United States
Environmental Protection
Agency
Office of
EfnerQoncy &ftd
Remedial Response
EPA/ROO/R03-87/034
Marehi9S7
ft EPA Superfund
Record of Decision:
West Virginia Ordnance, WV
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S>
TECHNICAL REPORT DATA
(Please read Insirticitons on the reverse before completing)
1. REPORT NO.
EPA/ROD/R03-87/034
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
West Virginia Ordnance Works, WV
First Remedial Action
S. REPORT DATE
March 27, 1987
8. PERFORMING ORGANIZATION CODE
AUTHORIS)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAM8 AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 N Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
IS. SUPPLEMENTARY NOTES
The West Virginia Ordnance Works (WVOW) site covers approximately 8,323 acres in
Mason County, West Virginia. In 1942, WVOW was established as a government-owned,
contractor-operated plant for the manufacture of trinitrotoluene explosives (TNT).
Approximately one-third of the area is currently occupied by the McClintic Wildlife
Station which is operated by the West Virginia Department of Natural Resources (DNR).
Smaller portions of the nonindustrial areas of the site were declared excess and sold. -
They are now owned by Mason County or by private owners. TNT was produced from
1942-1945 by a batch process involving the nitration of toluene by the addition of
nitric acid and sulfuric acid. Production during World War II resulted in soil
contamination of the industrial area, process facilities, and industrial waste water
disposal facilities by TNT, associated by products, and environmental transformation
products. At the close of operations in 1945, WVOW was decontaminated by the Department
of Defense and placed on standby status. Later that year, the plant was declared
surplus and the facilities salvaged or disposed of. Contaminated media include:
surface and subsurface soils, industrial sewer lines; underlying shallow aquifer of the
TNT manufacturing area; trunk sewer lines leading from Pond 13 to outfalls; surface
water and sediments of Pond 13; surface soils in the East and West Burning Grounds;
soils/sediments which eroded from the contaminated sources. The primary contaminants of
(See Attached Sheet)
7. .-
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIPIERS/OPEN ENOEO TERMS
c. COSATI Field/Croup
Record of Decision
West Virginia Ordnance Works, WV
First Remedial Action
Contaminated Media: soils, sediments,
sw, gw
Key contaminants: nitroaromatic residues,
2,4,6-TNT, 1,3,5-TNB, 2,4-DNT, asbestos
, DISTRIBUTION STATEMENT
19. SECURITY CLASS tTliuRtporti
None
21. NO. OF PAGES
83
20. SECURITY CLASS iThil pagti
None
22. PRICE
fttm 2220-1 (*•». 4-77) PMCVIOU* COITION is OMOLCTK
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EPA/ROD/R03-87/034
West Virginia Ordnance Work, WV
16. ABSTRACT (continued) ;.-
concern include: nitroaromatic residues, 2,4,6-TNT, 1,3,5-TNB, 2,4-DNT and
asbestos.
In January 1986, EPA and DOD mutually agreed to divide subsequent
studies at the site into two operable units. The selected remedial action
for the first operable unit includes: in-situ flaming of the reactive TNT
residue on the surface of the Burning Grounds Area followed by the
installation of a 2 ft. soil cover (1.5 ft. clay and 5 ft. soil) over areas
with greater than 50 ppm total nitroaromatics contamination; installation of
a 2 ft. soil cover over areas in the TNT Manufacturing Area with greater
than 50 ppm total nitroaromatics contamination; disposal of asbestos from
the Burning Grounds Area at an offsite facility to be identified during
design; excavation, flushing, and backfilling of the reactive sewerlines in
the trenches from which they were removed. All contaminated soils exceeding
50 ppm at the surface will be covered to achieve the 10~6 risk level. The
sewerline will be rendered unreactive by flashing and buried deeper than 2
ft. below ground surface; and assessment of the wetlands to be performed,
prior to construction activities.
The estimated capital cost for this remedy is $1,807,000. O&M costs
were not provided.
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
- FOR FIRST OPERABLE UNIT
SITE: West Virginia Ordnance Works, Mason County, West Virginia
DOCUMENTS REVIEWED
This decision is based primarily on the following documents
describing the analysts of the cost and effectiveness of remedial
alternatives for the West Virginia Ordnance Works:
- West Virginia Ordnance Works Remedial Investigation (Environmental
Science and Engineering, Inc., March 1986). Report No. AMXTH-IR-CR87004
- West Virginia Ordnance Works Feasibility Study for the TNT Manufacturing
Area, the Burning Grounds, and the Industrial Sewer lines (Environmental
Science and Engineering, Inc., October 1986). Report No. AMXTH-IR-CR87006
- West Virginia Ordnance Works: Endangerment Assessment for Sewer lines,
the TNT Manufacturing' Area, and the Burning Grounds (Environmental
Science and Engineering, Inc., June 1986). Report No. AMXTH-IR-CR87005
- West Virginia Ordnance Works Environmental Survey Final Management
Plan A004 (Environmental Science and Engineering, Inc., November 1984).
- Archives Search Report of the Former West Virginia Ordnance Works,
Point Pleasant, WV (Environmental Science and Engineering, Inc.,
August 1984). Report No. DRXTH-AS-IA-A001
- Responsiveness Summary
- Interagency Agreement
- Meeting with West Virginia Department of Natural Resources
r Meetings with technical staff of Department of Defense (DOD).
- Environmental Protection Agency (EPA) Internal staff reviews.
DESCRIPTION OF SELECTED REMEDY
An operable unit remedy for source control to include:
1. In situ flaming of the reactive TNT residue on the surface of the
I Burning Grounds Area,
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2* Installation of « 2 ft. soil cover over areas in the Burning Ground
Area with greater than 50 ppm total nitroaromatics contamination*
3. Installation of a 2 ft. soil cover over areas in the TNT Manufacturing
Area with greater than 50 ppm total nitroaromatics contamination.
4. Asbestos from the Burning Grounds Area will be disposed of in an
offsite sanitary landfill.
5. Reactive sewer lines trill be excavated, flashed, and backfilled in
the trenches from which they were removed.
6. A health and safety plan will be implemented for all activities
described in this Record of Decision. During excavation, flashing
and construction activities air monitoring will be conducted to en-
sure the safety of the onsite workers as well as to protect the
residents and wildlife living nearby the construction areas.
7. A Wetlands Assessment will be performed, before construction
activities to delineate potential wetland boundaries and identify
wetland functions and values in the areas where remedial actions
are to be taken. Impacts to wetlands will be avoided. Where no
other practical alternative exists, Impacts to wetlands will be
mitigated.
The DA is currently conducting an additional Remedial Investigation/
Feasibility Study to evaluate the second operable unit at WVOV. The
second operable unit consists of the Red Water Reservoir, Acids Area/
Yellow Water Reservoir and Pond 13 Areas. A Record of Decision will be
prepared for the subsequent operable unit(s).
DECLARATIONS
Consistent with the Comprehensive Environmental Response Compensation,
and Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA) and the National Contingency Plan
(40 CFR Part 300), we have determined that the remedial action described
above, together with proper operation and maintenance, constitute a cost-
effective remedy which mitigates and minimizes damage to public health,
welfare, and the environment. The remedial action does not affect or
violate any floodplain. The State of West Virginia has been consulted
and agrees with the approved remedy. These activities will be considered
part of the approved action. Based on discussions between EPA and the
Department of Army (DA), an Interagency Agreement has been developed be-
tween the Agencies in which it is agreed thac the DA will design and
implement the selected remedy.
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We have determined that Che action being taken is a cost-effective treat-
ment alternative, which reduces the volume of waste and provides a permanent
solution to the maximum extent practicable, when compared to the other remedial
options reviewed. Ve have also determined that although the contamination is
not totally eliminated the criteria established for clean up will protect
public health, welfare and the environment. Furthermore due to the deed re-
strictions which exist at this particular site, there is little potential
for industrial or residential development in the areas of remedial action.
In addition, the off-site disposal of asbestos to a sanitary landfill is
more cost-effective than other remedial action alternatives and is necessary
to protect public health, welfare or the environment.
DATE X Barnes tT. Self
Regional Administrator
EPA Region III
DATE Lewis D. Walker, Deputy for
Environment, Safety and
Occupational Health
Office of the Assistant Secretary
of the Army (Installations
and Logistics)
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Summary of Remedial Alternative Selection
for First Operable Unit At
West Virginia Ordnance Works
Site Description
The Vest Virginia Ordnance Works (WVOW) site covers approximately 8,323 acres
in Mason County, West Virginia. It is approximately 58 miles (ml) northwest
of Charleston, 41 ml northeast of Huntlngton, and 6 ml north of Point Pleasant,
WV, on the east bank of the Ohio River. Approximately one-third of the area
is currently occupied by the Clifton P. McCllntlc State Wildlife Station
(McClintic Wildlife Station), which Is 2,788 acres in size and operated by
the West Virginia Department of Natural Resources (DNR).
Prom 1942 to 1945, WVOW operated to produce trinitrotoluene (TNT) explosive.
Production of this material during World War II resulted in contamination of
the soils of the industrial area, process facilities, and industrial waatewater
disposal facilities by TNT and associated byproducts and environmental trans-
formation products. TNT was shipped to various Government installations to be
loaded into munitions or for other uses. No loading of munitions or testing
of ordnance was conducted at WVOW.
At the close of operations in 1945, WVOW was decontaminated to place it in
standby status. Later in 1945 the plant was declared surplus and the facil-
ities salvaged or disposed of. No records currently exist regarding the
general extent of this decontamination. The industrial portion of the site
was deeded to the State of West Virginia, with the stipulation that the site
be used for wildlife management. If the land were to be used for any other
purpose, or in the event of national emergency, the ownership of the land
would revert to the Pederal Government. The land, now owned by the state,
currently comprises the McCllntlc Wildlife Station and is managed by the West
Virginia DNR. West Virginia DNR'a management practices are primarily designed
to promote wetlands habitats and populations of resident and migratory water-
fowl. Consistent with this objective, more than 30 shallow ponds have been
constructed since cessation of military activities on the site, and most of the
ponds are stocked with bass and catfish. The area is open for public hunting
and fishing. Smaller portions of the nonindustrlal areas of the site were
'declared excess by the Government, sold, and are now owned by Mason County, WV,
or by private owners.
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In May 1981, a seepage of red water was observed adjacent to Pond 13
located on the McClintlc Wildlife Station. This pond is located near the
former TNT wastewater trunk sewerlines and pumping station. This inci-
dent was investigated by West Virginia DNR and the U.S. Environmental
Protection Agency (EPA). The shallow ground water discharging to Pond 13
was found to be contaminated by 2,4-dinitrocoluene (2,4-DNT) (up to
7,100 micrograas per liter (ug/L)), 2,6-dinitrotoluene (2,6-DNT)
(1,300 ug/L), 2,4,6-TNT (166 ug/L in one sample), and phenol (31 ug/L).
Based on these and other studies by West Virginia DNR and EPA in 1981
and 1982, WVOW has been ranked as the 84th site on the National Priorities
Llae (NPL) under the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA) (PL 96-510 amended by PL 97-272).
SITE HISTORY
WVOW was established in 1942 a* a Government-owned, contractor-operated
plant for the manufacture of TNT from toluene (Pig 1). General Chemical
Defense Corp* of New York (a subsidiary of General Chemical Co*, NY, which.
in turn, was a subsidiary of Allied Chemical and Dye Corp.) operated the
plant under contract. Prior to establishment of the plant, the major
land uses were cropland (approximately 50 percent of the area), forest,
pasture, and approximately 30 farm residences. Camp Conley, a West
Virginia National Guard site established in 1927, was included in the
acquisition for the plant.
From 1942 to 1945, WVOW operated to produce trinitrotoluene explosive
(TNT), which is the common name for the compound 2,4,6-trinitrotoluene
(2,4,6-TNT). Production of this material during World War II (WWII)
resulted in contamination of the soils of the industrial area, process
facilities, and industrial wastewater disposal facilities by TNT and
associated byproducts and environmental transformation products. TNT was
shipped to various Government Installations to be loaded into munitions
or for other uses. No loading of munitions or testing of ordnance was
conducted at WVOW. Table 1 provides a summary of contaminants and con-
centrations for the three (3) source areas evaluated, in this operable
unit as well as associated off-site media.
Twelve TNT process lines were installed in the TNT Manufacturing Area,
shown in Pig. 2, of which only Lines 1 through 10 were reportedly
operated. Lines 8, 9, and 10 had been partially decontaminated in the
1950s by the Department of Defense (DOD). TNT was produced by a batch
process involving the nitration of toluene by the addition of nitric
acid and sulfuric acid.
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v WEST VIRGINIA
ORDNANCE WORKS
s
I ID
CHESHIR1
WEST VIRGINIA ; '
ORDNANCE WORKS .v/
SITE ' *-
OHIO
y%r^
10^^^2 MILES
1 0 1 2 KILOMETERS
Figur* 1 Page 3
LOCATION OF THE WVOW SITE
SOURCES:
WEST VIRGINIA:'*-
ORDNANCE WORKS^
Remedial Investigation^
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MeCUNTIC
*fU)UPf
STATION
ftestftVATiON BOUNDARY
MCCUNTIC WILDUFI STATION SOUNOAMY
NOTE: Ponds and mttcnds fn«int*iMd by
Vlryini* ON* an *•• gnttvtf num«rteally
SCALi
1500 0
SOURCES: USATHAMA,
War ttooaftmcnt. O.C.C. Construction Division. 19SO
Slat* o< W*st Virginia. ON*. 19M.
ESf. 19U.
1500 3000 FEET
1000 MCTIRS
Figurt 2, Page 4
SITE MAP OF WVOW (1942-1945)
WEST VIRGINIA
ORDNANCE WORKS
Remedial Investigation
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Table 1 Summary of Contamination Status for WOW
Environmental
Medium —
Contaminant
Concentration
Detected
TNT Manufacturing Area
Soils
Surface Water
Sediments
Ground Water
Burning Grounds Area
Soils
Surface Water
Sediments
Ground Water
Nitroaromatlcs
Lead
Nitroaromatlcs
Nitroaromatics
Nitroaromatlcs
Lead
Nitroaromatlcs
Lead
PAHs
Friable asbestos
Lead
Asbestos
Lead
Uncontamlnated
3Z
320 ug/g
1 ug/L
(Pond 34 only)
0.4 ug/g
14,000 ug/L
20 ug/L
2Z
1,400 ug/g
100 ug/g
Observed
20.5 ug/L
2.6 x 106 flbers/L
31 ug/g
Industrial Sewerllnes
TNT Manufacturing
Area
Acids Area/Yellow
Water Reservoir
Red Water Reservoirs
Pond 137Wet Well
Area
Nitroaromatics
Nitroaromatlcs
Nitroaromatlcs
Uncontamlnated
71Z
400 ug/g
0.2Z
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Table 1. Summary of Contamination Status for WOW
(Continued, Page 2 of 2)
Maximum
Environmental Concentration
Medium Contaminant Detected
Offsite Areas
Soils Uncontaninated —
Surface Water Asbestos 480,000 fibers
Sediments Uncontamlnated —
Ground Water Uncontamlnated ' —-
NOTE: "fibers/L • fibers per liter
PAHs - polynuclear aromatic hydrocarbons
ft2 * square feet
ug/g - micrograms per gram
ug/L • micrograms per liter
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Red and yellow water are liquid wastes produced during the TNT manu-
facturing process. Yellow water was discharged to the Mill Creek
drainage system, which eventually drains into the Ohio River; red water
was discharged directly to the Ohio River through a pipe located about
100 feet (ft) offshore. Retention ponds shown as the Red Water
Reservoirs and Yellow Water Reservoir in Fig. 2. were constructed to
regulate the discharge of red and yellow water to the river.
Off-specification TNT was taken to the Burning Grounds (see Fig. 2.)
for destruction by burning. Surface and subsurface soils and ground-
water in areas of WVOW are still contaminated with nitroaromatic resi-
dues. IB addition, a potential exists for contamination of other areas
due to pose-operation contaminant migration. At the close of operations
in 1945, WVOW was decontaminated by DOD and placed in standby status.
Later in 1945 the plant was declared surplus and the facilities salvaged
or disposed of. No- records currently exist regarding the general extent
of this decontamination. Because the industrial area was contaminated
to the extent that complete decontamination was not feasible, a portion
of the land was not released to private ownership but was transferred to
the State of West Virginia for wildlife conservation. This area of the
site, including the industrial area, forms the McCllntic Wildlife Station.
Subsequently, limited industrial activity has occurred at the WVOW site.
Activities which have occurred and which potentially contribute or con-
tributed to environmental contamination by toxic and hazardous wastes
include:
1. Storage of explosives in the magazine area by several subsequent
operations from 1948 to the present;
2. Operation of vehicle maintenance/motor pool facilities by the
West Virginia National Guard from 1958 to the present;
3. Furniture manufacture by Mason Furniture Co. from 1948 to the
mid-1970s;
4. The recent storage of electrical equipment, including
transformers, in the magazine area by Appalachian Power Co.; and
5. Operation of a municipal landfill by the city of Point Pleasant.
None of these subsequent operations used the industrial wastewater
transport systems. Any solid or liquid Industrial discharges from these
subsequent operations are generally distinguishable from contaminants
resulting from WVOW operations. The potential for significant
contamination or contaminant migration from these sources is slight.
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Based on Che hydrogeologlc setting of WVOW, the potential exists for
contamination at WVOW to migrate via surface water and/or ground water
pathways to the deeper layers of the aquifer or to the Ohio River.
Contaminant migration is possible toward the city of Point Pleasant and
Camp Cbnley community potable water supplies.
Contaminants most likely to migrate beyond the former installation
boundaries and/or to present the most serious threat of environmental
degradation and threat to human health are nitroaromatic residues
12,4,6-TNT, 2,4-dinltrotoluene (2,4-DNT), 2,6-dlnltrotoluene (2,6-DNT),
and other TNT manufacturing byproducts, or environmental transformation
products of TNT] remaining as a result of WVOW explosives production.
Many of these compounds are toxic and/or suspected human carcinogens and
are persistent in the environment. Localized contamination of the
shallow ground water and discharge to surface waters have been documented
in the vicinity of the TNT Manufacturing Area. Dlnitrotoluene (DNT)
residues have been found in the soils of the TNT manufacturing area, the
burning ground, the sediments of the surface waters receiving
contamination, and the former wastewater storage lagoons.
For the'purpose of clarification, when general reference is made to the
'explosive, such as in Fig. 2 which describes the TNT Manufacturing Area,
the explosive is referred to as TNT, the common acronym. In this docu-
ment, specific references to the chemical compound which is actually
2,4,6-trinltrotoluene, and its environmental concentration, use the
acronym 2,4,6-TNT. References to concentrations of unspecified chemical
mixtures of byproducts of 2,4,6-TNT manufacture and environmental trans-
formation products of this compound are termed nitroaromatic compounds.
SURFACE HYDROLOGY
During the period of operation in the 1940s, WVOW was drained by two
major streams, their tributaries, and a number of intermittent streams
(see Fig. 3). The northern half of the Installation, Including the
magazine area and the acid area, were drained by Mill Creek and a small,
unnamed tributary. Mill Creek is a tributary to the Ohio River and
enters the river along the western boundary of the installation. The
Ohio River is located adjacent to the installation, along the western
boundary near the administration area and along the north and south well
fields. As shown In Fig. 3, the southern and eastern sections of the
installation were drained by Oldtown Creek. This stream and a number
of smaller tributaries drained che TNT Manufacturing Area. Oldtown
Creek is also a tributary to the Ohio River and intersects the river
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SOUHCE3: U3ATHAMA, 1M4*.
500
500 1000 METERS
ESC.1MS.
3, Page 9
SURFACE HYDROLOGY AT WVOW (1942)
WEST VIRGINIA
ORDNANCE WORKS
R«fn«dial Investigation
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south of Che Installation. Three surface impoundments called the Red Water
Reservoirs were located in the northwest section of the installation. These
reservoirs had a total capacity of 30 million gallons (MG). A small reservoir
called the Yellow Water Reservoir was located adjacent to the Acids Area. This
reservoir had a capacity of 5 MG. A smaller water recovery reservoir, was lo-
cated in the TNT production area; the capacity of this reservoir is unknown.
During plant operations, a wetlands southeast of the TNT Manufacturing Area
reportedly received runoff and process-water from TNT lines 1-4. This low-
lands, reportedly located at the present date site of McClintic Pond 10, was
referred to aa the the "Old Yellow Water Reservoir" and the "Toxic Swamp".
It should be noted that the exact location and operational history (if any) of
the old Yellow Water Reservoir and Toxic Swamp are not known.
A number of manmade surface water features were constructed subsequent to in-
stallation closure in 1945. Thirty-nine ponds are currently located at the
McClintic Wildlife Station (see Pig. 4). Most of these ponds were constructed
between 1953 and 1975 by the construction of impoundments and water control
structures (e.g., daaa and weirs) along the various drainageways. The ponds
were constructed to provide wetland habitats for various wildlife species.
Currently, two of the three Red Water Reservoirs contain standing water; the
northernmost reservoir is empty and has revegetated. The Yellow Water Reservoir
that was present in 1945 was filled shortly after the installation closed in the
raid-1940s and the small water recovery reservoir located in the TNT Manufac-
turing Area was removed prior to 1975. Natural drainage by Mill Creek
and Oldtown Creek has remained similar to the 1940s drainage, except for
alteration of a number of tributaries due to pond construction.
SITE GEOLOGY
WVOW is located in the Ohio River basin, which consists of Pennsylvanlan-
age rocks overlain by Quaternary alluvium. The rocks underlying the
installation are part of the Parkersburg syncllne. The synclinal axis is
located approximately 20 miles southeast of WVOW and has a northeast- *
southwest orientation. The oldest exposed rocks are Pennsylvanian in age
and crop out along stream valleys. Pig. 5 shows a generalized
geologic cross section across WVOW developed by Wilmoth (1966).
Crystalline basement occurs between 9,000 ft and 11,000 ft below the
Mlssissippian age rocks.
The Mississlpplan System Includes the Pocono and MacCrady Formations
overlain by the Greenbrler and Mauch Chunk Groups. The Pocono Formation
consists of mostly coarse-grained sandstone and sandy shale, with a
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SOUMCtS: USATMAMA. 1
W«r
500 ioooMcrms
4t Page H
•URFACE HYDROLOGY AT THE
AfVOW SITE (1985)
WEST VIRGINIA
ORDNANCE WORKS
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thickness of between 480 and 580 ft. The MacCrady Formation Is a shale
unit, with an approximate thickness of 50 ft. The Greenbrler Group —
primarily consists of limestone,.with some thin units of shale and
sandstone. This group has a thickness of between 100 and 215 ft; wells
screened in this unit produce a nonpotable saline brine. The Mauch Chunk
Group consists of sandstone and shale units, with a thickness of up to
80 ft. Wells In this unit also produce a saline brine, with a yield of
around 1 gallon per minute (gpm). The Pennsylvanlan System includes the
Pottsville, Allegheny, Conemaugh, and Monongahela Groups. These units
have a combined thickness of between 260 and 955 ft and were deposited
in a freshwater environment; all the groups contain carbonaceous deposits.
The Pottsville Group is the basal unit of the Pennsylvanlan System. The
unit consists of coarse-grained sandstone, with thin beds of coal, shale,
and clay. Figure 6 shows the major geologic units that comprise the
Allegheny. The formation is between 185 and 250 ft thick in the vicinity
of WVOW. The Allegheny does not crop out in Mason County and is
encountered only in subsurface borings. The Conemaugh Group overlies the
Allegheny Group and has a thickness of between 480 and 600 ft. The group
consists of alternating sandstones, shales, and limestones, with some
coal and clay units. The youngest Pennsylvanlan unit is the Monongahela
Group; this group also contains alternating shales, sandstones, and coal.
The cross section (see Figure 5) from Wllmoth's (1966) ground water
study shows the bedrock to be part of the Conemaugh Group; however, the
geologic map from the same study Indicates that rocks of the Monongahela
Group underly the area. Rocks from both of these groups are primarily
clastic with minor amounts of limestone and coal. The Conemaugh Group
contains a larger percentage of sandstone than the Monongahela Group, and
both groups contain siltstones and shales. Thickness ranges from 230 to
320 ft; these units form the upland areaa on the east side of WVOW.
Overlying the Paleozoic rocks at WVOW is an alluvial unit that reaches
thicknesses of up to 185 ft (see Figure 6). The alluvium is found as
river floodplaln deposits and elevated terraces along the Ohio River.
The terraces along the Ohio River were deposited as glacial outwash to
the south of the Wisconsin continental ice sheet. The alluvial deposits
overlying bedrock to the east and northeast of WVOW were deposited in the
channel of a pre-glaclal river that flowed southward from Ohio through
northern Mason County and then westward back into Ohio. The alluvium
consists of a basal gravel-sand unit and increases In coarseness from
top to bottom, with a clay and silt floodplaln near land surface. Figure
7, taken from Wllmoth (1966), shows a generalized cross section of these
upper geologic units.
The 1966 Wllmoth study was produced from a limited database in the
immediate vicinity of WVOW and was oriented primarily to defining and
delineating potable ground water supplies in Mason County. The major
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aqulfer of concern, therefore, was Che productive glacial outwash
sediments immediately overlying che bedrock. The shallow alluvial aquifer
at UVOW would not have been considered an important potable water _
supply.aquifer and may not have been detected or adequately defined in
the 1966 study. The water table shown in Fig. 7 represents the
interpreted potentiometrlc surface of the glacial outwash aquifer,
which was assumed to be in hydraulic communication with the Ohio River.
During the phases of deposition, the Ohio River Valley probably was
filled with at least 135 ft of sediment; complete sections of these
deposits are preserved within the WVOW area. As the river valley
filled with coarse sediment, water probably became ponded and allowed
finer sand, silt, and clay to be deposited.
The log of a USGS test boring (Table 2) made in 1960 and located just
east of the TNT Manufacturing Area shows this fining, upward,
depositional trend. This boring contains 103 ft of interbedded sands and
gravels which are overlain by 12 ft of fine sand, silt, and clay.
SITE SOILS
•
The U.S. Soil Conservation Service (USSCS) (1961) has mapped and
identified the soils on WVOW. Two regional soil associations are present
on the installation along the Ohio River bottomlands and terraces; the
Aston, Wheeling, and Lakin Associations are predominant. The upland
areas can be grouped into the Musklngum, Upshur, and Vandalia
Associations. The bottomlands and river terrace deposits consist of
alluvial soil, with a thin veneer of recent river silt and clays. The
upland soils consist of material weathered from the underlying bedrock,
mostly sandstone, shales, and siltstone. A third major soil type
consists of mixed amounts of alluvium and sediment disintegrated from the
underlying bedrock. These mixed soils are located on upland terraces and
consist of the Wheeling soil type on well-drained areas and the
Sclotovllle, Glnat, and Chilo soil types on the poorly drained areas..
Detailed soil locations, drainage characteristics, and permeabilities
were determined by USSCS (1961) and are presented in Fig. 8 and
Table 3.
SITE GROUND WATER
Ground water occurrences In the WVOW region have been documented by the
West Virginia Geological and Economic Survey and USGS. Potable ground
water in the vicinity of WVOW occurs in two main aquifer systems: an
unconsolldated or alluvial aquifer system and the consolidated Pennsyl-
vanlan Aquifer System.
-------
KEY
OHIO
RIVER
PLEISTOCENE AND RECENT ALLUVIUM
PENNSYLVANIAN MONONGAHELA GROUP
PENNSYLVANIAN CONEUAUQH GROUP
PENNSYLVANIAN ALLEGHENY GROUP
PENNSYLVANIAN POTT8VILLE GROUP
MISSISSIPPIAN MOCKS
COUNTY AIRPORT
WEST VIRGINIA UNIVERSITY
EXPERIMENTAL STATION
WATER TANKS
LOCATION OF
CROSS SECTION
END TNT AREA
, « •
* •
SOURCES: Wllwolh, IMS
iSE. IMS.
WEST VIRGINIA
ORDNANCE WORKS
Remedial Investigation *
-------
ft
Aliuviu*. rljv. tilt. i*n.
<«ctr; ort.-ic-.ojl
joui/cr in >io v«t:«v:
«>«?•)• *il ncld COO r
JOO c0K uK«r »utir»
toe*
Mi*. ca*i 230 ta~)20
t; lav <•!! .«i«ld of
10 f»K MCC
I* IBO*, «•»
Act
Mil*
Ket
' •ttrMvqn «nMtj» '4n to '
Licet* rtcr*fc*\n coil, cl*r
ter; lawwll
-------
•a
i!-
«*
S>
8
B
SECTION i-r
OHIO VALLEY EXPERIMENT STATION
B'
MMtMAUM •NOUI1
LOCATION OF CROM SCCTION
•••&.g&,$'.:'\-;-i$!-3$!&
KEY
ICLAYANDSN.T
•AND
18AND AND GRAVEL
•CALE
• «00 1.ZM FEET
200 • 200 400 METERS
SOURCES: Wilniolh. 1966
ESE. IMS.
WEST VIRGINIA
ORDNANCE WORKS
Remedial Invesllgalion
-------
-17-
Table 2
log of USGS Tesc Boring Located Ease of TNT
Manufacturing Area
Test boring 38-3-88
Altitude of Land Surface: 610 ft. MSL
Sample log by B.M. Wilmoth
Quaternary System
Thickness
(ft)
Depth
(ft)
Remarks
Clay, silty, medium-brown
Sand, very fine-grained, and silt,
trace of clay, medium-brown
Sand, fine-grained, trace of silt,
and clay, nediua-brown
Sand, medium-grained, trace of
fine-grained, and trace of
gravel, fine, medium-brown
Sand, medium- and coarse-
grained, medium-brown, wet
Sand, coarse-grained, medium-
brown, fluid
Sand, coarse-grained, medium-
brown, very fluid
Sand, coarse-grained, trace of
fine-grained and coarse-
grained, medium-brown
Gravel, fine to medium
Sand, medium-grained, medium-
grayish-brown
Clay, bluish gray, plastic
Gravel, tine to coarse, and sand,
coarse-grained, medium-grayish
brown, and some thin layers of
clay, dark gray, plastic,
stratified
4
6
2
7
30
30
3
2
1
7
Static water
level, 19 ft
4
10
12
19
23
27
57
87
90
92
93
115 Bedrock at
115 ft
-------
OMATMTLOAM
LTLOAM
MUNnNOTON SN.T LOAM
MAMLANO *UT CLAY LOAM
,T* CLAT LOAM
MONOMOAMtLA SILT LOAM
MOSMAMNOM SILT LOAM
KIOTOVIUJ SN.T LOAM
WUI SM.T LOAM
UM*HM CUAV LOAM
VAMOAUA cur LOAM
FOR FURTHeR OITAILS ON SOILS.
USSC9.1M1.
1 KILOMETERS
Flgurt S , Page 18
SOILS MAP OF THE
WVOW SITE
WEST VIRGINIA
ORDNANCE WORKS
R«m«dial Investigation
-------
-19-
Table 3
Soil Types Within che WVOW Sice
Soil Type
Soil Description
Drainage
Permeability
As
ChA
Du
GsA
Ha
Hu
La
Ma
Me
Mg
Mo
Mu
Sc
Se
So
Uc
Urn
Va
Wn
Ashton Silt Loan
Chilo Sandy Loan
Duncannon Silt Loan
Ginat Si1C Loan
Hackers Silt Loan
Huntington Silt Loan
Lakin Loamy Fine Sand
Markland Silty Clay Loan
Melvln Silty Clay Loan
Well Drained
Poorly Drained
Well Drained
Poorly Drained
Well Drained
Well Drained
Excessively Drained
Moderately Poorly Drained
Poorly Drained
Monongahela Silt Loam Moderately Well Drained
Moshannon Silt Loan Well Drained
Musklngum-Upshur Silt Loan -
Sciocoville Silt Loam Moderately Well Drained
Senecaville Silt Loan Moderately Well Drained
Sloping Land
Upshur Clay Loan Well Drained
Upshur-Muskingun Clay Loams
Vandalia Clay Loan Well Drained
Wheeling Pine Sand Loam Well Drained
Moderate-Rapid
Slow
Moderate
Very Slow
Moderate
Moderate
Rapid
Slow-Very Slow
Moderate Slow-Very
Slow
Slow
Moderate
Moderate
Moderate-Slow
Moderate-Slow
Slow-Very Slow
Moderate-Slow
Moderate-Rapid
-------
-20-
The gravel and sand lenses in Che glacial alluvium constitute the .
principal aquifer at WVOV. These deposits are the most productive
ground water units, with a high hydraulic conductivity and fairly
high well yields. The water table in Mason County was reported to
range from about 10 to 90 ft below land surface. At the WVOV site,
the level at which ground water may be encountered was expected to
range from 5 to 45 ft below land surface. Recharge to the alluvial
aquifer consists of infiltration of precipitation, movement of ground
water from the bedrock to the alluvium, seepage from small streams
flowing across the terrace deposits, and recharge from the Ohio
River during periods of high stage or flooding. Industrial and
public-supply wells in the area have an average yield of 200 gpm
according to Wilmoth (1966). WVOW radial collectors located adjacent
to the Ohio River ranged from 1,245 to 1,918 gpm, with a 1,565-gpm
average. Aquifer tests on a number of municipal well
fields in the alluvium indicated moderately good transmissivity
and water-table storage.
Based on historical well construction information and water-level data
available prior to the RI, a ground water divide appeared to
exist, most likely in the area of the TNT production lines. Because
of the "lack of well location and water-level data for the north-
eastern portion of WVOW, the exact location of the probable divide
could not be determined. Ground water movement in the alluvial aquifer
appeared to move to the northwest from the TNT Manufacturing Area to the
Mill Creek drainage and to the southwest along the Oldtown Creek drainage
after moving eastward to Oldtown Creek. Ground water recharging the
alluvial aquifer in the relatively high elevations along the eastern edge
of WVOW probably moves directly west to the Ohio River via Oldtown Creek.
Recharged ground water in the high elevations west of the TNT
Manufacturing Area may move directly west to the Ohio River.
As a result of the apparent complexity of local ground water movement
patterns in the upper portion of the alluvial aquifer, piezometers were
installed in the earliest phase of the RI program to determine local
gradients and aid in proper placement of the contaminant monitoring
wells.
-------
-21-
The Monongahela and Coneoaugh Groups form the deep potable Pennsylvania
aquifer system underlying WVOW. The Monongahela Group yields enough
water for domestic supply from a number of porous sandstone units. Veil
yields range from 1 to 25 gpmt with,an average of 9 gpm. The Monongahela
contains less sandstone than the Conemaugh and is situated topographically
higher. These factors make the Conemaugh aquifer the better water-bearing
formation. The Conemaugh is the principal aquifer to the south of WVOW
in the Kanavha River Valley. Most wells that draw from this aquifer are
for domestic and farm supplies, although a few industrial and public
supplies tap this formation. Well yields for this aquifer range from
less than 1 to 102 gpm and average about 9 gpm. Transmlsaivlty and
storage coefficients calculated from aquifer tests show a wide range of
values, depending on the zone of production and lithology encountered.
The lower units of the aquifer yield saline water in some sections and
are not suitable for domestic or public usage. Aquifer tests in the
Pennsylvanian rocks, where overlain by alluvium, commonly show some
indication of hydraulic connections between the bedrock and the alluvium
and/or the river. Water levels recorded in the alluvial and Pennsyl-
vanian aquifers have shown variable head differences between Che
the potentlometric surfaces of the two aquifers. Vertical gradients
developed In the vicinity of WVOW show head differences as great as 30
ft. Much of the ground water encountered in the deeper aquifer system
is presumed to occur in joint-openings, along bedding planes, and in the
rock's pore space.
A series of nonpotable aquifers are present at depths below WVOW. These
aquifers consist of Pennsylvanian and Misslssipplan age rocks that yield
saline brines. These brines have a number of industrial uses such as
cooling fluid and for the production of chlorine, bromine, and other
elements. Although generally these brines lie below the potable upper
aquifer systems, at least three brine wells less than 200 ft deep occur
in the vicinity of WVOW and were as identified during the RI. During the
1800s several operations existed along the reach of the Ohio River near
Point Pleasant to make salt by evaporation of brine from well water.
Two natural springs are located adjacent to WVOW. A small spring was
present prior to 1966 about 1,500 ft south of the installation along
State Rt. 62. This spring had about a 0.1-gpm flow rate and was used for
domestic supply aC times. The source of the spring was the Conemaugh
aquifer. The second spring was located approximately 500 ft east of the
installation boundary along Potter Creek. This spring flowed from the
Monongahela aquifer and had a yield of around 0.1 gpm. This spring was
used for stock watering and was not a potable water supply.
-------
-22-
SUMMARY AND CONCLUSIONS OF RI FOR FIRST OPERABLE UNIT
In January 1986, in a mutual agreement between EPA and DOD, it was decided
that in order to expedite the implementation of remedial actions that sub-
sequent studies at the site would be divided into two operable units and
that remedial efforts for the first operable unit would be initiated while
additional data is gathered for the areas in the second operable unit.
This section summarizes the principal findings of the first operable unit
RI and is organized according to the areas of concern which are 1) the TNT
Manufacturing Area including surface and underground wastewater transport
lines, and 2) the Burning Grounds. Contaminant sources are Identified
and observed levels of contamination in the various media (i.e., ground
water, surface water, sediments) are indicated. Actual migration or the
potential for migration of the observed contaminants are discussed, and
exposure pathways and potential receptors are identified.
TNT MANUFACTURING AREA
1. Contaminant sources observed in the TNT Manufacturing Area include
residual nitroaromatic compounds and the soils that had come into
contact with these compounds. Crystalline residues containing up to
70-percent nitroaromatlcs were observed in one of the excavated sewer-
lines, and soils beneath most of the sewerlines that were excavated
contained visible discoloration and had detectable levels (10 to 500
ug/g) of nitroaromatic contamination. Additional contaminant soures
exist due to nitroaromatic residues (up to 20,000 ug/g) in surface
soils within 5 to 10 m (i.e., 16 to 32 ft) of the foundations of the
process (i.e., nitrating) and refining (i.e., washer/flaker) facili-
ties. The principal nitroaromatic contaminant in soils is 2,4,6-TNT.
2,4-DNT and 1,3-DNB were also detected.
2. Nitroaromatic contamination was observed in ground water in the
shallow, water-table aquifer, in the shallow ground water emanating
from seeps, and in the surface water in Pond 34. Highest levels of
nitroaromatic contamination (up to 14,000 ug/L) were observed in the
shallow ground water in the vicinity of the Red/Yellow Wastewater
- Sewerlines in the main TNT processing area. This contamination
apparently resulted from leakage of red/yellow wastewater along the
underground sewer or infiltration from contaminated soils adjacent to
the processing facilities. Lower levels (up to 100 ug/L) of nitro-
aromatic contamination were observed In the shallow ground water along
the TNT Manufacturing Area east perimeter road, downgradient of the
primary processing facilities and sewerlines. This contamination may
result from the migration of contaminants that were observed in the
ground water along the Red/Yellow Water Sewerlines in the main pro-
cessing area or from spillage of finished TNT in the areas near the
conveyors and/or nail houses.
-------
-23-
3. The only surface water feature in the TNT Manufacturing Area,
Pond 34, contained low but detectable levels of 2,4-DNT (0.8 ug/L)
and 2,4,6-TNT (0.4 ug/L). These levels are below the 10-5 human
health criteria for 2,4-DNT (1.1 ug/L) and 2,4,6-TNT (44 ug/L).
This contamination apparently results from surface runoff of water
from contaminated soils in the TNT Manufacturing Area and/or seepage
of ground water through the sediments of the pond. No surface seeps
were identified leading into this pond during the RI.
4. Ground water migration of nitroaromatlcs is occurring from the TNT
Manufacturing Area through the shallow, water-table aquifer to ground
water seeps downgradient of the southeast end of the TNT Manufacturing
Area. While nltroaromatic contaminants (up to 200 ug/L) have been
measured in the ground water seeps which then migrate to Ponds 9 and
10, nitroaromatic contamination was not detected in either the sur-
face water or sediments of these ponds.
5. Surface migration of contaminants from the TNT Manufacturing Area is
occurring via drainage of water containing nitroaromatics from Pond
34, through a culvert beneath the east perimeter road and into Pond
9. Detectable levels of nitroaromatlcs, however, were not observed
in the water or the sediments of Pond 9.
6. The ground water gradient in the TNT Manufacturing Area is toward the
east-southeast with an estimated velocity of 0.6 ft/day. No westerly
component was observed. A lateral flow component occurs toward the
east-southeast in the shallow, water-table aquifer due to infiltra-
tion of rainfall and the low permeability of the underlying gray clay
confining unit. This lateral flow results in the observed downgrad-
ient ground water seeps. The potential for downward migration of
contaminants into the deep, confined alluvial aquifer is precluded
due to the confining gray clay unit.
7. No migration of contaminants to Oldtown Creek was observed in either
the ground water or surface water. The areally limited, silty sand
lens penetrated by monitor well CV21 contained a low level of 2,4,6-
TNT (0.8 ug/L) and low levels of trace metals, which may Indicate
residual contamination from overflow of the old Yellow Water Reservoir/
toxic swamp area.
-------
-24-
Exposure pathways to humans and animals for the nitroaromatic contami-
nants observed in the TNT Manufacturing Area include both direct.'and
indirect routes. Direct exposure of animals and humans to nitroaromatic
contamination can occur via direct contact (dermal and/or inhalation)
with nitroaromatic residues in the soils adjacent to the processing and
refining facilities or via direct contact with the contaminated ground
water seeps* Indirect exposure can occur via terrestrial and aquatic
food chain mechanisms. In addition to the chemical hazard associated
with exposure to nitroaromatics, a physical hazard exists due to the
numerous open manholes in this area, most of which are concealed by
vegetation.
BURNING GROUNDS
Nitroaromatic contamination, Including pieces of crystalline TNT and
soils containing up to 4-percent (40,000 ug/g) nitroarooatics exists
in the soils of both the East and West Burning Grounds area; In
addition to the nitroaromatic contamination, the soils of the West
Burning Grounds contain Polynuclear Aromatic Hydrocarbon* (PAHs), In-
cluding benzo(a)pyrene, large piles of friable asbestos, deposits of
elemental sulfur, and lead concentrations of up to 1,400 ug/g. These
contaminants principally are confined to the surface soil layer only.
2. No contamination by nitroaromatic compounds or priority pollutant
organlcs was observed in the ground water in the Burning Grounds
area. Additionally, no nitroaromatic contamination was detected in
the surface waters downgradlent of the Burning Grounds. One sediment
sample at OTC4, downgradlent of the Burning Grounds area, however,
did contain a low (0.2 ug/g) but detectable level of 1,3-DNB.
Asbestos contamination (2.6 x 10° fibers/L) was observed in the
surface waters downgradient of the Burning Grounds.
The only evidence of nitroaromatic contaminant migration via surface
water runoff from the Burning Grounds area was the low level of
1,3-DNB that was detected in the sediment at OTC4. Asbestos migra-
tion is occurring from this area via surface erosion into downgradlent
surface waters.
-------
-25-
Immediately below boch che Ease and Vest Burning Grounds is 30 co
35 ft of clay deposits. The observed ground water gradient is toward
a trough beneath the East Burning Grounds and toward the west in 'the
area of the West Burning Grounds. The surface clay deposits,
however, In the vicinity of Monitor Wells GW3 and GW4 are thin and
have been eroded. Elevated levels of sulfate and dissolved solids in
the ground water aC these locations indicate a potential migration
pathway exists for surface water infiltration to the water-table
aquifer is this area, which is topographically downgradient of the
West Burning Grounds. No contamination by nitroaromatics, however,
was detected in the ground water.
During the dry period of summer and early fall, an atmospheric route
for migration of nitroaromatics, asbestos, PAHs, and lead also exists
from the Burning Grounds area via wind-induced suspension of soil
particulate material. No measurements were performed during the RI
to quantify this atmospheric migration rate. However, due to clima-
tologlcal conditions for this area, the atmospheric rate is likely
small compared to the surface runoff/erosion rate.
6. Direct and indirect exposure pathways to humans and animals exist for
the contaminants observed in the Burning Grounds area. Direct
exposure of humans and animals to the observed soil contaminants
(nitroaromatics, asbestos, PAHs, and lead) can occur via contact
(dermal) with the soils in the Burning Grounds. Direct contact can
also occur via Inhalation of suspended soil particulates containing
these contaminants. Indirect exposure exists via both aquatic and
terrestrial food chain mechanisms.
INVESTIGATIONS BEYOND McCLINTIC
1. Thirteen domestic/municipal water supply wells were sampled during
the RI. All but one well (the McClintlc Doghouse Well) are located
off the McClintic State Wildlife Station. Each of the wells,
however, is located within the former boundary of WVOW as it existed
during WWII. No nltroaromatic compounds or significant trace metals
were detected in the ground water from any of the water supply wells.
All of the supply wells are installed in the deep, confined, alluvial
aquifer due to the high yields from this zone. Nitroaromatlc
-contamination from the TNT Manufacturing Area is limited to the
' shallow, water-table aquifer located in the sands above the confining
clay units. Several monitoring wells installed during the RI through
the confining gray clay unit exhibited artesian conditions, with
Monitor Wells GW21D and GW22D having continuous flow from the well
casing. The confining clay units and the observed artesian
conditions of the deep, alluvial aquifer greatly limit'the potential
for contamination of this aquifer.
-------
-26-
2. The sampling and analysis of water/sediment along Old town Creek and
the principal tributaries draining Che site indicate that significant
asbestos migration is occurring from the Burning Grounds area.
3. The remelt facility is located in the southern portion of the maga-
zine area along the upper reaches of Hill Creek. This operation
has been in existence since the 1950s to melt and recast explosives
reclaimed from ordnance materials. Sampling and analysis of soils
adjacent to this facility indicate that nitroaromatic contamination
exists in the soils at levels up to 6,000 ug/g. No nitroaromatic
compounds were detected in either the surface water or sediment at
sampling locations in the Mill Creek drainage system adjacent to the
remelt facility. Apparently, erosion of the contaminated soils
adjacent to the remelt facility and transport into Mill Creek is not
occurring or the rate is insignificant compared to Inputs of uncon-
tamlnated water and sediments.
CONTAMINATION STATUS
The following paragraphs are a summary of the overall site contaminant
sources, contaminated media, hydrogeological setting, contaminant
migrations and exposure pathways. See Figures 9 through 13 for the lo-
cations of ground water monitoring wells and soil, surface water and
sediment sampling locations. The principal sitewlde contaminants are
nitroaromatic residues, and the predominant compound observed was
2,4,6-TNT although, 1,3,5-TNB and 2,4-DNT were also widely distributed.
The major nitroaromatic contaminant source areas were:
1. The surface and subsurface soils in the TNT Manufacturing Area*
2. The industrial sewerlines in the TNT Manufacturing Area and
trunk sewerlines leading from the Pond 13 area to the outfalJLjk
and "*™
3. The surface soils in the Ease and West Burning Grounds.
In the surface soils of the TNT Manufacturing Area and the Burning Grounds
concentrations ranging to the low percent levels «10 percent) were en-
countered. The industrial sewerlines exhibited concentrations reaching
71Z. These source areas contribute surface water and ground water con-
tamination by nltroaromatics and represent a hazard to human beings and
wildlife as a result of direct contact.
-------
-27-
Asbestos, disposed primarily at the West Burning Grounds, represents a -
direct contact hazard in this area. Surface water migration of asbestos
is occurring into the drainage leading from this source area into Oldtown
Creek. Waters of the drainage area and Oldtown Creek are not used as
drinking water sources or for body contact recreation. PAHs and lead
also were observed in the West Burning Grounds. Although these
contaminants represent a potential contact hazard in the source area, no
generalized migration appears to have occurred. Asbestos also exists
offsite in the powerhouses and Mason Furniture Co. Access to the south
powerhouse is not restricted. Both powerhouses and the Mason Furniture
Co. are privately owned.
The major contaminated media are the following:
1. The source area soils described above and soils/sediments which
have eroded from the contaminated sources;
2. The shallow aquifer underlying the TNT Manufacturing Area;
3. The surface water -and sediments of Pond 13 which are being
contaminated by nitroaromatic residues traveling down the
gradient of the sewerline from the TNT Manufacturing Area and/or
from the Wet Wells; and
4. Waters of Pond 34 on the east side of the TNT Manufacturing Area.
WVOW is located on alluvial terraces of the Ohio River and is drained
primarily by two creek systems, Oldtown Creek and Mill Creek. Mill Creek
drains the northern portion of the site Including the Red Water
Reservoirs, Yellow Water Reservoir, Acids Area, and the magazine area.
Oldtown Creek drains the Pond 13 area, the TNT Manufacturing Area, and
the Burning Grounds. A total of 39 impoundments has been developed on
WVOW for the propagation of fish and waterfowl.
The sediments above bedrock consist of layers-and beds of gravel, sand,
silts, and clays which were deposited by the Ohio River as alluvium since
the Pleistocene glaciation. The surface sediments consist mainly of
silty clays in the southern portion of the site. The surface sediments
in the northwestern section are silts and sands of varying clay content.
A gray clay stratum exists at an elevation approximately 560 ft-MSL and
lies up to 20 to 30 ft below the surface. This layer acts as a confining
layer, dividing the aquifer system into two parts. Above the confining
layer a shallow water-table aquifer exists in which ground water flow is
primarily laterally to the east from the TNT Manufacturing Area.
-------
-28-
In the Burning Grounds, the ground water movement In this aquifer is complex.
The clay confining layer is thickest under the Burning Grounds and the TNT
Manufacturing Area. Below the confining layer a second alluvial aquifer
system exists which is under artesian pressure. At the center and south-
eastern portion of the site the potentiometrlc surface is higher that the
land surface. Vertical gradients vary from upward in these areas to strongly
downward in the center of the TNT Manufacturing Area. Contamination is con-
fined to the shallow aquifer system and Is migrating from the TNT Manufacturing
Area. Contaminated ground water discharges from the shallow aquifer to Ponds
9 and 10 via a aeries of seeps at the base of the escarpment along the southern
and southeastern edge of the TNT Manufacturing Area.
Migration of nitroaromatlcs is retarded significantly in the ground water
compared to the migration of the associated releases of sulfate and
nitrate. Contamination migration in surface waters (Pond 13 and
Pond 34), and from the seeps into Ponds 9 and 10 is limited by dilution
and by fate processes, primarily photolysis. No offsite surface water
contaminant migration or significant onsite spread was observed.
Direct and indirect contact via the food chain through hunting and fishing
are potential exposure pathways for nltroaromatic residue* from the soils.
The ground water exposure pathway from the shallow, contaminated aquifer in
the TNT Manufacturing Area is via discharge to surface waters and taking of
fish and/or waterfowl.
CONTAMINANT MONITORING WELLS
Fifty monitor wells were Installed in two phases (Phase IA and Phase IB)
during the WOW investigation. During Phase IA, 26 shallow monitor wells
and 3 deep monitor wells were installed; during Phase IB, 15 shallow moni-
tor wells and 6 deep monitor wells were installed. The locations of moni-
tor wells are shown in Figures 9, 10 and 11. The locations, depths, and
screened intervals of monitor wells were selected to delineate contaminant
distribution and the geohydrologlcal environment. This selection was based
on the results of ground water data obtained from the observation wells,
subsurface conditions observed during drilling, and from preliminary results
of the geophysical survey which was being conducted concurrently with the
observation well installation. The Phase IA monitor wells were Installed
from October to December 1984, immediately after assessment of ground water
level data from the observation wells.
Because of the time constraints of this study, Phase IB well installation
proceeded immediately following the conclusion of Phase IA drilling. Lo-
cation and screen intervals for Phase IB wells were based on the results
obtained from the Phase IA sampling. Ground water samples collected dur-
ing well development of Phase IA wells were analyzed using a rapid colori-
metric TNT detector kit. This detector kit provided a rapid presence-
absence determination for nicroaronatic compounds and was Instrumental in
the selection of several Phase IB veils.
-------
v£Jj£2J
SM _• • X
~ *«.*»>
aste
LOCATIONS CJF MONITOR WELLS
INCLUDING EXISTING EPA WELLS
ORDNANCE
SAMPLING WELLS
-------
r» ,- • , .»•
«9C ..- 4^. .-
«fft^
%^:-7
-------
* • \ '- . « . * <4
S**m ;£?:
Figure 11, Pag* 31
LOCATIONS OF MONITOR WELLS, EPA
WELLS, AND OFFSJTE DOMESTIC WELLS
WEST VIRGINIA
ORDNANCE WORKS
Investigation
-------
WATIM ftUWVOM
AMO TOXIC SWAMP AMIA
E3 VISUAL
OITICTOft A«0 COlOAfMCTmC
SOUftCU: U3ATMAMA.1
War
Slat* « Wwl
900 1000 MITERS
WEST VIRGINIA
ORDNANCE WORKS
Investigation-*
Figur* 12 , Page 32
LOCATIONS OF SOILS SAMPLING AREAS
-------
v. NORTH DRAINAGE (NO)
STATION ON UNNAMED
TRliUTAflY AT PATROL
ROAO
f-//l - '
- . / 9/""
»?•
#*&'• W
•J _ '• /
'0D* S-
...^ . v
•"•'Ar- - ' ' ~^
900 1.800 FEET
300 600 METERS
WEST VIRGINIA
ORDNANCE WORKS
Remedial Investigation
13, Page 33
LOCATIONS OF SURFACE WATER AND
SEDIMENT SAMPLING STATIONS
-------
-34-
ENDANGERMENT ASSESSMENT
The basic remedial objectives of the DA were defined in their endahger-
ment assessment (EA) report. The EA summarized and interpreted RI data>-'~
in order to assess actual and/or potential harm to public health, wel-
fare, or the environment from hazardous substances originating on WVOW.
Consequently, the EA justified the need for remedial action and served
to focus remedial action alternatives. Criteria for remediation were
developed in consideration of all realistic exposure pathways by which
people, wildlife, or aquatic life may be exposed to the contaminants.
Criteria development was modeled on the Preliminary Pollutant Limit Value
(PPLV) methodology developed at the U.S. Army Medical Bioengineerlng
Research and Development Laboratory (USAMBRDL). The PPLV methodology
represents an approach to criteria development based on site-specific
exposure and risk assessment techniques and Is documented by Small (1984).
The criteria were developed under the assumption that McClintic Wildlife
Station will continue to be managed as a hunting and fishing area with
unrestricted access. Furthermore, the methodology assumes that recrea-
tional users should not be exposed directly or through game and fish to
contamination levels that pose a significant risk. In addition, aquatic
and terestrlal biota should not .be exposed to toxic concentrations*
Several key factors affect the exposure assessment. Hazardous concen-
trations of contaminants associated with the TNT Manufacturing Area,
Burning Grounds Area, and Industrial Sewerllnes are restricted to the
McClintic-Wildlife Station and would, under the No Action alternative,
continue to be restricted. No residences will be constructed on the
McClintic Wildlife Station. Ground water resources that have become
contaminated are not now used for potable supply; the McClintic Wild-
life Station is served by a municipal supply and overwhelming institu-
tional constraints control against the use of ground water on the
McClintic Wildlife Station as a future potable supply. The McClintic
Wildlife Station is the most popular (i.e., heavily utilized) facility
in West Virginia's state wildlife management system because of its proxi-
mity to the state's two largest cities, Huntlngton and Charleston. More
importantly, the original deed transferring the property from DA to the
State had a restriction requiring that the property be maintained as a
wildlife preserve. Because of these constraints, it is clear that resi-
dences will not be constructed on McClintic Wildlife Station, nor will
onsite ground water be used as a drinking water supply.
The criteria for residual contaminant levels are summarized in Table 4.
By comparing actual contaminant levels with these criteria, the actual
risks Incurred by the exposed population have been estimated. The esti-
mated lifetime cancer risk associated with regular use of the site and
consumption of harvested game is estimated not to exceed 4 x 10~5. Since
the population exposed at the assumed levels is less than 200, the ex-
pected number of excess cancer incidences under the No Action alternative
is less than 0.008. In other words, odds are about 100 to 1 that no ex- .
cess cancers will occur as a result of contamination in the source areas.
Noncarcinogenlc health effects are not likely, with the possible excep-
tion of effects associated with 2,4,6-TNT which exceeds the derived cri-
terion by a factor of 4.
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Table 4. Acceptable Soil, Sediment, and Water Contamination Levels
for WVOW Source Areas
McClintic Soils* Pond
[0.5 to 2 feet (ft)] Waterst
Compound (ug/g) (ug/L)
Pond Surficlal Soils**
Sedimentst (to 0.5 ft)
(ug/g) (ug/g)
2,4,6-TNT
1,3,5-TNB
1,3 DNB
2,4-DNT
10~6 risk
10-5. risk
2,6-DNT
10"6 risk
10-5 risk
Total Nitroaro-
matics
10-6 risk
10"5 risk
7,300
72,000
3,400
15
150
3.1
31
500
NAtt
60
80
160
3.4
34
0.67
6.7
4
8
16
0.22
2.2
0.53
5.3
680
2,800
190
1.5
15
0.31
3.1
50
300
*Protects hunters from exposure by the plant-to-game pathway.
tProtects aquatic life and fishermen.
**Protecta frequent McClintic Wildlife Station visitors from exposure by
direct contact and Inhalation of dust.
TtPlants do not grow in soils containing total nltroaromatlc
-' contamination at concentrations that would result in 10"5 cancer risk.
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Aside from an endangennene posed by the toxioity of nitroaroraatic
contamination to humans and wildlife, additional hazards exist at
the site. Some sewerlines contain reactive wastes. These wastes
should be removed or rendered nonreactlve. Open manholes associated -
with sewerlines pose a safety hazard which should be remedied.
Friable asbestos deposits in the Burning Grounds Area pose an inhala-
tion hazard requiring remediation. Vegetation stress is evident in
the Burning Grounds Area, and it appears that vegetation will not
grow in soils containing more than 1,000 ug/g of total nltroaromatics.
Considering the findings of the EA, the following remedial objectives
were defined to minimize or eliminate the endangerment associated with
the source areas:
1. To eliminate safety hazards associated with reactive wastes:
remove or render nonreactive all reactive wastes.
2. To achieve less than 10"^ individual lifetime excess cancer risk
for avid hunters and their families or friends who consume meat
from game that feed in contaminated areas: remove or cover the
upper 2 ft of soil if total nltroaromaelc contamination exceeds
500 ug/g.
3. To achieve less than 10~6 individual lifetime excess cancer risk
for frequent visitors to the McClintic Wildlife Station who come
into direct contact with surficial soils: remove or cover the
upper 6 Inches of soil if total nltroaromatic contamination
exceeds SO ug/g.
Achievement of these criteria will also eliminate the endangerment associated
with other site contaminants since the other contaminants are found in
association with high levels of nitroaromatlc contamination. Achievement
of Objective 3 will also mitigate potential impacts on aquatic biota
associated with erosion and runoff from extreme storm events. All ponds
stocked and used for fishing currently achieve the recommended surface
water and sediment criteria designed to protect fishermen and aquatic
life. It is necessary that any remedial actions taken will not result in
exceedance of the acceptable contamination levels presented in Table 4.
To ensure that the individual lifetime excess cancer risk not exceed
10~5, the objectives could be modified as follows:
o No change for Objective 1.
o Delete Objective 2: Plants cannot grow in soils contaminated
with nitroaromatics at levels that would lead to a 10~5 risk
level for game meat consumers nor would exposure to
noncarcinogenic contaminants exceed acceptable levels as a
result of plant uptake, regardless of soil contamination.
o For Objective 3, change the criterion for removing or covering
the upper 6 inches of soil from SO ug/g to 300 ug/g total
nitroaromatlc contamination.
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ALTERNATIVE DEVELOPMENT
The major objectives for the remedial action to be taken at the WVOW
site are to eliminate the sources of contamination. This would involve
preventing and/or reducing: a) infiltration through the sources'; b) direct
contact with contaminated soil; c) future contamination of ground water,
and d) the degradation of surface waters. The requirements of CERCLA
Section 104, EPA's mandate to protect the public health and welfare and the
environment, determine the goals and level of response for the site.
In an effort to determine remedial alternatives for the subject site,
feasible technologies were identified. These technologies were then screened
to eliminate all but the most practicable and implementable ones. This
screening considered: technical, public health, environmental, institutional,
and cost considerations. Those technologies that passed the technology screen-
ing process were used to form remedial alternatives.
The remedial alternatives were developed using best engineering judg-
ment to select a technology or group of technologies that best addresses
the problems existing at the site to protect public health, welfare, and
the environment. In an effort to provide a degree of flexibility in the
final selection of a remedial action, alternatives covering a range of
remedial action categories have been developed.
These categories are described below:
a) No action
b) Alternatives for treatment or disposal in an offsite
facility.
c) Alternatives which attain public health and environmental
standards as defined by CERCLA.
d) Alternatives which exceed public health and environmental
standards as defined by CERCLA.
e) Alternatives which do not attain public health or environ-
mental standards but will reduce the likelihood of present
or future threat.
REMEDIAL ACTIOH ALTERNATIVES FOR AREAS OF STUDY (TNT MANUFACTURING AREA,
BURNING GROUNDS AREA AND INDUSTRIAL SEWERLINES)
1.1 OFPSITE DISPOSAL ALTERNATIVES
1.1.1 Alternative 1A2
Alternative 1A2 for the TNT Manufacturing Area and the Burning Grounds
involves the remediation of contaminated soil. Soil will be excavated
and transported to a RCRA-peraitted commercial Incinerator that will accept
nitroaromatics-contaminated soil in large quantities. The industrial sewer-
lines are not addressed, because 10 offsite facility was Identified which
would accept reactive materials for incineration.
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- 38 -
The objective of this alternative is complete removal of all contaminated
soil that contains nitroaromatic concentrations above the 10~& risk, levels.
To achieve a 10~6 risk level for soils in the TNT Manufacturing Area
and the Burning Grounds the following remedial objectives were establishedt
1. Remove, or render nonreactive, all reactive wastes;
2. Remove or cover the upper 2 ft of soil If total nitroaromatic
contamination exceeds 500 ug/g; and,
3. Remove or cover the upper 6 inches of soil If total
nitroaromatic contamination exceeds SO ug/g.
The worst-case estimate for surficial contamination (>50 ug/g) at the TNT
Manufacturing Area Is approximately 9,000 ft2 per TNT line, or 90,000 ft2
total for the 10 lines. The estimates for the Burning Grounds is 48,980 ft2.
The WVOW RI report (ESB, 1986a) Indicates contamination was consistently
below the 10~6 remedial objective of 500 ug/g at a depth of
50 centimeters (cm) (approximately 1.6 ft). Therefore, excavation to a
depth of 1.6 ft was assumed sufficient to achieve the 10-6 cleanup
objective to remove contamination within the upper 2 ft. Assuming a
25-percent swell factor upon excavation, approximately 10,325 cubic yards
(cy) of soil will be removed and incinerated offslte.
•
Site Preparation—Mobilization operations associated with this
alternative Include:
1. Clearing and grubbing of heavy vegetation over an estimated
2.1 acres (0.21 acre per TNT line, 2 acres for Burning Grounds)
2. Performing a topographic survey of the contaminated area to
document original elevations,
3. Installing trailers for decontamination and administration
purposes,
4. Constructing access roads capable of supporting heavy equipment,
5. Constructing surface water controls, and
6. Extending utilities to these mobilized areas.
Access roads must be constructed to each building foundation to
facilitate the movement of heavy earthmovlng equipment. Access roads to
the Burning Grounds will be reconstructed from a nearby existing gravel
roadway. An estimated 3,500 linear ft of berms and/or swales will be
constructed around the boundaries of contaminated areas to prevent surface
water from entering or leaving the area during construction activities.
Uncontaminated runoff will be routed around the area to existing drainageways.
Onslte surface water will be channeled to collection points for evaporation
and eventual offsite treatmenc (assuming significant runoff contamination).
Ground water is not expected to be encountered during excavation because
the uppermost aquifer is generally more than 15 ft below the land surface.
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.A decontamination station will be constructed to serve personnel, trucks,
and equipment entering and leaving the contaminated areas. A concrete
pad with a raised curb around the outer edges to collect rinsewacers is
usually installed for this purpose. The decontamination station will be
equipped with containers for disposal of contaminated Personnel Protec-
tive equipment, tubs and sprayers for personnel decontamination, a
pressure washer for equipment and-truck decontamination, and a pump to
transfer spent washwater from the sump to a holding tank. The
decontamination station will be centrally located to minimize the
distance contaminated vehicles must travel onsite.
Special Conditions—The decision to accept this material by a commercial
Incineration facility is dependent on many factors. First, a waste
profile sheet which gives detailed information on waste characteristics
must be submitted to the facility. After reviewing this sheet, the
commercial facility's management will decide if the waste is to be
accepted and under what conditions.
One facility was identified which gave a "prescreenlng" acceptance of the
waste, assuming nonreactlvity. The facility, located approximately
750 mi from the WVOW site, is one of a few commercial incinerators
capable of accepting the waste. One condition of acceptance is that the
wsste must be drummed. This condition, coupled with the long distance
which, vehicles must travel to deliver the waste, makes this alternative
undesirable from a cost and safety standpoint.
A second factor to be considered is the availability of commercial
Incinerators at the time of actual cleanup. With increasing regulatory
restrictions placed on the types of materials which can be landfilled,
the demand for alternate disposal options will increase. This may result
in a shortage of incinerator capacity in the near future, causing the
offsite disposal of large volumes of soil to be infeaslble.
Implementation—Implementation of this alternative requires excavation of
soil with a backhoe and/or other earthmoving equipment. Backhoes under
normal operating conditions will achieve greater than 100 cubic yards per
hour (cy/hr) production rate; however, to avoid overstockplllng
contaminated materials, excavation will coincide with loading and offsite
transport rates.
.The soil will be transported to a staging area where front-end loaders
place the soil into containers or load the soil directly into trucks..
Trucks will transport the material to a RCRA-permltted commercial
incinerator after manifest requirements are met. Contaminated soil will
be' transported.in accordance with DOT regulations covering transport of
hazardous materials.
Confirmatory sampling and analysis of soil will be required to provide
adequate assurances that soil has been removed to meet soil criteria
objectives.
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Asbestos and rubble will be loaded Into trucks for transportation to a
sanitary landfill. In-sltu flaming will be required for all TNT residue
in the Burning Grounds. Flaming entails the use of a hand held flamer to
thermally decontaminate surface contaminants.
Closure—Closure of the site involves backfilling the excavated areas to
original elevations, including compaction, final grading, and
revegetatlon. Temporary facilities will be removed following
decontamination. All wastes from the decontamination of equipment and
personnel will be collected and transported to a RCRA-permltted disposal
facility.
1.1.2 Alternative 1B1
Alternative 1B1 for the TNT Manufacturing Area involves the remediation of
soil surrounding the Washer/Plaker building foundations, di/trinltrating
houses, acid/fume recovery houses, dlacid fortifier house, and nail houses.
In the Burning Grounds, it involves the offsite disposal of contaminated
soil. Soil will be excavated and transported to a RCRA-permltted offsite
landfill for disposal. The Industrial Sewerlines are not addressed because
offsite facility was identified which would accept reactive waste.
The objective of this alternative is the complete removal of all nitroaro-
matlc concentrations above detectable levels (i.e., >2 ug/g, using field
analyses). The worst-case estimate for surficlal contamination is approxi-
mately 46,000 ft2 per TNT line, or 460,000 ft2 total for the 10 lines lo-
cated at the TNT Manufacturing Area, and 166, 550 ft2 at the Burning Grounds.
The excavation depth to achieve complete removal varies depending on the
level of surficlal contamination, due to the downward migration of various
pollutant concentrations. Approximately 69,000 cy of contaminated soil must
must be excavated and landfilled offsite, assuming a 25-percent swell factor.
The Washer/Plaker building foundations (approximately 27,000 ft2) will be
demolished, loaded into covered trucks, and transported to a sanitary land-
fill. These foundations must be removed to gain access to underlying soils.
If necessary, the Washer/Plaker foundations will be decontaminated prior to
offsite disposal using a hand-held flaming device. The contamination sur-
rounding other foundations in the TNT Manufacturing Area, which was generally
below SO ug/g, is not considered high enough to justify foundation removal.
Site Preparation—Site preparation is the same as that described under
Alternative lA2~~except:
1. The area to be cleared is approximately 15 acres; and
2. An estimated 16,000 linear ft of berms and/or swales will be
required to control surface runon/runoff.
Local soil imported from offsite will be used to backfill the excavated
areas. Approximately 69,900 cy of backfill will be placed and compacted
to minimize post-closure settlement. The top 1 ft of backfill will con-
sist of topsoil to facilitate the establishment of vegetative cover. The
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fill will be graded to prevent ponding of surface water, and native grasses
will be seeded and mulched to prevent erosion. Periodic post-closure in-
spection and maintenance of the revegetative areas and short-tern land use
restrictions will be required until the area is stable.
Implementation—Contaminated soil and foundations will be loaded from a
staging area into covered trucks for offsite transport. Each truck will be
decontaminated and Its contents manifested before leaving the site. The
nonreactive materials will be placed In double-lined, highly impermeable
cells meeting the technical construction and operation requirements of RCRA.
The landfill will also be EPA-approved for acceptance of CERCLA wastes. In
situ flaming will be accomplished prior to excavation of the soils in the
Burning Ground.
Confirmatory sampling and analysis of soil will be required to provide
assurances that soil has been removed to meet criteria objectives.
Closure—Closure and post-closure activities are the same as those described
under Alternative 1A2, except that 69,900 cy of backfill will be placed and
compacted to minimize poatclosure settlement.
Special Considerations—Before a commercial landfill will accept any nitro-
aromatlcs-contaminated soil, an analysis must be performed and a statement
provided certifying that the material is nonreactive. One commercial landfill
which gave a preliminary acceptance to the nonreactive soils was identified.
The facility is under RCRA interim status and is located approximately 200 mi
from the WOW site. Contaminated soil can be accepted in bulk by this facility.
The disposal of contaminated soils into landfills over the next few years is
questionable as the goal of the Federal hazardous waste management program is
to reduce dependence on land disposal as a predominant management option.
1.1.3 Alternative 1B2
Alternative 1B2 for the TNT Manufacturing Area Land the Burning Grounds is the
same as Alternative 1B1, except contaminated soil is removed to 10~° risk
levels. Approximately 10,325 cy of soil will be excavated from both areas and
landfilled offsite. The Industrial Sewerlines are not addressed because no
offsite facility was identified which would accept reactive wastes.
Site Preparation—Site preparation is the same as that described under Alter-
native 1A2.
Implementation—Implementation is the same as that described under Alternative
1B1.
Closure—Closure and post-closure activities are the same as those described
under Alternative 1A2.
Special Considerations—Special considerations are the same as those described
under Alternative 1B1.
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1.2 ATTAINS REQUIREMENTS ALTERNATIVES -
1.2.1 Alternative 2A
Alternative 2A for the TNT Manufacturing Area and the Burning Ground involves
the remediation of contaminated soil. For the Industrial Severlines it involves
excavation and onsite incineration and backfilling of all Severlines. Soil
will be excavated and transported to an onsite incinerator. TNT residue will
be JLn situ flaaed prior to soil excavation. The substantive requirements of
RCRA for incineration of hazardous wastes will be achieved. No peraits will
be required for this onsite CERCLA resedial action as per 40 CFR Part 300,
Vol. SO. No. 224, Nov. 20, 1985.
The objective of this alternative is the complete removal of all contaminated
soil above 10"6 risk levels, as described in Alternative 1A2. The estimated
volume of soil requiring remediation is 11,000 cy. An additional 18,000 cy of
uncontaminated soil excavation will be necessary to gain access to the
Sewerlines.
Site Preparation—Site preparation for the TNT Manufactuzlng Area and Burning
Grounds is the same as for Alternative 1A2, except additional trailers will be
used for incineration operations. Fencing muse be constructed around the
incinerator site to limit public access. For the Industrial Severlines site
preparation will be involve the the following:
*
1. Clearing and grubbing of heavy vegetation over an estimated 17 acres,
assuring a 30 ft. corridor along the Sewerlinea for equipment workspace;
2. Installation of trailers for decontamination and administrative
purposes;
3. Construction of access roads for heavy equipment;
4. Surface water controls; and
5. Extenstion of utilities to these mobilized areas.
Berms will be constructed to divert runoff around excavated areas. A
decontamination station will be established similar to Alt. 1A2.
Implementation—A transportable rotary kiln incinerator will be set up at the
TNT Manufacturing Area. The solids incinerator module consists of a trailer-
mounted rotary kiln, solids preparation and charging equipment, a burner, an
air blower, and an ash discharge system.
Contaminated soil will be trucked to a temporary storage area near the
incinerator. From there It will be loaded into the incinerator feed hopper
and fed to the incinerator at & rate between 1 and 4 tons per hour (tons/hr).
Ash formed during incineration is discharged into the kiln end breeching,
where it falls into an ash discharge chute. A water-cooled screw conveyor
subsequently carries the ash tj a storage bin, where it is sampled for
potential contaminants before being used as backfill in excavated areas.
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The incinerator will be equipped with an afterburner to ensure complete -
combustion of kiln off-gases. A constant afterburner temperature vj.ll be
maintained with auxiliary fuel oil or fuel gas. A baghouse will be necessary
to control release of particulate material and acidic gas products of
combustion. Periodic sampling of stack gases will be necessary to ensure
compliance with air quality restrictions.
Organic destruction efficiencies of greater than 99.99 percent will be
maintained as required by RCRA. Extraction procedure (EP) toxicity testing
for leachable metals in the ash will be necessary to determine whether or not
disposal at a RCRA-pernltted landfill will be required.
For the Industrial Sewerlines excavation of contaminated sewerlines will be
accomplished using two backhoes operating in tandem. The first backhoe will
perform nonhazardous excavation to the contaminated sewerlines. The second
backhoe will excavate contaminated sewerlines. A bulldozer will backfill the
trench immediately ahead of the second backhoe in order to provide a working
bench. Additional backfill may be necessary to completely fill the trench.
The use of two backhoes in this manner will minimize any cross-contamination
between contaminated media and uncontamlnated soil which is used as backfill.
For safety purposes, the sewerlines may be wetted to reduce the potential for
detonation from impact or confinement. Testwork and material evaluation will
be required to establish the percent moisture needed to effect excavation and
reliable conveyance of the materials. Blast shields will be employed during
excavation.
Contaminated soil removed from the trench will be returned to the trench at
locations that are greater than 2 ft below the land surface and covered with
clean backfill.
Special precautions will be used in the handling, transport, and loading of
reactive materials into the incinerator. If wetting or slurrying the materials
is used to reduce the potential for detonation, these factors must be accounted
for in the rotary kiln design and operating parameters. The water must be
evaporated in the kiln, resulting in an additional heat requirement.
The sewerline material will be burned separately from any unreactive con-
taminated soil in accordance with RCRA requirements. In addition, organic
destruction efficiencies of greater than 99.99 percent will be maintained.
No permits are required for implementation of this alternative. Nonhazardous
ash, as defined by EP toxicity testing for leachable metals, will be used as
backfill.
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Closure—Upon completion of incineration operations, the incinerator will be
decontaminated* and removed. Wastes generated from decontamination activities
vill be collected and hauled to a RCRA-permitted landfill for disposal.
For the Industrial Sewerlines—Closure involves backfilling of the excavated
areas, compaction, final regrading, and revegetation. Preliminary investiga-
tions indicate that sufficient amounts of clean fill are available onsite.
Open manholes will also be backilled for safety reasons* All wastes from
decontamination of equipment and personnel will be collected and transported
to a RCRA-permltted disposal facility. The top 1 ft of backill will be loosely
compated topsoll to facilitate the establishment of vegetative cover.
Maintenance of revegetated areas is the only post-closure activity predicted
for this alternative. At closure, the Incinerator vill be decontaminated and
removed from the site.
Ash from the Incinerator will be used as backfill In the excavated areas.
Fill material and topsoil will be brought in to fill gaps in the excavated
area* and to facilitate proper contouring of the area. Native grasses will be
seeded and mulched over the fill areas to assist In preventing erosion. Post-
closure maintenance and inspection of these areas will be required.
Special Considerations—The characteristics of soils in the TNT Manufacturing
Area and the Burning Grounds must be evaluated prior to implementation to
determine the operating conditions, including feed rate, for the incinerator.
A vendor estimate of 4 cy/hr was used In the FS.
For the Industrial Sewerlines one company which specializes in transportable,
rotary kiln Incinerators showed an interest in using its equipment for the
incineration of potentially reactive sewerlines. Nevertheless, onsite
incineration of this material may prove very difficult and/or costly due to
the potential for explosioin as reactlves are exposed to high temepratures.
1.2.2 Alternative 2B
Alternative 2B is similar to Alternative 2A, except that the contaminated soil
is landfilled onsite instead of being incinerated. Contaminated soil will be
removed to 10~6 risk levels, as described in Alternative 1A2. Approximately
10,325 cy of soil will be excavated and landfilled onsite, approximately 680
cy of aewerline will be flashed and landfilled. No permits for this onsite
alternative will be required as per the NCP.
Site Preparation—Site preparation for the.TNT Manufacturing Area and Burning
Grounds Is the same as for Alternative 1A2, except an additional 2 to 4 acres
must be cleared at the landfill site. The landfill site must be fenced to
limit public access. For the Industrial Sewerlines site preparation is the
same as alternative 2A.
Implementation—The landfill will be designed and constructed to meet RCRA
criteria, Including a double-lined bottom and sides, double-leachate collection
system, and double-lined cap. The landfill for the 10,325 cy of soil will
cover approximately 2.5 acres. The landfill will be graded to minimize standing
water and Infiltration. Native grasses will be seeded and mulched to prevent
erosion. Fencing will be placed around the landfill to limit public access.
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Confirraatory sampling and analysis will be performed to provide assurance chat
contamination remaining in soils is below criteria. As the landfill is
constructed, contaminated materials will be placed and compacted in 1-ft layers.
Monitor wells will be installed around the landfill and ground water periodically
analyzed in accordance with RCRA requirements. Permits are not required for
the'-landfill because it represents an onsite CERCLA response action. For the
Industrial Sewerllne excavation will be the same as for Alternative 2A.
For the Industrial Sewerlines—Excavation will be the sane as described for
Alternative 2A. Contaminated soil removed from the trench will be returned to
the trench 2 ft below the land surfaces and covered with clean backfill.
Flashing involves the use of a controlled, high-temperature flame to thermally
degrade all contaminants. Flashing provides complete and rapid destruction of
all residues contacted by the flame.
Once1 the sewerlines are brought to the surface, they will be wetted with water
to desensitize explosive residues toward Impact. Water containing dissolved
and/or suspended explosives residue will be retained and treated as necessary.
After the sewerlines are wetted, the sewerllne pipes will be mechanically
fractured and the explosive residue will be separated from the pipe. The
residue will be placed in a remotely operated flashing device which will expose
all residue to the flame front. Because of the high temperature of the flame,
there should be rapid decomposition of all explosive residues present.
Occasional turning of the materials may be required to expose all reactives to
the flame.
After flashing, confirmatory sampling will be used to ensure that destruction
of explosive residues is achieved. The ash from the flashing device will be
placed in an onsite landfill, along with the contaminated sewerllne pipe and
small volumes of soils attached to the pipe.
Closure—Closure will include the removal of all temporary facilities, post-
closure sampling and analysis of ground water from monitor wells, and post-
closure landfill cover maintenance. The site must be registered as a hazardous
waste disposal facility with permanent land use restrictions. Soil which was
excavated to construct the landfill will be used as backfill in the TNT
Manufacturing Area and Burning Grounds and will be seeded with native grasses
for stability.
Special Considerations—There are no special consideration for this alternative
relative to the TNT Manufacturing Area and the Burning Grounds.
For the Industrial Sewerlines—The design of the flashing device could be
modeled after a Rockwell International* flamer used for sewerline decontamina-
tion at Alabamas Army Ammunition Plant (AAAP) (Rockwell,' 1981). The determina-
tion of explosive concentration of the residue is required to optimize the
dwell time of the f lamer. • .• .
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1.2.3 Alternative 2C ;
Under Alternative 2C, a multimedia cap will be used to isolate contami-
nated areas (exceeding SO ug/g total nitroaromatics) from direct contact.
Contaminated foundations remain in place and are capped along with the
soil.- The estimated area to be capped is approximately 2 acres. No per-
mits, will be required for this onsite CERCLA response action as per the
NCP. TNT residue will be iii situ flamed prior to capping. This alter-
native is not applicable to the reactive wastes in the Industrial Sewer-
lines.
Site Preparation—Site preparation is similar to that described for
Alternative 1A2, except for the references to excavation.
Implementation—The design of multimedia caps will conform to EPA's
guidance under RCRA, which recommends a 3-1ayer system consisting of
an upper vegetative layer underlain by a drainage layer over a low-
permeability layer. The cap functions by diverting infiltrating liquids
from the vegetative layer through the drainage layer away from under-
lying waste materials. Local soils will be used to construct the vege-
tative (topsoil) layer and the low-permeability clay layer. Gravel,
crushed stone, or a synthetic material will be utilized for. the drainage
layer. A synthetic liner will be placed above the clay to ensure the
cap'a'integrity.
The site will be compacted and graded to promote runoff from the finished
cap. The top 1 ft of soil will be loosely compacted to promote
revegetation. Native grasses will be seeded and mulched to prevent
erosion.
Closure—Closure will involve maintaining the existing land use restric-
tions to protect the capped area, and Installing ground water post-
closure monitor wells as required under RCRA. Post-closure monitoring of
the ground water is required for 30 years under RCRA.
Special Considerations—Drainage ditches or berms will be Installed up-
gradlent of the capped areas to divert stormwater around the areas.
Frequent inspection and maintenance will be required until vegetative
growth can provide adequate support against erosion.
1.3 EXCEEDS REQUIREMENTS ALTERNATIVES
1.3.1 Alternative 3A
Alternative 3A, Onsite Incineration, is identical to Alternative 2A
except that contaminated soil is removed to below detectable levels.
Uasher/Flaker foundations will be decontaminated if necessary by using
a hand-held flaming device and disposed of in an offsite. sanitary land-
fill. The total volume to be excavated and incinerated onsite is
approximately 69,900 cy, as described in Alternative 1B1. No permits
will be required for this onsite CERCLA response action as per the NCP.
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-47-
For the Industrial Sewerlines, this Alternative is identical to Alter-
native 2A, except: That soils beneath the sewerlines are removed to below
detectable contamination concentrations. .
Site Preparation—Site preparation will be the same as for Alternative
1B1. Additional trailers will be used for incineration, and the inciner-
ator.site must be fenced to limit- public access. For the Industrial Sewer-
lines site preparation Is the same as Alternative 2A.
Implementation—Implementation will be the same as for Alternative 2A,
except that the tine to implement will be much longer due to the increased
quantity of soil to be processed.
Closure—Closure will be the same as for Alternative 2A.
Special Considerations—Special consideration* will be the same as for
Alternative 2A.
1.3.2 Alternative 3B
Alternative 3B, Onsite Landfllllng, is the sane as Alternative 2B except
that contaminated soil is removed to below detectable levels.
Contaminated foundations will also be removed, decontaminated with a hand-
held flaming device if necessary, and disposed of in the onsite landfill.
The total volume to be excavated and landfilled onsite i« approximately
69,900 cy, as described in Alternative 1B1. No permits are required for
this onsite CERCLA response action as per the NCP.
Site Preparation—Site preparation for this alternative Is the same as
for Alternative 1B1, except an additional 3 to 5 acres will be cleared
for the landfill site.
Implementation—Implementation of this alternative will be the same as
for Alternative 2B, except that the time to Implement will be longer
because of increased material volumes to be landfilled. For the Industrial
Sewerlines Implementation is the same as Alternative 2A.
Closure—Closure will be the same as for Alternative 2B. For the Industrial
Sewerllnea, closure is the same as Alternative 2A.
Special Considerations—There are no special considerations for this
alternative description, in the TNT Manufacturing Area and the Burning
•Grounds. For the Industrial Sewerlines the same considerations as for
Alternative 2B.
1.3.3 Alternative 3C
Alternative 3C, involving the use of a multimedia cap, is the same as
Alternative 2C except that all areas with detectable nitroaromatics
concentrations will be capped. No permits will be required for this
onsite CERCLA response action as per the NCP. TNT residue will receive
jltv situ flaming prior to Installation of the cap in the Burning Grounds ' •'
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-48-
Area. Asbestos and rubble will be disposed of in an offsite sanitary landfill.
This alternative is not applicable to the Industrial Severlines because of
reactive vaste.
Site Preparation—Site preparation is similar to that described for Alternative
1B1. In addition, extensive backfilling and grading of eroded areas is required
to provide a flat surface for capping.
Implementation—The design considerations for the multimedia cap are the same
as those described for Alternative 2C. Rubble and asbestos will be removed
and TNT residue will be flamed prior to capping.
Closure—Closure requirements are similar to those described under Alternative
2C.
Special Considerations—There are no special considerations for this alternative
description.
1.4 CERCLA ALTERNATIVE
1.4.1 Alternative 4A
Alternative 4A involves soil cover which will be placed over all contaminated
areas exceeding 50 ug/g total nitroaromatics to isolate the contaminants fro*
direct contact. Contaminated foundations remain in place and are capped with
the soil. The estimated area to be capped is 4.0 acre. No permit* are required
for this onsite CERCLA response action as per the NCF.
*
For the Industrial Sewerlines Alternative 4A Involves excavation and flashing
of the sewerlines, followed by backfilling the trench with resulting nonreactive
burned materials. The products of burning will be placed over the contaminated
materials to prevent direct contact. The estimated quantity of sewerlines to
be burned is 680 cy. No permits will be required for this CERCLA response
action, as per the NCP.
Site Preparation—Site preparation is the same as that described under
Alternative 1A2, except for the references to the trailers and utilities
required for mobilization. In addition, extensive backfilling and grading of
eroded areas Is required to provide a flat surface for capping. For the
Industrial Sewerlines Site preparation is the same as that described for
Alternative 2A.
Implementation—Onsite soils will be used to construct a soil cover over
•contaminated areas. The thickness of the cover will be a minimum of 2 ft.
(l.S ft. of clay and 5 ft. of soil). Rubble and asbestos will be removed and
TNT residue will be flamed prior to capping. The site will be compacted and
graded to promote runoff from the finished cover. Native grasses will be
seeded and mulched to prevent erosion. For the Industrial Sewerlines the
excavation and loading operacions will be the same as those described for
Alternative 2A. Sewerlines will be burned by a remotely operated flamer, as
described in Alternative 2B. After burning, confirmatory sampling
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-49-
and analysis will ensure chat materials have been adequately treated
to be returned Co the trench.
Closure—Closure will involve maintaining existing wildlife station land
us»-r*9-erictions, post-closure inspection, maintaining the cover, and
groundwater monitoring. Fot ttie Industrial Sewerlinea closure of this
alternative is the same as that described for Alternative 2A.
Special Considerations—There are no special considerations for this
alternative description. Frequent inspection and maintenance of the
cover will be required.
1.5 NO ACTION ALTERNATIVE
1.5.1 Alternative 5A
Under Alternative 5A, no remedial actions will be implemented at the
TNT Manufacturing Area. This alternative will not Improve site
conditions nor will it mitigate the migration of site contaminants. This
alternative has been included to establish a present site condition
baseline. The baseline conditions are as stated in the WVOW RI report
and the WVOW EA.
Alternative 5A Includes a long-term monitoring program to provide
Information on the extent of contamination migration a* a function of
time. The monitoring program includes sampling and analysis of ground
water1, surface water, and seeps. Existing onslte monitor wells can
continue to be used to monitor any possible future migration of con-
tamination past the installation boundary toward potential human or
environmental receptors.
This alternative does not address the public health and environmental
considerations, but it does provide a means to identify future
problems; it can be implemented easily, and no capital costs and low
0AM costs are required.
ALTERNATIVE EVALUATION
Consistent with the National Contingency Plan (NCF) the alter-
natives were developed, screened, and evaluated in accordance with
sections 300.68(g) through (1) of the NCP. Three broad criteria
shall, as appropriate, be used in the Initial screening of alternatives:
Criteria Definition
Cost For each alternative, the cost
of implementing the remedial
action must be considered, in-
cluding operation and maintenance
costs.
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-50-
Acceptable Engineering Alternatives must be feasible
Practices for the location and conditions
of the release, applicable to'the
problem and represent a reliable
means of addressing the problem.
Effectivenesss Those alternatives that do not
effectively contribute to the
protection of public health and
velfare and the environment shall
not be considered further.
Consistent with the NCP the DA screened their alternatives using six
criteria: Cost, Public Health Concerns, Environmental Concerns, Technical
Concerns, Community Response Concerns, and Operation and Maintenance (0/N).
ANALYSIS OF REMEDIAL ALTERNATIVES
Note; Table S contains costs and a summary of non-monetary considerations
for all alternatives while Table 7 summarizes the scope of the alter-
natives in terms of cleanup level, volumes of waste and soil covers,
etc.
• The following alternatives were evaluated for each one of the three
areas of study, namely the TNT Manufacturing Area, the Burning Grounds
Area and the Industrial Sewerlines.
OPPSITE ALTERNATIVES
Alternative 1A2 - Offsite Incineration - Offaite Landfill
This alternative involves removal and offsite treatment of contaminated
soils in an offsite commercial incinerator. For cost purposes, the offsite
incinerator selected was Ensco Environmental Services located in Little
Rock, AR.
This alternative involves the removal and offsite treatment of approxi-
mately 6,710 and 3,625 cy of soil from the TNT Manufacturing Area and Burning
Grounds Area, respectively. The Industrial Sewerlines are not addressed
because no offsite facility was identified which would accept reactive
materials for incineration. The asbestos piles of the Burning Grounds Area
will be removed and disposed of in an offsite sanitary landfill. This
alternative reduces the cancer risk to less than the 10~& criteria for the
both areas mentioned above.
The useful life of this alternative is potentially infinite because
nitroaromatic contaminants are totally destroyed. This alternative requires
only periodic attention (maintenance of revegetated areas) upon implementa-
tion. • ••
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Alternatiye 1B1 - Offstte Landfill
This alternative involves the complete removal of contaminated soils.
in each area to detection limits «2 ppm using field methods). The
material wlrl be transported approximately 200 mi to an offsite commercial
landfill. The landfill selected for cost purposes vas Cecos, International,
located in Wllliamsburg, OH.
The volume of material to be removed varies considerably between
sites. At the TNT Manufacturing Area, the estimated amount of soil
to be excavated is 53,000 cy. Burning Grounds soils to be removed
are estimated to be approximately 17,000 cy. There is no 1B1 Alter-
native for the Industrial Sewerlines because no commercial landfill
was identified which would accept reactive or shock-sensitive materials.
ln_ situ flaming will be used to thermally destroy the TNT residue at
the Burning Grounds Area prior to soil excavation.
This alternative reduces cancer risk to less than 10~*6 level for the
areas mentioned above. The useful life of this alternative is indefinite
because contaminants are removed and no longer pose a threat to the
community.
Alternative 1B2 - Offsite Incineration - Offsite Landfill
• This alternative involves the excavation and offsite disposal to a
RCRA-llcensed landfill, similar to Alternative 1B1 except that the
removal objective is to meet relevant requirements (Instead of complete
removal). Therefore, the volume of material from the TNT Manufacturing
Area and Burning Grounds Area is approximately 10,300 cy. The asbestos
piles are disposed of in an offsite sanitary landfill. Performance,
reliability, safety and technical feasibility are the same as for
Alternative 1B1.
ALTERNATIVES ATTAIN REQUIREMENTS
Alternative 2A - Onslte Incineration
This alternative involves the removal and onsite treatment of the
contaminated soil in an onsite Incinerator. The ash from the incin-
erator, if determined nonhazardous according to EP toxlclty character-
istics for metals, will be used as backfill in the excavated areas.
Permits are not required for the operation of the incinerator. An esti-
mated 6,710 cy and 3,625 cy of soil will be Incinerated from the TNT Manu-
facturing Area and Burning Grounds Area, respectively. In addition,
an estimated 680 cy of contaminated sewerllnes will be incinerated, for
a total volume of approximately 11,000 cy from the three areas. As in
previous cases the asbestos piles will be disposed of in an offsite sani-
tary landfill.
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-52-
The level of treatment is to achieve applicable (10~6) criteria for
the site. Removal and subsequent destruction of organic contaminants
are permanent and irreversible, resulting in an infinite useful life for
this alternative. Monitoring of onsite incineration effectiveness will
be required*
Alternative 2B - Onsite Landfill
This alternative involves the removal of contaminated soil from the
TNT Manufacturing Area and Burning Grounds Area and placing it in an on-
site landfill constructed to meet RCRA standards. Permits will not be
required for the construction and operation of the landfill. Severlines
will be flashed using a remotely operated flaaer and subsequently placed
in the landfill with the contaminated sewerline pipe. An estimated 11,000
cy of soil and severlines must be landf11led to meet the objectives of
these alternatives. Asbestos and rubble will be disposed of in the onsite
landfill along with the soils.
The useful life of this technology is infinite because contaminants
are destroyed. Post-closure O&M of the landfill must occur perpetually
after closure to ensure its integrity. This method reduces cancer risk
to 10-6.
Alternative 2C - Multimedia Cap
This alternative involves applying a multimedia cap to all area*
of contaminated soil where the surficial soil concentration exceeds 50 ppm.
Using this criterion, an estimated 15,194 square yards (sq yd) (i.e.,
3.1 acres) of soil must be capped at the WOW site. Contaminated sever-
lines must be removed to meet attainable requirement objectives; therefore,
there is no 2C Alternative for the sewerlines. The TNT residue must be
_iii situ flashed prior to cap installation. Asbestos and rubble will be
disposed of in a offsite landfill. The multimedia cap, which is designed
to RCRA specifications, can last Indefinitely if properly maintained.
O&M requirements Include regradlng, revegetation, and maintenance of
cracks occurring in the cover from climatic stress or burrowing animals.
Post-closure maintenance of the cap must occur perpetually to ensure its
integrity. This method reduces cancer risk to 10~&.
ALTERNATIVES EXCEED REQUIREMENTS
Alterative 3A - On site Incineration
This alternative includes the removal of contaminated soil to
detectable levels and treatment in an onsite incinerator. Incinerator
ash, if determined to be nonhazardous through EP toxicity testing, will
be used as backfill. To meet the alternative objectives, an estimated
99,680 cy of soil and sewerlines must be removed and incinerated from
the three areas of concern. Thf> contaminated soils underlying the sewer-
lines will be removed to a depth necessary to achieve complete removal
of nitroaromatics contamination. Reduces cancer risk to less than 10-6.
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-53-
Alternative 3B - Onsite Landfill
Under this alternative, approximately 99,680 cy of contaminated -
soil will be excavated and disposed of in an onsite landfill constructed
to RCRA standards. The reactive sewerline materials must be flashed
before placement in the onsite landfill. Reduces cancer risk to 10~&.
The facility will require significant O&M perpetually after closure.
Performance, reliability, implementability and technical feasibility
are the same as the 2B Alternatives.
Alternative 3C - Multimedia Cap
This alternative Involves the placement of a multimedia cap over all
areas where the surficial soil exceeds nondetectable levels. Using
this criterion, an estimated 69,811 sq yd (I.e., 14.4 acres) oust be
capped in the TNT Manufacturing Area and Burning Grounds Area. The
Industrial Sewerlines are not addressed under the 3C Alternative.
Performance, reliability, implementability and technical feasibility
are the same as the 2C Alternatives.
CERCLA REQUIREMENTS
Alternative 4A Alternative
This alternative involves the in_ situ flaming of the reactive TNT
residue on the surface of the Burning Grounds Area followed by the in-
stallation of 2 ft. soil cover over areas with greater than 50 ppa total
nltroaromatics contamination. The sane criteria will be used to cap
areas in the TNT Manufacturing Area. A total of approximately 15,194 cy
of soil will be used for the caps. Asbestos and rubble will be disposed
of In an offsite landfill. Reactive sewerlines will be excavated, flashed,
and backfilled Into the trenches out of which they came. All contaminated
soil at the surface exceeding 50 ppm will be covered. This action will
involve approximately 680 cy of soil.
The useful life of this alternative is based largely on adequate
maintenance of the caps. This alternative eliminates exposure to con-
taminants and endangerment to public health.
NO-ACTION ALTERNATIVE
Alternative 5A - No Action
Under Alternative 5A, no remedial actions will be implemented
at the three areas of concern. However, a monitoring program will
be implemented to provide information on the extent of contamination
as a function of time. The monitoring program includes annual sampling
and analysis of ground water wells (12), seeps (3), and surface
waters (2) in the TNT Manufacturing Area; sampling and analysis of
ground water wells (6) and surface water stations (4) in the Burning
Grounds Area; and, monitoring of the ground water wells along the
Industrial Sewerlines (5).
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-54-
This alternative does not reduce or eliminate any of the impacts
resulting from site contaminants. The sampling of surface and ground
waters will be from existing sample stations and wells, so that'no
construction is necessary. Unacceptable exposure limits to nitroaro-
matica will exist.
r-
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Alternatives were examined in light of applicable or relevant and
appropriate Federal, State and local environmental program requirements
and in light of all CERCLA requirements.
The remedial actions proposed will be coordinated with the State
to ensure that the water and air quality will meet all applicable stan-
dards .
PREFERENCE FOR PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
The alternatives evaluated for the site included a range of alter-
natives from no action (Alternative 5A) to complete elimination of the
waste through on-slte incineration (Alternative 3A). In evaluating
these alternatives a preference was given to considering treatment alter-
natives which provided for a reduction in the toxlclty, mobility or vol-
ume of the waste. Beyond incineration an alternative technology which
reduces the toxlclty and volume of the nltroaromatlc wastes at the site
is flashing/ flaming of the wastes. While this process will not be done
to a level which permanently eliminates wastes at the site, it will re- ,/
duce levels of nitroaromatica below a 10~6 cancer risk level and is
therefore protective of public health. Furthermore, it is approximately
25 times more economical in present worth costs than complete reduction
through incineration. Therefore, it is our belief that the flashing/
flaming option followed by a soil cover provides a permanent solution to
the maximum extent practicable.
RECOMMENDED ALTERNATIVE
Section 300.68(J) of the National Contingency Plan (NCP) states
that the appropriate extent of remedy shall be determined by the lead
agency'a selection of a remedial alternative which the agency deter-
mines la cost-effective (i.e., the lowest cost alternative that is
technically feasible and reliable and which effectively mitigates and
minimizes damage to and provides adequate protection of public health,
welfare and the environment). In selecting a remedial alternative, EPA
must consider all environmental laws that are applicable. Based on the
evaluation of the cost effectiveness of each proposed alternative, the
analysis contained above and Che comments received from the public and
the West Virginia Department of Natural Resources (WVDNR) we recommend
the following remedial alternative for the three source areas: ' •
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Alternative 4A
1. In situ flaming of the reactive TNT residue on the surface erf the
Burning Grounds Area followed by the installation of a 2 ft. soil cover
(1.5 ft. clay and 5 ft. soil) over areas with greater than SO ppm total
nitroaromatlcs contamination.
2. Installation of a 2 ft. soil cover over areas in the TNT Manufactur-
ing Area with greater than 50 ppra total nitroaromatics contamination.
3. Asbestos from the Burning Grounds Area will be disposed of in an
offsite facility which will be identified during design. Transporta-
tion of this material will be in covered trucks using local roads.
4. Reactive sewerllnes will be excavated, flashed, and backfilled in
the trenches from which they were removed. All contaminated soil
exceeding 50 ppm at the surface will be covered to achieve the 10~6
risk level. The sewerline will be rendered unreactive by flashing
and buried deeper than 2 ft. below ground surface.
5. A health and safety plan will be implemented for all activities
described in the ROD. During excavation, flashing and construction
activities, air monitoring will be conducted to ensure the safety
of .the onsite workers as well as to protect the residents and wild*
life living nearby the construction areas.
6. A Wetland Assessment will be performed, before construction
activities, to establish the potential existance of wetlands In the
areas where remedial actions are to be taken. It is currently
anticipated that this assessment will be accomplished during a one
day walk through by an experienced biologist/wetlands ecologist.
OPERATION AND MAINTENANCE
Operation and maintenance (0/M) at the site under this first
operable unit will consist of periodic checks and repairs, as necessary
to maintain the soil cap and vegetative cover at each source area.
Post-closure groundwater monitoring consistent with RCRA require-
ments must also be conducted. A groundwater monitoring plan for
such will be developed during design.
The current deed restrictions established when the property was
transferred from the DA to the State mitigate against the private use
of the McClintic Wildlife Station for development and consequently the
State of West Virginia has the incentive and authority to maintain the
land in this use. While not critical to the success of the selected
remedy, strengthening the deed restrictions should be considered in the
future to assure that any subsequent agreement between DA and the State
will not alter the current restraints scenario. The DA itself or by • .. .
agreement with the State of West Virginia will ensure that 0/M at the site
will be accomplished.
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EVALUATION OF ALTERNATIVES NOT SELECTED
A summary of the detailed technical, environmental, institutional,
public health, and cost evaluations is presented for each area of con-
cern in Table 5.
Selection of a remedial alternative is specified in Sec. 300.68(1)
(1) of the NCP, which states:
Except as provided in Sec. 300.68(i)(5), this will require
selection of a remedy that attains or exceeds applicable
or relevant and appropriate Federal public health and en-
vironmental requirements that have been Identified for the
specific site.
Federal and State public health and evironmental requirements are
identified in Table 6. All of the alternatives, except the No
Action SA Alternative, meet or exceed these requirements.
All alternatives for each of three areas, except the No Action
5A Alternative, meet or exceed the remedial action criteria and ob-
jectives established by the Endangerment Assessment. These criteria
and objectives are to:
1. Remove or render unreactive all reactive wastes, and
2. Remove or cover the upper 2 ft. of soil if total
nltroaromatlc contamination exceeds SO ppm to achieve
less than 10~6 individual lifetime cancer risk.
Environmental and public health impacts of nltroaromatic con-
tamination are eliminated or minimized to acceptable levels by
implementation of these alternatives. An onslte landfill or multi-
media cap will require long-term monitoring and maintenance. The
general impetus for installing a landfill or multimedia cap, designed
to meet RCRA standards, is to prevent ground water contamination.
As noted on pages 27 and 28, ground water beneath the source areas
at WVOW are either not a problem (TNT Manufacturing Area) or are
unaffected (Burning Grounds Area). This standard, therefore, does
not provide the basis to justify the extra expense required to
implement these alternatives. None of the alternatives, except
No Action 5A Alternative, will have a significant adverse effect
on the continued use of the site as a wildlife preserve. Additional
land use restrictions will probably be required for the areas con-
taining an onslte landfill or multlmediacapped contaminated soil to
protect the integrity of these structures. Existing wildlife station
land use restrictions are adequate to protect the integrity of the
4A alternative soil cover - no additional restrictions are required.
These restrictions will not affect the operation of McCllntlc Wildlife
Station, as the affected areas represent less than 0.3 percent of the
station's land.
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Table 5 Source Control Alternatives Summary for the TNT Manufacturing Area
Alternative
IBl-Offelte
Landfill
1A2-1B2-
Offsite
Inclneratlon-
Offslte
Landfill
2A-Onslte
Incineration
2B-Onslte
Landfill
1
Cost ($1,000)
Present Public Health
Capital Worth Concerns
16,300 16,300 Eliminates exposure
pathways. Reduces
cancer risk to less
than 10*6.
21,957 21,957 Minimizes exposure
2,509 2,509 pathways. Reduces
cancer risk to 10"6.
4,206 4,206 Minimizes exposure
pathways. Contami-
nation destroyed.
Reduces cancer risk
to 10-6.
1,054 1,111 Minimizes exposure
pathways. Contaml-
Environmental
Concerns
Environmental im-
pacts eliminated.
Environmental im-
pacts minimized.
Acceptable levels
remain.
Environmental im-
pacts minimized.
Acceptable levels
remain.
Environmental im-
pacts minimized.
Technical
Concerns
Proven tech-
nology. Future
regulatory
constraints.
Proven tech-
nology. Future
regulatory
constraints.
Proven tech-
nology. Not
limited by
site condi-
tions.
Long-term main-
tenance re-
Community
Response
Concerns
Increased
traffic
Acceptable.
Increased
traffic.
Acceptable.
Moderately
acceptable.
Moderately
Acceptable.
Other
Removal of
waste to RCRA-
permitted fa-
cility. Long
term monitoring
not required.
Removal of
waste to RCRA-
permltted fa-
cility. Long
term monitoring
not required.
Monitoring of
onsite inciner-
ation effective
ness required.
Long-terra moni-
toring and potei
2C-Multlmedla
Cap
1,159 1,178
nation not destroyed.
Reduces cancer risk
to 10-6.
Minimizes exposure
pathways.
Contamination not
destroyed. Reduces
cancer risk to 10~6.
Permanent onsite
facility.
Environmental im-
pacts minimized.
Permanent onsite
facility.
quired.
Long-term main- Acceptable.
tenance re-
quired.
tial leachate
management re-
quired.
Long-term moni-
toring required.
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Tahle 5 Source Control Alternatives Summary for the TNT Manufacturing Area
(Continued)
AJ ternative
3A-Onslte
Incineration
3B-Onslte
Landfill
Cost ($1,000)
Present Public Health
Capital Worth Concerns
26,283 26,283 Eliminates exposure
pathways. Contami-
nation destroyed.
Reduces cancer risk
to less than 10~*.
5,588 5,880 Eliminates exposure
pathways. Contaml-
Erivironmental
Concerns
Environmental im-
pacts eliminated.
Environmental Im-
pacts minimized.
Technical
Concerns
Proven tech-
nology. Not
limited by site
conditions.
Long-term main-
tenance re-
Community
Response
Concerns
Moderately
acceptable.
Moderately
acceptable.
Other
Long-term moni-
toring not re-
quired.
Long-term monl
toring and po-
3C-Multlmedla
Cap
AA-Soil Cover
4,783 '4,868
623
5A-No Action
nation not destroyed.
Reduce cancer risk
to less than 10~6.
Minimizes exposure
pathways. Contami-
nation not destroyed.
Reduces cancer risk
to less than 10~6.
642 Minimizes exposure
pathways. Contami-
nation not destroyed.
Reduces cancer risk
to 10-6.
0 Unacceptable ex-
posure to nitro-
aromatlcs.
Permanent onslte
facility.
Environmental im-
pacts minimized.
Permanent onslte
facility.
Environmental im-
pacts minimized.
Permanent onslte
facility.
Exposure pathways
remain. Use of
wildlife preserve
adversely affected*
quired.
Long-term main- Acceptable.
tenance re-
quired.
Long-term main-
tenance re-
quired.
Acceptable.
tentlal leachate
management re-
quired.
Long-term moni-
toring required.
Lowest cost al-
ternative. Meets
CERCLA goals.
Long-term moni-
toring required
Unacceptable.
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Table 5 Source Control Alternalves Summary for the Burning Grounds Area
(Continued)
Alternative
IBl-Offslte
Landfill
1A2-1B2-
Offslte
Incineration-
Cost ($1
Capital
5,575
10,720
1,268
,000)
Present
Worth
5,575
10,720
1,268
Public Health
Concerns
Eliminates exposure
pathways. Reduces
cancer risk to less
than lO"6.
Minimizes exposure
pathways. Reduces
cancer risk to 10~&.
Environmental
Concerns
Environmental im-
pacts eliminated.
Environmental Im-
pacts minimized.
Acceptable levels
Technical
Concerns
Proven tech-
nology. Future
regulatory con-
straints.
Proven tech-
nology. Future
regulatory con-
Community
Response
Concerns
Increased
traffic.
Acceptable.
Increased
traffic.
Acceptable.
Other
Removal of
waste to
RCRA-permit-
ted facility.
Long-term
monitoring
not required.
Removal of
waste to
RCRA-permit-
Offsite
Landfill
remain.
atraints.
ted facility.
Long term
monitoring
not required.
2A-Onsite
Incineration
2,380 2,380
2R-Onsite
Landfill
621
659
2C-Multimedla
Cap
603
612
Minimizes exposure
pathways. Contami-
nation destroyed.
Reduces cancer risk
to 10~6.
Minimizes exposure
pathways. Contami-
nation not destroyed^
Reduces cancer risk
to 10~6.
Minimizes exposure
pathways. Contami-
nation not destroyed^
Reduces cancer risk
to 10~6.
Environmental im-
pacts minimized.
Acceptable levels
remain.
Environmental im-
pacts minimized.
Permanent onslte
facility.
Environmental im-
pacts minimized.
Permanent onslte
faclllf
Proven tech-
nology. Not
limited by site
conditions.
Long-term main-
tenance re-
quired.
Long-term main-
tenance re-
quired.
Moderately
acceptable.
Moderately
acceptable.
'Acceptable.
Monitoring of
onslte inciner-
ation effective-
ness required.
Long-term moni-
toring and po-
tential leachate
management re-
quired.
Long-term'moni-
toring required.
-------
-60-
Table 5 Source Control Alternatives Summary for the Burning Grounds Area
(Continued)
Alternative
3A-Onslte
Incineration
t
Cost ($1,000)
. : Present Public Health
Capital Worth Concerns
8,453 8,453 Eliminates exposure
pathways. Contami-
nation destroyed.
Reduces cancer risk
to less than 10~6.
Environmental
Concerns
Environmental im-
pacts eliminated.
Technical
Concerns
Proven tech-
nology. Not
limited by site
conditions.
Community
Response
Concerns
Moderately
acceptable. •
Other
Remedial action
effectiveness
monitoring re-
quired.
3B-Onslte
Landfill
1,909 2,013
3C-Multlmedla
Cap
4A-Soll Cover
1,631 1,669
333
5A-No Action
Eliminates exposure
pathways. Contami-
nation not destroyed.
Reduces cancer risk
to less than 10~°.
Minimizes exposure
pathways. Contami-
nation not destroyed.
Reduces cancer risk
to less than 10~6.
342 Minimizes exposure
pathways. Contami-
nation not destroyed•
Reduces cancer risk
to 10-6.
0 Unacceptable ex-
posure to nitro-
aromatics.
Environmental im-
pacts minimized.
Permanent onsite
facility.
Environmental im-
pacts minimized.
Permanent onsite
facility.
Environmental im-
pacts minimized.
Permanent onsite
facility.
Exposure pathways
remain. Use of
wildlife station
adversely affected.
Long-term main-
tenance re-
quired.
Moderately
acceptable.
Long-term main- Acceptable.
tenance re-
quired.
Long-term main- Acceptable.
tenance re-
quired.
Long-term moni-
toring and po-
tential leachate
management re-
quired.
Long-term moni-
toring required.
Lowest cost al-
ternative. Meets
CERCLA goals.
Long-term moni-
toring require.
Unacceptable.
-------
-61-
Table 5 Source Control Alternatives Summary for the Industrial Sewerlines
(Continued)
Alternative
2A-Onelte
Incineration
2B-Onslte
Landfill
3A-Onsite
Incineration
38-Onalte
Landfill
4A-Burn
Backfill
Cost ($1,000)
Present Public Health
Capital Worth Concerns
1,306 1,306 Hlninizes exposure
pathways. Contami-
nation destroyed •
Reduces cancer risk
to 10-6.
949 968 Minimizes exposure
pathways. Contami-
nation not destroyed.
Reduces cancer risk
to lO-6.
1A.300 14,300 Eliminates exposure
pathways. Contami-
nation destroyed.
Reduces cancer risk
to less than 10~6.
3,518 3,680 Minimizes exposure
pathways. Contami-
nation not destroyed.
Reduces cancer risk
to 10-6.
851 851 Minimizes exposure
pathways. Contami-
Environmental
Concerns
Environmental im-
pacts minimized.
Acceptable levels
remain.
Environmental im-
pacts minimized.
Acceptable levels
remain.
Environmental im-
pacts eliminated.
Environmental Im-
pacts minimized.
Permanent onsite
facility.
Environmental im-
pacts minimized.
Technical
Concerns
Proven tech-
nology. Not
limited by site
conditions.
Long-term main-
tenance re-
quired.
Proven tech-
nology. Not
limited by site
conditions.
Long-term main-
tenance re-
quired.
Proven tech-
nology
Community
Response
Concerns
Moderately
acceptable.
Moderately
acceptable..
Moderately
acceptable.
Moderately
acceptable.
Moderately
acceptable.
Other
Monitoring of
onsite inciner-
ation effective-
ness required.
Long-term moni-
toring and po-
tential leachate
management re-
quired.
Remedial action
effectiveness
monitoring re-
quired.
Long-term moni-
toring and po-
tential leachate
management re-
quired.
Lowest cost al-
ternative. Meeti
5A-No Action
0
w +
nation not destroyed
Reduces cancer risk
to 10-6.
19 Unacceptable ex-
posure to nitro-
aromatlcs.
Permanent onsite
facility.
Exposure pathways
remain. Use of
wildlife station
adversely affected.
CERCLA goals.
Long-term moni-
toring required
Unacceptable.
-------
-62-
Table 6. Summary of Applicable and Relevant or Appropriate Laws,
Regulations, Policies, and Criteria
Law, Regulation,
Policy, or Criterion
Analysis
Federal
RCRA
National Ambient
Air Quality
Standards (NAAQS)
DOT Hazardous
Material* Transport
Rules
Federal Water
Quality Criteria
(FWQC)
National Environ-
mental Policy Act
(NEPA)
Treatment and disposal of materials removed
from HVOV to an offsite facility will be in
compliance with current RCRA regulation*
issued In the HSWA of 1984. Onslte treat-
ment and disposal operations will be in
accordance with the substantive technical
requirements of RCRA.
Implementation of alternatives that include
onslte incineration will result In the
emission of pollutants into the air. The
use of air pollution control equipment will
minimize the effect of incinerator emissions
on existing air quality. Incinerator
performance standards will be attained* but
permits will not be required. Because the
emissions from surface flashing are largely
uncontrollable, air quality standards may
not be met during flashing operations.
Particulate emissions dprlng excavation will
occur, although dust palliatives will be
used to minimize fugitive dust. Onslte
personnel, however, will be adequately
protected.
The transport of hazardous materials to off-
site facilities will be in compliance with
these rules, including use of properly
constructed and marked transport vehicles, a
licensed transporter, and hazardous waste
manifests.
During the implementation of alternatives,
the substantive requirements and standards
of FWQC in creeks that drain the site and
other downgradient surface water will be
attained.
The RL/PS process designed by EPA regulations
and guidance and as conducted at this site is
functionally equivalent to the requirements of
NEPA.
-------
-63-
Table 6. Summary of Applicable and Relevant or Appropriate Lavs,
Regulations, Policies, and Criteria
(Continued, Page 2 of 2)
Law, Regulation,
Policy, or Criterion
Analysis
Asbestos Disposal
Rule (40 CFR,
Part 61, Subparc M)
State of Vest
Virginia Water
Quality Standards
(WVWQS)
West -Virginia Solid
Waste Regulations
West Virginia
Hazardous Waste
Regulations
West Virginia Air
Pollution Control
Commission (WVAPCC)
Administrative
Regulations
-West Virginia
Pollution Discharge
Elimination System
(WVPDES)
Regulations
Clean Water
Act - Section
404 (Wetlands)
Since asbestos is present in the Burning
Grounds Area, alternatives for asbestos
disposal will meet or exceed this rule.
Offsite .alternatives will be in full
compliance; onsite alternatives will meet
technical requirements.
In implementing alternatives, WVWQS in
creeks that drain the site and other down-
gradient surface water will be considered.
The substantive requirements will be
complied with and the standards attained.
Implementation of alternatives will meet the
West Virginia regulations for noncontam-
inated materials taken to offsite sanitary
landfills.
Implementation of alternatives will meet
the requirements of current regulations,
Including manifest requirements.
The substantive technical requirements of
these regulations will be met, and the
standards and criteria of New Source
Performance Standards (NSPS) will be met.
The requirements of the open burning regu-
lations will also be met.
The substantive technical requirements of
these regulations will be complied with, and
the standards and criteria for point source
discharges will be met in implementation of
the alternative.
During the initial stages of design a wetlands
assessment will be conducted to establish the
existence of wetlands and define potential im-
pacts. If impacts are foreseen mitigatlve
measures can be factored into the remedial de-
sign to protect the wetland ecology.
-------
-64-
Alternative 4A, the soil cover, is Che least costly alternative
(achieving response objectives) at a present-worth cost of $642.;000-
for the TNT Manufacturing Area and $342,000 for the Burning Grounds
Area. This alternative achieves the response objectives of protecting
against direct contact and minimizing exposure pathways. The cancer
risk is reduced to the 10~6 risk level. Alternative 1B1, 3A and
3B could reduce this potential to below the 10~6 risk level, but at
costs between 5 and 25 times greater. The exposure pathways could be
entirely eliminated, assuming that all contamination is removed,
through implementation of their alternative; however, since direct
human contact Is the only endangerment pathway, the soil cover
(Alternative 4A) adequately provides this protection.
In all cases, the technologies involved in the alternatives are
technically acceptable and proven, and no alternative offers a signif-
icant technical advantage to achieve response objectives or an advantage
based on specific site condition at WVOW. Alternative 4A does require
long-term care to maintain the integrity of the cover. Periodic ground-
water monitoring will also be required after implementation.
The least costly alternative for the Industrial Sewerlines is
Alternative 4A, which consist of burning the sewerllnes and then back-
filling the area. This alternative meets the objectives of eliminating
the reactivity of the sewerlines and protecting human receptors from the
exposure. Alternative 2A costs $1,306,000, an increase just less than
twice that of Alternative 4A. Both alternatives are comparable in all
other areas evaluated.
The implementation, however, of an onslte Incinerator for a small
volume area is not as practical or viable an alternative as for
larger sites. In addition, a sensitivity analysis discussion has
demonstrated the extreme variation of cost of this alternative with
slight changes in quantity. Therefore, any increase in estimated
volume of contaminated sewerlines would significantly increase coat.
For the flashing/onslte landfill alternative, it would cost approxi-
mately 4 times more to exceed the standard. For onsite incineration
alternative, exceeding standards could cost 10 times more. Because
of the significant differential in cost and lack of adequate quanti-
fication of the extent of soil contamination below the sewerlines,
exceeding standards in these alternatives is difficult to justify.
-------
-65-
Table 7 Alternatives - TNT Manufacturing Area
Disposal/
•Excavated Treatment Treatment Disposal Capped Backfill Post- Years
Alternative
Off site 1A2
Offslte 1B1
Offslte 1B2
Attains
Require-
ments 2A
Attains
Require-
ments 2B
Attains
Require-
ments 2C
Exceeds
Require-
ments 3A
Exceeds
Require-
ments 3B
Exceeds
••• Require-
ments 3C
Cleanup
Level
10-6
-------
-66-
Table 7 Alternatives-Burning Grounds Area
(Continued)
Disposal/
Excavated Treatment Treatment Disposal Capped Backfill Post- Years
Alternative
Offsite 1A2
Offsite 1B1
Offsite 1B2
Attains
Require-
ments 2A
Attains
Requlre-
aen.t e 2B
Attains
Require-
ments 2C
Exceeds
Require-
ments 3A
Exceeds
Require-
ments 3B
Exceeds
Require-
ments 3C
Cleanup
Uvel
10-6
-------
-67-
Table 7 Alternatives-Burning Grounds Area
(Continued)
Disposal/ .
Excavated Treataertt Treatment Diapoaal Capped Backfill Post- Years
Cleanup Volume Volume Level . . . .. Volume, Area Volume Closure Mobil-
Alternative Level (cy)* Hethod (cy) (percent) Site (cy) (sq yd) Source (100) Honl- ized
toring
CERCLA 4A 10~& 0 Soil Cap 0 — Onsite 0 5.13A Onslte 0—1
No Action 5A - — No Action — — — — — — •*- GW/SW
— - Not Applicable.
GW - Ground Water.
SW - Surface Water.
*A11 volumes Include a swell factor of 25 percent.
-------
-68-
Table 7 Alternatives-Industrial Sewerlines
(Continued)
Cleanup
Alternative Level
Excavated
Volume
(cy)* Method
Disposal/
Treatment Treatment Disposal Capped Backfill Post- Years
Volume Level Volume Area Volume Closure Mobil -
(cy) (percent) Site (cy) (aq yd) Source (cy) Moni- tzed
torlng
Attains 10-6 20,400
Require-
ments 2A
Attains 10-6 20,400
Require-
ments 2B
Exceeds detection 47,680
Require-
ments 3A
Exceeds detection 47.680
Require-
ments 3B
CERCLA 4A 10~6 20,400
No Action 5A
Incinerate 680 95 Onalte 680 0 Onslte 500
Flaming/
Onsite
Landfill
680 — Onalte
680 0 Onslte 500 GW
Incinerate 29,680 99.99 Onsite 29,680 0 Onslte 8,000
Flaming/
Onalte
Landfill
Flaming/
Backfill
No Action
29,680
680
Onalte 29,680 0 Onsite 9,400 CW 3
Onslte
680 0 Onslte 500
GW
— - Not applicable.
GW « Ground Water'.
*A11 Volumes include a swell factor of 25 percent.
-------
RESPONSIVENESS SIBWARY
WEST VIRGINIA OFNANCE WORKS
1. OVERVIEW
— >•
To expedite cleanup activities, the West Virginia Ordnance Works Remedial
Investigation/Feasibility Study (RI/FS) has been divided into two operable units.
The first operable unit consists of the TNT Manufacturing Area, Burning Grounds
and Industrial Sewer lines. The remedial alternative reconnended by the Army for
the first operable unit based on results of detailed Feasibility Study analyses
includes! (1) flaming the reactive TNT pieces in place on the surface of the
Burning Grounds Area; (2) providing a soil cover over contaminated soils at the
TNT Manufacturing Area and Burning Grounds Area} (3) excavating industrial
sewer lines, flashing the industrial sewerlines to destroy the contamination, and
replacing the flashed nv**wH«i ^ the excavated trench; and (4) transporting
flffhoftfo^g to an offsite ^ 0*^*1 sanitary landfill for disposal.
This alternative will achieve the remedial response objectives upon
implementation. The alternative is nxumieuted to: (1) meet all criteria and
requirements established in the Endangeraent Assessment; (2) prevent significant
adverse impacts to the environment caused by prolonged onsite incineration; and
(3) provide viable, cost effective remediation in accordance with the National
plan*
Based on the connents received at the November 13, 1986 ccomunity meeting and
the fact that no written Garments were received during the public euiiuenL period,
there seems to be no objection to the leocmiended alternative as described above.
2. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Ccranunity interest in the former West Virginia Ordnance Works dates back to
i
1984, when the Army completed a Records Search into past operations of the former
•o
-------
WVOW now the the McClintic Wildlife Station. Concerns with groundwater quality
exist because there are residents living near the industrial area of the former
ordnance works. However, groundwater in the TOT Manufacturing Area does not flow
towards the residential wells and sampling of all area residential wells indicated
that drinking water criteria have not been exceeded.
Congressman Wise's office has requested and received periodic updates from the
Army on the environmental work being conducted at the site.
3. ^UMMARY OF PUBLIC CCM4EHTS RECEIVED DURING PUBLIC HOSTING
a. Wells
1. Concerns were expressed on drilling new wells into a contaminated area
and would a ban be placed on drilling new wells?
Ann/ Response: The first operable unit is located on McClintic Wildlife
Station. Groundwater use is already restricted on McClintic. McClintic can only
be used for its current use as a wildlife station or the land reverts back to the,
Federal government. Its use cannot change, it's in the deed.
2. What if Congress changes the law so McClintic could be used for other
purposes and the ban was lifted, from a scientific viewpoint, would you recommend
a ban so there would be no drilling into the main aquifer?
EPA/Army Response: The study would have to be redone; you've changed the
land use. Criteria and objectives developed were based on current land use of
McClintic. If land use changes, then the potential alternatives change based on
%
the study perfumed at that tine.
3. Is there anywhere in the U.S. where the method of covering and leaving
in place carcinogous materials is done where it is permissible to drill wells into
the aquifer?
Army Contractor Response: Yes. There is a Superfund site in Florida with'
!
various contaminants that have been left in place with an impermeable cap and
-------
there is a grounciwater barrier in the upper aquifer. There are nearby residential
veils and no ban on drilling. Monitoring wells have been installed and are being
monitored.
4. Are there any wells on MoClintic and have they been tested to assure
r-
no leaching has occurred and will these wells be capped?
Army Response: There are two wells on MoClintic. There is one well we
used as the drill water supply; the doghouse wall, and that has no contamination
in it. We used that well in the drilling process and we analyzed the water and
there's no contamination in it. As far as the first operable unit which we're
discussing tonight, groundwater in the TNT Manufacturing Area does not flow to the
residential walls and is not a problem. Groundwater is not contaminated in the
Burning Grounds Area. In regard to capping the walls, they are not in the areas
we're reporting on tonight. The groundwater does not flow in that direction.
b. Restoration/Cleanup
^^™—^^^™^^^*—^^^^"^^"^^"^^•^^^•|^™ .
1. Is the cleanup standard (10 ), site specific or is the same
standard applied at other sites? Would another site have higher concentration
values or exposure risks? Would cost guide the choice for cleanup?
EPA Response: When analyzing sites, wa try to ensure cleanup levels get
to that risk level (10 ). It is conceivable that in some instances there will
be certain characteristics of the site where we will not be able to achieve that
standard because it is technically impracticable or the cost is so prohibitive
that it's not applicable.
Army Response: We're developing criteria for the second operable unit
taking into account differences between land use on and off MoClintic. How you
cone into contact with contaminants is very site specific. We are doing
endangeznent assessments with the same goal, 10 ., for the other areas of the
i
site. It's conceivable a different concentration of nitroaromatics could be
developed.
-------
Concentration-differences would be dependent upon the land use, the contaminant
transport pathways and the potential receptors.
2. If the Army uses capping for the first operable unit, will the Army
use the sane technology for the second operable unit?
Army Response: The second operable unit concerns include surface waters
and groundwater, so there might be different action levels associated with these
areas. There axe different pathways in the second operable unit. In the first
operable unit we are concerned about ingestion of game animals and contact with
the skin.
3. What does the Array plan to do :about the groundwater?
Army Response: That study will be convicted in six months. Tonight we're
talking about the source areas.
4. What tlmft schedule will the work be peifbuued under?
Army Response: From the »ir^» a Record of Decision is signed, we're
expecting that in January, probably three months to get a contractor on board, and
we oonld start field work sometime in the summer. The actions will take about one
year to complete.
5. Where will the dirt come from?
Army Response: We think there is suitable soil available on Mcdintic.
The areas to be capped are a total of approximately three acres.
c. Contaminants/Contamination
»
1. What types of cancer are caused by TNT and its by-products?
Army Response: I don't know. The 10 is one additional occurence of
cancer of any type in one million people with a lifetime exposure.
2. Are TNT and its by-products bicdegradeable?
Army Response: Yes. It is a slow process though.
-------
3. Have pollutants reached residential veils?
Array Response: We have sampled residential wells off JteClintic and have
not found contamination in them.
4. Are there contaminants in the groundwater at the Red Water Reservoir?
At the TOT Area?
Any Response: Yes, there is contamination in the shallow aquifer. We
don't believe the deep aquifer is contaminated.
d. Costs
^ •^•M^MW
1. What are the costs of the studies?
Army Response: We've spent for the RX/FS apprcodjnately $1.7 million.
2. Can you break the $1.7 "-nUTi into portions for each operable unit?
Army Response: Not right off-hand.
3. Will you spend another $1.7 million on the second operable unit?
Army Response: The second operable unit is included in the $1.7 million.
4. REMAINING PUBLIC CONCERNS
The Feasibility Study on the second operable unit will be complete six months
following the FS on the first operable unit. Citizens are concerned about their
groundwater and what could happen in the six months. Also, a question was asked
about flooding that had occured in late winter, early spring 1985 in the Yellow
Water Reservoir Area. This same question had been asked by Point Pleasant Mayor
Wedge after the Commit^ meeting February 28, 1986. Attached is the response
^k
sent to the Mayor, March 18, 1986.
-------
ATTACHMENT A
Cconunity Relations Activities Conducted for the Fomer WVDW
Community relations conducted for the Former WVCW to date include the following:
'- Public Meeting held to discuss upcoming environmental survey (August
1984) . News release issued on the survey.
- Fact Sheet prepared and distributed on RI report (February 1986) .
- News Release on public meeting and RI issued (February 1986) .
f Public Meeting held to discuss RI (February 1986) .
Investigation Report placed in public repository at Point Pleasant
for public review (April 1986) .
- Community Relations Plan under development (October 1986) .
- Public Repository set up in Charleston, W (October 1986) .
- RI/FS and Bndangennent Assessment (E3V) sent to public repository in
Charleston; FS and EA to Point Pleasant public repository (October 1986) .
- Public Comment period (November 3-24, 1986) .
- Fact Sheet on first operable unit prepared and distributed (November 1986) ,
- Public Meeting to discuss FS at first operable unit (November 1986) .
-------
STATE Of WEST VIRGINIA
DEPARTMENT OF NATURAL RESOURCES .
CHARLESTON 25308
ARCH A, MOORE. JR. RONALD R. POTESTA
Gowmor Director
March 17, 1987 ROBERT K. PARSON*
O^uty OlfWttr
Mr. Hector Abreu (3HW12)
U. S. Environmental Protection Agency
Region III ,
841 Chestnut Building
Philadelphia, Pennsylvania 19107
*
RE: West Virginia Ordnance
Works, Mason County, WV
Dear Mr. Abreu:
The Enforcement Decision Document for the above referenced site
has been reviewed by members of my staff. It is their recommendation
that the selected remedy is the preferred option.
Sincerely,
Ronald R. Potesta
Director
RRP/phl/kr
-------
Mr. Turkeltaub/pd/3921
liarca Id, 1986
Kcstoration Division-
fir. Jinny Joe Wedge
i lay or
City oil PolnC Pleasant
WcsCt. Virginia 25550
Dear ilr. WeUge:
Uc have received Che unclosed response iron our contractor
regarding che drainage problcn you inforned us ot at the
rtbruary 28, 1980, coaounity meeting. I hope the information is
uulpi'uL to you.
As indicated in his Icccer, Mr. Kraus would be available to
discus* this caccer further should you desire a neeting. . If you
require additional information, please do not hesitate to contact
cu at (jUl) 671-3618 or ur. Robert Turkeltaub at (301) 671-3921.
Sincerely,
Andrew U. Anderson
Chief
installation Restoration Division
enclosure
-------
ENVIRONMENTAL SCIENCE
AND BNO,~««.~0. INO. „,„„,.„„
ESE Ho. 84-604-0700
Conaander
U.S. Army Toxic and Hazardous
Materials Agency
ATTH: AMXTH-IR (Mr. R.B. Turkeltaub)
Bldg. E4435
Aberdeen Proving Ground, MD 21010-5401
RE: Contract DAAK11-83-D-0007, Delivery Order 0005
Vest Virginia Ordnance Work* (WOW) Environmental Survey
Flooding Condition* of February-June 1985 in the Vicinity of the
t Yellow Water Reservoir
Dear Mr. Turkeltaub:
This is in response to the public inquiry received during the
February 27, 1986, Public Meeting for the above-referenced site at
Pt. Pleasant, Vest Virginia. The inquiry involved the flooding which
occurred in the vicinity of the former Yellow Water Reservoir during
February through June 1985.
/oilowing a wet fall, the winter of 1984-1985 was quite severe, with
extreme low temperatures occurring through most of -January 1985. At the
end of January when ESE concluded the ground water sampling program,
approximately 12 inches of snow remained on the ground. The subfreesing
temperatures resulted in substantial ground frecce. During spring thaw,
frozen (and saturated) soil will produce higher-than-normal surface
runoff and very little, if any, infiltration. This preceding combination
of meteorological conditions will frequently produce flooding or ponding
conditions in low areas exhibiting poor drainage characteristics.
Based on ESE's field program in the Yellow Water Reservoir area, poor
drainage conditions have been observed. During the Archives Search of
March 1984 and the Pre-Plan of Study site visit of May 1984, sedges were
observed growing in the area. Sedges are a type of wetland plant which
typically grows in areas of poor drainage subject to periodic flooding.
I have attached Figure 2.3-6 and Table 2.3-3 of the WVOW Remedial
Investigation Report,** map and accompanying data describing the various
soil type* present at WVOW. The soil type predominant in the Yellow
Water Reservoir is the Chilo Sandy Loam, designated ChA. The Chilo is
classified as poorly drained and is slowly permeable.
The nature of the soils in the area, coupled with the pattern of
precipitation and runoff which occurred during late winter through spring
1985, seems the likely cause of the flooding observed in the subject
area. The flooding appears to be in no way related to the ESE field
investigation. -
P.O. Box ESE Gainesville. Florida 33603 903/332-3318 TWX eiO-S2&631O
-------
Mr. R.B. Turkeltaub
March 8, 1986
Page Two
a A
site during the., ttai/I^iJ4-". 1986' X e
the partie. iavolved with this propert" opportunity to «eet with
Sincerely,
David L. Kraus
, Task Manager
DLX:ae
cc: L.J. Bilello
Project Piles
-------
2.3-3. SoU Type. Within
5i=e
As
OA
Du
GsA
Ha
Hu
la*
Ma
Me
Mg
Mo
Sc
S€
So
Uc
Un
V*
Vti
*See Fig.
— - Not
Sources:
Ashtoa Silt
Oiilo Sandy
Duncannon Silt
Ginat SLU
Hackers SLU
Huntingtoo Silt
Ukin Lo«y F«
Mtrkiani Silty Clay
Melvin Silty Clay
Silt
Moshannon Silt
HuskingurVpatwr Silt
Sciotoville Silt Lo»
Senecaville Silt Loan
Sloping Und
Upshur Clay Lo»
Upshur-MuskingM Clay
Vandalia CUy Lo»
Wheeling Fine Sand
Well Drained
Poorly Drained
Well Drained
Poorly Drained
Well Drained
Wall Drained
Excessively Drained
Moderately Poorly Drained
Poorly:Drained
Moderately Wall Drained
Well Drained
Moderately Wall Drained
Moderately Well Drained
Uell Drained
Well Drained
Well Drained
Moderate-aapid
Slow -.._. -
Moderate
Very Slow
Moderate
Moderate
Rapid
Slow-Very Slow
Moderate Slow-Very Slow
Slow
Moderate
Moderate
Moderaca-Slow
Moderate-Slow
Slow-Very Slow
Slow
Moderate-Slow
Moderate-Rapid
repotted.
USSCS, 1961.
ESE, 1985.
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OWAT SH.T LOAM
HACKIM SH.T LOAM
HUNTING-TON SILT LOAM
LAKNt LOAMV nNI SAMB
MAMKLANO SM.TV CLAY LOAM
MO.VIN SILTY CLAt LOAM
MONONOAMCLA SILT LOAM
MOSHANNON SILT LOAM
SCIOTOVHJJ SILT LOAM
SUMCAmLl M.T LOAM
SLOMNO LANO
UMHUN CLAY LOAM
U^SHUIMMISKINOUM CLAY LOAMS
VANOAUA CLAY LOAM
WMUUNO nNI SANO LOAM
NOTt HEFEB TO T^BLE 2.3-3 FOR FURTHER DETAILS ON SOILS.
0.3
1 MILES
0.5
0.5 1 KILOMETERS
SOURCES: USSCS. 1961.
ESE.1SSS.
Figure 2.3-6
SOILS MAP OF THE
WVOW SITE
.WEST VIRGINIA
ORDNANCE WORKS
Remedial Investigation
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