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PUBLIC HEALTH ASSESSMENT
VOLUNTEER ARMY AMMUNITION PLANT
CHATTANOOGA, HAMILTON COUNTY, TENNESSEE


FACILITY NO. TN6210020933
September 7, 2004



Public Health Action Plan

The Public Health Action Plan (PHAP) for VAAP contains a description of actions taken and to be taken by ATSDR, the Army, EPA, TDEC, and others subsequent to the completion of this PHA. The purpose of the PHAP is to ensure that this PHA not only identifies potential and ongoing public health hazards, but also provides a plan of action designed to mitigate and prevent adverse human health effects resulting from exposure to hazardous substances in the environment. The public health actions that are completed, ongoing, or planned are listed below.

Completed Actions
  1. The Army identified 26 sites at VAAP as potential locations for contamination. TDEC and the EPA accepted the list.
  2. Studies conducted according to RCRA began in the early 1980s and continued through the 1990s. These studies defined VAAP's geologic, hydrologic, and meteorological features, as well as confirmed and located contamination in groundwater, surface soil, surface water, and sediment at VAAP.
  3. In 1994, off-site groundwater contamination was identified in private wells near Chickamauga Lake. The Army supplied bottled water to these residents until they were connected to the public water supply in 1996/1997.
  4. Remedial actions began to occur in the 1990s. In April 1996, a RCRA closure of the landfill at VAAP-15 occurred, and the burn pad was issued a clean RCRA closure in 1999 (pending groundwater being addressed under VAAP-35).
  5. Army, TDEC, and EPA have conducted an extensive groundwater survey at VAAP. Phase I of the survey was begun in 1989, Phase II was completed in 2001, and Phase III is near completion.
  6. In 2000, vanadium pentoxide buried in drums at VAAP-18-Vanadium Pentoxide/ Asbestos Burial site were removed.
  7. In August 2001, the Army conducted a removal action to address five areas of PAH and one area of PCB contamination at VAAP-5-Old Storage Area/Western Magazine Area. Additionally, the approximately 100 storage magazines were demolished and removed. This area (approximately 975 acres) has since been transferred to Hamilton County for redevelopment.
  8. In 2002, surface debris was removed from VAAP-20-Construction Debris Disposal Area.
Ongoing Actions
  1. Groundwater investigations (VAAP-35) are ongoing.
  2. Areas of Concern in VAAP-32 (TNT Manufacturing Valley) are currently being delineated and addressed, including the investigation and remediation of soil contaminants.
Planned Actions
  1. State regulators and the RAB, which includes representatives from the Army, TDEC, EPA, and local citizens, will be making decisions regarding future remedial actions. Soil remediation will be required at the following sites:
    1. VAAP-1 (East Acid Area)
    2. VAAP-2 (CFI Lease Area)
    3. VAAP-32 (TNT Manufacturing Valley)
  2. Long term monitoring of groundwater (VAAP-35, which includes groundwater issues at VAAP-1, 2, 5, 6, 15, 16, 18, 20, 21, 23, 32, 33, and 34) is planned.
  3. A Corrective Measure Study (CMS) for surface water, sediment and drainage ditches in VAAP-32 (TNT Manufacturing Valley) is planned.
  4. Projected completion of the Army's IRP is April 2020.

Preparers of Report

Susan Neurath, Ph.D.
Environmental Health Scientist
Federal Facilities Assessment Branch
Division of Health Assessment and Consultation

Carole Hossom
Environmental Health Scientist
Federal Facilities Assessment Branch
Division of Health Assessment and Consultation

Gary Campbell, Ph.D.
Environmental Health Scientist
Federal Facilities Assessment Branch
Division of Health Assessment and Consultation

References

Army 2001. Installation Action Plan, Volunteer Army Ammunition Plant, Chattanooga, Tennessee, 2001.

Army 2003a. Installation Action Plan, Volunteer Army Ammunition Plant, Chattanooga, Tennessee, 2003.

Army 2003b. Communication between Robert Elmore (US Army) and ERG. Re: Background information about VAAP. October 2003.

Army 2003c. Spreadsheet of environmental sampling results. Received from Ronald D. Webb, US Army Corps of Engineers on June 6, 2003.

Army 2004a. Installation Action Plan, Volunteer Army Ammunition Plant, Chattanooga, Tennessee, 2003.

Army 2004b. Communication between Ronald Webb (US Army) and ATSDR. February 2004.

ATSDR 1995. Toxicological Profile for 2,4,6-Trinitrotoluene (TNT). June 1995.

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ATSDR 1998b. Toxicological Profile for Sulfur Trioxide and Sulfuric Acid. December 1998.

ATSDR 2001. Health Consultation Outline Exposure Issues From Site Visit April 18-19, 2001 Volunteer Army Ammunition Plant Chattanooga TN. September 2001.

ATSDR 2002a. Health Education (HE) Needs Assessment for Volunteer Army Ammunition Plant Chattanooga, Hamilton County, Tennessee, May 2002.

ATSDR 2002b. ToxFAQs for Nitrogen Oxides (Nitric Oxide, Nitrogen Dioxide, etc.). April 2002.

ATSDR 2002c. Health Consultation: Gavin Power Plant, Cheshire, Gallia County, Ohio. February 2002. http://www.atsdr.cdc.gov/HAC/PHA/gavinpower/gpp_toc.html

ATSDR 2003. ATSDR Background and Congressional Mandates. July 2003. http://www.atsdr.cdc.gov/congress.html

Bonds, JD, KC Govro, PC Geiszler, MT Park and S Cook (Bonds) 1985. Archives Search (Part I) and Results of Limited Sampling and Analysis (Part II) at the CF Industries, Inc. Lease Area of Volunteer Army Ammunition Plant, Chattanooga, TN. Prepared for US Army Toxic and Hazardous Material Agency. May 1985.

Cal/EPA. 1997. Health Effects of Exposure to Environmental Tobacco Smoke. Office of Environmental Health Hazard Assessment; California Environmental Protection Agency. Available at: http://www.oehha.org/air/environmental_tobacco.finalets.htmlAccessed on August 4, 2004.

CDM 2002. Enterprise South Industrial Park, Chattanooga, Tennessee Environmental Site Assessment Report. June 2002. http://www.chattanoogachamber.com/PDF_Files/esip%20environmental%20assessment%20executive%20summary.pdf

Chattanooga Free Times Press (CFTP) 2000. Special Report: The Volunteer Site, Plant Served Nation's War Needs. June 12, 2000. http://www.timesfreepress.com/2000/JUN/12JUN00/PICSTYTX.html

City of Chattanooga/Hamilton County (CoC/HC). 2000. Quitclaim Deed. Recorded at the Hamilton County Registry of Deeds October 2, 2000.

Department of Geology (DOG) 2003. Department of Geology. Last accessed July 2003. http://omt.cofc.edu/demo/geo/intro.htm

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Elmore, R. 2004. Personal Communication. Re: Completion of remedial activities at VAAP 5. Phone call, August 9, 2004.

EPA. 1982. Air Quality Criteria for Oxides of Nitrogen. EPA-600/8-82-026. September 1982.

EPA. 1991. Integrated Risk Information System (IRIS) Summary for Nitrate. Last revised October 1, 1991. http://www.epa.gov/iris/subst/0076.htm

EPA. 1993. Air Quality Criteria for Oxides of Nitrogen Volume III of III. EPA-600/8-91/049cF. August 1993.

EPA 2001. EPA Issues Corrective Action Order to Volunteer Army Ammunition Plant in Chattanooga, TN. Released January 21, 2001. Last accessed December 11, 2003. http://www.epa.gov/region4/oeapages/01press/010124.htm.

EPA 2002. A Lexicon of Cave and Karst Terminology with Special Reference to Environmental Karst Hydrology. February 2002. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=54964

EPA 2003a. Federal Facilities Enforcement and Compliance Accomplishments Report FY 2001. January 2003. http://www.epa.gov/Compliance/resources/reports/accomplishments/federal/fy01accomplrpt.pdf

EPA 2003b. Policy Statements and Strategy Documents. Last accessed July 2003. http://www.epa.gov/region4/about/index.html

EPA 2003c. Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume 1: Stationary Point and Area Sources. Last updated 2003. http://www.epa.gov/ttn/chief/ap42/

General Services Administration (GSA) N.D. Volunteer Army Ammunition Plant Draft Environmental Impact Statement. N.D. Downloaded from http://www.phe.com/downloads.html

GSA 1999. Volunteer Army Ammunition Plant Final Environmental Impact Statement. July 1999. Downloaded from http://www.phe.com/downloads.html

GSA. 2003. Communication between Lori Dennis (GSA) and ATSDR. October 2003.

International Technology Corporation (IT Corp) 1994. Site Investigation Report Volunteer Army Ammunition Plant, Draft. Prepared for the U.S. Army Environmental Center (USAEC). December 1994.

IT Corporation (IT Corp) 2001. Soil Removal Action Report for the Western Magazine Area (Including 940-Acre Hamilton County Parcel) Volunteer Army Ammunition Plant, Chattanooga, Tennessee. Prepared for U.S. Army Corps of Engineers. November 2001.

LDR International Inc. 2000. Preferred Alternative Map (draft). May 19, 2000.

Lipsett 2001. Chapter 66: "Oxides of Nitrogen and Sulfur," Michael J. Lipsett. in Clinical Environmental Health and Toxic Exposures, eds. John B. Sullivan, Jr., Gary R. Krieger. 2001.

Love, GJ, SP Lan, CM Shy, and WB Riggan. 1982. Acute respiratory illness in families exposed to nitrogen dioxide ambient air pollution in Chattanooga, Tennessee. Arch. Environ. Health. Volume 37. Pages 75-80.

Meditext. 2000. Nitrogen Dioxide. Meditext Medical Management. Last revised February 2002. Last accessed on September 3, 2003. http://csi.micromedex.com/fraMain.asp?Mnu=0

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Portage County Groundwater (PCG) 2003. Portage County Groundwater: Groundwater Storage in Aquifers. Last accessed July 2003. http://www.uwsp.edu/water/portage/undrstnd/aquifer.htm

Public Comment 2004a. Information provided in response to the public comment release of this Public Health Assessment. See comment #4 in Appendix F.

Public Comment 2004b. Information provided in response to the public comment release of this Public Health Assessment. See comment #5 in Appendix F.

The Proteus Foundation. 2003. The Proteus Foundation, What is Proteus Syndrome. Last accessed September 11, 2003. http://www.proteus-syndrome.org/html/whatisps.htm

Tennessee Department of Environment and Conservation (TDEC) 2003a. Communication between Nancy Frazier (TDEC, TN Superfund Regional Manager) and ERG. July and September 2003.

TDEC 2003b. TDEC Official Web Site. Last accessed July 2003. http://www.state.tn.us/environment/

Savannah Valley Utility District (SVUD). 2003. Communication between Ron West (SVUD Assistant Manager) and ERG. September 2003. Regarding municipal water supply.

Shaw Environmental, Inc. (Shaw). 2003. Communication between Mark Gardiner (Project Manager) and ERG. November 2003. Regarding bottle water supply to neighboring homes.

Shy, CM. 1970. The Chattanooga study. J. Air Pollut. Control Assoc. Volume 20. Pages 832-833.

Shy, CM, JP Creason, ME Pearlman, KE McClain, FB Benson, and MM Young. 1970a. The Chattanooga school children study: effects of community exposure to nitrogen dioxide. I. Methods, description of pollutant exposure, and results of ventilatory function testing. J. Air Pollut. Control Assoc. Volume 20. Pages 539-545.

Shy, CM, JP Creason, ME Pearlman, KE McClain, FB Benson, and MM Young. 1970b. The Chattanooga school children study: effects of community exposure to nitrogen dioxide. II. Incidence of acute respiratory illness. J. Air Pollut. Control Assoc. Volume 20. Pages 582-588.

US Army Environmental Hygiene Agency (USAEHA) 1985. Technical Guide 140: Water Pollution Aspects of Explosive Manufacturing. August 1985. http://chppm-www.apgea.army.mil/imo/ddb/dmd/DMD/TG/TECHGUID/Tg140.pdf

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Tables

Table 1: Potential Exposure Pathways at the Volunteer Army Ammunition Plant (VAAP)
Pathway/Route of Exposure Exposure Pathway Elements Comments
Source of Contamination Environmental Medium Route of Exposure Exposed Population Hazard Yes/No
Exposure to air contaminants from Volunteer Army Ammunition Plant (VAAP) Trinitrotoluene (TNT) production and associated activities Air Inhalation On-site workers and visitors
Off-site residents
Past: Unknown
Current: No
Future: No
Acute exposures to airborne contaminants occurred when TNT operations were active at VAAP (intermittently from 1942 to 1977). However, data are insufficient to determine if long-term health effect occurred. No current or future exposures are occurring because TNT production has ceased.
Public water supply systems serving VAAP and surrounding communities TNT production and associated activities Groundwater Ingestion, inhalation, and dermal contact On-site workers and visitors
Off-site residents
Past: No
Current: No
Future: No
No exposures to contaminants in the public water supply occurred in the past, are currently occurring, or are expected to occur in the future. VAAP and public water suppliers obtain water from surface water supplies, except for the Carson Well operated by a public water supplier. Regardless, the water supply is carefully monitored under federal and state regulation to ensure its safety. Due to location, the public well field is not within off-post groundwater flow directions and unlikely to ever have been affected by site-related contaminants (TDEC 2003a).
Off-site private drinking water wells. TNT production and associated activities Groundwater Ingestion, inhalation, dermal contact. Off-site residents served by private wells. Past
Current
Future
Past: Unknown
Current: No
Future: No
Private well users may have been exposed to groundwater contamination in the past. Off-site monitoring data indicate that contaminants have migrated beyond VAAP boundaries, mostly to the north. Residential well data are not available for the time period when TNT production actually occurred. Currently, all residents are believed to be connected to the municipal water system and receive clean water usable for all applications. Residential well data available since 1990 indicates most private wells do have detectable levels of explosive-related compounds; levels are not expected to cause health effects for residents using their well for irrigation. Because a few wells did have high concentrations of a few contaminants, residents who use their well to fill their swimming pool or for potable water should have their well sampled periodically.
On-site workers contacting soil in future industrial areas in the TNT Manufacturing Valley (TNTMV; VAAP-32) during remediation or construction activities. TNT production and associated activities Surface soil in the TNTMV industrial area Incidental ingestion, inhalation, dermal contact On-site workers Past: Unknown
Current: Unknown
Future: Unknown
High concentrations of explosive-related compounds have been detected in some of the soil samples from the TNTMV. However the exact location of those samples is unknown. Frequent, direct contact with soil with this level of contamination by construction workers could possibly result in exposure to contaminants at levels that could cause health concern. Current Army plans call for further investigation of this area and removal of contaminated soil (Army 2003a). Prior to remediation, the potential for exposure is indeterminate due to uncertainties in the locations of soil samples with high contaminant concentrations. Following the completion of the remedial activities, ATSDR expects that there will be no exposure to people who use this area.
On-site workers, trespassers, and future recreational users contacting areas of surface soil contamination for recreation. (e.g., walking, hiking). In all areas except VAAP-32. TNT production and associated activities Surface soil in the non-industrial areas Incidental ingestion, inhalation, dermal contact On-site workers, trespassers, future recreational users Past: No
Current: No
Future: No
Low levels of surface soil contamination have been identified in areas associated with TNT production support, TNT storage, and other post-related activities. ATSDR reviewed the environmental data, potential exposure scenarios, planned remediation activities and toxicology literature and determined that the concentrations of contaminants present in surface soil are, or will be, below levels of concern for the anticipated uses.
On-site workers, trespassers, and future recreational users contacting areas streams and ponds onsite for recreation (e.g., hiking, wading) Releases from TNT production and associated processes to Poe Branch, Harrison Branch, intermittent streams, and ponds/drainage ditches Surface water and sediment Incidental ingestion, inhalation, dermal contact On-site workers, trespassers, future recreational users Past: No
Current: No
Future: No
Surface water and sediment contamination is the result of former TNT manufacturing and associated processes. Evidence indicates that trespassing occurs in the streams and ponds on-site. ATSDR reviewed the environmental data, potential exposure scenarios, and toxicology literature and determined that the concentrations of contaminants present in surface water and sediment are below levels of concern.
Notes:
ATSDR Agency for Toxic Substances and Disease Registry
TNT trinitrotoluene
TNTMV TNT Manufacturing Valley
VAAP Volunteer Army Ammunition Plant


Table 2: Review of Contaminated Sites at the Volunteer Army Ammunition Plant (VAAP)
Site Name/Description Operational History Monitoring Efforts Public Health Concern
VAAP-1: East Acid Area
This site is a rectangular area of 18 acres located in the Volunteer Army Ammunition Plant's (VAAP) northwest quadrant, approximately 800 feet (ft) east of the old TNT production facilities. Most of the acid production facilities housed here have been removed, except for the foundations. Although much of the area between the former facilities was covered with concrete or asphalt, plants have begun to grow throughout the area. The site is bounded on the east and west by rail lines, and on the north and south by roads, it is generally accessible. Surface water drains westward, and the roads and rail lines direct most runoff toward a discharge area that feeds into Pond 7. Pond 7 lies to the west of the site and was formed to receive discharge from the Neutralization Plant. Surface water eventually reaches Waconda Bay (IT Corp 1994). The East Acid Area was operated intermittently from 1941-1970 to support TNT production at VAAP. The area housed nitric acid, sulfuric acid, and oleum (a sulfuric acid mixture with sulfur trioxide) production facilities, and an ammonia storage facility (which were mostly disassembled and sold in 1974, although the brick and concrete foundations remain). Three storage tanks, which alternatively stored toluene and fuel oil, were located at this site; the contents were removed in 1977, however, two tanks remain onsite.

Chemicals used in this area include: nitric acid, anhydrous ammonia, sulfuric acid, sulfur, sulfur dioxide, sulfur trioxide, vanadium pentoxide, oleum, toluene, fuel oil. A potential for heavy metal contamination exists, because acids may have corroded the metal storage structures or acid transfer lines (IT Corp 1994; Army 2003a, Public Comment 2004b).
Exploratory and confirmatory surveys (ES and CS) in 1981 and 1983 identified some contaminants in surface water and sediment at Pond 7 (IT Corp 1994).

As part of the 1994 Site Investigation (SI) groundwater, surface water, sediment, and surface soil were sampled. Groundwater is addressed under VAAP-35.

Supplemental sampling (SS) conducted in 1999 indicated that soil contamination covers a larger area than expected (Table 6). The 2003 Installation Action Plan (IAP) suggests a survey be done to determine the nature and extent of the soil contamination, followed by excavation and off-site disposal of the contaminated soil (Army 2003a).

Soil sampling in VAAP-1 identified organics, explosives, pesticides, polychlorinated biphenyls (PCBs), and inorganics about comparison values (CVs) for industrial use of the site. Table 6 details these contaminants.

VAAP-1, as well as VAAP-33 (New Acid Area), Pond 7, and Pond 10 are located in Drainage Basin B. The Army pooled data from these sites (from the ES, CS, SI, and SS) to provide information about the contamination in Drainage Basin B. Organics, explosives, pesticides, PCBs, and inorganics were found in surface water and/or sediment at concentrations above CVs in Drainage Basins A and B. Tables 7 and 8 detail these contaminants.
There are no current air emissions; past exposures are likely, however potential health effects are indeterminate.

VAAP-35 evaluates groundwater.

Surface soil results indicate some areas may contain high concentrations of contaminants. There is no exposure to off-post residents; planned remediation efforts are expected to eliminate the potential exposure to future on-site workers.

There is no current exposure to residents or on-site workers to the surface water or sediment in Drainage Basin B. Some samples suggest that the ponds and streams may contain high concentrations of some contaminants. The Agency for Toxic Substances and Disease Registry (ATSDR) expects that recreational access to Drainage Basin B surface water areas will be minimal due to the industrial land use; incidental contact is unlikely to cause health effects.
VAAP-2: CFI (CF Industries, Inc.) Lease Area
This area is located on the western perimeter of VAAP, southeast of Chickamauga Lake. The area is approximately 686 acres, 56 of which correspond to former ammonium nitrate and acid production facilities (Army 2003a). The majority of VAAP-2 is located in Drainage Basin A, which flows south. Runoff in this portion of the site is discharged through Ponds 2, 3, 4 and 5, eventually reaching Friar Branch. Surface water runoff from the northern part of the site (located in Drainage Basin B) is directed to Pond 1, eventually making its way west to the VAAP surface drainage system near the redwater treatment area. A residential area abuts the southwest corner of the site (Bonds 1985). The CFI Lease Area was used for the production, handling, and storage of nitric acid, ammonium nitrate, and urea; and had additional facilities for sulfuric acid concentration. Different companies operated the site to support TNT production, as well as to produce fertilizer (Army 2003a).

The site was initially used to produce nitric and sulfuric acid from 1942 to 1945 and 1952 to 1957. In 1962 the Army leased the area to CFI (Army 2003a). In 1963 a urea plant was established that doubled the capacity of the ammonia plant. The plants ceased operation in 1982. When VAAP was on standby status between the wars, the operator used the nitric acid plants to provide raw materials for the production of ammonium nitrate. While VAAP was operational, the facilities were used to produce acids required for TNT production and ammonium nitrate. Acid and toluene were stored in tanks on the site (the toluene tanks were bermed, and no spills or leaks were reported); pesticides were sprayed to control weeds around the perimeter; and the major wastes produced at the CFI Lease Area were oils from the compressor systems, small quantities of fertilizers, and acids (Bonds 1985, Public Comment 2004b).
Many of the buildings at the CFI Lease Area have been demolished, but their concrete foundation slabs remain. A SI conducted in 1994 determined the CFI Lease Area required remedial action. Supplemental sampling conducted in 1999 determined that the vertical extent of the soil contamination extended 10 ft. Table 6 summarizes soil sampling data. In the 2003 IAP report, the authors determined the metals in soil should be stabilized on site, and then the stabilized metals and other contaminants should be moved off site. Furthermore, they determined sediment and groundwater as additional media of concern (Army 2003a). Groundwater will be addressed under VAAP-35.

Portions of VAAP-2 are proposed for reuse as a recreational area and other portions for reuse as an industrial area. Comparison of soil sampling results to CVs for recreational use of soil found organics, pesticides, PCBs, and inorganics exceeding CVs.

Much of VAAP-2 is located in Drainage Basin A. The 1999 SS of Drainage Basin A indicates organics, explosives, pesticides, PCBs, and inorganics were found in surface water and/or sediment at concentrations above CVs in Drainage Basins A and B. Tables 7 and 8 detail these contaminants.
Air emissions from VAAP-2 ceased in 1982, exposures and potential health effects during operation are indeterminate.

VAAP-35 evaluates groundwater.

Surface soil results indicate some areas contain high concentrations of metals. There is no exposure to off-post residents; planned remediation efforts are expected to eliminate the potential exposure to future on-site workers.

There is no exposure to residents or on-site workers to the surface water or sediment in Drainage Basin A. Some samples suggest some surface water bodies may contain high concentrations of some contaminants. ATSDR expects that recreational access to Drainage Basin B surface water areas will be minimal due to the industrial land use; incidental contact is unlikely to cause health effects.
VAAP-3: Pistol Range
This area consists of two closed pistol ranges located in the northwest quadrant of VAAP, approximately 1,500 ft west of the land parcel acquired by the City of Chattanooga and Hamilton County (Army 2003a). The pistol ranges were used until 1995, most recently by VAAP security guards. Subsequently, lead slugs have contaminated the site and high levels of lead have been found in the soil (Army 2003a). In December 1998 a focused SI was conducted at this site. High levels of lead were detected in the soil (Table 6). Remediation, including removal of all structures, backstop berms, and lead-contaminated soil, has been completed. A final removal action report is scheduled for release in Spring 2004 (Army 2003a, 2004). Remediation of this site is ongoing. There is no exposure to off-post residents to the lead in this soil. Remediation efforts have eliminated potential exposure to future on-site workers and recreational users.
VAAP-4: Environmental Lab
The Environmental Lab is located in the southwest quadrant of VAAP, east of the southern end of the CFI Lease Area (Army 2003a). The facilities at this site were used to perform water quality analyses (Army 2003a). A focused SI conducted in 1999 found benzo(a)pyrene (to 1.6 ppm) in surface soil at concentrations above comparison values (CVs). In July 2001, the U.S. Environmental Protection Agency (EPA) and Tennessee Department of Environment and Conservation (TDEC) concurred that no further action was necessary at this site. VAAP-4 requires no further action (Army 2003a); the limited amount of soil contamination identified by soil sampling is below levels of health concern for the proposed future use. Under future reuse plans, VAAP-4 will be included in a light industrial area. Review of surface soil data and toxicological data found that contact with benzo(a)pyrene levels in surface soil are not expected to result in adverse health effects for current or future on-site workers.
VAAP-5: Western Magazine Area/ Old Storage Area
VAAP-5 is the westernmost of the two magazine areas, and just east of the TNT Manufacturing Valley (TNTMV). This site is located in the eastern half of the installation and is interspersed with small intermittent streams. The area was once heavily wooded, but has since been deforested. In 2000, the Army conducted extensive logging of pine trees, eliminating most of the remaining forested areas. VAAP-5 lies in Drainage Basin C; the small streams primarily drain to the west and empty into Poe Branch Creek, which flows south and exits VAAP along the southern perimeter. The majority of the approximately 976 acres sold to the city of Chattanooga and Hamilton county in September 2000 is the former Western Magazine Area (IT Corp 2001; Army 2003a). This site was constructed in the early 1940s for the storage of finished TNT product. There are 100 reinforced concrete magazines, covered with earth and grass. The magazines have double-walled metal doors through which TNT was loaded and unloaded. Additionally, there were four railcar-loading areas in the southwest side of the site. Two of these buildings and associated loading platforms have been demolished. TNT has not been stored at this site since the 1970s, when VAAP ceased producing TNT. Since then, documents have been stored in the magazines. The City and County plan to demolish the bunkers by 2002 (IT Corp 2001; CDM 2002).

Another source reported that the igloos at VAAP-5 were also used to store small arms ammunition and riot control agents, such as CS (o-chlorobenzylidene malonoitrile) and CN (chloroacetophenone). These items were also stored as finished product in sealed boxes (CoC/HC 2000).
Initial investigations in 1998 and 1999 were conducted at the Western Magazine Area. Soil sampling was performed at sites most likely to be contaminated and analyzed for nitroaromatic explosives (the contaminant type expected to be found), and TNT was detected. In 2000, a more extensive area was sampled and analyzed for a broader spectrum of constituents. Both groundwater and soil were sampled. Groundwater will be addressed under VAAP-35. PCBs were found in soil, and PCBs and polyaromatic hydrocarbons (PAHs) were found in soil and sediment. A follow-up study was conducted to define the vertical and lateral extent of soil contamination in eight areas for PAHs, PCBs, and TNT (IT Corp 2001). Table 6 summarizes soil sampling results.

A soil removal action was conducted at the Western Magazine Area beginning in August 2001. The six sites contaminated with PAHs, and the one site contaminated with PCBs were successfully remediated. One TNT remediation site requires further action; the soil removal ceased before remediation goals were met because the contamination was deeper than anticipated and further removal became logistically impossible (IT Corp 2001). Further remediation, occurred during Winter 2004, and addressed the one remaining structure at this site. All necessary remediation has been completed (Army 2004b, Public Comment 2004b, Mr Elmore 2004).
VAAP-35 evaluates groundwater.

VAAP-5 is included in the industrial area under the current reuse plans. Soil sampling results indicate some areas still have high concentrations of TNT. There is no current exposure to off-site residents and no exposure is expected for future recreational users. The remediation efforts eliminated the potential exposure concerns for future on-site workers.
VAAP-6: Eastern Magazine Area/ New Storage Area
This is the easternmost of the two magazine areas located in the eastern half of the installation (Army 2003a). A residential area is located to the east of this site. Most surface water at VAAP-6 (part of Drainage Basin C, E, and F) drains to the east, but a portion in the southern part of the site drains to the south, towards the Redoubt Soccer Field. VAAP-6 contains 100 Corbetta type magazines, once used to store final TNT product, although explosives are no longer stored at VAAP (Army 2003a). In January 1999, a SI conducted at the site did not detect contamination above CVs. The Army has proposed this site for no further action and is waiting for concurrence from EPA and TDEC (Army 2003a). No contaminants have been found above CVs in VAAP-6. No public health hazards exist for residents, past and current on-site workers, or future recreational workers.

Due to potential physical hazards associated with unauthorized use of the magazines, ATSDR recommends that the magazines be secured and periodically inspected to prevent unauthorized access.
VAAP-15: Burning Ground/New Landfill
This 80-acre area is located north of VAAP-6New Magazine Area in the northeastern half of the installation. The Burning Ground is a 0.6-acre burning pad and a 225 square foot (ft2) flash pad; the New Landfill is a 3.2 acre unlined landfill (Army 2003a). No information is available describing the materials burned, how often burns occurred, or how long burning activities lasted. In April 1996, the landfill was closed under the Resource Conservation and Recovery Act (RCRA). In May 1999, TDEC issued a clean RCRA closure for the burning pad, pursuant to groundwater at the site being addressed, which will be done under VAAP-35. Soil sampling results indicate contaminant concentrations are below levels of concern. VAAP-15 requires no further action (Army 2003a). Table 6 summarizes soil sampling results.

Most of VAAP-15 is located in Drainage Basin E (part of its southern perimeter lies in Drainage Basin C). Although no contaminants were found above CV in surface water in Drainage Basin E, PAHs and organics were found in sediment above CV. The contaminants detected and their CVs are detailed in Table 8.
VAAP-35 evaluates groundwater.

This site does not pose a public health concern for local residents of future recreational users. Soil, surface water and sediment (Drainage Basin E) sampling results indicate potential contaminants are below levels of health concern for the proposed land use.
VAAP-16 World War II Burning Ground
The World War II Burning Ground is a 2.5-acre site between the TNT production facilities and the Western Magazine Area, and south of the East Acid Area. There are no permanent surface water bodies at this site, however, there are ephemeral streams, and surface water (part of Drainage Basin C) drains in an east/southeasterly direction (IT Corp 1994; Army 2003a). From 1941 until the early 1960s, this site was used to burn explosives-contaminated material in an open unlined pit (Army 2003a). A SI in 1994 sampled groundwater, surface water, sediment, and surface soil at VAAP-16. Only arsenic (to 27 ppm) was found about its CV in soil. Groundwater will be addressed under VAAP-35.

A RCRA Facility Investigation (RFI) is planned for 2002-2003, with a report of the investigation expected in July 2003 (Army 2003a).

Both VAAP-16 and VAAP-20 are located in Drainage Basin C. Drainage Basin C contained manganese above its CV in surface water and PAHs, arsenic, and iron above their CVs in sediment. The contaminants detected and their CVs are detailed in Tables 7 and 8.
Past air releases from burning are unknown and possible health hazards indeterminate.

VAAP-35 evaluates groundwater.

VAAP-16 is included in the industrial area under the current reuse plans. A review of the data for surface soil, surface water, and sediment (Drainage Basin C) sampling indicate potential contaminants are below levels of health concern for the proposed land use.
VAAP-18: Vanadium Pentoxide/ Asbestos Burial
This 2-acre site is located 1,500 ft east of the TNT production facilities. The area contains two marked, unlined, capped burial areas. Although there is no evidence of permanent surface water bodies at this site, surface water drains in an easterly direction (IT Corp 1994; Army 2003a). There are two disposal units at VAAP-18. In the north, there is the vanadium pentoxide burial area, which contained 70,000 pounds (lbs) of waste vanadium pentoxide catalyst buried in drums. In the southern portion of the site, the Asbestos Burial Area contains 107 tons of double bagged asbestos pipe insulation, buried between 1977 and1987 (Army 2003a). A SI conducted in 1994 included VAAP-18. No sediment or surface water sampling was performed because there are no permanent streams, nor evidence of storm water erosion. Nor was soil sampling conducted because the vanadium pentoxide drums and asbestos were covered with native soil. Groundwater sampling was conducted in 1994 and in 1999; groundwater is considered site-wide, as a part of VAAP-35 (IT Corp 1994; Army 2003a).

Removal of the vanadium pentoxide drums was completed in 2000. A deed restriction is required for the asbestos burial site. The details regarding implementation of this deed restriction have not yet been determined. VAAP-18 requires no further action (Army 2003a, 2004).
VAAP-35 evaluates groundwater.

Reuse plans designate VAAP-18 as a future industrial area. Based on the existing soil cap, past drum, removal, and deed restrictions, no adverse health effects are expected for on-site workers.
VAAP-20: Construction Debris Area/ Industrial Landfill Area
VAAP-20 is a 2-acre unlined disposal area 800 ft east of the East Acid Area. The landfill is slightly elliptical and measures 150 by 200 ft. Grasses sparsely cover the landfill, whereas the surrounding area is vegetated with trees. There are channels that run down the northern facing slope, that have formed via storm water erosion. Surface water (part of Drainage Basin C) drains east down the landfill toward Poe Branch, where it eventually exits VAAP at its southern border (IT Corp 1994; Army 2003a). The site was first used as a landfill in the 1970s, and was reported to have received uncontaminated industrial wastes and construction debris until 2000 (IT Corp 1994; Army 2003a). As part of the 1994 SI, soil, surface water, sediment, and groundwater samples were collected and analyzed. Table 6 summarizes soil sampling data. Groundwater is addressed under VAAP-35. Surface water and sediment contamination is addressed under Drainage Basin C, which is reported under VAAP-16 (Tables 7 and 8).

In 2002, surface debris was removed from VAAP-20. An RFI (including sampling and possibly trenching) will be conducted beginning in 2002 and completed by October 2003 (Army 2003a).
VAAP-35 evaluates groundwater.

VAAP-15 is included in a future recreational area based on current reuse plans. Environmental sampling conducted to date has not identified any contaminants at concentrations that could affect the public health of future recreational users. Additional remedial investigations and remediation are planned with oversight from TDEC and EPA; results of these actions will ensure that future recreational users will not contact material that could cause health concerns.
VAAP-21: World War II Landfill
VAAP-21 is a 10-15 acre site located 1,600 ft south/southwest of the East Acid Area, in the west central portion of VAAP. The landfill is currently covered with grasses, and surface water flows via intermittent streams that travel in a south/southeasterly direction (IT Corp 1994; Army 2003a). The site was originally a coal yard, and converted to a 10-acre unlined landfill that was used between 1941 and 1969 for the disposal of general installation trash and garbage. The area has been used to dispose of chemicals and chemical residues (such as sodium sulfite, sodium sulfate, and soda ash) (IT Corp 1994). The landfill and disposal trenches also reportedly received redwater ash, redwater sludge, and refuse (Army 2003a). As a part of the SI in 1994, the only media sampled was groundwater. Groundwater is addressed as VAAP-35. The site was assumed covered with native soil; however, during the investigation, sulfur and other debris were observed exposed at the surface (IT Corp 1994).

Investigative trenching was conducted in September 2000. Only arsenic (to 33.5 ppm), lead (to 4,970 ppm), and benzo(a)pyrene (to 0.35 ppm) were found above CVs. VAAP plans to conduct an RFI (including sampling and trenching) beginning in 2003 and completed by October 2003 (Army 2003a).
VAAP-35 addresses groundwater.

VAAP-21 is included in the industrial area of the site based on reuse plans. Investigations and remediation are ongoing with oversight by TDEC and EPA. Results of these actions will ensure that future recreational users will not contact material that could cause health concerns. Currently available soil sampling data indicates only a few samples had concentrations of contaminants above CVs. Current residents are not exposed to any contaminants of concern. Potential exposures for past, current, or future on-site workers are also below levels of health concern.
VAAP-23: Magazine Area Redwater Ash-Gypsum Sludge Landfill
VAAP-23 is an open field of 3 acres located within the Magazine Area (in the eastern portion of VAAP). Although the Redwater ash burial area is covered with native soil, the gypsum sludge landfill is exposed. There is an intermittent stream along the northern border (~220 ft) that drains into a marshy area (~100 x 300 ft). The site is located in Drainage Basin F, and therefore water exits at the eastern border (drains to the SE) (IT Corp 1994; Army 2003a). From the mid-late 1960s, the site was used to dispose redwater ash (now capped with native soil). Redwater ash is a waste product from the TNT production process, as described in Appendix B. In the early 1970s, gypsum sludge (calcium sulfate) was piled in the northwest part of the field (IT Corp 1994). Studies prior to 1994 sampled groundwater, surface water, and sediment, and found no contamination at VAAP-23. A SI in 1994 sampled groundwater, surface water, and sediment for contaminants. Groundwater contamination is addressed under VAAP-35. Arsenic (to 116 ppm) and benzo(a)pyrene (to 0.37 ppm) were found in soil above their CVs. Surface water and sediment samples from Drainage Basin F, the location of this site, contained PAHs, arsenic, iron, and/or manganese above their CVs, as detailed in Tables 7 and 8.

Pending EPA and TDEC concurrence, no further actions are planned at VAAP-23 (Army 2003a) because soil sampling results indicate arsenic concentrations are below levels of concern for the expected future use.
VAAP-35 evaluates groundwater.

This area is not a health hazard for local residents or current on-site workers; however it is included in a future recreational area based on current reuse plans. Soil sampling results suggests that some samples have high concentrations of arsenic and TNT, while the vast majority have concentrations well below CVs. From the soil data it is not apparent whether the samples were from surface or sub-surface soil. The highest arsenic detection was five times greater than the second highest detection, indicating that the arsenic contamination is not wide-spread at this site but limited to small areas. Contact during recreational use is not expected to be a health concern.
VAAP-30: Mustard Agent Spill (1947)
The Mustard Agent Spill occurred beyond VAAP boundaries (Army 2003a). In July 1946, guards suspected mustard gas leaking from the floor of a railroad car transporting chemical munitions. This car was sidetracked near VAAP for assessment by chemical munitions specialists. The specialists identified a small vapor leak from one bomb, but determined that stains seen by the guards were grease stains. The specialists found no evidence of residual contamination in the unloaded railroad car and 5 miles of railroad track (Army 2004b). No ongoing remediation or monitoring efforts were required because munitions specialists found no evidence of contamination at the time of the reported leak. A minor mustard gas release was identified and munitions specialists found no evidence of contamination of the railroad car transporting the leaking bomb or the railroad tracks. As such, ATSDR identified no potential public health hazards associated with this event.
VAAP-31: Warehouse Area including Pesticide Storage
This site is located in the southwest portion of VAAP (Army 2003a). The warehouse area included a laundry facility, millwright shop, change houses, and other similar facilities. Hazardous materials, hazardous waste, and pesticides were located on this site (Army 2003a). The pesticide storage building was demolished in 1996, other buildings have been as well. Pesticides were a potential concern, however only dieldrin (to 0.091 ppm) was found in soil above its CV. A RCRA Facility Assessment (RFA) will consider the Pesticide Storage Area (Army 2003a). VAAP-31 will continue to be an industrial area under current reuse plans. Investigations are ongoing to protect the health of future on-site workers. There is no exposure to local residents.
VAAP-32: TNT Manufacturing Valley
This site is located in the western portion of VAAP, and includes the old and new TNT production facilities, Red Water Treatment Plant, and the Industrial Surface Water Pollution Control Facilities (former site VAAP-34). Currently, only the foundations of the old batch process lines, and buildings of six new continuous process lines are present at the site. The Red Water Treatment facilities and Building 816, VAAP's only designated state historical structure, remain in place (Army 2003a). Most of the surface water at VAAP-32 (part of Drainage Basin B) drains to the north, although parts of the perimeter are located in Drainage Basin A. The site originally consisted of 16 TNT production batch process lines built in 1942 to support World War II. Although a limited amount of disposal occurred at the site, contamination is suspected to be primarily the result of spills during production (Army 2003a).

Anecdotal information indicates that the number of production lines varied over time. Apparently 16 production lines were used during WWII, 6 were used during the Korean War, and 10 were used during the Vietnam Conflict (Public Comment 2004b).
An initial Remedial Investigation (RI) detected high levels of explosives in groundwater, sediment, and soil, as well as detectable levels of arsenic, lead, PCBs and PAHs. Table 6 summarizes soil sampling results. A draft RI, draft risk assessment, and draft final feasibility study (FS)have been completed but not finalized. A site investigation was conducted in 2000, and a draft RFA report for Area of Concern (AOC) 9, AOC 10B, and the Salvage Yard was submitted in April 2002.

Supplemental sampling was conducted at the TNTMV in 1999. Surface water and sediment in Drainage Basins A and B, in which the TNT Manufacturing Valley lies, contained organics, explosives, pesticides, PCBs, and inorganics at concentrations above CVs. Tables 7 and 8 detail these contaminants.

An RFI and Corrective Measure Study (CMS) are scheduled for completion in December 2004. The Army anticipates that soil remediation for some areas will be required. A CMS for surface water and drainage in this area is scheduled for 2005 (Army 2004a).

The redwater evaporator building was demolished in April 2004 (Public Comment 2004b).
Air emissions from VAAP-32 ceased in 1977, exposures and potential health effects during operation are indeterminate.

VAAP-35 evaluates groundwater.

A number of contaminants have been found in the soil. There is no current exposure to residents and no exposure is expected for future recreational users on other portions of the post. Re-use plans indicate the area will continue to be industrial. Soil data suggests there is a potential for future workers to come into contact with high concentrations of TNT. The planned future investigations are expected to identify corrective actions and protect future construction and industrial workers. ATSDR expects future remedial efforts will eliminate potential exposure concerns.

Some surface water samples from Drainage Basins A and B indicate contaminants may be present in on-post ponds and streams in this area. There is no current exposure of local residents or on-site workers to these contaminants.
VAAP-33: New Acid Area
The New Acid area consists of 50 acres located north of the Old Acid Area on hills that flank the eastern border of the TNT manufacturing valley. The area is known to be located on sinkholes. The production area only takes up 18 acres. Treated liquid waste from the production facilities at VAAP-33 were discharged to Pond 10 (Pond 10 also received discharge from the East Acid Area via an underground sewer). Anecdotal information indicates some of the buildings in this area have been removed. Surface water drains westward (IT Corp 1994; Army 2003a, Public Comment 2004b). Originally, the site was used as a burning ground and redwater ash disposal area. The sinkholes and surrounding area were subsequently filled in for the new facility construction. The burning ground and disposal area are now located 50-80 ft below ground. Between 1969 and 1973 the acid production facilities were built to support the new production lines. The facility was operated from 1971 to 1977. Underground acid sewer lines routed wastes to a diverter station near Pond 10, before eventual release to Waconda Bay via the Surface Water Discharge Area. In 1978, construction of the Industrial Liquid Waste Treatment Plant (ILWTP) was completed. Whether the ILWTP ever received and treated wastes from the New Acid Area is unclear (IT Corp 1994; Army 2003a, Public Comment 2004b). In 1981, surface water and sediment samples were collected at the New Acid Area as part of an ES, and sediment samples were collected again in 1983 as part of a CS. Detectable levels of arsenic, chromium, lead and explosives were found in these samples. A SI in 1994 sampled groundwater, surface water, and sediment. Groundwater is addressed under VAAP-35. Surface soil was not collected because the site is mostly paved. VAAP-33 is a part of Drainage Basin B, sediment and surface water contamination in Drainage Basin B is addressed and reported under VAAP-1.

A site investigation in 1999 detected arsenic (to 48 ppm) above its CV in soil. A RFI was scheduled to begin in 2002 and to be completed in July 2003 (Army 2003a).
VAAP-35 evaluates groundwater.

There is no current exposure of local residents to contaminants at this site. No exposure is expected for future recreational users enjoying other portions of the post. Re-use plans indicate VAAP-33 will continue to be used as an industrial area. Additional investigations and remediation actions, under TDEC and EPA oversight, are ongoing. Resulting actions are expected to protect the health of all future on-site workers.
VAAP-34: Industrial Surface Water Pollution Control Facility (Waste Water Treatment Ponds)
VAAP-34 is located in the northwest corner of VAAP. The site is partially outside the perimeter of VAAP, and drains into the southern tip of Waconda Bay (Army 2003a). This site is also included in VAAP-32. The site consists of the drainage ditches, equalization ponds and related facilities that drain some of the major suspected contamination source areas (i.e., Old Acid Area, CFI Lease Area, TNT Manufacturing Valley, and New Acid Area) into Waconda Bay, north of VAAP (Army 2003a). These ponds may be a source of contamination to groundwater at VAAP; therefore further action at this site will be addressed under VAAP-32 and VAAP-35 (Army 2003a). The public health concerns were addressed in VAAP-32.
VAAP-35: Groundwater (VAAP-1, 2, 5, 6, 15, 16, 18, 20, 21, 23, 32, 33, 34)
VAAP-35 includes VAAP-1, 2, 5, 6, 15, 16, 18, 20, 21, 23, 32, 33, and 34. This covers most of VAAP, and ventures to characterize on-site groundwater throughout the facility (Army 2003a). From 1942 to 1977, VAAP operated as a TNT production facility. The western portion of the site also supported a fertilizer plant (ammonium nitrate) from 1962 until 1982. As a result of these operations and associated processes, contaminants have been released to the groundwater underlying the site. The nature and extent of groundwater contamination at VAAP has proved difficult to characterize due to the karst geology and groundwater flow patterns at the site (Army 2003a).

On-site groundwater contamination (mainly explosives, arsenic, and lead) and off-site migration has been confirmed at VAAP. Therefore, VAAP has undertaken an extensive groundwater monitoring program. Currently, supplemental RI activities are being performed, additional monitoring wells are being installed, and well surveys and investigations are being conducted. A RFI to collect time-series and other pertinent data for all groundwater basins will begin in 2002 and finish in 2005 (Army 2003a).
Groundwater at VAAP has not served as a water supply for on-site VAAP-related activities.

Beyond VAAP boundaries, some residents historically used private wells as water supplies. Sampling indicates that contamination was found in these wells; however data are insufficient to determine if adverse health effects could have occurred. Private wells are no longer used for drinking water and municipal sources have not been contaminated (TDEC 2003a). Ongoing monitoring ensures the protection of the municipal water supply sources. Residential well sampling data indicates some wells have been impacted by VAAP-related contaminants. Most concentrations are below levels of health concern. ATSDR recommends that people who want to use their private well as a drinking water source or to fill their swimming pool should have their well periodically tested.
Sources: Army 2003a, 2004a, 2004b; Bonds 1985; CDM 2002; CoC/HC 2000; IT Corp 1994, 2001; TDEC 2003a

Notes:
AOC Area of Concern
ATSDR Agency for Toxic Substances and Disease Registry
CFI CF Industries, Inc.
CMS Corrective Measure Study
CS Confirmatory Survey
CV Comparison Value
EPA U.S. Environmental Protection Agency
ES Exploratory Survey
IAP Installation Action Plan
ILWTP Industrial Liquid Waste Treatment Plant
FS Feasibility Study
ft feet
ft2 square feet
lbs pounds
PAH Polyaromatic hydrocarbon
PCB Polychlorinated biphenyl
RCRA Resource Conservation and Recovery Act
RFA RCRA Facility Assessment
RFI RCRA Facility Investigation
RI Remedial Investigation
SI Site Investigation
SS Supplemental Sampling
TDEC Tennessee Department of Environment and Conservation
TNT Trinitrotoluene
TNTMV TNT Manufacturing Valley
VAAP Volunteer Army Ammunition Plant


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