Spring Valley Formerly Used Defense Site 7.) What has the Army spent thus far? What is the cost of sampling each of the 1,200 properties? How much is budgeted for sampling and remediation? Through the end of fiscal year 2001, the Army will have spent approximately $50 Million for investigations and response actions at the Spring Valley site. Under the Army's current sampling plan for all 1,200 residential properties and 400 non-residential lots located within the Spring Valley formerly used defense site, the first round of sampling is called "composite sampling." The purpose of this sampling is to serve as a screening tool to identify which properties may have contamination and may require additional investigation. Composite sampling involves subdividing the property into 2 to 4 smaller units, and within each unit we collect surface soil samples from several locations and mix them together. Each of these mixtures is analyzed for arsenic, so that there is a separate result for each of the sub-units on the property. The resulting arsenic concentration represents an "average" value for that sub-unit. Based on our knowledge of historical activities at each property (including aerial photography and historical records), we may also take subsurface samples, and we may analyze for other contaminants in addition to arsenic. The average cost per property for the composite sampling is $2,100.00. If the analysis results from the composite sampling finds an arsenic concentration less or equal to 12.6 parts per million, then our sampling plan indicates that no further action is necessary. If the analysis results find an arsenic concentration that is greater than 12.6 parts per million, then a second round of sampling is performed, called "grid sampling." Grid sampling involves laying out an imaginary grid over the entire property, 20 feet by 20 feet, and taking a discrete soil sample from within each grid. These samples are not mixed together; rather, each discrete sample is analyzed separately. Thus, each property ends up with approximately 50 individual sample results (depending on the size of the property) which can be used to conduct a human health risk assessment. If this risk assessment finds an unacceptable risk, then the Army will recommend that it be allowed to remediate the property. The average cost per property for the grid sampling is $10,000.00. Please note that the above costs are averages. Actual costs at individual properties may be higher or lower depending on the property size, the need for subsurface sampling, and the need to analyze for contaminants other than arsenic. The Army has programmed $34 Million to complete investigation and response activities at this site. Spring Valley Formerly Used Defense Site 8.) What action do you contemplate taking if you do not obtain the requisite number of properties to be sampled to ensure that your analysis and conclusions regarding how safe the area is? The nature of the former use of the Spring Valley area distinguishes it from the pattern of contamination more usually encountered in the environmental cleanup arena. The more usual pattern resulted from spills or releases from particular point sources, and the resulting contamination is more likely to be in the form of a plume or some other continuous area. At Spring Valley, the Corps has found a few discrete small burial areas containing munitions or chemical contamination. In addition, multiple pieces of ordnance scrap have been recovered throughout the site. The Corps has also found elevated levels of arsenic in the soil surrounding the burial areas. Arsenic was used at the site by the Army, and is also a chemical agent breakdown product. The Corps has found arsenic at various concentrations at other discrete areas in Spring Valley, as well. There is no discernible pattern to the location of these elevated-concentration areas, perhaps because Spring Valley has been heavily developed since 1920 when the Army left the site and the soils have been moved around extensively. As a result of the random location of the contamination, each investigative sample carries unique significance. One cannot assume that because no elevated levels of arsenic are found in soil on one property, the same will be true just across that property line. The current investigative plan for Spring Valley is to sample every property within the formerly used defense site boundary (approximately 1,200 residential properties, plus approximately 400 non-residential lots). Prior to sampling a property we must obtain a right-of-entry (ROE) from the property owner. As of August 27, 2001, we have obtained 917 ROEs or approximately 76% of the total properties. Based on the arsenic sampling results received through August 20, 2001, approximately 12% of the properties sampled have results that exceed our soil screening level (SSL) of 12.6 ppm. This means that these properties will require follow-on action, which will include grid sampling, risk assessments, and perhaps soil removals if necessary. Based on the current trend, if we did not receive any more ROES, there would be a potential for 30 to 40 properties out of 1,200 (about 3%) that do not get sampled that could have arsenic levels above our SSL. Since our pursuit of additional ROEs is ongoing and productive, this percentage will continue to be reduced. Therefore, it can be concluded that the overall sampling effort will be highly successful in identifying and addressing arsenic and other specific chemicals at the site. When we reach the point where no additional ROEs can be obtained by voluntary means, we will assess whether sampling at the remaining properties seems necessary for completion of the remediation of Spring Valley. If deemed necessary, we may seek to compel access to some or all of the remaining properties. Although used in only extreme cases, CERCLA grants the government authority to compel access to a property "where any hazardous substance or pollutant or Spring Valley Formerly Used Defense Site contaminant may be or has been generated, stored, treated, disposed of, or transported from... [or] from which or to which a hazardous substance or pollutant or contaminant has been or may have been released... [or] where such release is or may be threatened... [or] to determine the need for response or the appropriate response or to effectuate a response action...." When munitions are involved, the Corps may ask the Attorney General of the U.S. to compel access, if appropriate. If other types of contamination are involved, the Corps would notify the Environmental Protection Agency, the District of Columbia Health Department, and the local government agency responsible for safety. One or more of these agencies may decide whether to compel access. 1 - QUESTION = You are a citizen representative but you work for the EPA - please explain your position and responsibilities at the EPA. ANSWER = As I said in my response to the selection committee of the Restoration Advisory Board, I am and have been an employee of the US EPA here at Headquarters in Washington, DC. My relevant experience there has included being Liaison with the chemical industry for the Toxic Substances Control Act and being the signatory authority for the US EPA for the Consent Decree implementing the assessment and clean-up activities required of the Texas Eastern Natural Gas Pipeline Company. I currently serve in a staff role for the Director of the Office of Pollution Prevention and Toxics to establish an historical function as a model for the office and the agency. I volunteered for the Board and expressed a willingness to serve as it Co-chairman because of my civic interests. 2- QUESTION FROM WHOM DID YOU PURCHASE YOUR HOME? DID THE SELLER PROVIDE ANY DISCLOSURE THAT THE PROPERTY MAY CONTAIN HAZARDOUS MATERIALS? ANSWER = My home, located at 4710 Upton Street, NW, was built in 1935. When I purchased it in 1995, both the seller and myself, the buyer, were represented by real estate agents from the Spring Valley office of WC & AN Miller. There was no disclosure to me concerning any history of contamination or the historical activity in the area of the American University Experimental Station. 3- QUESTION = DO YOU KNOW OF ANY INSTANCES WHERE THE GOVERNMENT HAS PROVIDED WARRANTIES FOR THE WORK THAT IT HAS PERFORMED, ESPECIALLY WHEN THE WORK HAS INVOLVED REMEDIATION OF CONTAMINATED SOIL? ANSWER = No, I know of no such warranties, in my capacity as a private citizen and my experience with the US EPA has not involved any reason to know of such a practice or policy. 4- QUESTION = ARE YOU SATISFIED WITH THE JOB BEING DONE BY THE ARMY CORPS OF ENGINEERS? ARE YOU SATISFIED WITH THE JOB BEING DONE BY THE ANSWER = Yes, I am myself satisfied that the Corps is complying with ours as it is theirs. The community members do intend to use the. mechanism afforded by the federal government of Technical Assistance for Public Participation (TAPP) to obtain independent advice. Sarah Stowell Shapley Community Co-Chair, Spring Valley Restoration Advisory Board 4710 Upton Street, NW Washington, DC 20016-2370 202-Adams7-7530 |