than i n soft water. . _ " . - .

3.2.2 Dose-Response Evaluation _

Dose-response relationships provide a means by which potential public health impacts may beevaluated. There is a relationship between the.dose of a compound received by an individual and

I the potential for adverse health effects to result from that exposure.

3-19 3C0035

Table 3-7 presents the available regulatory stanaafds or guidelines for the indicator chemicals.Presently the only enforceable regu!atory__standards arejhe Maximum Contaminant Levels (MCLs).Relevant regulatory guidelines include the Ambient_Water___Qu_ajtty Criteria (AWQCs), MaximumContaminant^ Level Goals (MCLGs), Reference Doses (RfDs), Health Advisories, and CarcinogenicPotency Factors (CPFs).

3.2.3 Exposure Assessment ..". ~." 711 " "1JJ.1""

The third step in the public health assessment is to identify actual or potential routes of exposure forhuman and environmental receptors, and to characterize the likely magnitude of exposure. Anexposure pathway has four elements: (1).source_and mechanism of release to the environment;(2)transport medium such.as air or water; (3) point of human contact with the contaminatedmedium; and (4) an exposure route (such as ingestiori of drinking water) at the contact point. If oneof these elements is missing, there is no exposure. : ~ ~; ,. .

Potential human and environmental exposure pathways being identified under current or futureland use scenarios for this site include: . "...

• Erosion of contaminated soil by wind and transport to offsite human receptors exposedvia inhalation of particulates and/or inadvertantingestioh.

• Inadvertent ingestion of soil on hands by persons trespassing on site.. .

• Erosion of contaminated soil and transport.via storm water runoff to the drainage ditchwhere the sediment may be carried downstream to.the James River and to human as wellas environmental receptors in the food chain.

• Migration of soluble metals _to_ the. groundwater_.via. infiltration of acidic moisture,followed by subsequent transport to downgradient receptor wells where ingestion ofcontaminated water would be possible.

At the present time, the first three exposure pathways are likely to occur, but there is no currentevidence to support the groundwater exposure scenario.

Contaminant concentrations at the exposure points can be estimated either from monitoring dataor from the use of predictive models' Predictihg'the movementfbf inorganics is difficult without site-

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3-21 300037

specific' information"'brfarfiohs present", pH, and cation exchange capacity of the soils. These types of

data are not available at the present time. .The exposures associated with wind erosion ofcontaminated soi! .and subsequent inhalation and ingestion are.estimated by using the averageonsite. soi! concentration (It Ts assumed that the wind will act equally over the entire site).

Potential human exposures via the food chain and environmental impacts cannot be addressed inthis preliminary risk assessment because there is insufficient data available at this time to evaluatethese exposures. In addition, the drainage ditch does not support a permanent aquatic community.The downstream extent of lead (including potential deposition ih the James River) is not known, butif lead or other metals are traced from the site to the James River iiTthe R!, these potential exposureswill be evaluated in the risk assessment, in addition, potential impacts on the recreational value ofthe river or on downstream water intakes will be identified".

3.2.4 Risk Assessment _ .:

In order to assess the potential adverse human health effects, associated with the C&R Battery Site,the level of exposure must be estimated. The dose, or the amount of a contaminant absorbed by thebody, is related to a toxicologic response (dose-response relationship). Carcinogenic and/ornoncarcinogenic health effects may result from exposure to certain site contaminants. Doses may beestimated using the following assumptions: ." .

• Fugitfve dust inhalation and ina_dvertantjngestion

- - Contaminant concent'f'atrorfs'ih the air wereTestTrnated at a distance of 200 m from thesite, using, the Rapid Assessment of Exposure to Particulate Emissions model (Cowherdetal., 1984)

Deposition of contaminated soil at the receptor was calculated based on the USEPAISC deposition model. Deposition will reach equilibrium with losses due to such factorsas weathering. Estimates are based on predicted soi! contaminant concentrations inthetop2.5-Cfh (1 inch) of soil.

Contaminant doses were estimated using the .method outlined by Hawley (1985) forinhalation and ingestion exposure to soi! in residential areas. Maximum onsitecontaminant concentrations were=used to derive the worst-case dose estimates, whileaverage concentrations-were used to derive plausible dose estimates. Exposure ratesdefined in the mode! were not modified in this preliminary risk assessment.

3-22 - 300038

- - ,,.,Accidental ingestioTi of onsite soi I by

Contaminant, doses "were estimated using exposure rates presented by LaGoy (1987)for persons playing oh site for one-half "day per week for -12 weeks per year over a5-yearperiod. . . . . . -,. . .... _.-.__. .,. ...=..... _ .. ... .

Carcinogenic health effects are usually presented as an'average exposure over a lifetime (i.e., a time-weighted dose). These doses are multiplied by the carcinogenic potency factors to provide anestimate of the likelihood of developing cancer as a result "of a certain exposure. On the other hand,the likelihood of occurrence of noncarcinogenic effects, such as acute toxicity, is presented as a ratiobetween the maximum daily dose and the reference dose. If the ratio (also known as the hazardindex) exceeds unity, toxic effects are likely to occur. "

Based on the preliminary review'of existing site data, risks have been estimated for human exposuresunder a worst-case (using maximum soil, concentrations and suggested exposure rates) and aplausible case (using average soil.concentrations.and suggested exposure rates). Table 3-8 presentstotal carcinogenic and noncarcinogenic mks.

The carcinogenic risk is.a "total, risk fo_r aiLknown.or potential carcinogens found on site (i.e., arsenic,cadmium, and nickel). The total.noncarcinogenic risk," which includes individual risks for cadmium,copper, lead, nickel, and zinc, is greater than unity. At this time, there are no data to suggest thatother routes of exposure are occurring, such as groundwater ingestion. In addition, environmentaleffects cannot be-quantified with the existing data base. " . . . . .

3.3 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

Under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), or"Superfund/'the primary concern during the development of remedial action alternatives forhazardous waste sites is the degree of human health.and environmental protection afforded by agiven remedy. The National QiJ.and Hazardous Substances Contingency Plan (NCP), as amended bytheSuperfund Amendments and Reauthorization Act (SARA), requires that primary consideration begiven to remedial alternatives that attain, or.exceed ARARs. The purpose of this requirement is tomake.CERCLA response actions consistent with other pertinent Federal and State environmentalrequirements. The USEPAhas. indicated that ARARs must be identified for each site.

3-23- •,::- 300039

TABLE 3-8

POTENTAL RISKS FROM EXPOSURE TO SITE CONTAMINANTSC&R BATTERY SITE

2,5 yr child

6-yr childTeenagerAdult

Total Carcinogenic Risk

Offsite Ingestion & inhalation

Plausible Case

7.8x10-5

1.0x10-5

— =. ...9.1 x10-6

Worst Case

2.2X10-44.0x10-5

2.4x10-5

Onsite Ingestion

Plausible Case

--

--2.7x10-5

.,

Worst Case

-

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-

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6-yr child

Teenager ""-

Adult

Total Noncarcinogenic Risk

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Plausible Case

666.5 ,

-

5.0

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110

10

-

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41

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3.24 300040

Under SARA, an ARAR is defined as follows: ". r/6>vy,%

• Any standard, requirement, criterion,~b"r limitation under Federal environmenta! law.

• Any promulgated .standard, . requirement, criteria, or limitation under a State.environmental or facility siting law that is more stringent than the associated Federalstandard, requirement, criterion/or limitation. "

Applicable requirements" are those Federal and State requirements that would be legally applicableto the response action if that action were not taken pursuant to Sections 104 or 106 of CERCLA.Relevant and appropriate, requirements are those Federal or State requirements that, while notapplicable, are designed to apply to problems sufficiently similar to those encountered atCERCLAsites that their application is appropriate. Relevant and appropriate requirements areintended to have, the same weight as applicable requirements. USEPA has also indicated that"other" Federal and State criteria, advisories, arid guidelines be considered during the developmentof remedial alternatives. Examples of such other criteria include USEPA Drinking Water HealthAdvisories.(formerly Suggested No Adverse Response Levels or SNARLs), Carcinogenic PotencyFactors, and Reference Doses (similar to Acceptable Daily intakes or ADls).

Section 121 of SARA requires that the remedy for a CERCLA site must..attain a!l ARARs unless one ofthe following conditions is sati'sfied: (1) the remedial action is an interim measure where the finalremedy will attain the ARAR upon completion; (2) compliance will result in greater risk to humanhealth and the environment than other options; (3) compliance is technically impracticable; (4) analternative remedial action will attain the equivalent of the ARAR; (5) for State requirements, theState has not consistently applied the requirement in similar circumstances; or (6) compliance withthe ARAR will not provide a balance between protecting public health, welfare, and theenvironment at the facility with the availability of Fund money for response at other facilities (Fund-balancing). . , . . . . . . . . .

ARARs fall into three broad categories, based on the manner in which they are applied at a site.These categories are as follows: _ . " " " . . : .

• Contaminant Sp'ecific - These ARARs govern the extent of site cleanup. Such ARARs maybe actual concentration-based cleanup levels or they may provide the basis for calculatingsuch levels. Examples of contaminant-specific ARARs are.MCLs or air quality standards.

3-25 :-:: •--/-• - 30004

• Location Specific -These ARARs are considered in view of natural or man-made sitefeatures. Examples of natural site feature's include wetlands, scenic rivers, and floodplains.Man-made features could include, for examp!e,_the presence of historic districts. The siteis not~located in either a floodplain'or a wetland, but if a remedial action would affectsuch an area, these ARARs would apply.

• Action Specific - These ARARs pertain to the implementation of a given remedy. Examplesof action-specific ARARs include monitoring requirements, effluent discharge limitations,hazardous waste manifesting requirements, arid occupational health and safetyrequirements."" - - --— " - . . - " ^ . ..

Tables3-9 and 3-10 provide a preliminary listing of the Federal and State ARARs identified for theC&RBattery Site! A'.-descrrption of the ARARs is included in AppendixA. The Federal ARARsidentified in Tabfe~3-9 will be refined and revised as the Rl/FS develops to consider site-specificconditions and potential remedial actions. The Commonwealth of. Virginia ARARs identified inTable 3-9 are also, preliminary! The final I lit .of. Virginia ARARs will be obtained from the VirginiaDepartment of Waste Management. The ARARs will be evaluated in terms of their applicability,relevancy, and appropriateness to the site. The ARARs will be considered at five decision points inthe Rl/FS. These points include; - . .-- - - .-... -- ..1...--1 -

• Task 6 - Risk Assessment: Consider ARARs during the analysis of risks to the public healthand the environment. . " : " .,~~ .. ~~ ' ™ i:. : ...,.._..

• Task 9 - Development of Remedial Objectives: Compare site data base to ARARs.

* Task 9 -Jdentificatib'n o'f Applicable'Technologies and Assembly of Alternatives: Use site-specific ARARs to develop action levels, specific response objectives, and remedialalternatives relative to criteria defined in 4QCFR300.68(f). Also identify ARARs that apply

t o t h e formulated alternatives.. - - -,-- = . - " - .

• Task 9 - Screening of Remedial Technologies/Alternatives: Consider ARARs when assessingthe effectiveness of an alternative, as defined in 40 CF"R 300.68(g)(3).

'• Task 10 - .Remedial Alternatives Evaluation: Evaluate each alternative according to theextent it attains or exceeds ARARs, as defined" in 40 CFR 300.68(h)(2)(iv).

3-2S 300042

(Red)PRELIMINARY FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

BATTERY SITE

Requirement . . — - '-• =.. Rationale

Contaminant-Specific"

Safe Drinking Water Act_ ~ . " -::_ ".a. Maximum Contaminant Levels (MCLs)b. Maxium Contaminant Level Goals (MCLGs)c. . .Underground injection control regulations

(40 CFR, Parts 144-147).Clean Water Act (PL92-500)a. Federal ambient water quality criteria

(AWQQ. . - . . . - -

Clean Water Act(42 USC7401)a. National Ambient Air Quality Standards

(NAAQs) for6 criteria pbllutants.(40CFRPart 50). " T "

Reference Doses (RfDs), ERA Office of Researchand Development. . _-...-". ,. ..Carcinogenic Potency Factors, EPAEnvironmental Criteria and Assessment Office;EPA Carcinogen Assessment Group. ". ,Health Advisories, "EPA Office of DrinkingWater. .. . ..- .._-:. . -. . ....

Remedial actions may include groundwatercleanup to MCLs, SARA Section 121(d)(2)(A)(ii)

May be applicable to onsite groundwaterrecirculation systems.

Remedial actions may result in surface waterdischarges that could impact aquatic life.

Remedial alternatives may include excavationof lead - contaminated soil.

Considered in the public health assessment.



Location-Speciffc

Executive Order 11988(F!oodplainManagement). . :jf.-Fish and Wildlife Conservation Act of 1980 " ""(16USC2901)Fish and Wildlife Coordination Act_(16 USC 661).Fish and Wildlife Improvement Act of 1978(16USC742a).Flood Disaster Protection Act of 1 973 andNational Flood Insurance Act of 1968. " . .Groundwater Protection Strategy.

Floodplain resources may be affected byremedial action, _Remedial alternatives may affect fish andwiidlife habitat.Remedial alternatives may affectjfish andwildlife habitat.Remedial alternatives may affect fish andwildlife habitat.Floodpiain resources may be affected byremedial action...Remedial alternatives may be determined byclass designation.

. - :. ~L- 300043

TABLE 3-9 .. - ..._..._ ..._ ._ _. ._.. - ._. - &MQ.'FEDERAL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTSC&R BATTERY SITEPAGE TWO

Requirement Rationale

Action-Specific

Hazardous Waste Requirements (RCRASubtitle C, 40 CFR, Part 264, including cleanclosure requirements. _,. . .=.__,__^..._ _ = . ,OSHA Requirements (29CFR, Parts 1910, 1926, :and 1904).Threshold Limit" Values, American Conferenceof Governmental Industrial Hygienists, .:.DOT Rules for Hazardous Materials Transport(49 CFR, Parts 107, 171.1-500).Clean Water Act (PL92-500)a.. NPDES permits. " _ ,=..__;_"_. "..=_.._._

Standards applicable to treating, storing, anddisposing hazardous wastes.

Required for workers engaged in onsiteremedial activities.May be applicable to air concentrations duringremedial activities.Remedial alternatives may include offsitetreatmentand disposal.Standards applicable to surface waterdischarges.

3-28 300044

TABLE3-10 / .w.%< "

PRELIMINARY STATE APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTSC&R BATTERY SITE ~ *

Requirement Rationale

Contaminant-Specific

Virginia Ai'r Pollution Control Regulations

Virginia Water Quality Standards.

Governs releases of lead, particulates, andfugitive dust.

Water quality criteria set for the protection ofaquatic life.

Action-Specific"

Virginia Hazardous Waste Facility SitTng Criteria

Virginia Hazardous Waste ManagementRegulations . . . . . ; . "

Virginia Solid Waste Regulations

Virginia Erosio'n and Sedimentation ControlLaw and handbook.

Laws of Virginia Relating to Subaqueous Lands,Wetlands, and Coastal Primary Sand Dunes. -

Provides specific siting criteria for treatment,storage, and disposal facilities.

Controls the generation and transportation ofwastes for treatment, storage, and disposal.Similar to RCRA.

Governs construction and operation permits forlandfills, incinerators, and new/uniquetreatment methods.

Criteria for management of erosion andsedimentation during remediation/excavation.

Provides guidance on activities in wetlands andcoastal areas throughout the state.

3-29 300045

ARARs must also be considered when determining the types and amount of data to be collectedduring the field investigation. " " ." . "... _ "I... ', . _. _

- ' ; - • " ' ' ji..' "

3.4 PRELIMINARY SCOPING OF REMEDIAL TECHNOLOGIES ffi-ty'.?V

The project goal for the C&R. Battery Site "is to Identify ajid evaluate ...remedial alternatives to reducepresent and potential public health and environmental exposure routes and contaminant pathwaysto acceptable levels. To accomplish this goal, the problems associated with the site (e.g.,contaminated surface and subsurface soils, contaminated surface water and sediments, andpotential groundwater contamination) must._be_add_resse:d_,. Preliminary remedial technologies foreach site problem have., been identified and are summarized in Table 3-11. Source controltechnologies include treatment that eliminates or reduces the need for iong-term management at

-_-..-• •_... .-.. -. , .. , - ;;. .i. «i..,the site, containment and no action. . .

The screening of technologies (Task 9).and .the id_entjfication of innoyative.technologies will beginshortly after approval of the project plans. Treatability studies as well as bench-scale and pilottesting will be identified as a result of the source control technologies.evaluation conducted underTask9. - .... ._ ,-... -_^ ..=,.=_=,._,-_-=._:"":.-, ,_-". :....-,=_-,_..

3.5 DATA LIMITATIONS AND REQUIREMENTS

The previous sections of .this. Work. Plan discussed the site in"r_elation to the public health andenvironmental risks, ARARs, and potential remedial alternatives. Based on this,site information,specific data requirements G.eV, investigation objectives) are identified. Data needed to supplementthe existing limited data base, and to further evaluate .risks. ancT re media.!, alternatives, are presentedinTableB-12.. .. . "_'... ..::;;. ;".. '.._..:"'."'.: ":_:_... .:_"::" . rJ " ".. =

The specific objectives of the Rl/FS are to":" - V - - - - - - «------.

• Determine the.ap'pToximate lateral and approximate vertical extent of soil contaminatedwith lead and related metals, and, if possible, focus on prior operational areas and/orcasing disposal areas. Concurrently, assess the site for the presence of previous acid ponds.

• Determine the approximate volume and extent of buried, intact batteries.

• Determine whether the debris piles contain contaminated.soHs or other materials.

3-30

1

Disadvantages

OltoCra•a

CTiOOc.e

!r1?&1cc

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ce

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tions.

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300043

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TABLE

3-11

POTENTIAL RE

C&R BATTERY

PAGE

THHEE

201££ou

Disadvantages

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3-36 300052

Determine the downstream extent .of lead-contaminated sediments in the drainage ditch,particularly" focusing cTn potential impacts to resident biota.

• Determine groundwater flow direction as wjj as the physical and chemical aquiferparameters that affect contaminantTnigratioh/^ J ty

• Determine the presence or .absence of groundwater contamination resulting from thedownward migration of lead to the water table and subsequent potential public healthrisks from domestic use of the groundwater.

• Determine, potential public health risks resulting from wind erosion and deposition ofcontaminated soils, through paniculate inhalation and/or soil ingestion.

• Develop and evaluate appropriate remedial alternatives based on the data collectedduring the Rl.

3.6 DATA QUALITY OBJECTIVES (DQOs)

The development of data quality objectives (DQOs) focuses on identifying the end use of the data tobe collected, and determining" the degree of •certainty— with respect to precision, accuracy,representativeness, completeness, and comparability (PARCC)--necessary to satisfy the intended enduse. Once the acceptable degree of certainty regarding analytical results is determined, one of fivedata quality categories listed below is selected to describej:he_ approach taken to achieve the desired

level V -.Non-standard .Methods - Analyses that may require method modification arid/ordevelopment. - . ... .: .. ... .... .._... _. ...._ __

Leve! .IV - Contract Laboratory Program (CLP) Routine Analytical Services (RAS) - This leyei ischaracterized by rigorous quality assurance/quality control (QA/QC) protocols anddocumentation. It also provides qualitative and quantitative analytical data. Someregions .have obtained similar support via their own "regional laboratories, universitylaboratories, or other commercial laboratories...

Level M! - Laboratory analysis using methods .other, than the CLP RAS -.This level is usedprimarily in support of engineering studies using standard EPA-approved procedures.

3.37 . , 300053

• Level M - Field analysis - This level is characterized by the use of portable analyticalinstruments that can be used either onsite or in mobile laboratories.stationed near a site(close-support laboratories). Depending upon the types of contaminants, sample matrix,and personnel skills, qualitative and quantitative cra%.can be obtained.

• Level.1 -..FLeld_S-Cige.nina -.This level is characterized by the use of portable instruments thatcan provide real-time data to assist in the optimization of sampling point locations and forhealth and safety support. Data can be generated regarding the presence or absence ofcertain contaminants (especially volatiles) at sampling locations. These data arequantitative only for total organics.. . . . .

I Section 4.3 presents specific DQOsJorthe Rl/FS field investigation activities.i -- - - .

3-38 300054

300055

4.0 WORK ASSIGNMENT TASK PLAN

This section pr'esents.a" description of .each task to be performed during the Rl/FS at the C&R BatterySite.....The rationale for all activities described in these, tasks has been presented in detail inSection 3.0. It is the purpose of this section to summarize the activities that will be conducted and topresent the sequence in which the events will occur.

The Rl/FS consists of the standard Rl/FS tasks described in Office of Solid Waste and EmergencyResponse (OSWER) Directive 9242.3-7, November 13, 1986 Standard Rl/FS Tasks Under REM Contracts.The following are the standardized Rl/FS tasks used in this Work Plan:

• Task 1-ProjectPlanning . ;- -•-• Task 2-Community Relations• Task 3-Field.lnvestigations.• Task 4-Sample Analysis/Data Validation• Task 5 - Data Evaluation• Task.."6 -Assessment of Risks• Task 7-Treatability Study/Pilot Testing _ .• Task 8-Remedial Investigation Report• Task 9 - Remedial Alternatives Screening• Task 10 - Remedial Alternatives Evaluation"• Task11 - Feasibility StudyRe port .• Task 12-P.ost-RI/FS Support -• Task 13-Enforcement Support . -..• Task 14- Miscellaneous Support• Task 15-ERA Planning

4.1 TASK 1 - PROJECT PLANNING

Task! includesthe completion of the following activities: ri=1, - ..

• Initiation of Project Work Assignment• Data Collection and Review ...• Development of the Interim Health and Safety Plan• $ite~Reconnaissa~hce 7.. ", ' . -—. ..-..-...-._

4-1 300056

• Participation in Rl/FS Brainstorming Session• Preparation of Project Work Plan (WP) "

(fled)• Preparation of Project Operations Plan (POP)• Development of ARARs• Development of Data Quality Objectives (DQOs)

4.1.1 Site Reconnaissance ______. . : . ......... _.,r _ . : .. ,

On April 7,1988, a site re"c6nhaissance=was conducted at the C&R Battery Site to familiarize theproject team with the .site layout. The following were performed in preparation for the sitereconnaissance: " ~1J. - ._,. i-_-^- ---~_— _^. _..„.--:, . . . . . . . . .

• Interim Health and Safety Plan• Collection of data pertinent to the Work Plan and its review

A detailed description of the findings of the reconnaissance is presented in the trip report includedinAppendixB. .... _"-,-_ ., '."_-= r,- ...._ - ^^= ..-=__:-— -

4.1.2 Collect and Evaluate Data

EPA Region.!!!..file..material ..was received, on March25,198_8. .During the site reconnaissance,conversations with representatives of the Virginia Department of Health revealed that additionalsite-specific data were available in their files. Revievy of the available site-specific data as well asregional geologic and hydrogeologic data provided the basis for development of this Work Plan.

4.1.3 Brainstorminq Activities _ . ..,.-.

On April 15,1988, a project braihstorming meeting was conducted. Representatives of EPARegion Hi and NUS attended this meeting. The .technical scope of work was discussed and thegeneral scope of activities was established.

4.1.4 Preparation of Work Plan _ _._.... _._.__...,.„

This report, the Work Plan for the C&R Battery Site Rl/FS, presents the technical scope, schedule, andbudget for the Rl/FS. . . -- . . . . . . . . . . " . . .

nnn^u U U 0

4.1.5 Preparation of Project Operations Plan (POP)—— ——————————————————————— - .

(Red)The Project Operations Plan (POP), includes sampling'and analytical objectives; the number, type,and location of all samples to be collected during the field investigation; the site-specific qualityassurance requirements (which will" be in accordance with the Quality Assurance Project Plan for theARCS III program); and detaiie_d_procedures for field >ct!vftie_$. Appended to the POP is the Healthand Safety Plan (HASP). . . . . . ,.-.:,,,

The HASP includes site-specific information oh health and safety requirements, a hazard assessment,training Tec^uiremen.ts"/monitoring procedures for site operations, safety and disposal procedures,and other requirements in accordance with the"HASP developed for the ARCS Ml Program.

Task 1 will be completed with the approval of the Work Plan and the POP.

4.2 TASK 2-COMMUNITY RELATIONS

The Community Relations "task consists of three separate subtasks: the Community Relations Plan(CRP) preparation, public meetings, and community relations implementation.

4.2.1 Community Relations Plan

The C&R Battery Site.draft CRP was submitted May 19, 1988.

4.2.2 Public Meetings . __ . ~_ ..'

NUS will assist in_the planning and presentation of public meetings and the preparation of publicmeeting summaries. Two public meetings are budgeted at this time. The first meeting is scheduledto be held after preparation of the Work Plan but before the start of field activities. A second publicmeeting is planned to be held after completion of the Rl/FS. The need for additional public meetingsis not anticipated atthistime. " - . _ . . . . ..'.,

300058

4.2.3 Community Relations ImplementationOR(Redj

NUS will provide the following supportduring the Rl/FS:

• Preparation of one fact sheet . "• Preparation of and arrangements for placement of a newspaper public meeting notice• Update of the. CRP following the Record of Decision

The level of participation in=comrrTuWrty relations activities will be determined by EPA, as the project, progresses, and may include activities other than those noted (at EPA's request).i

j 4.3 TASKS-RETOiNVESTlGATION

* TheField Investigation task of. the. Rl .consists of six.subtas_ksas.shpyvni below:

• 4.3.1 Procurement of Subcontractors| • 4.3.2 Mobilization/Demobilization

• 4.3.3 Environmental Survey• 4.3.4 Hydrogeologic Investigation• 4.3.5 Media Sampling " ' • "" V _"_ '

(1) Groundwater Investigation(2) Buried Battery Investigation(3) Surface and Subsurface Soil Investigation(4) Surface Water and Sediment Investigation(5) Debris Pile Investigation ,. " . .

• 4.3.6 Site Survey/Topographic Mapping

4.3.1 Procurement of Subcontractors ___ . __

Under this subtask, bid specifications will be prepared and subcontractors will be procured forspecific Rl activities. The objective of these activities.is to develop and place bid solicitations at theearliest possible date for subcontractors required to start the Rl activities. The subcontracts that willbe prepared as part of the initial tasks identified at this time are:

4-4 300059

• A drilling and monitoring-wel! installation and development specification, (,-.j.

• Vendor specifications for the conduct of bench- and piiot-scale treatability studies. Aswork progresses on the R!, specifications for the described vendors will be developed, asdiscussed in Section 4.7, which describes Task 7.

4.3.2 Mobilization/Demobilization____

This subtask will consist of field personnel orientation (NUS and subcontractor personnel) andequipment mobilization, and will "be^erformed at the initiation of each phase of field activities, asnecessary. A field team orientation meeting will be held to familiarize NUS and subcontractorpersonnel with the site history, health and safety requirements, and field procedures.

Equipment mdbilization/demobiiization may include,, but will not be limited to, the setup andremoval of the following equipment: "" ~" -., ;

• Survey " " " ;"" " " "" '_• Field office.trailer (command post)• Drilling subcontractor equipment : .• Sampling equipment . .• Health and safety and decontaminatio'h equipment handling• Utility hook-ups r. ..._ . . _..• Warning signs posted on fence (eight signs total)

4.3.3 Environmentaijurvey ...... .__ ...__.

As part of the initial site investigation, a cje~her=at environmental survey will be performed to identifythe natural resources that could be adversely affected by site contaminants. These data will be usedin conjunction with the sediment/surface water analytical.results.to determine the need for andnecessary number of bioassays. _ _ . , ~~ _~ "

Potential environmental receptors will be identified in the survey. Terrestrial and aquatic flora andfauna will be identified, and a literature search will be performed to define any food chain(s). Sitehabitats, including floodplains and wetlands, will be identified, as well as the dominant speciesobserved or known to inhabit.such areas. The evaluation of potential environmental risks (i.e., thepotential for direct and" indirect .(bioaccumulation) toxic effects) will be presented in the riskassessment section of the Rl Report. ~ -= — --=-- -= - --

4-5 300060

4.3.4 Hvdroqeoloqic Investigation . ...._.. ...

The primary purpose .of the hydrogeorogic investigation is to "determine whether contaminationfrom the C&R Battery Site is presentTh"fhe~g round water In addition, information concerning thegeology and .aquifer characteristics of the vadose zone and the upper portion of the phreatic zonewill be collected and interpreted for the. study area included in the Rl/FS. Also, two onsitemonitortrTg~welfs and the bnslte office wei! wLM be properly plugged and abandoned to eliminatethe potential for groundwater contamination via. the two monitoring wells due to improperconstruction, or the onsite office well as a result of cracks in the"concrete casing. The hydrogeologicinvestigation consists of the following activities:

• Plug and abandon two existing monitoring wells due to improper construction

• Plug and^abandqn the=_on.site off ice well _.... _...._.. .....__. .. r .

• Drill and install four monitoring welTs

One'upgradient monitoring wellThree, downgradient monitoring wells

• Collect approximately 16 undisturbed samples of various cohesive lithotogies of thevadose zone for analysis of the foiiowing physical parameters:

Grainsize -, _ : _ . . _ . . . ;_ : j..- .-.,....,. .,--..

Atterberg limits . " ~ -PermeabilitySoil moisture " " ' ""."Unitweight . . ... " . :~Specific gravity

._....... 300064-6

• Collect two rounds of groundwater sampling as follows:

- -Collect one.round _o_f .samples from the four monitoring wells for CLP-SAS quick.turnaround lead analysis and for CLP-SAS and RAS chemical analysis of the otheranalytes (refer to Table 4-2). . . . ... -

Collect one round of samples from the four monitoring wells and two residential wellsfor CLP-SAS and RAS chemical analysis (refer to Table 4-2).

• Install a staff gauge in the James River.

• Perform rising-head slug tests on the four newly instajled wells

• Obtain two rounds oT water-level measurements at each monitoring well and at the staffgauge. .=_..*„=„--T-=T — - .-..-= -• - •- ----^-^------ --- •

• Install continuous water level recorders on the four monitoring wells.

Two monitoring wells were installed within the boundary during a previous environmental study atthe C&RBattery Site, by the .operator's consultants. Both wells were improperly constructedaccording to state and federal protocols. These two wells were constructed without emplacing 1 to2 foot thick clay seals above the grave! pack surrounding the screened interval. Also, the remainingannular space was backfilled with drill cuttings rather than cement/bentonite grout for both wells.As a result, the annular space of the two wells are potential conduits for contaminated surface waterto migrate directly to the groundwater. Therefore, the 2-ihch diameter PVC riser pipes and screen, aswell as the backfilled material within the original annular space of these two monitoring wells, shallbe milled out and removed with oversized augers (minimum 8-inch O.D.) using the hollow stemauger drilling method. Both of the newly drilled soi! borings shall be backfilled by lowering a tremiepipe inside the augers to.the bottom of each boring. A cement/bentonite grout shall then bepumped into the boring concurrently with the auger removal until the grout fills each boring to theground surface. -This procedure should eliminate the potential for contaminated surface waterrunoff migrating along the annular space of the two improperly constructed monitoring wells andinto the groundwater. A total of 60 feet of drilling is budgeted for the plugging and abandonmentof thesetwo monitoring wells. . .- - - .- ... -. --

The onsite office.well is descrfbed in the FIT Site Investigation (NUS, February 1986) as a 36-inchdiameter concrete-cased well which extends approximately to 30feet below ground surface.. -

3000624-7

According to personnel at the VaSWCB, the concrete casing is badly cracked resulting in open noles.As a resu.it, this well is a potential conduit for contaminated surface water to enter the well throughcracks or holes in the casing and migrate directly to the .groundwater. Therefore, this well will bebackfilled with grout from bottom to ground, surface, as discussed earlier, to eliminate the potentialfor surface water contaminant migration within this well. Any casing currently extending above theground surface will be removed prior to backfilling.

Rationale for the location of each of the four monitoring wells are fisted in_Tab!e4-1 and is discussedbelow. The location of each" ofthe four monitoring wells is shown on Figure 4-1.

• Monitoring "well MW1-1 is located west of the southern boundary of the site. It isanticipated that the location of this__well will be upgradient of the site based on theposition "of the James River which is located north and east of the site. The primarypurpose, for this well location is to obtain chemical analytical data to determinebackground.soil and groundwater .quality at the C&R Battery Site. Soil samples shall be .collected at discrete intervals for CLP-SAS and RAS chemical analyses as discussed inSection"4..3,4. .In addition, an attempt will be made to collect an undisturbed sample(3-inch O.D., thin-walled Shelby tube)' of each distinct cohesive lithologic unitencountered during the drilling. Approximately 4 undisturbed soi! samples shall becollected and analyzed for the previously listed physical parameters. These data arenecessary to evaluate the potential for contaminant migration in the vadose zone,through the use. of.a.model.such as.RITZ.. Slug testing will be conducted at this well toestablish, genera! characteristics, of .the uncQ.nf_ine_d__ water table aquifer beneath theC&R Battery Site. .-Also, since monitoring well MW1-1 is assumed to be upgradient ofthesite, it will be used as an upgradient control point for groundwater elevation data for usein calculating the groundwater flow direction beneath the site. .

• Monitoring'wel! MW2-1 is situated in^the anticipated downgradient direction from the.former acid pond area (F.e., to the north/northeast). The primary reason for thismonitoring well is to coil.ect;.che_mical data from groundwater to identify the presence ofcontamination, and from soil to determine whether suspected contamination exists and to"identify a vertical contaminant profile, if prese_nt (refer to 5ection4.3.4 for details of soi!sampling). Also, monitoring well"MW2-1 will serve as a control point of groundwaterelevation for determining the direction :of groundwater flow. Efforts will be made tocollect an undisturbed sample from each distinct cohesive lithologic unit encountered(approximately4) during the drilling, and analyzed for various parameters previouslymentioned which are necessary to evaluate the potential for contaminant migration

300063. ... .4-8

TABLE 4-1 ,n ,tejCRITERIA FOR PLACEMENT OF MONITORING WELLS FOR

C&R BATTERY SITE

MW1-1

MW2-1

MW3-1

MW4-1

D

2)

3)

4)

D

2)

3)

4)

D

2)

3)

4)

D

2)

3)

4)

Background chemical data for soil and groundwater.

Upgradient elevation control point for determination of groundwater flowdirection. "_ ._...._. " - - - - - - -- ;-— _

Data collection of physical properties for:Vadose zone evaluation for contaminant migrationImpact on remedial technologies . . . . . .

Control point for aquifer characteristics of the upper portion of the water table..Chemical data for soi! and groundwater downgradient of suspected contaminantarea (acid pond).

Data collection of physical parameters for:Vadose zone evaluation for contaminant migrationImpact on remedial technologies . . _ .

Anticipated downgradient elevation control point for determination ofgroundwater flow direction.

Control point for characteristics ofthe upper portion ofthe water table.Chemical data for groundwater downgradient of suspected contaminant area (leadextraction operations area).

Data collection of physical parameters for:Vadose zone evaluation for contaminant migration

- Impact on remedial technologies

Anticipated downgradient. elevation control point for determination ofgroundwater flow directions. - - =

Control point for aquifer characteristics of the upper portion of the water table.Chemical data for soil and groundwater downgradient of suspected contaminantarea (lead extraction operations area).

Data collection of physical parameters for:Vadose zone evaluation for contaminant migration

- - Impact on remedial technologies .. _ _ ..

Anticipated downgradient elevation control point for determination ofgroundwater flow directions.

Control point for aquifer characteristics of the upper portion of the water table.

3000614-9

ooc

< EoQ rcLUHCOLLXO

< _co ena >-UJ crco LUo0-oa<CD£TCOO

through the vadose zone,.__Slug testing will be performed to gather information on the

general hydrogeologic characteristics of the jjnconfined water table aquifer. /^ ,,

• Monitoring wells MW3-1 and MW4-1 are both situated downgradient of the former leadextraction operations relative to the anticipated groundwater flow direction(s) to thenorth and northeast, respectively. No samples for chemical analysis will be collected fromthe soil boring for monitor!ng^welI MW.3-1 since it is off site and no soil contamination isexpected. Otherwise, the various rationale for these two monitoring wells are similar tothose explained for MW2-1 in the previous paragraph.

Each monitoring well shall be screened immediately below the water table. The water table isapproximately 40 feet below ground surface based on data from .an onsite monitoring well. Exactscreening "lengths and .depths will be determined in the field based on observedgeologi.c/hydrocjeologic., conditions. Tidal,and.seasonal, .fluctuations shalj be considered whenemplacirig the well screens. Well screens will not be placed across lithologic boundaries or installedinto sediments which are considered to exhibit low permeability.

Rising head slug tests will be performed in monitoring wells installed in the unconsolidated alluvialaquifer. The data generated from the slug tests will yield hydraulic.conductivity values which will beused to develop groundwater velocity estimates in the unconsolidated alluvium aquifer.

During the field investigation, o.h "s"faTf_c _aug erWili_be instaljed in_the James River nearest the site.The staff gauge .will provide-information "to help define, local surface water/groundwaterinteractions. \ " \ ~ . "" . _...."_ ""777I"~M~""r7-.=~.""-" "'! ..."""/ ,...._ II.."."

Two comprehensive rouhds'of water level measurements will be taken in the four newly-installedmonitoring wells and at the James River staff gauge. All measurements for each collection roundshall be taken within a 24-hour penbd of consistent weather to minimize atmospheric/precipitationeffects.on groundwater conditions! These water levels wijl be used to determine groundwater flowdirections arid hydraulic gradients, and will ultimately be used, as input data for potentiometricsurface maps, hydrogeologic cross sections..and groundwater velocity calculations.

Continuous' water level recorders will be installed at each of the four newly - installed monitoringwells to obtain data regarding the "potential influence of tides on groundwater within the studyarea. A minimum of one week of continuous data will be obtained from each of the wells.

4-11 30005$

The Work Plan schedules 8 days for drilling, installing, developing, and (Round 1) sampling/tpproposed monitoring wells. The budget is based on drilling and Installation of approximately200 linear feet of 2-inch diameter Schedule40 PVC riser pipe" arid screen. The planned drillingmethod is hollow stem augering using a minimjjrh of 6-inch outer diameter augers.

Three of the four monitoring weils begin as deep test borings for the subsurface soil samplingprogram. As a result, these three borings shall be sampled continuously for chemical analysis to adepth of 12 feet (which will be later dis'cussed in Section 4.3.4)7 Therefore, a second soil boringadjacent to these three, test borings will be necessary to assure collection ofthe undisturbed (Shelbytube) sample for physical property analysis. An additional 40 feet of drilling is budgeted to allow forthis additional drilling. Discussions concerning the groundwater sampling program may be found inSection 4.3.4, Media Sampling. .' .. _ •• : . . ""'""

4.3.5 Media Sampling .____...,._..._. ..__.. ., .._.._. - - - .

Groundwater Investigation

Following the installation of each monitoring well, a groundwater sample will be individuallycollected and sent for CLP/SAS quick-turnaround analysis for lead. In addition, these groundwatersamples will be sent for CLP-SAS and RAS analysis for the following analytes Crefer to Table 4-2):

• TAL inorganics (filtered and unfiltered)• Alkalinity

• Acidity• TSS - —- - -----.-------- — - " —• TDS - . - - . - . . - - - - - _v-

• Sulfate. _.."_-.. _ •-.--.'.....:.-._._..._.-i..:..-l" - :;" " --".— - - . - --

The results from the quick-turnaround lead analysis on groundwater samples will provide the basisfor determining "whether.additional monitoring wells will be necessary for the hydrogeologicinvestigation. " . _. ....... ..,_-.._.._,.-."""__ .:__ . .:.-, ....._.,-__.......—.-.

The_ field investigation may be expanded by adding additional monitoring wells if above-background concentrations of lead are detected in groundwater.collected in one or more of thethree downgradient .monitoring wells. The number, location, and depth of screening of additionalwells will be determined during the field activities based on quick-turnaround analytical results of

300067

TABLE 4-2(Red) "

PROPOSED GROUNDWATER SAMPLING AND ANALYSIS PROGRAMC&R BATTERY SITE

SamplingEvent

I

111fi11I

I

I

IIIIII11111!

II

N

II

1!

Numberof

Samples

8

84

4

44

4

44 .

4

4

12

6666 "666 "

6

6

FieldDuplicates

2

2

00001111

1

210000111

1

RinsateBlanks

0

00000000

0

0

00000000

0

0

AnalysesRequired

Lead*

TAL Inorganics*PHEhTemperatureConductivity "AlkalinityAciditySulfate .Total SuspendedSolidsTotal DissolvedSolidsTAL Inorganics*SulfatePHEhTemperatureConductivityAlkalinityAcidityTotal SuspendedSolidsTotal DissolvedSolids

Source ofAnalysis

CLP-SAS QuickTurnaroundCLP-RASField AnalysisField AnalysisField AnalysisField AnalysisCLP-SAS

CLP-SASCLP-SAS

CLP-SAS

CLP-SAS

CLP-RAS

CLP-SAS

Field AnalysisField AnalysisField AnalysisField AnalysisCLP-SASCLP-SAS

CLP-SAS

CLP-SAS

AnalyticalOption

IV

IVIII1

I I II I II I I

I I I

i l l

IVMl1111

1 1 1111

111

in* Include filtered and unfiftered samples. . .... .. -Sampling Event II includes one residential and one bus! ness well.

^ -:--,=-:• , 3000664-13

lead concentration in the groundwater as determined by the NUS Project Manager and theRPM. A scope increase and budget modification wiM "be necessary"for additional monitoring wells.

A second round of groundwater sampling will be conducted following the completion of the drillingand installation ofthe monitoring wells at the C&R Battery Site, In addition, a residential well and abusiness well will also be sampled during this groundwater sampling event. The business well isowned by Capitol Oil and is located to the east and adjacent to the C&R Battery Site. The residentialwell is owned by Mr. Shopsmith and is located north of the site. Figure 4-2 shows the location ofthese two wells to be sampled. The second round of groundwater samples will be sent for CLP-SASand RAS analysis for the following analytes (refer to Table 4-2):

• TAL inorganics (filtered.a.n.d unfiltered)• Alkalinity """ -: - - - . - . . . . . .

• Acidity ". ". " ... i "... Vr~ ,. -••:•-:• -- - h ""..;." ..".• TSS - . - -____- -• TDS• Sulfate . ...... il. .==.•....;..-,._ .= : . ::., .../;, . .. .

Field measurements to betaken on all monitoring wells during both sampling tours include:

• Eh• pH ....._.....-.__..__.. ...___._.._.._ . ..._..._..__ ._ ..

• Specific Conductance . .• Temperature" - ......_. _: ..... _ .. . .._._... . ... .=..."-.

Table 4-2 summarizes the groundwater sampling and analysis program for the C&R Battery Site,

Surface and Subsurface Soil Investigation

Contaminated soils at the C&R Battery Site are suspected of being the primary source ofenvironmental contamination. Recent emergency remecfiaT actions"consisted of disking and limingthe soil over most ofthe site to a depth of approximately 2 feet. This act of homogenization is likelyto preclude identification of former operational areas or ponds based purely on analytical results.Therefore, that aspect of the Rl may rely heavily on information gained from regulatory personnelwho are familiar with thesite. .,_,. . ......__...- .. .. _:..

4-14 300069

SHOOSM1TH PROPERTY

CAPITAL OIL PROPERTY!

BASE MAP IS A PORTION OF THE USGS 7.5 MINUTE DREWRYS BLUFF,VIRGINIA QUADRANGLE, 1969 PHOTO-REVISED 1980. CONTOUR INTERVAL 10 FEET.

PROPOSED DOMESTIC WELL FIGURE 4-2SAMPLING LOCATIONS

C & R BATTERY SITE, CHESTERFIELD CO., VA' CORF CRATON

4-15

NUS300G70

A total of 27 test borings are to be dri.lied to obtain.soil, samples. The locations of these borings areshown on Figure 4-1. It is planned that seven deep borings"(to a depth of about 40 feet, or 1$ thewater table) will be drilled first. ..Soil samples will be collected from these borings for sejtf SSf'purposes... .= -----—^.———. -=-- - . - - .=•=--• - . ± -- -.-. - - -. — --.. .

• To determine whether contaminants have migrated downward and reached the watertable.. . . _ - - , . - - . . = - : . . . _ . , . . .

• To direct the installation of subsequent borings, particularly with respect to depth.• To assist m estimating the configuration ang1 volume.of contaminated soil.• To develop a better understanding of siteJithofogy..• To determine appropriate remediaT responses.

Ten samples will be collected for CLP analysis from each of seven deep soil borings at the followingintervals: ... . __ _._.. _ . . . . . . 'i.' _ ... _ ..-' .:__-_..--,- - .._._.

• 0- 1.5feet " . . :. ~.-\-r:". : r.------^ - - -

• 3.0-4.5 feet : . - - ~- -v . ".. .-• 6.0-7.5 feet ~ "= .... " " .i:. . -'.• 9.0-10=.5feet .. ". ." . ..:-_iv .=-:... ----------• 13.5-15.0feet - . . .fc .• 20.0-21.Sfeet - - " ... .- "~ ... -• 25.0 - 26,5 feet : . ____ .• 30.0 -31,5 feet• 35.0-36.5 feet . -,1,• 40.0-41.Sfeet - - - - - -~---:_- - :: - - --- .

The background boring west ofthe. site .a I ong Bellwood Road will not be sampled at the surfaceinterval. There is a possibility that lead deposited from auto exhaust emissions along the road couldbias the results. Therefore, background surface soil samples (0 to 6 inch depth) will be collected fromthe woodlands on either side of thesite"''.- :•'.. . ' . . 2 = r

Intermediate samples (e.g., 1.5-3.0"feet) will also be collected from the deep borings. These 70samples (and 2 background samples) will be analyzed by XRF in the field for lead. The timely receiptof the analytical result's for these 72samples will be used to help determine the depths of theremaining 20borings. _ ' _ ....... ._ .... _. __ ._._._. .___" ._"_ ._.....__ ..._._ . . _

300C7J

At the present time, the remaining 20 borings are piannecTto terminate at a depth of approximately15 feet Five samples will be collected for CLP analysis in each of these borings at the intervals \iabove to a depth of 15 feet. "....". . . ", '.,". - ". " " . " ""- '..'. "". -

The boring locations were selected based on a staggered grid system of approximately 50 feet (east-west) by 75 feet (north-south).... This pattern attributed to a relatively thorough coverage of the siteand a reasonable likelihood of encountering former operational areas. The locations ofthe deepborings were selected "based on severalf actors:

• The possibility of conversion to monitoring wells• Defining vertical contamination in the known acid pond area• Providing relatively even coverage.of the site to the water table.

The soil samples collected from the 27 borings will be analyzed for a specific set of parameters, theselection of which was based on known activities at the site, general battery chemistry, contaminanttransport mechanisms, and the results of previous sampling programs. Selected analytes are asfollows:

• TAL inorganics " . . . . . . . .."• p H - - . _ . - . . . . . .

• Alkalinity : " - - _ . . . - :• Acidity "" " ": --..-.- - ........ —... __..._ . . . . . . . . . .

• Cation exchange capacity• Sulfate - _ . - . . - , .• Geotechnical parameters• EP toxicity. (TO samples) (metals only)

Table 4-3 summarizes "the soil sampling and analysis program for the C&R Battery Site.. In order tocollect enough sample .material for the geotechnicaL analyses, there is a provision made forcontingency borings located adjacent to the wells.

Collection of the 10 proposed EP toxicity samples may be performed during test pit operations if itbecomes impractical to obtain an adequate volume of material required for proper analysis from testborings during drilling operations, . . _ " . _ . ... . .__ ._. ... . .....

4.

TABLE 4-3. . . - • - • -.-.

PROPOSED SOIL SAMPLING AND ANALYSIS PROGRAMC&R BATTERY SITE " '

Numberof

Samples

72(D

171(2)

171(2)171(2)

171(2)

171(2)

171(2)

10(3)

16(4)

FieldDuplicates

4

9999

9

9

1

0

RinsateBlanks

4

9000

0

0

0

0

Analyses Required

Lead

TAL InorganicspHAlkalinityAcidity

Cation ExchangeCapacity

SulfateEP toxicity (metalsonly)Moisture_ContentUnit Weight -Grain SizeAtterberg LimitsPermeabilitySpecific "Gravity

Source of Analysis

Field Analysis-X-RayFluorescenceCLP-RASCLP-SASCLP-SAS

CLP-SAS

CLP-SAS

CLP-SAS

CLP-SAS

CLP-SAS

AnalyticalOption

II

IVHI

i l l

III

Ml

II!

m

111

0) Ten samples from severj deep borings (70 sarrtplesj plus two background samples.(2) Ten'samples from six deep borings (60 samples), nine samples from one deep boring,

five samples from 20 shallow borings (100>amples), two background samples, -(3) Five samples from 6' to 2' depth, five samples from 2' to__4'. Samples to be collected

from test pits"/~~~L._ ..".'." '=-'.-.. .^-~.=L^_..=.T. i_.=-:_;; :.:..,,-._._ .-W Four samples from'four deep borings.

300G734-18

Drill cuttings from borings within the site fence will be raked into the soil in the vicinity'of eachboring. Drill cuttings from borings outside the site fence will.be. brought on site and placed on theground in an area to be designated by the EPA, " ' .

Buried Battery Investigation

A second aspect of this sampling effort will entail using a backhoe with an operator and one helperto search for buried, intact batteries in the northern portion ofthe site. This investigation will focuson the area beyond that which was disked and limed by EPA in 1986.

Batteries are known to be buried in at feast one location. The backhoe will be used to excavateshallow trenches in small increments searching for the batteries... The site geologist will determinethe depths .of test pits, based on field observations. .The test pits shall be excavated to a depth atwhich batteries are~"noTo~riger encountered or until undisturbed native overburden material/ soil ispenetrated. -Ten samples are planned to be collected for EP toxicity analysis. The approximatenumber and extent of buried batteries will be noted for the evaluation of remedial alternatives.

Surface Water and Sediment Investigation

There.are limited data available on lead in sediments and surface water from the onsite drainageditch. Exact sampling locations and sample handling methods are not known. Sampling and analysisare planned for these media to determine the downstream extent of contamination and whetherthe food chain js"6r maybe affected by the site. .Because the ditch contains no permanent water, it isintended that sampling be conducted after a rainstorm, if at all possible. This method of sampling isnecessary to collect adequate information to" conduct a public health and environmental riskassessment, as well as to evaluate, suitable remedial alternatives for the drainage ditch.

Proposed surface water (if the ditch.contains'water at the time of sampling) and sediment samplinglocations are shown in Figure 4-1.. Upstream samples are planned for both the east and westtributaries to.the site drainage ditch in order to evaluate input from offsite areas (e.g., lead fromautomobile exhaust emission). A surface water sample is planned for the confluence area of thedrainage ditch, one for the area immediately below the most recent acid ponds, and two moresamples along the site boundary. Between the site property boundary and the James River, oneadditional sample is planned. At the ditch's confluence with the James River, two samples will becollected (one upstream and one slightly downstream of the mouth of the ditch (refer toFigure 4-1)). It is important that all sediment samples be collected in areas of deposition (e.g., behindthe rip rap dams or in the river where the flow slackens and fine sediments are deposited). Gravel

4-19 30GC74

matrices are not suitable. In addition, three sediment samples will be tested for EP toxicity.Proposed sample locations are upstream of, at, and downstream ofthe known process area. rfp^

*v$t

In order to expedite a decision on whether bioassays are^ needed at this site, separate sedimentsamples will be collected early and analyzed in the field .by X-ray fluorescence. The criteria for thebioassays follow. __ ... ; _ . . _ . . . _ . . .

Sediment samples will be analyzed by CLP-SAS and RAS methodologies for the followingparameters: . - .

• TAL inorganics . '_ _, _ „ . "VILI1 ,__ _11L 1 "• pH (field analysis)" _ ... ~ ~ . . . .• Eh (field analysis)• Alkalinity """"" :. -—•----_ _'_'=~.'~^=^~ _"^~"• Acidity _.. ~; ;•••—-- - -• ••_— •

• Sulfate. ._... r ._.._ _. _ = . . . . . . .• Cation exchange capacity " '"• Moisture content and grain size.• Total organic carbon• Volatile residue• EP Toxicity (3 samples) (metals only)

Sediment (and water) samples "may also, be collected for elutriate bioassay analyses to be performedunder Tasks. NUS will collect, package, and ship samples to the bioassay laboratory from fourlocations. . _ . . . . _ _ =.. _ . . _ _ . _ , _ .._ ...._.._-_. ..:.....__._.__...:.

Surface water samples will be analyzed for the following parameters:

• TAL inorganics ;;_ .. , ," . —. . ,~ a, "...• Sulfate .. _ ._ . " .7 " " 1".". . .T. " .• pH (field arialysis)• Eh (field analysis)• Temperature (field analysis)• Dissolved oxygen (field analysis).• Conductivity (field analysis)"• Hardness ... . , . . _ . . , , :- ... - . - . . . .• Alkalinity ~ ~ ""~. ~ "": rT" --^--^ — •

4-20

• .Acidity " Of-... __ ... ,__.... . . . . . . .• Total dissolved solids . . . . . .• Total suspended solids .

These analyses are required to evaluate the extent of contamination and the environmental orhuman health risks. Levels Ml and IV analyses are required to achieve these objectives. Table 4-4summarizes the proposed surface water and sediment investigation.

Debris Pile Investigation

There are no data available on the chemical content of the two debris piles on site. ._There is anindication, however, that the larger pile contains soil and battery casing material removed from thearea east.of the ditch during the EPA emergency action. The soil_material in the two piles will besampled during thejieldjny_estiga_tj.on to determine what risks they present and how they should behandled during the site remediation. " . .

It is proposed that three soil debris samples be collected from the larger debris pile and one soildebris sample be collected from the smaller pile (refer to Figure 4-1). The soil.debris samples will beanalyzed for the following parameters: """ """"" " " .

• TAL inorganics .... "7 " 1. "".. .. "._:..:.: ,"_._ "._.;""-~ .." . "._• p H - . - . - = - _ . .

• Alkalinity• Acidity """ " "" "~~- " " " -— -- ...-—- _• Su!fate_. . . -. _,.,_. ...:•. . .=_._,_:_ .._.__::_- .. •—_ ..,,• Cation exchange capacity "• Grainsize ".'L_l ..".""' ."_" _~..'" _.: ~_7:.!._""..!- ...7 .__""._./.'._." . .• EP toxicity (one composite from each pile) (metals only)

Table 4-5 summarizes the debris pile sampling and analysis program for the C&R Battery Site.

Bioassays

Sediment and surface water samples will be collected and an environmental survey will beperformed early in the field investigation so that the need for bioassays. may be determined. If it isdemonstrated that lead or other metals have moved off site or if onsite receptors are actuallyidentified, then bioassays wilt be performed.

• - • -....•'. .300C76

TABLE 4-4 ' v,ftttf

PROPOSED SURFACE WATER AND SEDIMENT SAMPLING AND ANALYSIS PROGRAMC&R BATTERY SITE

SEDIMENTNumber ofSamples

9

9

9

9999

9

9

99

3

FieldDuplicates

1

1

1

1111

1

1

11

1

RinsateBlanks

0

1

0

0000

0

0

10

0

Analyses Required

Lead

TAL Inorganics ..

pH

EhAlkalinityAciditySulfate . _Cation ExchangeCapacityMoisture Content,Grain Size' . "TOCVolatile ResidueEP toxicity (metalsonly)

Source of Analysis

Field Analysis-X-RayFluorescenceCLP-RASCLP-SAS/FieldAnalysisField analysisCLP-SASCLP-SASCLP-SAS

CLP-SAS

CLP-SAS

CLP-SASCLP-SAS

CLP-SAS

AnalyticalOption

II

IV

III

1I I I1 1 1MI

1 1 1

mII!Ml

111

SURFACE WATER

Includes both filtered and unfiltered samples

189999999

9

21111111

1

000

00000

0

TAL Inorganics*SulfatepH.Eh

HardnessAlkalinityAcidityTSSTDSDissolved oxygen,temperature,conductivity"

CLP-RAS

CLP-SAS

Field AnalysisCLP-SAS

CLP-SAS

CLP-SASCLP-SAS

CLP-SAS

Field analysis

IVI I II

1 1 1i l lMlMlI I I

.. I

4_22

TABLE 4-5

DEBRIS PILE SAMPLING AND ANALYSIS PROGRAMC&R BATTERY SITE

Number ofSamples

4444 -4

4 --

4

2

FieldDuplicates

11111

1

0

1

• FieldBlanks

10000

0

0

0

Analyses Required

TAL inorganicspHAlkalinityAciditySulfateCation Exchange.Capacity

Grain SizeEP Toxicity (metalsonly)

Source ofAnalysis

CLP-RAS

CLP-SAS

CLP-SAS

CLP-SASCLP-SAS

CLP-SAS

CLP-SAS

CLP-SAS

AnalyticalOption

IVI I II I I1 1 1Ml

1 1 1

1 1 1

IN

It

300C784-23 - --.. . ,—. -,

At this time, sediment elutriate bioassays wi.l! be performed for four locations - one near the knownprocess area, one downstream in the ditch behind a rip-rap dam, and two in the James River(upstream and downstream of the ditch discharge)...The Fathead Minnow Embryo-Larval Survivaland Teratogenicity Test and the Ceriodaphnia Survival and Reproduction Test will be performed on

sediment elutriates,. The results of these, bioassays will be interpreted in light ofthe site ecosystem.Potential environmental impacts based on the test results will be presented in the Risk Assessment(Task 6).

4.3.6 Site Survey/Topographic Mapping

The C&R Battery Site Rl/FS will require surveying services, establishment of property lines, and thepreparation o"f a" topographic map of the study area.. The surveying services will include theestablishment of ground control topographic mapping and property lines, as well as the surveying ofhorizontal locations and vertical elevations of all monitoring wells and soil borings.

The surveying activities and subsequent topographic mapping ofthe study area will consist of thefollowing tasks: _. . _ _ _. .._

• Establish control for preparation of a topographic map. Vertical and horizontal controlpoints existing near the site, which are tied to the Virginia State Plane Coordinate System,

will be used. If the needed control points cannot be located or are encountered in adisturbed state, two benchmarks will be installed by surveying from the closest USC&GS (orequivalent) benchmarks. The 1929 MSL datum will be used as reference for verticalelevation (To be performed by EPA's Environmental Monitoring Systems Laboratory).

• Perform an aerial topographic survey that encompasses the study area (To be performedby EPA's Environmental Monitoring Systems Laboratory).

• Prepare a topographic map of the study area (To be performed by EPA's EnvironmentalMonitoring Systems Laboratory).

• Perform a field survey to establish property lines and corners and reconcile the deed to theactual field conditions. . . . .

3000794-24

• Survey the horizontal |pcation_and vertical elevation ofthe ground surface, tne uncappedwell riser, and the top of the protective casing of each of the four monitoring wells to beinstalled during this.investigation. ;

, -../ :.i &'-

• Survey the horizontal locations and ground surface elevations of all the soil borings andtest pits being placed within the site during the field investigation.

Costs for performing this subtask incl ude only those associated with the last three items listed above.

4.4 TASK 4 - SAMPLE ANALYSIS AND DATA VALIDATION

4.4.1 Field Instrument Analysis . _._..,....__..„. _...,. _

Field instrument analysis will include specific conductance, pH, Eh, dissolved oxygen, temperaturereadings. The rationale and application for these analyses is provided in Section 3.5.

4.4,2 Laboratory Analysis

Analysis of samples collected during the '"&RBattery Site investigation will be performed inaccordance with the.approach established in subsections3.5and3.6and discussed in detail in variousparts of Section 3..0.as a part of the proposed sampling and analysis activities. Sample analyses aresummarize'd in Tables 4-2 through 4-5. The majority of analyses wilj be performed by EPA's NationalContract Laboratory Program (CLP). The POP provides additional details and data quality objectivesand field as well as laboratory QA/QC requirements.

4.4.3 Quality Control and Data Validation

Quality control during sample analysis is described by EPA's CLP-COP and C1P. Quality control for allother aspects of this task will be in accordance with.the ARCS Ml Quality Assurance Program Plan.

Validation of measurements ifa'sysfematic process"of reviewincj a; body of data to provide assurancethat these results are adequate for their intended use. The process includes the following activities:

• Auditing measurement system calibration and calibration verification.• Auditing cfuality control activities.. ...• Screening data sets for outliers.• Reviewing "data for technical,credibility versus the sample site setting;

4"25 300080

• Auditing field sample data records and chain-of-custody.• Checking intermediate calculations,. _. , • • (,'k• Certifying the previous process. . „_,. _ .'. __., . . „ . " . .• NUS will perform these tasks following receipt of the "data" from the laboratories. -

The validation will be done by chemists not associated with the laboratory and will adhere to thelatest applicable EPA Region III validation protocols, . . . . . . . .

4.5 TASK 5 - DATA EVALUATION

Data evaluation will be initiated upon receipt of data from the field investigation (Task 3) and aftersample analysis/data validation (Task4) is completed. Data will be compared to project objectivesand summarized into a usable, form at f or data manipulation. Tables will be created to exhibit data,contaminant levels will be plotted on site maps, and groundwater contour maps and geologic crosssections will be developed.- Contaminant "receptors" will be identified, contaminant migrationpathways refined, and contaminant migration tools will be tuned and calibrated to meet site-specificcharacteristics." The results of this task will be used in the risk assessment (Task6) and in theevaluation of remedial alternatives (Tasks 7,8,9, and 10).

The specific subtasks of data evaluation are summarized below

• Evaluate surface and subsurface soil analytical data ••• -- -

• Evaluate.surface water and sediment data

• Evaluate bioassay test results ancTenvironrnental.survey information

• Calculate contaminant loadings to the groundwater from the vadose zone for estimatingcontaminant transport, using a vadose zone model such as RITZ

• Evaluate hydrogeologic data .Evaluate groundwater.analytical dataPrepare water-table contour mapEvaluate aquifer testing results

- - Calculate surface-water seepage rates . . . . . . :- Prepare hydrogeologic cross sections _ "_-~7\ .

4-26 30008)

This task will also include an assessment of whether additional investigation is required for the riskassessment and evaluation of remedial.alternatives, .Following a preliminary assessment of the fieldinvestigation findings, a meeting will be held between USEPA Region 111 and NUS to evaluate theneed for additional"investTgatToh'7 If it is" 'determined that additional site investigation orlaboratory/bench-scale studies.are required, a Technical Direction Memorandum (TDM) will beprepared. The TDM will be used to document completion of the first phase of the Rl and will providea mechanism for changing the authorized ceiling with respect to the obligated funding level for thework assignment (if necessary). Accompanying the TDM will be a revision to the Work Plandocumenting the scoping, scheduling, and budgeting requirements of the proposed subsequentphase., if required. .- - -.._-_ -. _._...= . -,-_-_ . _--._. . _"_.-".. . . , -

4.6 TASK 6-RISK ASSESSMENT

This task includes work efforts related to conducting the assessment of .risks to the human health andthe environment under the no-action scenario. An assessment will be performed that identifies thethreats to public health or the. environment that maybe posed by the C&R Battery Site. Componentsof this assessment include hazard Identification, dose-response evaluation, exposure assessment, andrisk characterization. ". ~ " _ . . _ . _ . . " . ".. "7.

The environmental assessment shall include a discussion ofthe potential for direct and indirect (i.e.,bioaccumulation) toxic effects..based on a" literature.review for the species identified on site. Actualsediment and surface water analytical results will also be used to assess potential environmentalimpacts of actual site conditions. The results of bioassays (if performed) will be included in theenvironmental assessment. . .. . v ..: . ..: \;:: ._ • -.-~...~- _ir::_-X-:.;" . :...':

Also included in this task (to be conducted concurrently with Task 10) will be the risk assessment forthe remedial alternatives evaluated during the feasibility study,.

4.7 TASK 7 - TREATABIL1TY STUDY/PILOTTESTING

Concurrently with data evaluation, bench- and pilot-scale studies will be performed on selectedsource-control technologies. ............ _ _ _ _ _ ... . _ . _ _ _ _ ...

4-27 3Q008&

f >Potential treatment techniques include; . . . . . . . . . _ . . .. . . ,f-'fa;

• So!idificatioh/Fixation"-"to"be"pefformed by a subcontractor to NUS• Soil Washing" (acid, EDTA) -to be performed by__EPA's..Office of Research and Development

In addition, the need for testing "additional technologies beyond those already identified will bere-evaluated during Task 9. Other app.ropriatetests may also be identified.

The process of implementing this task involves two steps, in the first step, NUS will:

• Develop specifications for vendors for performing bench-scale treatability studies.. Costsfor preparing specTficatibrTsTor sblidificatioh/fixatioh'.and soil washing have been included"in this Work Plan. .. :.:.

• Evaluate the bids received, recommend vendors, and develop cost estimates forimplementing these bench-scale studies. . . . . . ..^

• Provide EPA cost estimates of implementing the trea'tability studies and prepare anamendment to the work plan (as required). Preliminary costs for solidification/fixationtreatabiiity studies have been included in this Work Plan. Costs also include 1 week ofoversight activities at the site. .

Under the second step of this task, NUS will:

• Manage the implementation of the.bench-scale studies.

• Recommend technologies to be evaluated under field pilot studies (if necessary), based onthe results of their performance evaluation.

• Field pilot studies work plan/spedficatiorT preparation and vendor submittai (may be

different from bench scale testing vendors). Review vendor bids.

• Notify vendors of their selection to participate in field pilotstudies.

• Manage the implementation ofthe pilot-scale field studies.

300083

..->,• Obtain results of field studies and evaluate vendors for their technical and engineering"''

•""->?.performance to meet cleanup objectives... '..

• Prepare an evaluation document delineating candidate technologies suitable to meet thecleanup objective for the .site considering health, environmental, engineering, andeconomic factors. This document will provide a summary of costs and treatments achievedfor each of the technologies evaluated.

For costing purposes, it has been assumed that one technology will proceed through bench-scaletesting. .7 _'"" ; ".;_.._ .. ..: . 7 ... "...

4.8 TASK 8 - REMEDIAL INVESTIGATION (Rl) REPORT

The Rl report will summarize the data collected and the conclusions drawn from the investigationand will include the following information:

• An updated site..description."• Topographic and property maps.• Subsurface investigation results. .. " ..• Permeability testing results... . ... ....• Chemical analysis results.• Results_of the risk assessment. _.._...• Treatability study/piiot-scale testing results (as available, depending on the schedule for

these tasks). . . . . . . . . . ...

Project status meetings are scheduled foMowing EPA review ofthe R! report.

4.9 TASK 9 - REMEDIAL ALTERNATIVES SCREENING

The objective of this task is to refine""the range of response actions developed during the scopingprocess (Task 1). The alternatives will be screened using a defined set. of criteria. Only thosealternatives, which pass the initial screening process will undergo full evaluation.

This task will start upon approval of the final Work Plan. The results of this task will provide the basisfor recommending treatability studies/pilot testing. The subtasks comprising Task 9 will accomplisht h e following objectives: . ..... " " " . " _ - - , - - -

4-29 . . 300084

.• Development of remedial response objectives and General Response Actions. ,' •-.,• . .

^__ iffy,--.' -• Identification"^applicable technologies and assembly of alternatives. ^'• Screening of .remedial technologies/alternatives, including recommendations for

bench/pilottesting. ... • .- - . •

4.9.1 Development of-Remedial Response Objectives and Response Actions

Based on the data collected in the Rl, the remedial response objectives will be developed more fully.Specific response objectives will be developed using a risk-based methodology to define cleanuplevels that would reduce- risks to public health and the environment to acceptable levels (thisincludes ARARs considerations). Potential contaminant migration pathways, exposure pathways,and ARARs identified in the Risk Assessment will be examined further as a basis for estimatingacceptable onsite.-resiciual contamination levels. Acceptable exposure levels for potential receptorswill be. identified and onsite cleanup levels will then be estimated by extrapolating from receptorpoints back to source areas along "critical migration pathways. Development of response objectiveswill also include .refinement of ARARs specific to the C&R Battery Site. .

4.9.2 Identification of Applicable Technologies and Assembly of Alternatives

Based on the remedial response objectives, a list of applicable technologies will be identified. Thetechnologies list will contain those "previously identified in Section 3.4. After potential remedialtechnologies have been selected, operable units will be defined for each site condition requiringremediation. Each operable unit should meet at least one response objective.

After operable units .have been defined, remedial alternatives will be identified. Each remedial•alternative will be an overall site remedy. The no-action alternative will be considered a baselineagainst which the other alternatives can be evaluated.

CERCLA, as amended by SARA, states that, to the maximum extent practicable, remedial actions thatutilize permanent solutions and alternative treatment technologies, or resource recoverytechnologies must _be selected. Therefore, remedial actions that use these technologies willspecifically be considered for Task7. To the extent possible, treatment options will range fromalternatives that eliminate the need for long-term management at the site to alternatives involvingtreatments.that would reduce toxicity, mobility, and volume as a principal goal.

4-30 300085

4.9.3 Screening of Remedial Technologies/Alternatives

The lists of technologies and alternatives developed will be screened. The objective of this effort isto eliminate from further consideration any technologies and alternatives that are undesirableregarding implementabilify, effectiveness, and cost The list of alternatives being considered will benarrowed by eliminating the following types of technologies.

• Technologies/alternatives that are not implementable or technically inapplicable.

• Technologies/alternatives that.are not efje.ctive_because they have adverse environmentalimpacts, do not provide adequate protection of public health, or do not attain ARARs.

• Technologies/alternatives which are more costly than other .alternatives/technologies butdo not provide .greater environmental or public health benefits, reliability, or a morepermanent.._so!uti.on_ Costs", will" hot be used to discriminate between treatmenttechnologies and nontreatment technologies.

Reasons for elimination..of any alternative at this stage wil! be documented in the FS report.

A meeting with EPA'.will be hefcTfoilowing NUS'"screen ing of remedial technologies/alternatives toobtain EPA's input to the screening process. - .. -

4.10 TASK 10-REMEDIAL ALTERNATIVES EVALUATION

Remedial alternatives that pass the initial screening process (Task.9) will be further evaluated andcompared, as required in the NCP and in CERCLA, as amended by SARA. Criteria used in evaluatingthe remedial alternatives wili be those nine established in OSWER Directive 9355.0-21, approvedJuly 24, 1987, which include. _ ... _.. . . .__ -_-,_.._.__- .

• Compliance with ARARs. ___ ~~ ~ "=___"_ 77 .... _!__. . 77 7• Reduction of Mobility, Toxicity,' or Volume." . ...• Short-term Effectiveness. "7 . ' , . - . " 7. 7'. . .,- ,• Long-term Effect!veness'and Permanence. . 7. ~ ..• Implementability.• Cost; . : . " - .7 " . " " - - - - , .""* ., r• Community Acceptance. . ..._= .., _. .... = . . - =.„_.. .._. ., --_,. .

300086- , . • ' " . . : r_ 4-31 " ... 7., " =:7-7- .

• State Acceptance. . - •-.-•. .•= . = ••:-. :. • -.-~ ——-=—.—..— - . . - . - - '}.-...

^ • Overall ProteictLon of Human Health and the Environment.., •"'" ../, ''*•t ...

To the extent possible, remedial alternatives that use permanent'solutionsand alternative treatment1 technologies wil! b e considered. ...... . . - _ - _ _ = , .- -.-- -. ..,.. ..,. . . . . . .

Compliance with ARARs ... ._..„.._. .... ;._. _ ....... ___,.

Alternatives will be assessed as to whether they attain legally applicable or relevant and appropriate1 _ " •requirements or other Federal and State environmental and public health laws, including, as

appropriate; -HI" ..._._.-_ "_ .."••"— ._. ._- _ rr -•

• Contaminant-specific ARARs ""(e.g., MCLs, NAAQS). " _• Location-specific ARARs (e.g., restrict ions, on actiohs'a't historic preservation sites).• Action-specific ARARs (e.g., RtRA requirements for 'incineration and closure).

Reduction of Toxicity, Mobility, or Volume__

The deg/ee to which alternatives employ treatment that reduces toxicity, mobility, or volume will beassessed. Factors that are relevant include:

• The treatment processes the remedies employ and materials they will treat.• Theamountof hazardous materialsthat will be destroyed or treated.• The degree of expected reduction in toxicity, mobility, or volume.• The degree to which the treatment is.irreversible. . . .• The residuals that will remain foil owing treatment.

Short-term Effectiveness . _.,._._.... ...... ,_--.,._. -

The short-term effectiveness of alternatives will be assessed considering appropriate factors amongthefollowing: " ------.- ._ ,., . . --_=. - .

• Magnitude of reduction of existing risks.• Short-term risks that might be posed to the community, workers, or the environment

during implementation of an alternative. . , ..,• .... .• Time until full protectionls achieved. .. . ._..-

300087

Long-term Effectiveness and Permanence.

Alternatives will be assessed for thejong-term effectiyeness_and permanence they afford along withthe degree of certainty that the remedy.wil I prove successful. Factors to be considered are:

• Magnitude of residual.ris]<sjn terms of amountsand concentrations of waste remainingfollowing implementation of a remedial action.

• Type and degree of long-term management required, including monitoring andoperation and maintenance'.' " .'. '" ""' . ~ '. " .

• Potential for exposure of human and environmental receptors to remaining waste..

• Long-term reliability ofthe engineering and institutional controls, including uncertaintiesassociated with land disposal of untreated wastes and residuals.

• Potential need for replacement of the remedy.

Implementability _ ...

The ease or difficulty of implementing the alternatives shall be assessed by considering the followingtypes of factors; :.... . .. ._._ ..L__:_ ..____..-".. ". __"..7"~ ...._......

• Degree.of difficulty associated with constructing the technology.• Expected operational reliability of the technologies. :. . .• Need to coordinate with .and.obtain necessary approvals and permits (e.g., NPDES, Dredge

and Fill Permits for bffsfte actions) from other offices and agencies.• Availability of necessary equipment and specialists.• Available capacity and location of needed treatment, storage, and disposal services.• Need to respond toother sites (§104 actions only).

Cost

The types of costs that wil I be assessedlnclude the following: .

• Capital costs. .-~.--._.....__.- . ~ -. _. .. ._/ __..._.._._:.-.._.• Operation and maintenance costs. . . ;. ..

3000884-33 - - - - - - -

• Costs of 5-year reviews, where required.• Net present value of capital and O&M costs.• Potential future remedial action costs. .

For each alternative, the cost will be estimated within a range of -30 percent to +• 50 percent. Thecost analysis will include separate evaluation of capital and operation and maintenance costs.Capital costs will consist of short-term installation costs such as engineering/design fees, materialsand equipment, construction, and offsite treatment or disposal. Operation and maintenance costswill consist of long-term costs associated with operating and monitoring the remedial actions.Capital and annual operation and maintenance costs will be based on the anticipated time necessaryfor the alternative to achieve cleanup criteria, ......... . ._..__ _.....

A discount rate of 10 percent will be assumed for all present-worth calculations. Cost estimates willbe prepared using data-from project files, the current EPA.Remedial Action Costing ProceduresManual, USEPA technical reports, and quotations from equipment vendors. Equipment replacementcosts will be included when the required performance period exceeds equipment design life.

Community Acceptance ___ .,__._._._.-___ ._,.,„.__,_

Early readings of community acceptance of and preferences among the alternatives will depend onthe degree and type of community involvement in a "project during the Rl/FS process. This assessmentwill attempt to look at: • • ~

• Components ofthe alternatives_that the community supports.• Features of the alternatives for which, the community has reservations.• Elements of the alternatives that the community strongly opposes,

State Acceptance __. __. __... ._„. . ,. ..._.. ... ...

It may be appropriate toconsider incorporating the state's concerns into the evaluation with regardto: -- - - -; = - - - - • ,---,.-—-.--!"--= ._...= - ,-.~* ._= _ ..... .

• Components of the alternatives the state supports.• Features ofthe alternatives for which the. State has reservations.• Elements ofthe alternatives under consideration that the state strongly opposes.

o4-34 "- .. : -'

Overall Protection of Human Health and the Environment ..,.__;;. ". __ . ' ' .....

Following the analysis of remedial options against individual evaluation criteria, the alternatives wil!

be assessed from the standpoint of whetherthey provide adequate protection of human health andthe environment considering the multiple criteria. .._

4.11 TASK 11 - FEASIBILITY STUDY REPORT

Task 11 will consist of the following subtasks:

• Summarize each" alternative'in termsoTthe nine criteria mentioned above, ._ .• Compare the remedial alternatives, "".:."." "._. " = _-r_7

• Prepare the FS report. "• -7"'7 . :-_-...•.:"-" .."__ 7: :: _i_=: _:"!.• _..

The FS report for the C&R Battery Site will include an executive summary, an introduction, a

description"of the technologies considered, the. screening and evaluation process, a summary ofthedetailed technical and cost evaluations, and a comparative evaluation of the remedial alternatives.This summary will be presented as table matrices. Backup information and calculations will beincluded as appendices. ,- ..... ...._—-.. .. .7" _""—_.;._ . ..._r ==._...7 _"77.. . "

If Task 12 is requested as a component of the Rl/FS, the final FS report will include a responsivenesssummary and the selected remedy.

4.12 TASK 12 - POST-R1/FS SUPPORT

NUS wil! provide support to EPA for any requested assistance in activities that occur after theC&R Battery Site Rl/FS is completed"." Currently the scope and budget of this task is limited topreparation of a responsiveness.summary7ROD support, and project closeout. Additional scope andbudget.requirements for this effort, if needed, will be determined in meetings with EPA after theRl/FS report is approved and'follow-up actions are. "identified. Additional support may includecommunity relations beyond that defined Jn Section 4"72 and assistance in preparing the Record ofDecision or Responsiveness Summary.

..-.- -.-.. 3000904-35 . . . . . " . ... ' ' . .

4.13 TASK 13-ENFORCEMENT SUPPORT*c.

This task shall include efforts during the. JWFS.asspciated with enforcement actions.in support of civilcomplaints against C&R Battery. Activities may include:

• Review of Responsible Party documents.• Attendance at negotiation meetings!• Preparation of'briefing materials. "" " " . " "" "~

Because of the tentative nature of the task requirements, scope and cost wil! be provided as requiredduring the Rl/FS process. Currently this task is not budgeted in the cost estimate.

4.14 TASK 14- MISCELLANEOUS SUPPORT

The objective""6f this task is to perform work associated with the C&R Battery Site project that is insupport of the Rl/FS scope of work but that is not considered a routi ne part of the Rl/FS.

Miscellaneous support for the project will be determined in project status meetings and will beimplemented as additional scope under this task.

4.15 TASK 15 - ERA PLANNING

This task is to be used specifically for planning expedited response actions (ERAs). At this time, thereare no plans to implement an ERA for this site. Currently this task is not budgeted in the costestimate.. - -,- .__-.=,, _..__—. ~ .L:_ . _ . _ _ _ . . ; ... .... . . . . . . .

'" " 800094-36

300092

5.0 PROJECT MANAGEMENT APPROACH

>*5.1 ORGANIZATION AND APPROACH

The proposed project organization for the C&R Battery Site Rl/FS is shown in Figure 5-1. The ProgramManager, Mr. Arthur K. Bomberger, is. responsible for the quality of all ARCS work performed inRegion III. Mr. Richard M. Ninesteel will serve as the Project Manager (PM). The PM has primaryresponsibility for implementing aTTd executing the Ri/FS. .Supporting thePM are the Field OperationsLeader (FOL) and other technical support staff. The FOLis responsible for the onsite management ofactivities for the duration ofthe site investigation. ... " _

The Rl/FS tasks included in this Work. Plan, in addition to the schedule and budget, compose thebaseline plans. These plans form an integrated management information system against whichwork assignment progress can be measured. -The baseline plans are a precise description of how thework assignment wiM be executed in terms of scqpe,schedule_,_and_budget The project schedule ispresented in Section 5,3, - -.. ., ._., :..":. 7=,- ..-- V. - ,.-..-".—-"" ~7.,--: . - -

5.2 QUALITY ASSURANCE AND DATA MANAGEMENT

The site-specific" quality "assurance requirements will be in accordance with the .Quality AssuranceProject Plan (QAPjP) for the ARCS Ml Program, as approved by EPA. The QAPjP is part of the ProjectOperations Plan for the C&R Battery Site. ..The ARCS Ml QAPjP provides general guidance on the

following subjects: v._ ; ,„...-:;:, . ,. " ". , . ...-._. w, : ' f., ,

• Project organization and responsibility.• QA objectives for_.measurement of data in terms of precision, accuracy, representativeness,

completeness, and comparability. ~ ~ ~

Data management aspects of the program pertain to controlling and filing documents. NUS hasdeveloped a program filing system that conforms to the requirements, of EPA and the ARCS 111Program to ensure that.the integrity of the., documents .safeguarded. This guideline will beimplemented to control and file all documents associated with the C&R Battery Site Rl/FS. The systemincludes document receipt .control procedures, a ftie review and inspection system, and securitymeasuresto be followed. - .=. ...__ ...... ' - . . . , . _

3000935-1 "

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300094

5.3 PROJECT SCHEDULE

Figure 5-2 depicts the schedule of tasks and activities for the C&R Battery Site Rl/FS. The schedule forthe field investigation assume! that no site restrictions wili be encountered and is dependent uponEPA approval of this Work Plan and the POP as indicated.

5.4 PROJECT COSTS

An Optional Form 60 (OF 60) with detailed cost back-up has been submitted under separate cover.

. .-3000955-3

3)m*nm00m

REFERENCESftfltf)"

Caiver, J.L, 1973. Geologic Studies, Coastal Plain of-.Virginia: Bulletin 83 (Parts 1 and 2)Commonwealth of Virginia, Department of Conservation and Economic Development, Division ofMineral Resources. .. . _: ____.._. ._... . ......

Cowherd, C., Jr., G. E. Muleski, P. J. Englehart, and D. A. Gillette, September 1984. Rapid Assessment .of Exposure tQ.PartiCjulate.Emissions from Surface Contamination Sites. .Midwest Research Institute,Kansas City, Missouri. "~ ........ ""i-~" .~.T_~7~ ""__ "~~.~. "" " ~"

Gough, L. P., H. T. Shacklette, and A. A. Case, 1979. Eleme.nt Concentrations Toxic to Plants. Animals,and Man. U.S. Geological Survey Bulletin 1466. _____ _.

Hawley, J.K., 1985. "Assessment of Health Risk from Exposure to Contaminated Soil". Risk Analysis,Vol. 5, No. 4. -. -..,__ -,- ,_.=_.. ,.-..- --,_..._ .,..,..-, -. „.., .. : __._. ..

LaGoy, P. K., 1987. "Estimated Soil Ingestion Rates for_Use in Risk Assessment." Risk Analysis. Vol. 7,no. 3, pp. 355-359. ..._...... _ .::. ... _ ,_ . . ;.. ,., .___.. _ . . _

Meng, Andrew A., and John F. Harsh, 1984. Hydrogeoiogic Framework ofthe Virginia Coastal Plain.U.S. Geological Survey, Open File Report84-728.

NUS Corporation, February 24,1986. - Site inspection of C&R Battery. Prepared under TDDNo. F3-8503-29, EPA No. VA-281, Contract No. 68-01-6699 for the Hazardous Site Contract Division,U.S. Environmental Protection Agency. _ . . " . . .

Prugh, B,J., F. J. Eastern, and. D..D. Lynch, 1986. Water Resources-Data, Virginia. Water Year 1985.Water Data Report VA-85-1, U.S. Geological Survey, Richmond, Virginia.

Sayre and Associates, December 1983. Geotecbnjcal Study of the C&R Battery Company.Chesterfield, County, Vi"rgTniaT"~"~ - - . -.- "--,..-__,.. .. _- .:.L . ._. "

Shackiette, H. T., and J. G. Boerngen, 1984. Element Concentrations in Soils and Other SurficialMaterials of the Conterminous United States. .Professional Paper 1270, U.S. Geological Survey.

R-1 300098

I

United States Department of Agriculture, 1974. Soil Survey of Chesterfield County, VirqiConservation Service. "r.71. ^ ; ;:L, ;: i..__-=Li.._==_ji_:.i.; :__:'; ;;• "..: :._ :. . ." .: ~ =

USEPA (U.S. Environmental Protection Agency), November 28,1980. "Water Quality CriteriaDocuments; Availability." 45 Federal Register 231. 7931 Set seq.

USEPA (U.S. Environmental Protection Agency), February?, 1984. "Water Quality Criteria; RequestforCommehts:" 49 Federal Register 26,4551 et seq.

USEPA (U.S. Environmental Protection Agency), November 13,1985. "National Primary DrinkingWater Regulations; Synthetic Organic "Chemicals, Inorganic Chemicals, and Microorganisms."50 Federal Register 219, 46936et seq. _-..... ~"_ _ . . . /..--.___

USEPA (U.S. Environmental Protection Agency), October 1986.. Superfund Public Health Evaluation

Manual. EpA5_4pn_8_5-Q60..__ -"-.. - V __.,_..:.!. ;...."' ~ '~ " =

USEPA (U,S. Environmental Protection Agency), November 16,1987. Memorandum from Sandra Lee,Program Manager, Subject: Updated Reference Dose and Cancer Potency Number for Use in RiskAssessments, Office of Solid Waste and Emergency Response.

Wentworth, C. K., 1930. Sand and Gravel Resources, of the Coastal Plain of Virginia. Bulletin 32,Virginia Geological Survey.

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APPENDIX A

APPLICABLE OR RELEVANT ANDAPPROPRIATE REQUIREMENTS (ARARs)

C&R BATTERY SITE

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)

This appendix presents brief descriptions of the Federal and state ARARs identified for theC&R Battery Site.: The identified ARARs will be refined and revised, at a later date, to consider siteconditions and potential remedial actions, as the Rl/FS process develops.

Federal ARARs include the following:

• Safe Drinking Water' Act "- The Safe.Drinkinq~Water Act promulgated National PrimaryDrinking Water Standard Maximum .Contaminant Levels (MCLs). MCLs are enforceablestandards for contaminants in public drinking water supply systems. They not onlyconsider health factors, bufalso the economic and technical feasibility of removing acontaminant from a water supply "system. ...EPA has also recently proposed MaximumContaminant Level Goals (MCLGs) for several, organic and inorganic compounds indrinking water, MCLGs are non-enforceable guidelines that do not consider the technicalfeasibility of contaminant removal

• Clean Water Act (PL92-50Q as amended by the Federal Water Pollution Control ActAmendments)- Governs point-source djscharge through the National Pollutant DischargeElimihatio"n~System (NP.DES), discharge of dredge or fill materials, and oil and hazardousspills to U.S. waters. Ambient Wafer Quality Criteria" (AWQC) were developed for64 pollutants in 1980 (45CFRPart231) pursuant to Section 304(a) (1) of the Clean WaterAct,- In 1983, EPA revised nine criteria previously published in the "Red Book" (QualityCriteria for Water, 1976) and in the 1980 .criteria documents. Subsequent updates in theFederal Register and the "Gold=Bppk" ha.ye been published. These criteria are not legallyenforceable, but have been used by many states to develop enforceable water qualitystandards. AWQC a re "available for the protection of human health from exposure tocontaminants iri drinking water, from ingestion of aquatic biota, and for the protection offreshwater and saltwater aquatic life. . .. .-. -

• Clean Air Act of 1967- Governs ajc rnissions resujting from remedial .actions. The CleanAir Act promulgated the National Ambient Air Quality Standards (NAAQS)(40 CFR Part 50). NAAQS are available for six chemicals or groups of chemicals and forairborne particulates. The sources of the contaminant and the route of exposure wereconsidered in the formulation of the Standards, but the costs of achievement and the

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feasibility of implementation were not considered. The NAAQS allow for a margin ofsafety to account for unidentified hazards and effects.

• Health Effects. Assessments (HEAs)- HE As present toxicity data for specific chemicals foruse in public health assessments. Also considered applicable are Carcinogenic PotencyFactors and Reference Doses provided in the Superfund Public Health Evaluation Manual(USEPA, October, 1986, as amended by OS WE R. November 16, 1987).

• USEPA HeaitbLAdvi series - Health Advisories are non-enforceable guidelines, developed bythe EPA Office of Drinking Water, for chemicals that may be intermittently encountered inpublic water supply systems. Health Advisories are available for short term, longer-term,and lifetime exposures for a 10kg child and/or a 70 kg adult.

• Federal Floodpiain Executive Qrdej; .11958- Provides for considerations of floodplainsduring remedial actions. This Executive Order is to be considered as implemented by EPA'sAugust 6, 1985 .Policy on Floodplains and Wetlands Assessments for CERCLA actions(CERCLA Compliance Policy). .; _. "

• Fish and Wildlife Coordination Act 06 U5C661). Fish and Wildlife Improvement Act of1978 (16 USC 742a). and Fish and Wildlife Corise'rvation Act of 1980 (16 USC 2901) - Providefor consideration of the impact on wildlife habitats.

• The Flood Disaster Protection Act and the National Flood Insurance Act (24CFR1909)-Require" the purchase of flood insuranceTbeTore federal funds are spent for projects withina special flood hazard area in a community participating in the National Flood InsuranceProgram. Coverage^must.cohtrnue~throijghout_the useful life ofthe project.

• Groundwater Protection Strategy- EPA's policy is to protect groundwater for its highestpresent or potential beneficial use. This policy will be incorporated into future regulatoryamendments. The strategy designates three categories of groundwater:

Class 1 - Special Groundwaters- Waters that are highly vulnerable to contaminationand are either irreplaceable or ecologically vital sources of drinking water.

Class 2 - Current and Potential Sources of Drinking Water and Waters Having OtherBeneficial Uses -Waters that are currently used or" that, are" potentially available.

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Class 3 - Groundwater Not a Potential Source of Drinking Water and ofeBeneficial Use- Class 3 groundwater units are further subdivided into two subclasses.

-- Subclass 3A includes groundwater units that are highly to intermediatelyinterconnected to adjacent groundwater units of a higher class and/or surfacewaters. They may, as a result, be contributing to the degradation of the adjacentwaters, . They may be managed at a similar level as Class2 groundwaters,depending upon the potential for producing adverse effects on the quality ofadjacent waters. . " _ . . "

- Subclass3B is restricted to groundwater units characterized by a low degree ofinter-connection to" "adjacent surface waters or other groundwater units of ahigher ciass, within the Classification Review Area. These groundwaters arenaturally isolated from sources of drinking waters .in such a way that there is littlepotential for producing adverse effects on quality. They have low resource valuesoutside of mining or waste disposal. . ... ....

• Resource Conservatiori"and Recovery Act (RCRA) of 1976 (Amended 1984)- Governs thegeneration, transportation, storage, and disposal of hazardous wastes. RCRA 40 CFRPart264 standards are used for remedial actions that include offsite hauling and disposalof hazardous wastes, onsite capping and landfilling, and post-remediation groundwatermonitoring. . L . . . . . . ". . _ _ . : . . ,._.__"=_,_:._

• OSHA Requirements .(29.CFR Parts 1910, 1926, and 1904) - OSHA regulations provideoccupational safety and health requirements applicable to workers engaged in onsitefield activities."! ."Threshold Limit Values (TLVs) refer to airborne concentrations ofsubstances and represent conditions, under which it is believed, that workers may berepeatedly exposed without adverse effect. .TLVs are based on the best availableinformation from industrial'experience and experimental studies. These ARARs are thejurisdiction ofthe onsite health and safety officer.

• DOT Rules for Hazardous .Materials Transport (49 CFR, Parts 107.. 171.1 -171.500) -.Regulate the transport, of hazardous waste materials including packaging, shipperequipment, and placarding, These requirements are considered applicable to any wastesshipped offsite for laboratory analysis, treatment, or disposal.

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- .- , ,.__,..State ARARs include the tollowing: . • - :- -_-—•-• - - - ,._ -^fit j

* Virginia Air PolIjutlon. Control Regulations - Cpntrpl_a|r emissions by industry. Paniculateemission rate's"are" bas'ed on the"process rate. Also govern fugitive dust and visibleemissionsWd require continuous monitoring.

, • Virginia WateTQualitv Standards - Surface water quality criteria are set for each portion ofj each drainage basin, based on protection of aquatic biota.

I • Virginia Hazardous Wa'ste'Facility Siting Criteria - Siting" criteria for various categories ofwaste treatment/storage/disposai facilities. Requires a number of related permits and

| reviews for compliance with Federal and state regulations.

j • Virginia Hazardous" Waste "Mana'qernent Regulations - Control all .hazardous wastes* generated .within _o_r.transported to the State for purposes of storage, treatment, or^ disposal. Establish a cradie-to-gravemanagement.system. Similar to RCRA.

• Virginia Solid Waste Regulations - Govern construction and. operation permits for landfills,incinerators, new and unique treatment methods, and construction debris.

• Virginia Erosion and.. Sedimentation Control Handbook - Presents specific criteria formanagement of erosion and sedimentation during remediation activities that includeexcavation. " ~ • . . " " " : " . :

• Laws _of VirgTriia"!__Relatinq to Subaqueous Lands, Wetlands.and Coastal Primary SandDunes_- Regulates activities in wetlands and coastal areas throughout the state where localgovernments have_no requirements. ~ ......

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APPENDIX B

TRIP REPORT

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IMUSC-34-4-8-128

TRIP REPORT* C &~R BATTERY SITE

APRIL 7, 1988

NUS PROJECT NUMBER 9851

TO: RICH HINESTEEL

FROH: RICK BETHEL

DATE: APRIL 18, 1988

I." INTRODUCTION

A site reconnaissance was conducted at the C&R Battery Site, April 7, 1988, aspart of the NUS work assignment for a Remedial Investigation/Feasibility Study(Rl/FS) at this site. The participants arrived at the site at approximately10:50 a.m. and left the site at approximately 12:45 p.m. The following peopleparticipated in the site reconnaissance:

Paul Leonard - EPA Region IIIJim Adams - VA Department of Waste ManagementRichard Ninesteel - NUSArt Bomberger - NUSRick Bethel - NUS

Following the site reconnaissance, the participants visited the regional andcentral offices of the State Water Control Board in Richmond, Virginia toreview file material.

II. OBJECTIVES . " • " ""

The objectives of the site reconnaissance were to familiarize the project teamwith the site and surrounding areas.

III. OBSERVATIONS

The equipment used for the previous operation is no longer at the site. Theground surface has been leveled. There was shallow ponded water in surfacedepressions throughout the site as a result of a recent rain event. Thesurface" soil consists of soil mixed with lime and plastic shards from shreddedbattery casings. The southern portion of the site has very sparse grassyvegetation which increases toward the northern end. The site is surroundedby a 6-foot high cyclone fence with a locked entrance gate at the south endnearest Bellwood Road. Also, larger pieces of battery cases were noted in thenorthern portion of the site.

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TRIP REPORT °*tf//,C * R BATTERY SITEAPRIL 18, 1988 - PAGE TWO

Approximately 350 nickel cadmium batteries are stacked on a wooden pallet nearthe southeast corner of the site. Most of the batteries were still Intact,although a few of the casings were cracked. Also, a large mound of apparentsurface soil mixed with various debris, Including battery casings, is locatedapproximately 30 feet north of the stacked batteries. This mound 1sapproximately 8 feet high and covers an approximate area of 20 feet by 40feet. A second debris pile consisting of apparent surface soil mixed withmetal, tires, and battery casings 1s located along the west fenceline in thecentral portion of the site.

Just north of the second debris pile 1s a concrete slab with a mounted controlpanel which was apparently associated with incoming electrical lines. Apartially buried concrete pad Is located approximately 300 feet north of thesouth fenceline toward the middle of the site. The edges of the pad wereburied, therefore, the dimensions of the pad could.not be determined.

The former acid pond area Is located east of the concrete pad. This area isestimated to cover an ares of 200 feet by 100 feet along the east fenceline.There currently is no observable indication of the exact boundaries of theformer acid pond areas.

Approximately 50 feet northwest of the concrete pad Is a three-sided concretestructure which apparently is a former truck loading dock. . This structure isnow filled with soil and large boulders.

Old tires are stacked along both sides of the western fenceline and in thenortheast corner of the site, A dead tree has fallen Into the siteImmediately south of the tire pile.A six-foot deep trench runs along the entire southern and eastern siteboundary. This trench eventually leads directly into the James Riverapproximately 600 feet north of the site. There was ponded and tricklingwater in the trench as a result of a recent rain event. Approximately threeto four areas spaced apart within the trench have been filled with large rockboulders (diameter <_ I foot) for erosion control. A newly formed dike,presumably from the clay rich soil excavated from the trench, runs along theeastern site boundary. There are a couple of diversion drainage swales whichbisect this dike along the site for surface water run-off.

Two capped PVC riser pipes are located along the dike at the northeast end ofthe former acid pond area. They represent the two monitoring wells which wereInstalled by consultants to the former site operator.

Currently, there is evidence of a major construction project northeast of thesite. Approximately ten to twenty acres of land has recently been affected byexcavation and regrading of the surface soil.

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APPENDIX C

BATTERY CHEMISTRY OVERVIEW

C&R BATTERY SITE

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BATTERY CHEMISTRY OVERVIEW

C.1 GENERAL

Batteries are used throughout the United States for single use power generation (primary batteries)and for storage/multiple reuse (secondary batteries). The. primary batteries are used in manycommon applications (flash fights, etc.) and are generally disposed of after one use. ,The secondarybatteries can be discharged and recharged repeatedly. The two most common types of secondarybatteries are automotive lead-acid batteries and nickel-cadmium batteries. These secondarybatteries are frequently reclairhecT. The following sections provide additional characterization of thetwo common secondary batteries and general information for other batteries.

C.2 LEAD-ACID BATTERIES

The lead-acid battery contains a positive electrode consisting of PbO2 (lead oxide) and a negativeelectrode consisting "of Pb (lead). During the_discharge (use) of the battery, lead sulfate is formed atboth electrodes. .Separators are used to keep the plates apart and sulfuric acid is used as anelectrolyte.. Both the positive and negative lead alloy electrodes generally contain antimony at aconcentration of 2-12 percent by weight. The antimony is used to harden the lead and improve itscasting properties. Other "possible additives for the lead alloy include caicium, strontium, arsenic,tellurium, and tin. . . ___ .. . .__. . ..._........_... .,-... _ ,.

The electrodes are formed into, grids using lead oxides (with additives), sulfuric acid (40-42 percentby weight), fibers and.water,. the grids are then cured and .electrically converted into active positiveand negative electrodes in a weak (< 20 percent) sulfuric bath. For the positive plate, the lead oxidesconsist of PbO and Pb304. For the. negative plate, the lead oxide consists of only PbO, howeverexpanders such as lamp black (0.2 percent by weight), organic compounds, and barium sulfate(<3 percent by weight) are also added. . ... ,.. . L .

The separators are usually made of materials such as paper, rubber, glass, or plastic. The sulfuric acidused in the battery is of variable concentrations depending on the manufacturer.

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C.3 NICKEL-CADMIUM BATTERIES

The nickel-cadmium battery contains a positive electrode consisting of hydrated nickei oxide (NiOH2)and a negative electrode, consisting of. cadmium (Cd). During the discharge, the hydroxides of nickel(Ni(OH)2) and "cadmium. (Cd (OH)2) are formed at the electrodes, respectively. Alkaline (high pH)water containing potassium hydroxide and/or lithium hydroxide is used as an electrolyte. Nickel andcadmium compounds are apparently used in a relatively pure form in these batteries.

Nickel and cadmiunVelectrodes are generally formed using one of two methods. For the firstmethod, the metal hydroxide material is blended, admixed, or layered with an electronicallyconductive material. For the second method, the metal is deposited insitu or electrodeposited on aconducting metal sheet or fiber. .". ... ., ... .,....".

Materials of construction for nickel-cadmium batteries can also include polyethylene, polystyrene,and polypropylene. The potassium hydroxide concentration used in the battery is generally20-25 percent by weight. :. ___. _--.:.. ;;_„. _r ;=":._"..r.V ~ .: "-.,."...

C.4 OTHER BATTERIES

Numerous types of other batteries are used. For primary cells, metals consisting of zinc, manganese,copper, mercury, silver, lithium, nickel, ammonia, and rare earth materials are used. For secondarycells, metals consisting' of iron, zinc, silver, lithium, manganese, mercury, and sulfur are used.Electrolytes consistincjbf acids, alkalies, and water are commonly used.

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