'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.

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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

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                                                                                         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


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             •;                                                                                                                                                  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


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                                       - 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

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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.

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 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 .

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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.

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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
                                                         •>

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                                      - 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.

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                                      - 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.

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                                      - 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.

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                                      - 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.

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         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

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 (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.

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(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)

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                                      -  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.

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                        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.

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 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;

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         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.

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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.

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 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

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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

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     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.

-------
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ro
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                             AVTEX FIDEHS  PLANT
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   FRONT ROYAL, VIRGINIA     J
                                     r\
                                     §
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                                                                                                                0

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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

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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,

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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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