United States Office c,'
Environmental Protection • Emergency and
Agency Rerrjdial Response
EPA/ROD/R03-90/093
September 1990
Superfund
Record of Decision
Avtex Fibers, VA
-------
S027M01 _
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-90/093
1. Recipwnf • Acceuion No.
4. TMtMidSuMM*
SUPERFUND RECORD OF DECISION
Avtex Fibers, VA
Second Remedial Action
5. Report D«M
09/28/90
7.
I. Performing Orgtntndon Rept No.
*. Performing Orgtlniatfon Nun* ind Addrau
10. ProjecvTitk/Work Unil No.
11. Contnct(C) or Grtnt(G) No.
(C)
(0)
12. Sponsoring Orgeriution Nun* tnd Mdreee
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
11. Typo of Report 4 Period Covered
800/000
IS. Supplementary No»e
16.
The 440-acre Avtex Fibers site is a former synthetic fibers manufacturing facility in
Front Royal, Warren County, Virginia. The site is bounded by the South Fork of the
Shenandoah River to the west and northwest, and by residential areas to the south,
northeast, and east. A section of the site lies within the 100-year Shenandoah River
floodplain. The plant produced rayon (1940-1989), polyester (1970-1977), and
polypropylene fibers (1985-1989) . Until 1983, the by-products, including sodium
cellulose xanthate-based viscose waste and zinc hydroxide sludge, were disposed of
onsite in unlined surface impoundments or landfills. Subsequently, the waste was routed
to an onsite wastewater treatment facility. Fly ash (from incinerator exhaust air
pollution control devices) and boiler house solids were disposed of in four other
surface impoundments and one fly ash waste pile. In 1982, a State investigation
identified carbon disulfide, a constituent of viscose waste, in residential wells
located across the river from the plant. In 1983 and 1984, in response to the result of
this investigation, Avtex implemented interim measures to address this ground water
contamination by purchasing 23 subdivision properties in the area with contaminated
ground water, providing an alternate water supply to permanent residents, and
(See Attached Page)
17. Docunent Anelyete «. Oeecrlptofi
Record of Decision - Avtex Fibers,
Second Remedial Action
Contaminated Media: soil, debris
Key Contaminants: organics (PCBs)
b. MenMera/Open-fnoM Twim
VA
c. CO6ATI Hetd/Oroup
19. Security CUM (Thl» Report)
None
20. Security CUM (This Pege)
None
21.
54
22. Price
(8M AMS.Zn.1l)
SM Inttnictioni an
OPTIONAL rONM 273 (4*77)
(Formerly NT13-JS)
t of Coiimvf oc
-------
EPA/ROD/R03-90/093
Avtex Fibers, VA
Second Remedial Action
Abstract (Continued)
implementing a ground water pumping and treatment program. A 1988 Record of Decision
(ROD) addressed further remediation of ground water and dewatering of 3 onsite viscose
basin surface impoundments. In 1989, State site investigations identified PCS
contamination in the soil and in Shenandoah River fish. This contamination may have
been the result of a transformer explosion, general maintenance practices within the
facility's polyester drying area-, and subsequent discharge of PCB-contaminated waste
water from the plant's sewer system to the Shenandoah River. In October 1989, EPA
issued an Administrative Order (AO) to the site owners, Avtex Fibers Inc., requ ring PCB
cleanup and identification and disposal of drummed wastes present onsite. The State
revoked the plant's NPDES permit, and Avtex subsequently ceased operations. In 1989,
EPA initiated a removal action to stabilize the drummed wastes. In 1990, EPA issued
another AO and the former site owners took over the maintonance of freeboard in sulfate
basins and the continuation of wastewater treatment onsite. This ROD addresses the
removal of PCB-contaminated soil, breakdown of the acid reclamation facility, and the
disposal of drummed wastes thought to contain oils, bases, acids, solvents, and PCBs.
Also, this ROD addresses site security, control, maintenance, and health and safety
measures. A subsequent ROD will address possible remediation of remaining contamination
of onsite structures, surface water, sediment, ground water, sewer system, and waste
disposal areas. The primary contaminants of concern affecting the soil and debris are
organics including PCBs.
The selected remedial action for this site includes excavation and offsite disposal of
approximately 5,000 cubic yards of soil contaminated with PCB levels exceeding 10 mg/kg,
followed by restoration of excavated areas; identification of drum contents, treatment
and offsite disposal of drum contents that are RCRA wastes; decontaminating and
recycling or crushing the empty drums followed by incineration or disposal in a RCRA
landfill; dismantlement of the unstable acid reclamation facility with decontamination,
as necessary; and disposing of unusable rubble and machinery onsite. Drums containing
nonhazardous substances will remain onsite and available for liquidation by the
corporate trustee upon EPA's approval. The fourth component of this ROD is site
security, maintenance, control, and health and safety measures. The estimated capital
cost for this remedial action is $8,708,400. There are no O&M costs associated with
this remedial action.
PERFORMANCE STANDARDS OR GOALS.- Cleanup levels for PCB-contaminated soil are based on
EPA published guidance on "Remedial Actions for Superfund Sites with PCB Contamination."
The recommended action level for industrial land use soil is PCB 10-25 mg/kg. For this
site, all soil in excess of 10 mg/kg of PCB will be removed.
-------
U.S. Environmental Protection Agency - Region III
Superfund Program
RECORD OF DECISION
OPERABLE UNIT TWO
AVTEX FIBERS SITE
FRONT ROYAL, VIRGINIA
SEPTEMBER 1990
-------
RECORD OF DECISION
AVTEX FIBERS, INC
I. DECLARATION
Site Name and Location
Avtex Fibers Site, Operable Unit Two (OU2)
Front Royal, Virginia
Statement of Basis and Purpose
This decision document presents the selected remedial action for drummed wastes, PCS-
contaminated soils, the acid reclaim facility and site security, control maintenance, and health and
safety at the Avtex Fibers Site in Front Royal, Virginia, which was chosen in accordance with
CERCLA as amended by SARA, and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision is based on the Administrative Record
for this site.
The Commonwealth of Virginia concurs with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision, may present an imminent
and substantial endangerment to public health, welfare, or the environment.
Description of the Selected Remedy
This remedy is Operable Unit Two (OU 2) in the remediation process of the Avtex Fibers-Front
Royal site. This remedy addresses problems and risks associated with drummed wastes, PCB-
contaminated soils, the acid reclaim facility, and site security, control, maintenance, and health and
safe:- The objective of this remedy is to remove hazardous substances in drums, from
contaminated soils, from the facility structure and associated equipment, and from other safety
hazards and obstacles to future site work. White the remedy does address some of the principal
threats at the site, future actions will involve continued study and possible remediation of additional
site structures, ground water, surface water, a sewer system, and waste disposal areas associated
with the site. RfflU"^'"1 alternatives which address other areas of concern will be delineated in
future Records of Decision.
The major components of the selected remedy include:
* Identification, transportation and disposal of the 2,879 drums currently onsite. Upon
identification of drum contents, liquid hazardous wastes will be treated at an offcite
treatment facility. The contractor procured for this action will be responsible for the
ultimate disposal and/or destruction of the empty drums. Options for empty drums will
-------
likely include decontamination and recycling, crushing and disposal in a secure RCRA
landfill or incineration. Drums which contain non-hazardous substances will be left onsite
and available for liquidation by the corporate trustee upon EPA's approval.
• Excavation, transportation, and disposal of an estimated 5,000 cubic yards of PCB-
contaminated soils to an offsite approved chemical waste landfill. Soils contaminated with
PCBs in excess of 10 parts per million will be excavated for disposal. Following removal
of soils, the excavated area will be resampled to confirm that the cleanup level has been
met. The excavated area will be restored as necessary which may include grading and/or
seeding.
* Dismantling and demolition of the unstable acid reclaim facility. Both the building and
equipment within the building, to the extent practicable and necessary, will be
decontaminated using best management practices. Decontaminated usable equipment from
within the building may be liquidated for financial purposes by the corporate bankruptcy
trustee upon approval by EPA. The corporate trustee may also sell other facility
components as scrap or recyclable material upon approval by EPA. Decontaminated
building rubble, debris, and any unsold or recycled facility components will be left onsite.
A final determination for materials left onsite will be made in a future Record of Decision.
* Continued site security, control, maintenance, and health and safety measures to ensure
protection of human health and the environment
Statutory Determinations
The selected remedy is protective of human health and the environment complies with Federal and
State requirements that are legally applicable or relevant and appropriate to the remedial action.
and is cost-effective. This remedy utilizes permanent solutions and alternative treatment
technologies, to the maximum extent practicable for this Operable Unit There are 5,000 cubic
yards of PCB-contaminated soils present onsite surrounding the polyester loading dock of the plant
which require remediation. Because only a small volume of this PCS contaminated soil poses a
principal threat to public health, welfare or the environment treatment of the PCB-contaminated
soil is not appropriate for this situation. In order to streamline the cleanup process, EPA believes
that excavation and offsite transportation and disposal of the PCB-contaminated soil is the
appropriate remedial response action to address the problem.
Because this remedy will likely restrict future use of certain areas of the site to industrial operations
(due to PCB-contaminated soil remaining onsite above levels for residential use), a review will be
conducted within five yean after commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the environment
_*J SEP 281990
Edwin B. Erickson Date
Regional Administrator
Region HI
-------
n. DECISION SUMMARY
The Avtex Fibers, Inc. Site (Avtex) is a former synthetic flbers manufacturing facility that is located
at 1169 Kendrick Lane, in Front Royal, Virginia, as shown in Figure 1. Situated along the east
bank of the Shenandoah River, the facility occupies approximately 440 acres, 60 of which are under
roof.
Front Royal it located in northwest Virginia along the boundary of the Valley and Ridge and Blue
Ridge physiographic provinces. The facility is bounded to the northwest and west by the South
Fork of the Sbenandoah River and to the south, east and northwest by residential areas.
Approximately 1300 people live within one mile of the site. At the Avtex Fibers site, there are
viscose basins 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 The elevation change
establishes the limits of the 100-year floodplain for the Shenandoah River. The floodplain region
is flat for approximately 1,000 feet At the edge of the fJoodplain region the grade descends
approximately 20 feet to the river. The normal pool level of the river is at 470 feet above MSL
The Sbenandoah River is the only major natural surface water body adjacent to the facility and is
designated as a Gass IV and scenic river by the Virginia State Water Control Board (SWCB). The
Shenandoah River is used for recreational fishing. It also serves as a source of drinking water 23
miles downstream of the facility for the town of Berryville.
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 shak with occasional void spaces and
stringers of silty sandstone. In general, the attitude of the formation beds is nearly vertical with
geologic strike trending northeast-southwest.
The ground water flow system is controlled by the bedding-plane fractures, parallel to the structural
strike of the shate bedrock. The general direction of ground water through the fractured shale is
from the Avtex facility toward the southwest and the Shenandoah River. The ground water
migrating from the vicinity of the viscose basins pushes past the Shenandoah River at depth and
migrates beneath Rivermont Acres, a subdivision located on the west bank of the Sbenandoah
River.
Operations at the Avtex Fibers site began in 1940, when American Viscose first opened a rayon
production plant Subsequently, the site was sold to FMC Corporation in 1963, and to Avtex
Fibers, Inc. in 1976. Rayon fibers have been in constant production at the site since its opening.
Polyester was manufactured from 1970 to 1977 and polypropylene production occurred from 1985
until the plant's closing on November 11, 1989.
-------
Rayon fiber is manufactured from wood puJp by a series of chemical reactions and physical
operations. This process generated a number of wastes that were treated in an onsite wastewater
treatment system or disposed of onsite. Land disposal took place in both unlined surface
impoundments and landfills. The two major byproducts generated through the rayon process were
viscose wiste and zinc hydroxide sludge. The viscose waste was disposed in 11 viscose basins
(numbered 1-11) until 1983 when wastewater treatment of this waste stream was initiated. Waste
sludge containing zinc was disposed of in six unlined sulfate basins (numbered 1-4, 4E and 5) which
cover approximately 85 acres. The sulfate basins drain downhill into an unlined surface
impoundment known as the "emergency lagoon.' Additionally, there are four unlined fly ash basins
(numbered 1-3 and 6) and one fly ash stock pile which were used for the disposal of fly ash and
boiler bouse solids generated from operations at the facility. A solid waste landfill was built over
viscose basins 4, 5 and 6, and was subsequently closed as required by the SWCB. Since late 1983.
solid wastes were placed in a Virginia permitted solid waste landfill All waste disposal structures
are identified and located on Figure 1.
The main plant building was constructed in 1937 for the American Viscose Company. Inside the
building there are four major corridors which run perpendicular to four points of the compass:
north, south, east, and west The physical layout of the plant is organized around the -nain
corridors; The rayon production lines run from south to north adjacent to either side of the east
corridor. The caustic soda, acid reclamation, zinc reclamation, and water softening areas run
adjacent to the west corridor. Along the south corridor the wood, machine, and pipe shops as
well as the plant engineering offices are located South of the main building are the coal storage
field, the power plant, laboratory, and the plant maintenance shops. Figure 2 shows a layout of the
plant's manufacturing facility.
A very extensive underground sewer system traverses the Avtex property originating from the plant
building. Plant sewers were used to transfer wastes and wastewater from the manufacturing plant
to the disposal impoundments and wastewater treatment plant The sewer system consists of an
acid sewer, base sewer, bleach sewer, boiler biowdown sewer, laundry sewer, laboratory sewer.
rainwater sewer and viscose sewer which are constructed of terra cotta and have handled many
incompatible wastes. It is anticipated that the structural integrity of the sewer system has been
compromised and may be a source of subsurface soil and ground water contamination.
In 1982, carbon disulfide, a constituent of the viscose waste, was identified in ground water samples
from residential wells (Rivennont Acres) located across the Shenandoah River from the Avtex
facility. As a result of this discovery, the Virginia State Water Control Board (SWCB) requested
that Avtex perform a ground water investigation. In February 1983, Avtex retained Geraghty and
Miller, Inc. to perform the required study.
As a result of the initial field investigation, Avtex implemented interim remedial measures in 1983
and 1984 to addnas the identified contamination. The interim remedial measures included the
purchase by Avtaot of 23 Rivennont Acres properties whose domestic wells were affected by the
ground water contamination. For one permanent resident and the three seasonal residents, water
being supplied was financed by Avtex FMC Corporation has assumed this responsibility following
the Avtex closing. Avtex also initiated a ground water pump and treat program for purposes of
contaminant recovery and containment.
-------
In October 1984, the Avtex Flben site was proposed for inclusion on the National Priorities Li
(NPL), a list of hazardous waste sites across the country in need of remedial evaluation ano
potential response. The site was finalized on the NPL on June 1, 1966. In August 1986, Avtex
Fibers and the Environmental Protection Agency (EPA) entered into an Administrative Consent
Order to conduct a Remedial Investigation and Feasibility (RI/FS) at the site. The purpose of this.
study was to investigate the magnitude and extent of ground water contamination which resulted
from the viscose waste disposal The Consent Order was amended in January 1988 to include
FMC Corporation as a respondent The RI/FS reports were released to the public on August 27,
1988. The principal findings of the first RI/FS were that viscose basins 9, 10 and 11 are a source
of ground water contamination with respect to the elevated levels of carbon disulfide, hydrogen
sulfide, arsenic, cadmium and lead Based on the findings from the RI/FS, a Record of Decision
(ROD) was signed on September 30, 1988, requiring dewatering of viscose basins 9, 10, 11 and
pump and treat of contaminated ground water. This action is the first operable unit (OU 1) for
the site. Following negotiation periods, FMC Corporation and Avtex Fibers were issued an
Administrative Order (AO) by the EPA requiring these Potentially Responsible Parties (PRPs) to
finance and perform Remedial Design/Remedial Action (RD/RA) to implement the ROD. Both
Avtex and FMC agreed to comply with the AO. Avtex subsequently notified EPA of its alleged
inability to comply with the AO due to the shutdown of operations and financial viability. The
operable unit 1 remedy is currently in the design phase. FMC will perform this
RD/RA
Certain areas within the Avtex facility have been contaminated with porychlorinated biphenyis
(PCBs) resulting primarily from an explosion of an electrical transformer and from maintenance
practices in the polyester drying area. The presence of PCBs on the Avtex site has been confirmed
by the Virginia SWCB through its analysis of samples collected on August 28, 1989, and September
1, 1989. PCBs in excess of the Food and Drug Administration (FDA) Tolerance Level of 2.0 parts
per million (ppm) were detected in fish tissues collected by the SWCB from the Shenandoah River.
As a result, on May 12, 1989, the Virginia Department of Health (VDH) issued an advisory against
the consumption of fish from the lower portions of the North and South Fork Shenandoah and the
mainstem Sbenandoah River from the Front Royal area downstream to the West Virginia State
line. The SWCB also confirmed the presence of PCBs in river bank soil and sediment samples and
onsite soils.
In September 1989, the Commonwealth of Virginia requested an evaluation of the facility by the
EPA Superfund Removal Program. Upon review, the EPA On-Scene Coordinator (OSC)
determined that an imminent threat to the health of the workers at the Avtex facility existed from
contact with PCS contaminated soils. In addition, an imminent threat to the environment existed
from the discharge of PCS contaminated wastewater from the sewer system at the plant to the
Shenandoah River. The OSC initiated assessment activities which included: oversight of the
Avtex-initiated PCS cleanup and an evaluation of drums, bulk storage vessels and process lines.
On October 31,1919, EPA issued an Administrative Order (AO) which required Avtex to: perform
a PCs-contamination study and removal; perform waste identification; segregate and dispose of
hazardous substances contained in drums; and determine the potential release of hazardous
substances associated with site processes, operations and chemical/waste storage areas.
-------
On November 10,1989, the Commonwealth of Virginia revoked the Avtex Fibers National Pollutant
Discharge Elimination System (NPDES) permit Following this action, Avtex ceased operations at
the facility. On November 11, 1989, EPA Region HI responded under CERCLA, declaring an
emergency situation due to the uncontrolled nature of the site resulting from the plant shutdown.
Toe EPA removal action was activated to stabilize the tons of bulk chemicals left unattended
onsite. This included carbon disulfide, sulfuric acid, and system acid left at the facility. An integral
part of EPA's site stabilization activities included maintaining freeboard in the approximately 120
acres of industrial lagoons onsite. If left unattended, these lagoons presented a serious threat of
release of pollutants to the South Fork of the Shenandoah River with subsequent impacts to
drinking water intakes downriver.
On February 2, 1990, EPA issued an Administrative Order (AO) to FMC Corporation requiring
them to maintain freeboard in the sulfate basins and emergency lagoon by treating the industrial
wastewater in accordance with NPDES discharge limits set by the SWCB. On April 30, 1990,
pursuant to the AO FMC took over full operation of the wastewater treatment plant initiated and
operated by EPA to maintain freeboard. Wastewater treatment will continue until a final remedial
alternative is developed for the wastewater lagoons. This interim measure is needed to protect the
Shenandoah River from uncontrolled discharges of hazardous substances pending completion of a
forthcoming remedial investigation and feasibility study (RI/FS) of the entire site.
On or about February 6, 1990, Avtex Fibers Inc., and Avtex Fibers-Front Royal, Inc., (collectively
"Avtex*) had filed for bankruptcy under Chapter 11 of the federal bankruptcy code. The federal
bankruptcy judge has appointed a corporate trustee, Anthony H. Murray, Jr., Inc., to represent
Avtex in all matters. On August 28, 1990, EPA issued an Administrative Order (AO) to Avtex and
the corporate trustee which requires the corporate trustee, among other things, to submit a site-
specific Health and Safety Plan (HASP) that protects the health and safety of workers, other
personnel, and the public from the hazardous substances and other safety hazards at the site.
Htehltf hts of Community Participation
Numerous public participation activities have been conducted since the start of the removal action
in November of 1989. For the first three weeks of the removal action, a community relations
coordinator was on-sceoe. During that time EPA established an Emergency Response Center and
a telephone hot-line at the local youth center in Front Royal Press updates were provided at least
four times a day and the local radio station, WFTR, acted as a conduit for information that had
to be-'eieased immediately. The local cable TV channel was also used to provide information
updates.
Following the November 1989, response, several public meetings were held to bring the public and
press up-to-date activities at the site. Elected officials and the press were taken on site tours to
provide a first-hand view of site conditions. Currently, town officials and the media are updated
weekly by the EPA on site activities.
The proposed plan describing the selected remedy for the second operable unit at the Avtex
Fibers-Front Royal site was released to the public on August 14, 1990. This document and the
pertinent information generated from the EPA Superfund removal and remedial programs were
made available to the public in the local information repository maintained at the Samuels Public
-------
Library in Front Royal, Virginia. The notice of availability of these documents was published in
the Northern VjJTia'f P*'fr on August 14, 1990. A public comment period was held from August
14, 1990 to September 14, 1990. On August 22, 1990, a public meeting was held at the Front
Royal Youth Center specifically to elicit public comments on the proposed plan for the preferred
alternative. At this meeting, representatives from EPA and the Virginia Department of Waste
Management answered questions regarding site problems and the remedial alternatives under
consideration. A response to the comments received during this period is included in the
Responsiveness Summary, which is pan of this Record of Decision.
Scope and Rok of Action
As discussed above, because of the size and complexity of the Avtex site, the EPA has determined
that cleanup at the site will be guided by management principles which will expedite the completion
of total site cleanup. As a result, EPA is addressing portions of the site contamination using its
removal response authorities; whereas other portions will be addressed as pan of the remedial
program.
The remedial process at the Avtex Fibers site is enormous in scope and complexity. The site
occupies approximately 440 acres, 60 acres of which are under roof and includes 23 unlined disposal
lagoons located on the east bank of the Shenandoah River. Since performing the November 1989
removal action, EPA's OSC has remained at the site responding to releases and threats of releases
of hazardous substances, overseeing FMCs operation of the wastewater treatment facility,
overseeing the activities of the corporate bankruptcy trustee, his agents and contractors, assessing
the nature and extent of immediate threats to the public health, welfare, and the environment, and
overall safety measures in regard to this site. To this end the EPA, following the NCP, has taken
a phased analysis approach to responding to site conditions. EPA's removal program has taken
action to achieve significant risk reduction quickly and stabilize the numerous risks following the
shutdown of activities by Avtex at the site. As part of the removal response activities, however,
the OSC determined that further actions are necessary and appropriate to achieve significant risk
reduction quickly prior to beginning the RI/FS process for the entire site, [see Section 300.430 of
the NCP, 55 Federal Register at 8846 (March 8, 1990)]. With these principles in mind, the EPA
has determined that certain remedial actions should be accelerated to achieve significant risk
reductions at Avtex
The objective of this accelerated remedial action is to mitigate potential risks to public health and
the environment associated with wastes contained in drums, PCB contaminated soils, the acid
reclaim facility and the possible lack of site security, control, maintenance and 'health and safety
measures. Additionally, the remedial action will remove obstructions to future site investigations
and remediation efforts. This action will be the second operable unit (OU 2) of a long-term
remediation to address all the threats posed to public health and the environment by the Avtex
Fibers site.
EPA expects treatment to be the preferred method to address principal threats posed by a site.
wherever practicable. Principal threats are characterized as waste that cannot be reliably controlled
in place, such as liquids, highly mobile materials, and high concentrations of toxic compounds. This
action wjll achieve the program's expectation through treatment of all liquid hazardous wastes
contained in the drums. A portion of the PCB laden soils does meet the definition of a principal
8
-------
threat, however, EPA believes that volume to be a small part of the total estimated volume of
contaminated sod and, therefore, would not be cost-effective to treat. The entire estimated volume
of PCB contaminated soils will be disposed in an approved chemical waste landfill
As documented in the September 1988 ROD, EPA selected a partial source control remedy in
operable unit 1. Operable unit 1 addresses ground water contamination resulting from three
viscose disposal basins. That operable unit is currently in the remedial design stage.
After responding to the emergency situation at the site in November 1990, EPA recognized the
need for an RI/FS which thoroughly investigates site conditions beyond the groundwater
contamination study performed in 1986. As such, EPA intends to continue site investigations and
remedial measures which will focus on additional site structures, ground water, surface water and
sediments of the Shenandoah River, plant soils, the sewer system and the 25 waste disposal areas
previously dimmed As the site evaluation continues and other remedial actions are deemed
necessary additional operable units will be defined to facilitate the cleanup.
Site Characteristics Addressed bv the Remedy
As pan of its early removal actions, 2,879 (55-gallon) drums were segregated according to existing
drum labels, secured and staged onsite by EPA, Drums are currently staged in four areas at the
site: shipping #1, shipping #5, pulp storage #1 and beam storage (see Figure 2). According to
the outer drum labeling, the drums are believed to contain both hazardous and non-hazardous
substances including lubricating oil, acids, bases, flammable*, PCB containing oil and solvents.
Drums containing solvent wastes may pose a potential fire and/or explosion threat Continued
weathering of the plant building and structures could result in a potential release of unidentified
substances into the environment and mixing of incompatible wastes.
PCB contaminated soils were identified in soils surrounding the polyester loading dock by Avtex
as pan of an EPA required PCB study and cleanup. The subsequent plant shutdown prevented
completion of these cleanup activities. Approximately 5,000 cubic yards of soil contaminated with
PCBs at levels exceeding 10 pans per million (ppm) are present onsite. Chemical analysis of soils
by Avtex in these areas reveal concentrations ranging for OJ ppm up to 3,365 ppm. The PCB
contaminated soils are estimated to encompass a 34,000 square foot surface area. The vertical
extent of contamination above 10 ppm is approximately 2 feet The PCB contaminated soils have
the ability to migrate into the sewer system. Contaminated soils are in the direct pathway to
Manhole I which is adjacent to the porypropoh/ene process sewer. The OSC has determined that
the potential for continuing release to the process sewer exists. The process sewer discharges to
sulfate basin 4. The November 1969 removal response activities included an assessment of the
various basins to evaluate containment capacities. Based upon that assessment it was recommended
that no additional water be placed into sulfate basin 4. This recommendation was based on
observed erosion at the toe of the berm which encloses the south side of the basin by a small
stream. As previously discussed, the sulfate basins are located in the floodplain. In the event of
a heavy rain, JA, a ten-year storm, the disposal area would be flooded. The soil at the stream
elevation is quite sandy and therefore easily credible. The combination of an increased pond level
in the basin with a rain-swollen stream eroding the embankment toe could lead to a failure of the
basin's containment structure and a release of its contents to the Shenandoah River.
-------
The plant's acid reclaim facility is in extremely poor condition. Weathering, poor mainte.
production practices have caused significant corrosion of the building structure and erosf,3"
foundation. A series of structural studies were conducted at the site by the Department i L.*
during the period 6/12/87 to 8/89. The acid reclaim area was considered to have sig!a
structural problems at that time. Avtex was subsequently ordered to perform corrective ac at
the plant, including the acid reclaim area, as a result of litigation by the Department of ^
between 1968 and 1989. Avtex had begun repairs in the add reclaim area, however, site shutc^
prevented completion of these activities. During removal response activities, the OSC consoj
with a structural engineer and declared the facility extremely unstable. Continued degradau
through normal weathering could cause the structure to collapse, thereby presenting a safety haza.
to response action workers and/or trespassers. Such a structural collapse could also affect nearb
process buildings where vessels and process lines still contain hazardous substances, thereby causing
a release of these hazardous substances which could potentially impact soils and ground water.
Historically, spills which occurred in the building from process tanks, pumps or piping were routed
to the treatment plant via an acid sewer. Considering the drainage pattern and existing floor
conditions, it is likely that spilled materials infiltrated into ground water through foundation cracks.
Numerous tanks associated with the process that took place in the three-story building included the
following: crystallizer tanks, acid evaporator tanks, rotary filter tanks, anhydrous evaporator tanks,
melter tank, mother liquor tanks, glaubers slurry tank, glaubers slurry buffer tank, fine salt settler
tank, zinc settler tanks, caustic soda tanks, small staple sump tank, chemical cleaning tank, raw-acid
tanks, evaporated acid tanks, magma acid tanks, filtered acid tanks, and mixed acid storage tanks.
These tanks and process lines were drained as part of the November 1989 removal action. Most
of the building is constructed of brick and pre-cast roof. Demolishing the building will generate
an estimated 8,000 tons of debris. It is anticipated that salvageable tanks can be liquidated by the
corporate bankruptcy trustee. The Qoor-by-Qoor layout of the acid reclaim facility is shown on
Figures 3, 4, 5, and 6.
Site security, control, maintenance, and health and safety measures are required to ensure
protection of human health and the environment. Security is necessary to prevent public access
to the chemical and physical hazards which still exist at the site. In the event that site maintenance
is not provided, the facility's structures could deteriorate, resulting in release of hazardous
substances still present
SUHIHMFT of Site Risks
The problems and risks associated with each of the components of the remedial action are
identified as follows:
' Past poor maintenance practices and weathering have caused the acid reclaim facility to
become extremely unstable. Acid contained within the vessels of this facility was drained
and treated oosite during previous removal actions. However, the OSC has determined
that contiajued degradation of this facility via normal weathering can cause a complete
collapse. The OSC has also determined that a failure of the facility could impact other
nearby process buildings where both vessels and process lines still contain hazardous
substances, including flammable materials, thereby causing a release. A major release
caused by this type of collapse could force the evacuation of a large number of people in
close proximity to the site. In addition, continued degradation of the acid reclaim facility
10
-------
throufh the normal weathering process poses a physical safety hazard to visitors and workers
ooaite.
The acid reclaim facility also presents an obstacle to future site work. Without removal of
this structure, a comprehensive investigation of contamination remaining at the site cannot
be completed
* The concentration of PCBs that defines the area to be addressed for soils onsite depends
primarily on the type of exposure that will occur based on land use, i.e. residential or
industrial EPA has published 'Guidance on Remedial Actions for Superfund Sites with
PCB contamination." The Superfund cleanup levels contained in that guidance are consistent
with the TSCA PCB spill cleanup policy in 40 CFR Part 61, Subpart G. The Superfund
cleanup guidelines are based on generic exposure assumptions. The cleanup guideline
Superfund has established as protective for industrial land use is 10 - 25 ppm. PCB levels
ranging from 03 ppm to 3365 ppm were found in soOs at the Avtex site. PCB levels
exceeding 10 ppm in soils surrounding the loading dock are determined to pose an
unacceptable risk from exposure to humans. PCBs are classified as a suspected human
carcinogens.
Other factors that define an area to be addressed include the potential for PCBs to migrate
and affect environmental receptors. The PCB contaminated soils are located in a direct
migration pathway to the polypropylene process sewer which discharges to sulfate basin 4.
The containment ability of sulfate basin 4 is questionable due to erosion of the berra which
has occurred In the event of a very heavy rainfall event, the basin's containment could be
lost and contents released to the Sbenandoah River. PCBs are penis tent in the
environment, have a tendency to bioaccumulate in fat-soluble organs of fish and mammals.
and are toxic at low levels. PCB levels in excess of the 2.0 ppm FDA Tolerance Level
have been documented in aquatic life downstream of the facility demonstrating that PCBs
are bioaccumulating and establishing additional risk factors.
* According to the outer drum labeling, the drums are believed to contain both hazardous
and non-hazardous substances including lubricating ofl, acids, bases, flammables, PCB
containing oil, and solvents. A* a temporary measure, drums which were in poor condition
or leaking were overpacked and staged in four areas of the plant as pan of the removal
action. If left onsite, drums would be subject to freeze/thaw conditions which may
compromise the integrity of the drum and may result in a release of hazardous substances.
Any drums which may rupture have the potential to impact other drums of unidentified
substances. The solvent containing drums present a fire and/or explosion threat if allowed
to remain onsite.
' Lack of site security, control, and health and safety measures necessary to prevent public
access that may present an unacceptable direct contact risk to trespassers because of the
chemical and physical hazards which still exist at the site.
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
11
-------
of Ahern«rtve3
Using information collected by EPA's On-Sceoe Coordinator, two remedial action alternatives wen
developed
Alternative 1: No Action
The National Contingency Plan (NCP) requires that this alternative be evaluated at every site to
establish a baseline for comparison of other remedial alternatives. This alternative will not include
any remedial actions at this time to address the risks associated with drummed wastes, PCB
contaminated soils, the acid reclaim facility, or lack of site security, control, maintenance, and
health and safety measures.
This alternative would not minimize or appreciably eliminate, at this time, any threats to human
health and the environment that currently exist In addition, this alternative does not satisfy the
statutory mandate to utilize permanent solutions, nor does it comply with the statutory preference
for remedial actions that reduce toxicity, mobility, or volume. This alternative would allow no
remediation at the site until completion of an Rl/FS report.
Alternative 2: Completion of Site Stabilization Activities
The components of this alternative include:
* Identification, transportation, and disposal of the 24T79 drums of potentially hazardous
substances currently onsite. The actual characterization and volume of hazardous substances
contained in the drums is presently unknown and will have to be determined during the
identification period. The identification process will include sampling and field screening
for chemical characteristics, determination of hazard category for each drum, and
compatability testing for compositing the waste streams. Waste streams determined to be
compatible will then be bulked using sound scientific methods approved by EPA. Wastes
streams determined to be hazardous in accordance with the Resource Conservation and
Recovery Act (RCRA) and having the same RCRA waste code may be bulked for
transportation and disposal Liquid wastes determined to be RCRA hazardous wastes will
be treated at an appropriate offsite treatment facility. Drums containing RCRA hazardous
' wastes, if any, would be transported to an appropriate treatment facility in compliance with
standards for hazardous waste generators and transporters (40 GFR 262 and 263) and DOT
regulations pertaining to transportation of hazardous materials. Treatment technologies are
not specified at this point due to the sampling and analysis still necessary. Final selection
of treatment technologies and volumes to be treated will be made based on vendor
responses to performance specifications. The contractor procured for this action will be
responsible for ensuring proper disposal and/or destruction of the empty drums. Options
to be considered for empty drums are decontamination and recycling, crushing and disposing
in a secure RCRA landfill, or incineration. Drums which are determined to contain non-
hazardous nifrttanm will be left onsite and available for liquidation by the corporate trustee
upon EPA's approval
12
-------
Excavation, transportation, and disposal of PCB contaminated soils to an of&ite chemical
waste landfill in compliance with Toxic Substances Control Act (TSCA) 40 CFR 761.75.
EPA published guidance on "Remedial Actions for Superfund Sites with PCB
Contamination' which is consistent with the nationwide TSCA PCB cleanup policy in 40
CFR Part 61, Subpart G. Superfund guidance requires PCB spills to be cleaned up to
different levels primarily based on the type of exposure that will occur based on land use,
i.e., residential or industrial. EPA believes future land for this site to be industrial.
Recommended Superfund soil action levels of industrial land use range from 10-25 ppm.
For this operable unit, soils contaminated with PCBs in excess of 10 ppm will be excavated
and transported offsite via railcar for ultimate disposal at an approved chemical waste
landfill Railcars to be used are dedicated strictly to the transportation of PCBs. The
receiving facility will have the responsibility for performing any decontamination necessary.
Transportation requirements for hazardous wastes would be applicable for the site action.
Following removal of soils, the excavated area will be rraampled to confirm that the cleanup
level has been met The excavated area will be restored as necessary which may include
grading and/or dust and erosion controls (seeding). The need to alert future land purchasers
of PCB contamination above residential use will be determined in the final operable unit
for the site so that all potential notices can be placed at one time.
The alternative also includes dismantling and demolition of the acid reclaim facility. Both
building and equipment within the building will be dccon^mint^td, if necessary, using best
management practices. Upon EPA approval, decontaminated usable equipment from within
the building may be liquidated by the bankruptcy corporate trustee. Other metal structures
may be sold as scrap or recycled by the corporate trustee upon approval by EPA. or left
onsite. Decontaminated building nibble and debris will be left onsite. If building
decontamination is necessary, decontamination Quids would be treated at the onsite
wastewater treatment plant. However, based on current knowledge of past operations in
the facility, it has been determined that the building debris and rubble will not be
contaminated with any RCRA hazardous waste. Therefore, RCRA is not applicable to the
disposal of the building rubble and debris.
Continued site security, control, maintenance and health and safety to ensure protection of
human health and the environment Compliance with Occupational Safety and Health
Administration (OSHA) standards for worker health and safety 29 CFR Part 1910 and 1926.
1904 wiD be required.
A detailed analysts was performed on both alternatives using the nine criteria specified in the NCP
in order to select • site remedy. The following is a summary of the comparison of both alternatives
based on the evaluation criteria. These nine criteria are: 1) overall protection of human health
and the environment 2) compliance with applicable or relevant and appropriate requirements
(ARARs), 3) toof-term effectiveness and permanence, 4) reduction of toxkity, mobility or volume
through treatment, 5) short-term effectiveness, 6) imptementabOity, 7) coat 8) State acceptance, and
9) community acceptance.
13
-------
1. Overall Protection of Human Health *ad tax EavinwMit
Alternative 2 would eliminate the threat of release of hazardous substances in the drum.
significantly reduce the potential migration of PCBs into the environment; significantly reduce the
potential of direct contact with the chemical and physical hazards that still exist onsice through site
security, control, etc., and significantly reduce the safety hazard and threat of a release.due to the
structural instability of the acid reclaim facility, in a timely manner. In addition, the specified PCS
cleanup level is protective of human health for industrial land use. Alternative 1 would not reduce
any site risks at this time.
2. Compliance with ARARs
JEach alternative is evaluated for compliance with ARARs, including chemical-specific, action-
specific, and location-specific ARARs. Chemical-specific ARARs may be health or risk-based
values that govern the extent of site cleanup. Such ARARs may be actual concentration-based
cleanup levels. Location-specific ARARs include requirements which govern the development
and/or use of natural or culturally sensitive site features such as wetlands, scenic rivers, and
floodplains. Action-specific ARARs pertain to the implementation of the remedy.
The alternatives and associated ARARs for both remedial alternatives are presented in Table 1.
Only chemical-specific and action-specific ARARs are pertinent to tail action, since these activities
do not encompass areas which involve location-specific ARARs . Alternative 2 will meet all TSCA
ARARs for the PCB contaminated soil and tne appropriate RCRA requirements for drummed
wastes if determined to be an ARAR. ARARs are not germane in the case of the No Action
Alternative.
3. LoBf-tena Effectiveness and Perataaeace
This evaluation focuses on the results of a remedial action in terms of the risk remaining and the
ability of the remedy to maintain reliable protection of human health and the environment at the
site after response objectives have been met
Selection of the No Action alternative at this time would afford the lowest degree of long-term
effectiveness and permanence since contaminated soils, drummed wastes and the facility structure
would remain onsite over a long period of time (>3 years) potentially adversely impacting human
health and the environment. Under Alternative 2, drummed wastes and PCB contaminated soils
would be removed leaving no residual risk from these areas that would threaten the effectiveness
over time. The area of PCB soil cleanup would allow for unlimited industrial use, but, it would
require restrictions for residential use. This use restriction will likely be a deed notice to be
decided in a future operable unit
4. Redaction «€ ToxJdty, Mobility or VoluaM throufJi Treatment
This evaluation addresses the statutory preference for selecting remedial actions that employ
treatment technologies which permanently and significantly reduce tenacity, mobility, or volume of
the hazardous substances. This preference is satisfied when treatment is used to reduce the
14
-------
TaMe 1
ARAR Soauwf?
Acgoj
A1L2
Determination
Identification of waste
streams in drums
N/A
Ofbite transport of
drummed wastes and
PCB soils
N/A
RCRA 40 CFR, Pans
261, 264, 268.
Virginia Hazardous
Waste Management
Regulations (VR 672-
10-1), January 1. 1989.
Transport of hazardous
waste streams for
disposal must meet
DOT regulations as
outlined in 49 CFR
Pan 107, Sections
171.1-171.500 and
RCRA regulations as
outlined in 40 CFR
Pan 262 and 263.
Tnnspon of waste
streams must also
satisfy Virginia's
Hazardous Waste
Management
Regulations, January 1,
1989.
Potentially Relevant
and Appropriate
Potentially Relevant
and Appropriate
Applicable
Applicable
Removal and disposal
of drums
N/A
All appropriate
regulations concerning
Use and Management
of Containers; 40 CFR
Pan 264, Sections 170.
178.
Virginia Hazardous
Waste Management
Regulations, January 1,
1989.
Relevant and Appropriate
Relevant
Appropriate
and
15
-------
Landfill i iwul of
drummed w * * streams
N/A
RCRA Land Disposal
Restrictions 40 CFR
Sections 268.1-268.50.
Virginia Hazardous
Waste Management
Regulations. January 1,
1989.
Relevant an
Appropriate
Relevant and
Appropriate
Landfill disposal of
PCB soils
N/A
TSCA disposal
requirements for non-
liquid wastes, 40 CFR
Section 761.60 (a)(4)
and (e).
Applicable
PCB cleanup levels
N/A
'Guidance on Remedial
Actions for Superfund
Sites with PCB
contamination'
TSCA PCB Cleanup
Policy, 40 CFR Pan 61.
Subpart G.
To be considered
To be considered
Excavation of PCB
contaminated soils
N/A
N/A
N/A
N/A
Virginia Erosion and
Sediment Control Law,
Code of Virginia
Sections 10.1-560 ej,
Virginia Air Pollution
Control Board, Code of
Virginia Sections 10.1-
1300
Virginia Regulations for
the Control and
Abatement of Air
Pollution (VR-120-01-
01)
dean Air Act. 42
U.S.C 7401
Relevant and
Appropriate
Potentially Relevant
and Appropriate
Potentially Relevant
and Appropriate
Potentially Relevant
and Appropriate
16
-------
Acid Reclaim Rubble N/A Virginia Solid Waste Relevant and
and Debris Management Appropriate
Regulations (VR-672-
20-10)
Worker and visitor N/A Requirements for Applicable
health and safety workers enpgtag in
onsite activities, OSHA
29 CFR. Section 1910.
17
-------
principal threats it a site through destruction of toxic contaminant!, irreversible reduction ir
contaminant mobility, or reduction of total volume of contaminated media.
The No Action Alternative provides no reduction of tenacity, mobility, or volume of wastes at the
site.
The Site Stabilization Alternative may reduce the toxicity, mobility or volume of contaminants if
treatment is selected for the contents of the drummed wastes. As part of this action, EPA will
determine if decontamination of the acid reclaim facility is necessary. Should decontamination be
required wastewaters will be treated through a wastewater treatment plant.
5. Sbort-Tena Effectiveness
This evaluation concentrates on the effects on human health and the environment which may occur
while the alternative is being implemented and until the remedial objectives are met The following
factors were used to evaluate the short-term effectiveness of each alternative: protection of the
community and workers during the remedial actions, environmental impacts from implementation
until completion of the remedial action. Implementation of Alternative 1 would not result in
increased risk to the public, workers, or the environment because no remedial actions would occur.
Alternative 2 would require proper adherence to safety measures to protect onsite workers and the
local community during excavation and dismantling/demolition activities. Risks posed to the local
community through the offsite transportation of wastes are minimal Additionally, all the remedial
action objectives can be achieved within one year. Site security, maintenance, control and health
and safety measures will remain in effect at all times.
6. iBpfcaeatability
This evaluation deals with the technical and administrative feasibility of implementing the
alternatives and the availability of the various services and materials required during its
implementation.
Implementability is not applicable to Alternative 1 since no action would be taken.
In terms of technical feasibility, no obstacles for implementing Alternative 2 appear to exist. This
alternative requires structural dismantling, demolition and possible construction of a decontamination
pad which are common practices. Drum waste compatabflity testing, batching, treatment, and
disposal are well established and utilized procedures which will be implemented through the use of
performance specification approved by EPA. Excavation and transportation of PCS contaminated
soils are also commonly employed and implemented environmental practices.
The availability of offiite landGlls for hazardous materials is an important consideration for this
alternative. Sucb landfills have been determined to be available for the PCB contaminated soils.
The availability of RCRA treatment and disposal facilities is a concern for implementation of the
alternative. This will be carefully evaluated upon determination of the treatment and disposal
needs.
18
-------
Implementation of Alternative 2 requires a ten percent (10%) cost share from the Commonwealth
of Virginia. This required cost share may present an administrative impediment to the
implementation of the remedy due to the Commonwealth's current budget constraints.
7. Cort
This evaluation examines the estimated costs for implementing the remedial alternatives. Total
costs associated with the Site Stabilization Alternative are estimated to be $ 8.708,400. These costs
are capital costs for project implementation which include applicable transportation and disposal
expenses. There will be no operation and maintenance costs associated with this alternative.
8. State Acceptance
The Virginia Department of Waste Management (DWM) concurs with the U.S. EPA's selection
of Alternative 2 as the preferred remedial alternative for the second operable unit at the Avtex
Fibers site.
9. CoBunonirj Acceptance
A public comment period for the Proposed Plan was held from August 14, 1990 to September 14,
1990. On August 22, 1990, a public meeting was held at the Front Royal Youth Center to discuss
EPA's preferred alternative as described in the Proposed Plan. Area residents, local, and State
officials that attended the meeting were supportive of EPA's preferred alternative, Le.,
Alternative 2. Community acceptance is assessed in the attached Responsiveness Summary. The
Responsiveness Summary provides a thorough review of the public comments received on the
Proposed Plan, and the EPA's responses to those comments.
Selected Remedy
Section 121 of CERCLA, as amended by SARA, and the National Contingency Plan (NCP)
establish a variety of requirements relating to the selection of remedial actions. Based upon
consideration of the requirements of CERCLA, the detailed analysis of alternatives and public
comments, EPA has selected Alternative 2 - Continued Site Stabilization Activities. This
Alternative consists of:
' Identification, transportation, and oflsite disposal of drummed wastes. Liquid waste streams
classified as hazardous according to RCRA will be treated utilizing appropriate technologies.
* Excavation, transportation and disposal of an estimated 5,000 cubic yards of PCB
contaminated soils to an offsite TSCA approved chemical waste landfill Recommended soil
action levels for industrial land use range between 10-25 ppm. To ensure protection of
human health and the environment, soils contaminated with PCBs in excess of 10 ppm will
be excavated. Following removal of soils, the excavated area will be resampled to confirm
that the cleanup level has been met The excavated area will be restored as necessary
which may include grading and/or dust and erosion controls (seeding).
19
-------
• Dismantling and demolition of the acid reclaim building. Both the building and the
equipment within the building, to the maximum extent practicable and necessary, will be
decontaminated using best management practices. Decontaminated usable equipment from
within the building may be sold by the corporate trustee. Upon approval by EPA. the
corporate trustee may also sell other facility components as scrap or for recycling.
Decontaminated building rubble, debris and facility components which are not recycled or
sold wfll be left onsite.
•° Continued site security, control, maintenance, and health and safety measures to ensure
protection of human health and the environment
EPA has collected a significant amount of data regarding site conditions through the removal
response actions which have been conducted at the site since September 1989. The Agency has
evaluated alternatives based on the data collected and the Administrative Record and has
determined the remedial alternative selected in this ROD represents the quickest way to stabilize
the site and address risks previously outlined. Accordingly, EPA issues this ROD to eliminate.
reduce, and control the hazards described in this document consistent with the NCP's bias for
action.
The following represents a breakdown of costs (including contingencies) for each component ui the
remedy:
Component Cost
1. Drummed wastes $ 3,000,000
2. PCB contaminated soils $ 2,678,400
3. Acid reclaim $ 1,680,000
4. Site security, etc. S 1,350,000
TOTAL $8,708340
Th« Statutory Detenainatlona
Alternative 2 would achieve substantial reduction in risks and safety hazards through removal of
drummed wastes, PCB soils, and the demolition of the acid reclaim structure. Risks associated
with migration of PCBs, potential direct contact with drummed wastes, and structural collapse of
the acid reclaim building would be »»«>""•«•«< Obstructions to future site investigations will also
be reduced through the demolition of the acid reclaim building. In addition, there are no
unacceptable short term risks or cross media impacts caused by the implementation of the remedy.
This alternative fe consistent with the NCP which anticipates that the EPA will take early action
at sites where appropriate, and to remediate sites in phases using operable units as early actions
to eliminate, reduce or control the hazards posed by a site or to expedite the completion of total
site cleanup. The EPA is taking a phased approach to response actions at the site. The selected
remedy accomplishes the goal of taking an action where there is sufficient information available to
support the remedy selected. This remedy will streamline the cleanup process at Avtex and be
consistent with the implementation of a total site cleanup in the future.
20
-------
This action « t final action for this operable unit, however it * not the final action for the site nor
does it attempt to ensure compliance with ARARs for the entire site. It wilJ be consistent,
however, with the chemical-specific ARARs for PCBc and action-specific ARARs for PCB soils and
transportation and disposal of hazardous materials. Where not applicable, RCRA regulations may
still be relevant and appropriate for the drummed wastes.
As required by Section 121 of CERCLA, as amended, U.S.C Section 9621, Alternative 2 is
protective of human health and the environment and reduces the tenacity, mobility and volume of
contamination. The detailed analysis was performed using the nine criteria in order to select a site
remedy. Protectiveness was the most important evaluation criteria to the selection of Alternative
2 for this operable unit The remedy will also attain ARARs which are listed in Table 1 and
utilize permanent solutions to the maximum extent practicable. This Alternative is cost-effective,
establishes implementable objectives with a remedy that provides long-term remediation by removing
or destroying contaminants of concern from the site.
The Commonwealth of Virginia is in concurrence with the selected remedy. Although public
comments were received primarily concerning the PCB cleanup level, those comments are fully
addressed in the Responsiveness Summary.
The Proposed Plan for the Avtex Fibers site was released for public comment on August 14, 1990.
The Proposed Plan identified Alternative 2 as the preferred alternative. EPA reviewed the written
and verbal comments submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the remedy were necessary.
21
-------
III. FIGURES
22
-------
-------
I tHIIMMMIJ III!
HIM IM»IMMMMIIIMU|M
M • IMllimMIMIMMrffM/
Symbols '
l^B W- East Corridor
West Corridor
North Corridor
///// South Corridor
AV HX FIBERS INC.
i n/>. .1 >»:
-------
ACID RECLAIM SECTION IV
GROUND FLOOR
(FIRST FLOOR)
UJKKIUUK VWtSI TUNNEL BELOW)
ANHVMOUS LOADING
ROADWAY
Figure 3
-------
ACID RECLAIM MEZZ FLOOR
SECTION IV
(2ND FLOOR)
ACID RECLAIM
ME2ZFL
ACIO RECLAIM
"E22 FLOOR
ACIO RECLAIM
AMHVOROUS
KB FLOOR
Figurt •*
-------
ID RECLAIM OPERATING FLOOR
SECTION IV
(3RD FLOOR)
•N
ACDWC1AM
/
0000-^7
z
000
ANHVOftOUS
OPfRATIW FLOO*
TINGF
00ft
Figurt S
-------
ACID RECLAIM FOURTH FLOOR
SECTION IV
(CONDENSER FLOOR)
N
OMLONI
Figure 6
-------
RESPONSIVENESS SUMMARY
AVTEX FIBERS SUPERFUND SITE
SEPTEMBER 1990
-------
RESPONSIVENESS SUMMARY
AVTEX FIBERS, OPERABLE UNIT 2
FRONT ROYAL, VIRGINIA
I. RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public comment period from August
14, 1990, through September 14, 1990, for interested parties to comment on the Proposed Plan
for remedial action at the Avtex Fibers Superfund Site in Front Royal, Virginia.
The Proposed Plan, which has been provided as Appendix A to this document, provides a
summary of the background information leading up to the public comment period. Specifically,
the Proposed Plan includes information pertaining to the history of the Avtex Fibers-Front
Royal site, the scope of the proposed cleanup action and its role in the overall site cleanup, a
qualitative assessment of risk, the descriptions of the remedial alternatives evaluated by EPA,
the identification of EPA's preferred alternative, the rationale for EPA's preferred alternative,
and the community's role in the remedy selection process.
EPA held a public meeting at 7.-00 p.m. on August 22, 1990, at the Front Royal Youth Center
to outline the remedial alternatives described in the Proposed Plan in order to present EPA's
preferred alternative for continuing site stabilization activities.
The responsiveness summary, required by the Superfund Law, provides a summary of citizen's
comments and concerns identified and received during the public comment period, and EPA's
responses to those comments and concerns. All comments received by EPA during the public
comment period will be considered in EPA's final decision for selecting the remedial alternative
to continue site stabilization activities at the Avte* Fibers site.
This responsiveness summary is organized into the sections and appendices as described below:
I. • Responsiveness summary overview. This section outlines the purposes of the public
comment period and the responsiveness summary.
IL Summary of major questions and comments received during the public comment period
and EPA responses to these comments. This section summarizes the oral comments
received by EPA at the August 22, 1990, public meeting and provides EPA's responses
to these comments.
IH Written comments received during the public comment period and EPA responses to
these comments.
A. Comments which are relevant to the remedial action in a general nature received by the
EPA, as well as EPA's written response to those letters.
B. Comments which pertain to the response action for drummed wastes.
C. Comments pertaining to the PCB remedial action.
-------
D. Commeats cooceminf the site security, maintenance and health and safety.
E Comments relative to the costs associated with the remedial action.
F. Comments pertaining to the applicable or relevant and appropriate requirements for the
response action.
Appendix A: The Proposed Remedial Action Plan which was distributed to the public
during the public meeting on August 22, 1990.
Appendix B: Sign-in sheets from the August 22, 1990, Public Meeting held at the
Front Royal Youth Center, Front Royal, Virginia,
It PUBLIC MEETING COMMENTS
On August 22, 1990, EPA held a public information meeting to present the Agency's
proposed remedial plan for Operable Unit 2 at the Site. Approximately 45 people attended the
meeting, which took place from 7KJO p.m. to 8:00 p.m. at the Front Royal Youth Center.
Attending the meeting were citizens from the community, local officials, news media, businesses,
the Virginia Department of Waste Management and EPA.
Representatives from EPA made a presentation which addressed: the history of the site,
the conditions currently existing at the site, an explanation of the Superfund process, a
description of the remedial alternatives evaluated for Operable Unit 2, and EPA's proposed
alternative for Operable Unit 2.
Following the presentation, there was a question and answer session. During this period
the majority of the questions raised were outside the scope of the proposed alternative. For
example, the questions that were raised focused on; removal activities at the site, potential
impacts to the Shenandoah River from the site waste disposal activities, a study of the
Shenandoah River required by a Department of Defense Authorization Bill, health impacts
related to ground water contamination, and odors emanating from the property.
Representatives from EPA responded to each of these points.
*
With regard to the proposed alternative, the community appeared to concur with EPA's
preference for Alternative 2 to continue site stabilization activities. There were no objections
raised to impkaentiag Alternative 2. A question was raised as to whether the Virginia
Department of Waste Management would have to sign off this action. A representative from
the Department of Waste Management responded that white they agree that the actions
specified in the preferred alternative need to be done now, the Department still had some
procedural questions with regard to bow the action should be completed. At the time of the
public meeting Virginia believed that these actions should be completed as pan of the removal
program as opposed to the remedial program. The Department also indicated that if the action
is to be completed as a remedial action, the State would be required to contribute a ten percent
cost share. Currently, the Commonwealth of Virginia is operating under budget constraints.
Subsequent to the public meeting the Department of Waste Management concurred on the
proposed remedial alternative, however, funding options are still being explored.
-------
ID. WRITTEN COMMENTS
u G«twr«l Comments
1. During the public comment period written comments were received from Gve local
citizens, including the Warren County Administrator, supporting Alternative 2 as detailed
in the Proposed Plan issued August 14, 1990.
EPA Response EPA appreciated the concurrence of the local citizens on Alternative 2,
the preferred remedial alternative.
2. A separate comment was received from a concerned citizen regarding the cleanup
responsibility for the Avtex. The commentor believes that there are individuals
responsible for the problems at the Avtex Fibers Site that should be held accountable.
EPA Response: EPA conducts Potentially Responsible Party (PRP) searches to
determine who may be liable for response costs or performance of response actions.
The search for responsible panics continues throughout the course of site activities Le.,
the Remedial Investigation/ Feasibility Study (RI/FS), the Remedial Design and the
Remedial Action (RD/RA) as additional information is received. If and when additional
PRPs are identified, EPA will take appropriate action against these PRPs.
3. A comment was received stating that the plan was a long-term, not a short-term
remedial action. A September 21, 1989, memo from Richard Brunker, Toxicologist, to
Associate Division Director, Tom Voltaggio and the EPA "Guide on Remedial Actions
for Superfund Sites with PCB Contamination" was referenced to support the comment.
EPA Response The purpose of the September 21, 1969, memo cited above was to
provide a rapid assessment of possible health and environmental impacts from the PCBs
reported at the facility and from aquatic discharges to in order to assess the need to
perform a response under the removal program. However, the conclusions drawn in that
memo stated that PCB levels near the loading dock are sufficiently high to cause cancer
threats that exceed a 1.0 E-03. The 'Guide on Remedial Actions for Superfund Sites
with PCB contamination' was utilized for the determination of the PCB cleanup level.
The action EPA suggested to take in the Proposed Plan is an accelerated remedial
action. EPA's authority to perform this type of action is based on Section 300.430
(e)(l) of the March 8, 1990, Federal Register, National Oil and Hazardous Substances
Pollution Contingency Plan; Final Rule (NCP).
The NCP establishes a bias for action in the Superfund Program. The preamble explains
that the bias for action and principle of streamlining may appropriately be considered
throughout the life of the project The rule specifically states that "EPA expects to take
early action at sites where appropriate, and to remediate sites in phases using operable
units as early action to eliminate, reduce or control the hazards posed by a site or to
expedite the completion of total site cleanup. In deciding whether to initiate early
action, EPA must balance the desire to definitively characterize site risks and analyze
alternative remedial approaches for addressing those threats in great detail with the
-------
desire to implement protective measures quickly. EPA is promoting the responsiveness
and efficiency of the Superfund program by encouraging action prior to or concurrent
with conduct of an RI/FS as information is sufficient to support the remedy of selection.
TheK actions may be taken under removal or remedial authorities, as appropriate.*
EPA's rationale for performing an accelerated action to remove the PCB contaminated
soils is based upon the qualitative risk of PCB migration as dfrcvwd in the ROD.
4. The Site Background Section should include mention of the pending suit, FMC
Corporation vs. United States, et aL in the United States District Court.
EPA Response: The Agency does not believe that this litigation is relevant to the
remedial action selected. Site history and enforcement activities described in this section
are focused on the following: site activities that led to current site problems; site
investigations, remedial actions, and removal actions conducted; and enforcement
activities pertaining to the site. Additionally, EPA and the public are aware of this
litigation as it is a matter of public record in Federal Court
5. The commentor stated that the Trustee in this case is not an individual Rather it is
Anthony R Murray, Jr., Inc.
EPA Response The Record of Decision has been amended to include a statement that
the Trustee is Anthony tL Murray, Jr., Inc. Hereafter, reference will be made to the
"corporate" bankruptcy Trustee.
6. A comment was included regarding the consideration of only two alternatives. The
commentor stated that consideration should be given to additional possible courses of
action to resolve site problems in the most cost effective manner possible.
EPA Response The time period to perform an RI/FS at a site of average complexity is
approximately 18 months. EPA believes that the Avtex site is more complicated then
average and may take a considerably longer time period to perform an RI/FS there.
Existing she condition justify an accelerated action. Although significant site
stabilization measures were taken to eliminate the immediate fire and explosion threats,
the potential of a future fire exists. The acid reclaim facility is in very poor condition
due to past operation practices and neglect The threat of release of hazardous
substances due to collapse is a real possibility. If performing the response action were
to be pmlpmnl until the completion of an RI/FS, the probability that tms event will
occur ?•""••"» significantly. To delay the actions selected until an RI/FS is completed.
does not reduce the risk posed in a timely manner. EPA has chosen to take an
accelerated response action based on data which has already been collected concerning
site conditions as further explained in comment AJ. This approach to site remediation
is also consistent with the long range cleanup goals for the site.
-------
7. A comment was made that the plan is conceptual in nature and not sufficiently adequate
for the public to properly review and provide meaningful observations.
EPA RacpoBse: EPA Proposed Plan for the second operable unit at Avtex meets all
requirements as set forth in EPA's "Guidance on Preparing Superfund Decision-
Documents: The Proposed Plan; The Record of Decision, Explanation of Significant
Differences; The Record of Decision Amendment" dated June 1989.
8. Comments were provided on the implementation of Alternative 2 in terms of what
implementation entails, time to complete, what could remain to be completed after this
implementation, and potential impact to third-party actions, Le., availability of labor,
materials and supplies.
EPA Response: This response is offered to the extent that the EPA understands the
comment As previously stated in the Proposed Plan EPA's realistic estimate for
complete implementation of the remedial action is one year. The implementation of the
action will be determined to be complete upon fulfillment of the selected remedy as
described in the Record of Decision. The evaluation of the nine criteria completed in
the ROD include implementability of the remedy. Availability of the various services
and materials required during implementation was evaluated and determined not to
present and obstacle for implementation. Actions which remain to be performed onsite
following the completion of this remedial action will be assessed in subsequent operable
units. Continuing site investigations (including an RI/FS for the entire site) and
remedial measures will focus on additional site structures, ground water, surface water
and sediments of the Shenandoah River, plant soil, the sewer system and waste disposal
areas. As the site evaluation continues and other remedial actions are deemed necessary
additional operable units will be defined to facilitate site cleanup.
9. A commentor on behalf of the Trustee requested an extension of the public comment
period until a review of all requested information is made available for review.
EPA Response: As required by the NCP, a full 30-day comment period was held to
seek public comment on the Proposed Plan. Information pertaining to the proposed
plan was available in the Administrative Record located at the Samuels Public Library in
Front Royal, Virginia and EPA Region UL Philadelphia, Pennsylvania. It is EPA's
belief that Trustee's contractor, Pennoni Associates, Inc. reviewed the Administrative
Record ki EPA's office. In addition, the OSC offered the Trustee's contractor open
access to EPA files maintained onsite. According to the OSC the contractor never took
the opportunity to review information onsite. Finally, the RPM made additional files
available to be reviewed on September 12, 13, and/or 14 as a result of a September 10.
1990 phone request from Pennoni Moreover, the extension was requested on the
closing day of the public comment period. For these reasons EPA does not believe the
comment period should be extended. Any additional information the Trustee can supply
to the EPA will be given due consideration during the response action.
-------
10. A comment was received stating that through its environmental engineers, Pennoni
Associates^ Inc., the Trustee has requested access to certain study data and test results
upon which the Plan is based for which access has been denied. For that reason, the
Trustee • unable to properly comment on the following items:
a. The presence of carbon disulfide contamination at the Rrvermont Acres Domestic
Supply Wells.
EPA Response: This information is public information available in both the EPA
repository in Philadelphia, PA and local repository at Samuels Public Library in Front
Royal, VA. However, the presence of CSj in the Rivermont Acres domestic wells is not
pertinent to the preferred remedial alternative. Moreover, the Trustee may have access
to this information as it was developed by Avtex
b. Whether viscose basins 9, 10, and 11 are a source of ground water contamination with
respect to elevated levels of carbon disulfide, hydrogen sulfide, arsenic, cadmium, and
lead.
EPA Response: See response to comment la. above and the administrative record for
the September 30, 1988 Operable Unit 1 ROD.
c. The PCB contamination allegedly in 5sh tissues, onsite soils, river bank soil and
sediment. The Plan also does not reference any elimination of upstream site
contamination considerations.
EPA Response This information was obtained from the a study of the PCB
contamination in the North Fork, South Fork and Mainstem Shenandoah River
completed by the State Water Control Board dated August 1989. The second sentence
of this statement is vague. To the extent EPA understands the statement, elimination of
PCB contamination in the stream is not addressed in remedial action for the site. The
Virginia State Water Control Board (SWCB) conducted the sampling investigation which
concluded the presence of PCBs in the various media stated above. The SWCB
• sampling^ activity included river bank and sediment samples upstream of the Avtex
facility. Upstream samples results for PCBs were nondetectable.
d. The computation of 5,000 cubic yard of onsite PCB contaminated soils.
EPA RMpeaae The computation of the PCB contaminated soils is a estimate obtained
from the On-Scene Coordinator (OSC).
e. The finding that the Acid Reclamation Facility is extremely unstable and requires
dismantling and demolition and that the removal of the facility is required to complete
the investigation of contamination remaining at the site.
EPA Response: The acid reclaim facility was determined to be extremely unstable by
the OSC upon an onsite consultation with a structural engineer. The OSCs finding is
documented in the January 5, 1990, Funding Request which is part of the Administrative
-------
Record. It k also supported by a general evaluation performed by the removal technical
assistance team (TAT) contractor, Ecology and Environment, Inc. Additionally, a series
of structural studies were conducted at the site by the Department of Labor and
Industry during the period of 6/12/87 to 8/89. The acid reclaim area was considered to
have significant structural problems at that time. Avtex was subsequently ordered to
perform corrective action at the plant, including the acid reclaim area. Avtex had begun
repairs in the acid reclaim area, however, repairs were not completed due to the closing
of the plant
EPA also believes that the acid reclaim area is a source of ground water contamination.
In order to assess subsurface soil and ground water contamination, the building needs to
be removed. The work plan submitted by Avtex Fibers, which in part of the
Administrative Record, in response to the October 31, 1989, Administrative Order (AO)
acknowledges that acid spills be may have percolated down to ground water.
f. The decision to clean the PCB-laden soil to ten parts per million (ppm).
EPA Response The decision to cleanup to 10 ppm was based upon the application of
current EPA guidance which is documented in the Record of Decision (ROD). The
levels of 10-25 ppm are risk based levels which the Superfund program has set as
protective for industrial areas. A detailed explanation of the rationale for the 10 ppm
level is provided in the response to comment AJ.lu, and Cl.
g. The computation of the Estimated Costs for EPA's Preferred Alternative.
EPA Response EPA's cost estimate was initially developed by the removal TAT
contractor and revised by the OSC The OSC cost estimate was modified by the
Remedial Project Manager to provide for contingencies. The manner in which EPA's
current cost estimate was prepared is to ensure that the appropriate funding would be
available to complete the site stabilization measures. In this regard the estimated costs
provided are believed to be a conservative upper limit A large contingency is included
for each element of the alternative in the event that any unforeseen circumstances arise.
Moreover, the pricing figures for the transportation and treatment/disposal costs for
drummed wastes may appear high due to the unknown chemical characteristics and
volumes of waste streams. EPA's current cost estimate will be refined as additional
information is obtained. The most appropriate, cost-effective treatment/disposal
processes wffl be selected for the drummed wastes once sampling and analysis activities
are performed on the waste streams.
h. The extent to which the PCB contaminated soils present a risk to the environment due
to their alleged potential to migrate into the storm water conveyance system.
EPA Response: EPA believes that a risk to the environment through the migration of
PCB contaminated soils into the sewer system does exist. EPA recognized that the
proposed plan stated that PCBs could migrate to the sewer system, but inaccurately
specified the particular portion of the system that would be affected. The ROD
accurately reflects the correct portion of the sewer system involved and where the suifate
-------
basin which receives the discharge. As detailed in the ROD. the PCB contaminated
soils hew the ability to migrate into the sewer system. Levels in PCBs in soil range
from 03 ppm to 3,365 ppm. Contaminated soils are in the direct pathway of Manhole I
which is adjacent to the polypropylene process sewer. The OSC has determined that the
potential for continuing releases to the process sewer exists. The process sewer
discharges to sulfate basin 4. An assessment of sulfate basin 4 conducted identified the
erosion at the toe of the basin's berm by a small stream. The assessment also noted
that the combination of an increased pond level in the basin during a heavy rainfall
event and a rain-swollen stream eroding the toe of the berm could lead to failure of the
basin's containment and release of the its contents to the Shenandoah River.
B. Comments Pertaining to Action for the Drammed Waste
1. A comment was received that a portion of the drums which are targeted in the remedial
action are uncontaminated, resalable items which are of value to the estate.
EPA Response: EPA's knowledge as to what the drums contain is based on outer drum
labeling. EPA has done no sampling of these drums to date. Avtex had contracted with
Chem Waste Management to perform drum sampling and analysis. EPA contacted
Chem Waste Management during removal activities to obtain a copy of the analysis
record, however, Chem Waste Management would not release this information.
According to Chem Waste Management payment was never received for the activity,
therefore results were never provided to Avtex The remedial action will require
sampling of all drums. The ROD has been clarified to indicate that all nonhazardous
drums will be left onsite and available for liquidation by the corporate Trustee upon
EPA's approval
C. Comments Pertaining to PCB Contaminated Soils
1. The commentor stated that the choice of 10 parts per million (ppm) cleanup levels in
inconsistent with US EPA guidance.
EPA Response: EPA believes that the 10 ppm soil cleanup level is consistent with the
EPA "Guidance for Remedial Actions for Superfund Sites with PCB Contamination."
The aforementioned guidance sets forth recommended soil action cleanup levels which
range between 10 and 25 ppm for industrial areas. Future land use is a leading
consideration in determining cleanup levels. EPA believes the site to be prime industrial
area which is confirmed by the numerous inquiries made to the EPA regarding possible
future uses of the facility. Environmental considerations were also taken into account in
the decision to cleanup to 10 ppm is the environmental concern. The OSC has
determined that the PCBs contaminated soils near the loading dock have the potential
to migrate into the nearby potypropotyene process sewer which discharges into sulfate
basin 4 as further discussed in response A.10.h. above.
8
-------
2. A commentor noted that there appears to be no appropriate precedent for the 10 ppra
cleanup level based upon a search of RODs related to PCB-contaminated soil
EPA Response: EPA's decision was based on the most current, August 1990,
PCB guidance as previously stated and existing site conditions as discussed in the
response to comment C.I.
3. The commentor provided a great deal of toxicological data indicating that the need to
re -evaluate the mechanism of PCB carcinogenesis in order to establish safe cleanup
goals.
EPA Response: EPA appreciates the information provided by the commentor, however,
the "Guidance on Remedial Actions for Superfund Sites with PCB Contamination"
provide risk based soil action cleanup levels which are based on current EPA risk
assessment guidance.
4. A comment was received which indicated that 10 ppm PCB cleanup level was
inconsistent with the PCB Cleanup Policy which recommends 25 ppm to 50 ppm cleanup
levels.
EPA Response: EPA disagrees with this comment. The difference between the PCB
Spill Cleanup Policy and Superfund cleanup levels are due to the use of Superfund
standard exposure assumptions and a revised cancer potency factor for PCBs based on
recent policy. The August 1990 Superfund PCB guidance specifically states that the soil
levels are consistent with the PCB Spill Geanup Policy.
5. Two comments were received supporting a cleanup level of 25 ppm.
EPA Response: EPA maintains that the 10 ppm cleanup level is justified as the
remedial cleanup goal for the rationale set forth in response to comment A.10.h. and
6. The commentor noted that the Proposed Plan did not appear to consider onsite
treatment such as thermal treatment, bio-degradation, vitrification, incineration,
solidification and waste stabilization for PCB contaminated soils.
EPA Response: EPA agrees that onsite treatment was not considered for the PCB-
contaminated soils. The PCB-contaminated soils present threats to both human health
and the environment which is explained in response to comment A.10.h. above. EPA
believes that the risks associated with these PCB contaminated soils require an
accelerated action. Treatment techniques as do not facilitate accelerated responses due
to the time it takes to complete treatabiliry studies, therefore, treatment of soils was not
considered a viable alternative to evaluate. Moreover, offsite disposal is relatively less
costly.
-------
7. The commentor questioned the clarity of the following statement "a more inclusive
development of alternatives was not undertaken because of the immediate need to
proceed with site stabilization activities" and its relevance to the ultimate remediation of
PCB contaminated soil
EPA Response: EPA did not perform a more detailed analysis of alternatives due to the
risks to human health and the environment which exist and the amount of time it would
take to perform an RI/FS as described in the response to comment A.3. The
environmental risks presented by the migration potential and concentrations of PCB
contaminated soil is described in the response to comment A.10.Q.
8. The commentor indicated that proper stabilization of contaminated soils through storm
water management might be effective in preventing the migration of PCB contaminated
soils,
EPA Response EPA believes that effective storm water management would require a
detailed engineering study. In light of the risk and time factor discussed previously, EPA
does not believe this would provide a respond to site conditions in a timely manner.
9. The commentor believed that EPA should perform an evaluation of interim measures for
the cleanup of PCB contamination that includes capping with clean soils.
EPA Response: PCB levels in the contaminated soils range up to 3365 ppm. Due to
these high levels a portion of those soils are considered a principal threat by definition
in addition to the associated environmental risks e«pi«ingd in response to comment
A.10.h. Considering both of these factors, EPA believes an accelerated action is
necessary to significantly reduce the risks. Because treatment does not facilitate an
accelerated action, EPA has decided that containment of the PCB-contaminated soil to
be the appropriate option. EPA considers offsite disposal of the PCB-contaminated soils
to be more protective than capping with clean soils due to the existence of principal
threat (> 500 ppm) PCB soils.
D. Coauttits Pertaining to Sit* Scorify, Maintenance, sad Healtk and Safety Measures
1. The commentor indicated that the Proposed Plan incorrectly states that the Trustee has
agreed to continue providing site security, maintenance, health and safety for as long as
funds
EPA Raupwii At the time the Proposed Plan was published, EPA believed the
Trustee to be providing the aforementioned activities at the verbal direction of the On-
Scene Coordinator (OSC). Subsequent to the plan being published, EPA issued the
Trustee an Administrative Order (AO) to provide these activities. Subject to the
availability of money, the Trustee and EPA have reached an agreement regarding site
security, maintenance, control and health and safety measures.
10
-------
E. CoauMiJts PertaJninf to Costs
1. The commentor questioned what the actual cost outJay for Alternative 2 would be acting
that the present-worth capital cost is $ 8,708,400 and any other types of operation and
maintenance costs involved other than no annual
EPA Response: The actual cost outlay is estimated at S 8,708,400. The proposed plan
incorrectly specified the total cost estimate to be present-worth capital costs. EPA has
amended all references to the total cost estimate to be capital costs. There are no
annual operation and maintenance costs associated with the preferred alternative.
2. The commentor noted that the costs for dismantling and demolition for the acid reclaim
facility appears to be excessive.
EPA Response; The manner in which EPA's current cost estimate was prepared is to
ensure that appropriate funding would be available to complete the site stabilization
measures. In this regard, the cost estimate is believed to be a conservative upper limit.
Specifically related to the acid reclaim facility, an allowance was made in the cost
estimate for the decontamination of the building structure and equipment, if found to be
necessary. Also built into the cost of the activity is a large contingency for any.
additional unforeseen circumstances that may occur.
F. Comments Pertaining to Applicable or Relevant and Appropriate Requirements
(ARARs)
1. The commentor recounted that actions proposed under Alternative 2 of the Proposed
Plan will require compliance with other environmental laws that are determined to be
applicable or relevant and appropriate requirements without specifying exactly what the
compliance might be and the associated costs and risks.
EPA Response: The Proposed Plan identified applicable or relevant and appropriate
requirements (ARARs) in general terms. A detailed list of ARARs for the remedial
action are specified in Table 1 (pages 16 and 17) of the ROD. The following response
is offered to the extent EPA understands the remainder of the comment Incorporated
in the cost of the alternative 2 would be compliance with identified ARARs. Costs and
risks are not individualized for each ARAR.
2. A comment was received that stated that the Proposed Plan identified one ARAR
applicable to the proposed PCS cleanup activity which does not justify the 10 part per
million (ppn) cleanup criteria.
EPA Response: The ROD identifies a full list of Applicable and Relevant or
Appropriate Requirements (ARARs) for the action. The cleanup level of PCBs is based
primarily on "Guidance on Remedial Actions for Superfund Sites with PCB
Contamination." TSCA requirements are applicable to the disposal of the PCB
contaminated soils as was stated in the Proposed Plan. Specifically, 40 CFR Section
761.60 (a)(e) indicates that any non-liquid PCBs at concentrations of 50 ppm or greater
11
-------
in the form of contaminated soil, rags, or other debris shall be disposed of in a TSCA-
approvcd incinerator or in a TSCA-approved chemical waste landfill Disposal in an
approved chemical waste landfill was chosen for this action. The rationale for the
disposal selection and cleanup criteria are discussed separately in this response to
comments.
12
-------
APPENDIX A
PROPOSED PLAN
AVTEX FIBERS SUPERFUND SITE
OPERABLE UNIT TWO
AUGUST 1990
-------
U.S. Environmental Protection Agency - Region III
Superfund Program
PROPOSED PLAN
Avtex Fibers Site
Front Royal, Virginia
August 1990
m (If A) fr ta
Si*. FnmOtt
roso,
In
ly EPA*
a part of th*
for Ms
tedW
EfA
-------
This document si issued by the EPA, the lead agency for sit* Superfund activities. The EPA, in
consultation wttft the Virginia Deportment of Was* Management (VA DWM), will select a fin*
remedy only oft* the public comment period hat ended and the comments submitted during this time
have been reviewed and considered.
The EPA it issuing this Propoted Plan at part of 1st pubUe participation TwrMfrfet under Section
117 (a) of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
This plan summarizes information that can be found in rise-related documents that an available to
the public at tke local information repository established op
Samuels Public Library
539 VuTa Avenue
Front Kayak Virginia 22639
(793) 635-3153
The EPA and VA DWM invite the public to renew the materials available and to comment on the
Proposed Plan during the public comment period which bfgint on August 14, 1999 and ends on
14,1990.
The EPA, in mmlttaitm with the. VA DWM, may mtodify the preferred alternative or select another
response action pretnttd in this plan, based on new information or pubUe comments. Therefore, the
public it encouraged to review and comment on the irfrrmiirtw identified here. The final remedy for
the drummed masses, PC* (unrnmimmed sous, add reclaim euiUmg and site control wiH be selected
in a Record of Decision, which shall also be available far review at the local repository.
SITE BACKGROUND
Kendrict Lane, in Front Royal, Virginia. Situated along the east bank of the Shenandoah River, the
facility occupies approximately 449 acres, 69 of which are under roof, and includes 23 unUned waste
disposal structures. In addition to the river, the sat is surrounded to the south, east and northwest by
residential areas. Appmiimimeb 1399 people live within one mile of the SUB.
Operations at the sue began m 1949, when American Viscose fint opened a rayon production plant.
Subsequently, the tarn ma sold m FMC Corporation in 1963, and to Avea Fibers, Inc^ in 1976.
Rayon fibers hem bam m constant production at the site since iss opening. Polyester was
manufactured 9jam 1979-1977 and polypropylene production occurred from 1985 until the plant's
dose on November 11,1999.
Rayon fiber is manufactured from wood pulp by a series of chemical reactions and physical
operations. This process produced a number of wastes that were treated in an on-site wastewater
treatment system and/or land disposed. The two major byproducts gnemted through the rayon
process were sodium ceuukme xanthate-based viscou and zinc kycfavdde dudg* The viscose waste
was land disposed In eleven unUned basins until 1983 when wastewater treatment of this waste stream
was initiated. Waste sludge containing one was disposed of in six unUned suffate basins which cover
-------
approximately 95 egret and dram downhill into an unlined surfact impoundment known at tht
'emergency lagotn'. Additionally, then an Jour luuintdjfy ash basins o*-titt and one fly agh stock
pile which wot met far tht disposal of fly ash and boiler house solids generated from operations at
the facility.
In 1992, carbon dlsulfidt, a constituent of tht viseoet waste, wag identified In ground water samples
from midential wtus (Mvermont Acret) located acroa the Shtnandoah B*r from tht Axes facility.
As a result of this discovery, tht Virginia State Water Control Board rtoutsttd that Avtat perform a
ground water investigation. In February 1993, Avta retained Geraghry tt MuTer, Inc. to perform the
At a mult ofm* Initial fleU tnrnOiation, A*u Implemtntmi Interim rmtrfW moatum in 1993 and
1994 to addreu At idenjflei contamination Tkt interim remedial mmurm indudat tht purchau
of 23 Kftrmont Aen propertta by Avter wkott domettk »& w& affKttd by tkt pound vata-
contamination. Avtex alto initiated a ground water pump and tomumtnt puyum Jbr purpota of
contaminant rooofery and
In October 1994, tht Alex FUtn tint wag proposed for indution m the Notional Priorities U*
(NPL), a list ofhasardou was* sties acroa tht aunty in need of remedial evaluation and
In August 1994, Avta Fibers and. EPA entered inn am Administrative Content Order to conduct a
Remedial Investigation and Feasibility Study (XI/FS). Tht pmrpamt of this study wot to investigate tnt
Tkg Cement Order war tmmdtd m January 1999 to mdudt FMC Carporatkm at a tmfauhnt. Tht
U/FS npor* wtr* rd*utd to tk* fttMIc
of 2.0 pang per mOOon (ppm) wen detKtet in Jltn tiama coOtcttd by tkt SWCB from mt
Shtnandoak Kber. Tnt SWCB cojlrmod th* pmtna of PC8t m rber bank toil and stdlmtnt
sampta and on-sitt soils.
In September of 1999, tnt Commonweal* of Virginia rofieOtd an foliation of tnt JojcNtj by tht
EPA Superjund XmwoJ Program. Upon rmnr, tht EPA On-Sctnt Coordinator (OSC) determined
that an immintnt tnnat to tnt ntaUt of tnt worker* at t^ Avttx facility txisttd from contact with
PCB contaminated toils. In addition, an immintnt thrtat to tht enrironmtnt edaedfrom tht
-------
diseharft (^ PCM contaminated vastgwater from tnt frwer system at tnt plant to tht Shtnandoah
Kver. TV OSC initiated mama* ectMtits which included: irrrijftf tf fftr inn initial* fCT
cfeonup OK* on noluation of drums, bulk storag* Montr omf proem Una. ON Octtfar 31,1999,
EPA issued an Adrninistrattvt (unilateral) Order which requires" Avis* tot perform a PCS
•ination study and removal; perform wasst idtntiflcation; ttgngation and disposal of hazardous
substanca contained in drums and thntmim Ou potnttial for rdtast of kaxardotu
asfoaattd witk
On-jotar enforctma* action by At Commo**m& qf Wrfbu* piiniia* to Oa* lav rnuW i*
rrvocmtiom of On AMut Fttan dtoduajr perm* on Noitmbm' 19,1999. FaUowtaf tUt action, A«ex
aatod operation at thtfadUty. On ffotunbor llt 1999, EPA Kt^om m ntpandod under CEXCLA,
dodaring an umifUKji tituoOon duttotht uneontnuod aatun oftnt to* rmuUngJrom tnt plant
shutdown. Tnt EPA removal action war octtvoXd to ttabtUa Alton of on* enemies!* lefi
unattended onti*. TTUi included carbon dltuffidt, tuffiuie add, and tysttm add kft at tnt fodlity.
An intepal part of EPA* si* ttoMBxation aetMOet Indiided inatnldn^JreAoard In tnt
appnxunatefynOaermofinduttiialwojttlatoont. fflgjt unattended, tnem lagoom pnnnttd a
serioui tnrmt ofreleag to tnt Shatandoah Rber with subttautnt impact* to drinting water Intaim
On February 2,199*,** toejou. isaud « Adminterati* (unOaanl) Order m FMC Corporation
ro^uirinttnim.tomaiMoinlreAoarumth^ On
April 30,1999, FMC too* over Jet operation oftnt wotemoter tmrtmmt pJent Mtiatod and operated
by EPA to maiituunjrmooard. Troeantnt oftnt aitfe* basin weterwoten vB eontinut until a final
remedial auernativt it dtfoueod for tnt wvtffwMr lotoont* JNO interim ettasurt 0 nttdad to
romplfrion ofijortncamixf \tmmiiiil InmOfaian andJoexMBtj study (X1IFS).
On February 7,199$, EPA met mjermtd that Areet P9en Inc. ami Area Fteen-Froet loyal,
(couoabeb 'Aveef) homjttoijer bankruptcy under Chapter 11 oftnt bankruptcy law. Tktjtdtral
bankruptcy judejt hot appobeod a tnutet to reprettnt Avttx in at mautn* 1\t tnuttt it cumndy
providing tilt mainttnanet, health ami tajety jar any Area tmybym or visitor, and maintaining sitt
security at ordered by tnt OSC. Tkt tnaem he* agrttd to continnt mem ottMtiaJbr at long at hi*
fund* remain,
SCOPE AND fOLt Of ACTIOff
TH*
associated wa* tnt tee. Tkt eroobmu at tnt Avta Fiber* SUt en complex. AM a mutt, EPA it
addreaing portion oftnt tee iimtamimittoti using it* emergtncy mpont authorities whereas other
portion* Witt be addreoad at pert oftnt rtmmtial program.
This action win bt tnt seeond operetta unit (OU 2) of a long^erm remediation of off tnt threats
poud to public health and tnt tnvinnmtnt by tnt Avast Fiber* tit*. Operablt units art dlscreu
actions that comprist an Incremental step toward comprtlie*siveb alarming si* problems. As thg
Avttx Fiber* iit» tvaluation antinuts and other remedial actions art deemed nteeaary additional
operablt units wul bt dtfintd tofteuttau tnt deanup.
-------
Pertinent information from removal activities and the associated problems and risks an specified
below:
• 2,879 drums of both hazardous and non-hazardous substances are present on-site. Many
drums wen in poor condition and past releases .were evident. AM part of EPA* removal action
these drums have been secured and staged. Identification, transportation and disposal of these
drummed wastes Is now required;
• approxtmatefy 5000 cubu: yards cf PCS contaminated Previous actions
by Avtex under the Region's October 31,1989 order wen not completed out to plant damn.
Tht PCS contaminated soils present a risk of release to tke environment dut to their potential
to migrate into the storm water conveyance
tke add reclamation facility at the inanufactur^ pto Poor
maintenance and weathering have caused significant corrosion of tht building structun and
foundation. A structural engineer has dodand the facility uOvnofy unstablt. Continued
degradation through normal weathering could present a safety haurd from coBapse. This
could atm& nearbv ancess *"Jm
-------
2: COMPUTION OP SITE STABILIZATION ACTIVITIES
Under this aatmativt, tht appropriatt actions would bt taktn at tnt Avta Fibtn tits to
pnvtnt: tnt tknot of rtlaaut of luaavdaui tubstaneta from tnt drums, tilt migration if
hazardous nibetanca from eontaminattd soilt, rultastt of hazardous *"*fffirpg which would
occur at rault of budding degradation. Alia Indudad at part of this atitnatkt It tint
sacuruy, mainttnanet, control and a. titt specific ktaltn and sofa plan in tnt tvtnt that tnt
tnuttt eon no longar providt that actMtitt.
Undar this aamrnativt, tntJbOowing action would occur:
• Idtntiflauio*, transportation and dbpaul aftkt 2,879 dnunt eumntfy 0*4*. Upon
identification of drum ojnnintt, liquid wotta wtt bt tnatut at an appropriau off-out
tnatmtnt facility. Drum* may bt daeontaminatad, enukod and dtipomd in a
nazardoui was* landJUL
Excavation, transportation and disposal oftht atimattd 5000 cubic yards of Pd
with Kit m 000 of 10 pur* par mOkm wit bt acavottd Jar mtpataL
torn tba building -^
and aatipmant wtiUn tlut buSdint wtt bt aacontaminantd, if
manaatmtnt ftft^ifn Dacantaminattd utabtt tauipmtnt from witnin tnt building
may bt sold by tnt tnua*. Otnarfac&tj uompuntntt may bt told at xrap, roeydtd
or lajt oRptm}* Daeontaminatad building rubbut and dob/It will bt Mi *
and ktaltk
Ac&ms propotmi tutdtr tnig otmtmtiii wtt nouin compiianct wit* other mnronmtntal lawt that an
damrminadtootaautteabbjornunantandapprapriant i^fiiniiiiti (AMAMt). SpoefflcoBy, tnt
ditpoul of PCB \\wM\\m(mmm\ «dr wm raauirt compiianct with tnt Tude Subaanoa Control Act
(TSCA). Daatnding an tnt oannmtg of drummad wastat tnt Itatourct Contarfotton and Hacavart Act
(KCXA) may bt an AXAM. JOU may obo bt an AJtAA Jar tnt rubbbt and dtbrli loft o*-a* at a
retua oftkt add rocUm bulUbuj dlanantting and dtmolUen,
This phatt of ma A*tt Mart tint ratpontt action it an optnblt unit In tnt ovaraH tint nmtdiativn
to control immamatt hazards at Out tUt In a Omarj inannar at watt at eontr^utt m tnt officiant
ptrformanet of Out long turn rtmtritnl action. Tkt talnwnm prattnt-wortk capital cott of thit
atitrmu** it $ 8,708,400. Tntn an no annual optraOon and mainttnanet com aaodattd with this
alttmativt. Thit alttmattm could bt compltttfy impltmtnttd within ont (1) yamr.
No additional otonurtm wart contidtrod at thit timt. A mart comprtntntha rrrtgw wot not
performed dut tnt immadlatt nttd to procatd with si* itaNKiarian aaMOtt.
-------
EVALUATION Of ALTERNATIVES
EPA* pr&md abtmatb* for addnahg contamination at At Artec Fibers si* it Alttrnati* 2-
ComffaOom of Si* StaMftattn* Activities. Botk aagnatim won rvaluattd using tn* foOowuif aim
Tkt pnftma allentativt would tttmina* tht Anat of nuxm of hazardous
i* drums, tifniflcantfy nduet At potential migration of PCBi into tht mHronmtnt,
tht pommtial of dint* contact with tkt dttmicoJ and phyOeal hazardous that aill
Otrougm sin soairuy, control, ox\ and dfnjflcantfy nana a* laje* hazard and tHnat of
* r*mm 4* » srtcari ti*abOty
-------
In summary* a* frafirrot* abXrnati* it botbmd to prondt On bat baton* oftrodtojft
aaunattm nabMttd wiA mpoa to At criteria ttoluatod abort. Baud m At information ataOabut
at Out tima, SPA a* At Commomvoalt* of Virginia Mb* At pnftrrot oatntaum would pntua
human koolA and At ammo***, would comply wiA AJUXs and bt coet-dmstiM. In addition,
permantnt tolutiont, aatnatt troattntnt todvtotoejti or mount neomy ttennologltt will bt
to tht nvrriiHifp f \ttnt pnciicoblt*
EPA nUm am putUe Input to aa*n Out th* rtmtdj altemd far men S*p*fr*d d* mttat 0* imd
and eomnu of OH local eommiuiuy. Tktrtjbn, a fmoOe eommtmt fartod wiBkt ktU from Aitgiut
14,199$ * Sifttmoir 14,199$ to aOow tkt futOe to nvit* tUt froaomd Plam amd to amount or
^mmm^^^m *^*^*^^^mm ft* 99A m^^^*^*lt^^ *t*~ m/.m^ ^^4 *tm^ ^^^^^^^^^J ^fa^^^*^+t^^ AW A&^B^B
apm OMCW JP &fA rffrOMMf OTv ptBM •Mv Om ff^ftffWm 0flVMfl0Pfc Aim CDflUI
during tt* pttWc ammo* ptriod win bt eoivuMvod and addnaod by At SPA. Tkt
Pufovmt Atormab* itpntimuiaiy and may ckaxtt upom nvitw of comma** nbmtttoi That
and At Afjmcy't /VBMMV witt bt aocuintattd In a, Mtffonftftnasi ^utnmutf that witt
rttftkiltKrt.
panoo, m aonfnma mt mrvfmmf mtcow fwnatntf ant atntn an opponmnuj mt oosom
In tkt tltftikm •iilfni m>nm itotutffaf rtW rtmmttot ffiti^tfg tfMX witt occur tnAttr
It oj important to noni Aot triffcmjlt SPA not anpottd M prfflmd auamatbttt noflnal
Library.
EPA wiUhoUt pmbtie in t*i\* at 7*i JM* AmamM 22,199$, at At Front May* Youtk Ctnttr, 201
East 8A Strott, Front Moyai, Vtrffamt to dtaou At rtnwdU atotnattfoi and At pnpottd rtnwdy for
PCM eoammmawltd *&, add roeUm fodSty and tint mxritj,
fa^ w^^^^^^^^m^^M ^^^^^^^__ .^J^^ +^J!fM L^ ^^^^^^J^^J ^^Jta* ^^
OM, mnrtaoo opyant auo win ot pronaaa wun an
opporautoy to t
nt public nwaAmj wm lot* pltet during At 304ay public eomnmit ptriod on At Propoomi Plan.
Tktpubue i m ptriod bett* onAmgua 14,1990andtnanon Stptmbtr 14,1990. Ottoman
enoauratat to mum it* titan* aoatmmt* and submit written commons to ont >
Mr. Jtomfr Guy Croa (3HW34)
VS.
941
PnuadttpUa, PA 19107
-------
(3EAJ1)
Kdatiom Coordinator
UJ.
841
PA 19197
(215) 597-419$
miut Ift nAMjfhrf to 0w of tttt flfaw^ktotf ftotlt flW pcttntoflttd on OF btfon
14,199$.
-------
APPENDIX B
PUBLIC MEETING ATTENDANCE SHEET
AUGUST 22, 1990
-------
- a -v -
T j
sire—_
COMMUNITY QCLATiOHSCOORDINATOR
OAT!
US ENVIRONMENTAL PROTECTION AGENCY
SIGN IN so THAT WE CAN AOO YOUR NAHE TO OUR M.AILINO LIST
A80UT THIS SlTl If YOU 00 NOT WISH TO RiCCIVC INFORHATION f«OM US.
PLEASE SIMPLY INDICATE YOUR ATTCNOANCC WITH YOUR INITIALS .
PLCASC PRINT
------- |