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

-------
                                                                                              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

-------
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.

-------
                             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,

-------
                                    -2-
 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.

-------
                                    -3-
     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)

-------
                                       -1-
                    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.

-------
                                    -2-
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.

-------
        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^

-------
                                                    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

-------
                                        -5-
 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

-------
                                       -6-
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

-------
                                   -7-
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.

-------
                                        -8-
 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

-------
                               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

-------
                                        -10-
 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

-------
                   SOUMCtS: USATMAMA. 1
                          W«r
500  ioooMcrms
      4t Page H
 •URFACE HYDROLOGY AT THE
AfVOW SITE (1985)
                                  WEST VIRGINIA
                                 ORDNANCE WORKS

-------
                                     -12-
 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

-------
                                  -13-
 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.

-------
                                     -35-
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.

-------
                                 -36-
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.

-------
                                  -37-
     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.

-------
                                 - 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.

-------
                                  - 39-
.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.

-------
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

-------
                                      -41-
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.

-------
                                       -42-
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.

-------
                                      -43-
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.

-------
                                      -44-
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.

-------
                                       -45-
 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.                                                • .• .

-------
                                     -46-
 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.

-------
                                    -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  '  •'

-------
                                       -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

-------
                                   -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.

-------
                                      -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.                                                                 •  ••

-------
                                       -51-


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.

-------
                                       -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.

-------
                                      -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).

-------
                                      -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:         '  •

-------
                                       -55-

 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.

-------
                                      -56-
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.

-------
                                                    -57-
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.

-------
                                                   -58-
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.

-------
                                                           -59-
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.


-------
                   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

-------