Gainesville West Data Center

 The Atlantic Research Corporation former Superfund Site (VAD023741705) at 5945 Wellington Road, Gainesville, VA is being redeveloped into a series of Data Centers by Amazon Corporation. The site is 117 acres in the Data Center Overlay District. They have applied for a Special Use Permit to increase the height of the buildings to 100 feet from the 75 allowed by right. Currently, the site is being graded for construction.

 As part of the redevelopment plan the on-site stream is being reconfigured and moved. In the planning package there are no permits for moving the stream or studies if the site development and stream relocation will impact the stability of the site institutional controls or create a pathway of exposure for the contaminants known to remain in the groundwater. In addition, the Environmental Constraints Analysis has been waived by the county along with the Perennial Flow Analysis for the on-site stream.

In a June 14, 2018 the U.S. EPA indicated that ARC had satisfactorily completed corrective actions pursuant to the CMI Order, Sections VI. H7 and I8.  In addition, Atlantic Research Corporation had taken Interim Measures to address perchlorate and other constituents of concern in soils.  However, EPA approved leaving contaminants in soil at the site above residential risk management levels, and at concentrations above risk-based standards in groundwater.  To ensure that the contaminants left on site would not injure the public or leave the site,  the regulators required that the Final Facility-wide remedy include ongoing groundwater monitoring and Institutional Controls (IC) Including:

• Groundwater use restriction on the entire Facility
• Soil is restricted on certain areas of the western parcel and included as part of the IC plan.
• Vapor Intrusion controls are required for a specific area shown on a figure of the IC plan representing groundwater exceeding VISL.

According to the U.S. EPA website Atlantic Research Corporation continues to operate and manage a groundwater extraction and treatment system (Northern Deep Treatment System) with performance monitoring at on-site monitoring wells locations, including monitoring wells located at the downgradient property boundary. The groundwater extraction system includes approximately 53 monitoring wells that are sampled semi-annually or annually.

Constituents of concern (COCs) currently meet risk-based cleanup standards at the downgradient property boundary and there has been no off-site groundwater or surface water contaminant migration detected.

Pollution of surface water can cause degradation of ground-water quality and conversely pollution of ground water can degrade surface water. Thus, effective land and water management requires a clear understanding of the linkages between ground water and surface water as it applies to any given hydrologic setting. Within Prince William County Virginia there are four distinct geologic provinces: (1) the Blue Ridge, (2) the Culpeper Basin, (3) the Piedmont, and (4) the Coastal Plain. The U.S. Geological Survey divides the four geologic provinces of the county into seven hydrogeologic groups based on the presence and movement of the ground water calling them groups: A, B, B1, C, D, E and F.

It appears that in the area of this particular site, hydrogeologic group B and C are present.

Hydrogeologic group B underlies the western part of Prince William County and consists of sedimentary rocks of the Culpeper Basin. The predominant rock types are conglomerates, sandstones, siltstones, shales, and argillaceous limestones. Rocks within hydrogeologic group B tend to have moderate to excellent water-bearing potential because it is a fractured rock system with very little overburden. The highest reported yields in the county are from wells located in this hydrogeologic group, but this hydrogeologic group is susceptible to contamination- the fractures that carry water can easily spread a contaminant and without adequate overburden spills could flow to depth through a fracture.

Hydrogeologic group C, which is interspersed throughout the area of groups B and Bl, in the western part of the County, consists of igneous rocks (basalt and diabase) of the Culpeper Basin. The rocks of group C are Early Jurassic in age. The predominant rock types are basalt, sandstone, siltstone, diabase, hornfels, and granofels. Rocks within hydrogeologic group C tend to have generally poor water-bearing potential because of the wide spacing between fractures, mineralization of fractures, and random fracture orientations.

I am concerned that development of the site and relocation and reconfiguration of the stream could potentially mobilize the chemical constituents of concern known to remain on-site:

Tetrachloroethylene (PCE), 1,1-Dichloroethene (1,1-DCE), Methylene Chloride, 1,1,1-Trichloroethane, 1,1,2-Trichloroethane, 1,1-Dichloroethane (1,1-DCA), 1,2,3-Trichloropropane, 1,2-Dichloroethane (1,2-DCA), Benzene, Carbon Tetrachloride,  Chloroethane, cis-1,2-Dichloroethene, Trichloroethene (TCE), Vinyl Chloride (VC), Perchlorate and 1,4-Dioxane.  The following COCs exceed vapor intrusion screening levels: PCE, TCE, VC, Benzene, 1,1-DCA, 1,2-DCA, and 1,1-DCE.

The U.S. EPA, VA DEQ maintain responsibility for the site. The specific address/Parcel ID from the special use approval does not have a joint permit application in process or an active VWPP permit. Any surface water impacts from the eventual data center would likely require a Virginia Water Protection Permit (VWPP) and a permit from US Army Corps of Engineers.

Though it is likely that such an application is being developed, because surface water impacts are ultimately proposed; however, the applications for the required permits have not been submitted to DEQ/USACE and the site is being graded without regard for the soil restrictions in the institutional controls and to all appearances the perennial stream and RPA has been wiped out.  No RPA  hearing was held. This should not happen. The environmental regulations and institutional controls exist to protect the community and essential water resources from exposure.

It is important that the U.S. EPA, VA DEQ  and USACE (who maintain responsibility for the site) approve the planed changes to the site that may impact the institutional controls and hydrology and determine if additional monitoring is necessary to ensure that the COCs are not mobilized to leave the site, before excavation and site work begin. Not after construction. The regulations are to protect us. The  county has failed in its duty and is not protecting the interests of the pubic in waiving the Environmental Constraints Analysis, RPA disturbance hearing, and granting the excavation permit ahead of the VWP permit.