FEASIBILITY STUDY ADDENDUM REPORT *FINAL*
FEASIBILITY STUDY ADDENDUM REPORT*FINAL*Kenilworth Park Landfill SiteAnacostia ParkWashington, D.C.Prepared for:National Park ServiceNational Capital Parks - EastWashington, D.C.September 2020Prepared by:
FinalTABLE OF CONTENTSPageEXECUTIVE SUMMARY . 11.0 INTRODUCTION . 41.1NPS CERCLA Authority . 41.2Purpose . 51.3Report Organization . 52.0 BACKGROUND . 62.1Site Location and Description . 62.2Site History . 62.3Nature and Extent of Contamination. 72.4Conceptual Site Model Summary . 82.52012 Feasibility Study . 82.6Anacostia Park Management Plan . 93.0 BASIS FOR REMEDIAL ACTION. 103.1Applicable or Relevant and Appropriate Requirements (ARARs) and Criteria to beConsidered (TBCs) . 103.2Remedial Action Objectives (RAOs) . 114.0 PRELIMINARY REMEDIAL GOALS (PRGS) . 124.1Scenario 1: Recreational Land Use (high frequency/high intensity). 134.2Scenario 2: Organized Sport and Recreation/Community Activities and Special Events(high frequency/moderate intensity) . 144.3Scenario 3: Natural Resource Recreation (moderate frequency/moderate intensity) . 144.4Scenario 4: Natural Resource Recreation (low frequency/low intensity) . 154.5Methane PRG . 154.6Unexploded Ordnance . 154.7Implications of PRGs . 154.7.1PRG Exceedances at KPN. 164.7.2PRG Exceedances at KPS . 175.0 DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES . 185.1Alternative 1: No Action . 185.2Alternative 2: Limited Action/Institutional Controls . 195.3Alternative 3: Containment/Selective Placement of Clean Soil Barriers & InstitutionalControls . 205.4Alternative 4: Containment/Site-wide Clean Soil Barrier & Institutional Controls . 215.5Alternative 5: Removal/Landfill Removal & Shoreline Stabilization . 216.0 DETAILED ANALYSIS OF ALTERNATIVES . 227.0 COMPARATIVE ANALYSIS OF ALTERNATIVES. 237.1Overall Protection of Human Health and the Environment . 247.2Compliance with ARARs and TBCs . 247.2.1Chemical-Specific ARARs and TBCs . 247.2.2Location-Specific ARARs and TBCs . 25Feasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 2020i
Final8.07.2.3Action-Specific ARARs and TBCs . 257.3Long-Term Effectiveness and Permanence . 257.4Reduction of Toxicity, Mobility, or Volume Through Treatment. 267.5Short-Term Effectiveness . 267.6Implementability . 267.7Cost . 27REFERENCES . 28TABLESTable 1Table 2Table 3Table 4Table 5Table 6Table 7Location-Specific Applicable or Relevant and Appropriate Requirements (ARARs) and ToBe Considered (TBC) CriteriaChemical-Specific Applicable or Relevant and Appropriate Requirements (ARARs) and ToBe Considered (TBC) CriteriaAction-Specific Applicable or Relevant and Appropriate Requirements (ARARs) and To BeConsidered (TBC) CriteriaPreliminary Remediation Goals (PRGs) for Target Risk Level of 1 x 10-6Preliminary Remediation Goals (PRGs) for Target Risk Level of 1 x 10-5Preliminary Remediation Goals (PRGs) for Target Risk Level of 1 x 10-4Detailed Analysis of Remedial AlternativesFIGURESFigure 1Figure 2Figure 3Figure 4Figure 5Figure 6Figure 7Figure 8Figure 9Figure 10Figure 11Figure 12Site Area MapSite PlanLand Use Management ZonesPRG Exceedances (1x10-6 Excess Cancer Risk) at Kenilworth Park NorthPRG Exceedances Relative to Land Use Management Zone (1x10-6 Excess Cancer Risk) atKenilworth Park NorthPRG Exceedances Relative to Land Use Management Zone (1x10-5 Excess Cancer Risk) atKenilworth Park NorthPRG Exceedances (1X10-6 Excess Cancer Risk) at Kenilworth Park SouthPRG Exceedances Relative to Land Use Management Zone (1x10-6 Excess Cancer Risk) atKenilworth Park SouthPRG Exceedances Relative to Land Use Management Zone (1x10-5 Excess Cancer Risk) atKenilworth Park SouthRemedial Alternative 3 – Selective Placement of Clean Soil BarriersRemedial Alternative 4 – Site-wide Clean Soil BarrierRemedial Alternative 5 – Landfill Removal & Shoreline StabilizationAPPENDICESAppendix AAppendix BMemorandum: Development of Risk Based Cleanup Levels for SoilDetailed Opinion of Costs & AssumptionsFeasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 2020ii
FinalLIST OF ABBREVIATIONS AND ACRONYMSARARapplicable or relevant and appropriate requirementsCERCLAComprehensive Environmental Response, Compensation, and Liability ActCFRCode of Federal RegulationsCOCchemical of concernDistrictDistrict of ColumbiaDOEEDistrict of Columbia Department of Energy & EnvironmentEPAU.S. Environmental Protection AgencyEPCexposure point concentrationFONSIfinding of no significant impactFSfeasibility studyISMincremental sampling methodologyJCOThe Johnson Company, Inc.KPNKenilworth Park NorthKPSKenilworth Park SouthLELlower explosive limitManagement Plan Anacostia Park Management Plan/Environmental AssessmentNACENational Capital Parks - EastNCPNational Oil and Hazardous Substances Pollution Contingency PlanNPSNational Park ServiceOUoperable unitPAHpolycyclic aromatic hydrocarbonPCBpolychlorinated biphenylPRGpreliminary remediation goalRAOremedial action objectiveRCRAResource Conservation and Recovery ActRODRecord of DecisionRIremedial investigationSACMSuperfund Accelerated Cleanup ModelSiteKenilworth Park Landfill SiteTBCto be consideredµg/dLmicrograms per deciliterU.S.C.United States CodeUXOunexploded ordnanceFeasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 2020iii
FEASIBILITY STUDY ADDENDUM REPORTFinalKenilworth Park Landfill SiteWashington, D.C.EXECUTIVE SUMMARYOn behalf of the National Park Service (NPS), VHB (formerly The Johnson Company, Inc. or JCO) preparedthis Feasibility Study (FS) Addendum Report for the Kenilworth Park Landfill Site (Site) located inWashington, D.C. (Figure 1). The Site is located along the eastern bank of the Anacostia River, withinAnacostia Park, a unit of NPS which is managed by National Capital Parks – East (NACE). It is subdividedinto two areas, Kenilworth Park North (KPN) and Kenilworth Park South (KPS).NPS is exercising its authority to address the Site pursuant to the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA) and the CERCLA response requirements provided inthe National Oil and Hazardous Substances Pollution Contingency Plan (NCP). NPS is the lead responseagency for the Site under CERCLA. This report is an addendum to the 2012 Feasibility Study (JCO, 2012)and incorporates additional data collected as part of the Remedial Investigation (RI) Addendum (JCO,2019).The RI and RI Addendum concluded that there is a potential for a long-term exposure risk associated withvisitor and park worker exposure to contaminants in surface soil and an unacceptable risk to excavationworkers associated with potential for exposure to contaminants in buried waste, methane gas, and thepossible presence of buried unexploded ordnance. Although these potential exposure risks are low, theyare unacceptable in the context of NPS’s responsibilities as a federal land manager and the Organic Act of1916. This FS Addendum evaluates alternatives to mitigate identified potential exposure risks.As described in more detail within this report, significant additional information was included in this FSAddendum that was not available for the 2012 FS evaluations, including: Newly collected groundwater data. The RI Addendum concluded that chemicals in groundwatermigrating from the Site pose no unacceptable human health or ecological risk; and Revisions to KPS management zoning. NPS established in the Anacostia Park ManagementPlan/Environmental Assessment (Management Plan; NPS, 2017) that KPS will be managed for“Natural Resources Recreation” and no active recreational facilities will be developed (e.g., sportsfields, playgrounds, picnic areas, etc.) in that area of Anacostia Park.Activities NPS completed as part of the FS Addendum include an updated analysis of applicable or relevantand appropriate requirements (ARARs); confirmation of the remedial action objectives (RAOs) andremedial technologies developed in the 2012 FS; and, refinement and detailed analysis of the alternativesusing updated information available since the 2012 FS was completed.The five remedial alternatives considered in the FS Addendum include: Alternative 1: No Action - Under the No Action alternative, which is required by the NCP and usedas a baseline for comparison to other alternatives, contaminated soils and landfill waste materialswould be left in place with no treatment or controls to prevent human or ecological exposure. Alternative 2: Limited Action/Institutional Controls - This alternative would employ the use ofinstitutional controls to restrict and/or manage future activities that might otherwise result inhealth risks or hazards.Feasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 20201
FinalFEASIBILITY STUDY ADDENDUM REPORTKenilworth Park Landfill SiteWashington, D.C. Alternative 3: Selective Placement of Clean Fill Barriers & Institutional Controls - To mitigate thepotentially unacceptable risk to Site visitors and workers under the anticipated future land-usescenario, Alternative 3 would involve placement of clean soil barriers in areas of the Site reservedfor Organized Sport and Recreation and Community Activities and Special Events (approximately60 acres). Official trails (e.g., the Anacostia Riverwalk Trail) would also be paved with asphalt orcovered with clean gravel. As with Alternative 2, Alternative 3 would employ the use ofinstitutional controls to restrict and/or manage future activities that might otherwise result inpotentially unacceptable health risks or hazards. Alternative 4: Site-wide Clean Soil Barrier & Institutional Controls - This alternative wouldinclude installation of a site wide (approximately 117 acres) soil barrier to prevent humanexposure to contaminated surface soils. As with Alternatives 2 and 3, Alternative 4 would employthe use of institutional controls to restrict and/or manage future activities that might otherwiseresult in potentially unacceptable health risks or hazards. Alternative 5: Landfill Removal & Shoreline Stabilization - Alternative 5 involves removal andoff-Site disposal of all waste materials and previously placed cover soils with re-establishment ofthe original grades and wetlands habitat that existed before the development of the landfills.The table below provides an overall summary of the detailed analysis for each alternative presented inSection 6 of this Report. Cells in the table are shaded red if a threshold criterion is not met, orange whennon-cost balancing criteria are not met, and green when non-cost criteria are met. Cost cells are shadedorange if the alternative does not comply with section 300.430(f)(1)(ii)(D) of the NCP that indicates aselected remedy must be “cost-effective,” which means that “its costs are proportional to its overalleffectiveness.”Evaluation ative4Alternative5Compliance with pliantLong-term effectiveness iveEffectiveReduction of toxicity, mobility,or volume through mplementableImplementableImplementable 15,000,000 18,000,000 610,000,000 620,000,000Overall protection of humanhealth and the environmentShort-term effectivenessImplementabilityNotProtectiveCapital Cost:NPW: 0 170,000Protective 86,000 400,000Protective 7, 500,000 9,000,000ProtectiveProtectiveThis detailed analysis provides a basis for NPS to select a preferred remedial alternative which will bedescribed in a Proposed Plan and made available for public review and comment. After consideration ofFeasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 20202
FEASIBILITY STUDY ADDENDUM REPORTFinalKenilworth Park Landfill SiteWashington, D.C.public comments, NPS will select a remedy to address the Site and will document the decision in a Recordof Decision (ROD).Feasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 20203
Final1.0 INTRODUCTIONOn behalf of the National Park Service (NPS), VHB (formerly The Johnson Company, Inc. or JCO) preparedthis Feasibility Study (FS) Addendum Report for the Kenilworth Park Landfill Site (Site) located inWashington, D.C. (Figure 1). This FS Addendum Report was prepared under JCO BPA ContractP16PA00039, Call Orders P17PB00373 and 140P2018F0053.The Site is located along the eastern bank of the Anacostia River within Anacostia Park, a national parkmanaged by the National Capital Parks – East (NACE) administrative unit of the National Park Service(NPS). As shown on Figures 1 and 2, the Site is subdivided into two areas, Kenilworth Park North (KPN)and Kenilworth Park South (KPS). NPS divided the Site into two Operable Units (OUs): OU1 consists ofsurface and subsurface soils, including waste material in the landfill, and OU2 consists of shallowgroundwater beneath OU1.This report presents the basis for developing and selecting remedial alternatives and the results ofdetailed analysis of each alternative using criteria established by the National Oil and HazardousSubstances Pollution Contingency Plan (NCP), the regulations developed to implement theComprehensive Environmental Response, Compensation, and Liability Act (CERCLA).This report is an addendum to the 2012 Feasibility Study (JCO, 2012) and incorporates additional datacollected as part of the Remedial Investigation (RI) Addendum (JCO, 2019). As described in more detailwithin this report, significant additional information was included in this FS Addendum that was notavailable for the 2012 FS evaluations, including: Newly collected groundwater data. The RI Addendum concluded that chemicals in groundwatermigrating from the Site pose no unacceptable human health or ecological risk; and Revisions to KPS management zoning. NPS established in the Anacostia Park Management PlanEnvironmental Assessment (Management Plan) (NPS 2017) that KPS will be managed as a “NaturalResources Recreation” area, and NPS does not envision developing any active recreationalfacilities in that area of Anacostia Park.The 2012 FS was developed specifically to address contamination within OU1 with the understanding thata further response action may be required to address contamination in OU2. Based on the RI Addendumfindings, NPS determined that no further response actions are required for OU2; therefore, this FS onlyconsiders response activities for OU1.1.1 NPS CERCLA AuthorityNPS is authorized under CERCLA, 42 U.S.C. §§ 9601 et seq., to investigate and otherwise respond to therelease or threatened release of hazardous substances on or from land under the jurisdiction, custody, orcontrol of NPS. This FS Addendum Report was prepared in general accordance with the United StatesEnvironmental Protection Agency’s (EPA) Guidance for Conducting Remedial Investigations and FeasibilityStudies Under CERCLA (EPA, 1988).CERCLA’s implementing regulations, codified in the NCP, 40 Code of Federal Regulations (CFR) Part 300,establish the framework for responding to hazardous substance releases and threatened releases. TheNCP outlines two general processes for responding to releases: a removal action process (including bothtime-critical and non-time-critical removal actions) and a remedial action process (see NCP SectionsFeasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 20204
Final300.400 through 300.440). NPS is following the remedial action process at the Kenilworth Park LandfillSite. Under the remedial action process, an RI/FS is performed to characterize the nature and extent ofcontamination and evaluate remedial alternatives to protect the public health or welfare or theenvironment from risks posed by the release or threatened release (see NCP Section 300.430).1.2 PurposeThe purpose of this FS Addendum is to develop, screen, and analyze potential remedial alternatives thataddress contamination identified at the Site that is considered to be present at an unacceptable level ofrisk to human health or the environment. The FS Addendum process included: an updated analysis ofapplicable or relevant and appropriate requirements (ARARs); confirmation of the RAOs and remedialtechnologies; and refinement and detailed analysis of the alternatives.The primary objective of the FS is to develop appropriate remedial alternatives and evaluate thesealternatives such that relevant information concerning the remedial action options can be presented to adecision-maker and an appropriate remedy selected. This FS Addendum provides a basis for NPS to selecta preferred remedial alternative, which will be described in a Proposed Plan and made available for publicreview and comment. After consideration of public comments, NPS will select a remedial action to addressthe Site and will document the decision in a Record of Decision (ROD).1.3 Report OrganizationThe remainder of this report is organized by the following sections. Background: this section describes the site location and land use history. It summarizes the natureand extent of contamination and the conceptual site model as identified through the RI activitiesand summarized in the RI Addendum Report (JCO, 2019). Relevant documents that are alsodescribed in this section include the 2012 OU1 FS Report (JCO, 2012), to which this report is anaddendum, and the Management Plan (NPS, 2017), which defines the current and anticipatedfuture use of the park. Basis for Remediation: this section includes an analysis of ARARs and criteria to be considered(TBC) in the development and evaluation of alternatives. Remedial action objectives are definedin this section. Preliminary Remedial Goals (PRGs): this section defines the PRGs, which vary across the sitebased on the anticipated future land use and the potential for associated visitor and workerexposure risks. The PRGs also address potential risks associated with excavation that could berelated to future construction or installation of utilities. PRG exceedances are evaluated for bothKPS and KPN. Development and Screening of Alternatives: this section describes the five alternatives that wereconsidered as part of this FS Addendum and the basis for selecting them. Detailed Analysis of Alternatives: this section includes an analysis of each alternative using theseven threshold and balancing criteria established in the NCP. Comparative Analysis of Alternatives: this section summarizes the findings of the detailedanalysis relative to each alternative with respect to the threshold and balancing criteria.Feasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 20205
Final2.0 BACKGROUNDThis section provides a summary of the information used to support the development and analysis ofalternatives. A detailed discussion of the prior investigation activities, and the identified nature and extentof contamination, is provided in the RI Addendum Report (JCO, 2019).2.1 Site Location and DescriptionThe Site is located within Anacostia Park, a unit of NPS managed by NACE in Washington, District ofColumbia (District) (Figure 1). Access to KPN is from Deane Avenue NE near the intersection with LeeStreet NE. Access to KPS is either from the Deane Avenue extension within KPN (currently blocked byjersey barriers) or via the Anacostia Riverwalk Trail with access at the intersection of Foote Place NE andFoote Street NE.The Site consists of two closed landfills (KPN and KPS) separated by Watts Branch, a tributary of theAnacostia River. The Site occupies approximately 130 acres (KPN is approximately 80 acres and KPS isabout 50 acres). As shown on Figure 2, the Anacostia River flows along the western boundary of both KPNand KPS. Kenilworth Marsh is located to the north of KPN and Watts Branch flows along the southernboundary of KPN and provides the boundary between KPN and KPS. An unnamed tributary to WattsBranch runs along the east side of KPS. The Site is bordered by residential neighborhoods to the east. TheThomas Elementary School and Educare of Washington, DC (CDC Child Development Center) are locatedabout 300 feet southeast of KPS. The Benning Road solid waste transfer station is located to the south ofKPS.KPN consists of grassy open space with buffers or transition zones of trees and shrubs along riparian ormarsh boundaries. A large portion of KPN is maintained for public recreation (e.g., soccer fields, a footballfield, tennis courts, and a running track). In 2016, the District Department of Transportation completedan extension of the asphalt-paved Anacostia Riverwalk Trail over a portion of KPN.KPS consists of an open field with well-established grass cover and shrubs, and areas that are more denselyvegetated with shrubs and trees. Although KPS is administratively closed, the asphalt paved extension ofDeane Avenue NE is often used by the public for walking and biking. KPS is also visited by birders wholikely explore off-trail areas.2.2 Site HistoryPrior to its initial development as a landfill in 1942, the Site consisted of several recreational lakes thathad been excavated within the tidal mud flats by the United States Army Corps of Engineers in the 1930s.The landfill was operated by the District as a burning dump and a landfill for District incinerator ash from1942 until 1968. In 1968 the District discontinued the open burning practice but continued co-disposal ofraw waste and incinerator ash until 1970 when the landfill was closed. The closure activities includedplacement of soil fill over the waste and grading to promote runoff toward the perimeter surface waterbodies (Kenilworth Marsh, the Anacostia River, Watts Branch and the unnamed tributary to WattsBranch). Based on soil borings completed during the RI activities, the soil cover thickness generally rangesfrom approximately 2 to 7 feet but may be as thick as 15 feet in some areas of the Site. The soil coverappears to consist predominantly of fine-grained silt and clay, which limits the potential for rainwater andsnow melt infiltration. Following closure, the Site was developed for recreational purposes with runningtracks, sports fields and picnic areas.Feasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 20206
FinalIn the late 1990s, NPS developed a plan to raise the elevation of KPS and develop additional sports fields.Soil and demolition debris were placed over portions of KPS but the effort was discontinued before thefinal grades were reached, and the sports fields were never constructed. In the early 2000s NPS removeddemolition debris from the surface of KPS, improved the surface drainage by creating a series of stormwater ditches and berms, and seeded the area to establish the vegetative cover that is present today.Beginning in 1998 there have been multiple, increasingly more detailed, investigations of the Siteculminating in RI reports prepared in 2007 (KPN; E&E, 2007) and 2008 (KPS; E&E, 2008) and then in the RIAddendum Report prepared in 2019 (JCO, 2019). The RI Addendum Report includes summaries of eachinvestigation completed since 1998.2.3 Nature and Extent of ContaminationThe nature and extent of contamination at the Site was established in the 2007 and 2008 RIs, and the2010 Supplemental Data Collection Report (published as Appendix A to the 2012 FS report; JCO, 2012).The subsequent groundwater, porewater, seep water, and surface soil assessments completed as part ofthe RI Addendum filled data gaps and allowed for a refinement of the conceptual site model. The RIAddendum findings confirmed prior conclusions related to potential human health exposure to surfacesoil and ecological risk associated with groundwater migration.The inferred landfill boundaries shown on Figure 2 are based on a geophysical (EM-34) survey completedin 2006 supplemented with the review of historical aerial photographs and topography. The limits wereestablished as part of the 2007/2008 RIs. As shown, the inferred limits of waste for KPS and KPN extendup to and along the Anacostia Riverbank. There are three locations identified from the historical aerialphotographs where waste may have been disposed below the water line along the bank of the river andperimeter of Kenilworth Marsh. These areas were former inlets to the recreational lakes that wereexcavated by the US Army Corps of Engineers in the 1930s. Based on the results of the risk assessmentcompleted as part of the RI Addendum, using the expanded groundwater data set, there is no evidencethat buried waste at the landfill, or groundwater migrating from the buried waste, is causing anunacceptable risk to human health or the environment.Certain polychlorinated biphenyl (PCB) Aroclors, dieldrin, certain polycyclic aromatic hydrocarbons (PAHs)and metals are present in surface soil at both KPN and KPS. There is no distinct pattern of distribution thatwould indicate an on-site spill or release. Some of these chemicals are widespread in the environmentdue to atmospheric fallout from air pollution; however, analysis presented in the RI Addendum Reportindicates these chemicals are present at concentrations that are above off-site reference levels (E&E,2007; E&E, 2008). These chemicals were likely present in the soil fill used to cover the landfill. Some levelof surface soil contamination may also be due to atmospheric deposition (e.g., car exhaust, power plantsmokestacks, etc.). Based on the conservative recreational exposure scenarios established for the 2007and 2008 RIs, the potential risk associated with human exposure to these chemicals is greater than theNCP point of departure (excess cancer risk of 1 x 10-6).Prolonged worker exposure to buried soil and waste that contains lead could also cause adverse healtheffects associated with elevated blood lead levels if protective measures (engineering controls and/orpersonal protective equipment) are not taken by the workers. Excavation within the former landfill areasalso requires precautions to be taken due to the potential presence of methane gas (generated duringwaste decomposition) and potentially buried unexploded ordnance.Feasibility Study Addendum ReportKenilworth Park Landfill SiteSeptember 20207
Final2.4 Conceptual Site Model SummaryRefer to the RI Addendum Report (JCO,
Sep 21, 2020 · NACE National Capital Parks - East . NCP National Oil and Hazardous Substances Pollution Contingency Plan . off-Site disposal of all waste materials and previously placed cover soils with re-establishment of . Compliant . Not : Compliant . Compliant : Compliant . Compliant : Long-term eff
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