for site 4 – old landfill · 2017. 5. 12. · united states environmental protection agency...

Second Five-Year Review Reportfor

Site 4 – Old Landfill

Marine Corps Base (MCB) Quantico, Virginia

Naval Facilities Engineering Command Washington

Contract Number N62467-04-D-0055 Contract Task Order 480

March 2008

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103-2029

Colonel, Charles A. Dallachie Commander, Marine Corps Base 3250 Catlin Avenue Quantico, VA 22134-5001

Re: Second Five-Year Review Report for Site 4 - Old Landfill Marine Corps Base (MCB) Quantico, Virginia

Dear Colonel Dallachie:

The U.S. Environmental Protection Agency (EPA) Region III has reviewed the report entitled "Second Five-Year Review Report for Site 4 - Old Landfill". The report was prepared to address the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Section 121 (c) five-year review requirements. EPA has reviewed this five-year review report and has determined that it adheres to the OSWER Directive 9355.7-03B-P, Comprehensive Five-Year Review Guidance (EPA, June 2001). EPA concurs with the Navy's determination that with the completion of the required actions listed below, the remedies in place are protective of human health and the environment.

• Any depression/ruts where ponding would occur will be filled to the appropriate contours and seeded.

• The erosional channels behind the revetment and in the southern portion of the landfill will be filled.

• The groundhog holes will be filled. • The vegetation on the fence along the southern wetlands will be pulled and the

fence stabilized. • The phragmites in the wetlands will be eradicated via treatment with

postemergence herbicides.

o Printed on 100% recycled/recyclable paper with 100% post-consumer fiber and process chlorine free. Customer Service Hotline: 1-800-438-2474

EPA's Region III would like to congratulate the Navy in preparing a report that meets the intent of EPA's Five-Year Review Guidance Document. If you have any questions, please contact Lisa M. Cunningham at (215) 814-3363.

~~fl~ 6.Je~ J. HZe/Director

Hazardous Site Cleanup Division

cc: Ms. Donna Heric, MCB Ms. Kristen Harstad, NAVFEC, Washington Mr. Steve Mihalko, VADEP

Navy Five-Year Review Signature Cover

Key Review Information

Site Identification

Site Name: Marine Corps Base (MCB) Quantico (Site 4 – Old Landfill) EPA ID: VA1170024722

Region: 3 State: VA City/County: Quantico

Site Status

NPL Status: Final

Remediation Status (under construction, operating, complete): Interim Remedy for Site 4 is operating.

Multiple Operable Units (highlight): Y N Number of Sites/OUs: 1

Construction Completion Date: October 1997 (Interim Action)

Lead Agency: Department of the Navy Fund/PRP/Federal Facility Naval Facilities Engineering CommandLead: Federal Facility Washington

Has site been put into reuse? (highlight): Y N

Review Status

Who conducted the review (EPA Region, State, Federal Agency): Naval Facilities Engineering Command Washington

Author Name: Kristen Harstad Author Title: Remedial Project Manager

Author Affiliation: Department of the Navy, Naval Facilities Engineering Command Washington

Review Period: November 2007 Date(s) of Site Inspection: November 2007

Highlight: Statutory Policy Type (name): Review Number (1, 2, etc) Policy 1. Pre-SARA

2. Ongoing 2 3. Removal Only 4. Regional Discretion

Triggering Action Event: Initiation of the interim remedial action for Site 4 - Old Landfill: Completion of First Five-Year Review

Trigger Action Date: May 1996 Interim ROD; March 2003 Five Year Review

Due Date: March 2008

This five-year review only applies to the interim remedial action implemented at Site 4 – Old Landfill.

Issues:

� Six small depressions where water may pond were noted on the surface of the landfill. Four are on the northern portion of the landfill and two are on the southern portion of the landfill.

� Ruts from vehicles are present in a number of areas of the landfill (at lease five areas). Water may pond in these ruts.

� Numerous groundhog holes were noted in the surface of the landfill. � Several erosional channels were noted along the face of the landfill behind the shoreline revetment

(northern portion of the landfill). There is one erosional channel on the north slope of the southern portion of the landfill.

� A small section of the fence along the southern wetlands is covered with heavy vegetation and is starting to fall over.

� Although three invasive plant species were observed in the constructed wetland (phragmites, Japanese stiltgrass, and multiflora rose), the presence of phragmites only is considered to be problematic

Recommendations and Required Actions:

To verify the presence of the suspected depressions/vehicle ruts, the landfill surface should be surveyed as per the O&M Manual that is part of the Long-Term Monitoring Plan. In addition, it does not appear the two survey benchmarks have been surveyed recently. Any depression/ruts where ponding would occur will need to be filled to the appropriate contours and seeded as per the Long-Term Monitoring Plan.

The erosional channels in the face of the landfill behind the revetment and the erosional channel in the north slope of the southern portion of the landfill should be filled in.

The groundhog holes need to be evaluated to determine if the holes are active. If so, the groundhogs will need to be removed from the landfill area. Once any groundhogs are removed, the holes will need to be filled as per the Long-Term Monitoring Plan.

The vegetation on the fence along the southern wetlands will need to be removed and the fence stabilized.

The phragmites in the wetlands will need to be eradicated via treatment with postemergence herbicides. No actions are needed for the Japenese stiltgrass and multiflora rose because they are not expected to spread throughout the wetland.

Protectiveness Statement(s):

With the completion of the required actions listed above, the interim remedial action for Site 4 will be protective of human health and the environment. The remedy is functioning as intended.

This five-year review shows that the Navy is meeting the requirements of the ROD for the remedial action for Site 4.

Other Comments:

None.

Next Review:

The next five-year review of Site 4 will be completed in March 2013.

Signature of U.S. Marine Corps and Oate

CHARLES A. DALLACHIE Date " Colonel, U.S. Marine Corps Commander, Marine Corps Base, Quantico

f~~.·

\_)

REVISION 1 MARCH 2008

TABLE OF CONTENTS

SECTION PAGE NO.

NAVY FIVE-YEAR REVIEW SIGNATURE COVER KEY ............................................................................. i

ACRONYMS ................................................................................................................................................ vi

EXECUTIVE SUMMARY ........................................................................................................................ ES-1

1.0 INTRODUCTION..............................................................................................................................1

2.0 SITE CHRONOLOGY......................................................................................................................2

3.0 BACKGROUND...............................................................................................................................2 3.1 Physical Characteristics .................................................................................................. 2

3.2 Land and Resource Use ................................................................................................. 3 3.3 History of Contamination................................................................................................. 4

3.4 Initial Response............................................................................................................... 4 3.5 Basis for Taking Remedial Action ................................................................................... 5

4.0 REMEDIAL ACTIONS .....................................................................................................................6 4.1 Interim Remedial Actions ................................................................................................ 6

4.1.1 Interim Remedy Selection............................................................................................... 6 4.1.2 Interim Remedy Implementation ..................................................................................... 8

4.2 Final Remedial Actions ................................................................................................... 8 4.2.1 Final Remedy Selection .................................................................................................. 8 4.2.2 Remedy Implementation ............................................................................................... 10

4.3 System Operation/Operation and Maintenance............................................................ 11

5.0 PROGRESS SINCE THE LAST FIVE-YEAR REVIEW ................................................................12

6.0 FIVE-YEAR REVIEW PROCESS ..................................................................................................12 6.1 Administrative Components .......................................................................................... 12 6.2 Community Involvement................................................................................................ 13 6.3 Document Review ......................................................................................................... 13 6.4 Data Review.................................................................................................................. 14 6.5 Site Inspection............................................................................................................... 14 6.6 Interviews ...................................................................................................................... 15

7.0 TECHNICAL ASSESSMENT ........................................................................................................16 7.1 Question A: Is the remedy functioning as intended by the decision documents? ........ 16 7.2 Question B: Are the exposure assumptions, toxicity data, clean-up levels, and

RAOs used at the time of the remedy selection still valid?........................................... 17 7.2.1 Changes in Standards and To Be Considers (TBCs) ................................................... 17 7.2.2 Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics .... 17 7.3 Question C: Has any other information come to light that calls into question the

protectiveness of the remedy?...................................................................................... 18 7.4 Technical Assessment Summary.................................................................................. 18

8.0 ISSUES ......................................................................................................................................18

9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS ................................................................19

100709/P iv CTO 480


TABLE OF CONTENTS (Continued)

SECTION PAGE NO.

10.0 PROTECTIVENESS STATEMENT ...............................................................................................20

11.0 NEXT REVIEW ..............................................................................................................................20

APPENDICES

A FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST B SITE VISIT PHOTOGRAPHS C WETLAND INSPECTION MEMORANDUM

TABLES

NUMBER

1 Chronology of Site Events 2 Issues Identified During the Second Five-Year Review 3 Description of ARARs for Selected Remedy 4 Toxicity Data Summary

FIGURE

NUMBER

1 Site Layout 2 Results of November 1 and 2, 2007 Site Inspection

100709/P v CTO 480


ACRONYMS

ARAR applicable or relevant and appropriate requirement

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

CFR Code of Federal Regulations

CLEAN Comprehensive Long-Term Environmental Action Navy

CNS central nervous system

COCs contaminants of concern

CSF cancer slope factor

DON Department of Navy

DRMO Defense Reutilization and Marketing Office

EE/CA Engineering Evaluation/Cost Analysis

ERA ecological risk assessment

FFS Focused Feasibility Study

FS Feasibility Study

GI gastrointestinal

IAS Initial Assessment Study

IR Installation Restoration

IRA interim remedial action

IRIS Integrated Risk Information System

LTM Long-Term Monitoring

LUCs land use controls

MCB Marine Corps Base

mg/kg milligram per kilogram

NA not available

NCEA National Center for Environmental Assessment

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NOV Notice of Violation

NPDES National Pollutant Discharge Elimination System

NPL National Priorities List

NREA Natural Resources and Environmental Affairs

O&M operation and maintenance

PAH polynuclear aromatic hydrocarbon

PCB polychlorinated biphenyl

PRGs preliminary remediation goals

QPMT Quantico Project Managers Team

RAO remedial action objective

100709/P vi CTO 480


RBC risk-based concentration

RD remedial design

RF&P Richmond, Fredricksburg, and Potomac

RfD reference dose

RI remedial investigation

ROD Record of Decision

RPM Remedial Project Manager

STP sewage treatment plan

SVOC semivolatile organic compound

SWMU solid waste management unit

TBC to be considered

TtNUS Tetra Tech NUS, Inc.

USEPA United States Environmental Protection Agency

USFWS U.S. Fish and Wildlife Service

VAC Virginia Administrative Code

VDEQ Virginia Department of Environmental Quality

VOC volatile organic compound

WQC Water Quality Criteria

100709/P vii CTO 480


EXECUTIVE SUMMARY

The interim remedial action (IRA) for Installation Restoration (IR) Program Site 4 – Old Landfill at Marine

Corps Base (MCB) Quantico, Virginia, included the following:

� Excavation and off-site disposal of soil and drainage swale sediment contaminated with

polychlorinated biphenyls (PCBs) in excess of 10 milligrams per kilogram (mg/kg).

� Excavation and on-site disposal of landfill material and sediment from the Potomac River shoreline

adjacent to the site.

� Installation of a 23-acre permeable geotextile separation membrane and soil barrier layer over the

landfill

� Shoreline stabilization.

� Wetland mitigation.

� Institutional controls.

The construction activities associated with the interim remedy were completed in October 1997. The first

five-year review was completed in March 2003 and found the interim remedy was constructed in

accordance with the requirements of the Record of Decision (ROD) for the IRA and the interim remedy

was functioning as designed.

The ROD for the final remedy for Site 4 was signed in November 2007 by the Marine Corps and in

December 2007 by the United States Environmental Protection Agency (USEPA). The major

components of the final remedy selected in the 2007 ROD include the following:

� IRA (completed in 1997)

� Maintenance of the site fence and soil barrier layer

� Implementation of land use controls (LUCs)

� Implementation of a monitoring program and site reviews

Although the Long-Term Monitoring (LTM) Plan that includes an Operation and Maintenance (O&M)

Manual and a Remedial Design for LUCs was finalized in January 2008, the LUCs have not been

100709/P ES-1 CTO 480


implemented. Consequently, this five-year review evaluates if the interim remedy, not the final remedy, is

functioning as it should.

The trigger for the second five-year review was the completion of the first five-year review in March 2003.

The assessment of this five-year review found that the interim remedy is functioning as designed.

Although several issues were noted during the site inspection on November 1 and 2, 2007, they do not

appear to affect current protectiveness of the interim remedy. Recommendations have been made to

address the issues so that they do not affect future protectiveness of the interim remedy.

100709/P ES-2 CTO 480

1.0


SITE 4 – OLD LANDFILL MARINE CORPS BASE QUANTICO, VIRGINIA

SECOND FIVE-YEAR REPORT

INTRODUCTION

The purpose of this Five-Year Review Report is to determine whether the interim remedy at the site is

protective of human health and the environment (LUCs, which are part of the final remedy, have not been

implemented). The methods, findings, and conclusions of reviews are documented in five-year review

reports. In addition, five-year review reports identify issues found during the review, if any, and identify

recommendations to address them.

The Department of Navy (DON) is preparing this Five-Year Review Report pursuant to the

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §121 and the

National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or

contaminants remaining at the site, the President shall review such remedial action no less often

than each five years after initiation of such remedial action to assure that human health and the

environment are being protected by the remedial action being implemented. In addition, if upon

such review it is the judgment of the President that action is appropriate at such site in

accordance with section 104 or 106, the President shall take or require such action. The

President shall report to the Congress a list of facilities for which such review is required, the

results of all such reviews, and any actions taken as a result of such reviews.

The DON interpreted this requirement further in the NCP; 40 Code of Federal Regulations (CFR)

§300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants

remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead

agency shall review such actions no less often than every five years after the initiation of the

selected remedial action.

Naval Facilities Engineering Command Washington conducted the five-year review of the interim remedy

implemented at Site 4 – Old Landfill at the MCB in Quantico, Virginia. Tetra Tech NUS, Inc. (TtNUS)

conducted an analysis of the available information in support of the five-year review in November 2007 in

response to Contract Task Order 480 under the Comprehensive Long-Term Environmental Action Navy

100709/P 1 CTO 480


(CLEAN) Contract Number N62467-04-D-0055. Representatives of TtNUS conducted a site inspection

on November 1 and 2, 2007. Representatives of the DON, MCB Quantico, and Virginia Department of

Environmental Quality (VDEQ) accompanied the TtNUS representative for part of the day on

November 1, 2007. This report documents the results of the review. The Five-Year Review Site

Inspection Checklist is included as Appendix A and Site Visit Photographs are included as Appendix B.

This is the second five-year review for Site 4. The triggering action for the first statutory review was the

initiation of the IRA on May 19, 1996. The first five-year review was completed in March 2003. The

five-year review is required because hazardous substances, pollutants, or contaminants remain at the site

above levels that allow for unlimited use and unrestricted exposure.

2.0 SITE CHRONOLOGY

The site chronology lists all important site events and relevant dates and is shown in Table 1.

3.0 BACKGROUND

3.1 Physical Characteristics

Site 4 (Old Landfill) is a 24-acre landfill located on the banks of the Potomac River in the Mainside of

MCB Quantico (see Figure 1). The area of the Potomac River adjacent to Site 4 is known as the

Quantico Embayment. Site 4 is bounded to the north and west by industrialized portions of MCB

Quantico. The base sewage treatment plant (STP) borders the site to the north. The Richmond,

Fredricksburg, and Potomac (RF&P) railroad tracks (a subdivision of CSX Railroad), barracks, and

several offices are located along the western site boundary. The southern edge of the site is surrounded

partially by wetlands (Site 96) and the Marine Corps Airfield. The site also contains a constructed

wetland that was created in the area of an unnamed tributary to replace wetlands that were destroyed

during implementation of the IRA. There are no residential properties or areas near the site. During the

IRA, the site was significantly regraded, and all existing structures were removed. Currently, the surface

of Site 4 slopes gently from the access road near the railroad tracks to the Potomac River. The shoreline

has been covered with riprap revetment to prevent further erosion. Chain-link fencing has been installed

around the perimeter, except along the river. Based on information gathered during post-IRA activities,

the northern and western boundaries of the site were redefined when landfill waste was encountered

during construction activities near the RF&P Railroad tracks and soil removal activities at IR Program

Site 32 (Pesticide Control Building). The northern boundaries of the site overlap with the boundaries of

Site 32.

100709/P 2 CTO 480

3.2


Land and Resource Use

Landfill operations at Site 4 began in the early 1920s near the RF&P railroad tracks and continued to

expand eastward until 1971. Operations at Site 4 have extended the original shoreline an additional

600 to 1,200 feet eastward to create a new river bank, consisting of artificial fill. The Defense

Reutilization and Marketing Office (DRMO) Scrapyard [known as Solid Waste Management Unit (SWMU)

L-03] and Building 669 (known as SWMU B-08) were located within the landfill area. The scrap yard was

constructed in the 1950s on the northeastern portion of Site 4 and covered an area of approximately

2.5 acres. Building 669 was located near the Potomac River and was used to store electrical

transformers until 1979. The site has been inactive since the IRA was completed in 1997.

The site is currently an open, grass-covered field. The site is currently fenced, except along the river, and

the landfill waste is contained beneath a geotextile separation membrane and soil barrier layer. The

current and future land use for the surrounding area is military.

The Potomac River is not used for domestic or agricultural uses within the vicinity of MCB Quantico;

however, it is used for recreational and commercial fishing near the base. The base has a fish advisory

posted for waters in the Quantico Embayment, which is adjacent to the site. The advisory warns against

ingesting fish and shellfish species that are caught in the Quantico Embayment. The sediments in the

Quantico Embayment adjacent to Site 4 are being addressed as Site 99 (Quantico Embayment) and a

habitat enhancement cap was recommended for the sediment in the embayment in the Site 99 Feasibility

Study (FS).

Groundwater underlying the site is currently not used as a drinking water source. Groundwater is not

expected to be a future source of drinking water because potable water at the base is provided by three

surface reservoirs (Brackenridge Reservoir, Gray’s Reservoir, and Lunga Reservoir).

The surficial aquifer beneath the site consists of river deposits (alluvium and river terrace deposits) that

overlay the Potomac Group. The river deposits consist of sand, silt, and organic clay, interlayered with

peat in the southwest portion of the site. In northern portion of the site, this material consisted of gravel,

sand, silt, and clay mixtures. A 4- to 12-foot thick clay layer was encountered at the top of the Potomac

Group, ranging from 40 to 61 feet below the ground surface. Cohesive, dense sand with silt, clay, and

gravel, also part of the Potomac Group was encountered at depths ranging from 50 to 66 feet below the

ground surface. The depth to groundwater generally varied from 3 to 20 feet below the ground surface

depending on the season and amount of precipitation. The dominant groundwater flow direction at the

site is east toward the Potomac River.

100709/P 3 CTO 480


3.3 History of Contamination

Wastes reportedly disposed at Site 4 included municipal refuse, construction debris, paints and thinners,

transformers, dielectric fluids, batteries, and compressors. Wastes were burned prior to burial until the

mid-1960s. The estimated volume of fill material at Site 4 is 281,000 cubic yards. The fill material was

observed to be approximately 2 to 13 feet thick and generally thickens toward the south and east, toward

the Potomac River. Site 4 was used until 1971, when another municipal landfill was opened at the base.

Electrical transformers were stored in the eastern portion of the DRMO area and the transformer storage

area at Building 669. The transformers were reportedly opened to recover the copper wire and steel

casings. Consequently, transformer oil, possibly containing PCBs, was released onto the ground. No

information exists concerning quantities of contaminants spilled in the DRMO area in the past.

During the Initial Assessment Study (IAS) in 1984, Site 4 was recommended for further study because of

the potential impacts to groundwater and surface water. The 1988 Confirmation Study and preliminary

Remedial Investigation (RI) indicated that past operations at Site 4, the DRMO, and Building 669 have

resulted in contaminated soil, groundwater, and sediment. Soil contaminants included volatile organic

compounds (VOCs), semivolatile organic compounds (SVOCs), most of which are polynuclear aromatic

hydrocarbons (PAHs), pesticides, PCBs, and metals. Groundwater contaminants were mostly metals,

with a few detections of VOCs, SVOCs, and pesticides. Sediment contaminants were mostly PAHs,

pesticides, PCBs, and metals.

VDEQ issued Notice of Violation (NOV) No. 93-06-NRO-075 on June 24, 1993. The NOV noted

discharge of contaminants to state waters without authority of a National Pollutant Discharge Elimination

System (NPDES) permit, thereby violating water quality standards for surface water and groundwater and

causing environmental damage (i.e., PCBs were detected in fish tissue).

3.4 Initial Response

The initial responses discussed below were conducted before the IRA was implemented.

A removal action was conducted from September 1990 through December 1990 to remove PCB

contaminated soil from the DRMO Scrapyard and the adjoining Building 669. Approximately 3,800 tons

of contaminated soil, including soil from another site (Site 5 - Old Batch Plant) unrelated to Site 4, were

excavated and disposed off site.

In response to the 1993 NOV, the DON initiated immediate measures to eliminate further contaminant

migration from Site 4. Activities included installation of silt fences to prevent migration of contaminated

sediment, a blacktop area was scarified by breaking up the asphalt to make the area more permeable

100709/P 4 CTO 480

3.5


and to decrease runoff, collection of surface water samples to verify that PCBs were not migrating off site,

initiation of the Focused Feasibility Study (FFS), and initiation of an ecological risk assessment (ERA) by

the United States Fish and Wildlife Service (USF&WS).

MCB Quantico was proposed for the National Priorities List (NPL) on May 10, 1993, and finalized on the

NPL on May 31, 1994. In July 1995, the FFS and Proposed Plan identifying the DON's preferred interim

remedy were presented to the public, starting the period for public comment.

Basis for Taking Remedial Action

Based on information collected before implementation of the IRA, hazardous substances, pollutants, and

contaminants that have been released at concentrations greater than risk-based screening levels in each

site media include:

Soil Groundwater

� PAHs � Cadmium � Benzene � 4,4’-DDE

� PCBs � Chromium � Carbon disulfide � Aluminum

� 4,4’-DDD � Cobalt � Chlorobenzene � Arsenic

� 4,4’-DDT � Copper � 1,4-Dichlorobenzene � Barium

� Dieldrin � Lead � Vinyl chloride � Beryllium

� Aluminum � Manganese � Xylenes � Cadmium

� Arsenic � Thallium � Benzo(a)pyrene � Cobalt

� Barium � Vanadium � Bis(2-chloroethyl)ether � Copper

� Beryllium � Bis(2-ethylhexyl)phthalate � Lead

� 2,4-Dinitrotoluene � Manganese

� Hexachlorobenzene � Mercury

� Hexachloroethane � Selenium

� 1,2,4-Trichlorobenzene � Thallium

� 2,4,6-Trichlorophenol � Vanadium

� alpha-Chlordane � Zinc

� 4,4’-DDD

The media of concern for the IRA were soil and drainage swale sediment, which represented the highest

risk exposure pathways for Site 4. Potential exposure to soil is associated with significant human health

risks because of exceedance of the USEPA risk management criteria for either the average or the

reasonable maximum exposure scenarios. The unacceptable risks were only associated with the

hypothetical future residential exposure scenario.

100709/P 5 CTO 480


Unacceptable cancer risk from the soil contaminants was driven by PAHs, PCBs, and beryllium, with

PCBs contributing the most to risk. There were no unacceptable noncarcinogenic hazards associated

with exposure to soil. The presence of PCBs in soil and drainage swale sediment was determined to be

impacting the Quantico Embayment of the Potomac River. Once in the embayment, bioaccumulation of

PCBs could occur in aquatic receptors and pose a potential risk via human ingestion of contaminated fish.

Studies conducted after the IRA confirmed potential risks to ecological receptors and humans ingesting

fish.

Risks from exposure to groundwater were also considered in the FFS during the development of IRA

alternatives. Potential exposure to groundwater under the hypothetical future residential scenario is

associated with unacceptable carcinogenic and noncarcinogenic risks. Unacceptable cancer risks were

driven by benzo(a)pyrene, arsenic, and beryllium. Benzene, chlorobenzene, aluminum, arsenic, barium,

manganese, thallium, and vanadium drove the unacceptable noncancer hazards.

The IRA was followed by additional RI and FS activities for Site 4 to evaluate groundwater, surface water,

and sediment contamination. These studies have been completed and are documented in the April 2000

RI Report and the October 2005 FS Report for Site 4. Groundwater and waste discovered outside the

landfill area are addressed in the final remedy for Site 4. In addition, a Quantico Watershed Post-IRA

Study that evaluated potential impacts to the Quantico Embayment was completed in February 2004.

Surface water and sediment in the embayment are addressed in the March 2007 Site 99 (Quantico

Embayment) FS Report.

4.0 REMEDIAL ACTIONS

4.1 Interim Remedial Actions

4.1.1 Interim Remedy Selection

The ROD for the IRA for Site 4 was signed in September 1997. Remedial action objectives (RAOs) for

the IRA were developed as a result of data collected during the preliminary RI and FFS to aid in the

development and screening of remedial alternatives to be considered for the ROD. The RAOs for soil

and on-site sediment include the following:

� Minimize direct contact, inhalation, and ingestion of contaminants posing a carcinogenic risk.

� Reduce migration of contaminants to groundwater.

100709/P 6 CTO 480


� Minimize migration of contaminants to the adjacent embayment.

� Comply with applicable or relevant and appropriate requirements (ARARs) directly associated with

the action.

The major components of the IRA selected in the ROD include the following:

� Consolidation of existing berms, demolition and off-site disposal of scrap yard buildings, and

incorporation of scrap yard building foundations within the landfill.

� Excavation and off-site disposal of surface soil and drainage swale sediment contaminated with PCBs

in excess of 10 mg/kg.

� Excavation and on-site disposal of landfill material and sediment from the shoreline.

� Geotextile separation membrane and permeable soil barrier layer installation covering 23 acres, and

incorporation of flood control measures and shore protection.

� Shoreline stabilization

� Mitigation for wetlands destroyed or impacted by implementation of the IRA (1.8 acres impacted

versus 2.1 acres replaced), including monitoring of the replacement wetlands to ensure mitigation is

effective.

� Institutional controls, to include no breaching of the barrier layer, fencing around the entire site with

locked gates, and access restrictions from unauthorized personnel

� O&M.

� Five-year reviews as required by CERCLA.

Final use restrictions for the landfill will be addressed in the final remedy for Site 4.

100709/P 7 CTO 480


4.1.2 Interim Remedy Implementation

The DON prepared the Remedial Design (RD) and implemented the IRA. The RD was completed in July

1995. Site preparation activities for the IRA began in May 1996. The IRA was completed in October

1997. The major components of the IRA were as follows:

� Four on-site buildings were demolished and the landfill surface was cleared as initial steps for

preparing the site for subsequent actions.

� A total of 4,986 tons of soil and drainage swale sediment with PCB concentrations higher than

10 mg/kg was excavated and hauled off site for disposal. Erosion of the riverbank had resulted in

exposure of waste and debris along the shoreline from the shore to approximately 50 to 60 feet into

the river. Approximately 3,500 cubic yards of waste, debris, and sediment were excavated from the

river. The excavated material, which contained less than 10 mg/kg of PCBs, was placed on the

landfill and covered by a geotextile separation membrane and a soil barrier layer.

� The landfill surface was regraded, and a layer of geotextile separation membrane was placed at the

site. The soil barrier layer, which consists of 18 inches of common fill and 6 inches of topsoil, was

placed over the geotextile layer. The area was seeded upon completion of the topsoil layer. The

shoreline was stabilized with riprap to minimize erosion.

� A wetland was created to replace wetlands that were destroyed or impacted by installation of the soil

barrier layer (wetland mitigation). A stream was graded and backfilled with planting soil, and the

planting of new replacement wetland species was accomplished.

� Approximately 3,000 feet of chain-link fence was installed around the landfill perimeter, except along

the river, to control site access. Warning signs were posted on the fence.

The remediation contractor issued the final IRA report in February 1998. The DON, USEPA, and VDEQ

have determined that all IRA construction activities were performed according to specifications.

4.2 Final Remedial Actions

4.2.1 Final Remedy Selection

The ROD for the final remedy for Site 4 was signed in November 2007 by the Marine Corps and in

December 2007 by the USEPA. RAOs for the final remedy were developed as a result of data collected

100709/P 8 CTO 480


during the preliminary RI and FFS, as well as data collected during the RI, FS, and Post-IRA Study, to aid

in the development and screening of remedial alternatives to be considered for the ROD.

The RAOs for groundwater, soil, and buried waste include the following:

� Prevention of human exposure to contaminated groundwater (as long as it poses an unacceptable

risk), soil, and buried waste through ingestion, dermal contact, and inhalation.

� Minimization of the erosion of contaminated soil into the Quantico Embayment.

� Monitoring the potential migration of contaminated groundwater to the Quantico Embayment.

Preliminary remediation goals (PRGs) have not been established for soil/buried waste at Site 4 because

direct contact with this material has been eliminated/reduced through the implementation of the IRA.

Waste found outside the existing fence has either been removed or is covered with a geotextile

separation membrane and at least 2 feet of soil (which minimizes direct contact with the waste). Health

and-safety based restrictions are needed to protect the health and safety of the workers who would

engage in excavations in areas where waste is located outside the existing fence.

Groundwater PRGs based on protection of human and ecological receptors exposed to surface water,

sediment, and fish in the Quantico Embayment are currently being developed as part of a LTM Plan for

groundwater. The draft LTM Plan was submitted in July 2006. Although PRGs for groundwater were

presented in the FS Report, these values were set at the maximum detected groundwater concentration

for each detected chemical. Risk-based PRGs were developed in the LTM Plan such that the on-site

concentrations would not pose unacceptable risks if the contaminants migrate to the Quantico

Embayment.

USEPA does not require restoration of groundwater in areas where waste is left in place. Chemical

concentrations in the groundwater may reach levels that would allow for unrestricted use over time

because of natural processes. Unrestricted use of groundwater would be attained when concentrations

of chemicals meet acceptable levels based on drinking water standards and health advisories, state

groundwater standards, risk-based concentrations (RBCs), and upgradient (not site-related)

concentrations. Until groundwater concentrations meet these acceptable levels, restrictions would be

required on the use of the groundwater.

The major components of the final remedy selected in the 2007 ROD include the following:

� IRA (completed in 1997)

� Maintenance of the site fence and soil barrier layer

100709/P 9 CTO 480


� Implementation of LUCs

� Implementation of a monitoring program and site reviews

4.2.2 Remedy Implementation

An O&M Manual was included as Appendix D of the LTM Plan that was finalized in January 2008.

Maintenance of the landfill cover (soil barrier layer), groundwater monitoring wells, shoreline revetment,

and site fencing will consist of annual inspection and repairs, as necessary, if the integrity of any of the

components of the remedy have been compromised. In addition, the areas where wastes have been

noted outside of the existing fence will also be inspected to verify that the 2-foot layer of soil over the

waste has not been disturbed. Mowing of the landfill cover will occur twice a year. Inspection of the

constructed wetlands will occur once every five years. All inspections may occur episodically, if weather

conditions warrant. In addition, periodic surveys of the landfill surface will be performed to provide a

quantitative measure of settlement of the landfill.

As long as the MCB Quantico uses the land near Site 4 as an airfield, land use will be limited because the

majority of Site 4 lies within the “clear zone” of the air field. The placement of structures, buildings, and

above-ground utility lines in a “clear zone” is typically prohibited. Site 4 is expected to remain under the

control of MCB Quantico for the foreseeable future and is unlikely to be released to the public. DON will

be responsible for implementing, maintaining, reporting on, and enforcing the LUCs.

An RD for LUCs for Site 4 is included as Appendix E of the LTM Plan and was prepared to meet the

following objectives:

� No residential use.

� No use/access to shallow groundwater, except for environmental sampling.

� All other uses of groundwater require DON approval. The acceptability of such use will be evaluated

based on the chemical concentrations present in the groundwater at the time of such use and

whether such use would permanently damage the barrier layer at the site.

� Prevention of any activities that may disturb the barrier layer, the shoreline erosion controls, or fence.

� Maintain the integrity of any current or future remedial or monitoring system.

Once implemented, these LUCs related to groundwater use/access will be maintained until the

concentrations of hazardous substances in the groundwater are at such levels as to allow for unrestricted

use and exposure.

100709/P 10 CTO 480

4.3


The DON will obtain approval from USEPA and VDEQ prior to the conductance of any construction

activities at Site 4.

Monitoring of groundwater will be conducted in accordance with the final LTM Plan that was finalized in

January 2008. Monitoring will be conducted to confirm that contaminants are not present at

concentrations that may pose a threat to the human and ecological receptors in the Quantico

Embayment. The LTM Plan to be implemented as part of the Selected Remedy was developed with

USEPA and VDEQ concurrence and details the frequency, media type, analysis, and locations of the

LTM samples and the risk-based PRGs for groundwater.

At least every 5 years, a site review will be conducted to evaluate the analytical data, evaluate the site

status (i.e., current use and plans for future use) and regulations in effect at the time of the review, and

provide future direction as necessary. Site reviews are required because the Selected Remedy allows

contaminants to remain at concentrations that do not allow for unlimited use and unrestricted exposure.

The site review will document whether the remedy continues to be protective of human health and the

environment, and if not, what further actions need to be taken.

System Operation/Operation and Maintenance

The ROD for the final remedy states that O&M will include maintenance of the barrier layer, groundwater

monitoring wells, shoreline revetment, and site fencing and will consist of annual inspections and repairs,

as necessary, if the integrity of any of the components have been compromised. O&M for the IRA was to

include, at a minimum, the following items: performance standards to assure integrity of the barrier layer,

erosion control, wetland monitoring, and inspection and maintenance, as applicable.

MCB Quantico conducted inspection and maintenance activities according to the O&M Manual developed

as a result of the IRA and dated November 30, 1997. The primary inspection and maintenance activities

associated with O&M included the following:

� Site security, condition of gates, evidence of trespassing, evidence of vandalism, and condition of

warning signs.

� Condition of landfill cover, including erosion, ponded water, burrowing animal damage, and vegetative

cover.

� Condition of constructed wetland.

100709/P 11 CTO 480


� Condition of monitoring wells.

� Mowing and maintenance, as needed.

The primary cleanup of Site 4 took place during the construction phase of the IRA (i.e., removal of

contaminated soil and sediment and placement of geotextile separation membrane and soil barrier layer).

Therefore, as indicated in the planned elements above, the primary O&M activities have been geared

towards inspections and maintenance of the fence, landfill cover, and constructed wetland.

The LTM Plan finalized in January 2008 will replace the Maintenance Manual dated November 30, 1997.

The LTM Plan will assess and maintain the effectiveness of the final remedy at Site 4 and provides the

performance specifications for maintaining and monitoring the remedy.

5.0 PROGRESS SINCE THE LAST FIVE-YEAR REVIEW

The invasive plant species phragmites, identified as being present in the constructed wetlands during the

site inspection for the first five-year review, were partially treated with herbicides based on the

recommendations in the First Five-Year Review Report.

Additional evaluations of Site 4 (FS for Site 4) and adjoining sediment (Quantico Watershed Study Post-

IRA Study and FS for Site 99, Quantico Embayment) were completed.

Additional waste encountered during soil removal activities at IR Program Site 32 was removed.

The ROD for the final remedy at Site 4 was signed in November 2007 by the Marine Corps and in

December 2007 by the USEPA.

6.0 FIVE-YEAR REVIEW PROCESS

6.1 Administrative Components

The USEPA and Virginia DEQ were notified of the initiation of the second five-year review on October 17,

2007. The Site 4 five-year review team was led by Kristen Harstad, the Remedial Project Manager (RPM)

for the DON. TtNUS assisted in the review under contract to the DON. Donna Heric of MCB Quantico

assisted in the review as the representative of the base. Lisa Cunningham, the USEPA RPM, and Steve

Mihalko, the VDEQ RPM, assisted in the review as the representatives of the support agencies.

100709/P 12 CTO 480


Early in November 2007, the review team established the review schedule whose components included

the following:

� Community involvement

� Document review

� Data review

� Site inspection

� Five-Year Review Report development and review

The schedule extended through the end of March 2008.

6.2 Community Involvement

A notice was sent to three local newspapers that the second five-year review was to be conducted. The

notice announced that the results of the five-year review would be available to the public at the Chinn

Park Regional Library, John Porter Memorial Library, and Marine Corps Research Center.

6.3 Document Review

The five-year review consisted of a review of relevant documents including O&M records and monitoring

data. The documents reviewed include the following:

� RI/Risk Assessment Report, Old Landfill, November 1992

� FFS Report for Old Landfill, April 1995

� ROD for Old Landfill - Site 4, Interim Remedial Action, September 1997

� Maintenance Manual, Site 4 - Old Landfill, November 1997

� Final Report, IRA, Site 4 - Old Landfill, February 1998

� RI for Site 4 - Old Landfill, April 2000

� Survey Report, Quantico Watershed Study, Rapid Sediment Analysis Pilot Study, November, 2001

� Site Inspection Checklists, Site 4 - Old Landfill, December 1997 to December 2001

� Quantico Watershed Study Post-IRA Study Report, February 2004

� FS for Site 4 - Old Landfill, October 2005

� ROD for Old Landfill - Site 4, October 2007

� LTM Plan, Site 4 - Old Landfill, January 2008

100709/P 13 CTO 480


6.4 Data Review

No additional groundwater or sediment data have been collected since the first five-year review was

conducted. Consequently the data review presented in the First Five-Year Review Report presents the

most recent data collected at Site 4.

No distinguishable groundwater plumes were evident from the data collected prior to the IRA. Data

collected after the IRA supports this conclusion.

Evaluations of the past and present impacts of Site 4 on the Quantico Embayment were presented in the

Quantico Watershed Post-IRA Study and the Final FS for Site 4.

6.5 Site Inspection

An inspection of the site was conducted on November 1 and 2, 2007 by representatives of TtNUS,

including a wetland specialist. Representatives of the DON, MCB Quantico, and VDEQ participated in a

portion of the site inspection on November 1, 2007. The purpose of the inspection was to assess the

protectiveness of the interim remedy, including the presence of fencing to restrict access, the integrity of

the soil barrier layer and shoreline protection, and the condition of the constructed wetland. Photographs

taken during the site inspection are included in Appendix A.

The following issues regarding the soil barrier layer, shoreline protection, and fence were noted during the

site inspection on November 1 and 2, 2007.

� Six small depressions where water may pond were noted on the surface of the landfill. Four are on

the northern portion of the landfill and two are on the southern portion of the landfill. The locations of

these depressions were flagged in the field and the approximate locations are shown on Figure 2.

� Ruts from vehicles are present in a number of areas of the landfill (at least five areas). Water may

pond in these ruts. The approximate locations of the ruts are shown on Figure 2.

� Numerous groundhog holes were noted in the surface of the landfill. The locations were flagged in

the field.

� Several erosional channels were noted along the face of the landfill behind the shoreline revetment

(northern portion of the landfill). There is one erosional channel on the north slope of the southern

portion of the landfill (approximate location shown on Figure 2). None of the erosional channels are

100709/P 14 CTO 480


deep enough to impact the barrier layer, but if left unchecked, erosion of the cover soil may continue

and eventually impact the barrier layer.

� A small section of the fence along the southern wetlands is covered with heavy vegetation and is

starting to fall over. The location of this section of fence is noted on Figure 2.

No significant issues were identified during the site visit regarding the constructed wetland. The

vegetation planted during the IRA is healthy and dense. Some trees have emerged naturally. The only

issue that was noted during the site visit was the presence of three types of invasive plant species. MCB

Quantico personnel were notified of this issue and will apply a herbicide to the phragmites to

eliminate/control this invasive species (the other two invasive plant species were not expected to spread).

The wetland inspection report is included in Appendix C.

The overall condition of the soil barrier layer, shoreline protection, fence, and constructed wetland are

good. By conducting repairs associated with the issues noted above, the interim remedy at Site 4 will

continue to be protective of human health and the environment.

The institutional controls that have been put in place by MCB Quantico as part of the IRA include

restrictions on breaching of the barrier layer, access from unauthorized personnel, and any other activities

or actions that might interfere with the implemented remedy. No intrusive development of the landfill is

allowed. During the site visit, no activities were observed that would have violated the institutional

controls. The soil barrier layer was undisturbed (with the exceptions noted above), and no uses of

groundwater were observed.

The casings/pads for several of the monitoring wells appear to be cracked or damaged (see photographs

in Appendix B). Although the conditions of the monitoring wells do not affect the potential for release of

contamination from the site, the conditions of the monitoring wells will need to be evaluated as part of the

implementation of the LTM Plan.

Table 2 summarizes the issues noted during the site inspection, identifies whether the issues affect

protectiveness, and provides the corrective action that will be taken to address the issues. Milestone

dates for the corrective actions also are included.

6.6 Interviews

Three phone interviews were conducted as part of this five-year review. Mr. Dave Crosley, STP

Superintendent, was contacted and he indicated that he was not aware of any problems or concerns

100709/P 15 CTO 480


related to the current site conditions at Site 4. He was aware of the access restrictions to Site 4 and

indicated that the restrictions were not a hindrance to the operation of the STP.

Mr. Martin Scott, Turner Airfield Environmental Coordinator, was contacted and he also indicated that he

was not aware of any problems or concerns related to the current site conditions at Site 4. He indicated

that he was very happy with the outcome.

Mr. Albert Gasser, Mayor of the Town of Quantico, was contacted and he indicated that he was aware of

the Old Landfill (drives by it everyday) and had no concerns regarding the measures taken there.

7.0 TECHNICAL ASSESSMENT

7.1 Question A: Is the remedy functioning as intended by the decision documents?

The review of documents, ARARs, risk assumptions, and the results of the site inspection indicates that

the interim remedy is functioning as intended by the ROD, if the issues noted during the site inspection

are corrected. The removal of contaminated soil and drainage swale sediment, the removal of waste and

sediment from the Quantico Embayment, and the installation of the geotextile separation membrane and

soil barrier layer have achieved the RAOs to prevent direct contact, inhalation, and ingestion of soil and

sediment contaminants, reduce migration of contaminants to groundwater, and minimize migration of

contaminants to the adjacent embayment. The effective implementation of IRA institutional controls has

also helped to achieve the RAO to prevent direct contact, inhalation, and ingestion of soil and sediment

contaminants.

Informal inspections of the site were conducted between 1997 and 2005 by the MCB Quantico Natural

Resources and Environmental Affairs (NREA) Branch.

Inspection and maintenance of the site security controls and soil barrier layer have, on the whole, been

effective. Areas needing repair were noted on the site inspection checklists along with the status of the

repair. No formal inspections have been conducted since the completion of the inspection for the first

five-year review was completed in September 2002. With the exception of the issues noted above, there

are no indications of any difficulties with the final remedy.

The maintenance and survival of the constructed wetland has been good. A few clumps of several

invasive species were observed in the wetland. However, this does not affect the potential release of

contaminants from the site and does not affect protectiveness of the final remedy.

100709/P 16 CTO 480


There were no opportunities to improve the performance and/or reduce costs of monitoring, sampling,

and treatment systems because these activities were not part of the IRA and the LTM of the landfill has

not started.

The institutional controls that are in place for the IRA include restrictions on breaching of the barrier layer,

access restrictions from unauthorized personnel, and any other activities or actions that might interfere

with the implemented remedy. No invasive development of the landfill is allowed. No activities were

observed that would have violated the institutional controls. The soil barrier layer is generally undisturbed

with the exception of the issues noted. The fence around the site is intact and in good repair with the

exception of the short section of fence along the southern wetlands.

7.2 Question B: Are the exposure assumptions, toxicity data, clean-up levels, and RAOs used at the time of the remedy selection still valid?

There have been no changes in the physical conditions of the site that would affect the protectiveness of

the remedy.

7.2.1 Changes in Standards and To Be Considers (TBCs)

Since the remedial work has been completed, all ARARs for PCB-contaminated soil, wetlands, and

floodplains cited in the IRA ROD were met. A list of ARARs from the final ROD is included in Table 3.

There have been no changes in these ARARs and no new standards or to be considered (TBCs) that

would affect the protectiveness of the remedy.

7.2.2 Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics

The exposure assumptions used to develop the human health risk assessment for Site 4 included both

current exposures (adult trespasser and construction worker) and potential future exposures (hypothetical

adult and child residents). The risk assessment also included exposure of an adult recreational user that

ingests fish; however, this route of exposure is not applicable to the interim remedy at Site 4.

Changes in toxicity factors for soil contaminants of concern (COCs) were not evaluated for this five-year

review because the only contaminant-specific remediation goal for soil was for PCBs. The remediation

goal for PCBs in soil (10 mg/kg) is based on a concentration obtained from USEPA guidance and is still

applicable.

Changes in toxicity factors for groundwater COCs were evaluated for this five-year review. The toxicity

factors used in the risk assessment in the RI prepared in April 2000 and the current values are shown in

100709/P 17 CTO 480


Table 4. Although the risks associated with individual COCs will fluctuate slightly, the overall risks

associated with the COCs will not change substantially and the changes in toxicity factors do not affect

the protectiveness of the interim remedy.

The standardized risk assessment methodology has not changed significantly since the risk assessment

associated with the April 2000 RI was completed. Consequently, any changes in the risk assessment

methodology would not affect the protectiveness of the interim remedy.

7.3 Question C: Has any other information come to light that calls into question the protectiveness of the remedy?

There is no other information that calls into question the protectiveness of the interim remedy. No on-site

ecological targets were evaluated during the baseline risk assessment conducted, and none were

identified during the five-year review. Therefore, monitoring of on-site ecological targets is not necessary.

The site as a continuing source area (i.e., the potential for current migration of contaminants) was

evaluated in the FS for the final remedy for Site 4. Historical migration of contaminants was addressed in

the Quantico Watershed Post-IRA Study Report completed in February 2004 and the March 2007 Site 99

(Quantico Embayment) FS Report. An RD is currently being prepared for the Quantico Embayment.

Additionally, no weather-related events have affected the protectiveness of the remedy.

7.4 Technical Assessment Summary

According to the data reviewed and the site inspection, the remedy is functioning as intended by the

interim ROD. There have been no changes in the physical conditions of the site that would affect the

protectiveness of the remedy. All ARARs for soil contamination cited in the interim ROD have been met.

A review of changes in toxicity factors or risk assessment methodology indicated that the changes would

not affect the protectiveness of the remedy.

8.0 ISSUES

As noted above in Section 6.5, the following issues regarding the soil barrier layer, shoreline protection,

and fence were noted during the site inspection on November 1 and 2, 2007.

� Small depressions where water may pond were noted on the surface of the landfill.

� Ruts from vehicles are present in a number of areas of the landfill (at least five areas). Water may

pond in these ruts.

100709/P 18 CTO 480

9.0


� Numerous groundhog holes were noted in the surface of the landfill.

� Several erosional channels were noted along the face of the landfill behind the shoreline revetment

(northern portion of the landfill).

� A small section of the fence along the southern wetlands is covered with heavy vegetation and is

starting to fall over.

In addition, three invasive plant species were observed in the constructed wetland (phragmites, Japanese

stiltgrass, and multiflora rose). The presence of these invasive species does not affect the potential

release of contamination from the site and does not affect current or future protectiveness of the interim

remedy. Several monitoring wells appeared to be in a state of disrepair and the conditions of the

monitoring wells will need to be evaluated as port of the implementation of the LTM Plan. However, the

current conditions of the monitoring wells do not affect the potential release of contamination from the

site.

RECOMMENDATIONS AND FOLLOW-UP ACTIONS

To verify the presence of the suspected depressions/vehicle ruts, the landfill surface should be surveyed

as per the O&M Manual that is part of the LTM Plan. In addition, it does not appear the two survey

benchmarks have been surveyed recently. Any depression/ruts where ponding would occur will need to

be filled to the appropriate contours and seeded as per the LTM Plan.

The erosional channels in the face of the landfill behind the revetment and the erosional channel in the

north slope of the southern portion of the landfill should be filled in and seeded as per the LTM Plan.

The groundhog holes need to be evaluated to determine if the holes are active. If so, the groundhogs will

need to be removed from the landfill area. Once any groundhogs are removed, the holes will need to be

filled as per the LTM Plan.

The vegetation on the fence along the southern wetlands will need to be removed and the fence

stabilized.

The phragmites in the wetlands should be treated with postemergence herbicides.

The DON and MCB Quantico will be responsible for any follow-up actions associated with the issues

identified above.

100709/P 19 CTO 480


10.0 PROTECTIVENESS STATEMENT

The interim remedy for Site 4 is protective of human health and the environment and is functioning as

intended. Changes in the exposure assumptions, toxicity data, clean-up levels, and RAOs used at the

time of the remedy selection do not affect the protectiveness of the interim remedy. No other information

has come to light that could call into question the protectiveness of the interim remedy.

11.0 NEXT REVIEW

The next five-year review for Site 4 is required by March 2013, five years from the date of this review.

100709/P 20 CTO 480

TABLE 1

CHRONOLOGY OF SITE EVENTS SITE 4 – OLD LANDFILL

MCB QUANTICO, VIRGINIA PAGE 1 OF 2

Event Date Landfill operations Early 1920s - 1971 Landfill surface used by DRMO for storage of waste fuels and solvents, electrical transformers, and out of service military vehicles

1950s - 1979

Rupture of pipeline adjacent near the landfill spilled approximately 100,000 gallons of diesel fuel onto the landfill

June 1980

IAS (equivalent to a preliminary assessment) 1984 Confirmation Study (equivalent to a site inspection) 1988 Removal action for soil contaminated with PCBs from DRMO activities 1990 Preliminary RI 1991 VDEQ issues NOV for discharging contaminants without a NPDES permit June 1993 USFWS conducts ecological risk assessment 1993 to 1999 Final listing on USEPA National Priority List May 1994 EE/CA and FFS for IRA 1994 to 1995 FFS and Proposed Plan released to the public; start of public comment period July 1995 RD completed July 1995 IRA activities – sediment removed from drainage channel, sediment and waste material removed from Quantico Embayment, DRMO structures and surface debris removed, soil barrier layer installed over landfill, shoreline protection installed, wetlands concentration in southern portion of the site

May 1996 to October 1997

ROD for the IRA is signed September 1997 Final Report - IRA February 1998 Additional waste material found west of landfill boundary 1998 RI to support final remedial action 1997 to 1999 Federal Facility Agreement signed February 1999 FS to support final remedial action 2000 to 2005 Sampling to support Rapid Sediment Analysis Pilot Study for Quantico Embayment

October 2001

Survey Report for Rapid Sediment Analysis Pilot Study November 2001 Post-IRA Study Work Plan June 2002 Quantico Watershed Study Post-IRA Study September 2002 First Five-Year Review Report March 2003 Quantico Watershed Study Post-IRA Study Report February 2004 Additional waste material found north of Epperson Avenue during CERCLA non-time-critical removal action at IR Program Site 32; waste was removed and disposed of and area was restored

July 2005

Site 99 (Quantico Embayment) FS March 2007 Proposed Plan for final action released to the public; start of public comment period

March 2007

TABLE 1

CHRONOLOGY OF SITE EVENTS SITE 4 – OLD LANDFILL

MCB QUANTICO, VIRGINIA PAGE 2 OF 2

Event Date ROD for final action is signed November 2007

(Marine Corps) December 2007

(USEPA) LTM Plan for Site 4 - Old Landfill January 2008

Abbreviations:

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act DRMO Defense Reutilization and Marketing Office EE/CA Engineering Evaluation/Cost Analysis FFS Focused Feasibility Study FS Feasibility Study IAS Initial Assessment Study IRA interim remedial action LTM Long-Term Monitoring NOV Notice of Violation NPDES National Pollutant Discharge Elimination System PCB polychlorinated biphenyl RD Remedial Design RI remedial investigation ROD Record of Decision USEPA United States Environmental Protection Agency USFWS U.S. Fish and Wildlife Service VDEQ Virginia Department of Environmental Quality

TAB

LE 2

ISSU

ES ID

ENTI

FIED

DU

RIN

G T

HE

SEC

ON

D F

IVE-

YEA

R R

EVIE

W

SITE

4 –

OLD

LA

ND

FILL

M

CB

QU

AN

TIC

O, V

IRG

INIA

Issu

e A

ffect

s Pr

otec

tiven

ess

Cor

rect

ive

Act

ion

to

Add

ress

Issu

e M

ilest

one

Dat

eC

urre

nt

Futu

re

Six

sm

all d

epre

ssio

ns w

here

wat

er m

ay p

ond

wer

e no

ted

on th

e su

rface

of t

he la

ndfil

l. F

our a

re

on th

e no

rther

n po

rtion

of t

he la

ndfil

l and

two

are

on th

e so

uthe

rn p

ortio

n of

the

land

fill.

N

Y

To v

erify

the

pres

ence

of t

he s

uspe

cted

de

pres

sion

s/ve

hicl

e ru

ts, t

he la

ndfil

l sur

face

sh

ould

be

surv

eyed

as

per t

he O

&M

Man

ual t

hat

is p

art o

f the

Lon

g-Te

rm M

onito

ring

Pla

n. I

n ad

ditio

n, it

doe

s no

t app

ear t

he tw

o su

rvey

be

nchm

arks

hav

e be

en s

urve

yed

rece

ntly

. A

ny

depr

essi

on/ru

ts w

here

pon

ding

wou

ld o

ccur

will

ne

ed to

be

fille

d to

the

appr

opria

te c

onto

urs

and

seed

ed a

s pe

r the

Lon

g-Te

rm M

onito

ring

Pla

n.

Nov

embe

r 20

08R

uts

from

veh

icle

s ar

e pr

esen

t in

a nu

mbe

r of

area

s of

the

land

fill (

at le

ase

five

area

s).

Wat

er

may

pon

d in

thes

e ru

ts.

N

Y

Num

erou

s gr

ound

hog

hole

s w

ere

note

d in

the

surfa

ce o

f the

land

fill.

N

Y

The

grou

ndho

g ho

les

need

to b

e ev

alua

ted

to

dete

rmin

e if

the

hole

s ar

e ac

tive.

If s

o, th

e gr

ound

hogs

will

need

to b

e re

mov

ed fr

om th

e la

ndfil

l are

a. O

nce

any

grou

ndho

gs a

re

rem

oved

, the

hol

es w

ill ne

ed to

be

fille

d as

per

th

e Lo

ng-T

erm

Mon

itorin

g P

lan.

Nov

embe

r 20

08

Sev

eral

ero

sion

al c

hann

els

wer

e no

ted

alon

g th

e fa

ce o

f the

land

fill b

ehin

d th

e sh

orel

ine

reve

tmen

t (n

orth

ern

porti

on o

f the

land

fill).

The

re is

one

er

osio

nal c

hann

el o

n th

e no

rth s

lope

of t

he

sout

hern

por

tion

of th

e la

ndfil

l.

N

Y

The

eros

iona

l cha

nnel

s in

the

face

of

the

land

fill b

ehin

d th

e re

vetm

ent a

nd th

e er

osio

nal c

hann

el in

the

north

slo

pe o

f th

e so

uthe

rn p

ortio

n of

the

land

fill

shou

ld b

e fil

led

in.

Nov

embe

r 20

08

A s

mal

l sec

tion

of th

e fe

nce

alon

g th

e so

uthe

rn

wet

land

s is

cov

ered

with

hea

vy v

eget

atio

n an

d is

st

artin

g to

fall

over

.

N

Y

The

vege

tatio

n on

the

fenc

e al

ong

the

sout

hern

w

etla

nds

will

need

to b

e re

mov

ed a

nd th

e fe

nce

stab

ilized

.

Nov

embe

r 20

08

Alth

ough

thre

e in

vasi

ve p

lant

spe

cies

wer

e ob

serv

ed in

the

cons

truct

ed w

etla

nd (p

hrag

mite

s,

Japa

nese

stil

tgra

ss, a

nd m

ultif

lora

rose

), th

e pr

esen

ce o

f phr

agm

ites

only

is c

onsi

dere

d to

be

prob

lem

atic

.

N

N

The

phra

gmite

s in

the

wet

land

s w

ill n

eed

to b

e er

adic

ated

via

trea

tmen

t with

pos

tem

erge

nce

herb

icid

es.

Nov

embe

r 20

08

TAB

LE 3

DES

CR

IPTI

ON

OF

AR

AR

s FO

R S

ELEC

TED

REM

EDY

SI

TE 4

– O

LD L

AN

DFI

LL

MC

B Q

UA

NTI

CO

, VIR

GIN

IA

Aut

horit

y M

ediu

m

Req

uire

men

t St

atus

Sy

nops

is o

f Req

uire

men

t A

ctio

n to

be

Take

n to

Atta

in

Req

uire

men

t C

hem

ical

-Spe

cific

Fe

dera

l R

egul

ator

y R

equi

rem

ent

Gro

undw

ater

A

mbi

ent W

QC

(4

0 C

FR 1

31.3

6)

Rel

evan

t and

A

ppro

pria

te

Thes

e re

gula

tions

est

ablis

h co

ncen

tratio

n lim

its fo

r pr

otec

tion

of s

urfa

ce w

ater

.

Dev

elop

men

t of P

RG

s w

ill co

nsid

er a

ttain

men

t of a

mbi

ent

wat

er q

ualit

y cr

iteria

for s

urfa

ce

wat

er in

the

Qua

ntic

o E

mba

ymen

t. S

tate

R

egul

ator

y R

equi

rem

ent

Gro

undw

ater

V

irgin

ia W

ater

Qua

lity

Sta

ndar

ds

(9 V

AC

25-

260-

140)

App

licab

le

Thes

e re

gula

tions

est

ablis

h co

ncen

tratio

n lim

its fo

r pr

otec

tion

of s

urfa

ce w

ater

.

Dev

elop

men

t of P

RG

s w

ill co

nsid

er a

ttain

men

t of w

ater

qu

ality

sta

ndar

ds fo

r sur

face

w

ater

in th

e Q

uant

ico

Em

baym

ent.

Act

ion-

Spec

ific

Sta

te

Reg

ulat

ory

Req

uire

men

t

Sol

id W

aste

(L

andf

illed

M

ater

ial)

Virg

inia

Reg

ulat

ions

for

San

itary

Lan

dfills

(9

VA

C 2

0-80

-250

D a

nd

9 V

AC

20-

80-2

50 F

)

Rel

evan

t and

A

ppro

pria

te

Thes

e re

gula

tions

est

ablis

h st

anda

rds

for s

anita

ry la

ndfil

ls.

The

regu

latio

ns in

clud

e gr

ound

wat

er m

onito

ring

and

post

-clo

sure

car

e re

quire

men

ts.

Gro

undw

ater

mon

itorin

g an

d m

aint

enan

ce o

f the

soi

l bar

rier

laye

r mee

t the

mon

itorin

g an

d po

st-c

losu

re re

quire

men

ts.

Not

es:

Ther

e ar

e no

loca

tion-

spec

ific

AR

AR

s as

soci

ated

with

the

Sel

ecte

d R

emed

y. R

efer

to th

e FS

Rep

ort f

or A

RA

Rs

for o

ther

alte

rnat

ives

.

Abb

revi

atio

ns:

AR

AR

ap

plic

able

or r

elev

ant a

nd a

ppro

pria

te re

quire

men

t C

FR

Cod

e of

Fed

eral

Reg

ulat

ions

FS

Fe

asib

ility

Stu

dy

P

RG

s pr

elim

inar

y re

med

iatio

n go

als

V

AC

V

irgin

ia A

dmin

istra

tive

Cod

e

WQ

C

Wat

er Q

ualit

y C

riter

ia

TAB

LE 4

TOXI

CIT

Y D

ATA

SU

MM

AR

Y

SITE

4 –

OLD

LA

ND

FILL

M

CB

QU

AN

TIC

O, V

IRG

INIA

Che

mic

al

Valu

es fr

om 2

000

RI R

epor

t C

urre

nt V

alue

s O

ral C

SF

(mg/

kg/d

ay)-1

D

erm

al C

SF

(mg/

kg/d

ay)-1

O

ral R

fD

(mg/

kg/d

ay)

Der

mal

RfD

(m

g/kg

/day

) O

ral C

SF

(mg/

kg/d

ay)-1

D

erm

al C

SF

(mg/

kg/d

ay)-1

So

urce

/Dat

e O

ral R

fD

(mg/

kg/d

ay)

Der

mal

RfD

(m

g/kg

/day

) Ta

rget

O

rgan

(s)

Com

bine

d U

ncer

tain

ty/

Mod

ifyin

g Fa

ctor

s So

urce

/Dat

e

Alu

min

um

NA

N

A

1.0E

+00

2.7E

-01

NA

N

A

--

1.0E

+00

1.0E

+00

CN

S

NA

N

CE

A/2

007

Ars

enic

1.

5E+0

0 1.

58E

+00

3.0E

-04

2.9E

-04

1.5E

+00

1.50

E+0

0 IR

IS/2

007

3.0E

-04

3.0E

-04

Ski

n, C

NS

3/

1 IR

IS/2

007

Bar

ium

N

A

NA

7.

0E-0

2 7.

0E-0

2 N

A

NA

IR

IS/2

007

2.0e

-01

1.4E

-02

Kid

ney

300/

1 IR

IS/2

007

Iron

NA

N

A

3.0E

-01

3.0E

-01

NA

N

A

--

7.0E

-01

7.0E

-01

Blo

od, L

iver

, GI

NA

N

CE

A/2

007

Man

gane

se

NA

N

A

2.0E

-02

2.3E

-02

NA

N

A

IRIS

/200

7 2.

0E-0

2 8.

0E-0

1 C

NS

, Blo

od

1/3

IRIS

/200

7

Not

es:

This

tabl

e pr

ovid

es c

arci

noge

nic

and

nonc

arci

noge

nic

risk

info

rmat

ion

for t

he C

OC

s in

gro

undw

ater

. A

t thi

s tim

e, C

SFs

are

not

ava

ilabl

e fo

r the

der

mal

rout

e of

exp

osur

e. T

he d

erm

al C

SF u

sed

in th

e as

sess

men

t has

bee

n ex

trapo

late

d fro

m th

e

oral

val

ue.

An a

djus

tmen

t fac

tor i

s ap

plie

d an

d is

dep

ende

nt u

pon

how

wel

l the

che

mic

al is

abs

orbe

d vi

a th

e or

al ro

ute.

Adj

ustm

ents

are

par

ticul

arly

impo

rtant

for c

hem

ical

s w

ith le

ss th

an 5

0 pe

rcen

t abs

orpt

ion

via

the

inge

stio

n ro

ute.

Inh

alat

ion

sl

ope

fact

ors

are

not p

rovi

ded

beca

use

the

inha

latio

n ex

posu

re ro

ute

is o

nly

appl

icab

le fo

r inh

alat

ion

of V

OC

s w

hile

sho

wer

ing,

whi

ch is

not

a c

once

rn b

ecau

se n

o V

OC

s w

ere

sele

cted

as

CO

Cs

for t

his

site

.

All

of th

e C

OC

s ha

ve to

xici

ty d

ata

indi

catin

g th

eir

pote

ntia

l for

adv

erse

non

carc

inog

enic

ris

ks in

hum

ans.

Th

e ch

roni

c to

xici

ty d

ata

avai

labl

e fo

r or

al e

xpos

ures

hav

e be

en u

sed

to d

evel

op o

ral R

fDs.

A

s w

as th

e ca

se w

ith c

arci

noge

nic

data

, de

rmal

RfD

s w

ere

extra

pola

ted

from

ora

l val

ues

appl

ying

an

adju

stm

ent f

acto

r as

app

ropr

iate

. A

djus

tmen

ts w

ere

nece

ssar

y fo

r ba

rium

and

man

gane

se.

No

adju

stm

ent w

as n

eede

d fo

r al

umin

um, a

rsen

ic, a

nd ir

on.

Inha

latio

n R

fDs

are

not

prov

ided

bec

ause

the

inha

latio

n ex

posu

re ro

ute

is o

nly

appl

icab

le fo

r inh

alat

ion

of V

OC

s w

hile

sho

wer

ing,

whi

ch is

not

a c

once

rn b

ecau

se n

o V

OC

s w

ere

sele

cted

as

CO

Cs

for t

his

site

.

Abb

revi

atio

ns:

CO

C

chem

ical

of c

once

rn

CN

S

cent

ral n

ervo

us s

yste

m

CS

F ca

ncer

slo

pe fa

ctor

GI

gast

roin

test

inal

IRIS

In

tegr

ated

Ris

k In

form

atio

n S

yste

m

NA

no

t ava

ilabl

e

NC

EA

N

atio

nal C

ente

r for

Env

ironm

enta

l Ass

essm

ent

RfD

re

fere

nce

dose

VO

C

vola

tile

orga

nic

com

poun

d

•

• ~Site96

n t I nt

300 o 300 Feet

DRAWN BY DATE

LEGEND

Limit of Soil Barrier

Road Railroad

Fence

Stream

I

\ I

Old Lar:1d~1I {Site 4)

Constructed Wetlands

Former DRMO Area (L-3)--.

~~ . S~IA(

/ ~~~:~ ftj n-

~ Tetra Tech NUS, Inc.A.JANOCHA 9114104

CHECKED BY DATE

G. ZIMMERMAN 11/26107 SITE LAYOUT

• COST/SCHEDULE-AREA

SITE 4 - OLD LANDFILL

MCB QUANTICO, VIRGINIA DRAWING NO.

AS NOTED

P:\GIS\QUANTICO_MCB\APR\SITE04.APR SITE LAYOUT - 8.5)(11 1112810755

N

Former Transformer Storage Area (B-8)

Layer/Geotextile Layer

Land Use Control Boundary

Topographic Contour

Approximate Location of Waste Material Found Outside Fence in 1998

Approximate Location of Waste Material Found Outside Fence in 2005

Former DRMO Area (SWMU L-03). Former Transformer Storage Area (SWMU B-08) and Former Diesel Spill Area

Building

Wetland

Surface Water

CONTRACT NUMBER

CTO 0480 DATE

DATE

REV FIGURE 1 o

P:/GISIOUANTICO_MCBlMAPDOCSlMXD/SITE04_MW SAMPLES,MXD 11126107 S5 • • •

N

",

OLFMW013 ss OLFMW018

:H03

·4

")()"

OLFMW20A S

Portion of Fence Needing Repair

Possible Depression Noted During November 1 and 2, 2007 Site Inspection (approximate location)

Vehicle Ruts Where Ponding May Occur (approximate location)

Topographic Contour (contour interval = 1 foot)

Land Use Control Boundary

Legend tSl Groundwater Monitoring Well

Fence Line

o•

, I

)•

OLFMW04A S

I

200 i Feet

o100

,"'"

200 i

DRAWN BY DATE

K. MOORE 11/26107

CHECKED BY DATE

~ Tetra Tech NUS, Inc.

G. ZIMMERMAN 11/28107 RESULIS OF NOVEMBER 1 AND 2, 2007 SITE INSPECTION

COST SCHEDULE AREA SITE 4 - OLD LANDFilL

Mea QUANTICO, VIRGINIA FIGURE NO. SCALE

AS NOTED FIGURE 2

APPENDIX A

FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST

• OSWER No. 9355.7-03B-P

Five-Year Review Site Inspection Checklist

(Working document for site inspection. Information may be completed by hand and attached to the Five-Year Review report as supporting documentation of site status. "N/A" refers to "not applicable.")

I. SITE INFORMATION

Site name: Site 4 (Old Landfill) MCB Quantico Date of inspection: November I and 2, 2007

Location and Region: Quantico, Virginia EPA ill: VAI170024722

Weather/temperature: Sunny 50's and 60's review: Department of Navy Agency, office, or company leading the five-year

Remedy Includes: (Check all that apply) 181 Landfill cover/containment r Monitored natural attenuation 181 Access controls r Groundwater containment ~ Institutional controls r VertiCal barrier walls r Groundwater pump and treatment r Surface water collection and treatment rather

• Attachments: r Inspection team roster attached 181 Site map attached - See Figure 2

II. INTERVIEWS (Check all that apply)'

I. O&M site manager Name Title Date

Interviewed r at site r at office r by phone Phone no. Problems, suggestions; r Report attached

2.0&Mstaff Name Title Date

Interviewed r at site r at office r by phone Phone no. Problems, suggestions; r Report attached

• A-I

OSWER No. 9355.7-03B-P

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, OT other city and county offices, etc.) Fill in aJl that apply.

Agency Town of Quantico Contact Albert Gasser Mayor 1216/07 703-640-6998

Name Title Date Phone no. Problems; suggestions; r Report attached Mr. Albert Gasser, mayor of the Town of Quantico, was contacted and he indicated that he was aware of the Old Landfil1 (drives by it everyday) and had no concerns regarding the measures taken there.

Agency Contact

Name Title Date Phone no. Problems; suggestions; r Report attached

Agency Contact


Agency Contact


4. Other interviews (optional) r Report attached.

Dave Crosley - STP Superintendent - ] ]/26/07 - Knew of no site conditions, problems, or related

concerns that would impact the remedy.

Jim Scott - Turnei Airfield Environmental Coordinator - 1]/29/07 - Knew of no site conditions,

problems, or related concerns that would impact the remedy.

•

•

•A-2

• OSWER No. 9355.7-03B-P

III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)

I. O&M Documents rO&Mmanual r Readily available r Up to date rN/A r As-built drawings r Readily available rup to date rN/A rMaintenance logs r Readily available r Up to date rN/A Remarks O&M Manual - part of Long-Term Monitoring Plan - submitted as draft in July 2006 waiting for resolution of comments - Site Inspection completed from 12/8/97 to 119105 as per Maintenance Manual submitted I l/30197.

2. Site-Specific Health and Safety Plan r Readily available r Up to date l8J N/A r Contingency plan/emergency response plan r Readily available rup to date I8l N/A Remarks

3. O&M and OSHA Training Recofds r Readily available r Up to date I8l N/A Remarks

4. Permits and Service Agreements r Air discharge permit r Readily available rup to date I8l N/A r Effluent discharge r Readily available rup to date I8l N/A r Waste disposal, POTW r Readily available rup to date I8l N/A r Other permits r Readily available r Up to date I8l N/A

• Remarks

5. Gas Generation Records r Readily available rup to date I8l N/A Remarks

6. Settlement Monument Records r Readily available r Up to date rN/A Remarks Not Available

7. Groundwater Monitoring Records r Readily available rup to date rN/A Remarks No Groundwater Monitoring has been done since last samples collected in 1999 as part ofFS.

8. Leachate Extraction Records r Readily available rup to date 18I N/A Remarks

9. Discharge Compliance Records rAir r Readily available rup to date 18I N/A r Water (effluent) r Readily available rup to date I8l N/A Remarks

10. Daily Access/Security Logs r Readily available rup to date I8lN/A Remarks

• A-3


IV. O&M COSTS • 1. O&M Organization

o State in-house o Contractor for State o PRP in-house o Contractor for PRP o Federal Facility in-house {g] Contractor for Federal Fa~ility

o Other

2. O&M Cost Records o Readily available o Up to date {g] Funding mechanism/agreement in place Original O&M cost estimate d Breakdown attached

Total annual cost by year for review period if available

From l/l/03 To 12/31/03 $4,000 (approximate) o Breakdown attached Date Date Total cost

From l/1/04 To 12/3l/04 $4.000 (approximate) o Breakdown attached Date Date Total cost

From 1/1/05 To 12/31/05 $5,000 (approximate) o Breakdown attached Date Date Total cost

From 1/1/06 To 12/3l/06 . $5,250 o Breakdown attached Date Date Total cost

From 1/1/07 To 12/3l/07 $7,000 o Breakdown attached Date Date Total cost

3. Unanticipated or Unusually High O&M Costs During Review Period •Describe costs and reasons:

V. ACCESS AND INSTITUTIONAL CONTROLS o Applicable DN/A

A, Fencing

1. Fencing damaged {g] Location shown on site map 0 Gates secured 0 N/A Remarks Fence in good condition except for the fencing next to the Southern Wetlands (Site 96) near the airfield

B, Other Access Restrictions

1. Signs and other security·measures o Location shown on sIte map DN/A Remarks$igns are visible on fence.

A-4 •

OSWER No. 9355.7-03B-P e

e.

C. Institutional Controls (ICs)

1. Implementation and enforcement Site conditions imply ICs not properly implemented rYes jgJ No rN/A Site conditions imply ICs not being fully enforced rYes jgJ No rN/A

Type of monitoring (e.g., self-reporting, drive by) Part of Site Insoections Frequency Once a quarter between 12/8/97 and 1/9/05 Responsible party/agency MCB Quantico - NREA Contact

Name Title Date Phone no.

Reporting is up-to-date rYes rNo rN/A Reports are verified by the lead agency rYes rNo rN/A

Specific requireIl)entsin deed or decision documents have been met rYes rNo jgJ N/A Violations have been reported rYes rNo (2gN/A Other problems or suggestions: r Report attached

2. Adequacy (2g ICs are adequate r ICs are inadequate rN/A Remarks

D. General

1. Vandalism/trespassing r Location shown on site map (2g No vandalism evident Remarks

2. Land use changes on site (2g N/A Remarks

3. Land use changes orr site I8JN/A Remarks

VI. GENERAL SITE CONDITIONS

A. Roads r Applicable [8J N/A

1. Roads damaged r Location shown on site map r Roads adequate[8J N/A Remarks

e A-5

•• OSWER No. 9355.7-03B-P

B. Other Site Conditions

Remarks

VII. LANDFILL COVERS r Applicable rN/A

A. Landfill Surface

I. Settlement (Low spots) 18I Location shown·on site map· r Settlement not evident Areal extent Depth Remarks There were six small areas that appeared to be depressions where ponding may occur. In addition. tire tracks/ruts were evident in several places.

2. Cracks r Location shown on site map 1RI Cracking not evident Lengths Widths Depths

Remarks

3. Erosion r Location shown on site map r Erosion not evident Areal extent Depth Remarks Several places along interface of landfill behind revetment show signs of erosion. One erosional channel evident in southern portion of landfill. •

4. Holes r Location shown on site map r Holes not evident Areal extent Depth Remarks Numerous groundhog holes were discovered and marked. Could not tell if any are active.

5. Vegetative Cover 18l Grass 18l Cover properly established 18l No signs of stress r Trees/Shrubs (indicate size and locations on a diagram) Remarks

6. Alternative Cover (armored rock, concrete, etc.) 18I N/A Remarks

7. Bulges r Location shown on site map 18I Bulges not evident Areal extent Height Remarks

•A-6

• OSWER No. 9355.7-03B-P

Wet AreaslWater Damage ~ Wet areas/water damage not evident r Location shown on site map Areal extent

8.

rWet areas rPonding r Seeps r Soft subgrade Remarks

9. Slope Instability Areal extent Remarks

B. Benches

channel.)

1. Flows Bypass Bench Remarks

2. Bench Breached Remarks

3. Bench Overtopped Remarks

C. Letdown Channels

1. Settlement Areal extent Remarks

2. Material Degradation Material type Remarks

3. Erosion Areal extent Remarks

r Location shown on site map Areal extent r Location shown on site map Areal extent r Location shown on site map Areal extent

r Slides r Location shown on site map ~ No evidence of slope instability

. r Applicable ~N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined

r Location shown on site map ~ N/Aorokay

r Location shown on site map ~ N/A or okay

• r Location shown on site map ~ N/A or okay

r Applicable ~N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.)

r Location shown on site map r No evidence of settlement Depth

r Location shown on site map r No evidence of degradation Areal extent

r Location shown on site map r No evidence of erosion Depth

• A-7


4. Undercutting r Location shown on site map r No evidence of undercutting •Areal extent Depth Remarks

5. Obstructions Type r No obstructions r Location shown on site map Areal extent Size Remarks

6. Excessive Vegetative Growth Type r No evidence of excessive growth rVegetation in channels does not obstruct flow r Location shown on site map Areal extent Remarks

D. Cover Penetrations r Applicable rN/A

1. Gas Vents r Activer Passive r Properly securedllocked r Functioning r Routinely sampled r Good condition r Evidence of leakage at penetration r Needs Maintenance lID N/A Remarks

2. Gas Monitoring Probes· r Properly securedllocked r Functioning r Routinely sampled r Good condition • r Evidence of leakage at penetration r Needs Maintenance lID N/A Remarks

3. Monitoring Wells (within surface area of landfill) r Properly securedllocked r Functioning r Routinely sampled r Good condition r Evidence of leakage at penetration lID Needs Maintenance rN/A Remarks Wells/pads are in fair shape. Several need repairs. All will need to be evaluated before being used as part of monitoring program.

4. Leachate Extraction Wells r Properly securedllocked r Functioning r Routinely sampled r Good condition r Evidence of leakage at penetration r Needs Maintenance 181 N/A Remarks

5. Settlement Monuments rLocated r Routinely surveyed rN/A Remarks Did not locate; these are not routinely surveyed.

A-8 •

• OSWER No. 9355.7-03B-P

E. Gas Collection and Treatment r Applicable IE] N/A

I. Gas Treatment Facilities rFlaring r Thermal destruction r Collection for reuse r Good condition r Needs Maintenance Remarks

2. Gas Collection Wells, Manifolds and Piping r Good conditionr Needs Maintenance Remarks

3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) r Good condition r Needs Maintenance rN/A Remarks

F. Cover Drainage Layer r Applicable 18I N/A

I. Outlet Pipes Inspected r Functioning rN/A Remarks

• 2. Outlet Rock Inspected r Functioning rN/A

Remarks

G. Detention/Sedimentation Ponds r Applicable 18I N/A

I. Siltation Areal extent Depth rN/A r Siltation not evident Remarks

2. Erosion Areal extent Depth r Erosion not evident Remarks

3. Outlet Works r Functioning . rN/A Remarks

4. Dam r Functioning rN/A Remarks

• A-9


H. Retaining Walls r Applicable Igj N/A • 1. Deformations r Location shown on site map r Deformation not evident

Horizontal displacement Vertical displacement Rotational displacement Remarks

2. Degradation r Location shown on site map r Degradation not evident Remarks

I. Perimeter Ditches/Orr-Site Discharge r Applicable Igj N/A

1. Siltation r Location shown on site map r Siltation not evident Areal extent Depth Remarks

2. Vegetative Growth r Location shown on site map rN/A r Vegetation does not impede flow Areal extent Type Remarks

3. Erosion r Location shown on site map r Erosion not evident Areal extent Depth Remarks .'

4. Discharge Structure r Functioning rN/A Remarks

VIII. VERTICAL BARRIER WALLS r Applicable 129 N/A

1. Settlement r Location shown on site map r Settlement not evident Areal extent Depth Remarks

2. Perforinance MonitoringType of monitoring r Performance not .monitored Frequency r Evidence of breaching Head differential . Remarks

•A-tO

• OSWER No. 9355.7-03B-P

IX. GROUNDWATER/SURFACE WATER REMEDIES r Applicable [8JN/A

A. Groundwater Extraction Wells, Pumps, and Pipelines r Applicable rN/A

1. Pumps, Wellhead Plumbing, and Electrical r Good condition r All required wells properly operating r Needs Maintenance r NtA Remarks

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances r Good conditionr Needs Maintenance Remarks

3. Spare Parts and Equipment r Readily available r Good condition r Requires upgrade r Needs to be provided Remarks

B. Surface Water Collection Structures, Pumps, and Pipelines r Applicable rNtA

1. Collection Structures, Pumps, and Electrical r Good conditionr Needs Maintenance Remarks

• 2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances r Good conditionr Needs Maintenance Remarks

3. Spare Parts and Equipment r Readily available r Good condition r Requires upgrade r Needs to be provided Remarks

• A-II


C. Treatment System r Applicable rN1A • 1. Treatment Train (Check components that apply)

,

r Metals removal r Oil/water separation r Bioremediation r Air stripping r Carbon adsorbers rFilters r Additive (e.g., chelation agent, flocculent) rOthers r Good condition r Needs Maintenance r Sampling ports properly marked and functional r Sampling/maintenance log displayed and up to date r Equipment properly identified r Quantity of groundwater treated annually r Quantity of surface water treated annually Remarks

2. Electrical Enclosures and Panels (properly rated and functional) rN/A r Good condition r Needs Maintenance Remarks

3. Tankst Vaultst Storage Vessels rN/A r Good condition r Proper secondary containment r Needs Maintenance Remarks

4. Discharge Structure and Appurtenances •rN/A r Good conditionr Needs Maintenance Remarks

5. Treatment Building(s) rN/A r Good condition (esp.roof and doorways) r Needs repair r Chemicals and equipment properly stored Remarks

,"

6. . Monitoring Wells (pump and treatment remedy) r Properly securedllocked r Functioning r Routinely sampled r Good condition r All required wells located r Needs Maintenance rN/A Remarks

D. Monitoring Data

1. Monitoring Data r Is routinely submitted on time r Is of acceptable quality

2. Monitoring data suggests: r Groundwater plume is effectively contained r Contaminant concentrations are declining

A-12

• OSWER No. 9355.7-03B-P

D. Monitored Natnral Attenuation

1. Monitoring Wells (natural attenuation remedy) r Properly secured/locked r Functioning r Routinely sampled r Good condition r All required wells located r Needs Maintenance rN/A Remarks

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.

XI. OVERALL OBSERVATIONS

A• Implementation of the Remedy

•

• A-13

••


Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.). • The remedy is intended to prevent direct contact. inhalation. and ingestion of soil and sediment contaminants, reduce migration of contaminants to groundwater, and minimize migration of contaminants to the adjacent embayment.

Six small depressions where water may pond were noted on the surface of the landfill. Four are on the northern portion of the landfill and two are on the southern portion of the landfill. In addition. ruts from vehicles are present in a number of areas of the landfill (at lease five areas). Water may pond in these ruts. To verify the presence of the suspected dcmressions/vehicle ruts, the landfill surface should be surveyed as per the O&M Manual that is part of the Long-Term Monitoring Plan. In addition, it does not aPJlear the two survey benchmarks have been surveyed recently. Any depression/ruts where pODding would occur will need to be filled to the appropriate contours and seeded as per the Long-Term Monitoring Plan.

" Numerous groundhog holes were noted in the surface of the landfill. The groundhog holes need to be evaluated to determine if the holes are active. If so, the groundhogs will need to be removed from the landfill area. Once any groundhogs are removed. the holes will need to be filled as per the Long-Term Monitoring Plan.

Several erosional channels were noted along the face of the landfill behind the shoreline revetment (northern portion of the landfill). There is one erosional channel on the north slope of the southern portion of the landfill. The erosional channels in the face of the landfill behind the revetment and the erosional channel in the north slope of the southern portion of the landfill should be filled in. • A small section of the fence along the southern wetlands is covered with heavy vegetation and is starting to fall over. The· vegetation on the fence along the southern wetlands will need to be removed and .the fence stabilized.

Three invasive plant mecies were observed in the constructed wetland (phragrnites, Japanese stiltgrass, and multiflora rose). The phragmites in the wetlands will need to be eradicated via treatment with postemergence herbicides. No action is needed for the Japanese stiltgrass and multiflora rose because they are not expected to spread throughout the wetland.

A-14

• OSWER No. 9355.7-03B-P

c. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future.

• D. Opportunities for Optimization

Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In particular, discuss their relationship to the current and long-term protectiveness of the remedy.

• A-IS

APPENDIX B

SITE VISIT PHOTOGRAPHS

Western boundary fence line looking north from the access gate

Sign on the access gate

B-1

Access gate

Shoreline revetment looking north near OLFMW-25

B-2

One of a number of groundhog holes on the northern portion of the landfill


B-3



B-4

Vehicle ruts in landfill surface near OLFMW024

Vehicle ruts in landfill surface near western boundary just north of access gate

B-5

Vehicle rut in landfill surface between OLFMW-25 and OLFMW012/14A

Depression in landfill surface near northeast corner of landfill

B-6

Slight depression in landfill surface just south of access gate before landfill slopes toward the constructed wetlands

Vehicle ruts in the northern portion of the landfill surface running from access gate toward the entrance of the constructed wetland

B-7

Erosional channels on face of landfill behind shoreline revetment (near OLFMW-25)

Erosional channels on face of landfill behind shoreline revetment (near OLFMW-25)

B-8

Monitoring wells OLFMW01A, OLFMW16A, and OLFMW026 (pads/casings in good shape/small depression is located next to OLFMW16A)

Monitoring well OLFMW19A (overgrown, one post knocked over)

B-9

Monitoring wells OLFMW012 and OLFMW14A (casings/pads in good shape; no lock on OLFMW12)

Monitoring well OLFMW-25 (casing/pad okay; riser too high to lock cap)

B-10

Egret at entrance to constructed wetlands

Constructed wetlands looking from entrance toward the west

B-11

Raccoon near the culvert that feeds the constructed wetlands

Fence along southern wetlands that is overgrown with vegetation and is starting to sag

B-12

Post in southern portion of landfill – slight depression exists around post

B-13

Vehicle ruts in southern portion of landfill surface looking from southern weltands toward OLFMW17A

B-14

APPENDIX C

WETLAND INSPECTION MEMORANDUM

MEMORANDUM

TO: Karen Lyons

FROM: J. Peyton Doub, PWS, CEP

DATE: November 5, 2007

SUBJECT: Visual Site inspection of Constructed Wetlands, Installation Restoration (IR) Program Site 4 – Old Landfill, Marine Corps Base (MCB) Quantico, Virginia

The following memorandum documents a visual site inspection conducted by a wetland scientist

on November 2, 2007 for the subject wetlands. The wetlands were constructed as on-site

mitigation to compensate for unavoidable wetland losses resulting from an interim remedial action

(IRA) completed in 1997 at Site 4, the Old Landfill, at MCB Quantico. The inspection supports a

Five-Year Review (Year 2008) of the final remedy, as required under the Comprehensive

Environmental Response, Compensation, and Liability Act (CERCLA). It follows a similar

memorandum dated September 18, 2002 that outlined a visual site inspection supporting the first

(Year 2003) Five-Year Review of the IRA.

Background: Site 4, the Old Landfill, consists of approximately 23 acres occupied by an

abandoned landfill on the shore of a tidal reach of the Potomac River. Operations at the landfill

began in the early 1920s and ceased in 1971. The landfill was constructed by incrementally filling

tidal marshes and shallow waters on the river shoreline, ultimately extending the shoreline into

the river approximately 600 to 1,200 feet out from its original location. The interim remedial

action consisted of excavation and off-site disposal of PCB-contaminated soil, re-grading the

landfill, and covering the landfill with a soil barrier layer (Halliburton NUS, 1995a and b). The final

remedy includes the IRA completed in 1997, maintenance of the site fence and soil barrier layers

(layers installed as part of the 1997 IRA for Site 4 and a soil removal action at an adjoining site),

implementation of land use controls (LUCs), and implementation of a monitoring program and site

reviews.

Wetland Delineation: A wetland delineation following procedures in the Corps of Engineers

Wetlands Delineation Manual (Environmental Laboratory) and appropriate supplementary

guidance was conducted for Site 4 prior to the implementation of the interim remedial action in

1995 (Halliburton NUS, 1995a). Approximately 1.8 acres of wetlands were identified within the

proposed footprint of disturbance for the interim remedial action. The wetlands were situated in a

cove that roughly divided the landfill into northern and southern halves. The cove allowed

freshwater discharged from a storm drain northwest of the landfill to traverse the landfill and flow

into the Potomac River. After reviewing the wetland delineation, the Navy determined that it

MEMORANDUM November 9, 2007 Page 2 of 14

would not be possible to successfully implement the interim remedial action without permanently

filling the 1.8 acres of wetlands.

Wetland Mitigation Plan: To compensate for the unavoidable 1.8-acre wetland loss, the Navy

designed a plan for constructing approximately 2.1 acres of onsite wetlands as part of the interim

remedial action. The planned result was a net onsite wetland gain of approximately 0.3 acres.

The wetlands were restored in a reconfigured cove in the approximate original location of the

original cove and wetlands, dividing the covered landfill into northern and southern halves. The

original cove, which contained the 1.8 acres of wetlands, allowed freshwater released from a

storm drain at the northern perimeter of the landfill to traverse the landfill and flow into the

Potomac River. The new wetlands were designed to be influenced by the same hydrology

sources as the original wetlands in the cove. These sources included freshwater, both runoff

from the landfill surface and discharge the storm drain, and the tides of the Potomac River

(Halliburton NUS, 1995c). The Potomac River, although tidal at MCB Quantico, is normally fresh

or nearly fresh, with salinities normally less than 5 parts per thousand during all seasons (White,

1989).

The design called for restoring the approximate original elevations of wetlands in the cove and

planting three zones of herbaceous vegetation keyed to elevation as follows:

• Elevations Below 1 Foot: Saltmeadow Cordgrass (Spartina alterniflora)

• Elevations Between 1 and 2 Feet: Common Three-square (Scirpus americanus)

• Elevations Between 2 and 3 Feet: Soft-stem Bulrush (Scirpus validus)

The design also called for planting more widely spaced accents of other herbaceous species that

typically occur in similar landscape settings and are of good value to wildlife but which could not

be counted on to establish and spread rapidly. Accent species in the design included deep-water

duck potato (Sagittaria rigida), pickerelweed (Pontederia cordata), and marsh hibiscus (Hibiscus

moscheutos). The design also called for planting a fringe of woody vegetation around the edges

of the wetland, including black willow (Salix nigra) and red maple (Acer rubrum) (both trees) and

elderberry (Sambucus canadensis) and groundsel tree (Baccharis halimifolia) (both shrubs)

(Halliburton NUS, 1995c).

Installation of Wetland Mitigation Plan: OHM Remediation Services Corporation (OHM) and

their subcontractor, Coastal Environmental Services (Coastal), constructed the wetlands and

installed the plant material called for in the wetland mitigation plan in 1997. Coastal substituted

arrow arum (Peltandra virginica) for the deep-water duck potato. Coastal also shifted the planting


of the pickerelweed 25 feet down-gradient (i.e. toward the lower elevations in the center of the

wetland) to provide that species with a deeper hydrological regime. Planting took place between

April and June 1997. Planting was periodically delayed during this period by incidents of high

tidal flooding of the wetland (Coastal, 1997).

OHM and Coastal inspected the wetland mitigation area in November 1997 and presented their

observations in a written report. The report stated that a vigorous herbaceous stand comprised

predominantly of the planted soft-stem bulrush, common three-square, and saltmeadow

cordgrass had become established over much of the wetland. Several volunteer herbaceous

species had also reportedly begun to colonize the wetland. The volunteer species reportedly

included flat sedge (Cyperus sp.), soft rush (Juncus effusus), common cattail (Typha latifolia),

and smartweed (Polygonum persicaria) (Coastal, 1997).

Vegetative coverage was described as sparser in the upper (drier) fringe of the wetland. Possible

explanations provided in the report included flooding, herbivory, and low rainfall during the

summer of 1997. The report did not, however, recommend additional planting. It stated that tidal

wetland hydrology had been successfully established throughout the wetland and areas of sparse

vegetation in November 1997 would likely become colonized naturally by desirable wetland plant

species (Coastal, 1997).

A Site Inspection Checklist and Repair Report prepared by OHM in July 1998 stated that OHM

replanted vegetation in the wetland area (OHM, 1998). The reports did not provide information

on how much of the vegetation required replanting or what vegetation was used in the replanting.

It is assumed that OHM adhered to the original planting scheme when replacing vegetation.

First Five-Year Inspection: Peyton Doub, PWS, CEP of Tetra Tech NUS, who prepared the

wetland mitigation plan design, visited the site on Thursday, September 18, 2002 to evaluate the

wetland in support of the first (Year 2003) Five-Year Review. Also present were Andrew

Gutberlet of Engineering Field Activity Chesapeake, Lisa Bradford of the U.S. Environmental

Protection Agency, and Matias Santiago of the Natural Resources and Environmental Affairs

(NREA) office of MCB Quantico.

At that time, the entire wetland mitigation area supported dense vegetation. As called for in the

design, a shallow stream of running water flowed down the center of the wetland to the Potomac

River. The stream channel was generally around than 10 feet wide and 6 to 12 inches deep.

Low elevation lands adjoining the stream supported dense emergent wetland vegetation and

were saturated at the surface. Higher-elevation lands around the upper fringe of the wetland


were not saturated at the surface, but the vegetation displayed watermarks suggestive of a recent

history of shallow inundation.

Vegetation throughout the wetland was dense and dominated by herbaceous plant species that

typically grow in wetlands (i.e. hydrophytes). Most of the wetland supported dense patches of the

following species: jewelweed (Impatiens capensis), soft rush, soft-stem bulrush, common three

square, common cattail, woolgrass (Scirpus cyperinus), and rice cutgrass (Leersia oryzoides).

Other plant species observed in the wetland included marsh hibiscus, pickerelweed, smartweed,

wingstem (Verbesina alternifolia, erroneously identified as coreopsis in the 2002 memorandum),

and tall ironweed (Vernonia altissima). All of the observed species were regionally indigenous

hydrophytes with wetland indicator statuses of Facultative Wetland (FACW) or Obligate Wetland

(OBL) (Reed, 1988). The soft-stem bulrush, common three-square, marsh hibiscus and

pickerelweed were components of the original design; the other species had not been planted

and must therefore have become established as natural volunteers. Smooth cordgrass, which

was planted as part of the original design and observed in November 1997, was not observed.

A dense fringe of black willow saplings was observed at the outer edge of the wetlands. The

original design called for planting a mixture of black willow and red maple at the fringe. At least

some of the black willows appeared to be surviving planted specimens, while others could have

been volunteers. No red maple was observed. Several volunteer tree saplings of other species

were observed at widely scattered locations within the wetland, including sycamore (Platanus

occidentalis), elm (Ulmus sp.), and eastern cottonwood (Populus deltoides).

Among the shrubs, dense patches of groundsel tree were observed, especially near the fringe of

the wetland where this species was planted. No elderberry (the other planted shrub species) was

observed. Silky dogwood (Cornus amomum), another regionally indigenous shrub typical of

wetlands with fresh or nearly fresh water, was observed to have volunteered at several locations

in the wetland. The only invasive or exotic vegetation observed in the wetland were a few small

clumps of phragmites (Phragmites australis). Phragmites did not appear to have established

dominance over the wetland.

The first Five-Year Review concluded that the 2.1-acre wetland restoration had been successfully

accomplished in accordance with the general expectations of the design. Although not all of the

planted plant species had been successfully established, the entire wetland area supported

dense cover dominated by regionally indigenous wetland plants (hydrophytes) typical of natural

freshwater tidal marshes. The entire wetland displayed evidence of frequent soil inundation and

saturation expected for a tidal wetland. Spot infestation by the invasive plant phragmites was


observed. The first Five-Year Review recommended that areas of the wetland infested by

phragmites be treated using an herbicide.

Present Observations (November 2, 2007): As was true during the site inspection for the first

Five-Year Review, the reconstructed wetland continues to be densely vegetated with regionally

indigenous freshwater tidal marsh vegetation throughout. Photo 1 shows an overview of the

wetland on September 18, 2002 and Photo 2 shows an overview of the wetland on November 2,

2007. No visibly stressed vegetation or substantial areas of bare soil are apparent.

Black willow saplings presently form a tall, dense fringe between 20 and 30 feet in height around

the outer edge of the wetland (Photo 3). Comparison of Photos 1 and 2 reveals that the black

willow saplings have grown considerably taller and larger since 2002. Many of the saplings are

now 3 to 5 inches in trunk diameter. A few black willow stems on the north side of the wetland

display evidence of gnawing and felling beavers (Photo 4). A beaver dam is present at the

eastern edge of the wetland (Photo 5). However, the losses of black willow stems to beavers do

not appear to be substantial. As noted in 2002, several groundsel tree shrubs were also

observed in the woody fringe around the wetland. However, groundsel tree appears to be much

less abundant than in 2002.

Most of the wetland presently supports dense cover by regionally indigenous herbaceous plants

common in freshwater tidal marshes such as common three-square, cattail, jewelweed, rice

cutgrass, soft rush, marsh hibiscus, woolgrass, smartweed, wingstem, and common boneset

(Eupatorium perfoliatum). All of these species have a wetland indicator status of FACW or OBL

(Reed, 1988). Most of these same plant species were also observed in the wetland in 2002. No

soft-stem bulrush, which was called for in the design and observed during the 2002 site

inspection, was observed. However, common boneset, which was observed frequently

throughout the wetland during the 2007 site inspection, had not been observed in 2002. Hence,

while the plant species composition of the wetland may have changed somewhat since 2002, the

wetland continues to be dominated by regionally indigenous herbaceous plants typical of natural

freshwater tidal marshes.

The central stream (Photo 6) appears similar to how it appeared in 2002. It is generally about 10

feet wide and 6 to 12 inches deep. Except in the immediate vicinity of the discharge, there is no

visually discernable current. Any slow current would be expected to fluctuate with the tides.

Several small fish were observed in the stream. The stream banks are densely vegetated and do

not display any visually apparent erosion.


Even though the wetland is dominated throughout by regionally indigenous vegetation, three

invasive plant species were observed in the wetland on November 2, 2007. The first is

phragmites, which was also noted during the 2002 inspection. A linear area in the southeastern

quadrant of the wetland is presently infested with phragmites (Photo 7). The infestation appears

to be spreading westward, as evidenced by a small occurrence near the south-central part of the

wetland (Photo 8). The 2002 report describes the phragmites as occurring in “patches” (Photo 9).

This fact suggests that the present linear infestation may have resulted from the spread and

coalescence of the patches observed in 2002.

The second invasive plant species observed is Japanese stiltgrass (Microstegium vimineum). It

was observed in the groundcover under black willow growth near the western (up-gradient) tip of

the wetland (Photo 10). Its occurrence is limited to a small, elevated area accumulation of

sediment encompassing only a few square feet. Because it is generally intolerant of saturated

soil conditions, it is unlikely to spread into the remainder of the wetland. The third invasive plant

species observed is multiflora rose (Rosa multiflora). It was observed as a couple of isolated

specimens in the south-central part of the wetland (Photo 11). It too is only poorly tolerant of

saturated soils and hence unlikely to spread substantially over the wetland.

Conclusions and Recommendations: Based on field observations made during a site visit on

November 2, 2007, coupled with a review of the related documents as summarized above, it is

concluded that the 2.1 acres of reconstructed wetlands have been successfully established in

accordance with the general expectations of the design. The planned net gain of 0.3 acre of

freshwater tidal wetlands on the site, as called for in the design, appears to have been

successfully achieved.

The following recommendations are made to manage the successfully established wetland:

1. It is recommended that phragmites be eradicated from the wetland. Phragmites is an

invasive grass that is capable of forming dense monocultures spreading over large areas

of wetlands. While still limited to a small area in the southeastern quadrant of the

wetland, phragmites appears to have spread over a larger area since 2002. Treatment is

easier with less adverse effect on adjoining vegetation while patches remain small and

localized. Multiple postemergence herbicides are available to treat phragmites. Only

formulations labeled for use in aquatic habitats should be used. Application should be

manual only; aerial application, which could substantially damage non-target vegetation,

is not recommended.


2. The observed infestations by Japanese stiltgrass and multiflora rose do not appear

substantial enough to warrant control action. Neither species is expected to spread

substantially into adjoining areas of the wetland.

3. Activity by resident beavers does not appear to be jeopardizing the vegetational and

hydrological integrity of the wetland. Action to remove the beavers or to protect

vegetation from the beavers is therefore not recommended.

4. Further formal monitoring of the wetland is not recommended. However, the efficacy of

phragmites treatments should be monitored until successful eradication is achieved.

Multiple rounds of treatment may be necessary to achieve successful eradication.

No additional action is recommended for managing the wetland.

REFERENCES

Coastal (Coastal Environmental Services, Inc.). 1997. As-Built Description of Wetland Planting,

Old Landfill as Marine Corps Combat Development Command (MCCDC), Quantico, Virginia.

Prepared for OHM Remediation Services Corp., Pittsburgh, Pennsylvania. Project No. 41

133.01, December 17, 1997.

Halliburton NUS. 1995a. Wetland Delineation Report for Site 4 Old Landfill at Marine Corps

Combat Development Command (MCCDC), Quantico, Virginia. Prepared for Engineering Field

Activity Chesapeake, Naval Facilities Engineering Command, Washington, DC under Northern

Division Contract Number N62472-90-D-1298, Contract Task Order 198.

Halliburton NUS. 1995b. Erosion and Sediment Control Plan Report for Interim Remedial Action

at Site 4 - Old Landfill, Marine Corps Combat Development Command (MCCDC), Quantico,

Virginia. Prepared for Engineering Field Activity Chesapeake, Naval Facilities Engineering

Command, Washington, DC under Northern Division Contract Number N62472-90-D-1298,

Contract Task Order 198.

Halliburton NUS. 1995c. Wetland Mitigation Plan for Site 4 Old Landfill at Marine Corps Combat

Development Command (MCCDC), Quantico, Virginia. NAVFAC Drawing Number 3089092,

Sheet 16 of 17, Sheet Number C-14. Prepared for Engineering Field Activity Chesapeake, Naval

Facilities Engineering Command, Washington, DC under Northern Division Contract Number

N62472-90-D-1298, Contract Task Order 198.


OHM (OHM Remediation Services Corp.). 1998. Site Inspection Checklist and Repair Report,

July 1998.

Reed, P. B. 1988. National List of Plant Species that Occur in Wetlands. U.S. Fish and Wildlife

Service, U.S. Army Corps of Engineers, U.S. Environmental Protection Agency, and U.S. Soil

Conservation Service. Biological Report 88(24), September 1988.

White, C. P. 1989. Chesapeake Bay – A Field Guide. Tidewater Publishers, Centreville,

Maryland.


Photo 1 Overview of Reconstructed Site 4 Wetland

November 2, 2007

Photo 2 Overview of Reconstructed Site 4 Wetland

September 18, 2002


Photo 3 View South across Central Part of Wetland

Showing Portions of Black Willow Fringe on Northern and Southern Edges of the Wetland November 2, 2007

Photo 4 Beaver-Cut Black Willow Saplings on North Edge of Wetland

November 2, 2007


Photo 5 Beaver Dam at Eastern End of Central Stream

(Near Where Central Stream Empties to Potomac River) November 2, 2007

Photo 6 Central stream, looking west (upgradient)

November 2, 2007


Photo 7 Phragmites infestation in southeastern part of wetland

November 2, 2007

Photo 8 Small phragmites infestation in south-central part of wetland

November 2, 2007


Photo 9 Patch of Phragmites September 18, 2007

Photo 10 Japanese stiltgrass near western (up-gradient) tip of wetland

November 2, 2007


Photo 11 Multiflora rose in south-central part of wetland