EXPLANATION OF SIGNIFICANT DIFFERENCESFROM OU-1 ROD

CHISMAN CREEK StJPERFUND SITENEWPORT NEWS, YORK COUNTY, VIRGINIA

SXKiXHATtON OP SIGNIFICANT DIFFERENCESFROM OU-1 ROD

CHISMAN CREEK SUPERFUND SITENEWPORT NEWS, YORK COUNTY, VIRGINIA

Contents _ _____ Page

I. INTRODUCTION. . . . . . . . . . . . . . . . . 1

II. SUMMARY OF SITE HISTORY, CONTAMINATIONPROBLEMS, AND SELECTED REMEDY ........ 2

A. Site History. . . . . . . . . . . . . . . . . . . 2

B. Contamination Problems. . . . . . . . . . . . 3

C. Selected Remedy .... . . . . . . . . . .'. .4

III. DESCRIPTION OF SIGNIFICANT DIFFERENCESAND THE BASIS FOR IDENTIFIED CHANGES TOTHE SELECTED OU-1 REMEDY. . . . ....... 6

A. Description of Significant Differences. ... 6

B.* Basis for Identified Changes to theSelected OU-1 Remedy. . . . . . . . . . . . . 7

IV, - STATUTORY DETERMINATION REGARDING THENECESSITY OF A CERCLA § 121 FIVE-YEARREVIEW FOR HAZARDOUS SUBSTANCES REMAININGAT THE SITE . . . . . . . . . . . . . . . . . 9

V. SUPPORT AGENCY REVIEW ............ 9

VI. AFFIRMATION OF STATUTORY DETERMINATION. ... 9

VII. . PUBLIC PARTICIPATION. ............. 10

VIII. ADMINISTRATIVE RECORD . . . . . . . . . . . . 10

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= :"" :. ' . ,. Contents (Continued)

Figures __._.^,_ __.__- :.. ....".." . . ":: .:- "~ ..-:

Appendix I ._ —Supplemental Administrative Record Index

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EXPLANATION OF SIGNIFICANT DIFFERENCESFROM OU-1 ROD

CHISMAN CREEK SUPERFUND SITENEWPORT NEWS, YORK COUNTY, VIRGINIA

I. INTRODUCTION"

The Chisman Creek Superfund Site ("Site") is located inSoutheastern York County, Virginia, in a 520 acre sub-watershedof the Chisman Creek Coastal Basin on the Virginia Peninsula.Chisman Creek is a tributary to Chesapeake Bay. The Siteconsists of four abandoned sand and gravel pits that were filledwith fly ash from operations at the Virginia Power, (formerlyVirginia Electric and Power Company), Yorktbwn Power GeneratingStation- ("Yorktown Station"), three adjacent ponds, a freshwatertributary and the Chisman Creek estuary. EPA organized-remedialcleanup activities at the Site into two operable units. OperableUnit One ("OU-1") consists of the four abandoned sand and gravelborrow pits that were filled with fly ash. . Operable Unit 2 ("OU-2") consists of the three Ponds, the freshwater tributary stream,and the Chisman Creek estuary.

The U.S. Environmental Protection Agency ("EPA") has completedremedial action activities for OU-1 at the Site under theauthority of the Comprehensive Environmental ResponseCompensation and Liability Act of 1980, as amended ("CERCLA"), 42U.S.C. § 9601 et .seq-., commonly referred to as "Superfund". Theremedial action was performed in accordance with the Record of .Decision ("ROD") for OU-1, issued on September 30, 1986, andincluded the Administrative Record file for the Site. At thistime, EPA is conducting Operation and Maintenance ("O&M")responsibilities to monitor the effectiveness of completedactions at the Site. The O&M activities are being conducted withthe support of the Virginia Department of Environmental Quality("VDEQ"). Effective April 1, 1993, the Virginia Department ofWaste Management ("VDWM"), along with other Virginiaenvironmental agencies, were consolidated so as to create VDEQ, anew state agency. As of that date, VDEQ became the state agencyresponsible for Superfund activities conducted within theCommonwealth of Virginia. • . . .

Due to a recent change in circumstances, EPA has determined thatmodification of a component of the selected remedy for OU-1, asdescribed in the September 30, 1986 ROD ("OU-1 ROD"), iswarranted. Section 117(c) of CERCLA provides that if anyremedial action is taken which differs in any significant respectfrom the final remedial action plan, an explanation ofsignificant .differences ("ESD"), including the reasons suchchanges were made, must be published.

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This ESD is issued under the authority of the ComprehensiveEnvironmental Response Compensation and Liability Act of 1980,("CERCLA")/ 42 U.S.C. § 9601 et sea., section 117(c), and section300.43'5(c) (2) (i) of the National Oil and Hazardous SubstancesPollution Contingency Plan ("NCP"). The purpose of this documentis to explain the changes which are being made to a component ofthe selected Remedial Alternative, as described in the ou-1 ROD,and the reasons why such changes are appropriate.

II. SUMMARY OF SITE HISTORY, CONTAMINATION PROBLEMS, ANDSELECTED REMEDY,

A. ' Site History - ____ .._...

Between 1957 and 1974, Virginia Power began burning coal mixedwith petroleum coke at its Yorktown Station. This burningprocess generated = solici wast_e_resi_dues which contained metals andinorganic substances. One residue produce'd' was a dark graymaterial called fly ash. Virginia Power contracted with a hauler.to remove and dispose of residues, cinders and fly ash generatedat the Yorktown Station. Large quantities of this waste weretransported and deposited in four abandoned sand and gravel pitsone mile north of Grafton in Southeastern York County, Virginia;£During heavy rains, fly ash and other sediments washed from thepits into the tributaries of chisman Creek. The fly ash wastealso affected the groundwater beneath the disposal areas.

In 1980, a private drinking well on Wolftrap Road adjacent to thefour fly ash pits was reported to contain discolored water. TheVirginia state Water Control Board and Virginia.State Board ofHealth began sampling groundwater from residential wells in thevicinity of the Site ta_ determine _the types and concentrations ofcontaminants, affecting ihe local water. These tests revealedelevated levels"of. heavy metals in the groundwater, surface waterand soils in and around the disposal areas. As a result of thedata gathered and conclusions drawn by these studies, the sitewas included on "the National Priorities List ("NPL") in 1983.

As-previously noted, EPA organized its remedial cleanupactivities at the.Site into two operable units. OU-1 consists offour abandoned sand and gravel borrow pits (hereinafter "AreasA - .P") that were filled with'fly ash generated at the YorktownStation. These fly ash disposal pits are located adjacent toWolftrap Road (State Route 630), approximately 0.7 milesnortheast of the intersection of Route 630 and U.S. Route 17.The southernmost pit, Area A, is approximately 13.5 acres in areaand is bordered on the west: by the former York County municipallandfill" aricT "on the east by Route__63p. . Area B, approximately 4.5acres in area, is 700 -feet north of Area A and is bordered on theeast and west by intermittent streams. _Area C, approximately12.9 acres in size, is 500 feet northeast of Area B, and is

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bordered by Route 630 to the west and by Chisman Creek to thenortheast. Area D, approximately 5 acres in land area, is 150feet northwest of Area C (see Figures 1 and 2). Parts of Areas Aand C are elevated between 5 and 20 feet above the surroundingterrain while the topography of Areas B and D is comparable tothat of the surrounding landscape.

Operable Unit 2 ("OU-2") consists of three Ponds ("Ponds A - C"),a freshwater tributary stream, and the Chisman Creek estuary, asshown in Figure 2. The ponds are located west of Wolf Trap Roadimmediately north of Area A. The tributary consists of twobranches in the area of the ponds, with the confluence of thebranches near Pond C. From the confluence of the two branches,the,tributary flows eastward under Wolf Trap Road, along thenorth face of Area C, and -into the Chisman Creek estuary.

B. Contamination Problems . „..._..

After organizing the Site into the aforementioned operable.units,EPA conducted a Remedial Investigation ("Ri") of the Site todetermine the nature and extent of contamination. Thecontamination was found to be localized in and around the area ofthe fly ash pits, with contaminants present in the fly ashitself, in the sediments of Chisman Creek and its tributaries, 14groundwater within and adjacent to the ponds, and in pond andstream waters tributary to Chisman Creek. Nickel and vanadiumwere the most ubiquitous and abundant of the trace metalcontaminants. Arsenic, beryllium, chromium, copper, molybdenum,and selenium were also present at elevated concentrations in someparts pf the study area. Relatively high concentrations ofsulfate and total dissolved solids ("ITDS") were also found inground water proximate to the Site. The RI did not detect anyorganic contaminants that could be attributed to the fly ash atthe Site.

Soil and sediment samples taken during the RI from the fly ashdisposal pits were found to be•contaminated with vanadium,nickel, arsenic, beryllium, copper and selenium at concentrationswhich ranged from 10 to 100 times the general background levelsof 10 to 15 parts per million ("ppm"). However, samples of flyash taken directly from the.pits were not EP Toxic for the abovemetals. Levels of vanadium and nickel comparable to thosedetected in the fly ash disposal pits (and sometimes exceeding100 times the general background levels) were also found insediments from two of the three ponds directly north of Areas Aand B. Elevated levels (up to 50 times background) of .vanadiumand nickel were also detected in sediments from nearby parts ofthe tributary stream channels, while adjacent areas of_theChisman Creek estuary showed concentrations of nickel above 100

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TDS and sulfate, which occur naturally at relatively highconcentrations in the Chisman Creek estuary, were also elevatedin ground water within the immediate vicinity of the fly ash pitsand .in tributary channels downstream of these pits. Ground waterwithin, beneath, and in the immediate vicinity of the fly ashdisposal pits had concentrations of TDS and sulfate that wereabove the Secondary Maximum Contaminant Levels ("SMCL") of 500and 25.0 ppm,~ "respectively (SMCLs are Federal aesthetic standardsand have no regulatory weight) and which significantly (by afactor of 10 to 3.00_ times) exceeded general background levels.Metal contamination in the form of vanadium and nickel were foundimmediately in.and around the _fly ash disposal pits atconcentrations up to 1,000 "times the general background levels,while lesser concentrations (exceeding TO times the general'.background 'levels) of arsenic, beryllium, chromium, copper,molybdenum, and selenium were also detected in these areas.Shallow ground waters downgradient of Areas A and C exhibitedelevated levels of nickel and beryllium, and molybdenum,respectively.. Arsenic, chromium, copper, selenium, and vanadiumwere also detected, at sightly elevated levels, downgradient oforie_or more of ...the disposal pits.

Contaminated surface water was identified in two of the threeponds north of Areas A and B and in tributary channels downstreamof the fly ash disposal pits. TDS and sulfate concentrations ineach of .-these water bodies exceeded the SMCLs whileconcentrations in the two ponds were also between 5 and 20 timesthe general background levels. Vanadium, at concentrationsexceeding 10 times the background levels, was detected in theponds north of Areas A and B and in the stream channel adjacentto Area C. Slightly elevated _levels.._(approximately 2 times thedetection limits) of.nickel were also found in the stream channeladjacent to Area C, while similar levels of molybdenum weredetected in each of the two ponds. Surface waters elsewhere inthe study area were otherwise free of detectable contamination.

•C. Selected Remedy . =_ . . . _ - . .

At issue herein is OU-1 and the OU-1 ROD issued by EPA onSeptember 30, 1986. The objectives expressed in the OU-1 RODinclude the prevention of human exposure to the on-site fly ash,and against the ingestion of__0roundwater, as well as theprotection and restoration of wetlands. To address theseobjectives, the remedy selected in the OU-1 ROD contained thefollowihg~ma~jor components: •

. * Installation of a low-permeability soil cap in the areaof the filled sand and gravel pits designated as AreasA, B, and C (see Figure 1). [Area D warranted noremedial action since the fly ash originally placedthere had been removed and placed at Area C in theearly 1970's]; '

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• Collection of contaminated groundwater from Area C andtreatment at an on-site treatment plant;

* Installation of an alternate water supply to homesalong Wolf Trap and Aliens Mill Roads;

• Placement of deed restrictions or other land usecontrols at each of Areas A through D, including theprohibition of excavation and building on-site, andrestriction of ground water use; and

• Initiation of Post-closure monitoring of ground andsurface water.

Due to the stringent and enforceable project schedule agreed toby .Virginia Power and EPA, Virginia Power was requited toconstruct an on-site water treatment facility before effluent =discharge standards could be developed. In anticipation ofexceedingly low effluent limitations that would be necessary toensure compliance with the Commonwealth of Virginia's MarineWater Quality Standards, Virginia Power agreed to design andconstruct a state-of-the-art inorganic abatement facility. .£Construction activities for OU-1 were initiated in November, 1987and were completed in December, 1988. As documented in aSuperfund Site Interim Closeout Report, dated December 21," 1.990,all construction activities were completed-to EPA'sspecifications and met the full- intention of the OU-1 ROD. Thewater treatment facility was designed and constructed to treat amaximum capacity of 100 gallons/minute, with the plant operatorhaving the ability to control the volume of discharge. .

In order to ensure that effluent discharge from the watertreatment facility would meet the Commonwealth of Virginia'sMarine Water Quality Standards, EPA established ApplicableRelevant and Appropriate Requirements (VARARs"). These ARARswere designed so as to limit the flow of treated effluent as afunction of the receiving stream flow and to ensure that theexpected concentrations of arsenic, cadmium, copper, lead,nickel, selenium and zinc in the treated effluent were withinestablished Marine Water Quality Standards.

The process of establishing these ARARs proved somewhat of alaborious task because data on the dilution effect of ChismanCreek was not available. The task was further complicated inthat Chisman Creek sometimes exhibits periods of no flow duringthe summer months. Since the required data was not available,the State Water Control Board could-not establish fixed dischargelimits for the plant effluent relative to the contaminants ofconcern. As a result, EPA was required to develop variousmathematical models that could reliably determine effluent flow

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as ~a function b£ stream flow and effluent metals concentration.Using available data, initial computer runs identified the metalion(s) whose removal to levels neces~s~ary to" comply withVirginia's Marine Water Quality .Standards would prove mostproblematic* The_results indicated that the removal of copper toacceptable levels would prove" to^be the most difficult. EPA thenevaluated two different concentrations of copper at variousstream flow conditions to calculate acceptable treated planteffluent rates. Using.this mathematical modeling approach, EPAdeveloped a series of "'tiered effluent discharge limits that'corresponded to ~ a" ~rahg¥ "of "stream flow, conditions whereby allcontaminants of concern met the Commonwealth of Virginia's MarineWater Quality Standards. - _The._tiered effluent limits arepresented in Attachment B (Figure 2) of the Fact Sheet appendedto the Operable Unit One section of the Consolidated Monitoring-Plan ("CMP"), which has been entered into the AdministrativeRecord. ' - - _

Consistent with the OU-1 ROD and the established ARARs, thegroundwater beneath Area C continues to be collected in asubsurface drainage system, treated on-site and thereafterdischarged to ,a .tributary of the,Chisman__Creek. A completelisting of the periodic sample collection, and data reportingrequirements to monitor the Site and the treated plant effluent *are contained in the CMP. .

XII. DESCRIPTION OF SIGNIFICANT DIFFERENCES AND THE BASIS FORIDENTIFIED CHANGES TO THE SELECTED OU-1 REMEDY

This section of the ESD identifies and explains certainsignificant changes.Lwhich are;, being made to the remedy identifiedin the 1986 OU-1 ROD as well as the basis for, and the rationalein support of, the identified changes. While these changes donot represent a.fundamental departure from the selected OU-1•remedy, they do modify the method by which certain remedialactivities will -be performed such that the following explanation.is both necessary and appropriate.

A. , DESCRIPTION OF SIGNIFICANT DIFFERENCES _.. -

In August, 1986, a Feasibility Study for OU-1 was performed. TheOU-1 Feasibility Study evaluated various alternatives for Siteclean-up. The discharge of contaminated ground water to apublicly owned treatment"works ("POTW") was initially consideredas a viable remedial alternative. However at the time the OU-1Feaisibility Study was ..conducted,. personnel at the Hampton RoadsSanitation" District ("HRSD") indicated that the existing POTW,the York River Wastewater Treatment Plant, was not willing toaccept wastewater from a CERCLA site. Consequently, thisremedial alternative- was screened from further consideration.

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Pursuant to the remedy selected in the OU-1 ROD, ground water iscollected from Area C at the Site and- treated at an on-siteground water treatment plant. Collection of ground water fromareas A and B would have negatively impacted the water bearingzones directly below these areas as well as the surroundingsurface waters and therefore was not feasible. After treatmentof the ground water from Area C, the effluent is released into anon-tidal tributary of Chisman Creek. Since the initiation of theselected OU-l remedy, the OU-1 ROD requirement.for on-sitetreatment of ground water.from Area C has'been met.. To date over23 million gallons of water have been treated on-site.

The analytical data accumulated during the four-year period of -on-site plant operation indicates that ground water quality hasimproved since initiation of the selected remedy, but that .treatment is still required. The data also indicates tftat~groundwater collected from Area C is suitable for direct discharge intothe existing municipal sanitary system (the York County sanitarysewer system) because the untreated effluent meets the existingPOTW7s established pre-treatment requirements. On the basis ofthe analytical data referenced above, the HRSD and the existingPOTW have re-evaluated their initial decision not to acceptground water from the Site for treatment at the York River fWastewater Treatment -Plant. As a result, the HRSD and the POTWhave now elected to accept ground water from the Site fortreatment at the York River Waste Water Treatment Plant in YorkCounty, Virginia* The HRSD has approved and issued the necessarypermit to Virginia Power. In addition, the York CountyDepartment of Environmental Services has approved a connectionfrom the on-site treatment plant to the York County SanitarySewer System.

The project to connect the existing on-site treatment system tothe local POTW will involve the installation of 201 feet ofpipeline between Area C and the existing York County sewer line,a manhole, a valve box and an electrical conduit. All pipingwill .be installed within a trench that will be backfilled. Theconnection to the POTW sewer line system will allow ground watercollected from Area C to be discharged directly and ..continuouslyto the York County Sanitary Sewer System for conveyance to, and,treatment at, the existing POTW. Treated effluent will bedischarged into the York River via the Yorktown Power Stationcooling water canal. This operation is designed to replace thatportion of the current OU-l remedy which calls for the on-sitetreatment of contaminated ground water and its•subsequentdischarge to the Chisman Creek non-tidal tributary.•

B. BASIS FOR IDENTIFIED CHANGES TO THE SELECTED OU-1 -REMEDY

Pursuant to the requirements of the OU-l ROD, treated effluentfrom the on-site groundwater treatment plant may not bedischarged to the non-tidal tributary of Chisman Creek during

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periods of izero flow stream conditions. The OU-1 ROD prohibitsthe discharge of treated -effluent to the Chisman Creek tributaryduring zero flow 'stream conditions because a dilution 'safetyfactor was considered an appropriate prerequisite to such adischarge. Under normal stream flow conditions, the treatedeffluent .would be diluted immediately.and dispersed, upondischarge to the non-tidal tributary, thereby substantiallyreducing the potential .for any adverse environmental impacts.However, the absence of stream flow in the non-tidal tributary"effectively removes the otherwise present dilution safety factor.

In the past four years of operation, the on-site groundwatertreatment plant has been shut down for extended time periods dueto extreme dry weather, conditions which have resulted in zeroflow stream conditions. In addition, the on-site treatment planthas experienced a variety pf: unforeseen operation and maintenanceproblems resulting in additional and extended periods duringwhich the treatment plant has been taken off-line and out of'operation. Use o.f the POTW and the municipal sewer system offersa means for =the 'efficient and continuous treatment and dischargeof the ground water.collected from.the.site. At the same time,treatment of groundwater at the POTW will eliminate thoseoperational impediments associated with the on-site treatment. \plant, including the need for plant sJ ut-downs due to scheduledmaintenance activities, unanticipated break-downs and/or zeroflow stream conditions.

By proceeding with the proposed change to the OU-1 ROD, theRemedial Action Objectives specified in the OU-1 ROD willcontinue to be met,-the current level of protectiveness at theSite will be maintained and there will be no further discharge oftreated wastewater effluent from the Site to .the Chisman Creeknon-tidal tributary. To ensure a safe transition, the on-sitetreatment plant and all: of the currently installed pre-treatmentequipment shall be kept on-site _and available for start-up untilsuch time as the HRSD is confident that all permit limitsconsistently will be met without the need for on-site pre-treatment. In addition, ground water in Area C and in thecollection system w_ill_ continue to be,_ monitored, to .ensure thatall pre-treatment standards for the POTW are met. If monitoringdata indicates that the ground water collected at Area C does notmeet the pre-treatment standards, Virginia Power will be requiredto initiate on-site treatment to attain compliance with thepermit limits prior to continued discharge to the POTW. The sitewill continue to ,be periodically inspected for maintenanceproblems by representatives of EPA and VpEQ.

In lieu of the original ARARs established for the on-sitetreatment plant, the Industrial Wastewater Discharge Permit forDirect Discharge issued by HRSD has specified pre-treatmentdischarge limits which must be met for the contaminants known toexist at the Site. The complete listing of the pre-treatment

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limits, sampling and monitoring requirements and data submittalrequirements are contained in the Wastewater Discharge Permit -which has been entered into the Administrative Record. ShouldHRSD revoke Virginia 'Power's Industrial Wastewater dischargePermit, Virginia Power will be required to provide on-sitetreatment and to maintain compliance with the original ARARs andtha requirements of the Consolidated Monitoring Plan.

For each of the reasons that have been presented and explainedabove, EPA proposes the following change to the remedy originallyset forth in the OU-l ROD:

Virginia Power will collect ground water form "Area C" anddischarge the effluent directly to the Publicly OwnedTreatment Works ("POTW") of the York County Sanitary SewerSystem in accordance with Industrial Wastewater Discharge 'Permit No. 0342 for Direct Discharge, as issued by theHampton Roads Sanitation District ("HRSD"). In the eventthat it is unable to attain each of the pre-treatment limitsspecified in the permit, Virginia Power will be required toprovide on-site effluent treatment to attain compliance.If, at any time, HRSD revokes the Industrial WastewaterDischarge Permit, Virginia Power will be required to provideon-site effluent treatment and to comply with the original *ARARs and the requirements of.the Consolidated MonitoringPlan ("CMP").

IV. STATUTORY DETERMINATION REGARDING THE NECESSITY OF A CERCLA§ 121 FIVE-YEAR REVIEW FOR HAZARDOUS SUBSTANCES REMAINING ATTHE SITE

Since some hazardous substances will likely remain on-site aftercompletion of the activities specified in the OU-l ROD, asmodified by this ESD, a CERCLA 121(c), 42 U.S.C. § 9621(c), five-year review will be required. - . _ •

V. SUPPORT AGENCY REVIEW

In accordance with NCP § 300.435 (c)(2), the Commonwealth ofVirginia has been consulted regarding the above-described changein the .scope of the remedy selected for OU-l.

VI. AFFIRMATION OF STATUTORY DETERMINATION

EPA believes that the remedy selected for OU-l, including thechanges documented in this ESD, remains protective of humanhealth and the environment, complies with Federal and Staterequirements that are applicable or relevant and appropriate tothis remedial action, and is cost-effective. In addition, theremedy utilizes permanent solutions to the maximum extentpracticable for this Site.

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VII. PUBLIC PARTICIPATION

A notice of the availability of.this ESD. and a brief explanationof'its contents will be published in local -newspapers followingexecution of this ESD.

VIII. ADMINISTRATIVE RECORD

A copy of this ESD, together with documentation supporting thechanges described herein, will be included in the AdministrativeRecord file for the Site. An index of the documents added to theAdministrative Record file in support of this ESD is attached asAppendix X. The Administrative Record file for the Site isavailable'at the following locations:

U.S. EPA Region III Public Reading Roomc/o Anna Butch

841 Chestnut Street, 9th FloorPhiladelphia, Pa 19107

(215) 597-3037

and f.

_ -York County Libraryc/o Elizabeth Pessagno8500 G. w. HighwayYorktown, VA 23692

(804) 890-3377

Date -. - --..--._-. '-.- -£..- -Stanley L, Laskowski- , , - -> tActing Regional Administrator

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FIGURES

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PONDnU;:v 'POND

0* 2000*1* 2000*

VICINITY MAPPOQUOSON WEST QUAORAKQLS, V1RQ1NIA,PHOTOREVfSEO 1«78.

SITE LOCATION MAPCH1SMAN CREEK SUPER FUND 3ITE

VIRGINIA POWER

RICHMOND, VIRGINIADRAWING NUMBER /\

90-168-A28

flROOOZI i FIGURE 1

APPBHDIX I

Supplemental Administrative Record Index

1. Letter to Mr. Guy M. Aydlett, Hampton Roads SanitationDistrict, from Mr, B.M. Marshall, P.E., Virginia Power, re:Industrial Wastewater Discharge Permit Application,07/08/92.

2. Industrial Wastewater Discharge Permit No. 0342, andattached cover letter to Mr. B. M. Marshall, Virginia Power,from Mr. Guy M. Aydlett, Hampton Roads Sanitation District,10/21/92.

3. Letter to Mr. Bob Williams, Virginia Power, from A. TravisQuesenberry, P,E., re: Chisman Creek Site "C" SewerConnection, 12/11/92

4. Erosion and Sediment Control Plan Chisman Creek - Site "C" -Sewer Connection, by DAI Consultants, Inc. for VirginaPower, January 1993.

5. Virginia Power Technical Specification Connection To York jCounty Sewer System Chisman Creek - Site C York County.Virginia, by GAI Consultants, Inc. for Virginia Power, IssueDate, 7/27/92, Revision 12/23/92.

6. Constuction Dwg., CONNECTION OF LIFT STATION MANHOLE TO YORKCOUNTY SEWER - CHISMAN CREEK - SITE C YORKTOWN POWERSTATION, by GAI consultants. Inc., for Virginia Power, Dwg.Number 92-154-E1, Approved Date 5/11/92.

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