United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-88/040
March 1988
&EPA
Superfund
Record of Decision
LA. Clarke & Son, VA
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J0277-IO'
REPORT DOCUMENTATION 1 REPORT NO. „„,„,„ 2
PAGE EPA/ROD/R03-88/040
] 3. Recipient's Accession No
i
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
L.A. Clarke & Son, VA
First Remedial Action
7. Author(s)
! 8. Performing Organization Rept. No
9. Performing Organization Name and Address
!
_ i
I 10. Project/Task/Work Unit No.
11. Contracted or Grant(G) No.
I
'' (C)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
i 14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The 40-acre L.A. Clarke site is located in Spotsylvania County, Virginia. Wood
preserving operations began at L.A. Clarke & Son, Inc. in June 1937 and have continued
to date with only one inactive period, from April 1979 to June 1980. During the past 50
years, creosote contaminated soil and sediments resulted from facility operations
spills, waste streams entering the drainage ditches, and onsite disposal. Historical
aerial photography indicates that from at least 1953 through 1974 wastewater was
disposed into two concrete-lined pits. An area located north of the process facility
also received wastes. Overflow from the concrete pits was stored in an earthen pit.
Excess water was discharged to drainage ditches and sprayed on the ground around the
storage yard to control dust. Aerial photography identified four additional waste water
pits which date back to 1937. These four pits were filled in by 1979. In 1975, L.A.
Clarke & Son, Inc. was issued a National Pollution Discharge Elimination System (NPDES)
permit for outfalls from two onsite drainage ditches. These permits are still in
effect. Phenol is the only toxic contaminant regulated by the permit. In 1980, L.A.
Clarke & Son, Inc. was classified under RCRA as a treater of hazardous waste due to the
presence of a wastewater impoundment lagoon. As part of a State-mandated remedial
action in 1982, approximately 1,400 yd3 of soil was excavated from the processing area
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision .
L.A. Clarke & Son, VA
First Remedial Action
Contaminated Media: sediments, soil
creosote, PNAs
c. COSATI Field/Group
18. Availability Statement
. 19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
76
22. Price
(See ANSI-Z39.18)
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R03-88/040
L.A. Clarke & Son, VA
First Remedial Action
16.
ABSTRACT (continued)
to create a RCRA-regulated soil waste pile. The primary contaminants of concern
affecting both -the soil and sediments (total volume of 119,00 yd3) are constituents of
creosote including PNAs and ben::elJe.
The selected remedial action for this site includes: in-situ soil flushing of
subsurface soil underlying the process buildings followed by in-situ biodegradation in
the creosote layer area; biological degradation of bottom sediments in the lagoon;
onsite landfarming of excavated surface soil, sediments, and subsurface wetland soil;
excavation, dredging, and onsite consolidation of contaminated sediments, subsurface
wetland soil, buried pit materials, and surface soil not remediated via in-situ
flushing; erosion/sedimentation control; backfilling excavated areas with treated soil
and sediment; and ground water monitoring. The estimated capital cost for this remedial
action is $21,080,000 with present worth O&M of $33,900. Should be determined that
the onsite process building requires removal, landfarming/biodegraaation may be
implemented at an added capitalJst of $910,900.
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RECORD OF DFX:ISION
Site Name and Location
L.A. Clarke and Son, Inc. - Spotsylvania County, Virginia
StatE!tent of &sL. and Purpose
This decision document presents the selected remedial action for
the L.A. Clarke site developed in accordance with the Canprehensive
Envirorrnental Response, Canpensation and Liability Act of 1989,
as a a-nerx3ed by the Superfund Amerdnents and Reauthorization Act
of 1986, and to the extent practicable, the ~tional Contingency
Plan, 4~ CFR Part 399. This decision is based on the Administrative
Record for the L.A. Clarke site. 'n1e attached index identifies the
items which comprise the Administrative Record upon which the selec-
tion of the remedial action is based.
The Ccmnonwealth of virginia has concurred on the selected remedy.
Description of the Selected Remedy
The selected remedy addresses the principle threats at the site
by controll i rig contaminant sources. An estimated 118,999 cubic
yards of soil and sediment require remediation. Sources to be rene-
diated incllJde two Resource Conservation and Recovery Act regulated
uni ts which consti tute an estimated 2% of this vol line . Additional
remedial action addressing contaminant migration pathways (ground-
water and downgradient sediment) shall be determined in a Second
Operable unit Record of Decision.
The selected remedy inclOOes the following major elements:
o In situ soil flushing, utilizing a surfactant solution,
of subsurface soils (creosote layer) underlying the process buildings:
- Injection/teCOvery wells to direct washing solutions to
the conta'ftinated soils and then recover the contaminant-laden wash
solution.
- Design and use of a well systEltl to attain a self-contained
flushing scheme to prevent environmental Unpacts.
- A wastewater
washing solutions for
Disposal of treatment
characterization.
treatment system to remove contaminants fraa
recycling of solution back into the process.
residuals is dependent on post-treatment
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o In situ biodegradation in the creosote la~=r area (following
the in si tu flushing):
- Nutrient and oxygen-rich compounds shall be injected via
the well systan described above.
o on-site land facning of excavated surface soils, sedUDents, and
subsurface wetland soils. The main land facning operation will be
placed in northeast area of site. Same soils may be land fa~ ir~
place. The !eRA regulated soil pile and Westvaco Pond sedUDent
shall be landtreated in place.
o Creosote contaminated bot tan sediment in the ICRA regulated
lagoon shall be biologically degraded in a tank.
o Excavation/dredging and consolidation of contaminated sediments
(di tches l, 2, and 3, and wetlands), subsurface wetlands soils,
buried pit materials, and surface soils that are not ~iated via
in situ f1ushing/biodegradation and caMOt be land treated in place:
- Geotextile silt fences, sedimentation basins, and/or
diversion/ surface management to control off-site soil transport
and divert surface-water flows.
- Organic vapor monitoring.
- Dewatering of sediments, treatment of water (if required),
and on-site discharge of treated water.
o Erosion/sed~ntation control (as described for excavation) .
o Backf i 11 excavated areas wi th treated soil and sedUDent.
Cover backfilled areas with topsoil and revegetate.
o During and post treatment groundwater ttK>nitoring.
I
Should the on-site process building be removed, Alternative 4,
Landfaming/Biodegradation (as described in this dOC\Dent) would
be an equally preferable alternative and may therefore be UDple-
mented. '1be-camonwealth of Virginia concurs with this decision.
The EPA and the CaImohwealth of virginia are currently pursuing
measures to ensure that on-going wood treatment operations at the
L.A. Clarke site will not result in further contamination of soils
and sediments, and as a result, groundwater and surface water.
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Declaration
The selected remedy is protective of human health and the envirorment,
attains Federal and State requirements that are applicable or relevant
aoo appropriate to this remedial action, and is cost-effective.
This remedy satisfies the statuatory preference for remedies that
employ treatment which reduces toxicity, mobility, or volume as a
principal element. Finally, I have determined that this renedy
utilizes pecnanent solutions and alternative treatment to the maxim\Jl\
extent practicable.
J 1
Regional Adminlstrator
EPA Region III
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smt9.RY OF RE21IDIAL ALTERNATIVE SELECTION
SITE, LOCATION AND DESCRIPTION
~ne L. A. Clarke wood treating site is located in Spotsylvania
County, Virginia, approximately 2.5 miles south of Fredericksburg.
The site is about 43 acres in size and is situated at latitude
38014 '05"N and longitude 77025 '3S"E. The L.A. Clarke facility is
situated approxLmately one-quarter mile east'of Route 638 and north
of Massaponax Creek.
A regional location map (Figure 1-1) shows the general location of
the site. Figure 1-2 shows the location of the site on the USGS 7.5
minute quadrangle topographic map. Residential communities are
located 1000 feet northwest and east of the site. Figure 1-3 shows
the various structures and their relative locations on the site.
Major site structures include the processing facility where lumber
is treated, the soil waste pile and wastewater impoundment in the
west-central portion of the site and two major drainage ditches in
the western half of the site.
L.A. Clarke currently treats wood with a creosote/coal tar solution
in the pressure treatment facility at the site. Available data
indicates that only creosote has been used as a wood preservative
on-si te.
Surface runoff from the site flows into a series of drainage ditches
which discharge into a wetland south of the site. Groundwater at
the L.A. Clarke site flows in a southeasterly direction within two .
water-bearing zones separated by a low pecneabi1ity clay stratum.
The shallow aquifer flows beneath the operations area and surfaces
at the southern property boundary in the \lilletlands area. Ground\oiBter
from the site also enters the drainage ditches which outfall in .
the \lilletland. A deeper aquifer flows under the si te and the \lillet1ands.
Water fran the wetland. flows through several tributaries which flow
to Massaponu Creek, which discharges into Ruffins Pond approximately
2 miles dow8trema. Ruffins Pond is used for recreational swimning
and fishiag. W88tvaco Pond, not known to be used for fishing or
recreation, lies iDmediately to the west of the si te. Residential
wells are located wi thin 1339 feet of the si te and utilize ground-
water fran the shallow aquifer.
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D.C.
VIRGINIA
r-j
I
FIGURE 1-1 REGIONAL LOCATION OF THE L.A CLARKE SITE
SPOTSYLVAMA COUNTY. VIRGINIA
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FIGURE 1 -2 LA. CLARKE SITE LOCATION ON
GUINEA QUADRANGLE (USGS) MAP
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FIGURE M LA CLARKE SITE MAP
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SITE HISroRY
WOod preserving operations began at L. A. Clarke & Son, Inc. in
June 1937 and have continued to Gate with only one inactive period
(from April 1979 to June 1989). Until 1976, the property and facility
was owned by the Richmond, Potomac & Fredericksburg (R,F & P) Railroad
and leased to the operator of the facility, L.A. Clarke & SOn, Inc.
Creosote contaminated soils and sediments at the L. A. Clarke site
have resulted fram spills and leaks over the past 59 years from
facility operations, fram process waste streams entering the drainage
ditches, and fram waste disposal onsite in pits.
In the early 1979s, wastewater treatment consisted of draining process
wastewaters into two concrete-lined pits. Historical aerial phot~
graphy indicates that these pits were present at least fram 1953
through 1974, and are located north of the process facility. Overflow
frem the concrete pi ts went to an earthen pi t, and excess water was
discharged to drainage ditches and sprayed on the ground around the
storage yard to control dust. Four additional waste pits have been
identified in aerial photos dating back to 1937. All of these pits
had been filled in by 1979.
In 1975, L. A. Clarke and Son, Inc., was issued a National Pollution
Discharge Elimination System (NPDES) pe~it for outfalls from two
drainage ditches on-site (see Figure 1-3). These pecnits are still
in effect. The only toxic contaminant regulated by the pecnit of
concern is phenol.
In 1979, a wastewater impoundment (i.e., lagoon) was constructed to
separate creosote fram process wastewaters. In 1989, L. A. Clarke
and Son, Inc. was classified under RCRA as a treater of hazardous
wastes because of the use of this impoundment. L. A. Clarke was
issued EPA I.~. No. VAD997972482. In 1982, L. A. Clarke submitted
a ~RA Part B Permit Application, which addressed the impoun:inent
and a contaminated soil pile located south of the process area.
The facility lost 1CRA interim status on Novenber 8, 1985 as a result
of its failure to submit the certification required under Section
3995(e).
The RCRA-requlated soil waste pile was created when soils were excava-
ted fraD t:be processing area and from ditch 2 along the northern
property 111'8. This work was conducted as part of a state-mandated
remedial action in 1982. The waste pile contains approximately 1,499
cubic yard. of soil. .
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SITE aiARACTERI ZA T100
Physical investigations during the R1 have led to the following
conclusions regarding the drainage, soils and hydrogeology of the
site:
o Surface topogra~hy is relatively flat due to extensive fill
and grading operations.
o The site is underlain by 0 to 26 feet of alluvial gravelly
sands on top of a 13- to 32-foot thick silty clay/ clayey silt unit.
The alluvium pinches out along the southern margin of the site,
exposing ~~e underlying clayey silt.
. 0 A shallow water
the alluvial deposits,
out, into the adjacent
aquifer underlies this
table aquifer flows to the southeast within
and continues, where the alluvium pinches
fractured silty clay/clayey silt. A deeper
unit.
o Free product creosote is visible on the alluvium-clay inter-
face in nonproduction/disposal areas indicating that migration of
creosote is, in part, controlled by the undulatory nature of the
clay surface. .
o Creosote is present Sor more feet below the surface of the
clayey silt/silty clay both next to the facility and along the
southern si te boundary. The creosote appears in sandy interbeds and
along microfractures in ~~e clayey silt/silty clay.
o On-site soils and fill are pecneable, which reduces surface
runoff. Jitches that drain ~~e site maintain flow throughout the
year and are, in fact, surface manifestations of a shallow water
table system. The high creosote levels in soils at the ditch outfalls
(in ~~e wetlands adjacent to Massaponax Creek) indicate that the
ditches are a primary mechanism for off-site transport.
In all cases, the primary contaminants of concern are constituents
of creosote, particularly polynuclear aranatics (PNAs) and benzene.
Based on chemical analyses of surface and sub-surface soils, plant
practices have apparantly created the following contaminant source
areas (88 Selected SOil and Sediment Sample Results and Figures
4-9, 4-U ~ 4-12):
o Burial of waste creosote in pits has resulted in relatively
stationary pockets of elevated PNA concentrations and a source
of soluble contamination, which is transported by infiltration
to the groundwater. (See results for TP-96, TP-33 and TR-4.)
o Plant operations have included years of spills and leaks at
the treatment cylinders. Free prochx=t in these areas has canpletely
permeated subsurface soi ls down to the clay stratum. Horizontal
migration of free product along the top of this stratum is evident,
forming a "creosote layer" (see result for 'm-12).
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o Sample results also indicate substantial contamination of
surface sed~nts in on-site drainage ditches, particularly ~l
and ga2, and at the outfalls of these ditches (see results for Dll
and D12). A significant quantity of sub-surface sediment has
been detected at the outfall of ditch g91 (see \C-91).
o Areas of relatively higher PNA concentrations in surface soil
include areas around the process facility, the field southeast of
the lagoon, and the -~llands nea~ the outfalls. Surface soils in
the process area became increasingly stained approaching the opera-
tions buildings due to the frequent transport in that area of freshly
treated lumber. Surface soils in this area contain total PNA concen-
trations on ~~e order of 5,999 mg!kg. Surface soils in the wetlands
are heavily stained within 199 feet of the outfalls.
o PNA concentrations in excess of 5,900 mg!kg can be found in
surface soils in the area southeast of the wastewater lagoon. This
can be attributed to ~'e spraying of wastewater from the lagoon when
in service and the use of an earthen overflow pit, shown on historical
overflights, directly south of the lagoon.
o A soil pile, located west of the wastewater lagoon, consists of
contaminated soils excavated by L. A. Clarke from areas surrounding
the process facility. Soil samples taken from the pile by previous
investigators (Schnabel Engineering Associates) indicate the presence
of PNAs i:1 excess of 1,090 mg!kg and low levels of benzene. In
addition, the ~RA regulated lagoon has been-estimated to hold 278
cubic yards of creosote bottom sediment.
Chemical analyses have revealed the following about contaminant
migration pa~,ways:
o Significant contaminant levels have been detected in wetlands
tributaries receiving drainage from the site (see results for M02).
Massaponax Creek sediments downstream of the si te ranged fran below
detection to 12 mg!kg of PNA (detected by U.S. Fish and Wildlife Ser-
vice) .
o A survey of bettCD feeding fish from Westvaco Pond revealed
carciOO?8Qic lesions around the gills and mouth in several specimens.
'rhese abDDmali ties may be due to direct contact wi th creosote
contaminat8d sediments. Sediment samples taken from the edge of the
pond contained total PNA concentrations between 2 and 18 nq!kg.
Areas of blackened soils and sediments have been observed at the
water's edge.
o Total PNA concentrations in the shallow aquifer ranged up to
1599 1.19/1. Benzene ranged up to 199 ug/l.
o Total PNA concentrations in the deep aquifer were below
detection, with the exception of one detection of less than 19 ug/l.
FolloW\1p sampling of the well revealed no mAs. Benzene was not
detected in the deep aquifer.
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L.A. CLARKE RI/FS- SELECTED SOIL AND SEDIMENT SAMPLE RESULTS
Location
TP-17
18
13
6
7
33
22
23
SP-03
46
07
43
44
27
18
47
48
50
vr-oi
TB-12
Dll
D12
MO 2
Depth(ft.)
4
5
1
1
4
0,
0
4,
5
5
25
5
1.5
0,
0,
0
0,
1.0
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.5
1.5
3.5
5.5
11.5
25
25
0.25
TPNA (mg/kg)
3,390
739
3,686
19,260
264,984
701
4,422
3,262
8,183
817
6,880
784
4,604
7,120
4,031
14,267
3,630
4,883
2,493
2,912
54,034
4,295
4,231
38,790
1,481
1,480
11,140
Notes: 1) See figures for sample locations
2) TPNA (Total Polynuclear Aromatic) concentrations were
identified either via analysis by an EPA contracted
laboratory or via Ultraviolet Fluorescence Screening
Technique In the field (see RI/FS for information
regarding these analyses)
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'
; - , . - *~r • •<
DM MoM»'Cul««f1>
r>D>lH> Bouod»ry
Wood Sloog*
FIGURE «-11 SHALLOW TEST PIT LOCATION?
I
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.S3
tr-w
NMTrsckl
.1,
•-v
! ..
TP OMP Tm Pit
TM Tr.nct.
VC
DM
Wood Stof *g*
FIGURE 4 12 DEEP TEST PIT, TRENCH.
_ TEST 10111116 AND
1 VIBRACORE LOCATIONS
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• Mdi Swnpln
(J
FKMMK «-t MTCM. 1NBVMHT, CMBK AND
ItMWUNOlOCAnOMS
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SCOPE OP REMEDIAL ACTION
The overall objectives of the Remedial Investigation/Feasiblity Study
(RIfFS) were to: (1) generate i.nformat10n needed to evaluate actual and
potential risks to receptors from site-related contamination in s01l,
surface water and groundwater and (2) develop remedial alternatives to
eliminate unacceptuble risk. PI data and the Public Health Evaluation
of the data indicated that control of contaminant sources at L.A.
Clarke would address the principal threat to human health and the environ-
ment. As a result, the FS focused on the development of remedial alterna-
tives designed to control contaminant sources identified during the RI.
The selected alternative in this Record of Decision (ROD) is therefore a
source control remedy.
The RI has also has generated significant data on the migration of site-
related contaminants from the identified sources. In particular. the RI
indicates site related contaminants have migrated (1) into a shallow
aouifer lying both below and downgradient of the property of concern
and (2) into sed:ments located downgradient of the site. However, in
each case, additional information is needed to determine the extent of
contamination before remedial alternatives can be developed and one
selected. Therefore, the EPA will continue the RIfFS to develop alterna-
tives to address these migration pathways. (Note: This ROD does include
remediation of sediments already known to present an unacceptable risk.)
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REMEDIAL ACTION OBJECTIVES
Utilizing data generated during the RI, a Public Health Evaluation (PHE)
was conducted to help determine the objective(s) of CERCLA remedial action
at the L.A. Clarke site. The pr~mary objective in this case is to
eliminate soil and sediment contamination which presents an unaccePtable
risk to human health and tne environment. The primary actual and potential
risk pathways of concern in this case are: .
o Incidental in2estion/dermal contact - Concentrations of site-related
contaminants in surface soils and sediments should not exceed criteria
protective of current workers and potential future residents for
incidental ingestion and dermal contact. No federal or state standards
exist for protection from soil exposure via r~ese direct contact pathways.
Therefore, the criteria in this case must correspond to an acceptable
level of carcin02enic risk. Since there is actual exposure of workers
to the soils of concern, a risk level of 10-6 is determined to be appro-
priate in this case. To achieve a 10-fi risk level for on-site worker.,
carcinogenic polynuclear aromatic (CPNA) concentrations in surface
soils shoul~ not exceed 0.22 m2/k~. To achieve the same risk level for
potential future residents, surface soi:s:;r.c i not exceed 0.08 mg/kg
CPNA.
o In~estion of shallow groundwater - Concentrations of site-related conta-
minants in sub-surface soils (at or below an avera~e of 1.5' from ground
surface) should not exc~ed criteria protective of the shallow aquifer
underlying the site as a potential drinkiIT~ water supply. A~ain, there are
no federal or state standards for soils to achieve adequate protection
fro~ exposure via this pathway. Therefore, the criteria of concern is
- a carcin02en:.c-r:-sk-level. Because (1 ) the closest homewellsdrawing from
the shallow aouifer are locaced an estimated 1000 feet from the Sl"te boun-
dary and (2) these residential wells are currently either sidegradient or
up2radient of the site, a 10-5 risk at the site boundary is an reasonahle
goal for protectin~ these home well owners as well as other current and
future users of the aquifer of concern. In addition, this goal is achievable
through the use of soil/sediment treatment technologies. To achieve this
goal, target clean-up levels for site-related contaminated soils have been
developed (8ee RIIFS Addendum). The tar~et clean-up level for CPNA in soil
to achieve thi8 g081 i8 10.3 m~/kg. For benzene, the target clean-up level
to achieve th1& goal 1& 94.03 u!{/kg. These tar!{et clean-up levels shall be .
confirmed via studie8 in the Remedial Design phase. (Note: A remedial alter-
native. for restoration of ~roundwater to applicable or relevant and appro-
priate requirements (ARARs) of concern will determined in a subsequent
ROD. )
o Protection of aquatic life - Concentrations of site-related contaminants
in soils and sediments should not exceed criteria protective of aquatic
life in surface water e.g. Massaponax Creek. There are no federal or
state standards for soils to achieve such protection. The PRE ~as deter-
mined, via surface water modelin~, that ~revention of adverse effects on
aquatic life 1n surface water due to inputs from surface water runoff and
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~roundwater infiltration can be achieved by reducin~ TPNA (Total Polynu-
clear Aromatic) levels io soils and sediments to tar~et clean-up levels
of 352 mg/kg. If necessary, this level shall be confirmed during the
Remedial Des~~n.
The above clean-up criteria function as chemical specific ARARs in this
case. To achieve surface soil levels protective of direct contact exposure,
the site will he covered with 1.5 feet of seeded topsoil. To achieve
protection of the shallow aquifer for drlnkin~ water purposes, tar~et clean
up levels for s011s lyin~ under topsoil after the comoletion of remediation
are 10.3 m~/kg CPNA and 94.03 ug/k~ benzene. By meetin~ such levels,
protection of aauatic life in surface water shall also be achieved. To
estimate the cost of the remedial alternatives, the volume of soi1 and
sediment currentlv exceeding levels protective of the shallow aquifer
have been estimated. These volumes were developed utilizing contaminant
profiles located in Appendix B of the RI/FS and other information within
the RIfFS. CPNA concentrations were estimated usin~ a CPNA:TPNA ratio
of 0.13 (see RIfFS) i.e. the cleanup level was assumed to be roughly 80
mi/kg TPSA. The calculated volumes include: (1) the RCRA re~u1ated soil
pile and (2) bottom sediment in the RCRA regulated la~oon. In addition,
sediments of Westvaco Pond have been included hased on the results of 8n
aauatic life survey.
The estimated volumes of soils and sediments at the site requiring remedi-
ation are:
Volume (io vd3)
~edia
Surface soils
Buried pits
Creosote layer
Sediments
Subsurface wetland
soils
60,200
2,500
6,000
45,300
5,000
Total
119,000 yd3
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REMEDIAL ALTERNATIVE EVALUATION
The Feasiblity Study for the L.A. Clarke site screened a number of
alternatives which could potentially achieve the remedial objective
of concern i.e. reduce contaminant levels in on-site soils and
sediments to-Tevels which eliminate unacceptable risk to human
health 3nd the environment (see Remedial Action Objectives) .
~ll alternatives were evaluated via the following criteria:
o Protection of public health and the environment
o Compliance with applicable or relevant and appropriate
requ i rements (ARARs) .
o Long term effectiveness and permanence
o Reduction of waste. mobility, toxicity and vol~
o Short term effectiveness
o Im?lementability
~ Community acceptance
o State acceptance
o Cost
These criteria were derived fran the OCP and SARA of 1986. The
criteria relate directly to factors mandated in Section l21(b) (1) (A-G).
Utilizing these criteria, certain alternatives were eliminated during
the preliminary screening process. The eliminated alternatives and
~'e primary reason(s) for their elimination are listed below. (A
~ore detailed analysis of these alternatives may be found in the FS.)
Alternative
Reason(s) for Elimination
In-Sit~ .~sorption
Effectiveness is questionable due to
viscosity of creosote.
In-Situ Vitrification
In early development stages; applicability
to site is questionable.
Other technologies can achieve similar
results at considerably less cost.
Supercritical Extraction
Macroencapp11ation
Possible leaching of treated materials;
relatively unreliable.
Asphalt Incorporation
Little operating history; few operations
capable of Unplementation.
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DESCRIPTION OF ALTERNATIVES
Six alternatives were retained for the final evaluation. These six
alternatives have been further evaluated to determine which would be
most effective in achieving the goals of CERCLA, and in particular,
achieving the remedial objective for the site.
In the case of each of the six alternatives, cost estimates have
been developed. Each estimate incll)1es the addition of (1) a 25%
contingency rate for capital costs and (2) a 15% contingency rate for
operation and maintenance costs. The addition of these rates is to
prevent an underestimation of the final cost. Actual final costs may
therefore be less than these estimates. Building removal costs of $
1.5 million have been included under capital costs where such removal
is required.
-16-
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At TERNATI VE 1: NO l£.'T I ON
Capi tal Cost: $ 74,998.
Present Worth of Q&M: $ 5137,131313.
Total Present Worth: $ 581,999.
Under the no action alternative, no additional remedial action will
be taken at the L. A. Clarke site. The canponents of this alternative
include the following:
o Upgrade of ~ite security by the installation of fencing around
the perimeter of the site. .
o Implementation of a long-tetm quarterly ground/surface water
monitoring program.
Chemical specific ARARs established for the site would not be met
wi th No Action. In particular, PNA and benzene concentrations
in sub-surface soils would continue to SXceed levels which constitute
a carcinogenic risk of greater than 19- for potential consumers of
groundwater from the shallow aquifer at the site boundary. In addition,
while fencing the site would temporarily prevent access by area
residents, on-site workers would conttnue to be exposed to soil
contaminant levels which exceed a l~ risk for direct contact
pathways.
Action specific ARARs would also not be met with this alternative.
In particular, (1) applicable RCRA closure and post-closure require-
ments for the waste pi le and surface impourdnent would not be met,
(2) relevent and appropriate RCRA closure and post closure require-
ments for the hazardous waste contaminated soils and sedtments
located elsewhere at the si te would not be met and (3) appropriate
corrective action RCRA requirements. for releases of hazardous
wastes from solid waste management units would not be met.
-17-
-------
ALTERNATIVE 2: SOIL EXTRACTION
Initial Capital Cost: S 2,453,000.
Present Worth of Implementation: S 26,470,000.
Present Worth of O&M: $ 33,900.
Total Present Worth: $ 28,956,900.
This alternative consists of excavating all soils and sediments
exceeding target clean-up levels and treating these materials to
eliminate unacceptable risk and returning the treated soils and
sediments to their original location. The soils/sediments would
be treated via an on-site soil washing/extraction process. This
process involves the washing of contaminated soil with a surfactant-
type solution which mobilizes contaminants previously associated
with the soil. The extracted contaminants may then be disposed of
while the washing solution is recycled for further use. To fully
implement this alternative, building removal is required. The major
components of this remedial alternative include the following:
o Complete excavation/dredging of contaminated materials inclu-
ding surface soils, sediments in ditches 1, 2, and 3, the wetlands,
Westvaco Pond, buried pit materials, creosote layer, and sub-surface
wetlands soils.
- Geotextile silt fences, sedimentation basins and/or diver-
sion/ surface management to control off-site soil transport and
divert surface-water and groundwater flows.
- Organic vapor monitoring.
- Dewatering of sediments; treatment (if required) and on-
site discharge of sediment waters.
o On-site soil washing/extraction of contaminated material
using water/chemical solutions in a tank.
o On-site treatment of soil washing elutriate stream, using conven-
tional wastewater treatment methods.
o On-site discharge of treated process wastewater.
o Off-aite disposal of treatment residuals.
o Backfill and regrade surface and subsurface areas onsite and in
the wetlands with treated soil, cover with clean soil and revegetate.
tate.
o Post-treatment groundwater monitoring.
This alternative would meet Chemical Specific ARARs by elimina-
ting soil contaminant levels which present an unacceptable carcino-
genic risk (see Remedial Action Objectives). The attached ARAR
Compliance table summarizes other ARARs which should be met.
-18-
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ALTERNATIVE 3: IN SITU SOIL FLUSHING/BIORBCLAMATION
AND SOIL BIODEGRADATION VIA LANDFARMING
Initial Capital Cost: $ 2,295,000.
Present Worth of Implementation: $ 21,080,000.
Present Worth of O&M: $ 33,900.
Total Present Worth: $ 23,408,900.
This alternative includes the application of two different treatment
technologies to address two different areas of contaminated soil.
Contaminated soils under the process buildings would be remediated
in situ via soil flushing with a surfactant solution followed by in
situ bioreclamation. A flushing solution of appropriate viscosity
would be applied to sub-surface soils via injection wells to mobilize
creosote associated with these soils. The solution and associated
contaminants would then be recovered from the sub-surface soils via
a recovery well network. In situ bioreclamation of these subsurface
soils would then be implemented to reduce contaminant concentrations
to target clean-up levels. Bioreclamation would consist of the appli-
cation of a nutrient and oxygen rich solution to promote the biodegra-
dation of the contaminants via bacterial action. The solution would
be applied via the same injection wells used for surfactant solution
application.
Bottom sediment from the RCRA regulated impoundment would be biologi-
cally treated in a tank, while the RCRA regulated soil pile would
be land treated in place.
All other contaminated soils and sediments at the site would be
remediated by biodegradation via landfarming. This technology consists
ofl land .treatment-of -contaminated materials -erther" in-pi ace "or a
within an appropriately designed landfarm on-site. Landfarming
involves the initiation and maintenance of the conditions necessary
to promote the biodegradation of contaminants by either indigenous
or specially developed bacterial populations. These conditions are
can be generated by conventional farming techniques such as tilling
and nutrient application, supplemented by the application of oxygen-
rich compounds.
Both soil flushing and biodegradation would require bench and pilot scale
studies to develop the specific designs appropriate to conditions at
the site. The designs would also minimize releases to air, surface
water and the sub-surface by meeting the ARARs of concern. These
studies would be conducted as part of the Remedial [Design phase of
the project.
All chemical specific ARAR's identified under Remedial Action
Objectives would be met with this alternative. The attached ARAR
Compliance Table summarizes other ARAR's which would be met.
The major components of this alternative include the following:
-19-
-------
o In situ soil flushing, utilizing a surfactant solution,
of subsurface soils (creosote layer) underlying the process buildings:
- Injection/recovery wells to direct washing solutions to
the contaminated soils and then recover the contaminant-laden wash
solution.
- Design and use of a well system to attain a self-contained
flushing scheme to prevent environmental impacts.
- A wastewater
washing solutions for
Disposal of treatment
characterization.
treatment system to remove contaminants fran
recycling of solution baCK into the process.
residuals is dependent on post-treatment
o In si t'.J biodegradation in the creosote layer area (following
the in situ flushing):
Nutrient and oxygen-rich compounds shall be injected via
the well system described above.
o On-site land facuing of excavated surface soils, sed~nts, and
subsurface wetland soils. The main land faDning operation will be
placed in northeast area of site. Some soils may be land facned in-
place. The RCRA regula ted soil pile and Westvaco Pond sediment
shall ~ landtreated in place.
o Creosote contaminated bottcrn sediment in the RCRA regulated
lagoon shall ~ biologically degraded in a tank.
o Excavation/dredging and consolidation of contaminated sedUnents
(ditches 1, 2, and 3, and wetlands), subsurface wetlands soils,
buried pit materials, and surface soils that are not remediated via
in situ flushing/biodegradation and cannot be land treated in place:
- Geotextile silt fences, sed~ntation basins, and/or
diversion/ surface management to control off-site soil transport
and divert surface-water flows. .
- organic vapor ~nitoring.
- DMiatering of sediments, treatment of water (if required),
and on-site di8Charqe of treated water.
o
Erosion/sed~ntation control (as described for excavation).
o Backfill excavated areas with treated soil and sediment.
Cover ~ckfilled areas with topsoil and revegetate.
o During and post treatment groundwater monitoring.
-20-
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ALTERNATIVE 4:
rAND FARMING/BIODEGRADATION
Initial capital Costs: $ 2,999,999.
Present WOrth of Implementation: $ 18,967,999.
Present WOrth of O&M: $ 33,999.
Present Worth: $ 21,999,999.
This alternative implements biodegradation of contaminants associated
with soils and sedUnents as the sole remedial technology. Therefore,
removal of process buildings would be required to peDnit excavation
aoo subsequent landfarming of contaminated soils underlying the
process buildings. As in the case of Alternative 3, landfarming may
be conducted with soils in place or within a specially designed
treatment cell. The optUnum design for contaminant biodegradation
and prevention of contaminant migration would be developed in bench
and pilot scale studies during the Remedial cesign phase. To fully
implement this alternative, building removal would be required.
The major components of Alternative 4 include the following activities:
o Land faming of surface soils in-place where feasible. (The
RCRA regulated soi 1 pile and Westvaco Pond sedUnent shall be land
treated in place.) Land faming of all soils and sediments that
cannot be landtreated in place within a landfa~ area on-site.
Bottam sediment fram the RCRA regulated impourdnent shall be biologi-
cally treated in a tank.
o Excavation/dredging of contaminated sedUnents (ditches 1, 2,
and 3, and the \lEtlands), subsurface \lEtlands soi Is, creosote layer,
buried pit materials, and surface soils that cannot. be land fa~
-- in-place (i.e., process_area). These-materials will be landfarmecl-in
the land-farming area.
--.- -.--- - ---
- Geotextile silt fences, sedUnentation basins, and/or diver-
sion/surface management to control off-site soil transport and divert
surface-water flows.
- organic vapor monitoring.
- Dewtering of highly-contaminated sediments prior to treatment,
treatment (if required), and disposal of sediment waters on-site.
- Cb-si te land faming of highly contaminated materlals by
blending with lower contaminated soi Is in the landfaming cells.
o Backfill treated soil, regrade, cover site with clean soil
cover and revegetate.
o During/post-treatment monitoring.
All chemical specific ~'s identified under Remedial Action Objectives
would be met with this alternative. The attached ARM Canpliance .
Table summarizes other ARAR's which should be met.
-21-
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M.TERNATIVE 5:
CONTAINMENT
Initial Capital Cost: $ 1,215,000.
Present WOrth of Implementation: $
Present Worth of O&M:' $313,000.
Total Present Worth: $ 20,346,000.
18,818,000.
This alternative consists of establishing a containment area in the
western half of the site and depositing all contaminated soils and
sediments outside this area within. Prior to placement in the contain-
~ent area, the materials would be stabilized via a solidification
~rocess. The containment area itself would consist of a slurry wall
extending down to the clay formation underlying the site and a RCRA
cover. The major canponents of this alternative inclOOe the following:
o Diversion of surface water and groundwater around the proposed
containment area utilizing surface management techniques and subsurface
groundwater barriers.
o Excavation/dredging of contaminated materials including sedUnents
in ditches 1, 2, and 3, and in Westvaco Pond, sedUnents and subsurface
soils in the wetlands, buried pit materials, and surface soils outside
the containment area.
o Solidification/stabilizat ion of sediments and soils as necessary
to attain load-bearing capacity sufficient for cap placement.
o Backfill ditches 1, 2, and 3 and low-lying areas within the
containment area wi~~ stabilized material. Backfill excavation
areas outside the containment area with clean fill.
o Construct surface cap over stabilized material and surface
soils west of ditch 2 and including the process area.
o Condu:t post-construction rooni toring.
Rather than redu:e contaminant levels in soil and sedUnent to target
clean-up levels, these materials would be contained to prevent migration
to receptors. Such containment would prevent exposure of receptors
to contaminant levels which present an unacceptable health risk. In
this manner, c:hsnical specific MARs discussed under Remedial (]:)jectives
would be _t. Other ARARs are identified in the attached ARAR Canpli-
ance Table. .
-22-
-------
ALTERNATIVE 6:
~/OFF-SITE OPTION
Initial Capital Costs: For Incineration Option
For Landfill Option - $
Present Worth of ~lementation: $ 11,~27,~~9.
Present Worth of O&M: $33,999. .
Present Wor~~: Off-Site Incineration - $ 76,137,999.
Off-Site Disposal - $69,563,999.
- $ 63,576,999.
48,992,999.
(for both Options)
This alternative consists of removal, by excavation, of all sources
of contamination at the L. A. Clarke site and either 1) disposal in
a RCRA-approved landfill or 2) off-site incineration in a RCRA-approved
incinerator. To fully implement this alternative, building removal
would be required. This alternative incl\xSes the following major
activities:
o Complete excavation/dredging
surface soils, sedUnents in ditches
the wetlands, buried pit materials,
wetlands soils.
of contaminated materials including
1, 2, and 3, Westvaco Pond, and
the creosote layer, and subsurface
o Geotextile silt fences, sedimentation basins, and/or diversion/
surface management to control off-site soil transport and divert
surface-water/groundwater flows through ditches.
o organic vapor monitoring.
o Dewatering of sediments, treatment (if required), and on-site
discharge of sedllnent waters.
, ' '
,-, o~ 'bff':'sIte'dlspos,ii/treatment by one of the following options:
- Off-site thermal treatment and disposal at an offsite commercial
incinerator facility.
- Off-site disPosal at a RCRA-approved landfill.
o Transport of contaminated materials of concern.
o Post-remediation groundwater monitoring.
Chemical speCific ARARs identified under Remedial Action Objectives
woold be _t with this alternative. See MAR CaTlpliance Table for
other ARARs which would be met.
-23-
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STATEMENT OF FINDINGS REGARDING FLOODPLAINS AND WETLANDS
The RI/FS for L.A. Clarke has determined that soils and sediments
located within both a 100-year floodplain and wetlands contain site-
related contaminants at levels which constitute an unacceptable risk
to public health and the environment. (Wetland areas were assessed
as part of the RI/FS and are discussed on pgs. 2-19 to 2-22.) Exca-
vation and/or treatment of the soils and sediments of concern will be
required to eliminate this unacceptable risk. All remedial alterna-
tives in this case will require excavation except No Action, which
is not protective of public health. Upon completion of treatment, the
soils and sediments may be backfilled into their previous location
and covered with clean top soil (if necessary).
The excavation and fill activities of concern shall be conducted in
a manner consistent with provisions of Appendix A of 40 CFR Part 6.
The subject regulations have been entitled "Statement of Procedures
on Floodplain Management and Wetland Protection". These procedures •
constitute policy and guidance for carrying out provisions of Execu-
tive Orders 11988 and 11990. These orders address Floodplain Manage-
ment and Protection of Wetlands respectively.
The Remedial Design of the Remedial Action shall be developed in
a manner consistent with Appendix A of 40 CFR Part 6 to assure that
potential ham and adverse effects to the floodplain and wetlands is
minimized. The Remedial Design has not yet been initiated at this
time. Therefore, specific steps to minimize impacts have not yet
been identified. In addition, the effect of the Remedial Action on
the floodplain or wetlands of concern cannot accurately be assessed
at this time.
While all remedial measures shall be designed to minimize harm to wet-
lands, it is possible that some adverse effects may be unavoidable.
Should remedial activity be expected to create such effects, restora-
tive measures shall be developed during the Remedial Design. Should
unanticipated adverse effects occur, restorative measures shall be
implemented as part of the Remedial Action.
-24-
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Action/ARM
1. Construction and operation
of haza~us waste treatment
tanks (40 C.F.R.S 264.1-.118
and Su~rt J. ft.Ist conp1y
with substantive RCRA
standards and operat ion
of tanks).
2.
Discharge of dredge/fill
material into navigable
waters (Clean Water Act
S 404: 40 C.F.R. S 230.10:
33 C.F.R. SS 320-330.
Discharge RUst neet
standards in cited
provis ions).
Alternative
I
N/A
N/A
ACTlrn-SPOCIFIC AND [OCAT[(J-I-Sr~X::IFlC
ARARS MATR IX '
AI ternat i ve
2
Treatment of
contaminated
sol Is and
sediments with
soi I washing/
extraction
solut ions, ron-
taminated water
fran sediment
dewatering,
contaminated
soi 1 washing
elutriate
stream and
contami nated
process waste-
water in tanks.
Excavat ion/
dredginq of
contaminated
sediments in
pond, wet 1 ands
and back fi 11 ing
of same with
treated soi ls/
sed i ments may
constitute such
a discharge.
(See "Statenent
of Findinqs
Regarding ~t-
lands and
Fl oodp 1 a i n.s" ,
infra at
,
Alternat'ive
3
Treatment of
rontaminated
water fran
sediment
dewaterif1g,
. I
rontamlnated
soil flushing
solut ion; and
contaminated
process waste-
water inl
tanks. * Treat-
ment of highly
contaminated
wastes H-an
surface im-
poundment in
tank.
Sane as: 1\ 1 t. 2
.
Alternative
4
Treatment of
contaminated
water fran
sediment
dewatering
in tanks..
Treatment of
highly-con-
taminated
wastes fran
surface 1m-
poondrrent in
tank .
Same as 1\1 t. 2
Alternative
5
Treatment of
contami nated
water from
sediment
dewatering
in tanks..
Excavation/
dredging of
contaminated
sediments in
pond, wet-
lands, and
back f illi ng
with clean
fill.
Al ternat i ve
6
Treatment of
contaminated
water fran
sediment
dewateri ng
in tanks.*
I
11'\
N
I
Excavation/
dredg i ng of
contaminated
sediments in
pond, wetlands
may ronsti tu te
such a dis-
charge.
.If tank IS a "wastewater treatment Ulllt" as def lned In 40 C.F .R. S 260.10, treatrrent in such tank IS exent>t fran
ICRA regulat ion. .
-------
Action/ARAR
Alternative
1
Alternative
2
Alternative
3
Alternative
4
Alternative Alternative
5 6
3. Discharge of pollutants
into waters of the
United States (Clean
Water Act § 402(a)(l),
40 C.F.R. §§ 122.21, .41
and .44 and 125.100 and
.104 and 136. 1-. 4 and
State Water Quality
Standards. Discharges
must be in compliance
with applicable NPDES
standards ) .
4. Off-site disposal of
hazardous waste (40
C.F.R. Parts 262, 263-
off-site shipmment must
be performed in accord-
ance with substantive
RCRA standards for
generators and trans-
porters, CERCLA
§ 121(d)(3)-Hazardous
wastes shipped
off-site must be
disposed of at a
facility which is
operating in compli-
ance with interim
status requirements
or a permit and, if
! the wastes are to be
land disposal, the
receiving facility
N/A
N/A
Discharges of
treated water
from dewatering
of contami-
nated sediments
and treated
process water.
Off-site dis-
posal of resi-
duals of the
soil washing
solution.
Same as Alt. 2
May be off -site
disposal of
spent washing
solution.
Discharge of
treated water
from dewater-
ing of con-
taminated
sediments.
N/A
Same as Alt. 4
N/A
•
Same as Alt. 4
Off-site dis-
posal of haz-
ardous wastes
excavated
from the site
in an incin-
erator or
landfill.
* .
-------
AI ternat i va
AI ternat i va
Alternative
AI ternat i ve
At ternat i va
Altemat ive
Act ion/MAR 1 2 J ' 4 5 6
:
JftJst not be releas-
ing any hazardous :
wastes or oonstitu-
ents into ground- "
water, surface :
water or soil and
any releases from ;
other units at the :
facility JftJst be I
controlled by a
RCRA corrective
act ion ).
i
5. Construction/oper- The biodegra- Same as 1\1 t. 3 N/A
ation of a new haz- dation of con- I
r-
ardous waste land tami nated soils N
treatment unit N/A N/A and sedirrents I
(40 C.F.R. (land fatmi~)
S 269.1-.178 and at the site
.270-.279. New will constitute
land treatment 1anet treatnent.
units nust be
constructed and
operated in
accordance wi th ;
cited provisions). I
-------
a.... '--.. ...-.............
... \.,.-"','U\. ~"''-'
. ..I...\...V. ....\.. a. \Ie
tU LeL Ildt:. 1 ve
I\J --q\al I ve
~lon/AAAR 1 2 3 4 5 6
6. Construct:Ton/oper- Backfilling and - Establishing
ation of a new haz- regradin;J of a oontain-
ardous waste landfill N/A excavated areas N/A N/A nent area N/A
(40 C.F.R. S 264.1-.178 on-site with on-site and
and .300-.303. New treated soils depositing
landfills maut be oon- and sedinents oontaminated
structed and ~rated constitutes soi Is and
in accordance with construct ioo/ sedinents fran
cited provisions. operation of a discreet
new landfills... area of con-
tami nat ion
(the pond)
in that area
constitutes
oonstruct ion/
~ration of
a new land-
fill.
7. Land disposal of haz- Backfi llinq and Placement of Sane as Alt.) 11\e plaoenent Off-site
ardous wastes KOOI and regrading of hazardous wastes of excavated disposal of
U051 (RCRA S J004(g): N/A excavated areas fran waste pile contaminated excavated
40 C.F.R. Part 268. of the site with and surface soi Is and sed- contClTlinated
Land disposal of KOO I treated soils impoundrrent into i~nts f ran a soils and
and U051 is restricted and sediments new land treat- discreet area sedinents in
after August 8, 1988 constitutes land ment unit con- of contami - a landf ill
unless such wastes sat~ disposal of KOOI stitutes land nat ion (the would con-
isfy BOAT pretreatment and U051. ** disposal of pam) in a new stitute land
standards to be esta- KOOI and lJ051... landfill con- disposal of
blished for such wastes stitutes land KOO 1 and
by that date, or unless disposal of U051.
such land disposal qua- . K001 and U051.
1 i f ies for an eXEmpt ion
or variance. Land
disposal of hazardous
waste contaminated soil
or debris resulting
I f ran a CERCLA S 106
[ or S 104 cleanup
I or a RCRA corrective
action is exempt until
11/8/88).
uN/A If treated solIs and sedIments are dellsted prior to such dIsposal or placement.
I
10
......
I .
-------
Act ion/MAR
8. Closure of RCRA regu-
lated units (40 C.F.R.
S 264.111-.116 and
unit-specific closure
requirements for tanks
(40 C.F.R. S 264.197),
surface impoundments
(40 C.F.R. S 264.250),
land treatment units
(40 C.F.R. S 264.280)
and landfills (40
C.F.R. S 264.264.310),
as apprq>riate).
9. Closure of oon-RCRI\-
regulated areas of
facility (the gen-
era I closure re-
qui~nts of 40
C.F.R. 5 264.111 are
applicable to all
port ions of a RCRA
fad 1i ty. There are
no specific closure
standards for areas
of the facility which
are not regulated unit!';.
RCRA closure standard!';
for landfills and surface
inpJtmdnents are, to sOlre
extent, "relevant and
Altemat ive
1
AI temat i ve
2
Alternative
J
Surface inpoond- Surface impound- Surface inpoond-
lrent and waste trent and waste rent and waste
pile will be pile will be pile will be
closed with clean closed un- "clean closed"
wastes in place der 40 C.F.R. SS under 40 C.F.R.
and no addit- 264.228(a)(1) and S 264.228(a)(I)
ional treasures .258(a), respect- and 40 C.F.R.
taken. ively. New land- S 264.258(a),
fills will be respectively.
closed to meet New land treat-
"hybrid closure" rent units will
~i~nts of be closed to
52 Fed. Reg. 8712 meet 40 ~.F.R.
(March 19, 1987) S 264.280. New
(prqxJSed regu- tank closed to
lation). meet 40 C.F.R.
S 264. 197.
All non-RCRA-
regulated
areas of the
site will be
closed with
wastes in
pLace and no
additional
lreasu res
taken.
All non-RCRJ\-
regulated areas
of the site will
be closed to
meet "hybrid
closure" re-
quirements of
52 Fed. Reg.
8712 (March
19, 1987) (pr-o-
posed regu-
lation) as
relevant and
appropriate.
All non-RCRA-
regulated site
areas wi 11 be
closed to meet
"hybr-id closure"
r-equ i relrents of
52 Fed. Reg.
8712 (March 19,
1987) (prq>osed
regu tat ion) .
Alternative
4
Sane as Alt.]
S~ as Alt.3
Al ternat i ve
5
Alternative
6 .
Surface im- Surface im-
pol1rd1ent, poun~nt
waste pi Ie and and waste
new landfill pile will
will be closed be closed
to neet clo- to neat
sure require- clean
ments of 40 closure
C.F.R. ~ire-
5 264.310. ments of
40 C.F.R.
5S 264.228
(a )( 1) and
. 258(a),
respect-
ively.
SanI! as Alt. 3,
except that
contaminated
areas under
prooess wild-
il¥]S wi 11 be
.left in place
with no fur--
ther closure
measures
taken.
Sane as
Alt.2
I
C7\
N
I
-------
Ad. ion/A'RJ\
appropdate" for the
closure of the contami-
nated soil areas and
contaminated wetland
sediments which are not
RCRA uni ts. SUch re le-
vant and app~riate
standards may be net
via "hybrid closure"
described at 52 Fed.
Reg. 8712 (March 19,
1987) (prq>osed
regulation) .
10. Post-closure care
{40 C.F.R. S 264.
117-.120 and unit
specific standards
for tanks (40 C.F.R.
S 264.197), surface
irrpoondJrents (40
C.F.R. S 264.228),
waste pi les (40
C.F.R. S 264.258),
land treat.nent units
(40 C.F.R. S 254.280)
and landfills (40
C . F . R. S 264. 310 ), as
apprq>riate.
Alternative
I
Post~loSure
care is an
appl icable
requ i rerrent
for surface
i~ndent
and waste
pile closed
in a manner
other than
clean clo-
sure. Fbst-
closure care
for non-RCRA-
regulated
areas of site
is relevant
and appro-
priate.
AI ternat i \Ie
2
lternat i ve
3
Alternative
4
Saroo as AlL 3
Post~losure Post~losure
care is not an care is not
applicable re- an applicable
quirement for requirement for
clean closed clean~losed
surface iJTtXX-md- surface imp(~..md-
ment and waste ment and waste
pile. Post~lo- pile. Post-
sure care may closure care may
be requ i red for be app I icab Ie
new tank and is for new tank and
requi red for new new land treat-
landfill. Post- ment units.
closure care for
non-RCRA-regu-
lat~ areas of
site is relevant
and appropriate.
AIte~t ive
5
Post~losure
is an applic-
able requ i re-
rrent for sur-
face irrpoond-
rrent, waste
pile and new
landfill
closed as a
landfi 11.
Post-closure
care re levant
and apprcpr i -
ate for clo-
sure of non-
RCRA-regu-
, lated areas
of site.
Irnat ive
6
Post-closure
is an appl ic-
able require-
rrent for sur-
face. il11JOOnd-
rrent and was te
pile closed
under "hybrid
closure".
Post~losure
care is rele-
vant and
appropriate
for closure of
non-RCRA-regu-
lated areas of
the site.
I
o
M
I
-------
Act ion/ARM
Alternative
1
11. Act ions at the site Closure of
which would require the surface im-
facility to obtain a RCRA poundment
operat ing or post-cJLosure and waste
permit absent a CERCLA pile by
clean-up (RCRA S 3004(u): "hybrid
40 C.F.R. S 264.101). The closure"
owner or q>erator of a would re-
facility seeking an oper- quire a RCRA
ating or post-closure per- post-closure
mit nust institute oorrec- permit absent
ti \Ie action as necessary a CEOCLA
to protect human health clearup.
and the envirOl'"lOOnt for Thus, oorr-
all releases of hazardous ective action
wastes and constituents requi~nts
fran any sol id waste are relevant
management unit at such and apprq>rl-
facility. ate.
12. Undergroond injection of
fluids (40 C.F.R. Part
144. Must meet require-
ments of the UIC program).
N/A
Al ternat i va
2
Alternat;. ive
3 '
Construction of Construction of
new tank and new tank and new
landfill would land trea~ment
require a OCRA unit woold re-
q>erating permit quire a R$A
absent a .CERCLA q>erating per-
clearup. Thus, mit, ard qlosure
oorrecti ve act-of new tallk and
ion requirements land treafment
are relevant and uni t may have
apprq>riate. required a post-
closure pe.rmi t,
absent a CERCLA
clearup. Thus,
corrective act-
ion requirements
are re levant and
appropriate.
N/A
The underground
injection of
virgin and're-
cycled soil
flushing solu-
t ion nust rteet
II IC requ i r~nents
1\1 ternat 1 ve
4
Sane as Alt. 3.
N/A
1\1 ternat i ve
5
1\1 terr1at i \Ie
6
Construction Closure of
of new laOO- surface im-
fill would re- poornrent
qui re a ReM . and waste
.~rating per- pile by "hy-
mi l. Closure brld clo-
of surface im- sure" WCJjld
poordtent, requ ire a
waste pile am ReRA post-
new landfill c\osure per-
woold require a mit absent
RCRI\ post-clo- a CERCLA
. sure permi t clearup.
absent a CERCIA Thus, oorr-
clearup. Thus, ective act-
correct i ve act-ion requ i re-
ion require- ments are
ments are rele- relevant and
vant and appro- apprq>r iate.
priate.
I
.....
""
I
N/A
N/A
-------
Al ternat i ve
AI ternat i ve
.ternative
Alternati ve
J\.1temative
mati ve
ktion/ARAI 1 2 3 4 5 6
13. Activity within a wetlands This alter- Sane as Alt. 1 Sarre as Al t. 1 Same as Al to 1 Sane as Alt.l Same as AI t. 1
(Executive Order 11990, native will
Protect ion of Wetlands. involve act-
Act ion I11..Ist be taken to ivity within
minimize the destruction, wetlands.
loss or degradation of (See .State-
wetlands). ment of Find-
ings ReganJ-
ing Wetlands
and Flood-
plains-,
infra at
).
14. Activity within a flood- This alter- Same as AI t. 1 Sane as Alt.1 Sane as Alt.l Same as Alt.l Sane as Al t. 1
plain (Executive Order native will
11988, Protection of involve act-
FlOO<\>la ins , 40 C.F.R. ivitywithin
Part 6, App. A. Action wetlaoos. I
~-
must be taken to avoid I
adverse effects, mini-
mize potential harm,
restore and preserve
natural and benef idal
values).
15. Generation of air emiss- Air emissions Sane a~ All. 2 SanE as Alt.2 Same as Alt. 2 Same as AI t. 2
ions an:) odors (Rules and exbrs wi 11
4-2, 4-3, 5-2 aoo 5-3 of N/A be generated
I
Virginia Regulations for during excava-
Decont roi am Abatement of tion.
Air Pollution).
I
-------
Alternative
Alternative
Alternative
Alternative
Alternative Alternative
Action/ARAR 1 2 34 5
16. Excavation, filling, al-
teration or modification
of lake or channel of
navigable water (Rivers
and Harbors Act S 10; 40
C.F.R. S
17. Injection of substances
into groundwater (Virginia
Anti-Degradation Policy
for Groundwater. Under-
ground injection may be
prohibited without appro-
val of State Water Control
Board.
N/A
N/A
This alternative
will involve
excavation,
filling, alter-
ation and/or
modification of
Westvaco Bond.
N/A
Same as Alt. 2
•
i
Underground in-
jection of soil
flushing solu-
tion must meet
this require-
ment.
Same as Alt. 2
N/A
Same as Alt. 2
N/A
6
Same as Alt. 2
N/A
-------
EVALUATION OF ALTERNATIVES
Protection of public health and the environment
The No Action alternative would not be protective because contaminant
levels in soils and sediments would continue to present an unacceptable
risk to public health and the environment. In particular, soils and
sediments would continue to exceed clean-up levels protective of (1)
the shallow aquifer for drinking water purposes and (2) on-site
workers from unacceptable risk associated with direct contact pathways.
All of the remaining five alternatives are protective of the shallow
aquifer and aquatic life by either treating soils to target clean-up
levels, removing soils above such levels off-site or containing such
soils to prevent migration. These same alternatives are protective
of direct contact pathways by placement of a soil cover over the site.
Compliance with applicable or relevant and appropriate
requirements (ARARs)
All alternatives would meet chemical, location and action specific
ARARs with the exception of No Action and Off-Site Disposal. In
the No Action alternative, chemical specific ARARs would not be met.
In particular, levels of PNAs in surface soils would continue to
present an unacceptable carcinogenic risk to on-site workers (greater
than 13 ) and levels of PNAs and benzene in sub-surface soils would
continue to present an unacceptable carcinogenic risk (greater than
10~5) to users of groundwater in the shallow aquifer for drinking
water purposes. In addition, action specific RCRA ARARs would not be
met with No Action. Since the No Action alternative is not protective
and fails to meet ARARs, it shall not be further evaluated.
The Containment alternative would not actually reduce soils and sedi-
ments to target cleanup levels. Rather, soils and sediments exceeding
PNA levels protective of the shallow aquifer would be contained to
prevent migration into the aquifer. However, the described contain-
ment alternative is unlikely to meet RCRA landfill requirements.
Off-Site Disposal of untreated soils is likely to be prohibited by
future Land Disposal Restrictions and therefore may not meet action
specific ARARs.
In the case of the other alternatives, chemical, location and/or action
specific ARARs would be met. Location and action specific ARARs for
each alternative are identified in the ARAR Compliance Matrix.
Chemical specific ARARs are met by the treatment Alternatives 2,3 and
4 by reducing soil/sediment contamination to risk based clean-up
levels. The Off-Site Incineration option of Alternative 6 removes all
soils/sediments exceeding this level off-site.
-34-
-------
Long Term Effectiveness and Permanence
The Soil Biodegradation and Incineration alternatives provide
solutions that are equally permanent and effective over the long
term. In each case, there are little, if any, toxic residuals
generated during the treatment of waste. The compounds of concern,
PNAs and benzene, are permanently destroyed. Both the Soil Washing
and Soil Flushing\Soil Biodegradation alternatives are expected to
generate quantities of toxic residuals requiring off-site disposal.
In each case, contaminated soils/ sediments are mixed with a surfactant
solution which removes the compounds of concern. The contaminants
now associated with the surfactant solution are extracted via a
wastewater treatment process. Toxic residuals are generated by this
treatment while the surfactant solution is recycled for further use.
The residuals are likely to be non-biodegradable and require off-site
disposal. In the case of Soil Washing, all site soils and sediments
will be washed/extracted in this manner, while in the Soil Flushing/
Biodegradation, only soils under the process facility will be
washed (or flushed) with this solution. Therefore, the quantity of
toxic residuals is expected to be far greater for Soil Washing. In
the case of Soil Flushing/Soil Biodegradation, extensive use of
biodegradation will reduce the generation of such residuals.
The Containment alternative provides a lesser degree of permanence
and will require considerable maintenance, and possibly, significant
repairs. Should the containment structure leak, contaminated media
will be in contact with groundwater. Since the compounds of concern
are not permanently destroyed, leachate exceeding risk based levels
would be released into the aquifer of concern should there be leakage.
The Disposal alternative provides a long term/permanent solution
"fbr~the"L.A~. Clarke site. However, all wastes would be relocated to
a landfill. SARA specifies that landfilling without treatment is
the least preferred option.
Reduction of Mobility, Toxicity or Volume
The Soil Biodegradation and Incineration alternatives both permanently
destroy the compounds of concern, thus reducing the toxicity and
volume of the waste to levels which do not present an unacceptable
risk to the public.
The Soil Washing and Soil Flushing technologies do not reduce the
toxicity of the compounds of concern. Rather, the contaminants of
concern are removed from the soil/sediment and residuals are disposed,
thus reducing the volume of contaminated soil/sediment.
The Disposal alternative may temporarily reduce the mobility of the
contaminants of concern via placement in a secure landfill. Neither
the volume or toxicity of contaminants would be reduced.
-35-
-------
The Containment alternative would reduce neither toxicity nor
volume. The mobility of waste would be reduced by stabilizing
the waste of concern via a solidification process. However, due to
the high water table on-site, the cell would likely remain in close
proximity to, or in contact with, the groundwater. Therefore, reduc-
tion in mobility will be difficult to maintain on a permanent basis.
Short Term Effectiveness
Current conditions at the site do not present an immediate threat
to public health and the environment. All alternatives are expected
to take a minimum of two years to implement upon mobilization of
operations.
The Incineration and Disposal alternatives are expected to require
relatively shorter design periods than the other alternatives
and will require an estimated two years to complete remedial action
upon mobilization. However, transportation of contaminated materials
presents a short-term risk which does not occur with other alternatives.)
The Containment alternative is expected to have a similar implementation
time. However, the design of the containment system is expected to
be significantly longer than that required for Incineration or Disposal.
The Soil Washing, Soil Flushing/Soil Biodegradation and Soil Biodegra-
dation alternatives are all expected to require significant design
studies prior to mobilization and implementation of remedial action.
In each case, bench and pilot scale studies would be required during
the design phase. Once mobilized, Soil Washing and Biodegradation
operations are estimated to be completed in three years, while Soil
Flushing/Biodegradation is expected to take five years.
Any short term impacts to public health or the environment will be
prevented by designing remedies to meet ARARs of concern e.g. those
addressing discharges to air, groundwater, surface water and those
addressing activities within wetlands. The ARARs of concern have
been identified in the Description of Alternatives. To assure the
prevention of short term impacts, monitoring of air and water shall
be conducted both during and after the implementation of the selected
remedy. Air monitoring will be of importance during excavation.
Implementability
With the exception of the Containment and Soil Flushing/Soil Biodegra-
dation, all alternatives require the removal process buildings.
These buildings are actively being used at this time. Therefore,
building removal is expected to be a significant constraint for
any such alternative.
-36-
-------
The Soil Flushing/Soil Biodegradation alternative would address
soil contamination below the process buildings via in situ treaement
technologies, thus avoiding the necessity of building removal. How-
ever, removal and treatment of the surface soils of concern around
the facility under this alternative is expected to be difficult.
Maintenance of the soil cover placed after the completion of treacment
should be difficult with ongoing plant operations. In the same
manner, the maintenance of the cap required under the Contairment
alternative (which also does not require building removal) is also a
potential impleme~tation concern. Maintenance of the cap in the
Containment alternative is espec~ally important due to the relatively
high toxicity of materials within the contained cell.
Should the building be removed, Incineration or Disposal could be
implementable. However, a primary imp1ementability constraint would
be the capacity and availability of facilities to handle and accept
the large quantity of contaminated soil/sediment. In the case of
incineration, the material is expected to have a very low heating
value, adding to implementation concerns. In the case of disposal,
landfilling is likely to be prohibited by Land Disposal Restrictions.
Soil Washing and Soil Biodegradation are on-site treatment techno-
logies which could be implemented with building removal. Soil
Biodegradation would be more implementab1e should some in-place
landfarming be part of the remedy. Soil washing would involve the
excavation of all soils exceeding target cleanup levels. Generally,
both these two alternatives and Soil Flushing/Soil Biodegradation
are expected to require more design studies than the other alterna-
tives to identify the specific treatment system suitable for the
site. These studies would be most extensive for Soil Flushing/Soil
Biodegradation due to the use of two different technologies. .
Cc:rrmuni ty Acceptance
The public has expressed dissatisfaction with goverrment actions
regarding L.A. Clarke. Local residents do not understand why the
company has been allo'Ed to operate for so long while in violation
of its discharge peanit. Although air emissions have been reduced
in recent months, odor complaints persist.
The attitude of the public toward ongoing Superfund action is also
one of diuatisfaction. Many residents are skeptical of the treatment
.technology proposed in the preferred alternative and are unhappy
wi th the length of time projected for the cleanup. They have pointed
to the L.A. Clarke facility in Hollywood, ~., where similar treat-
ment was attempted and failed, as an example of what may happen here
. It cannot be said that the public has accepted the preferred alternative.
However, many residents have indicated they would not oppose the
cleanup if it can be shown that it will work. EPA has agreed that,
if the preferred alternative is chosen, the agency would provide the
public info~tion fram the design plans and bench scale studies
preoeeding cleanup Dmplementation.
~37-
-------
Cleanup alternatives were proposed by two members of the carmunity,
each involving contaii'rnent. EP~ has explained that contairnent may
not provide a pecnanent solution to site contamination, and is
discouraged by agency policy. Theccmnuni ty at large has not voiced
support of containment options.
State Acceptance
The Ccmnonweal th of Virginia has recarmended the selection of the
Soil Flushing/Soil Biodegradation alternative should the process
buildings remain in place. Should the process buildings be removed,
virginia has recommended the selection of the Soil Biodegradation
alternative.
Cost
The Present Worth estimates for the alternatives are as follows:
Alternative 1 - No Action
Alternative 2 - Soil Extraction
Alternative 3 - Soil Flushing/Biodegradation
Alternative 4 - Soil Biodegradation
Alternative 5 - Containment
Alternative 6 - Off-Site Incineration/
Off-Site Disposal
$ 591,999.
$ 28,956,999.
$ 23,498,999.
$ 21,999,999.
$ 29,346,999.
$ 76,137,999.
$ 69,563,9"".
See Evaluation of Alternatives Table for further cost breakdown
and a summary of the comparative evaluation.
-38-
-------
- Al te
-______l
(I) No
(2)
I
l..>
\0
I
(3) In
F
Blodeg
(4) S
Blodeg
(5) Con
(6)
Of
01
Incln
Evaluation of Alternative Table
- .__.~.._._---- - -------
Protective of
e--p!:_~_~er:~--*l__--___-------- lIuman lIealth
and the
csent Worth TOTAL F.nvlronment
& H Present Worth
---,------ ----- -- - ------------"~ ----.--------
No . 50 lIs
exceeding
target
c lelln up levels
would remain.
. =-----~_st (In HIlllons $. !.x!,~
rnatlve Initial Present Worth Pr
'L__- Capital Implementation 0
--- ~---
Action $14,000.* $50
-
. ...-_u.
Soil
actton $2.453 $26.470 $33
-
Situ
lushlngl $2.295 $21.080 $33
radlltlon
--
011
raciatton $2.990 $18.961 $33
talnment
$1.215 $18.818 $31
f-Slte
spos81 $63.5761
eratlon
$48.002 $l1.021 $3
Extr
7 ,000. *
$581,000.*
-- - - -- -.-.- ---- - - .- --.----.- n___- ---"- .- ---"- --- -
900.*
$28.957
-----------.---- .---
900.*
$23.409
_.~---- ---
900.*
$21.991
------
3,000.*
$20.346
3,900.*
$76.1371
$60.563
Yes. AI180l1s
exceeding tar-
get clean up
levels shall be
treated on-site
to meet such
levels.
Same as
Alternative 2
5".lIe 8S
Alternative 2
Yes. All so11s
exceeding
target clean-up
levela shall be
contained.
Yes. All soils
exceeding
target clean-up
levels shall be
re.oved from
the site.
Compliance
with
ARAR's
------------
No. Cheml ca I
s peel f t c ARARs
Ident (fled for
soils shall
continue to be
exceeded.
Yes. All
ARAR's are
expected to
be met.
Same as
Alternative 2
Same as
Alternative 2
Hay not
meet ARAR' s
addressing
RCRA land-
f11la.
ARAlls are
expected to be
met with
Incineration.
!Disposal of
untreated soil
Is 11 ke1r to
~e fr~~t61~eg-
811 lestr cf
Long Term
Effectiveness 6.
Permanence
-
NONE.
.--
Contaminants are
extracted from
soils. Residuals
are disposed
off-site.
5011 contaminants
above clean-up
levels are either
destroyed on-site
or extracted for
off-site disposal
5011 contaminants
above clean-up
levels permanent I
destroyed.
Contaminated soil
are contained on-
site. Permanent
containment
unlikely without
slgntf lcant
uintenance.
With incineration
organic 80il con-
ta.inants above
clean-up levels
destroyed.
With disposal.
such sol18 are
landf 11 led
(nof permanent).
-------
Alternative
( ')
(I) No Action
---
(2) Soil
Extraction
(3) In Situ -
Plushln,l
Ilode.radatlon
( 4 ) So II
Ilode.radatlon
Evaluation of Alternative TabJe (con't)
Reduction of "obility
Toxicity or Voluae
No reduction of 80btllty
toxldty or Vot....
Extraction technolo8J
ell.lnate. .011 yolu.e
exceedln, cleanup leyels.
Toxic re.ldual. dl.poaed
off-site.
Plushlna technolOlJ pro-
duces toxic re.ldual. for
off-.lte dlspo.al. Ilode-
Iradatlon via land far.-
Inl destroys toxlcs above
cleanup leve".
IlodeRradatlon via land-
far.lnl destroys toxlcs
above clean-up levels.
Toxicity and v~lU8e of
cont..lnated soil Is not
reduced. Rather, the soil
Is contained to reduce
80bllI t Y .
--------f- -
(6) Off-Site Incineration destroys
Inclneratlonl toxic orlanlc conta.lnants.
Disposal DI.,osal ..y te.porarlly
reduce .obility.
(~) Contaln.ent
Short Ter.
Effectlvenes8
Current l.pact8
shan continue.
De811n and
8Onltorlnl shall
prevent any short
ter. risk due to
excavation and
treat.ent.
Sa.e as
Alternat lye 2
Sa8e as
Alternst he 2
Sa.e 88
Alternative 2
l.pJe8entabIJlty
Readily l.ple8entable.
lulJdlnl re.oyal
required. De.lln
studies are expected
to conflr. 1.-
ple.entabllt ty.
Deslln studies for
tvo different techno-
JOlles expected to
conflr. l.ple8ent-
abillty.
Sa8e aa
Alternat Ive :)
Maintenance of the valls
and cap of the contaln-
.ent cell Is expected
to be difficult.
---------------- ------
Transportation of Availability/capacity
conta.lnated of facilities to handle
..terlal shall the .aterlals of concern
present a short Is questionable. Dls-
ter. risk. p0881 18 likely to be
prohibited under RCRA.
_.-
CO.8Un It Y
Acceptance
Unacceptable to
co_unity.
No preference
for thh
alternative h..
been expressed.
.
Appears
acceptable
provided the
re8edy work. and
short-ter. 1.-
pacts are pre-
vented.
s..e a8
Al ternat he :)
One local resi-
dent ha. pro-
po.ed the
.electlon of a
variation of
thl. alternative.
Mo preference
for thh alter-
natt.e has been
expre..ed.
State
Acceptance
Mot pre-
ferred.
Not pre-
ferred.
Preferred
alternative
should the
process
facH Ity
re_In In
place.
Preferred
alternat lye
should the
process bulld-
I nl be re.oved.
Not Preferred.
I
o
-:t
I
Not Preferred.
-------
SUMK\RY OF COMPARATIVE ANALYSIS
Alternative 1, No Action, is not protective of human health and
the environment. Therefore, it should be eliminated from further
consideration.
Among remaining alternatives, all are expected to be protective.
However, all remaining alter~~tives are not expected to meet ARAR's.
In particular, Alternative 4, Containment, and the diSposal, option
of Alternative 6 are not expected to meet RCRA MAR's.
Alternative 3, 4 and the incineration option of 6 each rate highly
in long teen effectiveness and pez::manence. In each case, risk
based levels of PNAs and benzene in soil are achieved via pecnanent
destruction of these compounds. Alternative 2 removes these conta-
minants from the soils of concern for off-site disposal,
while the disposal option of Alternative 6 involves the disposal
of all soil exceeding risk-based cleanup levels offsite. Alternative
5 nei t.~er destroys nor re:noves contaminants from the si tee ~
containment proposed within this alternative has a lesser degree of
pemanence compared to the other al ternati ves.
Alternatives 3, 4 and the incineration option of 6 also significantly
redu:::e the toxicity and volune of contaminated soil. Alternative 2
redu:::es the volune of contaminated material to treatment residuals.
The disposal option of Alternative 6 does not decrease the mobility,
toxicity or volune of of the waste. Alternative 5 would reduce only
the mobility of on-site contaminants.
Short tem impacts to public health and the environment would be
prevented via design and close monitoring. In the case of each
al.ternative,at -least two years would berequired--toimplement- .
the remedy. In the case of Alternative 6, a short teen health risk
shall occur due to the transport of contaminated material.
-- - ---- -- -- -----
Alternative 3 is expected to be implementable upon the completion
of design studies to identify the specific process for the
site. These studies would be bench and pilot scale and would be
conducted for both the soil flushing and biodegradation technologies.
Alternatives 2 and 4 would also require bench and pilot scale
studies, but only for one technology. However, these al ternati ves
can only be fully implemented with the removal of the facility.
Alternati..~ may be difficult to implement due, to limited landfill/
incinerator capacity and would require facility removal as well.
Due to active operations, the cap installation of Alternative 5
may not be implementable.
Generally, the community has not expressed a preference for any
, particular al ternati ve. Rather, they are concerned that the remedy
be effective and that adverse short-teen impacts on h\Dan health
during remedial action be prevented.
The Commonwealth of virginia has expressed a preference for Alternative
3 should remedial action be undertaken with the process building in
place. Should the facility be removed, virginia prefers Alternative 4.
-41-
-------
SELECTED RD4EDY
Alternative 3, In Situ Soil Flushing/Bioreclamation and Soil
Biodegradation via Landfarming, achieves the best balance in meeting
the evaluation criteria and is therefore the recommended remedial
action for the site. This alternative utilizes on-site biological
and chemical treatment to permanently destroy hazardous compounds
in soil/sediment which present a threat to human health and the
environment. This Alternative achieves a long term, permanent solu-
tion and is readily implementable. It should be noted that Alternatives
2,4 and 6 would be similarly effective if the active process facility
were removed. However, Alternative 4 would achieve the same result
at considerably less cost. Therefore, should the facility be removed,
Alternative 4, Soil Biodegradation via Landfarming, may replace
Alternative 3 as the Remedial Action.
As 'required by Section 121 of CERCLA, Alternative 3 is protective
of human health and the environment, reduces the volume and toxicity
of contamination, will attain ARARs, and utilizes permanent
solutions and alternate treatment technologies to the maximum extent
practicable. In addition, the selected remedy satisfies the statutory
preference for employing treatment which significnatly reduces the
mobility, toxicity and/or volume of hazardous substances as a princi-
pal element. This alternative is a most cost effective solution in
that it achieves the Remedial Action Objectives and meets the best
balance evaluation criteria at the least cost.
This remedy will be protective by reducing soil/sediment concentra-
tions to levels protective of the aquifer of concern for drinking
water purposes and protective of those persons potentially
or actually coming into direct contact with the contaminated soils/
sediments. These levels are also protective of aquatic life in
downgradient surface waters. The design of the remedy and monitoring
before, during and after remedy implementation will control contami-
nant releases during remedial action. Institutional controls neces-
sary to maintain the site after remedial action shall be developed.
Upon completion of the remedial action, a review of the effectiveness
of the remedy shall be conducted every five years to assure on-going
protection of human health and the environment.
All Federal, State and local ARARs will be met by the selected
remedy. The ARARs of concern are identified in the ARAR Compliance
Matrix.
-42-
-------
SIGNIFlCAlfl' ~ES
The EPA has reviewed all corrments subni tted both verbally and in
writing during the public corrrnent period. Upon review of these
carments, it has been detetmined that no significant changes in
the preferred alterntive(s) as presented during the comment period
are necessary.
-43-
-------
ENFORCEMENT SUMMARY (Confidential)
L.A. Clarke and Son, Inc. of Spotsylvania County, Virginia has operated
at its present site location since 1937. Until 1980, the property was
owned by the Richmond, Fredericksburg and Potomac (R,F & P) Railroad
and leased to L.A. Clarke and Son, Inc. In 1976, L.A. Clarke purchased
the property.
Notice letters were sent to L.A. Clarke and Son, Inc. and R,F & P Railroad
on March 4, 1985, offering these parties an opportunity to conduct the
RIfFS. Both parties declined to undertake the RI/FS. The RI/FS was
completed by the EPA in February, 1988.
On February 9, 1988, EPA sent CERCLA Section 104(e) letters to four poten-
cial responsible parcies (PRPs) to gain i..formation about the site. On
~arch 22, 1988, EPA sent special notice letters to the following six
potential responsible parties, notifying these PRPs of their potential
responsibility to conduct the Remedial Design/Remedial Action (RD/RA)
and establishing a 120 day moratorium period for RD/RA negotiations:
o L.A. Clarke and Son, Inc.
o Richmond, Fredericksburg and
o Westvaco
o Woodduck Partners
o Solite Corporation
o ~ssaponax Sand and Gravel
Potomac Railroad
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C0fMJN1'I'Y RELATIONS HIS'roRY
Public participation requirements in Section 113 (K) (2) (B) (i-v)
of CERCIA have been met. Specifically, the ccmnuni ties in the
vicinity of the site have been notified of the Proposed Plan
availability and provided a summary of the plan via an announcement
in the local press on February 22, 1988, the opening day of the
3" day publ ic corrment period (see attached announcement). The
Administrative Record for the site has been placed in a repository
located wi~~in the Spotsylvania County office.
A public meeting to discuss the proposed plan was held on March 9,
1988. The meeting was very well attended by local residents, who
showed ~~eir continued concern with the site.
Prior to this public meeting, primary cammunity concern with the
site was focused on air ~issions fran the continuing active
operations and groundwater contamination fran improper containment
of waste materials. This interest was evident during a public
meeting held to discuss the RIfFS Workplan. During the public
meeting of March 9, 1988, sane concern was still expressed regarding
continuing a~r emissions. These concerns were primarily related
to creosote odors. Concern was also expressed regarding potential
hane well contamination due to discharges fran the site. The
community was assured that EPA sampling had found no site-related
contamination of health concern in local residential wells. During
the March 9 meeting, residents also voiced concern over potential
impacts on neighboring Massaponax Creek. It was explained that
a survey of fish by the U.S. Fish and Wildlife Service had not
found a significant health threat associated with consumption of
fish from the creek.
Ccmnents during the meeting regarding the Proposed Plan are Sumtla-
rized and addressed in the Responsiveness Sl.ImIary within this
Record of Decision. Most of the comments questioned whether the
preferred remedy would work and be implemented in a manner which
would prevent short te~ Unpacts to residents. The community was
assured that the Remedial Design will specifically address these
two concerns. It was explained that the remedy would not be imple-
mented full scale until pilot studies during the design showed
that it '4IOJ:k8cS. In addition, residents were told that the design
would pJ:8¥8It any health impacts to res idents.
Considerable {"''-U8l11d'1ts during the meeting were directed at the
Virginia State water Control Board, which regulates the NPDES
discharges at the site. Re'1resentatives of this agen=y explained
that the facility may lose their NPDES peImit should they fail to
canply wi t.~ certain regulatory requirements in the near future.
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RESPONSIVENESS SUMMARY
FOR THE
L.A. CLARKE SUPERFUND SITE
SPOTSYLVANIA COUNTY, VIRGINIA
From February 22, 1988 through March 22, 1988, the U.S. Environmental
Protection Agency (EPA) held a public comment period on the Proposed Plan and
the Remedial Investigation/Feasibility Study (RI/FS) for the L.A. Clarke
Superfund site in Spotsylvania County, Virginia. The RI/FS and other
information utilized by the EPA to select a preferred remedial alternative is
included in the Administrative Record which has been available to the public
since the beginning of the public comment period. In addition, copies of the
Proposed Plan were distributed at the public meeting. The purpose of this
Responsiveness Summary is to summarize comments on these documents as
expressed by residents, local officials, and other interested parties during
the public comment period and EPA's responses to the comments. Public
comments have been submitted in writing and verbally.
SUMMARY OF MAJOR COMMENTS AND EPA RESPONSES
The public meeting was held at the Lee Hill Community Center on March 9,
1988 at 7:30 p.m. Those attending the meeting included representatives from
EPA, the Virginia Department of Waste Management, the Virginia State Water
Control Board, and the Virginia State Air Pollution Control Board, as well as
area news reporters, and approximately 100 residents. During the meeting,
EPA staff presented an overview of the events that had occurred at the
site, described how the Superfund cleanup program works, described the
proposed remedial alternatives, and explained why the EPA had recommended
Alternative 3 as the preferred alternative. Following this presentation, the
EPA answered questions from citizens about the proposed remedies and the
cleanup of the site.
Questions, comments, and concerns received during the meeting and
throughout the comment period are summarized below and are categorized into
the following topics: 1) Ground Water; 2) Nature of Contamination; 3) Health
Effects; 4) Soil Biodegradation; 5) Soil Flushing; and 6) Miscellaneous. Each
comment is followed by an EPA response. In addition to questions asked of
EPA during the meeting, citizens were given the opportunity to ask questions
of representatives of the State Water Control Board and the State Air Pollution
Control Board. These questions and responses are contained in the official
transcript of the meeting but are not addressed in this Responsiveness
Summary. The transcript Is available at the offices of the Spotsylvania County
Administrator, loote 208, Spotsylvania. Detailed comments submitted in
writing by the Richmond, Fredericksburg and Potomac Railroad are addressed
separately, but given equal weight in this Responsiveness Summary.
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GROUND WATER
Question: Several citizens asked questions about the extent of ground water
contamination in the deep aquifer underlying the site.
Response: EPA sampling of ground water from the deep aquifer underlying the
site has not detected any site-related contamination.
Ouestion: Several citizens wanted to kn~ hov the EPA w1l1 prevent
contamination from reaching the deep aquifer when ground water monitoring
wells are drilled through the clay layer into the deep aquifer.
Response: A double-cased well technique will be used to prevent contamination
of ~he deep aquifer while drilling through the clay layer.
Ouestion: A citizen asked whether contamination 1n the ground water 1s moving
and whether the EPA's statement that contamination is confined under the site
was correct.
Response: The EPA will conduct a thorough ground water investigation and
monitoring program during the remedial design, remedial action, and continuing
RI/FS studies, to further determine the nature and extent of ground water
contamination.
Question: Several citizens asked whether the contaminated ground water i8
moving off-site into residential wells. One resident stated that the EPA
found cadmium in well water and wondered if any action would be taken to
address this problem.
Response: Duri~ the meeting, residents were told that there were no site-
related contaminants at levels of health concern in local drinking water
wells. Phenol levels, well below health standards, have been detected in wells
t.?ot_tl- _up--gr_adieJ:lt and down gradient of the site. These levels-cannC?t-be
attributed to the site at this time. The EPA will conduct comprehensive
ground water investigations beginning this summer to better define the
nature and extent of site-related ground water contamination. EPA
added that several residential wells in the vicinity of the site contain
cadmium at levels slightly higher than EPA drinking water criteria. However,
cadmium contamination ha. not been detected at the site and the elevated
cadmium levels in well vater aay be due to natural conditions or corrosion
of pipes in water .yat.... Ground water contamination not related to the
L.A. Clarke site cannot b~dre.8ed as part of this project.
Question: A citizen a.ked whether the EPA would support a federal grant to
construct a vaterline to .erve the community.
Response: Result. obtained from residential well samples do not tndicate
that ground water contamination i8 related to the LA Clarke 8ite, thus a
waterline could not be funded under this Superfund response.
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Question; A citizen asked EPA to provide public water and sever lines
to all properties within 3/4 mile of the site.
Response: At this time, residential wells near the site are not being
impacted significantly from site contamination. This remedial action
and future actions should result in an improvement in ground water quality
near the site. EPA will continue to monitor ground water throughout the
project to be sure that residential wells are not contaminated.
Question; Several commentors suggested that ground water monitoring be
conducted during and after site cleanup activities.
Response; Ground water monitoring will continue throughout the project,
and for at least five years after completion.
NATURE OF CONTAMINATION
Question; A citizen asked whether site-related contaminants of concern such
as benzene and polynuclear aromatic hydrocarbons (PNAs) may become airborne.
Response: Benzene, which is a constituent of creosote, is a volatile solvent
which can become airborne.
Question: A citizen asked why the EPA did not find dioxin at the L.A. Clarke
site as it did at the Hollywood, Maryland site, considering the fact that both
sites are wood preserving facilities run by the same company. The citizen
added that the EPA did not find dioxin at the Hollywood site until it drained
the lagoon.
Response: Oioxin was found at the Hollywood site because the wood preserving
operations there used pentachlorophenol (PCP). which contains dioxin, while
the operations at L.A. Clarke did not use PCP. EPA further stated that more
than 200 samples taken at the L.A. Clarke site were analyzed and that none
were found to contain pentachlorophenol.
HEALTH EFFECTS
Question: A citizen asked about the human health effects of creosote.
Response: EPA responded that prolonged exposure to high levels of compounds
found in creosote is known to increase the risk of cancer.
Question; A citizen then asked about the cancerous lesions found on fish in a
nearby pond*
Response; The type of lesions found on the fish are the type that would be
associated with direct contact to high concentrations of creosote. The fish
may have been exposed to creosote deposited in bottom sediments of the pond.
Question; A resident asked whether contamination from the site is affecting
nearby creeks that flow into the Massaponaz River and whether the creeks will ever
be safe for recreational purposes.
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Response: Current information does not indicate a significant health risk
associated wi~h fishing or hunting in the area down-stream from the site.
SOIL BIODEGRADATION TECHNOLOGY
Question: A citizen asked whether soil biodegradation is the same approach
used at the Hollywood, Maryland creosote site and expressed concerns about the
effectiveness of the technology.
Response: The technology proposed for the L.A. Clarke site and the technology
attempted at the Hollywood site are basically the same. A critical factor in
implementing this technology is proper maintenance. The procedure was not
effective at the Hollywood site because it was not properly maintained. This
operation was not conducted or supervised by the EPA.
Question:
.
Citizens asked many questions about the biodegradation process.
Response: The type of bacteria that exist at the site have not been
identified at this time. Bacteria are naturally occurring at the site but the
proper conditions must be maintained for the bacteria to work effectively.
The bacteria must be "farmed" to create the proper environment. Specifically.
the soil must be tilled to supply more oxygen. and nutrients added to
promote bacteria groWth. This will result in biodegradation of creosote
and a reduction in the levels of contaminants.
Question: Citizens asked how the "bugs" (bacteria) digest creosote and what
happens to the "bugs" over time.
Response: The bacteria will "eat" the creosote. and destroy it in the
process. The bacteria metabolize toxic compounds found within creosote and
convert them to non-toxic compounds.
Question:
___site.
A citizen asked whether land farming would create odors at the
Response: Air monitoring will be conducted during the remedial action to
ensure that the odors at the site do not exceed rules and regulations
which address odors and air emissions. If odors are detected at levels
exceeding the regulations. activities at the site will be stopped until
the problem is corrected.
Question: A citizen a8ked bow the EPA would dispose of dirty water from
the land farm area.
Response: Cont_1nated water generated during the cleanup operations will be
treated on-lite. Toxic relidual8 that exist in the water will either be
biodegraded on-11te or dilpoledof off-site.
SOIL FLUSHING TECHNOLOGY
Question: One resident asked whether contaminants would move into the bedrock
aquifer when extraction wells for 8011 flushing are installed. A res1dent
asked whether the EPA would be responsible for any contamination that might
occur 1n residential wells due to the installation of the extraction wells.
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Response: The clay layer separating the shallow aquifer from the deep aquifer
Is likely to prevent contaainants from entering the deep aquifer. Ground
water monitoring will be conducted to ensure that chemicals are not entering
the deep aquifer.
Question: A citizen asked what type of soil flushing solution will be used
and how the EPA will prevent the solution from spreading laterally under the
ground after it is injected into the soil.
Response: Studies will be conducted to determine the most effective soil
flushing solution for conditions at the site. Small-scale tests of the
technology will be conducted before it is fully implemented, drilling one well
at a time to determine the best procedures for containing and recovering the
solution.
COMMUNITY RELATIONS
Comment: Several citizens expressed doubt that their views would be
considered before a final decision was made.
Response: A final decision cannot be made without addressing and answering
comments in the responsiveness summary. This summary is made part of the
Record of Decision (ROD), and includes all oral and written comments received
during the comment period. Copies of this summary will be made available to
the public.
Question: A citizen asked why more public meetings had not been held.
Response: During the Work Plan public meeting, residents were told that the
next regularly scheduled meeting would be at the conclusion of the FS. At
that time, EPA officials said they would meet sooner if requested. If
anyone desires a meeting when the final ROD is signed, they should contact
EPA.
Question: Several citizens asked what type of follow-up to the public meeting
EPA would conduct.
Response: EPA will mail a notice to announce the Record of Decision after it
is signed. EPA also offered to return to the community to explain the Record
of Decision. The sit* Administrative Record, which will contain site records
- including the public meeting transcript - pertaining to the decision, will
be placed in tb* County Office Building. EPA may hold a public meeting at the
start of the ground water investigation.
MISCELLANEOUS
Question; Residents asked how long the proposed recommended cleanup process
would take.
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Response: The schedule for the cleanup depends, to a great extent, on the
results of field tests conducted during design. The soil flushing and
land farming technologies require approximately five years to complete. EPA
stated that the design of the cleanup will begin this summer and may take
approximateLy year to complete.
Question:
complete.
A citizen asked how long the other FS alternatives would require to
Response: Soil flushing will require approximately three years to complete;
soil biodegrada~ion without soil flushing would require approximately three
years; and containment, off-site disposal, and off-site incineration would
each take approximately two years.
Question:
A citizen asked who makes the final cleanup decision
Response: The EPA Region III Regional Administrator makes the final decision
based on staff recommendations, technical reports and the Responsiveness Summary.
Question: A citizen wanted to know who would fund the cleanup at the site
aad whether the EPA has funds available for the cleanup.
Response: The EPA is prepared to conduct and pay for the cleanup using money
from the Superfund Trust Fund. EPA will first negotiate with potentially
responsible parties to encourage them to conduct the clea~up. If the
negotiations fail, EPA policy i8 to conduct the cleanup and take legal action
against the potentially responsible parties to recover cleanup costs.
Comment: Several citizens have requested that EPA shut down the facility
as part of the remedial action.
Response: At this time, EPA's Superfund program 1s not 1n a position to
shut this facility down. The Virginia Water Control Board is reviewing the
-- -facil-it-y'sdi-scharge permit-,-and is-constd-ertng -revoc-at1~n -of the--penilH.---
EPA 1s committed to working with the site owners to implement a cleanup which
will allow operations to continue.
- --.-T --- - --.-.
Question: A local family asked what guarantee would be issued to be sure
the cleanup is monitored constantly.
Response: Although the agency cannot give guarantees, it is committed to
making sure the cleanup i. iaplemented properly. Cleanup techniques will
be tested before t8pl..entatioD, and citizens will have the opportunity
to review the pro.rel. of tbe project.
Comment: Several citizen., including one who subaitted a two-page cleanup
plan, sUigelted that that best way to address contamination would be
to contain it on site.
Response: It is EPA's policy to el1minate or reduce contamination
from Superfund sites whenever possible. Because this goal is feasible at
the L.A. Clarke site, it must be given strong consideration.
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Comment: The government should set up an advisory panel comprised of
government representatives, potentially responsible parties and adjacent
landowners. This panel should review all cleanup steps taken.
Response: EPA has sought input from these entities throughout the project.
However, the agency will consider establishing such a review panel if it
1s desired by all parties involved.
Comment: EPA should cons~r'lct recreational facilities on the site when
the cleanup is complete.
Response: At this time, it 1s impossible to determine an appropriate future
use of this land. This suggestion will be considered.
Question: A local landowner asked EPA not to spend $23 million cleaning
up this site when cheaper alternatives are available.
Response: To date, EPA has seen no proposal which effectively addresses
contamination at the L.A. Clarke site and is significantly less costly
than the preferred alternative.
Question: Owners of property adjacent to the site asked whether they
may review worplans describing future EPA activity or comment on future
remedial actions.
Response: All workplans will be available at the Spotsylvania County
Administrator's Office. Extra copies can be obtained through EPA Region
III. All future remedial action will be subject to a 30-day public
comment period.
Question: An adjacent property owner asked that EPA cleanup activities
on his land not disturb his operations.
Response: EPA will work with the landowner during cleanup activities.
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Additio~al Comme~ts
Comment: Several citizens have requested EPA shut down the facility as
part ot the remedy.
Response: At this time, EPA does not have the legal authority to shut
down the fad 1 i ty. HO\Oever, should the fad li ty be shut down by the si te
owners or by other means, the EPA may implemsnt Al ternati ve 4, Soil Biode-
gradation via Landfa~ing. This alternative involves the removal of the
facility and excavation of ~rlying contaminated soils for treatment
on-site. .
Comment: Several commenters have suggested that groundwater
monitoring be conducted during and after the site clean-up activities.
Response: The EPA plans to conduct groundwater monitoring before,
during and after the site-cleanup. Both on-site moni toring wells
and residential wells shall be sampled regularly. Groundwater
monitoring shall continue for a minUnum of five years after the
cleanup is canpleted. In addition, air monitoring shall be conducted
during site clean-up.
Comment: Several residents have suggested various foens of containment
to address the soil/sediment contamination problem at the site.
These suggestions range fram lining the entire site with clay
to containing leachate with trenches.
Response: A containment alternative has been evaluated by EPA in the
RI/FS. EPA does not prefer this alternative because the hazardous
substances of concern will remain on-site. Containment to prevent
t.1-je migration of .t.1-tese substances is not likely to be petmanent and
will require continual maintenance. The EPA prefers to destroy the
hazardous substances through treatment to elUninate the possibility
of migration of these substances through the leakage of a contain-
ment structure.
Ccmnent: One cacmenter suggested that the alternative selected
should inclooe the construction of a recreational field at the site
after cleanup.
:e~e-= :A ~p~~~r~~ a a;:~:~i~~~~~e~: precl\Xie
Cl..&&aI8n'1t: An owner of property adjacent to the site has asked
whether they may review worJcplans describing future EPA activity
at the si te or catment on the selection of any future remedial
actions at the site.
Response: All worJcplans will be available in the Administrative
Record for the site located in the Spotsylvania COunty Office.
Wri tten copies may also be requested of EPA through the Freedan
of Information Act. All future remedial actions will also be ~
ject to a 30 day public comnent period.
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Stoel. Rives, Boley, Jones and Grey has submitted comments on behalf of the
Richmond, Fredericksburg, & Potomac Railroad Company to the EPA Within the
thirty day public comment period. One set of comments, dated March 18, 1988,
was provided to the EPA on March 18, 1988. A second set of comments was
submitted to EPA on March 22, 1988. Both sets of comments are part of the
Administrative Record.
Below are EPA responses to the comments noted above.
comments, please see the Administrative Record.
To identify the specific
St1MM.ARY OJ' IU"'P RAILROAD COMPANY
KARCH 18TH COMMENTS AND BPA RESPONSBS
Response to Comment I.A.l and I.A.2, 3/18/88, p. 1:
Contaminants found in the sediments and soil above health based
risk levels will be removed and treated. Also see response to
Comment A.l of 3/22/88.
Response to Comment I.A.3, 3/18/88, p. 1:
Dilution appears to be a major factor in the reduction of PNA
concentrations across the site in the wetlands. Other factors
may also playa role. In either case, surface water PNA
concentrations have been documented at a variety of locations on
and off-site and this pathway does not appear to be a major
contaminant pathway. Regarding attenuation mechanisms, also see
response to Comment 8.2, 3/22/88.
R..poa.. to Comment I.A.4, 3/18/88,
p. 1:
The relative importance of migration pathways has been assessed
and the analytical and hydrogeological data from the RI used in
modeling for current and future scenarios.
R.spons. to Comment I.B.l, 2 , C, 3/18/88, pp. 1, 2:
The RI states on page 5-7 that creosote "is a complex mixture of
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hundreds of organic compounds, many of which are polynuclear
aromatics, which vary in composition from source-to-source. When
released to the environment, the components of creosote are
subject to differential che~ical fate and transport processes."
In fact, all CPNA's do not travel at exactly the same rate. The
most cost-effective RI approach chosen was to utilize a screening
method for analysis of a very large number of samples for TPNAs
and analytically determine a representative fraction of the
CPNAs. However, the Public Health Evaluation does account for
the different migration rates for TPNAs and CPNAs through the use
of different partition coefficients (KD). Also see the response
to the 3/22/88 Comment A.9. .
The RI also states on page 5-8, "some of the exposure scenarios
to be assessed in this PHE require an assessment of total PNAs
(TPNAs) and others use only carcinogenic PNAs (CPNAs). During
remediation, verification sampling can focus on TPNAs, CPNAs or
an individual CPNA should that be deemed appropriate.
Response to Comment II.A.l, 3/18/88, p. 2:
The UV ~~ta accurately describes TPNA concentrations. During the
validation process it was determined that in all cases tested UV
.fl.uor~scence ..screening. .g.ave toj:al- .PNA .conc.enj:rations within.one._..
order of magnitude of total PNA concentration derived from GC/MS
analysis. Enhanced mixing of samples in the field would no doubt
have produced a better correlation between analytical methods.
Regardless, the correlation between TPNA and CPNA concentrations
was made via a regression model applied to the HSL data as
deta i 1 ed in Appendix K. Al so see response to Comment B. 2 ,
3/22/88.
R.spons. to Comment II.A.2, 3/18/88, p. 2:
See response to Comment 8.2, 3/22/88.
Respon.. to Comment II.A.3, 3/18/88, p. 2:
See response to Comment B.2, 3/22/88.
R.spons. to Comment II.B.1, 3/18/88, p. 2:
See response to Comment B.5, 3/22/88.
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Response to Comment II.B.2, 3/18/88, p. 2:
This is true, however, testing was not performed for PNA
metabolites and all PNA components of creosote.
Response to Comment III.A.I, 3/18/88, p. 2:
Home wells identified and sampled by EPA are upgradient.
Response to Comment III.A.2 and III.A.3, 3/18/88, p. 2,3:
Contamination characteristic of the shallow aquifer has not been
(to date) found in the deep aquifer in on-site wells monitoring
these zones. This does not preclude future migration or cross
contamination in off-site areas.
Response to Comment III.A.4, 3/18/88, p. 3:
The alluvial sands and silts which comprise the wetlands are in
fact the hydrostratigraphic equivalent of the shallow aquifer on
site.
Response to Comment III.B, 3/18/88, p. 3:
It is EPA policy to use an excess lifetime cancer risk level of
10-6 where applicable. As stated in EPA's addendum dated
2/18/88, "In this case, it is recommended that a 10~5 excess risk
is appropriate because 1) home wells highly likely to be drawing
from the aquifer of concern are upgradient of the site, 2) home
wells currently downgradient of the site are a significant
distance away and are not known at this time to draw from the
aquifer of concern and 3) development of home wells immediately
downgradient of the site in the near future is not likely."
Respon«« to-Comment III.C, 3/18/88, p.3:
In the future risk scenario "possible location" includes on-site
locations (i.e., within the site boundaries) not only locations
at the site boundaries.
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StnOIARY OP U'P RAILROAD COMPAlfY
l:ARCB 22ND COMM2NTS AH'D IPA RBSPONSBS
Respon.e to Comment A.l, 3/22/88, p. 1:
Surface water and groundwater sampling data is available from
previous private consulting and agency studies dating back to the
early 1980's (see Section 1.3.2) including numerous sampling
events on the 24 monitor wells installed by consultants for
L.A. Clarke and an EPA Site Investigation conducted by
NUS Corporation (FIT III) in 1983. The combined data from these
studies reflect "temporal and seasonal variation" in surface
water/groundwater quality and contaminant migration rates.
Because of the varying levels of quality assurance/quality
control (QA/QC) associated with the data, the current
questionable condition of the existing wells, and the absence of
background groundwater quality data, EPA Region III decided to
install a limited member of monitor wells to verify the existing
pool of information. Comparison of the results from the single
sampling event on the EPA wells with hic~~rical data is felt to
be sufficient to characterize groundwater and surface water
contaminant conditions.
While seasonal and other factors may cause variability in the
absolute concentrations of PNAs in surface waters at the same
locations at different times, the RI data reveals consistently
higher PNA concentrations in surface waters on-site.
Respon.. to Comment A.2, 3/22/88, p. 1,2:
The extent of surface soil contamination is detailed in the
extensive contaminant Depth Profiles table found in Appendix B.
Visual and analytical data from the over 100 test pits, trenches
and borings completed during the RI combined with historical
information (confirmed during the RI) on past disposal practices
over the past 40 years indicate the presence of numerous
scattered, isolated pockets of free-phase creosote, randomly
. distributed in the unsaturated zone. Considering some of these
deposits date back to 1953 (waste ponds north of the facility)
and are still present, there is little doubt that creosote and.
related by-products remain as a relatively constant source in the
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unsaturated zone for periods of 20 years or more. Owing to this
constant source over a prolonged period, monitoring of
dovngradient wells adequately defines contaminant rate in
relation to groundwater transport which is a main mechanism of
concern in this study.
Vertical profiles of contamination extent are provided in
Appendix B. The program approach concentrated on identification
and verification of "sources" (based on air photos, interviews,
field observations) which resulted in clustering of test pits and
the like rather than a systematic gridding of the site. While
gridding may have been more conducive to contour mapping, it
would not have been as effective in delineating source and
distribution.
Response to Comment A.3, 3/22/88, p. 2:
As stated in the response to Comments 1 and 2, groundwater
conditions are felt to be adequately understood based on the
volume of historical data available and the long-term presence of
the contaminants in the subsurface.
The multiplicity of sources verified in the RI in combination
with their associated "driving" mechanism (i.e. creosote below,
the water table produces a constant plume while dissolution of
product by infiltration in the unsaturated zone produces
intermittent enclaves or pulses of contamination) circumvent
"plume" characterization for any one particular area.
Data from existing wells located between the process facility and
the lagoon/soil pile showed high levels of PNAs. Free-phase
product was found on two occasions at the bottom of one of the
shallow wells in this area.
Response to Comment A.4, 3/22/88, p. 3:
Concentrations of CPNAs in soils, surface water, sediment and
groundvater have been determined, and these results have been
incorporated into the PHE.
Response to Comment A.5, 3/22/88, p. 3:
Total PNA concentration contours have been estimated from the
Contaminant Depth Profile data found in Appendix B, though not
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illustrated. Benzene profiles has been evaluated by
superimposing benzene data on the Contaminant Depth Profile
table.
Response to Comment A.', 3/22/88, p. 3:
The models presented in the Public Health Evaluation provide the
analysis of off-site contaminant migration rates suggested by the
comment.
Response to Comment A.7, 3/22/88, p. 3:
The creosote layer has been chemically characterized and its
depth from the surface and thickness have been estimated.
Hydrological characteristics will be estimated as necessary
~u~ing the treatability study phase of this project.
Response to Comment A.S, 3/22/88, p. 4:
EPA agrees that surface water does not appear to
migration pathway and that contaminant levels
significantly within a relatively short distance
outfalls. Regarding attenuation mechanisms, see
Comment B.2.
be a primary
decrease
of the site
response to
--. ------
-- -- --- --- -
. - -- --- --- .
- - ----- -
- - - - -- -.
Response to Comment A.9, 3/22/88, p. 4:
The different migration rates for TPNAs and CPNAs is accounted
for in the PHE through the use of different partition coeffi-
cients (KD) for the two different groups (Appendices Land M) .
Response to Comment A.l0, 3/22/88, p. 4,5:
Based on the RI/FS phenol results alone, it is agreed that a
conclusion of "not detected" would be. appropriate based upon
strict CLP-definitions and the RI/FS round of residential well
sampling alone, however, the similar results obtained by other
agencies warrant the noting of the low levels.
Response to Comment 1.1, 3/22/88, p. 5:
Institutional controls such as Virginia's law concerning minimum
casing requirements for wells are presently a topic of agency
debate. The debate centers on whether such controls preclude
protection of the shallow aquifer.
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Until guidance or policy is established, the goal of protecting
the shallow aquifer cannot be ignored.
The reviewers overlook the current use scenario exposure to
workers under which upper bound excess lifetime cancer risks of 1
x 10-5 and 3 x 10-3 are estimated for the average and. plausible
maximum cases. These risks may be underestimated by as much as a
factor of 10 since they do not include the skin cancer risks
associated with PNAs, nor do they include potential health
effects associated with non-carcinogenic PNAs.
Similarly, the reviewers overlook the plausible maximum risk from
fish ingestion which is 10-3. Studies of aquatic life in the
Massaponax (Table 4-18) indicate numerous edible fish species
including bluegill, bass, perch, and pickerel in the Massaponax.
Therefore, an assessment of the risks from fish ingestion is
appropriate. - -
With respect to assessment of the shallow aquifer, it is not
clear why a single sampling event is not acceptable to the
reviewers for shallow groundwater, whereas a single sampling
event is acceptable for surface water or the deeper aquifers.
Clearly, additional sampling would provide greater certainty to
the risk assessment. However, the data used in the assessment
are valid results, and are reasonable considering the high level
of soil contamination. We have assumed that the shallow aquifer
contamination is extensive in both areal extent and depth, this
is reasonable given the extent of soil contamination.
Consequently, there should not be any dilution effect from a
pumping well.
Benzene concentrations predicted for the deep aquifer are
predicted for 1 to 100 years from the Dresent. The fact that
contaminants are not currently in the deep aquifer, therefore,
does not invalidate the model.
Respon.. to Comment B.2, 3/22/88, p. 5:
See response to March 18th Comment II.A.l.
. As stated on page 5-7 of
organic compounds only a
Hazardous Substance List
creosote components not
the PHE, creosote contains hundreds of
small subset of which are PNAs on the
(HSL). Of particular concern among the
on the HSL are carbazole and other
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~~trogenous organics which are themselves carcinogenic or which
may interact synergistically with the potent carcinogenic
benzo(a)pyrene. Consequently, the UV screening cannot be said to
overestimate the concentrat.ions of PNAs simply because it does
not correspond to the HSL analyses.
Of the four attenuation mechanisms for PNAs listed by the
reviewers, volatilization is not considered by Callahan et ale
(1979) as an important mechanism. Callahan also notes that
biodegredation for PNAs of great~r than 4 rings (which includes
the CPNAs) is a slow mechanism. Adsorption cannot be considered
a complete attenuation process because sedimentation may be
resuspended and transported downstream, and because contaminants
in sediments may enter the food chain through benthics and bottom
feeders. Only photolysis may result in any significa~t breakdown
of PNAs, however no reliable literature values are available to
incorporate photolysis into the surface water transport model.
Consequently, not including these mechanisms ir the transport
model may result in some overestimation (as no~ed in Section
5.5.3, Risk Assessment Uncertainties); however, the level of
overestimation does not invalidate the analysis. The model
predictions are born out by the sampling results from the RI.
The reviewers overlook the first prediction of surface water
concentrations listed in Table 5-3 which predicts PNA' levels
- ~-betweenO-.057 ug/luand -5.8--ugI1-.-which--a-rebe-low.-the- 10 ug}r--- ---- -- -
detection limit for samples taken from Massaponax Creek. -
Respons. to Comment 8.3, 3/22/88, p. 6:
As stated above, the lack of detectable PNAs in surface water
does not indicate that PNAs are not leaving the site. Predicted
annual average concentration for PNAs are below detection limits.
Higher levels are undoubtedly encountered during and following
periods of storm runoff. The use of average soil and groundwater -
concentrations may overestimate loading rates since samples were
mainly collected from contaminated areas. However, the sampling
effort was sUfficiently extensive that this overestimation is not
believed to be very great.
R.spon.. to Comment 8.4, 3/22/88, p. 7:
As stated in response to Comment 5.1, it is not clear why the
reviewers accept the results of single samples for the deep
aquifer and surface water but not for the shallow groundwater.
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In any case, the shallow groundwater samples are valid results
and they are reasonable given the level of soil contamination.
The model predicts concentrations in the deeper aquifer at
intervals of 1 to 100 years from the 9resent. Therefore, the
lack of detectable benzene in the deeper aquifer does not
invalidate the model.
R.spons. to Comment 8.5, 3/22/88, p. 7,8:
Table 4-18 identifies several edible fish species observed in the
Massaponax Creek. Many of these species including largemouth
bass, bullhead and perch could easily be expected to reach sizes
of one to two pounds. Consequently, it would not be difficult
for a maximallY exposed individual to obtain the 5.2 pounds of
fish per year used as the fish consumption rate in the risk
assessment.
Response to Comment C.l, 3/22/88, p. 8:
See response to Comment B.2
Respons~ ~o Comment C.2, 3/22/88, p. 8:
The risk assessment presented in the Public Health Evaluation
probably does overestimate risk. This was stated in several
areas of the report. The overestimation is due to conservative
assumptions which are used to place upper bounds on areas of
uncert~~nty. This practice is clearly based on EPA policy and
guidance on risk assessments conducted at superfund sites.
Respons. to Comment C.3, 3/22/88, p. 8:
Cleanup levels account for potential current and future exposure
pathways as identified in the Public Health Evaluation. Without
information on the quantities of material originally disposed of
at the site and the rate of disposal, or time-dependent monitor-
ing, degradation rates cannot be included in the development of
cleanup levels. .
Respons. to Comment C.4, 3/22/88, p. 9:
We agree that the reference to inorganic contaminants on page
6-18 should be omitted.
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R..pon.. to Comment D.l, 3/22/88, p. 9:
The estimated volumes of contaminated soils, sediments, creosote
layer and buried pit materials are sufficient to allow FS .
analysis and cost estimation.
R..pon.. to Comment D.2, 3/22/88, p. 9:
The existing data is accurate and sufficient to allow cost
evaluation of FS alternatives.
R..pon.. to Comment D.3, 3/22/88, p. 9:
It is agreed that a phased approach to Alternative 3 is efficient
and cost effective. A phased approach beginning with
treatability studies is planned. The off-site disposal and
treatment alternatives were included, in part, to (1) put other
alternatives into cost perspective, (2) answer the question, "How
much would it cost to simply remove the contamination from site",
and (3) comply with the CERCLA requirement of evaluating an
off-site alternative.
R.spons. to Comment D.4, 3/22/88, p. 9:
.-Air--moni-to~ing-wil1- -be- .-condu~-ted -du-ring---the-remedial--act-ion-to- m - --
ensure that the odors at the site do not exceed state rules and
regulations. If odors are detected at levels exceeding the state
regulations, activities at the site will be stopped until the
problem is corrected.
R..pon.. to Comment 1.1.&, 3/22/88, p. 10:
The residential wells identified during the RI/FS draw from the
shallow aquifer upgradient of the site and presently do not show
contamination related to L. A. Clarke.
R..pon.. to Comment I.l.b, 3/22/88, p. 10:
, Data from on-site wells into the shallow and deep aquifers shows
that there is presently no degradation of the lower water bearing
zone immediately below the study area. Future groundwater.
quality conditions are speculative, at best. .
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Response to Comment B.l.o, 3/22/88, p. 10:
See response to Comment B.1, 3/22/88.
Response to Comment B.l.4, 3/22/88, p. 10:
The use or non-use of an aquifer as future source of drinking
water would not be based solely on downgradient aquifer
characteristics (i.e., saturated thickness).
Response to Comment E.l.e, 3/22/88, p. 10:
See response to Comment 8.1.
Response to Comment B.l.a an4 B.l.}), 3/22/88, p'. 11:
It is EPA policy to use an excess cancer risk level of 10-6 where
appl icable, for the reasons detailed in the response to the
March 18, III.B Comment a risk level of 10-5 has been chosen.
Air standards are not appl icable or relevant and appropriate
requirements where groundwater contamination is concerned. EPA's
air standards are not risk based. The risk of 10-4 associated
with benzene under the NESHAPS program is a residual risk
remaining after the regulation is applied, not a goal of the
regulation. A 10-5 or 10-6 risk level is more in keeping with
standards for groundwater such as the MCL. While the input
parameters to the model are conservative, they are not overly
conservative given the available data. Parameters such as
organic carbon content, hydraulic conductivity, and polarity are
derived from analyses performed at the site.
Re.pon.. to Comment ..1.0, 3/22/88, p. 11:
Risks associated with the plausible maximum cases were on the
order of 10-3 to 10-6.
R..pon.. to Comment ..1.4, 3/22/88, p. 11:
The plausible maximum cases are based on the upper 95% confidence
limit of the geometric mean soil concentrations. Many areas of
the site exhibit contaminant concentrations higher than these
values, suggesting that under some circumstances risks could be
even higher. The model input parameters are by no means
arbitrary. They are based on information gathered from extensive
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field work at the site. Conservative assumptions have been used
in order to place an upper bound on areas of uncertainty.
RespODse to Comment 1.2, 3/22/88, p. 11:
In the future risk scenario, "possible location" includes on-site
locations (i.e., within the site boundaries) not only locations
at the site boundaries.
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The following are additional responses to contents submitted by
representatives of Richmond, Fredericksburg & Potomac Railroad:
General Comment; The validity of target cleanup levels for the site is
questionable.
Response; The Public Health Evaluation has found the No Action
alternative is not protective of human health and the environment.
Target cleanup levels have been established to achieve such protection.
As indicated in the Remedial Action Objectives section of the ROD,
these target cleanup levels shall be confirmed via studies in the
Remedial Design phase.
Response to Comment D.3, 3/22/88, p. 9:
The description of the recommended alternative provides that some soils
may be land farmed in place. It is also stated that where materials
cannot be landtreated in place, they must be excavated for treatinent.
Studies during the remedial design shall determine which soils can be
treated in place and which soils must be excavated for treatment in the
landfarm. In all cases, treatment must reach confirmed target cleanup
levels which are protective of human health and the environment.
Response to Comment B.I, 3/22/88, p. 5:
The shallow aquifer of concern is highly likely to be the source of
water for at least three home wells (see RI/FS Addendum of 2/18/88)
within 2000 feet of the site. Two of these are dug wells and are an
estimated 1000 feet from the site. The third is within an estimated 2000
feet and is a recently drilled well which apparantly meets the Virginia
regulations of concern. Additional residential wells within one-half
mile of the site may currently be tapping this aquifer. Future
residential wells within one half mile of the site may tap this
aquifer. Based on this information, EPA has determined that the aquifer
of concern should be protected for drinking water purposes.
Response to Coanent E.I.a, 3/22/88, p. 10:
Though upgradient from the site, there appears to be, at a minimum,
at leaat one residential well within an estimated 2000 feet of the site
which meets current Virginia regulations and draws water from the
shallow aquifer of concern. Based on this and other information
(see Response to Comment B.I above) information, EPA has determined that
the aquifer of concern should be protected for drinking water purposes.
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to A. CUR.KE & SO~!S SITE:
ADMI~!STRATIV[ RECORD* **
!~EX OF OOCl~~S
SITE !DE~!FICAT!ON
Bacilgrour.d
:) Report: Contract V83512, Geotechnical Engine.ring and Groundwater I!v~rology
Study for L. A. Clarke. Inc., by Schnabel Engineering Associates. 12/18/8~.
P. 1-167.
2) Hazardous Yaste Per=it Application. 9/10/82.
P. 168-171.
3) Hazardous Waste Permit Application (undated).
P. 172-116.
?A/SI Reports
1) Repor:: Site Inspection of l. A. Clarke & Sons, prepared under TOO No.F3-830'-
04, by SCS Corporation, 5/21/84. P. 1-286.
2) Report: L. A. Clarke Site. Frederick. [sic],Virginia. Initial Site Inspecilon
~. 8/26/85. P. 287-320.
* Administrative Record available 2/1/88. updated 2/18/88.
** Supportina Sa.plin, Data i. stored at the EPA Relioft III Central ReJional
laboratory in Annapoli.. Maryland.
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REMEDIAL ENrORC£MEN'l' PLANNING
Potent1ally Respons1ble Party Search
1) Letter to Hr. Mark Curtas from Mr. Stephen R. Wassersus re: 1nfo~ation
reque.t, 12/84. P. 1-4. A rece1pt for resistered mail is attached to
the letter.
2) Letter to Mr. John J. Newbauer from Hr. Stephen R. Wa..ersu, re:
request, 12124/84. P.5-7.
information
3) Letter to Ms. Em11y S. Chow from Ms. Susan R. Pierce re: info~at10n in
compliance with Mr. Stephen Wassersus's letter of December 24, 1984 to
Mr. John J. Newbauer, 1/15/85. P. 8-14. fwo lease. are attached to the
letter.
4) Letter to Mr. Mark Curtas from Mr. Stephen R. Wa..erlu, re: info~ation
request, 3/4/85. P. 15-17b. Receiptl for regiltered ..i1 are attached
to the letter.
5) Letter to Mr. John J. Sewbaur (sic] from Mr. Stephen R. Wa..erlu, re:
information request, 3/4/85. P. 18-20b. Receipts for reliltered ..11 are
attached to the letter.
6) Letter to. Ms. Mary Cae from Hs. Susan H. Pierce re: I.edial Inve.ci,ation
and Feasibi11ty Study, 5/10/85. P. 21-23. A meaorandu. re,ard1ng the
completion of the Potentially Relponsible Party Search 1. attached to the
letter.
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REMEDIAL RESPONSE PLANNING
Work Plans
1) Report: Work Plan for L. A. Clarke & Sons, Inc.. Frederieksburg. Virginia,
Remedial Investigation/Feasibility Study. 11/1/85.P. 1-176. '
2) Report: Project Operations Plan, Health and Safety Plan for L. A. Clarke
Sice, Spoesylvanla Councy, Fredericksburg. Virginia. Remedial Investigation/
Feasibility. 4/25/86. P. 177-235. ~~~~ B '—
3) Meaorandum to Ms. Lisa Low* from Mr. Ralph M. Shapot re: L. A. Clarke
Rescoping Activity - Revisions to FOP, 4/3/86. P. 236-256. The following
are attached to the memorandum:
a) Activity No. 2 - Air Sampling,
b) Activity No. 4 - Selecc/Saaple Monitoring Wells,
c) Activity No. 5 - New Monitoring Well Installation,
rf) Activity No. 11 - Surface W«cer/Sediments Sampling.
4) Letter to Mr. Don Kane from Mr. Ralph M. Shapoc re: L. A. Clarke Sice
Sampling Coordination, 4/23/86. P. 257-264. A Surface Water/Sediment
Sampling Plan for L. A. Clarke is attached to che letter.
5) Letter to Mr. Robert Greaves from Mr. David C. Muntz re: proposed Closure
Plan and the Post Closure Care and Groundwater Monitoring Plan for L. A.
Clarke, Inc., 8/11/86. P. 265-334. The following are attached to the
letter :
a) The Closure Plan,
b) The Post Closure and Groundwater Monitoring Plan,
z) The Comprehensive Environmental Cleanup arid Hazardous
Waste Facility Closure Plan. .
6) Meaorandum to Mr. A. Szilagyi and Mr. L. Wlnlnger from Mr. R. M. Shapot
re: Phase II Site Work at the L. A. Clarke Site, 8/20/86. P. 335-341.
The Phase II analysis and a Site Protection & Safety Evaluation Form are
attached to the memorandum.
RI/FS Reports
1) Report: Draft Final Remedial Investigation/Feasibility Study for L. A.
Clarke Site. Prederlcksburg. Virginia, Volume I, by Roy F. Weston, Inc.,
10/87. P. 1-447.
2) Report: Draft Final Remedial Investigation/Feasibility Study for L. A.
Clarke Site, Frederlcksbun. Virginia. Voluae II. by Roy F. Wei con, Inc.,
10/87.P. 448-1291.
3) Report: Final Remedial Investigation/Feasibility Study for L. A. Clarke
Site. Fredericksburg. Virginia. Voluae I. by Roy F. Wescon, Inc.. 2/88.
P. 1292-1737.
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4) Report: Final Remedial Investigation/Feasibility Study for L. A. Clarke
~ Freder1cksburl, Virginia, Volume II, by Roy F. Weston Inc., 2/88.
P. 1 38-24.5.5.
5) ~emorandum to the file from ~r. Darius Ostrauskas re: addendum to the
Remedial Investigation/Feasibility Study, 2/18/88. P. 24.56-2498.
Correspondence
1) Letter to Mr. Darius Ostrauskas from Mr. John E. Varnum re: transmittat
of draft final Remedial Investigation/Feasibility Study, 12/29/87. P. :-12.
Comments concerning the draft report are attached to the letter.
2) Letter to Mr. Darius Ostrauskas fram ~r. John E. Varnum re: transmittal
draft final Remedial Investigation/Feasibility Study for L.A. Clarke.
1/22/88. P. 12-16. A document describing flaws in the draft final
Remedial Investigation/Fealibility Study of October 1987 is attached
to the letter.
3) ~e~orandum to Mr. Alan Humphrey from Ms. Carol Sim re: Mlcrotox Analysis
for t. A. Clarke & Sons Site, 6/17/85. P. 17-29. A report of the re.ults
is attached to the memorandum.
4) Memorandum to Mr. Royale Nadeau from Mr. Willia. E. Miller re: L. A.
Clarke & Sons bioa..ays, 7/17/85. P. 30-31. A table of the results is
attached to the memorandum.
5) tetter to Mr. Steven T. FOlter from Mr. H. S. Gill re: laboratory test
results of samples collected fram wells in Spotsylvania County, 10/3/85.
P. 32-33. A certificate of the analysis 1s attached to the letter.
6) Letter to Mr. Steven T. FOlter
results from aIr sa.ples taken
S potSylvan1a County, 10/18/85.
is attached to the letter.
fram Mr. RichardL. Cook re: laboratory'
by the Air Pollution Control Board of
P. 34-37. A map of Spot sylvania County
7) Letter to Hr. Willia. Raile fro. Hr. L. ~imball Payne re: results of
the well testial dofte by Spot.y1vania County in the vicinity of the
L. A. Clarke creolote plant, 10/28/85. P. 38-38. .
8) Letter to Mr. 1111 ...el fral Mr. Jerrold S.-ford re: C088ent. on the
Draft Work P!aft for the L. A. Clarke' Son. Facility, 11/13/85. P. 39-40.
9) Letter-to Mr. 1111 .a.el fral MI. Paultne H. Evald re: relation.hip
betw..n ve11-water quality and the L. A. Clarke' Sonl Pacility,12/9/85.
P. 41-50. The followinl are attached to the letter:
.) ~ Certificate. of Analy.e.,
b) Two Field and Laboratory Data POra8,
c) Water Well Coaplet10n Report.
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10) Memorandum to Mr. Ray German from Mr. Dan Chellaraj re: review and
comment' on ~. A. Clarke Remedial Investigat~on/Feasibility Study
Work Plan. 1/13/86. P. 51-53. A memorandum regarding comments on the
Remedial Investigation/Feasibility Study Work Plan is attached to the
memorandum.
11) ~emorandum to ~r. William A. Hagel from Mr. Ralph M. Shapot ra:
Clarke Resc~ping Considerations. 3/12/86. P. 54-55.
~. A.
12) ~emorandum to Mr. William A. Hagel from Mr. Ralph M. Shapot re:
of Refocusing Phase I meeting held on March .12. 1986, 3/13/86.
notes
P. 56-51.
13) Record of Phone Conversation to Ms. Laura loornazian and Mr. Jerry
Sanford from ~r. Don Messinger re: samples fral wells at L. A. Clarke
Site. 5/2/86. P. 58-60. A record of phone conversation regarding waste
generated on L. A. Clarke Site and a record of phone conversation.
regarding waste disposal are attached to the record.
14) ~etter to Ms. Laura Boornazian from M.. Pauline M. Evald re:
to the L. A. Clarke Work Plan. 5/16/86. P. 61-62.
revisions
15) Letter to Mr. Ralph Shapot fral M.. Anne Kopecky re: results fral the
Ecova Preliminary FeasibIlity Study pertormed on .a.ples from the site.
10/3/86. P. 63-65. A table ,f Percent Reduction of PNAs Resulting
from Microbial Activity Is attached to the letter.
16) Memorandum to Ms. Linda Boornazian tral Mr. H. Ronald Preston re:
toxicity test results performed in the Wheelinl BlololY lab on samples
from the L. A. Clarke Site. 11/20/86. P. 66-68. A report of the resul:s
1s attached to the memorandum.
17) ~temora~dum to Mr. Don Kane and Ms. Linda Boornazian re: aquatIc toxicity
conduc:ed on sample collected fral the L. A. Clarke Site. 1/12/87.
P. 69-81. A report of the re.ults Is attached to the 'memorandum.
18) Letter to Mr. DarIU8 O.trau.ka. fraa ~. Jonathan D. Horln re: Draft
Final Remedial Inve.tIlation/r...ibillty Study tor L. A. Clarke Site,
1/13/87. P. 82-88. A letter re.ardins the NPnES perait for L. A.
Clarke discharle, a letter reque.tIns appropriate require.ents of the
State AIr Pollution Control loard (SAPCI) tor Supertund, and a table
ot SAPCI re.pon.. to re.edial alternative. are attached to the letter.
19) Letter to Me. taura loornalian traa Mr. Ralph M. Shapot re:
Pilot Studie. at the L. A. Clarke Sit., 2/3/87. P. 89-162.
are attached to the leeeer:
Bench-Scale/
The following
a) Treat.ent technique. on In-Situ Soil Flu.hinl,
b) Trearaent technique. Oft Soil Wa.hiDl,
c) Tr.at..nt technique. on Solidification,
d) a Propo.al for In-SItu Soil Wa.h Inee.rated with In-SItu
110recla..tioa and Enaineered lioreclaaation Studies.
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20) Report: Treatability Study Approach, 81oreclaaat1on of POlynuclear
Aroaat1c. (PHA.) 1n S01l, L. A. Clarke Site, Fredericksburg, Virgin1a,
by Camp Dresser & McKee, 3/87. P. l63-226.
21) letter to Ms. Laura 8oornaz1an from Mr. Ralph M. Shapot re:
for Pha.e III activit1es It the L. A. Clarke Site, 3/4/87.
reconnaissance
P. 227-229.
22) Report: Cnion Pacific Railroad Laramie Tie Treatinl Plan, In-Situ Treatmen~
Process Development Prolram Mile.tone Report I, Overview Report. Volume I,
6/87. P. 230-286.
23) Letter to Mr. Darius Ostrau.kas from Mr. Irvine Alpert re: literature
on the services offered from Ecava Corporation, 11/25/87. P. 287-307.
A project summary, a project outline and a report entitled "Pilot-Scale
8ioremediation at the Brio Refining Superfund Site," are attached to
the letter.
24) Letter to Mr. Stephen R. Wasserlul from Ms. Cynthia v. aailey re:
consideration of a proposal to consolidate all RCRA/CERCLA actions at
the L. A. Clarke Site, 12115/87. P.308-310.
25) Letter to Mr. Bruce Smith fral Mr. K. C. Da. re: Draft Remedial Investigat1
and Feasibility Study report on the L. A. Clarke & Sons Site. 1/28/88.
P. 311-313.
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EMERCENCY REMOVAL
Technical
1) Memorandum to ~r. Cerald
of L. A. Clarke; 8/9/85.
and wood t~e&tment And a
mealorandulII.
Heston from Mr. Bhupi Khona re: Organic nlta Review
P. 1-3. A memorandum regarding samplin, a..essmen:
map of L. A. Clarke SIte are attached to the
2) Memorandum to ~r. Jerry Heston from Mr. Bhupi Khona re: DIoxIn Analysis for
L. A. Clarke, 10/28/85. P. 4-12. A letter and I report on Dioxln/Dlbenzofura~
are attached t~ the memorandum.
Operational
1) Memorandum to Mr. Gerry Heston from Mr. E. Terry Jen.en re: Trip Report to
t. A. Clarke Site, 9/9/85. P. 1-4. A table for Sample Locatlon to
Sample ~umber and a map of L. A. Clarke Site are attached to the ...orandulII.
2) Melllorandum to Mr. Chlrles Walters from Mr. Stephen Margolis re:
removal of contaminated lIIatertal, 11/14/85. P. 5-8.
1_ed1ate
3) Memorandum to Ms. VIckie Province from M.. Mrinll Bi.wa. re: Site
Assessment for t. A. Clarke Superfund Site, t/20/81. P. 9-11.
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COHKUNITY INVOLVEMENT
Community Relations Plan
1) Report: Final Communit Relations Plan for the L. A. Clarke Site 5 otsvlvan1.
County. Virg1nia. 4 21 86. P. 1-27. A mailing 11st is attached to the report
fact Sheets, Press Releale.. Public Notices
1) Press Release from U.5. EPA Environmental Newl enUtled, "EPA Approves Fund1n~
For Study of L. A. Clarke Superfund Site," 7/16/85. P. 1-1.
2) Press Release from U.5. EPA Environmental New. enUtled, "EPA Completes Plan
For Study of L. A. Clarke Superfund Slte," 11/14/85. P. 2-2.
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SIT! SPECIFIC C~IDANC! DOCL~~~S *
21) "Storemediaeion of Contamination by Heavy Organics ae a Wood Preserving
Plane Siee," by Mr. Ronald J. Llnkenheil and Mr. Thomas J. Patnode
(undated). P.1-5.
22) "Land Treat!!lent of Wood Preserving Wasus," by Mr. John tL Ryan and
~r. John Smith (undated). P. 6-12.
~
-Located in U.S. EPA Rel10n III ottice.
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GENERAL GUIDANCE DOCUMENTS *
1) "Promulgation of Sites from Updates 1-4," Federal Register, dated 6/10/36
2) "Proposal of update 4," Federal Register, dated 9/18/85.
3) Memorandum to U. S. EPA from Mr. Gene Lucero regarding count
at Superfund Enforcement sites, dated 8/28/85.
4) Croundvater Contamination and Protection, undated by Mr. Dor
Feliciano on 8/28/85.
i
5) Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedeaan and Mr. Gene Lucero re: Policy on Floodplains and
Wetlands Assessments for CERCLA Actions, 8/6/85.
6) Guidance of Remedial Investigations under CERCLA. dated 6/85.
7) Guidance on Feasibility Studies under CERCLA. dated 6/85.
8) "Proposal of Update 3," Federal Register, dated 4/10/85.
9) Memorandum to Mr. Jack McGrav entitled "CoaBunity Relations Activites
at Superfund Sites - Interim Guidance," dated 3/22/85.
10) "Proposal of Update 2," Federal Register, dated 10/15/84
11) EPA Groundvaeer Protection Strategy, dated 9/84.
12) Memorandum to U.S. EPA from Mr. William Heckman, Jr. entitled
"Transmittal at Superfund Removal Procedures - Revision 2," dated 8/20/34,
13) "Proposal of Update 1." Federal Register, dated 9/8/83.
14) Commmity Relations in Superfund; A Handbook (interim version), dated
JTsT.
15) "Proposal of first National Priority List," Federal Register, dated
12/30/82.
16) 'Expanded Eligibility List," Federal Register, dated 7/23/82.
17) "Interim Priorities List,' Federal Register, dated 10/23/81.
18) Uncontrolled Haiardous Waste Site Ranking Systea; A User's Manual
(undated).
19) Field Standard Operating Procedure* - Air Surveillance (undated).
20) Field Standard Operating Procedures - Site Safety Plan (undated).
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