SDMS DodO 2005304

Record of Decision for the Offshore Area

Former Nansemond Ordnance Depot, Suffolk, Virginia

6 Mav 2004

US Army Corpsof Engineers »Norfolk District

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'I'hc FoniiLT Nui iscniond OrdiKJiK'cSuttolk, V i r p n u aC03VA004500. Formerly I'sed Defense Sile

Prepared By:

Department or' the Arm>Norfolk Distr ic t Corps o! CngmccFort Nor fo lk 803 Front StreetNorfolk. V i rg in i a 23510- IU96

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T A B I . K OF CONTENTS

LIST OF FIGURES..1. DECLARATION.

1 . 1 . S u e Name a n d Location I1.2 S t a t em en t of Basis and Purpose 21.3 . Assessment Ot Site 21 .4 . Description of Selected Remedy 21.5 Statutory Determinations 21.6. A u i h o n / m g Signatures 3

2. DECISION SUMMARY 4Site Name, Location and Description 4Site History and Enforcement Actu Hies 5C o m m u n i t y Panic i pat ion 6Scope and Role of the Response Action 6Site Charuc ten sties 62 . 5 . 1 . Site Inves t igat ions 72.5.2. Remedial Act ion* 82.5.3. Conf i rmat ion Sampl ing 8Current and Potential Future Site and Resource Uses 9Summary of Site Risks 92 . 7 . 1 . 2002 Baseline Ecological Risk Assessment ( B E R A ) 102 .7 .2 . 2002 Human Heal th R i sk Assev,ment ( H H R A ) 14

2.8. Documentation of Significant Changes 173. RESPONSIVENESS S U M M A R Y ' 17

3.1 Background on Community Participation 173.2. Stakeholder Issues and Agency Response 183.3. Technical and Legal Issues 18

4. ACRONYMS ! 185. REFERENCES 19

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LIST OF FIGURES

Figure 1-1. Location of the Former Nanseraond Ordnance Depot (FNOD) in Suffolk, VAFigure 2-1. Marine aquatic areas being investigated at ihc FNOD site.Figure 2-2. Sediment sampling locations in the FNOD Offshore Area.Figure 2-3. Sediment Dimpling locations in ihe FNOD Old Pier Area.Figure 2-4. Crab and croaker sampling locations in the 1-NOD Old Pier Area.

A R S O O B O O

I . DKCLA RATION

This Record of Decision documents acceptance of the No Further Action i N F A ) determinat ionpresented in the Proposed Plan (PP; US ACE 2003) as ;he remedial a l t e rna t ive for the OffshoreArea of the Former Nansemond Ordnance Depot (FNOD). This a l t e r n a t i v e was accepted afterp u b l i c and regulator)' review of the PP.

1 .1 . Slit NAME AND LOCATION

The Former Nan.iernond Ordnance Depot (FNOD) 'Aas constructed and commissioned as the PigPoin t Ordnance Depot between November 1917 and December 1918 for munit ions storage ands h i p m e n t of these m u n i t i o n s overseas. The FNOD is located on the southern banks of the Jamesand Nai iacmund Rivers , in the northeast pan of the City of Suffo lk . Vi rg in ia (Figure 1 - 1 ) .Between Worid Wars I and II, operations at the Former Depot included preparat ion ofa m m u n i t i o n and components for permanent storage, p a i n t i n g and marking shel ls and containers,segregation of certain lots of a m m u n i t i o n , transference of powder charges from fiber to metalcontainers, salvage of munitions puns, and inspection and disposal of unserviceable ammunitionby defus ing or burning. On April 9. 1945. the Former Depot was incorporated into thedemobi i i /a t ion p l a n n i n g conducted bv the Ordnance Department. Currently, the FNOD isc lass i f i ed as a Formerly Used Defense S i t e i F U D S i .

On January 19. 1999, EPA proposed the FNOD for inclusiou on the National Priority Listi .NPLj, (64 Federal Register No. 27. 295U). The CL-RCL1S identification for the site isV'AD 123933426. The NPL final listing included several "Source Areas" and "Areas ofConcern" t .AOCsj requiring inves t iga t ion at the FNOD. The Offshore Area, extending fromStreeter Creek co Pig Point, was included on this NPL listing as "Area of Concern Number 3"(EPA 1999), and is the subject of this Record of Decision (ROD). Based on differences m thetype of equipment mat could be used for conducting surveys in die subtidal and intertidalzones, the Offshore Area has been divided into the Offshore and Nearshore Areas, which aredelimited by the Mean Lower Low Water (MLLW) line. The nearshore area w i l l be addressedas a separate 0[x:rable unit , and is thus not discussed in this ROD.

The Offshore Area was designated as an area of concern based on potential sources ofcontaminants from I-'NOD that could have affected the Offshore Area sediments. Potentialsources of contaminants that could have contributed to the Offshore Area include the JamesRiver Beachfront (JRB), the former site of burn pits for the destruction of materials related tothe disarmament of ordnance, and current shoreline areas containing metal debris, concrete andasphalt; Nansemond River Beachfront, and other nearshore waterways, such as TidewaterCommunity College tTCC) LaJce, Area J Lake, Horseshoe Pond, and Streeter Creek, that havethe potential to contribute contaminants to the James and Nanseraond Rivers. Analysis ofhistorical photographs showed that considerable loss of shoreline (greater than 300') hasoccurred along the James River Beachfront over the past 50 years (SAIC 2002). meaning thatthe Offshore Area was formerly located much closer to FNOD shoreline areas. Additionally,eroded material from upland areas on FNOD could have been deposited in the Offshore Area.'ITiese factors contributed to the determination to investigate the Offshore Area for FNOD-related contaminants.

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1.2. S l A T K . M K N I OK BASIS A N D PURPOSE

This decision document presents the Selected Remedy for die Offshore Area at the FNOD inSuffolk. Virginia. The remedy. No Further Action, was chosen in accordance with theComprehensive Environmental Response Compensation and Liability Act (CERCLA), asamended by the Superfund Amendments and Reauthorization Act (SARA) , and, to the extentpract icable, :he National Oil and Hazardous Substances Pollution Contingency Plan uNCP).This decision is based on the Adminis t ra t ive Record file for this site.

1.3. ASSESSMENT OK SITE

The U.S . Environmental Protection Agency and the U.S. Army Corps of Engineers havedetermined that no action is necessary to protect public health or welfare or the environment.The Commonwealth of Virginia concurs with the Selected Remedy.

1.4. DK.SCKIITION OK SK.I.KC TKD RKMKDY

The results of extensive environmental characterization investigations and both Ecological andHuman Health Assessments (described in detail in Section 2.7) have determined that site-related contaminants do not exist in the Offshore Area so as to result in unacceptable risk tohuman health or the aquatic environment. Therefore, no further action i N F A ) is necessary toachieve site closure of the Offshore Area. Hence, under this alternative, txo further remedialaction wi l l be performed at the site. Furthermore, no potential for unacceptable adverseenvironmental impacts remain at the site. As a result. CERCLA requirements are satisfied.For detailed information, all associated site documents are presented in the AdministrativeRecord Fi le .

1.5. S T A I U O K Y DK.TK.KMIWnO,\S

The Selected Remedy (No Further Action. N F A ) complies with the statutory requirements ofCERCLA in that it is protective of human health, and the environment. The Selected Remedyconsists of No Further Action because no remedial action is necessary for the Offshore Area toprotect human health and the environment. Statutory requirements pertaining to compliance ofthe Selected Remedy with Applicable or Appropriate and Relevant Requirements (ARARs).utilization of a cost-effective remedy, and u t i l i z a t i o n of permanent solutions, a l te rna t ivetreatment technologies and/or resource recovery technologies to the majumum extent practicabledo not apply to a NFA determination.

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LTHOKUING SlG.NATL

i/onne J. Pret .Slonel. U.S Army

Distr ict EngineerU.S. Army Engineer District. Norfolk

Dace

Abraham Ferdas, DirectorHazardous Site Cleanup DivisionU.S EPA Region I I I

Date

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2. DECISION SI MM A RY

Based on the results of ex tens ive si te inves t iga t ions ^nd risk assessments, remediation of theOffshore Area is not warranted, and No Fur the r .Act ion ( N F A ) is necessary to close out t h i sAOC. I he ; o i l o v \ i n g subsections present an o v e r v i e w of the evidence suppor t ing t h i s decision aspresented :ii the Proposed Plan.

2.1. SITE NAME. LOCATION VAD DESCRIPTION

I he FNOD i s located on the southern banks of the James and Nansemond Rivers , in thenortheast pan of the Ci tv of S u f f o l k . V i r g i n i a < F i g u r e 1 - 1 1 . The site is located w i t h i n the

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Tidewate r District, and is 6 miles across Hampton Roads from Newport News and approximately1 1 . 5 mi i e s hv land west from Nor fo lk . V i r g i n i a . The FNOD consists of approximately 975acres, acquired by the Depar tment of the Army between 1917 and i 'J28 by various deeds,easements, permits, and Deciaiat ion of Takings, i Foster Wheeler E n v i r o n m e n t a lCorporation 1998).

The lead agencies arc the U.S. Army Corps of Engineers i.USACE), Norfolk Distr ict , and theU.S. E n v i r o n m e n t a l Protection Agency (EP .Aj Region I I I . The source of remediation funds isthe Delense Env i ronmenta l Restoration Program iDERP) . tor Formerly Used Defense Sitesi F L D S ) .

The Oifshore Area extends from the low tide l i n e :o approximately 1 m i l e offshore to the JamesR i v e r and Nansemond R i v e r channels . Low tide occurs at d i f ferent sea level elevations (andhence, distances from shore) based on na tu ra l m o n t h l y var ia t ions in the tides ranging from the"Spring" strong tides to the "Neap" weak tides. In order to derive a precise de f in i t i on of theshoreline boundary, the Mean Lower Low Water ( \U_LW) l ine is used, being the averageseavvaier e l e v a t i o n of the lower low iides in the studs area over a 19-year period. This is thedesignat ion used b\ the Nat iona l Oceanic and Atmospheric Administrat ion (NOAA.i NationalOceanographic Survey i.N'OS) ortlce as a boundary tor ;he seaward l i m i t of the in ter t ida l /one.For the FNOD Offshore Area, the MLLW hne. when piojected on the measured seafloorc l c v a t : o n > a long (he FNOD coast l ine , varies between 200' and 300' from the shoreline.Conversely, the Nearshore Area extends from the Ml . l .W l ine to the high tide l ine, w h i c h inmost areas of FNOD is the embankment at the shorel ine.

The Offshore Area includes the remnants of a pier, called the "Old Pier Area", that extends fromihe shoreline out into the James River roughly 3000' (Figure 2 - 1 ) . Another pier is located alongthe Nansemond River shoreline, adjacent to a stone breakwater at Pig Point , w h i c h I N referred toas the F i>h ing Pier Area. This pier does not extend as far out in to the waterway as the Old Pier,and as w i t h the Nearshore Area, is the subject of a separate invest igat ion.

The Offshore Area has been ident if ied as an AOC based on the potent ia l for transport of materialfrom the FNOD site to the waterway. The primary transport mechanism is l i k e l y shorelineerosion, as over 300' of shorel ine has eroded over the past 50 scars (SAIC 2002). such tha tformer in l and site use areas are now p rox ima l to the shoreline. This erosion has provided as i g n i f i c a n t transport mechanism for potential movement of s i te- re la ted contaminants into theoffshore e n v i r o n m e n t . In add i t ion , runoff from iand could add to the transport ol an)con taminan t s .

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One such potential shoreline source of c o n t a m i n a n t s to the Offshore Area is the James R i v e rBeachfront. A separate AOC. :he beach!ront encompasses the locat ions ot h i s to r i c burn pitsoperated for ihe destruction of materials related to the disarmament of ordnance. 1'he area wasalso used ror disposal of large quan t i t i e s of metal debns. concrete and asphalt tUSACE 2000).Invest igat ions of the James R i v e r Beachfront identified contaminants of concern in soils anddebris; final investigations are neanng complet ion. A removal action has been completed,consisting of removal of contaminated soils and debris, and stabilization of the eroding banksand soil removal areas. The post-removal action Human Health Risk Assessment andEcological Risk Assessment have not yet been completed for the onshore portion of the JRB.

Other potent ia l sources of contaminant,- , to the Offshore Area located along the beachfrontinc lude an over f low culver t for the Tidewater Communi ty College (1'CO Lake, Streeter Creek,Area J Lake. Horseshoe Pond and the Nansemond River Beachfront. Inves t igat ions of each ofthese areas arc e i ther ongoing or under consideration. The Old Pier area mas have alsocontr ibuted con taminan t s , as ordnance or other materials could have been dropped during vesselloading. H o w e v e r , no ordnance materials were encountered during a N a v y d ive r une.xplodedordnance ( U X O ) su rvey of the James R i v e r area, which includes the Old Pier.

2.2. SITE 11 ISTORY AND ENFORCEMENT ACTIVITIES

I h e FNOD operated between 1917 and 1950, and was occupied bv the U.S. Army forammuni t ion supply, maintenance, and disposal functions. On April 9. 1945. the Former Depotwas incorporated in to trie demobi l isa t ion p l a n n i n g conducted by the Ordnance Department. In1950. the si te was transferred to the Department of the N a v y , and was subsequent ly named theCorps Supply Forwarding A n n e x . F o l l o w i n g N a v s operation, the FNOD was deactivated in1%0. and ownership of ihe property was transferred to the Beasley Foundation. TidewaterC o m m u n i t y College, the General Electric Company Jet Engine D i v i s i o n iGE) , and the HamptonRoads Sani ta t ion Distr ict ( H R S D y now pr inc ipa l ly occupy :hc FNOD land. Smaller parcels ofland are owned by the V i r g i n i a Department of Transportation, (Interstate 664). Dominion Lands,Inc. . C o n t i n e n t a l Properties and SYSCO Food Services ( U S A G E 2000).

On January 19. 1999. EPA proposed the FNOD for inclusion on the Nat ional Priority List (NPL).(64 Hederal Register No. 27, 2950). ' I h e NPL f i n a l l i .stmsj included several "Source Areas" and"Areas of Concern" (AOCs) r e q u i r i n g inves t iga t ion at the FNOD. The Offshore Area, ex tend ingfrom Streeter Creek to Pig Point, was included on this NPL l is t ing as "Area of Concern Number3" (EPA 1999). and is the subject of t h i s Record of Decision (ROD).

On J u l y 22, 1999, the U.S. Environmental Protection Agency < E P A i made a finaldetermination and placed the FNOD on the General Superfund List for private sites (.64Federal Register No. 140, 39878). On the final determination, the F'NOD was listed as a Non-Federal Facility Superfund Site, as the Federal Government does not currently control anyproperty at the FNOD. However, the EPA has named the Federal Government, specificallythe Department of Defense (DoD). as a Potentially Responsible Party < P R P > for addressingenvironmental issues at the FNOD.

To address environmental issues in the Offshore Area at the FNOD. the U'SACE, w i t h technicalguidance from EPA Region I I I . commissioned an envi ronmenta l characterization study of thisAOC. The goal of t h i s inves t iga t ion was to character)/.c the marine habi ta t and i d e n t i f y potentiala l tera t ion due to disposal ac t iv i t ies from past operations at the FNOD. as well as ident i fy the

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nature and extent ol chemical contaminat ion, m part to re l ine exposure models for the plannedEcological Risk Assessment ( E R A ) . Contaminant data from this invest igat ion, supplementedw i t h data collected during a surves of ihe Old Pier, were used i n preparation of the ERA andsubsequent Human Health R i s k Assessment ( H H R A ) for t h i s AOC. These studies are discussedm d e t a i l i n Section 2.7.

2.3. COMMUNITY P \RTICIPATION

To f u l f i l l the publ ic par t ic ipat ion requirement under Section 117(a) of CHRCLA, as amended byS A R A , the Proposed Plan for the Offshore Area was released to the pub l i c on December 4. 2003.and is a v a i l a b l e in the A d m i n i s t r a t i v e Record Fi les maintained at the Tidewater CommunityCollege Library in Portsmouth. V i r g i n i a ; and at the USAGE, Norfolk District b u i l d i n g inNorfolk. V i r g i n i a . The Proposed Plan was a v a i l a b l e for public comment from December 4,2003. to January 4, 2004. A Notice of A v a i l a b i l i t y for the Proposed Plan and notification of thepubl ic comment period was publ ished in the V i rg in i a Pilot and Dai ly Press on November 24,2003 The nonce stated tha t a p u b l i c meet ing concerning the Proposed Plan was planned forDecember 4, 2003. The publ ic meeting was held on December 4, 2003, to present the ProposedPlan to a broader audience than those tha t had already been involved at the site. At th is meeting.representat ives from EPA and the Army Corps of Engineers were ava i lab le to answer anyquest ions raised about the s i te and the Selected Remedy.

No comments were received in response to lite notice or at the Publ ic Meeting, as described inthe Responsiveness Summary i Section 5) of t ins ROD. This ROD presents the "No FurtherAct ion" decision for the Offshore Area at the FNOD located in Suffolk . Virginia , chosen inaccordance w i t h Ch'RCLA. as amended by SARA, and to the extent practicable, the NCP.

2.4. SCOPE A N D ROLE OK THE RESPONSE ACTION

I 'his Record of Decision addresses (he e v a l u a t i o n of remedial a l ternat ives for the Offshore Area.This response action does not inc lude or a f fec t anv other sites at the f a c i h t v that f a l l under theCERCLA process. In addition to upland areas being investigated throughout FNOD, and asstated i n Section 2.1 above, there are other waterway areas that are being evaluated separatelyfrom the Offshore Area, inc lud ing ihe Nearshore Area, Fishing Pier, Streeter Creek, and theponds that occur along the shoreline inc lud ing I'CC Lake. J Lake, and Horseshoe Pond. Theyare the subject of separate inves t igat ions and separate determinations of need for any remedialactions that may be necessary to protect human health and the environment.

Regarding the Offshore Area of Concern, the role of the preferred a l te rna t ive in the ResponseAction is to address all potential FNOD-related threats posed by the Offshore Area and toe l i m i n a t e current exposure pathways iha t may pose unacceptable human health or ecological riskfrom contamination.

2.5. SITE Ci LA KACTKKIS ncs

This section of the Record of Decision contains information on the phvsicai and biologicalconditions of the Offshore Area and the nature and ex ten t of contamination, and human heal thand ecological nsk assessments. Site characteristics were documented by two marineinves t iga t ions (2000 Envi ronmenta l Survev and the 2002 Old Pier Survey. Section 2 . 5 . 1 )

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summarised in the subsection below. I he nature and e x t e n t of c o n t a m i n a t i o n was determinedfrom these .surveys, and i d e n t i f i c a t i o n of Contaminants of Potential Concern iCoPCs) wasaccomplished ihrough the Ecological R i sk Assessments ( E R A ) and Flu man Health RiskAssessment (HHRA). Summaries of ecological and human hea l th CoPCs and site-related nsksare p r o v i d e d m Section 2.7 be low.

The complete reports for each i n v e s t i g a t i o n can be found in the associated Informat ionRepository and A d m i n i s t r a t i v e Record t i les at the locations provided below:

Tidewater Community College Library7000 College DrivePortsmouth. Virginia 23703( 7 5 7 ) 822-2130 "

U.S. Army Corps of Engineers, Norfolk District803 From StreetNorfolk . Virginia 23510-1096(757. 441-7507, FNOD Project Manager

2.5.1. Site Investigations

2000 Lnviraiinu'nUit Sun.-cy. A broad field survey of the enure Offshore Area was conducted in2000 and i n v o l v e d a m u l t i p a r t geophysical survey employing b a t h y m e t r y , side-scan sonar.subboitom p r o f i l i n g , magnetometry and sediment prof i le image (SPI) photography, as w e l l as thecollect ion of sediment cores and surface grab samples to characterize ex ten t and nature ofchemical contamination (Figure 2-2). A total of 234 sediment profile images were collected at136 s ta t ions throughout the Offshore Area to charactcn/c bottom sediments and benthic habitatcondi t ions . Sediment grab samples and cores were collected at 31 stations forcharac ten /a t ion ofgram size, total organic carbon, sediment chemistry, and sediment to .x ic i ty tests. The sedimentcores collected were up to 2 meters in length and were used to evaluate sediment chemistry atgreater depths than the surface grab sample sediment characten/alions. Sediment chemistryana lyses consisted of determination of metals. S imul taneous ly Extracted Metals (SF.M) and AcidVolatile Sul t idcs u\VS). polvcyclic aromatic hydrocarbons (PAHs), polychlor inated b iphenyis(PCBsi . pesticides, dioxins and explosive compounds. Arnphipod tox ic i tv tes t ing was alsoperformed on grab samples.

Findings from the Environmental Survey invest igat ion indicate that the Offshore Area consists ofa r e l a t i v e l y tlat intert idal and shal low subt ida l /one extending from the shoreline to a break inslope approximately 2500' to 3000' offshore. Scattered mclal objects were delected dunng. themagnetometer survey , including numerous ident i f iable objects (e.g., crab pots I as detected w i t hthe side-scan survey. Sub-bottom profiles showed evidence of l a y e r i n g in nearshore areas,presumably due to recent high rates of deposition associated wi th erosion of the adjacentuplands. Grain size consists p r edominan t ly of f ine sand, w i t h a trend toward finer gram sizeswi th increased depth. The sediment profile interface (SPh photographs revealed that recentlycolom/cd organisms dominate the benthic communi ty and are restricted ;o the top fewcentimeters of sediment; (his i s l i k e l y due to frequent phys ica l disturbance of the sediment f romwaves and currents. The benthic communi ty is dominated by opportunistic. Stage 1 organisms

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i l i k e l y due to physical sediment rework ing and h i g h organic loading). These results were used todevelop the conceptual model and design of the draft Screening Level Ecological RiskAssessment tSLERA) for the Offshore Area, as we l l as subsequent more detailed evaluat ions ofecological r i sk in the Baseline Ecological R:.->k Assessment (BERA) , as w e l l as in support of theH u m a n Heal th Risk Assessment ( H H R A i . First and foremost was the observation from sedimentprof i le i n t e r f a c e (SPI) photographs i h a t benthic ep i faunal ecological receptors occupy ab i o l o g i c a l l y ac t ive zone tha t is l imi ted to the top few centimeters of sediment, and most oftenex i s t i n the top few mi l l ime te r s of sediment since deep burrowing organisms were not observed.

Sediment chemis t ry analyses ind ica ted tha t contaminants were generally low m the surface tO-10cm dep th ) and sub-surface (>10 cm depth j sediments. Addi t iona l ly , no amphipod tox ic i tv wasobserved in these sediments.

2002 Old Pier Sttr.'c\. W h i l e the s u r v e y e f f e c t i v e l y characten/ed geophysical features andchemical extent wuh in most of the Offshore Area, it did :iol ef fec t ive ly characterise the Old Pierarea as remnant p i l ings and sha l low wa te r depths in ;his area impeded survey vessel access.Accordingly, a supplemental survey of the Old Pier area was conducted in 2002. and involvedsidescan sonar, SPI photography and sediment grab sampling as conducted for the 2000Environmental Survey (.Figure 2 - 3 ) . In addition, tissue samples (croaker and blue crab) werecollected at sediment grab locations to provide collocated sediment and tissue chemistry dataneeded to complete trophic models for the BERA (Figure 2-4). In a l l , 202 SPI images, 7sediment grab samples and 5 croaker and 6 blue crab samples were collected. As for the 2000Environmental Survey, sediment samples were analyzed for metals, SEM:AVS. PAHs, PCBs,pesticides and explosive compounds. Dioxins were not quantified in sediment samples as theywere in ihe 2000 survey because substantial elevated concentrations were not detected duringthat investigation in the subset of samples analyzed. Additionally, as in the 2000 survey,amphipod toxici tv testing was performed on collected sediments.

In i i l l , 202 SPI images. 7 sediment grab samples and 5 croaker and 6 b lue crab samples werecollected in the Old Pier Area. Concentrat ions of sediment contaminants w i t h i n the Old Pierarea were genera l ly low, and no amphipod t o x i c i t y was observed in the sediment toxici ly tests asin the 2000 Envi ronmenta l Su rvey . A d d i t i o n a l l y , the croaker and blue crab tissue concentrationswere also generally low. Results of a detailed eva lua t ion of the measured contaminant insediment and fish w i t h respect to possible ecological and human health risks are discussed in thefo l low mg Sections.

2.5.2. Remedial Actions

No remedial actions have been performed in me Offshore Area due to the t lndmg of negl ig ib lerisk described in Section 2.7, below.

2.5.3. Confirmation Sampling

As no remedial actions were performed in the Offshore Area, confirmation sampl ing was notrequired.

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2.6. C l R R K N T \ND POTENTIAL Fl Tl KK Si I K AND RKSOl KCF1 l.'SES

The Offshore Area is a s h a l l o w , s u b - t i d a l w a t e r w a y w i t h no vegetated or hard-bottom habi ta t .Its cur rent uses by humans arc pr imari ly for recreational and commercial f i s h i n g . During rieldi n v e s t i g a t i o n s , recreational hook and ime f ishermen were observed f i sh ing I rom several shoreside loca t ions , i n c l u d i n g Ihe banks near '.he Old Pier. Fishermen were also observed f i s h i n g fromboats t e m p o r a r i l y ra i ted along ihe Old Pier. Upon i n q u i r y , most f i she rmen replied they weref i s h i n g :'or croaker, presumably tor consumpt ion , a l though I rcquent landings were not observed.In terms of commercial f i s h i n g , ihe b lue crab trap f i shery is ac t ive in the Offshore Area, ase v i d e n c e d by observations dur ing f i e l d surveys and detection of numerous crab traps in sidescanimagery collected during the 2000 E n v i r o n m e n t a l Survey .

No add i t i ona l i n fo rma t ion regarding s i t e use was obtained through publ ic comments, inc lud ingm response to the p u b l i c comment period on (he Proposed Plan and at (he publ ic meeting held onDecember 4. 2003.

Risk to h u m a n s from c o n t a m i n a n t s i n ihe Offshore Area as a result of these act ivi t ies wasassessed i n ihe HHRA (Section 2 . 7 . 2 ) . I h e HHRA concluded tha t nsk was negl ig ib le as fewc o n t a m i n a n t e levat ions were iden t i f i ed in croaker and blue crab tissue, and these elevat ions werenot related so e leva ted l e v e l s of con taminants in the sediments of the Offshore Area. It isa n t i c i p a t e d tha i f u t u r e s i t e uses w i l l be s i m i l a r to current uses, and hence nsk w i l l continue to beneg l ig ib le .

2.7. S U M M A R Y o K S n i : R I S K S

Risks from con t aminan t s i n the Offshore Area were evaluated in two assessments: the Baselinetcological R i s k Assessment ( I J F . R A : Section 2 . 7 . 1 ) and a Human Health R i s k .Assessment{HHRA; Section 2.7.2) . These studies concluded l h a t FNOD-rela ted risks to ecological andhuman receptors presented by the Offshore Area arc negligible, and do not warrant remedialaction. (No te t h a t t h i s determinat ion pertains to FNOD-related nsks o n l y , not other sources ofrisk i n the region, as there is cur ren t ly a V'DEQ f i s h i n g advisory for t h i s area of the James R i v e r . )

Both ihe ecological and human hea l t h nsk assessments included identif ication of Contaminantsof Po ten t i a l Concern (CoPC). CoPC selection is a process that permits refinement of the l i s t ofthe Target Ana iy t c Lis t O'AL) compounds to i d e n t i f y those chemicals that are potentiallycausing site related nsks. The process i n v o l v e s screening m a x i m u m lor l>5'r confidence l i m i t )site chemical concentrations against respective ecological and human benchmarks, w i t h retentionof analytes that have a maximum concentration that exceeds the appropriate, conservativebenchmark va lue , per EPA guidance (EPA 1W2). Screening was performed using the combinedchemical concentration dataset from the 2000 and 2002 surveys. Two separate CoPC l i s t s weregenerated, one based on ecological nsk, the other on human risk, because the benchmarks foreach e v a l u a t i o n arc different. The results of ihese screenings are provided in Table 3.6-3(summary t a b l e ) and Appendices A - 1 to A-3 of the Baseline Ecological Risk Assessment for theMarine Ojfshore Area (SA1C 20021 and in Table 2 - 1 of ihe Human Health Risk Assessment <ifthe Marine O/fshore Area (SAIC 2002b). Detai ls of ihe screening process are contained in therespective sections of the reports, and bnel summaries of '.he findings ore provided below.

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2.7.1. 2002 Baseline Ecological Risk Assessment ( B E R A )

Sediment chemistry and SPI daia from the 21)00 E n v i r o n m e n t a l Survey, and sediment and t issuechemistry data from the 2002 Old Pier s u r v e y , were used to conduct the BLRA, w h i c h wascompleted in September 2002 \lia.\flinc' l:cnlo<>'.cal Riak Assessment for ihe Marine OffshoreArea »f ;hf l-onner \'ansi-rni»iJ Ordnance ttepin; SAIC 2002). The UShPA guidance onEcological R i sk Assessment i . E R A ) prescribes an S-step process separated i n to two pnmaryphases; Screening Level and Base l i ne R i s k Assessments (Sl.F.RA and B K R A , respect ively .USF.PA 1°97). S imply stated, ihe goal of the ecological r isk assessment is to assess theprobabi l i ty that chemicals arc present in the e n v i r o n m e n t of biotic receptors at concentrationsand form t h a t can cause harm. EPA defines ihe SI.F.RA as "a s imp l i f i ed nsk assessment tha t canbe conducted w i t h l imi ted data; where s i t e - spec i f i c informat ion is l ack ing , assumed va luesshould consis tent ly be biased m the direct ion of over es t imat ing risk" lUSEPA 1997).Ecological nsk assessment for the Offshore Area was in i t ia ted as a SLERA inves t iga t ion ,u ' . i l i /mg a conserva t ive approach to ihe hypothesis that ecological nsk docs not exist or thatcer ta in c o n t a m i n a n t s and exposure pa thways can be e l i m i n a t e d as po ten t ia l nsks.

Subsequent data collection efforts for the Old Pier s u r v e y provided addit ional , site-specific;n form.a i on t h a t a l lowed completion of a B E R A . i n c l u d i n g uu l i / a l i on of exposure est imationcalculations and trophic t rans fe r models, us ing the site-specific tissue data. The riskcharacien/ation approach employed i n the BER.A i n v o l v e d est imation of exposure to CoPCs andthen c a l c u l a t i o n of risk based on '.his exposure, w i t h sediment loxici ty test results providingsuppor t ing evidence in in t e rp re t ing s i ie-specif ic nsk. Exposure estimation for sediment-associated receptors (e.g., c lams, mussels, oysters) and demersal receptors (e.g.. b lue crabs,croaker) was accomplished through the calculat ion of Hazard Quotients i.HQs.i, or the d i v i s i o n ofmeasured sediment concentrat ions by threshold effects values. Risks were then evaluated byr a n k i n g these HQs according to four l e v e l s of probabil i ty of adverse exposure ( n e g l i g i b l e , l o w ,in t e rmed ia t e , h i g h ) , and t hen comparing these f i n d i n g s 10 sediment t ox i c i i y test results. Foraquat ic as urn (e.g., b lack-crowned n i g h t h e r o n ) and m a m m a l i a n (e.g.. raccoon) receptors, trophictransfer models were employed to estimate the dose of contaminants to these higher-levelpredators. These doses were screened against Toxic i iy Reference Values (TRV's) for avai lablespecies representing n igh t herons and raccoons, to est imate probabi l i ty for adverse effects onihese represen ta t ive species.

These assessments concluded that ecological nsks in the Marine Offshore Area, i nc lud ing theOld Pier area, were negl igible and therefore there was no need for remediation on the basis ofecological nsk. It was concluded that th i s f inding was adequately documented and technica l lydefensible as all data needs were adequately f u l f i l l e d by inves t iga t ions to date.

Identification of Ecological CoPCs. For identif ication of sediment CoPCs. sedimentconcentrations were screened against the lowest ava i l ab l e , conservative, sediment benchmarks,i n c l u d i n g NOAA Effects Range -Low i F . R - l . i , F.PA's Apparent Effects Threshold (ALT) , andFlorida Department of Env i ronmen ta l Protection ( 'DEP) Threshold and Probable Effects Levels(TEL/PEL) benchmarks. Comparisons to upper benchmarks (e.g.. Effects Range- Medium orER-Ms) were used to assess the magnitude of potent ia l hazard posed by a CoPC. CoPCs consistof a n a l y t e s detected in greater than 5'r of the samples, and for w h i c h the maximumconcentration exceeded the most conservat ive, lower screening benchmark.

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Metals. P.AHs. and dioxins were detected i n sediments i n more t h a n 20'^ of the samples, but atlow concentra t ions when compared to conserva t ive ecological benchmarks 195'* upperconf idence l i m i t of the mean were below lower benchmarks. NOAA Effects Range - Low, BR-Ls'i O n l y arsenic and mercury exceeded the ER-L benchmarks for metals. Arsenic exceedanccsoccurred i n seven samples, of wh ich on i s t w o were surface sediment samples (at the s tat ionsfarthest from shore.) and (he remainder were samples from depths greater than 20 cm. Mercury'exceeded the benchmark in three sub-surface samples, and not in any surface samples. Ana d d i t i o n a l ana lys i s for metals a v a i l a b i l i t y (SEM:AVS: see SAIC 2000) revealed tha t the d i v a l e n tmetals i copper, cadmium, lead, nickel , and / inc) were not biological ly ava i lab le to aquatic biota.The b io log ica l a v a i l a b i l i t y of arsenic and mercury could not be addressed in a manner s imi l a r tome d i v a l e n t metals. However, the results of the biological tes t ing of sediments tha t ind ica te alack of l o x i c i t y provides ev idence tha t these metals are not b iological ly a v a i l a b l e to the aquat icbiota.

For P.AHs. on ly acenaphthene and fluorene were found at concentrations higher t han the NOAAER-L ( b u t not at concentrations exceeding the upper benchmarks, ER-Ms). Dioxins weredetected in the majority of samples and thus were retained as a CoPC. Dioxin concentrationswere compared to low- and high-risk thresholds using ecological sediment q u a l i t y guidelinesrecommended by EPA, and sediment concentrations were an order of magnitude lower than thelower threshold for fish and birds, and only occasionally exceeded the lower threshold formammals by a s l i gh t marg in .

In the pe.sticide group, five chemicals . 4,4'-DDD, 4.4'-DDT. aldrin. d ie ldnn and endnn ketone,were detected w i t h a frequency >5'7 and had max imum concentrations that exceeded the ER-Lbenchmark, and thus were reta ined as CoPCs. Of these, only dieidnn exceeded the upperscreening benchmark ( L R - M t .

As for the PCBs. most of ;he 24 congeners were detected only in f requen t ly . Seven congenerswere detected w i t h at least 5'r frequency (52. 153. 169. 170. 180, 195, 206, and 209); PCBcongener 153 was the most f r e q u e n t l y detected i42'T of the samples). However, total PCBs onlyexceeded the benchmark in one location, and total PCBs were not retained as a CoPC based onfrequency of detection below' 5°r . F i n a l l y , ne i t he r explosives nor kcpone were detected and thuswere not retained as CoPCs.

Resul t s of the sediment toxicity tests us ing 10-day exposures of the amphipod..s, indicated no sediment t o x i c i t y .

In summary , the ecological CoPC screening process iden t i f ied the f o l l o w i n g chemical classesand compounds as CoPCs:

• Metals: arsenic and mercury:

• P.AHs: acenaphthene and tluorene: and

• Pesticides: 4,4'-DDD. 4. 4' - D D L , a ld r in , d i e ldnn and endnn ketone.

Ecological risk calculat ions were conducted on these identified sediment CoPCs as summan/edin the f o l l o w i n g section.

Ecological Risk Characterization. The nsk characterisation approach to evaluate potentialecological risks associated w i t h these CoPCs i n v o l v e d est imation of exposure to CoPCs and then

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ca lcu la t ion of risk based on t h i s exposure, w i t h sediment lox ic i ly tes t ing results p rov id ingsupporting evidence in in terpre t ing site-specific risk. Details of the exposure modeling effortsare presented in Section 4 of the BERA report. The analys is includes consideration of organismsthat w o u l d be subject to direct, continuous exposure ( I n f a u n a l . Epibenlhic and DemersalReceptors), and those ihal would be subject to d iscont inuous exposure to the sediments in theOffshore Area ( a v i a n and m a m m a l i a n receptors), discussed in Ihe sections below.

Risks to Infaunal. Epibenthic and Demersal Receptors. Direct, connnuous exposure wasc o n s e r v a t i v e l y assumed for organisms l i v i n g in the sediment (e.g., clams, mussels, oysters) anddemersal predators (e.g.. blue crabs, croaker). Potential r isk for these organisms was evaluatedthrough the ca lcu la t ion of Hazard Quotients iHQs), or the d iv is ion of measured sedimentconcentra t ions by threshold effects values (Table 4.2-1 in the BERA). High ly conservat ivethreshold effects levels were used !o account lor all potential nsk and to account for long-term,chronic effects of exposure. Risks were then evaluated by r a n k i n g these HQs according to lourl e v e l s of p robab i l i ty of adverse exposure (neg l ig ib l e or below lower benchmark, low.in termedia te , high or more t h a n t w o - f o l d above the upper benchmark), and then comparing thesef ind ings to sediment toxic i ty test results.

P r o b a b i l i t y of adverse exposure was determined based on a q u a l i t a t i v e eva lua t ion of thefrequency and magnitude of benchmark exceedances for each CoPC. Sta t i s t i ca l comparisonsamong stations were not conducted, and es t imat ions of FNOD background conditions were notincorporated into the e v a l u a t i o n . Consideration was g iven to the depth in the sediment at whichthe elevated concentrations occurred, a.s the t y p e of organisms l i v i n g in the sediment and feedingin the Offshore Area sediments wou ld not l i k e l y be m contact w i t h sediments at greater depth mthe substrate. For iden t i f i ed ecological CoPCs, benchmark exceedances were generally ofr e l a t i v e l y low magnitude (i .e. . not subs tan t i a l ly h igher than the very conse rva t i ve screeningbenchmarks used), inf requent (occurred m a l imi t ed number of samples), and/or occurred atsubstrate depths greater t h a n 20 cm.

Eva lua t ion of the sediment CoPCs indicated tha t mercury exceeded the lower benchmark at onlythree locations and at depths greater than 20 cm. Arsenic exceeded the benchmark at sevensta t ions , o n l y t w o of which occurred m the upper 20 cm of sediment, located at stations, furthestfrom ihe shoreline. PAH exceedances of the lower benchmark only occurred at one stat ion.S i m i l a r l y , isolated occurrences of benchmark exceedance for the pesticides DDD. DDT. andd ie ldnn were h i g h l y locali/ed and appeared unrelated to any FNOD source areas.

Results of sediment toxicity tests (no toxici ty observed) and evaluation of pore water exposure toCoPCs (modeled based on the sediment concentrations) supported the conclusions that thecons t i tuents identified as CoPCs do not appear to be an important source of risks to i n f a u n a l .cpibcmhic and demersal receptors at the site.

The characterizations of potential effects based on benchmarks are conserva t ive g i v e n that manyof the species do not spend t h e i r en t i re l i f e span at a single location. The acute t o x i c i t y testsconfirm the prediction of lack of effects based on these benchmark compansons. The spat ia lana lys i s , i nd i ca t i ng a lack of widespread contaminat ion addi t ional ly suggests that any location-specific benchmark exceedances are l i k e l y not a significant concern given the mobi l i ty of mostspecies.

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Risks to A v i a n and Mammalian Receptors. Discont inuous exposure scenanos were eva lua tedfor mammal ian (raccoon) and av i an (black-crowned n i g h t heron) aquatic predators that couldfeed in ihe Offshore Area. Trophic t ransfer models were employed to est imate the dose ofc o n t a m i n a n t s to these h igher - l eve l predators, Exposure levels were calculated by determining;he do.se of chemical (chemica l concentration in prey, sediment and/or pore water t imes themgestion ra te) , the exposure factor ( t h e duration the an imal is exposed to the con taminan ts ) , andthe b ioav a i l a b i l i t y ol the contaminants (how much chemical is absorbed by the an ima l ' s tissuesper u n i t lood consumed). These doses were screened against 1 'ox ic i ty Reference Values (TRVs)to represent (he local species i n c l u d i n g black crowned night herons (.Table 4.2-5 in BERA) andraccoons (Table 4.2-6 m B E R A ) . to estimate probabi l i ty for adverse effects on theserepresen ta t ive species. Trophic t ransfer models include numerous assumptions about ihe loodpreferences, si/e and behavior of ihe an ima l s t h a t are incorporated from the ava i lab le literature.The models inc lude the h i g h l y c o n s e i s a t i v e assumption that the animals spend thei r ent i re l i v e sfeeding m (he Offshore Area. In addition, the most conservative dose-based benchmarks arcused, or No Observed Adverse Effec t Level (NO.AF.L), to provide the most conse rva t ivee v a l u a t i o n possible and account for possible chronic effects .

Resul ts ior hiack-crowncd n i g h t heron indicated t ha t o n l y metals (chromium, lead and /me) weredetected i n surface sediments at severa l sampl ing locations at s u f f i c i e n t concentrations to predictan exposure that would exceed the TRV. Hazard Quotients for the exceedances for thesecomparisons were all less than 10.

Resul ts for raccoon indicated that the metals arsenic, cadmium, and chromium, were found insurface sediments at su f f i c i en t concentrations to predict an exposure that would exceed the TRV.A d d i t i o n a l l y , isolated exceedances were observed for PCBs. aldnn and hcptachlor. Allexceedances corresponded to Ha/ard Quot ien t s less lhan 10. and none of the unalytes wi th TRVexceedances ind ica ted a t rend of increased concentration near ihe FNOD shoreline.

These screenings were based on the NOAEL benchmark, wh ich is a factor of ten below theLowest Observed Adverse Effects Level (LOAEL) benchmark t y p i c a l l y representing a chronicor sub-chron ic t n o n - l e t h a l ) endpomt and is t hus h i g h l y conservative. Add i t iona l ly , calculation ofa stat ion-specific HQ (maximum site concentration compared to T R V ) assumes the animalw o u l d feed on prey items e x c l u s i v e l y at that particular station, which also represents a h i g h l yconserva t ive approach.

Based on the h igh ly conservative assumptions used in the exposure assessment, and the veryc o n s e r v a t i v e TRV values used, i t was concluded that the few identif ied exceedances do notrepresent a h i g h probability of adverse effects to aquatic predators such as black-crowned nightheron, and mammalian predators, such as raccoon, at the site.

Ecological Risk Summary. Based on these assessments presented in the BERA. chemicalcontaminants detected in the sediments of the Offshore Area do not appear to be related toac t iv i t i e s on the site and are u n l i k e l y to pose risks to ecological receptors. Uncertaint iesassociated w i t h th is conclusion are discussed in Section 4.2.3 of the BERA and inc ludeuncertaint ies associated wi th sample collect ion and iden t i f i ca t ion of CoPCs. and uncertaintiesassociated wi th the various modeling efforts undertaken to assess the potential nsks of thoseCoPCs to ecological receptors. The f ina l determination of the BERA is that ecological nsks inthe FNOD Offshore Area, i nc lud ing the Old Pier Area, are negligible and there is no need forremediat ion because of ecolosieal risk.

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The BERA was based on thorough documenta t ion of the s i te conditions and chemica ldis t r ibut ions: thorough rev iew ot s i te h is tory ; development of conceptual models, data needs,s tudy boundary and decision cr i ter ia , f o l l o w i n g Data Qual i ty Objectives tDQOsj; exposureestimates based on conservative assumptions and using maximum chemical concentrations;c a l c u l a t i o n of ITa/ard Quo t i en t s us ing c o n s e r v a t i v e benchmarks to indicate w h i c h contaminantsm i g h t pose ecological threats; and incorporation of sediment t o x i c i t y test results using sitesediments Uncer ta in t ies were m i n i m i z e d to the extent possible for ihe H E R A , and m u l t i p l eapproaches were under taken to subs tan t i a t e the lack of site-related risks to ecological receptors.Ihe re fo re , i t was concluded t h a t t h i s f i n d i n g was adequately documented and t echn ica l lydefens ible , as ai l data needs were adequately f u l f i l l e d by i n v e s t i g a t i o n s to date.

2.7.2. 2002 Human Health Risk Assessment ( H H R A )

The HHRA for ihe Offshore Area (SAIC. 2002b) was prepared in accordance w i t h bPAguidance described in Risk Assessment Guidance for Superfund (RAGS) , Volume I , HumanHealth E v a l u a t i o n Manua l . Part A ( L P A , I9S9) and Pun D (EPA, 2001). and EPA Region I I Iguidance documents for Risk Assessment. These methods consist of i d e n t i f y i n g l i k e l y potentialexposure p a t h w a y s in the Offshore Area, w h i c h were determined to consist of exposure tocontaminants through consumpt ion of recreat ional I y caught f i sh and she l l f i sh . Accordingly, thecroaker and b lue crab tissue concentrat ions u t i l i zed in the BERA were screened against humanheal th Risk-Based Concentrat ion i R B C ) benchmarks for fish and regional backgroundconcentra t ions to i d e n t i f y C o n t a m i n a n t s of Potent ia l Concern (CoPCs) that could pose risks tohumans. It was determined that direct human contact w i t h sediment in the Offshore Area wasu n l i k e l y , and sediment CoPCs were iden t i f i ed for comparison to t i s sue CoPCs and not fori d e n t i f i c a t i o n of p o t e n t i a l human h e a l t h nsks.

Conceptual Site Model. In ihe Conceptual Site Model foi the FNOD Offshore area, potentialroutes of exposure to FNOD-related contaminants include the consumption of chemicals in fishand crabs by adults , adolescents and ch i ld ren . Recreational f i sh ing occurs in (he Offshore Areaand around the Old Pier p i l i n g s , and presents .1 p l a u s i b l e exposure pa thway for humans based onconsumption of chemicals m f i n n s h and craos t h a t have be taken up chemicals into the i r tissuesfrom i i iges t ion of the sediment and sediment-associated prey i tems.

As the Offshore Area is l im i t ed to wa te r s offshore of ihe suntidal zone, there is no residentialaccess. The area is too deep for w a d i n g and other recreational ac t iv i t i es such as s w i m m i n g arenot i i k e l y to occur in the Offshore Area: therefore, i t was determined that human contact w i t h thesediment would be u n l i k e l y . There is potent ia l for human contact w i t h sediment w h i l e pu l l i ngimps set in the Offshore Area, but based on the prevalence of sandy substrate, i t is un l ike ly thatany appreciable amount of sediment would be earned to the surface on a trap. It was thereforedetermined that direct contact wi th sediment was not a l ike ly pathway for exposure of humans toc o n t a m i n a n t s in the FNOD Offshore Area. Accordingly , these pa thways were not evaluated.The i:;gcstion of sediment or water du r ing f i s h i n g is possible but is not considered a l i k e l y routeof chemica l exposure and therefore this p a t h w a y was not evaluated quant i ta t ive ly . Theconceptual sue model included evaluat ion of potential exposure from consumption of fish andcrabs by adul t s , adolescents, and chi ldren based on recreational li .e.. not commercial) f i sh ingpatterns, based on known patterns of use in the area.

Identification of Human Health Col'Cs. I he sediment and tissue chemistry data that wereused m the BtRA were also used for the H H R A . For the HHRA. the tissue concentrations of

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croaker and blue crab collected during the Old Pier su rvey were compared to the human healthRisk-Based Concentrations iRBCs) for f i sh . Appropriate adjustments wore made to ensureconsis tent u n i t s and to account for addi t ive effects on non-carcinogenic analytes , consistent w i t hEPA Region 111 guidance (EPA 2002). Resul ts are presented in Appendices B- l to B-3 of theHHR.A report, w i th comparisons to EPA RBC v a l u e s provided in Seclion 2.2.3 of the report.

For s i x b l u e crab (claw meat a n a l y z e d ) and f ive fish (croaker, cross-section of t a i l sectionanaly/.cd) tissue samples analy/ed. several metals were either not detected or were detected atlow concentrat ions s i m i l a r to those measured in b l a n k samples ( a l u m i n u m , a n t i m o n y , cadmium,lead, n i c k e l , s i l v e r ) . Arsenic, chromium, copper, i ron, mercury, and zinc were detectedfrequent ly , wh i l e silver was detected in two of 1 I samples.

P.AHs were e i ther not detected or were detected at low levels (e.g.. maximum concentrations lessthan 100 ug kg) w i t h the exception of four P.AHs detected at somewhat elevated concentrations(> 100 uii-kg). including ben/o(b)tluoranthene, tluoranthene, phenanthrene and pyrenc.

PCB congeners were e i the r not delected or delected at very low concentrat ions ( i . r . . less than10 ug kgj. with only one congener exceeding this v a l u e (PCB 153, 12 (.ig kg). I he highest fotalPCB concentration observed was 33 ^ig/kg. Two pesticides. 4.4'-DDE and 4.4'-DDT, weredetected at concentrations of 3.3 ugkg and 7.7 ug kg. respectively. Dioxins were not measuredin fish tissue samples. F ina l ly . 14 explosives compounds were analyzed in the tissues of crabsand f ish , but concentrations were non-detecl m all samples.

To address the fact that the t issue samples were collected from motile species tha t would beexpected to feed over a broad area, not limited to the FNOD Offshore Area, tissue CoPCs wereselected us ing a tiered analysis approach. First, predicted tissue residue concentrations weredeveloped from the measured sediment chemical concentrations at the site (using regionally-applicable bioaccumulation factors developed for this project) and compared to the EPA RBCs.Subsequent ly , for those chemicals where a prediction of fish tissue residues to exceed the RBCswas obtained, ihe corresponding measured fish and crab tissue concentrations were screenedagainst ihe same RBCs. Because not all elevated CoPCs in tissue were elevated in sitesediments , t h i s method ensured that the human heal th r isk ana lys i s focused only on those site-related sediment-associated CoPCs.

The F.PA Region 111 RBC screening v a l u e s used in screening the predicted and measured fishtissue concentrations incorporated the tPA guidance regarding target l i f e t i m e cancer risks( l . x io " ) for carcinogenic analytes as wel l as possible c u m u l a t i v e addit ive effects of non-carcinogenic analyles. Comparison of predicted tissue concentrations w i t h the appropriateRBCs el iminated all but eight ana ly t e s as CoPCs (Table 2-1 in che HHRA report). CoPCsinc lude two metals (arsenic and manganese) , three PAH compounds <bcn/.o(a)anthracene,bcn/o(a)pyrene and bcn/o(b)lluoranthcnc. Total PCBs, and the pesticides a idnn and dieldrin.

Based on these exceedances, these analytes were further evaluated by comparing the measuredtissue concentrations to the RBCs (Table 2-2 in the HHRA report). Aldnn and dieldnn wereel iminated as CoPCs based on this screening as they were not detected in any of the tissuesamples. Manganese is not on EP.A's l i s t of bioaccumulativc chemicals and has nocorresponding Bioaccumulation Factor (BAF), and thus was not retained as a CoPC. Theremaining analytcs i n i t i a l l y identified as CoPCs were retained as CoPCs for further quan t i t a t ivensk ana lys i s .

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In summary, the human hea l th CoPC screening process ident i f ied the fo l lowing chemical classesand compounds as CoPCs:

• Metals: arsenic;

• P.AHs: ben/o(a)anihracene. ben/o(a)pyrene. and ben/o(b)lluoranthene; and

• Total PCBs.

Human h e a l t h risk c a l c u l a t i o n s were conducted on these iden t i f i ed tissue CoPCs as summarizeds n the f o l l o w i n g section.

Human Health Risk Characterization. In order to evaluate potential risks associated w i t h thei d e n t i f i e d t i ssue CoPCs, exposure assessments (estimates of the magnitude, frequency anddura t ion of exposure) and t o x i c i t y assessments {assessment of potential adverse heal th effects ofthe CoPCs) were used to develop numerical human health nsk estimates. Exposure pointconcent ra t ions were est imated from the data for she highest exposures reasonably expected tooccur.

Exposure parameters required inc lude body w e i g h t , exposure duration, averaging t ime , which arecommon to all or most exposure pathways, and fish ingestion rate, exposure frequency andfraction ingested from the contaminated source, w h i c h would be variable for given populations.Selection of these factors for adults, adolescents, and children is described in Section 3,3.2 of theH H R A report. These factors and the exposure point concentrations were used to quant i fychemical intakes for each segment of ;he popula t ion. The chemical in takes for the f i v e tissueCoPCs were then evaluated in terms of to.xicity risks to humans using hazard iden t i f i ca t ion anddose-response assessment for carcinogenic and non-carcinogenic nsks.

Carcinogenic effects co h u m a n s from exposure to chemicals were estimated quan t i t a t i ve ly usingcancer slope factors (CSFs) that convert estimated exposures to incremental l i f e t ime cancer nsks.and us ing EPA classif icat ions for potential carcinogens (classes def in ing known , probably,possible, etc., carcinogens). Of the l i v e t issue CoPCs. arsenic is a Group A carcinogen or hask n o w n carcinogenic effects, w h i l e the remainder are Group B2 carcinogens or agents for w h i c hthere is suf f ic ient evidence for carcinogcnicity in an ima l s but inadequate or lack of evidence inhumans .

Cancer nsks were characterized as the incremental increase in the probabi l i ty that an i n d i v i d u a lwou ld develop cancer during his or her l i fe t ime due to site-specific exposure. The term"incrementa l" implies the nsk due to environmental chemical exposure above the backgroundcancer risk experienced by all i n d i v i d u a l s in the course of dai ly l i fe . For example, a 2x10 'cancer nsk means that for every one m i l l i o n people exposed to the carcinogen under thespc-eihod exposure conditions throughout the i r l i f e t imes , ihe incidence of cancer may inereo.se bytwo cases.

The combined nsk from exposure to m u l t i p l e chemicals was evaluated by adding the nsks fromi n d i v i d u a l CoPCs for adults, adolescents and children. The tPA considers action to bewarranted at a site when the total carcinogenic nsk to a receptor exceeds 1C"4 (tPA 19*) I ) .Action is generally not required for risks f a l l i n g w i t h i n 104 lo 10°; however, th is is judged on aca.se-by-cuse basis. Risks less than 10 '' usua l ly arc not of concern to regulatory agencies.

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The Reasonable Maximum Exposure i R M E j nsks were ca lcu la ted tor adult , adolescent and chi ldreceptors (summan/ed in Tables 7-1 to Table ~ - 3 in the H H R A report). R i s k s from exposures toArsenic, ihe three P.AHs and to t a l PCBs were each greater t han 10'° for all receptors (adult,adolescent and ch i ld) : the respective combined risks were 1 x 10'", 2 x 10° and 6 x 10"". In eachcase, the majority of risks were due to beiiAMaipyrcnc. Risks were higher for adult exposuresdue to a subs tan t i a l ly higher rate of f i sh ingestion and exposure duration. As the calculated nsksto adul ts , adolescents and chi ldren are w i t h i n F.PA's acceptable nsk range of I x l O ~ to 1 x l O 0 ,r isks to these receptor groups due to carcinogenic effects is considered acceptably low.

In the present study, all PCB congeners were non-detect for the crab samples. A few positivedetections tor d iox in - l ikc congeners were observed in fish samples from two stations. Toaddress the dioxin-like toxiciiy of these PCB detections, dioxin lo.xic equivalence concentrations(TECs) were calculated to evaluate potential for d iox in - l ike toxic i ty associated wi th PCBs. Themaximum calculated TEC concentration for the two fish samples was 1.62 x 10 mg/kg. Usingt h i s v a l u e as the tPC v a l u e for d iox in . a r isk v a l u e of 2.6 x 10"6 for d i o x i n - l i k e PCB congenerswas obtained. From this calculation, it is clear that the dioxin-likc congeners contributed little tothe observed overa l l nsk to adult receptor ( R M E nsk = 1 \ 10 ").

Non-carcinogenic effects were evaluated using chrome reference doses, which define the dailyexposure l i k e l y lo be w i t h o u t appreciable nsk of adverse effects during a lifetime. The sole non-carcinogenic tissue CoPC was arsenic. Estimated exposure point concentrations for arsenic werean order of magnitude below reference dose values for each population (adul t , adolescent andchi ld receptors). As arsenic was the o n l y CoPC contr ibut ing to the total non-cancer risk resul t ingfrom the f i sh ingest ion, and HI v a l u e s were < 1. i t was concluded that acceptable nsks to allhuman receptor populations were present for consumption of non-carcinogenic chemicals in fishand she l l f i sh due to recreational f i s h i n g in the FNOD Offshore area.

2.8. DOCUMENTATION OK SIGNIFICANT CHANGES

No s i g n i f i c a n t changes have been made to the "No Further Action" decision selected in theProposed Plan.

3. RESPONSIVENESS SUMMARY

1'he Proposed Plan document pertaining to th i s Record of Decision has been submitted for publicr e v i e w . This Responsiveness Summary summarizes public participation completed in support ofthe ROD. A Responsiveness Summary is required by CERCLA to provide a summary of cm/encomments and concerns about the site, as raised dunng the public comment period, and theagency responses to those concerns.

3.1. BACKGROUND ON COMMUNITY PARTICIPATION

The U S . Army Corps of Engineers (USACE) completed the Proposed Plan for the OffshoreArea at the FNOD in Suffolk . Vi rg in ia , in December, 2003 (USACE 2003). The USACE,Norfolk District, together w i t h the F.PA Region I I I . and the Vi rg in ia Department ofEnv i ronmen ta l Quality (VDtQ), established a public comment penod from December 4, 2003.to January 4. 2004, for interested parties to comment on US ACE's Proposed Plan for theOffshore Area.

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A pub l i c meeting was held on December 4. 2003, i n order to provide the pub l i c more detailedinformation and opportunity to comment on the rat ionale for the selected a l te rna t ive of "NoFunher Act ion" presented in the Proposed Plan .

At the tune of the Public Comment Penod. the preferred a l te rna t ive for the Offshore Area at theFNOD m S u f f o l k . V i rg in i a addressed the rat ionale for "No Further Action." The "No FurtherAct ion" a l t e r n a t i v e presented m the Proposed Plan was based on the f i n d i n g s of previousi n v e s t i g a t i o n s w h i c h determined that there are no ex is t ing and potential nsks to human healthand '.be env i ronment .

No copies or the Proposed Plan were picked up at the Informat ion Resource Center: severalcopies were obtained by members of the pub l i c at the public meeting for r e v i e w . There were noquest ions or comments received from i n d i v i d u a l s in at tendance at the publ ic meeting onDecember 4, 2003.

3.2. STAKEHOLDER ISSUES AND AGENCY RESPONSE

The p u b l i c comment penod was held for 30 days, from December 4, 2003. to January 4. 2004.No comments were received by the U.S. Env i ronmen ta l Protection Agency ( E P A ) Region I I I . theVi rg in ia Department of Envi ronmenta l Qua l i ty , or the Norfolk District of the U.S. Army Corpsof Engineers in response to the publ ic comment period or at the publ ic meeting held onDecember 4. 2003. As no comments were received, no agency response is required.

The fact tha t no comments were received during the public comment penod supports the "NoFurther Act ion" remedy. As a result , the preferred alternative of "No Further Action" has beenselected al the Offshore Area as presented in the Proposed Plan.

3.3. TECHNICAL A N D LEGAL ISSUES

There are no t echn ica l or legal issues to be resolved regarding the Offshore Area and NFAdetermina t ion .

4. ACRONYMS

AtiT Apparent Effects ThresholdAOC Area of ConcernAR.ARs Applicable or Appropriate and Relevant RequirementsAVS Acid Volati le SulfideBAF Bioaccumulation FactorCERCLA Comprehensive E n v i r o n m e n t a l Response. Compensation, and L iab i l i ty ActCoPC Chemical of Potential ConcernCSF Cancer Slope FactorBERA Baseline Ecological R i sk AssessmentDEP Department of Environmental ProtectionDERP Defense Environmental Restoration ProgramDQO Data Quali ty ObjectiveEPA United States h n v i r o n n i e n i a i Protection AgencyERA Ecological Risk AssessmentER-L Effects Ran^e-Low

IS

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ER-.M Effects Range-MediumFNOD Former Nansemond Ordnance DepotFUDS Formerly Used Defense SiteGE General ElectricHHR.A Human Hea l th R i s k AssessmentILRSD Hampton Roads Sanitat ion Distr ictHQ Hayard QuotientLO.AEL Lowest Observed Adverse Effects LevelM I . I . W M ea n Lowe r Low WaterNCP Nat ional Oil and Hazardous Substances Po l lu t ion Cont ingency PlanNFA No Further ActionNOAA Nat iona l Oceanic and Atmospheric Adminis t ra t ionNOAbL No Observed Adverse Ef fec t s LevelNOS Nat ional Oceanographic SurveyNPL National Priority ListPAH Polycycl ic Aromatic HydrocarbonsPCB Polychlorin-ated B i p h e n y l sPEL Probable Effects LevelPP Proposed PlanPRP P o t e n t i a l l y Responsible PansRAGS Risk Assessment Guidance for SuperfundRAO Remedial Action Object iveRBC Risk-Based ConcentrationRME Reasonable M a x i m u m ExposureROD Record of DecisionSARA Superfund Amendments and Reauthonzat ion ActSEM Simultaneously Extracted MetalsSI.F.R.A Screening I .eve) Ecological Risk AssessmentSPI Sediment P r o f i l e ImageTAL Target Anal vie ListTEL Threshold Effects Leve lTCC l iuevvater Communi ty CollegeTRV Toxicity Reference DoseUSACE United States Army Corp of EngineersUXO Unexploded Ordnance

5. RLFKRENCJiS

l-'nster \Vhoeler f - n v i r o n m e n t a l Corporation. I1JUJ8. Final Engineering Evaluat ion/Cost A n a l y s i s ;Former Nansemond Ordnance Depot. October.

SAIC. 2002. Baseline Ecological R i sk Assessment (BER.A) for Former Nansemond OrdnanceDepot. Prepared for: USACH- Norfolk Distr ict . September.

SAIC 2002h. Human Health Risk Assessment for the Offshore Area of the Former NansemondOrdnance Depot, Internal Draft Prepared for: USACE- Norfolk Distr ict . December.

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USACE ( U . S . .Army Corps of Engineers ) . 2000. Draf t F i n a l Sue Management P l a n . FormerNansemond Ordnance Depot. Prepared by Norfolk District. Norfolk, VA. J a n u a r y .

USACL ( U . S . Army Corps of Engineers). 2003. Proposed Plan for the Marine Offshore Area ofibc Former Nansemond Ordnance Depol. USACE- Norfolk Disinci . December. 2003.

l.'SF.PA ( I m:ed States E n v i r o n m e n t a l Protection A g e n c y ) . 1989. Superfund ( R A G S ) . \ 'olumeI , H u m a n Heal th Eva lua t ion Manual . Pan A .

USEPA. 1991. R i s k Assessment Guidance for Superfund, Volume I , Human Health Eva lua t ionM a n u a l . Part B. I n t e r i m F i n a l . O f f i c e of Solid Waster and Emergency Response.

USEPA. 1992. Calcu la t ing the Concentration Term. Risk Assessment Guidance for Superfund,Volume I ; Human H e a l t h E v a l u a t i o n Manual . Supplemental Guidance. Off ice of SolidWaste and trr.crg.ency Response. Publication 9285.7-081. May 1902.

USEPA < Uni ted States Envi ronmenta l Protection Agency » . 1997. The Incidence and Seventy ofSediment Contamination in Surface Waters of the United States. Vol. 1: National SedimentQ u a l i t y Survey. EPA 823-R-97-006. US Envi ronmenta l Protection Agency . Office ofScience and Technology, Wash ing ton . DC,

l.'SF.PA. 1999. Ha/ardous R a n k i n g System Documentation Record from the Former NansemondOrdnance Depot - HRS Scoring Package. J anua ry .

USEPA. 2 o O I . Supcrfundi .R.AGS). Volume I . Human Health Eva lua t ion M a n u a l , Part D.

USEPA. 2002. EPA Region ( I I Risk-Based Concentration Table,hup:/'/wsvsv.epa.gov/reg3 hwmd/'risk/rbc 1002.pdf

Weston. Roy P. Inc.. 2000. Draft: Risk Based Cleanup Criteria James R i v e r Beachfront InlenmRemoval Action, Nansemond Ordnance Depot. Suf fo lk . VA. Prepared for U.S. ArmyCorns of Engineers, Bal t imore , MD. J u K .

20

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Figure I I Location ol the Former Nansemoiid Oulnance Depot (FNOD) in Suflolk, VA.

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