United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/133
September 1991
&EPA Superf und
Record of Decision:
Dixie Caverns County
Landfill, VA
-------
"so272.101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R03-91/133
I~
3. Reclpient'8 Aca88lon No.
4. TI1Ie and Subtitle
SUPERFUND RECORD OF DECISION
Dixie Caverns County Landfill, VA
First Remedial Action
7. Author(8)
s. Report Date
09/30/91
6.
8. PerformIng 0rg8nIaII0n AepI. No.
I. FWformlng OrgeInlz81lon Heme and Addre..
10. ProjectfT88IIIWork UnI1 No.
11. Contrect(C) or Gnnt(G) No.
(C)
(G)
1~ SponeorIng Organlz81lon Heme and Addre88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & l'8Itoci Covered
Agency
800/000
14.
15. Supplementary NoIII8
16. AbeU'8ct (Umlt: 200 worcl8)
The 39-acre Dixie Caverns County Landfill is a former municipal landfill in Roanoke
County, Virginia. The surrounding land is rural, with the nearest residence located
1/2 mile from the site. The site is situated on a steep ridge between two valleys
surrounded by heavily forested mountains traversed by small streams. Two unnamed
headwater streams receive surface runoff from the site, and discharge to the the
Roanoke River, which is located 2 miles south/southeast. The landfill is currently
owned and was operated by the county of Roanoke from 1965 until its closure in 1976.
During operation, Dixie Caverns Landfill accepted an estimated 440,000 cubic yards of
municipal and industrial wastes including refuse, scrap metal, flyash, and sludge.
In 1983, EPA investigations identified several disposal areas including a discarded
drum area, a sludge pit, and a large flyash pile, which contained elevated levels of
metals. In 1987, EPA conducted a removal action that addressed the drum and sludge
areas; however, removal of the flyash was suspended on EPA's recommendation. In
1987, the County developed a removal work plan proposing a proprietary stabilization
process to treat the flyash, and the plan was approved in 1988 with remediation
levels set by EPA. Questions concerning the regulatory status of the waste caused
(See Attached Page)
17. Docwnent AnaJyaIa L De8cripIors
Record of Decision - Dixie Caverns County Landfill, VA
First Remedial Action
Contaminated Medium: debris
Key Contaminants: metals (lead, cadmium, zinc)
b. 1den1ifier8l0pen-EndecI Tenne
c. COSA T1 FleldlGrIq)
-18. Availabiity Statement
11. Security ca... (1hia Report)
None
20. Security CI888 (1hia Page)
Nnn~
- -.. -.
21. No. of P8ge8
30
I
~ PrIce
(See ANSI-Z39.18)
See InstnJctjOM on Re-
(4-77)
(Formetty N11S-35)
Deperunent of Commerce
-------
EPA/ROD/R03-91/133
Dixie Caverns County Landfill, VA
First Remedial Action
Abstract (Continued)
delay in implementing the work plan. At that time, EPA recommended suspension of further
removal activity pertaining to the flyash because of uncertainty as to whether or not the
County's plan would meet Federal and State requirements. This Record of Decision (ROD)
addresses the flyash at the site as Operable Unit 1 (OU1). Future RODs will address
other remedial actions based on RI/FS investigations. The primary contaminants of
concern affecting the debris are metals including lead, cadmium, and zinc.
The selected remedial action for this interim remedy includes excavating and transporting
approximately 9,000 cubic yards of flyash offsite to an EPA approved High Temperature
Metals Recovery Technology facility for treatment and subsequent reuse; and implementing
State dust and erosion and sediment controls during flyash excavation. The present worth
cost for the remedial action is $3,927,158. There are no O&M costs associated with this
remedial action.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific flyash clean-up goals are based on
onsite disposal criteria developed by EPA during the recent KOG1 LDR ruling, and include
lead 0.095 mg/kg and cadmium 0.032 mg/kg.
-------
Site Name and Location
Dixie Caverns Landfill Superfund Site
Roanoke County, Virginia
Statement of Basis and Purpose
This decision document presents the selected interim
remedial action for the flyash pile operable unit at the Dixie
Caverns Landfill Superfund Site (Site), Roanoke County, Virginia,
which was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent
practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 C.F.R. Part 300. This decision is
based on the Administrative Record for the Site. This decision
document explains the factual and legal basis for selecting the
interim remedy for this Site.
The Commonwealth of Virginia Department of Waste Management
concurs with the selected interim 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 (ROD), may present an
imminent and substantial endangerment to the public health,
welfare, or the environment.
Description of the Selected Remedy
This is the first planned response action for the Site.
This interim remedy addresses only the flyash pile located on the
Site. The flyash represents a principal threat to human health
requiring treatment. Subsequent response actions may take place
to address the rest of the Site.
The selected remedy includes the following major components:
Excavation of approximately 9000 yd3 of flyash material
at the Site;
Transportation of approximately 9000 yd3 flyash off-
-------
site for treatment using the High Temperature Metals
Recovery (HTMR) process;
Treatment of the flyash at an EPA approved HTMR
facility to achieve the treatment standards for K061
waste specified in 56 Fed. Reg. 41164-41178; and
Implementation of dust controls and erosion and
sedimentation controls during flyash excavation.
Declaration
This interim action is protective of human health and the
environment, complies with Federal and State applicable or
relevant and appropriate requirements directly associated with
this action, and is cost effective. This action utilizes
permanent solutions and resource recovery technologies to'the
maximum extent practicable, given the limited scope of the
action. Because this action does not constitute the final remedy
for the Site, the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, of volume as a
principal element will be addressed at the time of the final
response action. Subsequent actions are planned to address fully
the principal threats posed by this Site.
Edwin B. Erickson
Regional Administrator
Region III
SEP 30 1991
-------
DBCISIOR SOXMARY .
I. SITB RaNB. L~TIOR. AND DBSCRIPTIOR
The Dixie Caverns Landfill Superfund Site (Site) is located
in Roanoke County, virginia along State Route 778 approximately
one mile west of Exit 39 on Interstate 81. The landfill is
currently owned and was operated by the County of Roanoke from
1965 ,until 1976. During its operation, the landfill received
unknown quantities of municipal refuse, scrap metal, flyash,
sludge, and other industrial wastes. When the landfill ceased
operation in July 1976, it contained an estimated 440,000 cubic
yards (yd3) of waste which covered approximately 39 acres. In
addition to the landfill, the Site contains three other disposal
areas: a discarded drum area, an organic sludge pit, and a flyash
pile. A map of the Site is depicted in Fiqure 1.
The topography in the region is characterized by long,
narrow, parallel valleys and mountain ridges. The mountains in
this section of the country are rugged and heavily forested, and
traversed by numerous small streams. The slope of the surface'
grade ranges from a minimum of 20 percent up to 40 percent in
undisturbed areas. Ridg. tops are typically 500 to 700 feet
above adjacent small stream valley floors. The Site lies on a
relatively steep ridge complex between two steep valleys, each of
which contains an intermittent stream. The elevation at the site
ranges from approximately 1400 feet above mean sea level at the
Site entrance to 1650 feet in the northwest corner.
The Site is in a rural area with the nearest residence
located approximately one-half mile southeast along Twine Hollow
Road. A total of approximately 235 residents live within a one-
mile radius of the Site and an e.timated 2,110 residents live
within three mile.. The Roanoke County region covers
approximately 240 square miles and contains two adjacent but
independent cities, Roanoke and Salem, and one township, Vinton.
The total population of the County, including its two cities, is
approximately 229,600.
The average yearly temperature for the area is approximately
56 deqree. farenheiqht, with a maximum in the 90's and a minimum
in 'the 20'8. The averaqe precipitation is 44 inches, fairly
evenly di8~ibuted throughout the year.
The major surface water body potentially affected by this
site is the Roanoke River, which is located approximately 2 miles
south/southeast of the Site. Two unnamed headwater streams
l'
-------
IN
i
SOLD WASTE DISPOSAL AREA
\
RGURE 1 - SITE MAP
DIXIE CAVERNS LANDFILL
SUPERFUND SITE
-------
receive surface runoff from the Site - one flows throuqh the
northern portion of the Site across the base of the flyash pilei
the other flows alonq Twine Hollow Road just beyond the southern
Site boundary. These streams discharge to the Roanoke River.
Shallow qroundwater in the Site region moves along bedding,
fracture, and solution channels from recharge areas to discharge
areas at springs and along stream valleys. Natural groundwater
.recharge is rapid because of the thin soil mantle on the ridges.
The depth to groundwater is usually qreater than 20 feet, but
less than 100 feet. Boring loqs taken from the valley containing
the drum disposal area and flyash pile indicate that the depth to
groundwater is found at 18.0 and 19.5 feet, respectively. In
general, the qroundwater flow in the area would be expected to be
south to southeast in the direction of the Roanoke River, but
contaminant plumes from the Site could also move along the
formation strikes, parallel to the mountain chains.
. II. SITB HISTORY AND BBPORCBKBNT ACTIVITIB8
Municipal and industrial wastes were first disposed of at .
the Dixie Caverns Landfill Site in 1965. In 1972 Roanoke County
was notified by the Commonwealth of Virginia that their operation
must be phased out by July 1, 1973, the deadline for
jurisdictions to obtain a solid waste disposal permit. After
several unsuccessful attempts to obtain a permit, the landfill
ceased operating in July 1976.
In June 1983, EPA completed a Preliminary Assessment of the
Site and identified several disposal areas including a large
flyash pile of undetermined constituents. A sample of this
flyash material was collected during an EPA Site Inspection
conducted in September 1983. Results of this analysis identified
elevated levels of numerous metals in the flyash including lead
(45,000 parts per million (~pm», cadmium (1,600 ppm), and zinc
(220,000 ppm). A8 a result of these initial investigations, EPA
proposed the Dixie Caverns Landfill Site for inclusion on the
National Priorities List on January 27, 1987.
Pursuant to section 104(e) of CERCLA (42 U.S.C. 59604(e»,
EPA requested information from the Roanoke Electric Steel
corporation (RES) concerning its use of the Dixie Caverns
Landfill. Through RES's response dated February 4, 1987, the
flyash at the site was determined to be electric arc furnace air
emission control dust generated at the RES facility in Roanoke,
VA.
In September 1987, the County of Roanoke signed a Consent
Aqreement and Order under Section 106(a) of CERCLA (42 U.S.C.
59601(a» with EPA to conduct a reaoval action at three disposal
areas at the Site - the discarded drua area, the sludge pit, and
the flyash.pile. The drums area and sludge pit removal
3
-------
activities have been completed, however the flyash removal was
suspended on EPA's recommendation. At the time Roanoke county
was negotiating with EPA to remove the flyash at the Site, RES
was developing a proprietary stabilization process to treat the
emission control dust being generated at its facility. Since
emission control dust is a listed hazardous waste (K061) under
the Resource Conservation and Recovery Act (RCRA) (40 C.F.R.
5261.32), RES planned to petition EPA to exclude waste from its
facility from being considered a listed hazardous waste (i.e.,
delisted) based on the use ot the stabilization process.
with RES's assistance, the County developed a removal Work
Plan in December 1987. The plan proposed using the RES
proprietary stabilization process to treat the flyash at the Site
prior to its disposal in an on-site clay-lined monofill. As part
of a preliminary treatability study, the flyash was analyzed to
determine its toxic characteristics using RCRA's Extraction
Procedure Toxicity (EP Tox) test. The results for lead and
cadmium were 22.70 mg/l and 28.20 mq/l, respectively, which
exceeded the regulatory levels for toxicity. These levels are
5.0 mg/l for lead and 1.0 mg/l for cadmium (40 CFR 5261.24). The
preliminary study also provided evidence that significant
reductions in the EP Tox lead and cadmium concentrations could be
achieved through the stabilization process. . When the removal
Work Plan was approved in April 1988, EPA required the County to
achieve treatment standards at the Site that were equivalent to
those being required ot RES in their delisting petition for
stabilized K061 waste at their Roanoke tacility. These levels
are presented in Section VII. ot the Record ot Decision (ROD) in
Table 3. .
. A delay in implementation of the approved flyash
stabilization plan occurred in 1988 a. the county negotiated with
RES over the US8 ot their proprietary process and their financial
contribution to work at the Site. 8ymid-1989, the county was
prepared to begin stabilizing the flyash. However, questions
concerning the regulatory status of the waste at the Site as well
as several requlatory changes impacted the flyash stabilization
plans.
Although the flyash was initially clas.itied as a RCRA
characteri.tic wa.te due to it. lead and cadmium toxicity, the
waste was later deterained to be ..i..ion control dust from the
RES electric arc furnace which i. a RCRA li.ted hazardous waste
(K061). The .tabilized K061 wa.te would remain a li.ted
hazardous wa.te at the Sit. unle.. the sub.tantive requirements
of the d8li.t1ng proc.s. were met. If thes. requirements could
not be m8t, the on-.it. landfill would have to be d8siqned as a
hazardous wast. landfill in accordance with RCRA Subtitle C and
the Virginia Hazardous Waste Management Regulation. (VRWMR). In
addition, the stabilized flyash would have to .eet the interim
treatment standards published on August 8, 1988 in £PA's First
4
-------
Third Land Disposal Restriction (LOR) Rule (53 Fed. Reg. 31162-
31164). If the delisting requirements could be met, the on-site
landfill would have to be desiqned as a solid waste landfill in
accordance with RCRA subtitle D and the Virginia Solid Waste
Management Regulations (VSWMR). Because EPA was not certain that
the County's planned flyash stabilization and on-site disposal
activities would be consistent with these Federal and
Commonwealth requirements, EPA recommended that the County
suspend further removal activity pertaining to the flyash at the
Site.
EPA sent CERCLA 5122(e) special notice letters on January 2,
1988 and April 26, 1989 to identified Potentially Responsible'
Parties (PRPs) to offer them the opportunity to perform a
Remedial Investigation and Feasibility Study (RI/FS) at the Site.
When the PRPs declined to perform the work in July 1989, EPA
initiated an RIIFS to determine the full extent and impact of
contamination at the Site. On October 4, 1989, EPA finalized
inclusion of the Dixie Caverns Landfill Site on the National
Priorities List. The ongoing RIIFS will be the basis for
determining the final Site remedy.
III.
HIGHLIGHTS O. COMKUH%TY PARTICIPATIOR
A Community Relations Plan for the Dixie Caverns Landfill
site was developed in May 1990. This document lists contacts and
interested parties throughout the Federal and Commonwealth
governments and the local community. It also establishes
communication pathways to ensure timely dissemination of
pertinent information. EPA held a public meeting on January 23,
1991 to discuss the current status of RIIFS activities at the
site.
The Proposed Plan documenting EPA's Preferred Alternative
for remediating the flyash pile w~s released to the public on
August 15, 1991. The Proposed Plan and supporting documents were
made available to the public in the Administrative Record for the
site maintained at both the EPA Region III Docket Room in.
Philadelphia and at the Glenvar Branch Library in Sale.,
Virginia. The notice of availability of these documents and the
beginning of the public comment period on the Proposed Plan was
published in the Roanoke Times and World-News on August 15, 1991.
The 30-day public comment period extended fro. August 15, 1991
through September 16, 1991. In addition, a public .eeting was
held on August 22, 1991 at the Glenvar Branch Library to present
and discuss the Preferred Alternative as described .in the
Proposed Plan. Re.POnse to the significant comments which were
received by EPA prior to the end of this public comment period,
including those expressed verbally at the public .eeting, is
included in the Responsiveness Summary which is part of this ROD.
5
-------
IV. SCOPB AND ROLB OP THB PLYASH OPBRABLB UNIT
The interim remedj selected in this ROD addresses the
approximately 9,000 yd of flyash present at the Site. This
flyash is being addressed separately from the rest of the Site as
an operable unit (OU). Other remedial actions necessary at the
site will be evaluated after completion of the RIfFS and
documented in a subsequent OU ROD. The flyash beinq addressed in
this OU presents a principal threat due to its high metals
content. EPA is therefore proposinq this interim action to
remove the flyash from the Site and treat it at a Hiqh
Temperature Metals Recovery (HTMR) facility. Although the RIfFS
for the Site is not completed, sufficient information is
available to determine the appropriate flyash remedy. To the
extent possible, this interim action will be consistent with any
planned future response actions at the site.
The goal of this interim action is to remove and treat the
flyash to eliminate the principal threat posed by the metals and
to reduce the health risk from possible ingestion of the flyash
by children to acceptable levels. This interim action will also
significantly reduce any further off-site migration of
contamination from the flyash pile.
V. SUMMARY OP SITB CHARACTBRISTICS
The 9,000 yd3 of flyash at th.is Site contain several metals,
particularly lead, at levels that present an imminent and
substantial threat to human health and the environment as
described in Section VI., Summary of Site Risks. Table 1
presents the levels of inorqanic contaminants detected in a
sample of flyash analyzed durinq the 1983 Site Inspection.
Elevated level of cadmium (1,600 ppm or 0.16 percent(%», lead.
(45,000 ppm or 4.5%), and zinc (220,000 ppm or 22.0%) were
detected. The total concentration of orqanic contaminants in the
flyash was less than two ppm.
In June 1991, additional samples were taken from the flyash
pile in order to verify its metals content. Surface water and
sediment samples were also collected durinq the RI/FS from the
streams receivinq runoff from the flyash pile. The analytical
results of these samples were evaluated and three contaminants of
potential concern were identified - lead, cadmium, and zinc. The
maximum concentrations of these contaminants observed in the
flyash and the sediments and surface waters of streams receiving
flyash runoff are presented in Table 2. The data collected
durinq the RI/FS clearly demonstrates the migration of metals
from the flyash pile into stream surface waters and sediments.
6
-------
TABL8 1
IDO~q.D10 CODC.Dt~.t1oD. 1D .1y..h
(KOt1 ...t.) at the Dizie C&".~D. LaD4fill 8it.
(ppa)
CODst1tu.at
Antimony
Arsenic
Barium
Cadmium
Chromium
Cyanide
Lead
Mercury
Nickel
Selenium
Silver
Thalliwa
Zinc
coac.atratioD
14
16
30
.1,600
420
. 1. '7
45,000
. 3.1
200
1.5
31
0.9
220,000
IfUL8 2
Li.t of Cbeaica18
. Mastaaa CoaoeDt~atioD. (ppa)
.1,..h 8adia.at Surt.ce ..ter
1) Lead
2) CadmiUm
3) Zinc
49,50q
1,520
220,000
30,'80.0
605
127,000
0.056
. O. 006
0.162
7
-------
vx. SUXM1RY O. SIT. RISKS
Lead, cadmium, and zinc are present in the flyash at levels
which may pose an unacceptable threat to human health, based upon
frequent direct contact over an extended duration, or the
environment. Lead and zinc comprise the l~rgest fraction of the
flyash, 4.5' and 22.ot, respectively. Cadmium, c~omium, and
nickel comprise less than 1.0' of the flyash. Samples taken show
the inorganic contamination to be homoqeneous. Lead in the
flyash appeared to be the primary chemical of concern. Thus, the
potential risks associated with exposure to flyash is focused on
the potential impacts associated with direct contact to lead.
For zinc and cadmium the additional consideration of possible
inhalation of flyash is considered.
The exposure route of primary concern is incidental,
ingestion of flyash by children who trespass on the Site,. ,Dermal
absorption of inorganics bound in the flyash is considered
negligible. Inhalation of wind-borne dust from th* flyash may
also be of concern to public health, but apP8~s to be
insignificant compared to the risk posed by direct ingestion of
flyash.
A Preliminary Risk Assessment which quantified the health
risk posed by the flyash demonstrated that children playing at
the Site would have a 99.7' chance of experiencing blood-lead
levels exceeding the interi. criteria of 10 micrograms per
deciliter (ug/dl). Given the homogeneous nature of the collected
samples, EPA has determined that the entire flyash pile poses an
unacceptable risk to 'human health. Additional hazards may exist
due to exposure to other chemicals and exposure routes not
quantitatively evaluated in the Preliminary Risk Assessment.
"
Although the flya8h is relatively immobile, there is visible
evidence of flyash aiqration away fro. the pile over the surface
of the Site. Also, the data collected thus far during the RIfFS
identified 'elevated aetals concentrations in the surface waters
and sediments of str.... receiving runoff froa the flyash pile
(Table 2). This contuinant migration will continue without
further action. TbU8, EPA is implementing this interim action' to
achieve a significant reduction of risk to public health,
welfare, and the enviromaent wbile the final remedy for the
entire site is being developed. '
, Actual or threatened relea.e. of hazardous substance. from
the flyash pile at the Site, if not addre.sed by implementing the
response action selected in this ROD, may present an imminent and
substantial endanqermentto public health, welfare, or the
environment.
'8
-------
Chemical Descrictions:
Presented below are qeneric toxicoloqical protiles for the
contaminants ot potential concern in the flyash at the Site.
LDJ)I
.CADKIOJU
JIBe:
Since lead has been demonstrated to cause renal tumors
in rodents, this heavy metal is c~assitied by the EPA
as a Group B2 - Probable Human Carcinogen. With reqard
to noncarcinogenic endpoints, lead exposure has been
associated. with fatique, headache, abdominal crampinq,
kidney dystupction, and anemia. Additionally, .
neuroloqical deticits (periphe~al and central) have
been reported tollowinq exposure to this heavy metal.
Younq children are particularly susceptible to the
toxic effects ot lead, specitically with reqard to
impairment ot cognitive development.
Although gastrointestinal and dermal absorption ot
cadmium are minimal to negliqible, pulmonary.absorption
ot this metal can be siqniticant. Consequently, acute
cadmium toxicity is almost always attributable to .
inhalation exposure. Cadmium is a respiratory tract
irritant, causing coughing,. chest pain, sweating,
chills and dyspnea. cadmium exposure has. also been
associated with kidney damage. Because cadmium is
tound in ciqarette smoke, heavy smoking may increase
overall risk ot cumulative toxicettects related to
exposure. Additionally, cadmium is readily taken up by
.plants; this may s.rve as a m.chanis. tor human
exposure to this metal. .
Zinc is an essential trace element that is involved in
enzyme functiona, protein sYnthesis, and carbohydrate
metabolis.. However, ingestion ot excessive quantities
ot zi~c may caus. tever, stomach cramps, and diarrhea.
Additionally, excessive intake o.t zinc may cause
nutritional copper detieiencie., 'r.sulting in anemia. .
At high concentration., zinc salts are corrosiv. to the
skin and mucous membranes. Inhalation ot zinc may .
caus. irritation to the no.., throat, and re.piratory
tract. Zinc i. also extr_.ly phytotoxic; in tact,
this ..tal.vill d...g. or kill plants. at levels too low
to elicit adv.r.e health ettect. in animals or humans
conawainC) the attected vegetation..
..
9
-------
~%. ,DB8CRIPTIOH O~ aL~BRKaTrvB81
As discussed previously, this ROD is an interim action
decision vhich addresses remediation ot the tlyash pile only.
The ROD tor the final remedy at the Site vill be prepared after
the RIIFS tor the Site is completed. The tinal ROD vill evaluate
a complete range ot alternative. tor all the Site contaminants'
identified during ,the RI/FS.
A screening evaluation'vas pertormed to determine the range
of alternatives currently available for remediating 1:061 vaste.
In the final First Third Rule, EPA determined that HTMR
represented the Best Demonstrated Available Technology' (BOAT) for,
K061 waste when the waste contains 15' or more ot total zinc
(i.e, high zinc s~ateqory). The Land Disposal Restrictions for
Electric Arc Furnace Dust (1:061) published on Auqust 19, 1991 (56
Fed. Reg. 41164)' further support thia determination. However, ,
EPA also recoqnizes the strong preterence on the part ot Roanoke
County and RES to proceed wi~ the original stabilization and on-
site disposal plan which they developed pursuant to the 1987
Consent Agreement and Order with EPA~ The recent K061 LOR rule
does allow tor the use of stabilization technologies provided
that the treatment standards are achieved through 1:2smA na
treatment rather than impermissible dilution. Theretore, both
HTMR and stabilization verecon.idered in tbe screening
evaluation.' .
During the screening evaluation, the short- and long-term
aspects ot ettectivenesa, implem.ntability, ~d cost were .
considered. A key a.pect ot the evaluation ia the etfectiveness
ot each alternative in protecting human health and the '
environment. In addition, each alternative waa evaluated as to
its ettectivenesa' in reducing the toxicity, mobility, and volume
of the tlyaah at the 'Site. Baaed on a thorough review of the
available data, EPA baa determined that 1) it haanot been
demonstrated that atabilization can achieve the concentration
levels required to be protective of hU8aft h.-l th and the
,environment; 2) atabilization will aignificantly increa.e the
volUme of wa.te for land dispoRl; 3). the lonq-ter18 effectiveness
and permanence aaaociated with landfillinq .tabilized flyash is
uncertain ainca the _tala are atill preaent in the treated
waste; an4 4) the coat of atabilization and on-site land
disposal i. not .ignificantly different troa BTMR. Therefor.~
the stabilization alternative va. not considered for further
analys1a in the ROD. A detailed discua.ion of the acreening
evaluation foll0W8.
"
In April 1988, BPA' approved Roanoke county~. removal 'Wor~
Plan at:thi. Site wbich included using,the RES proprietary
stabilization process to treat the flyash. A8 part of the Work
Plan, prel1ainary treatability te.t data for .tabilized flyash
from the site were pre.8J)t8d. The EP Tox1ci~y concenuations
'10
-------
achieved ~or lead and cadmium,were 0~35,mq/l.and 0.73 mq/l,
respectively. These levels d1d not ach1eve the required
treatment standards ot 0.315 mq/l tor lead and 0.063 mq/l for
cadmium. However, the Work Plan stated that with additional
treatability efforts, the stabilization process could be .
optimized to achieve these levels. On that basis, and with the
understandinq th~t the treatment standards woul4 have to be
achieved, EPA approved the Work Plan.
. Since April 1988, several signiticant developments have
ensued. First, treated tlyash was analyzed tor toxicity at the
full-scale stabilization operation at the RES tacility in Roanoke
and at the operation that was initiated by Roanoke County at the
.Site. Two type. of testinq were conducted to evaluate the
effectiveness ot the stabilization - EP Toxicity and Toxicity
Characteristic Leachinq Procedure (TCLP). Table 3 summarizes the
results of this testinq. '.
The second significant development relates to chanqes in the'
'delistinq concentration level that must be achieved prior 'to on-
site land disposal of the. treated tlyash (RCRA li.ted waste
K061). The appropriate concentration levels are presented in .
Table 4.. The most significant chanqe has occurred. with respect.
to lead. The LOR treatment. standard usinq TCLP analysis tor lead
is 0'.37 mq/l, sliqhtly hiqher than the treatment level. required
durinq the removal action. However, flyash treated. to this level
would have to be disposed of in a RCRA Subtitle C/VRWMR hazardous
waste landfill. Since no facilities of this type exist- in .
Virqinia, the flyash would have to be transported out-of-state to
an existing tacility or a RCRA Subtitle C landfill would have to
be constructed on-site. The cost ot either of these options is
prohibitive. .
For treated tlyasb to be disposed ot in an on-site RCRA
Subtitle D/VSWMR solid waste landtill, TCLP analyse. tor lead
would have to achieve a level ot 0.095 89/1. EPA determined this
concentration level to be sate to human health and the
environ.ent during development ot the recent K061 LOR rUle usinq
the vertical and horizontal spread (VHS) .odel and the new lead
action level ot 0.015 89/1 contained in. an Ottice ot Drinkinq
Water requlation (5' Pad. Req. .26.60). None ot the analyses
performed using the RES stabilization proces. achieve the level
ot 0.095 89/1. While it may ultiaately be po.sible to achieve
the heal~-ba.ed concentration level tor lead in the stabilized
flyasb through alteration ot the aix ot ingr~ients, EPA does not.
believe th- concentrations can be achieved without turther
increase. in the voluae ot waste for disposal.
The imple.entability and cost ot the stabilization process-
were also considered during the screening evaluation. In .
qeneral, stabilization has been documented a. a process that is
hiqhly matrix-dependent and prone to cb..ical. interterences.
11
-------
--
TUL. 3
lmQuzam COBCD'l'RA'1'ZO. Lft'BL8 ~a ftBA'1'XDT
LOa DCL U8
, '1'Z'.ata8n1: D.1i81:in9 D.1i.1:inl
8undar4l L...183 L...1.
Con81:itu.n1: TeL. (89/1) TeL. (89/1) D '1'08 (89/1)
Antimony 2.1 0.063 ---
ArSeniC 0.055 0.32 0.315
Barium 7.6 6.3 6.3
Beryllium 0.014 0.0063 ---
Cadmium 0.19 0.032 0.063
Chromium 0.33 0.63 0.31.5
(total)
Lead 0.37 0.095 0.315
Mercury 0.009 0.013 0.0126
Nickel 5.0 0;.63 5.15
Selenium 0.16 0.32 0.063
Silver 0.30 0.32 0.315
Thalliwa 0.078 0.013 ---
'Vanadiwa r.8erved 1.26 ---
Zinc 5'.3 --- ---
. .
. 1 Land Dispo.al R..~ic~ion. for El.~ic Arc Furnace'Dust
.(K0611 pub1i.hed AUCJU8~ 19, 1991 (56 Fed: R8CJ. 41169) ,
2 Ccmc:entra~ion lev.ls tha~ have ~o be achieved wh.n
trea~incJ mel at t:h8 Dixi. Cav.rna Landfill (DCL) Si~. for the
was~. ~o DO 10ft98Z' be considered a RCRA lis~ed wa.~e (i.e.,
delis~ed) and can ~8Z'.fore be land dispo.ed on.i~e.
Concen~a~ioft8 developed in K061 LOR final rule (56 red. Req.
41170). . ..'
3 concentra~ion levels tha~ 1IUs~ be achieved by RES in'
treating K061 a~ i~. production facility for the was~e ~o no'
longer be con.idered a RCRA lis~ed wa.te (i.e., delis~ed).
12
-------
'l'ABLB ..
AHALY'l'ICAL DATA ~OR STABILIZBD K061 WASTB
Stabilized.K061 rrom Stabilized K061 rrom
D1rie Caverns Landrill site RES Production Facility :
I
'l'CLP (mg/l) BP Tax (mg/l) TCLP (mg/l)
COD8titU8.t SUJply Sample . Sample Sample Round 1 Round 2 Sample Sample.
TFA-l. TFA-2 TFA-3 TFA-4 Test2 TestJ 46036 46037
Antimony 0.019 B 0.031 B 0.040 B 0.048 B --- --- ---
Arsenic 0.007 0.002 U 0.023 0.002 U <0.0~1 0.018 <0.001 <0.001
Barium 0.846 J 1.00. J 1.070 J 1.230 J 1.14 0.6 0.69 0.58
Beryllium 0.001 U 0.001 U 0.001 U 0.001 U --- --- --- ---
cadmium 1.310 1.650 1.500 1.440 0.048 0.058 0.021 0.049
Chromium 0.136 0.159 0.173 0.184 0.180 0.085 0.10 0.09
Lead 1.270 L 1.180 L 1. 250 L 1.170 L 0.310 0.257 0.35 0.57
Mercury 0.0002U 0.002U 0.0002U 0.0002U 0.0022 0.0027 0.0004 0.0008
Nickel 0.019 B 0.021 B 0.026 B 0.026 B 0.17 0.27 --- ---
Selenium 0.006 J 0.003UL 0.003UL 0.300UL 0.002 0.030 0.020 0.007
silver 0.005 U 0.005 U 0.005 U 0.005 U 0.040 0.022 <0.0002 <0.0002
Thallium. 0.003 U 0.003UL 0.003 U 0.003 U --- --- --- ---
Vanadium 0.003UL 0.003 0.003UL 0.003UL --- --- --- ---
Zinc 85.30. 83.30 120.00 106.00 --- --- --- ---
13
-------
1
GLO."'W or 0&'1'& QUALlrlU CON.
COOKS RELATBDTO IDBNTIrICATIO~ (confidence concerning pre8ence or absence of ana1yteB);
u. .ot detected. The a..oclated number lndlcate.'approxtmate...ple concentration nece..ar1
to .. detected.
(NO COO., . CODfi~ identlflcation. .
.. ~ detected eub.tantlally above the level reported ln laboratory or field blank..
COO.S RBLATaD TO OO~I'1'A'I'IQI (can be u.ed for both po.lt1ve re.ult. and ...ple quantitation l~it.).
J' - ADalrt'". ~e..nt.. "ported value uy not be accurate or prec18e.
L .
ana1yt- ~.....t. "ported value uy be bia.ed low. Actual value 18 expected to be
bigb8c. .
IIot detected. Quantitat.ion 1181t ..y be lnaccurate or 18preci.e.
IIOt detected. Quutitation Ualt ie probably low.
w-
UL-
2
_-.ple. for lnitla1 te.ting of .tabl11aed 1061 for the full .c.le proce.. at the RlS production
'ae111&y Nere collected betweeD July 9, 1990 and &ugu.t 3, 1990. The....Laua concentration. ob.erved
for eaeb con.tituent in the .. 'I'o.lcity re.ult. are pre.ented in this table. It .hould be noted,
bowe.el', that Vil',lnia Departaent of "a.te Hanag_nt (YD"''' concern. relaUng to laboratory quaUty
a.."l'ue./quaUty eODtl'01 led to a 88Cond round of te.ting.
_..p1.e f~1' the .ecoDd round ~f te.tlng of .tabi11aed 1061 at the RlS production f.cility were
oo118CteclbetN88D D8c88b81' 28, 1110 and January 18, 1991. 'I'he...~ concentration. ob.erved for
.aob ooa.titu.nt ln tbe ., 'I'o.ioity I'e...lte al'e pre.ented 1n this table. VDNK cont1nue. to. have
qual1tr ..~"l'anc./qu.l1tr cODtrol cODcern. wltb tbe ... data.
. 3
. .
14
-------
Based .on the data currently available, EPA is not 90nfident that
the stabilization process can be reliably operated at the Site to
~chieve the appropriate health-based concentration levels. EPA
~s also concerned that the impacts ot long-term landtillinq on
the bondinq process that is the basis of stabilization are
unknown. In terms ot cost, the least expensive stabilization
option would include on-site disposal ot the. treated tlyash in a
newly designed and constructed RCRA Subtitle D/VSWMR landfill.
EPA estimated the cost ot stabilization a~d on-site disposal
. assuming a sot increase in volume ot waste (a typical value for
stabilization processes) to be approximately $3.1 million. The
details of this cost estimate are presented in Table 5. Since
changes to the stabilization process necessary to meet. health-
based concentration level may result in higher volumes for
disposal, this cost should be con.idered a lover limit estimate~
Based on the screening evaluation as vell as the statutory
requirements otSection 121 ot CERCLA (42 U.S.C. 9621) for'
utilization ot permanent solutions and alternative. treatment
technologies or re.ource recovery technologies to the maximum
extent practicable, EPA is evaluatinqtwo alternatives in this
ROD: 1) No action; and 2) High Temperature Ketals Recovery.
Alternative III . 80 actioa
capital Costl
baa.l 00 co.t I
pre.ent WortJu
.oath. to %8pl..eatl
.
.
.
o
o
o
o
The National Contingency Plan (HCP), 40 C.P. R. Part 300,
which requlates CERCLA response actions, requires that a "no
action" alternative be evaluated at every NPL Site. in order to.
establish a baseline for comparison. Under this Alternative, the
approximately 9,000 yd3 tlya.h pile would not be removed for'
treatment and would remain on-site until a tinal remedy could be
implemented. ..
Alt8rnative 121
a880val .01 the .1ya.Ja aza4 tr..taeat a.inq a Biqh
"88p8rat~e .etal. a8GOV~ .,eoJuaol097
cap!. tal Coat I
Ma1Ial 00 Coati
fte.eat Worthl
~.tha to %8pl..entl
. 3,.3',2'3
. . 0
. 3,'27,15'
. - ,
'.
. Under this Alternative, the a~proximat81y 9,000 yd3 flyash
would be removed trom the Site. and transported to an Hiqb
Te~perature Ketals Recovery (BTMR) tacility tor treatment. The
HTMR proce.a is a recovery technology by which zinc and other
metals (e.q., lead and cadmium) are collect8d:and concentrated
15
-------
TABI.B
5
Cost S-,.,. rzf ~1tdl"C8tI011 8l1li L""';11t~ of ~1, Alii ('.000 c)'Ot1
0'",. c.w- LtIIGf'I11 SIte
..---.............-..-.... ........... ...... ....... .........-... ...... ..-. ........................ ... .... . .....-.
:~~ tt.. tJrnc~':Jt1'" :.1c'~:' ""..~.' ;1-"",,: ..,r~. ;...,S ~: :
,.0' :~s: :;$: J~ " 1 :~ Z: ," J =,
............ .............. .....--............. ... ..'!! .-........... ........ ....... ...... .............. ........ ....................
...
:->::.~.::~A;, ::..CLS
-0-;.' =... (I)
:;(LI.I'UI'
S;S.:OO
1.
:"9,....r,"9 *'9" ;f ~..'Id',11 ~i... (DI
sZI.m
-:0"""---"---"--"""."..."""."..""""" .......-....--.--.-.--.. ........-.........................------.-................... .....
SyO:=~ i :
Sil. :co
...... -. ..--..----..- --.--....--..-..----..-----.... -- --.. .----.. ..------ -----... .------.-..------.. ........................ ... ............... ... ....
z.
"alll ":a~fonl O-"'ut."" leI
$X a' !. ::-1. .:... t::. ...: [~
$89..119
...--.........--............. ...................... ....... o8....... .... ..-.-........-...-........ ........ ...................
S..cta-.&1 :
$4:U71
..........-..........._..........~........-._.............-.-....-."-"'''''-''................-............. ..... ... .... .......o8".""."".
3.
~SIIrzf!11 Stt. P_~u'on
.. E"9'~ O',;=- ,oJ
,. q-, rzf &.1'1..11, ~~..t': ", AI" (., .
c. Sta"ltft 08cOllt..,...t,,,,,,Stao''''''''' (')
o. ...!~ SMY'Cft :,)
&. E,""",~'OII of ..1:,_c. ~"OCIS.i SIC. ('"
f. :"';aI1.ClOII 0' ~,...r (':
. S5.0~~
1S1.1:;
SZO. aoo
130.110
S.I.115
S.t.8oIO
, ,
.-.... ...............--.....-.. ......... .-.... ..-... ..---.... .-.-- -..-.....-.....--.. -...... -.... -..... ..e. e. e..... .......-... -....
s-..~~CUI:.
SZIt:011
. ..
."".
....e ... ..--....-.-. ........ .-.....---.-....-...... ... o8"o8 ...-. ....--.....--.....................-..----..... ..... .-.....o8.... o8."o8 o8..e-
~Uft'" CJ UW ~, ASII
I.
"7 .." c.c-CfOll IJ:
e. ~'''' (01
D. 11ItIt&11 [1'011011 8IICI *'-: ColIc...' (1)
c. SeT8U 58ca"" (1111
d. V8g8UCI". SU'- :"8&'011 ("I
0-181 ,..;'" ..10 ~1" of '~A'" (01
u.r.C'~ '-" (pI
IIO.:CO
SI. aoo
110.aoo
15.m
S52. caa
SlSO..
sm..
t.
3.
..--.----.-----------.-....-...---...--...-.....-.-....-....-....----....__...-..................-_......~...
S'/~tfta t :
Sl.U7.COII
IV.
.-...--.-.-...-...--............---......---...--......-....--....-......-----. ...--------......----...--..-.-..----.......-....
~'.UllllPtu. CIPOATtCIIIS
I.
2.
3.
CIa". !If LIIICIf": (cl
XP 'erlft"". !If "1 ..... ....,~C,= (r)
S8t.-, GrIwOoICIr "":01""1
a. 1118t&1fct181" lIaIt,cor .11 :.)
D. "''''' (eJ
a. UaM8''''.
"'" ,- ...t....... .
,....... .n ",_c
Sll.5iS
sn.us
$1&.1811
sa. :1:1
sm. SOl
SSO.eGO
".~
$1.*
U..
n. SOl
ssoo
SJS.~
I. .100
SU.OU
11..
e.
S.
--------....--....------------..---.-.---.-----.....-.-..-.-.-.
SoJIWU' :
1201..
11.100
1111'. ISO
"'.103
....-.............-.....----------..-----.-----------------.---~_.._----
II...J"
I:';..
S88.103
CAPI'- UIaTIL (:.It.tU .. t"
II..
J. ........------...........
1 -......
--.'N .......
-- ----.---
,. 81ft... CIII1'I
I.
r.
J.
- ,tit .... Wet7
'l1li C888 ll1f11187
'- ., .... c:.c 'ft1111C7
11..531
IZR.IOJ
SZIUQI
;~ 0' c:..IUlI S~t.UI'
1D rzf c.e,ul ~1
151 8f C81' U1 Soor.8U'
Zft of -"" SuIIt8UI'
11.700
1ft. U.
Ill. on
-..------------...------------..---......-.....-
,...., :
suSTOTJL ([.n.m.I' ... ')
4
S7SUAI
SUB. ..
SIG.l21
11.100
sn.UI
mo."
Slun
'1"""-
..5110
11........~1"T
-----...
1"
;"':\. . 1\ ~ ~.0(
\...t \,.j i-'.... i i
PI' ......, ...
- . ~' ~~U;~
O--.,.....INAL
~;{~\.;;~l
-------
TABLE 5 (CONTINUED)
Caat SiaMry of Sottdlfteuton and l»ndf«11tni of Fly Art (9.000 cyda)
Ol»ia C*««ma Landfill Slt« (Cant'd) .
>if*?::i« ;:s:s
»er»-tti-? and 't»jtl rM> . t\ st 'a::t' i.Jtstjl 19*. 3M
E';— ttrir^ S«r>.cn
Ca?'-? OsnstTMetie" :S* :' CwtS1 SuWTji S282.J03
- I37T :;:
A. TOTAL ctfi'M. c:s'5 U.OU.SM
s. -::». MINN. COSTS U.HO
*O*TM v AMUM. COSTS sno.au $M.in
WNTW Of .O»lT*l ARC *>»U. CIS-3 (»<) S3.UI.tM U.OM.M5
wrts *no »S$UK»TIO« rot nti!«[KMr ess: esriMATt
;ca ssLiiiriunai or $.wo c-os er .".r ISM
(4) I.«M* f«»r«M"Ut1oii auri»« contract r«gati«t>«. Airjnid 40 nr» I J400 M.
1») '^soget'sn ef eantruetien gltnt tne e«leultlio«* fv s«r»ttt!n5 4114 t^lc
(c) tMiOMxt tranaartat'T; ta 4fl4 *r«i utt.
'.a! SiMU eanttruetton trailer «na eanMi* tail«t.
It) 'r«n«aeru:ion af atnuiiy trMtw "r •»" ''•a* l f'y 4«fr 'rgn *tl1»iea :a cn-«itt Ml'dlftcitio" plant. »««Jiri? SXO/eyd :««»fl c~ ? :i-*
eon»trat«J.
('<) *»tfnd * 0.5 ft avtf*ic«Tat:en j«ie» "y itfl e'"t.
(1). In'.«»»r.t eroiian and utilmint :arfat •tcaiurM 'or taaroxirtta'y Z uro*. fncludtr^. :ut *o- Mmtta to: rarc:i-i-y
Mringur attcKinf anaVor biraf.nf. tMitvi twm anavar traat. rijraa an« Tvo-jnanti . ;nir »»a o^t» «« it -;
«ninaa« stmeturvt. tilt fencing. f:ltar fatric. ate. Inuaad 2 tern I 12500 aa. eon .-at . "return j -.•
jtaBtHtat'or aost^aratructton.
(n) lackfill ill aBUTat^am to or'final contour aluat'ar. «)t» ui f-ly aa*. nr*d ana otieod in linaa landfill. Salid ftloent nmcn ara ttackod into linad landfill.
;») ana aaMllnf avant >" •'" to K«iyaMd :r 'C'.:
p !••! far tn indicator wult.
(o) Cawlnf lamfMI. tao an* ttdtt. «'th MO 1«ytn of cactastt'a. ana *oot of a»M. and :-o fat: of c'ay.
(r) J-Oa^ fl«ar«aeanea »al»aatiori of mM) canctntrattona at fi«a> cut t'aration.
(») InataHatfaM of a ainft* mnitortfn »«!l to canlatt a thra* «ail1 reittsrtnf tyata* «rt>er :ncluda* t<* nut"^ >«i:i
!«W-3 4MIIV-4).
(t) '.atorttary amiyala of fnwdMta? 'v KM «atal» t*ict a ?w: > total of I aaw'aa '.'"cluon *ioiicatt«) aaen yiar
at a cam af S30Va**lt.
HMM. 1W: COM .J-tj
17
!-.-''-•.:•''%*"!- x"-,:. A? rrv
• r w'^-'K. v^wAi-i 8 I
-------
for reuse. This technology is designated by EPA in the First
Third tinal rule as Best Ceveloped Available Technology (BCAT)
for recovering zinc trom K061 high zinc (equal to or greater than
15'> subcategory wastes.
Essentially, the HTMR process involves heating the K061
. waste twice in ovens or rotary kilns. This heating volatilizes
metals which. are collected in baghouse filters. The HTMR process
attempts to recycle all.ot the materials produced in. the process
waste streams. The primary products which result trom HTMR are
iron-rich materials, zinc oxide (or the more refined zinc .
calcine), and lead/cadmium. concentrate.
Several HTMR systems are currently in operation. For
example, a system which was used to establish the treatment
standards for K061 wastes in the high zinc. subcategory uses a
seriesot waelz kilns, generating an iron-rich residue and a
crude zinc oxide residue from the first kiln. The iron rich non-
wastewater residue has been typically used as a road aggregate, .
and the crude zinc oxide is sent. to. a second kiln for further
separation and retininq. The zinc i. eventually recycled and
reintroduced in. to the market place as a useful product rather
than dispo..d in a landfill with hazardous wa.te..
Soils in the immediate vicinity of the flya.h pile will be
sampled after the removal o~ the flya.h. to confirm that the
residual contamination does not po.e an immediate threat to human
health anel the environment. However, the re.idual tlyash
contamination, it any, will be addressed in the final ROD for the
Site. Ero.ion anel sedimentation control. .hall be installed
prior to the tlyash removal to prevent any contaminant migration
from surface water runoff during flya.h excavation.
n.II.
81J1111aJtY O. CODUA'fIn ADLY8I8 O. aL'fDD'fIVW8
The two interia action alternative. de.cribed above were
assesseel in accordance with the nine evaluation criteria as set
forth in the NCP at 40 C.r.R. S 300.430(e) (9). The.e nine
criteria are categorized below into thr.. group.: thres~old .
criteria, priaary balancing criteria, and modifying. criteria.
Thr..hold eritarla
1.. Overall protection of hu.an health and the envir_~nment;
and
2. .C08pliance with Applicable or Relevant and Appropriate
. Requir_enu (ARAb). .
;
i
18
-------
ELimarv
Balancina criteria
3. Lonq-term effectiveness and permanence.;
4. Reduction of toxicity, mobility or volume
treatment;
5. Short-term effectiveness;
6. Implementability; and
7. Cost. .
throuqh
Modifvina criteria
8. State Acceptance; and
9. community Accep~ance.
1)
Overall Protection ot Human Health and the Environment.
A primary requirement of CERCLA is that the selected
remedial action. be protective of human health. and the .
environment. A remedy is protective if it reduces the current
and potential risk. to acceptable levels within the established
risk ranqe posed ~ouqh.each exposure pathway at the Sites. .
Alternative 1, the no action alternative, does not reduce
risk. Because protection of huaanhealth and the environment .is.
a threshold criteria for any CERCLA re.ponse action, Alternative
1 cannot be selected. and vill not be evaluated any further with
reqard to the nine criteria.
Alternative 2, HTMR, is protective of human health and the
environment because it would greatly reduce the risk of exposure
to the flyash pile by r..ovinq the waste fro. the Site and
treatinq it usinq a .recovery technology that reduces the toxicity
of the flyash and .iniaizes the voluae .of vaste which would
require land disposal.
2)
Comaliance Wi~ Aaalicable or Relevant and Aaaroariate
. Reauirements . .
.section 121(4) of CZRCLA (42 U.S.C. S 9S01(d» requires that
remedial a~ion. at SUperfund site. at least attain.legally
applicable or relevant and appropriate Federal and state
standarda, requir888ftta, criteria, and liaitation. (collectively
referrecl to .. .ARAJtS8) unle.. such ARAR8 -y be waived under
section 121(4)(4)" of CDCLA, 42 U.S.C. 9621(4)(4). Applicable
requirement. are those .substantive environ8ental protection
requirement., criteria, or liaitatlona proaulqat84 under Federal
or State lav that .pecifically a4dre.. 1) hazarclou. materials
found at the site, 2) the remedial action to be imple.ented at
the site, 3) the location of the sit., or 4) other circumstances
present at the sit.. Relevant and appropriate requirements are
19
-------
those substantive environmental protection requirements,
criteria, or limitations promulgated under Federal or State law
which, while .not applicable as described above, nevertheless
address problems or situations sufficiently similar to those.
encountered at the site that their use is well suited to the
site. ARARs fall .into three general cateqories: chemica l-
specific, action-specific, and location-specific. Alternative 2
meets all ARARs, as described more particularly in Section IX,
Selected Remedy, below.
Chemical-specific ARARs are those which. apply to the flyash,.
which is classified under RCRA as a listed hazardous waste, K061. .
The most significant "ARARs" for Alternative 2 are the RCRA Land
Disposal Restrictions (LDRs). The LDRs, which were included :in
the 1984 amendments to RCRA, prohibit the land disposal (i.e.,
landfilling) of certain wastes. K061 waste in the hiqh zinc
(equal or greater than 15' zinc) subcategory,. such as the flyash
(which is 22' zinc by weight) .cannot be land disposed \intil they
. are treated sufficiently so that they meet certain treatme~t
standards established by EPA in the K061 LDR final rule (56 Fed.
Reg. 41169, August 19, 1991). Treating.the flyash via HTMR.
(which is the process on which the treatment standards were
based) will assure that the flyash meets the K061 trea~ent
standards.
Action- and chemical-specific ARARs which pertain to the .
handling and off-site transport of K061 waste include RCRA, the
Virginia Hazardous Waste Management Regulations (VHWMR) and the
Department of Transportation Rules for Transportation of
Hazardous Materials. Other action-specific ARARs triggered by.
flyash excavation include Federal and Commonwealth laws and
regulations pertaining to control of erosion, sediment and air
. emissions, as well as worker safety.
3)
Lona~Term Effectiveness and ~ermanence
This evaluation criteria addresses the long-term protection
. of human health and the environment once remedial action clean-up.
goals. have been achieved, and focuses on residual risks that will
remain after completion of the remedial action.
Alternative 2 will provide a highly effective and permanent
solution to the risks currently posed bY the 9,000 yd3 of flyash.
The High Temperature Metals Recovery (HTMR) process will greatly
reduce. the toxicity of the flyash material and will also allow.
the zinc, lead, cadmium and iron residua to be recycled. The.
final response action for the Site will address the residual
contamination, if any., in the soils baneath tha flyash pile.
20
-------
4)
Reduction of Toxicitv. Mobility. and' Volume Throuah Treatment
section 121(b) of CERCLA, 42 U.S.C. Section 9621(b),
establishes a preference for remedial actions that permanently
and significantly reduce the toxicity, mobility, or volume of
hazardous substances. EPA's expectations are that treatment
should be utilized whenever principal threats occur and that
containment will be considered tor wastes that pose a relatively
low lonq-term threat or where treatment is impracticable. EPA'
also expects to use a combination of treatment and enqineerinq
controls to achieve protection of human health and the
environment, as set torth in the NCP at 40 C.F.R.
5300.430(a) (iii). .
Alternative 2 will
volume of flyash at the
EPA has determined that
toxicity, mobility, and
qreatly reduce the toxicity, mobility and
Site by removing and treating the flyash..
the HTMR process is BCAT tor reducinq the
volume of K061 waste.
5)
Short-Term Effectiveness
This evaluation criterion addresses the time needed to
achieve protection ot human health and the environment, and any
adverse impacts that may be posed during the construction and
implementation period of a remedy, until cleanup goals are
achieved.
Alternative 2 will have few, if any, short-term effects, and
will include measures to protect the surrounding area trom
accidental releases and miqration of contamination throuqh air
emissions and surface water runoff. Approximately 6 to 9 months
will be needed to remove the flyash from the Site.
6)
Imnlementability
This evaluation criterion addresses the technical and
administrative feasibility of a remedy, including the
availability of material and services needed to implement the
chosen remedy.
Alternative 2 will be technically and administratively
feasible. The excavation, removal and transport of the flyash is
a standard .ite cleanup and construction procedure and should not
present any Uftuaual technical or adaini.trative problems. An
HTMR facility i. al.o available. The HTMR process haa .been
proven to be an effective treatment method for flyash material.
21
-------
7)
~
CERCLA requires selection of a cost-effective remedy that
protects the human health and the environment and meets the other
requirements of CERCLA. The alternatives are compared with
respect to the present worth cost, which includes all capital
costs and the O'M costs incurred over the life of the project.
capital costs include those necessary to implement. a remedial
action, including the construction cost. Capital, annual
operation and Maintenance, and present worth costs are shown in
fable 6.
The.cost for this Alternative 2 is estimated at $3.9
million. This fiqure includes labor, equipment, analYtical
services, transportation, and treatment costs.
8)
state AcceDtance
The Commonwealth of Virginia has concurred with the interim
remedial action selected in this ROD.
9)
Communitv Partici~ation
On August 22, 1991, a public ..eting was held at the Glenvar
Branch Library in Salem, Virginia, to discuss EPA's preferred
alternative as described in the Proposed Plan. A public comment
period for the Proposed Plan was held fro. August 15, 1991
through September 16, 1991. Significant comments received during
th~ public .eeting and the public co..ent period are discussed in
the Responsiveness summary which i. part of this ROD.
22
-------
Ta]:)le
,
J:xrE CAVERNS ~RE~il'INAU COST Esril'ATE
.II a......"""""" ....... ............ ..... ........... .... ..... ......... ...... ..............
::em
~o
:tem ~.scr1ptIO"
C.C I ta i
::st
. .II","'"'''''''''''' ........ a.............. ........... .... ............... .... ......... ......
,.
:Nsor7 "n~NAL CONTROLS.
L89Al '001 (A)
S:6.000
?qE~:"INAaT
l.
o,g.n....ng OOllg" of E.t'let:o" PIA" (0)
SZS. ceo
.. --..... -.... _"A""'''' ...-..-......_..... .....................- ............ .........-.. .......... -..--...-................ ........... ..............................
S~tltOl:a I:
Ul. :00
~.. ................................. ......... ..............-.. -"'''''''-''''''''''''- .....-.....................-.. --.......-...--...--- ""'''''''' """'''''''''''''''''''''''''''''''''''
2
l'Qotllutto"1 0_11I1'uttall (e)
51 0' CAD' tAl SwOtOU 1
Sl2Z.7ZA
.. -----...- ..-..------.. .......-.....-..... -..........-............... .......... ...... -.. -...--...-....... --.........'" ....... --..-.. - -- - - - -.
;wCtoU I:
$lZ2.124
.. .. .. - -....-.. - -- -- -- __a______--------- - __a. ----- - -----...- - ...__a- -......----- --... ...-- ...-----...... -... -- -...-... - -.. ...
J.
S 1 to P,,"'AC to"
a. E"g'"..~, OffICI (d)
C. InnA11 E,os,an a"d S8d,.."t Co"trol (0)
e. StAoll,Z8 C8cO"U.'"At 'o"/Stag,ng A'" (fl
d. ~.tC/lp8r"," Sor.'ClI (g)
SS.OOO
$10.000
SIO. :00
SlO. ~OC
.. - --- ...-------------- -...- -... ...-- ---...- --... -... ---- ...a_____......- --.. - - ----......-...--- --.. - -.... - - -...
SwototA I:
SJ5.000
I!!
.. -... ................. --- - -- --..--------- -....----- ------... -- -- -...---... -- - ----...---------- ---...--... -----...-- -- - - - -.
"-'TERIAl EXTIIACTlOII AIIO TAEAT"UT
I
Z .
StAO' 1'&0. IIoIICI or 1-0'1'&0 MAtortAI (hI
"AtOrt A J Eru..t 1011 (,)
A. O.Oreaca.AC 'an (J 1
b. 1"'lIect'anl -""'tort"91 Tost'"g (kl
e. Select a.caf,11 (1)
d. Y8CJ8tat... StAOi "rattail (8\
S5.000
S90.000
$15.000
$10.000
$15.000
S52.000
- - ---...---------------.. -.. -..- ---.. - -- - - -... - - -... - a- - ---...- -...- -...... -......... -..- - -- - -... -... - - - - - - -..
..... - -.. -.. -.. - - -- - - - -.. --404O - -- -.--- --... --- ..-------... - -.--- --- -..- ..----- -------- - - - --- ..--- -- - - - - - -- -..
SwbtOtA I :
Sl87. ~OO
lV. MATERIAl. TRMSPOIITATlCIII AIIO OISPOSAL
l.
2.
TrAftIllOrUtlDft 1"\
O'llIOsa' (a)
SZAI. SOO
SI. 811. 2S0
SZ.OSZ.7S0
-----...--..---------------..--------...-- --- -------------- ---
SwOtotA I :
- -- --... -- ...---- -----...----------------- --------------------------------- - --- - -... - ---- --- -. - -- - - -..
S2.A54. A7A
-w8.-..-----........-......"........
V.
CAP ITAI. SUI TOTAl (I. II. !II ANI IV)
.......-....--...... '1---....--
AOOITIOIIAl casn
I.
Z.
3.
- It" ANI Safet,
Itd Cantlft9lllC'
SCOll8 0' .. Conc I fl98llCY
IOS of Coo i ta I SutltDU I
151 of Coo i U I Sutleou I
1510' Cool tal SutltDul
SZ.5.«7
U&8.I71
UII.11I
----..-----.---------- ---- -- --- -------- --... - - ----------------- --------------- -... -..
SutltoU I :
SHl. 7at
--..-..-.................-..---....-....--...--....
..--..---,,-
S3..3I.Z53
VI.
S..-rOTAl 11.11. III. IV ... V)
IIIPI.£lCJlTATlCIII casTS
---~............_.....-..........._.._..._.-..............,
.---..--- .
1.
Z.
'o..tttt.. ANI Lo;al F.., 51 of Coole.' SutltDul
£"9I_t.. Senlen 0..""9 Conlt~tlan 151 of Coolul 5wOeoui
,.
SIZZ.7Z.
S311.11I
---------------------- ------.-------- -----------------------------..--.---
Sutleou I : SAIO.IIS
.---........- ~...---------------------..._.-.....
TOTAl PI£5£11 WDlTM t1I CAP ITM. AlII AIIIIUAL COSTS 53.127.158
----.--..----... -..,,-.---------
..-...."'..-"fI'-'
23
POOR.QUALITY
ORIGINAL
-------
IX.
SBLBCTBD RBKBDY
EPA.has selected Alternative 2 as the interim remedy for the
flyash at the Dixie Caverns Landtill Site. This interim remedy
is protective ot human health and the environment, complies with
Federal and State applicable or relevant and appropriate
requirements directly associated with this action, and is cost-
effective. This interim action utilizes permanent solutions and
resource recovery technoloqies to the maximum extent practicable
and meets the statutory preference tor remedies that employ "
treatment that reduces toxicity, mobility, or volume as a
principal element. Subsequent actions are planned to tully
address any remaining principal threats at this site.
Performance Standards
The selected remedy shall consist of:
.
Excavation ot approximately 9,000 yd3 ot flyash
material at the Site;
Transportation ot approximately 9,000 yd3 tlyash off-
site to an EPAapproved HTMR facility;
.
.
Treatment of the flyash at an EPA approved HTMR
facility to achieve the treatment standards for K061
waste specified in 56 Fed. Reg. 41164-41178 and
delineated in Table 7, below; and.
Implementation of dust controls and erosion and
sedimentation controls during tlyash excavation.
.
As stated earlier, several HTMR systems exist which are
capable of recovering metals trom the tlyash. The treatment
standards tor the flyash are based on the determination that the
HTMR process is BOAT. Treatment standard. dev.loped by EPA
reflect the perforaance of typical well-operated HTMR systems.
The selected r..8dy shall comply with the following ARARs:
.
the Virginia Erosion and Sediment Control Law (Virginia
COd. 510.1-560 et. seq.);
land dispo8al restrictions and hazardous waste
management practices as set forth in the Solid Waste
Management, as ..ended by the Resource Conservation and
Recovery Act (RCRA) (40 C.F.R. Parts 262, 263, 266 and
268, including treatment standards tor K061 waste
delineated in"EPA Final Rule for Treatment Standards
.(56 Feel. Reg. 41164) (August 19,1991);
.
24
-------
.
the Virginia Hazardous Waste Management Requlations (VR
Section 672-10-1, Part 7);
Air Quality Standards for criteria Pollutants (40
C.F.R. Part 50);
.
.
the Virginia Department of Air Pollution Control's
Standards for Non-criteria Pollutants (VR section 120-
05-0301);
.
the Virginia Department of Air Pollution Control's
Standards for Particulate Air Emissions (VRCAPP Section
04-01-01);
the occupational Safety and Health Act (OSHA) (29
C.F.R. Parts 1910 and 1926); and
.
.
the u.S. Department of Transportation's Rules for
Transportation of Hazardous Materials (49 C.F.R. Parts
170, 171.1-172.558).
TABLB 7
Requlated
Constituent
Toxicity Characteristic Leaching Procedure
(TCLP) (mall)
2.1
0.055
7.6
0.014
0.19
0.33
0.37
0.009
5.0
0.16
0.30
0.078
reserved
5.3
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
(Total)
25
-------
x. STATUTORY DBTBRXI~TIOH8
EPA'S primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the
environment. In addition, Section 121 of CERCLA, 42 U.S.C. 9621,
establishes several other statutory requirements and preferences.
Section 121 of CERCLA specifies that the selected remedial action
for a Site, when complete, must 1) comply with ARARs, unless a
statutory waiver is justified; 2) be cost-effective; 3) utilize
. permanent treatment technologies or resource recovery
technologies to the maximum extent practicable; and 4) satisfy
the preference for treatment that reduces toxicity, mobility, or
volume as a principal element. The following sections discuss
how the selected interim remedy for the Site meets these
statutory requirements.
Protection of Human Health and the Environment
The selected interim remedial action protects human health
and the environment from the risks posed by ingestion, dermal
absorption, or inhaling of the flyash by significantly reducing
the toxicity and volume of the flyash. The selected interim
remedial action also includes measures to protect human health
and the environment from accidental releases or migration of
contamination from the flyash throuqh air emissions and surface
runoff.
Attainment of Aoolicable or Relevant and Aoor09riate Requirements
of Environmental Laws
As discussed earlier, the selected interim remedial action
will comply with all ARARs. RCRA land disposal restricti~ns,
specifically those that apply to K061 wastes in the high zinc
subcategory, are applicable to this Site. Off-site shipment of
the flyash (K061 waste) shall be carried out in accordance with
all applicable RCRA and/or VHWMR requirements such as
manifesting, EPA Identification Numbers, us. of a Virginia
permitted transporter, .hipment to a permitted or interim status
facility, etc.
Cost-Ettectiveness
The ..lected interi. remedial action is cost-ettective
because it greatly reduces the risk posed.by the tlyash at the
Site.. The estimated present WOrthC08t tor the selected remedy is
$3,927,158. A detailed cost estimate is provided in Table 6.
26
-------
utilization of Permanent Solutions and Alternative Treatment
Technoloaies or Resource Recovery Technoloaies to the Maximum
Extent Practicable
The selected interim remedy utilizes a permanent solution
and a resource recovery technology, HTMR, to the maximum extent
practicable. The HTMR process will essentially permanently
render the flyash non-hazardous by collectinq and concentrating
zinc and other trace metals for reuse. As described earlier, the
HTMR treatment process is BDAT for the treatment of K061 waste
with high levels of zinc. In addition, the removal and treatment.
of the flyash will pose a significant reduction of volume of the
flyash, a listed RCRA waste. Any residual contamination left in
the underlying soils after excavation of the flyash pile shall be
addressed in the final remedy for this Site.
EPA has determined that the selected interim remedial action
represents the maximum extent to which permanent solutions and
. treatment technoloqies can be utilized in a cost-effective manner
for the flyash Operable Unit at the Site. Given the limi~ed
scope of action, the selected interim remedial action provides.
the best balance of trade-offs in terms of lonq-term
effectiveness and permanence; reduction in toxicity, mobility or
volume throuqh treatment; short-term effectiveness;
implementability; and cost; while also considerinq the statutory
preference for treatment as a principal element and considering
state and community acceptance.
Preference for Treatment as. a Princinal Element
The selected interim remedy satisfies the statutory
preference for treatment as a principal element. Alternative 2
addresses the primary threat of incidental inqestion of flyash
using the HTMR treatment process to greatly reduce the toxicity,
volume, and mobility of the flyash.
XI.
DOCmmH'1'ATIOR 01' 8IGJlIJ'ICAII'l' CDlfGB8
.No significant chanqes to the Preferred Alternative, as
described in the Proposed Plan issued on August 15, 1991, are
made by thi. ROD.
27
-------
GLOSSARY
Administrative aecord: An official compilation of documents,
data, reports, and other information that is considered important
to the status of and decisions made relative to a Superfund site.
The public has access to this material.
Applicable or .elevant and Appropriate aequir..ents (ARARs):
federal and state requirements that a selected remedy must
attain. These requirements may vary among sites and
alternatives.
The
comprebensive BDvironaental aesponse, Co.pens.tion and Liability
Act (CBRCLA), or supertund: A federal law passed in 1980 and
modified in 1986 by the Superfund Amendments and Reauthorization
Act. The Act created a trust fund, known as Superfund, to
investigate and clean up abandoned or uncontrolled hazardous
waste sites.
Plyasb: Emission control dust/sludge from the primary production
of steel in electric furnaces.
Operele UDit (OU). A portion of a Superfund site that has been
conceptually seParated from the 'rest of the site to allow for
easier management.
.ecord at DecisioD (ROD)I A legal document that describes the
interim or final remedial action selected for a Superfund site,
why the remedial actions were chosen and others not, how much
they cost, and how the public responded.
...edial IDvestiq.tioD/~e.sibil1ty study (a%/~S)1 A two-part
study of a hazardous waste, site that 8Upports the selection of a
remedial action for a site. The first part, the RI, identifies
the nature and extent of contamination of the site. The second
part, the FS, identifi.s and evaluates alternatives for
addressing the contaaination.
Re.ource COD.ervatloD 8114 aecovery Act (aCJtA) 1 A federal law
enacted in 1976 and ..ended in 1980 and 1984 d.siqned to control
hazardoua wast. froa the qeneration of the waste to its ultimate
treatment, storaqe, and disposal.
28
------- |