Comment Form Remedial Investigation Work Plan, Anacostia River Sediment Project, Washington DC Commenter/ Section/Table/Figur Page Number Representative Organization Type e Nos. No. Comment Response The discussion of Sources does not seem to treat the re-suspension of in situ legacy sediments as a source of the toxics under The re-suspension and re-deposition of sediments is expected to occur during storm inv estigation. It may well be that a major source of the toxic sediments in any one place is depostion of these resuspended toxic ev ents and is a secondary source of sediment contaminants. The relativ e Anacostia materials af ter they hav e been stirred up by storms , dredging or other ev ents. While the extent of this source and the nature in which it signif icance of this process is dif f icult to quantif y and would v ary f rom storm to Watershed Citizens 1 William Matuszeski Env ironmental Group 3.1.2 24 deliv ers these toxics is dif f icult to determine, it is important to establish its relativ e contribution as a source. storm. Although the concentration distribution in sediments is expected to change in Adv isory response to these processes ov er time, the sampling approach presented in the RI Committee Work Plan will prov ide the data needed to support an ef f ectiv e f easibility study . The discussion of Ongoing Activ ites should include a detailed discussion of the current ef f ort by EPA and DCDOE to develop a new Total DDOE is engaged in an ef f ort to characterize the tributary mass loadings of the key Maximum Daily Load f or toxics in the Anacostia. Some of the monitoring and inv estigativ e ef f orts being carried out as part of the TMDL contaminants that are present in the riv er sediments. Giv en the complexities dev elopment could be usef ul to the RI and the FS. Furthermore, the TMDL should be identif y ing sources of the toxics and the inv olv ed, that ef f ort will be conducted independent of the RI and will consider resuspension of existing sediments bearing toxics may be a pathway . Ultimately , the Wasteload Allocation dev eloped under the TMDL prev ious and ongoing EPA ef f orts to dev elop new TMDLs f or the Anacostia Riv er. should be integrated with the remediation plan resulting f rom this RI/FS, and the desire and commitment to do that should be included here. DDOE believ es that sediment sampling results can help def ine goals f or the TMDL Anacostia program, which is separate and distinct f rom the RI. An appropriate role f or the RI is, Watershed Citizens 2 William Matuszeski Env ironmental Group 2.6 10 theref ore, to make appropriate recommendations regarding TMDL monitoring priorities. Adv isory Since any such recommendations must await the perf ormance of f ield sampling f or Committee the RI and associated analy sis and reporting, the RI report is the appropriate v enue f or indicating any such recommendations. No changes will, theref ore, be made in response to this comment. Anacostia While the dominant transport medium may be downstream migration, as stated in 3.1.5, it is important to understand the extent to which Comment acknowledged. As noted in the response to Comment #1. the sampling Watershed Citizens the tidal Anacostia transport sy stem f or sediment is chronic v ersus ev ent-driv en. A sy stem that is storm-ev ent driv en will obtain a larger approach presented in the RI Work Plan will prov ide the data needed to support an 3 William Matuszeski Env ironmental Group 3.1.5 and 3.1.6 31-32 Adv isory share of its loadings f rom the disturbance of insitu sediments and f rom bank erosion. In contrast, if the movement is ongoing and not ef f ectiv e f easibility study . Committee particularly variable with storm events, it may be easier to evaluate the rates and lev els of material transport. The monitoring being done Theb EPAdiscussion f th of TMDL Sources f suggests l that idthere may well h lf continue i h i to be ttoxic loadings f f i t tentering the thsy stem i bilitf rom upstream b t th t tributar llies, b t As noted in the response to Comment #2, DDOE is engaged in an ef f ort separate including the Northeast and Northwest Branches and Lower Beav erdam Creek. Since these are all in Mary land, it is important to indicate in f rom the RI to characterize the tributary mass loadings of key tributaries including Anacostia the Workplan how and how soon DOE will be engaging coiunty and state of f icials to assure timely consideration of data needs and Northeast Branch, Northwest Branch, and Lower Beav erdam Creek. Section 3.1.2.2 Watershed Citizens 4 William Matuszeski Env ironmental Group 3.1.2 24 ultimately remedies. will be rev ised to indicate that DDOE is in the process of exploring with the Mary land Adv isory Department of the Env ironment and other gov ernmental entities strategies f or Committee ev aluating the loadings of contaminants to the Anacostia Riv er v ia tributary inf lows. It is essential that the schedlule f or the RI /FS be rev ised to ref lect the delay s caused by non-prof essional rev iews within the DC DDOE is taking and will take all reasonably necessary steps to ensure ef f icient Gov ernment. Once that is done, the new schedule should include no time f or such unnecessary rev iews in the f uture and should set out administration of rev iews associated with the Anacostia Riv er sediment project. an achiev able set of dates. Ef f orts should be made to warn potential permit authorities of the anticipated need f or permits as well as the Additionally , DDOE and Tetra Tech are f requently in contact with all permitting importance of ef f icient handling of permit applications. In the past this has been a problem, especially with the National Park Service. authorities to ensure permit approv als are as expedited as possible. Anacostia Watershed Citizens 5 William Matuszeski Env ironmental Group 10 95 Adv isory Committee The Objectiv es are not well-aligned with the purpose of the study as outlined in the DDOE scope of work which is as f ollows: "The purpose Section 1.1 will be rev ised to discuss the alignment of Work Plan objectiv es with the of this statement of work (SOW) is to identif y the existing sources of sediment contamination in the Anacostia Riv er, to ev aluate the objectiv es indicated in the Statement of Work (SOW). The discussion will note the Chesapeake Bay 6 Beth McGee Env ironmental Group Section 1.1 Objectiv es 1 nature and extent of contamination in the sediments in the tidal portion of the Anacostia Riv er and conduct f easibility study to dev elop and SOW objectiv es that are explicitly addressed in the RI v ersus the SOW objectiv es Foundation ev aluate potential remedial actions to eliminate unacceptable risk to human health and the env ironment. " and includes dev eloping that will be addressed in companion ef f orts. monitoring plans f or outf allls and other sources. There is no mention of monitoring in the workplan. The statement that prev ious sampling in the Anacostia Riv er was concentrated near env ironmental areas of concern along the banks of the The ref erenced text indicating that Anacostia sediment inv estigations hav e been Chesapeake Bay riv er is not true. The ANS study and McGee et al 2009 were designed to be representatiav e of riv er conditions. env ironmental areas of limited to the responsible party (RP) sites will be rev ised to state that while most 7 Beth McGee Env ironmental Group Section 4.1 and Table 4.7 and 3 Foundation concern along the banks of the riv er is not true. studies hav e f ocused on the RP sites, sev eral studies hav e ev aluated conditions throughout the tidal riv er. The proposed approach includes sampling porewater, subsurf ace sediments and surf ace water. The rationale f or these analy ses is not Pore water will be collected as a parameter to support the ecological ev aluation of supported. shallow sediment conditions and to prov ide parameters required f or f easibility study . Chesapeake Bay 8 Beth McGee Env ironmental Group Table 4.1. Step 3 39 In addition, the data will support initial screening f or potential zones of groundwater Foundation impact to shallow sediment. Table 4.1 and associated text will be rev ised accordingly . As noted abov e, we don't not think subsurf ace sediment sampling is justif ied broadly in the riv er. There will be v aluable inf ormation f rom The text will be rev ised as noted abov e to expand on the discussion of the rationale site specif ic studies that might help determine where additonal subsurf ace samples should be collected, to tie sources with contamination, f or the collection of deep sediment and pore water samples. As noted abov e, pore but a broad scale assessment is not justif ied and would not be a good use of limited dollars. Porewater is proposed as an indicator of water is essential f or ev aluating benthic env ironmental conditions and f or prov iding Chesapeake Bay exposure f or benthic animals.