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This section examines the pathways for exposure to contamination atFort Eustis. We will examine each of the media (water, air, soil, foodchain)to determine whether contamination is present, and if people in the communityare exposed to (or in contact with) the contamination. If people are exposedto contamination in any of the media, we will evaluate whether there isenough contamination to pose a hazard to people in the community. Thisanalysis will follow the pattern depicted in Figure 1, and will systematicallyevaluate each of the media.

Evaluation of Possible Biota/Foodchain Exposure Pathways

The FDA (U.S. Food and Drug Administration) Action Level for PCBs infish is 2.0 parts per million (ppm), or 2,000 ppb. The Great Lakes FishAdvisory Task Force (GLFATF) uses 1.9 ppm as the maximum amount of PCBcontamination in fish tissue that could be safely eaten. The GLFATF recommendsthat no fish be eaten that are contaminated at these levels (5).FDA and GLFATF PCB advisory levels for consumption by the general publicof PCB-contaminated fish are shown in Table 2. The recommendations of theGLFATF will be referenced in recommendations made in this document. (Note:EPA Region III uses a risk-based approach to arrive at safe PCB levelsthat may in fact be lower than the FDA limits.)

Table 2.

Fish Consumption Advisory Levels
Table 2 - Examples of Fish ConsumptionAdvisory Levels for PCBs in Fish
Food and Drug Administration (FDA)
- No Consumption 2.0 ppm
Great Lakes Fishing Advisory Task Force (GLFATF)

- No Consumption >1.9 ppm
- 6 meals/year 1.1 - 1.9 ppm
- 12 meals/year 0.21 - 1.0 ppm
- 52 meals/year 0.06 - 0.2 ppm
- unrestricted 0 - 0.05 ppm

"meal" is defined as consisting of an 8 ounce (raw weight)fish fillet

Bailey's Creek

PCBs have been detected in the water and in biota samples collectedfrom Bailey's Creek.

Samples of localized populations of fish from Bailey's Creek are contaminatedabove the FDA suggested limit. Based on information obtained from the RIfor Bailey's Creek, PCBs in catfish muscle were detected at a maximum of29,200 nannograms/gram, (ng/g, or parts per billion, ppb) (4).Since levels exceed FDA action levels and GLFATF advisory levels forconsumption of PCB-contaminated fish, consumption of aquatic life fromthis creek may be hazardous. It should be noted that the levels foundwere determined from dry weight samples, not from whole or wet weight samples(4). (FDA and GLFATF advisories are based on wet weightanalysis.) Dry weight samples are only a fraction (generally around 5 -15 percent) of the total amount of flesh. This being the case, the actualconcentrations in the whole edible portion could be 7 to 20 times lowerthan that found in the dry weight fraction. According to information providedby Fort Eustis, the dry weight proportion for this specific catfish was5.51% (4). As a result, the actual concentration couldbe as low as 1,609 ppb (1.61 ppm). Although 1.61 ppm is below the levelsuggested by FDA and GLFATF for prohibiting any consumption, it exceedsthe suggested GLFATF standard of 210 ppb (0.21 ppm) for limited consumptionof 6 to 12 meals per year which would be possible by frequent users ofthis lake (5). (See Table 2).

Analysis of additional wet-weight samples collected from Bailey's Creekcould clarify this matter. However, it is uncertain that much fishing occursin the affected portions of Bailey's Creek. PCB levels may be high enoughthat frequent and regular consumption is not recommended. A usagesurvey could determine whether individual anglers use the affected areasof Bailey's Creek occurs often enough that fish consumption may be a publichealth hazard. However, the Army has announced plans to work with the Commonwealthof Virginia to place Bailey's Creek off-limits to anglers (6).If emplaced, this action will be protective of human health.

Eustis Lake

PCBs and other contaminants have been detected in Eustis Lake. As aresult of the ongoing remedial activities at Ft. Eustis, Eustis Lake hasbeen posted as a catch-and-release lake. Further environmental data analysesis planned to determine whether the catch-and-release measures should remainin effect.

In the text of the Draft RI for Fort Eustis, PCB levels in catfish livertissue from Eustis Lake were cited at a maximum of 2,000 ppb, or 2.0 ppm.This level equals the FDA action level and is greater than the advisorylevel for the GLFATF (5). However, PCB levels in livertissue can not be directly correlated with edible portions of the fish.In order to clarify this issue the Army has recently collected additionalsamples of several species of fish from Eustis Lake (10).A number of samples were collected of white catfish, largemouth bass, blackcrappie, gizzard shad, bluegill sunfish and carp. Of these fish, catfish,shad and carp had PCB (specifically, Aroclor 1260) levels exceeding therecommended maximum levels for safe consumption. In catfish, Aroclor 1260levels ranged up to 2.85 ppm. In shad, Aroclor 1260 ranged to 2.63 ppm.The maximum Aroclor 1260 concentration in carp was 9.43 ppm (10).Based on the PCB levels detected, consumption of these three speciesis not recommended.

PCBs were detected in the bass at levels up to 0.64 ppm (Aroclor 1260).At this level of PCB contamination, consumption should be limited toabout one meal per month. In crappie, Aroclor 1260 was detected ata range of up to 0.07 ppm. At this level of PCB contamination, consumptionshould be limited to no more than one meal per week. PCBs levels in bluegilldid not appear to represent a public health hazard.

The Fort Eustis fish consumption risk assessment (10)recommends continuation of the fishing advisory prohibiting consumptionof all six species. Continuation of this advisory is certainly protectiveof public health.

Brown's Lake

Carp and catfish muscle samples collected from Brown's Lake were foundto contain total PCBs ranging from 0.094 ppm to 0.133 ppm. According tothe GLFATF advisory, consumption of fish contaminated with PCBs at theselevels should be limited to about one meal per week. Accordingly, Brown'sLake should continue to be included in the Fort Eustis fishing advisory.Limiting or prohibiting consumption of fish from this lake is protectiveof public health.

Evaluation of Possible Surface Water Exposure Pathways

People can be exposed to contaminated water by drinking it, bathingor swimming in it, or, breathing vapors in steam (for instance, in a hotshower). There are two main water pathways to consider. These pathwaysare:

  • surface water, that is, ponds, lakes, creeks, and the sedimenton the bottom and along the edges of these water bodies.
  • groundwater, that is, water from wells, either private wellsor public water supply wells,

Surface Water

Contamination of surface water is an issue of potential concern throughoutFort Eustis because of either the detection of contaminants in water orin fish inhabiting these waters. In particular, the following water bodieshave documented or suspected contamination: Milstead Island Creek, EustisLake and Brown's Lake, and Bailey's Creek. The Warwick River comprisesthe eastern boundary of Fort Eustis, and is supplied in part by tributariesemanating from the installation. As a result of this geographic relationship,if contamination were to reach this water body, the possibility would existfor exposure to occur.

Milstead Island Creek

High concentrations of fuel and oil products were detected in surfacewater samples collected in 1993 from Milstead Island Creek. Concentrationsranged from 12,000 to 910,000 ppb. Based on ATSDR's recommendation, FortEustis conducted a supplementary site inspection of this area to determinea source for these contaminants and to determine if a hazard exists. Tensurface water samples were collected from Milstead Island Creek in thearea where previous sampling had detected the contamination (8).

In the 1996 survey, total petroleum hydrocarbons (TPH) were not detectedin any of the ten samples. The detection limit was 0.5 ppm. Even in theevent that TPHs were present below the detection level, it is not likelythat exposure would present a public health hazard. Milstead Island Creekis relatively remote and not likely to be regularly visited. The type ofcontact that would occur is expected to be dermal exposure through short-termand infrequent wading or incidental ingestion. The short-term and infrequentdermal contact that would occur, or the incidental inhalation or ingestionwould not be likely to result in a public health hazard (11,12).

Eustis Lake

Although water samples were not collected from Eustis Lake, there isindirect evidence of possible PCB contamination in this lake. Catfish collectedfrom this lake were found to have elevated PCB levels in their internalorgans. For significant adverse public health effects to occur, dermalcontact to relatively low levels of PCBs must be frequent and long-term.The relatively infrequent and short-term contact associated with recreationaluse of the lake would generally preclude significant exposure. Unlesswater samples from Eustis Lake are analyzed, the public health implicationscan not be addressed. However, it is unlikely that exposure to significantamounts of PCB will occur through contact with water from Eustis Lake.

Brown's Lake

Surface water contaminants in Brown's Lake are VOCs, fuel products,and lead (13). These chemical are not present at levelsthat might be of public health hazard via ingestion (drinking), and nothigh enough to present a hazard via short-term and infrequent dermal contactthat would be expected from swimming or wading in the lake. Therefore,ingestion or dermal exposure to contaminants in water are not public healthhazards at Brown's Lake.

Bailey's Creek

Only limited surface water sampling (six samples) has been done at Bailey'sCreek. Low concentrations of PCBs and metals have been detected in thewater samples collected (13). Based on the analysisof these samples, surface water contamination does not appear to pose apublic health hazard.

Warwick River

Monitoring of two small tributaries of the Warwick River is conductedon a regular basis as a part of the RI. To date, this monitoring hasnot detected any appreciable contamination that might reach the WarwickRiver (4).


Groundwater is not used for domestic purposes onsite. Water for domesticuse is provided by municipal water supplies (7). Thewater is supplied from a city reservoir located to the north of the post.As a result, there is no potential for public health hazard resultingfrom contact with contaminated groundwater.

Analyses of groundwater samples in the vicinity of the IRP sites onthe eastern side of the facility show that contaminant plumes are small-scaleand localized (13). Since this is the case, no significantcontaminants have reached as far as the Warwick River, so that groundwatercontaminants from Fort Eustis have not reached the main portion of theJames-York Peninsula.

Evidence presented in the RI suggests that the shallow aquifer is stronglyinfluenced by recharge from overlying surface water bodies. As a result,recharge from the Warwick River would serve as a effective barrier to anycontaminant plume that might originate from under Fort Eustis.

Evaluation of Possible Sediment Exposure Pathways

The principal concern for exposure to contaminated sediments is throughdermal contact. Sediment samples were collected from Brown's Lake, Bailey'sCreek, and Milstead Island Creek. Samples collected from the lake and creekbottoms may not be directly accessible to people. However, these samplescan provide insight into the possibility of harmful exposures for moreaccessible sediments, such as those along the edges of the water bodies.

Eustis Lake

Although analysis of sediment samples collected from Eustis Lake didnot detect PCBs, there is indirect evidence of possible contamination foundin the elevated PCB contamination found in organs from catfish collectedfrom this lake. As in the case of surface water, for significant adversepublic health effects to occur, chronic, long-term dermal contact to relativelylow levels or dermal contact with extremely high levels of PCBs would benecessary. Also, the relatively infrequent and short-term contact thatwould be likely would generally preclude significant exposure. Untilsediment samples from Eustis Lake are analyzed, the public health implicationsof exposure to sediment at Eustis Lake can not be addressed. However, itis unlikely that exposure to significant amounts of PCB will occur throughdermal contact with the sediment of Eustis Lake.

Brown's Lake

Sediment contaminants in Brown's Lake are PAHs, PCBs, fuel products,and metals (13). The levels detected are not highenough to present a public health hazard via short-term and infrequentdermal contact or incidental ingestion that would be expected from wadingalong the edges of the lake. Therefore, exposure to contaminated sedimentis not a public health hazard at Brown's Lake.

Bailey's Creek

Lead, PCBs and fuel products appear to be the principal contaminantspresent in Bailey's Creek sediment. The sampling survey of 1990 found leadlevels as high as 270,000 ppm. It should be noted that the areas of highlead concentration are located within the post skeet-shooting range. Thevery high concentration could be considered an anomaly representing a shotgunpellet, rather than lead-contaminated sediment. Although elevated leadlevels are found in these sediments, the potential for significant dermalcontact and absorption is very slight for individuals who may enter theskeet range. This is because such activity would be infrequent and shortterm, and also because lead is not easily absorbed through the skin (14).

PCB levels as high as 400,000 ppb have been detected in sediments. Thisis the highest concentration found and probably is not representative ofcontamination throughout Bailey's Creek. However, several samples in the1990 sampling round contained concentrations of PCBs ranging from 150 to1,400 ppb (13).

Dermal contact with sediment at Bailey's Creek would be short-term andinfrequent. Actual exposure to skin would be limited, because a tidal creekand marsh environment is not a likely site for people to walk through withoutshoes or boots. Dermal exposure to sediments in this situation willnot result in a public health hazard (15).

Milstead Island Creek

Low levels of PAHs, VOCs, and fuel products were detected in sedimentsof Milstead Island Creek. Based on sampling conducted in 1990 (13),there do not appear to be contaminants present in sediment at levels thatwould present a public health hazard.

Evaluation of Possible Soil Exposure Pathways

Soil contamination has been documented at several of the IRP sites withinFort Eustis. The contaminants present are metals, VOCs, PAHs and petroleumfuel products. The areas are generally fenced or have public access otherwiserestricted. As a result of these institutional controls (and as longas such controls are diligently maintained) these soil contamination sitesdo not represent a hazard to public health.

Evaluation of Possible Air Exposure Pathways

Air sampling is not planned for the remedial investigation at Fort Eustis.However, the type of activities occurring at Fort Eustis are not generallyassociated with the production of significant amounts of contaminationinto the air. As a result, there does not appear to be any significantexposure of the public to contamination via air pathways.

Evaluation of Possible Exposure to Physical Hazards

Mulberry Island has been an artillery range in the past and continuesto serve that function today. As such, there is an expected hazard fromunexploded ordnance. Access to this area is restricted by institutionalcontrols and warning signs are posted. Other than access through the mainpost, there is no means of entry except by boat. Seasonal hunting, understrictly controlled conditions, is allowed. Hunter access to Mulberry Islandis restricted to areas cleared of unexploded ordnance, and is only allowedafter a safety briefing is given by post representatives. In view ofthese precautions, there do not appear to be any hazards associated withthe artillery ranges beyond those expected in an area serving this purpose.


In preparing this Public Health Assessment, ATSDR relies on the informationprovided in the referenced documents. The Agency assumes that adequatequality assurance and quality control measures were followed with regardto chain-of-custody, laboratory procedures, and data reporting. The validityof the analyses and the conclusions drawn in this document are determinedby the availability and reliability of the referenced information.

The majority of the environmental data presented in this public healthassessment is from the Remedial Investigation (RI) report. Generally, themethodology used in the RI is appropriate for characterizing contaminationat Fort Eustis. Additional information collection is planned during completionof RI activities. This information will be evaluated by ATSDR. Conclusionsand Recommendations of this PHA will be modified if appropriate and necessary.


Public health concerns were investigated by ATSDR through meetings,correspondence, telephone conversations and information from Fort Eustis,EPA, state and local agency files. Draft versions of this document wereprovided to the Fort Eustis, the EPA, state regulatory agencies and wereprovided to the public repositories. All comments and suggested revisionswere incorporated in this final version.

Community concerns were voiced about the PCBs levels found at Bailey'sCreek. The effect on public health of this contamination is discussed indetail above. Dermal exposure to sediments in this situation will not resultin a public health hazard. Elevated levels of PCB have been found in fishtaken from Bailey's Creek. Because of questions on the analytical techniquesused (i.e., dry-weight analyses), it is not possible to state definitivelywhether consumption of these fish would be a public health hazard. Additionalinformation is needed to determine the current PCB levels and to ascertainthe amount of fishing that occurs at Bailey's Creek.

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