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Superfund Program Proposed Plan

Dates to Remember

July 31, 2003 to August 30, 2003
Public comment period on alternatives in Proposed Plan.

August 14, 2003
7:00 pm
Public meeting at the Warren County Government Center
220 N. Commerce Avenue
Front Royal VA 22630

Operable Unit 10
Avtex Fibers Superfund Site
Front Royal, Warren County, Virginia
July 31, 2003


EPA Announces Cleanup Plan

INSIDE

  1. Introduction
  2. Site Background and History
  3. Site Characteristics
  4. Scope and Role of Operable Unit 10
  5. Summary of Site Risks
  6. Remedial Action Objectives
  7. Summary of Remedial Alternatives
  8. Evaluation of Alternatives
  9. Preferred Alternatives
  10. Community Participation

I. Introduction

The United States Environmental Protection Agency (EPA) presents its Proposed Remedial Action Plan (Proposed Plan) for Operable Unit 10 (OU-10) at the Avtex Fibers Superfund Site (Site) in Front Royal, Virginia. OU-10 is composed of three management units: Viscose Basins 1-8, the New Landfill, and Plant Area Soils. This Proposed Plan presents background information about the Site, describes EPA's preferred alternative and the rationale for this preference, describes other remedial alternatives considered for this OU, solicits public review and comment on all of the alternatives described in this Proposed Plan, and provides information on how the public can be involved in the remedy selection process.

This Proposed Plan is being issued as part of EPA's public participation requirements under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the federal law that governs the Superfund program. This Proposed Plan summarizes information that can be found in greater detail in the Feasibility Study Report for OU-10 (FS). Additionally, the Proposed Plan relies on risk assessment information contained in the following two documents:

These documents are available for review in the Administrative Record file for the Site at the following locations:

Samuels Public Library

538 Villa Avenue
Front Royal, VA
540-635-3153

U.S. EPA - Region 3 Docket Room

Ms. Anna Butch
1650 Arch Street
Philadelphia, PA 19103
215-814-3157

The Administrative Record File can also be viewed at http://www.epa.gov/arweb/ or at the Administrative Record link on the sidebar of the U.S. EPA Region 3 Hazardous Waste Site Cleanup Division homepage at http://www.epa.gov/reg3hwmd/

EPA will select a final remedy for these units only after a 30-day public comment period beginning on July 31, 2003 and ending on August 30, 2003. On August 14, 2003 at 7:00 p.m., EPA will hold a public meeting at the Warren County Government Center, to discuss this Proposed Plan. Written comments, postmarked no later than August 30, 2003 should be sent to:

Megan Dougherty (3HS43)

Community Involvement Coordinator
U.S. EPA - Region 3
1650 Arch Street
Philadelphia, PA 19103
Phone: 215-814-5534

Bonnie G. Gross (3HS23)

Remedial Project Manager
U.S. EPA - Region 3
1650 Arch Street
Philadelphia, PA 19103
Phone: 215-814-3229

Interested persons are encouraged to submit their comments on this Proposed Plan to EPA during the public comment period. Although EPA has identified a preferred alternative, no final decision has been made. EPA, the lead agency for Site activities, in consultation with the Virginia Department of Environmental Quality (VDEQ), the support agency, may modify the Proposed Plan, select another response action, or develop another alternative based on comments received during the public comment period. EPA will announce the final selected remedy for the Site in a Record of Decision.

EPA is issuing this Proposed Plan as part of its public participation responsibilities under Section 300.430(f)(2) of the National Contingency Plan (NCP). This Proposed Plan fulfills the public notification requirements of Sections 113(k)(2)(B), 117(a), and 121(f)(1)(G) of CERCLA, 42 U.S.C. '' 9613(k)(2)(B), 9617(a), and 9621(f)(1)(G).

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II. Site Background and History

The Avtex Fibers Site is located in Front Royal, Virginia and occupies approximately 440 acres. Figure 1 shows a map of the property. The Randolph Macon Academy is located along the eastern property boundary. The former General Chemical plant is located along the northwest border of the Site. Residential areas are located to the east, south, and north of the property boundaries. The South Fork of the Shenandoah River is located along the western portion of the property. Drainage to the river occurs through overburden and bedrock ground water flow, and designed features such as the discharge from the onsite wastewater treatment plant (WWTP).

Operations at the Site began in 1940, when American Viscose opened a rayon production plant. In 1963, American Viscose sold the plant and property to FMC, and in 1976, the plant and property were sold by FMC to Avtex Fibers, Inc. Subsequently, Avtex Fibers, Inc. conveyed the plant and property to its wholly-owned affiliate Avtex Fibers-Front Royal, Inc. (hereinafter both companies will be referred to as "Avtex"). Rayon fibers were continually produced until the plant closed in 1989. Polyester and polypropylene were also produced over short periods of time.

In 1982, the Commonwealth of Virginia detected carbon disulfide in residential wells located across the South Fork of the Shenandoah River. In 1984, EPA proposed that the Site be addressed under the federal Superfund program. Between 1986 and 1988, Avtex conducted an investigation of the source and extent of the carbon disulfide in ground water. The investigation determined that waste viscose containing carbon disulfide was leaching from three of the eleven viscose basins (VB 9, 10, and 11). In 1989, EPA issued a Record of Decision which called for pumping and treating the ground water beneath and downgradient of VB 9-11. This remedy was subsequently suspended pending a Site-wide investigation.

Shortly after the 1989 Record of Decision was issued, Avtex shut down the facility. After the plant shut down in 1989, EPA initiated response actions to ensure there would be no uncontrolled releases of hazardous substances or other threats to human health and the environment. In the several years following the plant's shutdown, EPA responded to the various emergency and time critical conditions the Site presented.

With the Site becoming more stable, EPA and FMC entered into an EPA administrative order in 1993 for FMC to more thoroughly investigate the Site. In 1993 and 1994, EPA and FMC conducted a Site-wide investigation of buildings, sewers, waste disposal areas, onsite soils and ground water to assess the environmental condition of the Site. In 1999, EPA and FMC entered into a Consent Decree, which included work to be performed for OU-10. Work on the Feasibility Study was started in 2000 with the approval of a Feasibility Study Work Plan. The 1993 - 1994 Site-wide investigation, coupled with recent data collected during the Feasibility Study, have supported the identification of the preferred remedies for OU-10. The Feasibility Study Report was completed in July 2003 and is the basis for this Proposed Plan.

Operations at the plant generated three major waste types that were disposed at the Site. The first type was generated when the metal-bearing wastewater from the production process was treated with lime in the WWTP; the sludge generated by that treatment was placed in five sulfate basins. The second waste stream was fly ash generated from the combustion of coal in the onsite power plant. Fly ash was disposed of in four fly ash basins and one stockpile. The disposal areas for these two waste streams were addressed as part of the non-time-critical removal action (NTCRA) for basins. The final response action for the units was selected by EPA in an Action Memorandum dated January 31, 2000. Separate from the closure of OU-10, FMC is in the process of closing out the sulfate basins and fly ash units.

The third waste stream was waste viscose (an off-specification product of the production process) that was disposed in eleven onsite basins. Eight of these Viscose Basins (VB 1-8) are addressed as part of this Proposed Plan (Figure 1). VB 9-11 and Site-wide ground water are being addressed as a separate operable unit (OU-7).

This Proposed Plan also addresses the two units described below.

This is Operable Unit 10 for the Site. An unacceptable risk was identified for the future use of ground water as a potable water supply as documented in EPA's September 30, 1988, Record of Decision (ROD). This unacceptable risk triggered a remedial action associated with ground water at the Site. As previously mentioned, EPA issued a Record of Decision in 1989 which called for pumping and treating the ground water beneath and downgradient of VB 9-11. The 1989 ROD was subsequently suspended to address the groundwater risk comprehensively. EPA intends to deal with the ground water risk as OU-7 for the Site. Once EPA determines that a remedial action is needed at a Site, all areas of the Site must meet or waive all Applicable or Relevant and Appropriate Requirements (ARARs).

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III. Site Characteristics

Viscose Basins 1-8

Unit Description and Background

VB 1-8 occupy about 15 acres. The streams on the south side of VB 7-8 were determined to be Jurisdictional by the U.S. Army Corps of Engineers (USACE).

VB 1-8 were used for the disposal of waste or off-specification viscose, a sodium-cellulose xanthate based material. Figure 2 shows the original VB 1-8 basin configurations. The basins were constructed by excavating the native soil and pushing the soil to the outside of the basin to form the berms. After each basin was filled with waste viscose, it was covered with zero to eight feet of soil. VB 4-6 also contain construction debris and other non-hazardous waste that was placed over the viscose in the basins. The waste material consisted of demolition and construction debris, WWTP lime grit, air-dried sanitary sludge, off-specification crumb (cellulose which has been mercerized, chopped and aged), used filter media, unprocessed fiber, and tow (off-spec rayon yarn).

VB 4-6 were closed in 1983, when they were graded, covered with soil, and vegetated. After closure, plant wastes were placed into the New Landfill. Additionally, an estimated two thousand cubic yards of sodium sulfate (Globber salt) are currently located on the surface of VB 1 and VB 7. The salt, which is a white crystalline powder, has been covered with a plastic liner to prevent contact with rainwater.

It is estimated that the basins contain about 393,000 cubic yards (yd3) of commingled viscose and soil (final soil cover plus that which may have been used as daily cover during operations). This volume calculation also includes the construction debris and other landfilled materials in VB 4-6. The table below provides the years of operation, estimated areas, and thickness and volumes of waste and cover soils associated with VB 1-8. VB 2-3, 4-6 and 7-8 are shown in aggregate because they are conjoined and are best treated as an aggregate unit.

Viscose Basin Time Period for Viscose Disposal Area 1 (square feet) Basin Volume 2 (yd3) Soil Cover Volume (yd3) Soil Cover Thickness 3 (feet) Waste Thickness (feet) Thickness of Native Soil Underlying Viscose 3 (feet)
1 1940-42 55,000 15,000 3,900 0 to 3 feet 5 to 10 feet > 20 feet
2 & 3 1942-44 105,000 38,000 7,000 0 to 3 feet 2 to 10 feet 10 to 15 feet
4, 5, 6 1944-50 400,000 300,000 29,000 0.5 to 2 feet 2 to 29 feet 2 to 10 feet
7 & 8 1950-58 105,000 40,000 10,000 2 to 8 feet 1.5 to 15 feet 5 to 15 feet
Total   665,000 (~15 acres) 393,000 --- --- --- ---
  1. Basin areas determined using aerial photographs, historical Site maps, and current Site maps.
  2. Basin volumes include viscose, construction debris where present and soil cover, and are based on the information obtained from the 1993 boring logs.
  3. Soil thickness is an approximate range.

VB 1-8 do not have a liner or leachate collection system. Leachate seepage along the north side of VB 4-6 is collected in a trench and conveyed to a retention basin on the west side of the landfill, where it is then directed to the existing WWTP for treatment. The trench prevents the seepage from reaching the stream on the north side of VB 4-6. Currently, leachate from VB 4-6 is diverted to the existing onsite WWTP for treatment.

Twenty-four soil borings were drilled in VB 1-8 during the 1993-94 Remedial Investigation. Subsurface conditions beneath VB 1-8 were interpreted based on the drilling logs for these soil borings and surrounding monitoring wells. These interpretations include the following subsurface conditions:

  1. The basins are covered with a layer of soil ranging in thickness from about 0 feet to 8 feet;
  2. The thickness of the viscose and other waste in the basins ranges from about 1.5 to 29 feet; and
  3. Soil layers are interbedded with viscose waste at many locations, indicating that interim soil cover was used during the operational life of the basins.

Detections of combustible gas that exceeded the lower explosive limit (LEL) and hydrogen sulfide (H2S) were also characteristic of many of the soil borings drilled in the basins. Methane was believed to be the source of the combustible gas readings. Methane and hydrogen sulfide are likely formed during the decomposition of the viscose waste. No ambient odors have been attributed to gas released from VB 1-8.

Piezometers constructed within VB 1, 2, 3, and 7 in 1988 contained about 10 feet of water. These water levels indicate that the basins act as "bathtubs" by containing precipitation that infiltrates through the current soil covers. Water level data collected from monitoring wells surrounding the basins indicate that the natural water table in the overburden soil is about 10 to 15 feet below the bottom of VB 1-3 and 7.

The hydrology of VB 4-6 and VB 8 is believed to be similar to that found in VB 1-3 and 7, although piezometers were not installed into these basins. The seeps present on the north side of these basins result from perched leachate that discharges onto the land surface between elevations 500 and 510 feet.

Nature and Extent of Contamination

Viscose and Soil Evaluation
Samples of viscose and soil were collected from a surface soil (< 2 feet deep) and the 24 borings drilled in VB 1-8 (surface and subsurface samples) and analyzed for organic and inorganic parameters. Numerous metals, Volatile Organic Compounds (VOCs), and Semi-volatile Organic Compounds (SVOCs) were detected in these samples. The primary SVOCs were Polynuclear Aromatic Hydrocarbons (PAHs). The table below provides a comparison of contaminant concentrations with the U.S. EPA Region 3 Risk-Based Concentrations (RBCs) for industrial soil exposure at an excess cancer risk level of 1x10-5 and a Hazard Quotient (HQ) of 0.1. Acetone, carbon disulfide, 2-methylphenol, 4-methylphenol and phenol, which are also contaminants present in the onsite contaminated groundwater plume, were identified in some of the samples at concentrations less than the screening concentrations.

Compound EPA Region 3 RBC (parts per million [ppm]) 1 Maximum Concentration Exceeding EPA Region 3 RBC in VB 1-8 Soil and Waste (ppm)
Surface Samples (0 to 2 feet) Subsurface Samples (> 2 feet)
Antimony 82 No Exceedance 141
Arsenic 38 79.6 No Exceedance
Lead 1,000 2 3,600 6,790
Benzo(a)pyrene 7.8 40 No Exceedance
Dibenz(a,h)anthracene 7.8 10 No Exceedance
  1. U.S. EPA Region 3 RBCs for excess cancer risk of 1x10-5 and a HQ of 0.1 for non-carcinogens.
  2. The default lead standard is 1,000 mg/kg based on typical commercial/industrial exposure.

Sodium Sulfate Piles Evaluation
A representative sample was collected from the sodium sulfate piles for analysis. The analytical data confirmed that this material is not a Resource Conservation and Recovery Act (RCRA) hazardous waste, and its primary inorganic constituent is sodium. The material contained a very low level of carbon disulfide (likely a cross-contaminant). No other organic contaminants were detected.

Leachate and Leachate-Impacted Soils Evaluation
Leachate samples were collected from the seeps along the north side of VB 4-6 and from a sump within VB 5. Seepage on the west side of VB 7, representing the water overflowing from a depression in VB 7, was also sampled. This depression was subsequently backfilled with soil and there has been no seepage from VB 7 in the last several years. Soil samples were also collected from the area around the seeps. The leachate and soil samples were analyzed for organic and inorganic parameters. The results indicate that the leachate contains only low parts per billion (ppb) levels of certain organics and inorganics. The only organic analytes detected were carbon disulfide, 2-butanone, phenol, 2-methylphenol, 4-methylphenol, 2,4-dimethylphenol, and bis(2-ethylhexyl)phthalate (BEHP). Leachate data from VB 4-6 and the VB 7 seepage show that carbon disulfide levels were very low, indicating that the viscose wastes in these basins are not contributing substantive amounts of carbon disulfide to ground water.

The inorganic water quality data showed degradation of water quality in the leachate. The pH ranged from 7 to 9 and high alkalinity. The table below identifies compounds found at concentrations exceeding the Virginia Surface Water Quality Standards. Lead (180 ppb) and zinc (58,500 ppb) exceeded the existing onsite waste water treatment effluent limits of 78 ppb and 4,540 ppb, respectively; total suspended solids (TSS) and biochemical oxygen demand (BOD) also exceeded the existing effluent limits.

Compound Virginia Surface Water Quality Standard (ppb) Maximum Leachate Concentration (ppb)
Bis(3- ethylhexyl)phthalate 59 220
Cadmium 1.1 8.1
Chromium 0.21 276
Copper 12 834
Lead 14 180
Mercury 0.012 7
Nickel 20 686
Zinc 110 58,500

Four leachate-impacted soil samples were collected. None of the analyzed compounds exceeded the EPA Region 3 RBCs at an excess cancer risk level of 1x10-5 and a HQ of 0.1. PCBs were not detected in any of the surface soil samples, the only VOCs detected were ppb levels of acetone and carbon disulfide, and only low levels of SVOCs were detected in these surface soil samples. The primary SVOCs were PAHs such as naphthalene, benzo(a)pyrene (BAP), pyrene, fluoranthene and benzo(b)fluoranthene. The principal metals detected in the soil samples were the major elements, such as iron, calcium, potassium, and sodium. Metals that were consistently detected included arsenic, barium, copper, manganese, vanadium, and zinc.

Ground Water Evaluation
The lateral ground water flow direction in both overburden and bedrock is westerly towards the South Fork Shenandoah River (River). Six of the eight temporary well points installed in January 2002 were dry, indicating that overburden ground water can disappear during dry weather, and flow through the overburden is localized. The rainfall amount at the Site was below normal between September 2001 and March 2002.

The ground water quality data collected from monitoring wells in overburden and bedrock indicate that three conditions minimize the potential impact on ground water quality in the area of VB 1-8. These conditions are listed below and discussed in more detail in the remainder of this section.

  1. The chemical nature of the viscose waste in VB 1-8 is different than the waste in VB 9-11, as evidenced by average carbon disulfide levels two to three orders of magnitude lower than the levels measured in VB 9-11.
  2. The presence of the soil cover, grading and vegetation on VB 1-8 have limited infiltration of rainwater through the waste.
  3. The overburden water table is beneath the bottom of basins VB 1-8, and does not rise into the viscose wastes, indicating that the waters within the waste material are perched, and do not have direct hydraulic communication with ground water.

Impacts to overburden ground water from VB 1-8 were determined by examining water quality data from the following wells, which are located downgradient of the basins.

MW-11 does not show impacts to ground water from carbon disulfide, arsenic, or ammonia-nitrogen, which are indicators of the plume derived from VB 9-11; however, the Maximum Contaminant Level (MCL) for lead (15 ppb) was exceeded in well MW-11 (63.5 ppb lead). Dissolved arsenic (up to 120 ppb) and total arsenic (up to 161 ppb) were identified in MW-12, which exceeds the MCL for arsenic (10 ppb). The arsenic impact appears to be localized because arsenic concentrations in downgradient overburden, shallow and intermediate bedrock monitoring wells were less than the detection limit (1.2 ppb). Carbon disulfide concentrations up to 5 ppb were found in MW-12. MW-11 and MW-12 do contain elevated levels of sodium and other major ions, indicating that VB 1-3 and 7-8 have caused a localized impact of dissolved solids to ground water.

Elevated levels of acetone were detected in GPW 14 and GPW 16 (up to 27,000 ppb), indicating that there is a source of acetone in the vicinity of VB 3, 4 and 5. The U.S. EPA Region 3 RBC for acetone at a HQ of 0.1 is 61.0 ppb. However, the extent of acetone in ground water is limited because no acetone was detected in shallow bedrock wells 119, 120, 134 and 135. Arsenic (11 ppb) exceeded the MCL (10 ppb) in GPW 16. The inorganic water quality in GPW 14 is similar to the water quality in seep samples collected on the north side of VB 4-6. The water contains elevated total dissolved solids (TDS), consisting mostly of sulfate and sodium.

Impacts to bedrock ground water from VB 1-8 were determined by examining water quality data from the following monitoring wells, which are located immediately downgradient and downstrike of the basins:

Organic contaminants were not detected in most of the monitoring wells located cross-gradient and downgradient of VB 1-8 during multiple sampling events. Those parameters that were detected sporadically included methylene chloride, acetone, BEHP, naphthalene and phenol at concentrations generally less than 5 ppb. No organic contaminants were detected in the samples collected from shallow bedrock wells 134 and 135. Furthermore, other inorganic indicators of the plume emanating from VB 9-11, such as arsenic, antimony and zinc, were not elevated in these two wells. Wells 134 and 135 did contain elevated levels of sulfate and TDS, indicating that VB 1-6 have caused a localized impact of dissolved solids to ground water.

Elevated concentrations of carbon disulfide (2,600 ppb), arsenic (91.2 ppb) (exceeding the MCL of 10 ppb) and ammonia-nitrogen (1.5 ppm) were detected in well 132. These compounds are also characteristic of the contaminant plume derived from VB 9-11. The source of these compounds in well 132 may be from one or more of the VB 1-8 basins or from lateral migration and/or dispersion of the plume emanating from VB 9-11.

In summary, the ground water quality data from overburden wells, leachate seeps and bedrock monitoring wells identified impacts from VB 1-8. The MCL for arsenic was exceeded in overburden/shallow bedrock well MW-12, overburden well GPW-16, and shallow bedrock well 132. The MCL for lead was exceeded in overburden/shallow bedrock well MW-11.

New Landfill

Unit Description and Background

The location of the New Landfill is shown on Figure 2. The stream on the south side of the New Landfill was determined to be a Jurisdictional wetland by the USACE. The surface of the landfill is not covered with soil or vegetation. The top of the landfill is above natural grade and slopes to lower elevations on its north, south and east sides. Based on an average base elevation of 513 feet, a surface elevation of 523 feet and an area of 3.7 acres, the landfill is estimated to contain 54,000 cubic yards of waste. Information provided in the 1983 permit and visible observation of the exposed surface indicate that the waste in the landfill includes:

The landfill was designed with a leachate collection system that transmits leachate to the onsite WWTP. The landfill leachate collection system is directly underlain by 7 to 13 feet of low permeability native silts and clays. The leachate collection system includes a layer of stone overlying the soil-cement layer that was designed to carry leachate to a 10-inch PVC perforated pipe running the length of each trench. The in-situ permeability of the soil-cement liner met is 1 x10 -7 cm/sec. The perforated pipes are bedded in sand, and eventually join solid 10-inch PVC pipes, which were used to collect the leachate from each perforated pipe. All collection and transmission pipes were designed with a 0.5 percent slope. The leachate is directed to a sewer connected to the onsite WWTP.

Ground water elevation data collected from monitoring wells downgradient from the New Landfill indicate that the leachate collection system is above the overburden and shallow bedrock water table. The bottom elevation of the landfill varies from 512.5 feet to 513.7 feet above mean sea level (MSL). The ground water elevation in bedrock is more than three feet below the bottom of the landfill. Temporary well points GPW-19 through 21 monitor overburden ground water elevations and quality downgradient from the New Landfill. The well points were dry in February 2002 indicating that the water in the overburden is absent during dry periods.

Source, Nature and Extent of Contamination

Landfill Waste Evaluation
There is no information to indicate that the material placed in the landfill was derived from a RCRA listed hazardous waste/process. Furthermore, the permit issued by Virginia defined the types of waste that could be placed in the landfill, and none of the permitted waste was derived from a hazardous waste process. As such, the material placed in the New Landfill would not be classified as a RCRA listed hazardous waste. Samples collected from two locations on the landfill were analyzed for waste characterization parameters. The results indicated the waste was not a RCRA characteristic hazardous waste.

Waste samples were collected from seven locations that were representative of the waste exposed at the ground surface (upper 2 feet). These samples were analyzed for organic and inorganic parameters. Four of the sample locations were on the surface of the landfill, and the other two were from a wet area at the toe of the eastern side of the landfill. A comparison of contaminant concentrations with the EPA Region 3 RBCs for industrial soil exposure at an excess cancer risk level of 1x10-5 and a HQ of 0.1 indicated only arsenic (up to 103 ppm) exceeded the RBCs. A description of compounds found at concentrations below the RBCs is provided in the following paragraphs.

Landfill Leachate Evaluation
A sample of leachate was collected from the leachate collection system for laboratory analyses. The analytical results show that the leachate does not contain elevated concentrations of organic contaminants. The leachate does contain low levels of barium, chromium, manganese, nickel and vanadium. Arsenic is present in the leachate at 26.7 ppb. TSS and BOD exceeded the existing onsite waste water treatment effluent limits of 45 mg/L. A comparison of the landfill leachate analytical results to the RCRA Toxicity Characteristic Leaching Procedure (TCLP) characteristic standards indicate that the leachate is not a characteristic hazardous waste.

Ground Water Evaluation
Ground water quality data from monitoring wells MW-7, MW-8 and 133 are representative of ground water at the New Landfill, as they are located immediately downgradient and downstrike of its western boundary. Analytical results from samples collected from these wells indicate that the only MCL exceedance is arsenic at a concentration of 25.5 ppb in well 133. Well 133 contained elevated levels of sodium and sulfate. The data suggest that there is a source of sodium and sulfate in the landfill, or the sodium and sulfate is derived from the upgradient plant area.

Plant Area Soils

Unit Description and Background

The Plant Area Soils consist of potentially impacted soils located on the eastern portion of the Site (east of the railroad tracks) surrounding the footprint of the former manufacturing plant. The total area of this unit is estimated to be 65 acres (Figure 3). The Remedial Investigation (RI) conducted in 1993 and 1994 included the characterization of locations within the Plant Area Soils (called the Onsite Soils management unit at the time of the RI) that had been identified as potential contaminant sources based on historical Site activities and field observations. The Plant Area Soils part of the RI sampling program focused on 15 potential contaminant source areas.

Time-critical-removal actions were performed on soils associated with the Lead Casting Shop and Carbon Disulfide Storage areas to address unacceptable risk to Site remediation workers and trespassers identified during the RI.

In a December 2001 Action Memorandum, EPA selected a non-time-critical removal action (NTCRA) to decontaminate the remaining buildings and excavate sewers. Contaminated soils associated with sewers will be addressed as part of that action.

The building decontamination/sewer removal action is being coordinated with the USACE non-CERCLA action during which asbestos is being removed and the remaining plant buildings are being demolished. The remaining buildings are being demolished in order to prepare the Site for reuse as a new business park. The building demolition and demolition debris management process and the removal of the sewers had the potential to contaminate the Plant Area Soils; therefore, additional characterization and delineation of the Plant Area Soils was not appropriate.

Source, Nature and Extent of Contamination

Though a removal action was performed on the lead shop soils, some soils in the 0.5 to 2.5 feet depth range that were left in place are known to contain elevated lead concentrations (up to 89,700 ppm) that exceed the direct contact Site cleanup standard of 1,000 ppm.

Site-specific soil cleanup standards for direct contact and ground water protection were established for the NTCRA decontamination of the remaining buildings and excavation of the sewers in an Action Memorandum signed December 21, 2001. These standards were established to protect human health consistent with the planned future use of the area as a commercial/industrial park. Soils that do not meet the direct contact standards and/or ground water protection standards pose a potential unacceptable risk. Site-specific soil cleanup standards for OU-10 are proposed (see Section VIII under VB 1-8 Alternatives) that are consistent with the NTCRA. The extent of remaining contamination in surface and subsurface soils will be investigated after the building demolition and sewer removal actions to determine if the Plant Area Soils meet these Site-specific soil cleanup standards for OU-10.

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IV. Scope and Role of Operable Unit 10

The role of the remediation addressed by this proposed plan is two-fold: 1) mitigate potential risk to human health and the environment from exposed contaminants, and 2) ensure the closures are consistent with Virginia's solid waste regulations for closure of solid waste management units. With respect to the mitigation of risk, the Plant Soil and soil associated with the VB 1-8 leachate seeps and waste in the New Landfill are exposed; therefore, a potential direct contact risk to human health and ecological receptors may exist. Furthermore, exposed leachate seeps on the north side of VB 4-6 and leachate generated in the landfill will be contained to avoid direct contact by receptors and treated prior to discharge to the River. To ensure that the area where the WWTP is located is available for integration in the planned conservancy park the WWTP components need to be demolished at the completion of the remediation of the entire Site.

This Remedial Action is part of on-going clean-up activities at this Site. Other management units at the Site are being addressed by Time-Critical and Non-Time-Critical Response Actions (TCRA and NTCRA), and, in the case of OU-7, through a future remedial action. Proposed plans for the Response Actions for the buildings and sewers, and sulfate and fly ash wastes, have been presented to the public and response actions were selected by EPA though the issuance of Action Memoranda. The response action for the TCRA and NTCRA units are being implemented, and are expected to be completed in 2004. OU-7 consists of Viscose Basins 9 through 11 and ground water, and surface water, which includes the River. A future proposed plan for OU-7 will be prepared and made available for public comment after the Feasibility Study is completed in 2004.

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V. Summary of Site Risks

The investigation of the OU-10 units included analyses to estimate the human health and ecological hazards that could result if contamination at the Site were not cleaned up. These analyses are commonly referred to as Risk Assessments and identify existing and future risks that could occur if conditions at the Site do not change. The Baseline Human Health Risk Assessment evaluated human health risks associated with various areas of the Site. The Preliminary Ecological Risk Assessment and the Final Ecological Risk Assessment (baseline risk assessment) evaluated ecological impacts from OU-10.

Viscose Basins 1-8

The RI sampling program focused on the collection of data necessary to characterize risks and for selection of a remedy. The contaminant levels at VB 1-8 are similar to levels expected for solid waste landfills, and the primary problems associated with these basins are due to lack of proper closure. Therefore, consistent with EPA's presumptive remedy guidance (more fully discussed in Section VII. Remedial Action Objectives), a quantitative risk assessment was not prepared.

Human Health Risk

Under current conditions, Site remediation workers and trespassers are the only individuals with the potential to come in contact with waste materials in VB 1-8, and the leachate and associated soil on the north side of VB 4-6.

Soil/waste samples collected in the upper 2 feet of the basins indicated that several compounds exceed the EPA Region 3 RBCs based on industrial soil exposure at an excess cancer risk level of 1x10-5 and a HQ of 1. Screening against these concentrations is considered conservative for both the future recreational use scenario, and the current Site remediation worker and trespasser use scenarios for VB 1-8. The compounds exceeding the RBCs are: arsenic (79.6 ppm versus 38 ppm RBC), lead (3,600 ppm versus 1,000 ppm RBC), benzo(a)pyrene (40 ppm versus 7.8 ppm RBC), and dibenz(a,h)anthracene (10 ppm versus 7.8 ppm RBC).

The analysis of leachate samples indicated that lead (180 ppb) and zinc (58,500 ppb) exceeded the existing onsite waste water treatment effluent limits of 78 ppb and 4,540 ppb, respectively. The Virginia Surface Water Quality Standards for human health are exceeded by the following contaminants in leachate: lead (180 ppb versus the 15 ppb standard), mercury (7 ppb versus the 0.052 ppb standard), and nickel (686 ppb versus the 610 ppb standard).

Ecological Risk

A baseline ecological risk assessment (Final Ecological Risk Assessment) was conducted for the Avtex Fibers Site to evaluate the potential risks to ecological receptors from the contaminants of concern (COCs) identified by the Preliminary Ecological Risk Assessment. The COCs were those compounds that had been determined to pose a potential ecological risk during the Preliminary Ecological Risk Assessment. The COCs were metals, polynuclear aromatic hydrocarbons (PAHs), PCBs, and carbon disulfide. The risk assessment focused on the following three scenarios: exposure to contaminants in the sediment, water and biota from the South Fork of the Shenandoah River; exposure to the sediment, water, and biota from onsite basins; and exposure to soil and biota collected from onsite areas. The biological testing and sampling conducted was designed to determine the impacts from all the Site areas (fly ash basins, sulfate basins, viscose basins, and other onsite areas). Based on the types of habitats present at the Site, the risk assessment evaluated the potential risk to benthic invertebrate communities, fish communities, piscivorous birds (belted kingfisher), worm-eating birds (American woodcock), carnivorous birds (red-tailed hawk), carnivorous mammals (red fox and mink), and omnivorous animals (raccoon).

The Final Ecological Risk Assessment presented results of toxicity tests using sediment collected from the unnamed tributary north of VB 4-6, located to the north and adjacent to VB 1-8. The testing indicated there was a decrease in the survival of some sediment invertebrates. The report indicated that the sediment in the unnamed tributary had a potential impact on sediment invertebrates, and that the potential impact appeared to be related to the direct toxicity of the metals concentrations.

The Final Ecological Risk Assessment concluded that potential ecological risks exist at the Site. Metals and PCBs pose a potential risk to all receptors used in this study for at least one of the areas tested (river, upland soil, or onsite basins). Therefore, potential ecological risks have been identified for VB 1-8.

Ground Water Pathway

The MCL for arsenic (10 ppb) was exceeded in overburden/shallow bedrock well MW-12 , overburden well GPW-16 (11 ppb), and shallow bedrock well 132 (91.2 ppb). The MCL for lead (15 ppb) was exceeded in overburden/shallow bedrock well MW-11 (63.5 ppb).

There is no unacceptable risk posed to ecological receptors by ground water discharged to the River because VB 1-8 have not released contaminants to ground water at levels that have the potential to adversely impact the River.

New Landfill

The RI sampling program focused on collection of data necessary to characterize risks and for selection of a remedy. The RI data indicated that the concentration of Site contaminants in the New Landfill were low. In addition, the contaminant levels in the New Landfill are similar to levels expected for solid waste landfills, and the primary problems associated with the New Landfill are due to lack of proper closure. Therefore, consistent with EPA's presumptive remedy guidance (more fully discussed in Remedial Action Objectives, Section VII.), a quantitative risk assessment was not performed.

Human Health Risk

The wastes in the New Landfill are exposed and pose a direct contact risk to future recreational users and future construction workers. Arsenic concentrations (up to 103 ppm) in the surface materials (0 to 2 feet deep) and adjacent soils exceed the EPA Region 3 RBC (38 ppm) at an excess cancer risk level of 1x10-5.

Ecological Risk

The Final Ecological Risk Assessment was previously described in the Ecological Risk section for VB 1-8. The Final Ecological Risk Assessment concluded that potential ecological risks exist at the Site. Metals and PCBs pose a potential risk to all receptors used in this study for at least one of the areas tested (river, upland soil, or onsite basins). Therefore, potential ecological risks have been identified for the New Landfill.

Ground Water Pathway

The ground water quality data in wells MW-7, MW-8 and 133 indicate that arsenic (25.5 ppb) in well 133 exceeds the MCL (10 ppb). The landfill leachate that is currently being collected and treated in the onsite WWTP contains arsenic at 26.7 ppb, which would pose a threat to ground water quality if containment and collection of the leachate was discontinued.

Plant Area Soils

Human Health Risk

After completion of the RI sampling, an evaluation of the Plant Area Soils was performed to identify unacceptable risks. Samples collected during the RI indicate that, using industrial RBCs with a hazard quotient of 0.1 for non-carcinogens and a excess cancer risk level of 10-5 for carcinogens, 14 of the 15 discrete areas did not pose an unacceptable risk to human health from direct contact with the soil based on a current trespasser exposure scenario and commercial future use scenario. The single exception was lead-contaminated soils associated with the Lead Casting Shop area. During a previous removal action, the Lead Casting Shop soils were removed up to a depth of one-half to one foot to mitigate a potential direct contact and dust inhalation risk to Site remediation workers and trespassers from very elevated lead concentrations (up to 101,000 ppm). Some soils in the 0.5 to 2.5 feet depth range that were left in place are known to contain elevated lead concentrations (up to 89,700 ppm) that exceed the cleanup standard of 1,000 ppm. The removal of contaminated soil from the Lead Casting Shop area mitigated the unacceptable risk to Site remediation workers and trespassers from direct contact, thereby addressing the human health risk concerns pertinent to continued remediation activities at the Site. However, lead concentrations remaining in the area still present a risk to future users of the Site.

Ecological Risk

The Final Ecological Risk Assessment was previously described in the Ecological Risk section for VB 1-8. The Final Ecological Risk Assessment concluded that potential ecological risks exist at the Site. Metals and PCBs pose a potential risk to all receptors used in this study for at least one of the areas tested (river, upland soil, or onsite basins). Therefore, potential ecological risks have been identified for the Plant Area Soils.

Ground Water Pathway

Ground water data collected during the RI and the OU-7 FS identified exceedances of the MCLs by total metals in ground water in and downgradient of the Plant Area Soils. However, it is not known at this time if the contamination is attributable to Plant Area Soils. Additional Plant Area Soils characterization data is necessary. If the observed ground water contamination is attributable to Site-related activities on the east side of the railroad tracks, the most likely sources are spills within the buildings that leaked to surrounding soils or leaks from sewers; both of these potential sources are being addressed by the ongoing NTCRA - Buildings.

Basis for Taking Action

It is the lead agency's current judgment that the Preferred Alternative identified in this Proposed Plan, or one of the other active measures considered in the Proposed Plan, is necessary to protect public health or welfare or the environment from actual or threatened releases of hazardous substances into the environment.

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VI. Remedial Action Objectives

Viscose Basins 1-8 and the New Landfill

EPA's extensive experience in the complexities of NPL Site cleanup has revealed certain consistencies in Site characteristics and remedies. Some categories of Sites have similar characteristics, such as types of contaminants present, past industrial use, or environmental media affected. At similar Sites, standard remedies (called "Presumptive Remedies") can be applied. The Presumptive Remedy approach looks for remedies that are appropriate for specific Site types and/or contaminants. The objective of the Presumptive Remedy approach is to use EPA's past experience to streamline Site investigations and make remedy selection faster and more focused. Some examples of the types of Sites for which there is Presumptive Remedy guidance include: VOCs in soils, municipal landfills, wood treating facilities and contaminated ground water Sites.

EPA guidance, which is identified in the Administrative Record file for OU-10, states that Presumptive Remedies are expected to be used at all appropriate Sites, except under unusual Site-specific circumstances. This means that candidate Sites should be investigated to determine the applicability of the Presumptive Remedy approach. A remedy of containment is appropriate for landfills where the volume and heterogeneity of the disposed waste generally makes removal and/or treatment impractical. The presumptive remedy may be applied unless the integrity of the containment system would be threatened if certain waste is left in place.

Factors considered in determining the applicability of the Presumptive Remedy approach for VB 1-8 and the New Landfill include the fact that VB 1-8 and the New Landfill are solid waste landfills, contaminant levels are at levels expected for solid waste landfills and the primary problems associated with VB 1-8 and the New Landfill are due to the lack of proper closure. As a result, the RI and FS were streamlined so that activities were focused on collection of data necessary for implementation of a remedy typically used at a solid waste landfill.

The following remedial action objectives (RAOs) have been developed to address risks associated with VB 1-8 and the New Landfill:

  1. Prevent direct contact with the VB 1-8 and New Landfill soils and wastes by humans and ecological receptors and prevent the migration of contaminants;
  2. Mitigate current and future potential risk to human health and ecological receptors associated with VB 1-8 leachate and uncovered leachate-impacted soil;
  3. Mitigate production and uncontrolled release of VB 1-8 and New Landfill gases.

In addition, the closures of VB 1-8 and the New Landfill need to be consistent with the requirements of the Conservation and Environmental Protection Easement and Declaration of Restrictive Covenants (Environmental Easement) for the basin area (i.e., the area west of the railroad tracks). The Environmental Easement was recorded in the land records of the Town of Front Royal on December 7, 1999. The United States is a signatory to the easement. This easement placed permanent restrictions on the use of the property. Specifically, the area west of the railroad tracks is restricted to conservancy and open space, and will include unrestricted pedestrian access for hiking and biking. Furthermore, no temporary or permanent building (other than those necessary for remediation purposes) can be placed on the property and the use of ground water is prohibited.

Plant Area Soils

The following remedial action objectives (RAOs) have been developed to address risks associated with Plant Area Soils:

  1. Mitigate direct contact risks to humans and ecological receptors posed by contaminants in Plant Area Soils;
  2. Mitigate future human health and ecological risks associated with the potential migration of contaminants; and
  3. Mitigate current and potential future risks associated with the migration of contaminants to ground water.

In addition, the remediation of the Plant Area Soils needs to be consistent with the requirements of the Environmental Easement for the Former Plant Area. The Environmental Easement was recorded in the land records of the Town of Front Royal on December 7, 1999. The United States is a signatory to the easement. This easement placed permanent restrictions on the use of the property. Specifically, the Former Plant Area is restricted to light industrial or commercial use. Furthermore, the use of ground water is prohibited.

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VII. Summary of Remedial Alternatives

Viscose Basins 1-8

Three remedial alternatives have been considered for the closure of VB 1-8 to attain the RAOs:

The Preferred Alternative for VB 1-8 is Alternative 3 - Enhance Existing Covers and Collect and Treat Leachate.

Alternative 1 - No Further Action

Regulations governing the Superfund program generally require that the "no action" alternative be evaluated generally to establish a baseline for comparison. Under this alternative, EPA would take no action at the Site to prevent exposure to the soil, wastes, or leachate, and would not contain or treat the leachate.

Capital Cost:
$0
Annual O&M Cost:
$0
Time to Implement:
None
Alternative 2 - Excavation and Offsite Disposal of Waste

Under this alternative, the estimated volume of 400,000 cubic yards of viscose and other solid waste in VB 1-8 would be excavated to native soil, and properly disposed offsite at a RCRA Subtitle D facility as non-hazardous solid waste. The viscose waste would be transported by truck. It is estimated that more than 23,000 roundtrips (at 22 tons per truck) would have to be made to export the excavated viscose from VB 1-8 to a landfill. After the waste and any impacted soil were removed, the VB 1-8 area would be graded and vegetated. With the waste removed, the leachate seeps would not be an issue and ground water monitoring would not be required. No institutional controls, other than those already instituted by the Environmental Easement, would be required.

The onsite WWTP would be decontaminated and demolished when it is no longer required to treat stormwater and leachate. The decontamination and demolition of the WWTP includes:

The estimated cost to implement Alternative 2 is primarily based on the cost to excavate, load and dispose of the 400,000 cubic yards of viscose and other solid waste (approximately 500,000 tons assuming a density of 1.2 tons per cubic yard). Costs include costs for excavation, loading, truck transport, and the tipping fee. There would be no long-term O&M costs for this alternative.

VB 1-8 Capital Cost:
$40,555,000
WWTP Capital Cost:
$1,527,000
Annual O&M Cost:
$0
Total Present Worth Cost:
$42,082,000
Time to Implement:
1 year
Alternative 3 - Enhance Existing Covers and Collect and Treat Leachate

VB 1-8 Alternative 3 consists of closing VB 1-8 in-place in accordance with VSWMR. This alternative consists of the following remedial actions:

Post-closure cover maintenance is expected to be minimal for two reasons. First, post-closure settlement is not a major concern because the waste and existing soil covers on VB 1-8 have had adequate time to settle. Any further settlement resulting from increased loading from the upgraded cover system should be minimal and relatively uniform. Post-closure settlement will be evaluated during operation and maintenance (O&M) inspections. Settlement areas will be repaired as necessary. Second, long-term maintenance of the cover vegetation will not be necessary. The covers will be vegetated initially with native grasses or shrubs to prevent erosion. In the near-term, the grasses and shrubs will be inspected and repaired as necessary to prevent erosion of the cover. However, in the longer-term, once erosion has been controlled to meet the ARAR requirements, the grasses and shrubs will be left to grow naturally and the condition of the cover vegetation will be evaluated during O&M inspections. Native plant species, such as the coniferous trees located east of VB 3, that migrate onto the covers will be left to grow naturally, thus allowing the covers to evolve to a natural state in accordance with the intent of the Conservancy Park Master Plan. Therefore, in the longer-term, maintenance of the cover vegetation will not be required as long as ARARs (e.g., erosion control) are met, the soil cover system is functioning as designed, the direct contact risk to human health and ecological receptors is mitigated, and the cover vegetation is consistent with the intended future use as part of the Conservancy Park.

Post-closure care for the leachate conveyance and treatment will require O&M. The drain pipe will need to be inspected and cleaned periodically to ensure chemical precipitants do not obstruct the flow.

The ground water monitoring plan to be implemented during post-closure maintenance will be designed to determine whether the viscose waste causes further degradation of ground water quality. If monitoring indicates that the viscose waste is causing ground water quality degradation, risks to human health and the environment will be re-assessed, and the remedy may be modified to mitigate any unacceptable risk.

The onsite WWTP would be decontaminated and demolished when it is no longer required to treat leachate and stormwater, as described under Alternative 2. There would be no long-term O&M costs for the decontamination and demolition of the WWTP.

The restrictions in the existing Environmental Easement will prevent disturbance of the soil cover after it is constructed. Therefore, additional institutional controls are not anticipated.

The estimated costs listed below include construction of the soil cover, the gas venting system, leachate treatment, cover inspections and maintenance, and ground water monitoring for a period of 30 years.

VB 1-8 Capital Cost:
$2,081,000
WWTP Capital Cost:
$1,527,000
Annual O&M Cost:
$17,207
Total Present Worth Cost:
$4,124,210
Time to Implement:
1 year

Closure of the New Landfill

Three remedial alternatives have been identified for closure of the New Landfill to attain the RAOs:

The Preferred Alternative for the New Landfill is Alternative 3 - Soil Cover and Leachate Treatment.

Alternative 1 - No Further Action

Regulations governing the Superfund program generally require that the "no action" alternative be evaluated generally to establish a baseline for comparison. Under this alternative, EPA would take no action at the Site to prevent exposure to the soil, wastes, or leachate, and would not contain or treat the leachate.

Capital Cost:
$0
Annual O&M Cost:
$0
Time to Implement:
None
Alternative 2 - Excavation and Offsite Disposal of Landfill Waste

Under this alternative, approximately 72,000 tons of landfilled material would be excavated to native soil, transported by truck, and properly disposed offsite at a RCRA Subtitle D facility. It is estimated that nearly than 3,300 roundtrips (at 22 tons per truck) would have to be made to export the excavated material from the New Landfill to an offsite landfill. The leachate collection system would need to be removed and graded out. The remaining area would be graded and vegetated. A performance measure would be identified in the design phase to indicate the allowable concentration of constituents of concern (COCs) in soil. For this alternative, ground water monitoring and institutional controls would not be required because the wastes would have been removed and relocated.

The estimated cost to implement Alternative 2 is primarily based on the cost to excavate, load and dispose of the approximately 72,000 tons of mixed solid waste. This estimated cost is associated with capital construction expense because long-term O&M would not be necessary.

Capital Cost:
$5,856,000
Annual O&M Cost:
$0
Time to Implement:
1 year
Alternative 3 - Soil Cover and Leachate Treatment

Alternative 3 consists of closing the New Landfill in accordance with the VSWMR. This alternative consists of the following remedial actions:

Post-closure cover maintenance is expected to be minimal for two reasons. First, post-closure settlement should not be a concern because the waste in the landfill has had adequate time to settle, and will be compacted further prior to placement of the soil cover. Any additional settlement as a result of the increased loading of the cover should be minimal and relatively uniform. Second,in the near-term, the grasses and shrubs will be inspected and repaired as necessary to prevent erosion of the cover. However, in the longer-term, once erosion has been controlled to meet the ARAR requirements, the grasses and shrubs will be left to grow naturally, and the condition of the cover vegetation will be evaluated during O&M inspections. Native plant species, such as the coniferous trees located east of VB 3, that migrate onto the covers will be left to grow naturally, thus allowing the covers to evolve to a natural state in accordance with the intent of the Conservancy Park Master Plan. Therefore, in the longer-term, maintenance of the cover vegetation will not be required as long as ARARs (e.g., erosion control) are met, the soil cover system is functioning as designed, the direct contact risk to human health and ecological receptors is mitigated, and the cover vegetation is consistent with the intended future use as part of the Conservancy Park.

The leachate conveyance and treatment will require O&M. The drain pipe will need to be inspected and cleaned periodically to ensure chemical precipitants do not obstruct the flow.

The ground water monitoring plan to be implemented during post-closure maintenance will be designed to determine whether the New Landfill further degrades ground water quality. If monitoring indicates that the New Landfill has degraded ground water quality, risks to human health and the environment will be re-assessed, and the remedy modified to mitigate any unacceptable risk.

The Environmental Easement will prevent disturbance of the soil cover. Therefore, additional institutional controls are not required.

The estimated costs to implement this remedy are listed below and include construction of the soil cover, the gas venting system, leachate treatment, cover inspections and maintenance and ground water monitoring for a period of 30 years.

Capital Cost:
$768,300
Annual O&M Cost:
$10,217
Total Present Worth Cost:
$1,075,000
Time to Implement:
1 year

Plant Area Soils

The surface soils surrounding the former plant area will need to be addressed to ensure that future Site workers at the commercial office park proposed by the Town of Front Royal Economic Development Authority (EDA) are adequately protected against exposure to residual soil contamination. Surface soils remaining in the plant area shall not exceed the Site-specific soil cleanup standards for OU-10 for direct contact or ground water protection.

As discussed in Section III, soil sampling was conducted during the RI to characterize soil conditions surrounding the former plant area. The soil data indicate that a few areas of the plant contain soil contaminants above the proposed Site-specific cleanup standards for OU-10 for direct contact. Further characterization of soils will need to be conducted during the remedial design phase to determine whether the contaminant concentrations in other soils exceed the human health direct contact and ground water protection standards. For the purpose of this Proposed Plan, it is assumed that 10 percent of the 65 acre plant area (6.5 acres) contains contaminants above the Site cleanup levels to a depth of 2 feet. This assumption generates 22,000 cubic yards of impacted surface soil. Further, it assumed that half of this amount would fail the ground water protection standard and could not be beneficially used as backfill for deeper subgrade structures, or as construction material in basins or landfill closures. These assumptions provide the design basis for the evaluation of the remedial alternatives for Plant Area Soils.

Two remedial alternatives have been identified for the closure of the Plant Area Soils to attain the RAOs:

The Preferred Alternative for the Plant Area Soils is Alternative 2 -Remediation of Impacted Soils.

Alternative 1 - No Further Action

Regulations governing the Superfund program require that the "no action" alternative be evaluated generally to establish a baseline for comparison. Under this alternative, EPA would take no action at the Site to characterize and remediate contaminated soils in the Plant Area, which would result in direct contact human health risks and the potential for the migration of contaminants into groundwater.

Capital Cost:
$0
Annual O&M Cost:
$0
Time to Implement:
None
Alternative 2 - Remediation of Impacted Soils

Alternative 2 includes excavation, ex-situ stabilization, and onsite beneficial use or offsite disposal of impacted soils. Impacted soils will be defined as soils with contaminant levels exceeding the proposed Site-specific soil cleanup standards for OU-10 (See Attachment 1). Alternative 2 consists of the following:

The estimated costs to implement this alternative are listed below. The O&M costs associated with this alternative are expected to be minimal and have been estimated to be zero for the purpose of this cost estimate.

Capital Cost:
$2,582,000
Annual O&M Cost:
$0
Time to Implement:
2 years

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VIII. Evaluation of Alternatives

Evaluation Criteria

Below is a description of the nine criteria set forth in the NCP, 40 CFR 300.30(e)(9), used to evaluate each of the remedial alternatives summarized in this plan. The purpose of the comparative analysis is to identify the advantages and disadvantages of each alternative relative to the others. These nine criteria can be categorized into three groups: threshold criteria, primary balancing criteria, and modifying criteria.

Threshold Criteria
Primary balancing criteria
Modifying criteria

Threshold criteria must be satisfied in order for a remedial alternative to be eligible for selection. Primary balancing criteria are used to weigh trade-offs between alternatives. State acceptance and community acceptance are modifying criteria formally taken into account after public comment is received on the Proposed Plan. Provided below is a summary of the relative performance of the alternative with respect to each of the criteria. This summary provides the basis for EPA's preliminary determination of which alternative provides the best balance of all the criteria.

VB 1-8 Alternatives

1. Overall Protection of Human Health and the Environment

Alternative 1 (No Further Action) would not be protective of human health because it would not mitigate the risks associated with direct contact with contaminated soil, wastes and leachate. This alternative does not meet the threshold criteria of protection of human health and the environment; therefore, it will not be considered further in this analysis.

Alternative 2 would eliminate impacted soil, wastes and the leachate seeps completely, and thus it is protective of human health and the environment. Alternative 3 would mitigate the direct contact risks associated with soils and wastes by the placement of a clean soil cover over contaminated soils and wastes, and would mitigate risks associated with leachate by containing, collecting and treating the leachate.

The soil remaining after excavation of VB 1-8 and the soil located beneath or adjacent to the demolished WWTP concrete structures in Alternative 2 will also meet the proposed Site-specific soil cleanup standards for 1) human health direct contact standards for soils to depths of 10 feet below final or post-excavation grade, and 2) soil standards that protect ground water quality which would apply to the entire depth of soil to the water table. These soil standards, included in Attachment 1, were established using the procedures described below.

The risk-based numeric Site-Specific soil cleanup standards for OU-10 for the protection of human health due to direct contact will be the direct contact standards calculated according to the procedures utilized in the EPA Region 3 Risk-based Concentration Table (April 2003 Version) for industrial soil, except an indoor worker exposure scenario (soil ingestion = 50 mg/day) will be used instead of the outdoor worker scenario (soil ingestion = 100 mg/day). The direct contact cleanup goals will be based on a 1x10-5 risk level for carcinogens and a HQ of 1 for non-carcinogens if it can be demonstrated that there are no more than 10 carcinogens present in excess of the 1x10-6 risk level, and that none of the non-carcinogens exceeding a HQ of 0.1 have the same target organ. If more than 10 carcinogens are present in excess of the 1x10-6 risk level, the direct contact cleanup standards will be the levels identified for a 1x10-6 excess cancer risk. The cumulative risks for non-carcinogens that have the same target organ must not exceed a HQ of 1; therefore, the direct contact cleanup standards for non-carcinogens having the same target organ will be the levels for a HQ of 0.1.

The Site-specific soil cleanup standards for OU-10 for the protection of ground water (i.e., ground water protection standards) will be used to identify allowable chemical concentrations in soil. The objective of the ground water protection standard is to ensure that soil quality in the Plant Area does not adversely affect ground water quality. For soils greater than 10 feet in depth, only the ground water protection standards will apply because a future Site commercial/industrial or construction worker will not contact these soils. As a conservative approach, consistent with EPA guidance and allowing for Site ground water as a drinking water source, the ground water protection standards are the Safe Drinking Water Act (SDWA) Maximum Contaminant Level (MCL), or in the absence of an MCL, the current Region 3 risk-based screening concentrations for the ingestion of tap water, applied as described below.

The approach first involves using Synthetic Precipitation Leaching Procedure (SPLP) data to determine the concentration of a contaminant that could be leached from the soil into pore water. The second step consists of applying a dilution attenuation factor (DAF) of 10 to conservatively estimate the concentration that could occur in ground water beneath the source soils. The SPLP concentration is divided by the DAF of 10 and compared to the ground water protection standard.

For Alternative 3, the soils used for covering VB 1-8 will meet the proposed OU-10 Site-specific soil cleanup standards for 1) human health direct contact standards, and 2) soil standards that protect ground water quality. In addition, soil located beneath or adjacent to the demolished WWTP concrete structures will meet the proposed Site-specific soil cleanup standards for 1) human health direct contact standards for soils to depths of 10 feet below final or post-excavation grade, and 2) soil standards that protect ground water quality which would apply to the entire depth of soil to the water table.

Overall, Alternatives 2 and 3 are protective of human health and the environment to a similar extent. Alternative 2 eliminates the threats to human health and the environment by transporting the contaminated materials offsite, whereas Alternative 3 uses institutional controls, engineering controls and treatment to achieve a similar level of protection.

2. Compliance with ARARs

Alternatives 2 and 3 would comply with all Federal and State ARARs. Key ARARs are identified in the table provided in Attachment 2.

Virginia Solid Waste Management Regulations: Alternative 2 would eliminate impacted soil, wastes and the leachate seeps completely, and thus it would comply with the Virginia Solid Waste Management Regulations (VSWMR). Alternative 3 would comply with the VSWMR, which require that non-hazardous industrial waste, such as the viscose waste, be covered with soil, and that the cover meet certain engineering criteria for permeability, thickness and slope. Compliance with the VSWMR ensures that direct contact with waste materials will not occur and that leachate generation will be minimized and controlled. Although VB 1-8 are covered with soil, the covers will need to be improved to ensure they meet the VSWMR closure requirements for permeability, thickness and slope.

Pertinent requirements for closure under the VSWMR include:

3. Long-Term Effectiveness and Permanence

Alternatives 2 and 3 would provide long-term effectiveness and permanence.

Alternative 2 includes the removal of the viscose waste and proper offsite disposal at a permitted RCRA Subtitle D facility; therefore, Alternative 2 provides long-term protection against the potential release to the environment and direct contact.

Alternative 3 provides long-term effectiveness against release to the environment and direct contact, as the cover will be designed and constructed to minimize erosion and will require minimal maintenance. The final grading and vegetative cover would promote positive drainage and protect the cover against erosion and deterioration. Post-closure care, including annual inspections and maintenance, would facilitate maintenance of the integrity of the cover for an indefinite period. The existing Environmental Easement will prevent future disturbance of the viscose waste. Alternative 3 will also include a leachate collection and treatment system, which will be effective in the long-term. Furthermore, it is expected that the leachate discharge would be reduced over time due to the low permeability of the soil cover, evapotranspiration, and positive drainage of overland flow from precipitation events.

4. Short-Term Effectiveness

Three short-term risks may be encountered during the implementation of Alternative 2.

There are no short-term effectiveness issues associated with implementation of Alternative 3 because there are no unacceptable risks posed by the implementation of Alternative 3 to the community or Site workers.

The short-term risks associated with Alternative 3 are considerably less than those associated with Alternative 2.

5. Reduction of Toxicity, Mobility or Volume Through Treatment

Alternative 2 involves the offsite disposal of contaminated soil and wastes and does not include treatment - toxicity, mobility and volume issues are transferred to the receiving facility. Alternative 3 leaves wastes in place and includes the treatment of leachate, which reduces the toxicity and mobility of contaminants in the leachate. Although Alternative 3 treats the leachate, this alternative also results in the continued long-term generation of leachate.

6. Implementability

Alternative 2 could be implemented with little difficulty, except for potential health and safety hazards. The viscose waste, and in the case of VB 4-6, overlying demolition debris, can be excavated using conventional excavation equipment. There will be sufficient equipment and resources available to implement the remedy. There will be sufficient landfill capacity available in permitted Subtitle D facilities for disposal, although local capacity may not exist. However, as with most disposal/landfill areas, environments immediately dangerous to workers' life and health may be encountered.

Furthermore, Alternative 2 is inconsistent with EPA guidance establishing containment as a presumptive remedy for landfilled waste (EPA, 9355.049FS). The guidance emphasizes the NCP's expectation that engineering controls, such as containment, will be used for waste that poses a relatively low long-term threat and treatment is impracticable.

Alternative 3 is also technically feasible to implement. There would not be any significant concerns related to the availability of services or materials to implement this alternative. The onsite borrow areas or an offsite source will be able to supply adequate amounts of native clay soil for the covers. Construction of the covers will be straightforward. An evaluation of the ability to compact Site soil indicates that the permeability requirement of 1x10-6 cm/sec can be achieved through standard construction methods. Furthermore, there are no administrative feasibility factors that would affect the implementation of this alternative.

7. Cost

The table below compares the estimated costs associated with Alternatives 2 and 3.

Viscose Basin 1-8 Alternatives
Item Alternative 2 Alternative 3
VB 1-8 Capital Cost $40,555,000 $2,081,000
WWTP Capital Cost $1,527,000 $1,527,000
Annual O&M Cost $0 $17,200
Total Present Worth Cost $42,082,000 $4,124,000
8. State/Support Agency Acceptance

The Commonwealth of Virginia supports the preferred alternative described below, but reserves its final concurrence until community comments are evaluated.

9. Community Acceptance

Community acceptance of the preferred alternative will be evaluated after the public comment period ends and will be described in the Responsiveness Summary portion of the Record of Decision.

New Landfill Alternatives

1. Overall Protection of Human Health and the Environment

Alternative 1 would not be protective of human health because it would not mitigate the risks associated with direct contact with contaminated soil and wastes. This alternative does not meet the threshold criteria of protection of human health and the environment; therefore, it will not be considered further in this analysis.

Alternatives 2 and 3 are protective of human health and the environment. Alternative 2 would completely eliminate impacted soil and landfill wastes, and thus it is protective of human health and the environment; risks associated with leachate would be eliminated because no new leachate would be generated once the wastes are removed. Alternative 3 would mitigate the direct contact risks associated with soils and landfill wastes by the placement of a clean soil cover over contaminated soils and wastes, and would mitigate risks associated with leachate by containing, collecting and treating the leachate.

Overall, Alternatives 2 and 3 are protective of human health and the environment to a similar extent. Alternative 2 eliminates the threats to human health and the environment by transporting the contaminated materials offsite, whereas Alternative 3 uses institutional controls, engineering controls and treatment to achieve a similar level of protection.

The soil remaining after excavation of New Landfill in Alternative 2 will also meet the proposed Site-specific soil cleanup standards for OU-10: 1) human health direct contact standards for soils to depths of 10 feet below final or post-excavation grade, and 2) ground water protection soil standards to protect ground water quality which would apply to the entire depth of soil to the water table. The Site-specific soil cleanup standards for OU-10 were previously described in the section for VB 1-8 alternatives.

For Alternative 3, the soils used for covering the New Landfill will meet the proposed OU-10 Site-specific soil cleanup standards for 1) human health direct contact standards, and 2) soil standards that protect ground water quality.

2. Compliance with ARARs

Alternatives 2 and 3 would comply with all Federal and State ARARs. Key ARARs are identified in the table provided in Attachment 2.

Alternative 2 would eliminate impacted soil, wastes and the leachate seeps completely, and thus it would comply with the Virginia Solid Waste Management Regulations (VSWMR).

Alternative 3 would comply with the VSWMR, which require that non-hazardous industrial waste, such as the New Landfill contents, be covered with soil, and that the cover meet certain engineering criteria for permeability, thickness and slope. Compliance with the VSWMR ensures that direct contact with waste materials will not occur and that leachate generation will be minimized and controlled. Pertinent requirements for closure under the VSWMR were previously described in the section for VB 1-8 alternatives.

Variances to disposal facility requirements are allowable for cause, provided there is sufficient justification and the alternative assures protection of the public health and the environment.

3. Long-Term Effectiveness and Permanence

Alternatives 2 and 3 would provide long-term effectiveness and permanence.

Alternative 2 includes the removal of the landfill wastes and proper offsite disposal at a permitted RCRA Subtitle D facility; therefore, Alternative 2 provides long-term protection against the potential release to the environment and direct contact.

Alternative 3 provides long-term effectiveness against release to the environment and direct contact, as the cover will be designed and constructed to minimize erosion and will require minimal maintenance. The final grading and vegetative cover would promote positive drainage and protect the cover against erosion and deterioration. Post-closure care, including annual inspections and maintenance, would facilitate maintenance of the integrity of the cover for an indefinite period. The existing Environmental Easement will prevent future disturbance of the landfill waste. Alternative 3 will also include a leachate collection and treatment system, which will be effective in the long-term. Furthermore, it is expected that the leachate discharge would be reduced over time due to the low permeability of the soil cover, evapotranspiration, and positive drainage of overland flow from precipitation events.

4. Short-Term Effectiveness

Three short-term risks may be encountered during the implementation of Alternative 2.

There are no short-term effectiveness issues associated with implementation of Alternative 3 because there are no unacceptable risks posed by the implementation of Alternative 3 to the community or Site workers.

The short-term risks associated with Alternative 3 are considerably less than those associated with Alternative 2.

5. Reduction of Toxicity, Mobility or Volume Through Treatment

Alternative 2 involves the offsite disposal of contaminated soil and wastes and does not include treatment - toxicity, mobility and volume issues are transferred to the receiving facility. Alternative 3 leaves wastes in place and includes the treatment of leachate, which reduces the toxicity and mobility of contaminants in the leachate. Although Alternative 3 treats the leachate, this alternative also results in the continued long-term generation of leachate.

6. Implementability

Alternative 2 could be implemented with little difficulty, except for potential health and safety hazards. The material in the landfill can be excavated using conventional excavation equipment. There will be sufficient equipment and resources available to implement the remedy. There will be sufficient landfill capacity available in permitted Subtitle D facilities for disposal, although local capacity may not exist. However, as with most disposal/landfill areas, environments immediately dangerous to workers' life and health may be encountered.

Alternative 3 is also technically feasible to implement. There would not be any significant concerns related to the availability of services or materials to implement this alternative. The onsite borrow areas or an offsite source will be able to supply adequate amounts of native clay soil for the cover. Construction of the cover will be straightforward. An evaluation of the ability to compact Site soil indicates that the permeability requirement of 1x10-7 cm/sec can be achieved through standard construction methods. Furthermore, there are no administrative feasibility factors that would affect the implementation of this alternative. The NCP contains the expectation that engineering controls, such as containment, will be used for waste that poses a relatively low long-term threat and treatment is impracticable. The waste in the New Landfill meets these two criteria.

Furthermore, the New Landfill is comparable to a municipal landfill in waste type, and EPA established containment as the presumptive remedy for CERCLA municipal landfills.

7. Cost

The table below compares the estimated costs associated with Alternatives 2 and 3.

New Landfill Alternatives
Item Alternative 2 Alternative 3
Capital Cost $5,856,000 $768,300
Annual O&M Cost $0 $10,215
Total Present Worth Cost $5,856,000 $1,075,000
8. State/Support Agency Acceptance

The Commonwealth of Virginia supports the preferred alternative described below, but reserves its final concurrence until community comments are evaluated.

9. Community Acceptance

Community acceptance of the preferred alternative will be evaluated after the public comment period ends and will be described in the Responsiveness Summary portion of the Record of Decision.

Plant Area Soils Alternatives

Alternative 1 (No Further Action) is not acceptable because it does not mitigate direct contact risks posed by contaminants in the soils, does not mitigate future human health and ecological risks associated with the potential migration of contaminants, and does not mitigate current and potential future risks associated with the migration of contaminants to ground water. This alternative does not meet the threshold criteria of protection of human health and the environment; therefore, it will not be considered further in this analysis.

1. Overall Protection of Human Health and the Environment

Alternative 2 is effective in satisfying all the response action objectives by eliminating the soils with contaminant levels exceeding the Site-specific soil cleanup standards for OU-10, and thus is protective of human health and the environment.

Alternative 2 would also meet the proposed Site-specific soil cleanup standards for OU-10: 1) human health direct contact standards for soils to depths of 10 feet below final or post-excavation grade, and 2) ground water protection soil standards to protect ground water quality which would apply to the entire depth of soil to the water table. The Site-specific soil cleanup standards for OU-10 were previously described in the section for VB 1-8 alternatives.

2. Compliance with ARARs

The proposed Site-specific PCB soil cleanup standard for OU-10 is 25 mg/kg Total, which is consistent with the cleanup levels provided for PCB remediation wastes under 40 CFR 761.61. Soils with greater than 25 mg/kg Total PCB, but less than 50 mg/kg PCB, may be beneficially used in the sulfate basin closures or in VB 1-8 or the New Landfill if the closure of these units is subject to long term controls and monitoring. Soils with 50 mg/kg or greater Total PCB will be disposed offsite in accordance with 40 CFR 761.61.

Alternative 2 would comply with all Federal and State ARARs. Key ARARs are identified in the table provided in Attachment 2.

3. Long-Term Effectiveness and Permanence

Alternative 2 provides long-term protection to human health, as it will remediate the plant area soils with contaminant levels that exceed the Site-specific soil cleanup standards for OU-10.

4. Short-Term Effectiveness

The potential short-term impact may be the generation of contaminated soil that will require proper disposal. Fugitive dust resulting from Alternative 2 would be of short duration, and could easily be suppressed by wetting the materials during excavation and stockpiling.

No unusual hazards would be posed to workers. The primary potential impacts to workers would be limited to common physical hazards associated with Site work and materials handling.

5. Reduction of Toxicity, Mobility or Volume Through Treatment

Alternative 2 involves the stabilization of an estimated 3,000 cubic yards of metals-contaminated soils to remove any hazardous characteristic. The stabilized soil would be either disposed offsite or beneficially reused onsite.

6. Implementability

This alternative is technically feasible to implement. There would not be any significant concerns related to the availability of services, uniqueness of the work, materials or qualified contractors to implement this alternative.

7. Cost

The estimated cost to implement the remedy is $2,582,000. O&M costs associated with this remedy are expected to be minimal.

Plant Area Soils Alternatives
Item Alternative 2
Capital Cost $2,582,000
Annual O&M Cost $0
Total Present Worth Cost $2,582,000
8. State/Support Agency Acceptance

The Commonwealth of Virginia supports the preferred alternative described below, but reserves its final concurrence until community comments are evaluated.

9. Community Acceptance

Community acceptance of the preferred alternative will be evaluated after the public comment period ends and will be described in the Responsiveness Summary portion of the Record of Decision.

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IX. Preferred Alternatives

EPA prefers the following alternatives to clean up OU-10 of the Avtex Site:

The alternatives described above are being proposed as the preferred alternatives for remedial actions in the OU-10 management units discussed here. The preferred alternatives may be changed or modified based on public comments received or new information.

Based on information currently available, EPA believes the Preferred Alternative meets the threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria. EPA expects the Preferred Alternative to satisfy the following statutory requirements of CERCLA 121(b): 1) be protective of human health and the environment; 2) comply with ARARs (or justify a waiver); 3) be cost-effective; 4) utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable; and 5) satisfy the preference for treatment as a principal element (or justify not meeting this preference).

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X. Community Participation

This Proposed Plan is being distributed to solicit public comment on the appropriate cleanup action for portions of the Avtex Site. EPA relies on public input so that the remedy selected for each Superfund Site addresses the concerns of the local community. EPA is providing a 30-day public comment period beginning on July 31, 2003 and ending on August 30, 2003, to encourage public participation in the selection process. EPA will conduct a public meeting during the comment period in order to present the Proposed Plan and supporting information, answer questions, and accept both oral and written comments from the public. The public meeting will be held on August 14, 2003 at 7:00 p.m. at the Warren County Government Center.

EPA will summarize and respond to significant comments received at the public meeting and written comments post-marked by August 30, 2003, in the Responsiveness Summary section of the Record of Decision, which documents EPA's selected cleanup. To obtain additional information relating to this Proposed Remedial Action Plan, please contact either one of the following representatives:

Megan Dougherty (3HS43)

Community Involvement Coordinator
U.S. EPA - Region 3
1650 Arch Street
Philadelphia, PA 19103
Phone: 215-814-5534

Bonnie G. Gross (3HS23)

Remedial Project Manager
U.S. EPA - Region 3
1650 Arch Street
Philadelphia, PA 19103
Phone: 215-814-3229

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