W912DR18R0055_-_Attachment_AJ_-_2018_Draft_Management_Action_Plan_7.18.18REV1_clean.docx

COMMUNITY INVOLVEMENT

DRAFT

MANAGEMENT ACTION PLAN

FOR

DEFENSE SUPPLY CENTER RICHMOND

RICHMOND, VIRGINIA

Prepared For

Defense Logistics Agency

And

Defense Supply Center Richmond

July 2018

DRAFT

MANAGEMENT ACTION PLAN

FOR

DEFENSE SUPPLY CENTER RICHMOND

RICHMOND, VIRGINIA

Prepared for:

And

Prepared by:

Arcadis W912DR-13-D-0019, Delivery Order 0005

July 2018

PURPOSE

In an effort to coordinate planning information among Installation Restoration Program (IRP) managers, Department of Defense (DoD) Commands, the installation, executing agencies, and the public, this Management Action Plan (MAP) has been updated for (calendar year) 2018 for the Defense Supply Center Richmond. The purpose of the MAP is to outline the multi-year restoration program for the installation. The MAP defines the IRP requirements and proposes a comprehensive approach to conduct future investigations and remedial actions at each Operable Unit (OU) at the installation. The MAP is used to track requirements, progress towards cleanup objectives, and schedules. Under the current project schedule and projected funding, all OUs at the installation are expected to attain Remedy in Place (RIP) status by the end of FY 2021. This time frame will allow additional treatment of off-site areas at OUs 6 and 7, if needed, and to mitigate OU 8 plume off-site migration considering the complexities associated with the hydrogeologic regime at OU 8.

Defense Supply Center Richmond – Management Action Plan Contributors to the MAP – Page 4 REVIEWed by

ACRONYMS AND ABBREVIATIONS

ACRONYMS AND ABBREVIATIONS (contd)

Defense Supply Center Richmond – Management Action Plan Acronyms and Abbreviations – Page 6 summary Placed on National Priorities List (NPL) - July 1987 32 DSERTS (Defense Site Environmental Restoration Tracking System) Sites

Defense Supply Center Richmond – Management Action Plan Summary – Page 7

ACTIVE DSERTS SITES -

OUs AND SITE TYPES:

OUs 10, 11, 12 – Former Chemical Storage Buildings OU 9 – Interim Groundwater Treatment System OU 4 – Unlined chemical dumping area/fire training area OU 3 – Vehicle Maintenance Area 18 inactive DSERTS sites

and 13)

· Groundwater pump and treat system at OU 9

· Removal Action (REM)

· Soil excavation at OU 3

· Soil excavation at OU 4

· Soil excavation at OU 13

· Remedial Action (RA)

· Soil cover at OU 2

· Concrete cover and soil vapor extraction (SVE) at OU 5

· Vegetative covers at OU 10 and OU 11

· Asphalt cover at OU 12

· Low permeability soil backfill at OU 13

· Groundwater extraction and treatment for PX Gas Station

· Long-term monitoring (LTM) for soil OUs 1, 2, 3, 4, 5, 10, 11, 12, 13 and the PX Gasoline Station. Note land use controls (LUCs) for soil OUs 4 and 5 are included under OUs 7 and 8, respectively.

· LTM for all OUs

Final Deletion from the NPL: 2043 (All OUs). Deletion of specific OUs is anticipated prior to 2043.

INSTALLATION INFORMATION

LOCALE

Defense Supply Center Richmond (the installation) is located approximately 8 miles south of the city of Richmond, Virginia, along Jefferson Davis Highway. The installation consists of over 600 acres, approximately 1 mile wide (east to west) and 2 miles long (north to south). The property is roughly L-shaped, and the southeastern section currently consists of primarily administrative, operations, maintenance, housing, daycare facilities, and recreational areas (see Figure 1). The remaining areas include warehouses, open storage, and light industrial facilities. The installation’s current workforce is over 2,000 employees. The area surrounding the installation is primarily residential and woodland with a lesser proportion of commercial/light industrial property.

COMMAND ORGANIZATION

IRP EXECUTING AGENCY

· Investigation, Remedial Design and Remedial Action Phases Executing Agency: United States Army Corp of Engineers (Baltimore District)

REGULATORY PARTICIPATION

REGULATORY STATUS

· NPL Installation – 1987

· Federal Facilities Agreement (FFA) – 1990

Defense Supply Center Richmond – Management Action Plan Installation Information and Description – Page 12

INSTALLATION DESCRIPTION

Defense Supply Center Richmond is the home to DLA Aviation which supports more than 1,340 weapon systems as the U.S. military's integrated material manager for more than 1.2 million national stock number items, industrial retail supply and depot-level repairable acquisitions. In addition, DLA Aviation manages supply, storage and distribution operations alongside its military customers at Robins Air Force Base, GA; Tinker Air Force Base, OK; Hill Air Force Base, UT; Marine Corps Air Station Cherry Point, NC; Naval Air Station North Island, CA; and Naval Air Station Jacksonville, FL. DLA Aviation also manages depot-level reparable procurement operations at Robins, Tinker and Hill Air Force Bases; Navy Inventory Control Point Philadelphia; and Redstone Army Arsenal in Huntsville, AL. The aviation supply chain has personnel at over a dozen stateside sites directly supporting the warfighters. DLA Aviation also operates the federal government's only industrial plant equipment facility at Navy Inventory Control Point, Mechanicsburg, PA.

The United States government purchased the land from private owners in 1941, and construction activities began in September of that year. The installation was activated as the Richmond Quartermaster Depot on 1 January 1942, after the United States government purchased the land from private land owners in 1941. In 1943, the installation became the Richmond Armed Service Forces Depot. The Quartermaster Branch Depot was established on-site in 1949, followed by the U.S. Army General Supply Center in 1958. DLA began overseeing operations in 1962, when the installation became known as the Defense General Supply Center (DGSC). In 1996, the installation was renamed the Defense Supply Center Richmond.

Past operations at the installation have encompassed a variety of industrial operations including the following: tent, refrigerator, and parachute repair; military vehicle and equipment overhauling; automotive engine repair and rebuilding; sanitary and industrial waste treatment and disposal; helmet refurbishing; gas cylinder refurbishing and replenishing; firefighter training; and hazardous chemical storage, recoupment, and shipping.

Current missions at the installation include the following:

· Managing, controlling, storing, and distributing general military, administrative, and other supplies worldwide for DLA

· Storing industrial chemicals with no recoupment activities involved as damaged containers, if any are shipped for disposal

· Refurbishing and refilling chemical gas cylinders

· Storing and supplying operational and maintenance parts for military aircraft

· Disposing of excess inventory

· Maintaining and storing military and government vehicles

· Storing and distributing maps to DoD installations and other government agencies worldwide

· Providing professional development and training opportunities for Government supply and inventory specialists

· Maintaining the U.S. Army’s National Technical Information System for hazardous substances

· DLA Distribution Mapping - responsible for inventory and worldwide physical distribution of all maps, charts and other geodetic material for DoD, storing 85,000 map items for its military customers worldwide

INSTALLATION DESCRIPTION

DSERTS Site Descriptions and Status

Note: Numbers 001, 003, 005, 007, 016, and 035 were not used.

PROJECT TEAM

PROJECT TEAM

ROLES AND RESPONSIBILITIES

· DLA – Lead agency for remedial actions at Defense Supply Center Richmond; resource advocate; policy development; provides consultative support; decision validation and approval.

· DLA Installation Support at Richmond – Directs the installation’s daily restoration program execution (ensure costs/performance/ schedule are on target).

· USACE Baltimore District Service Center – Provide contracts for contractors and review contractor performance.

· Program Manager

· Manages budget/schedule/quality of deliverables produced by contractors.

· Provides timely funds obligation and contract execution and oversees costs/performance/ schedule as the Program Manager.

· VDEQ – Supporting regulatory agency for remedial actions at the installation.

· USEPA – Lead regulatory agency for remedial actions at the installation.

· ARCADIS

· Performs on-time, cost-effective consulting services for restoration activities.

· Meets DLA’s completion strategy for technically defensible site restoration.

Defense Supply Center Richmond – Management Action Plan Project Team – Page 14

INSTALLATION ASSESSMENT

Past industrial operations at the installation have resulted in the use, storage, management, inadvertent release, and/or disposal of hazardous materials, such as chlorinated solvents, petroleum products, and wastewater treatment sludge. Past storage operations at the installation have led to the accidental release of these and other hazardous materials, such as PAHs, pesticides, petroleum hydrocarbons, PCBs, and metals.

An initial assessment was completed in August 1981 that indicated potential soil impacts at six OUs and possible groundwater impacts at three OUs. During 1982, the U.S. Army Environmental Hygiene Agency (USAEHA) investigated the hydrogeologic setting, identified two areas of significant groundwater impacts associated with the Area 50 landfill and the former FTA, and installed monitoring wells in the vicinity of the most impacted areas. Elevated groundwater concentrations of CVOCs such as trichloroethene (TCE), tetrachloroethene (PCE), and chlorobenzenes were detected and compared to VDEQ Groundwater Quality Standards. A third possible source of groundwater impacts was determined to be the National Guard Area (NGA). Subsequent investigations showed CVOC constituents in both the upper and lower water bearing units (WBUs) east of Area 50, extending to and beyond the eastern boundary of the installation.

Initial testing of residential water wells near the installation was performed between 1982 and 1984. In 1984, chloroform was detected, but the concentration was well below the USEPA limit for drinking water. Trace amounts of 1,1,1-trichloroethane (TCA) and 1,1-dichloroethane were also detected. Monitoring wells were installed off-installation to the east of NGA. Off-installation wells were analyzed, along with the associated NGA and Area 50 monitoring wells, during subsequent investigations of the hydrogeology and the extent of potential groundwater impacts between 1985 and 1987.

Based on the results of these investigations, the installation was officially placed on the NPL in 1987 with a Hazard Ranking System score of 33.85 due to CVOCs in on-site groundwater, potential off-site migration of CVOC-contaminated groundwater, and groundwater discharge into surface water. In 1990, USEPA, VDEQ, and DGSC (now Defense Supply Center Richmond) entered into an FFA to continue monitoring the installation and to develop and implement remedial action plans. Thirteen OUs were ultimately defined for the IRP.

An RI was initiated in 1986 to characterize the nature and extent of CVOCs in soil at four OUs:

· Open Storage Area (OSA) – OU 1

· Area 50 Landfill – OU 2

· NGA – OU 3

· Former FTA – OU 4 The acid neutralization pits (ANPs – OU 5) were investigated as a possible CVOC source area.

The groundwater plumes associated with soil impacts were considered separately from the soil OUs:

· OSA/Area 50/NGA groundwater – OU 6

· Former FTA groundwater – OU 7

· ANP groundwater – OU 8 An installation-wide pesticide monitoring study completed in 1986 by USAEHA identified three additional possible areas of concern:

· Former Building 68 – OU 10

· Former Building 202 – OU 11

· Former Building 112 – OU 12 These areas were identified due to the various pesticide residues (i.e., DDT, chlordane, heptachlor, arsenic) discovered in the surface soils and storm drain sediments. In 1992, an area of PAH impacts was encountered near the FTA, which was associated with a past fuel oil release from an aboveground storage tank. This area was designated as OU 13. An IRA for OU 6, consisting of a groundwater extraction, CVOC treatment, and discharge system, began operating in 1996. This area was designated as OU 9.

In 2000, the installation began integrating RIs and Focused Feasibility Studies (FFSs) for source and groundwater OUs. RI/FFSs were conducted as part of a comprehensive, installation-wide completion strategy recognizing the interdependence of soil and groundwater impacts. This strategy involves removing or treating continuing sources of impacts, controlling migration in the environment, and limiting exposure to impacts that pose unacceptable human health or ecological risk through institutional or engineered controls. Response decisions made under this completion strategy are results-focused, with clearly defined performance expectations. DLA strives to effectively and efficiently meet its response action obligations under the Comprehensive Environmental Response Compensation and Liability Act.

Implementation of this completion strategy required an update of the installation’s Conceptual Site Model (CSM). Completed in 2006, the CSM summarizes relevant information on the nature, extent, and migration of constituents in soil and groundwater; provides a framework for cleanup programs; and serves as a foundation for risk assessments. Data gaps for the updated CSM were addressed in a supplemental FS investigation between August 2003 and April 2004. HHBRAs for each OU were subsequently revised using updated risk assessment guidance and industrial land use scenarios.

Three creeks near the installation property (Kingsland Creek, No Name Creek, and an unnamed tributary of Falling Creek) were evaluated to determine the potential impact from past on-site activities. Between 2001 and 2004, a creek monitoring study determined there were no significant impacts on habitat quality for aquatic organisms in the monitored creeks. HHBRAs were also performed on the creeks, and unacceptable cancer risk was determined for residential recreational users (waders) in each creek. However, the estimated risk was driven by infrequently detected constituents in groundwater and conservative exposure scenarios. Therefore, no further action was recommended to protect human health from potential installation impacts to the creeks.

Since the completion of the CSM, considerable progress has been achieved at the installation’s DSERTS sites. Records of Decision have been completed for OUs 2 (2008), 6 (2013), 7 (2012), 8 (2007), 10 (2007), 11 (2007), 12 (2005) and 13 (2011) and remedial action completion status has been achieved for OUs 2, 10, 11, 12 and 13. In addition, the interim remedial action (OU 9) has been decommissioned. As part of the feasibility studies at OU 6 and 7, low-cost passive groundwater treatment treatability studies were implemented in 2007. An in situ bioremediation treatability study at OU 8 was implemented in 2010 prior to full-scale application in 2013 and 2014. Full scale application was completed at OU 7 in 2013 and at OU 6 in 2015, and pressurized and gravity fed EVO injections took place at OU 6 in July 2015. These studies have shown favorable results for the treatment of the groundwater contamination at these OUs. Remedial action activities are ongoing at OUs 6, 7, and 8. In 2015, direct-push technologies were utilized to investigate the north-eastern edge of the OU 8 plume extending towards Bensley Elementary School. DLA initiated a long term pump test along the northern lobe of the OU 8 plume in 2015 and a long term pump test well int the southern lobe of the OU 8 plume in 2016. A targeted groundwater extraction and recirculation system for OU 8 was implemented successfully in 2017 to enhance biodegradation of the dissolved-phase plume beneath portions of OU-5 and Bay F of Warehouse 65 which are source areas of the OU 8 plume. Twelve new injection wells were installed in October 2017 for OU 7 in the intermediate zone followed by USACE completing an ISB injection of Lactoil (or equivalent) a blended carbon donor consisting of 35% EVO and 35% sodium lactate into 31 injection wells (12 new and 19 existing wells) from November 2017 to January 2018. Additional remedial action activities are planned for August 2018 for OU 8.

As a result of the building 65 sub-slab-depressurization system effectiveness study, modification activities to enhance the systems impact were made to Bldg 65 SSDS in 2016 to address ROI issues of the system. Additional SSDS optimization activities were completed in June 2018 to address operational deficiencies.

LUCs have been implemented at OUs 1, 2, 3, 6, 7, 8, 10, 11, 12, 13 and the PX Gas Station. These LUCs are documented in the LUC RD (AECOM, 2015). Annual inspections are conducted to verify that the LUCs are being implemented as proposed. Any deficiencies noted during the annual inspections are rectified. LUCs for OUs 4 and 5 are incorporated in the OUs 7 and 8 LUCs, respectively.

All open DSERTS sites listed under the Defense Supply Center Richmond IRP are eligible for funding. Sites that pose the greatest risk to public health (based on the Relative Risk Site Evaluation [RRSE]) are generally given priority in funding allocations. The RRSE is a qualitative tool used to group sites into low, medium, and high-risk categories based on site information and the contaminant hazard factor, the migration pathway factor, and the receptor factor. These sites are organized in the Site Descriptions section of the MAP by their DSERTS identification number but are primarily described by their OU number (1-13) or common name (PX Gas Station). RRSEs are not required at DSERTS sites classified as RIP or Response Complete (RC).

Defense Supply Center Richmond – Management Action Plan Installation Assessment – Page 17

Oct 01, PX Station LAW Engineering and Environmental Services, Inc.

Mar 02-Apr 02, OU 6 MACTEC Engineering and Consulting, Inc. (f/k/a LAW Engineering and Environmental Services, Inc.)

Mar 02-Apr 02, OU 8 MACTEC Engineering and Consulting, Inc.

Mar 02-Apr 02, OU 7 MACTEC Engineering and Consulting, Inc.

(Volume 1, Volume 2 Part 1 & Part 2, Volume 3 Part 1 & Part 2 and Volume 4) MACTEC Engineering and Consulting, Inc.

Adjacent to DSCR MACTEC Engineering and Consulting, Inc.

(Part 1 and Part 2) MACTEC Engineering and Consulting, Inc.

(Volume 1 and Volume 2) Earth Tech, Inc.

(Part 1 and Part 2)

AECOM/MACTEC

(Volume I, Volume II, Volume III)

AECOM

PX Gas Station

AECOM

Part 1, Part 2 and Part 3

AECOM

PX Gas Station

AECOM

(PFOS and PFOA)

AECOM

OU 8

AECOM

OU 8

AECOM

PREVIOUS STUDIES

Date Title Author

Defense Supply Center Richmond – Management Action Plan Previous Studies – Page 21

ER ELIGIBLE DSERTS SITES

Defense Supply Center Richmond – Management Action Plan ER Eligible DSERTS Sites – Page 32 Defense Supply CENTER RICHMOND – DSERTS Site 002 transitory shelter 202: ou 11

Defense Supply Center Richmond – Management Action Plan Site Descriptions – Page 45 Site Description Former Building 202, referred to as a Transitory Shelter (TS), was an open-front storage shed located along the western installation boundary). Formerly, the northern end of the shelter was used to store approximately 800 drums of DDT. In 1981, seepage from the drums was discovered. Soil from the floor was removed and backfilled with clean soil. The area was paved over, and a containment berm was constructed along the floor to contain future potential leakage. The drums were subsequently removed for off-site disposal in the early 1980s.

In 1986, soil samples were collected as part of a pesticide monitoring study. Analytical results indicated that the soil contained residues of DDT and its primary metabolites (dichlorodiphenyldichloroethane [DDD] and dichlorodiphenyldichloroethylene [DDE]). In 1992, an ESI revealed toluene, semivolatile organic compounds (SVOCs), metals, and pesticides in surface soil and sub-floor samples. As a result, the soil impacts were designated as OU 11.

Additional soil and storm drain sediment samples were collected in 1995. Soils were found to contain seven metals, DDT and its metabolites, and PCB-1254 above the USEPA Region 3 risk-based concentrations (RBCs) for residential exposure. Maximum concentrations were found in surface samples. Lead, DDD, and DDT concentrations exceeded residential soil RBCs in sediment samples, but there was not a complete receptor exposure pathway for impacted storm drain sediments. Groundwater collected in 2000 contained two metals and two volatile organic compounds (VOCs) at concentrations above the USEPA Region 3 tap water RBCs but below VDEQ groundwater quality standards. However, downgradient results were below upgradient groundwater concentrations.

An RI was submitted in 1997 and an FS in 2000. An FS Addendum was submitted in 2005 evaluating potential remedial alternatives for future industrial re-use of the site. The HHBRA was updated in 2006 for current and future on-site industrial workers and future construction workers. There was no unacceptable risk for any exposure scenario. The shed was demolished in October 2004, and the area was paved with asphaltic concrete in October 2005. The area is currently used for materials storage. A ROD for OU 11 was signed in 2007. Based on existing OU-specific data, the selected remedial alternative includes LUCs, maintenance of the existing cover system, and proper soil disposal and erosion control in case of future excavation. A vegetative cover was also recommended at OU 11. The RD and RA-C were completed in 2008, and the site has achieved RC.

Path Forward Annual LUCs and LTM of vegetative cover are ongoing and will continue at OU 11.

IRP STATUS

Defense Supply CENTER RICHMOND – DSERTS Site 006 Building 68: OU 10

Site Description OU 10 is the former site of Building 68, a small (30foot x 30-foot) brick building surrounded by an asphalt and gravel lot. OU 10 is located in Zone 1 in the northern part of the installation. From 1954 to 1972, the area served as a pesticide storage and operations facility. Additionally, in 1972 the surrounding gravel lot was used to store electrical transformers. A spill of transformer oil containing PCBs occurred during 1980. Affected soil was excavated and removed from the site. The lot surrounding the former building is currently used for vehicle parking. Storm drains in the area discharge into the Falling Creek Tributary, just west of the installation.

Soil and storm drain sediment samples were collected during a pesticide monitoring study in 1986. A human health risk assessment (HHRA) was performed using a residential exposure scenario. Dieldrin was detected in surface soils above the USEPA Region 3 RBC for residential exposure and above background concentrations. No evidence of pesticide migration to groundwater was found.

An ESI was performed in 1992, which included collecting surface and subsurface soil samples. Toluene, 16 SVOCs, 6 pesticides, and 20 metals were detected. Arsenic, benzo(a)pyrene, and manganese concentrations resulted in unacceptable human health risk under residential exposures, and the soil impacts were designated OU 10.

An RI report was submitted in 1998. Groundwater, subsurface soil, and storm sewer sediment samples were collected during 1995.