semspub.epa.gov › work › 03 › 157435.pdf · 2229 Tomlynn Street, Suite 100, Richmond, Virginia 23230 w June 21,1996 ^ g 4 Mr. Jeff Dodd (Mail Code: 3HW33) U.S. Environmental

2229 Tomlynn Street, Suite 100, Richmond, Virginia 23230

wJune 21,1996 ^ g 4

Mr. Jeff Dodd (Mail Code: 3HW33)U.S. Environmental Protection Agency, Region inRemoval Enforcement SectionHazardous Waste Management Division303 Methodist Building11th & Chapline StreetsWheeling, West Virginia 26003

TelephoneSubject: Submittal of Final Engineering Evaluation/Cost Analysis, June 19,1996

Potomac Yard, City of Alexandria, and Arlington County, Virginia 804.358.5400EPA Docket No. HI-92-61-DCEARTH TECH Job NO. 1725-014 Emergency

DearMr.Dodd:

On behalf of Mr. Scott Slagley, Project Coordinator for the Richmond, Fredericksburg, andPotomac Railroad Company (RF&P), EARTH TECH is pleased to submit the enclosed 804.358.5084revised text, tables, and figures (pages 1 through 78), and Appendix H of the FinalEngineering Evaluation/Cost Analysis (EE/CA) for Potomac Yard. The enclosed pages havebeen revised per U.S. Environmental Protection Agency (EPA) comments dated June 17,1996, and replace all text, tables, and figures included in the Final EE/CA, dated May 6,1996. Also enclosed are responses to the June 17, 1996 EPA comments. Appendices Athrough G have not been revised and, therefore, are not attached.

The EE/CA is being submitted in accordance with the requirements of the amendedAdministrative Order by Consent between RF&P and EPA (Docket No. II I -92- 61 -DC),paragraph 8.3.c.iv.

The text and table revisions of the Final EE/CA are being shipped separately to those personslisted below. If you have any questions, please contact Mr. Scott Slagley at (804) 225-1608.

Sincerely,

Christdph&K. MosesSenior Vice President

Enclosure

E A R T H S = l T E C H

R E M E D I A T I O N S E R V I C E S

Formerly Environmental Technology of North America

Mr.JeffDoddJune 21,1996Page 2

cc: Fran Burns, EPA Region El, Removal Enforcement SectionHiron Sikdar, EPA Region III Technical Assistance TeamWilliam J. Skrabak, Chy of Alexandria Health DepartmentJeffrey L. Ham, Arlington County Environmental Service DepartmentCynthia Sale, Virginia Department of Environmental QualityPat McMurray, Virginia Department of Environmental QualityDenton U. Kent, RF&PScott Slagley, RF&PChanning J. Martin, Esq., Williams, Mutlen, Christian & DobbinsKristine Endy, Consolidated Rail CorporationGibson Barbee, Norfolk Southern CorporationKeith Drinker, CSX TransportationTom Golojuch, The Weinberg Group

E A R T H = - I T E C H

R E M E D I A T I O N S E R V I C E S

ARI 082 10

Final EngineeringEvaluation/Cost AnalysisPrepared for:Richmond, Fredericksburg, and Potomac Railroad Company (RF&P)600 E. Main StreetRichmond, Virginia 23219

Site:Potomac YardAlexandria and Arlington County, Virginia

Prepared by:EARTH TECH Remediation Services2229 Tomlynn StreetRichmond, Virginia 23230

Revised June 19, 1996

ETRS Job No. 1725-014

082 I I

RESPONSES TO EPA COMMENTS DATED JUNE 17, 1996

I. Modifications to the EE/CA

A. Section 3.4.1 - North Yard Removal Schedule and Drainage Pathways

L The first sentence of the third paragraph on Page 26 of the EE/CA ishereby modified as follows: "During construction activities, a StormwaterPollution Prevention Plan $PPP) will be prepared and implemented inaccordance with VPDES General Permit for Storm Water Discharges fromConstruction Site requirements. As part of the SPPP, erosion and sediment(E&S) controls will be installed to minimize migration of sediments andcontact with impacted materials. The SPPP will be reviewed by EPA,VDEQ, City of Alexandria and County of Arlington to ensure that the SPPPand E&S controls will provide for the maximum level of protection tomitigate the release of contaminated materials from the Site. Inspectionsof the E&S controls implemented under the SPPP will be conducted byEPAt VDEQt City of Alexandria and/or County of Arlington personnel toensure that the E&S controls are being adequately implemented duringconstruction activities.

Response: The sentence has been revised to read as suggested (see page 26).

2. The last paragraph under the subsection titled "Drainage Areas NY-3 andNY-4" on page 28 is modified as follows:

"Outfall NY-3 will not be used after development of the PYRC. Outfall NY-4 will convey piped stormwater runoff from PYRC. PYRC stormwater thatdischarges from outfall NY-4 will be piped flow that passes through aninfiltration gallery and wet pond prior to reaching the outfall Thestormwater will be conveyed through new pipes and will not contact railyard material (see Plate 3-2). After development, stormwater quality willbe regulated under Commonwealth of Virginia stormwater regulations (seeSection 7.1)."

Response: The paragraph has been revised to read as suggested (see page 28).

B. Section 3.4.3 • Potomac Greens Removal Schedule and Drainage Pathways

L The modified language provided in section LA. I above is hereby insertedafter the fourth sentence of the third paragraph on page 31 of thedocument.

Response: The paragraph has been revised to read as suggested (see page 31).

MWP\R\W&rWOTOMAOCOMMENTS.DOC(ADD) /June 19, 1996 fl R I fl fl ? I

C. Section 4*1 - Effectiveness

L The first sentence of the first paragraph of this section is modified asfollows: "Table 4-1 at the end of this section presents an evaluation of theeffectiveness of the above-mentioned alternatives for each area of PotomacYard.19


D. Table 4-4 - Applicable or Relevant and Appropriate Requirements (ARARs)

L Table 4-4 is modified to include the following State ARARs:

a. Virginia State Water Control Law, Code of Va. 62.1-44.2 si sea.:Virginia Water Quality Standards (VR 680-21-00); and the VirginiaPollutant Discharge Elimination System (VPDES) Regulations (VR680-14-01).

b. Virginia Air Pollution Control Law, Code of Va. 10.1-1300 & seq.:Virginia Regulations for the Control and Abatement of Air Pollution(VR 120-01).

Note: Excavation of soil should be in compliance with the ambientair quality standards for paniculate matter contained in VRCAAP120-03-02 and 120-03-06, and the standards for lead contained in120-03-08, as -well as the standards of performance for visibleemissions and fugitive dust emissions from a new source containedin 120-05-0104. Under 120-05-014, sources of fugitive dustemissions must take precautions to prevent paniculate matter form[sic] becoming airborne.

c. Virginia Erosion and Sediment Control Law, Code of Va. 10.1-560Si seq.; and the Virginia Erosion and Sediment Control Regulations(VR 625-02-00). (Requirements satisfying these regulations areestablished in local stormwater management ordinance.)

d Chesapeake Bay Preservation Act, Code of Va. 10.1-2100 gt seq.:Chesapeake Bay Preservation Area Designation and ManagementRegulations (CBPA Regulations) (VR 173-02-01). (Requirementssatisfying these regulations are established in local stormwatermanagement ordinance.)

e. Virginia Stormwater Management Act Code of Va. 10.1-603.1 ftsea,: Virginia Stormwater Management Regulations (VR 215-02-00).(Requirements satisfying these regulations are established in localstormwater management ordinance).

Response: The table has been revised to included the suggested regulations(see page 60).

I:\WP\K\KF&P\POTOMACCOMMENTS.DOC(ADD) /June 19, 1996 _ . 2

ARI082I3

E. Section 5.1 - Comparative Analysis of North Yard Removal Action Alternatives -Short-Term Effectiveness

1. This section is modified by inserting the following sentence immediatelybefore the last sentence of this section: "However, a Storm WaterPollution Plan (SPPP) will be prepared and implemented in accordancewith the VPDES General Permit for Storm Water Discharges fromConstruction Site requirements. As part of the SPPP, erosion and sediment(E&S) controls will be installed to minimize migration of sediments andcontact with impacted materials. * In addition, "however" shall be deletedfrom the last sentence of the section.

Response: The section has been revised to read as suggested (see page 62).

F. Section 6.1 - Recommended North Yard Removal Action Alternatives

1 This section is modified to insert the following sentence immediately beforethe ninth sentence of this section; "However, a Storm Water PollutionPlan (SPPP) will be prepared and implemented in accordance with VPDESGeneral Permit for Storm Water Discharges from Construction Siterequirements. As part of the SPPP, erosion and sediment (E&S) controlswill be installed to minimize migration of sediments and contact withimpacted materials. " In addition, "however" shall be deleted from the lastsentence of the section.

Response: The section has been revised to read as suggested (see page 68).

G. Section 7.1 - Quarterly Stormwater Monitoring

L The last sentence of the second paragraph in this section is modified asfollows: "During construction activities, the discharges from the site willbe managed under a VPDES General Permit for Stormwater Dischargefrom Construction Sites. Appendix H includes the Commonwealth ofVirginia VPDES General Permit for Stormwater Discharge fromConstruction Sites permit regulations and/or requirements. "


2. The second to [sic] last sentence of the third paragraph is modified to readas follows: "If concentrations of constituents exceed AWQCs, otherappropriate criteria as determined by EPA, or increase from the presentlevel RF&P will discuss with EPA the need for further action. *


I:\WP\RW&P\POTQMAOCOMMENTS.DOC(ADD) /June 19, 1996 A R I 0 8 ? I tl

3. The EE/CA is modified to include a new Appendix H which shall includea copy of the Commonwealth of Virginia VPDES General Permit forStormwater Discharge from Construction Sites permit regulations and/orrequirements.

Response: Appendix H has been included as suggested.

H. Table 7-7 - Summary of Proposed Monitoring Plans

I. The analyses required for North Yard Outfall SS-2 is modified to includedissolved and total lead,

2. The analyses required for the South Poind [sic] Ditch outfall is modifiedto include analysis for beta-chlordane, not gamma-chlordane as indicated.

Response: The table has been revised to read as suggested (see page 76).

f:Wft\R\RFAP\POTOMAOCOMMENTS.DOC(ADD) /June 19. 1996

RESPONSES TO EPA COMMENTS DATED APRIL 17,1996

General Comments

A. The re-revised document should be titled as the Final Engineering Evaluation/CostAnalysis (EE/CA).

Response: The re-revised document is entitled Final Engineering Evaluation/CostAnalysis (EE/CA).

B. Several sections of the EE/CA (See Sections 3.2, 3.4, 3.4.1, 3.4.2, 3.4.3.t 6.1) state thatonce final development occurs at various areas of the Site, stormwater will not come intocontact with, or allow transport of, contaminants present at the Site to Four Mile Run orthe Potomac River. The EE/CA indicates that final development of the site will includethe use of a best management practice (BMP) pond(s)t wetpond(s), infiltration galleries,infiltration trench(es) and new stormwater drainage pipes. The document however, doesnot provide any further information on how these structures will mitigate the release ofcontaminants from the Site to Four Mile Run and the Potomac River. The documentmust be revised to indicate how these structures work, how the structures will beconstructed so that surface water will not come into contact with contaminants ofconcern, and how the structures will mitigate the release of contaminants of concernfrom the Site to Four Mile Run and the Potomac River.

Response: Sections 3.2, 3.4, 3.4.1, 3.4.2, 3.4.3, and 6.1 have been revised to state thatafter final development, the site will be covered with an impermeable material (e.g.,asphalt, concrete). Stormwater leaving the site will not have contacted the potentiallyimpacted rail yard/Potomac Greens material. Instead, the stormwater will only contactthe impermeable surface or newly installed subsurface pipes (see pages 22, 24, 26, 28-30, and Appendix C). Section 3.4.1 includes an explanation of how the stormwatermanagement structures function and how they mitigate the potential release ofconstituents of concern. Appendix D contains the design specifications for thesestructures.

C. Several Sections of the EE/CA (see Sections 3.4.1, 3.4.2) state that final development ofvarious areas of the Site will effectively mitigate concentrations of constituents instormwater runoff. No data are presented to verify these statements. In addition,Sections 3.2 and 3.4.2 state that stormwater quality will be regulated by Commonwealthof Virginia stormwater management regulations. However, the EE/CA does not identifyhow the stormwater quality will be regulated or whether monitoring of the stormwaterquality will occur upon discharge to Four Mile Run or the Potomac River. In theresponse to EPA's comments (E.4andF.3) of December 22, 1995, Respondent indicatedthat sampling and analysis of stormwater discharged to Four Mile Run and the PotomacRiver will be conducted upon implementation of final stormwater management andsediment controls. However, Section 7.1 and Table 7-1 do not indicate the sampling ofstormwater discharge to Four Mile Run and the Potomac River upon final development(and hence implementation of final surface water control measures at the site). TheEE/CA must include a discussion of how the effectiveness of final surface water/sediment

l:\Wpyt\RF&FM>OTOMACVCOMMENTS.DCX:/May6. 1996

ARI082I6

£

control measures taken as a part of development will be verified through either: 1)monitoring of the discharge of stormwater from the Site to Four Mile Run and/or thePotomac River for the contaminants of concern after implementation of final stormwatercontrol measures; 2) monitoring of stormwater quality under Commonwealth of Virginiastormwater management regulations for contaminants of concern at the Site.

Response: Sections 3.2, 3.4.1, and 3.4.2 have been revised to explain more clearly howdevelopment will mitigate concentrations of constituents in stormwater runoff. Afterfinal development, the site will be covered with an impermeable material (asphalt,concrete). Stormwater will flow across the impermeable surface into new, subsurfacepipes to stormwater management structures prior to discharging to Four Mile Run or thePotomac River. Sediments currently present at outfalls that will continue to be used afterdevelopment will be removed and/or the pipes will be replaced. The remaining existingoutfalls will be closed. Hence, creating a physical barrier between stormwater and railyard/Potomac Greens materials on the surface (e.g., asphalt, buildings, topsoil) and in thesubsurface (pipe conduits) eliminates any contact between stormwater and potentiallyimpacted material. In addition, the asphalt and concrete will stabilize the sediments andprevent their migration off site by physically holding them in place (see page 22).

Upon implementation of this EE/CA, outfalls which receive stormwater that hascontacted rail yard/Potomac Greens material will be monitored (see Table 7-1). RF&Panticipates implementing the removal action alternatives within three months of EPA'sapproval of the EE/CA Work Plan. Construction activities associated with the PotomacYard Retail Center may continue for longer than a three-month period after EPA'sapproval. Therefore, RF&P will monitor outfalls which continue to receive stormwaterthat has contacted rail yard material during the implementation period. Afterdevelopment, outfalls which are either closed or receive stormwater that has notcontacted rail yard/Potomac Greens material will be monitored in accordance withCommonwealth of Virginia stormwater management regulations. The regulations havebeen attached as Appendix G (see page 73).

Specific Comments

A. Section 1.0- Introduction

1. The third paragraph (page 4) of this section indicates that this EE/CA satisfiesthe final requirement of the Consent Order. This paragraph should be modifiedto indicate that the off-site ecological risk assessment must also be completedbefore the work to be performed section of the Consent Order is completedFurthermore, this section of the document should indicate that once the EE/CAand off-site ecological risk assessment are completed, then only the work to beperformed portions of the Consent Order is completed. Furthermore, thissection of the document should indicate that once the EE/CA and off-siteecological risk assessment are completed, then only the work to be performedportions of the Consent Order will have been completed. Please also see thefirst paragraph of the Executive Summary (page I).

Response: The reference to the EE/CA being the final requirement of the- Consent Order has been deleted (see pages 1 and 4).

l:\WP\R\RF&P\POTOMAOCOMMENTS.DOC/May6,1996 A R I D ft 9 I 7

2. The last sentence of the fourth paragraph (page 4) of this section should be>y revised to read as follows: "EPA approved the Revised ECS on September 19,

7995, after receiving the Supplemental Document."


3. The second sentence of the first bullet listed under #7 on page 5 of this section ofthe document must be revised as follows: "The concentrations of constituents ofconcern detected in surfacewater and sediments must not exceed EPA-approvedlimits, including but not limited to AWQCs, or other criteria protective ofecological receptors."


B. Section 2.1.2 - Type of Facility and Operational Status/Intermodal (Piggyback) Area

7. This section of the document (page 11) should be revised to indicate thehistorical uses of this area of the Site.

Response: Historical uses of the Intermodal (Piggyback) Area have been added(seepage II).

C. Section 2.1.6 - Sensitive Ecosystems

-~- 7. This section of the document (page 14) should be revised to reference the\j appropriate sections of the on-site ecological risk assessment which discuss

sensitive ecosystems at the Site.

Response: Section 4.1 of the on-site ecological risk assessment has beenreferenced (see page 14).

D. Section 2.3 - Extent and Nature of Contamination

7. The last sentence of the first paragraph (page 17) must be modified to indicatethat the ECS indicated potential (not determined) sources of contamination atthe Site are the cinder-based ballast, the fly ash, former oil/water separatorponds, off-site stormwater, ASTs, USTs and associated foel lines.

Response: The sentence has been modified as suggested (see page 17).

2. The top of page 15 lists the constituents of concern as identified by the riskassessment. Beta-chlordane is a pesticide and should be identified as such in thedocument.

Response: Beta-chlordane is identified as a pesticide (see page 18).

l:\Wpy \RF&I POTOMAOCOMME rrS.CXX:/May6,1996 3

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E. Section J. J - Determination of Removal Goals and Objectives

7. The fifth sentence of the first paragraph indicates that the EE/CA evaluates,proposes and reviews alternatives to mitigate the release of constituents ofconcern detected in stormwater and sediments from Potomac Yard to AWQCs.It would be more appropriate to indicate that the EE/CA evaluates, proposes andreviews alternatives to mitigate the release of constituents of concern detected insurfacewater and sediments from Potomac Yard to Four Mile Run and thePotomac River.


F. Section 3.4.7 - North Yard Removal Schedule and Drainage Pathways

7. The discussion concerning drainage area SS~4 (page 26) should indicate that thedischarge from SS-4 did not exceed TSVs and reference the appropriate Sectionsor Tables in the risk assessment.

2. Response: The discussion concerning drainage area SS-4 (page 27) has not beenrevised. A statement indicating that the discharge from SS-4 did not exceedTSVs and referencing the appropriate Sections or Tables in the risk assessmentwas already included.

X'-N

. 3. The discussions concerning drainage areas SS-l, SS-4 and NY-3 should indicatethat stormwater quality will be regulated under Commonwealth of Virginiastormwater regulations after final development of the Site.

Response: The discussions concerning drainage areas SS-l, SS-4 and NY-3 havebeen revised to indicate that stormwater quality will be regulated underCommonwealth of Virginia stormwater regulations after final development ofthe Site (see pages 27 and 28).

G. Section 3.4.3 - Potomac Greens Removal Schedule and Drainage Pathways

L The EE/CA states that a new drainage ditch or pipe will be installed in thenorthern portion of Potomac Greens to convey all stormwater from the southernportion of the rail yard. Metrorail tracks, and the northern portion of PotomacGreens to the existing culvert under the George Washington Parkway as part offinal development activities hence eliminating the use of the north and middleponds and drainage ditches. Although the EE/CA states that the new ditch orpipe mil not be constructed though the fly ash area of Potomac Greens, theEE/CA does not provide specify how a drainage ditch will be constructed tominimize contact with contaminated materials or control the migration ofsediments during construction of the new drainage ditch. The EE/CA mustindicate how the new drainage ditch will minimize contact with contaminatedmaterials and how migration of sediments will be controlled duringconstruction.

l:\WP\R\RFAPtfOTOMAOCOMMENTS.DOC/May 6,1996

Response: The section has been revised to describe how a drainage ditch will beconstructed to minimize contact with contaminated materials and control themigration of sediments during construction of the new drainage ditch. Designspecifications for the ditch have been included as Appendix E (see page 30).

2. The EE/CA states (page 30) that the Metrorail pipes and pipes from the rail yardeast of the Central Operations Area will be rerouted during track relocation sothat no pipes discharge into the Middle Pond ditch (see Plate 3-4). However,plate 3-4 does not clearly show how or where these existing pipes will bererouted. The EE/CA also states (page 29 and 30) that two drainage ditches inaddition to the middle pond ditch enter the north pond ditch on-site and twoother drainage ditches enter the south pond ditch on-site. However the EE/CAdoes not clearly explain what the fate of these ditches will be or how surfacewater/sediments in these ditches will be managed. The EE/CA must be revisedto clearly indicate where and how these pipes will be rerouted and the fate ofthese other drainage ditches and how surface water and sediments from theseother ditches will be managed

Response: Plate 3-4 has not been revised. Instead, drawings showing thelocation of the rerouted storm sewer pipes have been included as Appendix F.The EE/CA has been revised to explain that none of the secondary ditches wereidentified as potential pathways of concern during the Extent of ContaminationStudy. Unlike the North, Middle, and South Pond ditches, which drainedstormwater from the from retention ponds, none of the secondary ditches drainareas of known or potential on-site sources of contamination (see pages 31 and

H. Table 4-1

L The comments on overall protection of human health and the environment forseveral removal options (e.g. north yard - temporary sediment controls, sedimentremoval) indicate that the removal option is consistent with non-time criticalremoval action objectives, however they are unnecessary fie., cost-ineffective.inefficient) given current and future Site conditions. It appears that theseremoval options would be unnecessary given the time frame for finaldevelopment of the North Yard rather than being cost ineffective or inefficient.Similarly for other options, e.g., North Yard Tail - sediment removal; PotomacGreens - temporary sediment controls, sediment removal, the EE/CA indicatesthat the removal action alternative would not be cost-effective nor efficient givencurrent and future Site conditions. Further explanation of why the removalaction alternative is not cost effective or efficient must be addressed in thedocument.

Response: References to removal action alternatives being cost-ineffective orinefficient have been deleted from Table 4-1 .

2. The EE/CA discusses the removal option, "regrade ditches and close outfalls"for the North Yard Tail and ultimately recommends this removal actionalternative for this area of the Site (Section 6.2). However, the EE/CA does notdiscuss what the fate of the surface water/sediments will be once the outfalls in

L-\Wpyt\RFAPyOTOMAOCOMMENTS.DOC / May 6,1996

the North Yard Tail have been closed until final development of the North YardTail occurs and stormwater management structures are constructed. The EE/CAmust discuss the fate of the surface water/sediments under this recommendedremoval action.

Response: After the outfalls are closed and the North Yard Tail regraded,stormwater will infiltrate into the subsurface. Because stormwater will not beflowing off site, sediments will not be carried off site (see page 68).

3. This table states that "current site conditions pose acceptable risk to humanhealth" under the "comments on overall protection of human health and theenvironment" section. This comment should be modified to state that the currentconditions do not pose an unacceptable threat to human health.

Response: Table 4-1 has been revised as suggested.

Section 4.2, Section 6.1 and Table 7-7

L The last bullet item in Section 4.2 states, "proposed monitoring techniques toevaluate the effectiveness of the removal action alternatives." Therecommended removal action alternative (RRAA) for North Yard outfalls anddrains is "no action" (Section 6.1). The EE/CA proposes quarterly monitoringof stormwater at the North Yard outfalls SS-lt SS-2 and SS-3 (Table 7-1). It isnot understood how stormwater monitoring will help in evaluating a "noaction ". Furthermore, the EE/CA specifies that the drainage pipe in the NorthYard Tail will be extended through the North Yard Tail ditch. Table 7-7specifies that the North Yard Tail ditch will be sampled until the pipe has beenextended off-site. Again, it is not understood how stormwater monitoring of theNorth Yard Tail ditch will help evaluate the effectiveness of this finaldevelopment action. The EE/CA does not identify the actions to be taken in theevent the level of contamination in the stormwater samples increases from thepresent level or exceeds A WQCs. The EE/CA must be revised to include actionsthat may be taken in the event the level of contamination in the stormwatersamples increases from the present level, or exceeds A WQCs.

Response: Stormwater monitoring will not be conducted to evaluate a "noaction** alternative or to evaluate the site under the same conditions as existedduring the ECS investigation (see Section 7.1 and Table 7*1). The North Yardoutfalls at which A WQCs have previously been exceeded will be monitoredduring construction activities if 1) construction continues longer than threemonths after EPA's approval of the EE/CA Work Plan and 2) the outfallscontinue to receive stormwater which has contacted rail yard material. Onceconstruction is complete, stormwater leaving the North Yard will be monitoredin accordance with Commonwealth of Virginia stormwater managementregulations (attached as Appendix G).

RF&P anticipates that the 108-inch diameter Arlington County pipe will beextended to the property line prior to EPA's approval of the EE/CA Work Plan.Stormwater from the rail yard will not enter this pipe. Therefore, no monitoringof the North Yard Tail Ditch is proposed.

l:\WP\R\RF&P\POTOMAOCOMMENTS.DOC/May6,1996

Analytical data will be forwarded to EPA lifter each monitoring event. Uponreceipt, RF&P and EPA will discuss the results and the need for any furtheraction (see page 73).

J. Section 6.1

L In the original draft EE/CA. "no action" way not an option for North Yardoutfalls, but in the revised draft EE/CA it is the RRAA. During the developmentof North Yard, soil in the area will be disturbed and there is a potential ofadditional contaminants discharging into Four Mile Run and the Potomac Riverthrough run-off during precipitation. The EE/CA did not identify this as apotential problem. The EE/CA must be revised to address this potentialproblem.

Response: The EE/CA has been revised to address the potential of additionalconstituents discharging into Four Mile Run and the Potomac River duringdevelopment activities. However, the potential will be mitigated by theimplementation of erosion and sediment (E&S) controls during constructionactivities. The E&S controls will be installed in accordance with thespecifications and procedures required by the Virginia Erosion and SedimentControl Handbook (1992) (see pages 26,62 and 68).

X. Section 6.3.1 - North and Middle Pond Ditches

L This section of the EE/CA should specify that the drainage ditches will beplugged with bentonite to keep sediments in place prior to backfilling (seeFigure 3-4).

Response: The EE/CA specifies that the drainage ditches will be plugged withbentonite to keep sediments in place prior to backfilling (see page 69).

L. Section 6.3.2 - South Pond Ditch

7. The third last sentence of this section should be modified as follows: "Thesealternatives will require sampling and analysis of the discharge and periodicinspection, testing, and possible removal of accumulated sediments."


M. Table 6-1

7. The time frame/duration, "implement within a reasonable time frame" for theNorth Yard Tail removal options for outfalls SS-5, SS-6, SS-7 is too vague.These removal action alternatives should be implemented after the removalactions have been selected for this area of the Site and final work plans forimplementation of the removal actions have been approved by EPA.

Response: Table 6-1 has been revised to indicate that the North Yard Tailremoval actions will be implemented after the removal actions have been

l:\WIAR\RF&P\POTOMAOCOMMEKTS.DOC/May6,1996

selected for this area of the Site and final work plans for implementation of theremoval actions have been approved by EPA.

2. The comments for the north and middle pond ditches should indicate that theditches will be plugged with bentonite and backfilled.

Response: The comments in Table 6-1 have been revised as suggested.

N. Table 6-land Table 4-3

7. In Table 6-1, the RJKAA for the North Pond and the Middle Pond ditches is"regrade and reroute stormwater" and the RRAA for the South Pond ditch is"remove sediment and temporary sediment controls ". In Table 4-3, the costs foreach removal action were not presented separately for each ditch. This madethe cost comparisons for proposed removal actions difficult. The costs for eachremoval action must be presented separately for each ditch in Table 4-3.

Response: The costs for each removal action has been presented separately foreach ditch in Table 4-3.

O. Section 6.2 and Table 6-1, Section 5.2, Paragraph 2

L The following inconsistencies were found in the EE/CA regarding theconsideration of RRAA for the North Yard Tail ditch:

a) In Table 6-1, the RRAA for the North Yard Tail ditch was identified as"regrade and reroute stormwater" without involving any costs. In thefootnote of Table 6-1, it is noted that the rerouting costs have beenconsidered as development costs. Regrading costs are not addressed inthe revised draft EE/CA.

Response: The footnote in Table 6-1 has been revised to state that thererouting and regrading costs are considered development costs.

b) Section 6.2 does not identify a RRAA for the North Yard Tail ditch.Section 6.2 must discuss the actions which will be taken to address therelease of contaminants from the North Yard Tail ditch.

Response: Section 62 has been revised to identify the extension of theArlington County 108-inch pipe as the removal action for the NorthYard Tail ditch (see page 68).

P. Table 7-1

L The analyses listed for the North Yard Tail ditch and South Pond ditch do notcorrespond to those compounds of concern (COCs)for this outfall as determinedin the risk assessment (Tables 4-26 and 4-27). The COCsfor each outfall whereSite surface water/sediments are discharged to Four Mile Run and the PotomacRiver should be in agreement with the COCs identified in the risk assessment.

l:\WP\R\RF&P\POTOMAOCOMMEMTS.DOC/May6,1996

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Response: The COCs for each outfall where Site surface water/sediments are• j discharged to Four Mile Run and the Potomac River have been revised so that

they are in agreement with the COCs identified in the risk assessment (see Table7-1).

2. Visual inspections of the stormwater discharges (SS-2t SS-3, north pond ditch.middle pond ditch) that are closed should be conducted and noted in the Table.

Response: Table 7-1 has been revised as suggested.

!:\WPVR\RF&Py>OTOMAOCOMMENTS.DOC / May 6.1996

Final EngineeringEvaluation/Cost AnalysisPrepared for:Richmond, Fredericksburg, and Potomac Railroad Company (RF&P)600 E. Main StreetRichmond, Virginia 23219

Site:Potomac YardAlexandria and Arlington County, Virginia

Prepared by:EARTH TECH Remediation Services2229 Tomlynn StreetRichmond, Virginia 23230

Revised June 20, 1996

ETRS Job No. 1725-014

AHI08225

TABLE OF CONTENTS

EXECUTIVE SUMMARY .................................................. 1

1.0 INTRODUCTION................................................... 4

2.0 SITE CHARACTERIZATION .......................................... 82.1 Site Description and Background ................................... 8

2.1.1 Site Location ........................................... 82.1.2 Type of Facility and Operations Status ......................... 82.1.3 Structures/Topography ................................... 122.1.4 Geology/Soil Information ................................. 122.1.5 Surrounding Land Use and Populations ....................... 132.1.6 Sensitive Ecosystems .................................... 142.1.7 Meteorology .......................................... 14

2.2 Previous Removal Actions ...................................... 152.3 Extent and Nature of Contamination ................................ 172.4 Analytical Data .............................................. 192.5 Future Development Plans ...................................... 202.6 Potential Risks............................................... 20

3.0 IDENTIFICATION OF REMOVAL ACTION SCOPE, GOALS, AND OBJECTIVES .. 223.1 Statutory Limits on Removal Actions ............................... 223.2 Determination of Removal Scope .................................. 223.3 Determination of Removal Goals and Objectives ....................... 233.4 Determination of Removal Schedule................................ 23

3.4.1 ' North Yard Removal Schedule and Drainage Pathways ............. 243.4.2 North Yard Tail Removal Schedule and Drainage Pathways .......... 283.4.3 Potomac Greens Removal Schedule and Drainage Pathways .......... 30

3.5 Planned Remedial Actions ....................................... 33

4.0 IDENTIFICATION AND ANALYSIS OF REMOVAL ACTION ALTERNATIVES .... 344.1 Effectiveness ................................................ 344.2 Implementability ............................................. 354.3 Cost ...................................................... 364.4 Applicable or Relevant and Appropriate Requirements (ARARs) ............ 364.5 Removal Action Alternatives ..................................... 37

4.5.1 North Yard Removal Action Alternatives ....................... 374.5.2 North Yard Tail Removal Action Alternatives ................... 384.5.3 Potomac Greens Removal Action Alternatives ................... 38

5.0 COMPARATIVE ANALYSIS OF REMOVAL ACTION ALTERNATIVES ......... 615.1 Comparative Analysis of North Yard Removal Action Alternatives .......... 6!5.2 Comparative Analysis of North Yard Tail Removal Action Alternatives ....... 635.3 Comparative Analysis of Potomac Greens Removal Action Alternatives ....... 65

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6.0 RECOMMENDED REMOVAL ACTION ALTERNATIVES .................... 686. 1 Recommended North Yard Removal Action Alternative .................. 686.2 Recommended North Yard Tail Removal Action Alternative ............... 686.3 Recommended Potomac Greens Removal Action Alternative ............... 69

6.3.1 North and Middle Pond Ditches ............................. 696.3.2 South Pond Ditch ....................................... 69

6.4 Maintenance of Control Measures ................................. 69

7.0 MONITORING PROGRAMS .......................................... 737.1 Quarterly Stormwater Monitoring ................................. 737.2 Annual Ground Water Monitoring ................................ 74

8.0 REFERENCES .................................................... 78

Figures

Figure 2-1 Site Location and Topography ..................................... 9Figure 3-1 Potomac Yard Development Schedule .............................. 25Figure 7-1 Ground Water Monitoring Locations ............................... 75

Tables

Table 4-1 Removal Action Alternatives: Effectiveness ........................... 40Table 4-2 Removal Action Alternatives: Implementabiiity ........................ 50Table 4-3 Removal Action Alternatives: Relative Costs .......................... 59Table 4-4 Applicable or Relevant and Appropriate Requirements (ARARs) ............ 60Table 6-1 Recommended Removal Action Alternatives .......................... 70Table 7-1 Summary of Proposed Monitoring Plans ............................. 76

Appendices

Appendix A EPA EE/CA Approval Memorandum for Potomac Yard (dated October 6, 1995)Appendix B Plates

Plate 3-1 North Yard and North Yard Tail Drainage Patterns (Pre-Development)Plate 3-2 North Yard and North Yard Tail Drainage Patterns (Post-Development)Plate 3-3 Potomac Greens Drainage Patterns (Pre-Development)Plate 3-4 Potomac Greens Drainage Patterns (Post-Development)

Appendix C Interim Use Stormwater FlowAppendix D Design Specifications for PYRC Stormwater Management StructuresAppendix E Design Specifications for the Potomac Greens DitchAppendix F Post-Development Location of Stormwater Pipes Currently Discharging to the

Middle Pond DitchAppendix G Commonwealth of Virginia Stormwater Management RegulationsAppendix H Commonwealth of Virginia VPDES General Permit for Stormwater Discharge

from Construction Sites Regulations/Requirements (VR 680-14-19)

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EXECUTIVE SUMMARY

This Engineering Evaluation/Cost Analysts (EE/CA) identifies a limited number of removal actionalternatives appropriate to address the removal action objectives for Potomac Yard in Alexandria andArlington County, Virginia, as presented in the United States Environmental Protection Agency (EPA)EE/CA Approval Memorandum dated October 6, 1995. Based on the evaluation of the identifiedalternatives, this EE/CA recommends the implementation of specific removal action alternatives. Althoughthe EE/CA recommends alternatives, EPA will use the information provided in the EE/CA to select theremoval action alternative ) to be implemented. EPA will select die alternatives) after receiving publiccomments on the EE/CA, in accordance with the National Contingency Plan. Included in this EE/CA isa general description for implementing recommended removal actions at Potomac Yard. Once EPA selectsthe removal action alternative, Richmond, Fredericksburg, and Potomac Railroad Company (RF&P) willprepare a detailed work plan that describes specific procedures and includes a schedule for implementingthe selected alternatives. This EE/CA is being submitted in accordance with the requirements of theAdministrative Order by Consent and an Amendment thereto (Consent Order) between RF&P and EPA(Docket No. III-92-61-DC), paragraph 8.3.c.iv. This EE/CA has been written in accordance with the EPAGuidance on ConductingNon-Timc-Critical Removal Actions under CERCLA(Guidance Document)(EPA1993).

The scope of this EE/CA is limited to the North Yard, North Yard Tail, and Potomac Greens areas ofPotomac Yard because the drainage outfalls from Potomac Yard to Four Mile Run and the Potomac Riverare located in these areas. The drainage outfalls are the pathways by which constituents of concern couldpotentially migrate from the site. If these pathways are eliminated, then Potomac Yard will not impactFour Mile Run and the Potomac River. The scope of this EE/CA is to provide interim solutions withineach of the drainage pathways until the area has been developed and the migration pathways (outfalls) areremoved or closed.

The goal of this EE/CA is to evaluate and recommend removal action alternatives that not only mitigatethe concentrations of constituents of concern in stormwater and sediments leaving the site and enteringFour Mile Run and the Potomac River, but also are consistent with future site conditions and developmentplans. Development is important to the goals of the EE/CA because as part of development, the majorityof the pathways that allow sediments to be transported off site will be closed. In addition, the constructionof buildings, roadways, and parking lots, landscaping, and new subsurface pipes will place a barrierbetween potential sources of constituents of concern and stormwater.

This EE/CA recommends "no action" as the removal action alternative for the North Yard becausedevelopment is scheduled to occur within six months of the date of this document Development willeliminate most outfalls; those that wilt continue to be used will discharge stormwater that has beenconveyed through new pipes. Stormwater will not contact rail yard material prior to entering the new,subsurface pipes because the North Yard will be covered with impermeable materials (asphalt andbuildings). The rail yard material is the source of the constituents of concern identified in the RevisedRisk Assessment (Weinberg 1995). If development of the North Yard is postponed, alternatives other than"no action" will be considered.

The recommended removal action alternative for the North Yard Tail is "regrading ditches and closingoutfalls." As part of development activities scheduled to occur in summer 1996, the Arlington County

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stormwater pipe will be extended through the North Yard Tail to the Potomac Yard property line. Whenthe North Yard Tail is developed, rerouting stormwater via subsurface pipes is likely to occur. Closing

\~S outfalls will not only eliminate the potential migration pathway for constituents of concern, but is alsoconsistent with development plans.

This EE/CA recommends "regrading ditches and rerouting stormwater" as the removal action alternativefor the North and Middle Pond Ditches on Potomac Greens. This alternative coincides with developmentplans and is protective of human health and the environment As part of track relocation, a ditch or pipewill be installed through the northern portion of Potomac Greens. The ditch or pipe will be constructedso that stormwater will not contact Potomac Greens soils; it will convey all stormwater currently carriedby the North and Middle Pond Ditches. Backfilling the ditches will prevent contact between stormwaterand the sediments in the ditches, which is the source of the constituents of concern identified in theRevised Risk Assessment (Weinberg 1995). Implementing this option is a long-term solution for thenorthern portion of Potomac Greens.

The recommended removal action alternative for the South Pond Ditch on Potomac Greens b acombination of "temporary sediment controls" (rip rap) and "sediment removal." Sediment removalprotects the environment by removing the source of the constituents of concern. Placing rip rap in theditch will prevent future erosion of the ditch. The South Pond Ditch will continue to receive stormwaterat the head of the ditch until 1998. After 1998, runoff from the City of Alexandria stormwater may bererouted as part of development in the southern portion of Potomac Greens. The recommended optionsfor the South Pond Ditch are protective of human health and the environment, are consistent with futuredevelopment plans, and provide a long-term solution for the South Pond Ditch.

,s*<*\ This EE/CA evaluates and compares alternatives other than the recommended removal actions.v,' . Alternatives evaluated in this EE/CA are effective in mitigating potential risks to ecological receptors in

Four Mite Run, Potomac Greens and the Potomac River; can be implemented in a timely manner; and arecost efficient. The following removal action alternatives were evaluated and compared for the North Yard,the North Yard Tail, and Potomac Greens:

• No Action;• Temporary Sediment Controls (e.g., silt fence, check dam, rip rap until replacement of

drainage structure as part of development);• Sediment Removal from Ditches and Pipes;• Regrading Ditches and Closing Outfalls (eliminating the use of existing outfalls); and/or• Regrading Ditches and Rerouting Stormwater (continued use of outfalls).

The removal action schedule for the North Yard is defined by the development schedule. Developmentof the North Yard will begin in the summer of 1996, at which time the existing stormwater outfalls willbe closed or repiped within a short time period. The removal action will coincide with the developmentactivities. The schedule for implementing of the removal action for the North Yard Tail is defined by theneed to mitigate potential releases off site between the time the EPA approves the EE/CA and the timeof development, which will principally take place in 1999. Within three years of implementing a removalaction, the portion of the North Yard Tail adjacent to Four Mile Run will be developed. The schedulefor implementing of the removal action for Potomac Greens is defined by the time frame for reroutingwater away from the North and Middle Pond Ditches and the planned long-term use of the South Pond

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Ditch. The removal actions implemented for the South Pond Ditch will be implemented upon approvalof the EE/CA, and the removal action for the Middle and North Porid Ditches will coincide with theplanned rerouting.

Monitoring of stormwater leaving Potomac Yard will be conducted to verify the effectiveness of thesediment controls (see Section 7.1). Quarterly monitoring of stormwater runoff will be conducted for oneyear once sediment control measures are in place. At the end of the first year, stormwater data will bereviewed by EPA to determine the frequency of future monitoring. Stormwater runoff samples will becollected from Four Mile Run outfalls and from on-site Potomac Greens outfalls. The samples will beanalyzed for parameters that were identified as constituents of concern in the Revised Risk Assessment(Weinberg 1995). RF&P will compare the results of this analysis to chronic Ambient Water QualityCriteria (AWQCs) values.

Although the Revised Risk Assessment (Weinberg 1995) showed that ground water is not a pathway ofconcern to receptors, per EPA's request, RF&P will monitor ground water to verity that constituents arenot migrating at a rate or at concentrations which pose risks to receptors. RF&P will monitor groundwater downgradient of the Central Operations Area once a year until the Virginia Department ofEnvironmental Quality (VDEQ) notifies RF&P that free product remediation in the Central OperationsArea is complete. Ground water samples will be collected from monitoring wells MW-44 and MW-45and analyzed for polychlorinated biphenyls (PCBs).

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1.0 INTRODUCTION

This Engineering Evaluation/Cost Analysis (EE/CA) presents a comparative analysis of a limited numberof applicable alternatives to mitigate the potential release of constituents from Potomac Yard whichpotentially affect ecological receptors in the Potomac River, Four Mile Run, and Potomac Greens;establishes a quarterly monitoring program for constituents of concern at discharge points to Four MileRun and the Potomac River; and establishes a ground water quality sampling program downgradient ofthe portion of the rail yard known as the Central Operations Area, This EE/CA identifies a limitednumber of removal action alternatives appropriate for addressing the objectives. Although the EE/CArecommends specific removal action alternatives, the United States Environmental Protection Agency(EPA) will use the information provided in the EE/CA to select the removal action alternative ) to beimplemented. EPA will select the alternatives) after receiving public comments on the EE/CA inaccordance with the National Contingency Plan. This document was prepared in accordance with the U.S.Environmental Protection Agency (EPA) Guidance on Conducting Non-Time-Critical Removal Actionsunder CERCLA (Guidance Document) (EPA 1993).

In addition, this EE/CA provides a general description for implementation of recommended removalactions at Potomac Yard. Once the EPA selects the removal action alternative, RF&P will prepare adetailed work plan that describes specific procedures and includes a schedule to be followed duringimplementation of the selected alternatives.

In accordance with an Administrative Order by Consent and an Amendment thereto (collectively the"Consent Order") between Richmond, Fredericksburg, and Potomac Railroad Company (RF&P), thecurrent property owner, and EPA (Docket No. III-92-61-DC), RF&P prepared and submitted an Extentof Contamination Study (ECS) (ETI I995a) that describes the nature and extent of contamination atPotomac Yard. RF&P has also prepared and submitted to the EPA a Human Health Risk Assessment andOn-Site Ecological Risk Assessment (Weinberg 1995) for Potomac Yard.

The ECS (ETI 1995a), an environmental study during which more than 450 samples were collected andanalyzed for 134 analytes and compounds, was conducted at Potomac Yard between July 1992 andNovember 1994. The ECS evaluated the collected data and described the nature and extent ofcontamination at Potomac Yard. After reviewing the ECS, EPA requested additional information, and theECS was revised. The Revised ECS was submitted to EPA on July 21, 1995. Pursuant to City ofAlexandria comments on the ECS, EPA requested an additional document. Potomac Yard EnvironmentalActivities: Supplemental Information (Supplemental Document) (ETI 1995b), dated July 31, 1995, wasprepared to provide information concerning non-ECS-related environmental activities conducted atPotomac Yard. EPA approved the Revised ECS on September 19,1995, after receiving the SupplementalDocument

A Risk Assessment (RA) was prepared, based principally on the information contained in the RevisedECS. RF&P submitted the RA to EPA on June 7, 1995. Subsequent to receiving the RA, EPA madecomments (July 17, 1995, and September 22, 1995) and requested a Revised RA. The RA was revisedand submitted to EPA on October 4, 1995 (Weinberg 1995). EPA approved the Revised RA onOctober 13, 1995. The Revised RA addressed potential risks to both human health and the environmentusing analytical data collected for and presented in the Revised ECS. The Revised RA is comprised oftwo parts: the Human Health Risk Assessment (HHRA) and the on-site Ecological Risk Assessment

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,

(ERA). The primary objective of the HHRA was to evaluate potential risks to human health associatedwith exposure to chemicals at Potomac Yard in its present state and as a result of anticipated developmentactivities. The HHRA demonstrated that Potomac Yard does not pose unacceptable risks to human health.

The objective of the ERA was to determine if chemicals associated with Potomac Yard have the potentialto affect the structure, function, or interactions of biological populations and communities within PotomacYard. The ERA used a screening-level assessment approach in which estimated exposure concentrationswere compared to screening-level toxicity values, such as ambient water quality criteria (A WQCs). Themain concerns identified in the ERA were potential site-related impacts on the ecological receptors of FourMile Run, the Potomac River, and Potomac Greens.

In EPA's EE/CA Approval Memorandum, based on the Approved RA and signed on October 10, 1995(see Appendix AX EPA required RF&P to address the following concerns in an EE/CA:

I. Evaluate, propose, and review alternatives to mitigate the release of contaminants from PotomacYard which potentially may be affecting the ecological receptors in the Potomac River, Four MileRun and Potomac Greens areas.

Factors to be considered in this evaluation, proposal, and review of alternatives to mitigatethe release of contaminants at Potomac Yard should include, but not necessarily be limitedto, the following:

* Mitigating the release of constituents of concern from Potomac Yard via surface water andsediment to Four Mile Run and the Potomac River. The concentrations of constituentsof concern detected in surface water and sediments must not exceed EPA-approved limits,including but not limited to AWQCs, or other criteria protective of ecological receptors.

• Establishing a quarterly monitoring program for constituents at all discharge points to thePotomac River and Four Mile Run to evaluate the effectiveness of the measures) selectedand approved by the EPA to mitigate the release of constituents to Four Mile Run, thePotomac River, and Potomac Greens.

• Conducting ground water quality sampling downgradient of the Central Operations Areato monitor for potential migration of constituents in this area of Potomac Yard.

* Evaluating the nature and extent of constituents in sediments from the Potomac River andFour Mile Run to determine ecological risks associated with current and historical releasesfrom Potomac Yard.

2. Develop and submit an "off-site ecological risk assessment" based on the additional data collectedfrom Four Mile Run and the Potomac River sediment sampling, as well as data collected as partof the ECS already completed at the site.

The work plan for the off-site study of the nature and extent of contamination in Potomac River and FourMile Run sediments (Item I - Bullet 4, and Item 2) is not included in this EE/CA. As agreed betweenRF&P and EPA in a letter dated October 31, 1995, the preparation of a work plan for the Off-Site

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Ecological Risk Assessment, the study, and the assessment will be conducted as a separate task. The DraftWork Plan for Off-Site Ecological Risk Assessment for Potomac Yard was submitted to EPA onDecember 21, 1995.

The Approved RA identified the drainage outfalls from Potomac Yard to Four Mile Run and the PotomacRiver as the pathways by which constituents of concern potentially leave the site. If these pathways areeliminated, then Potomac Yard will not impact Four Mile Run or the Potomac River. The outfalls arelocated in the following areas of Potomac Yard: North Yard, North Yard Tail, and Potomac Greens.Hence, the scope of this EE/CA is limited to these areas of Potomac Yard. This EE/CA presentsapplicable removal action alternatives and evaluates each option in terms of the removal action scope,goals, and objectives and overall protection of human health and the environment. The effectiveness,implementability, and cost analyses of each alternative are presented in table format. The table formatpresents the information more clearly and concisely than a narrative format. In the comparison ofalternatives, this EE/CA considered the following factors: consistency with the removal action objectives;short- and long-term effectiveness; ability to reduce toxicity, mobility, or volume of constituents ofconcern; overall protection of human health and the environment; technical feasibility; compliance withapplicable or relevant and appropriate requirements (ARARs); and cost. Based on the comparativeanalysis, this EE/CA recommends a removal action alternative for the North Yard (No Action), the NorthYard Tail (Regrading Ditches and Closing Outfalls), and Potomac Greens (Regrading Ditches andRerouting Stormwater - North and Middle Pond Ditches; Temporary Sediment Controls and SedimentRemoval - South Pond Ditch). If development is postponed, alternatives other than "no action" will beconsidered for the North Yard.

A brief description of the organization of the remainder of this document is set forth below:

Section 2.0, Site Characterization, describes Potomac Yard and provides an overall description ofoperations at Potomac Yard. A discussion of the site-specific geology, ground water occurrence and flow,and meteorology is included in this section. Current surrounding land use and future land use plans forPotomac Yard are also described. Finally, this section summarizes previous removal actions at PotomacYard, the findings of the ECS, and the potential ecological risks identified in the Approved RA. SincePotomac Yard will be developed in the near future, structures and topography are not discussed.

Section 3.0, Identification of Removal Action Scope, Goal, and Objectives, identifies the removalaction scope, goals, and objectives for Potomac Yard. This section also sets forth a removal actionschedule and discusses future remedial actions for Potomac Yard.

Section 4.0, Identification and Analysis of Removal Action Alternatives, identifies and evaluates alimited number of alternatives that satisfy the removal action objectives, scope, and schedule for the NorthYard, the North Yard Tail, and Potomac Greens.

Section 5.0, Comparative Analysis of Removal Action Alternatives, compares the removal actionalternatives presented for each area of Potomac Yard.

Section 6.0, Recommended Removal Action Alternatives, recommends a removal action alternative atthe North Yard, the North Yard Tail, and Potomac Greens. The section also describes the evaluation

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process used in selecting the recommended removal action alternative and provides a cost estimate for the, implementation and maintenance of each recommended option.

Section 7.0, Monitoring Programs, presents specific stormwater and ground water monitoring programsfor Potomac Yard, as required in the EE/CA Approval Memorandum from EPA.

Section 8.0, References, provides a list of documents and sources used to prepare this report.

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COOOeoa

2.0 SITE CHARACTERIZATION

This section provides an overall description of historical operations at Potomac Yard; a discussion of thesite-specific geology, ground water occurrence and flow, and meteorological conditions at the site; currentsurrounding land use and future land use plans for Potomac Yard; and a summary of previous removalactions at Potomac Yard, the findings of the ECS, and the potential ecological risks identified in theApproved RA.

2.1 Site Description and Background

2.1.1 Site Location

Potomac Yard is located in the 2800 and 2900 blocks of Jefferson Davis Highway (U.S. Route 1) in theCity of Alexandria and Arlington County, Virginia, and is owned by RF&P. Potomac Yard is situatedwithin the United States Geologic Survey (USGS) City of Alexandria, Virginia-Maryland-District ofColumbia 7.5 Minute Series Topographic Map at 38 degrees, SO minutes north latitude, and 77 degrees,3 minutes west longitude (see Figure 2-1).

Potomac Yard includes the areas known as the rail yard (approximately 304 acres) and Potomac Greens(approximately 38 acres). Potomac Yard occupies a long, relatively narrow area extending from CrystalCity in Arlington County, Virginia, south to Braddock Road in the City of Alexandria, Virginia. PotomacYard is approximately 2.7 miles long and has a maximum width of approximately 2,000 feet near itscenter. Potomac Yard is bounded on the west by Jefferson Davis Highway (U.S. Route 1) and on the eastby George Washington Memorial Parkway, both of which are major commuter routes serving the area ofWashington, D.C. Crystal City, an urban development of high-rise office and hotel buildings, is locatednorth of the property, and Washington National Airport is to the northeast. Residential and lightcommercial developments are to the west, south, and southeast of Potomac Yard. The Arlington CountyWater Pollution Control Plant (WPCP) is located west of Potomac Yard. The pipe conveying dischargefrom the WPCP empties into Four Mite Run approximately 0.4 mile upstream of Potomac Yard.Daingerfield Island, which is managed by the U.S. National Park Service, and the Potomac River are tothe east of the site. Four Mile Run, a perennial stream that flows east to the Potomac River, divides thenorthern portion of Potomac Yard. Several military installations and a sewage treatment plant (BluePlains) are located across the Potomac River from Potomac Yard.

Potomac Yard is comprised of the following areas: Central Operations Area, North Yard, North Yard Tail,South Yard, South Yard Tail, Intermodal Area, and Potomac Greens. Figure 2-1 depicts each area of thesite. Descriptions of these areas and former operational uses of them are provided in Section 2.1.2.

2.1.2 Type of Facility and Operations Status

RF&P has owned Potomac Yard since 1906. Potomac Yard was operated by RF&P (in conjunction withother railroads) as a receiving and classification switch yard from 1906 to 1990. The classification andswitching tracks have been removed from Potomac Yard along with rail yard structures as part of"downsizing" the rail yard (i.e., reducing rail operations). The remaining active railroad components,which are currently owned and operated by CSX Transportation, Inc. (CSXT), consist of six yard trackson the eastern portion of the rail yard used for temporary storage of rail cars and mainline ("through")

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gpSs WOffTW YARD TAIL-;«j > tf • •(• .v... .. —• »—• • - — —— ^ k*N n Mr '

'CENTRAL OPERATIONS >U?EA"E ipcrrouAC GREENS

SOURCE:U.S.G.S. 7.5 MINUTE TOPOGRAPHIC QUADRANGLEALEXANDRIA, VA-D.C.-MD. 1965PHOTOREVISEO 1983 2000 0 2000 4000

CONTOUR INTERVAL - 10 FEET

ICAOO nLC: fc\OWG\BU)CKS\TOPO.OwC

PROJECT:

POTOMAC YARDALEXANDRIA. VIRGINIA

PROJECT UANACCR:C.K.U.

DRAWN 9f;

PROJCCT NO.:1725-OU

REVIEWER:R.HJ.

E A R T H & J T E C H

R E M E D I A T I O N S E R V I C E SFORMERLY OMRONueMTAL TECHNOLOGY OF NORTH AMERICA

FIGURE TITLE:

SITE LOCATIONAND TOPOGRAPHY

DATE:02/12/96

SOU:SHOWN

FIGURE NO.:: 2-1

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tracks on the western portion of the rail yard. RF&P ceased all railroad operations at Potomac Yard inOctober 1991. RF&P and CSXT are developing plans to relocate all mainline tracks to the eastern edgeof the rail yard. Relocation of the tracks is scheduled for summer 1996.

All but two buildings and work areas formerly located in the rail yard have been removed duringdownsizing of Potomac Yard. The only buildings remaining on the site are the office building andMetrorail substation. The substation is on a section of property leased to the Washington MetropolitanArea Transit Authority (WMATA), and WMATA is responsible for operating this building. Thesebuildings and operating areas, which existed prior to downsizing the rail yard, are described in Section2.2 of the Revised ECS (also see Plate 2-2 of the Revised ECS).

Central Operations Area

The Central Operations Area encompasses the area of the rail yard where the majority of the site buildingswere located. Most refueling and maintenance operations took place in this area. The Central OperationsArea is bordered by Jefferson Davis Highway to the west and the Metrorail Yellow Line to the east Itextends south to Swann Avenue and north to the northern edge of a parking lot adjacent to the southboundhump (see Figure 2-1).

Historically, the Central Operations Area was used to service, maintain, clean, and repair "yard"locomotives used on site. This area was used most recently for repair and servicing of track-maintenanceequipment. The former diesel-electric locomotive refueling area and a transformer/miscellaneousequipment storage area were once located within the Central Operations Area. An electrical substationhousing transformers was also located in the Central Operations Area. This substation and a secondsubstation near Four Mile Run have both been removed. All transformers, except a dry transformer (i.e.,no oils) which services the office building, have been removed from the site.

North Yard

The North Yard is defined as the area south of Four Mile Run, east of Jefferson Davis Highway, west ofthe Metrorail Yellow Line, and north of the southbound hump parking lot. Northwest of the main officebuilding was the car shop building, formerly used for rail car maintenance and repair. Numerous otherbuildings used for storage, maintenance, or yard activities (e.g., hump air compressor building, waste oilstorage building) were clustered near the car shop building. The former electric locomotive yard, whichwas used for minor repair, service, and maintenance of the electric locomotives, was also located near thecar shop building. An electrical switching substation was also formerly located north of the car shop andimmediately south of Four Mile Run. Former fuel lines and storage tank locations within the North Yardare depicted in Figure 2-3 of the Revised ECS.

A concrete oil/water separator was located northwest of and adjacent to the southbound hump area as partof the oil-collection system. The separator was installed in the late 1970s or early 1980s and was removedby RF&P in 1994.

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North Yard Tail

The North Yard Tail is bounded by Four Mile Run on the south, Crystal City on the north, Crystal Driveand Jefferson Davis Highway on the west, and the Metrorail Yellow Line and Washington NationalAirport on the east. The North Yard Tail consisted mainly of railroad switching tracks, which narrowedto the north and merged into five main rail lines near the northern terminus of the site. A lube oiltank/switch air compressor building and 250-gaIlon-capacity aboveground storage tanks (ASTs) were alsopresent. The ASTs were used to store fuel for heating ("de-icing") switches, fueling equipment, and/orheating track signal buildings. All structures in the North Yard Tail have been removed as a part ofdownsizing activities. Located west of the North Yard Tail is the WMATA bus maintenance and repairfacility, which has been in service since the 1930s. Various light industries and businesses are also locatedalong the western side of Jefferson Davis Highway.

South Yard

The South Yard extends from Swann Avenue to the Monroe Avenue Bridge, between Jefferson DavisHighway to the west and the Metrorail Yellow Line to the east Since the 1950s, the South Yard wasused for southbound classification and northbound receiving. A car oil tank was located near the centerof the South Yard.

South Yard Tail

The South Yard Tail is defined as the area bounded by Braddock Road to the south, the Monroe AvenueBridge to the north, the Metrorail Yellow Line to the east, and Jefferson Davis Highway to the west TheSouth Yard Tail consisted primarily of railroad switching tracks, which narrowed to the south and mergedinto four main rail lines near the southern terminus of the site. The area is surrounded by residential areasand businesses. A switch air compressor building was located south of the Monroe Avenue Bridge.

Intel-modal (Piggyback) Area

The Intermodal Area is bounded to the north by the vegetation line marking the southern border ofPotomac Greens. Potowmack Crossing residential units are along its eastern side. The area is boundedto the south by commercial property along Slaters Lane. The western border of this area is marked bythe Metrorail Yellow Line, although a portion of the Piggyback Area extends over the undergroundMetrorail tunnel. Intermodal (piggyback) transport involves the movement of loaded truck trailers onrailroad flat cars or cars of special design. In this area, truck trailers were loaded and unloaded to andfrom flat cars. A Washington and Old Dominion (W&OD) Railroad overpass previously crossed PotomacYard in this area and existed from the 1800s until its demolition in 1969. An engine house associatedwith the W&OD line was located in the southeast portion of the Intermodal Area from the early 1960suntil 1990.

Potomac Greens

The area to the east of the Metrorail Yellow Line and west of the George Washington Memorial Parkwayis known as Potomac Greens and consists of approximately 38 acres (see Figure 2-1). Potomac Greensoccupies the lowest area of Potomac Yard with surface elevations ranging from approximately 7 feet

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above mean sea level (msl) at the northern end of Potomac Greens to more than 29 feet above msl at thesouthern end (U.S. Department of the Interior, 1989). Bordering Potomac Greens to the east across theGeorge Washington Memorial Parkway is the 109-acre parkway system recreational area known asDaingerfield Island.

Potomac Greens was not used for rail operations. However, a fly ash deposition area and a dredge spoilsdeposition area are located on Potomac Greens. Three former retention (oil/water separator) ponds werelocated on Potomac Greens. These ponds were removed in 1993.

2.13 Structures/Topography

Because Potomac Yard will be developed in the near future, structures and topography are not discussedin this section of the EE/CA. A description of surface water and site drainage is included in Section 23.2of the Revised ECS. A detailed discussion of individual drainage pathways on Potomac Yard is presentedin Section 3.2.

2.1.4 Geology/Soi! Information

The geology of Potomac Yard was delineated from surface to bedrock on the basis of logged boreholesat the site. Plate 2-4 of the Revised ECS shows the location of boreholes at the site. The boring logs arepresented in Appendices B through F of the Revised ECS.

The stratigraphic sequence at Potomac Yard consists of six units. In descending order, these units include:ballast material, fill material, Shirley Formation, Patapsco Formation, Arundel Clay Formation, andPatuxent Formation. This section describes the ballast material, fill material, and Shirley Formation. Adescription of the remaining formations is provided in Section 2.3.3 of the Revised ECS.

Ballast Material

Two types of ballast material have been identified in the near-surface material at Potomac Yard. Thesematerials include gravel ballast and cinder ballast Most of the surface area of the rail yard is coveredwith a layer of stone or gravel ballast. Gravel ballast is a material used in a railroad bed to support theties, hold the track in line, and facilitate drainage. When the ECS investigation began (July 1992), thegravel ballast layer was up to 2 feet thick in parts of the rail yard. Since that time, much of the ballasthas been removed from areas no longer occupied by track. A layer approximately 6 inches thick remainsin these areas.

Cinder ballast lies beneath the gravel ballast over most of the rail yard. Cinder ballast consists of ashfrom coal-powered steam locomotives used prior to the advent of diesel-electric locomotives in the 1950s.Cinder ballast is found at depths of up to 8 feet, with an average thickness of 3 feet. Cinder ballast is notfound in the North Yard Tail, an area of the rail yard that was developed in the 1950s after the steamlocomotive era. Cinder ballast is not found in the Intermodal Area or Potomac Greens.

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Quaternary Sediment fFtll Material and Shirlev Formation)

A significant portion of surficial soils along the Potomac River in the area of Potomac Yard has beendisturbed as a result of urban development. Disturbed areas include filled areas within tidal marshes andwetlands (Obermeier 1986).

The composition and variable distribution of sediments of the Shirley Formation and much of the fillmaterial are simitar. Because it is difficult to distinguish between these units in the augered borehole logs,they are described here as one unit The Quaternary sediments extend to a depth of approximately 40 feet(-10 msl) at Potomac Yard.

Much of Potomac Yard has been cut and filled by regrading fill material at the site. Analysis of the grainsize of the material beneath the ballast layer in the North and South Yard Tails shows it is high in sandand clay content, with grain sizes ranging from 0.0002 to 0.002 millimeter (mm) (clay) to 0.05 to 2.0 mm(sand). This material has low to moderate permeability [3.73 X 10"* feet/day (ft/day) to 3.21 X 10~*ft/day] (see Table 2-8 of the Revised ECS and Appendix G of the Revised ECS). The Quaternarysediments at the rail yard consist primarily of silly and clayey sand (SM-SC) with soft to stiff, lean clay(CL), and occasional deposits of clayey gravel (CG) and poorly graded sand (SP). The Quaternarysediments at Potomac Greens contain more clay (CL) and silt (SM), with silt-size fly ash and dredgespoils. Characteristics of soils at the Potomac Greens are presented on Table 2-10 of the Revised ECS.The distribution of these soil materials in the subsurface at Potomac Yard is shown on the hydrogeologiccross-sections (Plates 2-5 through 2-7 of the Revised ECS).

Ground Water Occurrence and Flow at Potomac Yard

Shallow ground water occurs at depths ranging from approximately 10 feet to 25 feet below groundsurface (bgs). The ground water elevations in monitoring wells at the site range from approximately 5feet to 33 feet msl (see Appendix H of the Revised ECS).

Ground water at the site south of Four Mile Run flows eastward toward the Potomac River and Four MileRun. Immediately north of Four Mile Run (the North Yard Tail), ground water flows south. Furthernorth of Four Mile Run, the pumping of ground water from basements in the Crystal City developmentalong the northern edge of the North Yard Tail creates a hydraulic depression and a localized reversal ofground water flow toward the north and west (Plate 2-8 of the Revised ECS).

2.1.5 Surrounding Land Use and Populations

Potomac I'ard is located in the southeastern portion of Arlington County and the northeastern portion ofthe City of Alexandria, Virginia, across the Potomac River from Washington, D.C. Potomac Yard iscentrally located in a development corridor extending from the Pentagon on the north to Interstate 95 onthe south. Potomac Yard is one of the largest undeveloped tracts of land in the urban core of theWashington, D.C., area. Potomac Yard is bounded on the:

North by Washington National Airport and the large-scale hotels and office buildings of CrystalCity;

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East by Washington National Airport, George Washington Memorial Parkway, the Potomac River,Daingerfield Island, mid-rise Potowmack Crossing apartments, and City of Alexandria residentialneighborhoods;

* South by Braddock Road, the Braddock Road Metrorail station, and City of Alexandria residentialneighborhoods and commercial areas; and

* West by Jefferson Davis Highway, light industrial and commercial properties along U.S. Route 1,City of Alexandria and Arlington County residential neighborhoods, and the Arlington CountyWPCP.

The populations of the City of Alexandria and Arlington County are approximately 115,000 and 170,000,respectively. Current land uses in the vicinity of the site are typical of a densely developed urban area.These uses include an airport; small-, medium-, and large-scale hotels and office buildings; light industrialand commercial establishments; residential uses including single-family homes, townhouses, and a rangeof small- to large-scale apartment buildings; a variety of public-use buildings; and a variety of recreationalresources, including parks, playgrounds, and bike paths.

Except for existing railroad and Metrorail tracks, most of the rail operations at Potomac Yard have ceasedand facilities have been removed. With the exception of Potomac Greens, the site is generally flat withlittle vegetation, as a result of being graded in the past for rail operations.

2.1.6 Sensitive Ecosystems

The Approved RA presents a discussion about sensitive ecosystems at Potomac Yard (see Section 4.1 ofthe RA). Portions of Potomac Greens have been delineated as wetlands.

2.1.7 Meteorology

The climate in the Washington, D.C., metropolitan area is continental, humid, and temperate with warmsummers and mild winters. The frost-free season is generally 200 days, with the ground frozen only toshallow depths during the winter. The following is a summary of climatological data for the WashingtonNational Airport located adjacent to the site. The coldest month is usually January, when the normalmaximum temperature is 40.1° F and the normal minimum temperature is 26.8° F. The warmest monthis usually July, when the normal maximum temperature is 88.5° F and the normal minimum temperatureis 71.4° F. The normal maximum annual temperature is 66.9° F and the normal minimum annualtemperature is 49.2° F. ["Normals" are defined as the arithmetic mean of a climatological elementcomputed over a long time period. The normal is calculated by averaging the appropriate monthly valuesfrom the 30-year record of 1961 to 1990, according to the National Oceanic and AtmosphericAdministration (NOAA) 1992.]

The wettest month is usually August, with a normal precipitation of 3.91 inches. The normal annualprecipitation is 38.63 inches, with snowfall usually in the range of 10 to 15 inches annually. The averagetemperature and precipitation data for each month at Washington National Airport from 1961 to 1990(NOAA 1992) are summarized in Table 2-1 of the Revised ECS.

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Wind speed and direction were determined from wind rose charts prepared for Washington NationalAirport (NOAA 1981). These charts present an annual distribution of wind speed and directional

- measurements using data collected every three hours from 1948 through 1978. These data are subdividedinto seven classes according to cloud ceiling and visibility conditions. Based on information containedin die wind rose charts during a class-one day, where the cloud ceiling is greater than or equal to 1,500feet and visibility is greater than or equal to 3 miles, wind direction is generally from the south. Averagewind speed is approximately 9 miles per hour (mph). At night under the same conditions, typical winddirection is from the south to south-southwest, with an average speed of approximately 8 mph. Theannual distribution of measurements over the 30-year period for all ceiling and visibility conditions ispresented in Table 2-2 of the Revised ECS. Data presented in this table indicate 223 percent of theobservations are for wind speeds from 4 to 12 mph from a south to southwesterly direction.Approximately 12 percent are for winds in the O-to-3-mph range with no discernible wind direction.

2.2 Previous Removal Actions

Potential sources of contamination periodically have been removed from the rail yard as rail operationschanged. Although not all of these actions were conducted as "environmental cleanups,** removal of theitems described below has had the effect of eliminating potential sources of environmental releases at thesite:

• Cleanup of potassium hydroxide (KOH) spill;• Cleanup of diesel fuel (investigation ongoing);* Removal of retention ponds;• Removal of transformers;

""!TH> • Removal of underground storage tanks (USTs);^_/ . • Removal of ASTs, hump retarder boxes, and miscellaneous drums; and

• Removal of oil/water separator.

KOH Spill

On June 23, 1991, a tank car carrying KOH derailed, releasing between 1,000 and 1,500 gallons of 45percent KOH solution onto the rail yard ballast in the South Yard Tail. Recovery trenches and a treatmentand recharge system were installed to neutralize impacted, perched ground water. By March 9V 1992, theCommonwealth of Virginia deemed the cleanup complete.

Diesel Fuel

During an environmental assessment conducted in July 1991, approximately 7 feet of fuel were observedin one ground water monitoring well in the Central Operations Area. This release was assumed to haveoccurred over many years due to overfilling of locomotives and leaks in the fuel storage and distributionsystem. An initial site characterization was conducted and a recovery well was installed to retrieve theliquid product. Initial recovery rates, however, indicated it would take an extended period of time toremove the product completely. As part of the ECS investigation, additional monitoring wells wereinstalled in the Central Operations Area, and weekly manual bailing was conducted for wells exhibitingfree product. These wells provide an extensive network surrounding the free product In August 1993,an additional series of wells was installed in trenches approximately 3 feet by 12 feet located in and

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around the free product. Two product skimmer pumps were installed in trench wells in May 1994.Additional information on the free product recovery program is included in the Supplemental Document(ETI 1995b).

As of January 30, 1996, the system had recovered approximately 2,696 gallons of free product. Thesystem is still operational and is continually re-evaluated to enhance product recovery. Recovery of freeproduct is under the direction of the Virginia Department of Environmental Quality (VDEQ) per regulationVR-680-13-02, and VDEQ procedures and regulations will be followed while continuing the remediationof the petroleum-impacted portion of the Central Operations Area.

Closure of Retention Ponds on Potomac Greens

Three stormwater retention ponds were located in the north, middle, and south portions of PotomacGreens. These ponds collected surface water that contained grease and spilled fuel oil from refueling andmaintenance operations in the Central Operations, North Yard, and South Yard areas. The North andSouth Ponds also collected discharges from the City of Alexandria. On the downstream side of each pond,wooden baffles served to retain the floating oil and grease in the ponds while allowing water to discharge.Oil and grease were periodically removed and taken off site. The pond discharge was permitted throughthe Virginia Pollutant Discharge Elimination System (VPDES) (see Appendix U of the Revised ECS).After 1990, when locomotive servicing operations were discontinued, the three retention ponds collectedonly stormwater runoff from portions of the rail yard and from the City of Alexandria (across JeffersonDavis Highway) to the west.

During October 1993, RF&P voluntarily removed the three ponds on Potomac Greens. The retentionponds were dewatered, and the sludge/sediment was solidified in place using kiln dust, a by-product ofcement fabrication. The solidified material and soils beneath the ponds were excavated until theconcentration of total petroleum hydrocarbons (TPH) in the underlying soil was less than 100 milligramsper kilogram (mg/Kg). Approximately 2,500 tons of excavated material were disposed of in a properlypermitted off-site facility. Closure of the retention ponds was completed on October 21,1 993, after pipingwas installed to convey stormwater runoff from the City of Alexandria through the former North andSouth Pond areas, and the ponds were backfilled with clean soil and seeded with grass. Documentsrelated to the closure of the ponds are included in the Supplemental Document (ETI I995b).

Electrical Transformers

In 1984, RF&P arranged for removal and disposal of regulated polychlorinated biphenyl (PCB)transformers from various RF&P facilities. Regulated transformers are those that have transformerdielectric fluids containing concentrations of PCBs greater than 50 parts per million (pprn). BetweenApril 30 and June 1 1, 1984, fluids from 25 transformers were drained and drummed. The transformersand fluids were disposed of at SCA Chemical Services Landfill, Model City, New York. According toavailable documentation, at least two of these transformers came from Potomac Yard. In 1990, RF&Premoved 26 nonregulated transformers from the site. Between 1992 and 1993, RF&P inventoried andremoved all but one transformer remaining on the site. Of the 85 transformers removed, 21 wereregulated transformers. All transformer components and fluids were either recycled or properly disposedof off site. At the time of this writing, one dry transformer remains on the site and services the mainoffice building.

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The remaining structures at the Central Operations Area substation and the switching substation near FourMile Run were demolished and removed in late 1993. Additional information on removal of the electricaltransformers is included in the Supplemental Document (ETI 1995b).

Underground Storage Tanks

In February 1993, an empty 1,000-gallon UST, which formerly contained unleaded gasoline, was removedand properly disposed of by RF&P. A Tank Closure Report was submitted to the VDEQ on April 20,1993. During downsizing operations in September 1993, a 20,000-galIon UST was uncovered within an80-foot turntable in the Central Operations Area. Further investigation revealed that the UST containedapproximately 30 gallons of petroleum product. Analytical results indicated the product contained PCBsat a concentration of 23 1 ppm. Upon receipt of the analytical data, RF&P removed and properly disposedof the tank and its contents. A Tank Closure Report was submitted to the VDEQ on July 7, 1994. Copiesof the tank closure reports were included in the Supplemental Document (ETI 1995b).

ASTs, Hump Retarder Boxes, and Miscellaneous Drums

In late 1992 and early 1993, RF&P sampled the contents of the 10 remaining ASTs on the rail yard, 1 1hump retarder boxes, and eight drums. Analytical data indicated that five ASTs contained a total of 2,300gallons of car oil, two ASTs contained a total of 125 gallons of quick soak oil, and three ASTs containeda total of 210 gallons of waste oil. Analytical data also showed that the hump retarder boxes containeda total of 200 gallons of lubricating oil and grease, and that the drums contained a total of 450 gallonsof tarring compound and grease. All vessels and their contents were removed and properly disposed ofoff site.

Oil/Water Separator

As part of the AST closure operations, the concrete oil/water separator was also removed. In 1993,contents of each of the four chambers were sampled. Analytical data indicated that the oil/water separatorcontained approximately 1 ,000 gallons of sludge and 3,000 gallons of wastewater. The contents were thenremoved and properly disposed of off site. In 1994, the concrete structure was demolished, removed, andproperly disposed of off site.

23 Extent and Nature of Contamination

The Approved ECS (ETI 1995a), an extensive environmental study during which more than 450 sampleswere collected and analyzed for 134 analytes and compounds, was conducted at Potomac Yard betweenJuly 1992 and November 1994. The Approved ECS evaluated the collected data and described the natureand extent of contamination at Potomac Yard. The Approved ECS indicated the potential (notdetermined) sources of contamination were the coal-based cinder ballast, the fly ash (a coal-combustionby-product), the former oil/water separator ponds, off-site stormwater discharging onto the site, and theASTs and USTs and associated fuel lines.

Based on the Approved ECS, an RA was completed to identify potential risks to human health and theenvironment presented by constituents detected at Potomac Yard. This Approved RA identified thefollowing constituents of concern:

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• Metals: aluminum, arsenic, chromium, copper, iron, lead, mercury, and zinc;

• Polycyclic aromatic hydrocarbons (PAHs): anthracene, benzo(a)anthracene, dibenz(a,h>anthracene, and fluorene; and

• Pesticides: beta-chlordane, endosulfan sulfate, heptachlor, heptachlor epoxide, endrin, and endrinketone.

The Approved RA concluded the potential migration pathway of the above-listed constituents of concernto be stormwater carrying impacted sediments or constituents in the dissolved phase. The findings of theApproved ECS, as qualified by the Approved RA, are summarized below:

• Metals are commonly found in rail yards as a result of the use of coal-based ballast Cinderballast, which consists of coal ash from steam-powered locomotives, contains a variety of metalsthat occur naturally in coal. Coal ash, which has been deposited on Potomac Greens, is similarlyderived and typically contains a variety of metals. Metals are also native to the regional soils dueto weathering of mineral-bearing rocks.

Target Analyte List (TAL) metals were detected in a layer of cinder ballast (coal ash from steam-powered locomotives), which was placed over large portions of the rail yard, with an averagedepth of approximately 3 feet. Metals were also found in fly ash (a coal-combustion by-product)and dredge spoils from Four Mile Run, which were deposited on Potomac Greens. Studiesconducted at the site and elsewhere indicate that metals that occur naturally in coal-combustionby-products, such as the fly ash and cinder ballast found at Potomac Yard, are chemically boundin die ash and do not readily leach out (see Table 6-34 of the Revised ECS).

Metals that were detected in ground water tended to be sorbed to soil particles rather thandissolved. The Approved RA did not identify ground water as a migration pathway of concern.

Some migration of metals is occurring through movement of sediments and, to a lesser degree,movement of dissolved-phase metals in stormwater runoff.

* PAHs were found in cinder ballast in the rail yard and in fly ash and dredge spoils on PotomacGreens. PAHs are found in coal and coal-combustion by-products, as well as petroleumhydrocarbons, such as diesel fuel. Potential sources of PAHs at the Potomac Yard include: I) airdeposition from coal-powered locomotive emissions as well as off-site diesel fuel emissions (urbanbackground); 2) cinder ballast (coal ash) and fly ash placed on the site; 3) railroad ties; and 4)diesel fuel and lubricating oils stored, piped, and dispensed at the site.

To the extent PAHs were found in native soil/fill, they were in areas where ballast has been mixedinto the soils or where petroleum hydrocarbons were detected. Migration of PAHs in groundwater and surface water/sediments also tended to be associated with petroleum hydrocarbons,although movement of cinder ballast as sediment in stormwater runoff may also be occurring.

* Semi volatile organic compounds (SOCs) other than PAHs were detected sporadically. No SOCs(other than PAHs), however, were identified as constituents of concern in the Approved RA.

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* PCBs were detected in soils at the site in low concentrations. PCBs are present in some of thefree product found in the Refueling Area, but have not been found to be migrating at detectable

> levels in ground water or surface water. Limited migration of PCBs in sediment appears to beoccurring along a drainage ditch that received discharge from a former oil/water separator. TheApproved RA did not identity PCBs as constituents of concern.

A number of transformers existed at Potomac Yard. These transformers have been removed andthe PCB contents disposed of off site. There have been no known or recorded releases of PCBsat Potomac Yard; however, the transformers and electric locomotives historically present at therail yard represent potential sources of PCBs.

* Some pesticides that may have been used on the rail yard for termite control (e.g., chlordane) orother pest control purposes were detected sporadically throughout the site. The most frequentlydetected pesticide is DOT and associated breakdown products (DDD and DDE). DDT has beenused extensively throughout the United States for mosquito control and is widespread in theenvironment Migration of pesticides is not occurring through ground water, but some migrationof DDT and other pesticides may occur via sediment in surface water runoff. Pesticides detectedin surface waters in drainage ditches on Potomac Greens have been found both in site soils andin stormwater coming onto the site via storm sewer pipes originating off site in the City ofAlexandria. These are commonly used pesticides.

* Volatile organic compounds (VOCs), principally solvents, were detected sporadically in soilsacross the site, primarily in the Central Operations Area and the North Yard. VOCs may be foundin rail yards as a result of the use of cleaning solvents, degreasers, paints, diesel fuel, and partially

>***» or completely combusted fossil fuels. At Potomac Yard, VOCs were most likely to have beenv j . used in the Central Operations Area, where the majority of maintenance activities and fueling

operations were conducted.

VOCs were also detected sporadically in ground water, although residual VOC concentrationsdetected in soil are too low to provide an ongoing source of ground water contamination. TheApproved RA did not identify VOCs as constituents of concern.

• The extent of free product (diesel fuel and oil), which was evaluated in an earlier siteCharacterization Report (SCR), was confirmed in the ECS as being limited to the Refueling Areawithin the Central Operations Area. Two small free product areas were also identified. One areais east of the refueling area; the other area is southeast of the refueling area. Recovery of freeproduct in these areas is regulated by the VDEQ under regulation VR-680-13-02 and is currentlyunderway (see Supplemental Document, ETI 1995b). 'The Approved RA did not identify groundwater impacted by constituents as a migration pathway of concern.

2.4 Analytical Data

Extensive analytical data collected during the ECS (more than 450 sample locations analyzed for 134analytes) are in Volume IV of the Approved ECS (ETI 1995a). Evaluation of that data is presented inSection 6.0 of the Approved ECS (ETI I995a).

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2.5 Future Development Plans

RF&P plans a variety of urban-density land uses at Potomac Yard, including office, hotel, retail,residential, and open space. Open space may include small parks, recreational areas, and playing fields.The types of residential dwellings that will be constructed include townhouses, stacked townhouses,condominiums, mixed-use dwellings, and low-, mid-, and high-rise buildings (maximum height of 110 feetunder current community development district guidelines). No single-family detached dwellings withprivate yards are expected to be developed. Buildings are expected to be constructed at grade orsufficiently below grade to provide for parking. In general, areas surrounding residential, commercial,and retail locations will serve as common areas and will be landscaped or paved for roads, parking,walkways, or bike paths. Interim land uses may occur for periods of 15 to 20 years prior to finaldevelopment of Potomac Yard. Interim uses will include warehouses (as exist in the Potomac TechnologyPark), "big-box" retail stores (in the final planning stage), parking lots, recreational space, and similardevelopments. Appendix P of the Approved ECS includes conceptual drawings, site plans, buildingelevation plans, footprint plans, and details regarding the amounts and types of development envisionedfor Potomac Yard.

The Approved RA incorporated these future development plans to evaluate potential risks to human healthand the environment under interim and future use conditions of Potomac Yard (see Section 2.4 of theApproved RA).

2.6 Potential Risks

The Approved RA used a conservative, stringent approach when calculating risks associated withconstituents detected on site. The Approved RA incorporated data collected during the ECS for theevaluation of potential risks. The HHRA demonstrated that constituents are not in a form or atconcentrations that present risks to human health or require response action per EPA guidelines.Therefore, this EE/CA does not address human health risks.

The ERA identified chemicals present at Potomac Yard that pose a potential risk to ecological receptors.The ERA established surface water and sediments leaving the site as the means by which theseconstituents potentially threaten off-site ecological receptors. The conclusions of the ERA are:

• Potomac Yard poses no risk to terrestrial wildlife feeding at or otherwise inhabiting PotomacYard.

• Potomac Yard is a source of low concentrations of PAHs, metals, and pesticides to Four Mile Runand the Potomac River.

Pesticides in surface waters and sediments of Potomac Greens exceed screening-level aquatic lifecriteria.

Measured concentrations of some metals, PAHs, and pesticides (see below for list of constituentsof concern) at the property boundary exceed toxicity criteria for sensitive species of aquatic life.

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• Risk may be overestimated or underestimated. One factor contributing to a potentialunderestimation of risk is calculating summary statistics, without the use of sample-specificdetection limits, that exceed the maximum detected value by a factor of two or more. Factorscontributing to possible overestimation of risk are the screening-level risk assessment approachand assumption of a 100 percent bioavailability of chemicals in exposure media.

• The available sampling data cannot be used to evaluate ecological risks associated with historicalreleases.

In the ERA, constituents detected at Potomac Yard that exceeded toxicity screening values (TSVs) wereidentified as constituents of concern (i.e., constituents that pose an elevated level of risk to ecologicalreceptors). The following constituents exceeded toxicity screening levels in surface water at PotomacYard:

• Four Mile Run Stormwater/Drainage Ditches: aluminum, arsenic, chromium, copper, iron, lead,and zinc.

• Potomac Greens and Potomac River Drainage Ditches: aluminum, copper, iron, lead, zinc,anthracene, beta-chlordane, endosulfan sulfate, heptachlor, heptachlor epoxide, and endrin.\

The following constituents exceeded toxicity screening levels in sediments at Potomac Yard:

• Four Mile Run Stormwater/Drainage Ditches: copper, endrin ketone, dibenz(a,h)anthracenetand fluorene.

• Potomac Greens and Potomac River Drainage Ditches: arsenic, copper, lead, mercury,anthracene, benzo(a)anthracene, fluorene, beta-chlordane, and endrin ketone.

EPA used this information to determine the objectives of this EE/CA.

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3.0 IDENTIFICATION OF REMOVAL ACTION SCOPE, GOALS, AND OBJECTIVES

The EPA Guidance Document (EPA 1993, pp. 19-20) states that an EE/CA is:

a flexible document tailored to the scope, goals, and objectives of the non-time-criticalremoval action.... The scope of the action takes into account two major considerations:the physical portion of the site to be addressed and whether the action represents a finalor interim step toward addressing a particular exposure pathway. . . . Removal actionobjectives generally consist of environmental medium-specific goals for protecting humanhealth and the environment

This section identifies the removal action scope, goals, and objectives for Potomac Yard.

3.1 Statutory Limits on Removal Actions

Statutory limits apply to removal action programs financed by Superfund allocations. At such sites, andsubject to certain exceptions, removal actions must be implemented within a 12-month time frame andcosts associated with the she may not exceed $2 million. Because Potomac Yard is not a Superfund-financed site, however, statutory limits do not apply.

3.2 Determination of Removal Scope

During development of Potomac Yard, the rail yard and Potomac Greens will be covered with asphalt andbuildings. In effect, the site will be covered with an impermeable material (asphalt and concrete).Stormwater will not contact the impacted rail yard or Potomac Greens soils, which are the sources ofconstituents that pose an elevated risk to ecological receptors. Instead, the stormwater will flow acrossthe impermeable surface into new, subsurface pipes to stormwater management structures (infiltrationgalleries, BMP pond, etc.) prior to discharging to Four Mile Run or the Potomac River through new orexisting outfalls. Sediments currently present at outfalls that will continue to be used after developmentwill be removed and/or the pipes will be replaced. The remaining existing outfalls will be closed. Hence,by creating a physical barrier between stormwater and rail yard/Potomac Greens material on the surface(e.g., asphalt, buildings, topsoil) and in the subsurface (pipe conduits), development will prevent anycontact between stormwater and potentially impacted material. In addition, the asphalt and concrete willstabilize the sediments and prevent their migration off site by physically holding them in place. Therefore,the scope of this EE/CA is to provide interim solutions within each of the drainage pathways until the areahas been developed and the migration pathways (outfalls) are removed or closed. During and after interimdevelopment, stormwater quality will be regulated by Commonwealth of Virginia stormwater managementregulations (see Section 7.1).

The drainage outfalls from Potomac Yard to Four Mile Run and the Potomac River are the pathways bywhich constituents of concern potentially leave the site. If these pathways are eliminated, then PotomacYard will not impact Four Mile Run or the Potomac River. The outfalls are located in the following areasof Potomac Yard: North Yard, North Yard Tail, and Potomac Greens. The scope of this EE/CA is limitedto these areas of Potomac Yard.

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Evaluation of data in the ECS shows that the principal source of the constituents of concern in the railyard portion of Potomac Yard is the cinder ballast material. Sediments derived from the cinder ballastmaterial contain concentrations of constituents that may pose an elevated risk to ecological receptors.Evaluation of data in the ECS also shows that the potential sources of the constituents of concern inPotomac Greens are the former retention ponds, the fly ash, and off-site stormwater runoff from the Cityof Alexandria. The ditches continue to carry off-site (City of Alexandria) stormwater.

3.3 Determination of Removal Goals and Objectives

The goal of this EE/CA is to evaluate and recommend removal action alternatives that mitigate theconcentrations of the constituents of concern in stormwater and sediments leaving the site at outfallslocated on the North Yard, the North Yard Tail, and Potomac Greens and entering Four Mile Run and thePotomac River. Development is important to the goals of the EE/CA because as part of development themajority of the pathways that allow sediments to be transported off site will be closed. In addition, theconstruction of buildings, roadways, parking lots, and landscaping will place a barrier between potentialsources of constituents of concern and stormwater. Therefore, the removal action alternatives should beconsistent with future site conditions and development plans. This EE/CA evaluates, proposes and reviewsalternatives to mitigate the release of constituents of concern detected in surface water and sediments fromPotomac Yard to Four Mile Run and the Potomac River. Section 2.6 lists the constituents of concern instormwater and sediments at Potomac Yard. In accordance with the EPA Guidance Document (EPA1993), the alternatives evaluated in this EE/CA are limited in number and satisfy requirements definedin Section 3.2, Determination of Removal Scope. The goal of this EE/CA does not include mitigatingconstituents of concern detected in off-site stormwater that discharges to Potomac Greens.

The removal action objectives to be addressed in this EE/CA are identified on page 11 of the EE/CAApproval Memorandum (see Section 1.0 and Appendix A). Although the EE/CA Approval Memorandumdefines four objectives for the removal action required at Potomac Yard, the second and third objectives(monitoring of stormwater and ground water) do not require an evaluation of appropriate removal actionsbecause monitoring is specified. Monitoring plans are presented in Section 7.0.

The fourth objective, writing the work plan for the off-site study of the nature and extent of contaminationin Potomac River and Four Mile Run sediments, is not included in this EE/CA. As agreed between RF&Pand EPA in a letter dated October 31, 1995, the preparation of that work plan, the study, and the off-siteecological risk assessment will be conducted as a separate task. The Draft Work Plan for Off-SiteEcological Risk Assessment for Potomac Yard was submitted to EPA on December 21, 1995.

3.4 Determination of Removal Schedule

This section discusses the removal schedules for the North Yard, the North Yard Tail, and PotomacGreens. For each of the three areas, a brief synopsis of existing drainage patterns and of how and whendevelopment will alter these drainage pathways is also provided. Plates 3-1 and 3-2 show current andfuture (after development) drainage pathways, respectively, on the North Yard and North Yard Tail.Plates 3-3 and 3-4 depict current and future drainage pathways, respectively, on Potomac Greens. Plate3-4 also includes the recommended removal actions for Potomac Greens (see Appendix B for all plates).

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Development is important to the removal schedule because as part of development the majority of thepathways that allow sediments to be transported off site will be closed when development occurs.Therefore, the development schedule determines the type and duration of interim solution required. Abrief discussion of development plans for Potomac Yard is presented below.

Development of Potomac Yard began in the South Yard in late spring 1995, and is planned to continuethroughout the rest of Potomac Yard until the year 2020 (see Figure 3-1). According to developmentplans, construction activities are scheduled to occur within individual areas of Potomac Yard during thefollowing time periods: the North Yard in summer 1996; relocation of the mainline tracks in summer1996; the northern portion of the North Yard Tail in early summer 1996; the Metrorail station in 1998;the southern portion of the North Yard Tail in 1999; and Potomac Greens may occur in conjunction withthe Metrorail station or shortly thereafter. Once each area is developed, 90 to 95 percent of Potomac Yardwill be covered with asphalt, concrete, or buildings. Stormwater will be conveyed by new pipes and willnot come in contact with existing rail yard materials (see Section 3.2). Therefore, the stormwater will nottransport constituents associated with rail yard activities to Four Mile Run or the Potomac River, andmonitoring may no longer be required.

As is evident in the preceding paragraph, different areas of Potomac Yard will be developed (i.e., covered)at different times. In areas of the site, rail yard materials will remain exposed until developed. Althoughrainwater will contact this material, stormwater will either infiltrate into the subsurface or will enter stormsewer systems that this EE/CA is proposing to monitor. Appendix C includes a drawing which showsstormwater flow and identifies areas that will remain uncovered during the interim use period.

The drawing does not depict the drainage divides of the North Yard Tail during the interim use period.If the removal action recommended by this EE/CA is implemented, all outfalls from the North Yard Tailto Four Mile Run will be closed. In addition, as part of track relocation, the on-site portion of the NorthYard Tail Ditch will be backfilled and the 108-inch diameter Arlington County pipe will be extended tothe property line. Rail yard materials will not leave the North Yard Tail via stormwater. Stormwater thatcontacts the North Yard Tail will neither enter the pipe nor enter Four Mile Run. Instead, the stormwaterwill infiltrate into the subsurface.

3.4.1 North Yard Removal Schedule and Drainage Pathways

The schedule for implementing the removal action for the North Yard is defined by the developmentschedule. Development of the North Yard will begin in the summer of 1996. The existing outfalls willbe closed or repiped within a short time period, and the removal action will coincide with the developmentactivities.

Plate 3-1 shows the existing North Yard drainage areas and stormwater flow patterns. Stormwatercurrently leaves the North Yard via pipes and ditches to five stormwater outfalls to Four Mile Run (SS-I,SS-2, SS-3, SS-4, NY-3). Stormwater also drains into the Potomac River from the North Yard via onegrate inlet and pipe which conveys water under the Metrorail and the George Washington MemorialParkway (NY-4; see Plate 3-1). Stormwater enters this inlet as sheet flow.

Development of the Potomac Yard Retail Center (PYRC) in the North Yard is scheduled to begin insummer 1996. The development of the PYRC includes the relocation of mainline tracks to the eastern

RF&P / PY Engineering Evaluation/Cost Analysis / I:\WP\R\RF&P\POTOMACWEVEECAFIN /June 19. 1996 24

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side of the rail yard. The preliminary development plans show that the majority of the North Yard willbe covered with an impermeable surface (asphalt and buildings), and all stormwater will be conveyed bynew subsurface pipes. Most of the existing outfalls will be closed. Those that will be used afterdevelopment will not contain the sediments currently present in the outfalls. The sediments will beremoved from the outfalls and the pipes will be replaced. Prior to discharging to Four Mile Run,stormwater will flow from the new pipes into one of five stormwater management structures that will beconstructed according to City of Alexandria requirements (City of Alexandria, 1992). As discussed inSection 3.2, no stormwater will contact the rail yard material.

The stormwater management structures consist of a best management practice (BMP) pond, a wet pond,two infiltration galleries, and one infiltration trench. The purpose of these stormwater managementstructures is twofold. During construction, the structures will function as erosion and sediment controlsand will capture sediments dislodged during earth-moving activities. The structures will retain stormwaterfor a long enough period of time to ensure sediments have settled out of the water column before thewater is discharged to Four Mile Run or the Potomac River. After construction is complete, the structureswill manage stormwater that contacts only the impermeable surface. Geotextile fabric covered with riprap will line the bottom of the structures to prevent rail yard materials from migrating off site. Thestructures will be designed to ensure that the stormwater leaving the site will not contain unacceptablelevels of nitrogen and phosphorous. Appendix D contains examples of typical design specifications forthese structures. These structures and the outfalls to be used after development are depicted on Plate 3-2.

During construction activities, a Stormwater Pollution Prevention Plan (SPPP) will be prepared andimplemented in accordance with VPDES General Permit for Stormwater Discharges from ConstructionSite requirements. As part of the SPPP, erosion and sediment (E&S) controls will be installed tominimize migration of sediments and contact with impacted materials. The SPPP will be reviewed byEPA, VDEQ, City of Alexandria, and Arlington County to ensure that the SPPP and E&S controls willprovide for the maximum level of protection to mitigate the release of potentially impacted materials fromthe site. Inspections of the E&S controls implemented under the SPPP will be conducted by EPA, VDEQ,City of Alexandria, and/or Arlington County personnel to ensure that the E&S controls are beingadequately implemented during construction activities. The following controls will be used duringconstruction of the PYRC and will meet the specifications presented in the Virginia Erosion and SedimentControl Handbook (1992):

• construction entrancesilt fence

• inlet protection• outfall protection• permanent seeding• stockpile berms.

E&S controls will be implemented to protect the existing outfalls. These controls will be maintainedthroughout construction and grading activities until upstream stabilization is achieved. All E&S controlswill be inspected daily and will be repaired as necessary within 24 hours.

Areas of the PYRC that are not covered with asphalt, concrete, or buildings will be landscaped. Becausestormwater runoff will not come in contact with existing rail yard material, the post-development

RF&P / PY Engineering Evatuation&ost Analysis / l:WP\R\RF&PV>OTOMAC\REyEECA.FIiV /June 19. 1996 26

stormwater will not carry constituents of concern (dissolved in the water or sorted to sediments) associatedwith the former rail yard activities to Four Mile Run or the Potomac River. The covered surface, the newpiping system, and the stormwater management controls will effectively mitigate concentrations ofconstituents of concern in stormwater runoff. In addition, the PYRC will be enclosed by a curb.Stormwater runoff from undeveloped areas of Potomac Yard will not enter the PYRC storm sewer system(see Plate 3-2).

The following discussion describes current drainage patterns through each North Yard outfall and the waysin which development of the PYRC will change stormwater flow and effectively mitigate stormwaterrunoff quality.

Drainage Area SS-l

SS-l currently drains an area of approximately 19.5 acres. The majority of this area drains into DrainageDitch No. 1, which is located on the west side of the North Yard adjacent to mainline tracks used byAmtrak (see Plate 3-1). The ditch discharges into a grate inlet to an 18-inch diameter pipe that emptiesinto Four Mile Run at outfall SS-l. During construction of the PYRC, the ditch will be eliminated andthe 18-inch diameter pipe will be removed and replaced. PYRC stormwater that discharges from outfallSS-l will be piped flow that passes through an infiltration trench prior to reaching the outfall. Thestormwater will be conveyed through a new pipe and will not contact existing rail yard material (seePlate 3*2). After development, stormwater quality will be regulated under Commonwealth of Virginiastormwater regulations (see Section 7.1).

Drainage Area SS-2

SS-2 currently drains an area of approximately 34.5 acres. The majority of this area drains via stormwaterinlets into an 18-inch diameter, subsurface storm sewer approximately 2,000 feet long. Each of thesesurface inlets has been filled with rip rap that catches sediments as stormwater enters and flows throughthe pipe. The storm sewer discharges to Four Mile Run at outfall SS-2. A short, vegetated ditch,approximately 150 feet long, is also located in drainage area SS-2. The ditch drains into a cementdepression where two 6-inch diameter pipes also discharge. The water leaves the cement depression viaan 18-inch diameter pipe that leads underground and joins the 2,000-foot-long, 18-inch diameter pipe.A second subsurface inflow pipe, originating at the bridge east of SS-2, also joins the 2,000-foot-long,18-inch diameter pipe just prior to where the 18-inch pipe discharges to Four Mile Run (see Plate 3-1).

The 2,000-foot-long, 18-inch diameter pipe will be removed or plugged during construction of the PYRC.The cement depression and associated 6-inch and 18-inch diameter pipes also will be removed and/orplugged. Similarly, the 18-inch diameter pipe extending to SS-2 from the bridge over Four Mile Run eastof SS-2 will be removed or plugged. No rail yard stormwater runoff will discharge via outfall SS-2 (seePlate 3-2).

Drainage Area SS-3

SS-3 drains an area of approximately 1.9 acres. The majority of this area drains into a vegetated ditchthat leads to outfall SS-3 via a steep concrete flume (see Plate 3-1). The ditch will be eliminated duringconstruction of the PYRC. Stormwater will not discharge from outfall SS-3 (see Plate 3-2).

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Drainage Area SS-4

SS-4 drains an area of approximately 26.09 acres. Surface runoff from this area enters a steep rip rapditch leading down the bank of Four Mile Run to SS-4 (see Plate 3-1). Concentrations of constituentsabove the TSVs presented in the ERA have not been detected in sediments and stormwater from drainagearea SS-4 (see Tables 4-26 and 4-27 of the RA). SS-4 may be used after development of PYRC for railtrack drainage. Although the ditch may remain after construction of PYRC, the area within 100 feet ofFour Mile Run will be vegetated and landscaped (see Plate 3-2). After development, stormwater qualitywill be regulated under Commonwealth of Virginia stormwater regulations (see Section 7.1).

Drainage Areas NY-3 and NY-4

NY-3 and NY-4 drain areas of approximately 1.43 and 1.88 acres, respectively. Surface water leavesPotomac Yard via a grate inlet in each of these drainage areas. The inlet at NY-3 leads to a pipe whichpasses under the Metrorail and discharges to an off-site vegetated ditch that empties into Four Mile Run.The inlet at NY-4 leads to a pipe that passes under the Metrorail and discharges at an outfall under theGeorge Washington Memorial Parkway. The combined Potomac Yard and George Washington MemorialParkway stormwater runoff empties into the Potomac River (see Plate 3-1). The discharge from NY-3and NY-4 were shown not to contain concentrations of constituents above the TSVs presented in theApproved RA (see Tables 4-26 and 4-27 of the Approved RA).

Outfall NY-3 will not be used after development of the PYRC. Outfall NY-4 will convey pipedstormwater runoff from the PYRC. PYRC stormwater that discharges from outfall NY-4 will be pipedflow that passes through an infiltration gallery and wet pond prior to reaching the outfall. The stormwaterwill be conveyed through new pipes and will not contact rail yard material (see Plate 3-2). Afterdevelopment, stormwater quality will be regulated under Commonwealth of Virginia stormwaterregulations (see Section 7.1).

3.4.2 North Yard Tail Removal Schedule and Drainage Pathways

The schedule for implementation of the removal action for the North Yard Tail is defined by the need tomitigate potential releases off site between the approval of the EE/CA by the EPA and development whichwill principally take place in 1999. Within three years of implementation of a removal action, the portionof the North Yard Tail adjacent to Four Mile Run will be developed. Plates 3-1 and 3-2 show currentand future (after development) drainage pathways, respectively, on the North Yard Tail.

There are three outfalls to Four Mile Run (SS-5, SS-6, and SS-7) that carry stormwater from the NorthYard Tail via shallow, vegetated ditches (less than 3 feet deep and 3 feet wide) and/or pipes (seePlate 3-1). While water is frequently present in the subsurface pipes, water is present in the ditches onlyduring and immediately after rain events. In addition, there is a large drainage ditch (15 to 25 feet wideand approximately 20 feet deep) that leads to Four Mile Run (North! Yard Tail Drainage Ditch; seePlate 3-1). The ditch traverses the North Yard Tail and carries stormwater from Arlington County via a108-inch diameter pipe. Stormwater runoff from the North Yard Tail, which enters the ditch as sheetflow, constitutes a small percentage of water in the ditch. Due to the influx of water coming fromArlington County, flow through this ditch is perennial.

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Development of the portion of the North Yard Tail adjacent to Four Mile Run is scheduled to begin in1999. Commonwealth of Virginia stormwater management regulations will be followed after development(see Section 7.1). As with the development of the PYRC, the area will be covered with asphalt andbuildings, and all stormwater will be conveyed by subsurface pipes. As discussed in Section 3.2,stormwater runoff will not come in contact with existing rail yard material and will not carry constituentsof concern (dissolved in the water or sorbed to sediments) from the former rail yard to Four Mile Run.

Prior to discharging to Four Mile Run, stormwater will flow from the pipes into a stormwater managementstructures) that will be constructed according to Arlington County requirements. The purpose of thesestormwater management structures is twofold. During construction, the structures will function as E&Scontrols and will capture sediments dislodged during earth-moving activities. The structures will retainstormwater for a long enough period of time to ensure sediments have settled out of the water columnbefore the water is discharged from the site. After construction is complete, the structures will managestormwater that contacts only the impermeable surface. Geotextile fabric covered with rip rap will linethe bottom of the structures to prevent rail yard materials from migrating off site. The structures will bedesigned to ensure that the stormwater leaving the site will not contain unacceptable levels of nitrogen andphosphorous.

The covered surface, the piping system, and the stormwater management controls will effectively mitigateconcentrations of constituents in stormwater runoff. Track relocation, which will occur in summer 1996,will affect the Arlington County stormwater flow. The 108-inch diameter Arlington County pipe thatdischarges onto the North Yard Tail will be extended through Potomac Yard and will discharge off site.The following discussion describes current drainage patterns through each North Yard Tail outfall.

Drainage Area SS-5

SS-5 drains an area of approximately 15 acres. The majority of this area drains via stormwater inlets intoa 36-inch diameter subsurface storm sewer that discharges directly to Four Mile Run. A vegetated ditch,in which the inlets are located, parallels the storm sewer pipe (see Plate 3-1).

Drainage Area SS-6

SS-6 drains an area of approximately 9.5 acres. The majority of this area drains into a vegetated ditchleading to SS-6 via a raised grate inlet that empties into a steep concrete flume to Four Mile Run. Athree-sided cement box surrounds the raised grate inlet The ditch enters the cement box on the open side(see Plate 3-1). I

Drainage Area SS-7

SS-l drains an area of approximately 2.4 acres. The majority of this area drains into a vegetated ditchleading to SS-7 via a raised grate inlet that leads to an outfall pipe. A three-sided cement box surroundsthe raised grate inlet The ditch enters the cement box on the open side (see Plate 3-1).

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North Yard Tail Drainage Ditch

The North Yard Tail Ditch drains an area of approximately 9.8 acres (see Plate 3-1). The ditch, whichis 15 to 25 feet wide and approximately 20 feet deep, traverses Potomac yard for approximately 300 feetof its total 2,300 feet Arlington County stormwater discharges into the head of this ditch via a 108-inchdiameter pipe. Stormwater from Potomac Yard, which enters the ditch as sheet flow, constitutes a smallpercentage of the water present in this ditch. As part of track relocation in summer 1996, the Arlingtonpipe will be extended through Potomac Yard to an off-site discharge point, and the on-site portion of theditch will be backfilled (see Plate 3-2).

3.43 Potomac Greens Removal Schedule and Drainage Pathways

There are three drainage ditches of concern that carry water through Potomac Greens: the North, Middle,and South Pond Ditches. The North Pond Ditch and South Pond Ditch convey water that discharges fromthe City of Alexandria. After development the South Pond Ditch will continue to convey stormwater fromthe City of Alexandria and developed areas of the rail yard. In contrast, after Potomac Yard is developed,stormwater which is presently flowing through the North and Middle Pond Ditches will be conveyed bya new ditch or pipe through the northern portion of Potomac Greens to the existing culvert under theGeorge Washington Memorial Parkway. Stormwater will not come in contact with sediments in the Northand Middle Pond Ditches. The ditch or pipe will be designed so that geotextile fabric will underlay thestormwater pathway. The geotextile fabric will prevent the sediments beneath the pipe or ditch fromleaving Potomac Greens by holding them in place. If a ditch is installed, rip rap will be placed on topof the geotextile fabric. The rip rap will hold the geotextile fabric in place and will capture any sedimentscarried by stormwater through the ditch. The presence of sediments in the stormwater should be minimalas the majority of the stormwater will be piped flow from developed areas that discharges into the ditch.A berm will be constructed on either side of the ditch to prevent stormwater from the northern portionof Potomac Greens from entering the ditch. Instead, this stormwater will percolate into the subsurface.Design specifications for the proposed ditch are included in this document in Appendix E. Thespecifications are currently being revised to show the bermed areas on either side of the ditch. Designspecifications for the pipe are not available at this time. If a pipe is installed, construction details will beincluded in the Work Plan.

The schedule for implementation of the removal action for Potomac Greens is defined by the time framefor rerouting water away from the North and Middle Pond ditches and the planned long-term use of theSouth Pond Ditch. The removal actions for the South Pond Ditch will be implemented upon approval ofthe EE/CA while the removal action for the Middle and North Pond Ditches will coincide with theplanned rerouting of the stormwater associated with the Middle and North Pond Ditches.

The head of the South Pond Ditch will receive stormwater discharge from the City of Alexandria untilthe Metrorail Station is developed in 1998. The bottom of the ditch will receive stormwater fromdeveloped portions of the rail yard, Potomac Greens, and the City of Alexandria until Potomac Greensis developed. Plates 3-3 and 3-4 depict current and future drainage pathways, respectively, on PotomacGreens. Plate 3-4 also includes the recommended removal actions for Potomac Greens.

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North Pond Ditch

The North Pond Ditch is approximately 600 feet long, 3 to 10 feet wide, and 2 to 3 feet deep. The ditchcurrently drains an area of approximately 13 acres. The ditch receives stormwater carried by a 42-inchstormwater main from a 9-acre area of the City of Alexandria along Jefferson Davis Highway. The pipedischarges directly into the North Pond Ditch, which runs east to the property boundary, and then turnssouth and flows along the eastern edge of Potomac Greens until it turns east again and exits PotomacGreens, entering a culvert that passes under the George Washington Memorial Parkway. Three otherditches, including the Middle Pond Ditch, enter the North Pond Ditch before it exits Potomac Greens.One ditch drains only surface runoff from the area of Potomac Greens north of the former North Pond;this ditch enters the North Pond Ditch as the latter ditch turns south. A second ditch is fed by a pipe thatdrains a portion of the Metrorail Yellow Line north of the Metrorail substation. This pipe conveys waterbeneath the Metrorail Yellow Line between the North and Middle Ponds, and enters the North Pond Ditchat the eastern edge of the Fly Ash Area. Runoff from George Washington Memorial Parkway also entersthe North Pond Ditch before the ditch exits Potomac Greens (see Plate 3-3).

The Middle Pond and North Pond Ditches were identified in the ECS as potential pathways for migrationof impacted sediments and surface water. These ditches were considered potential pathways because theditches conveyed water from the former stormwater retention ponds, which were identified as a potentialsource of contamination in Potomac Greens. The other two ditches were not considered potentialmigration pathways for constituents of concern since these ditches have not carried stormwater originatingfrom a known or potential source of contamination.

During track relocation (summer 1996), and construction of the PYRC, a new ditch or pipe will beinstalled in the northern portion of Potomac Greens to convey stormwater from the Metrorail and railroadtracks to the existing culvert under the George Washington Memorial Parkway (see Plate 3-4). After eacharea is developed, the ditch will convey stormwater from the southern portion of the rail yard (South Yardand South Yard Tail; see Appendices C and E). Fly ash was identified in the Approved ECS as apotential source of constituents of concern in Potomac Greens. Although the new ditch or pipe will beconstructed through a small portion of the Fly Ash Area, E&S controls will be installed to minimizecontact with impacted materials and migration of sediments during construction.

iDuring construction activities, a SPPP will be prepared and implemented in accordance with VPDESGeneral Permit for Stormwater Discharges from Construction Site requirements. As part of the SPPP,E&S controls will be installed to minimize migration of sediments and Contact with impacted materials.The SPPP will be reviewed by EPA, VDEQ, City of Alexandria, and Arlington County to ensure that theSPPP and E&S controls will provide for the maximum level of protection to mitigate the release ofpotentially impacted materials from the site. Inspections of the E&S controls implemented under the SPPPwill be conducted by EPA, VDEQ, City of Alexandria, and/or Arlington County personnel to ensure thatthe E&S controls are being adequately implemented during construction activities. The following controlswill be used during construction of the ditch or pipe and will meet the specification presented in theVirginia Erosion and Sediment Control Handbook (1992): j

• construction entrance• silt fence

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• outfall protection• permanent seeding• stockpile berms

E&S controls will be implemented to protect the existing outfall. These controls will be maintainedthroughout construction and grading activities until upstream stabilization is achieved. All E&S controlswill be inspected daily and will be repaired immediately.

The 42-inch diameter City of Alexandria stormwater pipe that empties into the North Pond Ditch will bererouted and will discharge into an infiltration gallery located on the North Yard that will be constructedas part of PYRC stormwater management The North Pond Ditch will no longer be used, so stormwaterwill not come in contact with sediments in the North Pond Ditch.

Middle Pond Ditch

The Middle Pond Ditch is approximately 550 feet long, 3 to 8 feet wide, and 2 to 3 feet deep. The ditchcurrently drains an area of approximately 4 acres. Some stormwater from portions of the rail yard eastof the Central Operations Area and along the Metrorail drains through pipes that pass through theMetrorail embankment and enter the Middle Pond Ditch. In addition, stormwater runoff from a portionof the Metrorail tracks and ground water seeps create perennial flow in the Middle Pond Ditch. TheMiddle Pond Ditch enters the North Pond Ditch shortly before the latter enters a culvert that passesbeneath the George Washington Memorial Parkway (see Plate 3-3).

During track relocation (summer 1996), and construction of PYRC, a new ditch or pipe will be installedin the northern portion of Potomac Greens to convey stormwater from the Metrorail and railroad tracksto the existing culvert under the George Washington Memorial Parkway (see Plate 3-4). After each areais developed, the ditch will convey stormwater from the southern portion of the rail yard (South Yard andSouth Yard Tail; see Appendices C and E). Fly ash was identified in the Approved ECS as a source ofcontamination in Potomac Greens. Although the new ditch or pipe will be constructed through a smallportion of the Fly Ash Area, E&S controls will be installed to minimize contact with impacted materialsand migration of sediments during construction. The following controls will be used during constructionof the ditch or pipe and will meet the specification presented in the Virginia Erosion and Sediment ControlHandbook (\992):

• construction entrance• silt fence* outfall protection• permanent seeding• stockpile berms.

E&S controls will be implemented to protect the existing outfall. These controls will be maintainedthroughout construction and grading activities until upstream stabilization is achieved. All E&S controlswill be inspected daily and will be repaired immediately. j

The Metrorail pipes and pipes from the rail yard east of the Central Operations Area will be reroutedduring track relocation so that no pipes discharge into the Middle Pond Ditch. Appendix F depicts the

RF&P / PYEngineering Evatuation&ast Analysis /IMrPWRF&PWOTOMAOREyEECA.FM /June 19. 1996 32

location of the rerouted pipes. The Middle Pond Ditch will no longer be used. Therefore, stormwaterwill not come in contact with sediments in the Middle Pond Ditch.

South Pond Ditch

The South Pond Ditch currently drains an area of approximately 67 acres. Stormwater from the City ofAlexandria and portions of the Intermodal Area, South Yard, and South Yard Tail discharges directly tothe South Pond Ditch on Potomac Greens. The stormwater eventually reaches the Potomac River aftertraveling off site through a pipe under the George Washington Memorial Parkway, and then as surfaceflow across Daingerfield Island.

Stormwater from 35 acres within the City of Alexandria along Jefferson Davis Highway discharges to thehead of the South Pond Ditch via a 54-inch diameter pipe. The ditch extends for approximately 20 feetbefore the water enters a 78-inch pipe that carries the flow for 800 feet and then discharges into anotherditch. Drainage from the Metrorail tracks travels through embankment pipes and surface flow into thehead of the South Pond Ditch as well (see Plate 3-3).

Surface runoff from the southern portion of Potomac Greens is routed into a box inlet conveying the flowto an 8-inch corrugated metal pipe. This pipe conveys the water to a small secondary drainage ditch. Thesecondary ditch joins the main South Pond Ditch at the foot of the 78-inch pipe. Other ditches enterPotomac Greens from the south and convey stormwater runoff from off site in the City of Alexandria andfrom the Intermodal Area to the South Pond Ditch. The ditches, located upstream from the point at whichthe South Pond Ditch passes under the George Washington Memorial Parkway, are not consideredpotential migration pathways for impacted sediments or stormwater. The ditches have not carriedstormwater originating from a known or potential on-site source of contamination. Runoff from portionsof the George Washington Memorial Parkway enters the South Pond Ditch on both sides of the Parkway(see Plate 3:3).

After development of the PYRC, City of Alexandria stormwater will continue to enter the head of theSouth Pond Ditch. However, in 1998 the City of Alexandria stormwater will be rerouted to discharge toNY-4. Until the South Yard and South Yard Tail are developed, the South Pond Ditch will continue toreceive stormwater runoff from these areas. Once the southern portion of the rail yard is developed,stormwater from the South Yard and South Yard Tail will not discharge to the South Pond Ditch. Instead,stormwater from these areas will discharge to the new ditch (see North Pond Ditch section above).Stormwater from the rail yard east of the Metrorail and a portion of the City of Alexandria will continueto be conveyed to the ditch below the 78-inch pipe (see Plate 3-4 and Appendix C).

3.5 Planned Remedial Actions

RF&P is currently remediating a limited area of petroleum free product (diesel fuel and lube oil) in theCentral Operations Area (see Section 2.3). Under Commonwealth of Virginia regulation VR 680-13-02,RF&P is required to report, investigate, and remediate petroleum releases. RF&P continues to recoverfree product and to submit monthly free product recovery reports to VDEQ (see Section 3.0 of theSupplemental Document, EH I995b). VDEQ procedures and regulations will be followed whilecontinuing the remediation of the petroleum-impacted portion of the Central Operations Area.

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ARI08261*

4.0 IDENTIFICATION AND ANALYSIS OF REMOVAL ACTION ALTERNATIVES/ •

The first removal action objectives as identified by the EPA EE/CA Approval Memorandum dated October6,1995, is to review alternatives to mitigate the release of constituents from the site which may potentiallyaffect the ecological receptors in the Potomac River, Four Mile Run, and Potomac Greens. In accordancewith the EPA guidance document for conducting non-time-critical removal actions (EPA 1993), thisEE/CA identifies and evaluates a limited number of practical alternatives that satisfy the removal actionobjectives, scope, and schedule for the North Yard, the North Yard Tail, and Potomac Greens. Thesethree areas of the site include all discharge avenues from Potomac Yard. The second removal actionobjective as identified in the EPA EE/CA Approval Memorandum is address in the separate document,Off-Site Ecological Risk Assessment Work Plan,

The effectiveness, implementability, and cost analyses are presented in table format at the end of thissection (Tables 4-1,4-2, and 4-3). The table format presents the information more clearly and conciselythan a narrative format. This section also presents a table listing applicable or relevant and appropriaterequirements (ARARs) (Table 4-4) and a brief discussion of how each removal action alternative meetsthe ARARs.

4.1 Effectiveness

Table 4-1 at the end of this section presents an evaluation of the effectiveness of the above-mentionedalternatives for each area of Potomac Yard. The table evaluates the consistency of each alternative withthe removal action scope and objectives and the short- and long-term effectiveness of each alternative.The table discusses how each alternative reduces the toxicity, mobility, or volume of constituents ofconcern, and how the alternative protects human health and the environment.

The short-term effectiveness criterion addresses the effects of the alternative during implementation beforethe removal objectives have been met. The following two factors are evaluated in Table 4-1:

• Protection of the Community/Workers: addresses any risk to the affectedcommunity that results from implementation of the proposed action (e.g., airquality impacts, fugitive dusts, transportation of hazardous materials) and assessespotential threats to site workers and the effectiveness and reliability of protectivemeasures that would be taken.

* Environmental Impacts: evaluates the potential adverse environmental impactsfrom the implementation of each alternative, as well as the reliability ofmitigation measures in preventing or reducing the potential impacts.

Table 4-1 does not consider the time until response objectives are achieved. The time needed to achieveprotection for the site itself or for individual elements or threats associated with the site is presented inTable 4-2 under implementation.

The long-term effectiveness criterion assesses the extent and effectiveness of the controls that may berequired to manage the risk posed by untreated wastes at the site. The following two factors are evaluatedin Table 4-1:

RF&P / PY Engineering Evaluation/Cost Analysts / fiWrVW&rVOWWCWytt 34

ARI08265

* Magnitude of Risk: evaluates the effectiveness of the alternative and assesses therisk from waste and residuals remaining at the conclusion of site activities. Inaccordance with the EPA Guidance Document (EPA 1993), because all removalaction options presented in this EE/CA are interim steps and future remedialaction or development is expected to follow the action, this is not applicable forany of the options presented.

* Adequacy and Reliability of Controls: assesses the degree of operation andmaintenance (O&M) required to maintain the effectiveness of each removal actionalternative,

4.2 Implementability

Table 4-2 addresses the technical and administrative feasibility of implementing a removal action option,evaluates the availability of various services and materials required for option implementation, and reviewsacceptance of the remedial option by support agencies and the public.

The discussion of technical feasibility evaluates the following five factors for each alternative:

* Implementation: evaluates technical difficulties such as assembling, staffing, andoperating the option within the time frame of planned site development

• Reliability and Operational Difficulties of the Technology: assesses difficultiesexperienced during prior use of the technology under similar conditions and/orwith similar wastes, possible difficulty in operation, frequent or complexequipment maintenance or controls, required raw materials or technical staff, andpotential impacts on the local community (i.e., human health and theenvironment) during construction operations.

• Environmental Conditions Which May Impact Set-up, Construction* andImplementation of the Technology: considers factors that may impede the set-up, construction, or operation of the technology (e.g., climate, terrain, seasons).

• Future Remedial Actions and O&M: evaluates O&M requirements and theoption's ability to contribute to the efficient, cost-effective performance ofplanned remedial actions or site development

• Monitoring Considerations: presents proposed monitoring techniques to evaluatethe effectiveness of the removal action alternative.

The administrative feasibility presented for each option is the same. All options are exempt from statutorylimits, and each option (with the exception of "no action**) requires an Erosion and Sedimentation (E&S)plan. For removal actions conducted on Potomac Greens, a wetlands permit from the U.S. Army Corpsof Engineers may also be required.

frafoa/fo ^ /June 19. 1996 35

The required services and materials and their availability at the time of implementation are discussed foreach removal action alternative. Important availability factors are personnel and technology (e.g., skilledpersonnel, equipment requirements); off-site treatment, storage, and disposal (TSD); services and materials(e.g., laboratory analysis, additional utility requirements); and prospective technologies (i.e., is technologyavailable for full-scale use?).

Support agency and community concerns are also in Table 4-2. Both the City of Alexandria andArlington County act as local governmental agencies, and the VDEQ acts as the state support agency.

ARARs are not included in this implemcntability section. Instead they are discussed in Sections 4.4 and5.0 and presented in Table 4-4.

4.3 Cost

Table 4*3 presents relative costs for implementation and maintenance of each alternative. BecausePotomac Yard is a non-Superfund-financed site, this EE/CA has adopted a two-phase cost breakdown(installation and O&M), rather than the three-phase cost breakdown (direct capital, indirect capital, andannual post-removal site control) specified in Section 2.6 of the EPA Guidance Document (EPA 1993).

4.4 Applicable or Relevant and Appropriate Requirements (ARARs)

Applicable requirements are defined as:

cleanup standards, standards of control, and other substantive environmental protectionrequirements, criteria, or limitations promulgated under Federal or State law thatspecifically address a hazardous substance, pollutant, contaminant, remedial action,location, or other circumstance at a site regulated by the Comprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980 (CERCLA).(EPA 1989)

Relevant and appropriate requirements are defined as:

cleanup standards, standards of control, and other substantive environmental protectionrequirement, criteria, or limitations promulgated under Federal or State law that, while not'applicable* to a hazardous substance, pollutant, contaminant, remedial action, location,or other circumstance at a CERCLA site, address problems or situations sufficientlysimilar to those encountered at the CERCLA site mat their use is well suited to theparticular site.(EPA 1989)

There are three types of ARARs: chemical-specific requirements; performance, design, or other action-specific requirements; and location-specific requirements. Chemical-specific requirements are typicallyhealth- or risk-based numerical values or methodologies that result in the establishment of numericalvalues when applied to the site-specific condition. These numerical values establish the acceptable amountor concentration of a chemical that may be found in, or discharged to, the ambient environment Action-specific requirements are typically technology- or activity-based requirements or limitations on actions

i - RF&P IPY Engineering Evaluation/Cost Analysis //:WP\KUtF&PV>QTOMAaREyEECA.Fir* /June 19. 1996 36

taken with respect to hazardous wastes, while location-specific requirements are restrictions placed on theconcentration of hazardous substances or the conduct of activities solely because they occur in speciallocations.

Table 4-4 presents a list of ARARs which apply to the removal action alternatives evaluated in thisEE/CA. A discussion of the types of ARARs that are associated with each removal action alternative isincluded in the comparative analysis of the options, provided in Section 5.0.

4.5 Removal Action Alternatives

As mentioned previously, the drainage outfalls from Potomac Yard to Four Mile Run and the PotomacRiver are the pathways by which constituents of concern potentially leave the site. The outfalls arelocated in the following areas of Potomac Yard: North Yard, North Yard Tail, and Potomac Greens.Alternatives evaluated in this EE/CA are effective in mitigating the discharge of constituents of concernto Four Mile Run, Potomac Greens and the Potomac River; can be implemented in a timely manner; andare cost efficient In Tables 4-1 through 4-3 at the end of Section 4.0, the justification for the inclusionof each alternative is presented. Because the removal action scope and schedule are different for each ofthese areas of Potomac Yard, this section presents an individual discussion of removal action alternativesfor each of the three areas. This EE/CA evaluates the following removal action alternatives for the NorthYard, the North Yard Tail, and Potomac Greens:

• No Action;* Temporary Sediment Controls (until replacement of drainage structure as part of

development, e.g., silt fence, check dam, rip rap);• Sediment Removal from Ditches and Pipes;• Regrading Ditches and Closing Outfalls (eliminating the use of existing outfalls); and/or* . Regrading Ditches and Rerouting Stormwater (continued use of outfalls).

This EE/CA does not evaluate removal action options that are not consistent with the developmentschedule. Of the five alternatives listed above, options that do not appreciably add to the protectivenessof human health and the environment prior to development are eliminated from consideration in each areaof Potomac Yard.

4.5.1 North Yard Removal Action Alternatives

Of the five removal action alternatives listed in Section 4.5, three removal action alternatives are beconsidered for the North Yard. Removal action alternatives to be considered can be implemented in atimely manner, demonstrate effectiveness and protectiveness of human health and the environment, andwill not be affected by construction/development activities. Tables 4-1 through 4-3, presented at the endof Section 4.0, evaluate the following removal action alternatives for the North Yard:

* No Action;* Temporary Sediment Controls (e.g., silt fence, check dam, vegetated ditch); and* Sediment Removal from Ditches and Pipes.

KF&P f'N Engineering EvaluationKost Analysis /t:\WP\R\RF&PV>QrOMAC(REYEECA.FIN /June 19, 1996 37

ARI08268

The removal action alternatives of "regrading ditches and closing outfalls" and "regrading ditches andrerouting stormwater" were not considered for the North Yard. As part of development activities(anticipated to begin in summer 1996), the existing stormwater outfalls to Four Mile Run will be closedand ditches will be regraded/backfilled, existing pipes leading to the outfalls will be plugged or removed,new pipes and stormwater management structures (e.g., wet pond, BMP pond, infiltration gallery) will beinstalled, and stormwater will be rerouted (see Plate 3-2). Therefore, implementation of these removalaction alternatives prior to development would result in duplication of activities upon initiation ofdevelopment activities.

4.53 North Yard Tail Removal Action Alternatives

Of the five removal action alternatives listed in Section 4.5, three removal action alternatives will beconsidered for the North Yard Tail. Removal action alternatives to be considered can be implemented ina timely manner, demonstrate effectiveness and protectiveness of human health and the environment, andwill not be affected by construction/development activities. Tables 4-1 through 4-3, presented at the endof Section 4.0, evaluate the following removal action alternatives for the North Yard Tail:

• Temporary Sediment Controls (e.g., silt fence, check dam, vegetated ditch);• Sediment Removal from Ditches and Pipes; and• Regrading Ditches and Closing Outfalls.

The removal action alternatives of "no action" and "regrading ditches and rerouting stormwater" were notconsidered for the North Yard Tail. However, it should be noted as part of track relocation (scheduledto begin in summer 1996), the Arlington County 108-inch diameter pipe will be extended to the PotomacYard property line. The North Yard Tail will be developed beginning in 1999. At the time ofdevelopment, the area will be regraded, existing pipes leading to the outfalls will be plugged or removed,new pipes and stormwater management structures (e.g., wet pond, BMP pond, infiltration gallery) will beinstalled, and stormwater will be rerouted. The "no action" alternative is not appropriate since this wouldallow potential pathways for off-site discharge of constituents of concern to remain until 1999. The"regrading ditches and rerouting stormwater" option is not appropriate because implementation of thisremoval action alternative prior to development would probably result in rerouting of stormwater againas part of development activities.

4.5.3 Potomac Greens Removal Action Alternatives

Of the five removal action alternatives listed in Section 4.5, three removal action alternatives areconsidered for Potomac Greens. Removal action alternatives to be considered can be implemented in atimely manner, demonstrate effectiveness and protectiveness of human health and the environment, andwill not be affected by construction/development activities. Tables 4-1 through 4-3, presented at the endof Section 4.0, evaluate the following removal action alternatives for the Potomac Greens:

* Temporary Sediment Controls (e.g., silt fence, check dam, rip rap);* Sediment Removal from Ditches and Pipes; and

Regrading Ditches and Rerouting Stormwater.

RF&P /PY Engineering Evatuationfcost Anafais / t:\WPWRF&P\POTOMAC\REVEECA.FM /June 19. 1996 38

The removal action alternatives of "no action" and "regrading ditches and closing outfalls" were notconsidered for Potomac Greens. The "no action" alternative would allow pathways for constituents ofconcern to remain: regrading ditches and closing outfalls would prevent not only development, but impactCity of Alexandria stormwater management and cause flooding of Potomac Greens and the GeorgeWashington Memorial Parkway.

RF&P/PYEngineering EwtuationSCost Anafysis / l:\WP\ftRF&PV>QTOMAC\REVEECA.FIN /June 19. 1996 39

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Table 4-4 Applicable or Relevant and Appropriate Requirements (ARARs)

ARARI.A.

B.

C.

ILA.

B.

C.

D.

E.

F.

Type of ARAR CommentFEDERAL - ....Clean Water Act33 USCA 1251-1376, 40 CFR 122Federal Water QualityNPDES40 CFR Part 6 Appendix A andAppendix 6 (Flood plains managementand wetlands protection)RCRA, 40 CFR Part 261, 268

OSHAStds 29 CFR 1910OSHA requirements for workers engagedin hazardous waste operations

C-S, A-SC-S, A-SL-SA-S

A-S

A-S

May apply to discharges to the Potomac River or Four Mile Run dueto construction/remediation activities or non-point source discharge(stormwater/runoff).

Applies to protection of wetlands (Potomac Greens) and managementof floodplains (Potomac River).

Will apply to characterization of sediment to be stabilized with kilndustWill apply to all workers removing/transporting any soils/sedimentsfound to be hazardous, as well as to general construction workers.

STATEVirginia State Water Control Law(62.1-44.2 g segjVirginia Water Quality Standards(VR 680-21-00)VPDES Regulations (VR 680-14-0!)Virginia Erosion and Sediment ControlLaw f 10.1-560 et seo.lVirginia Erosion and Sediment ControlRegulations (VR 625-02-00)Virginia Air Pollution Control Law(10.1-1300 etseaJVirginia Regulations for the Control andAbatement of Air Pollution (VR 120-01,120-03-02, 120-03-06. 120-03-08,120-05-0104)Chesapeake Bay Preservation ActftOM-2100 et sco.)Chesapeake Bay Preservation AreaDesignation and Management Regulations(VR 173-02-01)Virginia Stormwater Management Act(10.1-603.1 etseq.)Virginia Stormwater ManagementRegulations (VR 215-02-00)OSHA * All Federal OSHA rcgs.Virginia OSHA also follows 29 CFR1910, 1915, 1917. 1918. 1926, 1928

C-S, A-S

C-S. A-S

C-S, A-SC-S, A-S

C-S. A-S

C-S, A-S, L-S

C-S, A-S, L-S

C-S, A-S, L-S

C-S, A-S, L-S

A-S, C-S

A-S, C-S

A-SA-S

May apply to discharges to Potomac River and Four Mile Run fromconstruction and remediation activities or from non-point run-off(stormwater).

Applies to erosion control excavation activities.

Applies to excavation activities and dust suppression.

Applies to the protection of water quality, wetlands, floodplains, andother environmentally sensitive areas. Requirements satisfying theseregulations are established in local stormwater managementordinances.

Applies to erosion controls and water quality activities. Requirementssatisfying these regulations are established in local stormwatermanagement ordinances.

See Federal sectionGenerally follows Federal regulations governing training of hazardousmaterials workers

Notes:

C-S Chemical specificA-S Action specificL-S Location specificCFR Code of Federal RegulationsNPDES National Pollutant Discharge Elimination SystemVPDES Virginia Pollutant Discharge Elimination SystemOSHA Occupational Safety and Health AdministrationRCRA Resource Conservation and Recovery AdUSCA United States Code (xk.a. USC)

lAWPUt RFJtftFOTOMAOAIURNEW.TBL

RF&P /PY Engineering EvaluationKost AnatysU / IWPUbRF&PWOTOMAOREVEECA.FM /June 19. 1996 60

oo

pib

ARI08292

5.0

This section compares and evaluates the three removal action alternatives presented for each area ofPotomac Yard in Tables 4-1 through 4-3. The alternatives are compared on the basis of their consistencywith the removal action objectives; short- and long-term effectiveness; ability to reduce toxicity, mobility,or volume of constituents of concern; overall protection of human health and die environment; technicalfeasibility; compliance with ARARs; and cost Administrative feasibility and availability of services andmaterials were not considered because for each alternative because these factors are equal. Support agencyand community acceptance, although not equal among each alternative, can be obtained with educationand information.

5.1 Comparative Analysis of North Yard Removal Action Alternatives

Of the five removal action alternatives listed in Section 4.5, three removal action alternatives areconsidered for the North Yard. Removal action alternatives to be considered can be implemented in atimely manner, demonstrate effectiveness and protectiveness of human health and the environment, andwill not be affected by construction/development activities. This section compares the following removalaction alternatives: "no action," "temporary sediment controls" (e.g., silt fence, check dam, rip rap, untilthe drainage structure is replaced as part of development), and "sediment removal" from the ditches andpipes.

As explained in Section 4.5.1, the removal action alternatives of "regrading ditches and closing outfalls"and "regrading ditches and rerouting stormwater" were not considered for the North Yard. As part ofdevelopment activities (anticipated to begin in summer 1996), the existing stormwater outfalls to FourMile Run will be closed and ditches will be regraded/backfilled, existing pipes leading to the outfalls willbe plugged or removed, new pipes and stormwater management structures (e.g., wet pond, BMP pond,infiltration gallery) will be installed, and stormwater will be rerouted (see Plate 3-2). Therefore,implementation of these removal action alternatives prior to development would result in duplication ofeffort when development activities begin.

Consistent with Objectives

The "no action," "temporary sediment controls," and "sediment removal" from ditches and pipesalternatives are consistent with future site development. While the "temporary sediment controls" and"sediment removal" options mitigate constituents of concern in surface water and sediments potentiallyleaving Potomac Yard, the "no action" alternative does not. However, the "no action" alternative isconsistent with the removal action schedule. Development of the North Yard is anticipated to begin insummer 1996. As part of development, the existing outfalls will be closed or repiped.

Short-Term Effectiveness

The "temporary sediment controls" option provides an increase in the protection of human health and theenvironment because the option reduces sediment mobility. The sediment removal alternative initiallyprovides a decrease in the protection of human health and the environment due to the potential increasein sediment mobility caused by the land disturbance. After removal, an increase in protection is providedbecause removal reduces sediment volume. The "no action" option does not provide an increase in the

RF&P / PY Engineering EvatuationJCost Analysis t l:\WPWRF&PU>O7OMAC\REyEECA.FM / June 19. 1996 61

ARI08293

protection of human health and the environment. However, the RA concluded that constituents are notpresent in a form or at concentrations that present risks to human health or require response action in the

-> short term. The "no action" alternative is consistent with the removal action schedule. Once developmentoccurs, the protection of human health and the environment will be increased since the existing outfallswill be closed or repiped and the North Yard will be covered with asphalt, concrete buildings, and topsoit.Construction and earth-moving activities may initially decrease the protection of human health and theenvironment since construction activities tend to increase sediment loading. However, an SPPP will beprepared and implemented in accordance with VPDES General Permit for Stormwater Discharges fromConstruction Site requirements. As part of the SPPP, E&S controls will be installed to minimizemigration of sediments and contact with impacted materials. E&S controls will be implemented inaccordance with the Virginia Erosion and Sediment Control Handbook (1992) to control loading.

Long-Term Effectiveness

Long-term effectiveness does not need to be considered for the North Yard because the outfalls will beclosed in the near future.

Technical Feasibility

Technical feasibility does not apply to the "no action" option.

Installation of temporary sediment controls is technically feasible. Implementation of the "temporarysediment controls" option can be achieved in a short time frame, but some planning, staffing, andcoordination is required. "Temporary sediment controls" is an established technology. There are few, if

""* any, operational difficulties as long as maintenance is performed on a regular basis. The controls mayv: . be installed during any type of weather, but it easier to install temporary sediment controls during dry

conditions. Regular maintenance is required to ensure the effectiveness of the "temporary sedimentcontrols" option. Implementation of "temporary sediment controls" is not cost effective in regard to futuredevelopment plans.

"Sediment removal" is technically feasible, but it presents more technical challenges than the "temporarysediment controls" option. The implementation of sediment removal is similar to the implementation oftemporary sediment controls. Implementation can be achieved in a short time frame, but some planning,staffing, and coordination is required. Sediment removal is also an established technology. However,operational difficulties include limited access to outfalls, making sediment removal difficult, and the factthat special equipment and technical staff are required for implementation. In addition, disturbance ofsediments during removal poses potential impact to the environment during implementation. Unlike the"temporary sediment controls" option, sediment removal must occur during dry conditions to reducesediment disturbance. Although maintenance is not required to ensure the effectiveness of the "sedimentremoval" alternative, the implementation of sediment removal is not cost effective in regard to futuredevelopment plans.

j RF&P /PY Engineering Evaluation/Cost Analysis / I:\WPWRF&P\POTOMAC\REVEECA.FM /June 19. 1996 62

ARI0829H

Compliance with ARARs

No ARARs apply to the "no action" alternative; therefore, "no action" does not involve the considerationof difficulties associated with complying with ARARs. The "temporary sediment controls" and "sedimentremoval" options must consider ARARs associated with erosion and sedimentation. In addition, the twoalternatives must consider ARARs associated with transporting and disposing of materials off site ifanalytical data show that the material is hazardous. See Table 4-4 for a general list of applicable ARARs.

Cost

There are no costs associated with "no action". Costs to install temporary sediment controls arecomparable to those to remove sediments. However, O&M costs are higher for temporary sedimentcontrols than for sediment removal.

S3 Comparative Analysis of North Yard Tail Removal Action Alternatives

Of the five removal action alternatives listed in Section 4.1, three removal action alternatives areconsidered for the North Yard Tail. Removal action alternatives to be considered can be implemented ina timely manner, demonstrate effectiveness and protectiveness of human health and the environment, andwill not be affected by construction/development activities. This section compares the following removalaction alternatives: "temporary sediment controls" (e.g., silt fence, check dam, rip rap, until the drainagestructure is replaced as part of development), "sediment removal from the ditches and pipes," and"regrading ditches and closing outfalls."

As explained in Section 4.5.2, the removal action alternatives of "no action" and "regrading ditches andrerouting stormwater" were not considered for the North Yard Tail. However, it should be noted that aspart of track relocation (scheduled to begin in summer 1996), the Arlington County 108-inch diameter pipewill be extended to the Potomac Yard property line. The North Yard Tail will be developed beginningin 1999. At the time of development, the area will be regraded, existing pipes leading to the outfalls willbe plugged or removed, new pipes and stormwater management structures (e.g., wet pond, BMP pond,infiltration gallery) will be installed, and stormwater will be rerouted. The "no action" alternative is notappropriate because it would allow potential pathways for off-site discharge of constituents of concern toremain until 1999. The "regrading ditches and rerouting stormwater" option is not practical becauseimplementation of this removal action alternative prior to development would probably result in needingto reroute stormwater again as part of development activities.


The "installation of temporary sediment controls," "sediment removal from ditches and pipes," and the"regrading ditches and closing outfalls" options are all consistent with the removal action scope, goals,and objectives. Each alternative can be implemented in a timely manner, maintained until developmenteliminates drainage pathways and outfalls, and will not be destroyed during construction activities.

/ -v, RF&P t PY Engineering EvatuationftCost Anafysis f !:WPWRF&P\POTOMAC\REVEECA,FM /June 19. 1996 63

Short-Tenn Effectiveness/ -~s' Installation of temporary sediment controls provides an increase in the protection of human health and the

environment because sediment controls reduce sediment mobility.

Sediment removal initially provides a decrease in the protection of human health and the environment dueto the potential increase in sediment mobility caused by land disturbance. After removal, an increase inprotection is provided because removal reduces sediment volume.

Similarly, regrading the North Yard Tail, including backfilling the North Yard Tail Ditch and closing theoutfalls to Four Mile Run, initially provides a decrease in the protection of human health and theenvironment due to the potential increase in sediment mobility caused by land disturbance. After theoutfalls are closed, an increase in protection of human health and the environment is provided due to theelimination in sediment mobility.


The long-term effectiveness of "temporary sediment controls" is the least of the three options becauseregular maintenance is required to ensure sediments are not leaving Potomac Yard and entering Four MileRun.

The long-term effectiveness of "sediment removal" is adequate; however, the migration pathways remainopen and future sediment removal may be required.

.*"<-* Hie long-term effectiveness of "regrading ditches and closing outfalls" is the best of the three options,v, . because this alternative eliminates the mechanism by which sediments enter Four Mile Run.


Implementation of temporary sediment controls can be achieved in a short time frame, but some planning,staffing, and coordination are required. "Temporary sediment controls" is an established technology, andthere are little to no operational difficulties as long as maintenance is performed on a regular basts. Thetemporary sediment controls may be installed during any type of weather, but it is easier to install themduring dry conditions. Regular maintenance of temporary sediment controls over a three-year period isnot cost effective in regard to future development plans.

Sediment removal is technically feasible. Sediment removal presents more technical challenges thaninstallation of temporary sediment controls, although the implementation of the two options is similar.Sediment removal is an established technology and implementation can be achieved in a short time frame,but some planning, staffing, and coordination are required. Unlike the "temporary sediment controls"option, operational difficulties exist. These difficulties include limited access to outfalls, making sedimentremoval difficult, and the fact that special equipment and technical staff are required for implementation.In addition, disturbance of sediments during removal poses a potential impact to the environment duringimplementation. Sediment removal must occur during dry conditions to reduce sediment disturbance. Theimplementation of sediment removal is not cost effective in regard to future development plans.Additionally, subsequent sedimentation may necessitate repeated removal events.

' RF&P / PY Engineering Evaluation/Cost Analysis / I;\WP\R\RF&P\POTOMACWEVEECA.FM /June 19. 1996 64

"Regrading the North Yard Tail and closing existing outfalls" is the most technically feasible alternative.Similar to installation of temporary sediment controls and removal of sediments from ditches and pipes,closure of outfalls is an established technology. The implementation of regrading and closing outfalls canbe achieved in a short time frame, but some planning, staffing, and coordination are required. Likesediment removal, special equipment and technical staff are required for implementation, and disturbanceof sediments during regrading activities poses a potential impact to the environment duringimplementation. Like the installation of temporary sediment controls, the implementation of regradingditches and closing outfalls may be conducted during any type of weather, but it is easier to performduring dry conditions. Maintenance is not required for the "regrading ditches and closing outfalls" option.Unlike the implementation of sediment removal and temporary sediment controls, the implementation ofregrading ditches and closing outfalls is cost effective in regard to future development plans.

Compliance with ARARs

The same types of ARARs apply to these three options and include ARARs associated with erosion andsedimentation. However, temporary sediment controls and sediment removal must also consider ARARsassociated with transporting and disposing of materials off site if analytical data show that the materialis hazardous. See Table 4-4 for a general list of applicable ARARs.

Cost

Costs associated with implementation of the "regrading ditches and closing existing outfalls" option arecomparable to those associated with the "temporary sediment controls" alternative, but less than thoseassociated with the "sediment removal" option. O&M costs for the "regrading ditches and closing outfalls"option are similar to the "sediment removal" alternative and are about twenty percent of the O&M costsfor the "temporary sediment controls" option.

53 Comparative Analysis of Potomac Greens Removal Action Alternatives

Of the five removal action alternatives listed in Section 4.5, three removal action alternatives areconsidered for Potomac Greens. Removal action alternatives to be considered can be implemented in atimely manner, demonstrate effectiveness and protectiveness of human health and the environment, andwill not be affected by construction/development activities. This section compares the following removalaction alternatives: "temporary sediment controls" (placing rip rap in ditches), "sediment removal fromditches and pipes," and "regrading ditches and rerouting stormwater."

As explained in Section 4.5.3, the removal action alternatives of "no action" and "regrading ditches andclosing outfalls" were not considered for Potomac Greens. The "no action" alternative would allowpotential pathways for constituents of concern to remain. Closing outfalls would prevent not onlydevelopment, but also would impact City of Alexandria stormwater management and cause flooding ofPotomac Greens and the George Washington Memorial Parkway.


Installation of temporary sediment controls and sediment removal are consistent with the removal actionscope, goals, and objectives for the North, Middle, and South Pond Ditches. Either option can be

RF&P t PY Engineering Evaluation/Cost Anafysis / t:\WPW(RF&F\POTOMACWEVEECA.FIN /June 19. 1996 65

ARI08297

implemented within a reasonable time frame, maintained for the required duration, and will not beC destroyed during construction activities. While the "regrading the ditches and rerouting stormwater" option~J is consistent with the scope, goals, and objectives for the North and Middle Pond Ditches, the alternative

is not consistent with the scope, goals, and objectives for the South Pond Ditch. The South Pond Ditchwill continue to receive stormwater runoff from the City of Alexandria at the head of the ditch until 1998.In addition, stormwater may be rerouted as part of final development for Potomac Greens.

Short-Term Effectiveness

The "installation of temporary sediment controls" and the "regrading ditches" alternatives provide anincrease in the protection of human health and the environment because both options reduce sedimentmobility. Sediment removal provides an increase in the protection of human health and the environmentby reducing sediment volume. However, initially the "sediment removal" and "regrading ditches andrerouting stormwater" options provide a decrease in the protection of human health and the environmentdue to the potential increase in sediment mobility caused by land disturbance and the continual presenceof surface water in ditches.


The long-term effectiveness of "temporary sediment controls" is the least of the three options becauseregular maintenance is required to ensure sediments are not leaving Potomac Yard and entering thePotomac River.

The long-term effectiveness of "sediment removal" is adequate; however, the migration pathways remain/*"**• open and future sediment removal may be required.O •

The long-term effectiveness of "regrading ditches and rerouting stormwater" is the best of the three optionsbecause this alternative prevents sediments from entering the water column, and therefore, from leavingPotomac Greens.


"Installation of temporary sediment controls," "sediment removal," and "regrading ditches and reroutingstormwater" can all be implemented within a reasonable time frame. All three options are establishedtechnologies. Special equipment and trained personnel are required for all three options as well.Placement of rip rap in ditches has little to no potential negative impact on human health and theenvironment However, an initial decrease in the protection of human health and the environment isassociated with the implementation of the "sediment removal" and "regrading the ditches/reroutingstormwater" options due to sediment disturbance during these activities and the presence of perennial waterflow in ditches. Implementation of any removal action in Potomac Greens should occur during dryconditions and preferably during the summer or winter due to the shallow depth to ground water (0 to 10feet). Implementation of any removal action in Potomac Greens during dry conditions will likewisereduce the potential impact to human health and the environment since water flow volume is reduced atthese times. However, regardless of what time of year implementation occurs, extensive erosion andsediment controls must be installed and maintained, and the South Pond Ditch must be dewatered.

. RF&P /PY Engineering EwluationKost Analysis / I:\WFWW&rWmMA(3REVEECA.FlN /June 19. 1996 66

ARI08298

c

The "installation of temporary sediment controls" and the "sediment removal" alternatives at the North andMiddle Pond Ditches will not require maintenance. However, neither installing temporary sedimentcontrols in, nor removing sediment from these ditches, is cost effective in regard to future developmentplans. Stormwater will be rerouted by summer 1996 in conjunction with development activities.Regrading and rerouting stormwater through the northern portion of Potomac Greens (i.e., backfilling theditches with bentonite plugs and soil) requires no maintenance and is consistent with future developmentplans.

In contrast, regrading the South Pond Ditch and rerouting stormwater is neither cost effective norconsistent with future development plans. Since the South Pond Ditch will continue to conveystormwater, installing temporary sediment controls and removing sediments are cost effective in regardto future development plans.

Compliance with ARARS

The same types of ARARs apply to these three options. However, installing temporary sediment controlsand sediment removal must also consider ARARs associated with transporting and disposing of materialsoff site if analytical data show that the material is hazardous. See Table 4-4 for a general list ofapplicable ARARs.

Cost

Implementation of the "temporary sediment controls" alternative is half as costly as implementation of the"regrading and rerouting stormwater" option, which in turn is half as costly as implementation of the"sediment removal" alternative. O&M costs associated with the "temporary sediment controls" option arecomparable to those associated with the "sediment removal" option. O&M costs for both of these optionsare two times the O&M costs associated with the "regrading and rerouting stormwater" alternative.

RF&P /PY Engineering Evatuation&wt Anafysts / IWPW\RF&rV>OTOMACUtEYEECA.FM /June 19. 1996 67

o&o3p)o

6.0 RECOMMENDED REMOVAL ACTION ALTERNATIVES

Section 4.0 of this EE/CA presented applicable removal action alternatives and evaluated each option interms of the removal action scope, goals, objectives, and overall protection of human health and theenvironment. Section 5.0 compared the effectiveness and implementability of each option, includingconsistency with the removal action objectives; short-and long-term effectiveness; ability to reducetoxicity, mobility, or volume of constituents of concern; overall protection of human health and theenvironment; technical feasibility; compliance with ARARs; and cost. Based on the comparative analysispresented in Section 5.0, this section recommends a removal action alternative for the North Yard (NoAction), the North Yard Tail (Regrading Ditches and Closing Outfalls), and Potomac Greens (RegradingDitches and Rerouting Stormwater • North and Middle Pond Ditches; Temporary Sediment Controls andSediment Removal * South Pond Ditch).

6.1 Recommended North Yard Removal Action Alternative

This EE/CA recommends "no action" as the North Yard removal action alternative because developmentis scheduled to occur in summer 1996. Development of the PYRC will eliminate most existing outfalls.The outfalls that remain in use will convey stormwater via new pipes. As discussed in Sections 3.2 and3.4.1, stormwater runoff will not come in contact with existing rail yard material and therefore will notcarry constituents of concern (dissolved in the water or sorbed to sediments) to Four Mile Run or thePotomac River. Areas of the PYRC that are not covered with asphalt, concrete, or buildings will belandscaped. The covered surface, the new piping system, and the stormwater management controls willeffectively mitigate concentrations of constituents of concern in stormwater runoff (see Section 3.4.1)*Stormwater runoff from undeveloped areas of Potomac Yard will not enter the PYRC area (see Plate 3-2).Development will initially decrease the protection of human health and the environment duringconstruction activities. However, a SPPP will be prepared and implemented in accordance with VPDESGeneral Permit for Stormwater Discharges from Construction Site requirements. As part of the SPPP,E&S controls will be installed to minimize migration of sediments and contact with impacted materials.E&S controls will be implement in accordance with the Virginia Erosion and Sediment Control Handbook(1992). Ultimately, development will increase the protection of human health and the environment bypermanently preventing impacted sediments and surface water from leaving the site. If development ofthe North Yard is postponed, other alternatives will be considered.

6.2 Recommended North Yard Tail Remova! Action Alternative

This EE/CA recommends closing existing outfalls and regrading the North Yard Tail to preventstormwater that contacts rail yard material from discharging to Four Mile Run (see Plate 3-2). TheArlington County 108-inch diameter pipe will be extended to the Potomac Yard property line as part oftrack relocation (summer 1996). The on-site portion of the ditch will then be backfilled, therebypreventing stormwater from Potomac Yard from entering the ditch. As discussed in Section 5.2, regradingditches and closing existing outfalls meets the removal action scope, goals, and objectives for the NorthYard Tail. Stormwater will infiltrate into the subsurface, thereby eliminating the pathway by whichsediments potentially could leave the site. This alternative provides an increase in protection of humanhealth and the environment and is consistent with future development plans. This alternative provides apermanent solution to the discharge of constituents to Four Mile Run. "Temporary sediment controls" and"removal of sediments" would both require sampling and analysis of outfalls and future removal actions

RF&P / PY Engineering Evatuation&ost Analysis / l:\trPWRF&P\POTOMAC\REVEECA.FLV /June 19. 1996 68

to remove accumulated sediments. Costs associated with closing existing outfalls and regrading the North? Yard Tail are presented in Table 6-1.

63 Recommended Potomac Greens Removal Action Alternative

63.1 North and Middle Pond Ditches

This EE/CA recommends "regrading ditches and rerouting stormwater" as the removal action alternativefor the North and Middle Pond Ditches because this option is protective of human health and theenvironment and consistent with development plans. As discussed in Section 5.3, this alternative meetsthe removal action scope, goals, and objectives for the North and Middle Pond Ditches. In summer 1996a new ditch or pipe will be installed through the northern portion of Potomac Greens to transferstormwater across Potomac Greens. At that time, the City of Alexandria stormwater and rail trackdrainage pipes will be rerouted, and no stormwater will flow in the existing ditches (see Plate 3-4). Thetwo existing ditches will be plugged with bentonite and then backfilled with soil once stormwater has beenrerouted. For these two outfalls, the selection of this alternative provides a permanent solution to thedischarge of constituents of concern to the Potomac River. The other alternatives would require long-termsampling and maintenance. Costs associated with regrading the ditches and rerouting stormwater throughthe northern portion of Potomac Greens are presented in Table 6-1.

63.2 South Pond Ditch

This EE/CA recommends a combination of "sediment removal from ditches and pipes" and "temporarysediment controls" as the removal action alternative for the South Pond Ditch because these options are

**"*" protective of human health and the environment and consistent with development plans. As discussed in\ /' . Section 5.3, these alternatives meet the removal action scope, goals, and objectives for the South Pond

Ditch. Sediments present in the 78-inch diameter pipe will be removed. The ditch between the end of the78-inch diameter pipe and the property boundary will be backfilled with rip rap to stabilize sediments inthe ditch (see Plate 3-4). If necessary, sediments will be removed from the ditch prior to placing rip rapin the ditch. Sediments removed from the ditch and pipe will be stabilized with kiln dust, a by-productof cement fabrication. The stabilized material will be characterized in accordance with the ResourceConservation and Recovery Act (RCRA). If the material is found to be hazardous, then it will be disposedof at an EPA-approved off-site facility. If analytical results indicate the material is nonhazardous, thematerial will remain on site. RF&P will use experience gained during the removal of the former retentionponds to minimize sediment mobility. The selection of these alternatives for the South Pond Ditchprovides a nearly permanent solution for this drainage pathway. These alternatives will require samplingand analysis of the discharge and periodic inspection, testing, and possible removal of accumulatedsediments. Due to existing sediment traps in the pipe, future removal will be minimized and easilyfacilitated. Costs associated with removing sediments from the pipe and stabilizing the ditch with rip rapare presented in Table 6-1.

6.4 Maintenance of Control Measures

All control measures recommended, except the removal action for the South Pond Ditch, are permanentsolutions and do not require maintenance. The South Pond Ditch requires inspection every six monthsto evaluate the need for sediment removal.

RF&P / PY Engineering £wr/i/a/«w/Cart Analysis / IMVPWRF&PWOTOMAOREVEECA.FIN /June 19. 1996 69

ARI 08302

Table 6-1 Recommended Removal Action Alternatives

DRAINAGE AREA and .CURRENT DRAIN AGE

PATHWAY :

REMOVALOPTION

TIMEFRAME/ :DURATION

INSTALLATIONCOST

., ANNUALMAINTENANCE

COST1

COMMENT

North YardSS-l

Drainage Ditch H (2,300 feein length) along west side ofsite to f rue inlet to pipe tooutfall (see PUte 3-1).

SS-2

18-inch subsurface pipedischarges to outfall. A 150-foot ditch discharges tocement depression to pipe tooutfall; surface inlets to 18-inch ptpe have been filledwith rip rap (see Plate 3-1).

SS-3

Shallow, vegetated ditch tocement flume to outfall (seePlate 3-1).

SS-4

Small ditch to rip rap ditchdown bank (see Plate 3-1).

NY-3

Grate inlet to pipe underMetrorail to Four-Mile Runust east of Metrorail (seePlate 3-1).NY-4

irate inlet under Metrorail toIrainage ditch under GeorgeWashington Memorial*arkway to Potomac Riversee Plate 3-1).

No Action.

No Action.

No Action.

No Action.

No Action.

No Action.

Maintain untiloutfall isremoved andreplaced duringPYRCdevelopment(Summer 1996).

Maintain untiloutfall isremoved andreplaced duringPYRCdevelopment(Summer 1996).

Maintain untiloutfall isremoved andreplaced duringPYRCdevelopment(Summer 1996).Maintain untiloutfall isincorporatedinto trackrelocationdevelopment(Summer 1996).

Maintain untiloutfaH isremoved andreplaced duringPYRCdevelopment.No Action.

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

No; Applicable

Not Applicable

Not Applicable

Not Applicable

During PYRC development.ditch will be eliminated andcovered with topsoil andvegetation. Hie pipe tooutfall SS-l will be removedand replaced. Stormwaterrunoff from PYRC win bepiped to an infiltration trenchand then piped to outfallSS-l (see PUte 3-2).During PYRC development,all pipes will be removed orplugged; cement depressionwill be removed. Nostormwater runoff wfll exitthrough outfall SS-2 (seePlate 3-2).

During PYRC development.ditch will be eliminated. Nosiorrmvater runoff wiltdischarge at outfall SS-3(see PUte 3-2).

An estimated 90* ofdrainage area will becovered with asphalt, niltracks, or stormwater controlstructures. Most stormwaterwill be piped to infiltrationfacilities or BMP pond. Alimited amount ofstormwater runoff from thenew rail corridor may exkthrough outfall SS-4 (seePlate 3-2).Relocated track corridorcovers former drainage area.No stormwater runoff wiltexit through outfall NY-3(see Plate 3-2).

Relocated track corridorcovers former drainage area.Piped stormwater will exitthrough outfall NY-4 afterpassing through InfiltrationFacility I-l and wet pond(see Plate 3-2).

RF&P / PY Engineering Evaluationfcost Analysis 11:\WPW&F&P\POTOMAOREVEECA.FIN I May 6. /wfl H | U 0 *J U 3 70

Table 6-1 Recommended Removal Action Alternatives (continued)

DRAINAGE AREA andCURRENT DRAINAGE• PATHWAY

REMOVALOPTION

TIMEFRAME/DURATION

INSTALLATIONCOST

ANNUALMAINTENANCE

COST

COMMENT

North Yard TailSS-5

Subsurface pipe to outfall;vegetated, shallow ditchparallels pipe on the surface;water enters pipe via grateinlets (see Plate 3-1).SS-6

Shallow, vegetated ditch »raised grate inlet situatedwhhin a cement box; inletleads to outfall via a cementflume (see Plate 3-1).SS-7

Shallow, vegetated ditch toraised grate inlet situatedwithin a cement box; drainsto outfall pipe(see Plate 3-1).North Yard Tail DUch

Perennial flow; ArlingtonCounty storm water entershead of ditch, traverses 300feet of Site, crosses underMetrorail cracks, joined byNational Airport runoff; ditchis 15 lo 25 feet wide and 20feet deep (see Plate 3-1).

Regrade andclose outfall.



Regrade andclose outfall1.

Implement afterEPA approvesfinal plans forimplementation;maintain untilarea isdeveloped.Implement afterEPA approvesfinal plans forimplementation;maintain untilarea isdeveloped.Implement afterEPA approvesfinal plans forimplementation;maintain untilarea isdeveloped.Implementwithin 12months (duringtrack relocationin Summer1996).

$14,500.00

$13.000.00

$9.000.00

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Regrade drainage area, plugpipe, and dose outfall (seePlate 3*2).

Regrade drainage area andclose outfall (see Plate 3-2).

Regrade drainage area, plugpipe, and close outfall (seePlate 3-2).

During Summer 1996. theArlington County stormsewer pipe will be extendedoff site and the ditch will bebackfilled.

Potomac GreensNorth Pond Ditch

City of Alexandria stormwater discharges at NorthPond; also drains northportion of Potomac Greens;SCO feet long. 3-10 feet wide.2-3 feet deep (see Plate 3-3).

,

Regrade andreroutestormwater1.

Implementwithin 12months andmaintain untilarea isdeveloped.

$350.000.00 Not Applicable In conjunction with trackrelocation (Summer 1996).install a new ditch throughthe northern portion ofPotomac Greens; outfallunder George WashingtonMemorial Parkway willcontinue » be used. City ofAlexandria stormwater willbe rerouted during trackrelocation; no stormwaterwill flow through ditch.Ditch will be plugged withbentonite and backfilled withsoil (see Plate 3-4).

RF&P / PY Engineering Evaluation/Cost Analysis I I:\WPWRF&P\PQTOMAC\REVEECA.FM /May 6. /fW» I U 0 J U 4 71

Table 6-1 Recommended Removal Action Alternatives (continued)

DRAINAGE AREA andCURRENT DRAIN AGE

PATHWAYPOTOMAC GREENS(continued)

Middle Pond Ditch

Drains area east of CentralOperations Area. Metrorail.ground water seeps;converges with Nonh PondDitch; 550 feet long, 3-8 feetwide; 2-3 feet deep(see Plate 3-3).

South Pond Ditch

Drains areas of SouthYard/South Yard Tail.southern portion of PotomacGreens. City of Alexandria;series of large pipes andsmall ditches converge intomain South Fond Ditch atsoutheast portion of PotomacGreens; 900 feet long (800 ofwhich is an underground 78-inch diameter pipe), atconvergence point of ditches3-4 feet deep. 10-12 feetwide (see Plate 3-3).

REMOVALOPTION

Regrade andreroutestormwater'.

Removesediments andtemporarysedimentcontrols.

TIMEFRAME/DURATION

Implementwithin 12months andmaintain untilareabdeveloped(2015).

Implementwithin 12months andmaintain untilthe area isdeveloped.

INSTALLATIONCOST

$350.000.00

$200.000.00

ANNUALMAINTENANCE

COST1Not Applicable

«,

$5.000.00(each yearfor 2 years)

COMMENT

In conjunction with trackrelocation (Summer 1996).install a new ditch or pipethrough the northern portionof Potomac Greens; outranunder George WashingtonMemorial Parkway wfllcontinue to be used. Pipesdischarging at the head ofthe ditch will be reroutedduring track relocation; nostormwater will flow throughditch. Ditch will be pluggedwith bentonite and backfilledwith soil (see Plate 3-4).

Remove sediments from 78-inch diameter pipe. Ifnecessary, remove sedimentsfrom ditch below the pipeprior to backfilling with riprap (see PUte 3-4).Sediments removed will bestabilized with kfln dust andcharacterized. Any sedimentscharacterized u hazardouswilt be disposed of.Nonhazardous material willbe left on she.

NOTES:

1 Does not include monitoring costs (see Table 7-1).

3 Existing pipe to be extended through North Yard Tail to convey Arlington County water as pan of development. Cost for pipeextension and regrading not shown since development cost.

9 Cost for new ditch or pipe split equally berween North and Middle Pond Ditch removal actions.

TSVs toxicity screening valuesERA Ecological Risk AssessmentPYRC Potomac Yard Retail CenterE&S erosion and sedimentcfs cubic feet per second

fclWRtvlFAFirOTOMACvrABLEMEV

RF&P / PY Engineering Evaluation/Cost Analysis //:WPUt\RF&P\POTOMACVlErEECA.FM / May 6. 1996

COCDO&os2

7.0 MONITORING PROGRAMS

<*y The EPA EE/CA Approval Memorandum required that this EE/CA establish the following two monitoringprograms at Potomac Yard:

A quarterly monitoring program for constituents at all discharge points to thePotomac River and Four Mile Run to evaluate the effectiveness of the measure(s)selected and approved by the EPA to mitigate the release of constituents to FourMile Run, the Potomac River, and Potomac Greens; and

• A ground water quality sampling program for an area downgradient of the CentralOperations Area to monitor for potential migration of constituents present in thisarea of Potomac Yard.

This section presents specific stormwater and ground water monitoring programs. These programs aresummarized in Table 7-1 at the end of this section.

7.1 Quarterly Stormwater Monitoring

Quarterly monitoring of stormwater will be conducted for one year. The first sampling event will occurwithin three months of EPA's approval of the EE/CA Work Plan. Within this three-month period, theremoval action alternatives will be implemented. Stormwater samples will be collected from outfallswhich, after implementation of the removal action, carry stormwater that has contacted rail yard materialand that previously contained constituents of concern above AWQCs. After implementation of theremoval action alternatives recommended in this EE/CA, the South Pond Ditch will be the only outfall

tf . carrying stormwater that satisfies both criteria.

As stated above, RF&P anticipates implementing the removal action alternatives within three months ofEPA's approval of the Work Plan. If the implementation period of a removal action is longer than threemonths, stormwater samples will be collected from the affected outfalls on a quarterly basis until theremoval action is complete. As an area of the site is developed (e.g.. North Yard), stormwater dischargedto Four Mile Run and the Potomac River will be managed under the Commonwealth of Virginiastorm water regulations. Appendix G includes Commonwealth of Virginia storm water regulations. Duringconstruction activities, the discharges from the site will be managed under a VPDES General Permit forStormwater Discharge from Construction Sites. Appendix H includes the Commonwealth of VirginiaVPDES General Permit for Stormwater Discharge from Construction Sites permit regulations and/orrequirements.

To evaluate the effectiveness of the removal actions, stormwater samples will be collected during a stormevent. All samples collected will be unfiltered except those to be analyzed for dissolved metals. Specificanalytical methods will be specified in the Work Plan. Stormwater sample locations and analyticalparameters are summarized in Table 7-1 at the end of this section. A letter report that includes the datawill be submitted to EPA each quarter comparing the data to chronic AWQCs. EPA will review the dataeach quarter to evaluate the effectiveness of the removal actions and to determine future monitoring

RF&P / PY Engineering EvaluaiionKost Analysis / l:\WP\R\RF&P\POTOMAC\REl'££CA.FIS /June 19. 1996 73

ARI08307

activities. If concentrations of constituents exceed the AWQCs, other appropriate criteria as determinedby EPA, or increase from the present level, RF&P will discuss with EPA the need for further action.Estimated costs associated with four sampling events and reporting results are presented in Table 7-1.

7.2 Annual Ground Water Monitoring

Although the Approved RA showed that ground water is not a pathway of concern and constituentconcentrations in ground water are below risk levels, per EPA*s request, RF&P will monitor ground waterto verify that constituents are not migrating at a rate or at concentrations that pose ecological risks toreceptors. Ground water samples will be analyzed for PCBs downgradient of the Central Operations Areaper EPA's request. PCBs have never been detected in ground water at Potomac Yard. Monitoring willbe conducted once a year to measure any changes in the downgradient concentrations until the VDEQcloses the pollution complaint number associated with Potomac Yard. Ground water monitoring forpetroleum constituents will be under the direction of VDEQ under regulation VR-680-13-02.

Ground water samples will be collected from monitoring wells MW-44 and MW-45. Figure 7-1 showsthe sampling locations. Both wells are downgradient of the Central Operations Area at a location justupgradient of where ground water surfaces in Potomac Greens. In the event either of these wells isdestroyed during development activities, the well will be replaced, if possible. RF&P will notify EPAprior to installing the replacement well.

The analytical data will be provided to the EPA within 30 days of RF&P's receipt of results from thelaboratory. A letter report will be submitted to the EPA comparing the data to an appropriate criteriondetermined by the EPA. If constituents above regulatory levels of concern are shown to be migrating,RF&P will consult with EPA personnel to determine what, if any, additional response actions areappropriate. A cost estimate for five annual sampling events and the preparation of five reports isprovided in Table 7-1.

RF&P / PY Engineering Evatuationfcost Analysis / I:\WP\R\RF&P\POTQMACAEVEECA.FM /June 19. 1996 74

ARI08308

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8.0 REFERENCES

City of Alexandria, Department of Transportation and Environmental Services, 1992. AlexandriaSupplement to the Northern Virginia BMP Handbook February.

Environmental Technology of North America, Inc. (ETI), I995a. Revised Extent of Contamination Study:Potomac Yard, Alexandria, Virginia, 21 July.

____. I995b. Potomac Yard Environmental Activities: Supplemental Information, 31 July.

Green, Jay, 1995. Geologist Supervisor, Virginia Department of Environmental Quality, Water Division,Northern Regional Office. Personal communication with EARTH TECH Remediation Services,10 July.

Obermeier, Stephen R., and William H. Langer. 1986. Relationship Between Geology and EngineeringCharacteristics of Soils and Weathered Rocks of Fairfax County and Vicinity, Virginia, U.S.Geological Survey Professional Paper 1344. Washington, D.C.: GPO.

U. S. Environmental Protection Agency, 1989. CERCLA Compliance with Other Laws Manual: Part II.Clean Air Act and Other Environmental Statutes and State Requirements (Directive No.9234.1-02, EPA 540-G-89-009), August.

____. 1993. Guidance on Conducting Non-Time-Critical Removal Actions under CERCLA (DirectiveNo. 9360.0-32, EPA 540-R-93-057), August.

Virginia Department of Conservation and Recreation, Division of Soil and Water Conservation, 1992.Virginia Erosion and Sediment Control Handbook Third Edition.

Weinberg Consulting Group, Inc., 1995. Human Health and Ecological Risk Assessment: Potomac Yard,Alexandria/Arlington, Virginia, 13 October.

t RF&P IPY Engineering Evaluationfcost Analysis IMWrWRF&WOTOMAOREyEECA.FlX /June 19. 1996 78

ARI083I3

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ARI083II*

Appendix A

EPA EE/CA Approval Memorandum for Potomac Yard (dated October 6,1995)

OCT-11-1995 15:55 US EPA REGION III 215 597 8138 P. 62x13

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION 1(1

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

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

FROM: a/fpftxey &* Dodd,TTO&moval Enforcement

TO: Thomas c. Voltaggio, DirectorHazardous Waste Management Division (3RWOO)

THRU: ^ Abraham Ferdas, Associate Director* Office of Superfund Programs (3HWOI

X. PURPOSE

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

An Extent of Contamination Study (ECS) and Baseline HumanHealth and On-Site Ecological Risk Assessment (BHERA) haverecently been completed pursuant to EPA's Administrative Order byConsent ("Order"1) [Docket Ho. III-92-61-DC] by RespondentRichmond, Fredericksburg & Potomac Railroad- Company (RF&P).Based upon the results of the BHERA, elevated levels of risk tothe environment nay be posed by the Site, primarily to thePotomac River, Four Kile Run and Potomao Greens areas of theSite. Specifically, the BHERA stated that "pesticides in *»urfacewaters and sediments in the Potomac Greens area of the eite maycause a localized reduction in the abundance and diversity ofaquatic insects.*1 In addition, the BHERA stated that "PotomacYards is a source of low concentrations of PAHs, uetale andpesticides to Four Mile Run and the Potomac River. Measuredconcentrations at the property boundary exceed toxicity criteriafor sensitive species of aquatic life, possibly resulting inlocalized decreases in benthic species abundance and diversity.*

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

AR I 083 I 6

II. BITS CONDITION* MO

A. Cite

The Sita ic located in the northeastern portion of the CityQt Alexandria and the southeastern portion of Arlington county,Virginia. Tfca Site is approximately 342 acres in SIM and isgenerally bordered by 273* street to the north, Braddock Road tothe south 9 by U.S. Route 1 (Jefferson Davie Parkway) to t&e vestand the George Washington Memorial Parfcvay to the east. The siteio approximately 2.7 miles in length and approximately 2,000 feetvide near the center of the Site. Crystal City, VA, an urbanarea of high-rise office end hotel feuildinge ia located to thenorth of the site/ and Washington National Airport ie located tothe northeast. Residential and light commercial developments,including the Arlington County Water Pollution Control Plantborder the Site to the vest, eouth, and southeast. DaingerfieldIsland, e mixed-use recreational facility, and the Potoaac Riverlie to the east of tho Site. Four Mile Run, a perennial streamwhich flows vast to the Potouac River, divides thft northernportion of the Site.

The majority of the Site (approximately 300 acres) issimilar in nature and historical use and io characterized tsgenerally flat in topography, and covered vith a layer of largestone ballast material, which was used as a base for railroadtrades which once traversed the Site. Approximately 40 acres ofthe Site,* referred to as Potooac Greens, lies to the east of thaformer active portion of the Site and is generally characterizedas being covered with vegetation and was the location of threeoil/water separator ponds which collected run-off from the Siteand is also the location of fly-ash and dredge spoils disposalareas, wetland, areas also currently exist in the Potomac Oreensarea of the site. No railroad activities actually tool: place onthe Potaaac Greens area of the Site, surface water drainage atthe Sita, la generally controlled by topographic relief andurbanisation. There are seven storm water sever discharges fromthe Site into Four Mile Bun from both the northern and southernportions of the Site* Other surface wator drainage featuresinclude a larae drainage ditch which traverses the length of thenorthern portion of the Site and which originates off-site in theCounty of Arlington, VA and discharge* to Four Nile Run, severalother drainage ditches located on the southern portion or theSite which direct surface water towards Four Bile Ruts and POtouacGreens* and three drainage ditches located in the Potomac Croon*portion of the Bite vhich were part of the fornor oil/waterseparators. The oil/vater separators vere removed in 1991,however two of the drainage altcbes located in the Potomac Greenspotion of the Site continue to receive etorm v&ter runoff fromthe City of Alexandria via atormvater sewera which traverse theSite as well 00 ctonavater drainage frca the Pctcaoao Greenaportion of the Site. Theae two drainage ditches ultimatelydischarge to the Potomac River to the eant of the Site.

Bi Site History

The Potomac Yard Cite served as a major railroad switchingand maintenance yard for over 100 years. Railroad operationsbegan in the ftict*1600e with development of the Site into a majorrail yard in the early 1900s. By 1937, the rail yard hadexpanded to approximately its maximum extent. Potomac Yardserviced several different*- railroad lines, and locomotiveclassification, c wit china, maintenance, servicing, and refueling(dlesel~el*otrie locomotives only) were carried out at the flite*coal-fired, steam powered locomotives were serviced from 1906 tothe mid-IP 5 oa; electric locomotives were serviced from 1936 until1980; and dlosel-electric locomotives were serviced from the mld-1950s until 1990 at the Cite. Maintenance and servicingoperations also were carried out for other types o£ rail cars atthe Site, in isfl9, a decoandssloning process of the rail yardoperation* begun at the Cite and continued through 1993. Duringthis period, all but two building structures, eight traadcs, andthree fttoruvater retention ponds vare removed. Currently,railroad activities at the site are limited to two mainline(through) tracks on the western portion of the site and sixtracks on the eastern portion cf the Bit* which ore used for thetemporary storage of trains.

The Cite is proposed for ruturi development on an interimand long-term basis. Xaterim development of the Site began inJUly 1995 with the construction of the first phase of a warehousecomplex and may also include "big-cox" retail 5tores, parkinglots, recreation or construction staging areas. Interimdevelopment of th* yard is envisioned for a period of 15*20years* lo&g term development plans, which trill ultimately resultIn phasing out of the interim use developments. Include a varietyof urban-density land uses, including a regional transportationhuh, office, betel, retail, and residential, us veil as openspace uses.

In April 19S9. a Preliminary Assessment (PA) of the Cite wasperformed by the Virginia Department cf waste Management (VDHK)Cor EPA. The PA recommended that a Sits investigation (61) beperformed. The PA cited concerns regarding potential surfacerater contamination migrating from the Site end the possibilityof adverse effects in the food chain from consumption by watarlife' of soluble fuel-»oil/grease constituents In discharge waterfrom th» site.

A 61 was performed by VDWM in February 1989, whichidentified several metals present ia soils at the Sits abovebackground soil concentrations. Specifically, arsenic, chromium,lead, bariuan and zinc with maximum concentrations of 123 og/fcg,30 nig/kg, ill ing/kg, 463 eg/Kg and 769 mg/fcg respectively vereidentified as a result of the 61. Also found in the soil at the

were total xylenes, toluene and ethylbeneene at

ARI083I8

OCT-11-1S9? 15 = 57 US EPA REGION III 215 597 8133 P.65'13

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

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

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

In Spring of 1992, development of the central portion of theSite, particularly as the location of a new football stadium forthe Washington Redskins was contemplated. In July 1992, RF&P, inanticipation of having to complete an environmental siteevaluation before development of the central portion of the Sitecould begin, collected approximately 305 soil, 41 ground water,26 sediment and 26 surface water samples in the A-l area of theSite. The A-l area of the Site encompasses, the area of the Sitebetween South Glebe Road to the north and the Monroe StreetBridge to the south. ARI083I9

OCT-11-1S95 15:53 US EPrt REGION III 215 597 8133

In September 199?, EPA and RF&P signed a Consent Order whichrequired RF&P to investigate the nature and extent ofcontamination which may be present at the Site. The Orderspecified the investigation ir three phases which includeseparate extent of contamination studies (ECS) for the A-l areaand all other areas of the Site outside Area A-l and the conduct*of an EE/CA, if EPA determined further removal actions areappropriate. The Order acknowledged that RF&P has alreadyperformed an extensive sampling effort of the A-l area, andrequired -a detailed work plan describing the sample collectioneffort to date, and the identification of further sampling, ifwarranted.

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

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

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

In March 1994, RF&P collected approximately 108 soil, 36groundwater, 18 sediment and 23 surface water samples in theNorth Tail, South Tail, Potomac Greens and A-l areas of the site.

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

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

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

OCT-11-1995 15:59 US EPA REC.jN III 215 597 8133 P.07xi3

vassessment. Pertinent observations made in the ECS reportinclude the following:

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

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

* The PAH most frequently detected in site sediments isfluoranthene, detected in 77 percent of camples collected(23 of 30) at a site wide mean concentration of 2,528 ug/kg.Fluoranthene was also the PAH with highest detectedconcentration in Site surface water at 82 ug/L. PAHs weredetected infrequently in Site surface water, with mostdetected only in a drainage ditch that formerly drained aretention pond on Potomac Greens (North Pond drainageditch). Petroleum sheens are present periodically in thisditch, which receives storuwater runoff originating off citein the City of Alexandria.• Polychlorinated biphenyls (PCBs) have been detected insoils at the Site in low concentrations (less than 1.0Kg/kg) t except in one sample, where PCBs were detected at1.05 mg/kg). PCBs are present in some of the free productfound in the Central Operations area of the Site atconcentrations i 10.2 mg/L but have not been found to bemigrating at detectable levels in ground water or surfacewater. Limited migration of PCBs in sediment appears to beoccurring along a drainage ditch that received dischargefrom a former oil/wat*%r separator.

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

ARI0832I

OCT-11-1995 15:59 US EPH REGION I!I I'i5 597 813=5 P. 03/13

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

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

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

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

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OCT-11-1995 16 00 US EP* REGION HI. -« 2155973133 P.09/13

* The baseline human health risk assessment concludedthat the Site does not pose elevated risks to human health.All of the upperbound excess cancer risks were within orbelow EPA's risk range (io~4 to IO"6) for risk management atSuperfund Sites. The hazard indices for noncancer healtheffects were predominately below EPA's guideline thresholdof 1. The hazard index for high-end occupational exposurewas slightly exceeded in only one localized area of theSite. However, all of the estimated air concentrationsassociated with this exposure were far below occupationalstandards and criteria.

• Pesticides in surface waters and sediments in thePotomac Greens area of the site may cause a localizedreduction in the abundance and diversity of aquatic insects.

* Potomac. Yards is a source of low concentrations ofPAHs, metals and pesticides to Four Mile Run and the PotomacRiver.

• Measured concentrations of some contaminants at theproperty boundary exceed toxicity criteria for sensitivespecies of aquatic life, possibly resulting in localized

\f decreases in bent hie species abundance and diversity.

• The available sampling data cannot be used to evaluateecological risks associated with historical releases fromthe Site primarily to the Potomac River and Four Mile Run.Chemical concentrations in sediments are the most relevantdata for addressing historical releases, chemicalspotentially associated with the site include PAHs, PCBs andarsenic.

• The following contaminants exceeded toxicity screeninglevels in surface water at the Site indicating elevatedlevel of risk to ecological receptors:

Four Kile Run storm water/Drainage Ditches s Aluminum,arsenic, lead, and zinc.Potomac River Drainage Ditches t beta-ohlordane, cndosulfansulfate, heptachlor, and zinc.

Potomac Greens Drainage Ditches s beta-chlordane, 'endosulfansulfate, endrin, heptachlor epoxide anthracene, and zinc.

• The following contaminants exceeded toxicity screeninglevels in sediments at the Site indicating elevated level ofrisk to ecological receptors:

WFour Mile Run storm Water/Drainage Ditches: endrin ketone,dibenz ( a , h ) anthracene , f luorene , and copper .

OCT-11-1995 16:01 US EPA REGION til A 5 597 S13S P.10"13

Potomac River Drainage Ditches: anthracene,ber.zo (a) anthracene, fluorene, arsenic, copper, lead, andmercury.

Potomac Greens Drainage Ditches t beta-chlordane, endrinketone, anthracene, benzo (a) anthracene, fluorene, arsenic,copper, lead, and mercury.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR TEE ENVIRONMENT

Section 3 00. 4 15 (b) (2) of the National Oil and HazardousSubstances Pollution Contingency Plan outlines the factors whichshould be considered in determining the appropriateness of aremoval action. Under Section 300.415(b) (2) , five of the eightfactors are directly applicable to the situation at the Site.These are as follows:

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

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

B) 300.415(b)(2)(ii) "Actual or potential contaminationof drinking water supplies orsensitive ecosystems*

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

ARI08321*

OC7-11-1995 16:02 US EPA REGION III 215 597 813S

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

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

(D) 300.4l&(b) (2) (v) "Weather conditions that may causehazardous substances or pollutantsor contaminants to migrate or bereleased"

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

(E) 300.41S(b)(2)(vii) "The availability of otherappropriate federal or stateresponse mechanisms to respond tothe release"

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

IV. ENDANGERMENT DETERMINATION

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

V. ENFORCEMENT ACTIONS

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

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OCT-11-1935 16:02 US EPrt REGION III 215 597 8138 P. 12x13

VI. PROPOSED PROJECT DESCRIPTION/OVERSIGHT COSTS

A. Proposed Project Description

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

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

Factors to be considered in the evaluation, proposaland review of alternatives to mitigate the release ofcontaminants at the Site which may be potentiallyaffecting the ecological receptors in the Potomac

. River, Four Mile Run and Potomac Greens ar.eas of theSite should include, but not necessarily be limited tothe following:

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

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

• Conducting groundwater quality samplingdowngradient of the Central Operations area of theSite to monitor for potential migration ofcontaminants present in this area of the Site.

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

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

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OCT-11-1995 16:03 US EPA REGION MI 215 597 8138 P.13X13

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

B. Oversight costs

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

VII. RECOMMENDATIONS

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

or disapproval by signingYou joay indicate your appro

APPROVED I.

DISAPPROVED: __ _____ DATE:

ARI08327

I3aR-a

ARI08328

Appendix B

Plates

EPA REGION IIISUPERFUND DOCUMENT MANAGEMENT SYSTEM

DOC IDPAGE ft

IMAGERY COVER SHEETUN8CANNABLE ITEM

SITE NAME

ADMINISTRATIVE RECORDS-

REPORT OR DOCUMENT TITLE

DATE OF DOCUMENT

DESCRIPTON OF IMAGERY

r

NUMBER AND TYPE OF IMAGERY ITEM(S)_

oocIDPAGE«

IMAGERY COVER SHEETUNSCANNABLE ITEM

SITE NAME.

OPERABLE UNIT

ADMINISTRATIVE RECORDS- SECTION \i/L_VOLUME_jA)

REPORT OR DOCUMENT TITLE f 'Afti

DATE OF DOCUMENT.

DESCRIPTON OF »MA«gpv

NUMBER AND TYPE OF IMAGERY ITEM(8*


PAGE

SITE NAME.

OPERABLE UNIT

ADMINISTRATIVE RECORDS- SECTION_V/£v VOLUME

DESCRIPTON OF

NUMBER AND TYPE OF IMAGERY ITEM(S) \ "


DOC IDPAGE *


OPERABLE

ADMINISTRATIVE RECORDS- SECTION V ft VOLUME N/Uill

REPORT OR DOCUMENT TITLE. (HMa\/COfrfftMgl^SlS

DATE OF DOCUMENT.

DESCRIPTON OF

NUMBER AND TYPE OF IMAGERY ITEM(8)——\

OS

o

f$:$$ i

Appendix C

Interim Use Stormwater Flow

ARI08335

DOC IDPAGE #

IMAGERY COVER SHEETUNSCANNABLE ITEM

SITE NAMEUNIT €jftf~ fle»\A6V&\OPERABLE

ADMINISTRATIVE RECORDS- SECTION _VOLUMEUfl_VOLUME_A)/lL

REPORT OR DOCUMENT TITLE FJAMJ

/DATE OF DOCUMENT.

/M)gmU

NUMBER AND TYPE OF IMAGERY ITEM(8)


PAGE» 1


SITE NAME.

OPERABLE UNIT.

ADMINISTRATIVE RECORDS- SECTION_VOLUMEVOLUME_X\/lIi

REPORT OR DOCUMENT TITLE ffodl

DATE OF DOCUMENT.

DESCRIPTON OF IMAGERY

NUMBER AND TYPE OF IMAGERY ITEM(8)—L

•a•oID

a

/

ARI08338

Appendix D

Design Specifications for PYRC Stormwater Management Structures

/ -

ARI08339

City of Akiindrii, VbffateChrtM»ph«rCMMKmti Ltd.M»rcfcM»M

08NORMAL <BMP> POOL

WSEL.' 20.23

COOcsr?

so *•!OH n c e.

ARI083Iil

oCO¥UJ

O5

"a i .==ra /pissil w Scvw-c UJ SuN^ Ê ioA«iv-v

c|

I

*

8

C\J

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ICO

I " • -*£ co* , <»o

OJH

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fc:LLJ

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asCO

O

iID

ARI083H

Appendix £

Design Specifications for the Potomac Greens Ditch

5

g.R'•n

ARI083U7

Appendix F

Post-Development Location of Stormwater Pipes Currently Discharging to the Middle Pond Ditch

ARI083l»8

COCOo0=

3aR1O

ARI08350

Appendix G

Commonwealth of Virginia Stormwater Management Regulations

ARI0835I

DEPARTMENT OF CONSERVATION AND RECREATION Page 1 of 19

VR 215-02-00. STORMWATER MANAGEMENT REGULATIONS

PART I*

GENERAL.

§ 1.1. Definitions.

:, The following words and terms used in these regulationshave the following meanings, unless the context clearlyindicates otherwise.

"Act" means Article 1.1 (§10.1-603.1 et seq,) of Chapter 6of Title 10.1 of the Code of Virginia.

"Adequate channel" means a channel that will convey thedesignated frequency storm event without overtopping thechannel banks nor causing erosive damage to the channel bed orbanks.

"Applicant" means any person submitting a stormwaterL j management plan for approval.

"Channel" means a natural stream or manmade waterway.

"Department" means the Department of Conservation andRecreation.

"Development" means a tract of land developed or to bedeveloped as a unit under single ownership or unified controlwhich is to be used for any business or industrial purpose oris to contain three or more residential dwelling units.

"Director" means the Director of the Department ofConservation and Recreation.

"Flooding" means a volume of water that is too great to beconfined within the banks or walls ^*" the stream, water body orconveyance system and that overflows onto adjacent lands,causing or threatening damage.

"Flood^lain" means those areas adjoining a river, stream,channel, ocean, bay or lake which are likely to be covered byflooding.

"Infiltration facility" means a stormwater managementfacility which temporarily impounds runoff and discharges it

\^ via infiltration through jthe surrounding soil. While an

ARI08352

DEPARTMENT OF CONSERVATION AND RECREATION Page 2 of 19»


infiltration facility may also be equipped with an outletstructure to discharge impounded runoff, such discharge isnormally reserved for overflow and other emergency conditions.Since an infiltration facility impounds runoff onlytemporarily, it is normally dry during non-rainfall periods.

"Inspection" means an on-site review of the project'scompliance with the approved plan, the local stormwatermanagement program, and any applicable design criteria.

"Land development" or "land development project" means amanmade change to the land surface that potentially changes itsrunoff characteristics.

"Local stormwater management program" or "local program"means a statement of the various methods employed by a localityto manage the runoff from land development projects and mayinclude such items as local ordinances, policies andguidelines, technical materials, inspections, enforcement andevaluation.

"Locality" means a county, city, or town.

"Nonpoint source pollution" means pollution whose sourcescannot be pinpointed but rather.is washed from the land surfacein a diffuse manner by stormwater runoff.

" Onsite stormwater management facilities" meansfacilities which are designed to control stormwater runoffemanating from a specific site.

"Person" means any individual, partnership, firm,association, joint venture, public or private corporation,trust, estate, commission, board, public or privateinstitution, utility, cooperative, county, city, town or otherpolitical subdivision of the Commonwealth, any interstate bodyor any other legal entity.

"Post-development" refers to conditions that reasonablymay be expected or anticipated to exist after completion of theland development activity on a specific site or tract of land.

"Pre-development" refers to the land use that exists atthe time that plans for the land development are submitted tothe locality. Where phased development or plan approval occurs(preliminary grading, roads and utilities, etc.), the existingland use at the time the first item is submitted shallestablish pre-development conditions.

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"Regional (watershed wide) stormwater management facility"or "regional facility" means a facility or series of facilitiesdesigned to control stormwater runoff from a large contributingarea, although only portions of the watershed may experienceland development.

"Regional stormwater management plan" or "regional plan"means a document containing material describing how runoff fromopen space, existing development and future planned developmentareas within a watershed will be controlled by coordinateddesign and implementation of regional stormwater managementfacilities.

"Runoff" or "stormwater runoff" means that portion ofprecipitation that is discharged across the land surface orthrough conveyances to one or more waterways.

"State project" means the construction of any facility orexpansion of an existing facility including, but not limited toland clearing, soil movement, or land development, which isundertaken by any state agency, board, commission, authority orany branch of state government, including state supportedinstitutions of higher learning, which disturbs more than oneacre of land area.

"Stormwater detention basin" or "detention basin" means astormwater management facility which temporarily impoundsrunoff and discharges it through a hydraulic Outlet structureto a downstream conveyance system. While a certain amount ofoutflow may also occur via infiltration through the surroundingsoil, such amounts are negligible when compared to the outletstructure discharge rates and are, therefore, not considered inthe facility's design. Since a detention facility impoundsrunoff only temporarily, it is normally dry during non-rainfallperiods.

"Stormwater management facility" moans a device thatcontrols stormwater runoff and changes the characteristics ofthat runoff including, but not limited to, the quantity andquality, the period of release or the velocity o.f flow.

"Stormwater management plan" or "plan" means a documentcontaining material for describing how existing runoffcharacteristics will be maintained toy a land developmentproject and comply with the requirements of the local programor these regulations.



"Stormwater retention basin" or "retention basin" means astormwater management facility which, similar to a detentionbasin, temporarily impounds runoff and discharges its outflowthrough a hydraulic outlet structure to a downstream conveyancesystem. Unlike a detention basin, however, a retention basinalso includes a permanent impoundment and, therefore, isnormally wet, even during non-rainfall periods. Storm runoffinflows are temporarily stored above this permanentimpoundment.

"Subdivision" unless otherwise defined in a localordinance adopted pursuant to § 15.1-465 of the Code ofVirginia, means the division of a parcel of land into three ormore lots or parcels of less than five acres each for thepurpose of transfer of ownership or building development, or,if a new street is involved in such division, any division of aparcel of land. The term includes resubdivision and, whenappropriate to the context, shall relate to the process ofsubdividing or to the land subdivided.

"Water quality volume" means the volume equal to the first0.5 inch of runoff multiplied by the total area of the landdevelopment project.

"Watershed" means the total drainage area contributingrunoff to a single point.

§ 1.2. Authority.

Article 1.1 (§10.1-603.1 et seq.) of Chapter 6 of Title10.1 of the Code of Virginia authorize? the department topromulgate these regulations.

§ 1.3. Purposes.

The purposes of these regulations are to:

1. Inhibit the deterioration of existing waters andwaterways of the Commonwealth by requiring that state agencyand local stormwater management programs maintainpost-development runoff characteristics, including both waterquantity and quality, as nearly as practicable, equal to orbetter than the pre-development runoff characteristics;

2. Control nonpoint source pollution, localized floodingand stream channel erosion, by establishing minimum acceptabletechnical criteria that must be met by state agencies and allstormwater management programs implemented by localities;

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3. Establish minimum acceptable administrative proceduresthat must be met by all local stormwater management programsimplemented by localities;

4. Require the provision of long-term responsibility for,and maintenance of, stormwater management facilities and othertechniques specified to manage the quality and quantity of'runoff;

5. Provide for the integration of stormwater managementprograms with erosion and sediment control, site plan review,flood insurance, floodplain management and other landdevelopment related programs and laws and regulations requiringcompliance prior to authorizing construction; and

6. Provide for the periodic review and evaluation oflocal stormwater management programs and state agencycompliance and for annual reporting to the General Assembly ofthe extent to which the state stormwater management program hasreduced nonpoint source pollution and mitigated the detrimentaleffects of localized flooding.

§ 1.4. Applicability.

A. These regulations are applicable to:1. Every locality that establishes a local stormwatermanagement program; and2. Every state agency that, after January 1, 1991,undertakes any land clearing, soil movement, orconstruction activity involving soil movement or landdevelopment.

B. The following activities are exempt from theseregulations:

1. Permitted surface or deep mining operations andprojects, or oil and gas operations and projectsconducted under the provisions of Title 45.1 of theCode of Virginia.2. Tilling, planting or harvesting of agricultural,horticultural, or forest crops.3. Single-family residences separately built and notpart of a subdivision, including additions ormodifications to existing single-family detachedresidential structures.

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4. Land development projects that disturb less thanone acre of land area, except that the governing bodyof a locality that has adopted a local stormwatermanagement program may exempt a smaller area ofdisturbed land or may qualify the conditions underwhich this exemption shall apply.

PART II.

TECHNICAL CRITERIA.

§ 2.1. Applicability.

Except as provided for in § I.4.B. of these regulations,all local stormwater management programs and state projectsmust comply with the general requirements and water qualityrequirements in this Part.

§ 2.2. General requirements.

A. A stormwater management plan for a land developmentproject shall be developed so that from the site, the post-development peak runoff rate from a two-year storm and a 10-year storm, considered individually, shall not exceed theirrespective pre-development rates.

B. These design storms shall be defined as either a 24-hour storm using the rainfall distribution recommended by theU.S. Soil Conservation Service when using U.S. SoilConservation Service methods or as the storm of criticalduration that produces the greatest required storage volume atthe site when using a design method such as the RationalMethod.

C. For purposes of computing runoff, all lands in thesite shall be assumed prior to development to be in goodcondition (if the lands are pastures, lawns, or parks), withgood cover (if the lands are woods), or with conservationtreatment (if the lands are cultivated); regardless ofconditions existing at the time of computation.

D. Construction of stormwater management facilities ormodifications to channels shall comply with all applicable lawsand regulations. Evidence of approval of all necessary permitsshall be presented.

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E. Localities shall require impounding structures that •are not covered by the Virginia Dam Safety Regulations to bechecked for structural integrity and floodplain impacts for the100-year storm event.

F. Pre-development and post-development runoff ratesshall be verified by calculations that are consistent with goodengineering practices and are acceptable to the locality.

G. Outflows from a stormwater management facility shallbe discharged to an adequate channel, or velocity dissipatorsshall be placed at the outfall of all detention and retentionbasins and along the length of any outfall channel as necessaryto provide a non-erosive velocity of flow from the basin to achannel.

H. Proposed residential, commercial, or industrialsubdivisions shall apply these stormwater management criteriato the land development as a whole. Individual lots in newsubdivisions shall not be considered separate land developmentprojects, but rather the entire subdivision shall be considereda single land development project* Hydrologic parameters shallreflect the ultimate land development and shall be used in allengineering calculations.

I. New construction, including construction of stormwatermanagement facilities, should be avoided in floodplains. Whenthis is unavoidable, a special examination to determineadequacy of proposed stormwater management facilities duringthe 10-year flood shall be required. The purpose of thisanalysis is to ensure that the stormwater management facilitywill operate effectively.

J. In addition, such construction shall be in compliancewith all applicable regulations under the National FloodInsurance Program.

K. To prevent flooding or stream erosion downstream ofthe development site, it may be necessary to increase thedetention storage requirements and reduce peak outflow rates tolevels that exceed the requirements of § 2.2.A. of theseregulations. This requirement can be imposed only if awatershed analysis has been made by the locality.

L. Land development projects roust comply with theVirginia Erosion and Sediment Control Act and attendantregulations.

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§ 2*3, Water quality requirements.

The water quality volume shall be treated by one of thefollowing methods.

A. For a detention basin, the water quality volume shallbe detained and released over 30 hours.

1. The detention time is a brim-drawdown time andtherefore, shall begin at the time of peak storage ofthe water quality volume in the detention basin.2. If the above requirement would result in an outletopening smaller than three inches in diameter or theequivalent cross sectional area, the period ofdetention shall be waived so that three inches will bethe minimum outlet opening used.

B. For a 'retention basin, the volume of the permanentpool must be at least three times greater than the waterquality volume.

C. For an infiltration facility, the water quality volumemust be completely infiltrated within 48 hours.

1. The invert of the infiltration facility must be atleast four feet above the seasonal high groundwaterelevation.2. A detailed soils analysis and report shall berequired.3. Approvals will be on a case-by-case basis aftertechnical review by the designated authority. Theobject of this review will be to avoid groundwatercontamination.

D. Design calculations verifying compliance with thewater quality requirements shall be submitted.

§ 2.4. Nonstructural measures.

It is not necessary that basic requirements for waterquality and quantity control be satisfied by means ofstructural methods. Non-structural practices including, butnot limited to, cluster land use development, minimization ofimpervious surface and curbing requirements, open spaceacquisition, floodplain management, and protection of wetlands,steep slopes and vegetation should be coordinated withstructural requirements. Such changes in land use often

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decrease the runoff coefficients, thus reducing the scope andcost of structural practices.

PART III.

LOCAL STORMWATER MANAGEMENT PROGRAMS.-. **§ 3.1. Applicability.

A. This Part specifies administrative procedures for alllocalities operating local stormwater management programs.

B. Except for regulations related to plan approval, whichare set forth in §§ 3.5. and 3'.6. of these regulations, alocality may adopt regulations that are more stringent thanthose necessary to ensure compliance with these regulations,provided that the more stringent regulations are based upon thefindings of local comprehensive watershed management studiesand that prior to adopting more stringent" regulations a publichearing is held after giving due notice.

C. The department and a locality operating a stormwatermanagement program are authorized to cooperate and enter intoagreements with any federal or state agency in connection withstormwater management plans.

1. A locality that has adopted more 'stringentrequirements or regional stormwater management plansmay request, in writing, that the department considerthese requirements in its review of state agencyprojects within that locality.2. To the maximum extent practicable, the stateagencies shall comply with these local programrequirements.3. Nothing in this i>ar*- "lall be construed esauthorizing a locality to regulate, or to requireprior approval by the locality for, a state project.

D. Localities with existing stormwater managementprograms shall have one year from the effective date of theseregulations to modify their programs to comply with the minimumrequirements of these regulations.

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\

§ 3.2. Requirements for local program and ordinance.

A. At a minimum, the local stormwater management programand implementing ordinance shall require compliance with thestormwater management technical criteria established in Part IIof these regulations.

B. Each locality shall submit its stormwater managementprogram, implementing ordinance, and amendments to thedepartment for review. The department shall determine if theprogram and ordinance are consistent with the state stormwatermanagement regulations and notify the locality of its findingswithin 60 days.

C. Each stormwater management program shall consider theunique character and limitations of the environment in theplanning area.

D. Stormwater management programs shall refer to and bein compliance with requirements for the control of soilerosion. The stormwater management program and ordinance shallalso be consistent with relevant federal and state laws, rulesand regulations concerning stormwater management, dam safety,management and flood control. Additionally, such programsshould be coordinated with any stormwater management plansprepared by any other locality in the watershed.

E. The local stormwater management program and ordinanceshall be included in the periodic reexamination of thelocality's comprehensive land use plan.

F. Except as provided for in § I.4.B. of theseregulations, no grading, building, or other permit shall beissued for land development unless a stormwater management planhas been submitted to the locality and approved.

G. Nothing in this regulation shall be construed aslimiting the rights of other federal and state agencies fromimposing stricter standards or other requirements as allowed bylaw.

§ 3.3. Watershed planning encouraged.

A. In developing a local stormwater management program, alocality should consider regional planning for the appropriatewatershed. The objective of regional stormwater managementplanning is the achievement of greater economy and efficiency

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through the use or regional stormwater management facilitiesthat can serve several land development projects, as opposed tothe use of a multitude of facilities that are intended solelyfor individual land development projects. In addition tomitigating the impacts of new development, regional stormwatermanagement facilities may also provide an opportunity to.Remediate flooding or water quality problems caused byUncontrolled existing development. Because watershedboundaries typically transcend political boundaries, localitiesare encouraged to develop cooperative regional stormwatermanagement plans.

B. Regional stormwater management planning should include•the following, as a minimum:

1. Consideration of the locality's comprehensiveplan, zoning, government facility plans and similarplanning tools.2. An analysis of the impacts of development on thewatershed based on hydrologic and hydraulic modeling.At a minimum, the 2-year, 10-year, and. 100-year stormsshall be studied. Ultimate development of thewatershed shall be assumed.3. Recommendations for locations, specified releaserates, and required storage capacities of neededregional stormwater management facilities based on themodeling.4. Consideration of future expansion of regionalstormwater management facilities based on thepossibility that development might exceed theanticipated level.5. Requirements for necessary onsite stormwatermanagement facilities and release rates.6. An implementation schedule and financingrequirements.

§ 3.4. Administrative procedures: Stormvater management plans.

A. A local stormwater management program and ordinanceshall require a person who intends to initiate a landdevelopment project to submit a stormwater management plan andobtain the locality's approval of the plan prior to beginningthe land development project.



B. The local stormwater management program and ordinanceshall establish stormwater management plan submittalrequirements. The stormwater management plan may include theappropriate maps, calculations, detail drawings, reports and alisting of the status of all major permit decisions to assurethat the land development project achieves the objectives ofthe local program. Maps, plans, and designs shall be certifiedby a professional engineer or Class III B surveyor.

C. A locality may charge applicants a reasonable fee tovdefray the costs of program administration, including costs* associated with plan review, issuance of permits, periodic"inspection for compliance with approved plans and necessaryenforcement, provided that charges for such costs are not madeunder any other law, ordinance or program. The fee shall notexceed an amount commensurate with the services rendered andexpenses incurred or the amount established in § 10.1-603.10 ofthe Code of Virginia, whichever is less.

D. Prior to issuance of any permit, the locality may alsorequire an applicant to submit a reasonable performance bond inaccordance with § 10.1-603.8.A of the Code of the Virginia.

§ 3.5. Administrative procedures: Approval and disapproval ofplans.

A. A maximum of 30 calendar days from the receipt of anapplication will be allowed for preliminary review of theapplication for completeness. During this period, the localitywill either accept the -application for review, which will beginthe 60-day review period, or reject the application forincompleteness and inform the applicant in writing of theinformation necessary to complete the application.

B. The 60-day review period begins on the day thecomplete stormwater management plan is accepted for review. Atthis time, an acknowledgement letter is sent to the applicant.During the 60-day review period, the locality shall eitherapprove or disapprove the plan and communicate its decision tothe applicant in writing. Approval or denial shall be based onthe plan's compliance with the locality's stormwater managementprogram.

C. A disapproval of a plan shall contain the reasons fordisapproval.

D. The applicant or any aggrieved party authorized by lawmay appeal a locality's decision of approval or disapproval of

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a stormwater management plan application within 30 days afterthe rendering of such a decision of the locality, to thecircuit court of the jurisdiction in which the land developmentproject is located.

E. Judicial review shall be on the record previouslyestablished and shall otherwise be in accordance with the'provisions of the Administrative Process Act (§ 9-6.14:1 etseq.).

§ 3.6. Administrative procedures: Conditions of approval. .

Each plan approved by a locality shall be subject to thefollowing conditions:

1* The applicant shall comply with all applicablerequirements of the approved plan, the local program, theseregulations and the Act, and shall certify that all landclearing, construction, land development and drainage will bedone according to the approved plan.

2. The land development project shall be conducted onlywithin the area specified in the approved plan.

3. The locality shall be allowed, after giving notice tothe owner, occupier or operator of the land developmentproject, to conduct periodic inspections of the project.

4. The person responsible for implementing the approvedplan shall conduct monitoring and submit reports as thelocality may require to ensure compliance with the approvedplan and to determine whether the plan provides effectivestormwater management*

5. No transfer, assignment or sale of the rights grantedby virtue of an approved plan shall be made unless a writtennotice of transfer is filed with the locality and thetransferee certifies agreement to comply with all obligationsand conditions of the approved plan.

§ 3.7. Administrative procedures: Changes to an approved plan.

No changes may be made to an approved plan without reviewand written approval by the locality.

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§ 3.8. Administrative procedures: Exceptions.

A. A request for an exception shall be submitted, inwriting, to the locality. An exception from the stormwatermanagement regulations may be granted, provided that: (i)exceptions to the criteria are the minimum necessary to affordrelief, and (ii) reasonable and appropriate conditions shall beimposed as necessary upon any exception granted so that thepurpose and intent of the Act is preserved.

B. Economic hardship is not sufficient reason to grant anexception from the requirements of this regulation.

A. Maintenance of stormwater management facilities is anintegral aspect of a stormwater management program.Responsibility for the operation and maintenance of stormwatermanagement facilities, unless assumed by a governmental agency,shall remain with the property owner and shall pass to any

\ successor or owner. If portions of the land are to be sold,legally binding arrangements shall be made to pass the basicresponsibility to successors in title. These arrangementsshall designate for each project the property owner,governmental agency, or other legally established entity to bepermanently responsible for maintenance.

B. In the case of developments where lots are to be sold,permanent arrangements satisfactory to the approving agencyshall be made to insure continued performance of theseobligations.

C. A schedule of maintenance inspections shall beincorporated into the local ordinance. Ordinances shall alsoprovide that in cases where maintenance or repair is neglected,or the stormwater management facility becomes a danger topublic health or safety, the locality has the authority toperform the work and to recover the costs from the owner.

D. Localities may require right of entry agreements oreasements from the applicant for purposes of inspection andmaintenance.

E. At a minimum, stormwater management facilities shallbe inspected on a semi-annual basis and after any storm whichcauses the capacity of the facility to be exceeded.

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F. During construction of the stormwater managementfacilities, localities shall make inspections on a regularbasis.

G. Inspection reports shall be maintained as part of theland development project file.

§ 3*10. Compliance,

If the locality determines that there is a failure to* comply with the plan, notice shall be served upon the applicantor person responsible for implementing the plan by registeredor certified mail to the address specified in the applicationor plan certification, or by delivery at the site ofdevelopment activities to the agent or employee supervisingsuch activities. The notice shall specify the measures neededto comply with the plan and shall specify the time within whichsuch measures shall be completed. Upon failure to complywithin the time specified, the permit may be revoked and theapplicant or person responsible for implementing the plan shallbe deemed to be in violation of the Act and upon convictionshall be subject to the penalties provided in § 10.1-603.14 ofthe Code of Virginia.

§ 3.11. Review of plans by the department.

The department will review any stormwater -management planwith real or potential inter jurisdictional impacts, upon therequest of one of the involved localities, to determine whetherthe plan is consistent with the provisions of the Act and theseregulations. Any such review shall be completed and a reportsubmitted to each locality involved within 90 days of suchrequest.

PART IV.

STATE AGENCY PROJECTS.

§ 4.1. Stormwater management plans or standards required.

A, After January 1, 1991, a state agency shall notundertake any land clearing, soil movement or constructionactivity involving soil movement or land development unless thestate agency has:

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1. Submitted to the department a stormwatermanagement plan for the state project and has obtainedapproval of the plan from the department; or2. Submitted annually to the department stormwatermanagement standards and specifications and hasobtained approval of those standards and

: -t specifications.

B. Stormwater management plans prepared for stateprojects shall comply with the technical criteria establishedin Part II of these regulations and, to the maximum extent'practicable, any local stormwater management requirements inaccordance with § 3. I.e. of these regulations.

C. The following schedule for compliance with the statestormwater management regulations shall be applied to stateprojects.

1. As of January 1, 1991, state projects subject tothe capital outlay process described in the Department

. of General Services, Division of Engineering andBuildings' Capital Outlay Manual that have receivedapproval of preplanning studies or schematic drawingsby the Art and Architectural Review Board, and thosecapital outlay projects not subject to the capitaloutlay manual that have completed 50% or more of finalconstruction plans, shall make every effort toretrofit their projects with the appropriate measures.However, substantial redesign of the project oradditional land acquisition will not be required. Ata minimum, these projects must comply with thestormwater management criteria established in thestate Erosion and Sediment Control Act and attendantregulations.2. All other state projects must comply fully withthese regulations as of January 1, 1991.

§ 4.2. Minimum requirements for stormwater management plans.

As a minimum, a stormwater management plan shall containthe following:

1. The location and the design of the proposedstormwater management facilities.2. Overall site plan.3. Comprehensive hydrologic and hydrauliccomputations for the pre-development and post-

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development two-year and 10-year storm events,considered individually.4. Calculations verifying compliance with the waterquality requirements.5. A description of the requirements for maintenanceof the stormwater management facilities and arecommended schedule of inspection and maintenance.6. The identification of a person or persons who willbe responsible for maintenance.7. Certification of maps, plans and designs by aprofessional engineer or Class III B surveyor.

§ 4.3. Minimum requirements for submission of stormwatermanagement standards and specifications.

A. A request for approval of stormwater managementstandards and specifications may be submitted to the departmentby a state agency on an annual basis. At a minimum, thefollowing certifications shall accompany the request.

1. Individual stormwater management plans shall beprepared for all state agency projects.2. The stormwater management plans shall comply withthe technical requirements established in Part II ofthese regulations and, to the maximum, extentpracticable, any local stormwater managementrequirements in accordance with § 3.I.e. of theseregulations.3. An inspection and maintenance schedule shall bedeveloped and implemented.

B. Copies of stormwater management specifications andstandards including, but not limited to, design manuals,technical guides and handbooks, sb->*l be submitted.

§ 4.4. Actions on plans or specifications by the department.

A. Not later than 30 days after receipt of a completestormwater management plan submitted by a state agency, thedepartment shall approve or disapprove the plan.

1. The department shall transmit its decision inwriting to the state agency which submitted the plan.2. Disapproved plans must be resubmitted to thedepartmant.

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B. The department's recommendations shall be binding onthe state agency and on the private business or businesses, ifany, hired by the state agency.

C. A state agency shall not change an approved stormwatermanagement plan without approval from the department.

'»§ 4.5* Compliance.

A. The state agency responsible for the land development"shall ensure compliance with the approved plan orspecifications, even if actual plan implementation is performedby a private business or businesses, hired by the state agency.

B. The department shall perform random site inspectionsof state projects to assure compliance with these regulations,the Erosion and Sediment Control Act and related regulations.

C. The department may require monitoring and reports fromthe state agency responsible for implementing the plan, toensure compliance with the approved plan and to determine ifthe measures required in the plan provide effective stormwatermanagement.

PART V.

REPORTING.

§ 5.1 Reporting on stormwater management.

A. Localities with stormwater management programs andstate agencies shall submit an annual report to the department.The report shall cover the period from July 1 to June 30 andshall be submitted to the department by September 1.

B. For localities, an annual report shall include, at aminimum, the number and type of stormwater facilities installedin the locality during the preceding year; their storagecapacities; the affected water body, watershed or basin; asummary of any water quality monitoring data associated withthe facilities; and the number and reasons for any exceptionsapproved by the locality.

C. For state agencies, an annual report shall include, ata minimum, the location (locality) , number and type ofstormwater facilities installed during the preceding year;their storage capacities; the affected water body, watershed or



basin; and a summary of any water quality monitoring dataassociated with the facilities.

.- STORMWATER KANAGEMENT ACT•

The following is the complete, edited text of Title 10.1,Chapter 6, Article 1.1 of the Code of Virginia as amended through1991.

§ 10.1-603.1. Cooperative state-local program.

The General Assembly has determined that the lands and waters ofthe Commonwealth are great natural resources; that as result ofintensive land development and other land use conversions.degradation of these resources frequently occurs in the form ofwater pollution, stream channel erosion, depletion of groundwater

:* resources, and more frequent localized flooding; that theseimpacts adversely affect fish, aquatic life, recreation,shipping, property values and other uses of lands and waters;that existing authorities under the Code of Virginia do notadequately address all of these impacts. Therefore, the GeneralAssembly finds it in the public interest to enable theestablishment of stormwater management programs.

§ 10.1-603.2. Definitions.

"Applicant" means any person submitting a stormwatermanagement plan for approval.

"Board" means the Board of Conservation and Recreation.

"Department" means the Department of Conservation andRecreation.

"Flooding" means a volume of water which is too great to beconfined within the banks or walls of the stream, water body orconveyance system and which overflows onto adjacent lands,causing or threatening damage.

"Land development" or "land development project" means amanmade change to the land surface that potentially changes itsrunoff characteristics.

"Local stormwater management program" or "local program"means a statement of the various methods employed by a localityto manage the runoff from land development projects and mayinclude such items as local ordinances, policies and guidelines,technical materials, inspection, .enforcement, and evaluation.

"Nonpoint source pollution" means .pollution whose sourcescannot be pinpointed but rather is washed from the land surfacein a diffuse manner by stormwater runoff.

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;- "Runoff" means that portion of precipitation that isdischarged across the land surface or through conveyances to oneor more waterways.

"Subdivision" means the same as defined in § 15.1-465.

§ 10.1-603.3. Counties, cities and towns may by ordinanceestablish stormwater management programs as a local option;effective date.'»Each locality may, by ordinance, to be effective on or afterJuly 1, 1990, establish a local stormwater management programwhich shall include, but is not limited to, the following:

1. Consistency with regulations promulgated in accordancewith provisions of this article;

2. Provisions for long-term responsibility for andmaintenance of stormwater management control devices andother techniques specified to manage the quality andquantity of runoff; and

3. Provisions for the integration of locally adoptedstormwater management programs with local erosion andsediment control, flood insurance, flood plain managementand other programs requiring compliance prior to authorizingconstruction in order to make the submission and approval ofplans, issuance of permits, payment of fees, andcoordination of inspection and enforcement activities moreconvenient and efficient both for the local governments andthose responsible for compliance with the programs.

S 10.1-603.4. Development of regulations.

The Board is authorized to promulgate regulations which specifyminimum technical criteria and administrative procedures forstormwater management programs in Virginia. In order to inhibitthe deterioration of existing waters and waterways, theregulations shall:

1. Require that state and local programs maintain after-development runoff rate of flow, as nearly as practicable,as the pre-development runoff characteristics;

2. Establish minimum design criteria for measures tocontrol nonpoint source pollution and localized flooding,and incorporate the stormwater management regulationspromulgated pursuant to the Virginia Erosion and SedimentControl Law, Article 4 (§ 10.1-560 et seq.) of Chapter 5 of

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.' this title, as they relate to the prevention of stream.. * channel erosion. These criteria shall be periodically

modified as required in order to reflect current engineeringmethods;

3. Require the provision of long-term responsibility forand maintenance of stormwater management control devices andother techniques specified to manage the quality andquantity of runoff; and

4. Require as a minimum the inclusion in local programs ofcertain administrative procedures which include, but are notlimited to, specifying the time period within which a localgovernment which has adopted a stormwater management programmust grant written approval of a plan, the conditions underwhich approval shall be granted, the procedures forcommunicating disapproval, the conditions under which anapproved plan may be changed and requirements for inspectionof approved projects.

§ 10.1-603.5. State agency projects.

A. After January 1, 1991, a state agency may not undertake anyland clearing, soil movement, or construction activity involvingsoil movement or landdevelopment unless the agency has submittedand obtained approval of a stormwater management plan from theDepartment. In lieu of such a plan, the agency may annuallysubmit stormwater management standards and specifications.

B. Notwithstanding the provisions of this article, all stateagencies shall comply with the stormwater management provisionsof the Erosion and Sediment Control Law, Article 4 (§ 10.1-560 etseq.) of Chapter 5 of this title, and related regulations. TheDepartment shall perform random site inspections to assurecompliance with this article, the Erosion and Sediment ControlLaw and regulations promulgated thereunder.

C. The Department shall have thirty days in which to comment onthe stormwater management plan, and its recommendations shall bebinding on the state agency or the private business hired by thestate agency. Individual approval of separate projects is notnecessary when annually approved standards and specificationshave been approved.

As on-site changes occur, the state agency shall submit changesin the stormwater management plan to the Department.

The state agency responsible for the land-disturbing activityshall ensure compliance with the approved plan or specifications.

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§ .10.1-603.6. Involvement of the Department with local programs.

B. The Department is authorized to review the plan for anyproject with real or potential interjurisdictional impacts uponthe request of one of the involved localities to determine thatthe plan is consistent with the provisions of this article. Anysuch review shall be completed and a report submitted to eachlocality involved within ninety days of such request.*>

§ 10.1-603.7. Authorization for more stringent regulations..Localities are authorized to adopt more stringent stormwatermanagement regulations than those necessary to ensure compliancewith the Board's minimum regulations, with the exception ofregulations related to plan approval, provided that the morestringent regulations are based upon the findings of localcomprehensive watershed management studies and that prior toadopting more stringent regulations a public hearing is heldafter giving due notice.

§ 10.1-603.8. Regulated activities; submission and approval of acontrol plan; security for performance; exemptions.

A. Except as provided in § 10.1-603.5, after the adoption of alocal ordinance, a person shall not develop any land forresidential, commercial, industrial, or institutional use in thatlocality until he has submitted a stormwater management plan tothe locality that has jurisdiction and has obtained approval ofthe plan from that locality. The plan may include appropriatemaps, mathematical calculations, detail drawings and a listing ofall major decisions to assure that the entire unit or units ofland will be so treated to achieve the objectives of the localprogram. Prior to issuance of any permit, the locality may alsorequire an applicant to submit a reasonable performance bond withsurety, cash escrow, letter of credit, any combination thereof,or such other legal arrangement acceptable to the locality, toensure that measures could be taken by the locality at theapplicant's expense should he fail, after proper notice, withinthe time specified to initiate or maintain appropriate actionswhich may be required of him by the approved stormwatermanagement plan as a result of his land-development project. Ifthe locality takes such action upon such failure by theapplicant, the agency may collect from the applicant for thedifference should the amount of the reasonable cost of suchaction exceed the amount of the security held. Within sixty daysof the completion of the requirements of the approved stormwatermanagement plan, such bond, cash escrow, letter of credit or

ARI0837U

other legal arrangement, or the unexpended or unobligated portion.thereof, shall be refunded to the applicant or terminated. Theserequirements are in addition to all other provisions 'of lawrelating to the issuance of such plans and are not intended tootherwise affect the requirements for such plans.

B. Notwithstanding any other provisions of this article, thefollowing activities are exempt:

1. Permitted surface or deep mining operations andprojects, or oil and gas operations and projects conductedunder the provisions of Title 45.1 of the Code of Virginia;

2. Tilling, planting or harvesting of agricultural,horticultural, or forest crops;

3. Single-family residences separately built and not partof a subdivision, including additions or modifications toexisting single-family detached residential structures; and

4. Land development projects that disturb less than oneacre of land area; however, the governing body of a localitywhich has adopted a stormwater management program may reducethis exception to a smaller area of disturbed land orqualify the conditions under which this exception shallapply.

§ 10.1-603.9. Approved plan required for issuance of grading,building, or other permits.

Upon the adoption of a local ordinance no grading, building orother permit shall be issued for a property unless a stormwatermanagement plan has been approved that is consistent with thelocal program and this article and unless the applicant hascertified that all land clearing, construction, land developmentand drainage will be done according to the approved plan.

§ 10.1-603.10. Recovery of administrative costs.

Any locality which administers a stormwater management programmay charge applicants a reasonable fee to defray the cost ofprogram administration, including costs associated with planreview, issuance of permits, periodic inspection for compliancewith approved plans, and necessary enforcement, provided thatcharges for such costs are not made under any other law,ordinance or program. The fee shall not exceed an amountcommensurate with the services rendered and expenses incurred or$1,000, whichever is less.

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. § 10.1-603.11. Monitoring, reports and inspections.

A. The plan-approving authority or, if a permit is issconnection with land-disturbing activities which involvissuance of a grading, building, or other permit, the pissuing authority (i) shall provide for periodic inspections ofthe installation of stormwater management measures and (ii) mayrequire monitoring and reports from the person responsible forcarrying out the plan, to ensure compliance with the approvedplan and to determine whether the measures required in the planprovide effective stormwater management. The owner, occupier oroperator shall be given notice of the inspection and anopportunity to accompany the inspectors. If the permit-issuingauthority or plan-approving authority determines that there is afailure to comply with the plan, notice shall be served upon thepermittee or person responsible for carrying out the plan by

% -registered or certified mail to the address specified in thepermit application or in the plan certification, or,by deliveryat the site of the development activities to the agent oremployee supervising such activities. Where the plan-approvingauthority serves notice, a copy of the notice shall also be sentto the issuer of the permit. The notice shall specify themeasures needed to comply with the plan and shall specify thetime within which such measures shall be completed. Upon failureto comply within the time specified, the permit may be revokedand the permittee or person responsible for carrying out the plan

\ shall be deemed to be in violation of this article and uponconviction shall be subject to the penalties provided by § 10.1-603.14.

B. Notwithstanding subsection A of this section, the followingmay be applied:

1. Where a county, city, or town administers the localcontrol program and the permit-issuing authority and theplan-approving authority are not within the same localgovernment department, tha locality may designate onedepartment to inspect, monitor, report and ensurecompliance.

2. Where a permit-issuing authority has been established,and such authority is not vested in an employee or officerof local government but in *.!:. commissioner of revenue orsome other person, the locality shall exercise theresponsibilities of the permit-issuing authority withrespect to monitoring, reports, inspections, and enforcementunless such responsibilities are transferred as provided forin this section.

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§ ,10.1-603.12. Department to review local and state agencyprograms. *

A. The Department shall periodically conduct a comprehensivereview and evaluation of the effectiveness of each localgovernment's and state agency's stormwater management program.The review shall include an assessment cf the extent to which theprogram has reduced nonpoint source pollution and mitigated thedetrimental effects of localized flooding. A summary of thesereviews and evaluations shall be submitted annually to theGeneral Assembly.

B. If, after such a review and evaluation, a local government is:>found to have a program which does not comply with the provisionsof this article or regulations promulgated thereunder, theDepartment may issue an order requiring that necessary correctiveaction be taken within a reasonably prescribed time.

§ 10.1-603.13. Appeals of decisions of counties, cities ortowns.

A. An appeal from a decision of a locality concerning anapplication for approval or disapproval of a stormwatermanagement plan may be taken by the applicant, or any aggrievedparty authorized by law, within thirty days after the renderingof such a decision of the locality, to the circuit court of thejurisdiction in which the land development project is located.B. Judicial review shall be on the record previously establishedand shall otherwise be in accordance with the provisions of theAdministrative Process Act (§ 9-6.14:1 et seq.).

§ 10*1-603.14. Penalties, injunctions and other legal actions.

Any person who violates any provision of a local ordinance orprogram adopted pursuant to the authority of this article shallbe guilty of a misdemeanor and shall be subject to a fine notexceeding $1,000 or up to thirty days imprisonment for eachviolation or both. Such a local ordinance may also include thefollowing sanctions:

1. A locality operating its own program may apply to thecircuit court in any jurisdiction wherein the land lies toenjoin a violation or a threatened violation of theprovisions of this article or of the local ordinance withoutthe necessity of showing that an adequate remedy at law doesnot exist.

2. Without limiting the remedies which may be obtained inthis section, a locality operating its own program may bringa civil action against any person for violation of anyordinance or any condition of a permit, or any provision ofa local program adopted pursuant to this article. The

3. With the consent of any person who has violated orfailed, neglected or refused to obey any ordinance or anycondition of a permit or any provision of a local programadopted pursuant to this article, the administrator of thelocal program may provide, in an order issued by theadministrator against such person, for the payment of civilcharges for violations in specific sums, not to exceed thelimit specified in subdivision 2 of this section. Suchcivil charges shall be instead of any appropriate civil

\ penalty which could be imposed under subdivision 2.

§ 10.1-603.15. Cooperation with federal and state agencies.

Localities operating their own programs and the Department areauthorized to cooperate and enter into agreements with anyfederal or state agency in connection with plans for stormwatermanagement*

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IQ.

Appendix H

Commonwealth of Virginia VPDES General Permit for Stormwater Discharge fromConstruction Sites Regulations/Requirements (VR 680-14-19)

ARI08380

i .>§7. General permit.

Any owner whose registration statement is accepted by thedirector or his designee will receive the following permit andshall comply with the requirements therein and be subject to allrequirements of the Permit Regulation.

General Permit No.: VAR4xxxxx

Effective Date:

Expiration Date:

GENERAL PERMIT FOR STORM WATER

DISCHARGES FROM CONSTRUCTION SITES

AUTHORIZATION TO DISCHARGE UNDER THE VIRGINIA POLLUTANT DISCHARGEELIMINATION SYSTEM AND THE VIRGINIA STATE WATER CONTROL LAW

In compliance with the provisions of the Clean Water Act, asamended, and pursuant to the State Water Control Law andregulations adopted pursuant thereto, owners of constructionsites (those sites or common plans of development or sale thatwill result in the disturbance of five of more acres total landarea) with storm water discharges associated with industrialactivity from these construction sites are authorized todischarge to surface waters within the boundaries of theCommonwealth of Virginia, except those where Board regulation orpolicies prohibit such discharges.

The authorized discharge shall be in accordance with thiscover page, Part I. Effluent Limitations and MonitoringRequirements, Part II. Monitoring and Reporting, Part III. StormWater Pollution Prevention Plan and Part IV. ManagementRequirements, as set forth herein.

PART I. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS.

A. Storm water from construction sites.

1. During the period beginning with the date of coverage underthis permit and lasting until the permit's expiration date, thepermittee is authorized to discharge from point sources, stormwater from construction sites.

Such discharges shall be limited and monitored by the

Copyright 1996 The Bureau of National Affairs, Inc.

ARI0838I

permittee as specified below:

NO LIMITATIONS OR MONITORING REQUIRED

2. There shall be no discharge of floating solids or visiblefoam in other than trace amounts.

PART II. MONITORING AND REPORTING.

A. Sampling and Analysis Methods.

1. Samples and measurements taken if requested by the directorshall be representative of the volume and nature of the monitoredactivity.

2. Unless otherwise specified in this permit all samplepreservation methods, maximum holding times and analysis methodsfor pollutants shall comply with requirements set forth inGuidelines Establishing Test Procedures for the Analysis ofPollutants { 40 CFR Part 136 (1994)).

3. The sampling and analysis program to demonstrate compliancewith the permit shall at a minimum, conform to Part I of thispermit.

4. The permittee shall periodically calibrate and performmaintenance procedures on all monitoring and analyticalinstrumentation at intervals that will insure accuracy ofmeasurements, in accordance with approved EPA and stateprotocols.

B. Recording of Results.

For each measurement or sample taken pursuant to therequirements of this permit, the permittee shall record thefollowing information:

1. The date, exact place and time of sampling or measurements;

2. The person(s) who performed the sampling or measurements;

3. The dates analyses were performed;

4. The person(s) who performed each analysis;

5. The analytical techniques or methods used; and

6. The results of such analyses and measurements.


7. The date and duration (in hours) of the storm event(s)i j sampled;

8. The rainfall measurements or estimates (in inches) of thestorm event which generated the sampled runoff; and

9. The duration between the storm event sampled and the end ofthe previous measurable (greater than 0.1 inch rainfall) stormevent.

C. Records Retention.

All records and information resulting from the monitoring andinspection activities required by this permit, including allrecords of analyses performed and calibration and maintenance ofinstrumentation and recording from continuous monitoringinstrumentation, shall be made a part of the pollution preventionplan and shall be retained on site or at the corporate office forthree years from the date of the sample, measurement, report orapplication or until at least one year after coverage under thispermit terminates, whichever is later. This period of retentionshall be extended automatically during the course of anyunresolved litigation regarding the regulated activity orregarding control standards applicable to the permittee, or asrequested by the director.

"" ' The permittee shall retain a copy of the storm water pollution^-^ * prevention plan required by this permit at the construction site

from the date of commencement of construction to the date offinal stabilization.

D. Additional Monitoring by Permittee.

If the permittee monitors any pollutant at the location (s)designated herein more frequently than required by this permit,using approved analytical methods as specified above, the resultsof such monitoring shall be included in the calculation andreporting of the values required by this permit. Such increasedfrequency shall also be reported.

E. Water Quality Monitoring.

The director may require the permittee to furnish such plans,specifications, or other pertinent information as may benecessary to determine the effect of the pollutant (s) on thewater quality or to ensure pollution of state waters does notoccur or such information as may be necessary to accomplish thepurposes of the Virginia State Water Control Law, Clean WaterAct or the Permit Regulation.

The permittee shall obtain and report such information ifrequested by the director. Such information shall be subject to


Aft 108383

inspection by authorized state and federal representatives andshall be submitted with such frequency and in such detail asrequested by the director.

F. Reporting Requirements.

1. The permittee shall submit any monitoring data collectedduring the term of the permit to the department uponreregistration for coverage under the general permit.

2. If, for any reason, the permittee does not comply with oneor more limitations, standards, monitoring or managementrequirements specified in this permit, the permittee shall submitto the department as quickly as possible upon discovery, at leastthe following information:

a. A description and cause of noncompliance;

b. The period of noncompliance, including exact dates andtimes or the anticipated time or both when the noncompliance willcease; and

c. Actions taken or to be taken to reduce, eliminate, andprevent recurrence of the noncompliance.

Whenever such noncompliance may adversely affect surfacewaters of the state or may endanger public health, the permitteeshall submit the above required information by oral report within24 hours from the time the permittee becomes aware of thecircumstances and by written report within five days. Thedirector may waive the written report requirement on acase-by-case basis if the oral report has been received within 24hours and no adverse impact on surface waters of the state hasbeen reported.

3. The permittee shall report any unpermitted, unusual orextraordinary discharge which enters or could be expected toenter surface waters of the state. The permittee shall provideinformation specified in Part II F 2 a-c regarding each suchdischarge immediately, that is as quickly as possible upondiscovery, however, in no base later than 24 hours. A writtensubmission covering these points shall be provided to thedepartment within five days of the time the permittee becomesaware of the circumstances covered by this paragraph.

Unusual or extraordinary discharge would include but not belimited to (i) unplanned bypasses, (ii) upsets, (iii) spillage ofmaterials resulting directly or indirectly from processingoperations or pollutant management activities, (iv) breakdown ofprocessing or accessory equipment, (v) failure of or taking outof service, sewage or industrial waste treatment facilities,auxiliary facilities or pollutant management activities, or (vi)


ARI083814

flooding or other acts of nature.

V^ If the department's regional office cannot be reached, a24-hour telephone service is maintained in Richmond(804-527-5200) to which the report required above is to be made.

G. Signatory Requirements.

Any registration statement, report, certification, or Noticeof Termination required by this permit shall be signed asfollows:

1. Registration Statement/Notice of Termination.

a. For a corporation, by a responsible corporate official. Forpurposes of this section, a responsible corporate official means(i) a president, secretary, treasurer, or vice-president of thecorporation in charge of a principal business function, or anyother person who performs similar policy or decision-makingfunctions for the corporation, or (ii) the manager of one or moremanufacturing, production, or operating facilities employing morethan 250 persons or having gross annual sales or expendituresexceeding $25,000,000 (in second-quarter 1980 dollars), ifauthority to sign documents has been assigned or delegated to themanager in accordance with corporate procedures.

b. For a municipality, state, federal or other public agency^j • by either a principal executive officer or ranking elected

official. (A principal executive officer of a federal, municipal,or state agency includes the chief executive officer of theagency or an executive officer having responsibility for theoverall operation of a principal geographic unit of the agency).

c. For a partnership or sole proprietorship, by a generalpartner or proprietor respectively.

2. Reports. All reports required this permit and otherinformation requested by the director shall be signed by:

a. One of the persons described in subdivision :. a, b, or c ofthis subsection; or

b. A duly authorized representative of that person. A personis a duly authorized representative only if:

(1) The authorization is made in writing by a person describedin subdivision 1 a, b, or c of this subsection and submitted tothe director; and

(2) The authorization specifies either an individual or aposition having responsibility for the overall operation of theregulated facility or activity, such as the position of facility


AR108385

manger, superintendent, or position of equiyalent responsibility.(A duly authorized representative may thus be either a namedindividual or any individual occupying a named position).

(3) If an authorization is no longer accurate because adifferent individual or position has responsibility for theoverall operation of the facility, a new authorization must besubmitted to the director prior to or together with any separateinformation, Registration Statement or Notice of Termination tobe signed by an authorized representative.

3. Certification. Any person signing a document undersubdivision 1 or 2 of this subsection shall make the followingcertification: I certify under penalty of law that this documentand all attachments were prepared under my direction orsupervision in accordance with a system designed to assure thatqualified personnel properly gather and evaluate the informationsubmitted. Based on my inquiry of the person or persons whomanage the system or those persons directly responsible forgathering the information, the information submitted is to thebest of my knowledge and belief true, accurate, and complete. Iam aware that there are significant penalties for submittingfalse information including the possibility of fine ar.dimprisonment for knowing violations.

H. Prohibition on Nonstorm Water Discharges.

All discharges covered by this permit shall be composedentirely of storm water except as provided in subdivisions 1 and2 of this subsection.

1. Except as provided in subdivision 2 of this subsection,discharges of material other than storm water must be incompliance with a VPDES permit (other than this permit) issuedfor the discharge.

2. The following nonstorm water discharges may be authorizedby this permit provided the nonstorm water component of thedischarge is in compliance with Part III D 5: discharges fromfire fighting activities; fire hydrant flushing; waters used towash vehicles or control dust in accordance with Part III D 2 c(2); potable water sources including waterline flushing;irrigation drainage; lawn watering, routine external buildingwashdown which does not use detergents; pavement washwaters wherespills or leaks of toxic or hazardous materials have not occurred(unless all spilled material has been removed) and wheredetergents are not used; air conditioning condensate; springs;uncontaminated ground water; and foundation or footing drainswhere flows are not contaminated with process materials such assolvents.

I. Releases in Excess of Reportable Quantities.


ARI 08386

1. This permit does not relieve the permittee of the reportingrequirements of 40 CFR Part 117 (1992) and 40 CFR Part302 (1992). The discharge of hazardous substances or oil in thestorm water discharge(s) from a construction site shall beprevented or minimized in accordance with the applicable stormwater pollution prevention plan for the site. Where a releasecontaining a hazardous substance in an amount equal to or inexcess of a reporting quantity established under either 40CFR Part 117 (1992) or 40 CFR Part 302 (1992) occurs during a24-hour period, the storm water pollution prevention plan must bemodified within 14 calendar days of knowledge of the release. Themodification shall provide a description of the release, thecircumstances leading to the release, and the date of therelease. In addition, the plan must be reviewed by the permitteeto identify measures to prevent the reoccurrence of such releasesand to respond to such releases, and the plan must be modifiedwhere appropriate.

2. Spills. This permit does not authorize the discharge ofhazardous substances or oil resulting from an on-site spill.

PART III. STORM WATER POLLUTION PREVENTION PLANS.

A storm water pollution prevention plan shall be developed forthe construction site covered by this permit. Storm waterpollution prevention plans shall be prepared in accordance withgood engineering practices. The plan shall identify potentialsources of pollution which may reasonably be expected to affectthe quality of storm water discharges from the construction site.In addition, the plan shall describe and ensure theimplementation of practices which will be used to reduce thepollutants in storm water discharges at the construction site andto assure compliance with the terms and conditions of thispermit. Permittees must implement the provisions of the stormwater pollution prevention plan required under this part as acondition of this permit.

A. Deadlines for Plan Preparation and Compliance.

1. For construction activities that have begun on or beforethe effective date of this permit, the plan shall be prepared andprovide for compliance with the terms and schedule of the planbeginning within 30 days after the effective date of this permit.

2. For construction activities that have begun after theeffective date of this permit, the plan shall be prepared priorto submittal of the registration statement and provide forcompliance with the terms and schedule of the plan beginning with


ARI08387

the initiation of construction activities.

3. For ongoing construction activity involving a change ofownership of property covered by this general permit, the newowner shall accept and maintain the existing storm waterpollution prevention plan or prepare and implement a new stormwater pollution prevention plan prior to taking over operationsat the site.

B. Signature and Plan Review.

1. The plan shall be signed in accordance with Part II G, andbe retained on-site at the facility which generates the stormwater discharge in accordance with Part II C (retention ofrecords) of this permit.

2. The permittee shall make plans available upon request tothe department; a state or local agency approving sediment anderosion plans, grading plans, or storm water management plans; orin the case of a storm water discharge associated with industrialactivity which discharges through a municipal separate stormsewer system to the municipal operator of the system.

3. The director may notify the permittee at any time that theplan does not meet one or more of the minimum requirements ofthis part. Such notification shall identify those provisions ofthe permit which are not being met by the plan and identify whichprovisions require modifications in order to meet the minimumrequirements of this permit. Within seven days of suchnotification the permittee shall make the required changes andshall submit to the department a written certification that therequested change have been made.

C. Keeping Plans Current.

The permittee shall amend the plan whenever there is a changein design, construction, operation, or maintenance, which has asignificant effect on the potential for the discharge ofpollutants to the surface waters of the state and which has nototherwise been addressed in the plan or if the storm waterpollution prevention plan proves to be ineffective in eliminatingor significantly minimizing pollutants from sources identifiedunder Part III D 1 of this permit, or in otherwise achieving thegeneral objectives of controlling pollutants in storm waterdischarges associated with industrial activity. The plan shall beamended in accordance with Part III E to identify any newcontractor that will implement a measure of the plan.

D. Contents of Plan.

The storm water pollution prevention plan shall include thefollowing items:


ARI08388

1. Site Description. Each plan shall provide a description ofpollutant sources and other information as indicated:

a. A description of the nature of the construction activity;

b. A description of the intended sequence of major activitieswhich disturb soils for major portions of the site (e.g.grubbing, excavation, grading);

c. Estimates of the total area of the site and the total areaof the site that is expected to be distrubed by excavation,grading, or other activities;

d. An estimate of the runoff coefficient of the site prior toconstruction and after construction activities are completed andexisting data describing the soil or the quality of any dischargefrom the site;

e. A description of existing vegetation at the site;

f. A description of any other potential pollution sources,such as vehicle fueling, storage of fertilizers or chemicals,sanitary waste facilities, etc.

g. The name of the receiving water(s) and the ultimatereceiving water(s), and areal extent of wetland acreage at thesite.

h. A site map indicating:

(1) drainage patterns and approximate slopes and contoursanticipated after major grading activities;

(2) areas of soil disturbance;

(3) the location of major structural and nonstructuralcontrols identified in the plan;

(4) the location of areas where stabilization practices areexpected to occur including the types of vegetative cover;

(5) surface waters (including wetlands);

(6) locations where storm water is discharged to a surfacewater with an outline of the drainage area for each dischargepoint;

(7) existing and planned paved areas and buildings;

(8) locations of permanent storm water management practices tobe used to control pollutants in storm water after construction


ARI08389

— activities have been completed.

(9) locations of other potential pollution sources asdescribed in subdivision 1 f of this subsection.

Two site maps may be developed, one indicating preconstructionsite conditions and the second indicating final site conditions.The two maps should be on the same scale.

2. Controls. Each plan shall include a description ofappropriate controls and measures that will be implemented at theconstruction site. The plan will clearly describe for each majoractivity identified in the site plan appropriate control measuresand the timing during the construction process that the measureswill be implemented. (For example, perimeter controls for oneportion of the site will be installed after the clearing andgrubbing necessary for installation of the measure, but beforethe clearing and grubbing for the remaining portions of the site.Perimeter controls will be actively maintained until finalstabilization of those portions of the site upward of theperimeter control. Temporary perimeter controls will be removedafter final stabilization). The description and implementation ofcontrols shall address the following minimum components:

a. Erosion and Sediment Controls.

i (1) Stabilization Practices. A description of interim and>s~y ' permanent stabilization practices, including site-specific

scheduling of the implementation of the practices. Site plansshould ensure that existing vegetation is preserved whereattainable and that disturbed portions of the site arestabilized. Stabilization practices may include: temporaryseeding, permanent seeding, mulching, geotextiles, sodstabilization, vegetative buffer strips, protection of trees,preservation of mature vegetation, and other appropriatemeasures. A record of the dates when major grading activitieswill occur, when construction activities temporarily orpermanently cease on a portion of the site, and whenstabilization measures will be initiated shall be included in theplan. Except as provided in Part III D 2 a (1) (a) and (b),stabilization measures shall be initiated as soon as practicablein portions of the site where construction activities havetemporarily or permanently ceased, but in no case more than 14days after the construction activity in that portion of the sitehas temporarily or permanently ceased.

(a) Where the initiation of stabilization measures by the 14thday after construction activity temporary or permanently cease isprecluded by snow cover, stabilization measures shall beinitiated as soon as practicable.

(b) Where construction activity will resume on a portion of


the site within 21 days from when activities ceased (e.g., thetotal time period that construction activity is temporarilyceased is less than 21 days), then stabilization measures do nothave to be initiated on that portion of site by the 14th dayafter construction activity temporarily ceased.

(2) Structural Practices. A description of structuralpractices to divert flows from exposed soils, store flows orotherwise limit runoff and the discharge of pollutants fromexposed areas of the site to the degree attainable. Suchpractices may include silt fences, earth dikes, drainage swales,sediment traps, check dams, subsurface drains, pipe slope drains,level spreaders, storm drain inlet protection, rock outletprotection, reinforced soil retaining systems, gabions, andtemporary or permanent sediment basins. Structural practicesshould be placed on upland soils to the degree attainable. Theinstallation of these devices may be subject to Section 404 ofthe CWA.

(a) For common drainage locations that serve an area with 10or more disturbed acres at one time, a temporary (or permanent)sediment basin providing 3,600 cubic feet of storage per acredrained, or equivalent control measures, shall be provided whereattainable until final stabilization of the site. The 3,600 cubicfeet of storage area per acre drained does not apply to flowsfrom offsite areas and flows from onsite areas that are eitherundisturbed or have undergone final stabilization where suchflows are diverted around both the disturbed area and thesediment basin. For drainage locations which serve 10 or moredisturbed acres at one time and where a temporary sediment basinproviding 3,600 cubic feet of storage per acre drained, orequivalent controls is not attainable, smaller sediment basinsand/or sediment traps should be used. At a minimum, silt fences,or equivalent sediment controls are required for all sideslopeand downslope boundaries of the construction area.

(b) For drainage locations serving less than 10 acres,sediment basins or sediment traps or both should be used. At aminimum silt fences or equivalent sediment controls are requiredfor all sideslope and downslope boundaries of the constructionarea unless a sediment basin oroviding storage for 3,600 cubicfeet of storage per acre drained is provided.

b. Storm Water Management. A description of measures that willbe installed during the construction process to controlpollutants in storm water discharges that will occur afterconstruction operations have been completed. Structural measuresshould be placed on upland soils to the degree attainable. Theinstallation of these devices may be subject to Section 404 ofthe CWA. This permit only addresses the installation of stormwater management measures, and not the ultimate operation andmaintenance of such structures after the construction activities


ARI0839I

have been completed and the site has undergone finali, stabilization. Permittees are only responsible for the

installation and maintenance of storm water management measuresprior to final stabilization of the site, and are not responsiblefor maintenance after storm water discharges associated withindustrial activity have been eliminated from the site.

(1) Such practices may include: storm water detentionstructures (including dry ponds); storm water retentionstructures; flow attenuation by use of open vegetated swales andnatural depressions; infiltration of runoff onsite; andsequential systems (which combine several practices). Thepollution prevention plan shall include an explanation of thetechnical basis used to select the practices to control pollutionwhere flows exceed predeveloptnent levels.

(2) Velocity dissipation devices shall be placed at dischargelocations and along the length of any outfall channel asnecessary to provide a nonerosive velocity flow from thestructure to a water course so that the natural physical andbiological characteristics and functions are maintained andprotected.

c. Other Controls,

(1) No solid materials, including building materials, garbage,> and debris shall be discharged to surface waters of the state,^ " except as authorized by a Section 404 permit.

(2) Where construction vehicle access routes intersect pavedpublic roads, provisions shall be made to minimize the transportof sediment by vehicular tracking onto the paved surface. Wheresediment is transported onto a public road surface, the roadshall be cleaned thoroughly at the end of each day. Sedimentshall be removed from the roads by shoveling or sweeping andtransported to a sediment control disposal area. Street washingshall be allowed only after sediment is removed in this manner.

(3) The plan shall ensure and demonstrate compliance withapplicable state or local waste disposal or both, sanitary seweror septic system regulations.

d. Approved State or Local Plans.

An erosion and sediment control plan that is approved by stateor local officials may be used to satisfy the requirements ofthis permit for the development of a pollution prevention plan ifall the requirements of the pollution prevention plan are met bythe erosion and sediment control plan. Any erosion and sedimentcontrol plans or storm water management plans approved by stateor local officials shall be retained with the storm water

1 pollution prevention plan prepared in accordance with this\


permit. Requirements specified in sediment and erosion site plansor site permits or storm water management site plans or sitepermits approved by state or local officials that are applicableto protecting surface water resources are, upon submittal of aRegistration Statement to be authorized to discharge under thispermit, incorporated by reference and are enforceable under thispermit even if they are not specifically included in a stormwater pollution prevention plan required under this permit. Thisprovision does not apply to provisions of master plans,comprehensive plans, nonenforceable guidelines or technicalguidance documents that are not identified in a specific plan orpermit that is issued for the construction site.

3. Maintenance. A description and schedule of procedures tomaintain in good and effective operating conditions vegetation,erosion and sediment control measures and other protectivemeasures during construction identified in the site plan.

4. Inspections. Qualified facility personnel shall inspectdisturbed areas of the construction site that have not beenfinally stabilized, and areas used for storage of materials thatare exposed to precipitation, structural control measures, andlocations where vehicles enter or exit the site. Theseinspections shall be conducted at least once every seven calendardays and within 24 hours of the end of a storm event that is 0.5inches or greater. Where areas have been finally stabilized suchinspections shall be conducted at least once every month.

a. Disturbed areas and areas used for storage of materialsthat are exposed to precipitation shall be inspected for evidenceof, or the potential for, pollutants entering the drainagesystem. Erosion and sediment control measures identified in theplan shall be observed to ensure that they are operatingcorrectly. Where discharge locations or points are accessible,they shall be inspected to ascertain whether erosion controlmeasures are effective in preventing significant inpacts toreceiving waters. Locations where vehicles enter or exit the siteshall be inspected for evidence of offsite sediment, tracking.

b. Based on the results of the inspection, the sitedescription identified in the plan in accordance with Part III D1 of this permit and pollution prevention measures identified inthe plan in accordance with Part III D 2 of this permit shall berevised as appropriate, but in no case later than seven calendardays following the inspection. Such modifications shall providefor timely implementation of any changes to the plan within sevencalendar days following the inspection.

c. A report summarizing the scope of the inspection, name(s)and qualifications of personnel making the inspection, the


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date(s) of the inspection, major observations relating to theimplementation of the storm water pollution prevention plan, andactions taken in accordance with Part III D 4 b of the permitshall be made and retained as part of the storm water pollutionprevention plan in accordance with Part II C of this permit. Thereport shall be signed in accordance with Part II 4 G of thispermit.

5. Nonstorm Water Discharges. Except for flows from firefighting activities, sources of nonstorm water listed in Part IIH 2 of this permit that are combined with storm water dischargesfrom the construction site must be identified in the plan. Theplan shall identify and ensure the implementation of appropriatepollution prevention measures for the nonstorm water component(s)of the discharge.

E. Contractors.

1. The storm water pollution prevention plan must clearlyidentify for each measure identified in the plan, thecontractor(s) or subcontractor(s) or both that will implement themeasure. All contractors and subcontractors identified in theplan must sign a copy of the certification statement in Part IIIE 2 of this permit in accordance with Part II G of this permit.All certifications must be included in the storm water pollutionprevention plan.

2. All contractors and subcontractors identified in a stormwater pollution prevention plan in accordance with Part III E 1of this permit shall sign a copy of the following certificationstatement before conducting any professional service at the siteidentified in the storm water pollution prevention plan:

"I certify under penalty of law that I understand the termsand conditions of this Virginia Pollutant DischargeElimination System (VPDES) general permit that authorizesthe storm water discharges associated with industrialactivity from the construction site identified as part ofthis certification."

The certification must include the name and title of theperson providing the signature in accordance with Part II G ofthis permit; the name, address and telephone number of thecontracting firm; the address (or other identifying description)of the site; and the date the certification is made.

F. Notice of Termination.

1. Where a site has been finally stabilized and all stormwater discharges from constructipn activities that are authorizedby this permit are eliminated, the permittee shall submit aNotice of Termination that is signed in accordance with Part IIG.


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2. The terms and conditions of this permit shall remain ineffect until a completed Notice of Termination is submitted andapproved by the director. Coverage under the permit will bedeemed terminated seven days after the date the Notice ofTermination is signed.

PART IV. MANAGEMENT REQUIREMENTS.

A. Treatment Works Operation and Quality Control.

1. All waste collection, control, treatment, management ofpollutant activities and disposal facilities shall be operated ina manner consistent with the following:

a. At all times, all facilities and pollutant managementactivities shall be operated in a prudent and workmanlike mannerso as to minimize upsets and discharges of excessive pollutantsto state waters.

b. The permittee shall provide an adequate operating staffwhich is duly qualified to carry out the operation, maintenanceand testing functions required to ensure compliance with theconditions of this permit.

c. Maintenance of treatment facilities or pollutant managementactivities shall be carried out in such a manner that themonitoring or limitation requirements or both are not violated.

B. Adverse Impact.

The permittee shall take all feasible steps to minimize anyadverse impact to state waters resulting from noncompliance withany limitation(s) or conditions or both specified in this permit,and shall perform and report such accelerated or additionalmonitoring as is necessary to determine the nature and impact ofthe noncomplying limitation(s) or conditions or both.

C. Duty to Halt, Reduce Activity or to Mitigate.

1. It shall not be a defense for a permittee in an enforcementaction that it would have been necessary to halt or reduce thepermitted activity in order to maintain compliance with theconditions of this permit.

2. The permittee shall take all reasonable steps to minimize,correct or prevent any discharge in violation of this permitwhich has a reasonable likelihood of adversely affecting humanhealth or the environment.


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\ . D. Structural Stability.

The structural stability of any of the units or parts of thefacilities herein permitted is the sole responsibility of thepermittee and the failure of such structural units or parts shallnot relieve the permittee of the responsibility of complying withall terms and conditions of this permit.

E. Bypassing.

Any bypass ("Bypass" means intentional diversion of wastestreams from any portion of a treatment works) of the treatmentworks herein permitted is prohibited unless:

1. Anticipated bypass - if the permittee knows in advance ofthe need for a bypass, the permittee shall notify the departmentpromptly at least 10 days prior to the bypass. After consideringits adverse effects the director may approve an anticipatedbypass if:

a. The bypass is unavoidable to prevent a loss of life,personal injury, or severe property damage ("severe propertydamage" means substantial physical damage to property, damage tothe treatment facilities which causes them to become inoperable,or substantial and permanent loss of natural resources which canreasonably be expected to occur in the absence of a bypass.Severe property damage does not mean economic loss caused bydelays in production); and

b. There are no feasible alternatives to bypass, such as theuse of auxiliary treatment facilities, retention of untreatedwaste, or maintenance during normal periods of equipmentdowntime. However, if a bypass occurs during normal periods ofequipment downtime, or preventive maintenance and in the exerciseof reasonable engineering judgment the permittee could haveinstalled adequate backup equipment to prevent such bypass, thisexclusion shall not apply as a defense.

.2. Unplanned bypass - if an unplanned bypass occurs, thepermittee shall notify the department as soon as possible, but inno case later than 24 hours, and shall take steps to halt thebypass as early as possible. This notification will be acondition for defense to an enforcement action that an unplannedbypass met the conditions in subdivision 1 of this subsection andin light of the information reasonably available to the permitteeat the time of the bypass.

F. Compliance with State and Federal Law.

Compliance with this permit during its term constitutescompliance with the State Water Control Law and the Clean Water


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Act except for any toxic standard imposed Under Section 307(a)i . of the Clean Water Act.

Nothing in this permit shall be construed to preclude theinstitution of any legal action under, or relieve the permitteefrom any responsibilities, liabilities, or penalties establishedpursuant to any other state law or regulation or otherappropriate requirements of the State Water Control Law notrelated to the activities authorized by this storm water generalpermit or under authority preserved by Section 510 of the CleanWater Act.

G. Property Rights.

The issuance of this permit does not convey any propertyrights in either real or personal property, or any exclusiveprivileges, nor does it authorize any injury to private propertyor any invasion of personal rights, nor any infringement offederal, state, or local laws or regulations.

H. Severability.

The provisions of this permit are severable.

I. Duty to Reregister.

If the permittee wishes to continue to discharge under a^^ * general permit after the expiration date of this permit, the

permittee shall submit a new Registration Statement at least 120days before the expiration date of this permit.

J. Right of Entry.

The permittee shall allow authorized state and federalrepresentatives, upon the presentation of credentials:

1. To enter upon the permittee's premises on which theestablishment, treatment works, pollutant management activities,or discharge(s) is located or in which any records are requiredto be kept under the terms and conditions of this permit;

2. To have access to inspect and copy at reasonable times anyrecords required to be kept under the terms and conditions ofthis permit; ,

3. To inspect at reasonable times any monitoring equipment ormonitoring method required in this permit;

4. To sample at reasonable times any waste stream, discharge,process stream, raw material or byproduct; and

5. To inspect at reasonable times any collection, treatment.


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pollutant management activities or discharge facilities required•i - under this permit.

For purposes of this section, the time for inspection shall bedeemed reasonable during regular business hours, and whenever thefacility is discharging or involved in managing pollutants.Nothing contained herein shall make an inspection timeunreasonable during an emergency.

K. Transferability of Permits.

This permit may be transferred to a new owner by a permitteeif:

1. The current permittee notifies the department 30 days inadvance of the proposed transfer of the title to the facility orproperty;

2. The notice to the department includes a written agreementbetween the existing and proposed new permittee containing aspecific date of transfer of permit responsibility, coverage andliability between them; and

3. The department does not within the 30-day time periodnotify the existing permittee and the proposed permittee of the

... board's intent to modify or revoke and reissue the permit.

^~/ ' Such a transferred permit shall, as of the date of thetransfer, be as fully effective as if it had been issued directlyto the new permittee.

L. Public Access to Information.

Any secret formulae, secret processes, or secret methods otherthan effluent data submitted to the department may be claimed asconfidential by the submitter pursuant to § 62.1-44.21 of theCode of Virginia. Any such claim must be asserted at the time ofsubmission in the manner prescribed on the application form orinstructions or, in the case of other submissions, by stampingthe words "secret formulae, secret processes or secret methods"on each page containing such information. If no claim is made atthe time of submission, the department may make the informationavailable to the public without further notice. If a claim isasserted, the information will be treated in accordance with theprocedures in the Virginia Freedom of Information Act (§ 2.1-340et seq. of the Code of Virginia) and § 62.1-44.21 of the Code ofVirginia.

Claims of confidentiality for the following information willbe denied:

1. The name and address of any permit applicant or permittee;W


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, 2. Registration statements, permits, and effluent data.

Information required by the Registration Statement may not beclaimed confidential. This includes information submitted on theforms themselves and any attachments used to supply informationrequired by the forms.

M. Permit Modification.

The permit may be modified when any of the followingdevelopments occur:

1. When a change is made in the promulgated standards orregulations on which the permit was based;

2. When an effluent standard or prohibition for a toxicpollutant must be incorporated in the permit in accordance withprovisions of Section 307(a) of the Clean Water Act;

3. When the level of discharge of or management of a pollutantnot limited in the permit exceeds applicable Water QualityStandards or the level which can be achieved by technology-basedtreatment requirements appropriate to the permittee;

,K.X N. Permit Termination.

V^/ ' After public notice and opportunity for a hearing, the generalpermit may be terminated for cause.

O, Permit Modifications, Revocations and Reissuances, andTermination.

This general permit may be modified, revoked and reissued, orterminated pursuant to the Permit Regulation and in accordancewith Part IV M, IV N and IV P of this permit.

P. When an Individual Permit May Be Required.

The director may require any permittee authorized to dischargeunder this permit to apply for and obtain an individual permit.Cases where an individual permit may be required include, but arenot limited to, the following:

1. The discharge (s) is a significant contributor of pollution.

2. Conditions at the operating facility change altering theconstituents or characteristics or both of the discharge suchthat the discharge no longer qualifies for a general permit.

3. The discharge violates the terms or conditions of thispermit.

V> Copyright 1996 The Bureau of National Affairs, Inc.

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4. A change has occurred in the availability of demonstratedtechnology or practices for the control or abatement ofpollutants applicable to the point source.

5. Effluent limitation guidelines are promulgated for thepoint sources covered by this permit.

6. A water quality management plan containing requirementsapplicable to such point sources is approved after the issuanceof this permit.

This permit may be terminated as to an individual permitteefor any of the reasons set forth above after appropriate noticeand an opportunity for hearing.

Q. When an Individual Permit May be Requested.

Any permittee operating under this permit may request to beexcluded from the coverage of this permit by applying for anindividual permit. When an individual permit is issued to apermittee the applicability of this general permit to theindividual permittee is automatically terminated on the effectivedate of the individual permit. When a general permit is issuedwhich applies to a permittee already covered by an individualpermit, such owner may request exclusion from the provisions ofthe general permit and subsequent coverage under an individualpermit.

R. Civil and Criminal Liability.

Nothing in this permit shall be construed to relieve thepermittee from civil and criminal penalties for noncompliancewith the terms of this permit.

S. Oil and Hazardous Substance Liability.

Nothing in this permit shall be construed to preclude theinstitution of any legal action or relieve the permittee from anyresponsibilities, liabilities, or penalties to which thepermittee is or may be subject under Section 311 of the CleanWater Act or §§ 62.1-44.34:14 through 62.1-44.34:23 of the Codeof Virginia.

T. Unauthorized Discharge of Pollutants.

Except in compliance with this permit, it shall be unlawfulfor any permittee to:

1. Discharge into state waters: sewage, industrial wastes,other wastes, or any noxious or deleterious substances, or


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2. Otherwise alter the physical, chemical or biologicalproperties of such state waters and make them detrimental to thepublic health, or to animal or aquatic life, or to the uses ofsuch waters for domestic or industrial consumption, or forrecreation, or for other uses.
