Superfund Record of Decision: Ordnance Works Disposal Area Site OU 1, Morgantown, WV


                              PB99-963920
                              EPA541-R99-068
                              1999
EPA Superfund
      Record of Decision;
      Ordnance Works Disposal Areas Site OU 1
      Morgantown, WV
      9/30/1999

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RECORD OF DECISION
ORDNANCE WORKS DISPOSAL AREAS SUPERFUND SITE
OPERABLE UNIT ONE

DECLARATION
SITE NAME AND LOCATION

Ordnance Works Disposal Areas Superfund Site
Morgantown. Monongalia County, West Virginia

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for Operable Unit No. 1 ("GUI") of
the Ordnance Works Disposal Areas Site ("Site") located in Morgantown, Monongalia County.
West Virginia, developed and chosen in accordance with the Comprehensive Environmental '
Response, Compensation, and Liability Act of 1980, as amended ("CERCLA"), 42 U.S.C. §§
9601 ersea,, and to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan ("NCP"), 40 C.F.R. Part 300. This decision is based on the Administrative
Record for this Site.

The West Virginia Division of Environmental Protection has concurred with the selected remedy
by letter dated September 29, 1999 (see Appendix B of the Record of Decision).

RECISION OF PREVIOUS RECORD OF DECISION

This document supersedes the September 29, 1989 Record of Decision issued for Operable Unit
No. 1 of the Ordnance Works Disposal Areas Superfund Site.

ASSESSMENT OF THE SITE

I hereby determine, pursuant to Section 106 of CERCLA, 42 U.S.C. § 9606, that actual or
threatened releases of hazardous substances from this Site, if not addressed by implementing the
response action selected in this Record of Decision ("ROD"), may present an imminent and
substantial endangerment to the public health, welfare, or the environment.

DESCRIPTION OF THE REMEDY

This ROD selects a remedial action for implementation at OU1 of this Site and supersedes the
ROD for Operable Unit No. 1 issued on September 29, 1989. This selected remedy is intended to
be the final response action for the Site. The selected remedy includes the following components:

• Excavation and offsite treatment of all soils and sediments contaminated with visibly
stained tar-like material from the Lagoon Area, Scraped Area, and stream/wetland
sediments;

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• Excavation and consolidation into the existing landfill of all soils and sediments in the
Lagoon Area. Scraped Area, and the streams that are contaminated above the cleanup
standards established in this ROD;

• Backfilling, regrading, revegetating, and restoring the areas that have been excavated:

• Restoration of streams and wetland areas where sediment has been excavated:

• Construction of a multi-layer RCRA cap over the existing landfill:

• Long-term monitoring;

• Maintenance of the existing perimeter fence; and

• Institutional controls.

STATUTORY DETERMINATIONS

I hereby determine that the selected remedy is protective of human health and the environment.
complies with Federal and State requirements that are applicable or relevant and appropriate
requirements ("ARARs") to the remedial action, and is cost effective.

The principal threat presented by the highly concentrated carcinogenic polycyclic aromatic
hydrocarbons ("cPAHs") in the visibly stained tar-like material onsite will be addressed as a part
of this Remedial Action. The reduction of cPAHs via offsite thermal treatment will be permanent
and satisfies the statutory preference for remedial actions in which treatment that reduces toxiciry.
mobility, or volume is a principal element. The selected remedy utilizes permanent solutions and
innovative treatment technologies to the maximum extent practicable.

Because this remedy will result in hazardous substances remaining onsite above levels that allow
for unlimited use and unrestricted exposure, a review will be conducted every five years after
initiation of the remedial action in accordance with Section 121(c) of CERCLA, 42 U.S.C. §
962 l(c), to ensure that human health and the environment continue to be adequately protected by
the remedy.
Abraham Ferdas, Director Date
Hazardous Site Cleanup Division

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RECORD OF DECISION
OPERABLE UNIT ONE
ORDNANCE WORKS DISPOSAL AREAS SUPERFUND SITE

DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION

The Ordnance Works Disposal Areas Superfund Site ("Site") is located in Monongalia
Counrv- along the west bank of the Monongahela River approximately one mile southwest of the
City of Morgantown, West Virginia (see Figure 1). The property on which the Site is located
consists of approximately 800 acres and is wooded with rolling hills. A small portion of this
property was used as a disposal ground during manufacturing operations and later became known
to EPA as Operable Unit No. 1 ("OU1") of the Site. The remaining tracts of land within the
property containing, among other things, the manufacturing facilities, are known to EPA as
Operable Unit No. 2 ("OU2") of the Site (see Figure 2). This Record of Decision ("ROD")
addresses OU1 only.

OU1 consists of approximately four to six acres and is located at the southern end of the
Site property. Major OU1 features include an inactive, abandoned landfill; a former lagoon area;
an area referred to as the "scraped area" formerly used for the shallow disposal of wastes; and
contaminated stream sediments (see Figures 3 and 4). There is also a small wetland area located
adjacent to the onsite landfill. This wetland area is approximately one half acre in size and is
depicted on Figure 5.

There are no domestic or municipal wells used for drinking water supply in the vicinity of
the Site. The area population draws drinking water from a surface water intake on the
Monongahela River located approximately one mile downgradient of the Site.
II. SITE HISTORY AND ENFORCEMENT ACTIVITY

The property where the Site is located consists of numerous tracts of land containing
approximately 800 acres originally assembled by E.I. DuPont de Nemours & Company
("DuPont") between 1940-1943 pursuant to agreements between DuPont and the United States.
These agreements additionally provided for the construction and operation of chemical
manufacturing facilities. The Site property has contained active chemical production facilities
since the 1940's. Between 1943 and 1962, the United States held legal title to these facilities.
Between 1941 and 1958, various operations were conducted by private parties, in some cases
pursuant to government contracts and operating agreements, and in other cases pursuant to
commercial leases. During this time, the facilities were used to produce, among other substances,
hexamine. ammonia, methyl alcohol, formaldehyde, ethylene diamine, and coke. From 1958
through 1962, the plant was idle.

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In 1962. the property was sold to Morgantown Ordnance Works. Inc. Between 1962 and
1978, Morgantown Ordnance Works, Inc. leased and/or sold portions of the Site propemiibr
various industrial and chemical manufacturing activities. In 1964, Weston Chemical Company
("Weston") purchased a small parcel at the Site. Weston subsequently expanded its operations.
This expansion continued after 1969, when Borg-Warner Corporation ("Borg-Warner")
purchased Weston. with the result that Borg-Warner ultimately operated two plants and
laboratories on company-owned property amounting to approximately 62 acres at the Site. In
1988. General Electric Company ("GE") purchased Borg-Warner's operations. The GE facilities
are currently active and are being investigated by the company under a Resource Conservation
and Recovery Act ("RCRA") agreement with EPA.

Except for parcels previously sold, the Site was acquired by Princess Coals, Inc. in 1978.
In 1982. the Site was purchased by private individuals who later formed Morgantown Industrial
Park, Inc. In 1983, the property was conveyed to Morgantown Industrial Park Associates.
Limited Partnership ("MIPA"), the current property owner.

As a result of the manufacturing operations conducted at the Site, hazardous substances
were generated arid subsequently disposed at, among other places, OUI at the Site.
Contamination at OU2, except for the aforementioned GE facilities, was addressed through a
removal action completed in 1997. The area referred to as OUI was proposed for inclusion on
EPA's National Priorities List ("NPL") on October 15, 1984 and was finalized on the NPL on
June 10, 1986.

In January 1988, EPA completed a Remedial Investigation and Feasibility Study for OU1.
At that time, soils and sediments within the contaminated areas of OUI were determined to be a
principal threat because of the potential for direct dermal contact and ingestion of soils and
sediments.

In March 1988, EPA issued a ROD for OUI calling for onsite incineration of soils and
sediments contaminated with carcinogenic polycyclic aromatic hydrocarbons ("cPAHs") and
heavy metals. In November 1988, EPA opened an additional thirty day comment period for
responsible parties to comment on the ROD.1 Based on comments received during this period,
EPA conducted a focused feasibility study ("FFS") in 1989 to re-evaluate the alternatives
described in the March 1988 ROD and to conduct a risk-based analysis of cleanup levels. This
FFS was completed in June 1989.

On September 29, 1989, EPA issued a new ROD selecting a "preferred" and
"contingency" remedial action for OUI of the Site. The "preferred" remedial action involved,
1 The Agency concluded that the out-of-state responsible parties had not received notice
of the original Proposed Plan for OUI.
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among other things, excavation and treatment of inorganic hot spots from the lagoon and scraped
areas; disposal of treated inorganic contaminants at the former landfill area: capping the former
landfill; and excavation and treatment of organics-contaminated soils and sediments using
bioremediation. The "contingency" remedial action called for treatment of soils and sediments
using soil washing technology. In June 1990, EPA issued an administrative order directing
several responsible parties to implement the September 1989 ROD for OUI.

The human health risk assessment3 that was conducted in conjunction with the OUI
Remedial Investigation ("RI") completed in 1988 was performed prior to the issuance of the new
cancer potency factor ("CPF") established in IRIS3 for Benzo(a)pyrene and the interim
comparative potency estimates provided by EPA's Office of Research and Development ("ORD")
in the guidance document entitled "Provisional Guidance for Quantitative Risk Assessment of
Polycyclic Aromatic Hydrocarbons" (EPA/600/R-93/089 (July 1993)). In 1995. during
implementation of EPA's June 1990 administrative order, the responsible parties recalculated the
cleanup standards for cPAHs at the Site using the new CPF established in IRIS, and the interim
comparative potency estimates established by ORD. The resulting cleanup standard was less
stringent than the cleanup standard identified in the September 1989 ROD. The responsible
parties then submitted a proposal to EPA in July 1995 requesting that the Agency adopt the newly
calculated cleanup standard of 78 ppm total cPAHs. EPA evaluated this proposal using a Monte
Carlo simulation and determined that this cleanup level would result in risk within the acceptable
risk range established in the NCP.4 EPA agreed to adopt the new cPAH cleanup level for OUI.

The responsible parties completed treatability studies for the bioremediation component in
March 1997 under EPA?s June 1990 administrative order. The responsible parties concluded and
EPA agreed that bioremediation was not capable of meeting the 78 ppm total cPAH cleanup
standard within a reasonable time-frame and was not cost-effective. The responsible parties and
EPA additionally concluded that the soil washing contingency action described in the September
1989 ROD was similarly deficient. In the Spring of 1997, the responsible parties submitted a
proposal to EPA to conduct a second Focused Feasibility Study ("FFS") to identify a more
effective remedy for OUI. EPA agreed and negotiated a new agreement with such parties for this
: An ecological risk assessment was not conducted as part of the 1988 RI.

3 IRIS (Integrated Risk Information System) is a database containing Agency consensus
scientific positions on potential adverse human health effects that may result from exposure to
environmental contaminants.

- The Monte Carlo risk assessment concluded that 78 ppm total cPAHs is an acceptable
cleanup standard as long as the associated Benzo (a) Pyrene (B(a)P) equivalent value does not
exceed 18 ppm. Achieving 18 ppm B(a)P equivalents will be part of the cPAH cleanup standard
(see footnote 16 and accompanying text).

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  work in October 1997.  In December 1997, while the draft FFS report was under review by EPA
  and the West Virginia Division of Environmental Protection ("WVDEP"), the State requested
  that more recent groundwater data be collected from GUI. In response to this request.
  groundwater sampling was conducted in January 1998. This groundwater data revealed no
  significant contamination and was incorporated into the FFS report.  The FFS report was
  approved by EPA on September 9, 1998.


  III.   HIGHLIGHTS OF COMMUNITY PARTICIPATION

        Pursuant to section 113(k)(2)(B) of the Comprehensive Environmental Response.
  Compensation, and Liability Act of 1980, as amended ("CERCLA"). 42 U.S.C. § 96113(k)(2)(B).
  EPA released for public comment the final FFS report and the Proposed Remedial Action Plan
  ("Proposed Plan") setting forth EPA's new preferred alternative for Operable Unit No. 1  of the
  Ordnance Works Disposal Areas Site on June 7. 1999.  EPA made these documents available to
  the public in the Administrative Record located at the EPA Region III offices in Philadelphia.
 Pennsylvania, and at the Morgantown Public Library in Morgantown, West Virginia. The notice
 of availability of these documents was published in The Dominion Post on June"7. 1999. A public
 comment period was held from June 7, 1999 to July 8, 1999.  In June 1999. EPA issued a Fact
 Sheet announcing the availability of the Proposed Plan and the date for the public meeting. The
 June 1999 Fact Sheet discussed EPA's Preferred Alternative, as well as other alternatives
 evaluated by EPA. and solicited comments from all interested parties.  In addition, EPA
 conducted a public meeting on June 23, 1999.  At this meeting, EPA and WVDEP representatives
 answered questions about conditions at the Site and the remedial alternatives under consideration.

       The responses to comments received during the public comment period are included in the
 Responsiveness Summary which is part of this ROD.

       This decision document presents the selected remedial action for OU1 of the Ordnance
 Works Disposal Areas Superfund Site, Monongalia County, West Virginia, chosen in accordance
 with the CERCLA and, to the extent practicable, the National Oil and Hazardous Substances
 Pollution Contingency Plan ("NCP"), 40 C.F.R. Part 300.  The selection of the remedial action
 for this Site is based on an Administrative Record which is available for public inspection (see
 footnote 5).
IV.    SCOPE AND ROLE OF THE RESPONSE ACTION

       The selected remedial action described in this ROD is intended to be the final response
action for OU1. The selected remedy eliminates unacceptable risks and hazards presented to both
human health and the environment from contamination at OU1. This ROD supersedes the OU1
ROD issued by EPA on September 29, 1989.

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OU2 was remediated via a removal action in 1997. EPA does not anticipate further
CERCLA response actions within OU2 of the Site, expansion of the NPL listing to include OU2.
or issuance of a ROD for OU2. Although cleanup actions deemed necessary by EPA at the GE
properties within OU2 will likely occur under RCRA, the Agency has reserved' its right to perform
or require CERCLA response actions in connection with such properties.

V. SUMMARY OF SITE CHARACTERISTICS AND EXTENT OF
CONTAMINATION

A. Site Characteristics

1. Topography

The topography at the Site, including OU1, is typical of the Allegheny Plateau, with steep
hilly slopes and narrow valleys drained by short tributary streams. Ground surface elevations
range from 950 feet above mean sea level ("msl") in the lowest areas of OU2 to 1.010 feet above
msl at the Lagoon Area within OU1.

2. Surface Hydrology

All surface drainage in Monongalia County runs to the Monongahela River, which flows in
a northwesterly direction across the county. The system is principally dendritic. Erosional
terraces, high in the Monongahela River valley walls, indicate lake and stream erosional surfaces
at various stages in the regional drainage development. After the terraces were formed, they were
covered with thin deposits of sand, silt, and clay. The Monongahela River and its tributaries
provide water supplies and outlets for sewage disposal for cities and industries situated along the
valleys. The closest drinking water intake for the City of Morgantown is approximately one river
mile downstream from OU1. This intake is located on the river bank opposite the Site.

3. Hydrogeology

Groundwater at the Site occurs primarily in the sandstone bedrock under semi-confined to
confined conditions. To a lesser extent, perched groundwater may also occur within the
unconsolidated sediments overlying the bedrock. The groundwater flow direction is easterly
toward the Monongahela River. There are no direct groundwater users present between OU1 and
the Monongahela River.

The groundwater at the Site is recharged by precipitation. Approximately 42.3 inches of
rainfall occur annually in the Morgantown area. Between 4.2 and 10.5 inches of rain recharge
both the localized, discontinuous, shallow, perched water and the deeper, regional, bedrock
aquifer. The depth to groundwater at OU1 ranges from approximately 30 feet to 88 feet in the
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bedrock aquifer at OU1.

4. Population Demographics

The population in Monongalia County increased from 63.714 to 73.981 over the years
1970 to 1980. In 1983, the county population was 78,842. The city of Morgantown itself had a
population of 30,681 in 1980.

According to 1990 census information, the population of Monongalia County is 75.509
and the population of the city of Morgantown is 25,879. The population is approximately 49.6%
male and 50.4% female and is broken down by race as follows: 95% Caucasian. 2.4% African
American. 2.1%Asian, .84% Hispanic. .24% other, and .17% American Indian. Eskimo, or Aleut.
More than half of the people living in Monongalia County are younger than 40 years old. The
population is broken down by age as follows: 28.2% under 20 years old, 38.6% between 20 and
39 years old, 18.6% between 40 and 59 years old, 12.2% between 60 and 79 years old, and 2.4%
80 years old or older.

5. General Site Geology

Consolidated sedimentary rocks of the Mississippian, Pennsylvanian, and Permian Ages
are present in Monongalia County. In the area of the Site, the upper unit is the Conemaugh
series, a sedimentary rock unit composed of lenticular gray and brown sandstone interbedded with
siltstone and gray and red sandy shale, thick beds of red shale, thin beds of freshwater and marine
limestone, and thin coal beds underlain by clays. The Conemaugh is of Pennsylvanian Age and is
exposed at the surface in West Virginia in a band about 6 miles wide, which trends northeastward
through the Site, locally dipping very gently to the southeast. The thickness of the Conemaugh
series in Monongalia County is from 550 to 600 feet.

The Conemaugh series contains a large number of shale members that weather to form
clays. These clays are characterized by low permeability and, therefore, inhibit the infiltration of
water and promote surface runoff.

B. Nature and Extent of Contamination

EPA has developed an extensive amount of information detailing conditions at OU1. A
majority of the analytical data was obtained during the 1988 Remedial Investigation ("RI"),
during which groundwater, surface and subsurface soils, surface water, and sediments were
sampled. In 1996, after several years of treatability studies were conducted in support of the OU1
remedy selected by EPA in 1989 (bioremediation), EPA arranged for extensive sampling in the
Lagoon Area and Scraped Area (the data from this sampling is presented in the report entitled
"Phase II Interim Design Tasks Report"). Additional groundwater data was obtained in January

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1998. The data evaluated by EPA for purposes of this ROD are available for review in the
Administrative Record.5 This section summarizes Site characteristics based on the sources
discussed above.

1. Groundwater

As part of the 1988 Rl, six monitoring wells were installed into the bedrock formation at
the Site, in areas both upgradient and downgradient of suspected contamination sources. Two
rounds of groundwater sampling were conducted during the RI. the first in March 1986 and the
second in January 1987. During the 1986-87 groundwater sampling events, manganese and iron
were detected at levels above Secondary Drinking Water Standards.6 Methylene chloride and
toluene were detected in nearly every sample; however, these constituents were also detected in
trip and field blanks, indicating that cross contamination at the laboratory was the most likely
source of these detections.

Additional groundwater samples were collected in January 1998 at the request of the
WVDEP. During this 1998 groundwater sampling event, both manganese and iron
concentrations again exceeded Secondary Drinking Water Standards. However, neither
manganese nor iron exceeded Region Ill's risk based concentrations ("RBCs")-7 Data from the
1998 groundwater sampling indicated that the RBC for arsenic (.045 ug/1) was exceeded. A
concentration of 23 ug/1 arsenic was detected in monitoring well DG-03. However, the maximum
contaminant level ('"MCL")8 for arsenic is 50 ug/1. There were no MCL exceedances in either the
1986-87 sampling events or the 1998 sampling event. The groundwater at and downgradient of
OU1 is not used as a drinking water source.
The Administrative Record can be viewed at the following locations: Morgantown
Public Library, 373 Spruce Street, Morgantown, WV 26505; and the U.S. EPA-Region III
Docket Room, 1650 Arch Street, Philadelphia, PA 19103

Secondary Drinking Water Standards are unenforceable federal guidelines regarding
taste, odor, color, and certain other non-aesthetic effects of drinking water.

EPA Region III Risk-Based Concentration Table, originally developed by Roy L. Smith,
Ph.D., Toxicologist, revised 4/12/99 by Jennifer Hubbard, Toxicologist. Also found at
http://www.epa.gov/reg3hwmd/risk/rislcmenu.htm.

3 Safe Drinking Water Act Maximum Contaminant Levels (MCLs) are enforceable
federal standards for public drinking water supplies.
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Neither the March 1988 ROD nor the September 1989 ROD required actions to address
groundwater. There is no evidence that the groundwater has been significantly impacted by
disposal operations at OU1 and no unacceptable risks are posed to receptors of the groundwater
at OU1. Therefore, the remedy selected in this ROD does not include a groundwater remediation
component. EPA does not anticipate the need for a groundwater remedy in the future. However.
this does not preclude the implementation of a groundwater remedy should future conditions
indicate that one is necessarv.
2.
Landfill
The currently inactive landfill was formed when solid and chemical wastes were disposed
of in and around an existing ravine. The landfill was reportedly active from 1942 to 1962. There
are no records regarding the types or quantities of waste material that were disposed of in the
landfill. Information obtained from various witnesses indicates that landfilled wastes included
construction debris, slag, ash, and catalyst pellets. To characterize the Landfill Area, three test
pits were dug and sampled during the RI. Test pitting results indicated a fill depth of 16 to 20
feet. Contaminants detected in the landfill test pits are identified in Table 1 below.
TABLE 1 - LANDFILL SAMPLING RESULTS
Contaminant
Arsenic
cPAHs
Lead
Copper
Concentration (ppm)
6.9- 300
9.6- 1,700
10.0- 2.000
21.0-67,800
The 1989 FFS Report estimated the volume of the landfill at 29,150 yd3, based on an
estimated area of 1.08 acres. During the 1997 removal action at OU2, approximately 10,000 yd3
of soils contaminated with lead (1,600 ppm) and total cPAHs (up to 146 ppm) were removed
from the Coke Ovens and By-Products Area and relocated to OU1 for consolidation into the
landfill.9 These contaminated soils were placed adjacent to the landfill and covered with a
geotextile layer and approximately eight inches of backfill material. The area was then seeded and
surrounded with a silt fence to prevent erosion.

The responsible parties have estimated the area of the landfill to be approximately 1.6
acres. Using this figure, the revised estimate of landfill volume becomes 46,773 yd3. This volume
3 The Coke Ovens and By-Products Area is one of nine specific areas that were
remediated during the 1997 removal action at OU2.
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estimate is a conservative one and was used to estimate the costs of the remedial alternatives
identified in the 1998 FFS Report. The actual boundaries/volumes associated with the Landfill
Area will be established during Remedial Design. The Landfill Area is generally depicted in
Figure 3.

3. Scraped Area

This area consists of bare soil adjacent to the landfill where solid wastes (e.g., construction
debris, oil-stained soils, and catalyst pellets) were buried. This area slopes north and east in the
direction of the Monongahela River. Ten test pits were dug in the scraped area during the 1988
RI. The pits contained cinder-like back fill material, catalyst pellets (blue and black), and yellow
solid materials.

In 1996, as part of the Phase II Interim Design Tasks work, samples were taken from the
Scraped Area, Lagoon Area, and the streams in an attempt to further define volumes of
soil/sediment to be remediated. Thirty-six soil borings were drilled in the Scraped Area on a grid
of approximately 150 by 350 feet. Visible tar was present in samples up to eight feet in depth!
The concentrations of total cPAHs in this area ranged from 94 ppm to 36,000 ppm. The
estimated volume of soils that are contaminated above the total cPAH cleanup standard is 2.000
yd3. Analysis of samples taken in this area in 1996 did not confirm the presence of inorganic
contaminants at concentrations detected during the 1988 RI (EPA has not identified a reason for
this data variation). The Scraped Area is generally depicted in Figure 3.

4. Former Lagoon Area

Between approximately 1970 and 1976, a subsidiary of Rockwell International
Corporation disposed of metal plating wastes containing chromium in two lagoons located
adjacent to the landfill. Between March and September 1981, under the supervision of the West
Virginia Department of Natural Resources (now known as the West Virginia Division of
Environmental Protection), these lagoons were excavated and their contents disposed of offsite.
During the OU1 RI soil boring program, EPA observed miscellaneous wastes, including coal tars,
in this area.

Sample results from soil borings taken during the RI indicate that chromium was present
at concentrations only slightly above background levels, the highest concentration being 2.690
ppm-well below Region Ill's current risk-based concentration level for Chromium VI (10,000
ppm). Arsenic and copper were also detected in the test pit samples but not at concentrations
above their respective soil cleanup standards.

Organic contamination was also detected in soil borings from the Lagoon Area during the
RI. Volatile organic compounds ("VOCs") including xylene (10,000 ppb), toluene (4,100 ppb),
benzene (3,400 ppb), and methylene chloride (2,900 ppb) were detected at elevated levels.

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However, these concentrations are not above the Region III RBC's for industrial soils.

The most notable organic contamination found in the Lagoon Area was cPAHs. which are
semi-volatile in nature. Total cPAHs were detected at concentrations as high as 31.800 ppm.

In 1996, as part of the Phase II Interim Design Tasks work. 103 soil borings were drilled
in the Lagoon Area on a grid of approximately 330 by 380 feet. Fill material such as
brick/concrete fragments, black cinders, and tar were visible in most of the borings. Total cPAH
concentrations in this area ranged from 3.2 ppm to 30,000 ppm. The estimated volume of soils
contaminated above the cPAH cleanup standard (including visibly stained tar-like material) is
24,000 yd3. Analysis of samples taken in this area in 1996 did not confirm the presence of
inorganic contaminants at concentrations detected during the 1988 RI. The Lagoon Area is
generally depicted in Figure 3.
5.
Contaminated Surface Water, Stream Sediments, and Wetlands
Surface water and sediment samples were obtained from four streams during the RI which
was completed in 1988. Elevated levels of total cPAHs (up to 318 ppm) were detected in stream
sediments. The RI/FS Report also indicated that surface water and sediments downgradient of
the Site contained elevated levels of several inorganic compounds. The concentrations of such
inorganic compounds in sediments are well above the background levels (see Table 7 on page
17).'° The contaminant concentrations in surface water and sediment that present ecological
concerns are identified in Table 2 below.
L
TABLE 2 - RI SURFACE WATER AND SEDIMENT SAMPLING RESULTS
Contaminant
Arsenic
Copper
Lead
Mercury
Zinc
Sediment Concentration (ppm)
253
2,150
920
5.4
25.100
1
Surface Water Concentration
N/A
553 ppm
N/A
1.2ppb
44 ppm
•; Existing background levels are identified in "Report of Findings, Sediment and Soil
Sampling For Proposed Outsale Property, Ordnance Works Disposal Areas Superfund Site
Operable Unit Two" (MSES Consultants, Inc. (August 1994)), which is included in the
Administrative Record.
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In 1996, as part of the Phase II Interim Design Tasks work, only three drainage areas from
the Site were identified. Samples from these drainages areas were taken at 100 foot intervals (see
Figure 4). These samples were analyzed solely for cPAHs. Results of this analysis were as
follows:
1 Table 3 - Sediment Sampling Results I
Drainage Swale No.
1
2
3
cPAH Concentration Range (ppra)
5.7 - 1,686
1.1 - 65
19.2 - 221
The total estimated volume of contaminated sediments above the cPAH cleanup standard
from all three streams combined is 500 yd3. This volume estimate is based on cPAH
contamination and does not necessarily include sediments contaminated with inorganic
compounds above background levels.

An ecological risk assessment was not conducted as part of the 1988 RJ. During a recent
review of the RI data, EPA's Biological Technical Assistance Group ("BTAG") identified a
potential concern to ecological receptors due to the inorganic contaminants that were detected in
the surface water and stream sediments during the 1988 RI (see Table 2 on page 10). These
contaminants, if still present at the concentrations listed in Table 2, are believed to coincide in
location with the elevated cPAH concentrations in sediments.

A wetland area associated with the onsite landfill in the northeastern portion of OU1 was
identified by the responsible parties during the Phase II Interim Tasks Remedial Design work
completed in 1996. This wetland area has been delineated and adverse impacts will be mitigated
as appropriate as part of remediation activities. The wetland area is depicted in Figure 5.
VI. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES

Neither OU1 nor the land immediately adjacent to OU1 is currently being used in a
commercial, industrial, or residential capacity. Within one mile of OU1 the land uses range from
active chemical production facilities to the northeast (e.g., GE Specialty Chemicals) to residential
areas to the west. EPA assumes that OU1 will be used for commercial/industrial purposes
following remediation. At present, EPA is not aware of any plans for the reuse of the OU1
property. EPA and WVDEP will work closely with the property owner to ensure that future use
does not adversely impact the selected remedial action
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VII. SUMMARY OF SITE RISKS

As part of the 1988 RI/FS report, EPA prepared an Endangerment Assessment for the
Site in order to identify and define possible existing and future human health risks associated with
exposure to the contaminants present in the various media at OU1 if no action were taken. This
Endangerment Assessment was revised in the 1989 FFS report." In both the 1988 original and
1989 revised Endangerment Assessment documents, EPA concluded that action is necessary to
prevent contact with contaminated soil and sediments found at OU1 of the Site. The
Endangerment Assessment and all supporting environmental data can be found in the
Administrative Record.

A comprehensive Ecological Risk Assessment was not conducted during either the 1988
RI/FS or the 1989 FFS. Following a recent review of the 1988 RI data. EPA's BTAG concluded
that inorganic contaminants are present in surface water and sediments within OU1 at levels that
are acutely toxic to potentially affected ecosystems12.

A. Human Health Endangerment Assessment

In the 1988 Endangerment Assessment, EPA considered the impact of Site-related
contamination on human health for both present and future potential exposure pathways. EPA
concluded that OU1 presented an unacceptable risk to human health from soil and sediment
contamination. Groundwater was not determined to be a contaminant exposure pathway. The
remedy selected in the 1988 ROD, onsite incineration and containment, focused on source control
of contaminants in soils and sediments. The risk-based cleanup level for soils and sediments was
established at 20 mg/kg arsenic and 26 mg/kg total cPAHs, based on a future use scenario in
which construction workers were exposed to Site-related contaminants.

In November 1988, EPA opened an additional thirty day comment period for responsible
parties to comment on the ROD. Based on comments received during this period, EPA
conducted a focused feasibility study ("FFS") in 1989 to re-evaluate the alternatives described in
the March 1988 ROD and to conduct a risk-based analysis of cleanup levels. During this
analysis, EPA specifically focused on eight contaminants: cPAHs, arsenic, cadmium, chromium.
copper, lead, mercury, and zinc. The exposure pathways and use scenarios evaluated in the 1988
The term "Endangerment Assessment" is no longer used in the risk assessment field.
Current guidance refers to a Baseline Human Health Risk Assessment when evaluating human
health risk. For the purposes of this document, "Endangerment Assessment" will be synonymous
with "Baseline Human Health Risk Assessment."

" Memorandum from Jeffrey Turtle to Melissa Whittington re "Comments" (August 25
1998).

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Endangermenl Assessment were used in the analysis. This analysis was used in establishing the
cleanup levels set forth in Table 4 below, for the 1989 ROD. Cleanup levels were not identified
for chromium, mercury, and zinc because the maximum concentrations detected during the 1988
RJ were at concentrations that were below the risk-based cleanup levels.
1 TABLE 4 -SOIL/SEDIMENT CLEAN-UP LEVELS SFT IN THE 1989 ROD 1
CONTAMINANT
Total cPAHs
Arsenic
Cadmium
Copper
Lead
CLEAN-UP LEVEL (mg/kg)
44.7
88.8
642
41,100
500
The Endangerment Assessment was prepared prior to issuance of the new cancer potency
factor ("CPF") established in IRIS13 for Benzo(a)pyrene and the interim comparative potency-
estimates provided by EPA's Office of Research and Development ("ORD") in the guidance
document entitled "Provisional Guidance for Quantitative Risk Assessment of Polycyclic
Aromatic Hydrocarbons" (EPA/600/R-93/089 (July 1993)). In 1995, during implementation of
EPA's June 1990 administrative order, the responsible parties recalculated the cleanup standards
for cPAHs at OU1 using the new CPF established in IRIS, and the interim comparative potency
estimates established by ORD. The resulting cleanup standard was less stringent than the cleanup
standard identified in the September 1989 ROD (44.7 ppm total cPAHs). The responsible parties
then submitted a proposal to EPA in July 1995 requesting that the Agency adopt the newly
calculated cleanup standard of 78 ppm total cPAHs.

While evaluating the responsible parties' proposal, EPA re-evaluated the exposure
scenarios identified in the original Endangerment Assessment. EPA determined that the "future
construction worker" scenario was unrealistic and did not adequately assess the potential risks
posed by contamination at OU1 under the future use scenario. EPA determined that an
"industrial worker" — an individual who would be potentially exposed to soils and sediments
while working at an industrial facility located at OU1 following completion of remediation--
would more accurately depict risks to human health arising from future use of OU1. The
potential exposure pathways that were considered when evaluating the proposed cPAH cleanup
13 See footnote 3.
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standard are shown in Table 5 below.1"1 Three exposure pathways—ingestion of soil/sediment.
dermal contact, and inhalation of dust — are relevant to the future use exposure scenarios_
identified below in Table 5.
1 TABLE 5 - POTENTIAL FUTURE-USE EXPOSURE SCENARIOS 1
EXPOSURE
MEDIUM
Soil/sediments
Air
POTENTIAL
CONTAMINANT
SOURCE
Contaminated
soils
Contaminated
soils
TRANSPORT
MECHANISM
Direct contact
by an industrial
worker
Incidental dust
generation
POTENTIALLY
EXPOSED
POPULATION
Industrial
workers.
unauthorized
persons
Industrial
workers,
unauthorized
persons
POTENTIAL
EXPOSURE
PATHWAY
Ingestion of
soil/sediment,
dermal contact
Inhalation of
dust
EPA incorporated the "industrial worker" future use scenario into its evaluation of the
responsible parties' 1995 proposal to revise the cPAH cleanup standard. l5 Using a Monte Carlo
simulation, EPA determined that as long as a B(a)P equivalence of 18.2 ppm is achieved, cleanup
to 78 ppm total cPAHs would result in risk that is within the acceptable risk range established in
the NCP.16

Excess lifetime cancer risks for carcinogens are determined by multiplying the intake
contaminant level with the Cancer Potency Factor ("CPF"). These risks are probabilities generally
expressed in scientific notation (e.g., 1 x lO"6). An excess cancer risk of 1 x 10'6 indicates that an
individual has a one in one million chance of developing cancer as a result of site-related exposure
14 No unacceptable human health risks have been identified for the current-use exposure
scenario. Therefore, both the 1989 ROD and this ROD focus on the future-use exposure
scenario.

15 When identifying the potentially exposed populations, the Proposed Plan incorrectly
referred to the "construction worker" exposure scenario. EPA considered the "industrial worker"
exposure scenario and not the "construction worker" exposure scenario when it prepared the
Proposed Plan.

•' Hereinafter in this document the term "cPAH Cleanup Standard" shall refer to
achievement of both 78 ppm total cPAHs and 18.2 ppm B(a)P equivalents.
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to a carcinogen over a lifetime under specific exposure conditions at a site. Potential concerns for
effects from non-carcinogens are expressed by calculating a hazard index. The hazard index
provides a useful reference point for determining the potential significance of contaminant
exposure. A hazard index that exceeds 1.0 is unacceptable.

Risk-based cleanup levels for soil and sediments identified in the September 1989 ROD for
the inorganic contaminants at OU1 were not revised and are shown in Table 6 below. The revised
cleanup standard for cPAHs is also shown in Table 6. Following cleanup of arsenic and cPAHs to
their respective risk-based levels, the carcinogenic risk from exposure to arsenic will be 2.34 x
10°, the carcinogenic risk from exposure to cPAHs will be 2.65 x 10'5. and the combined
carcinogenic risk from exposure to arsenic and cPAHs will be 5 x 10'5.17 Therefore, the risk from
exposure to site-related carcinogens after completion of the cleanup action will be within EPA's
acceptable risk range of 1 x 10"4 to 1 x 10~6.

Following cleanup of the non-carcinogenic contaminants of concern — cadmium, copper
and lead ~ to their respective risk-based levels, the risk from exposure to these compounds will
result in an HI of less than one.
1 TABLE 6-CLEA1V
CONTAMINANT
Total cPAHs
Arsenic
Cadmium
Copper
Lead
-UP STANDARDS
CLEAN-UP LEVEL (mg/kg)

78 (18.2 B(a)P equivalent)
88.8
642
41,100
500
B. Environmental Risk Evaluation

The principal purpose of an ecological risk assessment is to determine the extent to
which ecological receptors at a site, if present, are exposed to unacceptable risks from site
contaminants. As most characterization was performed at this Site before EPA developed its
current risk characterization procedures, ecological risks (e.g., the threats to organisms in the
streams and wetland) were not evaluated during the 1988 RI/FS.
-7 See Memorandum from Nancy Rios-Jafolla to Melissa Whittington re "Comments"
(August 17, 1999)(included in the Administrative Record).
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1 TABLE 7 - SEDIMEN1
Contaminant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Zinc
P CLEANUP LEVELS
(ppm)

9.62
0.35
30.20
22.70
31.60
ND
86.80
IX. DESCRIPTION OF REMEDIAL ACTION ALTERNATIVES

The following locations and media at OU1 of the Site warrant action to minimize
potential exposure to hazardous substances as described above:

Onsite surface/subsurface soil in the Scraped Area and the Former Lagoon Area;

Sediments in the streams (also referred to as drainage swales) originating onsite
and in the onsite wetland area;

• Visibly stained tar-like materials in the Scraped Area and Former Lagoon Area
and in sediments in the streams/wetlands; and

The existing, onsite landfill.

This section identifies the remedial alternatives considered by EPA for implementation at
OU1 of the Site to reduce unacceptable risks presented in these locations.
Description of Remedial Alternatives

The September 1998 FFS Report presented nine cleanup options for consideration.
Option 2 (Institutional Controls Only) in the FFS Report does not meet the threshold criteria
(see discussion of threshold, balancing, and modifying criteria in Section X - Summary of
Comparative Analysis of Alternatives) because it does not provide adequate protection of human
health and the environment. Therefore, Option 2 could not be the selected remedy and is not
included among the alternatives discussed in detail in this ROD. Treatability studies performed
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in the course of implementing the remedy selected in the 1989 ROD18 have demonstrated that
Option 7 (bioremediation) is not capable of achieving the cPAH cleanup standards within a
reasonable time frame, if at all. Similarly, Option 8 in the 1998 FFS Report (solvent extraction)
is not anticipated to be capable of achieving the cPAH cleanup standard. Therefore. Options 7
and 8 from the 1998 FFS Report are also not included amona the alternatives discussed in detail
in this ROD.

A description of each of the options, referred to as alternatives below, from the 1998
FFS Report that are protective of human health and the environment, achieve State and Federal
regulatory requirements, and best achieve the cleanup goals for the Site is provided below.1"
The alternatives presented in this ROD are numbered consecutively and do not necessarily
correspond with the numbering system used in the 1998 FFS Report. A description of the
alternatives and the detailed analysis of each follows below.

Alternative 1: No Action

Capital Cost: $0
Annual O&M Cost: $0
Present Worth Cost: $0

The NCP requires that EPA consider a "No Action" alternative for every Superfund site
to establish a baseline or reference point against which each of the alternatives are compared. In
the event that the other alternatives do not offer substantial benefits in the protection of human
health and the environment, the No Action alternative may be considered a feasible approach.
This alternative leaves the Site in its current state and all current and potential future risks would
remain.
Alternative 2: Capping Selected Areas; Excavation and Offsite Treatment of
Stream Sediments; Long-Term Monitoring; and Institutional
Controls

Capital Cost: $ 3,034,686
Annual O&M Cost: $ 58,800
Present Worth Cost: $ 3,767,464
13
'.9
Option 7 in the 1998 FFS Report (Bioremediation and Landfill Capping).
Although Alternative 1 (No Action) does not meet the threshold criteria, EPA includes
the alternative in the detailed analysis as required by the NCP.
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Alternative 2 includes the following components:

• Capping areas within the Lagoon Area and the Scraped Area where surface
and/or subsurface soils are contaminated with cPAHs in excess of the cPAH
Cleanup Standard (see footnote 16) or heavy metals in excess of risk-based
cleanup levels established in the 1989 ROD for OUI20 and capping of the
existing landfill with multi-layer caps meeting the performance requirements for
landfill closure defined in RCRA Subtitle C regulations and associated
guidance;21

• Excavation of sediments contaminated with cPAHs in excess of the cPAH
Cleanup Standard (see footnote 16) and sediments contaminated with inorganic
compounds above background levels from the wetland area and drainage swales
1, 2, and 3 (see Figures 4 and 5) and transportation of these sediments to an
offsite facility for thermal treatment;

• Long-term monitoring;

• Maintenance of the existing perimeter fence; and

• Implementation of institutional controls to protect the cap and prohibit residential
development, recreational use, schools and child care facilities.

Health and safety monitoring, including perimeter monitoring of air for organics and dust
and health monitoring for job site personnel, would be performed throughout the Remedial
Action. This Alternative would also provide appropriate measures to control dust during
construction.

Cap Construction

A separate multi-layer RCRA cap would be constructed over soils exceeding the cPAH
and metals cleanup standards in the Lagoon Area and the Scraped Area. In addition, a multi-
layer RCRA cap would be constructed in the Landfill Area which would cover the areal extent
Those standards are as follows: 88.8 ppm for arsenic, 642 ppm for cadmium, 500 ppm
for lead, and 41,100 ppm for copper.

The description of Alternative 2 in the Proposed Plan erroneously omitted that the
area to be capped also includes soils exceeding the inorganic soil cleanup standards.

21 Hereinafter, the term "multi-layer RCRA cap" shall refer to a cap that meets the
performance requirements for landfill closure defined in RCRA Subtitle C regulations and
associated guidance.
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of previously landfilled material and the materials which would be consolidated into the landfill
from the 1997 removal action at OU2. Pre-design sampling would be conducted to determine
the areal extent of the Landfill Area. The areal extent of the Lagoon Area and Scraped Area is
well defined.

The caps would be constructed to minimize infiltration of precipitation throughout these
areas as well as to minimize contaminant migration to streams. The caps would also prevent
direct exposure to contaminated soils. The caps would be designed in accordance with RCRA
Subtitle C closure requirements to, among other things, promote run-off and drainage and
minimize erosion. Extensive grading would be needed within the Landfill Area because of the
existing exposed face and steep slope on the northeast side.

Surface water controls, including drainage ditches and regrading, would be provided to
control run-on and run-off of surface waters. Settling and subsidence would be considered in
the design to maintain long-term integrity of the caps.

A multi-layer RCRA cap can vary in design configurations based on site characteristics
and intended future use of the capped area. Although the exact configuration of the cap
components for OU1 would be determined during remedial desigorthe typical components of a
RCRA multi-layer cap are as follows:

• Top Cover: This layer is designed to minimize erosion and infiltration of rain water. A
vegetative cover is the most common top cover used to protect the underlying layers of a
cap, but alternative designs would be evaluated and considered based on anticipated
future use of the capped areas (e.g., parking).

• Soil Cover: This layer is designed to provide sufficient root support for the vegetative
cover, if appropriate. It should provide sufficient thickness to protect the underlying
layers from vegetative root disturbance, to prevent freeze damage to liner, and should
act as a cushion between vehicles and underlying liners, which could be stressed by the
movement of vehicles on the surface.

• Filter Layer: This layer separates the soil cover layer from the drainage layer, thus
preventing soil layer fines from clogging the drainage layer. Typically, the filter layer is
comprised of sand, gravel, and/or geotextiles.

• Biotic Layer: This layer, generally consisting of rock and/or geotextiles, prevents
ground squirrels, rats, groundhogs, and other burrowing animals from penetrating the
impervious layer.

• Drainage Layer: This layer provides a path that diverts precipitation and runoff from
infiltrating into the waste. Material options for the drainage layer generally include
multiple layers of geotextile fabrics, sand, and/or gravel.

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Low Hydraulic Conductivity Geomembrane/Soil Layer: This layer reduces the amount
of water that percolates down through the soil and which would otherwise come into
contact with the underlying waste. ~~

Gas Vent System Layer. This layer reduces or eliminates the buildup of gas inside
capped areas. The systems used are site-specific and components may vary.

• Surface Water Controls: This cap component typically includes installation of drainage
ditches and regrading of the surrounding area to control run-on and run-off of surface "
waters.

Site preparation activities would have to be performed at OU1 before cap construction
could begin. Site preparation would include mobilization, clearing and grubbing, regrading,
miscellaneous site improvements, and surface water control as described below.

It would be necessary to clear certain areas of OU1 of trees, brush, and other vegetation.
Removal of tree roots, or grubbing, would also be necessary. Site access roads would be
improved, as needed, and temporary utilities (electric, sanitary, potable water, etc.) would be
installed.

Surface water would be controlled through the installation of permanent surface run-off
controls such as drainage swales, berms, and channels. Additional surface water controls, such
as regrading, stabilization of embankments, and revegetation. would be implemented as
necessary.

Sediment Excavation

Ail visibly stained tar-like material in the streams (identified as drainage swales 1, 2, and
3 (see Figure 4)) and the wetland area would be excavated. All sediment in the above-
mentioned drainage swales that exceed the cPAH Cleanup Standard or are above background
levels for inorganic compounds would also be excavated. Prior to excavation activities,
sampling would be performed in the drainage swales and wetland areas to ensure that all areas
with concentrations of inorganic compounds exceeding background levels are identified. All
Work would meet West Virginia Water Quality Standards.

The excavated tar-like material and sediments would be transported to an offsite facility
for thermal treatment. Confirmation sampling of excavated areas would be required to ensure
achievement of cleanup standards. Analysis of confirmation samples from the streams would
include Target Analyte List ("TAL") metals as well as cPAHs. If confirmation sampling reveals
cPAHs at levels in excess of the cPAH Cleanup Standard (see footnote 16) or TAL metals for
those compounds identified in Table 7 at levels greater than the cleanup standards set forth
therein, excavation activities would continue until the cPAH Cleanup Standard is achieved and
metals concentrations are at or below the cleanup levels in Table 7 (see footnote 23 and

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accompanying text for details regarding the establishment of the metals cleanup levels).
Following excavation, the streams would be restored as described below to minimize erosion of
the stream beds.

Stream Restoration and Wetlands Mitigation

Stream restoration activities would be required to prevent flooding or erosion and to
help the stream beds recover from excavation activities. Restoration measures could include,
among other things, reshaping or lining of stream areas with a geotextile and/or rip-rap to
prevent flooding and erosion. Specific stream restoration measures would be determined during
the design phase of remediation. However, restoration goals would include maintenance or
replacement of existing contours, vegetative characteristics, instream aquatic habitat, and vernal
pools for the benefit of macroinvertebrates and fauna. EPA anticipates that bermswould be
constructed across the drainageways during construction and or restoration activities to provide
further assurance that contaminated sediments are not released and to provide a means to
mitigate impacts to the wetland that may result from capping activities. It is anticipated that the
resulting retention areas would be planted with aquatic vegetation that would stabilize
sediments.

All unavoidable wetland impacts would be clearly documented during design and would
include acreage estimates and the type of wetlands affected. All unavoidable losses would be
mitigated. The specific size, type, and location of the replacement wetlands, if necessary, would
be developed in consultation with Federal and State Natural Resource Trustees and would be set
forth in the Remedial Design. Wetland losses would be mitigated "in-kind" and onsite. if
possible. Replacing the existing wetland function and values would be the primary mitigation
goals.

Long-Term Monitoring

A long-term monitoring program would be required for this alternative because waste
materials would be left onsite. Groundwater, surface water, and sediment sampling would be
conducted in accordance with a monitoring plan developed during the design phase. EPA
presently anticipates that groundwater sampling would be conducted on a quarterly basis and
that surface water and sediment sampling would be performed on an annual basis. All sampling
would be performed in accordance with an approved sampling and analysis plan. Laboratory
analysis would be performed in accordance with EPA protocols. Other elements of the long-
term monitoring would include periodic cap inspections. 5-year reviews, maintenance of the
perimeter fence installed in 1996, and cap maintenance activities as appropriate (e.g., mowing).
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Institutional Controls

Institutional controls are generally intended to isolate human or animal populations from
contaminants through, among other things, land use controls and public awareness. Because
these controls do not prevent migration of contaminants, long-term monitoring is normally
provided to measure the effectiveness of site isolation. In some cases, institutional controls
alone will prevent completion of an exposure pathway and protect human populations.
Frequently these actions are combined with containment or treatment methods to achieve
protectiveness. At OU1 under Alternative 2. institutional controls would be implemented to
protect the integrity of the caps, to prohibit residential development, to prohibit recreational use.
and to prohibit operation of schools or child care facilities within OU1.
Alternative 3: Consolidation of Contaminated Media; Capping of Existing
Landfill; Long-Term Monitoring; and Institutional Controls

Capital Cost: $2,296,260
Annual O&M Cost: $ 52,500
Present Worth Cost: $2,950,526

Alternative 3 consists of consolidating cPAH- and inorganics-contaminated soils and
sediments from Lagoon Area, the Scraped Area, and the streams into the existing landfill, which
would then be capped. This alternative would involve:

• Excavation of all sediments contaminated with cPAHs in excess of the cPAH
Cleanup Standard (see footnote 16), sediments contaminated with inorganic
compounds above background levels, and visibly stained tar-like material from
the wetland area and drainage swales 1, 2, and 3 (see Figures 4 and 5) as
described in Alternative 2;

• Consolidation of the excavated soils and sediments, as well as materials
stockpiled onsite from the 1997 removal action at OU2, into the existing landfill;

• Capping the existing landfill using the procedures described in Alternative 2;
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• Backfilling, regrading, and revegetating the excavations in the Lagoon Area and
the Scraped Area;

• Restoration of streams and wetland areas where sediment was excavated as
described in Alternative 2;

• Long-term monitoring;

• Maintenance of the existing perimeter fence; and

• Implementation of institutional controls to protect the cap and prohibit residential
development, recreational use, schools and child care facilities.

This alternative is very similar to Alternative 2, but involves consolidation of
contaminated media (i.e., soils and sediments above the cPAH and inorganic cleanup standards)
from the Lagoon and Scraped Areas and the drainage swales into the existing landfill prior to
capping rather than construction of three separate caps. A multi-layer R.CRA cap would be
constructed over this landfill. The exact specifications for this multi-layer RCRA cap would be
determined during Remedial Design. No waste would be shipped offsite for treatment under this
alternative.

After excavating the contaminated sediments from the streams, the streams would be
restored to minimize erosion of the stream beds. Wetlands mitigation would be required and
confirmation sampling for stream sediments would be conducted as described in Alternative 2
(including inorganic analysis of the stream sediments).

Institutional controls would be implemented to protect the integrity of the cap, to
prohibit residential development, to prohibit recreational use, and to prohibit operation of
schools or child care facilities within OU1.

Site preparation and health and safety monitoring activities similar to those identified in
Alternative 2 would be performed under this alternative.

Because waste would be left onsite. the long-term monitoring program (including 5-year
reviews) described for Alternative 2 would be required for Alternative 3.

Excavation of Soils

The soils contaminated with total cPAHs or metals in excess of the cleanup standards in
the Lagoon and Scraped Areas as well as surface and subsurface debris and visibly stained tar-
like materials would be removed from these areas. All debris currently piled onsite or
encountered during excavation would be separated from the contaminated soils, temporarily
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staged, and ultimately disposed of in an appropriate manner (e.g., recycled, landfilled. etc.). The
actual equipment and methods used in excavation activities would be determined during pre-
design and design phases of the remediation.

Excavated areas would be backfilled to maintain acceptable grades and control surface
water runoff. The backfill media could originate from offsite source(s) or could be media
(verified clean) from the Site, depending on the remedial alternative. Generally, the top 4 to 6
inches of backfill material would be topsoil capable of sustaining plant growth indigenous to the
area. Typically, the topsoil would be seeded with grasses. The specific requirements for
backfilling and revegetation, if any, would be determined during the design phase of the
remediation. When determining the procedures for backfilling, grading, and revegetating
excavated areas during design (if appropriate), the anticipated future use of the property will be
taken into consideration.

The presence of inorganic contaminants detected during the 1988 RI was not confirmed
during the 1996 sampling of the Scraped Area and the Lagoon Area. However, to ensure that
unacceptable levels of metals are not left in the soils, analysis of confirmation samples in these
areas would include TAL metals. The cleanup standards for metals from the September 1989
ROD (see footnote 20) will be applied in the Scraped Area and the Lagoon Area.

Confirmation sampling of the excavations in the Scraped Area and Lagoon Area would
be required to ensure achievement of cleanup standards. If confirmation sampling reveals
cPAHs or metals at levels greater than the cleanup standards, excavation activities would
continue until both the cPAH and metals cleanup standards are achieved.
Alternative 4: Construction of an Onsite RCRA Subtitle C Compliant Landfill;
Consolidation of Contaminated Media; Long-Term Monitoring; and
Institutional Controls

Capital Cost: $ 6,964,103
Annual O&MCost: $ 63,000
Present Worth Cost: $ 7,749,222

Alternative 4 involves construction of an onsite landfill which meets the requirements of
RCRA Subtitle C. This alternative includes the following components:

• Excavation of the existing landfill, including soils contaminated with cPAHs in
excess of the cPAH Cleanup Standard (see footnote 16), soils contaminated with
inorganic compounds in excess of the inorganic cleanup standards set in the
September 1989 ROD (see footnote 20), miscellaneous debris, and all visibly
stained tar-like material;
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Excavation of all sediments contaminated with cPAHs in excess of the cPAH
Cleanup Standard (see footnote 16), sediments contaminated with inoraanic
compounds above background levels, and visibly stained tar-like material from
the wetland area and drainage swales 1, 2, and 3 (see Figures 4 and 5) as
described in Alternative 2;

Construction of an onsite landfill which meets the requirements of RCRA Subtitle
fromQQ or n SXCaVTd S°ilS ^ S6dimentS' as wel1 as stockPiIed
irom the 1997 OU2 removal action, into the newly constructed landfill:

Construction of a multi-layer RCRA cap over the new landfill;

Backfilling regrading, and revegetating the excavations in the Lagoon Area and
the bcraped Area;

Backfilling, regrading, and revegetating the excavated landfill;

Restoration of streams and wetland areas where sediment was excavated as
described in Alternative 2;

• Long-term monitoring;

Maintenance of the existing perimeter fence; and

Implementation of institutional controls to protect the new landfill and prohibit
residential development, recreational use, schools and child care facilities.

,'nn™ F°r,thiS altema?ve' a11 soils md sediments that are contaminated above the cPAH and
norganic cleanup standards would be excavated and consolidated into a newly constructed

slthle C T™ " CrtmCted landfi11 W°Uld bC dCSigned t0 meet the requirements of RCRA
ltdfi 1 L^'P, P^Prre t0 my contaminated materials consolidated into the new
andfill, a multi-layer RCRA cap would be constructed over this landfill. The specifications for
the cap would be determined during Remedial Design. ""canons »r

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The new landfill would be designed to contain all of the wastes from the Landfill Area
(approximately 46,773 yd3); from the Lagoon Area (approximately 24,000 yd3); from the_
Scraped Area (approximately 2,000 yd3); the stream sediments (approximately 500 yd3), and the
materials from the 1997 OU2 removal action that are stockpiled at OU1 (approximately 10.000
yd3). The capacity of this new landfill is estimated at between 80.000 yd3 and 105.000 yd3
(including fill materials) and is estimated to occupy an area between 2 and 4 acres.

Health and safety monitoring activities and dust control measures similar to those
identified for Alternative 2 would also be required under this alternative.

Institutional controls would be implemented to protect the integrity of the new RCRA
landfill as well as its cap, to prohibit residential development, to prohibit recreational use. and to
prohibit operation of schools or child care facilities within OU1.

Excavations in the Scraped Area, the Lagoon Area, and the Landfill Area would be
backfilled, regraded, and seeded. Confirmation sampling for the Lagoon Area, the Scraped
Area, and the Landfill Area soils would be conducted as described in Alternative 3.

Because waste would be left onsite, the long-term monitoring program (including 5-year
reviews) described for Alternative 2 would be required for Alternative 4.
Alternative 5: Offsite Treatment of Visibly Stained Stream, Lagoon, and Scraped
Area Soils/Sediments; Consolidation of Contaminated Media into
the Existing Landfill; Capping of Existing Landfill; Long-Term
Monitoring; and Institutional Controls

Capital Cost: $6,033,199
Annual O&M Cost: $ 52,500
Present Worth Cost: $ 6,687,465

Alternative 5 includes the following components:

• Excavation of all visibly stained tar-like material from the Lagoon Area, Scraped
Area, and stream sediments and transportation of this visibly contaminated waste
material to an offsite thermal treatment facility for treatment;
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• Excavation of all soils contaminated with cPAHs in excess of the cPAH Cleanup
Standard (see footnote 16) and soils contaminated with inorganic compounds in
excess of the inorganic cleanup standards set in the September 1989 ROD (see
footnote 20) from the Lagoon Area and the Scraped Area and consolidation of
this contaminated soil into the existing landfill as described in Alternative 3:

• Excavation of all sediments contaminated with cPAHs in excess of the cPAH
Cleanup Standard (see footnote 16) and sediments contaminated with inorganic
compounds above background levels from the wetland area and drainage swales
1, 2, and 3 (see Figures 4 and 5) as described in Alternative 2. and consolidation
of these sediments into the existing landfill:

• Backfilling, regrading, and revegetating the excavations in the Lagoon Area and
the Scraped Area;

• Restoration of streams and wetland areas where sediment was excavated as
described in Alternative 2;

• Construction of a multi-layer RCRA cap over the existing landfill:

• Long-term monitoring;

• Maintenance of the existing perimeter fence; and

• Implementation of institutional controls to protect the cap and prohibit residential
development, recreational use, schools and child care facilities.

Alternative 5 involves excavating the visibly stained tar-like materials from the Lagoon
Area, Scraped Area, and stream sediments and transporting these excavated materials to an
offsite thermal treatment facility. Mechanical methods such as a shaker-screen could be used to
isolate debris (wood fragments, construction debris, bricks, etc.), tar, and soils. The actual
equipment and methods which would be used in excavation and segregation activities will be
determined during pre-design and design phases of the remediation. It is appropriate to treat the
visibly stained tar-like material differently than the rest of the contaminated soil because it
contains extremely high concentrations of cPAHs and is, by virtue of its consistency, less
amenable to capping.

All other soils from the Lagoon Area and Scraped Area that contain cPAHs in excess of
the cPAH Cleanup Standard (see footnote 16) and inorganic compounds in excess of the
inorganic cleanup standards set in the September 1989 ROD (see footnote 20), but do not
contain visibly stained tar-like media, would be excavated and consolidated onto the existing
landfill. Similarly, all sediments that contain cPAHs in excess of the cPAH Cleanup Standard or
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inorganic compounds above background levels, but do not contain visibly stained tar-like media.
would also be excavated and consolidated onto the existing landfill. The materials staged at OU1
during the 1997 OU2 removal action would also be consolidated onto the existing landfill.

A multi-layer RCRA cap would be constructed over the existing landfill. The exact
specifications for this multi-layer RCRA cap would be determined during Remedial Design.

Health and safety monitoring activities and dust control measures similar to those
identified for Alternative 2 would also be required under this alternative.

Excavations in the Scraped Area and the Lagoon Areas would be backfilled, regraded.
and seeded. Confirmation sampling for the Lagoon Area and Scraped Area soils would be
conducted as described in Alternative 3.

Institutional controls would be implemented to protect the integrity of the cap, to
prohibit residential development, to prohibit recreational use. and to prohibit operation of
schools or child care facilities within OU1.

Because waste would be left onsite, the long-term monitoring program (including 5-year
reviews) described for Alternative 2 would be required for Alternative 5.
Alternative 6: Offsite Treatment of all Contaminated Stream, Lagoon, and
Scraped Area Soils/Sediments; Capping of Existing Landfill; Long-
Term Monitoring; and Institutional Controls

Capital Cost: $14,517,761
Annual O&M Cost: $ 52,500
Present Worth Cost: $15,172,027

Alternative 6 includes the following components:

• Excavation of all soils contaminated with cPAHs in excess of the cPAH Cleanup
Standard (see footnote 16), soils contaminated with inorganic compounds in
excess of the inorganic cleanup standards set in the September 1989 ROD (see
footnote 20), and all visibly stained tar-like material from the Lagoon Area and
the Scraped Area, as described in Alternative 3;
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• Excavation of all sediments contaminated with cPAHs in excess of the cPAH
Cleanup Standard (see footnote 16), sediments contaminated with inorganic
compounds above background levels which are identified in Table 10 of this
ROD, and visibly stained tar-like material from the wetland area and drainage
swales 1, 2. and 3 (see Figures 4 and 5) as described in Alternative 2;

Transportation of the excavated material as well as material stockpiled from the
1997 OU2 removal action to an offsite thermal treatment facility for treatment:

• Backfilling, regrading, and revegetating the excavations in the Lagoon Area and
the Scraped Area;

• Restoration of streams and wetland areas where sediment was excavated as
described in Alternative 2;

Construction of a multi-layer RCRA cap over the existing landfill;

• Long-term monitoring;

• Maintenance of the existing perimeter fence; and

• Implementation of institutional controls to protect the cap and prohibit residential
development, recreational use, schools and child care facilities.

Alternative 6 involves excavating all soils and sediments above their respective cleanup
standards and visibly stained tar-like material from the Lagoon Area, the Scraped Area and
drainage swales 1, 2. and 3 (see Figure 4).

All excavated material, as well as the materials staged onsite from the 1997 OU2
removal action, would be transported to an offsite thermal treatment facility for treatment.

A multi-layer RCRA cap would be constructed over the existing landfill. The exact
specifications for this cap would be determined during Remedial Design.

Health and safety monitoring activities and dust control measures similar to those
identified for Alternative 2 would also need to be performed for this alternative.
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Excavations in the Scraped Area and the Lagoon Area would be backfilled, regraded.
and seeded. Confirmation sampling for the Lagoon Area and Scraped Area soils would be
conducted as described in Alternative 3.

Because waste would be left onsite, the long-term monitoring program (including 5-year
reviews) described for Alternative 2 would be required for Alternative 6.
X. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

Each of the remedial alternatives summarized in this ROD has been evaluated against the
nine evaluation criteria set forth in the NCP (see 40 C.F.R. § 300.430(e)(9)). These nine criteria
are organized into three categories—threshold criteria, primary balancing criteria, and modifying
criteria. Threshold criteria must be satisfied in order for a remedy to be eligible for selection.
Primary balancing criteria are used to weigh major trade-offs between remedies. Modifying
criteria are formally taken into account after public comment is received on the Proposed Plan.
The criteria, as well as the evaluation of each of the alternatives against such criteria, is set forth
below.
Threshold Criteria

1 - Overall protection of human health and the environment determines whether
an alternative can adequately protect human health and the environment, in both
the short- and long-term, from unacceptable risks posed by hazardous substances
present at the Site.

2. Compliance with Applicable or Relevant and Appropriate Requirements
P'ARARs") evaluates whether the alternative attains Federal and State
environmental statutes, regulations, and other requirements that pertain to the
Site.
Primary Balancing Criteria

3. Long-term Effectiveness and Permanence considers the ability of an alternative
to maintain protection of human health and the environment over time.
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4- Reduction ofToxicitv. Mobility, or Volume of Contaminants through
Treatment evaluates an alternative's use of treatment to reduce the harmful
effects of contaminants, reduce their ability to move in the environment, and
reduce the amount of contamination present.

5- Short-Term Effectiveness considers the length of time needed to implement an
alternative and the risks the alternative poses to workers, residents, and the
environment during implementation.

6- Implementability considers the ease or difficulty of implementing an alternative
and includes, among other things, technical feasibility, administrative feasibility.
and availability of services and materials.

7. Cost includes estimated capital and operation and maintenance costs expressed as
present worth costs. Present worth cost is the total cost of an alternative over
time in today's dollars.

Modifying Criteria

8- State Acceptance considers whether the State concurs with, opposes, or has no
comment on the Selected Remedy.

9- Community Acceptance considers whether the community agrees with the
selected remedy. This is assessed in detail in the ROD responsiveness summary
(attached) which addresses public comments received on the Proposed Plan.

A. Overall Protection of Human Health and the Environment

A primary requirement of CERCLA is that the selected remedial alternative be protective
of human health and the environment. A remedy is protective if it reduces current and potential
risks to acceptable levels, as set forth in the NCP, for each exposure pathway at the Site.

Alternative 1 (No Action), would not effectively reduce risk to human health and the
environment. Alternative 1 involves no remediation to address the contamination or risks at
OU1 of the Site. Contaminated soils and sediments in the Lagoon Area, Landfill Area, Scraped
Area, and streams/wetland would remain. Trespassers and potential future industrial workers
could be exposed to potentially harmful levels of contaminants in these soils and sediments.
Contaminated surface soil would continue to migrate offsite and into the streams and wetland
area. In addition, potentially adverse ecological impacts could continue unabated at the Site.
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The "No Action" alternative is considered in the detailed analysis to provide a baseline
for comparison with the other remedial alternatives. Because Alternative 1 does not meet the
threshold criteria of overall protection of human health and the environment, this alternative will
not be considered further in this analysis.

Alternatives 2. 3, 4. 5, and 6 are all protective of human health and the environment.
Each of these alternatives reduces the potential for exposure to and migration of OU1
contaminants.

Under Alternative 2, the contaminated soil in the Lagoon Area.. Scraped Area, and
Landfill Area would remain in place, but the threats presented to human health and the
environment through contact or migration would be reduced by capping the contaminants in
place. Alternative 3 combines all of the contaminated soils and sediments into one place (the
existing landfill) and reduces contact and migration risks through capping. Under Alternative 4.
Site risks are reduced by combining all of the onsite contaminated soils and sediments in a newly
constructed RCRA Subtitle C compliant landfill. Alternative 5 reduces Site risks by separating
and removing the highly concentrated waste to an offsite treatment facility and consolidating and
capping the remaining contaminated soil and sediment. Alternative 6 combines capping of the
Landfill Area with excavation of all remaining OU1 contaminants (soil and sediments in the
Lagoon Area, the Scraped Area and the streams) for treatment offsite.

Alternatives 2, 3, 4, 5, and 6 all include long-term monitoring to ensure the engineering
controls continue to be protective and institutional controls to protect the remedial components
and prevent exposure to contaminants remaining onsite.
B. Compliance with ARARs

Any cleanup alternative selected by EPA must comply with all applicable or relevant and
appropriate federal and state environmental requirements ("ARARs"). Applicable requirements
are those substantive environmental standards, requirements, criteria, or limitations promulgated
under federal or state law that are legally applicable to the Remedial Action to be implemented
at the Site. Relevant and appropriate requirements, while not being directly applicable, address
problems or situations sufficiently similar to those encountered at the Site that their use is well-
suited to the particular site.

ARARs are chemical-specific (which pertain to certain substances), action-specific
(which pertain to certain activities, such as cap construction), or location-specific (which pertain
to certain locations, such as wetlands). An assessment of each of the Alternatives' ability to
attain major chemical-, action-, and location-specific ARARs follows.
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Chemical-Specific ARARs

There are currently no chemical-specific ARARs establishing acceptable concentrations
for contaminants in soil or sediment at OU1 of the Site.

Action-Specific ARARs

Alternatives 2. 3. 5. and 6, which all include construction of RCRA multi-layer cap(s).
would meet the substantive requirements of any required RCRA ARARs with regard to closure
and post-closure at a RCRA landfill.

Alternative 4, which includes construction of a new RCRA landfill, would meet RCRA
ARARs with regard to design, operation, closure, and post-closure of a RCRA landfill.

Alternatives 3, 4, 5, and 6, would meet RCRA hazardous waste ARARs triggered by
excavation of contaminated soils including storage time limits, manifesting, and transporting
requirements.

Location-Specific ARARs

Alternatives which may disturb wetlands during implementation (Alternatives 2. 3. 4. 5.
and 6) would include actions to avoid adverse impacts to such wetlands, minimize wetlands
destruction, and preserve and enhance the value of the wetlands, to the extent required by 40
C.F.R. Part 6, Appendix A. In addition, such Alternatives would meet West Virginia Water
Quality Standards found at 46 CSR 1.
C. Long-Term Effectiveness and Permanence

Alternatives 2, 3, 4, 5, and 6 would all effectively prevent direct contact exposure to, and
migration of, contaminated soils in the Scraped Area. Lagoon Area, and Landfill Area by
capping the contaminated soils in place, consolidating contaminated soils into the existing
landfill and capping, or consolidating contaminated soils into a newly constructed landfill and
capping. Monitoring would, however, be necessary to ensure the long-term effectiveness and
permanence of all capping alternatives.

Alternatives 2, 3, and 4 would provide adequate long-term effectiveness as long as the
visibly stained tar-like media does not reduce the stability of the caps. The stability issue relates
to the ability of the tar-like media to provide a stable base for the various capping layers. Under
Alternative 2, the tar-like media would be capped in place; under Alternative 3, all media
contaminated above the cleanup standards (including the tar-like media) would be consolidated
into the existing landfill and capped; and under Alternative 4, all media contaminated above the
cleanup standards (including the tar-like media) would be placed in a newly constructed landfill
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and capped. EPA anticipates that the stability issue relating to the tar-like media would be less
of a concern for Alternative 4, given the large volume of material that would be mixed with the
tar-like media prior to landfilling. The cap components of Alternatives 2, 3, and 4 would have
to be engineered to take into account the potential instability of the tar-like material.

Alternatives 2, 3. 4, 5, and 6 would reduce risks posed by the contaminants contained in
sediments by effectively preventing direct contact exposure to, and migration of. these
contaminated sediments. This would be accomplished via excavation of such sediments and
either offsite thermal treatment (Alternatives 2, 5, and 6) or consolidation into the existing or
newly constructed landfill and capping (Alternatives 3, 4, and 5). No further controls for the
excavated stream sediments would be necessary for Alternatives 2 or 6 to ensure long-term
effectiveness and permanence.

Alternatives 5 and 6 would eliminate the risks posed by the contaminants contained in
the visibly stained tar-like material via offsite thermal treatment. Further controls for those
materials would not be necessary to ensure long-term effectiveness and permanence.
D. Reduction of Toxicity, Mobility and Volume

Section 121(b) of CERCLA, 42 U.S.C. § 962l(b), establishes a preference for remedial
actions which include treatment that permanently and significantly reduces the toxicity. mobility,
or volume of contaminants.

The principal threat identified at OU1 is presented by the very high concentrations of
cPAHs in the visibly stained tar-like materials present in the Scraped Area, Lagoon Area, and
the streams draining the Site. Alternatives 5 and 6 would address this threat via offsite
treatment of the tar-like media, thereby reducing toxicity, mobility, and volume of the highest
concentrations of contaminants through treatment. Alternative 2 would use treatment to
address the threats posed by the tar-like material in the sediments only.

Alternative 2, 3,4, 5, and 6 would reduce mobility of contaminants remaining onsite
through capping, which would reduce infiltration of precipitation and surface erosion.
E. Short-Term Effectiveness

Alternative 2 offers the greatest short-term effectiveness. This alternative requires the
least amount of soil-handling activities because it entails the least amount of excavation (stream
sediments only) and no consolidation of contaminated soil would be required. Therefore, under
this alternative, there would be little potential for exposure of workers and/or potential
trespassers to Site-related contaminants.
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Alternatives 3 and 5 achieve very good short-term effectiveness. Although these
alternatives require more excavation and handling of contaminated materials than Alternative 2.
the level of potential exposure to workers or trespassers to Site-related contaminants would be
minimal. Alternatives 5 and 6 involve the excavation and offsite treatment of contaminated soil
and could pose an increased short-term health risk to onsite workers and/or potential trespassers
during earth-moving activities.

Alternatives 4 and 6 require the most excavation and handling of contaminated materials
and thereby pose the greatest short-term risks for exposure of workers and/or trespassers to
Site-related contaminants among the alternatives.

All short-term risks to site workers and/or potential trespassers would be minimized
using standard safety measures.

There is no significant difference among implementation times for each of the
alternatives meeting the threshold criteria. It is anticipated that Alternatives 2, 3, 5, and 6 could
be implemented within 6 months from the start of construction. Although Alternative 2 requires
a greater area to be capped, this alternative does not require excavation in the Lagoon Area and
the Scraped Area and the time required for implementation of this remedy should be comparable
to Alternatives 3, 5, and 6. Alternative 4 would have the longest implementation time because it
requires construction of a new RCRA compliant landfill. This alternative is estimated to take up
to one year to complete.
F. Implementability

Installation of the caps called for in Alternatives 2, 3,4, 5, and 6 involves well-known
construction methods and is easily implementable. Necessary services and materials for caps are
readily available. It should be noted however, that Alternatives 2, 3, and 4 would have to be
engineered to address the stability issues associated with the tar-like material.

Alternatives 2, 3,4, 5, and 6 also require some degree of excavation of contaminated soil
and sediments. Excavation is similarly a straightforward and commonly performed process
using readily available materials and services. Additional sampling and waste characterization
would be necessary for these alternatives to ensure the removal of the appropriate volume of
soils and sediments. Sampling and analysis are routine activities in the Superfund program.
Excavation activities for Alternative 5 would be slightly more difficult to implement than
Alternatives 2, 3, 4, and 6 because the additional step of segregating the tar-like material from
the remaining contaminated soils and sediments would be required. Segregation methods would
be determined in the remedial design phase.
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Alternatives 2, 5, and 6 require offsite transportation and treatment of contaminated soils
and sediments. Transportation of Site soils and sediments should not pose any unusual technical
difficulties and appropriate treatment facilities with capacity for the contaminated soils and
sediments should be available within a reasonable distance from the Site.

Alternative 4-construction of a new onsite landfill-would be the most complex
alternative to implement. Excavation and storage of contaminated soils and sediments durinc
construction of the new landfill would present complications as space within OU1 is limited."
Additional precautions would be necessary to prevent contamination of clean areas used to store
excavated contaminants.

Worker exposure and protective equipment requirements for construction activities can
be readily achieved for each of the alternatives. Alternatives 2, 3. 4, 5. and 6 would include air
monitoring. All alternatives would provide appropriate measures to control dust.

Alternative 2 would be the easiest alternative to implement. Alternatives 3. 5. and 6
would be slightly more difficult to implement because these alternatives require more extensive
excavation. Alternative 4 would be the most difficult to implement because it requires
construction of a new RCRA compliant landfill as well as the greatest amount of excavation.

G. Cost

Evaluation of the cost of each alternative generally includes the calculation of direct and
indirect capital costs and the annual operation and maintenance O'O&M") costs, both calculated
on a present worth basis. An estimated capital, annual O&M. and total present worth cost for
each of the Alternatives has been calculated for comparative purposes and is presented in Table
8 below.

Direct capital costs include costs of construction, equipment, building and services, and
waste treatment. Indirect capital costs include engineering expenses, start-up and shutdown,
and contingency allowances. Annual operation and maintenance costs include labor and
materials; administrative costs and purchased services; monitoring costs; cost for periodic Site
review (at least every five years); and insurance, taxes, and license costs. For cost estimation
purposes, a period of 30 years has been used for operation and maintenance. In practice,
operation and maintenance of a site with waste left in place would be expected to continue
beyond this period. The actual cost for each alternative is expected to be in a range from 50
percent higher than the costs estimated to 30 percent lower than the costs estimated. This cost
evaluation was based on the cost estimates prepared by the United States Army Corps of
Engineers (USAGE).22
22 Following completion of the September 1998 FFS report, comments from EPA's
BTAG required that additional measures regarding remediation and restoration of the stream and
wetland areas be added to the options identified in the FFS report. The alternatives in this ROD
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38
[\ TABLE 8 - SUMMARY OF ESTIMATED COSTS 1
Alternative No.
2
3
4
5
6
Capital Cost
$ 3.034,686
S 2,296,260
S 6,964,103
S 6,033,199
S 14.517,761
Annual O&M Cost
$ 58.800
S 52,500
S 63^000
$52,500
$ 52.500
Present Worth Cost
S 3,767,464
S 2.950.526
S 7.749.222
S 6,687.465
S 15,172.027
H. State Acceptance

The West Virginia Division of Environmental Protection ("WVDEP"). on behalf of the
State of West Virginia, concurs with the selected remedy (see Appendix B).
I. Community Acceptance

A public comment period on the Proposed Plan was held from June 7, 1999 (the date the
Proposed Plan was issued) through July 8, 1999. On June 23. 1999, EPA and WVDEP
conducted a public meeting at the Westwood Middle School gymnasium in Morgantown, West
Virginia, to discuss the Proposed Plan. At this meeting, representatives from EPA answered
questions about conditions at the Site and the remedial alternatives under consideration.

Comments received orally at the public meeting and in writing during the comment
period are presented and addressed in the Responsiveness Summary, which is included in this
ROD.
XI. THE SELECTED REMEDY AND PERFORMANCE STANDARDS

Following consideration of the requirements of CERCLA, a detailed analysis of the
alternatives using the nine criteria set forth in the NCP, and careful review of public comments,
EPA has selected Alternative 5 (Offsite Treatment of Visibly Stained Stream, Lagoon, and
Scraped Area Soils/Sediments; Consolidation of Contaminated Media into the Existing Landfill;
include these additional measures. Using estimates provided by USAGE, EPA revised the cost
estimates in this ROD to include the costs of these additional stream and wetland remediation and
restoration measures.
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Capping of Existing Landfill; Long-Term Monitoring; and Institutional Controls) for
implementation at OU1 of the Site. The following are the key components of the selected
remedy as well as the Performance Standards associated with such components:

1. Excavation of all visibly stained tar-like material from the Lagoon Area,
Scraped Area, and stream sediments and transportation of this visibly
contaminated waste material to an qffsite thermal treatment facility for
treatment.

Tar-like material is present throughout OU1 of the Site. The tar-like material is easily
distinguishable from contaminated soils because of its distinctive black color and rubber-like'.
elastic consistency. All such material shall be identified and excavated from the Lagoon Area.
the Scraped Area, and the streams/wetland area. Throughout the soils excavation activities
(described below), the tar-like material shall be segregated from the contaminated soils and
stockpiled onsite until all excavations are complete. All of the stockpiled tar-like material shall
then be transported, in accordance with Department of Transportation regulations governing
shipment of hazardous wastes, to an offsite facility for thermal treatment to destroy the cPAH
contamination. Selection of such treatment facility shall be subject to approval by EPA.

2. Excavation of all soils contaminated with cPAHs in excess of the cPAH
Cleanup Standard and soils contaminated with inorganic compounds in
excess of the inorganic cleanup standards set in the September 1989 ROD
from the Lagoon Area and the Scraped Area and consolidation of this.
contaminated soil into the existing landfill.

Contaminated surficial and subsurface soils in the Lagoon Area and the Scraped Area
shall be excavated and consolidated into the existing landfill prior to capping. Following
excavation of such soils, confirmation sampling shall be conducted to ensure all soils
contaminated above cleanup standards have been removed. The excavations shall then be
backfilled, regraded, and seeded.

Excavation of contaminated surface and subsurface soils within the Lagoon and Scraped
Areas shall continue until (1) all soils contaminated with total cPAHs in excess of 78 ppm have
been removed, (2) all soils contaminated with B(a)P equivalents in excess of 18.2 ppm have
been removed, and (3) all soils contaminated with inorganic compounds exceeding any of the
levels identified in Table 9, below, have been removed:
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Ordnance Works Disposal Areas Superfund Site
Operable Unit No. I Record Of Decision
40
TABLE 9 - INORGANIC CLEANUP LEVELS FOR
Contaminant
Arsenic
Cadmium
Copper
Lead
Cleanup Level
88.8 ppm
642 ppm
41.100 ppm
500 ppm
As indicated above, achievement of the cPAH Cleanup Standard shall include
achievement of 78 ppm total cPAHs and achievement of 18.2 ppm B(a)P equivalent. All
excavated soils shall be consolidated into the existing landfill prior to capping.

Confirmation sampling shall be conducted in accordance with an EPA-approved
sampling plan which shall include, at a minimum, collection of grab samples from the bottom and
sides of the excavation and analysis of such samples for TAL metals and Semi-Volatile Organic
Compounds ("SVOC") in accordance with EPA protocols.

After confirmation sampling has confirmed that the above-described contaminated soils
have been removed, the excavations shall be backfilled with clean fill material. Erosion control
measures (e.g., seeding) shall be implemented.
3. Excavation of all sediments contaminated with cPAHs in excess of the cPAH
Cleanup Standard and all sediments contaminated with inorganic compounds
above background levels from drainage swales 1, 2, and 3 and the wetland
area, and consolidation of these sediments into the existing landfill.

At present, the full extent of inorganic contamination in the streams and the wetland area
is not known. In addition, the full extent of cPAH contamination in the wetland area is not
known. Prior to sediment excavation activities, streams and wetland area sediments shall be
sampled in accordance with an EPA-approved sampling plan. Stream sediment samples shall be
analyzed for TAL metals. Wetland sediment samples shall be analyzed for TAL metals and
cPAHs. The results of such sediment sampling will be used to identify the areas of the streams
and wetland that may contain inorganic contamination above background levels and areas of the
wetland that may contain cPAH contamination above 78 ppm total cPAHs and 18.2 ppm B(a)P
equivalents. The areas to be excavated shall be based on the above-described inorganic
sampling data as well as the extensive cPAH data obtained during the 1996 Phase II Interim
Design activities. A summary of the results of this sampling event are found in Table 3 on page
11 of this ROD.
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Ordnance Works Disposal Areas Superfund Site
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41
Contaminated sediments in the streams and wetland area which exceed either the above-
described cleanup level for cPAHs or the background levels for inorganics shall be excavated.
This excavated sediment shall then be dewatered and consolidated into the existing landfill prior
to capping. Following excavation of such sediment, confirmation sampling shall be conducted
to ensure all sediment contaminated above these cleanup standards has been removed.

Excavation of contaminated sediments shall continue until (1) all sediments contaminated
with total cPAHs in excess of 78 ppm have been removed, (2) all sediments contaminated with
B(a)P equivalents in excess of 18.2 ppm have been removed, and (3) all sediments contaminated
with inorganic compounds exceeding any of the levels identified in Table 10. below, have been
removed.'3
1 TABLE 10 - INORGANIC CLEANUP LEVELS FOR SEDIMENTS IN
1 STREAMS AND WETLANDS
Contaminant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Zinc
Cleanup Levei
9.62 ppm
0.35 ppm
30.2 ppm
22.7 ppm
3 1 .6 ppm
Non-detect
86.8 ppm
^Background levels were calculated using sample data obtained during a June 23, 1994
assessment performed on behalf of the Site owner in support of the proposed sale of a portion of
the property (see "Report of Findings, Sediment and Soil Sampling for Proposed Outsale Property
Ordnance Works Disposal Areas Super Fund Site, Operable Unit Two" (August 1994) in the
Administrative Record). The background for each contaminant was calculated by taking the mean
concentration for each contaminant based on the June 1994 samples. The cleanup levels are
equivalent to the mean concentration of each contaminant plus one standard deviation. EPA's
BTAG agrees that such levels are protective of the environment (see Memorandum from Jeffrey
Turtle (Biologist, USEPA Biological Technical Assistance Group) re "Inorganic Cleanup Levels
for Sediments in Streams and Wetlands" (September 20, 1999), also in the Administrative
Record).
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Ordnance Works Disposal Areas Superfund Site 42
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As indicated above, achievement of the cPAH Cleanup Standard shall include
achievement of 78 ppm total cPAHs and achievement of 18.2 ppm B(a)P equivalent. All
excavated soils shall be consolidated into the existing landfill prior to capping.

Confirmation sampling shall be conducted in accordance with an EPA-approved
sampling plan which shall include, at a minimum, collection of samples from an area immediately
adjacent to and downstream of the excavated sediments and analysis of such samples for TAL
metals and SVOCs in accordance with EPA protocols. All work shall meet West Virginia Water
Quality Standards.

Reasonable efforts will be taken to protect wildlife from harm during the excavation
activities including, among other things, temporary relocation of such wildlife if necessary.
4. Consolidation ofOU2 Materials.

The materials that were stockpiled at OU1 during the 1997 OU2 removal action shall be
consolidated into the existing landfill prior to capping. For purposes of this ROD. the
stockpiled materials shall include all cPAH- and lead-contaminated rubble formerly located along
the southern coke oven and lead- and cPAH-contaminated soil that was excavated and moved to
OU1 during a removal response action completed in 1997. This material is approximately
10,000 cubic yards in volume and was stockpiled adjacent to the landfill's west side. This
stockpiled material was then covered with eight inches to one foot of soil, mulched, and seeded.

Following consolidation of such OU2 material into the existing landfill, confirmation
sampling shall be conducted in the area where such material was stockpiled to ensure that no
contamination above 78 ppm total cPAHs, above 18.2 ppm B(a)P equivalents, or above 500
ppm lead is left in this area. This confirmation sampling shall be conducted in accordance with
an EPA-approved sampling plan which shall include a minimum of two grab samples analyzed
for TAL metals and SVOCs in accordance with EPA protocols.
5. Restoration of streams and wetland areas where sediment was excavated.

The streams and wetland areas shall be restored to prevent flooding or erosion and to
help the stream beds recover from excavation activities. Restoration goals shall include
maintenance or replacement of existing contours, vegetative characteristics, instream aquatic
habitat, and vernal pools for the benefit of macroinvertebrates and fauna. Specific stream
restoration measures shall be determined during Remedial Design and shall be implemented in
accordance with an EPA-approved Stream Restoration Plan.
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Ordnance Works Disposal Areas Super/and Site 43
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All unavoidable wetland impacts shall be clearly documented during design and shall
include acreage estimates and the type of wetlands affected. All unavoidable wetland losses
shall be mitigated.

Specific wetlands mitigation measures shall be determined during Remedial Design and
shall be implemented in accordance with an EPA-approved wetlands mitigation plan. The
specific size, type, and location of the replacement wetlands, if any, shall be developed in
consultation with Federal and State Natural Resource Trustees and shall be determined during
Remedial Design. Wetland losses shall be mitigated "in-kind" and onsite. if deemed appropriate
by EPA. Replacing the existing wetland function and values shall be the primary wetland
mitigation goals.
6. Construction of a multi-layer RCRA cap over the existing landfill.

Following consolidation of soils and sediments from various areas of the Site, a multi-
layer RCRA cap shall be installed over the existing landfill. The exact areal extent of the landfill
shall be determined during Remedial Design. The cap will prevent direct contact with, and
inhalation of, potentially harmful dust generated from contaminated soil. The cap will also
prevent offsite migration of contaminated soil and reduce the amount of precipitation which
infiltrates through contaminated soil above the water table and into the ground water.

A multi-layer RCRA cap shall be installed over the existing landfill. This cap shall be
designed, constructed, and maintained to meet the performance requirements of RCRA Subtitle
C regulations found at 40 C.F.R. §§ 265.19, 265.111, 265.117, 265.118, and 265.310. The cap
shall cover the areal extent of the existing landfill as determined during Remedial Design.

The cap shall also be designed to meet the performance requirements of the following
EPA technical guidance documents: "Final Covers on Hazardous Waste Landfills and Surface
Impoundments" (EPA/530-SW-89-047, July 1989); "Design and Construction of
RCRA/CERCLA Final Covers" (EPA/625/4-91/025, May 1991) and "Construction Quality
Management for Remedial Action and Remedial Design Waste Containment Systems"
(EPA/540/R-92/073, October 1992).

The cap shall be designed to minimize infiltration, control surface water run on/runoff,
and collect and monitor landfill gas (when necessary to protect the cap and prevent the
uncontrolled release of landfill gasses). Cap construction/characteristics shall also include, at a
minimum, the following:

• Surface water drainage controls, including drainage channels, will be constructed to
prevent erosion of the cap and to channel runoff away from the landfill.
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1
Ordnance Works Disposal Areas Superfund Site
Operable Unit No. I Record Of Decision
44
• The top layer shall consist of two components: (1) either a vegetated or armored surface
component, selected to minimize erosion and, to the extent possible, promote drainage
from the cover, and (2) a soil component with a minimum thickness of 60 cm (24-
inches), comprised of topsoil and/or fill soil as appropriate, the surface of which slopes
uniformly at least 3 percent but not more than 5 percent. A soil component of greater
thickness may be required to assure that the underlying low-permeability laverls below
the frost zone.

A drainage layer shall be installed above the synthetic barrier to allow water to drain off
the synthetic barrier and to prevent the ponding of water over the synthetic barrier. If
this layer is soil, it shall have a minimum thickness of 30-cm (12 inch) with a minimum
hydraulic conductivity of 1 x 10'2 cm/sec and a minimum transmissivity of no less than
3 x lO" m-/sec. This soil layer is intended to minimize water infiltratio'n into the low-
hydraulic conductivity layer and should have a final slope of at least 3 percent after
settlement and subsidence. The drainage layer can be comprised of a geosynthetic
material having the above hydraulic characteristics.

The top low hydraulic conductivity layer shall be a synthetic barrier. This will be the
main barrier which prevents water infiltration from entering the landfill. This synthetic
barrier shall be a type of flexible geomembrane at least 40 mil thick. The type of flexible
geomembrane shall be selected to prevent infiltration and minimize the potential for
sliding. Selection of this material shall occur during remedial design.

The bottom low hydraulic conductivity layer shall be installed to minimize potential
leakage through the low hydraulic conductivity geomembrane into the landfill. This layer
acts as a safeguard to the geomembrane and is generally made of clay or a geosynthetic
clay liner O'GCL"). The bottom layer for the selected remedy shall be a GCL. However.
GCLs cannot be placed on very steep slopes. The side slopes of the composite barrier
layer shall be on a 4:1 angle and may, if needed to increase the friction angle for the
GCL, be reinforced with a geogrid. This layer shall have a hydraulic conductivity no
greater than 1 x 10-7 cm/sec.

A gas management layer may be installed, if necessary to protect the cap and prevent the
uncontrolled release of landfill gasses.

An engineered surface water runoff and erosion control system will be designed and
installed to control surface water runoff. The system will include surface grading and storm
water retention basins and outfall structures, as necessary. The design for the erosion control
system shall be subject to EPA approval.

Specific plans for maintenance of the cap and surface water control structures shall be
included in the Operation and Maintenance Plan ("O&M Plan"). Maintenance of these
components shall continue for 30 years from construction completion or such other time period
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as EPA, in consultation with WVDEP, determines to be necessary, based on the statutory
reviews of the Remedial Action conducted no less often than every five years.
7. Long-term Monitoring.

Long-term ecological monitoring will be performed to confirm that the RCRA cap is
preventing offsite migration of Site-related contaminants. The ecological monitoring program
shall include sediment and surface water sampling in the streams and the wetland area. The
specific monitoring program will be developed during the Remedial Design and shall be subject
to EPA approval.

Periodic monitoring of groundwater will be conducted to ensure that the selected remedy-
is preventing migration of Site-related contaminants into the groundwater. The specific ground
water monitoring plan will be developed during the Remedial Design and shall be subject to
EPA approval. The ground water monitoring well network will be comprised of a combination
of existing and new monitoring wells established to optimize the monitoring program. All
monitoring wells must be designed, installed, maintained, and abandoned in accordance with the
substantive provisions of the West Virginia Groundwater Protection Act (see Appendix A).

Long-term ecological and groundwater monitoring shall continue for 30 years from
construction completion or such other time period as EPA, in consultation with WVDEP.
determines to be necessary based on the statutory reviews of the Remedial Action conducted no
less often than every five years from the initiation of the Remedial Action in accordance with the
applicable guidance.
8. Maintenance of the Perimeter Fence.

OU1 is currently enclosed by a perimeter fence. Following completion of the Remedial
Action the fence may, upon approval by EPA, be reconfigured to enclose only those areas where
wastes have been managed in place (e.g., the existing landfill). The existing perimeter fence, as
well as any fence subsequently reconfigured, shall be maintained to prevent access to the
contaminated and capped areas by trespassers.
9. Institutional Controls.

The integrity of the cap shall be protected through the implementation of institutional
controls. Residential development, recreational use, schools, and child care facilities shall be
prohibited within OU1. Institutional controls shall be implemented to accomplish these
objectives in accordance with an EPA-approved plan to be developed during Remedial Design.

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Ordnance Works Disposal Areas Superfund Site
Operable Unit No. 1 Record Of Decision
10. Five-Year Reviews.
Five-year statutory reviews under section 121(c) of CERCLA, 42 U.S.C. § 962 l(c), will
be performed as long as hazardous substances remain onsite. Five-year reviews will be
conducted after the remedy is implemented to assure that the remedy continues to protect
human health and the environment.
XII. STATUTORY DETERMINATIONS

Section 121 of CERCLA, 42 U.S.C. § 9621, requires that EPA select a remedial action
that is protective of human health and the environment, complies with ARARs, is cost effective.
and utilizes permanent treatment technologies to the maximum extent practicable. This section
describes how the selected remedy meets these statutory requirements.

A. Protection of Human Health and the Environment

Based on the Endangerment Assessment for OU1, EPA concludes that action should be
taken to reduce potential risk from cPAHs and heavy metals in the soil and sediments at the Site.
Such action is necessary because potential health hazards for some exposure scenarios evaluated
in the Endangerment Assessment exceeded EPA's target range of 1.0 x 10'6 (or 1 in 1,000.000)
to 1.0 x 10"* (or 1 in 10,000) for increased lifetime cancer risk. In addition, EPA concludes that
concentrations of inorganic contaminants in surface water and sediments present an
unacceptable risk to ecological receptors. These risks were considered in establishing the
Remediation Objectives set forth in Section VIII of this ROD.

The capping and consolidation of soil and sediment into the existing landfill called for in
the selected remedy will prevent direct contact with organic contaminants in soils and sediments
that exceed the cPAH Cleanup Standard, prevent direct contact with inorganic contaminants in
soils that exceed risk-based cleanup standards, reduce or eliminate inorganic contaminants in
sediments that exceed background levels, reduce the potential for organic and inorganic
contaminants in soils and sediments to migrate to the groundwater or to migrate offsite, reduce
or eliminate the threat of direct contact with contaminants in the landfill and reduce or eliminate
the threat of migration of contaminants from the landfill. Implementation of the selected remedy
will thereby reduce the human health risks presented by OU1 to within EPA's target risk range
and prevent exposure of ecological receptors to harmful levels of Site-related contamination in
sediment and surface water in the onsite streams and wetland area.

The institutional controls called for in the selected remedy will help preserve the integrity
of the cap and prevent exposure to sensitive populations (e.g., children) to onsite contaminants.

Implementation of the selected remedy will not pose any unacceptable short term risks or
cross media impacts to the Site or the community.
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Ordnance Works Disposal Areas Superfund Site 4 j
Operable Unit No. 1 Record Of Decision

B. Compliance with and Attainment of Applicable or Relevant and Appropriate
Requirements ("ARARs")

The selected remedy will comply with all applicable or relevant and appropriate
chemical-specific, location-specific, and action-specific ARARs. Those ARARs are identified in
Appendix A.

C. Cost-Effectiveness

Section 300.430(f)(l )(ii)(D) of the NCP, 40 C.F.R. § 300.430(f)(l)(ii)(D), requires EPA
to evaluate cost-effectiveness by comparing all the alternatives which meet the threshold criteria-
-protection of human health and the environment and compliance with ARARs-against long-
term effectiveness and permanence; reduction of toxicity, mobility or volume through treatment:
and short-term effectiveness. The NCP further states that overall effectiveness is then compared
to cost to ensure that the remedy is cost effective and that a remedy is cost effective if its costs
are proportional to its overall effectiveness.

EPA concludes, following an evaluation of these criteria, that the selected remedy is
cost-effective in providing overall protection in proportion to cost and meets all other
requirements of CERCLA. The estimated present worth cost for the selected remedy is
$6,687,465.

D. Utilization of Permanent Solutions and Alternative Treatment Technologies to the
Maximum Extent Practicable

The principal threat presented by the tar-like material at OUI will be eliminated by
offsite thermal treatment of such material. The reduction of highly concentrated cPAHs will be
permanent. An alternative treatment technology will not be utilized. The remainder of the
selected remedy addresses lower-level threats through waste containment, institutional controls,
and long-term monitoring and maintenance to provide the necessary level of protection to
human health and the environment.

EPA has determined that the selected remedy represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in a cost effective manner for
OUI. Of those remedial alternative combinations that are protective of human health and the
environment and comply with ARARs, EPA has determined that the selected remedy provides
the best balance in terms of short-term effectiveness; long-term effectiveness; implementability;
cost; reduction in toxicity, mobility, and volume; and State and community acceptance.

E. Preference for Treatment as a Principal Element

The selected remedy satisfies the preference for treatment in that it employs treatment to
address the principal threat posed by conditions at OUI of the Site (i.e., the tar-like materials).
The remaining lower- level threats at OUI will be addressed via waste containment, institutional
controls, and long:term monitoring and maintenance.
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RESPONSIVENESS SUMMARY
ORDNANCE WORKS DISPOSAL AREAS SUPERFUND SITE
OPERABLE UNIT ONE
MORGANTOWN, MONONGALIA COUNTY, WEST VIRGINIA

This community relations responsiveness summary is divided into the following sections:

Overview: This section discusses EPA's preferred alternative for remedial action.

Background: This section provides a brief history of community interest and concerns raised
during remedial planning at the Ordnance Works Disposal Areas Site.

Parti: This section provides a summary of issues and concerns raised by the local
community at the public meeting on June 23, 1999. "Local community" includes
local homeowners, businesses, the municipality, and potentially responsible parties
('•PRPs").

Part K: This section provides a summary of commentors' issues received in writing
throughout the comment period.

OVERVIEW

On June 7, 1999, EPA published its preferred alternative for the Ordnance Works Disposal Areas
Superfund Site, Operable Unit One ("OU1"), located in Morgantown. Monongalia County. West
Virginia, and announced the public comment period. EPA screened six possible alternatives to
remediate soil and sediment contamination, giving consideration to nine key evaluation criteria
found in the NCP:

• Threshold criteria, including

Overall protection of human health and the environment
Compliance with Federal and state environmental laws

• Balancing criteria, including

Long-term effectiveness
Short-term effectiveness
Reduction of mobility, toxicity, or volume
Ability to implement
Cost, and
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« Modifying criteria, including

State acceptance, and
Community acceptance

The selected remedy. Alternative 5, includes the following components:

• Excavation and Offsite Treatment of Tar-Like Material: Excavation and offsite
treatment of the principal threat waste (tar-like material) to reduce the potential for
migration of contaminants to offsite soils and surface water/sediment as well as to reduce
the risk due to the potential exposure to such principal threat waste;

• Consolidation of Contaminated Soils and Sediments: Excavation and consolidation of
soils and sediments contaminated with cPAHs and heavy metals in excess of their
respective cleanup standards into the existing landfill;

• RCRA Cap: Construction of a RCRA cap over the existing landfill and consolidated soils
and sediments to prevent offsite migration of contaminants and to eliminate the potential
threat of direct contact with contaminated soils and sediments;

• Institutional Controls: Implementation of institutional controls to protect the integrity
of the cap, to prohibit residential development, to prohibit recreational use. and to prohibit
operation of schools and child care facilities within OU1.

• Long-Term Ecological and Groundwater Monitoring: The purpose of such monitoring
is to ensure continued protectiveness of the remedy.
BACKGROUND

To obtain public input on the Proposed Remedial Action Plan (Proposed Plan or PRAP), EPA
held a public comment period from June 7, 1999 to July 8, 1999. In addition, EPA held a public
meeting on June 23, 1999 to explain the preferred alternative and to answer questions. Local
residents and officials, news media representatives, representatives from EPA, and representatives
from companies interested in Site activities and cleanup decisions attended the meeting.

EPA notified the public of the June 23,1999 public meeting and announced the public comment
period in a display ad placed in the June 7, 1999 editions of The Morgantown Dominion Post.
In addition, EPA placed copies of the Proposed Plan in the Site information repository at the
Morgantown Public Library. The repository contains the Administrative Record supporting
selection of the Remedial Action and includes, among other things, the Remedial Investigation,
the Endangerment Assessment, the 1989 and 1998 Feasibility Studies, the Proposed Plan, and
other relevant documents upon which EPA relied in selecting the remedial action for OU1.
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EPA also prepared a fact sheet which was mailed to the community and local officials and
distributed to individuals in attendance at the public meeting. The fact sheet included a summary
of the Proposed Plan.

Part I: Summary of Issues and Concerns Raised at the Public Meeting ~

This section provides a summary of issues and concerns raised by the local community at the
public meeting held on June 23, 1999. Two individuals provided oral comments at the public
meeting. Both of these comments covered essentially the same issue and are summarized as
follows:

Comment: Both commenters expressed the opinion that removal of the contaminated
soils and sediments would be preferable to capping such materials onsite.

EPA Response: Under the selected remedial action (Alternative 5). the principal threat
presented at OU1 of the Site-the highly concentrated carcinogenic polycyclic aromatic
hydrocarbons in the visibly stained tar-like material-will be addressed by removing such
materials from the Site for treatment. The cap component of the selected remedial action
will effectively manage the remaining consolidated wastes in place. Caps are often
constructed at sites to prevent the potential for direct contact with the contamination and
to prevent the offsite migration of wastes. Capping is a proven technology and has been
used at similar sites across the country. While the Superfund law expresses a preference
for treatment of hazardous wastes, the law requires EPA to take cost-effectiveness into
account in its selection of remedies. In this case, the cost of excavating all contaminated
material and transporting it offsite for treatment (SI5,172,027.00) is significantly higher
than the cost of capping this material and does not yield significantly greater protection
of human health or the environment. The selected remedy protects human health and the
environment at a more reasonable cost (S6,687,465.00) and is therefore more cost-
effective.
Part II: Summary of Comments and Questions Received in Writing During the
Public Comment Period

This section provides a summary of commentors' issues received in writing throughout the
comment period. The Agency received one letter. That letter contained the following substantive
comment:

Comment: The commenter was concerned about the use of the "mean background
concentration" as a cleanup standard for inorganic contaminants in sediments. Because
these values are averages derived from several samples, the commenter expects that some
number of samples would naturally be above the "mean background concentration" and yet
still be within the acceptable background concentration range.
-------
EPA Response: EPA agrees. To address this concern, the cleanup standards for inorganic-
contaminants in sediment have been revised. The cleanup standards in this ROD are now
based on the mean value plus one standard deviation as shown in Table 10. The data used
in calculating the cleanup levels was limited to the nine (9) samples taken during the June
23, 1994, sampling event conducted on the proposed outsale property at the Ordnance
Works Disposal Areas Superfund Site, Operable Unit Two ("OU2"). The proposed outsale
property consists of a 272.87 acre parcel of land that occupies the westerly portion of the
property known as the Morgantown Industrial Park. A detailed description of the property
as well as its historical use can be found in the Administrative Record in a report entitled
"Report of Findings, Sediment and Soil Sampling for Proposed Outsale Property
Ordnance Works Disposal Areas Super Fund Site Operable Unit Two, Mon View Heights
of West Virginia ("MVH"), Dupont Road, Morgantown. West Virginia" authored by MSES
Consultants. Inc. C'MSES") dated August, 1994. See also Memorandum from Ken Brown
(Director. USEPA Technical Support Center) re "Statistical Questions Regarding
Background Metals Concentrations" (September 20, 1999), also in the Administrative
Record.
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1
Figures
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ORDNANCE WORKS DISPOSAL
AREAS SUPERFUND SITE
REGIONAL SETTING
Morgantown
Figure 1
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Figure 2

RDNANCE WORKS DISPOSAL
AREAS SUPERFlND SITE
OPERABLE UNITS
ONE AND TWO
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31 IS SXMOM 13NVNOMO NMOINVSMOH
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DRAINAGE SWALE
DRAINAGE SWALBS
ORDNANCE NORKS DISPOSAL AREA SITE
MORGANTOWN, NV
Figure 4
.,-M
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ETLANUS=-O.I49| ACRES
•WETLANDS •= 0.4060 ACRES
;Sc\~ -' N i I / -. i \y\n\ w /.< //
ORDNANCE WORKS DISPOSAL AREAS

xNWETLANDS DELINEATION MAP/ "

- '- I///FIGURE 5 •'-^/^3/
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Appendix A
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Appendix A
Applicable or Relevant and Appropriate Requirements
Ordnance Works Disposal Areas Superfund Site
Morgantown, West Virginia
Statute/Authority
I. LOCATION
SPECIFIC
Groundwater
Protection Act
(State)

Executive Order
11990, Protection
of Wetlands
(Federal)

Regulation

47 CSR 58-
4.10

40 C.F.R. 6,
Appendix A

Clean Water
Act of 1972
(CWA)
Section 404
Classification

Relevant and
Appropriate

Applicable

Requirement Sy

Facility or activity design
adequately address the iss
from locating in karst, we
subsidences, delineated w
protection areas determine
Action to minimize the de
or degradation of wetland;

Applicability to Selected Remedy
This regulations shall apply if
implementation of the remedy affects
such vulnerable areas.
This applies to ensure the minimization
of wetland impacts to remedial action
activities.
nUSER\AGOLDMAN\MAILDOCtAVERIOARA (September 28. 1999 (5.39PM)]
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Appendix A
Applicable or Relevant and Appropriate Requirements
Ordnance Works Disposal Areas Superrund Site
Morgantown, West Virginia
II. ACTION
SPECIFIC
Resource
Conservation and
Recovery Act
(Federal)
40 C.F.R.
265.19
Relevant and
Appropriate
Construction Quality Assurance
Program.
Construction of the cap shall comply
with these quality assurance
requirements.
Resource
Conservation and
Recovery Act
(Federal)
40 C.F.R.
265.111
Relevant and
Appropriate
For a closing facility, owner must
minimize need for further maintenance;
control, minimize, or eliminate post-
closure escape of hazardous waste,
hazardous constituents, leachate,
contaminated run-off, or hazardous
waste decomposition products to the
ground or surface waters or to the
atmosphere; and comply with other
closure requirements.
Post-closure monitoring and maintenance
of the landfill shall comply with these
requirements.
F \USER\AGOLDMAWHAILDOCU\VER10 ARA (StpitmbCT 28.1999 (5:39PM))
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Appendix A
Applicable or Relevant and Appropriate Requirements
Ordnance Works Disposal Areas Superfund Site
Morgantown, West Virginia
Resource
Conservation and
Recovery Act
(Federal)
40 C.F.R.
265.114
Relevant and
Appropriate
During final closure, all contaminated
equipment, structures, and soil must be
properly disposed of, or
decontaminated.
During implementation of the selected
remedy, all required decontamination
procedures will be complied with.
Resource
Conservation and
Recovery Act
(Federal)
40 C.F.R.
265.117
Relevant and
Appropriate
Post-closure care for each hazardous
waste management unit must begin after
completion of closure and continue for
30 years after that date. It must consist
of monitoring and reporting of
environmental media and maintenance
and monitoring of waste containment
systems.
Post-closure monitoring and maintenance
of the landfill shall comply with these
requirements.
Resource
Conservation and
Recovery Act
(Federal)
40 C.F.R.
265.118
Relevant and
Appropriate
The owner or operator must develop a
written post-closure plan. The post-
closure plan must identify activities to
be carried on after closure and the
frequency of these activities .
To ensure the integrity of the cap and the
function of the monitoring equipment,
post-closure monitoring and maintenance
of the landfill shall comply with these
requirements.
F:\l)SER\AGOLUMAN^MAIl.DOClWER10.ARA (Stpirmbcr 28, 1999 (5 19PM))
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Appendix A
Applicable or Relevant and Appropriate Requirements
Ordnance Works Disposal Areas Superfund Site
Morgantown, West Virginia
Resource
Conservation and
Recovery Act
(Federal)
AIR
Clean Air Act,
National Ambient
Air Quality
Standards
(Federal)
Air Pollution
Control Act
(State)
40 C.F.R.
265.310
40 C.F.R.
Part 50
45 CSR4
Relevant and
Appropriate
Applicable
Applicable
Final cover to provide long-term
minimization of infiltration. Function
with minimum maintenance. Promote
drainage and minimize erosion. 30-year
post-closure care to ensure site is
maintained and monitored.
Defines air quality standards that are
necessary to protect human health
Regulations to prevent and control the
discharge of air pollutants into the open
air which causes or contributes to an
objectionable odor or odors.
These requirements shall apply to
construction and post closure
requirements for the cap.
Applicable if work at the Site affects
ambient air quality.
The remedial action will comply with the
substantive requirements of these
regulations
F:\USER\ACXDLDMANWAJLDOCU\VER10ARA [September 28. 1999 (5.39PM))
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Appendix A
Applicable or Relevant and Appropriate Requirements
Ordnance Works Disposal Areas Superfund Site
Morgantown, West Virginia
Air Pollution
Control Act and the
Hazardous Waste
Management Act
(State)
45CSR25-
4.3
Relevant and
Appropriate
Facilities shall be designed, constructed,
maintained, and operated in a manner to
minimize hazardous waste constituents
to the air.
During construction of the cap and
excavation activities, any fugitive air
emissions shall be in compliance with
this state regulation.
Air Pollution
Control Act
(State)
45CSR27-
4.1 thru 4.2
Applicable
Best Available Technology
requirements for Fugitive Emissions of
Toxic Air Pollutants.
During construction of the cap and
excavation activities, any fugitive air
emissions shall be in compliance with
this regulation.
Air Pollution
Control Act
(State)
45CSR30
Applicable
Requirements for the air quality
permitting system.
During construction of the cap and
excavation activities, any fugitive air
emissions shall be in compliance with
the substantive requirements of this
regulation.
F \USER\ACXDLDMAN\MAILDOCIAVERIO ARAjScptcmber 28. 1999 <5:31PMH
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Appendix A
Applicable or Relevant and Appropriate Requirements
Ordnance Works Disposal Areas Superfund Site
Morgantown, West Virginia
WATER
Groundwater
Protection Act
(State)
47CSR58-
4.2
Applicable
Subsurface borings of all types shall be
constructed, operated and closed in a
manner which protects groundwater.
Installation of new monitoring wells, as
well as abandonment of existing
monitoring wells (if appropriate) shall
comply with this requirement.
Groundwater
Protection Act
(State)
47CSR58-
4.4(a)
Applicable
Loading and unloading stations including
but not limited to drums, trucks and railcars
shall have spill prevention and control
facilities and procedures as well as
secondary containment, if appropriate or
otherwise required. Spill containment and
cleanup equipment shall be readily
accessible.
Excavation and offsite transportation of
wastes shall comply with these loading
requirements.
F.\USERVAGOLDMAN\MAILDOCU\VERIO.ARA (September 28, 1999
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Appendix A
Applicable or Relevant and Appropriate Requirements
Ordnance Works Disposal Areas Superfund Site
Morgantown, West Virginia
Oroundwater
Protection Act
(State)
47CSR58-
4.9.d to 4.9.g
Applicable
Groundwater monitoring stations shall
be located and constructed in a manner
that allows accurate determination of
groundwater quality and levels, and
prevents contamination of groundwater
through the finished well hole or casing.
All groundwater monitoring stations
shall be accurately located utilizing
latitude and longitude by surveying, or
other acceptable means, and coordinates
shall be included with all data collected.
Development and implementation of the
long-term groundwater monitoring plan
shall comply with these requirements.
Groundwater
Protection Act
(State)
47CSR58-
Applicable
Adequate groundwater monitoring shall be
conducted to demonstrate control and
containment of the substance.
Groundwater monitoring program shall
comply with this requirement.
Groundwater
Protection Act
(State)
47CSR60-I
to 23
Applicable
Monitoring well design standards.
Monitoring well design shall comply
with these standards.
F.\USER\ACOLDMAN\MAILDOCU\VERIO.ARA[Sfpt
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Appendix A
Applicable or Relevant and Appropriate Requirements
Ordnance Works Disposal Areas Superfund Site
Morgantown, West Virginia
Environmental
Quality Board
(State)
46CSR1-1
to 9
Applicable
Requirements governing water quality
standards.
The on-site streams and wetlands are
designated "for the Propagation and
maintenance of Fish and Other Aquatic
Life (Category B) and for Water Contact
Recreation (Category C) pursuant to 46
CSR1 -6.1. The water quality standards
established in these regulations will be
applicable to the remedial action.
Groundwater
Protection Act
(State)
47CSR59-1-
47 CSR59-9
Applicable
Monitoring well rules.
The remedial action will comply with the
substantive requirements of these
regulations.
Miscellaneous
Resource
Conservation and
Recovery Act
(Federal)
40 C.F.R.
264.10to
264.18
Relevant and
Appropriate
Requirements regarding waste analysis,
security, training, inspections, and
location applicable to a facility that
stores, treats, or disposes of hazardous
wastes.
These requirements shall be met when
handling wastes onsite.
Resource
Conservation and
Recovery Act
(Federal)
40 C.F.R.
262.34
Relevant and
Appropriate
Generator may accumulate waste onsite
for 90 days or less or must comply with
requirements for operating a storage
facility
If it is necessary to store waste onsite
during implementation of the selected
remedy, this requirement shall apply.
F-\USER\AGOLDMANWHAILIXX;U\VERIO.ARA (Scplcmbn 28, 1999 (539PM)]
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Appendix A
Applicable or Relevant and Appropriate Requirements
Ordnance Works Disposal Areas Superfund Site
Morgantown, West Virginia
Resource
Conservation and
Recovery Act
(Federal)
40 C.F.R.
Part 268
Relevant and
Appropriate
Movement of excavated materials to
new location and placement in or on
land will trigger land disposal
restrictions (LDRs) for the excavated
waste or closure requirements for the
unit in which the waste is being placed.
Consolidation of materials within an area
of contamination does not trigger LDRs.
Therefore, implementation of the
selected remedy will be in compliance
with this ARAR.
F:\USER\AGOLDMAN\MAIl.DOC
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Appendix B
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Office of Environmental Remediation
13 56 Hansford Street
Charleston, West Virginia 25301-1401
(304) 558-2745
(304) 558-3998
West Virginia Division of Environmental Protection
Cecil H. Underwood Michael C. Castle
Governor Director

September 29, 1999

Abraham Ferdas, Director, 3HSOO
Hazardous Site Cleanup Division
Environmental Protection Agency, Region III
1650 Arch Street
Philadelphia, Pennsylvania 19103-2029

Re: State of West Virginia Concurrence with Record of Decision dated September 1999
Operable Unit One
Ordnance Works Disposal Areas Superfund Site
Morgantown, Monongalia County, West Virginia

Dear Mr. Ferdas:

This letter is to officially express the State of West Virginia, Division of Environmental Protection, Office of
Environmental Remediation (OER) concurrence with the Record of Decision (ROD) dated September 1999 for
Operable Unit One (OU-1), Ordnance Works Disposal Areas Superfund Site, located in Monongalia County,
Morgantown, West Virginia.

The OER has actively participated in the investigation and the assessment of risks potentially present at the
site. Additionally, the OER has been actively involved in the selection of the remedy proposed for OU-1.

The State looks forward to the implementation of the selected remedy, which we believe will be protective
both to human health and the environment, as well as providing a cost-effective remedy for the site.

Sincerely,
Ken Ellison, Chief
Office of Environmental Remediation
cc: Christian Matta, EPA Remedial Project Manager
Peter Ludzia, EPA Program Manager
Mark Slusarski, OER Remedial Project Manager
Project File
a:\mowou I \rodlettr.wpd
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