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Fact Sheet Proposed Site Restoration Activities at Building 4343 to Facilitate Clean Close Out This fact sheet describes the selected action for cadmium-contaminated soil at Building 4343 – Former Cadmium Plating Facility at Radford Army Ammunition Plant (RFAAP). This alternative was selected in accordance with the Resource Conservation and Recovery Act of 1976 (RCRA), the Hazardous and Solid Waste Amendments of 1984 (HSWA), the RFAAP Resource Conservation and Recovery Act (RCRA) Permit requirements (USEPA, 2000) (EPA ID No. VA1210020730), and the Final RCRA Corrective Action Plan (USEPA, 1994), as applicable. Background The Building 4343 parcel is located in the west central portion of the Horseshoe Area and was established in 1956. Cadmium plating activities were conducted at Building 4343 in support of the NIKE missile program. Treated process water was discharged to an unlined ditch north of the site. The RFAAP RCRA Corrective Action Permit, signed in September 2000, identified Building 4343 as an Area of Concern (AOC) that had the potential to pose a threat, or potential threat, to human health and the environment. The Permit required that a sampling strategy be developed to complete the delineation and characterization of the site. RCRA Facility Investigation (RFI) field efforts were conducted in 1999 and 2002. Data indicated that metals (mainly cadmium) had contaminated soil around Building 4343 and in the process water discharge ditch and alluvial fan. The contamination was mostly confined to the top two feet of soil. Two sumps, related to Building 4343, were identified as having elevated concentrations of metals. Since one of these sumps was located inside Building 4343 there is the potential for contaminated soil underneath the building. Human Health and Screening Level Ecological risk assessments indicated there was elevated risk at the site and remedial measures were necessary to ensure the protection of human health and the environment. Remedial Alternatives Based on the findings of the Building 4343 RFI, a Corrective Measures Study (CMS) was conducted. The CMS evaluated remedial alternatives to address the cadmium contamination at the site. Four corrective measures alternatives were evaluated to address cadmium in soil at Building 4343:
These four alternatives were evaluated using the selection criteria: effectiveness, implementability, and cost. The corrective measures objective (CMO) for the RFI/CMS was to reduce contaminant concentrations in soil to allow clean close out of the site. To fully address this objective, a remedy that addressed the potential for future groundwater impact received preferential consideration. RFAAP is underlain by karst geology. The preferential remedial alternative in this type of geological setting is source removal. Allowing waste to remain in place above actionable regulatory levels represents a risk to RFAAP and the Army. Alternative Three was selected as the final alternative for Building 4343 because it is implementable and provides a greater level of protection to human health and the environment not provided by Alternatives Two and Four. Alternative Three facilitates clean close out, is cost effective, and is protective of groundwater. By achieving clean close out, these corrective measures accomplish the Army’s IRP goal by cleaning up the site and restoring it for beneficial use. This alternative includes the following:
Implementation of this alternative will reduce the concentrations of cadmium to below the Residential RG and facilitate clean close out. In addition, the proposed human health RG for residential land use is expected to result in reduction of ecological risks associated with chemicals in the soil to levels that are protective of the environment. Therefore, implementation of this alternative meets the corrective action objective and is protective of human health and the environment. The data, findings, assessments and recommendations are contained in the Building 4343 RFI/CMS Report, October 2003 and is being reviewed by the U.S. Army Environmental Center (USAEC), U.S. Environmental Protection Agency (USEPA) Region III and Virginia Department of Environmental Quality (VDEQ). The U.S. Army Center for Health Promotion and Preventive Medicine has concurred with the findings of this report. A copy of this document is located in the RFAAP information repository. Conclusion The selected remedy - Excavation of Soil for Clean Close Out, Off-site Disposal, Removal of Sumps, and Removal of Building 4343 – was chosen because it is considered implementable and provides protection to human health and the environment. In addition, this alternative facilitates clean close out and is cost effective. By achieving clean close out, these corrective measures accomplish the Army’s Installation Restoration Program (IRP) goal by cleaning up the site and restoring it for beneficial use. This remedy has been selected by RFAAP in the Building 4343 RFI/CMS Report, October 2003. The U.S. Army Center for Health Promotion and Preventive Medicine has concurred with the findings of this report. This report is under review by the U.S. Army Environmental Center (USAEC), U.S. Environmental Protection Agency (USEPA) Region III and Virginia Department of Environmental Quality (VDEQ). A copy of the Building 4343 RFI/CMS Report, October 2003 is located in the RFAAP information repository. |
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