PB94-963922
EPA/ROD/R03-94/185
October 1994
EPA Superfund
Record of Decision:
Buckingham County Landfill
Superfund Site, VA,
9/30/1994
-------
RECORD OF DECISION
BUCKINGHAM COUNTY LANDFILL SUPERFUND SITE
BUCKINGHAM COUNTY, VIRGINIA
PREPARED BY
THE U.S. ENVIRONMENTAL PROTECTION AGENCY
SEPTEMBER 1994
-------
RECORD OF DECISION
BUCKINGHAM COUNTY LANDFILL SUPERFUND SITE
BUCKINGHAM COUNTY, VIRGINIA
PREPARED BY
THE U.S. ENVIRONMENTAL PROTECTION AGENCY
SEPTEMBER 1994
-------
TABLE OF CONTENTS
PART I - DECLARATION
I. SITE JIAME AND LOCATION 1
«
II. STATEMENT OF BASIS AND PURPOSE 1
III. ASSESSMENT OF THE SITE. 1
IV. DESCRIPTION OF THE SELECTED REMEDY 1
V. STATUTORY DETERMINATIONS 3
PART II - DECISION SUMMARY
I. SITE NAME, LOCATION, AND DESCRIPTION 4
II. -SITE HISTORY AND ENFORCEMENT ACTIVITIES 7
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION 10
IV. SCOPE AND ROLE OF THE RESPONSE ACTION 10
V. EXTENT OF CONTAMINATION 11
a. General 11
b. Surface and Sub-surface Soils 11
c. Waste Characterization 12
d. Ground Water 12
e. Leachate 13
VI. SUMMARY OF SITE RISKS 15
A. Background 15
B. Human Health Risks 15
1. Contaminations of Concern 15
2. Exposure Assessment 17
a. Transport Pathways 17
b. Exposure Scenarios 18
c. Exposure Point Concentration 19
3. Toxicity Assessment 19
a. Background 19
b. Risk Characterization 21
C. Environmental Risks 22
VII. DESCRIPTION OF ALTERNATIVES 23
A. Alternative 1 23
B. Alternative 1A 23
C. Alternative 2 24
i.
-------
D. Alternative 3 24
E. Alternative 4 25
F. Alternative 5 25
6. Alternative 6 26
H. Alternative 7 26
I. Alternative 8 27
J. Alternative 8A 28
K. Alternative 8B 29
L. Alternative 8C 32
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 36
A. Overall Protection of Human Health and the
Environment 37
B. Compliance with Applicable or Relevant and
Appropriate Requirements 38
c. Long-Term Effectiveness 39
D. Reduction of Toxicity, Mobility, or Volume
Through Treatment 40
E. Short-Term Effectiveness 41
F. Implementability 43
6. Cost effectiveness 44
H. State Acceptance. 45
I. Community Acceptance 45
IX. SELECTED REMEDY 45
A. Remedial Options 45
B. Contingency Trigger 46
C. Remedy Description and Performance
Standards 46
1. Ground Water Monitoring Performance standards....47
2. Cap Performance Standards 47
3. Source Control - Eastern Disposal Trench.........48
a. ISVE Performance Standard 48
b. Excavation and Offside Incineration
Performance Standards 48
4. Source Control - Barrel Trench Performance
standards 49
5. Ground Water Treatment Performance Standards 50
6. Institutional Controls 50
X. STATUARY DETERMINATIONS 53
A. Overall Protection of Human Health and the
Environment 53
B. Compliance with Applicable or Relevant and
Requirements 54
1. Chemical-Specific ARARs 55
2. Action-Specific ARARs 55
3. Location-Specific ARARs 57
ii.
-------
C. Cost Effectiveness 57
D. Utilization of Permanent Solutions and Alternative
Treatment Technologies to the Maximum Extent
Possible 57
E. Preference for Treatment as a Principle Element 58
XI. DOCUMENTATION OF SIGNIFICANT CHANGES 58
PART III - RESPONSIVENESS SUMMARY
I. OVERVIEW 60
II. RESPONSES TO COMMENTS RECEIVED DURING THE MAY 25, 1993
PUBLIC MEETING 61
III. RESPONSES TO COMMENTS RECEIVED FROM CITIZENS DURING THE
FIRST PUBLIC COMMENT PERIOD 70
IV. RESPONSES TO COMMENTS RECEIVE FROM THE POTENTIALLY
RESPONSIBLE PARTIES (PRP) DURING THE FIRST PUBLIC
COMMENT PERIOD 80
V. RESPONSES TO COMMENTS RECEIVED DURING THE APRIL 26,
1994 PUBLIC MEETING 91
VI. RESPONSES TO COMMENTS RECEIVED FROM CITIZENS DURING
THE SECOND PUBLIC COMMENT PERIOD 101
VII. RESPONSES TO COMMENTS RECEIVED FROM THE PRPs DURING
THE SECOND PUBLIC COMMENT PERIOD 108
VIII. RESPONSES TO COMMENTS RECEIVED FROM CONGRESSMAN PAYNE
DURING THE SECOND PUBLIC COMMENT PERIOD 115
IX. RESPONSES TO COMMENTS RECEIVED FROM THE VIRGINIA
DEPARTMENT OF ENVIRONMENTAL QUALITY (VDEQ) ON THE
DRAFT RECORD OF DECISION 116
ill.
-------
LIST OF FIGURES
Figure 1 - Site Location Map 5
Figure 2 - Hazardous Waste Disposal Area 6
Figure 3 - Configuration of Trenches 8
Figure 4 - Area of Assumed Ground Water
Contamination 14
LIST OF TABLES
Table 1 - Contaminants of Concern 20
Table 2 - MCL Exceedances in Ground Water 13
Table 3 - Contaminant Levels in the Eastern Disposal
Trench 30
Table 4 - Cost Estimate Summary for Alternative 8B...32
Table 5 - Alternative 8B Plus Contingency Costs 32
Table 6 - Cost Estimate Summary for Alternative 8C...35
Table 7 - Alternative 8C Plus Contingency Costs 36
Table 8 - Cost Estimate Summary for Option 1 of
the Selected Remedy 51
Table 9 - Option 1 Plus Contingency Costs 52
Table 10 - Cost Estimate Summary for Option 2 of
the Selected Remedy 52
Table 11 - Option 1 Plus Contingency Costs 53
APPENDICES
Appendix A - Glossary of Superfund Terms
iv.
-------
RECORD 07 DECISION
BUCKINGHAM COUNTY LANDTILL SUPERTUND 8ITB
PAR* X - DBCLARAIXO*
Z. SITE NAME AMD LOCATION
Buckingham county Landfill Superfund site
Buckingham County, Virginia
IX. STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the final remedial
action selected for the Buckingham County Landfill Superfund Site
(Site), located near the town of Sprouse's Corner in Buckingham
County, Virginia. This remedial action was chosen in accordance
with the requirements of the Comprehensive Environmental Response
Compensation and Liability Act of 1980 (CERCLA), 42 U.S.C. §§9601
et. seq.. as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 C.F.R.
Part 300. This decision document explains the factual and legal
basis for selecting the remedial action and is based on the
Administrative Record for this Site.
The Commonwealth of Virginia has had the opportunity to
comment on this remedy and their comments for the most part have
been incorporated.into this ROD.
XXX. ASSESSMENT OF THE SITE
Pursuant to duly delegated authority, X hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. § 9606, that actual
and threatened releases of hazardous substances from this Site,
as discussed in Part IX, Section VX (Summary of Site Risks) of
this ROD, if not addressed by implementing the remedial action
selected in this ROD, may present an imminent and substantial
endangerment to human health or the environment.
XV. DESCRIPTION OF THE SELECTED REMEDY
The Environmental Protection Agency (EPA), in consultation
with the Virginia Department of Environmental Quality (VDEQ), has
selected the following remedial action for the Buckingham County
Landfill Superfund Site (Site). This remedy addresses the
hazardous wastes and contaminated soils located in the four
onsite trenches as well as the plume of ground water
contamination.
The selected remedy includes the two following options, both
of which are fully protective of human health and the
environment:
-------
option 1 -
Option 2
Monitor the ground water and cap the hazardous
waste disposal area. 1£ ground water monitoring
detects migration of the plume, as defined below,
remove appropriate portions of the cap, implement
source control measures, replace the cap, and
treat the ground water.
Monitor the ground water, implement the source
control measures, and then cap the hazardous waste
disposal area. I£ ground water monitoring detects
migration of the plume, as defined below, treat
the ground water.
The selected remedy includes the following major components:
A ground water monitoring program to include
residential wells as well as bedrock and saprolite
monitoring wells shall be implemented. Samples shall
be collected at the points of compliance which shall be
no further than 150 feet from the edge of the cap. If
any analytical result from a ground water monitoring
sample collected at the points of compliance exceeds
the Safe Drinking Water Act Maximum Contaminant Level
(MCL) or the health-based contaminant level (if an MCL
has not been established) for any Site-related
contaminant, a confirmatory sample from the well where
the exceedance occurred shall be collected and analyzed
for all Site-related contaminants. If the analytical
results from the confirmatory sample also exceed the
MCL or health-based level, appropriate contingency
actions shall be invoked.
A RCRA multilayer cap over the hazardous waste disposal
area and the area south of the barrel trench shall be
constructed. The cap shall not extend beyond the
disposal trenches and previously capped area south of
the barrel trench.
Excavation and offsite incineration of the waste layer
and contaminated soils in the eastern disposal trench
(approximately 675 cubic yards). This source control
action would be implemented as part of the contingency
requirements under Option 1. Under Option 2, this
action would be completed prior to cap construction.
II it is determined via treatability studies that
Insitu Soil Vapor Extraction (ISVE) can effectively
remove contaminants from the waste layer, ISVE may be
used. However, if full scale ISVE cannot meet
performance standards set by EPA in this ROD,
excavation and offsite incineration as described above
must be implemented.
-------
Excavation of test pits and sampling will be conducted
in the barrel trench; information gained from these
activities will be used to prepare a Focused
Feasibility Study (FFS). EPA will issue a subsequent
decision document regarding source control measures for
%his trench. This action will be implemented as part
of the contingency requirements under Option 1. Under
Option 2, this action would be completed prior to cap
construction.
Extraction and treatment of contaminated ground water
by air stripping to remove Volatile Organic Compounds
(VOCs) in order to contain the ground water plume; this
- action would be implemented as a contingency for both
Options l and 2.
Deed and access restrictions.
V. STATUTORY DETERMINATIONS
This 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. If Option 2 is
implemented or if the contingency requirements for Option 1 are
invoked, the selected remedy will utilize permanent solutions and
alternative treatment technologies to the maximum extent
practicable, and will satisfy the statutory preference for
remedies that employ treatment that reduces toxicity, mobility,
or volume as a principal element.
Because this remedy will result in hazardous substances
remaining onsite above health-based levels, a review will be
conducted within five years after initiation of remedial action
to ensure that the remedy continues to provide adequate
protection of human health and the environment.
peter H./4(ostmayer Data
Regional Administrator
Region III
-------
xi - nemo* moan __
COMIX HXDFXUI 011*0700 nn
Z. gita K»a«. Location
Tha Buckingham County Landfill Sita is located in central
BuckinghamtCounty, Virginia, near ths town of Spreuss's Corner,
about 1.5 ailes southwest of ths intersection of U.S. 60 and U.S.
IS on County Road 640 (ssa Figurs 1). Buckingham county is
locatad approximately 60 miles vest of Richmond, SO ailes sooth
of Charlottesvills, and 40 miles northeast of Lynchburg.
Ths land immediately surrounding ths Sits is rural sad
mostly forested. The property on vhich ths Sits is locatad is
owned by Buckingham County and consists of 125 vooded acres, with
approximately 8 open acres that ware used for disposal operations
(see Figure 2). When this Sits vas placed on tha national
Priorities List (HPL) it vas described as ths S-acra araa
surrounding tha hazardous and doaastic vaste disposal oparations.
For tha remainder of this document, "Site* vill refer to ths
hazardous waste disposal area and any surrounding areas onto
vhich hazardous substances have migrated.
Locally, tha Site is drained by tha Warner Branch of Cooper
Creek to tha south and by Coopar Creek, itself, to ths north. A
ditch drains tha immediate vicinity of tha landfill aad
discharges into an unnamed tributary of Warnar Branch. Although
there ara vatlands in tha Sita vicinity, these wstlands ara
upgradiant and not affected by tha Sita. Tha habitat for sa
endangered plant species (ths Small Whorled Pogonia) which is
considered a unique ecosystea, is present at tha Sits. Based on
ths results of s June 23, 1993 survey conducted by ths U.S. Fish
and Wildlife Service, it vas determined that this plant species
does not actually rasids onsits.
A majority of tha county's residences obtain potable vatar
from Troublesome Creek Reservoir. Although ths reservoir is
topographically lover than ths Sits, it is in a different
watershed. A ground vatar uss survay vas conducted as part of
tha Remedial Investigation (sss RI Report Figurs 3.17).
According to this survey, 52 persons vithia s one-mile radios of
ths Sita use private veils as their source of drinking vatar.
Tha closest dovngradient drinking vatar vail is located
approximately one third of a mils from ths Sits (2,000 feet).
There ara no reaidences onsits or directly adjacent to ths Sits.
Several residences uss sa alternate source of water for drinking
because of taste sad odor problems vhich ara due to naturally
occurring background concentrations of certain inorganics.
Tha Sits includes of a number of trenches sad a borrow* pit
used in hazardous vasts disposal oparations. Ths trenches
includs an evaporation trench, two disposal tranches, sad a
-------
-------
r
MMIIIC "Mlt !
-------
barrel trench. The area where the trenches are located is
approximately one to two acres in size, surrounded by a fence,
and is referred to in this document as the "hazardous waste area"
(see Figure 3). The borrow pit is located to the north of the
hazardous waste area. A solid waste landfill is located directly
south. The Remedial Investigation/Feasibility Study (RI/FS)
focused on the hazardous waste disposal area as well as the
surrounding 8-acre area.
II. Site History and Enforcement Activities
The Buckingham County Landfill facility was owned and
operated by Joseph Love (Love's Container Service) from 1962
until 1982. Mr. Love initially used the Site for disposal of
municipal solid waste. Between 1962 and 1972, Mr. Love collected
municipal solid wastes from Buckingham County and surrounding
counties which were disposed of at the Site. Mr. Love was issued
a Sanitary Landfill Permit (Number 83) by the Virginia State
Board of Health (VSBH) in November 1972, which covered
approximately 7 of the cleared acres of the property (shown in
Figure 2). He sold the solid waste portion of his business in
1976, but continued his commercial waste disposal operations.
The solid waste landfill was covered and closed in 1979 under the
supervision of the VSBH.
In 1977, the Sanitary Landfill Permit was modified to
allow for the disposal of 50 gallons per week of industrial
furniture making waste. This waste allegedly consisted of
lacquer paints, polyester filler, acrylic paints, and
nitrocellulose dust. In 1979, the VSBH approved an increase in
the quantities of "special11 wastes Mr. Love could accept to
30,000 to 40,000 gallons per month. In 1980, Mr. Love sought
interim status for his hazardous waste operations pursuant to
Section 3005 of the Resource Conservation and Recovery Act,
(RCRA). The waste was described on the Site's Notification of
Hazardous Waste .Activity form as ignitable hazardous waste
bearing the EPA hazardous waste number DOOl. In 1981 and 1982,
Mr. Love also received still-bottom waste at the Site from a
solvent recovery process. These wastes bore the EPA hazardous
waste numbers F003 and F005. The total quantity of waste
received and disposed of at the Site has not been clearly
established due to Mr. Love's incomplete record keeping
practices.
In general, operations in the hazardous waste area involved
the receipt of drummed liquid wastes, which were poured into the
evaporation trench. The evaporation trench was approximately 80
to 125 feet long, 10 to 20 feet wide, and 10 to 15 feet deep.
Based on information received from Mr. Love, the trench was
reportedly lined with a synthetic liner. However, no written or
physical evidence of this liner has been found. A tin roof
supported by wooden poles was installed over the evaporation
trench in 1980 to minimize dilution of the waste with rain. The
trench was periodically cleared of solid residues that remained
-------
L
n
-------
after evaporation and/or percolation. These residues were
transferred to one of the two disposal trenches. The disposal
trenches, which were each approximately 18 to 20 feet deep, were
unlined. The borrow pit supplied cover material for the entire
operation.
Based on information received from Mr. Love, the drums were
supposedly-emptied, crushed and placed in the barrel trench,
which was 400 feet long, 20 feet wide, and 14 feet deep. The
barrel trench was also unlined. This trench was never completely
filled during the operational life of the Site; the west end
remained open until the hazardous waste area was closed in 1983.
As described below, Schnabel Engineering Associates ("Schnabel")
was the firm hired to close the hazardous waste portion of the
Site. During closure, portions of empty crushed drums were
encountered south of the area previously believed to be the edge
of the barrel trench. Schnabel dug test pits in the area in
question which indicated that a combination of domestic wastes,
clean fill and empty crushed drums were present in this area.
Because of this discovery, the cover for the hazardous waste area
was extended to include the area where additional drums were
found.
Hazardous wastes were received at the site through February
1982. In April 1982, Buckingham County purchased the property
and disposal permit from Mr. Love. The County contracted
Schnabel to close the Site in accordance with state regulations.
The County submitted a closure/post-closure plan addressing the
hazardous waste area under State law to the Commonwealth in 1982.
Closure was begun in February 1983 and was completed in May 1983.
The closure plan called for installation of a cover constructed
of four layers: a layer of clay, a synthetic cover, a layer of
fine aggregate, and a layer of topsoil. This cover was installed
over what Schnabel determined to be each individual trench area.
Additionally, surface water diversion trenches were constructed
around the covered areas, and a fence was constructed around the
area of the trenches. Several monitoring wells were also
installed throughout the Site. The domestic solid waste landfill
was not addressed in this closure plan.
A number of EPA-led site investigations were conducted
between January 1983 and April 1989. In November 1984, the Site
was scored using the EPA Hazard Ranking System (HRS) in order to
determine its eligibility for inclusion on the National Priority
List (NPL). The score for the Site was 40.77. Sites which score
greater than 28.5 are eligible for inclusion on the NPL. The
Site was listed on the NPL on October 4, 1989. £sa 54 Fed.Reg.
41015 (October 4, 198*>).
An Administrative Order on Consent (AOC) between EPA and a
number of Potentially Responsible Parties (PRPs) was signed on
January 31, 1991, becoming effective on February 13, 1991. Under
this AOC, the PRPs were to conduct an RI/FS at the Site. The
purpose of the RI/FS is to identify the types, quantities and
locations of contaminants and to develop ways of addressing the
-------
contamination problems. Field work for the RI was conducted from
March through July 1992. The RI was accepted as final by EPA on
March 24, 1993. The FS was submitted on April 27, 1993 and
following modifications by EPA, became final on May 3, 1993.
III. Highlights of Community Participation
The RI/FS Report and the Proposed Remedial Action Plan
(PRAP) for'the Buckingham County Landfill Site were released to
the public for comment on May 5, 1993, in accordance with the
requirements of Sections 113(k), 117(a), and 121(f) of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended (CERCLA), 42 U.S.C. Sections 9613(k),
9617(a), and 9621(f). These documents were made available to the
public in the Administrative Record at both an information
repository maintained at the EPA Docket Room in Region III,
Philadelphia and the Buckingham County Library in Dillwyn,
Virginia. The notice of availability for these two documents was
published in the Farmville Herald on May 5, 1993. A public
comment period on the documents was held from May 6, 1993 to July
6, 1993.
In addition, a public meeting was held by EPA and the
Virginia Department of Environmental Quality (VDEQ) on May 25,
1993, at the Buckingham County High School Gymnasium in Dillwyn,
Virginia, in accordance with Section 117(a)(2) of CERCLA, 42
U.S.C. Section 9617(a)(2). At this meeting, representatives from
EPA presented the findings of the RI/FS and answered questions
about the Site and the remedial alternatives that were under
consideration at that time.
Following the public meeting held on May 25, 1993 and the
close of the first comment period on July 6, 1993, EPA evaluated
and considered comments that were received from all interested
parties. In response to concerns voiced by the community, EPA
developed two new alternatives and, on November 24, 1993, issued
an Addendum to the PRAP which opened a second public comment
period. Following issuance of the Addendum, EPA attempted to
schedule a public meeting on several different occasions starting
in January and these meetings were all cancelled due to inclement
weather. The second public meeting was held on April 26, 1994.
The purpose of this meeting was to present the new alternatives
to the community and to provide the community with an opportunity
to ask questions and offer comments on the new alternatives. The
second comment period closed on May 3, 1994.
Response to comments that related to the cleanup
alternatives being considered, including those expressed verbally
at the public meetings, are included in the Responsiveness
Summary, which is part of this Record of Decision (ROD).
IV. Scope and Role of Response Action
The selected alternative will address all media impacted by
the contamination at the Site including: contaminated trench
10
-------
materials, contaminated soils, and the contaminated ground water.
This response action, includes contingencies and a potential for
subsequent actions regarding remediation of the barrel trench.
EPA has determined that addressing the Site as separate operable
units for individual media is not warranted.
V. Extent of Contamination
A. General
The Rl field activities and analytical program were designed
to define the extent of contamination in the soils, disposal
trenches, ground water, surface water, sediments and leachate, as
well as identify migration pathways and provide data to support a
feasibility study of potential remedial actions. The following
tasks were completed at the Site:
Surface soil sampling;
Subsurface soil boring and sampling;
Hazardous characteristic testing;
Geophysical surveying;
Ground water monitoring well installation and sampling;
Hydraulic conductivity testing;
Leachate sampling.
A summary of the results from the RI sampling program is provided
below.
B. Surface and sub-surface soils
The contaminants found in the most significant
concentrations in the soils at the Site were Volatile Organic
Compounds (VOCs). Samples with the highest VOC concentrations
were collected within the hazardous waste area adjacent to or
near the base of the disposal trenches.
There was a single soil boring sample in the western
disposal trench. In this soil boring at approximately 10 feet
toluene, ethylbenzene, and styrene were detected at levels above
background. These same compounds and several others were
detected at lower levels in the 14 to 20 foot depth of that same
boring. Two borings were placed in the eastern disposal trench
and sampled at various depths. Samples from each boring
indicated extremely high levels of acetone, toluene, 2-butanone,
4-methyl-2-pentanone, ethylbenzene, styrene, and xylene.
Analysis of samples from two borings in the evaporation trench
indicated the presence of similar contaminants at concentrations
slightly above background levels. Three borings were placed in
the area south of the barrel trench. These samples also
11
-------
indicated levels of VOCs slightly above background levels.
However, these samples cannot be considered representative of the
barrel trench because they were not taken from within the trench
itself.
C. Waste characterization
Waste.material is present in the eastern disposal trench
from about'10 to 14 feet below grade. Elevated levels of VOCs
were noted to at least 24 feet below grade in the soils
underlying this waste material, indicating that the contaminants
in this waste are, or were at one time, mobile. A sample of the
waste material was tested and determined to exhibit the
characteristic of ignitability under RCRA (see 40 C.F.R.
§261.21(a)(i)and $3.6 of the VHWMR, VR $672-10-1) Moreover, the
RI reports that listed hazardous wastes bearing the EPA hazardous
waste numbers F001 and F005 were disposed of in the trenches (See
40 C.F.R. $261.31(a) and Appendix 3.1 to Part III of the VHWMR,
VR $672-10-1).
D. Ground water
Two rounds of ground water sampling were conducted.
Analytical results from both rounds indicated that several VOCs,
primarily chlorinated hydrocarbons, were detected at
concentrations above Safe Drinking Water Act Maximum Contaminant
Levels (MCLs)1 in a cluster of monitoring wells including MW-2B,
MW-2SL, and MW-2SU. These wells are located between the western
disposal trench and the barrel trench (MW-2 cluster). MCL
exceedances were also detected in MW-6S. Contaminants that
exceeded MCLs in the first round of ground water sampling
include: 1,1-dichloroethene, trichloroethene, 1,1,1-
trichloroethane, tetrachloroethene, and toluene. All of the
above six compounds in addition to the following contaminants
were detected at levels above the MCLs in the second round of
sampling: bromoform, cis-l,2-dichloroethene, 1,2-dichloroethane,
1,2-dichloropropane, styrene, bromodichloromethane, chloroform,
1,1,2-trichloroethane, and 1,4-dichlorobenzene. Table 2 shows
the levels of contaminants that were detected in ground water as
well as the MCL for these contaminants. Figure 4 depicts the
area where ground water is anticipated to have VOCs at levels
above MCLs.
1 Maximum contaminant levels are contaminant specific
drinking water standards applicable to certain public water
suppliers established under the federal Safe Drinking Water Act.
See 40 C.F.R. Part 141, Subpart B.
12
-------
MCL BXCEEDANCE8 IH OROUHD WATER
COHTAXXH&HT :
1, 1-dichloroethene
1,1, 1-tr ichloroethane
tr ichlor oethene
tetrachloroethene
toluene
bromoform
cis-1 , 2 -dichlor oethene
chloroform
1 , 2-dichloroethane
styrene
bromodichloromethane
1 , 2 -dichlor opropane
1,1, 2 -tr ichloroethane
1 , 4 -dichlor obenzene
MCL
(ug/1)
7
200
5
5
1000
100
70
100
5
100
100
5
5
75
GROOHD
WATER
(ug/1)
1400
6600
800
3700
5800
460
210
230
450
200
310
300
490
430
TABLE Z
Because the discrepancy between filtered and unfi1tered
ground water results for inorganic contaminants was significant,
the EPA Baseline Risk Assessment (BRA) established that filtered
metal samples were the most appropriate indicator of Site related
metals contamination. According to EPA guidelines, filtered data
may be selected for use in risk assessments if there is an
obvious discrepancy between concentrations in the filtered and
unfiltered ground water samples (USEPA, Exposure Point
Concentrations in Ground Water, Office of Superfund, Hazardous
Waste Management EPA/504/1-89/002). Although metals were
detected in monitoring wells at levels above background, no
dissolved metals were detected at levels above MCLs in the
filtered samples.
E. Leaohate
Leachate seeps, present at the base of the hazardous waste
area to the west, were found to contain elevated levels of
several metals as well as trace levels of VOCs. The metal
concentrations that were detected in the leachate are consistent
with metal concentrations noted in the MH-2 well cluster.
13
-------
-------
VI. ?MinmflP^ °^ Site Risks
A. Background
As part, of the RI/FS process, a Baseline Risk Assessment
(BRA) was prepared by EPA utilizing data from the RI. The
purpose of the BRA is to characterize the current and potential
threats to-human health and the environment in the absence of
remedial action (i.e., the "no action" alternative). These
threats may be posed by contaminants migrating in ground water or
surface water, released to the air, leaching through the soil,
remaining in the soil, or bioaccumulating in the food chain at
the Site.
Based on the BRA discussed below, 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.
B. Human Health Risks
1. ??]\^^fflinants of Concern
The initial step of the BRA was to compile a list of
indicator contaminants which represent a potential risk to human
health. The following contaminants of concern were judged to
contribute significantly to potential health risks at the Site:
1 , 2-dibromoethane acetone
l,2-dibromo-3-chloropropane methylene chloride
1, 1-dichloroethylene tetrachloroethylene
1,2-dichloropropane trichloroethylene
cis-l,3-dichloropropylene vinyl chloride
trans-1, 3-dichloropropylene 1, 1, 2-trichloroethane
1,1,2, 2-tetrachloroethane l , 2-dichloroethane
A description of the toxicological effects of each
contaminant of concern is as follows:
acetone; Primarily, acetone acts as an irritant and as a central
nervous system depressant.
l . 2-dibromo-3-chloropropanes The main target of l,2-dibromo-3-
chloropropane is the testes, causing reproductive effects. This
compound has also been implicated in cardiovascular disease.
l . 2-dibromoethanes This contaminant is classified by EPA as a
Group B2 - Probable Human Carcinogen. Additionally, 1, 2--
dibromoethane is a poison by ingestion, inhalation and dermal
contact. It is an eye and skin irritant, and has been implicated
in sterility in exposed workers. Prolonged exposure may cause
liver and kidney damage.
15
-------
1f2-dichloroethane: This contaminant is classified by EPA as a
Group B2 - Probable Human Carcinogen. In humans, systemic
effects of acute oral exposure to this compound include
bronchitis, hemorrhagic gastritis and colitis, blood cellular
damage, central nervous system depression and histological
changes in brain tissue.
lf1-dichlogoethvlene: This contaminant is classified by EPA as a
Group C - Possible Human Carcinogen. High levels of 1,1-
dichloroethylene are reported to cause a variety of adverse
health effects in animals, including liver, kidney, heart and
lung damage, as well as nervous system disorders and death.
1.2-dichloropropane; This contaminant is classified by EPA as a
Group B2 - Probable Human Carcinogen. Although exposure to 1,2-
dichloropropane has not been shown to be fatal in humans, case
studies have reported several adverse effects after inhalation
exposure, .including chest discomfort, cough, nose bleeds, acute
liver damage and depression.
cis-1.3-dichloropropvlene; This contaminant is classified by EPA
as a Group B2 - Probable Human Carcinogen. Following exposure in
animals, adverse impacts on the liver and kidney have been
observed. In humans, inhalation of this compound has caused lung
injury. Skin irritation has also been reported in exposed
workers.
trans-1.3-dichloropropylenet This contaminant is classified by
EPA as a Group B2 - Probable Human Carcinogen. Following
exposure in animals, adverse impacts on the liver and kidney have
been observed. In humans, inhalation of this compound has caused
lung injury. Skin irritation has also been reported in exposed
workers.
methylene chloride: This contaminant is classified by EPA as a
Group B2 - Probable Human Carcinogen. Methylene chloride is
readily absorbed by the lungs, and can be fatal to humans if
inhaled in sufficient quantities. Additionally, acute exposure
can affect vision, hearing, and motor skills.
1.1.2.2-tetrachloroethane; This contaminant is classified by EPA
as a Group C - Possible Human Carcinogen. In humans, ingestion
and inhalation of 1,1,2,2-tetrachloroethane is known to cause
nausea, vomiting and drowsiness.
tetrachloroethvlene; This contaminant is classified by EPA as a
Group B2 - Probable Human Carcinogen. The primary targets of
tetrachloroethylene are the central nervous system, liver, and
kidney. Toxic effects include dizziness, impaired memory,
confusion, tremors, hepatitis, and chronic kidney disease.
l.l.2-trichloroethane; This contaminant is classified by EPA as
a Group C - Possible Human Carcinogen. In animals, 1,1,2-
trichloroethane has been shown to affect the central nervous
system, liver, kidney and digestive tract.
16
-------
trichloroethvlene; This contaminant is classified by EPA as a
Group B2 - Probable Human Carcinogen. Symptoms of oral exposure
to trichloroethylene in humans include muscle weakness, vomiting,
and unconsciousness.
vinyl chloride; This contaminant is classified by EPA as a Group
A - Human Carcinogen. Vinyl chloride has been found to cause
cancer in the liver, brain, lungs, and blood system of humans.
It can also cause liver damage and an enlarged spleen.
2. Exposure Assessment
The goal of the exposure assessment is to determine the type
and magnitude of human exposure to the contaminants present at,
and migrating from, the Site. The exposure assessment was
conducted to estimate the Site risks if remedial action is not
taken.
To determine if human and environmental exposure to the
contaminants of concern might occur in the absence of remedial
action, an exposure pathway analysis was performed. An exposure
pathway has four necessary elements: 1) a source and mechanism
of chemical release; 2) an environmental transport medium; 3) a
human or environmental exposure point; and 4) a feasible human
or environmental exposure route at the exposure point. The
potential for completion of exposure pathways at the Site is
described in the following sections.
a. Transport Pathways
For any particular site, there may be a variety of potential
exposure routes, with either simple or complex pathways. The
simple pathways are of primary significance at this Site. Such
simple exposure routes for humans generally include consumption
of ground water, bathing with ground water, inhalation of VOCs in
ground water during showering, consumption of surface water,
bathing with or playing in surface water, ingestion of soil,
dermal exposure to soil, and inhalation of fugitive dust
emissions. The ingestion pathways are the most important at the
Site, based on Site contaminants and their distribution. Complex
exposure routes are significantly less important at the Site than
simple pathways because the primary contaminants have not been
shown to bioaccumulate. Furthermore, sampling data indicate that
only minimal migration of contaminants has occurred in any
environmental media to date.
The transport pathways evaluated at the Site include ground
water, soils, sediments, and leachate. Based on the results of
the sampling performed as part of the RI, the four primary areas
of contamination associated with the Site are as follows:
surface soils associated with the trench areas;
subsurface soils underlying the trench areas;
17
-------
waste materials in the trenches; and
ground water.
Only trespassers could potentially be exposed to
contaminated media. There are no residences onsite or directly
adjacent to the Site. However, there are an estimated 52 persons
living within one mile of the Site. The media that were sampled
outside the hazardous waste area include surface water, sediment,
leachate and surface soil.
With respect to ground water, there is currently no complete
exposure pathway to the contaminants detected in this media
because there are no onsite residents that use ground water for
potable supply. Ground water in the vicinity of the Site is
considered a potential drinking water supply, however, which
necessitates evaluation of future residential use of the Site to
support risk management decisions. Potential exposure to Site
contaminants by future residents adjacent to the Site may occur
via contact with ground water (if used for drinking supply),
surface soils, surface water, and sediment.
Buckingham County bought the Site and contracted to have it
closed in accordance with State regulations; closure was
completed in 1983. The Site closure plan called for installation
of four distinct layers of cover materials over each of the four
individual trenches located onsite. Soil borings obtained during
the RI in 1992 indicate that these trench covers currently do not
meet the design specifications outlined in the closure plan.
Additionally, to prevent infiltration of precipitation through
the contaminated materials present in the trenches, a more
effective cap design would have included the entire trench area
and not simply each individual trench. For the reasons discussed
above, the current cover materials on the trenches at this Site
are not adequate to protect human health and the environment.
b. Exposure Scenarios
The BRA was developed for the Site utilizing EPA
methodologies from the Risk Assessment Guidance for Superfund
(EPA/540/1-89/002) which is included in the Administrative Record
file. The BRA provides a conservative assessment of the
potential risks to humans associated with residential or
trespasser land use at the Site and subsequent exposure to
contaminated media. The potential exposure pathways that have
been evaluated are:
(1) Current use scenario: trespasser
(2) Future use scenario: residential
The current use scenario involves exposure of a trespasser
to Site contamination via incidental ingestion of surface soil,
dermal absorption of contaminants from surface soil, incidental
ingestion of surface water, dermal absorption of contaminants
18
-------
from surface water, incidental ingestion of sediments, dermal
absorption of contaminants from sediment, and dermal absorption
of contaminants from leachate.
The future use scenario involves exposure of a resident to
Site contamination via ingestion of ground water, inhalation of
VOCs from ground water, dermal absorption of contaminants from
ground water, incidental ingestion of surface soil, and dermal
absorption of contaminants from surface soil.
c. Exposure Point Concentrations
Reasonable Maximum Exposure (RME) concentrations have been
calculated for each of the contaminants of concern in ground
water, surface soil, surface water, sediments, and leachate.
Table 1 presents the RME concentrations for contaminants of
concern in each medium. The RME was calculated according to EPA
risk assessment guidance. The 95% upper confidence limit of the
arithmetic mean is considered the reasonable maximum exposure
concentration. If the 95% upper confidence limit of the
arithmetic mean exceeded the maximum detected concentration, then
the maximum concentration was substituted as the reasonable
maximum exposure concentration for the risk calculations.
3. Toxicity Assessment
a. Background
The purpose of the toxicity assessment is to review and
evaluate available information regarding the potential for site
specific contaminants to cause adverse health effects. As the
level of exposure (the dose) to contaminants increases, the
probability of an adverse effect (the response) also increases.
In the toxicity assessment, the dose-response relationship is
quantified so that site-specific exposure levels can be
correlated with the likelihood of an adverse health effect.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals. CPFs, which are expressed in units of (milligram
(mg)/kilogram (kg) per day)"1, are multiplied by the estimate
intake of a potential carcinogen, in mg/kg-day, to provide an
upper-bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. Cancer potency factors are
derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation
and uncertainty factors have been applied.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs, which are
19
-------
i I
I i
-------
expressed in unit* of mg/kg-day, are estimates or lifetime daily
exposure levels for humans, including sensitive individuals, that
arc expected to be without adverse health effects. Estimated
intakes of chamicals from anvironaantal madia (e.g., tha amount
of a.chaaical ingastad from contaminated drinking vatar) can ba
compared to tha RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied (e-^g., to account for the use of animal data to predict
effects on humans). These uncertainty factors help ensure that
the RfDs vill not underestimate the potential for adverse
noncarcinogenic effects to occur.
b« Rialc Characterization
Excess lifetime cancer risks for a contaminant are
determined by multiplying the intake level with the cancer
potency factor. These risks are probabilities that are generally
expressed in scientific notation (£*&«.* 1 * 10~*, otherwise
expressed as 1E-6). An excess lifetime cancer risk of 1 x 10~*
indicates that, as a plausible upper bound, over a 70-year
lifetime an individual has a one in one million chance of
developing cancer as a result of site-related exposure to a
carcinogen under the specific exposure conditions at a site.
Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (RQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). The Hazard Index for the Site
(HZ) is calculated by adding the HQs for all contaminants within
a medium or across all media to which a given population may
reasonably be exposed. The HZ provides a reference point to
gauge the potential significance of multiple contaminant
exposures within a single medium or across media. Any media with
a cumulative HZ equal to or greater than 1.0 is considered to
pose a potential risk to human health. The His for the future
land use scenario for this Site were separated into adult
resident and child resident.
Unacceptable cancer and systemic health risks were
identified with respect to the future residential use scenario
ri.e.. hypothetical future residents living adjacent to the Site
and using ground water for drinking, or migration of contaminated
ground water to existing residential wells). The excess lifetime
cancer risk determined under the future use exposure scenario
from incidental inhalation, incidental ingestion, and dermal
absorption of contaminants in ground water is 2.6 x 10"1. Zn
other words, if no remedial action is taken, those people who are
exposed to the contaminated ground water have a 26% chance of
developing cancer. Most of this visk is due to the ingestion of
VOCs in the contaminated ground water.
With respect to noncarcinogenic systemic risks a total HZ of
greater that one (1) was calculated based on a number of VOC's.
The HZ under a future residential exposure scenario, for an adult
21
-------
is 58 and for a child the HI is 112. VOCs, even though they are
not all carcinogens, could pose systemic health threats to
potential adult and child residents from exposure to ground water
under a future residential use scenario.
The evaluation of human health risks (both carcinogenic and
noncarcinogenic) from exposure to the ground water is intended to
provide a reference point for evaluating potential future ground
water expos'ures; it does not represent present day health risks
since the ground water contamination is confined to the area in
the immediate vicinity of the Site and no one is currently
exposed since there is no use of this portion of the aquifer as a
potable supply.
The BRA did not identify any direct unacceptable health
risks associated with the remaining Site media (contaminated
soils/trench materials, sediments, leachate, and surface water).
However, the trench materials and underlying contaminated soils
represent a continuing source of contaminants to ground water.
c. Environmental Risks
EPA evaluated the environmental problems at the Site in an
Ecological Risk Assessment (ERA). The possible areas of
environmental exposure were identified as: streams at ground
water discharge points, and leachate seeps. Observation of
ecological effects have been limited to observations during RI
activities. Because no tissue analyses or bioassays (either
acute or chronic) were performed, the assessment uses a
conservative approach with hazard indices based on statistically
derived concentrations of contaminants found onsite and in the
study area.
The ERA indicated that the following contaminants were found
at ecologically hazardous levels in one or more of the four major
media (ground water, surface water, sediment and leachate):
Aluminum Trans-1,3-Dichloropropylene
Arsenic Heptachlor
Beryllium Chlordane
Copper Butyl-benzene-phthalate
Mercury Methoxychlor
Lead Bis-(2ethylhexyl)Phthalate
The ERA concluded that the potential exists for impact to
ecological receptors due to threatened or actual releases of
hazardous substances from the Site. This assessment, based on
federal Ambient Water Quality Criteria as well as calculations of
hazard indices for the four major media, concludes that the Site
is the source of several contaminants that could pose a risk to
ecological receptors.
Actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
22
-------
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
VII. Description of Alternatives
In accordance with Section 300.430 of the NCP, 40 C.F.R.
Section 300.430(e) (9) , remedial response actions were identified
and screened for effectiveness, implementability, and cost during
the FS to meet remedial action objectives at the Site. The
technologies that passed the screening were assembled to form
remedial alternatives. The alternatives were then evaluated
using the nine criteria required by 40 C.F.R. Section
300. 430 (e) (9) . The FS evaluated a variety of technologies used
in the development of alternatives for addressing the sources of
contamination at the Site as well as the existing ground water
plume. According to the FS and additional information received
during the public comment period, the technologies and the
approaches' contained in the alternatives listed below were
determined to be the most appropriate for this Site. The
descriptions of Alternatives 1 through 8 are derived from the
descriptions in the FS. Alternatives 8A, 8B, and 8C were
developed after receipt of the final FS. The capital costs, the
Operation and Maintenance (O&M) costs, present worth costs, and
months to implement for each of the alternatives listed below are
estimates based on currently available information.
Elements
All of the alternatives will include a periodic review
pursuant to Section 121 (c) of CERCLA. Except for the "No Action"
alternative, the following controls are common to all of the
alternatives for the Site: revegetation; installation of
diversion ditches; long-term ground water monitoring; and
implementation of deed and access restrictions to prohibit future
residential development of the Site and areas immediately
surrounding the Site.
A. Alternative 1: NO ACTION
Capital Cost: $ -0-
Annual O&M Cost: $ -0-
Total Present Worth: $ -0-
Section 300.430 (e) (6) of the NCP requires that a "no
action" alternative be evaluated at every NPL site in order to
establish a baseline for comparison. Under this alternative, EPA
would take no further remedial actions at the Site to prevent
exposure to the contaminated media or to reduce risks at the
Site.
B. Alternative 1A: LIMITED ACTION
Capital Cost: $ 70,000
Annual O&M Cost: $ 46,000
Total Present Worth: $ 772,000
23
-------
Alternative IA would require limited additional action at
the Site to prevent exposure to the contaminated media and to
reduce risks at the Site. Contaminated trench materials found in
all four trenches would remain in place and the existing covered
areas would be graded and revegetated. Long-term monitoring of
both existing and additional ground water monitoring wells would
be performed to measure VOC concentrations over time. See Table
5.9 on page 5-48 of the Feasibility Study Report (FS) for the
assumptions made to estimate the cost of ground water monitoring
for this alternative.
C. Alternative 2: GROUND WATER EXTRACTION AND TREATMENT
Capital Cost: $ 680,000
Annual O&M Cost: $ 325,000
Total Present Worth: $5,673,000
Under Alternative 2, contaminated trench materials found in
all four trenches would remain in place and the existing covered
areas would be graded and revegetated. Extraction wells would be
constructed for the purpose of recovering contaminated ground
water. Actual well locations and pumping rates would be
determined after additional ground water studies were conducted
during remedial design. Contaminated ground water would be
pumped to an onsite treatment system which would consist of VOC
removal via an air stripping unit. Residuals from the air
stripping unit would be treated and disposed of in accordance
with Applicable or Relevant and Appropriate Requirements (ARARs).
Emissions from the air stripping unit would be treated via vapor
phase carbon adsorption. The treated water would then be
discharged to a nearby surface water body and would meet the
substantive requirements of a Virginia Pollution Discharge
Elimination System (VPDES) permit. All ground water wells would
be sampled bi-annually for the duration of the treatment period
(assumed to be 30 years). See Table 5.9 on pages 5-48 and 5-49
of the FS for the assumptions made to estimate the cost of ground
water recovery and treatment for this alternative.
D. Alternative 3: RCRA CAP AND GROUND WATER MONITORING
Capital Cost: $ 586,000
Annual O&M Cost: $ 46,000
Total Present Worth: $ 1,288,000
Time to construct: 8-12 months
Under Alternative 3, contaminated trench materials found
in all four trenches would remain in place. An approximately one
to two acre RCRA cap would be constructed over all four trenches,
the area south of the barrel trench, and the entire area of
assumed ground water contamination. Prior to cap construction
the existing cover on each individual trench area would be
removed. These materials would be used as fill where
appropriate. The cap would meet the design requirements for
hazardous waste landfill caps under VDEQ regulations as well as
24
-------
RCRA. The existing wells in the area would be abandoned prior to
cap installation. Surface water drainage patterns would be
revised to reflect the cap configuration. The estimated
implementation time for construction of the cap is 8-12 months.
Long-term ground water monitoring would be implemented as
described above for Alternative 1A.
E. Alternative 4: RCRA CAP AND GROUND WATER EXTRACTION
AND TREATMENT
Capital Cost: $ 1,196,000
Annual O&M Cost: $ 322,000
Total Present Worth: $ 6,146,000
Time to construct: 8-12 months
Under Alternative 4, contaminated trench materials found
in all four trenches would remain in place. This alternative
consists of the replacement of the existing cover materials with
a RCRA cap as described for Alternative 3. Long-term ground
water monitoring would be conducted and a ground water extraction
and treatment system would be designed and implemented, as
described above for Alternative 2.
F. Alternative 5: ONSZTE INCINERATION OF TRENCH MATERIALS
AND GROUND WATER MONITORING
Capital Cost: $ 39,124,000
Annual O&M Cost: $ 46,000
Total Present Worth: $ 39,826,000
Time to construct: 12-18 months
Alternative 5 is a source removal/treatment/disposal
alternative that includes excavating trench materials and
underlying soils, onsite incineration of these materials, and
backfilling the excavated areas with clean fill. Areas to be
excavated would include the existing cover over the trenches, the
waste materials in the evaporation, eastern disposal, western
disposal and barrel trenches, as well as underlying and
surrounding contaminated soils. All excavated materials (except
for the existing cover) would be incinerated in a mobile
incinerator that would be brought to the Site. The excavated
areas would be backfilled with previous cap materials and clean
fill. The estimated amount of time for excavation and onsite
incineration of the contaminated materials is 12 - 18 months.
The ground water would be monitored on a long-term basis as
described above for Alternative LA.
Since a RCRA cap is not included as part of this
alternative, the volume of trench materials and contaminated
soils to be excavated would be determined based on the soil
cleanup levels presented in the PRAP issued May 5, 1993.
Excavation of the trenches would continue until all waste
materials, as well as surrounding and underlying soils, with
contaminant concentrations above the soil cleanup levels
presented in the PRAP had been removed.
25
-------
The costs stated above for Alternative 5 (see Appendix A of
the FS) were estimated based on the following assumptions: (i)
residuals generated from incineration would be delisted and
disposed of onsite; and (2) these residuals would be used as
backfill making it unnecessary to obtain clean backfill material.
If delisting and onsite disposal of the residuals is not
possible, these residuals would have to be disposed of offsite
and alternate materials for backfill would have to be obtained.
Therefore,'the costs for this alternative would substantially
increase if offsite disposal is deemed necessary. If this were
the selected remedy, costs would also be higher than those listed
above because EPA would require excavation and incineration of
contaminated materials/soils from the western disposal trench,
which was not included as part of this alternative in the FS.
G. Alternative 6: ONSITE INCINERATION OF TRENCH MATERIALS
AND GROUND WATER EXTRACTION AND TREATMENT
Capital Cost: $ 39,725,000
Annual O&M Cost: $ 325,000
Total Present Worth: $ 43,903,000
Time to construct: 12-18 months
Alternative 6 consists of excavation and onsite
incineration of trench materials and contaminated soils as
described in Alternative 5. Long-term ground water monitoring
would be conducted and a ground water extraction and treatment
system would be designed and implemented, as described above for
Alternative 2.
H. Alternative 7: OFFSITE INCINERATION OF DRUMS AND ONSITE LOW
TEMPERATURE THERMAL DESORFTION OF REMAINING TRENCH
MATERIALS AND GROUND WATER MONITORING
Capital Cost: $ 24,661,000
Annual O&M Cost: $ 46,000
Total Present Worth: $ 25,363,000
Time to construct: 12-18 months
Alternative 7 consists of: (1) excavation of contaminated
trench materials found in all four trenches and soils exceeding
cleanup standards presented in the PRAP for VOCs; (2) offsite
incineration of drums from the barrel trench; (3) onsite
treatment via Low Temperature Thermal Desorption (LTTD) of the
remaining contaminated trench materials and contaminated soils;
and (4) long-term ground water monitoring.
This Alternative is similar to alternatives 5 and 6 in that
contaminated trench materials found in all four trenches and the
surrounding contaminated soils will be excavated. A mobile LTTD
unit equipped for hazardous waste treatment would be brought to
the Site to treat the excavated trench materials from the eastern
disposal trench, western disposal trench, and the evaporation
trench, as well as contaminated soils from the barrel trench.
The drums from the barrel trench would be transported offsite for
26
-------
incineration at a RCRA permitted incineration facility. For cost
estimation purposes it was assumed that the drums would be
transported to a permitted incineration facility in either
Coffeyville, Kansas, or Roebuck, South Carolina. The estimated
amount of time to implement this remedy is 12 - 18 months. The
ground water would be monitored on a long-term basis as described
for Alternative 1A.
*«,
The costs stated above for Alternative 7 (see Appendix A of
the FS) were estimated based on the following assumptions: (1)
residuals generated from the LTTD process would be delisted and
disposed of onsite; and (2) these residuals would be used as
backfill making it unnecessary to obtain clean backfill material.
If delisting and onsite disposal of the residuals is not
possible, these residuals would have to be disposed of offsite
and alternate materials for backfill would have to be obtained.
Therefore, the costs for this alternative would substantially
increase if offsite disposal is deemed necessary. If this were
the selected remedy, costs would also be higher than those listed
above because EPA would require excavation and treatment via LTTD
of contaminated materials/soils from the western disposal trench,
which was not included as part of this alternative in the FS.
I. Alternative 8: OFFSITE INCINERATION OF DRUMS, ON8ZTE LOW
TEMPERATURE THERMAL DESORPTION OF TRENCH MATERIALS,
AND EXTRACTION AND TREATMENT OF GROUND WATER
Capital Cost: $ 25,262,000
Annual O&M Cost: $ 325,000
Total Present Worth: $ 29,440,000
Time to construct: 12-18 months
Alternative 8 consists of: (l) excavation of contaminated
trench materials found in all four trenches and soils exceeding
cleanup standards presented in the PRAP for VOCs; (2) offsite
incineration of drums from the barrel trench; (3) onsite
treatment via Low Temperature Thermal Desorption (LTTD) of the
remaining contaminated trench materials as well as underlying and
surrounding soils; (4) ground water extraction and treatment and
(5) long-term monitoring of the ground water.
Alternative 8 is similar to Alternatives 5, 6, and 7 in
that contaminated trench materials found in all four trenches
would be excavated and treated. Alternative 8 consists of onsite
treatment via LTTD of trench materials and contaminated soils
from the eastern disposal tiench, western disposal trench and the
evaporation trench, as well as offsite incineration of drums from
the barrel trench, as described in Alternative 7.
Long-term ground water monitoring would be conducted and a
ground water extraction and treatment system would be designed
and implemented, as described above for Alternative 2.
27
-------
J. Alternative 8A: OPPSITE INCINERATION OF MATERIALS FROM
THE EASTERN DISPOSAL TRENCH, OFFSITE DISPOSAL OF THE
MATERIALS FROM THE BARREL TRENCH, RCRA CAPPING OF TRENCH
AREAS AND RECOVERY AND TREATMENT OF GRODNDWATER
Capital Cost: $ 18,962,697
Annual O&M Cost: $ 62,700
Total-Present Worth: $ 20,216,697
Time to construct: 14-24 months
Alternative 8A is a source removal/treatment/disposal
alternative that includes excavating and treating those trench
materials that are posing a principal threat2 and backfilling
these excavated areas with clean fill. Alternative 8A consists
of: (1) excavation of approximately 2,531 yd3 of waste and
contaminated soils from the eastern disposal trench and
incineration at an offsite RCRA-permitted facility; (2)
excavation of drums and associated material from the barrel
trench (approximately 6,858 yd3 in volume) with offsite treatment
and/or disposal of hazardous substances at a RCRA-permitted
facility and onsite or offsite disposal of non-hazardous
substances; (3) removal of the existing cover material from each
individual trench and construction of a RCRA cap over the entire
area of the trenches and the area south of the barrel trench; (4)
extraction and treatment of the contaminated ground water with
the goal of restoration of the aquifer to beneficial use; and (5)
long-term monitoring of the ground water.
Volumes to be excavated from the eastern disposal and barrel
trenches were calculated based on historical and soil boring
data. Dust control, air monitoring, and VOC emissions control
would be performed while contaminated trench materials were being
excavated. The excavated materials would be handled in
accordance with any applicable and relevant or appropriate RCRA
requirements.
For this Alternative, a RCRA cap would be constructed over
the entire trench area where the hazardous waste disposal
operations occurred, as well as the area south of the barrel
trench (see figure 3). Unlike Alternative 3, Alternative 8A does
not require the area of expected ground water contamination to be
capped. The cap would meet the design requirements for hazardous
waste landfill caps under VDEQ regulations as well as RCRA
requirements.
2 Principal threat wastes are defined as those source
materials considered to be highly toxic or highly mobile that
would present a significant risk to human health or the
environment should exposure occur. The National Oil and
Hazardous Substances Pollution Contingency Plan
300.430(a)(1)(iii)(A) indicates that principal threats should be
treated whenever practical.
28
-------
Alternative 8A includes installation of a ground water
extraction and treatment system similar to the one described for
Alternative 2. The groundwater extraction and treatment system
would remain in operation until the aquifer is restored to its
beneficial use. For cost estimation purposes this time period is
assumed to be 30 years. The cost estimate for Alternative 8A can
be found in the Administrative Record.
K. Alternative 8B: LIMITED EXCAVATION ALTERNATIVE
AND GROUND WATER MONITORING
Capital Cost: $ 5,399,000
O&M Cost (present worth): $ 2,815,000
Total Present Worth: $ 9,293,800
Time to construct: 14-24 months
Alternative 8B consists of: (1) excavation of an estimated
675 yd3 of" concentrated waste from the eastern disposal trench
and offsite incineration of waste materials at a RCRA-permitted
facility; (2) test pits would be excavated in the barrel trench
with disposal of non-empty drums and associated hazardous
material from this trench; (3) construction of a RCRA cap over
the entire hazardous waste disposal area as well as the area
south of the barrel trench; and (4) installation of a long-term
ground water monitoring network using "trigger wells" with a
contingency requirement to extract and treat ground water.
The goal of excavation for Alternative 8B in both the
eastern disposal trench and the barrel trench is to remove the
concentrated waste sources which are considered to be a principal
threat at the Site. The volume of hazardous material to be
excavated from these trenches would be reduced from that of
Alternative 8A without decreasing the effectiveness of the
remedy.
A distinct layer of waste is present in the eastern disposal
trench from approximately 10 to 14 feet below grade (RI p.4-70).
This layer is approximately 4 feet thick. In addition to the
waste layer, one foot of soil both above and below the layer
would be removed. The total thickness of the excavated materials
is estimated at 6 feet. The dimensions of this trench are 75
feet by 30 feet. The total depth of the excavation would be
approximately 15 feet. The estimated volume of waste to be
excavated from the eastern disposal trench is 675 yd3.
The waste materials found in the eastern disposal trench are
grossly contaminated. Table 3 identifies the contaminants found
in the eastern disposal trench and their concentrations. The
excavated materials from the eastern disposal trench will be
treated at an offsite, RCRA permitted, hazardous waste
incineration facility.
29
-------
TABLE 3- CONTAMINANT LEVELS IN
THE EASTERN DISPOSAL TRENCH
CONTAMINANT:
acetone
2-butanone
benzene
4 -me thy 1 - 2 -pent anone
toluene
ethylbenzene
styrene
xylene
LEVEL (ug/kg)
14,000
140,000
28,000
340,000
330,000
30,000
80,000
86,000
The barrel trench is a suspected source of ground water
contamination. Since there were no samples obtained from within
this trench during the RI, there is no conclusive data available
to indicate otherwise. Therefore, as part of Alternative 8B, a
representative number of test pits would be excavated in the
barrel trench in accordance with a work plan that would be
subject to approval by EPA in consultation with VDEQ. The
purpose of the test pits will be to provide a representative
evaluation of the condition of drums buried throughout the barrel
trench, to determine if the buried drums are empty, and to
determine the levels of contaminants in the waste materials and
soils in this trench. The materials from this trench would be
sampled and analyzed. Remediation of the barrel trench would
include excavation of drums with offsite treatment and or
disposal of hazardous materials (e.g.. drums, drum contents,
incidental soils or debris) and onsite or offsite disposal, as
necessary, of non-hazardous materials. The barrel trench was
approximately 400 feet long, 20 feet wide, and 14 feet deep.
Estimated excavation depth is 15 feet. The estimated volume of
waste to be excavated from the barrel trench is 6,000 yd3.
For cost estimation purposes, assuming that excavation of
the entire barrel trench is necessary, it is anticipated that
less than 50% of this material will need to be incinerated or
disposed of at a RCRA Subtitle C hazardous waste landfill
facility. The remaining non-hazardous materials from the barrel
trench will either be decontaminated and allowed to remain onsite
(beneath the RCRA cap) or transported offsite to a RCRA Subtitle
D facility.
A RCRA cap would be constructed over the entire area of the
trenches and the area south of the barrel trench, as described
under Alternative 8A.
30
-------
The long-term ground water monitoring program included in
this alternative is more extensive than the program described for
Alternative 1A. In order to design an effective ground water
monitoring system that can verify that the existing ground water
contamination is not migrating offsite, additional study of the
ground water during remedial design will be necessary. The goals
of this additional study will be to further characterize the
horizontal-and vertical extent of the plume of ground water
contamination, the rate and direction of migration, and specific
contaminant concentrations.
The monitoring program is intended to verify that the
existing contaminated ground water has not migrated beyond the
points of compliance, which have been defined as no further than
150 feet beyond the edge of the RCRA cap. The "trigger wells"
will be placed at the most ideal locations no further than 150
feet beyond, the edge of the cap. Placement of these wells will
be based on information obtained during design and will be
subject to EPA approval. In the event that migration of the
ground water plume to the points of compliance is detected by the
"trigger wells", a ground water extraction and treatment system,
as described for Alternative 8A, would be implemented. The goal
of this system would be to contain the plume within the
designated points of compliance and to comply with cleanup
requirements in the area of attainment beyond the points of
compliance.
The ground water monitoring wells included in the monitoring
program would be sampled and analyzed for VOCs and metals.
Sampling on a quarterly basis for a minimum of three years would
be required. If, twelve (12) consecutive rounds of sampling
demonstrate that Site-related contaminants are not present above
MCLs, or risk-based contaminant levels3 if MCLs have not been
established, at the points of compliance, EPA may determine that
sampling frequency can be reduced to bi-annually. The
downgradient residential wells closest to the Site, would be
sampled as frequently as the monitoring wells. The monitoring
will include, but not be limited to, the requirements of Sections
10.5 and 10.6 of the Virginia Hazardous Waste Management
Regulations [VHWMR], (VR §672-10-1). The ground water monitoring
will be performed for at least thirty years, in accordance with
the VHWMR.
The cost estimate listed above for Alternative 8B does not
include the cost for the ground water containment system. Table
4 provides a cost estimate summary for Alternative 8B and Table 5
provides the total cost of Alternative 8B along with the costs
associated with the ground water contingency requirement.
Documentation for these cost estimates is in the Administrative
Record.
3 In cases where the risk-based contaminant level is lower
than the detection limit, the detection limit would be used as
the standard.
31
-------
TABLE 4- COST ESTIMATE SUMMARY FOR ALTERNATIVE 8B
ITEM:
Mobilization
Eastern Trench
Barrel Trench
RCRA Cap
Install GW
Monitor System
Decon
Demobilization
Capital Costs
Contingencies
(20%)
O&M Present
Worth
TOTAL COST
QUANTITY
1
675
6000
2
1
1
1
UNIT
LS
yd3
yd3
acre
LS
LS
LS
UNIT COST
N/A
3,360
310
N/A
N/A
N/A
N/A
COST ($)
161,000
2,268,000
1,860,000
578,000
330,000
95,000
107,000
TOTAL: 5,399,000
1,079,800
2,815,000
$ 9,293,800
TABLE 5- ALTERNATIVE 8B PLUS CONTINGENCY COST
INSTALL GW EXTRACTION AND TREATMENT
CONTINGENCIES (20%)
TOTAL CAPITAL COST
INCREASE IN O&M (PRESENT WORTH)
ALTERNATIVE 8B - NO CONTINGENCY
TOTAL POTENTIAL COST
$
$
$
$
$
$
430,000
86,000
516,000
1,900,000
9,293,800
11,709,000
L.
Alternative 8C: INSITU VAPOR EXTRACTION (ISVE)
AND GROUND HATER MONITORING
Capital Cost:
Cap/Monitor O&M Cost:
ISVE O&M (18 months):
Total Present Worth:
Time to Construct:
$ 3,731,000
$ 2,815,000
$ 700,000
$ 7,992,200
32-42 months
Alternative 8C includes treatment of the waste materials in
the eastern disposal trench via In Situ Vapor Extraction (ISVE)
32
-------
using horizontal wells. The ISVE process involves the removal of
VOCs from soils and wastes, in-place. Therefore, no excavation
or offsite transportation of wastes is necessary. The ISVE
system would involve the installation of a horizontal well into
the contaminated waste layer in the eastern disposal trench. A
vacuum pump is attached to the well to withdraw air from the
contaminated area. This air is then transported through the well
to the surface. The contaminants in the extracted air are then
subjected to onsite treatment. The method of treatment (e.g.
activated carbon, catalytic oxidation, etc.) will be determined
during remedial design.
A pilot scale treatability would be performed for ISVE in
the eastern disposal trench during the remedial design to
determine if ISVE can effectively remove contaminants from the
waste layer. The treatability study would need to demonstrate
the following:
1) adequate air flow can be achieved throughout the waste
layer;
2) ISVE can meet the performance standards described
below;
3) an effective method for measuring performance of the
system can be developed and implemented.
If EPA determines that the treatability study successfully
meets the above criteria then full scale ISVE may be implemented.
ISVE will continue until contamination levels in the waste layer
and surrounding soils are no longer a source of contamination to
underlying ground water which results in ground water
contamination above MCLs, or health-based contaminant levels4 if
MCLs have not been established. The cleanup criteria will be
determined during the remedial design by considering the
characteristics of the waste layer and contaminated soils and
associated contaminants and then deriving specific levels of
contaminants in the waste layer and surrounding soils that would
not be expected to exert a significant impact on underlying
ground water.
If EPA determines that the treatability study does not
successfully meet the criteria listed above or if full scale ISVE
in the eastern disposal trench can not meet the performance
standards described above, excavation and off-site incineration
would be implemented for the eastern disposal trench as described
for Alternative 8B.
If ISVE is deemed feasible and implemented full scale, the
emissions from the ISVE unit would be treated and monitored to
ensure that unacceptable levels of contaminants would not be
released to the atmosphere. Residuals from the treatment process
4 In cases where the risk-based contaminant levels are lower
than the detection limits, the detection limits would be used as
the standard.
33
-------
(e.g. spent carbon, etc.) would be handled in accordance with
substantive requirements of federal and state hazardous waste
regulations or treated/disposed of offsite at a RCRA-permitted
hazardous waste disposal facility. The ISVE unit would be
operated in accordance with applicable and relevant and
appropriate requirements of federal and state hazardous waste
management regulations and Virginia Air Pollution Control
regulations.
Test pits would be dug in the barrel trench and hazardous
materials, if present, would be removed and treated as described
for Alternative 8B. If no hazardous wastes are present in this
trench, then the test pits would be filled in and the trench
would be capped along with the rest of the Site. A RCRA cap
would be constructed over the entire area of the trenches and the
area south of the barrel trench, as described under Alternative
8A.
The long-term ground water monitoring using "trigger wells"
is included in this alternative and is the same as described for
Alternative 8B. This monitoring program is intended to verify
that the existing contaminated ground water is not migrating and,
if migration is detected, the ground water contingency action
will be implemented to contain the plume as described for
Alternative 8B.
The cost estimate listed above for Alternative 8C does not
include the contingency costs for excavation and incineration of
waste materials in the eastern disposal trench or the ground
water containment system. Table 6 provides a cost estimate
summary for Alternative 8C and Table 7 provides the total cost of
Alternative 8C along with the costs associated with the
contingency requirements for this alternative. Documentation for
these cost estimates is in the Administrative Record.
34
-------
TABLE 6- COST ESTIMATE SUMMARY FOR ALTERNATIVE 8C
ITEM:
Mobilization
Eastern Trench
Barrel Trench
RCRA Cap
Install GW
Monitor System
Decon
Demobilization
Capital Costs
Contingencies
(20%)
QUANTITY
1
1
1
2
1
1
1
UNIT
LS
LS
LS
acre
LS
LS
LS
UNIT
COST
N/A
N/A
N/A
N/A
N/A
N/A
N/A
COST ($)
161,000
600,000s
1,860,000
578,000
330,000
95,000
107,000
TOTAL: 3,731,000
746,200
Operation & Maintenance:
ISVE
Cap and Monitor
TOTAL COST
1
1
LS
LS
N/A
N/A
700, OOO6
2,815,000
$ 7,992,200
5 This figure for the cost of ISVE was supplied by the PRPs.
This cost estimate is for full scale ISVE and assumes that the
treatability study for ISVE proves that this technology is
feasible. Treatability study costs are not included in this
estimate.
35
-------
TABLE 7 - ALTERNATIVE 8C PLUS CONTINGENCY COST
EXCAVATION/TREATMENT OF EASTERN TRENCH
' INSTALL GW EXTRACTION AND TREATMENT
INCREASE IN MOB /DECON/ DEMOB
SUBTOTAL
CONTINGENCIES (20%)
TOTAL CAPITAL COST
INCREASE IN O&M (PRESENT WORTH)
ALTERNATIVE 8C - NO CONTINGENCIES
TOTAL POTENTIAL COST
$
$
$
$
$
$
$
$
$
2,268,000
430,000
100,000
2,798,000
559,600
3,357,600
1,900,000
7,992,200
13,249,800
Alternatives 1 through 8C were retained for detailed
analysis. Alternatives 9 and 10 described in the FS, were
screened from further consideration because at this time there
are no offsite incineration facilities available that have the
capacity to treat the large volume of materials involved with
these alternatives and relative costs of these alternatives were
significantly higher than other alternatives of comparable
effectiveness. Alternatives 8B and 8C were developed based on
comments from the community and information gained from
interested parties during the first public comment period (May 5,
1993 - July 6, 1993).
VIII. Summary of Comparative Analysis of Alternatives
The twelve remedial action alternatives described above were
assessed in accordance with the nine evaluation criteria as set
forth in the NCP at 40 C.F.R. Section 300.430(e)(9). These nine
criteria are categorized below into three groups: threshold
criteria, primary balancing criteria, and modifying criteria.
THRESHOLD CRITERIA
1. Overall protection of human health and the environment;
and
2. Compliance with applicable or relevant and appropriate
requirements (ARARs).
PRIMARY BALANCING CRITERIA
3. Long-term effectiveness and permanence;
4. Reduction of toxicity, mobility, or volume through
treatment;
5. Short-term effectiveness;
6. Implementability; and
7. Cost.
36
-------
MODIFYING CRITERIA
8. State acceptance; and
9. Community acceptance.
^
These evaluation criteria relate directly to requirements in
Section 121 of CERCLA, 42 U.S.C. Section 9621, which determine
the overall feasibility and acceptability of the remedy.
Threshold criteria must be satisfied in order for a remedy
to be eligible for selection. Primary balancing criteria are
used to weigh major trade-offs between remedies. State and
community acceptance are modifying criteria formally taken into
account after public comment is received on the Proposed Plan. A
summary of the relative performance of the alternatives with
respect to each of the nine criteria follows. This summary
provides the basis for determining which alternative provides the
"best balance" of tradeoffs with respect to the nine evaluation
criteria.
A. overall Protection of 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 current and
potential risks to acceptable levels within the established risk
range posed by each exposure pathway at the Site.
Alternatives 6 and 8 are fully protective of human health
and the environment. These alternatives achieve this protection
through excavation, treatment, and proper disposal of the
contaminated trench materials found in all four trenches as well
as extraction and treatment of contaminated ground water. These
alternatives eliminate all sources of contamination at the Site
and, therefore, eliminate the potential for further degradation
of ground water quality. Protection from exposure to
contaminated ground water would be achieved through a ground
water extraction and treatment system.
Alternatives 8A, 8B, and 8C are fully protective remedies.
Protection of human health and the environment is provided by
these remedies in a variety of ways. All of these alternatives
include treatment of the primary source of contamination at the
Site (the eastern disposal trench and the barrel trench)) and,
therefore, eliminate the potential for this source to further
degrade ground water quality. Additionally, the RCRA cap for all
three of these alternatives will decrease the infiltration of
precipitation through the remaining areas of low level
contamination at the Site and thereby curtail continuing
degradation of the aquifer. For each of these alternatives,
protection from exposure to contaminated ground water will be
provided through a ground water monitoring network, as well as
deed and access restrictions. To provide additional protection,
Alternative 8A includes implementation of a ground water
extraction and treatment system. Alternatives 8B and 8C include
ground water extraction and treatment in the event that the plume
37
-------
migrates to the points of compliance.
Alternatives 2 and 4 provide protection of human health and
the environment. For both of these alternatives, the source of
the ground-water contamination would be allowed to remain onsite.
Protection from exposure to such contaminated ground water would
be provided through implementation of a ground water extraction
and treatment system, as well as, deed and access restrictions.
For Alternative 4, the RCRA cap will decrease the infiltration of
precipitation through the contaminated waste materials in the
trenches and thereby curtail continuing degradation of the
aquifer.
Alternatives 3, 5, and 7 may not provide protection of human
health and the environment due to the fact that extraction and
treatment of the ground water is not included in these remedies.
Monitoring of the ground water in all three of these alternatives
will allow EPA to detect movement of the contaminated ground
water, however, additional actions would be required to prevent
exposure to the plume. As long as the contaminated ground water
plume does not migrate beyond the points of compliance,
Alternatives 5 and 7 will provide protection by eliminating all
potential sources of ground water contamination and the
Alternative 3 will provide protection by decreasing the
infiltration of precipitation through the contaminated waste
materials in the trenches.
Alternatives 1 and 1A are not protective of human health and
the environment. Under Alternative 1, contaminated trench
materials found in all four trenches would remain in place and no
actions would be taken to address the potential threats posed by
either the contaminated trench materials or contaminated ground
water. Alternative 1A includes long-term ground water
monitoring, as well as, deed and access restrictions, however,
should the plume migrate further offsite, this alternative does
not provide a mechanism for treating or containing contaminated
ground water. Also under Alternative 1A, all contaminated
trench materials found in all four trenches and contaminated
soils would remain onsite. For the reasons discussed above, both
Alternatives 1 and 1A are not protective of human health and the
environment and thus, can not be evaluated further.
B. Compliance with ARARs
This criterion addresses whether a remedy will meet all of
the Applicable or Relevant and Appropriate Requirements (ARARs)
of other environmental statutes and/or provide grounds for
invoking a waiver under the NCP at 40 C.F.R.
300.430(f)(1)(ii)(C).
All alternatives that are protective of human health and the
environment would be in compliance with existing Federal and
State ARARs.
38
-------
C. Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to the
expected residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment over
time, once the cleanup levels have been met. This criterion
includes the consideration of residual risk and the adequacy and
reliability of controls.
Alternatives 6 and 8 afford the highest degree of long-term
effectiveness because all contaminated soils and waste materials
would be excavated, treated and properly disposed of either on-
or off-site and the contaminated ground water would be extracted
and treated. Alternatives 5 and 7 are effective in the long term
because all contaminated soils and waste materials would also be
addressed as described above, however, these alternatives do not
provide for extraction and treatment of the ground water.
Alternatives 8A, 8B, and 8C are effective in the long term
because these alternatives use treatment to eliminate principal
threats posed by waste materials present in onsite trenches.
Potential risk from concentrated waste sources present in the
eastern disposal trench and barrel trench would be eliminated
after implementation of these alternatives and their
contingencies. The long-term risk of contaminants leaching from
areas of low level contamination at the Site would be reduced via
capping. Implementation of ground water extraction and
treatment, either immediately as in Alternative 8A or as a
contingency as in Alternatives 8B and 8C, further increases the
long-term effectiveness of these alternatives. Proper
maintenance of the cap, along with institutional controls would
be necessary to ensure the overall long term effectiveness of
these alternatives.
Alternative 4 provides a moderate degree of long-term
effectiveness. This alternative allows all contaminated wastes
to remain at the Site and relies solely on a cap to reduce the
long-term risk of contaminants leaching from both areas posing a
principal threat and areas posing low level threats at the Site.
This alternative also has cap maintenance requirements which are
highly critical to the effectiveness of the remedy since all of
the wastes would remain under the cap without prior treatment.
However, the ground water extraction and treatment measures
included in this alternative increases its long-term
effectiveness
Alternative 2 provides a low degree of long-term
effectiveness. Ground water extraction and treatment measures
included in this alternative provide for long-term effectiveness,
however, no treatment or containment of the contaminated wastes
onsite would be provided under this alternative.
Alternative 3 provides the lowest degree of long-tern
effectiveness. Although the cap included in this alternative
would reduce the long-term risk of contaminants leaching from the
waste materials in the trenches into the ground water, this
39
-------
alternative lacks ground water extraction and treatment measures
which decreases its long-term effectiveness.
D. Reduction of Toxicity, Mobility, or Volume through
Treatment
This evaluation criterion addresses the degree to which a
technology or remedial alternative reduces the toxicity,
mobility, or volume of a hazardous substance. Although 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 expects to use a combination of
treatment and engineering controls, such as containment measures,
to achieve protection of human health and the environment, as set
forth in the NCP at 40 C.F.R. Section 300.430(a)(iii).
Alternatives 6 and 8, would provide the most significant
reduction of toxicity, mobility, and volume through treatment
because all of the contaminated waste materials in the potential
source areas would be excavated and treated. For Alternative 6,
this reduction would be achieved via onsite incineration of all
of the excavated trench materials and underlying soils. For
Alternative 8, this reduction would be achieved via offsite
incineration of the drums from the barrel trench and via onsite
LTTD of the remaining contaminated waste material and soils. The
treatment processes discussed above would significantly reduce
toxicity, mobility, and volume of the potential sources at the
Site and leave relatively little residual risk. Additionally,
both Alternatives 6 and 8 include extraction and treatment of the
contaminated ground water which further reduces toxicity,
mobility, and volume of contamination through treatment.
Alternatives 8A, 8B, and 8C would provide reduction of
toxicity, mobility, and volume through treatment, but to a lesser
degree that Alternatives 6 and 8. For Alternatives 8A through
8C, treatment measures are focused on the eastern disposal trench
which appears to represent the primary source of contamination at
the Site. For Alternatives 8A and 8B, reduction of toxicity,
mobility, and volume would be achieved in the eastern disposal
trench through offsite incineration. For Alternative 8C,
reduction of toxicity and mobility would be achieved in the
eastern disposal trench through ISVE using horizontal wells. In
addition to the treatment measures described above, Alternatives
8A, 8B, and 8C also utilize a RCRA cap to contain the waste and
soil contamination which reduces the mobility of the remaining
low level threats.
Under Alternative 8A, the barrel trench, which is also a
potential source area would be excavated and, if drums containing
wastes are found, then these drums would be incinerated offsite
thereby, further reducing toxicity, mobility, and volume of
contaminants via treatment. For Alternatives SB and 8C, test
pits would be excavated in the barrel trench to determine if
hazardous wastes are present. If found, the remaining portions
of the barrel trench would be excavated and offsite treatment
40
-------
and/or disposal of hazardous wastes would follow, thereby further
achieving reduction of toxicity, mobility and volume. Also,
under Alternative 8A and as a contingency for Alternatives 8B and
8C, the contaminated ground water would be extracted and treated,
thereby further achieving reduction of toxicity, mobility and
volume of contaminants through treatment.
Alternatives 5 and 7, would provide reduction of toxicity,
mobility, and volume through treatment because all of the
contaminated waste materials in the potential source areas would
be excavated and treated. For Alternative 5, this reduction
would be achieved via onsite incineration of all of the excavated
trench materials and underlying soils. For Alternative 7, this
reduction would be achieved via offsite incineration of the drums
from the barrel trench and via onsite LTTD of the remaining
contaminated waste material and soils. The treatment processes
discussed above will significantly reduce toxicity, mobility, and
volume of the potential sources at the Site and leave relatively
little residual risk. However, neither Alternatives 5 nor
Alternative 7 include extraction and treatment of the
contaminated ground water.
Alternatives 2 and 4 do not propose any waste or soil
treatment and would therefore not reduce the toxicity, mobility,
or volume of these media through treatment. However, Alternative
4 includes a cap which would be used to contain the waste and
soil contamination to reduce mobility and both Alternatives 2 and
4 include extraction and treatment of the ground water which
reduces the toxicity, mobility, and volume of contamination in
the ground water.
Alternative 3 does not include any form of treatment for the
source areas at the Site, instead a RCBA cap would be used to
contain the waste and soil contamination, therefore reducing
mobility.
E. Short-Term Effectiveness
This evaluation criterion addresses the period of time
needed to achieve protection of 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. The time for completion of the remedial actions for
each of the alternatives listed below does not include the time
for long-term monitoring, which will be required for all of the
alternatives. All of the timeframes listed below are estimates.
The primary short-term effects associated with each of the
source control alternatives are possible exposure to air borne
contaminants generated during excavation and exposure to physical
safety hazards that exist around heavy equipment. Air-borne dust
containing VOCs could be generated during soil waste excavation
required for Alternatives 5 - 8C. The extent of soil/waste
excavation is highest under Alternatives 5-8 and lowest under
Alternatives 8B and 8C. Additional dust could be generated
during soil/waste handling and operation of treatment units
41
-------
onsite, particularly under Alternatives 5-8.
Release of air-borne contaminants would be expected to be
minimal under Alternatives 3 and 4, because land disturbing
activities-would involve surface soils which may contain low
levels of contamination and buried waste materials would not
disturbed. Measures would be taken to control dust during
implementation of not only Alternatives 3 and 4, but also
Alternatives 5 - 8C. These measures would be detailed in the
Remedial Action Work Plan and the associated Health and Safety
Plan which must be prepared and approved by EPA prior to
initiation of construction. These measures would include, but
not be limited to, (1) dust suppression during excavation,
handling, and treatment activities, (2) air monitoring before and
during remedial activity, and (3) the use of specialized
equipment, engineering controls, and experienced and trained
personnel.
Because transportation of materials offsite is involved for
Alternatives 7, 8, and 8A, as well as 8B and 8C (if hazardous
wastes were found in the barrel trench), there would be an
increase in truck traffic in the vicinity of the Site and along
the transportation route during implementation of the remedy.
Increased truck traffic may result in a greater potential for
accidents along the transportation route, although it is unlikely
that any accident would pose a serious health threat to residents
along that route. To minimize the potential for accidents, truck
traffic would be strategically spaced throughout the remedial
action and all Virginia. Department of Transportation (VDOT)
regulations regarding the transportation of hazardous wastes
would be adhered to.
Implementation of Alternatives 3 and 4 would take the least
amount of time. Although Alternative 2 would take less that six
months to construct, implementation of this ground water
treatment remedy would be ongoing for at least 30 years.
Alternatives 5 through 8 are expected to take approximately one
to two years to construct, however, implementation of the ground
water treatment components for Alternatives 6 and 8 would be
ongoing for at least 30 years.
Some of the activities associated with the Alternatives 8A
and 8B will occur sequentially as opposed to simultaneously. It
is expected to take approximately 6 months to construct the
ground water monitoring system and to excavate and transport
materials from both the eastern disposal trench and the barrel
trench for Alternatives 8A and 8B, followed by up to 12 months
for cap construction.
Alternative 8C is expected to take approximately 6 months
for construction of the ISVE system, however, the ISVE system
must be in operation until the goals of the system are met and it
is not known exactly how long this will take, other activities
(i.e., completion of ground water monitoring network) will occur
simultaneously with ISVE system design and operation.
42
-------
Alternative 8B would most likely take less total time to
construct than Alternatives 8A and 8C. However, implementation
of ground water extraction and treatment will be ongoing for at
least 30 years under Alternative 8A and, if contingency actions
are required, under Alternatives 8B and 8C as well.
F. Implementability
This evaluation criterion addresses the technical and
administrative feasibility of each remedy, including the
availability of materials and services needed to implement the
chosen remedy.
The ground water extraction and treatment system included in
Alternatives 2, 4, 6, 8, and 8A and as a contingency for
Alternatives 8B and 8C is routinely implemented at many Superfund
Sites. The treatment would rely on proven technologies (air
stripping and carbon adsorption) and could be implemented
relatively easily. The air stripper system contemplated under
these alternatives would require treatability tests to assure
that stream effluent limits set by the Virginia State Water
Control Board would be met prior to discharge. Long-term
maintenance of the ground water treatment system and long-term
ground water monitoring would be required to assure the
effectiveness of all alternatives that include ground water
extraction and treatment. Although ground water extraction and
treatment systems are readily implementable, restoration of the
aquifer, which is the goal of these systems under Alternatives 2,
4, 6, 8, and 8A, may not be achievable.
The RCRA cap included in Alternatives 3, 4, 8A, SB, and 8C
could be readily implemented. The cap is straight forward to
construct. Long-term maintenance and repairs of the cap would be
required to assure the integrity of these alternatives. The
required labor, equipment, and materials are readily available to
construct and maintain the cap.
The excavation and offsite treatment/disposal of waste
materials and contaminated soils from the eastern disposal trench
and the barrel trench in Alternatives 8A, 8B and potentially 8C
could be readily implemented. Excavation is relatively straight
forward and the availability of treatment/disposal facilities is
adequate. Alternatives 8A and 8B would be easier to implement
than Alternatives 5 through 8 because acquisition and operation
of a mobile incinerator or LTTD unit would not be necessary and
excavation of a lesser amount of waste materials would be
required.
Operation of either the incinerator under Alternatives 5 and
6 or the LTTD system under Alternatives 7 and 8 would be more
difficult to implement than the offsite treatment alternatives.
Treatability tests would have to be completed and the systems'
operating parameters would have to be established. Onsite
incinerators and LTTD units are available for use. The
remediation schedule would need to be coordinated with the
availability of the needed mobile units and the availability of
43
-------
experienced contractors. The ability of LTTD to meet the soil
cleanup goals for VOCs needs to be confirmed in treatability
tests. Incineration is a highly reliable technology for organics
treatment; trial burns would, however, be undertaken to ensure
compliance'with air emission requirements. The handling,
treatment, and disposal of the large volume of contaminated
wastes and soils would require a design plan sequencing remedial
activities to facilitate efficient removal. Varying volumes or
concentrations of contaminants in soils could be handled easily.
Implementation of the ISVE system under Alternative 8C may
prove to be difficult. There are many factors involved that will
determine the success or failure of this system. These factors
include, but are not limited to, the following: soil and waste
permeability in the eastern disposal trench and the ability of
the system to meet the performance standards.
G. cost Effectiveness
Section 121 of CERCLA, 42 U.S.C. Section 9621, requires
selection of a cost-effective remedy that protects human health
and the environment and meets the other requirements of the
statute. The alternatives are compared with respect to present
worth cost, which includes all capital costs and the operation
and maintenance cost incurred over the life of the project.
Capital costs include those expenditures necessary to implement a
remedial action, including construction costs. All of the costs
indicated below are estimates.
Alternatives 3 and 8C have the lowest total present worth
costs at $1.3 million, and $ 7.9 million respectively. However,
Alternative 3 is clearly the least effective of all alternatives
considered. Alternative 8C has the potential to be highly cost-
effective, however, if the contingencies for the eastern disposal
trench and the ground water have to be invoked to ensure the
remedy's effectiveness, then this alternative could cost up to
$ 13.2 million. The overall cost-effectiveness of Alternative 8C
would decrease if the contingencies were invoked.
Alternatives 5 - 8A range in cost from $20.2 million to
$43.9 million. Although Alternatives 5 - 8A offer a high degree
of effectiveness, the relative costs of these alternatives are
significantly higher than other alternatives which offer an
acceptable level of effectiveness.
The remaining alternatives, 2, 4, and 8B range in cost
between $5.6 million and $ 9.2 million. Alternatives 2 and 4,
although reasonably priced, do not provide an adequate degree of
effectiveness. Alternative 8B, at $ 9.2 million, is the most
cost-effective of the alternatives considered. Contingencies
included with this alternative could increase the cost to $ 11.7
million.
44
-------
H. State Acceptance
VDEQ has had the opportunity to review and comment on all
the documents in the Administrative Record and has actively
participated in selecting a remedy for this Site. VDEQ has had
the opportunity to comment on the draft ROD and, to the extent
possible, the State's comments have been incorporated into the
ROD.
I. Community Acceptance
On May 25, 1993 and April 26, 1994, public meetings were
held at the Buckingham County High School Gymnasium, in Dillwyn,
Virginia to discuss EPA's preferred alternatives. The first
preferred ~alternative (8A) was presented in the Proposed Remedial
Action Plan (Proposed Plan) issued on May 5, 1993 and the second
preferred alternative (8C) was presented in the Addendum to the
Proposed Plan (Addendum) issued on November 24, 1993. There was
a public comment period following the issuance of both the
Proposed Plan and the Addendum.
Both of the public meetings were well attended by the
community (800 - 1,000 people). An overwhelming majority of the
community expressed a strong desire for: (1) EPA to select the
"cap and monitor" remedy (Alternative 3); (2) a remedy that did
not include excavation and offsite incineration; and (3) an
inexpensive remedy. The desires of the community were closely
aligned with those of the PRPs. Many of the citizens who
commented on the PRAP and the Addendum were employed by Armstrong
Furniture, a PRP for the Site. The citizens expressed concern
that their jobs would be in jeopardy if an expensive remedy were
selected. Many residents of Buckingham County also commented and
expressed concern that their local taxes would increase
significantly if an expensive remedy was selected because the
County is also a PRP. The Administrative Record for this Site
contains hundreds of letters that express the sentiments
discussed above. The nearest residents downgradient of the Site
expressed a strong preference for EPA to select Alternative 8A.
IX. Selected Remedy
A. Remedial Options
EPA carefully considered the concerns expressed by the PRPs
and the public during the two public comment periods. The
primary area of disagreement centered on the need for source
control. EPA has maintained that the highly toxic concentrated
waste present at the Site should be removed prior to capping to
reduce the potential for continued migration of contaminants in
the groundwater. The PRPs and the public have maintained that
source control is not warranted and that capping will be
sufficient to prevent further migration of the contaminants. EPA
believes that allowing the highly toxic concentrated waste to
remain beneath the cap will (1) increase the likelihood of
contaminant migration; and (2) increase the required duration of
extraction and treatment of the ground water. The Agency's
45
-------
position is based in part on its experience in tracking ground
water movement. However, the Agency concedes that the existing
Site data is open to interpretation on the issue of potential
offsite ground water migration. As a result, EPA has structured
the selected remedy for this Site to allow for two options, both
of which are fully protective of human health and the
environment:
Option 1 - Monitor the ground water and cap the hazardous
waste disposal area. If ground water monitoring
detects migration of the plume, as defined below,
remove appropriate portions of the cap, implement
source control measures (as described below),
replace the cap, and treat the ground water.
Option 2 - Monitor the ground water, implement the source
control measures (as described below), and then
cap the hazardous waste disposal area. If ground
water monitoring detects migration of the plume,
as defined below, treat the ground water.
B. Contingency Trigger
If any analytical result from a ground water monitoring
sample collected at the points of compliance exceeds an MCL or
the health-based contaminant level6 if an MCL has not been
established, for any Site-related contaminant, a confirmatory
sample from the well where the exceedance occurred shall be
collected and analyzed for all Site-related contaminants. If the
analytical results from the confirmatory sample also exceeds the
appropriate MCL or health-based level, the contingency actions
for the option of the selected remedy that is being implemented
(i.e., Option 1 or Option 2) shall be triggered.
The points of compliance shall be no more than 150 feet from
the edge of the cap. This cap, which will be constructed as part
of both Option 1 and Option 2, shall not extend beyond the
disposal trenches and previously-capped area south of the barrel
trench.
C. Remedy Description and Performance standards
The selected remedy for the Site is comprised of specific
combinations of components from Alternatives 8B and 8C and a
modification regarding barrel trench remediation based on public
comment. The components include ground water monitoring,
capping, source control, ground water treatment, and
institutional controls. As discussed above, implementation of
the ground water treatment component shall be contingent upon
detection of contaminant migration through the ground water
monitoring system. Implementation of source control components
6 In cases where the risk-based contaminant level is lower
than the detection limit, the detection limit would be used as
the standard.
46
-------
shall also be contingent upon detection of contaminant migration,
if Option 1 is chosen for implementation. Source control
measures are mandatory components of Option 2.
1. Ground Water Monitoring Performance standards
A ground water monitoring system shall be installed to
detect migration of Site-related contaminants beyond the
hazardous waste disposal area in accordance with 40 C.F.R.
Part 264, Subpart F and §10.5.H of VHWMR, VR §672-10-1; 40
C.F.R. Part 141, Subparts C and E. The system shall include,
at a minimum: (1) existing wells and new wells located no
more than 150 feet from the edge of the cap, and (2) the two
nearest downgradient residential wells. Monitoring wells
shall be located in both the saprolite and bedrock aquifers.
Monitoring wells located no more than 150 from the edge of
the cap shall be the points of compliance for containment of
the plume.
The ground water monitoring system wells shall be sampled in
accordance with 40 C.F.R. Part 264, Subpart F and §§10.5 and
10.6 of VHWMR, VR §672-10-1; 40 C.F.R. Part 141, Subparts C
and Eflpn a quarterly basis. Samples shall be analyzed for
all EPA Contract Laboratory Program Target Compound List
VOCs and Target Analyte List Metals. If no Site-related
contaminants are detected at the points of compliance during
consecutive quarterly samples for a period of three years,
the ground water sampling may be reduced to bi-annual
collection.
Ground water monitoring will be conducted in accordance with
40 C.F.R. Part 264, Subparts F and G and § 10.5 and 10.6.H.
of [VHWMR] (VR §672-10-1) .
2. Cap Performance Standards
A multilayer cap shall be installed over the hazardous waste
disposal area in accordance with RCRA Subtitle C
requirements, 40 C.F.R. Part 264, Subpart G and N and VHWMR
S10.13.K. to reduce infiltration of surface water and
migration of contaminants into the ground water. The cap
shall cover the trench areas and the previously capped area
south of the barrel trench and will be approximately two
acres in size. The cap shall not extend beyond the disposal
trenches and previously capped area south of the barrel
trench.
Maintenance of the cap shall be performed in accordance with
40 C.F.R. Part 264, Subpart G and N and VHWMR §10.6.H. and
§10.13.K. to prevent degradation of the cap and to ensure
long-term effectiveness.
A fence shall be constructed and maintained around the
perimeter of the cap to restrict access.
47
-------
3. Source Control - Eastern Disposal Trench
One of the following options shall be completed as the
source control measure for the eastern disposal trench:
a. ISVE Performance Standard
A pilot scale treatability study would be performed for ISVE
in the eastern disposal trench during the remedial design to
determine if ISVE can effectively remove contaminants from
the waste layer. The treatability study would need to
demonstrate the following:
1) adequate air flow can be achieved throughout the waste
_layer;
2) ISVE can meet the performance standards described
below;
3) an effective method for measuring performance of the
system can be developed and implemented.
If EPA determines that the treatability study successfully
meets the above criteria then full scale ISVE may be
implemented in the eastern disposal trench.
ISVE will continue until contamination levels in the waste
layer and surrounding soils are no longer a source of
contamination to underlying ground water which results in
ground water contamination above MCLs, or health-based
contaminant levels7 if MCLs have not been established. The
cleanup criteria will be determined during the remedial
design by considering the characteristics of the waste layer
and surrounding contaminated soils and associated
contaminants and then deriving specific levels of
contaminants in the waste layer and surrounding soils that
would not be expected to exert a significant impact on
underlying ground water.
If EPA determines that the treatability study does not
successfully meet the criteria listed above or if full scale
ISVE in the eastern disposal trench can not meet the
performance standards described above, excavation and off-
site incineration would be implemented for the eastern
disposal trench as described below.
b. Excavation and Off-site Incineration Performance Standard
The layer of concentrated waste located in the eastern
disposal trench and contaminated soil one foot above and
below the layer shall be excavated to eliminate the
continued migration of contaminants from this source into
soil and ground water. The waste layer is encountered at a
7 In cases where the risk-based contaminant level is lower
than the detection limit, the detection limit would be used as
the standard.
48
-------
depth of approximately ten feet below the ground surface and
extends to an approximate depth of fourteen feet. The
volume of waste material and contaminated soil has been
estimated to be 675 cubic yards. Soil excavated from the
surface of the eastern disposal trench to the depth of one
foot above the waste layer shall be considered overburden
material.
Excavated waste material, contaminated soil, and overburden
soil shall be temporarily staged on-site in accordance with
40 C.F.R. Part 264, Subpart L, and §10.11 of VHWMR, VR §672-
10-1 if material can be staged in an area that will
subsequently be capped. If waste material and soil cannot
be staged in an area that will subsequently be capped, the
waste material and soil shall be temporarily staged in
containers in accordance with RCRA regulations contained in
40 C.F.R. Part 268, Subpart E and §15.3 of VHWMR, VR §672-
10-1; containers used for staging shall be in compliance
with 40 C.F.R. Part 264, Subpart I and §10.8 of the VHWMR,
VR §672-10-1.
Excavated waste material and contaminated soil shall be
transported from the Site in accordance with Part VII of the
VHWMR, VR §672-10-1, VR §672-30-1, and VR §672-20-1; 40
C.F.R. Parts 262 and 263 and §268.7; 49 C.F.R. Part 107 and
49 C.F.R. Subchapter C.
Excavated waste material and incidental soil shall be
incinerated at an off-site permitted RCRA Subtitle C
facility operating in accordance with 40 C.F.R. Part 264,
Subpart O.
The eastern disposal trench shall be backfilled with the
overburden soil and additional clean soil, as necessary, to
achieve an appropriate surface grade for capping.
Source Control - Barrel Trench Performance standards
A representative number of test pits shall be excavated and
samples shall be obtained from the barrel trench to provide
a representative evaluation of the condition of drums buried
in the barrel trench, to determine if the buried drums are
empty, and to determine the levels of all contaminants
present in this trench. Samples obtained from the test pits
shall be analyzed for all priority pollutants set forth in
40 C.F.R Part 423, Appendix A.
The information gained from visual observations during test
pitting and analytical results from sampling shall be
compiled and remedial action alternatives shall be evaluated
in a Focused Feasibility Study (FFS).
The appropriate source control measures for the barrel
trench shall be selected in a subsequent EPA decision
document, based on the FFS.
49
-------
5.
The ground water treatment system shall be designed at the
same time that the ground water monitoring and capping
components of the remedy are designed.
A network of ground water extraction wells shall be
installed. These wells shall be specifically located in
order to facilitate achievement of MCLs, or risk-based
levels in the absence of MCLs, for Site-related contaminants
in the area of attainment in accordance with 40 C.F.R. Part
141, Subpart B and Part 264 Subpart F as well as VR §355-18-
004.08. The area of attainment has been defined as the area
beyond the points of compliance. The points of compliance
shall be the ground water monitoring wells located no
further than 150 feet from the edge of the cap as described
both in Section IX.C.I. above and in "Guidance for Remedial
Actions for Contaminated Ground Water at Superfund Sites,"
December 1988, OSWER Directive 9283.1-02.
Ground water shall be treated to meet the discharge limits
established by the VDEQ Water Division in accordance with
Virginia State Water Control Law, Code of Virginia §§ 62.1-
44.2 et seq.. Virginia State Water Control Board Regulations
VR §§680-21-00 and 680-14-00 as well as 40 C.F.R. Parts 122,
129, and 131. Treatment shall take place in an on-site
facility that includes air stripping and, if necessary, a
process to remove metals. Treated ground water shall be
discharged to the surface water body adjacent to the Site.
Emissions from the air stripping unit shall not exceed
health-based levels established for on-site workers or
downwind residents. Air emissions shall be in compliance
with National Ambient Air Quality Standards (NAAQS) set
forth in 40 C.F.R. Part 50, National Emissions Standards for
Hazardous Air Pollutants (NESHAPs) set forth in 40 C.F.R.
Part 61, and described in "Control of Air Emissions from
Superfund Air Strippers at Superfund Ground Water Sites,"
June 15, 1989, OSWER Directive 9355.0-28.
Chemical and biological monitoring shall be performed to
evaluate the performance of the ground water treatment
system and detect any impacts to the surface water body
receiving the treated ground water. The monitoring
requirements shall be developed during the remedial design
in accordance with Virginia State Water Control Law, Code of
Virginia §§ 62.1-44.2 et sea.. Virginia State Water Control
Board Regulations (VR 680-21-00), and 40 C.F.R. Part 141
Subparts C and E and Part 264, Subpart F, G, and N. These
monitoring requirements shall be subject to EPA approval.
6. Institutional Controls
A deed restriction shall be place on the property within the
points of compliance prohibiting residential development or
use of the ground water as a potable source.
50
-------
EPA may modify or refine the selected or contingent remedies
during remedial design and construction. Such modifications or
refinements, if any, would generally reflect results of the
engineering design process. The estimated present worth cost of
the selected remedy without the contingency requirements is $4.3
million for Option 1 (see Table 8) and $7.3 million for Option 2
(see Table 10). The estimate for Option 1 is comprised of a
capital cost of $1.2 million and $2.8 million for 30 years of
operation and maintenance. The estimate for Option 2 is
comprised of a capital cost of $3.7 million and $2.8 million for
30 years of operation and maintenance.
The costs for both options of this remedy could increase if
migration of the contaminated ground water is detected and,
therefore, contingency requirements are invoked. The estimated
cost of Option 1 plus contingencies is $10.7 million (see Table
9) and the estimated cost of Option 2 plus contingencies is $9.7
million (see Table 11). Documentation for these costs is in the
Administrative Record.
TABLE 8 - SELECTED REMEDY COST ESTIMATE SUMMARY - OPTION 1
ITEM:
Mobilization
RCRA Cap
Install GW
Monitor System
Decon
Demobilization
Capital Costs
Contingencies
(20%)
O&M Present
Worth
TOTAL COST
QUANTITY
1
2
i
i
i
UNIT
LS
acre
LS
LS
LS
UNIT COST
N/A
N/A
N/A
N/A
N/A
COST ($)
161,000
578,000
330,000
95,000
107,000
TOTAL: 1,271,000
254,200
2,815,000
$ 4,340,200
51
-------
TABLE 9 - SELECTED REMEDY OPTION 1 + CONTINGENCY COSTS
REMOVE PORTIONS OF THE CAP
EXCAVATION/ TREATMENT OF EASTERN TRENCH
BARREL TRENCH - TEST PIT/ SAMPLE/ FFS
INSTALL GW EXTRACTION AND TREATMENT
RE-CAP
INCREASE IN MOB /DECON/ DEMOB
SUBTOTAL
CONTINGENCIES (20%)
TOTAL CAPITAL COST
INCREASE IN O&M (PRESENT WORTH)
OPTION 1 - NO CONTINGENCIES
TOTAL POTENTIAL COST
$
$
$
$
$
$
$
$
$
$
$
$
100,000
2,268,000
250,000
430,000
578,000
100,000
3,726,000
745,200
4,471,200
1,900,000
4,340,200
10,711,400
TABLE 10 - SELECTED REMEDY COST ESTIMATE SUMMARY - OPTION 2
ITEM:
Mobilization
Eastern Trench
Barrel Trench
RCRA Cap
Install GW
Monitor System
Decon
Demobilization
Capital Costs
Contingencies
(20%)
O&M Present
Worth
TOTAL COST
QUANTITY
1
675
1
2
1
1
1
UNIT
LS
yd3
LS
acre
LS
LS
LS
UNIT COST
N/A
3,360
N/A
N/A
N/A
N/A
N/A
COST ($)
161,000
2,268,000
250,000
578,000
330,000
95,000
107,000
TOTAL: 3,789,000
757,800
2,815,000
$ 7,361,800
52
-------
TABLE 11 - SELECTED REMEDY OPTION 2 -I- CONTINGENCY COSTS
INSTALL GW EXTRACTION AND TREATMENT
CONTINGENCIES (20%)
TOTAL CAPITAL COST
INCREASE IN O&M (PRESENT WORTH)
OPTION 2 - NO CONTINGENCY
TOTAL POTENTIAL COST
$
$
$
$
$
$
430,000
86,000
516,000
1,900,000
7,361,800
9,777,800
X.
Statutory Determinations
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.
Section 9621, establishes several other statutory requirements
and preferences. These requirements/preferences specify that,
when complete, the selected remedial action for a site must
comply with applicable or relevant and appropriate requirements
established under Federal and State environmental laws, unless a
statutory waiver is justified. The selected remedy must also be
cost-effective and utilize permanent treatment technologies or
resource recovery technologies to the maximum extent practicable.
The statute also contains a preference for remedies that employ
treatment as a principal element. Site-specific conditions have
influenced the Agency to select an alternative that may not, if
Option 1 is implemented, utilize permanent treatment technologies
or resource recovery technologies to the maximum extent
practicable or employ treatment as a principal element, unless
the contingency requirements are invoked. These site-specific
conditions include: (1) the fact that this Site poses no current
risk to public health; and (2) the options that make up the
selected remedy are more cost-effective, without decreasing
overall protection of human health and the environment, than the
alternatives that more completely utilize permanent treatment
technologies.
A. Protection of Human Health and the Environment
The BRA for the Buckingham County Landfill Site determined
that the Site potentially presents an unacceptable risk to future
residents in the vicinity of the Site who would use ground water
for drinking. Specifically, the risk assessment indicates that
the cumulative risk posed by ingestion and inhalation of VOCs in
ground water is unacceptable. Furthermore, many of these
contaminants exceed MCLs. Over a lifetime, the total excess
cancer risk associated with exposure to contaminated ground water
at the Site is 2.6 x 10'1 for future residents (i.e. those people
who are exposed to the contaminated ground water have a 26%
53
-------
chance of developing cancer).
For both Options 1 and 2, a RCFA cap would provide
protection of human health and the environment by decreasing the
infiltration of precipitation through the trench areas at the
Site and thereby curtailing continuing degradation of ground
water. Under both options, protection from exposure to the
contaminated ground water will be provided through a ground water
monitoring network as well as deed and access restrictions.
If Option 1 were implemented, the sources of contamination
that are posing a principal threat would be allowed to remain
onsite beneath the cap. EPA maintains that allowing the highly
toxic concentrated waste to remain beneath the cap will (1)
increase the likelihood of contaminant migration; and (2)
increase the required duration of extraction and treatment of the
ground water. If Option 2 were implemented, the sources of
contamination that are posing a principal threat would be removed
prior to capping to reduce the potential for continued migration
of contaminants in the groundwater.
Under both options, if at any time following issuance of
this ROD, EPA determines that the ground water contamination has
migrated to a point of compliance, extraction and treatment of
the ground water shall be implemented to ensure that the
contaminated ground water remains within the points of compliance
therefore providing additional protection.
The short-term threats associated with both options of the
selected remedy and their contingency requirements can and will
be readily controlled and no adverse cross-media impacts are
expected as a result of implementation this remedy. Both Options
are equally protective of human health and the environment.
B. Compliance with Applicable or Relevant and Appropriate
Requirements
Under Section 121(d) of CERCLA, 42 U.S.C. § 9621(d), and EPA
guidance, remedial actions at Superfund sites must attain legally
applicable or relevant and appropriate Federal and state
environmental standards, requirements, criteria, and limitations
(collectively referred to as ARARs). Applicable requirements are
those substantive environmental protection requirements,
criteria, or limitations promulgated under Federal or state law
that specifically address hazardous material found at the site,
the remedial action to be implemented at the site, the location
of the site, or other circumstances at the site. Relevant and
appropriate requirements are those which, while not applicable to
the site, nevertheless address problems or situations
sufficiently similar to those encountered at the site that their
use is well suited to that site.
The selected remedy will comply with all Applicable or
Relevant and Appropriate Requirements (ARARs). The ARARs are
presented below.
54
-------
1. Chemical Specific ARARs
Treatment of the ground water to ensure the area of
attainment will comply with the requirements of the Safe
Drinking Water Act 40 C.F.R. Part 14lf Subpart B and VR
§355-18-004.08, pertaining to maximum contaminant levels.
Offsite treatment, storage and disposal of materials to be
excavated from the eastern disposal trench will comply with
RCRA regulations and standards for owners and operators of
hazardous waste treatment, storage and disposal facilities,
40 C.F.R. Part 264 and the Virginia Hazardous Waste
Management Regulations (VHWMR), VR § 672-10-1 and Virginia
Solid Waste Management Regulations (VSWMR), VR §672-20-10.
Offsite treatment/disposal of materials to be excavated from
the eastern disposal trench and residues from ground water
treatment will comply with the RCRA requirements for
treatment before disposal to meet RCRA's Land Disposal
Regulations, 40 C.F.R. Part 268, Subpart C and D and §§15.3
and 15.4 of VHWMR, VR §672-10-1.
Emissions from the air stripping unit, specifically the VOCs
identified as the contaminants of concern in the baseline
risk assessment for the Site, will be monitored and, if
required, a vapor phase carbon adsorption unit can be
installed to ensure compliance with the Clean Air Act
National Emission Standard for Hazardous Air Pollutants
(NESHAPs), 40 C.F.R. Part 61, National Ambient Air Quality
Standards (NAAQS), 40 C.F.R. Part 50 and VR §§120-03-02,
120-03-06, and 120-04-07.
2. Action-Specific ARARs
The ground water monitoring component of the selected remedy
will comply with the requirements of 40 C.F.R Part 264
Subpart F, G, and N as well as §10.5.H. of the VHWMR, VR
§672-10-1. The ground water monitoring will be performed
for at least thirty years.
Capping of the trench areas with a RCRA Subtitle C cap will
comply with the requirements set forth at 40 C.F.R. Part
264, Subparts 6 and N and SS 10.6 and 10.13 of the VHWMR,
VR § 672-10-1.
Any land-disturbing activities associated with the selected
remedy will comply with the Virginia Erosion and Sediment
Control Law, Code of Virginia §§ 10.1-560 et seq.. and
Virginia Erosion and Sediment Control Regulations, VR §625-
02-00 to prevent erosion and transport of sediments in
surface water runoff during earth moving activities.
During all Site work, Occupational Safety and Health
Administration (OSHA) Standards set forth at 29 C.F.R. Parts
1904, 1910, and 1926 governing worker safety during
hazardous waste operations, shall be met.
55
-------
Any offsite disposal of hazardous materials will comply with
CERCLA §121(d)(3) which prohibits the disposal of Superfund
Site waste at a facility not in compliance with §§3004 and
3005 Of RCRA, 40 C.F.R. §300.440.
Transportation of excavated wastes, soils and ground water
treatment residues to a RCRA-permitted treatment/disposal
facility would comply with RCRA regulations at 40 C.F.R.
Parts 262, 263, and §268.7; as well as the Department of
Transportation (DOT) regulations set forth in 49 C.F.R. Part
107 and 49 C.F.R Subchapter C and Part VII of the VHWMR,
§672-10-01.
The excavation associated with the selected remedy will
cause no violation of NAAQS due to fugitive dust generated
during construction activities as set forth in 40 C.F.R.
§50.6 and 40 CFR §52.21(j) and VR §120-04-0104.
The treatment of contaminated ground water by air stripping
and contaminated waste/soils by ISVE must comply with 40
C.F.R Part 262, and Part VI of the VHWMR, § VR 672-10-1.
If materials can be staged onsite in an area that will
subsequently be capped, temporary staging of excavated
materials (in tanks or drums) will comply with 40 C.F.R.
Part 264, Subpart L, and §10.11 of the VHWMR, VR §672-10-1.
If materials can not be staged onsite in an area that will
subsequently be capped, temporary staging of materials (in
tanks or drums) will comply with 40 C.F.R. Part 268, Subpart
E, and §15.3 of the VHWMR, VR §672-10-1.
Containers used for temporary staging shall be in compliance
with 40 C.F.R. Part 264, Subpart I and VHWMR §10.8, VR §672-
10-1.
The federal National Pollutant Discharge Elimination System
(NPDES) under the Clean Water Act 33 U.S.C. §§1251 et sea..
and the Virginia Pollution Discharge Elimination System
(VPDES) under the Virginia Water Control law, Code of VA
§62.1-44.2 et seq.. establishes discharge limitations for
point source discharges to surface water based on designated
use of the receiving stream. Since the treated ground water
will be discharged to a nearby surface rater body, NPDES
requirements set forth in 40 C.F.R. Part 122, 129, and 131
and VPDES requirements set forth in VR §§680-14-00 and 680-
21-00 will be met.
Operation of the air stripping unit must comply with the
requirements of 40 C.F.R Part 264, Subpart AA and §10.15 of
the VHWMR, VR §672-10-1.
56
-------
2. Location-Specific ARARs
The Endangered Species Act of 1973 (16 U.S.C. §1651 et.
sea.), the Virginia Board of Game and Inland Fisheries (Code
of Virginia S§ 29.1-100 et sea.l. and Virginia Endangered
Species Act, Code of Virginia §S 29.1-563, provide a means
for conserving various species of fish, wildlife, and plants
that are threatened with extinction. These ARARs will be
applicable if a determination is made that endangered
species are present or will be affected by the remedial
alternative.
C. Cost-Effectiveness
Section 300.430(f)(1)(ii)(D) of the NCP requires EPA to
evaluate cost-effectiveness by first determining if the
alternative satisfies the threshold criteria: protection of human
health and the environment and compliance with ARARs. The
effectiveness of the alternative is then determined by evaluating
the following three of the five balancing criteria: long-term
effectiveness and permanence, reduction of toxicity, mobility, or
volume through treatment, and short-term effectiveness. Both
options of the selected remedy meet these criteria to varying
degrees. Both options of the selected remedy are cost-effective
because the costs are proportional to their overall
effectiveness. The estimated present worth cost for Option 1 the
selected remedy is $ 4,340,200 with the potential to cost
$10,741,400 if contingencies are invoked and the estimated
present worth cost of Option 2 of the selected remedy is
$7,361,800 with the potential to cost $9,777,800 if the
contingencies are invoked.
D. Utilization of Permanent Solutions and Alternative
Treatment (or Resource Recovery) Technologies to the
Maximum Extent Practicable (HEP)
Section 121(b) of CERCLA, 42 U.S.C. § 9621(b), establishes a
preference for remedial actions that permanently and
significantly reduce toxicity, mobility or volume of hazardous
substances over remedial actions which will not.
If Option 2 of the selected remedy is implemented or if the
contingency requirements for Option 1 of the selected remedy are
invoked, permanent solutions and alternate treatment technologies
will be utilized to the maximum extent practicable in a cost
effective manner to control contamination at this Site. EPA
issued two different proposed plans (5/5/93 and 11/24/94). Each
proposed plan also presented preferred alternatives that
represented different ways in which permanent solutions and
treatment technologies could be utilized to the maximum extent
practicable in a cost effective manner to control contamination
at this Site. However, site-specific conditions have influenced
the Agency to select an alternative that may not initially
utilize permanent treatment measures. The site-specific
57
-------
conditions mentioned above include: (1) the fact that this Site
poses no current risk to public health; and (2) the options that
make up the selected remedy are more cost-effective, without
decreasing overall protection of human health and the
environment:, than the alternatives that more completely utilize
permanent treatment technologies.
E. Preference for Treatment as a Principal Element
If Option 2 of the selected remedy is implemented or if the
contingency requirements for Option 1 of the selected remedy are
invoked, the selected remedy will satisfy the statutory
preference for treatment as a principal element. The waste
sludge and the surrounding contaminated soils in the eastern
disposal trench, which are considered to be a principal threat
will be excavated and incinerated offsite. Additionally, if the
contingency requirements are invoked, for both Option 1 and
Option 2 of the selected remedy, ground water treatment will be
implemented.
XI. Documentation of Significant Changes
The Proposed Remedial Action Plan (PRAP) for the Buckingham
County Landfill was first issued on May 5, 1993. The preferred
alternative (8A) included excavation and offsite incineration of
wastes/soils from the eastern disposal trench, excavation and
offsite treatment/disposal of miscellaneous hazardous substances
from the barrel trench, construction of a RCRA Subtitle C cap
over the trench areas, and extraction and treatment of the ground
water. The cost of this remedy was estimated at $20 million.
During the public comment period following issuance of this plan,
the PRPs adamantly opposed this remedy and the community followed
suit.
The major comments regarding the Alternative 8A were as
follows: (1) the cost of the remedy was too high; (2) any
excavation or offsite transportation of hazardous wastes was
perceived to be a significant health threat and, therefore, was
opposed by the community; and (3) treatment via air stripping of
the ground water was thought to be an "ineffective" technology.
EPA also received comments from the responsible parties which
indicated that Insitu Soil Vapor Extraction (ISVE) would be an
effective technology for treatment of the eastern disposal trench
as well as an acceptable alternative to the community.
EPA took all of the comments that were received into
consideration and issued an Addendum to the Proposed Plan which
identified Alternative 8C as the preferred alternative.
Alternative 8C included the following components: (1) ISVE in the
eastern disposal trench with an offsite incineration contingency
if ISVE was not successful; (2) sampling in the barrel trench
with an offsite treatment/disposal contingency; (3) construction
of a RCRA Subtitle C cap over the trench areas; and (4) ground
water monitoring with a ground water extraction and treatment as
58
-------
a contingency.
The selected remedy is neither Alternative 8A nor
Alternative 8C. The selected remedy is comprised of specific
combinations of components from Alternatives 8B and 8C and a
modification regarding barrel trench remediation based on public
comment. The significant changes between the last preferred
alternative (8C) and the selected remedy are as follows: (1)
permanent treatment measures may not be initially implemented;
(2) Option 1 of the selected remedy, without contingencies,
consists of a RCRA cap and ground water monitoring; (3) ISVE will
only be used in the eastern disposal trench if treatability
studies are performed during remedial design that indicate
implementation of ISVE will be successful; (4) source control
measures for the barrel trench will be determined based on
additional investigation followed by an FFS; EPA will issue a
subsequent decision document which will specifically address
remediation of the barrel trench; and (5) all of the contingency
requirements, if they have not already been implemented as part
of Option 2, will be triggered by migration of the ground water
plume to the points of compliance.
EPA continues to maintain the position that the source
control measures should be initially implemented to prevent
further migration of the contamination. However, other
interested parties maintain that the ground water will never
migrate to the boundary of the property and therefore, excavation
and treatment of the source areas is not necessary. EPA has
therefore, allowed for two options under the selected remedy.
Both options ensure protection of human health and the
environment in the long-term.
59
-------
1. The County of Campbell and the County of Appomattox submitted
comments in the form of resolutions adopted by their respective
Boards of Supervisors. These resolutions voiced opposition to
the preferred alternative presented in the EPA PRAP and support
for Alternative 3.
EPA Response; EPA believes that excavation of the concentrated
waste areas, in conjunction with a cap (and possibly extraction
and treatment of the ground water), will be necessary to ensure
that the contaminated ground water does not migrate offsite.
However, EPA's selected remedy allows the implementing party to
choose a cap and monitor option, provided the party agrees to
perform excavation and extraction/treatment of the ground water
if migration of the ground water plume is detected at the points
of compliance. Also see Section IX. of the ROD, Selected Remedy
and Performance Standards, for an explanation regarding why
Alternative 3 is not the selected remedy.
2. A written statement was received from Gordon G. Ragland, Jr.,
Chairman, Buckingham County Planning Commission. The major
issues in his statement are as follows:
(a) The planning commission is opposed to the EPA plan and
supports the plan proposed by Engineering-Science, Inc.
EPA Response; See response to Comment 1.
(b) For Buckingham County to fully fund Alternative 8A there
would have to be an increase in the County tax rate of 1850%.
When using a cost/benefit analysis approach to decision making,
the costs of Alternative 8A are out of proportion with the
benefits.
EPA Response; There are a variety of mechanisms to ensure that no
PRP, regardless of whether it is a governmental or private
entity, will incur the severe financial hardship anticipated by
this commenter in order to fulfill its obligations under CERCLA.
EPA has never imposed such severe financial burdens on any County
or Municipality in the 14 years since CERCLA was enacted. EPA
has offered to meet with the County to equitably resolve the
County's CERCLA responsibilities for this Site. The Agency has
also advised the County regarding the various settlement options
available to it which would allow the County to fulfill its
CERCLA responsibilities without imposing undue financial
hardships on the taxpayers. These negotiations are ongoing at
this time.
(c) The Site was operated in compliance with the laws at the time
and Buckingham County bought the Site with the intent to properly
close it.
EPA Response; CERCLA imposes strict liability for cleanup (i.e.,
liability without regard to fault) on site owners and operators,
as well as those who generated and transported hazardous
62
-------
substances that were disposed at a site. The intent of the lav
is to have those most closely associated with the problem bear
the cost of cleanup rather than the public at large. In many
cases, environmental laws governing disposal of hazardous
substances'did not exist or were of limited scope at the time
when disposal at most Superfund sites occurred. Nevertheless,
under CERCLA persons who owned or operated a site at the time of
such disposal (or who currently own or operate the site) are
liable for cleanup of the Site.
B. A presentation was given as a verbal comment on behalf of the
PRPs by Susan Fullerton of Engineering-Science, Inc. at the May
25th public meeting, significant comments made in this
presentation are summarized below, followed by the EPA response.
3. The statement was made that the Site is located on a 120 acre
property and the 2 acre landfill is located on an 8 acre cleared
area. The ground water contamination has only moved about 50
feet outside the 2 acre area and therefore, has not moved
offsite.
EPA Response: If by Site, Ms. Fullerton means the 8-acre cleared
area surrounding the area where hazardous waste disposal
operations took place, then EPA agrees that the ground water
contamination has not moved "offsite". However, regardless of
what the Site definition is, the ground water contamination has
migrated beyond the area where disposal took place and EPA
believes it will continue to do so. For the record, it should be
noted that Section 101(a) of CERCLA, 42 U.S.C., §9601, defines a
facility as, inter alia,"...any site or area where hazardous
substances has been deposited, stored, disposed of, placed, or
otherwise come to be located." (emphasis added). Therefore, as
the hazardous substances released from the Site expand, the
boundaries of the Superfund Site also expand.
4. The statement was made that the cancer risk, which was quoted
to be 2.6 x 10"1 during the EPA presentation, was misleading. It
is the opinion of the PRPs that this risk would apply only if a
well was drilled within the area of the plume.
EPA Response; The above stated risk translates to: 26% of the
people exposed to the contaminated ground water under the
exposure scenario described in the ROD would develop cancer.
This is an accurate description of the risk associated with this
Site. EPA agrees that it is unlikely that anyone would build a
home or drill a well directly on the disposal area at the Site,
because such development would be prohibited under current
Virginia law and the institutional controls described in the ROD.
Because the properties in the general vicinity of the Site are
primarily residential and are expected to remain so, EPA
considered future residential land use near the Site to be
appropriate. At Superfund sites with ground water contamination,
the area of consideration in performing the risk assessment
includes areas where contamination would likely migrate given
63
-------
PART III - RESPONSIVENESS SUMMARY
BUCKINGHAM COUNTY LANDFILL
This Responsiveness Summary documents public concerns and
comments expressed during both the comment period following
issuance of the Proposed Remedial Action Plan (PRAP) on May 5,
1993 and the comment period following issuance of the Proposed
Plan Addendum (Addendum) on November 24, 1994. The summary also
provides EPA's responses to those comments. The information is
organized as follows:
I. Overview
II. -Summary of significant comments from the May 25, 1993,
public meeting and EPA responses
III. Summary of significant comments from citizens received
during the first public comment period and EPA
responses
IV. Summary of significant comments from the Potentially
Responsible Parties (PRP) received during the first
public comment period and EPA responses
V. Summary of significant comments from the April 26,
1994, public meeting and EPA responses
VI. Summary of significant comments from citizens received
during the second public comment period and EPA
responses
VII. Summary of significant comments from the PRPs received
during the second public comment period and EPA
responses
VIII. Summary of comments received from Congressman Payne
regarding the Addendum to the Proposed Plan and EPA
responses
IX. Summary of comments received from the Virginia
Department of Environmental Quality (VDEQ) on the Draft
Record of Decision and EPA responses
I. OVERVIEW
There has been two public comment periods associated with
remedy selection for the Buckingham County Landfill Site (Site).
The first comment period followed issuance of the PRAP and began
on May 5, 1993. This comment period was initially scheduled to
end on June 4, 1993, however, it was extended until July 6, 1993,
as requested by the County of Buckingham. The first EPA public
meeting was held on May 25, 1993, in the Buckingham County High
School gymnasium in Dillwyn, Virginia.
60
-------
At that meeting, EPA discussed the Remedial Investigation
(RI) , the Baseline Risk Assessment (BRA), and the Feasibility
Study (FS) reports prepared for this Site. EPA also presented
the PRAP for eliminating and/or mitigating the public health and
environmental threats posed by the contamination detected in the
environmental media at the Site. At that time, EPA explained
that the preferred alternative included the following components:
excavation and offsite incineration of materials from the eastern
disposal trench; excavation and treatment/offsite disposal of the
materials from the barrel trench; construction of a RCRA cap over
the hazardous waste disposal area; recovery and treatment of
ground water; ground water monitoring; and institutional
controls.
The EPA public meeting held on May 25, 1993, provided the
first opportunity for the public to ask questions and express
opinions and concerns. Residents questioned the need for such a
comprehensive remedy considering that the risk for the Site is
based on future ground water use. The perceived economic impact
that the preferred alternative would have on the PRPs, including
the County of Buckingham, was a concern voiced by many citizens.
And the overall cost of the preferred alternative was then, and
is still, the concern expressed most vehemently and most often by
the concerned community.
Following the public meeting held on May 25, 1993 and the
close of the first comment period, July 6, 1993, EPA evaluated
and considered comments that were received from all interested
parties. In response to concerns voiced by the community, EPA
developed two new alternatives and issued an Addendum to the PRAP
on November 24, 1993, which opened a second public comment
period. Following issuance of the Addendum, EPA attempted to
schedule a public meeting on several different occasions starting
in January 1994 and each meeting had to be cancelled due to
inclement weather. The public meeting was held on April 26,
1994. The purpose of this meeting was to present two new
alternatives to the community and to provide the community with
an opportunity to ask questions and offer comments on these new
alternatives. The second comment period closed on May 3, 1994.
After considering all of the input received during the comment
period, EPA issued a Record of Decision (ROD) on September 30,
1994, documenting the Agency's final decision regarding cleanup
of this site.
II. SUMMARY OF SIGNIFICANT COMMENTS FROM THE MAY 25, 1993 PUBLIC
MEETING AND EPA RESPONSES
Significant questions and comments presented at the May 25,
1993, public meeting are listed and/or summarized briefly in this
section. The EPA response, if appropriate, follows each of the
questions or comments presented.
A. The following written comments were submitted to EPA at the
public meeting:
61
-------
groundwater movement at the site, hence the 2.6 x 10""1 cancer
risk. Baseline risk assessments at all Superfund Sites are
performed to determine the risks to human health and the
environment that would occur if no further actions were taken.
5. The statement was made that the soils at the Site are
relatively impermeable and, although not as impermeable as clay,
these soils (saprolite) tend to hold the ground water in place.
The conclusion was that although the ground water is moving it is
moving at a very slow pace.
EPA Response; EPA does not consider soils with a permeability
factor of 1.1 x 10~3 to be "relatively impermeable". Although
EPA believes that the contaminated ground water is migrating,
experts at- the EPA Robert S. Kerr Environmental Research
Laboratory have determined that more data regarding the geology
(fractured bedrock) and the ground water at the Site needs to be
gathered before final conclusions regarding the rate or direction
of the ground water flow can be made. The first priority for
implementation of the selected remedy will be to gather this
information and design and install the ground water monitoring
network.
6. The statement was made that the existing caps on each of the
individual trenches are limiting the movement of the contaminated
ground water.
EPA Response: Any cap, including the existing caps or even a RCRA
multilayer cap, can only prevent contaminants from leaching
downward under the influence of infiltration. Ground water moves
in all directions including upward and laterally. The ground
water is already contaminated. EPA does not believe that the
RCRA cap included in the selected remedy will effect the movement
of the contaminants that are already in solution in the ground
water.
7. The area of the barrel trench has been questioned. It has
been stated by the PRPs that the entire barrel trench was not
represented in the proposed remedy.
EPA Response; During operations at the Site, the barrel trench
was located at the southern portion of the Site and, as described
on page 1-8 of the RI, was approximately 400 feet long, 20 feet
wide, and 14 feet deep. This area was specifically used for
disposal of supposedly empty, crushed drums. This trench was
never completely filled; The west end remained open until the
Site was closed in 1983. During installation of the cap in 1983,
portions of empty crushed drums were found mixed in with the
solid waste landfill south of the barrel trench. Fourteen test
pits were dug in this area to determine if drums were disposed of
throughout this area. Five test pits uncovered portions of empty
drums and two pits uncovered cloth laden with solvents. There
were no reports of finding drums containing hazardous wastes.
EPA does not consider the area where the test pits were dug to be
64
-------
part of the barrel trench.
8. The statement was made that the EPA cost estimate for the
preferred remedy is low. The PRPs estimated that the preferred
remedy would actually cost $30-40 million as opposed to the $20
million estimate prepared by EPA because (1) EPA's volume
estimate for the barrel trench is incorrect and (2) in order to
meet the soil cleanup goals presented in the proposed plan more
of both the barrel trench and the eastern disposal trench would
have to be excavated.
EPA Response; Engineering-Science (ES) announced to the residents
at the May 25th public meeting that EPA's remedy (Alternative 8A)
would cost_$30-40 million. However, no backup cost documentation
has ever been provided to substantiate this claim.
Due to unknown factors, assumptions must be made when costs
are estimated for Site cleanups. There are some fundamental
differences between ES's and EPA's assumptions that were made
during cost estimation which account for the differences in the
cost estimates. ES assumed that EPA would require a much larger
volume to be excavated from the barrel trench. The area of the
barrel trench is addressed in the response to Comment 7.
However, aside from the test pits, no excavation of the barrel
trench would be required under the selected remedy until
additional information has been obtained, a Focused Feasibility
Study (FFS) is performed, and EPA has set excavation performance
standards in a subsequent decision document.
Regarding the assumption that, in order to meet the soil
cleanup goals more of the barrel trench, as well as more of the
eastern disposal trench> would need to be excavated, EPA
acknowledges that the cleanup goals specified in the PRAP would
only have to be met for the excavation as described for
Alternatives 5-8, because these alternatives do not include a
RCRA cap. It should also be noted that the volume targeted for
excavation under Alternative 8A from the eastern disposal trench
has been reduced in the selected remedy, without decreasing the
effectiveness of the remedy. As noted above, a decision
regarding performance standards for barrel trench excavation is
being postponed until EPA has more data regarding the
contaminants in the barrel trench.
9. ES believes that Alternative 3 provides overall protection of
human health and the environment, which is an EPA threshold
criteria.
EPA Response: EPA has carefully considered this position. The
ROD states that Alternative 3 may provide protection of human
health and the environment. However, this protection is only
provided if the ground water contamination does not migrate to
the points of compliance at which time extraction and treatment
of the ground water would be necessary to provide adequate
protection. The PRP's alternative is no longer screened out
65
-------
because of not meeting this criteria.
10. It was stated that 700 dump trucks would be needed to
transport the excavated materials from the Site to offsite
facilitiesrcreating a "significant threat11 to the community. The
possibility of accidental spills along the route was mentioned as
well as the liability of such a spill. Specifically it was
stated that, "...you (the local community) are still involved in
this Site, you're still paying for long-term liability".
EPA Response: The estimate of 700 dump trucks has never been
substantiated by ES. This was not an EPA estimate and EPA
maintains that the actual number of trucks for Alternative 8A
would have been much less than 700. If Option 2 of the selected
remedy is -implemented or if the contingency actions for Option 1
of the selected remedy are deemed necessary, EPA estimates that
no more than 35 trucks would be needed for disposal of materials
from the eastern disposal trench.
The Agency is aware of the concern the community has
regarding the transportation of hazardous materials.
Transportation of hazardous materials does not pose a
"significant threat" to human health as stated by ES. To minimize
the potential risk, all Virginia Department of Transportation
(VDOT) regulations regarding the transportation of hazardous
wastes would be adhered to and truck traffic would be
strategically spaced throughout the remedial action to avoid high
traffic volumes at any one time.
The statement that "you" (the community) are liable for
actions taken at the Site is inaccurate. The PRPs for the Site
are responsible for the cleanup costs and potential extended
liability, not the community.
11. The statement was made that ground water pump and treat is
not an effective technology. Additionally, the extracted ground
water would not be treated to the point that it is free of
contaminants, therefore, previously clean streams will be
contaminated by the discharge.
EPA Response: EPA agrees that the extraction and treatment of
ground water may not, in all situations, be 100% effective in
reducing the concentration of contaminants below health based
standards throughout the plume. However, this ineffectiveness,
in most cases, is due to the presence of Non-aqueous Phase
Liquids (NAPLS) in the contamination plume which serve as a
continuing source of contamination for long periods of time. The
possible presence of NAPLS at this Site was not explored by ES
but will be investigated during design of the ground water
monitoring system as part of the selected remedy. Extraction and
treatment systems have consistently been proven effective when
the goal of the treatment is to contain the plume, and not to
restore the aquifer to its' beneficial use. At this time, the
ROD requires ground water monitoring with a contingency
66
-------
requirement for extraction and treatment of the ground water.The
goal of the extraction and treatment system will be to contain
the plume within the points of compliance. Ground water
underneath the waste disposal areas is not part of the area of
attainment^and hence does not have to meet ground water
protection levels applicable to the points of compliance.
A concern about discharging treated ground water into clean
streams was also raised. Although it is true that the treated
ground water may contain trace levels of contamination, these
levels would have to meet the Virginia Pollution Discharge
Elimination System requirements which are established to protect
both human health and the ecological integrity of streams.
C. The following significant issues were raised by citizens
during the May 25, 1993, public meeting:
12. One citizen was concerned that samples were not taken from
other areas of the county to determine if the levels of heavy
metals found at the Site were comparable to natural background
levels.
EPA Response; Background samples were collected from offsite
areas, as required by EPA guidelines, to determine if the levels
of contaminants found onsite are comparable to background levels.
EPA is not required to sample other areas of the county.
13. One citizen wanted to know if it had been determined when the
actual ground water contamination occurred. Specifically, the
commenter was curious as to whether the contamination had
occurred before or after the trenches were capped. The EPA
Response to that question was that it is not known when the
actual contamination occurred. This citizen then went on to ask,
if we didn't know when the contamination occurred, why would EPA
not consider a "more conservative financial approach to monitor
the situation with a new cap without going to something as
drastic as pumping and removing the material1*.
EPA Response; Knowing when the actual contamination occurred
would not change the fact that the ground water contamination
exists today. Alternative 8A included a RCRA cap. EPA does not
disagree that a cap is warranted at this Site. Although capping
the Site will limit the amount of infiltration through the waste
materials to the ground water, EPA does not believe the cap will
ultimately impede the contaminated ground water from migrating at
its natural pace. EPA has consistently maintained that removing
the most contaminated waste materials from the Site initially
would ensure that these waste materials could no longer
contribute to the already existing ground water contamination.
If the Site is capped prior to removal of the source areas then
these source areas will continue to contribute to the
contamination already present in the ground water, conceivably
making it necessary to extract and treat the ground water
indefinitely. Also, see response to Comment 6.
67
-------
The Agency has selected a remedy in this ROD that includes
two options for remediation. Option 1 is to cap and monitor the
Site until the migration of the ground water contamination beyond
the points of compliance is documented. Once the ground water
contamination has migrated beyond the points of compliance, then
the source'control measures will be required. Option 2 requires
implementation of source control measures prior to capping. The
implementing party will be given the opportunity to either
address the source areas up front or install a cap while
reserving source control as a contingency requirement. Given the
currently documented movement of the plume, EPA believes it is
likely that the contingency requirements will be invoked, making
Option 2 much more cost-effective that Option 1.
14. One citizen also commented about the ineffectiveness of "pump
and treat" technologies and specifically referenced an article in
the June 1993 Readers' Digest by John Cherry.
EPA Response: See response for Comment 11.
D. The following comments were made during the comment segment of
the public meeting:
15. Mr Watkins Abbitt, member of the Virginia State House of
Delegates, made the following comments:
(a) He objected to the structure of the public meeting, stating
that people who had come to comment had to leave because of job
or family constraints due to the late hour and did not get the
chance to comment.
EPA Response; The typical format for a public meeting on a
Proposed Remedial Action Plan (PRAP) includes presentation of the
PRAP by EPA, an opportunity for questions and answers, and then
an opportunity for anyone wishing to provide oral comments to do
so. EPA followed this format at the May 25, 1993, public
meeting. EPA typically tries to answer all the questions
individuals have before moving on to accepting comments. With an
attendance of an estimated 800 to 1000 people at the meeting, the
question-and-answer period was understandably lengthy. Many
comments were actually given by individuals during the question-
and-answer segment of the meeting. EPA has a complete transcript
of the meeting and has included all significant comments provided
at the meeting in this Responsiveness Summary. EPA did not close
the meeting until all comments has been made. EPA also
encouraged those present to take the opportunity to provide
written comments because the public comment period would be
continuing through July 6, 1993. Hundreds of people did, in
fact, provide letters to EPA. All significant comments contained
in these letters are also included in this Responsiveness
Summary.
(b) Mr. Abbitt questioned the assertion that the hazardous
compounds at the Site are "highly mobile", as stated in the EPA
68
-------
presentation.
EPA Response; Volatile Organic Compounds (VOCs) are present at
significantly elevated levels in the waste materials and the
ground water at this Site. Of all the contaminants that are
considered to be hazardous, VOCs are most likely to migrate
because of their tendency to volatilize. In other words, these
compounds are highly mobile as stated in the presentation. The
fact that contaminants that were present in the waste materials
in the trenches have migrated into the ground water indicates
that these compounds are highly mobile. Additionally, residual
waste material is present in the eastern disposal trench from
about 10 feet to 14 feet below grade. Elevated levels of VOCs
were noted to at least 24 feet below grade in the soils
underlying this waste material, as well as in the ground water
also indicating that the contaminants in this waste are highly
mobile.
(c) Mr. Abbitt then went on to stress that the ground water
contamination has only moved forty feet.
EPA Response; EPA's conclusion after analyzing the monitoring
data is that the ground water contamination has moved further
than this distance. As of July 1992, the plume of ground water
contamination at this Site has expanded up to 140 feet from the
most highly contaminated cluster of monitoring wells. This
cluster of wells is located between the western disposal trench
and the barrel trench. In 1992, it was estimated by the
potentially responsible parties that the plume may actually
extend up to 60 feet beyond monitoring well 6S (see Figure 4 of
the ROD) , leaving approximately 60 feet to the boundary of the 8-
acre Site, defined as the points of compliance.
(d) Mr. Abbitt then commented on the three in ten cancer risk and
stated that it only applied to a well drilled right through the
trenches.
EPA Response; See response to Comment 4.
(e) Mr. Abbitt then commented on the proposed pump and treat
system and how he was opposed to discharging the treated ground
water into a nearby stream.
EPA Response; See response to Comment 11.
16. Mr. Wayne Wright, a citizen of Buckingham County and an
employee of one of the PRPs, brought up the possible economical
ramifications of implementing Alternative 8A. He stated that he
cannot afford higher taxes and he believes that layoffs, cutbacks
and bankruptcy may be the result of implementation of Alternative
8A.
EPA Response; Many Buckingham County residents believe that they
may have to pay for a substantial portion of the cleanup through
69
-------
higher taxes. However, as is stated in the response to comment
2(b), EPA has the authority to settle with the County to ensure
that the County does not incur an undue financial hardship in
assisting with the remediation of this Site.
The remedy selection process, as defined by law, is not
based on whether or not the PRPs can pay for the cleanup. EPA is
responsible for protecting human health and the environment.
There are many site cleanups that are paid for by the Superfund,
if either PRPs don't exist or are not financially viable. If
there are legitimate reasons to believe that any PRP cannot
afford to pay for a particular remedy, EPA investigates the
parties in question and prepares complete financial analyses to
determine if they are capable of paying for the selected remedy.
III. SUMMARY OF SIGNIFICANT COMMENTS FROM CITIZENS RECEIVED
DURING THE FIRST PUBLIC COMMENT PERIOD AND EPA RESPONSES
A. Over one thousand postcards were received by EPA which stated
the following:
17. "I strongly support the plan to cap and
monitor Love's Landfill, but otherwise leave
it alone. I believe this plan fully protects
Buckingham County and its citizens.
I oppose the EPA plan. It gives no more
protection, creates risks, and could result
in job losses. The EPA plan makes no sense
for Buckingham County."
EPA Response; EPA believes that excavation of the concentrated
waste areas, in conjunction with a cap (and possibly extraction
and treatment of the ground water), will be necessary to ensure
that the contaminated ground water does not migrate offsite.
However, EPA's selected remedy allows the implementing party to
choose a cap and monitor option, provided that the party must
perform excavation and extraction/treatment of the ground water
if migration of the ground water plume is detected at the points
of compliance. Also see Section IX. of the ROD, Selected Remedy
and Performance Standards, for an explanation regarding why
Alternative 3 is not the selected remedy.
B. Over eight hundred letters were received by EPA during the
comment period. Many of the concerns expressed in these letters
were also voiced at the May 25, 1993 public meeting and
therefore, have been addressed previously in this responsiveness
summary. The following additional comments/concerns about the
proposed plan, which are significant and relevant to this Site,
were raised in the letters from citizens:
18. Many citizens are concerned in general with the cost of the
preferred alternative (8A) in the proposed plan.
70
-------
EPA Response; The cost estimate for this remedy was $20,216,697.
When developing the preferred alternative in the PRAP (8A) , EPA
carefully considered which areas of the Site pose a principal
threat. Alternative 8A specifically identified areas where
excavations-would be required and the estimated cost was a
conservative figure which assumed greater levels of excavation
and treatment than were actually anticipated. However, EPA has
made specific changes to the remedy presented in the PRAP to
address these citizens' concerns by reducing the scope of the
remedy without decreasing its effectiveness and thereby, reducing
the overall cost. The cost estimate for Option 1 of the remedy
selected in the ROD is $4,340,000 with the potential for costing
$10,711,400. Option 2 is estimated to cost $7,361,800 with the
potential for costing $9,777,800.
19. Many citizens were generally concerned about the liability of
Thomasville furniture and the other PRPs. There seemed to be an
overall lack of understanding regarding the PRPs liability (why
the PRPs have to pay for the cleanup).
EPA Response; CERCLA imposes liability for cleanup on site owners
and operators, as well as those who arranged for disposal of
hazardous substances at a Site. Thomasville Furniture disposed
of hazardous wastes at the Site and Buckingham County owns the
Site. The intent of the law is to have those most closely
associated with the problem bear the cost of cleanup rather than
the public at large. Where, as in this case, the management
practices at a Site have given rise to releases of contamination,
entities associated with the facility are required under the law
to bear the responsibility of remediating the contamination.
20. Many citizens are concerned with the possibility of employee
layoffs when the PRPs are required to pay for the selected
remedy.
EPA Response; As mentioned in response to comment 18 above, EPA
has made many changes to the preferred alternative presented in
the PRAP that significantly lowers the cost of the Site
remediation work specified in the ROD. EPA can negotiate
settlements based on "ability to pay11 in cases where a party would
suffer severe economic hardships in attempting to comply with its
CERCLA obligations regarding Site cleanup. Nonetheless,
decisions regarding the optimum number of employees working for a
company is ultimately under that company's discretion. Moreover,
that decision is based on a variety of factors in addition to the
company's environmental obligations. Also, see EPA response to
Comment 16.
21. Many citizens are concerned with the possibility of higher
taxes because Buckingham County is one of the PRPs required to
pay for the selected remedy.
EPA Response; See EPA response to Comments 2 (b), 16, and 18.
71
-------
22. The citizens are concerned that implementation of the
selected remedy will be creating safety and health risks to the
citizens of Buckingham County.
EPA Response; If Option 2 or the contingencies for Option 1 are
implemented, the selected remedy, could pose some risks to
workers in the immediate area of the-excavation. However, these
workers will be protected by personal protective equipment, will
be required to have the 40-hour health and safety training course
and will be required to adhere to all Federal health and safety
regulations, including ambient air monitoring.
Risks associated with transportation of wastes from this
Site will be minimized by adhering to health and safety
regulations relating to transportation of hazardous materials and
truck traffic would be strategically spaced throughout the
remedial action to avoid high traffic volumes at any one time.
Transportation of hazardous materials occurs safely in this
country everyday. The Agency believes that the incidental risk
due to excavation and transportation of wastes currently onsite
to a treatment or disposal facility is more than offset by the
fact that excavation and appropriate treatment of the waste
materials at this Site would eliminate any risk that these
materials could pose to residents in the future.
23. Many citizens voiced the opinion that Alternative 3 would
provide just as much protection of human health and the
environment as the preferred alternative in the PRAP (8A) and
would cost much less.
EPA Response: Although Alternative 3 is a less expensive
alternative, the Agency does not agree that Alternative 3 is
equally as protective of human health and the environment as
Alternative 8A for the reasons stated in Section IX. of the ROD.
24. Many citizens voiced the opinion that there is no current
risk and therefore, there is no need for cleanup.
EPA Response; The fact that there is no current risk at the Site
does not mean that the Site is safe. When making decisions
regarding Superfund sites, EPA must consider the long term
effects of contamination at a Site and not just the present
conditions. Currently, the properties in the general vicinity of
the Site are primarily residential and are expected to remain so.
Therefore, future residential use of the ground water (future
risk) must be considered when making any decisions regarding this
Site.
25. Many citizens are concerned with the hazards posed by hauling
the wastes through their county. They feel that it does not make
sense to burn or bury the waste somewhere else.
EPA Response; As discussed above in the response to Comment 22,
risks associated with transportation of wastes from this Site can
72
-------
be minimized by adhering to health and safety regulations
associated with transportation of hazardous materials.
Additionally, the volume of waste materials that will be
transported offsite under Option 2 or the contingency options for
Option 1 of. the selected remedy, is significantly less than that
of the preferred remedy presented in the PRAP. Because the
volume of materials to be transported has been reduced, the risks
of this transportation are also reduced. EPA does not deny that,
when transporting hazardous materials, there is the risk of
accidents and therefore, the risk of spills. However, the
possibility of this occurring is remote.
The wastes that are currently present onsite were just
dumped into open trenches. There is no evidence of a liner
between any of the wastes and the ground water and there is no
system in place for the collection and/or treatment of leachate.
If Option 2 or the contingency options for Option l of the
selected remedy are implemented, the waste material from the
eastern disposal trench will be incinerated at a RCRA permitted
incineration facility. The incineration treatment process
actually destroys the contaminants, in this case VOCs. EPA
believes that despite the marginal risks, excavation and offsite
incineration of the wastes at a RCRA-permitted facility will be
more environmentally sound than allowing the wastes, which
represent a continual source of ground water contamination, to
remain at the Buckingham Site untreated. It should be noted that
Insitu Soil Vapor Extraction (ISVE) is also an option for
treating the waste materials in the eastern disposal trench.
26. Many citizens believe that ES's plan (Alternative 3), if
implemented, will "ensure that the landfill remains safe".
EPA Response; As previously explained, the fact that there is no
current risk at the Site does not mean that the Site is "safe".
The cap and monitor plan (Alternative 3) is not a permanent
remedy, does not provide for measures that actively address the
concentrated waste sources at the Site, provides no contingency
for treatment of contaminated ground water should the plume
migrate to the points of compliance, and therefore, this remedy
may not be able to guarantee effectiveness in the long term.
EPA, therefore, does not agree with the statement that
Alternative 3 will "ensure that the landfill remains safe".
Although Option 1 of the selected remedy is essentially the "cap
and monitor" remedy, tLis option also provides for source control
measures and extraction and treatment of the ground water if the
ground water contamination migrates beyond the points of
compliance. See also Section VIII. of the ROD for further
analysis of Alternative 3.
27. Some citizens expressed the concern that Buckingham County
alone would be spending $30 million on this remedy. Fear that
the county will go bankrupt has stemmed from this belief.
73
-------
EPA Response: The cost estimate for the preferred alternative
(8A) presented in the PRAP was $20,216,697, not $30 million. In
addition, the selected remedy has been modified with a
corresponding reduction in the cost without decreasing the
effectiveness of the cleanup. The cost estimate for Option 1 of
the remedy selected in the ROD is $4,340,000 with the potential
for costing $11,711,400. Option 2 is estimated to cost
$7,361,800 with the potential for costing $9,777,800. Also, see
response to comment 2(b).
28. Some citizens brought up the fact that public sentiment is
against the alternative presented in the PRAP (Alternative 8A).
Some citizens stated that this needs to be a major factor in
EPA's decision.
EPA Response: Alternative 8A has been modified in such a manner
that total anticipated costs are approximately half as expensive
as the cost estimate for Alternative 8A presented in the PRAP.
In addition, EPA has provided the PRPs with the option of
essentially implementing Alternative 3, provided that they are
willing to take the risk of also implementing more costly
contingency requirements should the ground water contamination
migrate to the points of compliance.
29. A few citizens were concerned that the existing ground water
contamination actually occurred before the trenches were capped.
One citizen stated that there was evidence to that effect.
EPA Response: There is no evidence that the contamination
occurred before the trenches were capped. Also, see response to
Comment 13.
30. Many citizens do not feel that the PRPs should be responsible
because at the time of disposal no laws were broken.
EPA Response; See response to Comment 2(c).
31. Many citizens voiced the concern that they did not want
"partly cleaned ground water" discharged into local streams.
EPA Response: See response to Comment 11.
32. A majority of the letters from local citizens indicated that
they were against the EPA plan and in favor of the plau proposed
by ES.
EPA Response: See response to Comment 1.
33. Some citizens are concerned that the facilities where the
waste is sent may become Superfund sites and the PRPs would then
also be PRPs for those sites.
EPA Response; There is a very remote possibility that this will
occur. Environmental laws are much more strict today than they
74
-------
were at the time of disposal at the Buckingham Site. Many more
precautions are required such as double liners and leachate
collection systems. Therefore, it is highly unlikely that the
PRPs will be responsible for cleanup of another Superfund Site
due to disposal of materials from this Site.
34. A couple of citizens questioned why the costs of cleanup
would not be paid for by the "Superfund".
EPA Response: The "Superfund" is only used at sites where the
PRPs are unknown or not financially viable. The PRPs for this
Site have been identified and, at least as a group, appear to be
capable of paying for the cleanup. Also, see responses to
comments 2(b), 16, and 20.
35. Many citizens were concerned with the fact that (for
Alternative 8A) EPA only proposed to remove approximately one
third of the waste from the Site and not all of the waste.
EPA Response; CERCLA and the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) specify a preference
for using treatment technologies to treat principal threats at
sites whenever practical. At this Site, EPA has determined that
the wastes in the eastern disposal trench and the barrel trench
pose a principal threat. The only actual "waste" material
(sludge) onsite is located in the eastern disposal trench.
Additionally, there are drums with an unknown amount of waste
materials located in the barrel trench. The remaining areas of
the site (the evaporation trench and western disposal trench)
have been found to have relatively low levels of contamination
and are therefore considered to be low level threats. CERCLA and
the NCP indicate that it is acceptable to cap such low level
threats. Therefore, under Option 2 or the contingency
requirements for Option 1, EPA will be systematically removing
those waste materials that represent a principal threat at the
Site.
36. A few citizens voiced the concern that EPA's proposed remedy
did not include long term monitoring of the ground water.
EPA Response; EPA agrees that the inclusion of long term
monitoring of the ground water as set forth in the preferred
remedy presented in the PRAP was not evident. However, long term
ground water monitoring is an inherent part of the ground water
extraction and treatment system described in the PRAP. In order
to determine if any extraction and treatment system is working
effectively, routine samples must be obtained and analyzed on a
regular basis. Both Options 1 and 2 of the selected remedy in
the ROD include long term monitoring of the ground water using a
network of "trigger" wells.
37. A few citizens were concerned about the release of hazardous
substances into the atmosphere during the excavation of the
hazardous materials.
75
-------
EPA Response; The only individuals who could potentially be
affected by any volatilization of the hazardous materials would
be the onsite workers. As previously mentioned, these workers
will be protected by personal safety equipment and the levels of
contaminants in the air will be monitored to insure that these
workers are* not exposed to unacceptable levels of contaminants.
Once the contaminants reach the atmosphere, not only will they
volatilize, but they will also dissipate. Any amount of
contaminants leaving the Site through the air will not exist in
high enough concentrations to be harmful by the time they would
reach any residential areas.
38. More than one citizen stated that the landfill was approved
by EPA. They in turn believe that EPA should be a PRP.
EPA Response; The landfill was not approved by EPA. The
hazardous waste disposal operations run by Mr. Love had received
RCRA Interim Status. This only means that EPA identified it as a
Site where disposal operations involving hazardous wastes were
occurring and could continue if performed in accordance with
certain legal standards pending the issuance of a RCRA permit for
the Site. EPA's acknowledgement of the facility's interim status
under RCRA § 3005(e) had and has no impact on liability for
cleanup imposed by CERCLA, a separate and distinct statute. Mr.
Love was required to obtain a RCRA Part B permit which would
actually regulate the operations at the Site. This was never
done. Also, see response to comment 129.
39. One citizen expressed the opinion that providing a public
water line would eliminate the risk by eliminating the use of
ground water as a potable source.
EPA Response; Section 121 of CERCLA 42 U.S.C. § 9601 contains a
statutory preference for treatment of the source of contamination
at a site. The remedial alternative selected by this ROD
provides a compromise between permanent treatment measures and
cost effectiveness. The installation of a water line would not
in any way address the source of contamination at the Site.
40. One citizen made the statement, "as of May 19, 1993, EPA
announced it would limit the use of incineration to dispose of
hazardous wastes".
EPA Response; Although EPA has cut back on the use of
incineration to dispose of hazardous wastes, there are some
materials that are still most effectively addressed by
incineration. Offsite treatment via incineration of the waste
from the eastern disposal trench is still, in the Agency's
opinion, the best option for that material. Moreover, the volume
of materials to be incinerated is relatively small (675 yd3) .
41. One citizen questioned why the Site was put on the National
Priority List (NPL) when it poses no risk.
76
-------
EPA Response; The Site poses a future risk to human health via
the existing plume of ground water contamination. These risks
have been discussed in detail in the response to Comment 4. All
sites are evaluated for placement on the NPL using a systematic
mathematical model (the hazard ranking system). Each site is
assigned a numerical ranking based on this system. If this
numerical ranking is above the cutoff point of 28.5, the site is
eligible for placement on the NPL. The score for the Buckingham
County Landfill was 40.77, making it eligible for the NPL.
42. One citizen voiced the opinion that replacement of the
existing cap (Alternative 3) would "accomplish the purpose of
reducing the mobility of the ground water and soil
contamination".
EPA Response: Replacement of the existing cap would only decrease
the infiltration of contaminants through the trench materials to
the ground water. A cap does not tend to impede the natural
movement of ground water and will therefore probably not impede
the movement of contaminants already in solution in the ground
water. Also, see response to comment 1.
43. Virginia State Senator Houck provided the following
additional comments to the ones already listed above:
(a) The Senator points out the following : (1) any cost the
County is required to contribute will be in addition to the
approximately $500,000 it has already spent in acquiring,
closing, monitoring, and conducting studies at the Site; (2) the
County's motive in acquiring the Site was to prevent its further
use as a hazardous waste disposal facility; and (3) these actions
were taken in the best interest of the community and ought not be
used against Buckingham County by serving as the basis for an
assessment of liability.
EPA Response; EPA is aware that the County has expended a
substantial amount of money on the Site in construction of a
ground cover that has helped impede the leaching of the source
contaminants into the ground water. Such actions by the County
are appropriate for consideration during any settlement
negotiations that might ensue between the County and EPA
concerning this Site. However, the County was also aware at the
time of purchase of the Site that the purchase alone would make
it a responsible party for any future CERCLA Site remediation.
(b) The Senator states that "EPA's analysis of cleanup
alternatives fails to take into account the risks to which county
residents would be subjected by diverting to landfill cleanup the
huge share of resources that would be required by 8A. Such a
diversion of revenue could strip the locality of the money it
needs to provide its citizens with police and fire protection,
education, and other vital services."
77
-------
EPA Response; whenever an entity spends money on a given activity
or project it cannot spend the same money on some other activity
or project. When Congress enacted CERCLA and placed the burden
for environmental cleanup on the parties responsible for creating
the problem, it understood that these parties - be they counties,
municipalities, or private parties - would have fewer funds
available for other activities. By enacting CERCLA without any
special limitations for counties and municipalities, Congress
determined that environmental remediation took precedence over
alternate fiscal decisions available to the responsible counties
and municipalities. Nonetheless, should site remediation pose a
severe economic hardship to the County, EPA would consider
entering into settlement with the County based on its ability to
pay. Also, see response to comments 2(b) and 16.
44. One citizen suggested EPA take the following steps to resolve
controversy over the Site that: (1) The EPA and the PRPs should
first attempt to define reasonable achievable remediation
objectives; (2) EPA should then review the site remediation plan
which is proposed by the PRPs and assess its capability of
achieving the stated objectives. As part of this assessment,
risk analysis would be performed; (3) An implementation plan and
schedule would be agreed upon and the project completed; (4) the
Site would be monitored for a reasonable period of time to ensure
the effectiveness of the solution; and (5) if unsuccessful, a
corrective action plan would be prepared and implemented.
EPA Response; This citizen is essentially describing the
Superfund process and most of these steps have either already
been taken or will be taken in the future. Remedial Action
Objectives (RAOs) were identified in the FS. The PRPs site
remediation plan (Alternative 3) along with all the other
alternatives presented in the FS, were evaluated in the FS and
subjected to detailed analysis during the ROD process. Both a
human health and ecological risk assessment were conducted in
conjunction with the RI, prior to evaluation of the alternatives.
Implementation of the remedy selected in the ROD, including a
schedule for work to be performed, will be negotiated between the
PRPs and EPA and, if an agreement is reached, a Consent Decree,
which is a legal document specifying actions to be taken, will be
signed by the PRPs and EPA. As part of both options in the
selected remedy, monitoring of the ground water will be conducted
to ensure the effectiveness of the remedy. If migration of the
ground water plume is detected, then corrective measures will be
taken to address this migration.
45. One citizen indicated that his well was contaminated with
chromium and beryllium as a result of the hazardous waste
practices at this Site.
EPA Response; Chromium and beryllium were not detected in
significant levels in the wastes, soils or ground water samples
obtained from the Site. At this time, it is not clear what the
source of this contamination is. It is possible that the
78
-------
chromium and beryllium in this residential well is naturally
occurring.
46. One citizen indicated that borings dug by a geologist he
hired revealed no evidence of a liner in the evaporation trench.
EPA Response; EPA agrees that this liner does not appear to
exist.
47. One citizen expressed the opinion that the western disposal
trench and the evaporation trench should also be excavated and
treated as a source of contamination along with the eastern
disposal trench and the barrel trench.
EPA Response; Samples obtained from the western disposal trench
and the evaporation trench during the RI indicated that there
were no significant levels of contamination in these trenches.
Unlike the eastern disposal trench and possibly the barrel
trench. The western disposal trench and the evaporation trench
do not constitute concentrated waste sources. Therefore, it is
appropriate to cap these particular areas as opposed to
excavating them. It should be noted that any excavation decision
for the barrel trench will be postponed until after additional
information on this trench has been gathered. Any subsequent
excavation decision will be subject to public comment prior to
that decision becoming final.
48. One citizen stated that the following statement in the PRAP,
"Troublesome Creek Reservoir is upgradient of the Site", is an
incorrect statement.
EPA Response; Although the reservoir is topographically lower
than the site, it is in a different watershed. The RI did not
indicate that this reservoir was affected by Site-related
contamination.
49. One citizen stated the opinion that the selected remedy must
include active measures for cleaning up the ground water.
EPA Response; EPA's selected remedy for the ground water includes
monitoring alone with a network of "trigger wells" until such a
time that the plume is shown to be migrating. In the event that
the plume migrates to the points of compliance, extraction and
treatment of the ground water will be implemented. However, the
purpose of the extraction and treatment would be to contain the
plume rather than to restore the ground water underneath the
waste management areas to the protection levels specified for the
points of compliance.
50. One citizen voiced the opinion that the soil cleanup goals
are too high, not protective enough.
EPA Response; The soil cleanup goals identified in the PRAP will
not be used. Under Option 2 and the contingencies for Option 1
79
-------
of the selected remedy the goal of excavation will be to remove
the concentrated waste sources. In the eastern disposal trench
the layer of waste present between 10 and 14 feet below ground
surface comprises the concentrated waste source. Performance
standards for excavation in the barrel will be set by a
subsequent "EPA decision document. The remaining contaminated
soils would remain onsite beneath the multilayer RCRA cap.
51. One citizen stated that the RI/FS should not have been
limited to the hazardous waste disposal area. This citizen felt
that all waste management areas on the property should have been
investigated.
EPA Response; The remaining areas of the Site include a borrow
pit and a .solid waste landfill. The borrow pit was used for
excavation of clean soils to be used as cover material for the
wastes during disposal operations. There is no evidence that
hazardous wastes were disposed of in the borrow pit or the solid
waste landfill.
52. One citizen stated that the current ground water monitoring
network is inadequate.
EPA Response: EPA agrees with this statement and during design of
the selected remedy a new system of monitoring wells will be
developed using both saprolite and bedrock wells. Additionally,
the two closest downgradient residential wells will be sampled
regularly. This monitoring well system will be subject to EPA
approval.
IV. SUMMARY OF SIGNIFICANT COMMENTS FROM THE POTENTIALLY
RESPONSIBLE PARTIES RECEIVED DURING THE FIRST PUBLIC COMMENT
PERIOD AND EPA RESPONSES
During the comment period, EPA received formal comments from
the PRPs or their respective representatives. Many of the
comments in the letters listed below were also voiced at the
public meeting and in letters from the community and have been
addressed previously in this responsiveness summary and
therefore, are not addressed below. The following additional
comments/concerns about the PRAP, which are significant and
relevant to this Site, were raised in the letters from PRPs:
Buckingham County Board of Supervisors
. Letter to Melissa Whittington from David Moorman, County
Administrator, dated July 6, 1993.
53. It was stated that the VOCs in the existing plume would be
eliminated through the natural attenuation processes of
biodegradation, adsorption, and dilution.
EPA Response; EPA Region III received technical assistance from
experts at the EPA Robert S. Kerr Environmental Research
Laboratory (RSKERL) regarding many Site related issues including
80
-------
natural attenuation of the ground water. Experts from RSKERL
have determined that there is insufficient data to determine if
natural attenuation of the plume will occur at all, let alone
eliminate the existing contaminants. Actual degradation rates
would be dependant on a myriad of environmental, physical and
chemical factors. RSKERL experts indicated that the following
additional data would have to be gathered in order to adequately
evaluate the effectiveness of natural attenuation (for more
detailed information on this subject see Memo from Don Draper
(RSKERL) to Melissa Whittington dated August 4, 1993 in the
Administrative Record):
The concentration of all electron acceptors associated
with the Site would have to be known.
Tests to determine Biological Oxygen Demand (BOD) and
Chemical Oxygen Demand (COD) would have to be obtained
from ground water samples. Total Organic Carbon (TOC) and
Dissolved Organic Carbon (DOC) would also be useful in the
evaluation.
A microcosm test would need to be performed mimicking as
closely as possible ambient aquifer conditions.
Analysis of intermediate and final end products of
Contaminants of Interest (COI) degradation.
54. "The discharge of partially treated ground water into surface
waters presents significant potential for the build up of
contaminants over time so as to render currently clean surface
waters additional clean-up sites."
EPA Response; See response to Comment 11.
55. It is stated that "both the community and the Commonwealth
adamantly oppose the PRAP".
EPA Response; EPA does not dispute the fact that a majority (not
all) of the community is opposed to the preferred remedy
presented in the PRAP. However, the statement that the
Commonwealth "adamantly opposes" the plan is inaccurate. The
Commonwealth has raised certain questions and issues on the PRAP
which EPA has tried to address in this ROD. Also, see response
to comment 17.
Sara Le« Knit Products (8LKP)
. Letter to Melissa Whittington from Steve Draper, dated
July 1, 1993.
56. It is stated that Alternative 8A as presented in the Proposed
Plan "violates at least four major concerns associated with
selecting a protective remedy". CERCLA S121(b)(1)(A)-(G) is
referenced. SLKP recommends EPA adopt Alternative 3.
81
-------
EPA Response:. The concerns outlined in the referenced section of
CERCLA above are not criteria for remedy selection. The above
referenced section of CERCLA states, "In assessing alternative
remedial actions, the President shall, at a minimum, take into
account: (h) the long-term uncertainties associated with land
disposal; (B) the goals, objectives, and requirements of the
Solid Waste Disposal Act; (C) the persistence, toxicity,
mobility, and propensity to bioaccumulate of such hazardous
substances and their constituents; (D) short and long-term
potential for adverse health effects from human exposure; (E)
long-term maintenance costs; (F) the potential for future
remedial action costs if the alternative remedial action in
question were to fail; and (G) the potential threat to human
health and the environment associated with excavation,
transportation, and redisposal or containment." EPA did take all
of these concerns into account when selecting the remedy. In
addition to the above criteria, CERCLA also requires that, "the
President shall select a remedial action that is protective of
human health and the environment, that is cost-effective, and
that utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable". In this respect, the modified Alternative
8A selected in the ROD ranks well above Alternative 3, which is
the alternative selected by the PKPs.
57. SLKP poses the question," While Alternative 8A would reduce
the volume of some source materials, to what extent would
excavation of those materials reduce the inherent hazards posed
by principal threats at the Site"?
EPA Response; The PRAP, as well as the ROD, makes a clear
distinction between source materials that are posing a principal
threat and source materials that are posing a low level threat.
The sole purpose of excavation at this Site is to remove the
principal threats in order to eliminate the possibility of
further degradation of the aquifer. The eastern disposal trench
is currently considered an area that poses a principal threat and
will be excavated if Option 2 of the selected remedy is
implemented or the contingencies for Option 1 are invoked. The
barrel trench might also be an area posing a principal threat and
will be further investigated to determine it this is the case.
The remaining areas of the Site are considered to be low level
threats. It is appropriate under CERCLA to cap low level
threats *
58. SLKP has implied that the preferred remedy in the PRAP is
significantly less implementable than the PRP's preferred
alternative (3).
EPA Response; Evaluating the implementability of alternatives
does not mean that the simplest, least complex remedy should be
selected to clean up Superfund Sites. In order to effectively
clean up Sites, more complex remedies are often justified.
Although capping and monitoring alone may be easier to implement
82
-------
than some of the other options included in the selected remedy,
that does not necessarily mean that the selected remedy poses
implementation difficulties.
SLKP particularly emphasized the "unknowns with designing
and testing a ground water extraction and treatment system or
ensuring massive amounts of soil are properly excavated,
analyzed, transported and ultimately incinerated or land disposed
in accordance with RCRA". EPA agrees that designing a ground
water extraction and treatment system, considering the complex
geology at this Site, may be a difficult task. However, if
contaminated ground water is migrating toward residential wells,
extraction and treatment, regardless of complexity, is certainly
warranted. _ At this time, both options in the selected remedy in
the ROD do not include extraction and treatment of the ground
water. Extraction and treatment of the ground water will be
implemented if and when the ground water contamination migrates
beyond the points of compliance.
Excavation and transportation of materials is not a complex
activity, as implied by SLKP. These activities are commonplace
among site cleanups and for experienced contractors are
relatively simple tasks. The incineration will occur at an
existing permitted facility that has been designed specifically
for this purpose. In order to incinerate materials from this
Site, aside from transportation, no additional effort will have
to be expended.
59. SLKP discusses a statutory bias against the offsite
transportation and disposal of hazardous substances without
treatment, specifically emphasizing "wastes to be land disposed".
EPA Response; Excavation will only be part of the selected
remedy if Option 2 is implemented or if the contingency
requirements for Option 1 are invoked. The only known waste
(sludge) material present onsite is found in the eastern disposal
trench. This material will either be treated offsite via
incineration or treated onsite via ISVE. No materials from the
eastern disposal trench are intended to be land disposed. The
remaining materials to be potentially excavated include drums and
associated contaminated materials from the barrel trench as well
as the surrounding incidental soils. EPA will issue a subsequent
decision document regarding excavation of the barrel trench which
will be made available for public comment.
60. SLKP has questioned the cost-effectiveness of the selected
remedy.
EPA Response; The cost-effectiveness criteria does not dictate
that the least expensive remedy be selected. The purpose of this
criteria is to weigh the effectiveness of the remedy as well as
the cost. By removing the waste materials located in the eastern
disposal trench (and potentially the barrel trench if warranted),
EPA is eliminating the possibility of further degradation of the
83
-------
already-contaminated ground water by this source. In addition
both options of EPA's selected remedy will also cap the Site and
monitor the ground water as recommended by the PRPs. EPA has
made many modifications to the preferred remedy presented in the
PRAP and as a result of these changes the estimated cost of the
cleanup has been reduced. The cost estimate for Option 1 of the
remedy selected in the ROD is $4,340,000 with the potential for
costing $10,711,400. Option-2 is estimated to cost $7,361,800
with the potential for costing $9,777,800. Both options of the
selected remedy are cost-effective.
Wombla carlyl* Sandridge and Rice (WCSR)
. Letter (including enclosures) to Melissa Whittington
from Karen Carey, dated July 1, 1993.
. Two letters (including enclosures/attachments) to Melissa
Whittington from Karen Carey, dated July 6, 1993.
61. The July 1, 1993 letter and one of the letters dated July 6,
1993, from Ms. Carey enclosed a variety of newspaper articles,
editorials, announcements, letters, resolutions, a petition, a
press release, and a videotape of television news coverage of the
Site. Ms. Carey requested that EPA respond to these items in the
Responsiveness Summary.
EPA Response; The issues raised in the letters to Stan Laskowski,
Acting Regional Administrator of EPA, and issues raised in the
County Resolutions have been addressed previously in this
Responsiveness Summary. The remaining items are not comments and
were not submitted by the respective authors to EPA for comment.
Therefore, those remaining items are not addressed in this
Responsiveness Summary.
62. WCSR states that "the Remedial Investigation (RI) showed that
the only medium of concern at the Site is ground water under the
center of the Site which contains volatile organic compounds
above federal drinking water maximum contaminant levels". Page 9
of the PRAP is referenced.
EPA Response; The Baseline Risk assessment, not the RI, is the
document that identifies media, as well as contaminants, of
concern for Superfund Sites. The above-mentioned risk assessment
for this Site states that the plume of contamination poses an
excess cancer risk of 2.6 x 10"1, if exposure to the plume should
occur. The plume is not only present at the center of the Site
but it has expanded at least 140 feet from the center of the Site
referenced above.
63. WCSR states that EPA's plan will not meet ARARs at the center
of the Site due to the demonstrated ineffectiveness of pump and
treat technology.
EPA Response; See response to comment 11 regarding the perceived
ineffectiveness of extraction and treatment of the ground water.
WCSR appears to misunderstand the ARARs for potential ground
84
-------
water extraction and treatment remedies. EPA presumes that the
ARAR WCSR is referring to is that of attaining MCLs in the ground
water as set forth in 40 C.F.R. Part 141, Subpart B. As is clear
from EPA guidance, whenever the source of the contamination is
removed duaring a remedial cleanup, MCLs must be met throughout
the contaminated plume. However, when waste is left onsite the
ground water underneath the waste management area is excluded
from the definition of "area of attainment" for MCL purposes (see
Section 5.2, "Guidance for Remedial Actions for Contaminated
ground Water at Superfund Sites", December 1988, OSWER Directive
9238.1-02). Therefore, even though MCLs might not be met
underneath the cap, EPA's selected remedy still meets the ARAR
MCL requirement because the monitoring network surrounding the
cap will ensure that MCLs are achieved in the ground water
outside the management area.
64. In WCSR's evaluation of alternatives 8A and 3 using the nine
criteria, it is stated that Alternative 3 "reduces toxicity and
volume through the processes of natural attenuation of the
volatile organic compounds in the ground water; it reduces
mobility through capping the entire area to prevent ground water
movement and reduces the likelihood of future ground water
contamination."
EPA Response; The criteria that WCSR appears to be evaluating is
the reduction of toxicity, mobility, and volume of contamination
through TREATMENT. Natural attenuation and capping are not
treatment methods and therefore, do not constitute achievement of
this criteria. Moreover, EPA does not have sufficient
information indicating that the contaminants in the ground water
will naturally attenuate. Even if this were to happen, it might
take dozens or even hundreds of years thereby posing threats to
future generations during the process. Also, see response to
comment 53.
65. WCSR goes on to state that the RCRA cap included in EPA's
plan would not cover the entire area.
EPA Response; This statement is inaccurate. The RCRA cap
identified as a component of both options of the selected remedy
outlined in the ROD, will cover the entire 2 acre hazardous waste
disposal area, which is the only area for which capping is
required.
66. WCSR states the following, "The PRAP, in the section on
Short-term Effectiveness, treats restoring the aquifer to
beneficial use as a requirement of a remedial plan."
EPA Response; The Short-term Effectiveness section of the PRAP
does not state that EPA requires that the affected aquifer be
treated to its beneficial use. However, for ground water
extraction and treatment systems at most Superfund sites the goal
is restoration of the aquifer to its beneficial use. Based on
the guidance the Region has received from RSKERL on this matter,
85
-------
should extraction and treatment of the ground water be deemed
necessary at this Site based on ground water monitoring results,
the most realistic goal would be containment of the ground water
plume.
67. WCSR indicates that the conclusions drawn in EPA's ecological
risk assessment are "flawed" and should not be given any
consideration in developing a remedial plan for the Site.
EPA Response; EPA has already supplied correspondence to ES that
states the driving force behind remedy selection at this Site is
human health risk and not ecological risk. It is important to
point out, however, that many of the assumptions made in the
ecological risk assessment are conservative due to the fact that
the ecological characterization in the RI (conducted by ES) was
not complete.
68. WCSR states that EPA has violated the NCP by not including
certain key documents in the Administrative Record that reflect
the Commonwealth's involvement in EPA's decisions, specifically
(1) no comments from the Commonwealth on the draft or final
Remedial Investigation Report; (2) no comments from the
Commonwealth on the draft or final Feasibility Study; (3) no
comments from the Commonwealth on the draft or final ecological
risk assessment; (4) no comments from the Commonwealth on the
draft or final baseline risk assessment; and (5) no ARARs from
the Commonwealth.
EPA Response; There were representatives from the Commonwealth on
the panel at the public meeting. All of the draft documents
mentioned above were reviewed and commented on by the
Commonwealth. Additionally, the final documents were reviewed to
ensure that the Commonwealth's comments were adequately
incorporated into the final documents. EPA is not required to
include review comments on any draft documents in the
Administrative Record because these review comments are not
"documents that form the basis for the selection of a response
action". Preliminary ARARs were supplied by the Commonwealth
along with its review comments for the RI. Because these ARARs
were only preliminary in nature, they were not included in the
Administrative Record. In Addition, the Commonwealth supplied
EPA with comments on the draft ROD. These comments are in the
Administrative Record. Most of the Commonwealth's comments have
been incorporated into the ROD and are addressed in Section IX.
of this Responsiveness Summary.
69. WCSR states that because the transcript of the public meeting
was not placed in the Administrative Record prior to the close of
the public comment period this constitutes a "blatant disregard
for the community involvement requirements of the NCP". WCSR
additionally states that this "failure, in and of itself, could
make any remedial decision issued by EPA with respect to the
Site, arbitrary and capricious". Reference is made to 40 CFR
§300.430(f)(3) (E).
86
-------
EPA Response; 40 CFR §300.430(f)(3)(E) states: "Keep a transcript
of the public meeting held during the public comment period
pursuant to CERCLA section 117(a) and make it available to the
public". There is no time restriction associated with providing
this information, therefore, EPA has not violated the NCP. The
transcript of both public meetings are available in the
Administrative Record.
Engineering-Science, Inc.
. Letter (including attachments) to Melissa Whittington
from Susan Fullerton, dated June 25, 1993.
. Letter (including attachments) to Melissa Whittington
from Susan Fullerton, dated July 2, 1993.
70. In discussing the emphasis that EPA placed on restoring the
aquifer to its beneficial use in the PRAP, ES quotes the
following from the NCP: "when restoration of the ground water to
beneficial use is not practicable, EPA expects to prevent further
migration of the plume, prevent exposure to the contaminated
ground water, and evaluate further risk reduction." ES then
states that Alternative 3 meets these expectations.
EPA Response; Alternative 3 would not necessarily prevent
exposure to the contaminated ground water. Although Alternative
3 includes monitoring of the ground water and deed and access
restrictions, this alternative would not prevent exposure to the
contaminated ground water should this ground water migrate to
residential areas. Alternative 3 would probably not prevent
further migration of the plume anyway. Although a cap may reduce
the infiltration of precipitation through the contaminated trench
areas to the ground water, a cap will probably not affect the
migration of contaminants already in solution in the ground
water. The area surrounding this Site is a recharge area.
Precipitation will probably not be prevented from infiltrating
through these surrounding areas which will account for the
natural movement of ground water. In addition, Alternative 3 as
presented in the FS did not include any further evaluation of
risk reduction.
71. ES stated that "the ground water extraction and treatment
system would be run 24 hours a day without attendance.
Breakdowns and/or operating problems could result in emissions of
volatile chemicals to the local environment." ES concluded by
stating that these concerns were not adequately addressed in the
PRAP.
EPA Response; Both options of the selected remedy in the ROD
include provisions for long-term ground water monitoring using
trigger wells. Extraction and treatment of the ground water will
only be implemented if the ground water contamination migrates
beyond the points of compliance. If extraction and treatment of
the ground water must be implemented, breakdowns and operating
problems would not be considered a substantial risk because the
treatment units are equipped with alarm systems that would alert
87
-------
the appropriate personnel if problems were to occur. These
systems would additionally receive routine maintenance to prevent
such breakdowns.
72. ES states that the cost estimates given in the PRAP do not
reflect the descriptions of the alternatives provided in the
PRAP. ES uses Alternative 2 as an example by stating that the
costs include long-term ground water monitoring but the
description does not. ES goes on to state that EPA's cost
estimate for Alternative 8A was on a completely different basis
than the ES alternatives and it is their opinion that EPA's costs
are low.
EPA Response: As previously discussed in this Responsiveness
Summary, EPA agrees that the PRAP was not completely clear when
discussing all of the components of the remedies that included
ground water extraction and treatment. Although not expressly
stated, all of the ground water extraction and treatment remedies
presented in the PRAP do include long-term monitoring. An
extraction and treatment system cannot run effectively unless its
progress is monitored through sampling. This sampling was
inherently included as a component of all extraction and
treatment systems in the PRAP.
The reason that EPA's cost estimate for Alternative 8A is on
a different basis from the ES estimates is because EPA did not
agree with.the methodology used by ES in its cost estimates. ES
cost estimates, especially for the alternatives that included
excavation, appeared to be biased high. Specifically, the
percentages used for contingencies were not realistic. In the
draft FS, ES included as much 70% markups to the estimated
capital cost of the remedy. The contingency percentages were
revised in the final FS, in response to EPA and VDEQ comments,
but were still higher than necessary (50%). EPA contends that a
thorough cost estimate for a remedy, such as 8A, that utilizes
known technologies with limited uncertainty do not need to be
marked up any more that 20%, which was used in EPA's cost
estimate for Alternative 8A and EPA's cost estimate for the
selected remedy. In addition, the cost estimate for the selected
remedy in the ROD was prepared by the Estimates and Technical
Services branch of the Bureau of Reclamation (BUREC) in Denver,
with the assistance of EPA Region III. Complete detailed cost
documentation is provided in the Administrative Record.
73. ES points out that excavation of the western disposal trench
was not included in the description of Alternatives 5 through 8
in the feasibility study yet were included in the PRAP without an
adjustment of cost.
EPA Response; For excavation alternatives that did not also
include RCRA capping, both EPA and VDEQ determined that the
remedies would not be complete unless excavation of the western
disposal trench was included. In order for EPA to select any of
those alternatives the western disposal trench either had to be
88
-------
included as part: of the excavation or capped. It was an
oversight on the part of EPA to not adjust the cost estimates
accordingly. The ROD states that these alternatives, if
selected, would cost more than the estimates provided due to
inclusion «f the western disposal trench in the excavation.
74. ES contends that the following statement from the PRAP, which
refers to Alternative 8A, is inaccurate, "...these alternatives
would eliminate the source of contamination at the Site...". ES
implies that EPA would only be removing a portion of the
contamination source.
EPA Response: The contamination referred to in the above
statement is the plume of ground water contamination, which is
the media which presents the unacceptable risks at this Site.
The RI states on page 7-5 that, "the easternmost disposal trench
was shown to be the primary source of contamination". In
addition, due to the direction of the ground water flow, the
location of the existing plume, and the fact that contaminants
were found in the ground water that were not found in the eastern
disposal trench, EPA contends that the barrel trench may also be
a primary source of the ground water contamination. ES goes on
to state on page 7-6 of the RI that, "Samples from the
evaporation trench, the western disposal trench and from the
south boundary of the barrel trench (as defined by ES) had low
levels of several organics and metals but not significant
levels". Accordingly, EPA does not consider these areas
significant sources of the ground water contamination.
Therefore, the original statement is not inaccurate.
75. ES has outlined specific comments stating its opinion
regarding errors in the EPA cost estimate. In addition, ES
contends that because different methods of cost estimation were
used by ES and EPA that the costs for the alternatives presented
in the FS can not be compared with the costs for Alternative 8A.
ES also commented that the EPA cost estimate was not reviewed by
a licensed engineer.
EPA Response: EPA cost estimate for Alternative 8A was prepared
using the Cost of Remedial Action (CORA) program. The CORA model
uses Site assumptions that are inserted into the program via data
input and the model does not provide comprehensive backup
documentation. The complete detailed package for documentation
of the cost estimate for the selected remedy in the ROD was
prepared by BUREC and is in the Administrative Record.
Volumes estimated for excavation are directly related to the
cost estimates. The difference between ES's volume estimates for
the eastern disposal trench and the barrel trench and EPA's
volume estimates used for these same trenches have been clearly
explained in both the ROD and previously in this Responsiveness
Summary (see response to comments 7 and 8). Concerns about the
cost estimate for 8A in the PRAP not being reviewed by a licensed
engineer are not relevant because there is no such requirement.
89
-------
The statement that a comparison can not be made between the
cost estimates provided for Alternatives l through 8 in the FS
and the cost estimate for 8A is a moot point. Comparison of
costs is a requirement of the law. As previously stated, EPA
does not agree with the methodology used by ES to estimate costs
and therefore, will not be adopting this methodology for the sake
of comparison. However, even if different methodologies have
been used for various alternatives, this information still gives
the Agency sufficient information to make rough cost comparisons
between the various alternatives.
76. ES had concerns over the preliminary remediation goals (PRGs)
listed in the PRAP.
EPA Response; The selected remedy in the ROD does not utilize the
PRGs presented in the PRAP. Because the entire Site will be
covered by a RCRA cap, preferably after the principal threat
wastes have been treated or removed (under Option 2), it is not
necessary to set soil cleanup goals for the selected remedy.
EPA has adopted the position that due to specific Site-
related circumstances it is appropriate to monitor the ground
water using "trigger wells", until such a time that migration of
the ground water plume beyond the points of compliance is
detected. At that time, ground water extraction and treatment
with the goal of containing the plume within the points of
compliance will be implemented. When ground water extraction and
treatment is implemented, the cleanup goals for the area of
attainment will be the MCLs or heath based levels, if no MCL
exists.
77. ES states, "in light of USEPA's preference for treatment as
part of the remedial plan, ES and the PRP's propose that the
agency incorporate into Alternative 3, as a contingency, vapor
extraction at the eastern disposal trench". ES goes on to
explain that Alternative 3 would be implemented and in the event
that migration of contamination was detected by the "trigger
wells", the vapor extraction contingency would automatically be
implemented.
EPA Response; Treatment of the principal threat wastes at this
Site was not incorporated into the preferred remedy presented in
the PRAP solely because of the Agency's preference for treatment.
Alternative 8A was presented as the preferred alternative in the
PRAP because it represented the best balance among all the
evaluation criteria for achieving long term environmental
protection in a cost-effective manner.
EPA is aware of the PRPs desire to use ISVE in the eastern
disposal trench. However, EPA is not convinced that this
technology can effectively treat the waste material in this
trench. ISVE was included as part of the preferred remedy in the
Addendum to the Proposed Plan (Addendum) issued on November 24,
1993, however in the event that ISVE proved to be unsuccessful
90
-------
then excavation and offsite incineration would be have been
implemented under the preferred alternative in the Addendum
(Alternative 8C). In the ROD, both options 1 and 2 of the
selected remedy give the implementing party the opportunity to do
a pilot study for ISVE in the eastern disposal during design of
the cap and ground water monitoring system for Option 1 or at any
time during design of Option 2. If this pilot study indicates
that ISVE may be feasible based on specific criteria outlined in
the ROD, then full scale ISVE may be implemented. If either the
pilot study indicates that ISVE is not feasible in the eastern
disposal trench or full scale ISVE cannot meet the performance
standards mentioned above, then excavation and offsite
incineration of the waste materials in the eastern disposal
trench will be implemented.
V. SUMMARY OF SIGNIFICANT COMMENTS FROM THE APRIL 26, 1994 PUBLIC
MEETING COMMENTS AND EPA RESPONSES
Questions and comments presented at the April 26, 1994,
public meeting are listed and/or summarized briefly in this
section and are grouped according to subject. Many of the
concerns and issues raised at this meeting have been covered
previously in this responsiveness summary and therefore will not
be addressed in this section. The EPA response follows each new
significant question or comment.
A. The following written comments were submitted to EPA at the
public meeting:
78. In addition to reading a statement at the April 26th public
meeting, Representative L.F. Payne provided written comments.
Significant comments, not previously addressed are summarized
below followed by EPA responses.
(a) Rep. Payne states in his written comments that, "the
relocation of wastes does nothing to reduce the long-term
liability of the PRPs. Moving contaminated waste materials from
place to place does not eliminate environmental pollution."
EPA Response; The purpose of selecting a remedy to cleanup a
Superfund Site is to protect human health and the environment,
not to reduce PRP liability. When hazardous wastes are disposed
of in uncontrolled situations with no liner or leachate
collection systems to protect the environment from releases of
contamination, then there is value in relocation of the waste
materials to a facility that employs such environmental
safeguards. In addition, under either Option 2 of the selected
remedy, or if the contingencies are triggered under Option 1, the
concentrated hazardous wastes will be excavated and incinerated
offsite at an already existing permitted hazardous waste
incineration facility. This facility would not just cover up the
waste but would actually destroy the waste materials so that
their associated contaminants would not be available to migrate
into the environment. EPA will issue a subsequent decision
91
-------
document addressing excavation in the barrel trench based on
additional studies of that area.
(b) Rep. Payne discusses EPA's change in cleanup standards for
the eastern disposal trench when the preferred remedy changed
from excavation to insitu soil vapor extraction (ISVE).
EPA Response: In the PRAP, preliminary soil cleanup goals were
developed by EPA using the Summers Method for protection of
ground water. The preferred alternative in the PRAP included
excavation of concentrated waste material and soil in the eastern
disposal trench and the barrel trench with incineration and
disposal of these wastes. In both cases, the trenches would be
opened, and visibly contaminated material (such as drums in the
barrel trench and the waste layer in the eastern disposal trench)
could be observed and removed. Thus, the preliminary soil
cleanup goals were provided for post-waste-removal soil sampling
to ensure that significant contamination in soil below and
surrounding the visibly contaminated waste material would also be
removed. EPA's selected remedy requires additional study of the
barrel trench and a subsequent decision document, including
performance standards for excavation of this trench, will be
issued when the studies are complete.
If the preferred remedy involved any technology other than
excavation, EPA did not envision using these preliminary soil
cleanup goals presented in the PRAP. If implementing party can
prove that ISVE is feasible in this trench, then ISVE may be
implemented full scale. The performance standard for ISVE set in
this ROD is as follows:
ISVE will continue until contamination levels in the waste
layer and surrounding soils are no longer a source of
contamination to underlying ground water which results in
ground water contamination above ground water cleanup
requirements set in this ROD. The cleanup criteria will be
determined during the remedial design by considering the
characteristics of the waste layer and surrounding soils and
associated contaminants and then deriving specific levels of
contaminants in the waste layer and surrounding soils that
would not be expected to exert a significant impact on
underlying ground water.
79. Two written comments were submitted at the public meeting
which simply stated, "I support cap and monitor".
EPA Response; See response to Comment 17.
80. The County of Appomattox submitted comments in the form of a
resolution adopted by its Board of Supervisors. This resolution
voiced opposition to the EPA PRAP Addendum and support for
Alternative 3.
EPA Response: See response to Comment 1.
92
-------
B. At the April 26th public meeting, prior to presentations by
EPA staff/ statements were read by Representative L.P. Payne,
Chief of Staff from Senator Charles Robb's office, Tom Lehner,
and William Woodfin, former Deputy Director for Operations for
the Virginia Department of Environmental Quality, significant
comments not previously addressed are summarized below followed
by EPA responses.
81. Tom Lehner made the following comments, not already addressed
in this responsiveness summary, on behalf of Senator Charles
Robb:
(a) Mr. Lehner specifically stated that Senator Robb was troubled
by EPA's "abandonment of the Summers Model".
EPA Response; This statement is the same as the one made by
Representative Payne in his written comments regarding the change
in the cleanup standards. See response to Comment 79 (b) .
(b) Mr. Lehner stated that Senator Robb was troubled that EPA had
billed over $500,000 to the County without providing specific
justification for the costs.
EPA Response; At that time and to date, EPA has not billed the
County or any of the other PRPs for the RI/FS oversight costs.
However, the PRPs agreed to pay any and all oversight costs
associated with the RI/FS when they signed the Administrative
Order by Consent with EPA. When a bill is sent, it will be sent
to the PRPs' project coordinator with a package, detailing the
costs, accompanying the bill. The actual figure is $229,345,71,
not $500,000. This figure may be adjusted for annual allocation
costs from EPA contractors.
C. At the April 26th public meeting, prior to the start of the
question and answer segment, a presentation was given by Susan
Fullerton of Engineering-Science, Inc.(ES). Any significant
comments made during this presentation, which are different from
those already addressed above, are summarized below, followed by
the EPA response.
82. As at the first public meeting, ES indicated that the cost of
EPA's preferred alternative in the Addendum would actually cost
much more than the $9 million dollar cost estimate provided by
EPA, assuming all the contingencies would have to be implemented.
EPA Response; ES announced to the residents at the April 26th
public meeting that if all the contingencies had to be
implemented, EPA's remedy (Alternative 8C) would cost $30-40
million. However, again no backup cost documentation was
provided to substantiate this claim.
83. ES stated that, "EPA came to the PRPs, and told us that we
needed to come up with some other ideas for the eastern disposal
trench, or excavation and incineration would remain in the plan."
93
-------
EPA Response; EPA never asked the PRPs to come up with other
ideas for the eastern disposal trench. On the contrary, EPA
indicated to the PRPs that it was highly unlikely that the ROD
would call for capping and monitoring of the Site alone, and that
the source'areas at the site would have to be addressed via
treatment, as opposed to containment. In response, the PRPs
proposed using soil vapor extraction with horizontal wells at the
eastern disposal trench.
84. ES stated that, "the new standards are significantly lower
and harder to meet". ES went on to say that the new model had
not been used to their knowledge at any other sites.
EPA Response; There were no new standards set in the Addendum.
What was presented in the Addendum was a methodology that EPA had
considered using, to set standards for the performance of the
ISVE system that was proposed. The methodology had recently been
used at a site in Region VII that had named ISVE as the selected
remedy. EPA included this proposed methodology to allow the
PRPs, as well as other interested parties, to comment on it so
that EPA could take their comments into consideration when the
cleanup standards were actually set for ISVE in the ROD. Also,
see response to comment 78(b) for an explanation regarding the
inappropriateness of using the Summers Method to set standards
for ISVE.
85. ES stated that, "EPA has set a time limit on how long the
system would be allowed to operate, and if we don't meet those
stringent cleanup limits within the time period, or show
substantial gains toward meeting them, then the contingency kicks
in for excavation and offsite incineration."
EPA Response; EPA did not develop the timeframe mentioned by ES.
When ES came to EPA with its proposal for ISVE, it indicated to
us that it could meet the preliminary soil cleanup standards that
were identified in the PRAP within 18 months. However, as
explained in response to comment 78(b), the preliminary soil
cleanup standards presented in the PRAP are not appropriate for
evaluating ISVE. In the Addendum, the 18 month time frame was
identified as an evaluation point. EPA did not state that the
ISVE system would be abandoned if the standards were not met
within the 18 months.
86. ES states that the Addendum makes broad statements regarding
the excavation of the barrel trench. And in addition, if the
barrel trench is sampled and contamination is found above the
levels that were set for ISVE at the eastern disposal trench,
then EPA would implement excavation in the barrel trench.
EPA Response; As stated above in the response to comment 84,
cleanup standards were not set for ISVE in the eastern disposal
trench. Under Option 2 of the selected remedy or Option 1 in the
contingency requirements are invoked, a representative number of
test pits will be excavated in the barrel trench and samples from
94
-------
these pits will be analyzed. The information gained from visual
observations during test pitting and analytical results from
sampling shall be compiled and remedial action alternatives shall
be evaluated in a Focused feasibility Study (FFS). The
appropriate source control measures for the barrel trench will
then be selected in a subsequent EPA decision document.
87. ES states that, "EPA would require test pits or some type of
large hole to be dug through the existing cap in order to sample
the contents of the barrel trench. That would ruin the existing
cap that's there and allow rainfall to enter this closed, dry
system."
EPA Response; Yes, EPA will require test pits to be dug through
the existing cap in order to sample/observe the contents of the
barrel trench, if Option 2 of the selected remedy is implemented
or if the contingency requirements for Option 1 are invoked.
However, this piercing of the existing cap will not pose a risk
to the community. At the end of each working day and during the
time that samples are being analyzed, the test pits will be
appropriately covered to prevent precipitation from entering the
pits.
88. ES states that EPA's cost estimate includes only 1/5 of the
volume of the barrel trench.
EPA Response; See response to Comment 7 regarding the volume
estimate for the barrel trench. Also, additional studies in the
barrel trench required by this ROD will provide sufficient
information for an accurate volume estimate should excavation
prove to be necessary.
89. ES states, "In one of EPA's recent newsletters that you-all
have received, they stated that although test pits conducted in
the 1980's showed empty crushed drums throughout the entire
trench, EPA does not consider this to be part of the barrel
trench. Why? They don't explain why."
EPA Response; The test pits dug in the 80's did not show that
empty crushed drums were present throughout the entire capped
area of the barrel trench. On the contrary, less than half of
the test pits showed empty crushed drums. Although the
newsletter referred to above does explain why EPA does not
consider the area south of the barrel trench to be part of the
"barrel trench", for the sake of clarity it is re-explained
below. EPA is not opposed to the cap and monitor theory.
However, in the Agency's opinion, in order for a cap and monitor
remedy to be successful in the long-term, the concentrated waste
sources that are present onsite must first be removed. The
concentrated waste source in the eastern disposal trench is
defined as the layer of "taffy-like" waste present in this
trench. For the barrel trench the designation of "concentrated
waste source" is more difficult. Because of this EPA has
determined that additional information is needed regarding the
95
-------
barrel trench and once this information is available, EPA will
issue a subsequent decision document which will select an
appropriate remedial action for the barrel trench.
However, it should be noted that there were contaminants
found in the ground water that were not detected in the eastern
disposal trench and the direction of flow of the ground water in
conjunction with the current known location of the plume
indicates that the barrel trench is a probable source of the
ground water contamination. Since the area south of the
"historical barrel trench" was not found to contain any drums or
significantly elevated levels of contamination during the RI,
this area is not included in previous volume estimates for
excavation of the barrel trench. Also, see response to Comment 7.
90. In the same newsletter referenced above, EPA stated that,
"Records describing the hazardous waste operation at the Site are
almost non-existent." According to ES, this statement is not
true for the following reasons: (1) EPA used Mr. Love's past
records to identify PRPs for the Site; (2) Mr. Love still lives
in the County; and (3) old landfill operators still live in the
County.
EPA Response; There are no clear written records, in the form of
manifests, or something comparable to manifests, that can
document the types of wastes or the exact volumes of these wastes
that were disposed of at the Site.
91. ES discusses a specific error regarding the cost of operation
and maintenance for the ground water pump and treat system.
EPA Response: EPA's cost estimates for ground water monitoring
and ground water extraction and treatment were re-calculated by
the Engineering Services Group of the Bureau of Reclamation
(BUREC). Documentation of the cost estimate details are in the
Administrative Record.
D. The following significant issues were raised by residents
during the April 26, 1994, public meeting:
92. One citizen asked if EPA is willing to settle with the County
for an amount significantly less than 100% cost of the Site
remediation and if the County had pursued this option.
EPA Response; EPA has had discussions with the County regarding
this particular issue. EPA is willing to consider a settlement
with the County that would be based on the County's ability to
pay and has suggested to the County that negotiations for a
settlement be initiated. At this time, EPA is waiting for the
County to respond to the Agency on this matter.
93. One citizen was concerned about the fact that the PRPs had
not received a bill for RI/FS oversight.
96
-------
EPA Response; It is not uncommon for there to be a delay in the
actual billing. The bill for RI/FS oversight costs is currently
being prepared and will be sent to the PRPs project coordinator
as soon as it is completed.
-»
94. One citizen asked if the EPA had considered the economic
impact to Central Virginia, including the potential loss of jobs,
and if this information was documented anywhere.
EPA Response; What EPA is required to do under the formal
Superfund process is to look at the cost of each alternative
relative to one another and evaluate the cost effectiveness along
with the other eight criteria outlined in CERCLA and the NCP. A
cost-benefit type analysis for the community is not something
that EPA is required to do when selecting a remedy for a
Superfund Site. The remedy selection process is purposefully not
based on the PRPs ability to pay. However, EPA may consider
entering into "ability to pay" settlement when the cost of
implementing a remedy would impose a significant economic
hardship on one or more PRPs. Also, see response to comment
2(b), 16, and 20.
95. One citizen, who lives downgradient of the Site, made the
following comments:
(a) It doesn't matter what is costs, just clean it up.
EPA Response; Although CERCLA has a statutory preference for
removal or permanent treatment of the Site contamination, CERCLA
also requires EPA to take cost-effectiveness into account in its
selection of remedies. SPA believes that the most cost-effective
remedy that eliminates risks to human health and the environment
has been selected.
(b) It is hard to believe a company with $2.5 billion in sales
during 1992 alone would go bankrupt from funding their share of
this remedy.
EPA Response; This commenter appears to be referring to
Thomasville Furniture. EPA has not received any documents from
Thomasville, or any of the other PRPs, to indicate that
implementing the proposed remedy for the Site would cause an
undue economic hardship for any of these companies.
96. One resident, who claimed to be the closest resident to the
Site, made the following comments:
(a) If Armstrong has the money to put out for all the advertising
for cap and monitor that they have been doing, they certainly
should have enough money for their share of the cleanup.
EPA Response; EPA takes no position on this assertion.
(b) Let's not leave it (the waste) there for future generations
97
-------
to have to deal with later. Let's do something now and get it
over with.
EPA Response; This is part of the statutory intent of CERCLA.
97. Susan Fullerton of Engineering-Science made the following
comments during the comment section of the meeting:
(a) Ms. Fullerton made the statement that in EPA's March 30th
newsletter 5 compounds were listed as being found in the eastern
disposal trench but that 2 of those five compounds were not
actually detected in the soil/waste samples in the RI.
EPA Response; Technically, that statement is correct. But, what
is not explained is that the samples that were obtained from the
eastern disposal trench were so grossly contaminated that the
laboratory had to dilute them. This means that the detection
limits for certain compounds increased substantially.
Specifically, for 1,1,1-Trichloroethane and tetrachloroethane,
the samples had to be diluted to such an extent that, for each
compound, as much as 28,000 parts per billion of the contaminant
could be present and the sample results would still indicate non-
detect. This cannot be overlooked by EPA and in most cases when
such high detection limits are used the compounds are assumed to
be present. Additionally, in the newsletter these compounds were
used as examples and there were many compounds that were actually
detected. In addition to toluene and xylene that were mentioned
in the newsletter, the following compounds were actually detected
in samples from the eastern disposal trench: 2-Butanone, 4-
Methy1-2-Pentanone, styrene and ethylbenzene.
(b) Ms. Fullerton stated that in the February 1994 EPA newsletter
the Agency stated that the ground water has moved outward from
the Site. She claims that this is not the case.
EPA Response; See response to Comment 3.
(c) Ms. Fullerton again discussed a statement from the April 13th
newsletter that indicated records describing hazardous waste
activities are nonexistent. She claims that this is not the
case.
EPA Response; See response to Comment 91.
(d) Ms. Fullerton made, the statement that in one of EPA's
newsletters the statement was made that, if crushed empty drums
are found in the barrel trench then the trench could be capped
without excavation. She then questioned how EPA could find out
about the drums without excavation.
EPA Response; EPA has proposed test pitting in the barrel trench
to find out what is actually present in this trench. Further
investigation of this kind is necessary in order appropriately
remediate this trench. EPA agrees that test pitting is a form of
98
-------
excavation and the newsletter should possibly have been more
specific.
(e) Ms. Fullerton stated that the "area of the barrel trench is
in dispute*.
EPA Response: EPA does not believe that the area of the barrel
trench is "in dispute". The area of the barrel was clearly
identified in the RI. The barrel trench was located at the
southern portion of the Site and, as described on page 1-8 of the
RI, was approximately 400 feet long, 20 feet wide, and 14 feet
deep. This area was specifically used for disposal of supposedly
empty, crushed drums and is referred to as the barrel trench.
Also, see response to comments 7 and 8.
(f) Ms. Fullerton stated that none of the compounds that were
found in the eastern disposal trench are known carcinogenic.
EPA Response: This statement is technically correct. However,
many compounds that are carcinogenic (i.e.. tetrachloroethene)
could be present at levels up to 28,000 (ug/kg) and still not be
detected due to the significant increase in detection limits as a
result of dilution of samples in the laboratory [see response to
comment 97(a)]. Moreover, the waste material in the eastern
disposal trench is characteristically ignitible and is therefore,
a hazardous substance. There were extremely high levels of many
other contaminants in this trench and excavation and treatment of
the waste materials in this trench is warranted, as set forth in
Sections V. and VI. of the ROD and the Baseline Risk Assessment.
More importantly, many compounds found in the ground water are
carcinogenic. One possible source for these ground water
contaminants in the eastern disposal trench, if the carcinogens
in the ground water did not originate in the eastern disposal
trench then EPA believes they must have originated in the barrel
trench.
98. One citizen made the following comment, "I don't care how
much it costs to fix something that future generations can use.
And I think that if we don't do something now, in 20, 50 years
the cost will be 1000 times what we are talking about today.11
This commenter closed with the statement, "I think the cap and
monitor is a band-aid for a cancer1*.
EPA Response; Cost-effectiveness is one of the nine criteria EPA
uses to evaluate each of the alternatives. EPA has revised the
preferred alternatives presented in the PRAP and the Addendum to
reduce the cost without decreasing the effectiveness of the
selected remedy. EPA agrees that preserving areas for future
generations is not only important but is mandated by CERCLA.
Also, see response to comment 97(a).
99. One citizen made the following comment, "Since the material
has not moved, let us monitor and deal with it when and if the
99
-------
problem arises".
EPA Response; The "material" has moved. Contaminants have
migrated from the trenches into the ground water and the ground
water contamination has migrated approximately 140 feet from the
center of the trench area. However, some believe that this
migration occurred prior to closure of the Site in 1983, when the
individual trenches were capped. As a result, the selected
remedy includes the option the cap and monitor the Site initially
with the requirement of implementing source control measures only
if the ground water contamination migrates beyond the points of
compliance. If the implementing party chooses to implement this
option of the selected remedy (Option 1), that party runs the
risk of having to remove the cap to implement the source control
measures and then replacing the cap. Also, leaving the source
materials onsite increases the risk that the implementing party
may have to implement ground water extraction and treatment
measures indefinitely, if the cap proves to be ineffective in
preventing source contamination from leaching into the ground
water.
100. Marie Hill, a member of the Buckingham County Board of
Supervisors, made the following comments and requests:
(a) Ms. Hill requested that a transcript of the briefing EPA gave
to the Buckingham County Board of Supervisors on February 24,
1994, be made part of the public record.
EPA Response: EPA is not required to have transcripts made of
briefings for the local elected officials. Due to the fact that
a stenographer was not present at that briefing, no transcript is
available.
(b) Ms. Hill also made the following request, "I am requesting an
itemized accounting of EPA's expenses on Love Landfill. I am
sure EPA would not accept this report which EPA gave Senator
Warner's office showing the expenses to be $530,000. "
EPA Response: An itemized accounting of the RI/FS oversight costs
incurred by EPA will accompany the oversight bill which will be
sent to the PRPs' project coordinator in the near future. The
"report" referred by Ms. Hill is a document given to Senator
Warner's office by EPA. This document was not a report but the
summary sheet showing the categorized costs incurred by EPA at
this Site. This summary sheet is the first page of the EPA
report that itemizes and accounts for all costs incurred by EPA
at this Site for oversight of the RI/FS that was conducted by
Engineering-Science, Inc., the PRP's contractor.
(c) Ms. Hill commented that EPA did not include the Buckingham
Board of Supervisors in any of the four mailings sent to the
Buckingham citizens. The Board of Supervisors finally received
copies of these four mailings on April 20, 1994.
100
-------
EPA Response: The master mailing list was originally made up of
citizens who signed up to be on such a mailing list at the
beginning of the RI/FS process. EPA did not intentionally
exclude the Board of Supervisors from that mailing list. When it
was discovered that the County Administrator, Dave Moorman, was
not on the master mailing list, EPA went back and sent all four
of the mailings to each of the board members to make sure that
they had received them before the public meeting which was held
on April 26, 1994.
(d) Ms. Hill Made the comment that EPA never officially notified
Buckingham County of this public meeting and she questioned this
failure to notify the Board.
EPA Response; Buckingham County Administrator, Dave Moorman, was
closely involved with rescheduling the second public meeting.
EPA spoke to Mr. Moorman on a number of occasions in an attempt
to specify a date that was suitable to all parties. It should be
noted, however, that coordination with local officials when
scheduling public meetings is not required by law, but is done at
the discretion of EPA. The only requirement in this regard is
that EPA run an ad in the local newspapers announcing the date,
time and location of the public meeting and this was done for
this particular meeting.
VI. SUMMARY OF SIGNIFICANT COMMENTS FROM CITIZENS RECEIVED
DURING THE SECOND PUBLIC COMMENT PERIOD AND EPA
RESPONSES
Between two and three hundred letters were received by EPA
during the second public comment period. Many of the concerns
voiced in these letters have been addressed previously in this
responsiveness summary. The following additional comments
regarding the Addendum to the Proposed Plan, which are
significant and relevant to this Site, were raised in the letters
from citizens:
101. One citizen commented that cap and monitor was not the
solution to the problem but would only turn the problem over to
future generations.
EPA Response; See response to comment 98.
102. One citizen commented that to ensure that no releases of
hazardous substances from the Site occur which could threaten
human health or the environment, "active measures" need to be
taken.
EPA Response; EPA agrees that active measures need to be taken
which is why the selected remedy includes active source control
measures initially for Option 2 and as a contingency for Option
1. These active measures include the following: (1) ISVE in the
eastern disposal trench if this technology is proven to be
feasible; (2) excavation and offsite incineration of wastes and
101
-------
contaminated soils from the eastern disposal trench if ISVE is
not proven to be a feasible; (3) potential excavation and offsite
disposal of hazardous substances from the barrel trench if this
is warranted based on additional studies; and (4) extraction and
treatment of the contaminant ground water if migration of the
plume is detected. Although Option 1 does not initially include
source control measures, such measures will be required if
migration of the contaminated ground water plume is detected.
103. One citizen stated that the position taken by the PRPs that
the ground water contamination is not moving can not be
substantiated.
EPA Response: EPA agrees with this statement. Also, see response
to comments 13 and 15(c).
104. One citizen stated that limiting assessment of metals
contamination to filtered samples was erroneous.
EPA Response: EPA risk assessment guidance indicates that when
there is a large discrepancy between the filtered and unfiltered
sample results, then the filtered sample results should be used
in the risk assessment. However, EPA has similar concerns
regarding heavy metals in the ground water and the long term
ground water monitoring program will include analysis of heavy
metals.
105. One citizen made the statement that, "EPA has previously
attributed beryllium and chromium to the Site". Letters from EPA
were attached.
EPA Response: Although EPA indicated that beryllium and chromium
were present in the residential well in question, neither of the
letters provided indicated that this contamination was Site-
related.
106. One citizen made the statement that the current ground water
monitoring network was inadequate.
EPA Response; EPA agrees with this statement and both options of
the selected remedy, require design and construction of a new
ground water monitoring network. This network may, however,
utilize some of the monitoring wells that currently exist.
107. One citizen indicated that the RI/FS should not have been
limited to the hazardous waste disposal area but should have also
included the domestic waste landfill.
EPA Response: See response to comment 51.
108. One citizen stated that "cap and monitor" does not meet the
threshold criteria and that ground water treatment was necessary.
102
-------
EPA Response: The threshold criteria include the following (1)
overall protection of human health and the environment; and (2)
compliance with Applicable and Relevant and Appropriate
Requirements (ARARs). The cap and monitor option of the selected
remedy will meet both of these criteria (as does the source
control option). For the cap and monitor option, ground water
extraction and treatment as well as source control measures will
be implemented when and if the ground water contamination
migrates beyond the points of compliance.
109. One citizen stated that additional study should be done in
the evaporation trench and the western disposal trench.
EPA Response; To make decisions regarding Superfund cleanups, it
would be ideal for EPA to have complete sampling data for every
area of each Site. However, due to time and financial
constraints, and given the existing information available to EPA
on these two areas, EPA decided to make the decision regarding
the selected remedy for this Site without additional studies of
these two areas. In this situation, we have sampling data that
indicates there are only slightly elevated levels of contaminants
in the evaporation trench and the western disposal trench. As a
result, EPA has determined that the selected remedy will include
capping of these particular areas.
110. One citizen discusses a 5 x 5 x 8 foot pit that was used to
dispose of waste from Thomasvilie Furniture.
EPA Response; It is not clear where this particular trench is
located onsite. All of the trenches in the hazardous waste
disposal area were investigated as part of the RI.
111. One citizen discussed how the State was aware that disposal
of liquid hazardous wastes at this Site would lead to ground
water contamination.
EPA Response; EPA can not respond on behalf of the Commonwealth
regarding this comment. Also, see response to comment 38.
112. One citizen made the statement that the evaporation trench
was actually an injection trench and that this trench should be
considered a source and treated accordingly.
EPA Response; See response to comment 109.
113. One citizen has made the comment that there appears to be
conflicts of interest between the State, Engineering-Science
(ES), and the County. Additionally, there appears to be a
connection between Armstrong Furniture and the Buckingham County
Board of Supervisors.
EPA Response; EPA does not have any information to substantiate
this citizen's claim that there is a conflict of interest between
these entities.
103
-------
114. One citizen questioned whether the Troublesome Creek
Reservoir was actually upgradient.
EPA Response; As stated in the ROD, although the Troublesome
Creek Reservoir is topographically lower than the Site, it is in
a different watershed. The RI did not indicate that this
reservoir was affected by site-related contaminants.
115. One citizen asked that EPA postpone the making a final
decision about the remedy long enough for the following: (1) the
community to obtain a Technical Assistance Grant (TAG); (2) to
hold a public meeting; and (3) then allow 30 days of comment
after the public meeting.
EPA Response: A TAG grant can be obtained at any time during the
Superfund process. It would not be advantageous to either the
citizens or EPA to postpone the ROD issuance until a TAG grant
could be obtained, since these grants can take up to 6 months or
more to procure by interested parties.
116. One citizen expressed concerns about the feasibility of
using ISVE at this Site and wanted to know what EPA considered
the probability to be of ISVE's success.
EPA Response: EPA also has concerns regarding the feasibility of
ISVE in the eastern disposal trench at this Site. For this
reason, the contingency requirements for excavation and offsite
incineration- of the waste materials in the eastern disposal
trench were built into the Addendum to the PRAP. Currently, the
selected remedy in the ROD gives the implementing party the
opportunity to conduct ISVE treatability studies. If these
studies prove that ISVE could be a feasible technology for
treatment of the waste in the eastern disposal trench, then the
implementing party may implement this technology in full scale.
However, if the full scale ISVE can not meet the performance
standards set by EPA after the necessary additional information
is gained in the treatability study, then excavation and offsite
incineration will be implemented. EPA believes the most prudent
approach would be to utilize already proven technologies and
implement excavation and offsite incineration up front.
117. One citizen commented that they were in favor of "vapor
extraction only" without any of the contingency options.
EPA Response: In order for EPA to ensure protection of human
health and the environment it is necessary to include contingency
options just in case ISVE fails. One other problem with not
including the contingency options deals with the timeframe of
cleanup. Significant delays could be experienced if no alternate
cleanup methods were included in the ROD now.
118. A few citizens have indicated that if the Superfund Law were
to be reauthorized prior to issuance of the Buckingham ROD, that
"cap and monitor" would be the most appropriate remedy for the
104
-------
Site.
EPA Response: Comments about the impact that reauthorization of
Superfund might have on proposed remedies at existing Superfund
sites are too speculative to require response in this Responsive
Summary. However, EPA Headquarters has advised the Regions to
move forward with Superfund site remediations without waiting to
see when, and under1 what conditions, Superfund is reauthorized.
119. One citizen indicated that our "treatment" under Alternative
8C would not be a permanent remedy which will restore the Site to
any usefulness.
EPA Response: EPA has never intended to "restore the Site to any
usefulness" in the sense that the property would not be suitable
as a residential area even with the treatment measures that have
been proposed under Alternative 8C. In this respect this citizen
is correct. However, ISVE, if it were successful, or off site
incineration, if ISVE is not successful, would remove the
contaminants from the waste layer in the eastern disposal trench.
This treatment is permanent, unlike capping alone, which allows
the contamination source to remain onsite increasing the
possibility that additional remediation measures will be
necessary in the future. In addition, removal of hazardous
substances from the barrel trench, if deemed necessary by EPA
following additional studies in this trench, would also
represent use of permanent remediation measures.
120. One citizen made the following statement, "In your March 19,
1994, newsletter you state, "EPA by law, has a preference to
treat rather than rather than contain (e.g.,cap) concentrated
hazardous waste that is likely to move." At no time have you
provided any evidence showing the probability of the VOC's to
move from their present position".
EPA Response: The concentrated waste sources at this Site are
present in trenches that are no deeper that 15 feet. These waste
sources contain extremely high concentrations of VOCs. Ground
water is encountered approximately 30 to 35 feet below the ground
surface. The ground water is contaminated with the same
contaminants found in the waste sources onsite. Therefore, the
contaminants have migrated from the trenches to the ground water.
With regard to lateral movement, the plume of contaminated ground
water has expanded approximately 140 feet from the center of the
Site (MW-2 well cluster). As far as the probability that the
contaminants will move from their present position is concerned
should a RCRA cap be installed at the Site, it is difficult to
calculate such probabilities. However, keep in mind that all
ground water moves and this ground water contamination has moved
already. The data outlined above is evidence that the ground
water has moved. Nonetheless, the selected remedy in the ROD
gives the implementing party the opportunity to cap and monitor
the Site with the contingent source control and ground water
treatment measures if the ground water migrates beyond the points
105
-------
of compliance. These monitoring points are approximately 60 feet
beyond where the plume was estimated (by the PRPs) to be in July
of 1992.
121. One citizen made the statement that, "You (EPA) disregard
the possibility that a future treatment could be more efficient,
effective, which could erase the problem, and not just cause us
to spend millions now and again later."
EPA Response; EPA is responsible for cleaning up hazardous waste
sites. The decisions regarding what technologies/treatment
measures will be used to clean up these sites must be documented
in Records of Decision (RODs). EPA cannot postpone the issuance
of RODs on all Superfund sites in hopes that in the future there
will be more effective cleanup technologies. However, if Option
1 of the selected remedy is implemented, the Site will be capped
and monitored until migration of the ground water contamination
is detected at the points of compliance, at which time the source
control measures outlined in the ROD will be implemented. If
there is a new technology available that is more effective and is
feasible for this Site, EPA could choose at that time to change
the selected remedy in a document called an Explanation of
Significant Differences (ESD) or an amendment to the existing
ROD.
122. At the public meeting on April 26, 1994, EPA indicated that
there was a similar site in Manassas, Virginia where ISVE was
being used successfully. One citizen commented that when
checking out this site, he found that ISVE had been operating for
three years, "double what you (EPA) are allowing for the
Buckingham Site", and the remediation was not yet complete. This
citizen then indicated that EPA's estimate of time for ISVE to
work and cost figures for ISVE were therefore not accurate.
EPA Response: EPA based its ISVE time frames and cost estimates
on information supplied by the PRPs. Prior to issuance of the
Addendum, the PRPs indicated to EPA that they could meet EPA's
cleanup standards for ISVE in 18 months (see response to comments
78(b), 84, and 85). The PRPs also estimated that it would cost
$600,000 to construct the ISVE system and $700,000 to operate it
for 18 months.
123. One citizen commented on EPA's proposal to dispose of
treated ground water at a Publically Owned Treatment Works
(POTW). This citizen indicated that there were only two POTWs in
the county neither of which has the capacity for the treated
water from this Site. This citizen went on to discuss the costs
of disposing at a POTW and concluded that this disposal, not
including transportation costs, would be too expensive.
EPA Response: The ground water treatment contingency included in
both options of the selected remedy do not include disposal of
treated water at a POTW.
106
-------
124. One citizen commented that EPA's March 1992 fact sheet
indicated that there were unacceptable levels of two substances,
beryllium and chromium. This citizen wanted to know why our
evaluation of the contamination at the Site had changed to focus
on VOCs. -
EPA Response; The most up to date sampling data, as well as, the
most comprehensive data for this Site can be found in the
Remedial Investigation Report (RI). The sampling data from the
RI, specifically for the ground water which is the media that EPA
is most concerned about, was obtained in July of 1992. This was
after the fact sheet referred to by this citizen. The RI and the
Baseline Risk Assessment identified VOCs as the contaminants of
concern. EPA continues to have concerns regarding metals in the
ground water and metals analysis will be included in the long
term ground water monitoring program which is part of both
options of the selected remedy. It is unclear why earlier
sampling events did not identify VOCs as contaminants of concern.
125. Commonwealth of Virginia State Senator R. Edward Houck, in
discussing the draft proposal for reauthorization of the
Superfund Law, Senator Houck made the following statement,
"Specifically the proposal provides that the President shall give
"substantial weight" to any consensus recommendation of the
community working group with respect to future land use of a
site."
EPA Response; EPA, the PRPs and most of the community agree that
this Site will not be used as a residential property in the
future. Nonetheless, the Agency is required to base its site
remediation decisions on the existing law and not on the draft
language in the reauthorization proposals. Aside from the fact
that these proposals are not the law, the draft language
contained in these proposals might be greatly modified or totally
eliminated prior to the enactment of any given reauthorization
proposal.
126. EPA received several letters from one particular resident,
Mr. Earl Repsher, from Forest, Virginia. Forest is approximately
50 miles away from the Site and is not located in Buckingham
County. His questions/comments that have not previously been
answered in this Responsiveness Summary are responded to below.
(a) In discussing the EPA fact sh^et dated February 23, 1994, Mr.
Repsher was concerned with the statement that delaying the
cleanup of hazardous waste can be costly. Specifically all three
statements under this heading assumed that the waste had to be
treated and that he did not believe this to be the case.
EPA Response; EPA is aware that there are differing opinions on
this issue. Therefore, the selected remedy was structure to
allow for the following two options, (1) cap and monitor with
source control contingencies if the ground water moves; and (2)
implementation of source control measures, cap, and monitor.
107
-------
Extraction and treatment of the ground water will be implemented
under both options if the ground water moves to the compliance
monitoring wells.
(b) Mr. Repsher also had concerns regarding ISVE, specifically
how long it would continue and how it would be evaluated.
EPA Responses Performance standards for ISVE regarding how long
it would have to operate and what cleanup standards it would have
to achieve are difficult to set without having more information
specifically regarding the feasibility of this technology at this
Site. The selected remedy allows the implementing party the
opportunity to conduct a treatability study for ISVE at this Site
to obtain the information necessary to set performance standards
which would include how long the system would have to run.
(c) Mr. Repsher was also particularly concerned with the proposed
sampling in the barrel trench and wanted to know how EPA would
prevent precipitation from seeping through the contaminated area
into the ground water.
EPA Response; See response to comment 87.
VII. SUMMARY OF SIGNIFICANT COMMENTS FROM THE PRPS RECEIVED
DURING THE SECOND PUBLIC COMMENT PERIOD AND EPA
RESPONSES
During the second public comment period, EPA received formal
comments from the PRPs or their respective representatives. Many
of the comments in the letters listed below have been addressed
previously in this responsiveness summary and therefore, are not
addressed below. The following additional comments/concerns
about the Addendum to the Proposed Plan, which are significant
and relevant to this Site, were raised in the letters from PRPs:
Buckingham County Board of Supervisors
. Letter to Melissa Whittington from David Moorman, County
Administrator, dated May 3, 1994.
127. Mr. Moorman discussed the EPA proposal to amend the
Superfund law and specifically the role of the community under
the new Superfund law.
EPA Responses The Agency is required to base its remediation
decisions on existing law rather than draft language in
reauthorization proposals. Aside from the fact that these
proposals are not the law, the draft language contained in these
proposals might be greatly modified or totally eliminated prior
to the enactment of any given reauthorization proposal.
128. Mr. Moorman made the following statement, "The Board places
great significance, and urges EPA to place great significance, on
the fact that the Commonwealth of Virginia supports Buckingham
108
-------
County's desire to for a cap and monitor remedy at this site."
EPA Response; Although Virginia Department of Environmental
Quality (VDEQ) did not concur with EPA's proposal due to its
concern over the excavation contingencies included in the
Addendum to the proposed plan, VDEQ has never indicated to EPA
that it supports the cap and monitor remedy. Moreover, VDEQ had
a key role in the inclusion of ISVE as part of the preferred
remedy in the Addendum.
129. Mr. Moorman indicates that the Site was closed with the
approval of EPA.
EPA Response: Although EPA reviewed the closure plans, EPA's
records do-not indicate that EPA ever formally approved the
closure plan for this Site or certified completion of such
closure. In any event, it appears that the existing cap was not
constructed in accordance with design specifications and is not
performing in a manner sufficient to prevent infiltration of
precipitation through the waste materials. Moreover, EPA advised
the County when it closed the Site that it may be required to
take additional actions in the future regarding the wastes
present in the trenches. Also, see response to comment 38.
130. Mr. Moorman made the following statement, "...we support
long-term monitoring to make sure no significant migration of
contaminated ground water occurs...".
EPA Response; This statement has been a recurring theme in many
of the letters received by EPA. Although previously addressed in
response to various other comments, the following point is
important enough to reiterate. Monitoring of the ground water
alone will not, in any way, ensure jthat significant migration of
the ground water will notoccur. The purpose of long-term ground
water monitoring is to alert EPA when the ground water has
migrated. It will then be necessary to take additional actions
to ensure that the ground water contamination does not migrate
further. The selected remedy includes extraction and treatment
of the ground water if migration of the contaminated ground water
is detected at the points of compliance.
Womble Carlyla Sandridga and Rica (WC8R)
. Letter (including enclosures) to Melissa Whittington
from Karen Carey, dated May 3, 1994.
_ Letter (including enclosures/attachments) to Melissa
Whittington from Karen Carey, May 3, 1994.
131. Ms. Carey enclosed a letter from Engineering-Science dated
October 12, 1993 re: Review of Analytical Findings From
Historical Sampling and RI/FS Sampling, Buckingham County
Landfill Site. According to Ms. Carey, this letter indicates
there is no cause for concern in the barrel trench. This letter
raises the following issues:
109
-------
(a) According to ES, because data from one soil boring collected
from the barrel trench in 1983, by NUS Corporation, indicates
that the contaminants of concern in the ground water were not
found in"the barrel trench, that EPA should therefore conclude
that the barrel trench is not a source of the ground water
contamination.
EPA Response; The barrel trench covers a relatively large area,
its dimensions are 400 feet long by 20 feet wide. NUS only took
one soil boring sample from the barrel trench. One sample is not
enough to characterize the entire trench. Additionally, ES does
not indicate where from within the trench this sample was taken.
During the RI, ES contends to have sampled the barrel trench,
when in fact they actually sampled the domestic waste landfill
located south of the barrel trench. EPA does not consider the
data presented by ES to be comprehensive or conclusive enough to
exclude the barrel trench from remediation. However, before EPA
makes a final decision regarding whether and to what extent
excavation may be warranted in the barrel trench, additional
studies will be required. Based on information gained by these
studies EPA will make a decision regarding the necessary source
control measures in this trench. This decision will be subject
to public comment.
132. Ms. Carey enclosed tables prepared by Engineering-Science
dated November 6, 1993. According to Ms. Carey, these tables
represent numbers generated by using the Summers Method which
"confirm" that the eastern disposal trench is not posing a threat
to ground water.
EPA Response; The Summers Method is a model that when used
appropriately indicates what level of contamination can be left
in the soil without threatening the ground water. This model is
designed to set soil cleanup levels. There is a layer of
concentrated hazardous waste present in the eastern disposal
trench. Although EPA used the Summers Method to calculate soil
cleanup levels in the Proposed Plan, the use of these cleanup
levels would be in conjunction with complete removal of the
source itself, the waste layer. ES appears to be using the
Summers Method to calculate cleanup levels for waste. which is an
inappropriate use of the model. Furthermore, EPA and ES have
differences of opinion regarding what parameters should be used
when running this particular model. EPA does not concur with
ES's contention that the Summers Method indicates that no cleanup
is necessary in the eastern disposal trench.
133. One of the letters dated May 3, 1994, from Ms. Carey
enclosed a variety of newspaper articles, editorials, photographs
from the April 26, 1994 public meeting, a memorandum from
Buckingham County Board of Supervisors and Armstrong Furniture,
and a videotape of television news coverage of the Site. Ms.
Carey requested that EPA respond to these items in the
Responsiveness Summary.
110
-------
EPA Response; The enclosed items are not comments, were not
submitted by the respective authors to EPA for comment and
therefore, are not addressed in this Responsiveness Summary.
Engineering-Science, inc.
. Letter (including attachments) to Melissa Whittington from
Susan Fullerton, dated May 3, 1994.
- Letter (including attachments) to Melissa Whittington
from Susan Fullerton, dated august 25, 1994.
A majority of the concerns expressed in these two letters
either have been previously addressed in this Responsiveness
Summary or are not relevant to the Addendum to the Proposed Plan
or selection of remedy at this Site and therefore are not
addressed below. The following are relevant comments not
previously made and EPA response to these comment.
134. ES stated, "The only future threats are associated with the
use of ground water within the four-trench area..".
EPA .Response,;, The contaminated ground water within the four-
trench area is to be monitored and contained. However, the
primary threat posed by this ground water is not its current
location underneath the four trench area, but the potential
migration of this contamination toward residential areas. It
should be noted that the contaminated ground water has migrated
beyond the four-trench area, specifically levels of VOCs have
been detected above MCLs in monitoring well 6S, which at least 60
feet beyond the four-trench area.
135. ES stated, "The EPA has arbitrarily used a figure of 4 feet
of waste in calculating cost of excavation and incineration from
the eastern disposal trench". ES believes that the actual
thickness could be more that 4 feet.
EPA Response; The estimated 4 feet of waste in the eastern
disposal trench is based on information provided by ES in the RI.
If ES believes that the actual thickness may be more than 4 feet,
it is unclear why the thickness was represented as 4 feet in the
RI. Cost estimates have to be developed for all alternatives set
forth in the ROD to allow for comparison of their respective
cost-effectiveness. These cost estimates are based on data
contained in the RI. Hence, a thickness of the 4 feet was used
when costing this alternative. Additionally, an amount equal to
20% of the estimated capital cost was added to the cost estimates
to account for situations where estimated volumes may not be 100%
accurate.
136. ES made the following statements, "Mr. Love used the trench
and fill method of disposal at this Site. He used a series of
three trenches for disposal of empty drums. The first trench was
filled, covered, and closed and then the second and third
trenches were likewise used. Only that area of the barrel trench
most recently used by Mr. Love is that portion termed the
111
-------
"historical" barrel trench."
EPA Response: If these statements are true, ES did not accurately
represent the barrel trench in the RI. The RI is a comprehensive
document that should include all details of Site activity. EPA
is concerned with concentrated waste sources in the barrel
trench. The test pits that were dug south of the barrel trench,
the area that ES considers to actually be the barrel trench,
uncovered crushed empty drums indicating that excavation of this
area in not necessary. Further study of the barrel trench will
take place to determine whether and to what extent excavation is
needed in this trench (unless Option 1 of the selected remedy in
implemented and the contaminated plume does not migrate to the
points of compliance).
137. ES listed concerns with EPA calculation of soil cleanup
goals presented in the PRAP.
EPA Response; These comments are no longer relevant because EPA
does not intend to use those particular soil cleanup goals in
conjunction with the selected remedy. Also, see response to
comment 78(b).
138. ES states, "The addended PRAP described two new alternatives
for the Site and also provided cleanup/action limits for these
alternatives".
EPA Response; This statement is not quite correct. While
Alternative SB in the Addendum to the PRAP contained new
performance criteria for excavation in the eastern disposal
trench, there are no such standards for the ISVE proposal set
forth in Alternative 8C of the Addendum. As stated in the
Addendum, "The ROD will set forth performance criteria by which
the effectiveness of the ISVE system will be measured". The
performance criteria in for ISVE in the eastern disposal trench
are specified in Section IX. of the ROD.
139. ES was concerned with the possibility of using soil cleanup
standards in the barrel trench based on the proposed method for
setting ISVE standards in the eastern disposal trench.
EPA Response; EPA has delayed the decision on whether and to what
extent excavation may be warranted in the barrel trench, until
after additional studies have been conducted.
140. ES states, "At most Superfund Sites where excavation is
required a contaminant structure of some type is required to
contain or minimize dangerous air emissions."
EPA Response; EPA disagrees with this statement. Excavation is
done routinely at Superfund Sites and only under extremely
hazardous conditions are containment structures warranted such as
those described by ES. EPA does not believe this to be
112
-------
necessary at this Site. However, if the PRPs were to implement
the ROD and excavation is performed as part of the remedy, the
PRPs are not precluded from incorporating a containment structure
into the excavation remedy.
141. ES states, "If long-term monitoring detects significant
contaminant migration, then a further ground water containment
remedy could be initiated at that time, as provided by
Alternative 3".
EPA Response; Alternative 3 does not provide for implementation
of a ground water containment system nor does the cost estimate
for Alternative 3 include costs for a ground water containment
system. However, this concept is incorporated into both options
of EPA's selected remedy
142. ES states, "...contaminated ground water is restricted to
the 2 acres in the centermost part of the 120 acre Site."
EPA Response; Superfund sites are not defined by the property
that they are located on, but instead are defined by the actual
area of contamination. Therefore, the reference to the 120 acre
Site is inaccurate if ES is referring to the Superfund Site as
opposed to the overall 120 acre piece of property owned by the
County. Furthermore, the ground water contamination is not
restricted to the 2 acres where hazardous waste disposal
operations took place. The investigation conducted by ES not
only indicates that the ground water contamination extends at
least 60 feet beyond the 2 acre fenced area, but the
contamination is present in monitoring well 6S at levels that
exceed MCLs (see figure 4 of the ROD).
143. When discussing the proposed method of evaluation of ISVE
presented by EPA in the March 30, 1994, fact sheet, ES states
that, "..EPA discusses using performance-based goals. This would
mean establishing the initial mass of VOCs and setting a goal of
removal (i.e., 90%)."
EPA Response; In that particular newsletter EPA did not discuss
establishing the "initial mass of VOCs". The 90% removal
pertains to removal of VOCs in the vapor surrounding the wastes
in the eastern disposal trench. This is an approach EPA is using
at other sites that are using ISVE. However, refer to Section
IX. of the ROD for the performance standards for ISVE at this
Site.
144. In ES's August 25, 1994 letter to EPA, ES states, "This
letter responds to the USEPA's request that the Potentially
Responsible Parties (PRPs) submit proposed language to implement
this remedy (cap and monitor with contingencies) and to provide
for contingency actions should such contingency actions become
necessary."
113
-------
EPA Response; EPA did not request that the PRPS submit language
for the ROD. Preparation of RODS is solely the responsibility of
EPA. EPA is not required to include PRP proposed language in
this or any other ROD.
145. ES states, "Our understanding is that the ROD will call for
installation of a RCRA cap covering the entire trench area and
the placement of ground water monitoring wells outside the area."
EPA Response: The ROD allows for capping as mentioned in ES's
comment above. EPA has further defined the points of compliance
to be no further than 150 feet from the edge of the newly
installed cap and the cap is not to extend beyond the previously
fenced hazardous waste disposal area.
146. ES discusses the need for contingency actions only if
migration of the contamination is detected with reasonable
confidence and goes on to describe how reasonable confidence
should be defined.
EPA Response; EPA has determined that the contingency actions
will be invoked under the following conditions: If any
analytical result from a ground water monitoring sample collected
at the points of compliance exceeds the Safe Drinking Water Act
Maximum Contaminant Level (MCL) or the health-based contaminant
level, if an MCL has not been established, for any Site-related
contaminant, a confirmatory sample from the well where the
exceedance occurred shall be collected and analyzed for all Site-
related contaminants. If the analytical results from the
confirmatory sample also exceeds the appropriate MCL or health-
based level, the contingency actions appropriate for the option
of the selected remedy that is being implemented shall be
triggered. Assuming that this remedy will be implemented by the
PRPs, EPA would split any confirmatory samples from the wells
where there was an exceedance. Assuming there was an exceedance
in all three samples, this would give the Agency a total of three
data points making the exceedance statistically significant.
The point of compliance shall be no further than 150 feet
from the edge of the cap. This cap, which will be constructed as
part of both Option 1 and Option 2, shall not extend beyond the
disposal trenches and previously capped area south of the barrel
trench.
147. ES states, "If excavation is ultimately required, the
portion of the cap covering the eastern disposal trench can be
effectively removed without removing the entire cap."
EPA Response: EPA is not convinced that this is the best course
of action. If this situation occurs and ES can develop a way to
ensure the integrity of the synthetic liner, EPA will consider
such actions. However, if this can not be done the entire cap
must be removed and ultimately replaced. EPA's cost estimate for
Option 1 takes the latter approach into account.
114
-------
VIII. SUMMARY OF COMMENTS RECEIVED FROM CONGRESSMAN PAYNE
REGARDING THE ADDENDUM TO THE PROPOSED PLAN AND EPA
RESPONSES
EPA received a letter from Congressman Payne dated August
22, 1994, which discusses certain aspects of the proposed cleanup
for this Site. Any comments raised by Congressman Payne that
have not been addressed previously in this Responsiveness summary
are addressed below.
148. Congressman Payne discusses semi-annual sampling of ground
water monitoring wells for VOCs.
EPA Response; Ground water monitoring is a very important part of
both options of the selected remedy in the ROD. Although the
PRPs believe that the ground water contamination will not migrate
EPA believes that it will. In order to ensure that any ground
water contamination at the points of compliance is detected, EPA
determined that quarterly ground water sampling for both VOCs and
metals will be required. If, after three years, consecutive
sampling events have shown that the ground water contamination
plume has not reached the points of compliance, EPA may reduce
the frequency of the sampling to bi-annually.
149. Congressman Payne discusses removal of wells currently
existing within the 8-acre cleared area.
EPA RESPONSE: EPA does not intend to remove all of these wells
because some of them will be used as part of the monitoring
network.
150. Congressman Payne discusses implementation of ISVE in the
eastern disposal trench.
EPA Response; ISVE may be implemented in the eastern disposal
trench if (1) the technology has been proven to be feasible at
this Site during treatability studies that will be conducted
during design (not at the time of trigger); and (2) the ISVE
treatability study will be implemented only if the implementing
party chooses to do it.
151. Congressman Payne provided information on ISVE performance
standards.
EPA Response; See Section IX of the ROD for ISVE performance
standards.
152. Congressman Payne indicated that information gained during
additional study of the barrel trench should be used in
preparation of a Focused Feasibility Study for that trench.
EPA Response; EPA agrees that a Focused Feasibility Study is
necessary and has incorporated this approach into the ROD.
115
-------
153. Congressman Payne indicated that two test pits would be
excavated in the barrel trench and that these test pits would be
ten feet long by five feet wide.
EPA Response: The number and size of test pits to be dug in the
barrel trench will be determined during design. However, a
sufficient number of test pits will be required to determine the
conditions in this trench.
154. Congressman Payne discussed additional monitoring of the
ground water after all contingency requirements have been
completed at the site.
EPA Response: If the ground water contamination migrates to the
points of -compliance, EPA will require extraction and treatment
of the ground water to ensure that the contamination remains
within the points of compliance. Monitoring of the ground water
will be required in conjunction with extraction and treatment.
IX. SUMMARY 07 COMMENTS RECEIVED FROM THE VIRGINIA DEPARTMENT
OF ENVIRONMENTAL QUALITY (VDEQ) ON THE DRAFT RECORD OF
DECISION AND EPA RESPONSES
VDEQ supplied comments to EPA on the draft ROD that was
submitted to them for comment. EPA has incorporated these
comments into the ROD to the extent possible. The following is a
summary of VDEQ's comments and EPA responses.
155. VDEQ indicated that the requirement of monthly sampling was
excessive.
EPA Response: EPA agrees and has changed this requirement to
quarterly sampling in the ROD.
156. VDEQ indicated that the performance standard for triggering
additional action at the Site were not consistent with "typical
CERCLA methodology". MCLs were suggested.
EPA Response; EPA has changed the basis for the standard to MCLs
or equivalent risk-based standards if MCLs have not been
established.
157. VDEQ indicated that the draft ROD did not specify how an
exceedance at a. trigger well would be determined. Using
"statistically significant1* language was suggested.
EPA Response; See response to comment 145.
158. VDEQ stated that the requirement for additional ground water
studies appeared to be too broad.
EPA Response; EPA did not intend to indicate that additional
studies, above and beyond what is typically done during design of
a ground water monitoring system, would be required. The ROD
116
-------
language has been revised to reflect this.
159. VDEQ indicated that the State did not agree with the methods
EPA had outlined for evaluation of the ISVE system in the draft
ROD.
EPA Response; The ROD was revised to indicate that the
treatability study for ISVE would have to provide evidence that
ISVE is feasible for this Site. See Section IX. for ISVE
performance standards.
160. VDEQ had concerns with the contingency actions in the barrel
trench and suggested a focused feasibility study.
EPA Response; EPA agrees with this comment and will conduct such
a study after test pits have been excavated and samples from this
trench have been analyzed.
161. VDEQ had concerns with the requirement to remove the entire
cap if contingency actions were triggered.
EPA Response; See response to comment 146.
162. VDEQ had concerns with the requirement for extraction and
treatment upon detection of the migration of the plume to the
points of compliance.
EPA Response; EPA contends that ground water extraction and
treatment will be necessary to ensure that the ground water
contamination remains within the points of compliance. All
remedial actions are required to meet HCLs in the area of
attainment, which lies beyond the points of compliance. If after
implementation of the extraction and treatment, it is discovered
that the plume no longer extends to the points of compliance, EPA
may then determine that the extraction and treatment can be
suspended until such a time that the plume again migrates to the
points of compliance. See also Section 5.2 of EPA's Guidance on
Remedial Action for Contaminated Ground Water at Superfund Sites.
December 1988, OSWER Directive 9283.1-02.
163. VDEQ suggested that EPA should include analysis for metals
into the ground water monitoring program.
EPA Response; EPA has included metal analysis in the ground water
monitoring program required in the ROD.
117
-------
APPENDIX A - GLOSSARY
of Stiperfund Terms
This glossary defines terms often used by the U.S. Environmental
Protection Agency (EPA) staff when describing activities under the
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA, commonly called Superfund), as amended in 1986. The
definitions apply specifically to the Superfund program and may have
other meanings when used in different circumstances. Underlined words
included in various definitions are defined separately in the glossary.
Administrative Order on Consent (AOC): A legal agreement between
EPA and potentially responsible parties (PRPs) whereby PRPs agree
to perform or pay the cost of a site cleanup. The agreement describes
actions to be taken at a site and may be subject to a public comment,
period. Unlike a consent decree, an administrative order on consent
does not have to be approved by a judge. .
Administrative Record: A file which is maintained and contains
all information used by the lead agency to make its decision on the
selection of a response action under CERCLA. This file is to be available
for public review and a copy is to be established at or near the site,
usually at one of the information repositories. Also, a duplicate
file is held in a central location, such as a Regional or State office.
Air Stripping: A treatment system that removes, or "strips,"
volatile organic compounds from contaminated around water or surface
water by forcing an airstream through the water and causing the compounds
to evaporate.
Aquifer: An underground rock formation composed of materials
such as sand, soil, or gravel that can store and supply around water
to wells and springs. Most aquifers used in the United States are
within a thousand feet of the earth's surface.
Carcinogen: A substance that causes cancer.
Carbon Adsorption: A treatment system where contaminants are
removed from around water or surface water when the water is forced
through tanks containing activated carbon, a specially treated material
that attracts the contaminants.
Cleanup: Actions taken to deal with a release or threatened
release of hazardous substances that could affect public health and/or
the environment. The term "cleanup" is often used broadly to describe
various response actions or phases of remedial responses such as the
-------
Comment Period: A time period during which the public can review
and comment on various documents and EPA actions. For example, a
comment period is provided when EPA proposes to add sites to the National
Priorities List. Also, a minimum 3-week comment period is held to
allow community members to review and comment on a draft RI/FS and
proposed plan.
Community Relations (CR): EPA's program to inform and involve
the public in the Superfund process and respond to community concerns.
Community Relations Plan (CRP): Formal Plan for EPA community
relations activities at a Superfund site.
Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA): A federal law passed in 1980 and modified in 1986 by
the Superfund Amendments and Reauthorization Act. The Acts created
a special tax that goes into a Trust Fundr commonly known as Superfund.
to investigate and clean up abandoned or uncontrolled hazardous waste
sites. Under the program, EPA can either:
o Pay for site cleanup when parties responsible for the
contamination cannot be located or are unwilling or
unable to perform the work; or *
o Take legal action to force parties responsible for
site contamination to clean up the site or pay back
the Federal government for the cost of the cleanup.
Consent Decree (CD): A legal document, approved and issued by
a judge, that formalizes an agreement reached between EPA and potentially
responsible parties (PRPs) where PRPs will perform all or part of
a Superfund site cleanup. The consent decree describes actions that
PRPs are required to perform and is subject to a public comment period.
Cost-Effective Alternative: The cleanup alternative selected
for a site on the National Priorities List based on technical feasibility,
permanence, reliability, and cost. The selected alternative does
not require EPA to choose the least expensive alternative. It requires
that if th+re are several cleanup alternatives available that deal
effectively with the problems at a site, EPA must choose the remedy
on the basis of permanence, reliability, and cost.
Cost Recovery: A legal process where potentially responsible
parties can be required to pay back the Federal government for money
it spends on any cleanup actions.
Enforcement: EPA's efforts, thr ugh legal action if necessary,
to force potentially responsible parties to perform or pay for a Superfund
site cleanup.
Explanation of Significant Differences: After adoption of a
final remedial action plan, if any remedial action is taken, or any
enforcement action under Section 106 is taken, or if any settlement
or consent decree under Sections 106 or 122 is entered into, and if
-------
such action, settlement, or decree differs in any significant respects
from the final plan, the lead agency is required to publish an explanation
of the significant differences and the reasons the changes were made.
gae Guidance on Preparing Suoerfund Decision Documents; the Proposed
Plan and Record of Decision for further information.
Feasibility Study (PS): See Remedial Investigation/Feasibility
Study.
Ground Water: Water found beneath the earth's surface that fills
pores between materials such as sand, soil, or gravel. In aquifers
ground water occurs in sufficient quantities that it can be used for
drinking water, irrigation and other purposes.
Hazard Ranking System (HRS): A scoring system used to evaluate
potential relative risks to public health and the environment from
releases or threatened releases of hazardous substances. EPA and
States use ths HRS to calculate a site score, from 0 to 100, based
on the actual or potential release of hazardous substances from a
site through air, surface water, or around water to affect people.
This score is the primary factor used to decide if a hazardous waste
site should be placed on the National Priorities List. J
Hazardous Substance: Any material that poses a threat to public
health and/or the environment. Typical hazardous substances are materials
that are toxic, corrosive, ignitable, explosive, or chemically reactive.
Incineration: Burning of certain types of solid, liquid, or
gaseous materials under controlled conditions to destroy hazardous
waste.
Information Repository: A file containing current inf rmation,
technical reports, and reference documents regarding a Superfund site.
The information repository is usually located in a public building
that is convenient for local residents such as a public school,
city hall, or library.
Leachate: A contaminated liquid resulting when water percolates,
or trickles, through waste materials and collects components of those
wastes. Leaching may occur at landfills and may result in hazardous
substances entering soil, surface water, or around water.
Monitoring Wells: Special wells drilled at specific locations
on or off a hazardous waste site where around water can be sampled
at selected depths and studied to determine such things as the direction
in which around water flows and the types and amounts of contaminants
present.
National oil and Hazardous Substances Pollution Contingency
Plan (NCP): The Federal regulation that guides the Superfund program.
National Priorities List (NPL): EPA's list of the most serious
uncontrolled or abandoned hazardous waste sites identified for possible
long-term remedial response using money from the Trust Fund. The
-------
list is based primarily on the score a site receives on the Hazard
panic ing System (HRS). EPA is required to update the NPL at least
once a year.
operable Unit: An action taken as one part of an overall site
cleanup. For example, a carbon absorbtion system could be installed
to halt rapidly spreading ground-water contaminants while a more comprehensive
and long-term remedial investigation/feasibility study is underway.
A number of operable units can be used in the course of a site cleanup.
Operation and Maintenance (OSM): Activities conducted at a
site after a response action occurs, to ensure that the cleanup or
containment system is functioning properly.
Parts Per Billion (ppb) /Parts per Million (ppm): Units commonly
used to express low concentrations of contaminants. For example,
1 ounce of trichloroethylene (TCE) in 1 million ounces of water is
1 ppm; 1 ounce of TCE in 1 billion ounces of water is 1 ppb. If one
drop of TCE is mixed in a competition-size swimming pool, the water
will contain about 1 ppb of TCE.
Potentially Responsible Party (PRP): An individual(s) or company (ies)
(such as owners, operators, transporters, or generators) potentially
responsible for, or contributing to, the contamination problems at
a Super fund site. Whenever possible, EPA requires PEPs, through administrative
and legal actions, to clean up hazardous waste sites they have contaminated.
Proposed Plan: A public participation requirement of SARA in
which EPA summarizes for the public the preferred cleanup strategy,
the rationale for the preference, reviews the alternatives presented
in the detailed analysis of the remedial investigation/feasibility
study, and presents any waivers to cleanup standards of §121(d)(4)
may be proposed. This may be prepared either as a fact sheet or as
a separate document. In either case, it must actively solicit public
review and comment on all alternatives under Agency
consideration.
Record of Decision (ROD): A public document that explains which
cleanup alternative (s) will be used at National Priorities List sites.
The record of decision is based on information and technical analysis
generated during the remedial investigation/feasibility study and
consideration of public comments and community concerns.
Remedial Action (RA): The actual construction or implementation
phase that follows the remedial design of the selected cleanup alternative
at a site on the National Priorities List.
Remedial Design (RD): An engineering phase that follows the
record of decision when technical drawings and specifications are
developed for the subsequent remedial action at a site on the National
Priorities List.
-------
Remedial Investigation/Feasibility study: Investigative and
analytical studies usually performed at the same time in an interactive,
iterative process, and together referred to as the "RI/FS." They
are intended to:
o Gather the data necessary to determine the type and
extent of contamination at a Superfund site;
o Establish criteria for cleaning up the site;
o Identify and screen cleanun alternatives for remedial
action: and
o Analyze in detail the technology and costs of the
a1ternatives.
Remedial Response: A long-term action that stops or substantially
reduces a release or threatened release of hazardous substances that
is serious, but does not pose an immediate threat to public health
and/or the environment.
Resource Conservation and Recovery Act (RCRA): A Federal law
that established a regulatory system to track hazardous substances.
from the time of generation to disposal. The law requires safe and
secure procedures to be used in treating, transporting, storing, and
disposing of hazardous substances. RCRA is designed to prevent new,
uncontrolled hazardous waste sites.
Response Action: A CERCLfr-authorized action at a Superfund site
involving either a short-term removal action or a long-term remedial
response that may include, but is not limited to, the following activities:
o Removing hazardous ma'terials from a site to an EPA.
approved, licensed hazardous waste facility for
treatment, containment, or destruction.
o Containing the waste safely on-site to eliminate
further problems.
o Destroying or treating the waste on-site using
incineration or other technologies.
o Identifying and removing the source of around water
contamination and halting further movement of the
contaminants.
Responsiveness Summary: A summary of oral and/or written public
comments received by EPA during a comment period on key EPA documents,
and EPA's responses to those comments. The responsiveness summary
is a key part of the ROD, highlighting community concerns for EPA
decision-makers.
-------
Superfund: The common name used for the Comprehensive Environmental
Response. Compensation, and Liability Act, also referred to as the
Trust Fund.
Superf und Amendments aud Reauthorization Act (SARA): Modifications
to CERCLA enacted on October 17, 1986.
Surface Water: Bodies of water that are above ground, such as
rivers, lakes, and streams.
Treatment, Storage/ and Disposal Facility (TSD Facility): Any
building, structure, or installation where a hazardous substance has
been treated, stored, or disposed. TSD facilities are regulated by
EPA and States under the Resource Conservation and Recovery Act.
Trust Fund: A Fund set up under the Comprehensive Environmental
Response. Compensation, and Liability Act to help pay for cleanup
of hazardous waste sites and to take legal action to force those responsible
for the sites to clean them up.
Volatile Organic Compound: An organic (carbon-containing) compound
that evaporates (volatizes) readily at room temperature. I
------- |