'United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-88/055
September 1988
Superfund
Record of Decision
Avtex Fibers, VA
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50277-101
REPORT DOCU MENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-88/055
3. Recipient's Accession No.
,] 4. Title end Subtitle
SUPERFUND RECORD OF DECISION
i Avtex Fibers, VA
5. Report Oete
09/30/88
?irst Remedial Action
Authors)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10. Project/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
300/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The 440-acre Avtex Fibers site is located in Warren County, Front Royal, Virginia.
The facility is bounded to the west and northwest by the Shenandoah River and to the
south, nor.thwest, and east by residential areas. Approximately 1,300 people live within
one mile of the site. The western part of the site lies within the limits of the
Shenandoah River's 100-year floodplain. The Avtex Fibers site has produced rayon fibers
since 1940, polyester between 1970 and 1977, and polypropylene since 1985.. During this
"8-year period, byproducts from the rayon manufacturing process were disposed of in
isite surface impoundments. These byproducts included sodium cellulose xanthate-based
iscose and zinc-hydroxide sludge. Fly ash (from incinerator exhaust air pollution
control devices) and boiler house solids were disposed of in five other surface
impoundments. "Land disposal of viscose waste ceased in 1983; since that time, the waste
has been routed directly to an onsite wastewater treatment plant, in 1982, carbon
disulfide, a constituent of viscose waste, was identified in ground water samples from
residential wells located across the Shenandoah River from the site. In response to the
results of a ground water investigation Avtex implemented interim measures, which
included purchasing 23 subdivision properties on the west side of the river that had
contaminated domestic wells, and initiating a ground water pump and treatment program.
(See Attached Sheet)
12. Document Analysis . a.. Descriptors
Record of Decision
Avtex Fibers, VA
First Remedial Action
Contaminated Media: gw
Key Contaminants: metals (arsenic, lead), organics (phenols)
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
76
22. Price
(See ANSI-Z39.18)
See /nstructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R03-88/055
Avtex Fibers, VA
irst Remedial Action
16. ABSTRACT (continued)
This ROD is the first of two operable units and addresses ground water remediation and
interim remedial measures for the viscose basins responsible for ground water
contamination. A subsequent remedial action will address source control and viscose
basin remediation. The primary contaminants of concern affecting the ground water are
phenols, and metals including arsenic and lead.
The selected remedial action for this site includes: ground water and basin liquid
pump and treatment in the existing onsite activated sludge wastewater treatment plant,
following completion of necessary upgrades, modifications, and construction of
pretreatment units, with offsite discharge of treated water to the Shenandoah River;
monitoring on- and offsite ground water, surface water, and basin fluids; and placing
deed restrictions prohibiting the use of ground water on the affected properties. The
estimated present worth cost for this remedial action is $9,122,000.
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RECORD OF DECISION
DECLARATION
SITE NAME AND LOCATION
Avtex Fibers NPL Site - Operable Unit One
1169 Kendrick Lane
Front Royal, Virginia
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action
for the Avtex Fibers NPL Site - Operable Unit 1 in Front Royal,
Virginia. The selected remedial action has been developed in
accordance with CERCLA, as amended by SARA, and, to the extent
practicable, the National Contingency Plan. T.he attached index
identifies the items which comprise the administrative record upon
which the selection of the remedial action is based.
The State of Virginia concurs on the selected remedy.
DESCRIPTION OF THE SELECTED REMEDY-
This operable unit is the first of two operable units planned
to address contamination at the site. This operable unit addresses
ground water contamination and remediation of the contaminant plume.
As an interim remedial measure, this operable unit addresses dewater-
ing of Viscose Basins 9, 10, and 11 (the source). The function of
this operable unit is to address ground water contamination caused
by leaching of fluids from Viscose Basins 9, 10, and 11; and, to re-
duce further leaching of fluids from the basins while further bench
scale and treatability studies of the source are conducted. The
second operable unit will address source control and treatment.
The major components of the selected remedy include:
the use of existing on-site pumping wells, numbers 1, 2 and
3 to pump and recover the contaminated ground water;
installation of modified wells or extraction trenches in
Viscose Basins 9, 10, and 11 for dewatering operations;
pumping and treatment of contaminated ground water and
basin liquid in the existing on-site activated sludge
wastewater treatment plant following necessary upgrades,
modifications and construction of pretreatment units;
periodic monitoring of on-site and off-site ground water,
surface water, and basin fluids throughout the operation
and maintenance;
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- 2 -
placement of deed restrictions prohibiting the use of
ground water on the affected properties;
DECLARATION
The selected remedy is protective of human health and the
environment, is expected to attain Federal and State requirements
that are applicable or relevant and appropriate to this remedial
action, and is cost-effective. This remedy satisfies the statu-
tory preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element and utilizes
permanent solutions and alternative treatment technologies to the
maximum extent practicable.
SPA believes that the recommend'ed operable unit one remedy
will remediate ground water contamination in the future. However,
hazardous substances will be present in ground water as long as
viscose basins 9, 10 and 11 (the source of the contamination) are
unremediated. Remediation of viscose basins will be addressed in
the second operable unit.
Date ' /,' Stanle-y L. Laskowski
//v Actiryg Regional Administrator
EPA Region III
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RECORD OF DECISION
DECISION SUMMARY
I. Site Name, Location, and Description
Avtex Fibers, Inc. is located at 1169 Kendrick Lane in Warren County,
Front Royal, Virginia as shown in Figure 1.
Scrap batches of viscose, zinc, and other wastes were disposed of in
23 unlined basins and/or landfilled at the site over a period of 45 years
(Figure 2).
Front Royal in located in northwest Virginia along the boundary of the
Valley and Ridge and Blue Ridge physiographic provinces. The facility covers
approximately 440 acres. The facility is bounded to the northwest and west by
the South Fork of the Shenandoah River and-to the South, northwest, and east by
residential areas. Approximately 1300 people live within one mile of the Site.
At the Avtex Fibers Site, the viscose basins are located on a relatively flat
terrace which is at an elevation of approximately 510 feet above mean sea level
(MSL). Immediately west of the viscose basins, toward the river, the ground
surface drops abruptly to approximately 490 feet above MSL. This elevation
change establishes the limits of the 100 year floodpiain for the Shenandoah River.
The flood plain region is flat for approximately 1,000 feet. At the edge of the
flood plain region the grade descends approximately 20 feet to the river. The
normal pool level of the river is at 470 feet above MSL. The Shenandoah River is
the only major natural surface water body adjacent to the facility and is
designated as a Class IV river by the Virginia State Water Control Board (SWCB) .
The Avtex facility is located on river alluvial deposits of sand, silt,
clay, and meta-igneous cobbles. These surficial deposits are approximately 10 to
20 feet thick, as recorded from the installation of onsite monitoring wells. The
river deposits are underlain by the Martinsburg Formation. Locally,, the formation
consists of massive and fractured greenish-gray shale with occasional void spaces
and stringers of silty sandstone. In general, the attitude of the formation beds
is nearly vertical witr geologic strike trending northeast-southwest.
The ground water flow system is controlled by the bedding-plane fractures,
parallel to the structural strike of the shale bedrock. The general direction of
ground water through the fractured shale is from the Avtex facility toward the
southwest and the Shenandoah River. The groundwater migrating from the vicinity
of the viscose basins pushes past the Shenandoah River at depth and migrates
beneath Rivermount acres.
II. Site History and Enforcement Activity
The Avtex" Fibers site has been in operation since 1940, when American
Viscose opened the plant for rayon production. Subsequently, the site was sold
to FMC Corporation in 1963, and to its present owner, Avtex Fibers, Inc., in
1976. Rayon fibers has been in constant production at the site since its opening;
polyester was made there between 1970 and 1977, and polypropylene has been
produced since 1985.
-------
i »
AVTSXSlie
. I
£^\
MftSHNGIONDC
VIRGINIA
SOUCt USOS lUPOGHAFlCCkMOHANGiE. fnQNinOMl u* iu/«
•CJU.I
SITE VICINITY MAP
SITE LOCATION MAP
(FIGURE i
GMCE
0«M < 0~t..l~C. 1M—«l»l ML
SITE LOCATION MAPS
*EAS«ttW SlUUT t-OH
AVTEX MttrHS. WC
FHONT ROYAL.
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AVTEX FIBERS PLANT
SKIxn
[FIGURE
OMAMUM MO'
DRAWN •¥•
OATfi
•CM.I
GAM CONSUUING ENGINEERS INC
LOCATION OF AVTEX
MONITORING WELLS
AVTEX FIBERS, INC.
FRONT ROYAL, VIRGINIA
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- 4 -
The rayon-manufacturing process has not changed significantly during
the 48 years the plant has operated. The process has generated two major
byproducts which have been land disposed in on-site surface impoundments. These
byproducts are sodium cellulose xanthate-based viscose and zinc-hydroxide sludge.
Fly-ash (material from incinerator exhaust by air-pollution control devices) and
boiler house solids had been disposed in five other surface impoundments. The
practice of land disposing the viscose waste was ended in 1983. Since 1983, the
waste viscose has been routed directly to the on-site wastewater treatment
plant.
In 1982, carbon disulfide, a constituent of the viscose waste, was
identified in ground water samples from residential wells (Rivermont Acres)
located across the Shenandoah River from Avtex. Due to this discovery, the
Virginia State Water Control Board requested that Avtex perform a ground water
investigation. In February 1983, Geraghty & Miller were retained by Avtex to
conduct such studies.
As the result of the initial field investigation, Avtex implemented
interim remedial measures in 1983 and 1984 to address the identified contamina-
tion. The interim remedial measures included the purchase of 23- of the Rivermont
Acres subdivision properties on the west side of the Shenandoah River. Houses
in this subdivision had domestic wells which were affected by the identified
contamination. Avtex also initiated a ground water pumping and treatment program
for purposes of contaminant recovery and containment.
The Avtex Fibers Site was proposed 'for inclusion on the National
Priorities List (NPL) in October 1984. In August 1986, a Consent Order for the
conduct of the Remedial Investigation/Feasibility Study (RI/FS) was signed by
Avtex Fibers and EPA. Field work defined in the RI/FS Work Plan was conducted
between May 1987 and January 1988. In January 1988, the consent order was
amended to include FMC Corporation as a respondent. The RI/FS reports were
released to the public on August 27, 1988.
III. Connmnity Relations History
In 1983, following the release of the Avtex Fibers, Inc. consultants
(Geraghty & Miller) report, local officials from the SWCB, the Warren County
office of the Lord Fairfax Health and Planning District and the Town of Front
Royal held a public meeting. The meeting was well attended and many of the
citizens in attendance were Avtex employees.
Since Avtex Fibers, Inc. purchased 23 of the 38 properties in Rivermont
Acres in 1983, citizen interest has diminished. Citizens who have retained
ownership of their properties remain very interested in site related development,
and the Rivermont Acres Property Owners' Association continues to work to protect
the interests of its membership. The group's efforts often involve an exchange
of correspondence with Avtex officials and local officials; sometimes the group
arranges press conferences. Since the discovery of ground water contamination in
1983, the public has been kept informed of site-related developments by news
releases from SWCB, according to an SWCB official.
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- 5 -
The interim Administrative Record was sent to the site repository
located at the Samuels Public Library in Front Royal in June 1988. The proposed
plan was available for public comment on August 27, 1988. A public meeting concern-
ing the proposed plan was held September 14, 1988. The meeting was well attended
and many of the cititzens in attendance were Avtex employees. Response to commu-
nity concerns are addressed in the Responsiveness Summary which represents the
final portion of this Record of Decision (ROD).
IV. Scope and Role of Response Action within Site Strategy
This operable unit is the first of two operable units planned to address
contamination at the site. The first operable unit will address ground water
remediation and interim remedial measures for waste Viscose Basins 9, 10, and 11.
The second operable unit will address source control and viscose basin remediation.
Ground water pumping and treatment are proposed to reduced the toxicity
and mobility of contaminants in the ground water related to the viscose waste
basins. Dewatering of free liquids in the viscose basins is proposed as an
interim remedial measure within this operable unit. Basin dewatering is an
interim measure required before any of the technologies for treatment that were
presented in the draft Feasibility Study Report could be employed. At this time
the total reduction in toxicity via dewatering, and the leacnability of residues
from the dewatered waste, is conjecture. Therefore, the appropriate treatment of
the dewatered waste can not be determined. EPA recommends that the decision of
the preferred final remedial response action for the viscose waste basins be
deferred until the toxicity of the dewatered waste can be verified. Bench scale
studies and treatability studies must be conducted concurrently with the interim
measure to determine what final treatment of the dewatered viscose waste is
appropriate.
V. Site Characteristics
The remedial investigation confirmed the source of the ground water
contamination to be Vicose Basins 9, 10 and 11.
Two rounds of ground water samples were collected. Parameters of interest
for all of the ground water sampling locations were as follows: (See Figure 2 for
sampling locations.)
Alkalinity Potassium pH
Arsenic Magnesium Sulfide
Cadmium Manganese Sulfate
Chloride Sodium TDS
COD Nitrate TOC
Conductivity Lead TSS
Iron • Phenolics . Zinc
Additionally, carbon disulfide was analyzed for each sample. Several of
the collected samples during both the first and second round of sampling were
also analyzed for the full Contract Laboratory Program (CLP) Target Compound List
(TCL) of organic parameters.
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- 6 -
To date, the data collected from monitoring wells and the results of
aquifer performance tests have indicated that laterally, the plume is within a
narrow fracture system.
The results of ground water analyses indicated two distinct geochemical
patterns are discernible at the Avtex Fibers Site. With respect to carbon
disulfide, total phenolics, cadmium and pH, a plume of ground water contamination
was identified (See Figure 3). Degradation of the ground water with respect to
these parameters is attributable to the leaching of viscose-waste material disposed
within Viscose Basins 9, 10, and 11. The constituents detected also reflect the
constituenrs identified on the west side of the Shenandoah River at Rivermont
Acres.
Within this plume of contamination, a narrow band of elevated arsenic
concentrations was also identified. The presence of the dissolved arsenic is the
result of the interaction between the high pH fluids within the viscose basins
and the impoundment berms which are composed of clay with a fly-ash core.
The second geochemical pattern in the ground water is illustrated by the
sulfate and total dissolved solids parameters as shown in Figure 4. Ground water
degradation with respect to these two parameters is facility wide. This facility-
wide ground water degradation with respect to the non-hazardous constituents was.
not the focus of the FS and will not be addressed by this ROD. However, rsnedial
actions which recover the viscose waste constituents in ground water from the
west side of the river will also capture these secondary constituents within the
area of influence of the pumping.
The sampling of solid and liquid phases within the viscose basins provided
specific data on the waste characteristics. For solid samples collected within
Basins 1, 2, 3, and 7, carbon disulfide concentrations were less than 3.0 milligrams
per kilogram (mg/kg). Liquid samples collected from the piezometers installed
within the basins were found to contain less than 1.5 milligrams per liter
(mg/1) of carbon disulfide. Ground water samples from wells hydraulically down
gradient did not contain detectable levels of carbon disulfide.
Solid samples from Viscose Basins 9, 10, and 11 contained as much as
20,000 mg/kg carbon disulfide. Measurement of water levels from wells and
piezometers installed in and around these three basins suggests hydraulic
communication between the basins and the ground water regime. Geochemical data
demonstrate that wells MW-2, 3, 9, 10, and GM-8 contain appreciable
concentrations of carbon disulfide and confirm that Viscose Basins 9, 10, and 11
are the primary source of the contaminant plume.
Tables 1 and 2 provide a summary of the analytical results for the
groundwater samples and the viscose basin samples.
Based upon current use and future use conditions, the potential exposure
pathways associated with the site are:
- Dermal contact with solid or liquid viscose waste
- Dermal contact with ground water and basin liquids pumped for
treatment
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AVTEX FIBERS PLANT
III*
(FIGURE
It-OOUHM A04
OATH
SCM.C IK.11
GMCE
OiM CONSUIIlNG (NOINCCnS. INC
PLUME DELINEATION
VISCOSE BASINS
AVTEX FIBERS, INC.
FRONT ROYAL. VIRGINIA
-------
c>
AVTEX FIBERS PLAN
SO, >tX>.«/|
»"•
[FIGURE 4 )
NOi
TE003S FRS-AOS
OMAWM •»•
lOVIO'
SCM.C |U.I|
SOURCE: GERAGHTY & MILLER. INC.
GI/ICIH
C»M CCmiULTlNG ENGINEEHS. INC
y
PLUME DELINEATION
FACILITY
AVTEX FIBERS, INC.
FRONT ROYAL, VIRGIN!,
'/
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a/ USCHt. 1983
to/ Not available
c/ Not Analysed
TABLE I
Analytical Raaulta for Vlacose Basin Solid and
Uquld Haate Sample Collected In Soptonbar 1987
Solid Mbat* (axi/kg)
Constituent
•
Carbon dlaulflde
Arsenic
CadMlua
Chloride
Iron
Uad
Manganeae
Rtenols
SodlUB
Sulfate
line
SurClcIal
Range
0.070
0.42 - 12
• .0
MA^
1.92 - 9,700
32 - 42
•.4 - 160
<0.28
65 - 25,000
NA
274 - 7,900
Subaurface
Average
Detected
Range
Concentration
0.070
4.4
8.0
—
3,300
37
74
—
8,905
—
4,400
0.17
0.25
7.0 -
NA
157 -
8.1 -
2.2 -
0.21
46 -
NA
13.3
Average
Detected
Liquid Haate (MO/L)
Cannon
Range
1(1 ay
Sollv Range
Concentration
7 20.000 ^
- 13.1
11
52.000
3,700
991
- 87
113.000
- 2,900
3,100
3.4
9.0
—
9,500
840
208
23
36,000
—
380
-b/ 1.5 -
1 - 50 0.16 -
0.01 - 0.7
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o
rn
O
n:
•; H
». ~s
lcrj j .
Gbllactud In SqpUsLer 1987 [^
• (acnauntcatlans (qpcrtad In mj/L) '
h
But Sld» Along Mver
Qjratltuant
^AxoiAu ftffiisncy A^ccocp
CkonHbtar of Ibbaatiai Rnp tbtactel
Starehai NXWB SUndacd CLrortratlcn
Gutan dlsulfkto O.X 2/17 .006
frank:
Origin
Oikrldi
Inn
tad
Kngeraaa
Iterate
Salkn
Sulfata
SUlf kto Oyk)
Zinc
a05 2/25 .004
-360
-.07
aqp04 6/25 .0068 - .032
250rC 0/25 26-
O.J*^ 20/25 .05-
0.06 , 5/25 .035
aOS* 25/25 .33-
aOOl 3/25 .03 •
27Q . 24/25 82 -
250^ 25y« 720-
Djpnp aOz*^ 23/25 .2-
0.05 2/25 .04 -
J20
-33
-.229
- 29
-2.0
1,800
-3,200
920
•19
49.
.019
.018
75
3.2
.081
2.9
1.2
940
I, TOO
70
.092
ttet Skte Men] River
of tetacdan tettp
2/11
2/11
0/11
0/11
9/11
0/11
9/11
2/11
2/11
2^1
10/11
.007
.027
—
2.4
.036
—
.098
6.3-
9.3
79-
0.2-
.056
-470
-.32
- 160
- L8
-.37
-29
-4,100
2,000
• 1,700
-.22
IWaatnl
CLnuatiaLlai
150
.21
—
38
.&
—
.19
18
730
440
5JO
.16
aellcw Huiitar Hills roar Vlsacaa Buins
of IWuetlcn Rtt>3
/UMJ SLaiiiuiJ
2/7
J/7
0/1
3/7
5/1
4/7
6/7
V»
y
6/7
7/7
7/7
1
.022-
.003-
—
44 -
.15 -
.02 -
.14 -
.02 -
89 -
0.2 -
TOO -
.13 -
IfctucteJ
Uiru Italian
3 *3 t~ft
3T*V-
2,800 '
.087
1,900
46
7.1
15
16
14/AJO
5,000
4,600
9^
1,100
.045
—
400
7.8
1.1
5.9
6.0
4,500
840
2,400
2.4
drinVlig MBtHf
t/ no atat* gaanl-waber stantedi vaka la state sucCao* »*>tfir/****} M lykcgen eulfids baoouw cf lii^ieat totidty, Itvewr, miiUxiig dtji la for total aulf ktaaj
•ilfltfa anoBrtzatkn mey to noil faction of total «ultl(b anortrz>LkrB
-------
- 11 -
- Inhalation of volatilized constituents or fugitive dust
- Ingestion of ground water for domestic use
- Surface water through dermal contact and ingestion of locally
caught fish
VI. Sunmary of Site Risks
Utilizing data generated during the RI, a Risk Assessment was conducted
to evaluate the potential impacts to human health and the environment which may
result from the release of hazardous substances from the Avtex Site. The consti-
tuents that have been detected in the waste viscose materials and ground water
and considered in the Risk Assessment are arsenic, cadmium, carbon disulfide,
chloride, iron, lead, manganese, phenolics, sodium, sulfate, sulfide, and zinc.
Elevated levels with respect to chloride, manganese, sodium, sulfate,
-and zinc were considered constituents of potential public welfare concern due to
aesthetics but were not used as health-risk indicator chemicals. The indicator
chemicals (those having- potential adverse health risks) are arsenic, cadmium,
lead, carbon disulfide, hydrogen sulfide and phenolics. Of these, only arsenic
represents a known human carcinogen.
Acute and chronic toxic responses associated with the indicator chemicals
are summarized in Table 3. Table 4 is a summary of toxicity'profiles of indicator
chemicals. Although some of the indicator chemicals may have toxic end points,
the actual mechanism of toxicity varies between the chemicals, and there are no
reported synergistic interactions between the indicator chemicals.
The Reference Doses (RfDs) for the indicator chemicals are derived from
levels which did not result in any of the summarized toxic responses. The refer-
ence doses for the indicator chemicals are in Table 5. The RfD for arsenic is
based on the federal M3L of 0.05 mg/1, and is calculated for comparison with the
other constituents.
Present Use (Risk to workers on-site)
A daily intake level was calculated for skin absorption and small quan-
tity ingestion of viscose basin solids and liquids and ground water using the
equations in Tables 6, 7, and 8. For the basin solids, the intake levels were
calculated for the constituents detected in the surficial samples from Viscose
Basins 9, 10, and 11. For basin liquids the intake levels were calculated using
the concentrations detected in the viscose basin piezometers and seep samples.
For the ground water, intake levels were calculated using the average concentra-
tions detected in the monitoring or recovery wells along the shoreline on the
east side of the river, because the concentrations and the likelihood of exposure
are greater on this side of the river. Intake levels are determined for worst-case
working lifetime exposure.
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GERAGHTV J- MILLER. INC.
Tab le 3 Suraaary of totential Toxic Responses of Constituents Associated with the
Avtax Visosee aasins
Reproductive/ Acute Dironie Aniaal Environmental
Constituent Careinogonicity Teratogenicity Mutagenicity Toxicity Effects Toxicicy Toxicity
a/ b/ =/ d/ a/ f/ ?/
Arsenic
Cadmiuo
Carson oisulfide
.t/drogen sulfide
Lead
X X
X X
X
X
X XXX
XXX
Y
X X
XXX.
Adopted from 'Chemical, Riysical, and Biological Properties of Compounds Present at Hazardous Waste Sites.* Office
of Haste Programs Enforcement (CWPC), U. S. CIA, 1.985. Criteria presented, in chis taole is enat of CWB. Xn *X*
indicates the cnemical meets the criteria outlined by OUR for the particular toxic affect classification. The lacx of
an *X* under a classification does not necessarily inply that tAe chemical cannot have a toxic effect.
a/ A coipound is classified as carcinooenict if it is a known or suspected human carcinogen; if it has seen Deen shown
to Be carcinogenic at a particular site in more than one species or set in a anuael oioaseey; or if it has oeen
shown to increase the incidence of site^pecific malignant tutors in a single species or sex. and Uere is a
statistically significant aoei r«jpor»e relationship in nere than one ««poe«d group.
3/ Chemicals are class if iod as ceratogens and reproductive toxins if tnere is suggestive evidence of an effect in
numans or if at least one study in wnole anunais is clearly positive. Urnuppocteo in vitro evioenee 19 considered
sufficient to classify a cnamcal as a reproductive toxicity/tentogetucicy nazaza.
c/ A chemical is classified as Rutagenic if it has given a positive result in at least one of the manaslian in vivo or
aacteriai or maoBiliaa cell ui vitro assay* for nutagenicity.
d/ A conpound is considered to be acutely toxic if it has an oral L050 < or • 100 mj/kg, an inhalation LCSO < or • 400
mg/cuoic meter, or a. deraeU U950 < or • 400 ngyka. LD mint lethal doeer LC mene lethal concentration.
e/ Chemical* will be considered to came chronic toxicity if they cause serious irreversible effects otner Chan cancer
or reproductive) effects after extended •xposure to oral doses of lee* than 100 rag/kg/day, inhalation concentrations
less ttian 400 ag/tamir Beter, or deraal dose* less Uian 400 mj/Xg/day.
f/ A chemical will be conetderert to be toxic to donwcic animela if a oeoonstrmted serious toxic effect has been seen
in the field* Also, chemicals chat cause reproductive toxicity, teratogenicity, or subchromc eoxicity at oral
doses of less) than 100 nj/kg/day will be considered as domeetic aniaal hazards unless they are unlikely to be
present ae toxic levels oftsita.
g/ A chemical is classified as hazardous to aquatic wildlife if an acute tCSO is < 1000 ug/T. or chronic effects are
reported at < 100 ug/Lj to terrestrial wildlife if toxicity has been seen in the field, if acutely toxic, or if it
causes reproductive toxicity/teratoganiciey at oral fVaees < 100 mg/kg body weight; or are persistent in the
environment and are toxic at levels up to 10 times less than those indicated above.
000774
-------
619/S
Clinlui
CutxndiaiUklj
Table 4
iliiiiiuy H.»>i,:ily Ikiiibr; it livlicubi UuniuiLs >•* Hi; Vi-n
tajltt Tbidciiy 3in»uy
Cluuiic Hjxicily Sinniiy
Ii4nili.il
• linij: mil l>'imil»h>jii;il offrxt-S Ui:lii- *,in 'i In. Inn'I'Mnio H>ik i.c ui>ilixv in ini.l
litiijrJ am tliuj (cu.fclijtj c«kl ilufcorul biji««illy .mni.Hiil on.siii,* Itk&ni.il bs;t syUuni (li9t ail luunliijiinl Uu U.S. wild .iriiiic inrt,ijnlcily. 'H-iaUjjiiic in
vnitinj, ill^nlin, u;ii(liril.i <i, Ouriiic IIH| omnium out Imj <•>! |»K,l.n.' ';ui>i( otlninn inilUir (mis liit. liu> fii In riLs. dlidira
JLs- cjbiiJiiria, .ill ounid. Kl<)- Nieviiliuj >t >nii:iinj]iiuity tliu ill imlily mm Uu
«il rvyn acu Uu mxt ajuitlve dimtiuuiloaal-oifiiiiiu. skui. Hi; ilii.t is Uu im)r
QOMilaiam. In (J(al U«I.K|- cn>»i ta kw-lojul dicaUc 31110; <.i linai ofucuiv Ui
tat Ian, tiun s^«|ibiii> *u oifuiuc. oilraun.
folkMxl ly dnit Jil/>r mul
|>n
k/n,
duels,
Riikln
oular
ail
RjlyitiiritLs incbiliiij liwx* U»iii-l»rii\c rfjil
exLiunily tuJuuse ail jaiua- t^nicily ly tCI.
Utnkia. Bfierliiiital ly In ouvrinrjulcity
di/j, k>ili)H uf Uu injura lulnj UiloJ.
slrlau, Hukln^j uill'i of Ue
oiiUullm anl Lua ul by UltiLilioi. blula-
uiiutly Lini is Uu |»in,-i(>il cold cf
d>ii|*.lcii in nui. MuLiptim
Umn^i Ui; skin anl a tiv»t
mdi lu:i si
o
m
O
X
H
r;-
I-
m
po
x
o
e>
o
-------
TABLE 4 Cont.
m
CbEtllual
lull
Rural
taila Hxicity Hiniuiy
Quuiic Djiicity 3iimuy
tntl
luji oUuooJ.
nuy or*; bmuli.ita l>i.iii«n, wifai*n, &il natr-
oom or tiidUi Uildi imy nuir n»» uf uxuumitles nay uuir.
with or wlthut oiMil-iiriB. [fere asm of polyiaitllU aa
irrltatl'ii of ths & n»ilt of vustUuUr <loil
lead tael eweab IS uj/-
dadlltar of bkui. It
IS U>
«nl aim lirn>
M)
i< i.il
Uln
Mt^itivi; in mi4. luLii.'niil
Uul s^siniti Kr iiU.i^jticUy.
', Do nu)x A jili< ilium! in
iLJl/iSJ, nut- niul (imi'iKti u<»| in i.ils
I, irritability, heal- ^i
ouir at levula lukx Uiuo mm.
-. CUur
Utit b>
«E£act.
an l/xlc
culcllni In col bind cull
lif<*taii Jiil InMbitlon of
ayiiUmIs of hiiojlcbin, |iri-
(Jiifal nuninUy, and IBB!
liriution uf UM i.yn, mu,
and ttvoat, annueicla, bna of
teli/t, uadtmn, macle
«Ltua, pain, cbiV urim, cya-
aala, liver ail Hiluy
uVnarj9( *li> bun, ibuiutltla,
i, aid
Jin tic eifiiuaii U)
j*iiol at hb|> ajvutratLiu
houo ojailtaJ In otmnlc llvur
«.Uiu>) in mm*
rjyinj fan 50 to
luV M-'kj* In nits duui
oily sib/* kUlty ail I Ivor
alterdt IIIB (olUxtiij i ncrtla
of
I !•> a ii;llnl.ir
lul.ir Imicity
31) u> 2,(»)nm li:f.jo milipilcity until ta
IM f.»13 Mil] ,lB.'l\ul at lilt
li.n ll»ui|i UK &kiii la iir-
slijiifiojii un)ui»l with Uu
Gl aiil iu|>ia>liiy I
Ml uin:iu>;.ii.v in
lUa aally dbul.
.13 iMil H|ijvii-2i| ovbkivu uf inil>i-
(jiilcily. Ib euiiliiB uf
tuiatujiiiclty. Riitil la
n«llly UtLiUvl ly all lulua
of u^tiv*
H
V
r
m
x
n
o
o
o
•"JO
o
-------
GERAGHTV^ MILLER. INC.
Table 5 Indicator Chemical Reference Doses (RfDs) for
Chronic Exposure
Constituent
Arsenic
Cadmium
Carbon disulfide
Hydrogen sulfide
Lead
Phenol
Chronic RfD
(mg/kg/day)
0.0014
0.00029
0.10
0.003
0.0014
0.04
Source
a
b
c
b
b
d
a/ Calculated from MCL of 0.05 mg/L assuming 70 kg adult
daily ingesting 2 liters of water.
b/ Superfund Public Health Evaluation Manual (USEPA, 1986c)
c/ USEPA Office of Solid Waste Appendix IX RfD List (USEPA,
1987)
d/ PHRED - Public Health Risk Evaluation Data Base.
-------
619/24
Table 6 Estimated Intake Levels from
Dermal Contact/Ingest Ion Exposure to
Viscose Basin Solid Wastes
/
>
Constituents ••'
Araenicb/
Cadalua
Carbon dlsulfide
Hydrogen suit Ida
Lead
,
t VB-9
Concentration Intake"'
•g/kg mg/kg/day
0.66 4.5 x 10~7
__ --
70. 1.2 K I0~*
C
32. 5.6 x 10"5
Viscose Basins
VB-10- VB-II ,
Concentration Intake ' Concentration Intake
mg/kg mg/kg/day mg/kg mg/kg/day
12 9.4 x I0~6 0.42 3.3 x I0"7
8 1.4 x I0~5
15. 2.6 H I0~5
C __C
42. 7.4 x 10"5
o
m
O
rr:
m
po
X
n
a/ Equation 1.0 Equation Definition
Dorsal Contact/
Ingestion Intake
aotid (skin surface
viscose waste * (area of hands x dust * differential
concontratIon (body weTgfTtadherence absorption
(weight fraction) factor
* goiI Ingested) x exposure K exposure
body weight) frequency length
Equation I.I Adult Worker Intake Calculation! Carbon Dlsulflde
Dermal Contact/
Ingest Ion Intake
- 70 x I0~6 rag/«g * (870 cm2 x 1.45
"
x 0.02
» 100 mil) x 365 days x 70 yr
"70 kg) 1S5~diy *- ~
- 1.2 x I0~4 mg/kg/day
b/ Exposure frequency for arsenic is 250 days per year and exposure luixjih ia 45 year working
lifetime because exposure Cor carcinogens Is an raged lifetime Intako.
,-/ Concentrations of hydrogen sulfldo assumed to be ow quant I tat Ion lovul:i liucunun i>ll i :i
,,-,-..:... IT, ~ It >!•:• 10 ,1 HI .
-------
CD
O
-J
O
619/25
table 7 Estimated Intake l-evola from
Dormal Contact Exposure to
Viscose Oasin Liquid Hastes
o
m
o
H
Viscose Dasins
,1 VD-9 , VB-10
Constituents .,. Concentration Intake3' Concentration Intake3' Conccntral
mg/L mg/kg/day rag/L mg/kg/day mg /kg
Carbon dlsulflde 710 3.8 x 10~4 320 1.7 x 10~* 3431
Hydrogen aulflde — ' — , — -- --1/
Phenols 14 7.4 x I0~° 0.07 3.C x 10-0 20
Vn->l -a/
;lon Intake '
™S days 70 yr
- 3.0 x I0~4 mg/kg/day
b/ Concentrations of hydrogen an Hide assumed to be below quant 1 tat ion levels because pll Is
greater than 10 s.u.
-------
GERAGHTV s MILLER. INC.
619/26
Table 8 Estimated Daily Intake Levels from
Dermal Contact/Ingestion Exposure co
Ground Water
Maximum ,
Constituents Concentration ' Intake '
rag/Kg/day
Arsenic ~
Cadmium
Carson disulfide
Hydrogen sulfiied//
-sad
0.
0.
360.
9.
C.
07
032
2
229
6.
6.
0.
1 .
4.
4
6
X
X
10-
10"
6
6
075
3
a
X
X
10"
1C"
3
5
a/ Maximum concentration in any well along east shoreline of Shenandoan River; Sap teaser 155""
sampling
3/ Equation 3.0 Equation Definition
(skin surface water differential
Dermal Contact/ • ground water x ( area x flux x aosorption
Ingestion Exposure concentration ( oody rate factor
( weight
x exposure x unit *• water ingested)
duration conversion aody weignt )
x exposure x exposure
frequency lengtn
Equation 3.1 Adult Worker Intake Calculation! Caroen Oisulgide
Dernal Contact/'• • 360 ng/L x (18150 em x 0.3 mg/ca -hr x 0.5
Ingestion Exposure ( 70 leg
* .- x 1.0 hr/d»y * .lO'^t •*• .OIL) x 363 days x 70 yr
mg ~ 70kg) 365 days 70 yr
• 0.07S ng/kQ/day
c/ Exposure fnqpoacy Cor arsenic is 230 days per year and exposure length is 43-year working
lifetime b«eaaM exposure Cor carcinogens is an averaged lifetime intake.
d/ Concentration of hydrogen sulfide is 1% o£ total sulfide concentration because pa is >9 s.i
This assumption is currently being assessed.
0007°f
•>
-------
- 19 -
Using the daily exposure intake levels for a worker at the Avtex waste-
treatment area, hazard indices for the noncarcinogens were calculated for the
solid viscose waste, viscose liquid and ground water exposure pathways (Table 9).
The hazard index is the; ratio of the estimated intake levels to the Refer-
ence Dose (RfD). An index value less than one is an indication of an acceptable
level of exposure or minimal risk. Hazard indices for the indicator chemicals
were less than 1 for all three media (solid waste, liquid waste, and ground water
(dermal contact)). The RfDs used to calculate the risks were for chronic or
lifetime exposures; therefore, the hazard indices calculated are valued for a
lifetime exposure of workers to the wastes and ground water (dermal contact).
The intake for arsenic was calculated as a exposure averaged over a
lifetime, because cancer potency factors are determined on the basis of lifetime
exposure. The upperbound lifetime excess cancer risk for a exposure to the solid
waste or ground water (dermal contact) is 1.4 x 10" and 9.6 x 10" , respect-
ively. The cancer risk associated with a 45-year working lifetime for combined
dermal contact/ingestion exposure to both liquid and solid wastes and ground
water is 2.4 x 10~D.
Future Use Of Ground Water As A Potable Water Supply
Ground water used as a potable water supply would result in unacceptable
intake levels. The total hazard index for drinking water exposure is 298. This
value only represents the risk posed by oral intake and does not include the risk
posed by the volatilization of these constituents in the home.
Drinking water exposure to the noncarcinogenic constituents presents an
unacceptable level of human health hazard (See Table 9_1. For arsenic, the cancer
risk associated with drinking ground water is 1.4 x 10" (See Table 9).
Surface Water Pathway
Flow of constituents in the shallow ground water to the Shenandoah
River is occurring; however, shallow ground water flow during pumping of the
recovery wells will be reversed and will flow toward the pumping wells.
A model was developed to estimate the total rate of shallow ground water
discharge to the river, and the effects of this discharge on river water quality.
3 The rate of ground water discharge was calculated and estimated to be
111 ft /min or 1.2 million gallons/day (MOD) using the following Equation:
Qgw -Vv*
Q ; = the volume rate of discharge of ground water
where: ^* to the river
K = the vertical hydraulic conductivity
i = the vertical hydraulic gradient = .05
A = the area of concern over which the
shallow ground water is discharging to
the river = (X average width, 350 ft, by
length of the river frcra the north end
of Sulfate Basin 1 to the South end of
Sulfate Basin 4, = 3500 ft) '••
-------
Carctnogena
Conatltuant
Solid
•g/kg/day
Chronic Dally Intake (CPU Cancar
Liquid ~f SrounS Ground Potancy
Maata ' Hatar Hatar factor
aHJ/kg/day (Daraiall (Ingaatlon) (*g/kg/day)
aig/kg/day »g/kg/day
Araanlc
9.4
10
-C
a.4
10"' 9.1 x
10
-1
Solid
Halt*
Upper bound l.lfotlae
Excoaa Cancar Btak
r.fquld Ground
Haata : Hatar
Ground
Hatar
(Ingaallon)
l.S
1.4 x 10
-5
9.6 x
IO'6 1.4 x
10
-2
a/ Hlghaat Intaka lavala Croai Vlacoaa Baalna 9. 10, or II
b/ Haiard Indax • COI/BfO .
c/ Cancar rlak - COI • potancy (actor
*/ Intake level does not represent the inlialcit ion route due to volatilization in the home.
It lias been determined that this route could contrihu1 n intake five times greater than this
water oral intake.
o-
ft)
O
. 3:
H
619/28
Lifetime Risks Associated with Potential Exposure to
Constituents Oatactad In the
. Viscose Oasln Hastaa and Ground Hater
Moncarctnogena
Conatltuant
Cadaluai
Carbon dlauldda
Hydrogen auldda
Laad
Phanola
Chronic Dally Intaka (CDI |
Solid.
Mast* *'
•tg/kg/day
1.4 * 10"*
1.] B 10 *
~~ -5
S.( K 10 *
~—
Liquid.
Maata *'
a>g /kg/day
~~ _•»
I.I « 10 J
--
1.0 x I0~"
Ground
Ma tar
(Oaraiall
•g/kg/day
6.6 * 10"'
0.075 ,
1.9 • 10 *
4. • x 10
•"-
Ground
Hatar
I Ingest Ion)
•fl/kfl/day
--
11 *
0.48 *
— .
0.81
Reference
Doaa (MfD)
•g/kg/day
2.9 K 10"*
0.10
0.001 .
1.4 x 10
0.10
Hazard Index ^
Solid
Hasta
0.048
0.0012
--
0.04
— _
Liquid
Haste
0.018
--
—
1.0 x 10"*
Ground
Hater
(Deraal)
0.021
0.74
0.61
0.014
--
Ground
Uatar
( Ingest Ion )
..
110
160
-_
8.1
r
m
x
o
Total Hazard Indai
0.089
0.018
0.80
298
-------
- 21 -
The rate of organic loading to the river from this area of affected
ground water quality could then be calculated by multiplying the volumetric rate
of ground water discharge to the river, Q , by the average concentration of
specific constituents in the shallow ground water. The ground water samples from
PZ wells located along the river represent the shallow ground water.
The concentration of constituent X that would result in the river from
shallow ground water discharge to that river, can be calculated using the following
equation:
C(x)r = QrC(x)ro + Q^ C(x)gw
where: Qr = the volumetric flow rate of the river
C(x) = the concentration of constituent X in
the river water
C(x)ro = the concentration of constituent X in
the river water prior to encountering
the shallow ground water discharged in
the vicinity of the plant
C(x)(-i = the concentration of constituent X in
the ground water
If it is assumed that the concentration of the constituent in the river
is initially zero, before encountering the shallow ground water discharged from
the vicinity of the plant, then Equation 3 is reduced to the following expression:
C(x)r =
and represents the change in river water quality that is attributable to the
discharge to the river of shallow ground water in the vicinity of the plant.
This calculation was performed for several inorganic constituents, assuming the
volumetric flow rate of the river is 35 MGD, and the results of these calcula-
tions are presented in Table 10.
Air Pathway
Volatilization from basins 9, 10, 11 is probably resulting in the
release of carbon disulfide to the atmosphere. However, concentrations of carbon
disulfide were monitored in the air during drilling and sample collection at
these three basins and the levels were always below the Threshold Limit Value
(TLV) of 30 tng/irr; with few exceptions, the hydrogen sulfide levels were below
the TLV of 14 mg/m^. Only when the surface was disturbed by drilling activities
did levels exceed the TLV for hydrogen sulfide.
-------
rn
po
'\*
I AIL E .10 2£
CNAN0C IN CONSIIIUENI CONCENIRA I I OHS IN RIVE* ~'
•VI 10 MSCNARGE Of GROUND UAIER 10 IKE RIVER ^
(concentrations In «g/t) ^
F
r
Avarage . Change In virgin)* py
Concentration Concentration Surface Water '_
' v«f Lt • n d • f d t >
B.
C
8
Z
-Z.
k
OJ.
1
od
1
SU
c
I
A
S
.
or
Ida
lua>
nc
1
ad
fa
• 1
t a
urn
• ad
r
u
,
a
1
an
f 1
Ic
da
Concant rattan u
•valuation that
1
0
1
0.
0
0
1 1 1
ul 1
t
•
71
ai
01
900
0056
*
•
7
1
osa
00ft
.•
be
be
1 .
ir
0.000
• 5
0.000
0.00
0.000
o.i
4
1]
19
19
19
S
established based on the
perforated In 1900
*
25
• •
S .
25
0 .
0 .
0 .
a >
river
0
0
0
01
OS
OS
uater- quality
••v
-------
- 23 -
Fugitive dust releases from basins 9, 10, and 11 are expected to be
low because a crust is formed a"t the surface of the waste. The crust has low
concentrations of carbon disulfide (<0.1 mg/1).
Runoff from the basins is not significant because the wastes are perme-
able, and the waste basins have berms that extend above the waste levels.
VII. Documentation of Significant Changes
The Proposed Remedial Action Plan released on August 27, 1988, identi-
fied Alternative 3 which required construction of a new wastewater treatment
plant (WWTP). Since that time Alternative 2 has been amended to include
upgrading and modification of the existing WWTP. EPA does not consider this a
significant change since the technology of pumping and treating ground water
remains the same. At the.public meeting on September 14, 1988, an addendum to
the Proposed Plan was released explaining this modification.
VIII. Description of Alternatives
A. Summary of Alternatives
The three screened alternatives evaluated are summarized below.
Water Institutional Basin
Alternative Monitoring Controls Dewatering
1 X X
2 X X X
3 X X X
Pump and treat Pump and treat
in existing WWTP Package Plant
2 X
3 X
B. Treatment Conponents
The options comprising the above alternatives are described below:
Monitoring - For all alternatives a ground water and surface water
monitoring program will be implemented to monitor leachate generation and ground
water quality and surface water quality. The data will be evaluated to determine
if the parameters and/or sampling frequency should be modified.
-------
- 24 -
Since Alternatives 2 and 3 include ground water recovery and basin
dewatering, the recovery wells and the liquids from dewatering the basins
would be included in the ground water monitoring program.
Ground water and surface water monitoring would be implemented to de-
termine conclusively whether or not withdrawal from wells PW-1, 2, 3 is effect-
ive in managing the lateral and vertical migration of the plume.
Institutional Controls - institutional controls may include:
Ground water
use restrictions to be obtained by site owners or operators from owners
of property affected by the ground water remediation operable unit, prohibiting
the construction of any water supply wells
restrictions recorded in the Registry of Deed forbidding the installa-
tion of ground water wells on property at RiVermont acres owned by Avtex. These
controls are expected to mitigate the risk from the potential exposure related
ro direct ingestion of ground water affected by the site until the aquifer res-
toration objective is achieved (see Section VIII on aquifer restoration).
Viscose Basins
For alternative 1, deed restrictions would be recorded in the appro-
priate Registry of Deeds forbidding the use of the viscose basins for anything
but industrial purposes. Access restrictions currently used at the Avtex Fibers
site include a security fence and a security guard at the plant entrance. Con-
struction of a second fence around Viscose Basins 9, 10, and 11 would further
restrict access to the viscose waste. -
Basin Dewatering
Viscose Basins 9, 10, and 11 presently contain approximately 314,000
cubic yards of viscose solids with 90% water content, by weight, as well as an
undetermined quantity of free water. The dewatering will result in approximate-
ly a 50% reduction in the viscose material and a great deal of contamination from
the source area will be treated at the WWTP. In addition, dewatering acts to
eliminate or reduce the hydraulic head within the basins, thus reducing the
vertical gradient and hydraulic release to the underlying aquifer.
The rate of dewatering Viscose Basins 9, 10, and 11 will be dependent
upon the WWTP's capacity to handle the hydraulic and contaminant loading from
the dewatering operations. Based on the information presently available, it is
perceived that the dewatering system for the basins would be installed at the
western end of each viscose basin since .the bottom of the basins slope to the
west. The dewatering system may include modified wells and/or an extraction
trench system. Final design and implementation would proceed based on the
results of pilot studies which are presently underway.
-------
- 25 -
It is expected that the dewatering of the viscose basins would be completed
in two years based on a liquid recovery rate of 50 gallons per minute (gpm) .
It will be necessary to evaluate the need for ground water table depression
at the viscose basins; the effectiveness of dewatering will be evaluated after
one year.
Bench scale studies on the dewatered waste will also be conducted to
determine what final treatment of the dewatered waste is most appropriate.
Pumping and Treating
Both alternatives 2 and 3 require the recovery of contaminated ground
water and collection of fluids from dewatering the basins, and assumes that the
treated water will be discharged to the Shenandoah River in conformance with
NPDES permit requirements. The action alternatives only differ in the methodo-
logy used to treat the recovered water to acceptable levels.
Pumping performed during the operation of interim measures and aquifer
tests performed on the east side of the Shenandoah River have shown that the
fracture system on both sides of the river are hydrauiically connected and that
there is some hydraulic separation of the fracture system from the river. The
pump tests have shown the extraction of ground water from recovery wells FW-1, 2,
and 3 is effective in capturing contaminated ground water on the west side of the
river. A ground water monitoring program will be implemented to determine conciu-r
sively whether or not withdrawals from only these wells in effective in managing
the lateral and vertical migration of the plume.
Existing WWTP following Pretreatment
Pretreatment options include the equalization of the recovered ground
water and the viscose basin fluid in an equalization tank. Aeration in the equa-
lization tank will be adequate to remove excess carbon disulfide frcm solution;
a portion of the total sulfides will also be removed as hydrogen sulfide via
aeration. EPA in consultation with the Virginia Air Pollution Control Board
will determine if any pollution control devices will be necessary at the WWTP due
to releases of carbon disulfide and hydrogen sulfide.
A neutralization process follows to adjust pH value to 6.5 - 7.0.
Chemical precipitation in an acidic environment will remove the insoluble sulfides
of cadmium, arsenic, and lead. Bench and/or pilot studies will be required to
verify the appropriate treatment scheme prior to design of an effective treatment
program. The recovered waters are then transferred to the existing WWTP for
further treatment. The WWTP process consists of primary sedimentation followed
by mechanically aerated activated sludge and final clarification. The primary
sedimentation process is enhanced by lime addition to neutralize the acidic waste
stream and precipitate zinc. This process will also precipitate arsenic, cadmium,
lead, and other heavy metals.
It is anticipated that the sludge will not be EP toxic and .therefore may
be disposed on site. Testing will be required and if found to be EP toxic, the
sludge will be disposed in a RCRA-approved landfill. If RCRA Land Ban require-
ments are applicable, sludge will require treatment before disposal. The NPDES-
permitted effluent is discharged to the Shenandoah River.
-------
- 26 -
Package Activated Sludge Wastewater Treatment Plant
A package activated-sludge wastewater treatment plant could be utilized
to treat the recovered ground water and liquids generated from dewatering and
leachate collection from the viscose basins. The package plant design would be
similar to that of the existing WWTP since it has been proven effective for the
constituents of concern and will be designed to comply with all RCRA regulations.
Biological treatment is considered by EPA to be the best available technology for
viscose waste treatment (40 CFR 414). The waste stream would require pH stabili-
zation at the plant influent and the means for sludge disposal. The process
options required before biological oxidation are those discussed previously under
the pretreatment options.
As stated previously, sludge will be tested for EP toxicity. If toxic,
disposal will be in an approved RCRA landfill. If RCRA land ban applies, sludge
will require treatment before disposal. Also, the Virginia Air Pollution Control
Board will determine if any pollution control devices will be necessary to abate
releases of carbon disulfide and hydrogen sulfide from the aerators.
C. Implementation Timeframe
The estimated remedial action timeframes for each of the alternatives
are summarized below:
Alternative
Time to
achieve
aquifer
restoration
N/A
unknown
Time to-
dewater
waste
N/A
2 years
Comments
Will not achieve
aquifer restoration
Once the source of
the ground water
contamination in
completed remediate
time will be
estimated. Bas i n
dewatering and
pumping could
commence following
construction of
pre treatment options..
Construction is
estimated at 1 1/2 to
2 years. FS cost based
on 30 years O&M.
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- 27 -
3 unknown 2 years Time can be
estimated once the
source is remediated.
FS costs based on
30 years O&M.
Construction time
for package plant
is estimated at 2 years.
D. Description of Major ARARs for Selected Remedy
Chemical Specific ARARs for Ground Water Pumping
The following table lists cleanup criteria proposed for chemicals of
concern that will be treated and monitored.
These ARARs are based on values derived frcm the following: MZLs freer.
the Federal Drinking Water Standards, EPA Reference Dose-based water limits,
Federal Ambient Water Quality Criteria and Virginia State Drinking Water Standards.
These are based on identifying the aquifer of concern as equivalent to a Class II
aquifer.
Chemical Specific ARARs
Par ameter (mg/1) ARAR Method/Source
carbon disulfide ' .7 RfD
hydrogen sulfide TBD (1)
sulfide TBD (1)
phenol .3 AWQC
cadmium .01 MCL
lead .05 MCL/VAGWS
arsenic .05 MCL/VAGWS
zinc 5 AWQC/VAGWS
MCL-Maximum Contaminant Level
RfD-EPA Reference Dose-based water limit, assuming 20% contribution
frcm drinking water
(1)-Cleanup level based on further characterization of
site background
VAGWS-Virginia Ground Water Standard
AWQC -Ambient Water Quality Criteria based on organoleptic effects.
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- 28 -
Clean-up criteria would be applied to ground water quality monitored
at both the recovery and monitoring wells. The operation of the ground water
recovery and treatment system may be discontinued when all ARARs for ground
water are attained. The pump and treatment system would be reactivated if
the concentration of indicator chemicals shows a significant increase above the
clean-up criteria in two consecutive quarters.
Performance Criteria ARARS for Ground Water and
Basin Fluid Treatment
On-site discharges from CERCLA sites to surface waters are required to
meet the substantive CWA NPDES requirements, including discharge limitations,
monitoring requirements, and best management practices. State Water Control
Board Regulation 6: NPDES Permit Program, Federal water quality criteria and
State surface water quality standards are also applicable.
Chemical Specific Water Quality ARARs .(in ppb)
Parameter
. Regulation Arsenic Cadmium Lead Zinc Phenolics Hydrogen Sulfide
Human Health Protection
1. CWA Fish and
water 0.0022* 10 50 5000"1" 3500
2. CWA Water Only 0.0025* 10 50 5000+
3. CWA Fish Only 0.0175* --
4. VA Surface 50 10 50 5000 1
Water
Aquatic Life Protection
5. CWA Freshwater 360** -3.9 82 120* 10200
Acute
6. CWA Freshwater 190** 1.1 3.2 . 110* 2560
Chronic
7. VA Freshwater 190** 3.2 16.8 47 1 2
* Risk level of 1 in a million is presented
** Criterion is for trivalent form of arsenic
+ Organoleptic criterion
# Hardness-based criterion, calculated using a value of 100 mg/1
1. Clean Water Act, criteria based on ingestion of fish and water.
2. Clean Water Act, criteria based on ingestion of water only.
3. Clean Water Act, criteria based on ingestion of fish only.
4. Virginia Surface Water Standard for Public Water Supply.
5. Clean Water Act, criteria for protection of freshwater organisms from
acute toxicity. ?
6. Clean Water Act, criteria for protection of freshwater organisms from
chronic toxicity.
7. Virginia water quality criteria for surface water, freshwater organisms.
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-29-
Land Disposal ARARs
If sludge is found to be EP toxic, Hazardous Waste Requirements (RCRA
Subtitle C, 40 CFR, Part 264) is an ARAR. If sludge is EP toxic to levels
that would trigger RCRA Land Ban requirements, then Land Disposal Restrict-
ions (RCRA Subtitle C, 40 CFR, Part 268) is an ARAR. Then, sludge will re-
quire treatment prior to disposal.
Performance Criteria ARARs for Air Emissions from Remedial Activities
- OSHA Requirements (29 CFR'Parts 1910, 1926, and 1904) - OSHA regulations
provide occupational safety and health requirements applicable to workers engaged
in onsite field activities. Threshold limit values (TLVs) refer to airborne
concentrations of substances and represent conditions under which it is believed
that workers may be repeatedly exposed without adverse effects.
- Virginia Air Pollution Control Board Regulations for control and abatement
of air pollution, Subsection 120-05-0300 for new or modified facilities. Remedial
actions will result in emissions of carbon disulfide and hydrogen sulfide. The
standard for non-criteria pollutants (non-carcinogens) is based on the threshold
limit value - time weighted average (TLV-TOA) for that pollutant divided by a
factor of 60 (see Section 120-05-0300), and is applicable at the site boundary
for emissions resulting from the treatment of groundwater and basin fluids.
Location Specific ARARs
Executive Order 11988, Floodplain Management (40 CFR Part 6, Appendix A).
This order requires Federal agencies to evaluate the potential effects of
actions they may take in a floodplain to avoid, to the extent possible, adverse
effects.
Executive Order 11990, Protection of Wetlands (40 CFR Part 6, Appendix A).
This order requires Federal agencies conducting certain activities to avoid, to
the extent possible, the adverse impacts associated with the destruction or loss
of wetlands and to avoid support of new construction in wetlands if a practicable
alternative exist.
The site is located in the 100 year floodplain. Wetlands also have been
identified in the area of concern. However, EPA believes that the remedial action
proposed for Operable Unit 1 will not adversely impact the floodplains or wetlands.
E. Description of the Preferred Alternative
EPA's preferred alternative differs from the alternative recommended by
Avtex and FMC, as discussed in the FS report.
While the ground water remediation component of the alternatives EPA
evaluated in the Proposed Remedial Action Plan are similar to those alternatives
evaluated in the RI/FS, the alternatives EPA evaluated differs from all five
alternatives analyzed in the RI/FS. This is because EPA and the Virginia
Department of Waste Management (DWM) determined that additional studies were
required to fully evaluate the effects dewatering the waste viscose basins has on
the toxicity of the waste, and the volume of waste requiring treatment.
-------
SPA'S preferred alternative for Operable Unit One is comprised of
the following:
the use of existing on-site pumping wells numbers 1, 2, and
3 to pump and recover the contaminated ground water;
installation of modified wells or extraction trenches in Viscose
Basins 9, 10 and 11 for dewatering operations;
pumping and treatment of contaminated ground water and basin liquid
in the existing on-site activated sludge WWTP following necessary
upgrades, modifications and construction of pretreatment units;
periodic monitoring of on-site and off-site ground water, surface
water, and basin fluids throughout the operation and maintenance; and
placement of deed restrictions prohibiting the use of ground
water on the affected properties.
Basin dewatering is an interim measure required before any treatment
of the waste could be implemented. Based on the information gathered in the
remedial investigation, basin dewatering should reduce the toxicity of the
basin material significantly; however, it is unknown if basin dewatering will
be effective in the deeper portions of the basins. The total reduction in
toxicity via dewatering and natural degradation can only be assumed. EPA
therefore recommends that the decision of the preferred final treatment of
the waste be deferred until more is known about the characteristics of the
dewatered waste. Concurrent with the dewatering of the waste, EPA has
recommended that a focused feasibility study to include bench-scale studies
on dewatered waste and treatability studies be conducted to determine:
1) the toxicity of the viscose waste following the dewatering, .and 2) the
technology most effective to treat the remaining volume of hazardous waste.
IX. Summary of Comparative Analysis of Alternatives
A summary o
the following table.
the comparative analysis of alternatives is provided in
Costs included in the table are estimates only.
Comparison of Remedial Alternatives
Avtex Fibers,
Front Royal, Virginia
Remedial Alternatives Operable Unit 1
Alternative 1 Alternative 2
Alternative 3
Screening Criteria No Action GW
GW to Existing WWTP
Dewater Viscose Basins
GW to package WWTP
Dewater Viscose
Basins
Short-term
Effectiveness
Does not miti-
gate potential
risks due to
ingestion of
ground water
Effectively mini-
mizes potential
future risk due to
ingestion of ground
water
Effectively mini-
mizes potential
future risk due to •
ingestion of ground
water
-------
(Cont.)
- 31 -
Alternative 1
Alternative 2
Alternative 3
Screening Criteria No Action GW
GW to Upgraded Existing
WWTP Dewater Viscose Basins
GW to package WriTP
Dewater Viscose Basins
Minimal risk
to workers
Moderate risk to
workers while instal-
ling dewatering system
Moderate risk to
workers while instal-
ling dewatering system
Long-term
Effectiveness
Potential risk
due to ingestion
of ground water
not mitigated
Minimal O&M
required for
security fence
Potential risk due to
ingestion of ground
water minimal
Potential risk due to
ingestion of ground
water minimal
Reduction of
Toxicity, Mobi-
lity and Volume
Ground water
in not affected;
still remains a
potential threat
Low O&M required for
GW recovery and basin
dewatering
Low O&M required for
GW recovery and basin
dewatering
Toxicity and
volume of vis-
cose waste not
affected
Toxicity, mobility
and volume of ground
water permanently and
significantly reduced
Toxicity and volume
of viscose waste
reduced due to
dewatering
Toxicity, mobility and
volume of ground water
permanently and signifi-
cantly reduced
Toxicity and volume of
viscose waste reduced
due to dewatering
Implementabi1i ty
Capital and O&M
Cost (Present
Worth)
Compliance with
ARARs
Utilizes conven-
tional construc-
tion methods
Future remedial
actions not pre-
cluded by the
.current action
$603,000
Does not meet
ARARs in aquifer
Utilizes conventional
construction methods
Future remedial
actions not precluded
by the current action
$9,122,000
Would meet ARARs in
the aquifer and
discharge ARARs
Utilizes conventional
construction methods
Future remedial actions
not precluded by the
current action
$15,421,000*
Would meet ARARs in
the aquifer and dis-
charge ARARs
* If air pollution control devices are required at WWTP, cost will increase.
-------
(Cont.
- 32 -
Alternative 1
Alternative 2
Alternative 3
Screening Criteria No Action GW
GW to Upgrade Existing
WWTP Dewater Viscose Basins
GW to package WWTP
Dewater Viscose Basii.
Overall Protection
Does not protect
against future
ingestion of
ground water
Risk form potential
exposure to ground
water will be mini-
mized while aquifer
is being restored
Risk from potential
exposure to ground water
will be minimized while
aquifer is being restored
The Selected Remedy
Section 121 of SARA and the National Contingency Plan (NCP) establishes a
variety of requirements relating to the selection of remedial actions under CERCLA.
Having applied the current evaluation criteria to the three remedial alternatives,
EPA reccntnends that Alternative 2 be implemented at the Avtex Fibers Site. This
alternative is recommended with the following considerations:
1) the proposed upgrading of the existing WWTP will bring the plant into
steady compliance and
2) treatability studies will conclusively demonstrate that the upgraded plant
will have the capability to treat the recovered ground water and basin fluids.
Alternative 3 will be the contingency plan should the use of the existing
WWTP be excluded.
This is an operable unit remedy for the site and as such does not attempt to
ensure compliance with all ARARs for the entire site. It will be consistent, however,
with those action-specific ARARs addressing the ground water remediation. This
operable unit remedy will not be inconsistent with a final comprehensive remedy for
the source (waste viscose).
The No-Action Alternative is not protective of human health or the environ-
ment and does not meet ARARs; therefore, the No-Action Alternative will not be
considered for this site. Alternative 2 will be protective of human health and
the environment and attains all applicable or relevant and appropriate requirements
identified for this operable unit. The selected alternative can be operational
in approximately two years. Final treatment of the source will not be directly
addressed in this operable unit.
Point of Compliance
The point of compliance for ground water remediation will be the recovery
wells and the monitoring wells on site.
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- 33 -
Preference for Treatment as a Principal Element
The selected remedy involves pumping and treatment of ground water to
address the principal threats posed by ground water contamination. It will also
involve extraction and treatment of basin fluids as an interim measure. This
will reduce the toxicity of the viscose material and its volume. The ROD for the
treatment of the Viscose Waste will address in its entirety remediation of threats
to ground water, air and surface water caused by the viscose basins.
Risk Level To Be Attained
When the aquifer restoration goals are attained, the hazard index
for ingestion of ground water will be less than 1 for the non-carcinogen
contaminants in the ground water. With respect to arsenic, the cancer
risk will be that risk associated with the EPA Primary Drinking Water
Standard of 0.050 mg/1 which is a calculated cancer risk of aporoximatelv
"
Statutory Determinations
Protection of Human Health and the Environment
The selected remedy will provide adequate protection of human health
and the environment by managing the migration of the contaminant plume and by
recovering the contaminated plume for treatment. Institutional controls will
also protect by prohibiting the installation of wells for potable water on •
the east side and the west side of the river. The alternative will not pose
any unacceptable short term risks or cross-media impacts.
Attainment of the Applicable or Relevant and Appropriate Requiranents
The selected alternative will be consistent with those chemical and
action and location specific ARARs detailed in Section D - Description of Major
ARARs.
1. The selected alternative attains the chemical specific ARARs identified
on pages 27 and 28. (Applicable)
1. RCRA Subtitle C, Land Disposal Requirements in 40 CFR 264 and RCRA Subtitle
C Land Disposal Restrictions in 40 CFR 268 which address disposal of hazardous
waste. (Applicable if sludge from wastewater treatment plant is found to be EP
toxic.)
2. Executive order 11988, Protection of Flood Plains and Executive
order 11990, Protection of wetlands. (Applicable) Groundwater pumping
and basin dewatering will not impact the floodplain or the wetlands
identified on site.
3. CWA NPDES Permit Requirements, VA Water Discharge Permit Regulations
which govern the dischares to navigable waters. (Applicable)
-------
- 34 -
4. OSHA Requirements (29 CFR Parts 1910, 1926, and 104). Provides occupational
safety and health requirements applicable to workers engaged in onsite
field activities. (Applicable)
5. VA Air Pollution Control Board Regulations for control and abatement
of air pollution, Subsection 120-05-0300. (Applicable)
Cost Effectiveness
The selected remedy, Alternative 2, is more cost effective than Alter-
native 3 in that it will provide the same level of protection as Alternative 3
but can be implemented at a savings estimated at $6.0 million.
Preference for Treatment as a Principal Element
The selected remedy involves pumping and treatment of ground water
to address the principal threats posed by the Groundwater Operable Unit. It will
also involve extraction and treatment of basin fluids as an interim measure.
This will reduce the toxicity of the viscose material and its volume. The ROD
for the treatment of the viscose waste (second operable unit) will address in its
entirety remediation of threats to ground water, air and surface water caused by
Viscose Basins 9, 10 and 11.
-------
AVTEX FIBERS, INC. SITE
ADMINISTRATIVE RECORD *
INDEX
SITE IDENTIFICATION
Background
1) Letter to Mr. E. E. Campbell, Avtex Fibers, Inc., from Mr. jC. R. Hinkle,
Virginia State Water Control Board, re: response to compliance schedule
submitted 10/26/83 for providing an alternative water source to affected
residents, 10/26/83. P. 1-4. A compliance schedule is attached.
2) Letter to Mr. R. B. Chewning, Virginia State Water Control Board, from
Mr. E. E. Canpbell, Avtex Fibers, Inc., re: preliminary analysis of
monitoring wells, expansion of drilling program, and efforts to provide
alternative water source to affected residents, 12/15/83. P. 5-7.
Notification and Site Discovery
1) Memorandum to U.S. EPA, Region III, from Mr. N. C. Elphick, FMC Corporation,
re: transmittal of notification of Hazardous Waste Site Forms, 6/2/81.
P. 1-3. The forms are attached.
Preliminary Assessment and Site Inspection Reports
1) Report: Preliminary Assessment/Site Inspection Using Available
Information from Avtex Fibers, Inc., prepared by NUS Corporation,
8/28/86. P. 1-89.
Correspondence and Supporting Documentation
1) Contamination Potential Form re: Avtex Fibers, Inc., 7/15/80. P. 1-1.
2) Memorandum to Thomas Voltaggio, U.S. EPA, from Mr. Jeffrey Alper,
U.S. EPA, re: concerned citizen's discovery of suspected contamination
in Front Royal, Virginia, 10/13/83. P. 2-2.
3) Letter to Mr. Darius Ostrauskas, U.S. EPA, from Mr. K. R. Hinkle,
Virginia State Water Control Board, re: presentation summarizing water
pollution problems in Front Royal, Virginia, 10/19/83. P. 3-6. A
report entitled "State Presentation To Board" is attached.
4) Letter to Mr. Darius Ostrauskus [sic], U.S. EPA, from Mr. Khizar Wasti,
Virginia Department of Health, re: well analysis, 11/16/83. P. 7-9.
* Administrative Record available 6/6/88, update 9/12/88.
Note: Company or organizational affiliation is identified in the index only
when it appears in the record.
-------
5) Memorandum to File from Mr. Darius Ostrauskas, U.S. EPA, re: Avtex
Fibers Site Visit, 12/8/83. P. 10-10.
6) Handwritten memorandum to File from Mr. Darius Ostrauskas, U.S. EPA,
re: number of people served by aquifier, 5/22/84. P. 11-11.
7) Handwritten memorandum to File from Mr. Darius Ostrauskas, U--S. EPA,
re: Avtex Fibers' progress in addressing an open dump of viscose
contaminated waste, 5/22/84. P. 12-12. ""*
8) Letter to Mr. Darius Ostrauskas, U.S. EPA, from Mr. K. R. Hinkle,
Virginia State Water Control Board, re: number of people served by the
aquifier of concern within a three-mile radius of Avtex, 5/31/84.
P. 13-17. A letter regarding groundwater Study Progress Report, a
list of property owners, resident status and waters status and a letter
regarding Avtex's Final Closure Plan are attached.
9) Letter to Mr. Darius Ostrauskas, U.S. EPA, from Mr. K. R. Hinkle,
Virgina State Water Control Board, re: status reports generated by
Avtex Fibers, Inc., on their ground water study since May 1984,
10/10/84. P. 18-29. The following are attached:
a) a letter regarding the ground water study;
b) a letter regarding a study to determine river contamination;
c) a letter regarding a ground water Pollution Study;
d) a letter regarding a ground water Study Progress Report, July 30-
August 24, 1984;
e) a letter regarding a ground water Study Progress Report, June 20-
August 24, 1984;
f) a letter regarding a ground water Study Progress Report, Mav 17-
June 20, 1984.
10) Letter to Ms. Susan Insetta, U.S. EPA, from Mr. K. R. Kinkle, Virginia
State Water Control Board, re: Avtex request to revise their Hazardous
Ranking System Score, 1/4/85. P. 30-53. The following are attached:
a) a letter regarding a ground water Pollution Study;
b) a letter regarding comments on the proposed second update to the
National Priorities List;
c) a transmittal letter of analysis ran on ground water samples;
d) a certificate of analysis;
e) a letter regarding Mr. C. Ray Enicks as Plant Manager of Avtex
Fibers;
f) a letter regarding a ground water Study Progress Report, November
1984;
g) a list of laboratories used by Avtex Fibers.for ground water
sampling;
h) an additional monitoring proposal;
i) a status of RiVermont Acres-Fiddlers Green Residents list;
j) a letter regarding the ground water contamination problem in
Front Royal;
-------
k) a letter regarding additional ground water analysis;
1) a map of locations of monitoring and punping wells;
ra) a letter regarding ground water study progress reports, October
1984;
n) a table of sample results;
o) a/sit^-map;
p) a letter regarding the ground water Pollution Study. __
11) Memorandum to File from Mr. William L. Walsh, U.S. EPA, reT Avtex
Fibers, Inc., trip report, 8/6/85. P. 54-58. Two handwritten tables
of viscose basins results are attached.
-------
REMEDIAL ENFORCEMENT PLANNING
Correspondence by Potentially Responsible Party
1) Memorandum to Mr. H. S. Hall from Mr. R. M. Biggs, Jr., re: amended
NPDES Permit,^ 11/9/76. P. 1-15. A letter regarding the amendment of
VA-NPDES"Permit No. VA0002208, a memorandum regarding the amendment and
change in ownership of VA-NPDES Permit No. VA0002208 and gn authorization
to Discharge Under the National Pollutant Discharge Elimination System
and the Virginia State Water Control Law are attached.
2) Memorandum to Mr. A. G. Ruff, Jr., from Mr. R. M. Biggs, Jr., re: solid
waste which falls under hazardous waste definition, 8/29/78. P. 16-16.
3) Memorandum to Mr. Ruff and Mr. Hall from Mr. R. M. Biggs, Jr., re:
Resource Conservation and Recovery Act, 3/21/80. P. 17-18.
4) Memorandum to Mr. R. M. Biggs from Mr. J. D. Ringer, re: disposal of
scrap chemicals, 5/19/80. P. 19-19.
5) Table: Solid Waste Inventory for Front Royal Plant, 7/1/80. P. 20-22.
6) Memorandum to Mr. E. E. Campbell, Avtex Fibers, Inc., from Mr. R. M.
Biggs, Jr., Avtex Fibers, Inc., re: EPA Notification of Hazarous Waste
Activities, 8/13/80. P. 23-24.
7) Letter to Mr. Richard J. Criqui, Jr., Virginia State Water Control Board,
from Mr. R. M. Biggs, Jr., Avtex Fibers, Inc., re: location and frequency
of monitoring wells, 10/23/80. P. 25-26.
8) Handwritten memorandum to Mr. Jim Ringer from Mr. R. M. Biggs re: disposition
of drum chemicals, 10/28/80. P. 27-28.
9) Letter to Mr. H. L. Rexrode, R.S., Virginia State Department of Health,
from Mr. R. M. Biggs, Jr., Axtex Fibers, Inc., re: application for a
Hazardous Waste Permit, Forms 1 and 3, 11/11/80. P. 29-37. The
application is attached.
10) Handwritten memorandum to Mr. Jim Ringer from Mr. R. M. Biggs re: excess
chemicals update, 12/15/81. P. 38-41.
11) Letter to Ms. Lauren Fillmore, Avtex Fibers, Inc., from Mr. John C.
Kendall, PPG Chemical Industries, re: hazardous and safe handling of
Food Chemicals, 3/30/82. P. 42-43. A list of Sodium Hydroxide
Specifications from Food Chemicals Codex is attached.
12) Memorandum to Mr. J. Ringer from Mr. R. M. Biggs, Jr., Avtex Fibers, Inc,
re: excess chemicals, 4/8/82. P. 44-44.
13) Letter to Mr. Harlan Rexrode, Virginia State Department of Health, from
Mr. R. M. Biggs, Avtex Fibers, Inc., re: submission of closure plans
for Present Landfill, for Viscose Basins and for Fly Ash Basins, 7/29/82.
P. 45-50. A Closure Plan for Present Landfill, a Closure Plan for
Viscose Basins, a Closure Plan for Fly Ash Basins, and a facility map
are attached.
-------
14) Memorandum to Mr. C. A. Zarroli, Avtex Fibers, Inc., from Mr. A. G. Ruff,
Jr., Avtex Fibers, Inc., re: Front Royal ground water pollution, 6/7/83.
P. 51-60. • A meeting agenda and a ground water pollution report are
attached.
15) Memorandum tcrMr. R. H. Hughes, Avtex Fibers, Inc., from Mr. A. G. Ruff,
Jr., Avtex Fibers, Inc., re: minutes from 9/27/83 State Watar Control
Board Meeting, 10/4/83. P. 61-62. ~~
16) Letter to Mr. Ken Hinkle, Virginia State Water Control Board, from Ms.
Lauren Fillmore, Avtex Fibers, Inc., re: Phase lib Report, 3/15/84.
P. 63-65.
17) Letter to Mr. J. N. Gregg, Avtex Fibers, Inc., from Mr. Stephen R.
Wassersug, U.S. EPA, re: EPA consideration to spend public funds to
investiaate and take corrective action at Avtex Site, 1/30/85.
P. 66-68.
18) Letter to Ms. Judith Dorsey, U.S. EPA, and Mr. Gregg H. Crystall,
U.S. EPA, from Mariam G. Matrangola, Avtex Fibers, Inc., re: S106
Notice Letter, 2/13/85. P. 69-69.
19) Letter to Mr. Robert Makott, FMC Corporation, from Mr.. Stephen R.
Wassersug, U.S. EPA, re: EPA consideration to spend public funds to
investigate and take corrective action at Avtex Site, 3/8/85.
P. 70-75. A handwritten note is attached.
20) Letter to Ms. Judith Dorsey, U.S. EPA, and Mr. Gregg H. Crystall,
U.S. EPA, from Mr. John Horfler, FMC Corporation, re: S106 Letter
from EPA, 4/15/85. P. 76-76.
Orders
1) Letter to Mr. Gregg H. Crystall. U.S. EPA, from Mr. K. P. Hinkle,
Virginia State Water Control Board, re: EPA becoming the lead agency
handling cleanup of the ground water pollution problem, 8/6/85.
P. .1-5. A letter regarding executing the consent order and a letter
regarding the administrative consent order are attached.
Signed Orders
1) Memorandum to Mr. James M. Seif, U.S. EPA, from Mr. Stephen R. Wassersug,
U.S. EPA, re: amended CERCLA S106(a) Administrative Order of Consent
for a Remedial Investigation/Feasibility Study at the Avtex Fibers Site,
1/27/85. P. 1-1.
2) Letter to Mr. Robert J. McManus, FMC Corporation, from Mr. Henry H.
Sprague, U.S. EPA, re: draft amendments of the Consent Order (undated).
P. 2-17. The amended consent order is attached.
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REMEDIAL RESPONSE PLANNING
Work Plans
1) Report: Remedial Investigation/Feasibility Study Work Plan, prepared by
Geraghty and .Miller, Inc., 3/86. P. 1-375.
2) Report: Quality Assurance Project Plan for Avtex Fibers Site^. Front
Royal, Virginia, prepared by Geraghty and Miller, Inc., 7/8/. P. 376-437.
Remedial Investigation/Feasibility Study Reports
1) Report: Quality Assurance/Quality Control, Remedial Investigation/
Feasibility Study, Revision 1, prepared by Geraghty and Miller, Inc.,
1/1/87. P. 1-139.
2) Report: Sampling and Analysis Plan, Remedial Investigation/
Feasibility Study, Revision 1, prepared by Geraahrv and Miller, Inc.,
1/9/87. P. 140-408.
3) Report: Health and Safty Plan, Remedial Investigation/Feasibility
Study, Revision 1, prepared by Geraghty and Miller, Inc., 1/9/87.
P. 409-523.
4) Report: Remedial Investigation Report, Volumes I, II, and III, Interim,
Final Report, Administrative Order on Consent, Remedial Investigation/
Feasibility Study, Avtex Fibers, Inc., Front Royal, Virginia, prepared by
Geraghty and Miller, Inc., 2/88. P. 524-1758. References are
listed on P. 824-826.
5) Letter to Ms. Ruth Rzepski, U.S. EPA, from Mr. Mark E. Wagner,
Geraghty and Miller, Inc., and Mr. Jeffrey P. Sgambat, Geraghty
and Miller, Inc., re: transmittal of the Field Investigation Summary
Document, Volumes I, II, and III, Administrative Order on Consent,
Remedial Investigation/Feasibility Study, Avtex Fibers, Inc., Front
Royal Virginia, reports, 2/88. P. 1759-3167. The reports are attached.
6) Report: Interim Final Report, Feasibility Study, Administrative Order
on Consent, Remedial Investigation/Feasibility Study, Avtex Fibers, fnc.,
Front Royal, Virginia, prepared by Geraghty and Miller, Inc., 8/88.
P. 3168-3438.
Health Risk/Endanqerment Assessment
1) Memorandum to Mr. Gregg Crystall, U.S. EPA, from Mr. Bruce Molholt,
U.S. EPA, re: Carbon Disulfide Toxicity at Avtex Fibers, 7/10/85.
P. 1-2.
2) Handwritten memorandum to File from Mr. Jim Miller re: telecon with
Mr. Mark Wagner, 5/2/86. P. 3-3.
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Correspondence and Supporting Documentation
1) Letter to Mr. Ken Hinkle, Virginia State Water Control Board, from Mr.
C. R. Enicks, Avtex Fibers, Inc., re: Avtex Fibers, Inc.'s comments to
EPA's March 2i, 1985 letter, 4/3/85. P. 1-2.
2) Memorandum to site file from Mr. Gregg Crystall, U.S. EPA, r»j site
visit on June 11, 1985, 6/18/85. P. 3-3.
3) Letter to Mr. Gregg H. Crystall, U.S. EPA, from Mr. K. H. Hinkle,
Virginia State Water Control Board, re: concerns about the Remedial
Investigation/Feasibility Study Work Plan, 8/7/85. P. 4-5.
4) .Letter to Mr. Robert H. Kirby, Virginia Department of Planning and
Budget, from Ms. Kathryn Hodgkiss, U.S. EPA, re: funding of a proposed
Superfund project, 9/25/85. P. 6-7.
5) Letter to Mr. Gregg Crystall, U.S. EPA, from Ms. Cynthia A. Martin,
Virginia State Water Control Board, re: comments on the proposed
Superfund Site, 10/29/85. P. 8-8.
6) Letter to Mr. Jim Miller, U.S. EPA, from Mr. K. R. Hinkle, Virginia State
Water Control Board, re: Remedial Investigation/Feasibility Work Plan,
4/25/86. P. 9-10.
7) Letter to Ms. Judith A. Dorsey, U.S. EPA, from Mr. R. H. Hughes, Avtex
Fibers, Inc., re: revised draft Work Plan, 3/17/86. P. 11-11.
8) Handwritten memorandum to file from Mr. Jim Miller re: Avtex
Technical Meeting on April 30, 1986, 6/2/86. P. 12-13. A
handwritten agenda is attached.
9) Letter to Mr. Richard H. Hughes, Avtex Fibers, Inc., from Mr. Dennis
Carney, U.S. EPA, re: revisions to the work plan document, 6/18/86.
P. 14-14.
10) Letter to Mr. Mark Wagner, Geraghty & Miller, Inc., from Mr. Dennis
Carney, U.S. EPA, re: comments on the Remedial Investigation/
Feasibility Study, 11/17/86. P. 15-16.
11) Letter to Mr. Michael R. Pisarcik, Avtex Fibers, Inc., from Mr. Dennis
Carney, U.S. EPA, re: response to EPA's request of October 14, 1986,
11/26/86. P. 17-17.
12) Letter to Mr. R. H. Hughes, Avtex Fibers, Inc., from Mr. Dennis Carney,
U.S. EPA, re: Remedial Investigation and Feasibility Study, 12/30/86.
P. 18-20. A certified mail receipt is attached.
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13) Letter to Mr. Janes Miller, U.S. EPA, frcm Mr. Richard H. Hughes, Avtex
Fibers, Inc., re: explanation of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), 1/26/87. p. 21-23. A letter
regarding the Remedial Investigation and Feasibility Study is attached.
14) Letter to -Mrr*Mark Wagner, Geraghty & Miller, Inc., from Mr. Dennis P.
Carney, U.S. EPA, re: comments on the sampling, Quality Assurance/Quality
Control, and Health and Safety Plans, 3/16/87. P. 24-26.^
15) Letter to Mr. James Miller, U.S. EPA, from Mr. Mark E. Wagner, Geraghty
& Miller, Inc., re: modification to the survey conducted on Avtex
Property, 5/18/87. P. 27-27.
16) Memorandum to Mr. James Miller, U.S. EPA, from Mr. H. Ronald Preston,
U.S. EPA, re: Bioassessment Work Group review, 6/1/87. P. 28-28.
Letter to Ms. Ruth Rzepski, U.S. EPA, from Mr. Mark E. Wagner, Geraghty
& Miller, Inc., re: suspension of all counter-pumping activities,
17)
&
6/9/87. P. 29-29.
18) Letter to Mr. Mark E. Wagner, Geraghty and Miller, Inc., from Mr. K. R. .
Hinkle, Virginia State Water Control Board, re: suspending pumping the
recovery wells, 6/12/87. P. 30-30.
19) Letter to fir. Mark Wagner, Geraghty & Miller, Inc., from Mr. Dennis P.
Carney, U.S. EPA, re: dismantling of well series for a six to eight
week period, 6/17/87. P. 31-31.
20) Letter to Ms. Ruth Rzepski, U.S. EPA, from Mr. Mark E. Wagner, Geraghty
and Miller Inc., re: modifications to the bench-scale treatability study,
7/16/87. P. 32-32.
21) Letter to Ms. Ruth Rzepski, U.S. EPA, and Ms. Diana Pickens, U.S. EPA,
from Ms. Michele C. Ruth, Geraghty and Miller, Inc., and Mr. Jeffrey P.
Sgambat, Geraghty and Miller, Inc., re: deletion of the solubility
range test for the viscose basin samples, 7/30/87. P. 33-33.
22) Memorandum to Ms. Ruth Rzepski, U.S. EPA, from Ms. Diana Pickens, U.S.
EPA, re: conraents on additional submissions (July 1 to July 31, 1987)
for Avtex Fibers Site, "8/3/87. P. 34-36. A table on minimum performance
criteria to determine technical adequacy is attached.
23) Letter to Mr. Jeffrey P. Sgambat, Geraghty and Miller, Inc., from Mr.
Dennis P. Carney, U.S. EPA, re: review of the supplemental information
for the Sampling and Analysis and Quality Assurance/Quality Control Plans,
8/6/87. P. 37-38.
24) Letter to Ms. Ruth Rzepski, U.S. EPA, from Mr. Mark E. Wagner, Geraghty
and Miller, Inc., and Mr. Jeffrey P. Sgambat, Geraghty and Miller, Inc.,
re: existing deadline for the submission of the the draft Remedial
Investigation report, 8/12/87. P. 39-39.
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25) Letter to Ms. Ruth Rzepski, U.S. EPA, from Ms. Michele C. Ruth, Geraghty
and Miller, Inc., and Mr. Jeffrey C. Sgambat, Geraghty and Miller, Inc.,
re: modifications to the quality assurance and quality control plan,
8/21/87. P. 40-40.
26) Memorandum" to"*Ms. Mindi Snoparsky, U.S. EPA, from Ms. Kim A Kariya,
U.S. EPA, re: electrical resistivity surveys, 8/24/87. P._4i-44.
27) Report: Evaluation Report of the Geophysics Survey Report (Tasks),
Avtex Fibers Site, Front Royal, Virginia, prepared by EBASCO Services, Inc.,
8/28/87.P. 45-60.'
28) Letter to Mr. Michael Pisarcik, Avtex Fibers, Inc., from Mr. Dennis P.
' Carney, U.S. EPA, re: request for additional time for the submission
of the draft Remedial Investigation Report, 9/3/87. P. 61-61.
29) Letter to Mr. Michael Pisarcik, Avtex Fibers, Inc., from Mr. Dennis P.
Carney, U.S. EPA, re: Final Modifications to the Sampling and Analysis
and Quality Assurance/Quality Control Plans, 9/3/87. P. 62-62.
30) Letter to Mr. Michael Pisarcik, Avtex Fibers, Inc.,- from Mr. Dennis P..
Carney, U.S. EPA, re: review of the geophysical report, 9/4/87. P. 63-;64.
31) Memorandum to Ms. Ruth Rzepski, U.S. EPA, from Mr. Daniel K. Donnelly, -
U.S. EPA, re: analytical reports for Avtex Fibers, 9/30/87. P. 65-90.
The following are attached:
a) a memorandum regarding N03N results of Avtex Fibers;
b) a memorandum regarding Hydrogen Sulfide results for Avtex Fibers;
c) a memorandum regarding volatile organics analysis?
d) a Volatile Organics Analysis Report;
e) a memorandum regarding inorganic results for Avtex Fibers;
f) two chain of custody records.
32) Letter to Ms. Ruth Rzepski, U.S. EPA, and Ms. Diana Pickens, U.S. EPA,
from Mr. Mark E. Wagner, Geraghty and Miller, Inc., re: comments on the
work plans, 7/1/87. P. 91-147. The following are attached:
a) a letter regarding comments on Appendix D, Revisions to the
Sampling and Analysis Plan and Appendix D, Revisions to the
Quality Assurance/Quality Control Plan
b) a memorandum regarding review of 4/23/87 revisions to Avtex
Fibers, Inc. Work Plans
c) a report on comments 1 and 2 - Quality Control Documentation
'for Avtex Laboratory.
33) Letter to Ms. Ruth Rzepski, U.S. EPA, and Ms. Diana Pickens, U.S. EPA,
from Ms. Michele C. Ruth, Geraghty and Miller, Inc., re: revision of
responses to comments 1 and comments 2, 7/31/87. P. 148-164. The revised
comments are attached.
34) Memorandum to file from Mr. Gregg Crystall, U.S. EPA, re: Avtex Fibers,
Inc. meeting on January 30, 1985 (undated). P. 165-166.
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35) Meraorandun to Ms. Diana Baldi from Mr. Mila Javellana, Weston, Inc.,
re: evaluation of Bench Treatability Study Site, 6/8/88. P. 167-239.
A memorandum regarding inorganic data validation and a memorandum regarding
organic data validation are attached.
36) Memorandum" to~"Ms. Ruth Rzepski, U.S. EPA, from Ms. Diana Baldi, U.S. EPA,
re: review of PRP Treatability Study Data, 6/13/88. P. 240-^240.
37) Memorandum to Ms. Ruth Rzepski, U.S. EPA, from Mr. Peter S*tokely, U.S. EPA,
re: wetlands assessment, 8/10/88. P. 241-245.
38) Letter Ms. Ruth Rzepski, U.S. EPA, from Mr. Bill Kregloe, Virginia State
. Water Control Board, re: Avtex Fibers Site, 8/18/88. P. 246-247.
39) Letter to Mr. R. H. Hughes, Avtex Fibers, Inc., fran Ms. Ruth Rzepski,
U.S. EPA, re: Consent Order for the Remedial Investigation/Feasibility
Study, 8/22/88. P. 248-249.
40) Letter to Mr. R. H. Hughes, Avtex Fibers, Inc. from Ms. Ruth Rzepski,
U.S. EPA, re: comments on the Remedial Investigation/Feasibility Study,
8/25/88. P. 250-250.
41) Letter to Ms. Ruth Rzepski, U.S. EPA, from Mr. James A. Adams, Virginia
Department of Waste Management, re: comments on the Draft Feasibility-
Study, 5/25/88. P. 251-253.
42) Letter .to Ms. Ruth Rzepski, U.S. EPA, from Mr. James A. Adams, Virginia
Department of Waste Management, re: comments on the Draft Feasibility
Study, 5/25/88. P. 254-257.
43) Memorandum to Ms. Ruth Rzepski, U.S.'EPA, from Mr. Bruce Molholt, U.S.
EPA, re: Avtex Risk Assessment, 8/31/88. P. 258-259.
44) Letter to Ms. Ruth Rzepski, U.S. EPA, from Mr. Robert B. Ambrose, U.S.
EPA, re: suggestions on the preliminary evaluation of Deseadation
Pathways at the Avtex Fibers Site, 8/31/88. P. 260-265. The suggestions
are attached.
10
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COMMUNITY INVOLVEMENT
Corcnunity Relations Plans
1) Report: Conraunity Relations Plan, Avtex Fibers Site, Front Royal, Warren
County/ Virginia, prepared by EBASCO Services Inc., 3/31/87.p. 1-20.
2) Report: The Citizens' Guidance Manual For The Technical Assistance
Grant Program/ prepared by U.S. EPA, 6/88. P. 21-340. ===*
Facts Sheets, Press Releases, Public Notices
1} Press Release from U.S. EPA Environmental News entitled "EPA Orders Cleanup
of Contamination at Avtex Fibers Site, Front Royal, VA," 9/5/86. P. 1-1.
11
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GZNEHAL GUIDANCE DOCUMENTS *
1) -Promulgation of Sites from Updates 1-4," Federal R««i«t«r. dated 6/10/86.
2) "Proposal of update 4," Federal Register, dated 9/18/83.
3) Memorandua to 0. S. EPA from Mr. Gene Lucero regarding community relations
at Superfund Enforcement sites, dated 8/28/85.
4) Groundvater Contamination and Protection, undated by Mr. Donald 7.
Fellelano on 3/23/85.
5} Memorandua to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedemaa and Mr. Gane Lucero r«: Policy on Ploodplains and
Wetlands Assessments for CZRCLA Actions, 3/6/8S.
6) Guidance of Remedial Investigations under CTMLCLA. dated 6/85.
7) Guidance on Feasibility Studiesunder CZRCLA, dated 6/85.
3) "Proposal of Update 3," Federal Register, dated 4/10/83.
9) Memorandum to Mr. Jack MeCrav entitled "Community Relations Aetlvitas
at Superfund Sites - Interim Guidance," dated 3/22/83.
10) -Proposal of Update 2," Federal Register, dated 10/15/84
LI) EPA Groundvater Protection Strategy, dated 9/84.
12) Memorandum to U.S. EPA fro* Mr. William Heekman, Jr. entitled
"Transmittal at Superfund Removal Procedures - Revision 2," dated 8/20/84.
13) "Proposal of Update I," Federal Register, dated 9/8/83.
14) Community Relation* in Smxrfundt A Handbook (Interim version), dated
9/83.
IS) "Propoosa of first Sational Priority List," Federal Register, dated
12/30/82.
16) "Expands* lli«ibility List," Federal Register, dated 7/23/82.
17) •Interim Priorities List," Federal Register, dated 10/23/81.
18) Uncontrolled Hazardous Waste Site Ranking System; A User's Manual
(undated).
19) Pield Standard Operating Procedures - Air Surveillanem (undated).
20) Pield Standard Operating Procedures - Site Safety Plan (undated).
* Located In SPA Region III office.
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RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION, OPERABLE. UNIT 1
AT THE
AVTEX FIBERS SUPERFUND SITE
FRONT ROYAL, VIRGINIA
September 28, 1988
Prepared for:
U.S. Environmental Protection Agency
Region III
Prepared by:
Booz, Allen & Hamilton Inc.
Under Subcontract Number TESK-TEAM-013, WA Number 1075
with CDM Federal Programs Corporation
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RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION, OPERABLE UNIT 1
AT THE
AVTEX FIBERS SUPERFUND SITE
FRONT ROYAL, VIRGINIA
TABLE OF CONTENTS
Pace
I. Introduction 1
II. Summary of Meeting Presentations 2
III. Public Meeting Comments 5
A. Recommended Alternative 5
B. • Costs.of Remedial Action 6
C. General Questions 7
IV. Written Comments 10
A. Citizen Comments 10
B. Avtex Fibers, Inc. Comments 11
C. FMC Issues 11
D. Other Issues Not Appropriate
to Superfund 13
Attachment 1 - Meeting Agenda and Distributed Information
Attachment 2 - Proposed Remedial Action Plan for the Avtex
Fibers Superfund Site, with Addendum
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RESPONSIVENESS SUMMARY
FOR THE PROPOSED REMEDIAL ACTION, OPERABLE UNIT 1
AT THE AVTEX FIBERS SUPERFUND SITE
FRONT ROYAL, VIRGINIA
I. INTRODUCTION
In accordance with the U.S. Environmental Protection
Agency's (EPA) community relations policy and guidance, the EPA
Region III Office held a public comment period from August 24,
1988, to September 26, 1988, to obtain comments on the proposed
remedial action for Operable Unit 1 at the Avtex Fibers
Superfund site in Front Royal, Vi.rginia. Operable-Unit 1
encompasses the contaminated ground water at the site. On
September 14, 1988, EPA held a public meeting to explain the
Proposed Remedial Action Plan (PRAP) and to obtain public
comments on the proposed remedy. Approximately 80 community
residents and interested persons attended the meeting. Copies
of the PRAP were distributed at the meeting and were placed in
the information repository/administrative record for the site.
The purpose of the Responsiveness Summary is to document
questions and comments raised during the public comment, period
and EPA's responses to them. Section II, immediately
following, summarizes the presentations made at the public
meeting on September 14. Section III presents a summary of the
questions and comments expressed by the public at the meeting.
Section IV then.contains a summary of written comments received
during the public comment period. The questions and comments
are grouped into general categories, according to subject
matter. All questions or comments are followed by EPA's
responses.
This document was prepared by Booz, Allen & Hamilton Inc.,
a subcontractor to CDM Federal Programs Corporation,-under
contract to U.S. EPA Region III to provide community relations
services.
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II. SUMMARY OF MEETING PRESENTATIONS
A. Purpose of Meeting and Meeting Introduction
Colleen Leyden, the U.S. EPA Region III Community
Relations Coordinator for the Avtex Fibers Superfund site,
welcomed meeting attendees. She explained that the public
meeting was being held during the public comment period on the
proposed remedy for the contaminated ground-water portion of
the Avtex Fibers Superfund site, which will be Operable Unit 1
of a two-phased action. The meeting was to fulfill two
purposes: 1) to inform the community of EPA's proposed
remedial action for Operable Unit 1, and 2) to,obtain public
comments on the proposed remedy. She introduced speakers and
other State and EPA personnel.
Ms. Leyden pointed out that EPA had amended its proposed
remedial action, as originally described in the PRAP
distributed to the community in late August 1988. The PRAP had
recommended Alternative 3, pumping of contaminated ground water
and treating it in a newly constructed wastewater treatment
plant. Since the PRAP was written, however, Avtex Fibers had
proposed to upgrade the existing wastewater treatment plant at
the site. EPA, therefore, now recommends Alternative 2, as
amended — pumping of contaminated ground water and treatment
in the existing wastewater treatment plant, which will be
upgraded to meet applicable standards. Ms. Leyden explained
that this change was outlined in the PRAP Addendum, distributed
at the meeting (see Attachment 2).
Ms. Leyden then stated that the Superfund program was
established to address abandoned hazardous waste sites, and
cannot be used to take action at currently operating
facilities. She also explained that the Superfund program
undertakes two kinds actions to respond to hazardous waste
problems. The first type is a "removal" action, which is a
short-term response taken to clean up immediate problems. The
second type is a "remedial" action, designed to address
long-term hazardous waste threats; the actions planned for the
Avtex site fall under the remedial category. The Avtex actions
will be conducted in two phases: the first, Operable Unit 1
now under consideration, will address ground-water
contamination; the second, Operable Unit 2, will address the
viscose basins, and will be undertaken in the near future.
B. Site Background and the Proposed Plan
Ruth Rzepski, the EPA Enforcement Project Manager for the
site, briefly outlined the Avtex Fibers site history. The
plant was built in 1940 to manufacture rayon. It has operated
continuously under the ownership of several firms, including
Avtex Fibers, Inc., the current owner. In 1982, tests showed
the presence of carbon disulfide and phenols in some local
private wells. The site was proposed for EPA's National
-------
Priorities List (NPL), the list of nationwide hazardous waste
sites eligible to receive Federal funds for long-term cleanup,
and was officially added to the list in 1986.
V
Ms. Rzepski explained that after a site is placed on the
NPL, EPA identifies and negotiates with the parties who
contributed to the problem, called potentially responsible
parties (PRPs), to pay to study and clean up the site. EPA
began negotiations with with Avtex Fibers, Inc. and, in 1987,
entered into an Administrative Order with the firm to conduct a
Remedial Investigation and Feasibility Study (RI/FS) at the
site. An RI/FS is a Superfund activity that determines the
extent of contamination present at a hazardous waste site and
evaluates possible actions to address the problem. EPA
concurrently negotiated with FMC Corporation, another PRP, and
in January 1988, amended the Administrative Order to include
FMC. The RI was conducted between May 1987 and January 1988.
Ms. Rzepski briefly outlined the findings of the RI. The
viscose basins were tested and monitoring wells installed to
sample the ground water. From data gathered, it was determined
.that Viscose Basins 9, 10, and 11 are contaminating the ground
water. The hazardous substances of concern found during site'
sampling were summarized in a list distributed at the meeting
(see Attachment 1). Substances from the basins are migrating
through fractures in the bedrock and contaminating wells across
the Shenandoah River from the Avtex site. Viscose, which is
heavier than water, sinks to bedrock level and into cracks,
moves under the river, and contaminates ground water on the far
side; the Shenandoah River is not greatly affected by the
contaminated ground water.
EPA had originally evaluated three remedial alternatives to
address the ground-water contamination at the Avtex site, Ms.
Rzepski explained. The first was the "no-action" alternative,
which would involve construction of a fence to prevent site
access but no actions to clean up the ground water; EPA
regulations require that this alternative be considered for all
Superfund sites. Alternative 2 involved pumping and treating
the contaminated ground water using the existing wastewater
treatment plant. Alternative 3 involved pumping and treating
the contaminated ground water using a newly constructed
wastewater treatment plant. After these alternatives had been
published, however, Avtex Fibers, Inc. recommended modifying
Alternative 2 by upgrading the existing wastewater treatment
plant to meet' applicable standards.
Ms. Rzepski explained that, after careful consideration,
EPA is now recommending Alternative 2, with upgrades.
Alternative 2 as now proposed can be implemented faster than
Alternative 3, and should prove equally effective after
upgrades are completed. If Alternative 2 is found not to be
treating ground water properly, Alternative 3 will be
implemented.
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Ann Cardinal, head of the EPA Region III Community
Relations Staff, provided additional information. In making
its decision on a remedy for the site, EPA will take into
consideration all public comments received during the comment
period. After a remedy is selected, EPA will publish a notice
in local newspapers explaining the remedial action that will be
taken to address the contaminated ground water.
Ms. Cardinal also explained that, once a remedial
alternative is selected for the Avtex Fibers site, EPA will
enter into negotiations with the PRPs to design and implement
the remedy. She cautioned that it will take some time to begin
actual construction of the remedy; it cannot begin immediately
because it will take some time to design properly.
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III. PUBLIC MEETING COMMENTS
Recommended Alternative
1. One questioner asked whether either Alternative 2 or 3
represents a state-of-the-art treatment technology
that can be relied upon to function properly. She
also asked who will determine the effectiveness of the
remedy and how long the pumping and treating will
continue.
EPA Response: The treatment technology that will be
implemented under Alternative 2, as amended, is the
recommended method to treat viscose waste. If the
existing wastewater treatment plant, after being
upgraded, cannot comply with its State discharge
permit, Alternative 2 will be terminated and be
replaced by Alternative 3. Thus, a new wastewater
treatment plant will be constructed. EPA will work
closely with the State to determine the upgraded
plant's effectiveness, and the permit under which the
plant will be operating will be issued by the State.
The State will help to determine the technical and
economic feasibility of the plant's operation.
The wastewater treatment plant will continue to
operate until the contaminated ground water is cleaned
up; at this time it is impossible to determine how
long that will be.
2. A community resident requested information on the
locations of the ground-water monitoring wells
installed during the RI/FS, and asked whether they
will continue to operate during the Remedial Design
and Remedial Action. He specifically asked if ground
water will be monitored on the east side of the
Shenandoah River.
EPA Response: The locations of the monitoring wells
are indicated on the map distributed at the meeting
(see Attachment 1). These wells are located on both
the east and west sides of the river. The wells will
continue to operate throughout the remedial action
until ground water reaches target levels.
3. A meeting attendee asked whether EPA will monitor
neighboring "clean" areas during pumping to determine
whether removing large amounts of water will
contaminate those areas/ or whether pumping will force
contaminated ground water into the Shenandoah River.
EPA Response: The dynamics of the pumping will make
it almost impossible to disperse contaminated ground
water into areas that are currently clean. Ground
5
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water tends to flow from higher to lower levels.
Because of the pumping action, which will extract
large amounts of water, ground water near the pumping
well will be at a lower level than the surrounding
areas. Thus, the pumping would tend to pull cleaner
water toward the contaminated areas and dilute the
substances present, rather than force contamination
toward purer areas. Pumping tests have indicated that
this will occur and EPA is confident that that pumping
will not further disseminate contaminants.
Similarly, tests have shown that it is unlikely that
contaminated ground water will be forced into the
Shenandoah River by the pumping. Some minor leakage
. may occur from the river to the ground water; however,
because the river-water quality is higher than the
water in the plume, this would improve the quality of
the ground water rather than further degrade it.
4. The same attendee asked how deep the ground-water
pumping wells will be; how EPA will dispose of the
treated ground water; and whether EPA will install
additional monitoring wells during the Remedial
Action.
EPA Response: The wells used to pump ground water
will be 150-175 feet deep. After treatment is
completed, the water will be discharged into the
Shenandoah River. At this time, EPA is in the process
of determining whether to drill more ground-water
monitoring wells, although the existing wells have
functioned adequately for nearly two years.
5. The same individual then asked whether Geraghty &
Miller, who performed the RI/FS, will conduct the
Remedial Design and Remedial Action at the Avtex site.
EPA Response: The decision of a Remedial Design and
Remedial Action contractor will be made by the PRPs.
EPA does not yet know which firm will be used.
6. One individual asked what role the Virginia State
Water Control Board will have in monitoring the
wastewater treatment plant.
EPA Response: The Water Control Board will set the
discharge limits that the plant must meet. The Water
Control Board, using State personnel, will also
monitor the plant's discharge levels.
B. Costs of Remedial Action
1. One attendee pointed out that Alternative 2, if
selected, will require approximately $10.2 million to
implement according to the PRAP cost estimates. He
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asked EPA to explain how much of this money will be
spent during the first two to three years of the
remedy, and how much will be required thereafter. He
also stated that reports in the information repository
indicate that approximately 40 percent, or $4 million,
will be used during the two to three years for start
up and the remaining $6.2 million in later years.
EPA Response: The estimated cost for Alternative 2,
as shown in the PRAP Addendum, is now $9.1 million,
representing a difference of approximately $1.1
million from the $10.2 figure originally quoted. At
this time it is not possible to state precisely how
much money will be spent on the remedy during its
first years of operation. After the existing
wastewater treatment plant is upgraded to comply with
applicable treatment standards, most of the remainder
of the money will be used for operation and
maintenance of the plant.
Reports on file in the information repository do
estimate that roughly 40 percent of the remedial
implementation funds will be spent during the first -
two or three years of the remedy, with the remainder
being used throughout the life of the cleanup action.
These figures, and those shown in the PRAP, are
estimates of present-worth costs in today's dollars.
Actual costs are likely to vary depending on numerous
factors such as inflation.
2. Another meeting attendee asked whether Avtex Fibers,
Inc. will be expected to bear the entire cost of the
remedial action itself, or whether other firms will
share them.
EPA Response: That is still to be determined. There
are currently two signatories to the Administrative
Order under which the RI/FS was conducted: Avtex
Fibers, Inc., and FMC Corporation. That agreement,
however, covered only the investigation and planning
phase of site response. There will be a second round
of negotiations with the PRPs to determine whether
they -will pay for the Remedial Design and Remedial
Action.
C. General Questions
1. One County resident asked whether EPA has investigated
or plans to investigate reports of Dupont's disposal
of wastes into the City sewer system.
EPA Response: It is likely that any disposal of
wastes into the City sewer system would primarily
affect the Shenandoah River. Operable Unit 1, which
is the subject of this public comment period, deals
-------
only with ground-water contamination, not with the
river. In addition, Superfund cannot address problems
associated with discharging substances into permitted
municipal treatment plants; problems of this type are
regulated under other laws.
2. A meeting participant asked whether public comments
received during the comment period will be considered
when EPA selects the remedy.
EPA Response: All comments that EPA receives during
the designated public comment period are reviewed and
considered equally in EPA decisionmaking. Only EPA
and State comments receive added emphasis. After the
public comment period is completed, all comments will
be summarized in a document called a Responsiveness
Summary, which will be attached to the decision
document for the Avtex site.
3. One attendee read into the meeting minutes a prepared
statement that voiced dissatisfaction with all of the.
alternatives considered for the Avtex site. . She cited.
environmental problems reportedly caused by Avtex
Fibers, Inc., especially air emissions and dumping
wastes into the river, and stated that she would like
the plant to be closed.
EPA Response: EPA is sometimes in the position of
improving the environment without closing important
economic resources. It will take many millions of
dollars for EPA to clean up the environment;
environmental problems have taken years to create and
they will take years to clean up. Thus, EPA must
proceed in a step-wise fashion. Although EPA has more
than $8 billion to clean up abandoned hazardous waste
sites, it will actually take many times that amount to
address just the sites that are known. EPA is
required by necessity and by law to conserve the Trust
Fund as much as possible. It must work with
economically viable industries, such as Avtex,
toinvestigate and clean up the problems that they have
helped to create. Avtex is cooperating with EPA to
address the contamination present.
4. Several attendees voiced their concern about general
environmental problems and attitudes. One stated that
EPA is not generally complying with the National
Environmental Protection Act (NEPA), which is a law
passed to protect, preserve, and restore the
environment. Another stated that the National
Pollution Discharge Elimination System (NPDES)
permitting process, under which the Avtex wastewater
treatment plant will operate, is a license to pollute.
8
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EPA Response: NEPA is a goal toward which EPA strives.
The U.S. has progressively tried to address different
environmental problems with the successive passage of the
Clean Air Act in 1970, the Clean Water Act in 1972, the
Resource Conservation and Recovery Act in 1976, and
Superfund in 1980. The magnitude of the problems that EPA
must address, however, is large and it is impossible to
succeed completely immediately. It is, therefore,
necessary to institute such programs as NPDES. However,
the purpose of this meeting is to discuss issues specific
to the-Avtex site. These comments are outside the scope of
our current purposes, and will be more appropriately
referred to Congress for consideration.
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IV. WRITTEN COMMENTS
A. Citizen Comments
1. In separate coraents, a Rivermont Acres property owner
and a Fiddler's Green property owner expressed concern
over the quality of ground water in the subdivisions.
One of these residents also indicated that the quality
of the ground water had been poor since 1966.
EPA Response: The Virginia State Water Control Board
in 1982 detected ground-water contamination in private
wells located in the Rivermont Acres subdivision
across the Shenandoah River from Avtex, and requested
that Avtex Fibers, Inc. perform ground-water studies.
Upon completion of these studies, Avtex undertook
measures to address the contamination, measures that
included the purchase of most subdivision properties
and ground-water pumping and treatment. Through the
Virginia State Water Control Board, EPA also became
aware of the ground-water problem in 1982, a problem
that will be addressed and eventually remediated
through Alternative 2, the preferred alternative. EPA-
records indicate that no wells within the contaminated
plume are being used to provide drinking water.
2. One resident asked who will be responsible for
enforcing cleanup activities at the Avtex Fibers site;
EPA Response: Once the ROD is signed, negotiations
will begin with the potentially responsible parties
(PRPs) associated with the Avtex Fibers site. EPA
will seek to have the PRPs implement the Remedial
Action. If negotiations are successful, EPA would
enter into an agreement with the PRPs. If
negotiations are unsuccessful, EPA would either
perform the remedial work itself and then attempt to
recover these costs from the PRPs, or could begin
legal proceedings to force the PRPs to perform all
necessary actions.
3. A citizen was concerned that only two wells on the
west bank of the Shenandoah River would be used to
monitor ground-water quality on the river's west
side. He was also concerned that no wells further
southwest had been tested, and worried that the
contaminant plume may have migrated past the ridgeline
southwest of Rivermont Acres. He suggested that his
well be sampled along with the other two wells.
EPA Response: EPA will require the monitoring of
ground water on the west side of the river; however,
the number and locations of these wells has yet to be
determined.
10
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EPA has asked the companies who have entered into the
Administrative Order to sample three additional wells,
which are located southwest of the Rivermont Acres
subdivision, for indicator chemicals. These wells are
Numbers 187, 199, and 201, and were chosen because of
their location along the bedrock and their depth to an
elevation near 430 feet mean sea level. If
contamination has migrated this distance, EPA would
expect to find the contaminants at or near 430 feet
mean sea level.
B. Avtex Fibers, Inc. Comments
1. Avtex Fibers commented that they agree with
Alternative 2 as proposed in the Addendum to the PRAP,
issued on September 14, 1988.
EPA Response: EPA appreciates the concurrence of
Avtex Fibers, Inc. on Alternative 2, the preferred
remedial alternative.
C. FMC Issues
1. The "Two-Stage Process" is inappropriate.
• EPA Response: The Agency has the authority to split
remediation into operable units. Because EPA does not
know the concentrations of hazardous substances' which -
will remain in the viscose basins after dewatering,
the operable unit-approach to this remediation is
appropriate. EPA has recommended the pumping and
treating of ground water and basin fluids. After that
has been completed, the toxicity of the viscose basins
will be determined.
The comment by FMC that they have proposed capping the
basins during the dewatering process is in error.
Page 4-14 of the FS Report dated August 26, 1988,
states, "After dewatering, a 2 to 4 foot soil cap
would be placed on top of the basins." The statement
by the commentor that a soil cap be placed on the
viscose basins during the dewatering is not
acceptable, since this suggests leaving the dewatered
viscose waste in place without treating the remaining
hazardous waste.
Furthermore, data in the RI are not sufficient to
support the conclusion that the concentrations of
hazardous substances in the viscose basins will
decrease significantly with time, and that the
concentrations of these substances remaining after
dewatering will not present a significant threat to
human health and the environment.
11
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FMC was given notice during an August 19, 1988,
meeting with EPA, and by a letter dated August 23,
1988, confirming the substance of that meeting, that
it was necessary to obtain additional information
about the hazardous substances in the viscose basins
and effective treatment methods for the viscose basin
materials after dewatering.
2. The PRAP may mischaracterize FMC's responsibilities.
EPA Response: The FS Report submitted to EPA by Avtex
Fibers, Inc. and FMC Corporation on August 26, 1988,
proposed modifying and upgrading the existing
wastewater treatment plant (WWTP). On page B-ll, -it
states, "The existing plant must be modified to attain
compliance with existing and future NPDES permits...
General maintenance and upgrading of the aeration
basins and clarifiers would also increase the removal
efficiency of the existing WWTP." Also on page B-15
of the FS Report, $1 million has been estimated for
modifications to the existing WWTP. Therefore, it is
not misleading to state in the Addendum to the PRAP
that Avtex Fibers, "inc. and FMC Corporation proposed
updating the existing plant.
Based on the cost estimates for the Remedial Action
presented in the FS Report, it was considered more
cost-effective to bring the existing WWTP into
compliance with existing and future NPDES permit
requirements. Therefore, upgrading and modifying the
existing plant remains a viable option as opposed to
constructing a new package plant to treat the
recovered ground water and basin fluids.
The companies also proposed in the FS Report that the
package plant should be considered as a contingency,
should the proposed modifications to the existing
plant be found infeasible or if, based on bench-scale
and/or pilot studies, it is later determined that the
existing WWTP cannot adequately treat the liquids.
EPA agreed with the approach presented in the FS
Report and modified the PRAP accordingly.
3. The NPDES contingency cannot be open-ended.
EPA -Response: As presented in the FS Report submitted
by Avtex Fibers, Inc. and FMC Corporation, upgrades to
the existing WWTP are considered part of the remedial
action. EPA takes no position as to the apportionment
of liability of costs for remediation associated .with
the existing WWTP. Under CERCLA, each of the PRPs may
be jointly and severably liable for implementing the
selected remedy and for the cost thereof. Absent of
showing a divisible injury, EPA takes no position on
the allocation of liability among PRPs.
12
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4. Joinder of PRPs.
EPA Response: EPA is evaluating the information
provided by FMC Corporation concerning additional
responsible parties and, where appropriate, will issue
notice letters to these parties. EPA welcomes all
information concerning other parties that may be PRPs
at the Avtex Fibers site.
Other Issues Not Appropriate to Superfund
Other issues raised in writing during the public comment
period, but which could not be addressed under Superfund,
included the following:
Dikes built and installed by Avtex along the
Shenandoah River across from the Fiddler's Green
subdivision;
Fiddler's Green and Rivermont Acres subdivision
settlements, transactions, and negotiations with
Avtex Fibers, Inc.;
Operations internal to the Avtex Fibers facility,
including pensions and benefits;
The installation of a sewer line through the
Fiddler's Green subdivision; and
The the removal of top soil from Fiddler''s Green
lots.
Superfund is designed to address past hazardous waste
disposal and handling practices that have resulted in
proven or potential environmental problems. It does
not provide the authority to respond to current waste
production nor to activities that are internal to
currently operating facilities. Hazardous waste that
is being produced today is regulated under the
Resource Conservation and Recovery Act (RCRA).
13
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ATTACHMENT 1
><^% UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
^ ": REGION III
841 Chestnut Building
Philadelphia. Pennsylvania 19107
Avtex Fibers,Inc.
Superfund Site
Public Meeting
Wednesday, September 14, 1988
Agenda
Opening Remarks
Superfund Discussion
Colleen Leyden, EPA
Superfund Community Relations Coordinator
Technical Presentation
Ruth Rzepski, EPA
Enforcement Project Manager
Questions and Answers
Closing Remarks
Colleen Leyden
Attending Experts
E.Ann Cardinal, EPA
Superfund Community Relations Coordinator
Bruce Mulholt, EPA
Toxicologist
James Adams, Remedial Design/Remedial Action Supervisor
Virginia Department of Waste Management
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«° **>, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
\ *SSi
841 Chestnut Building
««»»'• Philadelphia, Pennsylvania 19107
AVTEX FIBERS SUPERFUND SITE
FRONT ROYAL, VIRGINIA
The Avtex Fibers, Inc. site is an active synthetic manufacturing facility
located on Kendrick Lane in Front Royal, Virginia. The facility occupies
approximately 440 acres, includes 23 unlined basins, and is situated along
the South Fork of the Shenandoah River.
Avtex Fibers has been in operation since 1940, when American Viscose opened
the first rayon production plant there. Subsequently, the site was sold to
FMC Corporation in 1963, and to its present owner, Avtex Fibers, Inc., in
1976. Rayon fibers have been in constant production at the site since its
opening, polyester was produced between 1970 and 1977, and polypropylene
has been produced since 1985.
Wastes disposed at the site are byproducts of the rayon production process
and include sodium cellulose viscose, zinc-hydroxide sludge and carbon disuifide,
a constituent of viscose waste.
The Avtex Fibers site was proposed to the National Priorities List (NPL)
in October, 1984 and was added to the list in 1986. The NPL is the list
of hazardous waste sites eligible to receive Federal, long-term, cleanup
funds under the Comprehensive Environmental Response, Compensation and
Liability Act, enacted by Congress in 1980 and commonly known as Superfund.
Superfund is designed to address past hazardous waste disposal and handling
practices that have resulted in proven or potential problems. It does not
provide the authority to riespond to current waste production nor to activities
that are internal to currently operating facilities.
-------
I
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AVTEX FIDEHS PLANT
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K&M CONSULIING ENGINEEHS. INC
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VISCOSE BASINS
AVTEX FIBERS, INC.
FRONT ROYAL, VIRGINIA J
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THE FOLLOWING TABLE CONTAINS THE PROPOSED CLEANUP GOALS FOR AQUIFER
RESTORATION. THESE LEVELS ARE BASED ON VALUES DERIVED FROM THE FOLLOWING:
MCLs FROM THE FEDERAL DRINKING WATER STANDARDS, EPA REFERENCE DOSE-BASED
.WATER LIMITS FEDERAL WATER QUALITY CRITERIA AND VIRGINIA DRINKING WATER
STANDARDS.
THESE CLEANUP GOALS ARE BASED ON IDENTIFYING THE AQUIFER'OF CONCERN AS
EQUIVALENT TO A CLASS I! AQUIFER. A CLASS II AQUIFER MEANS THE AQUIFER
IS CURRENTLY USED OR HAS THE POTENTIAL TO BE" USED AS A DRINKING WATER
SOURCE.
PARAMETER CLEANUP GOAL (mg/l)
CARBON DISULFIDE " 0.7
HYDROGEN SULFIDE 'TBD*
PHENOL ICS 0.3
LEAD 0.05
ARSENIC 0.05
CADMIUM TBD*
*TBD - CLEANUP GOAL WILL BE ESTABLISHED AFTER FURTHER CHARACTERIZATION OF
BACKGROUND QUALITY CONDITIONS.
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ATTACHMENT 2
Superfund Update.
&EPA
Region 3 .
Avtex Fibers Site
Front Royal, Virginia
August 1988
PROPOSED REMEDIAL ACTION PLAN
Purpose of the Proposed Plan
This proposed remedial action plan
(Proposed Plan, or PRAP) describes the
preferred alternative for addressing ground-
water contamination at the Avtex Fibers, Inc.
Superfund site, in Front Royal, Warren
County, Virginia. This action is considered
to be Operable Unit 1 in a two-step process
to clean up the Avtex site. The United
States Environmental Protection Agency
(EPA) has recently completed review of a
Remedial Investigation (Rl) and Feasibility
Study (FS) conducted by Geraghty & Miller,
Inc. under an Administrative Order between
Avtex Fibers, Inc., FMC Corporation, and
EPA. The Rl report characterizes the nature
and extent of contamination present at the
site; the FS report describes how various
cleanup technologies that may address site
contamination were developed, evaluated,
and screened. The preferred alternative is
based primarily on the Rl and FS
documents.
This Proposed Plan is being distributed in
order to solicit public comment regarding
the most acceptable method for addressing
the ground-water contamination present at
the Avtex Fibers site, Operable Unit 1. The
fact sheet begins with a brief history of the
Avtex Fibers site, describes the purpose of
the Superfund program, and outlines the
findings of the Rl. It also summarizes project
objectives, the alternatives considered for
Operable Unit 1 at the site,
the preferred alternative and the rationale
for its designation. Finally, the tact sheet
explains community relations during the
remedy selection process and lists sources
for further information.
Site Description and Background
The Avtex Fibers, Inc. site is an active
synthetic fibers manufacturing facility that is
located at 1169 Kendrick Lane, in Front
Royal, Virginia. Situated along the east
bank of the South Fork of the Shenandoah
River, the facility occupies approximately
440 acres, 60 of which are under roof, and
includes 23 unlined waste disposal
structures, in addition to the river, the site is
surrounded to the south, east, and
northwest by residential areas.
Approximately 1,300 people live within one
mile of the site.
The Avtex Fibers site has been in operation
since 1940, when American Viscose
opened the first rayon production plant
there. Subsequently, the site was sold to
FMC Corporation in 1963, and to its present
owner, Avtex Fibers, Inc., in 1976. Rayon
fibers have been in constant production at
the site since its opening; polyester was
made there between 1970 and 1977, and
polypropylene has been produced since
1985.
Wastes disposed at the site are byproducts
of the rayon production process, which
-------
generates two major products: sodium
cellulose viscose, and zinc-hydroxide
(sulfate) sludge. Between 1940 and 1983,
approximately 14 million cubic feet of waste
viscose was disposed in 11 unlined surface
impoundments (basins) on site. After 1983
disposal in the basins ceased and the liquid
viscose was treated in the wastewater
treatment plant (WWTP) located on the site.
Sludge was disposed in seven unlined
basins, which cover approximately 85 acres.
In addition to the 18 viscose and sludge
basins, fly-ash (material removed from
incinerator exhaust by air-pollution control
devices) and boiler-house solids have been
disposed in five other surface
impoundments.
in 1982, carbon disulfide, a constituent of
viscose waste, was identified in private
wells located in a subdivision across the
Shenandoah River from Avtex. The Virginia
State Water Control Board requested that
Avtex perform a ground-water study. After
the investigations were completed, the
company undertook measures to address
the contamination, including purchase of
subdivision properties and ground-water
pumping and treatment.
EPA proposed the Avtex Fibers site on the
EPA Superfund National Priorities List
(NPL), the list of hazardous waste sites
eligible to receive Federal long-term
cleanup funds, in October 1984. Avtex
Fibers, Inc. and EPA in 1986 entered into an
Administrative Order to conduct an RI/FS at
the site; this Order was amended in 1988 to
include FMC Corporation as a respondent.
The purpose of the RI/FS was to define the
nature and extent of contamination at the
site, determine any potential threat posed,
and evaluate possible cleanup alternatives
for the site. Work was begun in 1986. The
Virginia Department of Waste Management
is the support agency in this action.
Purpose of the Superfund Program
The Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA), commonly known as Superfund,
was enacted in 1980. The law provided
broad Federal authority and money to
respond to releases or threats of releases
that could endanger human health or the
environment. Superfund is designed to
address past hazardous waste disposal and
handling practices that have resulted in
proven or potential problems. It does not
provide the authority to respond to current
waste production nor to activities that are
internal to currently operating facilities.
Hazardous waste that is being produced
today is regulated under a separate statute,
the Resource Conservation and Recovery
Act (RCRA).
The U.S. EPA has the primary responsibility
for managing activities under Superfund,
although numerous other parties are
involved with a response. Each cleanup
action must be designed to respond to the
unique conditions of a specific hazardous
waste site; each response is a coordinated
effort of federal, state, and local
governments, private industry, and citizens.
EPA makes every effort to encourage those
responsible for creating the problem to
conduct or pay for the cleanup by
negotiating with the potentially responsible
parties (PRP's) and using the enforcement
authorities in the Superfund law. The
Superfund program is based on the
principle that "the polluter pays." EPA also •
involves state governments in all phases of
response. The Agency provides a number
of opportunities to states to review and
comment on documents, become involved
in long-term planning, and participate in
negotiations with PRP's. States also may
assume the lead role in managing cleanup
activities.
Findings of the Remedial
Investigation
The Rl conducted at the Avtex Fibers site
examined the various site environmental
media at the site, including the ground water
and the viscose basins. Major findings and
conclusions of the Rl were as follows:
Ground-water analyses indicate that
a narrow band, or plume, of ground-
water contamination composed of
carbon disulfides, sulfides, phenols,
-------
and cadmium is present on the site.
This plume appears to be caused by
leaching of viscose waste from
Viscose Basins 9,10, and 11.
Because the constituents detected
are the same as or similar to those
found in wells on the western bank
of the Shenandoah River, the plume
is interpreted to extend from Basins
9, 10, and 11 across the river.
A narrower band of arsenic exists
within the area of ground-water
contaminated by disulfides and
phenols. This appears to have
been caused by the interaction of
the leachate from the viscose basins
and their surrounding berms, or
protective embankments, that are
composed of ciay with a fly-ash
core.
Viscose Basins 9, 10, and 11
contain significantly higher
concentrations of carbon disulfide
than Basins 1, 2, 3, and 7. Whereas
liquid and solids from Basins 1, 2, 3,
and 7 show disulfide levels of less
than 1.5 parts per million (ppm) and
3 ppm, respectively, liquid and solid
samples from Basins 9, 10, and 11
contain concentrations of up to
3,500 ppm and 20,000 ppm,
respectively.
Constituents detected at the Avtex
site include arsenic, cadmium,
carbon, lead, disulfide, chlorine,
iron, sulfate, sulfide, and zinc.
Release of these substances is due
primarily to precipitation infiltration
and leaching of the viscose.
Potential exposure pathways to
chemicals present on site are
dermal (skin) contact with viscose
waste, ground water, or surface
water; ingestion of ground water;
and inhalation. Most of the
exposure pathways are of limited
access. As a result, chemical-
based health risks are within
acceptable ranges.
Carbon disulfide, arsenic, sulfide,
cadmium, phenols, and lead are the
substances of primary concern in
the ground water.
Remedial Objectives
The remedial-action objectives for the Avtex
Fibers site address ground-water
management and interim source control for
the protection of human health, public
welfare, and the environment. The remedial
action selected for the Avtex facility will
satisfy the following primary objectives:
Eliminate the potential for dermal
contact or ingestion of waste material
Reduce or eliminate the infiltration of
the basin liquids to the ground water
Manage the migration of
contaminated ground water from the
site
Remediate, or clean up,
contaminated ground water to
acceptable health levels.
Each of the alternatives considered for the
first operable unit implemented at the site
was evaluated against these objectives.
Summary of Remedial Alternatives
Three remedial alternatives were identified
as possible response actions to address the
contaminated ground water at the Avtex
Fibers site, Operable Unit 1. This operable
unit is the first of two planned to address the
full extent of contamination at the site. It will
focus on eliminating ground-water
contamination and on implementing interim
remedial measures to prevent further
wastes from being released from Viscose
Basins 9, 10, and 11. Interim remedial
measures include basin dewatering.
Once EPA has fully evaluated the effect that
dewatering the waste viscose basins has on
the toxicity of the waste, a second operable
unit will be selected to undertake final
remedial actions for the viscose basins. It
will first be necessary to implement the
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interim measure of basin dewatering before
any of the permanent remedies evaluated in
the Draft FS report can be selected. This is
because the total reduction in toxicity that
will be brought about by dewatering and
natural disulfide degradation can only be
estimated at this time. EPA, therefore, is
recommending that the decision of the final
preferred alternative be deferred until the
toxicity of the dewatered waste can be
evaluated and verified.
Each of the three alternatives for Operable
Unit 1 is briefly summarized below.
Following the construction of the
pretreatment units, the removal of the liquids
from the viscose basins should be
completed in approximately two years,
based on the present estimated liquid-
recovery rate of 50 gallons per minute
(gpm). Basin dewatering will continue until
the final remedial action for the viscose
waste basins is decided. Ground-water
recovery will continue until ground-water
cleanup levels are reached.
The Present Worth Cost of Alternative 2 is
$7,080,000.
Alternative 1 - No Action with Site Security
This alternative meets the requirements of
the National Contingency Plan. The
purpose of including a no-action alternative
is to provide a basis for comparing existing
site conditions with those resulting from the
implementation of the other proposed
alternatives. Under the no-action
alternative, no measures will be taken to
address ground-water contamination
migration pathways. The two major
components of this alternative are
installation of a security fence, including its
annual maintenance, and quarterly ground-
water, monitoring.
The Present Worth Cost of Alternative 1 is
$603,000.
Alternative 2 - Ground-Water Recovery.
Basin Dewaterino with Treatment in Existing
Wastewater Treatment Plant (WWTP).
Following Pretreatment of the Recovered
Fluids
This alternative involves the extraction of
contaminated ground water from wells PW-
1, -2, and -3 and the dewatering and
collection of liquids from Viscose Basins 9,
10, and 11. The recovered liquids would be
treated in the existing WWTP, following
pretreatment to reduce their organic
chemical content. Ground-water monitoring
will ensure that the ground-water recovery
system is operating as designed.
Alternative 3 - Ground-Water Recovery.
Basin Dewatering with Treatment in
Package (New) WWTP
This alternative also requires the same
remedial measures for the ground water
and the same interim remedial measures of
viscose basin dewatering as Alternative 2.
The key difference between Alternatives 2
and 3 is the wastewater treatment system
that will be used for the treatment of the
recovered fluids. Alternative, 3 requires the
construction of a new WWTP. This new
plant will use a conventional activated-
sludge process.
The removal of the viscose basin liquids
should be completed in two years following
completion of construction of the WWTP.
The Present Worth Cost of Alternative 3 is
$10,212,000.
Preferred Alternative and Rationale
for Selection
After careful consideration of the
alternatives, EPA recommends that
Alternative 3, Ground-Water Recovery,
Basin Dewatering with Treatment in a New
WWTP, be implemented. The rationale for
selection of Alternative 3 is as follows :
Although Alternative 2 could be
implemented more quickly, the
existing WWTP has not been in
compliance with the water
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interim measure of basin dewatering before
any of the permanent remedies evaluated in
the Draft FS report can be selected. This is
because the total reduction in toxicity that
will be brought about by dewatering and
natural disulfide degradation can only be
estimated at this time. EPA, therefore, is
recommending that the decision of the final
preferred alternative be deferred until the
toxicity of the dewatered waste can be
evaluated and verified.
Each of the three alternatives for Operable
Unit 1 is briefly summarized below.
' Alternative 1 - No Action with Site Security
This alternative meets the requirements of
the National Contingency Plan. The
purpose of including a no-action alternative
is to provide a basis for comparing existing
site conditions with those resulting from the
implementation of the other proposed
alternatives. Under the no-action
alternative, no measures will be taken to
address ground-water contamination
migration pathways. The two major
components of this alternative are
installation of a security fence, including its
annual maintenance, and quarterly ground-
water monitoring.
The Present Worth Cost of Alternative 1 is
$603,000.
Alternative 2 - Restrict Access. Ground-
Water Recovery. Basin Dewaterino with
Treatment in Existing Wastewater Treatment
Plant (WWTP). Following Pretreatment of the
Recovered Fluids
This alternative involves placing a security
fence around Viscose Basins 9, 10, and 11.
In addition, it includes the extraction of
contaminated ground water from wells PW-
1, -2, and -3 and the dewatering and
collection of liquids from Viscose Basins 9,
10, and 11. The recovered liquids would
be treated in the existing WWTP, following
pretreatment to reduce their organic
chemical content. Ground-water monitoring
will ensure that the ground-water recovery
system is operating as designed.
Following the construction of the
pretreatment units, the removal of the liquids
from the viscose basins should be
completed in approximately two years,
based on the present estimated liquid-
recovery rate of 50 gallons per minute
(gpm). Basin dewatering will continue until
the final remedial action for the viscose
waste basins is decided. Ground-water
recovery will continue until ground-water
cleanup levels are reached.
The Present Worth Cost of Alternative 2 is
$7,080,000.
Alternative 3 • Restrict Access. Ground-
Water Recovery. Basin Dewatering with
Treatment in Package (New) WWTP
This alternative also includes constructing a
fence and requires the same remedial
measures for the ground water and the
same interim remedial measures of viscose
basin dewatering as Alternative 2. The key
difference between Alternatives 2 and 3 is
the wastewater treatment system that will be
used for the treatment of the recovered
fluids. Alternative 3 requires the
construction of a new WWTP. This new
plant will use a conventional activated-
sludge process.
The removal of the viscose basin liquids
should be completed in two years following
completion of construction of the WWTP.
The Present Worth Cost of Alternative 3 is
$10,212,000.
Preferred Alternative and Rationale
for Selection
After careful consideration of the
alternatives, EPA recommends that
Alternative 3, Restrict Access, Ground-
Water Recovery, Basin Dewatering with
Treatment in a New WWTP, be
implemented. The rationale for selection of
Alternative 3 is as follows :
Although Alternative 2 could be
implemented more quickly, the
existing WWTP has not been in
compliance with the water
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discharge permit that was issued by
the Virginia State Water Control
Board. Because the facility has not
functioned properly in the last year
and is currently in violation of its
permit, EPA does not recommend
that the recovered waste fluids and
ground water be treated in the
existing WWTP.
The criteria used to evaluate the
alternatives for this operable unit
include effectiveness,
implementability, and cost-
effectiveness. Together, the above
remedial measures included in
Alternative 3 will meet all of EPA's
remedial objectives for Operable
Unit 1. As combined actions they
will minimize direct contact with the
viscose basins, reduce the volume of
infiltration of the basin liquids to
ground water, manage the migration
of the plume of contamination, and
begin to remediate the ground water
to acceptable, health-based levels of
contaminants.
Communlfy Role In the Selection
Process • :
EPA relies on public comment to ensure that
the remedial alternatives being evaluated •
and selected for each Superfund site are
fully understood and that the concerns of the
local community have been considered.
Written comments on the RI/FS and the
PRAP can be submitted through September
26, 1988, to:
Ruth Rzepski
Enforcement Project Manager
U.S. Environmental Protection
Agency (3HW16)
841 Chestnut Street
Philadelphia, Pennsylvania 19107.
All public comments will be recorded and
responded to in the Responsiveness
Summary section of the Record of Decision
(ROD) for the Avtex Fibers site. A ROD is a
legal document prepared by EPA that
describes the selected remedial action(s) for
a Superfund site. The selection of remedy
will be made after full consideration of all
public comments on the RI/FS and the
PRAP, and will be documented in the ROD.
For More Information
If you have any questions or need additional
information concerning the Avtex Fibers site,
you can call this toll-free number, 1 -800-
438-2474, or you can contact:
Colleen Leyden
Community Relations Coordinator
U.S. EPA, Region III (3PAOO)
841 Chestnut "Street
Philadelphia, Pennsylvania 19107 .
(215) 597-8573
Ruth Rzepski
Enforcement Project Manager
U.S. EPA, Region III (3HW16)
841 Chestnut Street
Philadelphia, Pennsylvania 19107
(215)597-1113.
Copies of the RI/FS and other information
used in the remedy selection process are
part of the Administrative Record for the site,
which is established at the following
location:
Samuels Public Library
538 Villa Avenue
Front Royal, Virginia 22630
(703) 635-3153
Contact: Maria Chiodi.
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MAILING LIST ADDITIONS
To be placed on the mailing list to receive information of the Avtex Fibers, Inc. Site,
please complete this form and mail to:
Colleen Leyden
Community Relations Coordinator, U.S. EPA, Region m (3PAOO)
841 Chestnut Street Philadelphia. Pennsylvania 19107.
Name ___
Address
Affiliation
Telephone.
United States Region II!
Environmental Protection Agency 841 Chestnut Street
Philadelphia, PA 19107
Official Business
Penalty for Private Use
$300
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ADDENDUM TO THE AVTEX FIBERS
PROPOSED REMEDIAL ACTION PLAN
Summary of Remedial Alternative*
Three remedial alternatives were
identified as possible response actions
to address the contaminated ground
water at the Avtex Fibers site. Operable
Unit 1. This operable unit is the first of
two planned to address the full extent of
contamination at the site. It will focus on
eliminating ground-water contamination
and on implementing interim remedial
measures to prevent further wastes from
being released from Viscose Basins 9,
10, and 11. Interim remedial measures
include basin dewatering.
Once EPA has fully evaluated the effect
that dewatering the waste viscose
basins has on the toxicity of the waste, a
second operable unit will be selected to
undertake final remedial actions for the
viscose basins. It will first be necessary
to implement the interim measure of
basin dewatering before any of the
permanent remedies evaluated in the
Draft FS report can be selected. This is
because the total reduction in toxicity
that will be brought about by dewatering
and natural disulfide degradation can
only be estimated at this time. EPA.
therefore, is recommending that the
decision of the final preferred alternative
be deferred until the toxicity of the
dewatered waste can be evaluated and
verified.
Each of the three alternatives for
Operable Unit 1 is briefly summarized
below.
Alternative 1 - No Action with Site
Security
This alternative meets the requirements
of the National Contingency Plan. The
purpose of including a no-action
alternative is to provide a basis for
comparing existing site conditions with
those resulting from the implementation
of the other proposed alternatives.
Under the no-action alternative, no
measures will be taken to address
ground-water contamination migration
pathways. The two major components of
this alternative are installation of a
security fence, including its annual
maintenance, and quarterly ground-
water monitoring.
The estimated Present Worth Cost of
Alternative 1 is $603,000.
Alternative 2 - Ground-Water Recovery.
Basin Dewaterino; with Treatment in
Upgraded. Existing Wastewater
Treatment Plant fWWTPV Following ,
Pretreatment of the Recovered Fluids
This alternative involves the extraction of
contaminated ground water from wells
.PW-1, -2, and -3 and the dewatering and
collection of liquids from Viscose Basins
9,10, and 11. The recovered liquids
would be treated in the
upgraded.existing WWTP, following
pretreatment to reduce their organic
chemical content Ground-water
monitoring will ensure that the ground-
water recovery system is operating as
designed.
Following the construction of the
upgrades and pretreatment units, the
removal of the liquids from the viscose
basins should be completed in
approximately two years, based on the
present estimated liquid-recovery rate of
50 gallons per minute (gpm). Basin
dewatering will continue until the final
remedial action for the viscose waste
basins is decided. Ground-water
recovery will continue until ground-water
cleanup levels are reached.
The estimated Present Worth Cost of
Alternative 2 is $9,122.000.
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. Ground-Water Recovery.
Pewaterino: with Treatment in
WWTP
This alternative also requires the same
remedial measures for trie ground water
and the same interim remedial
measures of viscose basin dewatering
as Alternative 2. The key difference
between Alternatives 2 and 3 is the
wastewater treatment system that will be
used for the treatment of the recovered
fluids. Alternative 3 requires the
construction of a new WWTP. This new
plant will use a conventional activated-
sludge process.
The removal of the viscose basin liquids
should be completed in two years
following completion of construction of
the WWTP.
The estimated Present Worth Cost of
Alternative 3 is $1 5,421 ,000.
If Alternative 2 cannot be implemented
successfully, Alternative 3 will then be
initiated.
The criteria used to evaluate the [Hazardous Was
alternatives for the operable unit ino information K&
effectiveness, implementability, and yc jrp/s, Region\
cost-effectivenes. Together, the abo ^^Heinhia, P!
remedial measures included in
Alternative 2 will meet all of EPA's
remedial objectives for Operable Unit 1.
As combined actions they will minimize
direct contact with the viscose basins,
reduce the volume of infiltration of the
basin liquids to ground water, manage
the migration .of the plume of
contamination, and begin to remediate
the ground water to acceptable, health-
based levels of contaminants.
Preferred Alternative and
Rationale for Selection
New information has become available
since the release of the PRAP for the
Avtex Fibers site on August 27,1988.
Avtex Fibers, Inc. and FMC Corporation
have proposed modifying or upgrading
the existing WWTP so that it can attain
and maintain compliance with the
National Pollution Discharge Elimination
System (NPOES) Permit requirements.
Previously, EPA had recommended
Alternative 3, which would have required
the construction of a package (new)
WWTP to treat ground water and basin
fluids. After careful reconsideration of
Alternative 2 as now proposed,
Alternative 2 is now the preferred
alternative. The implementation of
Alternative 2. however, will be.
contingent on the ability of the existing
plant to attain NPOES compliance and
property treat the recovered liquids.
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