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PUBLIC HEALTH ASSESSMENT

NAVAL WEAPONS STATION YORKTOWN, CHEATHAM ANNEX
WILLIAMSBURG, YORK COUNTY, VA
CERCLIS NO. VA3170024605


Evaluation of Environmental Contamination and Potential Exposure Situations

Introduction

During a public health evaluation, ATSDR evaluates whether people are coming in contact with environmental contaminants released at the base and, if so, whether or not the exposure could affect the health of on-base residents or visitors, or the neighboring community. Figure 4 provides an overview of ATSDR's exposure evaluation process, which is described in more detail below. Appendix C defines some of the technical terms used in this PHA.

What is meant by exposure?

ATSDR's PHAs are driven by evaluation of the potential for human exposure, or contact with environmental contaminants. Chemical contaminants released into the environment have the potential to cause adverse health effects. However, a release does not always result in human exposure. People can only be exposed to a contaminant if they come in contact with it-if they breathe, eat, drink, or come into skin contact with a substance containing the contaminant.

How does ATSDR evaluate whether exposures are harmful?

ATSDR evaluates the conditions at each on-base site where contaminants have been identified in the environment to determine if people could have been, are, or could be exposed (i.e., past, current, or future exposures) to contaminants at levels that could cause adverse health effects. If exposure is possible, ATSDR further evaluates the site by comparing the concentration of the contaminants measured in the environment to health-based comparison values (CVs).

CVs are developed by ATSDR from scientific literature related to potential health effects from exposure to a contaminant. A significant amount of toxicological and epidemiological information is available for most of the contaminants commonly found at military bases. As a result, a specific CV has been developed for the majority of those contaminants. CVs are derived for each of the different media and reflect an estimated contaminant concentration that is not expected to cause adverse health effects for a given chemical, assuming a standard daily contact rate (e.g., an amount of water or soil consumed or an amount of air breathed) and body weight.

CVs are not thresholds for adverse health effects. ATSDR CVs establish contaminant concentrations that are many times lower than levels at which no effects were observed in experimental animals or human epidemiologic studies. If contaminant concentrations are above CVs, ATSDR further analyzes the exposure variables to evaluate if adverse health effects are, or are not, expected to occur. The primary exposure variables include the duration and frequency of exposure, the toxicology of the contaminant, and results of epidemiology studies.
If someone is exposed, will they get sick?

Exposure does not always result in harmful health effects. The type and severity of health effects a person can experience because of contact with a contaminant depend on the exposure concentration (how much), the frequency and/or duration of exposure (how long), the route or pathway of exposure (breathing, eating, drinking, or skin contact), and the toxicity of the contaminant. Once an exposure occurs, characteristics such as age, sex, nutritional status, genetics, lifestyle, and health status of the exposed individual influence how the individual absorbs, distributes, metabolizes, and excretes the contaminant. Together, these factors and characteristics determine the possible health effects that may occur.


Some of the CVs used by ATSDR include ATSDR's environmental media evaluation guides (EMEGs), reference dose media evaluation guides (RMEGs), and cancer risk evaluation guides (CREGs) and EPA's maximum contaminant levels (MCLs). MCLs are enforceable drinking water regulations developed to protect public health. CREGs, EMEGs, and RMEGs are non-enforceable, health-based CVs developed by ATSDR for screening environmental contamination for further evaluation. Appendix D provides an overview of the CVs that ATSDR used in evaluating site environmental data.

In almost any situation, there is considerable uncertainty about the true level of exposure to environmental contamination. To account for this uncertainty and to be protective of public health, ATSDR typically uses reasonable exposure level estimates as the basis for determining whether adverse health effects are possible. These estimated exposure levels are often much higher than the levels that people are really exposed to. If the exposure levels indicate that adverse health effects are possible, ATSDR performs a more detailed review of exposure, also consulting the toxicologic and epidemiologic literature for scientific information about the health effects from exposure to hazardous substances. What potential exposure situations were evaluated for Cheatham Annex?

ATSDR identified the following five potential exposure situations at and near CAX for in-depth evaluation and discussion: Table 1 provides a summary of all potential exposure situations evaluated by ATSDR. Information about IRP sites and AOCs at CAX, along with our evaluations of potential exposures, is summarized in Table 2. Even though soil is contaminated in some locations, Navy families and the public are not exposed to soil contaminants at levels that could cause health effects. Sites that have, or had, higher levels of soil contamination are located inside fenced areas or remote areas of the base. As a result, residents and visitors have had only limited contact with the contaminated soil. ATSDR expects that EPA and VDEQ oversight of remedial actions at those sites will eliminate the potential for people to come into contact with soil contaminants at levels of potential concern in the future, if access constraints are modified in such a way as to allow unrestricted access. There is no exposure to contaminated groundwater, as it is not used for on-base drinking water. While some off-base private drinking water wells may exist, those wells are not expected to be affected by contaminant detected in the groundwater at CAX. Exposures to seafood from water bodies that extend beyond the boundaries of CAX (and those in other local communities) are discussed in the "Community Health Concerns" section of this document, as well as in an associated appendix.

ATSDR did not identify any current sources of air emissions at CAX. Limited information indicates an incinerator did operate between 1942 and 1951. However, it is not known if it operated between 1951 and 1990, when it was dismantled, what it burned, or how often it was used. The nearest family housing area that is still in use was over 1 mile away. Locations of additional family housing areas that may have existed in the past are not known. Given these data gaps and the fact that there are no records on incinerator emissions, ATSDR cannot evaluate whether people could have been affected by possible past releases. Emissions usually disperse quickly, and any exposures would likely have been intermittent and reduced with distance from the source.

Potential Exposure to Contaminants in Drinking Water

Jones Pond was the source of on-base drinking water from the 1940s through 2002. Currently, CAX receives its drinking water from the City of Newport News. This section reviews information about past waste disposal practices near Jones Pond because contaminants released at those disposal sites may have affected the water quality of Jones Pond. This section does not discuss groundwater contamination at CAX because the Navy did not use groundwater for drinking water and the existing off-base private drinking water wells are not expected be affected by groundwater contamination from CAX.

Background

The Cheatham Annex Water Supply

The Cheatham Annex water supply system was established in the early 1940s. Water was drawn from Jones Pond. Historical documents indicate that CAX filtered water it distributed at least as early as 1961 (PWC Regional Environmental Group 2003b). There is little or no other information available about filtration, treatment, and sampling conducted at CAX prior to the 1960s, when safe drinking water requirements went into effect. The original CAX treatment plant was replaced by a new water treatment plant around 1990 (PWC Regional Environmental Group 2003b). CAX complied with all SDWA and VDH requirements, including sampling treated water prior to distribution.
What were the requirements for treating and testing drinking water in the past?

Water supply systems are required to treat and sample water under the Safe Drinking Water Act (SDWA), passed in 1974 and amended in 1986 and 1996. The U.S. Public Health Service had published recommended drinking water standards beginning in 1914, when the standards addressed only bacteriological contaminants. The standards were revised and expanded in 1925, 1942, and 1962, at which time they addressed 28 potential types of contamination. The 1962 standards, adopted in some form by all of the states, were later superceded by SDWA requirements (EPA 1999c). The CAX water supply complied with all SDWA and Virginia Department of Health requirements.


ATSDR reviewed available records about sampling conducted at the CAX water treatment plant. However no information was available for sampling conducted prior to the 1990s. According to EPA records and VDH, levels of chemical contaminants measured in post-treatment samples from the CAX water treatment plant have consistently been below regulatory limits for the past approximately 10 years (EPA n.d.a.; D. Tucker, 2003). As of 2002, samples of water treated by the CAX treatment plant (i.e., post-treatment samples) were analyzed for metals annually, for volatile organic compounds (VOCs) every three years, for radiological contaminants every four years, and for cyanide every nine years. In prior years, through the 1990s, samples were also analyzed periodically for synthetic organic contaminants (SOCs). These SOCs included pesticides, polychlorinated biphenyls (PCBs), dioxin, and a few volatile and semi-volatile organic compounds. During that time SOCs were only detected at low concentrations (Tucker 2003; EPA 2002).

In 2002, CAX started using the Newport News water supply as its source of drinking water (PWC Regional Environmental Group 2003a). The Navy is still responsible for distributing the water throughout Cheatham Annex and performing some monitoring, such as sampling for disinfection byproducts and bacteriological contamination (Tucker 2003).

Studies of Contaminants Potentially Affecting Jones Pond

The Navy identified two historical disposal areas (Site 12 and AOC 1) in the southwestern portion of CAX that could be sources of contamination affecting Jones Pond. While the Virginia Fuel Farm is also located west of AOC 1 and Site 12 (across Route 641), EPA reports that groundwater contamination from the Fuel Farm does not extend beyond the boundaries of the Fuel Farm (EPA 1999a, b). The IAS indicated that Site 12, within approximately 300 feet of a tributary to Jones Pond, was used at one time for surface disposal of scrap metal, including automobile parts and iron pipe. The metal debris are no longer present and may have been moved to an off-site disposal area or to AOC 1. AOC 1 is approximately 1,000 feet from Jones Pond and was identified in 1998 following site visits by the Navy, EPA, and VDEQ. Aerial photographs from 1942 and 1963 indicate activity in the area (CH2M Hill 2000). Some of this waste dates to the Penniman era (Weston 1999a). However, no documentation was identified that described historical disposal practices for this site. The partially buried debris includes drums, metal objects, wood, gas cylinders, and construction debris. AOC 1 is located within two neighboring ravines that ultimately empty into Jones Pond.

ATSDR identified three sampling events for Jones Pond and its tributaries, two in 1999 and one in 2000 (CH2M Hill and Baker 2000a; Weston 1999b; CH2M Hill and Baker 2003a). Low concentrations of nitroaromatics (specifically TNT and 4-amino-2,6-dinitrotoluene) were intermittently detected in the surface water and sediment at concentrations below CVs. Two other organic compounds and three metals were also intermittently detected in the surface water samples. Details about these sampling events and their results are presented below.
Nitroaromatics are organic chemicals at least one nitro group (-NO2) bonded to one or more carbons in a benzene ring. They are present in some pesticides, herbicides, industrial chemicals and explosives. The presence of TNT with the other nitroaromatics suggests they may be the result of previous Penniman activities.
The results of these three sampling events (Table 3) represent only a snapshot (in space and time) of the water and sediment conditions at and near Jones Pond, but provide some insights regarding what might be in or carried to Jones Pond and supplements the sampling data collected under the SDWA.

Nitroaromatics
Nitroaromatics were not measured as a part of the sampling for the SDWA. Reported levels of nitroaromatics in Jones Pond and its tributaries (surface water and sediment) obtained during the environmental investigations were generally low. Almost all of the nitroaromatics were detected at concentrations below ATSDR CVs. Cyclotrimethylenetrinitramine (RDX) was detected in one surface water sample; TNT and 4-amino-2,6-dinitrotoluene were detected in one and two sediment samples, respectively. These sampling results are summarized in the following tables. The actual presence or representativeness of nitroaromatics in the samples is uncertain in some cases. Based on sampling documentation, some of the reported contamination might have been introduced during sampling procedures or laboratory analysis. Therefore, ATSDR cannot draw firm conclusions about exposures or health implications based on these samples alone.

Other organics (VOCs, SVOCs, pesticides, and PCBs)
Only two non-nitroaromatic organic compounds were measured in surface water samples at concentrations exceeding CVs. Bis(2-ethylhexyl)phthalate was detected at levels up to 98 ppb in a tributary sample exceeding its CV (4.8 ppb), but was detected at concentrations below the CV in surface water from Jones Pond (CH2M Hill and Baker 2003a). All concentrations of bis(2-ethylhexyl)phthalate in sediment samples were below CVs.

Surface water sampling results for nitroaromatics from Jones Pond and tributaries
Sample Location Sampling Event Number of Samples Concentration of Nitroaromatics Detected in Surface Water (ppb) CVs of Nitroaromatics in Drinking Water (ppb)
Jones Pond Pond Study 1 RDX, 0.11B 0.3
Tributaries Penniman SI 3 None detected  
B: Indicates that the sample was also detected in either a field or laboratory blank. RDX detected in the sample was slightly lower than the concentration measured in the blanks (0.17 ppb and 0.21 ppb RDX).
CV: comparison value
ppb: parts per billion


Sediment sampling results for nitroaromatics from Jones Pond and tributaries
Sample Location Sampling Event Number of Samples Concentration of Nitroaromatics Detected in Sediment (ppb) CVs of Nitroaromatics in Soil (ppb)
Jones Pond Penniman SI 1 None detected  
Jones Pond Pond Study 1 4-amino-2,6,-dinitrotoluene, 0.095 16
Tributaries Penniman SI 1 TNT, 0.25 4-amino-2,6-dinitrotoluene, 11B 20
16
Tributaries SI of AOC 1 4 None detected  
For comparison, detected levels of nitroaromatics in sediment samples from the other three on-site ponds were similar. TNT and its breakdown products were detected at levels below 0.1 ppm in samples collected from Youth Pond and Cheatham Pond and at levels ranging from approximately 0.1 to 2 ppm in Penniman Lake (CH2M Hill and Baker 2000a).
B: Indicates that the sample was also detected in either a field or laboratory blank.
CV: comparison value
ppm: parts per million


During EPA's 1999 investigation, heptachlor was measured in a Jones Pond surface water samples at a maximum concentration (0.012 ppb) slightly exceeding its CV (0.008 ppb). In a duplicate sample collected from the same location, a concentration of 0.008 ppb was measured. However, the validity of the detection is not known due to possible blank contamination (Weston 1999b). Heptachlor was not measured in the only other surface water sample from Jones Pond, collected as part of the Pond Study.

Metals
Metals were not detected in the surface water of the tributaries or Jones Pond at concentrations above ATSDR's CV. Arsenic was detected in the sediment of Jones Pond at maximum concentration of 5.6 ppm exceeding the ATSDR CV for soil (0.5 ppm).

Discussion

A trace concentration of one nitroaromatic compound (RDX) was measured in the only available surface water sample from Jones Pond, at a concentration below the CV. Even regular exposure to the detected concentration would not have caused adverse health effects. Furthermore, the RDX detected in the sample may have been accidentally introduced during the sampling process, and may not be the result of RDX in Jones Pond. No nitroaromatics were detected in three surface water samples from the tributary. However, nitroaromatics were measured in some of the sediment samples from Jones Pond and a tributary. The concentrations were generally low and below levels of health concern. The nitroaromatics could have been introduced by Penniman-era waste left at AOC 1, and further investigation at that site is planned.

Before 1999, none of the surface water samples from Jones Pond were analyzed for nitroaromatics; including samples collected at the CAX water treatment plant in accordance with SDWA requirements. Given that sources of nitroaromatics may date back to the Penniman era, it is possible that the past concentrations could have been higher or lower than those reported in the previous tables. As a result, ATSDR cannot assess whether past exposure to nitroaromatics in drinking water from Jones Pond could have posed a health concern.

Bis(2-ethylhexyl)phthalate was only measured at levels exceeding CVs in samples from a tributary to Jones Pond, not in samples from the pond itself. Heptachlor was detected in one surface water sample from Jones Pond, but may have been introduced into the sample during sampling or analysis. The detected concentration only slightly exceeded the CV. Even regular exposure to drinking water containing the detected concentration would not be expected to cause any adverse health effects. Both bis(2-ethylhexyl)phthalate and heptachlor are SOCs regulated by the SDWA. Post-treatment samples were analyzed periodically at the CAX water treatment plant to ensure that concentrations were below SDWA standards. Since CAX water consistently met SDWA standards, past exposure to bis(2-ethylhexyl)phthalate and heptachlor were below levels known to cause health effects.

In 2002, the Navy stopped treating and distributing the water from Jones Pond and connected to the Newport News municipal water supply system. The Navy continues to operate the on-base drinking water distribution network. There is no current or future exposure to drinking water from Jones Pond. The Newport News municipal water supply system draws on water sources outside of Williamsburg, several miles away and unaffected by CAX or Penniman activities.

Potential Exposure to Contaminants in Surface Water, Sediment, and Fish at On-Site Lakes and Ponds

Background

The four major on-site lakes and ponds within CAX are open for boating and fishing. Until 2000, people were allowed to eat fish they caught from all these water bodies. In 2000, the Navy collected and analyzed surface water and sediment samples from all four water-bodies. Based on those results, the Navy now prohibits the consumption of fish caught in Youth Pond or Penniman Lake. This precautionary measure was based on the elevated levels of PCBs measured in sediment samples from those two water bodies. Surface water and sediment sampling results from Jones Pond and Cheatham Pond indicate that PCB concentrations there are below levels expected to affect fish or fish consumers, therefore fish consumption from these ponds is still permitted. The Navy has collected some surface water and sediment samples, however fish tissue samples have not been collected from any of the lakes or ponds (Harlow 2003; Bridges 2003). Consumption of seafood from water bodies that extend beyond the boundaries of CAX is discussed later in this PHA.

A 1994 fish population study by the U.S. Fish and Wildlife Service for Jones Pond, Cheatham Pond, and Penniman Lake concluded that all three had "reasonably healthy" sportfish populations. All three water bodies contained largemouth bass, bluegill, American eel, and a few types of forage fish. Some of them also contained redear sunfish, pumpkinseed, and black crappie. The Fish and Wildlife Service noted that striped bass and striped bass hybrids had historically been stocked in Cheatham Pond, but were not found during the fish population study (Swihart and Daniel 1999).

Swimming in all three ponds and Penniman Lake has always been prohibited. Signs to this effect are posted (Hill 2004). As a protective measure, ATSDR evaluated exposures to Navy personnel and their families that would occur if people accidentally consumed surface water or sediment from any of the four water bodies while boating in, fishing at, or otherwise using any of the four water bodies.

Various IRP sites, AOCs, and/or areas thought to have been used for shell loading or related activities during the time the Penniman plant operated are located near each of the on-base water bodies. For perspective on potential exposures to recreational users of the lakes and ponds, ATSDR reviewed information about their potential sources of contamination. In order to assess possible exposures, ATSDR reviewed surface water and sediment samples from the Pond Study and other documents provided by the Navy and EPA. The Navy collected surface water and sediment samples from Penniman Lake during its confirmation investigations in 1986 and 1987 and in 1992 as part of preparing a site screening process report for Sites 1, 10 and 11 (Baker 1997; Dames & Moore 1998). These samples were analyzed for selected VOCs, SVOCs, and metals. Samples collected during the Pond Study in 2000 were analyzed for VOCs, SVOCs, pesticides, PCBs, metals, and nitroaromatics. EPA sampled surface water and sediment in Jones Pond, Cheatham Pond, and Penniman Lake in 1999 (Weston 1999b). Sediment samples were analyzed for the same compounds as the Navy's 2000 samples. Surface water samples were analyzed for the same parameters, with the exception of nitroaromatics.

Tables 3, 4, 5, and 6, address Jones Pond, Cheatham Pond, Youth Pond, and Penniman Lake, respectively. These tables summarize the potential sources of contamination and the contaminants detected at concentrations exceeding ATSDR CVs for each water body. Findings are summarized below. Discussion

Surface Water and Sediment

ATSDR evaluated the potential for health effects to result from incidental ingestion of surface water or sediment by Navy personnel and their families during recreational activities at the on-site ponds and lakes. We conservatively assumed people are regularly exposed to the highest measured concentration of each contaminant. In reality, contaminant levels fluctuate and lower levels have been observed during different sampling events. Our evaluation assumed that these exposures occurred every day from June through August and 2 days per week (on weekends) in May and September. These assumptions are believed to overestimate the likely exposures of on-base residents and visitors. As a result they are expected to be protective of anyone frequenting these areas, even those who might swim in these waters, even though swimming is not allowed.

For sediment exposures, ATSDR assumed that the adults inadvertently ingest 100 milligrams of sediment each time they visit on-site lakes and ponds, whereas children ingest 200 milligrams of sediment per day. ATSDR assumed that if anyone disregards the signs indicating that swimming is prohibited, they would incidentally ingest between ½ and ¾ cup of water (0.15 liters) over a 3-hour period every time they visit the water bodies (EPA 1997a). For all scenarios evaluated, the estimated exposure doses were consistently below those shown in the scientific literature to cause adverse health effects. For this reason, adults and children coming into contact with surface water and sediment are not exposed to contaminant levels of potential health concern.

Unfortunately, no data about contaminant concentrations prior to the mid-1980s exist, and higher levels of contaminants may have been present in the past, given that the sources of contamination pre-date the mid-1980s. Because earlier data are not available, ATSDR cannot draw firm conclusions about past exposures to surface water and sediment at the on-site water bodies. However, it is likely that people were not exposed to contaminants in the surface water or sediment of the ponds or lakes long enough or often enough to cause health concerns.

Fish Consumption

Fishing has always been allowed in all four of the major CAX on-base water bodies. In 2000, PCBs were detected in sediment samples from Penniman Lake and Youth Pond. The measured PCB concentrations in the sediment ranged between 1.9 ppm to 6.4 ppm for Aroclor 1260. No other forms of PCBs were measured in the samples. No PCBs were detected in the Penniman Lake sediment samples gathered in 1999. In addition, PCBs were not detected in three 1999 samples collected near former Penniman buildings, along the south-central shore of the lake. Subsequent sampling performed in 2000 did detect PCBs; however, the actual concentrations could not be reliably measured (Weston 1999b, CH2M Hill and Baker 2000a, CH2M Hill and Baker 2003a).

As a precaution, based solely on the 2000 sampling results, the Navy advised people who fish on-base to not eat any fish from Youth Pond or Penniman Lake. Current or future exposures to fish are not expected to pose a health concern. People are not allowed to eat fish that they catch from the Youth Pond and Penniman Lake, where PCBs were measured in sediment. The contaminant concentrations measured in Cheatham Pond and Jones Pond are below levels where significant uptake by fish is not expected. People who consume fish from Cheatham Pond and Jones Pond are not expected to be exposed to contaminant concentrations in the fish at levels that could cause health concerns.

The Navy's advisory to not eat fish caught from Youth Pond and Penniman Lake stems from the ability of PCBs to accumulate in the tissue of some types of fish. However, fish tissue sampling was not performed, so it is not known if the fish from Youth Pond and Penniman Lake actually have accumulated PCBs. The extent to which accumulation occurs can vary widely depending on the type PCB present, the type of fish, and other environmental factors (ATSDR 2000c). While it is not possible to conclusively evaluate the potential exposure people could experience by eating fish from Youth Pond or Penniman Lake, it is likely that on-base residents and visitors did not eat enough fish from these two water bodies to cause any type of health concern. There is no past or current concern for people who eat fish from Cheatham Pond or Jones Pond.

In the future, if the Navy is considering lifting its prohibition on eating fish from Penniman Lake and Youth Pond, ATSDR recommends that fish tissue be sampled before any decision is made.

Potential Exposure to Contaminants Associated with the Penniman Shell Loading Plant

Nitroaromatics and some of the other contaminants detected in some areas of CAX are possibly due to activities associated with the Penniman Shell Loading Plant during and after World War I. This section describes the contaminants measured in the environment, available information describing the deposition of the remaining shells after the plant closed, and potential public health implications.

Background

DuPont operated the Penniman Shell Loading Plant in 1917 and 1918. The plant included three discrete areas, known as the "D" Plant, the Shipping Area, and the "G" Plant. Documentation of activities that occurred in these areas is incomplete.

The D Plant was northwest of Sanda Avenue, on both sides of Cheatham Pond. The Shipping Area was to the west of the D Plant. The D Plant was approximately 433 acres and included what was referred to as a TNT production area, pack houses, and two shell loading lines. There were 24 earthen bunkers in the TNT production area, some of which were used as nitro-starch dry houses, dry stores, and dynamite mix houses. Areas that were part of the D Plant are located on both Navy and NPS property. Navy IRP Sites 1, 2, 3, 4, 7, 8, and 9 and AOCs 3 and 5 are located within this general area.

The 515-acre Shipping Area is now entirely on NPS property. It included ammunition magazines and numerous blast holes. Some of the structures at the D Plant and the Shipping Area were as close as 40 feet from Cheatham Pond (Weston 1999a, b).

The G Plant was southeast of Sanda Avenue, entirely on Navy property. It included a 258-acre Shell Loading Area, with three shell loading lines. There were also eight concrete structures, described in engineering drawings from the World War I era as gauge pouring houses. The Navy currently uses these buildings for storage. Among the facilities within the G Plant were ammonia evaporating and finishing buildings, shipping houses, assembly houses, and areas where paint, TNT, and other compounds needed for the shell loading process were stored (Weston 1999a, b). The remains of some of these structures are still present.

EPA reviewed maps of and information about the locations of Penniman plant activities to select appropriate locations from which to collect soil, surface water, sediment, and background samples. Soil samples collected by EPA during the 1999 SI contained metals, PAHs, and nitroaromatics. Some of these contaminants were also detected in surface water and sediment samples, suggesting that contaminants might have been or might be migrating to nearby surface water bodies (Table 7) (Weston 1999a, b). The SI recommended additional sampling of all environmental media potentially impacted (including groundwater, which had not been sampled), along with completion of a human health risk assessment (CH2M Hill 2000; CH2M Hill 2002; Weston 1999b). To date, EPA has not undertaken this type of assessment or conducted further sampling.

When EPA added CAX to the NPL, it named five specific locations at the Penniman G Plant as potential sources of contamination. The Navy designated these sources as the Penniman AOC. The remainder of this section focuses on those five locations (sometimes referred to as sub-areas): The TNT graining house sump, TNT catch box ruins, and ammonia settling pits were along the southern shore of Penniman Lake, in an area that today is little-used and overgrown. The TNT graining house sump and catch box ruins were adjacent to each other. Both were used to separate TNT particles from wastewater, which was then discharged to Penniman Lake, approximately 25 feet away. Northwest of the TNT graining house, within 500 feet, were ammonia settling pits, which received wastewater from the ammonia finishing building and then discharged it to Penniman Lake, approximately 20 feet away (Weston 1999a, b).

Samples collected from the TNT graining house sump and the TNT catch box ruins contained TNT (and some of its breakdown products), PAHs, and metals at concentrations exceeding soil CVs. At the ammonia settling pits, only arsenic was present at a level exceeding its CV. One surface water and three sediment samples were collected from Penniman Lake, near the location where runoff from the three sites was suspected to enter the lake. No contaminants were present in the surface water or sediment samples at levels exceeding their CVs other than arsenic, which was measured only at relatively low levels. Contaminants detected in sediment samples at concentrations below CVs included SVOCs, pesticides, metals, and nitroaromatics. (While the sediment samples were analyzed for nitroaromatics, the surface water sample was not.) EPA did not attribute the arsenic or any other contaminants present in the Penniman Lake samples to the Penniman AOC locations that have been sampled. The Navy has proposed collecting and analyzing soil, surface water, sediment, and groundwater samples at all three sub-areas. VDEQ also supports additional investigations and remediation of these areas. While investigations are planned, they have not yet been scheduled (CH2M Hill 2002; Weston 1999a, b; Goodwin 1994; Willis 2004). Due to the continued interest in these areas by the Navy and regulators, ATSDR expects that the necessary investigations and remedial actions will occur before the land use changes are implemented that would allow greater public access to these areas.

At this time, the Navy, EPA, and VDEQ are still discussing what measures, if any, will be taken at the 1918 drum storage area and from areas affected by waste slag material. EPA identified the 1918 drum storage area from a 1918 photograph that showed wooden barrels and/or 55-gallon drums. The area depicted in the photograph was south of Sanda Avenue, near its intersection with B Street. Samples collected there contained only arsenic at levels above its CV. Waste metallic slag is scattered throughout the shell loading area, predominantly along former railroad beds. Some slag is present on what is now NPS property. An NPS employee speculated that the slag was broken out of boilers on locomotives while the Penniman plant operated. EPA samples were collected east of AOC 2, near the bend in Garrison Road, and contained elevated concentrations of five metals (CH2M Hill 2002; Weston 1999a, b).

During its 1999 investigation, EPA also collected soil samples from two other locations within the G Plant and three locations on NPS property that were within either the Penniman D Plant or the shipping area. The two potential sources of contamination sampled within the G Plant were (1) an underground mixing tank and (2) the opening of a pipe that runs between the TNT graining house and the ammonia evaporating building. The samples in the tank area contained concentrations of arsenic, lead, and PAHs exceeding CVs. A soil sample near the pipe opening contained arsenic at a level that exceeded the CV. No nitroaromatics were detected. One of three areas sampled on NPS property was near bunkers where nitro-starch was dried; associated sump pits and sediment from a nearby drainage way were also sampled. No contaminants were present at concentrations exceeding CVs. EPA also identified more than 100 blast holes 10 to 25 feet in diameter and up to 6 feet deep on NPS property and collected two samples within the holes. The blast holes are thought to have been created from quality control detonations of packed shells. Soil samples collected there contained two metals at levels exceeding CVs. Finally, two samples were collected near a heavily-reinforced drum on NPS property that was thought to have contained an agent that generates smoke. Two pesticides and two PAHs were present at concentrations exceeding CVs (Weston 1999a, b).

Information about the disposition of ordnance, explosive materials, and other compounds handled at the Penniman Shell Loading Plant after World War I ended is limited. An EPA review of available documents associated with Penniman activities summarizes the information in a 1999 "Data Acquisition/Summary Report." Records indicate that the U.S. government sent DuPont instructions modifying the processes used to prepare and store ordnance and explosives in December 1918. DuPont reportedly decommissioned shells through February 1919. DuPont also dismantled the plant and salvaged certain materials used there (Weston 1999a; Goodwin 1994).

Beginning in late 1918 or early 1919, the U.S. government operated the Penniman General Ordnance Depot in part of the area that the Penniman plant had occupied. Little information is available about operations at the depot. Workers there were charged with sending an estimated 5 million pounds of ammonium nitrate present at the Penniman plant to a company in North Carolina. The last shipment of ammonium nitrate was reportedly sent in 1920. EPA also notes that in 1923, almost 50,000 155-millimeter shells were shipped to another U.S. ordnance depot (known as Pig Point at that time, but later renamed Nansemond Ordnance Depot) in Virginia. The Penniman plant loaded five sizes of shells and reportedly had the capacity to load approximately 54,000 shells per day. EPA could not locate information about the disposal of shells of the other four sizes (and any additional 155-millimeter shells) (Weston 1999a).

Records about materials handled at the former Nansemond Ordnance Depot also indicated that some shells from the Penniman plant were shipped there after the war and that the plant received substantially fewer shells than what would have been present at the Penniman plant at the end of the war. According to EPA, other ammunition expected to have been present at that time has not been accounted for. It may have all been shipped off site. Or, some of it may have been burned. Ground scarring evident in subsequent aerial photographs may have been caused by burning activities. Some of it may have been melted for reclamation or been buried. While documentation describing the final disposition of the remaining ammunition is incomplete, there is no specific evidence pointing to on-site disposal (EPA 2003a).

Discussion

Some soil and sediment samples collected by EPA since the 1980s to characterize areas most likely to be impacted by Penniman-related activities have contained elevated concentrations of metals, PAHs, and nitroaromatics. However, in most locations the contaminants have been detected at low levels, below CVs. The highest levels of contaminants were observed at the TNT graining house sump, TNT catch box ruins, and the slag area. Sampled locations were selected in part because they might contain some of the highest levels of contaminants still present. It is unlikely anyone is regularly exposed to any of the source areas sampled. The TNT graining house sump, catch box ruins, and slag area are not easily accessible. They are not close to common recreational destinations like camp sites and picnic areas, and they are amidst thick vegetation. Potential contact with this area by base residents or visitors is expected to be incidental, rather than frequent or for long periods of time. On-base residents or visitors may be able to come into contact with contaminants at these locations, however no adverse health effects are expected because the contact would be both infrequent and for short periods of time. Additional environmental investigations or remedial actions may be necessary if land use changes occur which allow greater public contact with the area containing the TNT graining house sump and catch box ruins.

There are no data about contaminant levels present at the time Cheatham Annex opened or in the decades that immediately followed. Given the history of the site, contaminant levels may have been higher in the past, so ATSDR cannot definitively evaluate past exposures. However, there is no information to indicate that frequent contact by on-base residents or visitors would have been likely following the end of the Penniman operations. It is likely that past exposures to soil contaminants would have been incidental, as it is now, and no adverse health effects are expected due to past contact with soil contaminants at these sites.

Some of the ordnance that would have been present at the Penniman plant at the time World War I ended has not been accounted for in the available records. It may have been transported off-site, buried, melted and/or burned. No buried ordnance has been encountered at CAX or areas once part of CAX that have been transferred to other agencies. Historical aerial photographs have not shown any locations at CAX or nearby property with where there were remains of shells or associated materials from World War I or any ground scarring conclusively attributed to burning ordnance. Although all of the former Penniman property has not been thoroughly searched, none of the investigations conducted by EPA, the Navy, and the other agencies that hold nearby parcels have revealed any ordnance. However, EPA has recommended that some areas continue to be evaluated for possible buried explosive materials (EPA 2003b). ATSDR concurs with those recommendations. ATSDR also acknowledges that there will likely always be some uncertainty about how some of the ordnance was disposed of and that new information may become available in the future. If requested, we will review any additional data after it becomes available, if it is likely to modify this health evaluation.

Potential Exposure to Physical Hazards At and Near CAX IRP Sites

ATSDR identified two locations with potential physical or safety hazards. Both are in areas that base residents or visitors might encounter (one is near Youth Pond and the other is near cabins by the York River). The Navy has not reported to ATSDR any occasions during which people were injured at these locations. Recent and planned actions are expected to address these issues and ultimately eliminate the safety hazards.

Buried Medical Waste; Sharps from Site 4

The Navy previously disposed of out-of-date medical supplies, including syringes and empty intravenous bottles, in a depression adjacent to an unnamed pond, within the fenced-in warehouse area of CAX. The waste, as much as 7,000 cubic yards, was then covered with soil. Sometime before 1984, a considerable volume of this waste was removed from the site. Nevertheless, after heavy rains, syringes were reportedly sometimes seen floating in the unnamed pond, Youth Pond (which is outside of the fenced-in area and immediately downgradient of the unnamed pond), and a culvert where water from Youth Pond drains to the York River. During May 1998, approximately 215 pounds of debris and sharps were removed from the surface of Site 4 (CH2M Hill 2000; Baker 2003).

Particularly before the 1998 removal action, sharps, glass bottles, and certain other types of medical supplies that were washed outside the fenced warehouse area posed a safety hazard to Navy personnel and their families visiting affected areas. Medical supplies in Youth Pond were of particular concern for children of on-base residents or visiting families who may have used the pond for recreational activities. However, no past injuries were recounted to ATSDR.

The Navy investigated the extent of remaining contamination in 2001 and plans to evaluate remedial options to prevent the remainder of buried waste from being transported off site and into the ponds (CH2M Hill 2000; Baker 2003). Although the previous removal actions significantly reduced the potential for waste transport into Youth Pond, the remaining waste still represents a potential physical hazard. ATSDR recommends that the Navy complete the remedial actions necessary to prevent additional waste transport from the burial site.

Damaged fence near the rental cabins; Sites 7 and 13

Within the main part of CAX, near the edge of a cliff by some recreational cabins, there are two discrete disposal areas. The IAS indicated Site 7 had received waste from the Penniman Plant and the City of Penniman but did not provide details about the types of waste present, other than that it included ammunition waste. Site 7 was reportedly located between two cabins along the York River. In 1999, the Navy investigated a disposal area in the same approximate area and found that at least some of the waste present post-dated World War I. In 2000, the Navy discovered a nearby dump site that it determined was the one described in the IAS. It was located between the cabins and the York River on a steep bank about 20 feet above the water surface. This site was designated Site 13. In the future, the Navy plans to address Site 13 along with the nearby Site 7 area (CH2M Hill and Baker 2001a).

The Navy installed a fence to keep recreational users from getting too close to the cliff; it was not erected to keep people from coming into contact with the buried debris (CH2M Hill and Baker 2001a). In September 2003, heavy rainfall from Hurricane Isabel caused extensive erosion of the cliff along the York River, near Sites 7 and 13. Due to the soil erosion, the fence installed by the Navy now dangles over the cliff drop-off in some places. Some of the waste present at that time may have been carried into the York River (Harlow 2003b). Because more than half a dozen cabins are located nearby, visitors may frequent this area. The two cabins closest to the cliff are no longer being used and will be moved elsewhere within CAX. However, additional cabins approximately 100 yards away are still being used (Bond 2004).

ATSDR is concerned that children may be tempted to play near the fence and possibly slip under the dangling fence. If so, there is a risk that they might come into contact with waste or that they may come too close to the edge of the cliff. Therefore, the dangling fence poses a potential safety hazard. The Navy indicated it plans to fix the fence, but this had not occurred as of May 2004. ATSDR recommends that the fence be repaired as soon as possible or that other measures be taken promptly to reduce this hazard.

The Navy is also evaluating how to remediate the waste still present, which is complicated by the fact that not all the waste has been characterized. A variety of different waste could be considered ammunition waste, and no information about the types of materials dating back to the Penniman era that are present is currently available. Therefore, ATSDR cannot evaluate the potential for waste material to pose a physical hazard. Future investigations and remediation of disposal sites will be conducted by the Navy and overseen by EPA and VDEQ. This work is expected to be carried out in a manner that protects residents and visitors from coming into contact with any physical hazards that may be posed by the waste associated with ammunition.

Potential Exposure to Contaminants at the Fuel Farm

Background

A 460-acre area, now known as the Fuel Farm, is located south of the Colonial National Historical Parkway, east of Highway 199, and west of Burma Road. Limited historical records of Penniman activities suggest that a hospital was located in the area that later became the Fuel Farm (Weston 1999b). Aerial photographs from the 1920s and 1930s show ground scarring in this area, which may indicate of burning activities (EPA 2003a). In the 1940s, the Navy installed 18 concrete underground fuel storage tanks (USTs). During the Korean War, another five steel tanks were installed. The tanks each have the capacity to hold approximately 2 million gallons of fuel. Fuels stored included No. 2 fuel oil, kerosene, gasoline, and aviation fuels (ATSDR 2000a; VIMS 1994).

Beginning in 1973, the Commonwealth of Virginia leased the facility to store fuel during the energy crisis. The Commonwealth bought the Fuel Farm from the Navy in 1981 but closed it in 1982. The tanks were disconnected from several miles of fuel delivery pipelines, and the pipelines were capped. All 23 fuel tanks were cleaned out in 1992, and delivery pipelines were fully cleaned in 2002 (ATSDR 2000a; EPA 1997b). Abandoned fuel drums and cans were removed. There were some transformers and other on-site equipment containing PCBs, but were removed, and PCB contamination was remediated (EPA 1997b; EPA 2003b).

Fuel releases over time contaminated surface and subsurface soil, sediment, and groundwater at the Fuel Farm with petroleum hydrocarbons (EPA 1997b). According to summary information, five separate plumes of groundwater contamination containing benzene, toluene, ethylbenzene, xylenes (BTEX), and other contaminants have been identified at the site. BTEX compounds exceed EPA's MCLs in the centers of the groundwater plumes. Groundwater contamination does not extend beyond the Fuel Farm boundaries, it remains within the northern part of the site and has stabilized naturally (EPA 1999a, b). When sampled around 1990, off-site monitoring wells west of the Fuel Farm were not affected by fuel-related contamination (VIMS 1994). A long-term monitoring program is in place to track the extent to which contaminant levels in soil and groundwater decline as a result of natural attenuation or degradation. Surface water in an on-site pond, Hipps Pond, and its two tributaries have BTEX concentrations slightly above CVs. Sediment in the pond and tributaries remains heavily contaminated, particularly with PAHs (EPA 1999a, b).

Approximately 200 acres of the 460-acre Fuel Farm are contaminated. In 1997, EPA and the Commonwealth of Virginia agreed to a final remedy for the Fuel Farm property. Remedial actions included: 1) an upgrade to the dam at the outlet of Hipps Pond, to prevent contaminated sediments from being washed downstream; 2) the excavation and removal of a sludge pit and a Cosmoline (a jelly-like preservative) dump; 3) remediation of an additional sludge pit; 4) long-term groundwater monitoring; and 5) installation of a fence and warning signs to prevent public access to the contaminated portion of the property. By August 2002, all construction activities associated with the remedy had been completed, including the installation of a perimeter fence (EPA 2003d; Noel 2003).

The York County Industrial Development Authority (IDA) has promoted construction of a golf course on approximately 260 acres in the northern part of the former Fuel Farm property (separated from the southern portion by a line roughly parallel to the Colonial National Historical Parkway). The approximately 200 acres contaminated by past fuel storage fall within the 260-acre proposed golf course site (York County Public Information Office 2002; Noel 2003). The contaminated area is subject to a Corrective Action Plan to address hydrocarbon contamination. Creation of a golf course is consistent with the requirements of this plan and is considered a "brownfields" project, because it entails redevelopment of an idle property affected by past contamination.

The York County Comprehensive Plan calls for commercial development in the southern, uncontaminated part of the Fuel Farm. The County indicates that no residential development is planned (Noel 2003; York County Planning Division 1999). The IDA is marketing approximately 80 acres within the uncontaminated portion of the Fuel Farm to commercial interests (and to parties who conduct light industrial activities). So far, a 15-acre parcel has been earmarked for office and storage space for one future tenant. Many of the remaining 120 acres in this portion of the Fuel Farm are wetlands and ravines and are not well-suited to development (Noel 2003; York County Office of Economic Development n.d.).

Discussion

There is no indication that anyone will be exposed to contaminated groundwater, because the groundwater contamination is confined to the northern part of the site, and there are no residences or drinking water wells in that area. The public water supply from Newport News has been extended and will provide drinking water to any future facilities constructed at the Fuel Farm (Noel 2003). The perimeter of the Fuel Farm is currently fully fenced, preventing public access to on-site soil or to Hipps Pond surface water or sediment. There was no public access to the site in the past, when the Navy and then the Commonwealth of Virginia used it for fuel storage. Any unauthorized access during those time periods or afterwards, before the perimeter fence was secured, would probably have been very limited, if it occurred at all, as there are other areas nearby that are open to the public for recreational use (such as National Park Service land and the County park). As a result there is no significant exposure to potential soil contaminants. Planned remedial actions are expected to ensure that future users will not be exposed to Fuel Farm-related contaminants at levels that could cause health effects.

ATSDR expects that if evidence of previously buried Penniman-era materials are discovered during the re-development, EPA and VDEQ approved remedial actions will prevent exposures that could result in adverse health effects for future users of this area. If requested, ATSDR will review any additional data after it becomes available, if it is likely to modify this health evaluation.



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