United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response.K
EPA/ROD/R03-90/083
November 1989
<& EPA Superfund
Record of Decision
U.S. Titanium, VA
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50272.101
REPORT DOCUMENTATION 11. REPORTNO.
. PAGE EPA/ROD/R03-90/083
4. TIlle and &.tJ1I1Ie
SUPERFUND RECORD OF DEC1SI9N
U.S. Titanium, VA '
First Remedial Action - Final
7. Aulhor(8)
2.
3. R8dp1anr8 Accesalon No.
5. Report Date
.~
..
11/29/89
6.
8. Performing Organization Rep&. No.
I. P8rf0rmlng Org8InIza1Ion Name and Add-
10. ProjectlTuklWork Unit No.
11. Cordr8ct(C) or Grant(G) No.
(C)
(G)
12. ~ Org8JU8tlon Name and Addre88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & PeriOd Covered
Agency
800/000
14.
15. ~ No..
18. Ab8tr8ct (lJJNt: 200 worda)
The 175-acre U.S. Titanium site, in Nelson County, Virginia, is a former titanium
dioxide manufacturing plant which was operated from 1931 to 1971. The facility has had
a succession of owners and is currently owned by U.S. Titanium Corporation.
Approximately 50 acres of the site will be addressed by this remedial action, including
seven waste storage areas containing process wastes. These seven areas include: Area
1, a burial pit containing 16,000 cubic yards of solid ferrous sulfate (copperas); Area
2, a former copperas stockpile area; Area 3, an evaporation pond; Area 4, a 1-acre ore
waste pile; Area 5, sedimentation ponds containing fine-grained sediment composed of
un reacted ore, filter cake, and gypsum,; Area 6, a settling pond used to recover
phosphate ore; and Area 7, a drainage area, which received surface water runoff.
Several of these areas lie within the 100-year floodplain of ,the nearby Piney River.
After a large fish kill in 1979, the State ordered U.S. Titanium to bury the copperas
waste from Area 2 by December 1980. The copperas waste was collected and buried in Area
1, the onsite burial pit. A supplemental remedial investigation revealed the presence
of acidified soil underlying the waste storage areas that contributes to ground water
contamination. The primary contaminants of concern affecting the soil, ground water,
(See Attached Page)
17. Document An8/y8i8 L Deacrlptonl
Record of Decision - U.S. Titanium, VA
First Remedial Action - Final
Contaminated Medium: soil, gw, sw
Key Contaminants: metals (arsenic, chromium); other inorganics (acids)
b. IcI8ntltler8lOpen.EncIed Tenna
c. COSAlI ReIdIGr~
18. AV8II8b11ty Statement
11. Secwfty ClaM (ThJ8 Repart)
None
20. SecurIty CI- (ThJ8 Pege)
None
21. No. 01 P81188
146
I
(See At5-Z38.18)
22. PrIce
SHIMITUCfiOM on Re-
. fORM 272 (4-77)
(Formetly NTls.35)
Dep8J1ment 01 Commerce
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EPA/ROD/R03-90/083
U.S. Titanium, VA
~irst Remedial Action
Final
Abstract (Continued)
and surface water are metals including arsenic and chromium; and other inorganics
including acids. .
The selected remedial activities for the seven areas within this site include: Area
1, in-situ dissolution of copperas waste and treatment of resulting leachate using
physical and chemical processes; Areas 2, 3, 4, and 5, diversion of surface .water
flow using drainage controls followed by revegetation; and Area 7, excavation and
neutralization of acidified soil, followed by placement of the mixed material around
a wetland that will be constructed onsite. Area 6 requires no remedial action.
Ground water will be collected passively using subsurface drains and trenches and
treated passively in an oxidation/settling .pond, a constructed wetland, and a
limestone neutralization bed. The oxidation/settling pond will be capable of .
completely removing iron and' sulfur elements from the collected ground water and will
make up for any loss in the performance of the wetland. Wetland vegetation and
anaerobic bacteria will remove iron and sulfur species from the water. As a result
of this process, an inc'rease in pH can be expected. The limestone bed will act as a
. final polishing step for pHadjustment before the effluent is discharged to the Piney
River. The estimated present worth cost for this remedial action is $5,895,000,
which includes present worth O&M costs for 30 years.
PERFORMANCE STANDARDS OR GOALS: Action levels for in-situ dissolution and leachate
collection for Area 1 w~ll ensure that leaching of contaminants to ground and surface
waters will not exceed State water quality standards which include arsenic 0.19 mg/l
nd chromium 0.011 mg/l. Effluent limits for discharge from the ground water
treatment system into the surface water include iron 97,583 mg/l and pH ranging from
6.0 to 9.0
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RECORD OF DECISION
u. S. TITANIUM SUPERFUND SITE
NELSON COUNTY, VIRGINIA
PREPARED BY .
VIRGINIA DEPARTMENT OF WASTE MANAGEMENT
OCTOBER, 1989
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TABLE OF CONTENTS
PART A: DECLARATION ..... ........................... ............ ...... .......... ......
Site Name and Location [[[
Statement of Basis and Purpose "'''Y''''''''''''''''''''''''''''''
Assessment 'of the Site [[[
Description of the Selected Remedy .......................'........
Statutory Determinations ........... .:.. ....................................
Signature................ ........... ..:........... ........ ............ ................
PART B: DECISION SUMMARY[[[
Site Name and Location [[[
Site History and Enforcement Activities ..........................
Highlights of Community Participation "............................
Scope and Rokt of the Response Action .......................
Site Characteristics ......... ........... ........ .............. ..................
Summary of Site Risks [[[
Description of Alternatives .................................................
Summaty of Comparative Analysis of Alternatives ........
Selected Remedy ................... .... ..................... ..... ....... .......
Statutory Determinations .............. ..... ................ ..... ...........
Appendix I: Efftuent Umitations and Monitoring
Requirements.......... ..... ............... ......... ....
Appendix II: Description of Evaluation Criteria ...............
PART C: RESPONSIVENESS SUMMARY ......................................
Overview [[[
Background on CornInunity Involvement ........................
s..nrnary of CornrnenIs and Responses ........................
Rllpoi1S8 to Comments from American Cyanamid ......
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PART A
DEClARATION
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2
DEClARA110N
SITE NAME AND LOCA110N
U. S. Trtanium
Nelson County, Virginia
STATEMENT OF BASIS AND PURPOSE
This decision document presentS toe selected remedial action for the U. S. Trtanium Superfund
site, Nelson County I Virginia, developed in accordance with the Comprehensive Environmental
Response, Compensation and uability Ad of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and to the extent pradicable, the National
Contingency Plan (NCP). This decision is based on the administrative record for this site. An index
of the administrative record upon which the selection of the remedial action is based is attached.
Both the Commonwealth of Virginia and the Er'Mronmental Protection Agency (EP A) support the
SeIeC1ed remedy. .
ASSESSMENT OF THE SfTE
AduaJ or threatened releases of hazardous substances from this site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present a current or
potential threat to public health, wetfar8, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This action addresses all known sources of contamination at the site, specifically acidic
discharge to the Piney RIver. The remedy incfudes efimination of buried copperas waste, and
remediation of contaminated groundwater. The major componentS of the selected remedy include:
. DissoMng the buried copperas waste in place and treating the generated leachate
~;
. St"'''~ 0Ih8r area 01 the site by implementing drainage controls and establishing
~.6. covers;
. CoII8cdng grcu1dw8r8r . the boaom 01 the slope and tr88ting it using a combination of
chenicaI and bioIcgicaI (wetland) procesS98: .
. Uming 01 acidified soil in areas associated with the Implementation 01 groundwater treatment;
. Diverting surface run4r from groundwater tr88b.18f'1t areas and former sedimentation
ponds;
. Installing 100-y" ftood protection around the forr1W sedimentation ponds and groundwater
treatment at88I;
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- Installing security fences around waste and groundwater treatment areas; and
-Conducting environmental monitoring to enSure the effectiveness of the remedial action.
STATUTORY DETERMINA TlONS .
The selected remedy is protective of human health and the environment. complies with Federal
and State requirements that are legally applicable or relevant and appropriate to the remedial action.
and is cost effective. By eliminating the copperas waste through treatment and by collecting and.
treating contaminated groundwater, this remedy satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility or volume as a principal stement and utilizes permanent
solutions and alternative treatment technologies to the maximum extent practicable. .
However. bEtcaUS8 treatment of other less major contaminant sources was not found to be
practicable, and contaminants would be accumulated in the wetland during groundwater treatment, the
selected remedy could result in hazardous substances remaining on site above health based levels.
Consequently, a review will be conducted within five years after the commencement of remedial action
to ensure that the remedy continues to provide adequate protection of human health and the
environment.
UNITED STATES ENVIRONMENTAl
P~ON AGEN~. .
~~~ () L{~~~
Regional Administrator
It / ;)../ I rJ
Date
VIRGINIA DEPARTMENT OF
WASTE MANAGEMENT
J ivo vtMt) 8< {erg,
Date
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4
PART B
DECIsIoN SUMMARY
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'5
DECISION SUMMARY
SITE NAME AND LOCATION
The U. S. Trtanium Site is located at the southern border of Nelson County along the north bank
of the Piney River and east of Virginia Route 151, abQut 40 miles south of Char1ottesville, in west central,
Virgi(1ia. The center of the site is located approximatefy at longitude 7go 01' 00", West and latitude 3~
42' 30" North. The site lies just east of the rural community of Piney Riv,er, Virginia. Figure 1 shows'
the general location of the site, on the USGS Piney River 7.5' quadrangle topographic map.
, The U. S. Trtanium site lies on 175 acres of a former titanium dioxide manufacturing, plant.
Superfund remedial efforts are concemec:t with approximatefy 50 acres of the site. This acreage
contains seven separate and distinct areas which were identified as possible sources of contamination
and are described betow. A site map is shown in Figure 2.
Area 1 is a clay lined, clay capped buriaJ pit Where copperas (ferrous sulfate) from Area 2 was-
landfilled in 1980. It encompas5es approximatefy two acres and' contains abOut 16,000 cubic
yards of copperas.
Area 2 is the former copperas stockpile area located on the slope east of Area' 3. It covers
approximately eight acres. Copperas from manufacturing operations was deposited here from
1949 to 1971. The copperas was buried in Area 1 in 1980. '
Area 3 contained, the evaporation pond operated between 1974 and 1980 and is located
between Area 1 and Area 2. This pond, which covered about two acres, was part of a system
to prevent discharges to the Piney River operated under a NC>Oischarge Certificate issued by
the Virginia Water Control Board (VWCB). Surface water run-off and some groundwater
discharges were collected in a containment pond and pumped up to the evaporation pond.
Area 4 is an unreacted ore waste pile located south of Area 2. It covers about one acre and
consists of cIean-outI from reactor vall used in the titanium dioxide process and dredged
materiaJ from the sedimentation ponds in Area 5.
Area 5 contains two sedimentation ponds located along the Piney River used to remove
settleable IOid8 from pear-. wastewater prior to discharge to the river. The ponds cover an area
of appradmatett seven acres and contain an extremety flne.grained sediment composed of
unr~ ore, filter cake. and gypsum. This 8188 lies within the 1 ()().year floodplain of the Piney
River.
Area 8 contains a sealing pond used to recover, phosphate ont. a by-produd from' titanium
dioxide prod« ICtian. It covers about one acre and Is loc3ed north of Area 5.
Area 7 is the drainage area receMng most of the surface water rund from the site and the
flow from tributaries. Thi8 area is located In the southea8t comer of the site and covers abOut
one acre. This area lies within the 1QO.year ftoodplain of the Piney RIver.
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CONTOUR INTERVAL 20
DATUM IS M£*M SE* LCVtL
Figure 1: Location Map for the U. S. Titanium Site
in Nelson County, Virgina.
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"
"
\
.~.
!@
I
LEGENO:
(;\1 ClaY-LIN(O COPp(lIa,
\.!I DISPOSAL aAI a
'2' '011"(11 COPf,"as
~ S 10llAU PIU
~ ,Illt. III UP,,'.
~ ,y"", . "flOII .0...
'4' 'IHIO.'" LOWIII OI'Cllall'[
\:!.J COll(ClIO" PONO
@ OlO KULING 'ONO
@ 'luIO-IM SQuaAI lAGOON
9 SURFACE WATER DISCIIAl1G£
\!J 'M '0 TII£ PINEY RIVER
.. . -... OV(II\ AMO 'LOW a
SUA'ACI IIUNO"
~ '"OUNo.anl flOW
(PA WELL #Z
..01 onn", 10 scalI
Amherst County
BOOl.ALLEN & HAMILTON. INC.
Endangerment AlsessmenllFeaslbllll, Stud,:
U.S. Tllanlum SlIe (April 1986' '
Source:
Figure 2: U. S. Titanium Site
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8
SITE "HISTORY AND ENFORCEMENT ACTMT1ES "
In 1931, the Virginia Chemical Corporation beQan producing titanium dioxide from ilmenite ore
using the sulfate process at the site. The ore was obtained from mining operations directly south of
the Piney River. In the sulfate process, the ilmenite ore is treated with sulfuric acid to dissolve the
titanium dioxide product. Waste streams from this process include acid contaminated unreacted ore,
spent sulfuric acid, and solid ferrous sulfate, called .copperas..
In July 1944, American Cyanamid Corporatiof1 purchased the Virginia Chemical Corporation and.
operated the plant until it closed in June 1971. Following the plant c~re, the site passed through
various ownerships including the U.S. Titanium Corporation from which the Site received its name. "
" .
. Six major fish kills occurred in the Piney. River between 1977 and 1981, as documented by the
VWCB, which were attributed to contamination from the site:
DATE
NUMBER OF FISH KIU.ED
July 1977
August 1977
August 1979
July 1980
May 1981
June 1981
TOTAL
73,056
8,940.
26,138
53.980
20.482
46.243
228,837
The 1979 fish kill prompted the VWCB to request the Circuit Court of Nelson County to order
U. S. Titanium to bury the copperas by December 31. 1980. In response to the court order.. U. S.
Titanium Corporation contacted New Enterprise Construction Co. to dispose of the copperas waste.
The copperas waste from the storage pile (Area 2) was collected and then buried in Area 1.
Unci« co.lbact with EPA, Ecology and Environment submitted a Preliminary Assessment report
of the site on August 3, 1980. 'The burial of Copperas in Area 1 was completed on December 12, 1980.
A report of a screening Sb Inspection conducted by EPA on August ~, 1982. was released on
November 19, 1982. In 08c8mb8r 1982, the U. s. T1tanium site was proposed for inclusion on the
NationaJ PrtorIy UII purIU8I'It to SectIon 105(8) of CERCLA. The site was finaJly listed on the NPL. in
September, 191&
. On F8bru8y 1 and 2, 1983, NUS Corporatiori,. under """lbact with EPA, conducted a site
inspection - P8t of . Rem8dIaI Action Mast. Plan which was relllSad in August, 1983. GCA
Corporatior"., undIr COIlbact with EPA also conducted. Focused FMSibiDly Study on the nature and
extent of the ackIc diIchargeI from the site and evaJuated alternative rern&diaI actions. The report was
released by EPA on October 8, 1985.
FoOowing . cMI action filled by the ConmonweaIIh of VIrginia against American Cyanamid
Company and others in Stale Court. based on a nuisance action for fish kills and environmental
degradation resulting from the site, a liability judgemert was rendered against American Cyanamid or
November 7, 1985. "
On April 30, 1988, the Attorney General for the Commonwe8Ith of Virginia and American
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9
.
Cyanamid Company signed a Stipulation and Order establishing a schedule for completion, by .
American Cyanamid Company,.~ a temporary source controt actiori for the copperas burial pit. a
Supplemental Remedial Investigation (SRI), anc;t a Feasibility Study (FS) for the site. The SRl.and FS
were conducted by Hydrosystems under contract with Cyanamid company and submitted in November
1988 and April 1989 respectively. The SRI characteriZed the nature and extent of contamination at the
site. The FS described various cleanup technologies and how remedial alternatives were developed,
screened, and evaluated based on these technologies.
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HIGHUGHTS OF COMMUNrTY PARTICIPATION
While the U.S. Titanium site is located in a predominantly rural area. there has been
" considerable imerest among residents since the late 1970's, when fish kills began to occur. The local
Blue Ridge Chapter of the Sierra Club was formed in response to site events. In addition, the local
media have followed the site activities consistently. "
". The post-RIIFS community participation acWities began in April, 1989, when a fact sheet
describing the Remedial Investigation/Feasibility Study was .mailed to a list of residents, officials, and
media. In addition,informal meetings were held with local officials and Sierra Club represematives on
May 18. The Community Relations Plan (CRP)' was revised at this time, and a repositories for the.
Administrative Record File and other information was established at the Nelson County Memorial Ubrary
and the County Administration office. The Proposed Plan was formally released to the public on July .
31. A notice announcing the availability c:A the Proposed Plan. the public comment period, and the
Administrative Record File was published in the Charlottesville Dailv Proaress on July 31. The Virginia
Department of Waste Management (VOWM) also cosponsored an informal wort
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SCOPE AND ROlE OF RESPONSE ACT10N
The SuppMHnentaJ Remedial Investigation (SRI) characterized the nature and extent of
contamination at the site. The SRI data as well as data and/or conclusiOns from all previous studies
were used in the Feasibility Study (FS) to develop remedial atternatives to eliminate unacceptable risks
at the site. The FS described various cleanup technologieS and how remedial atternatives were
developed, screened, and evaJuated based on these technologies.
Contaminant source control was identified during the RI as the most effective way of eliminating
risk to human health and the environment at the U. S. Titanium site. Consequently, the FS focused on
the devefopment of remedial alternatives designed to control contaminant sources identified during the
Rio The sefected alternative in this Record of Decision (ROD). incfudes a.source control remedy tor all
areas of the site currently impacting groundwater and surface water discharging from the site into the'
Piney River. . '. ..
Significant data were also generated during the RI on the migration of site-retated contaminants
trom the identified sources. In particular, the RI indicates that site related contaminants are migrating
into groundwater. The ROD therefore includes groundwater remediation. .
By eliminating most of the sources of acidic discharge, the proposed remedial action will prevent
future fish kills, and stop further degradation of the Piney River.
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srTE CHARAC I t:HIST1CS
Based on the findings of the SRI and previous site investigations, the following conclusions can
be made regarding the site, the types of contamination, and affected media.
. .
The site is located in the Piedmont physiographic province, about five miles east c:t the Virginia
Blue Ridge. The elevation ranges from 728 feet on tapa the copperas burial pit in Area 1 to 618 feet
in the Piney River near the drainage area (Area 7). 'J!1ebedrock underlying the.site consiSts of igneouS
and metamorphic rocks. . Two distinct sets of nearty vertical fractures are present in the. bedrock and
have approximatefy nonhwest~southeaSt and northwest-southwest orientatJon&
. .
Two soil groups exist at the site. In the uplalid areas. the soil is a residuum. (saprolite) . derived
from the weathering 01 the undertying parent bedrock material It Is composed predominantly of .clays
and silts. Within the fIoodptain, the soil consists 01 heterogeneous allwiaJ deposits of grav.., sand. silt.
and clay. In general, the soil depth decreases from near 60 feet at the tap of the slope in Area 3, to
less than one fOot near the stream at the base 01 Area 2. .
Groundwater occurs primarily in the porous.. unconsolidated granular material of the saprolit~
and, to a much lesser extent, in the fractures that run through the dense, hard igneous and
metamorphic bedrock. These two units are hydraulically interconnected CNfIl larger distances. The
depth to water table is about 44 feet on the south side a Area 1. Comk1g down the valley, the water
table becomes shallower, intersecting ground surface in the stream beds and springs alOng the base
of the hill. Groundwater flow within the site originates in the uptand area containing Areas 1 and 3,
flows in a radiating pattern down hill toward. the streams surrounding the base a the hill and to the
Piney River.
The site lies within the Piney River drainage basin, a part 01 the larger James River drainage
basin. Areas 5 through 7 lie within the floodplain 01 the Piney River.. Surface water drainage runs off
the site primarily via three drainage channets into the Piney River.
In Area 1, the copperas burial pit. the cap system has not functioned proper1y allowing water
to infiltrate the pit. The ~ acidic and high iron cant.. leachate has acidified soils underneath
the pit and contaminated groundwater. Acidic seepages from the burial pit have killed trees and other
vegetation down-gradient from Area 1. This area accountS for ~ 65 percent a the total acidic
discharge at the site. AnaIysiI 01 groundwater samples down-gradient a the burial pit have shown a
pH as low as 3.88. and ~~~ a total dis80Ned Iron of up to 2190 mgII, sulfate a up to 14,000
mgII. and acidly ~ up to 10,050 mwt . calcium carbonate.
The 101 &niIr the fonn8r copperas stockpile area. Area 2. is acidIIed and groundwater
seepages 81 the b88 of the 8IOp8 have killed the graa stand and fonned iron sulfate deposits. The
addic contribudon tram thi8 area II 11 percett. Analyses a sampIeI from seeps at the base a Area
2 have shown . pH 81 low 81 a.ee. and conce. ~Miona a total di880IYed iron of up to 17,720 mgII.
sulfate a up to 45,000 r19\ and addity a up to 41,000 mwt 81 caIcUn carbonate.
The soil under Area 3. the former evaporation pond, is acidified up to the water table. Total
acidic contribution from thiI area is ~ 7 percert. The most rec:8d analysis a groundwater from
a weD located within Area 3 h8 shown. pH a 3.32. and conce.c.iIion8 of total dissolved iron a 4,360
mgll, sulfate a 54.000 mgII, and acidly 0140,500 mww as calcium carbonate.
Area 4, the uMNlCted ore waste pile .... coruin8 residual acidly from precessing. The soil
underneath this area is also acidified. Feu percent of total acidly 81 the site is 8ttI'IbUabI8 to this area.
j
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Area 5, which contains the two sedimentation ponds. contains residual acidity from processing. '
During Storm events, erosion of sediments by Storm run-off has resulted in a significant lowering of the
pH in the Piney RIver. In addition. groundwater flowing through this area is acidified by contact with
the waste prior to discharge to the Piney River. Area 5, accounts for' 12 percent of the total acidity at
the site. Analyses of samples from wells located on the nonheastem edge of this area have shown a
pH as low as 3.42, and concentrations of total dissolved iron of up to 1,840 mg/l, sulfate of up to 5,400
mg/l, and acidity of up to 3,220 mg/l as calcium carbonate.
Area 6, the settling pond used to recover phosphate ore has no detectable copperas or acidity
problem. There is alsO no groundwater contamination. .
The soil under Area 7, the drainage area receiving most of the surface run-off from the site, has
become acidified and contributes about one percent to total site acidity. 'Analysis of samples from a '
well down-gradient of Area 7, have shown a pH as low 3.09, and concentrations of total dissolved iron
of up to 570 mg/l, sulfate of up to 2,400 m9ll, and acidity of up to 1,542 mg/l as calcium carbonate.
The acidic nature of the site has alsO led to the leaching of other metals such as aluminum,
copper, zinc, cadmium and nickel from on site soils. The concentration of these metals in surface
water and groundwater at the site, as well as that O! iron, exceed surface water criteria (Table 1).-
Figure 3 shows the percentage contribution by area to acidic contamination at the site.
Area 6 . 0..
Area 7
1~
Area 5
12~
Area 2
11~
Area 4
Area 3 4~
7~
Ftgure 3:
Contribution by Area to Total Acidic Contamination
at the U. S. Titanium site.
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TABlE 1: MEAN CONCEHTRAT1ON IN SURFACE WATER DISCHARGE &
GROUNDWATER AT THE U. S. lTTANUM SITE
Units in mg/I
SUIface~ Surfacec
Water Ground' Water
Contaminants Discharae Water Criteria
AI 200. 200. 0.08~
As. <0.01 0.028 0.190
Cd 0.013 . 0.047 0.0003
Cr 0.335 0.084 .011'
Cu 1.355 0.45 0.0025
Ni 0.692 2.67 0.023
Zn 1.56 19.27 0.047
Iron 267. 698. 1.0
pH 2.4 3.1 6-9-.
Acidity 10M8 2090
a. Scuce: Report." J. Novak. VirgInIa Tech (1984)
b. SoLn8: Mon1I. Ph.D. Th8II8. VIrgInia Tech (1984)
c. Scu8 VIrginIa W.. Control Board
d. So&n8: USEPA Arnb81t W.. QU8IIy Crbrta (1988)
e. Scuce: NUS (1983)
f. Cr(Vl) (total r8CCN8y)
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SUMMARY OF SfTE RISKS
Without remedial action. the site will continue to contaminate groundwater and surface water
in the Piney River sub-basin. Acidified soils and buried copperas wastes will continue to leach
contaminants into the groundwater. The dissolution of copperas produces acidity as the result of a
sequence of reactions that include oxidation, of the ferrous iron to ferric iron, and hydrolysis of the ferric
iron to ferric oxyhydroxide. Th4;l net effect of these reactions is that for every mole of copperas
dissolved. two moles of excess hydrogen iron (H) are produced resulting in the acidic leachate.
Groundwater eventually discharges into, the Piney R~er either directly or by way of two site' tributaries,
Surf~ce water run-off from the site erodes acidic sediments and discharges them into the river.
These discharges can contain high iron concentrations and have low pH values. The high iron
concentrations have resulted in the deposition of ferric hydroxide sediments at the bottom of the river.,
These sediments are still present today and have disruPted the benthic community in the river. This
in turn has resulted in a decrease in the number and diversity of the fish population in the river
adjacent to and downstream of the site. Low pH discharges can be toxic to aquatic organisms. Based'
on sampling as late as fall 1988. the State Water Control Board has concluded that the aquatic
invertebrate community has not completely recovered in the Piney River even at a distance of 3.5 miles
downstream.
Actual or threatened releases of pollutants from this site. if not addressed by implementing the
response action selected in this ROD. may present substantial endangerment to aquatic lif,e in the Piney
River.
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16
DESCRtPT10N OF AlJCRNATlVES
Several alternatives were evaJuated in detail to determine which would be most effective in
achieving the goaJs of CERCLA, and in particular. achieving the remedial Objective for the site. The
detailed analyses of remedial alternatives for the various areas of the site are briefly described below.
NO ACTlON
CapitaJ Costs:
Annual 0 & M:
Five Year Review: .
. Months to Implement:
. ,
5 21.000.
5156.000.
5133.000. .
3.
The Superfund program is required to evaJuate the "No. Action- alternative. Under this
alternative. no remedial action would be taken to prevent contamination from entering groundwater or
the Piney River. Site access controts. deed restrictions. and maintenance of on site roads would ~
performed. In addition. monitoring of the groundwater and surface water would be performed along
with a formal review of the site condition every five years. ARARs associated with surface water and
groundwater would not be attained.
The remedial objectives for the site would not be in8t by the no action alternative and impacts
on the benthic community in the Piney River would continue. The no action alternative does not meet
SARA's preference for permanent treatment.
GROUNDWATER COLLECTION SYSTEM
Alternative GW-2: Passive Groundwater Collection
CapItaj Costs:
Annum 0 & M Costs:
Months to Implement:
$142,000.
$2.000.
3.
~ would be int~ed by a series of sub8urface drains and/Or trenches instaJled
bekJw the w-. t8bI8 along the b888 of the hi containing Areas 1. 2. 3. and 4. Gravity flow would be
used to feed the oaI8/:t8d ... to the groundwater treatment system. Measures would be taken to.
prevent the fonnIIb. 01 iron saI deposits in the collection syStem during pertods of low flow.
Uncontarninabd Uf8c8 ... n,n.off would be diverted tNI"f from the collection syStem.
~ would be coIected tor tr.-..ent until the groundwater quality achieves a lev..
which aaows It to be diIcharged dIr8cdy irto the Piney ANer. 'The dJIcharge lima for this site
~ary to meet water quaIty Itandards in the Piney RIver and so comply with the Clean Water Act
(CWA) and Virginia Water Control Board (VWCB) regldatJons have been determined by VWCB and are
presented in Appendix I.
. AM COStS and implementation times .. estimated.
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17
.
GROUNDWATER TREATMENT SYSTEM
Alternative WT-2: Passive Water Treatment
Capital Costs:
Annual 0 & M Costs:
Months to Implement:
$119,000.
$20,000.
6.
The components of the treatment syst8ft"l would inctude an oxidation/settling pond, a
co~ructed wetland, and a limestone neutralization bed.
The oxidation/settling pond would be caps:a-ble of complete remov~ of iron and sulfur elements
from the collected groundwater. Its design would utilize existing knowledge of acid mine drainage.
treatment where the use of oxidation/settling ponds is a standard technique. Such treatment sy.stems
often utilize alkaline chemicals to raise the pH of the water and cause metals to precipitate. The sulfur
element would also be precipitated. The oxidation/settling pond would make up for any loss in the
performance of the wetland.
Wetland vegetation works in conjunction wid) anaerobic bacteria to remove iron and sulfur
species from the water; an increase in the pH can also be expected. The wetland would be protected .
from a 100-year flood by constructing a berm around-it.
Should the presence of other metaJs in the effluent from the wedand make the discharge
requirements set by the VWCB non-attainabIe and thus prevent direct discharge into the Piney River,
additional physical or/and chemical treatment steps would be installed.
The limestone bed would act as a final polishing step for pH adjustment before discharge of
the effluent to the Piney RiVer. .
An eight-foot high, locked chain-llnk fence would be installed around the wetland for the
protection of the community, on site wortcers, and game and wildlife. Routine maintenance of the entire
groundwater system would include restocking at the wetland with new plants, dredging of the oxidation
pond and wetland, periodic efIIuent and influent monitoring. The monitoring program for groundwater
treatment is presented. in AppendIx I.
AJI residual wastes would haYe to undergo Extraction Procedure Toxicity (EP Tax). testing to
determine their da88ificaIion before disposal Wast. that fall under ReAA Subtitle C (Hazardous
Waste) would be managed according to the VIrginia Hazardous Waste Management Regulations
(VHWMR) and ~ ReM Land 0I8p0saI Restrictions (lDRs). Wastes that are classified as RCRA
Subtitle D (SaId W_) would be managed according. to the VIrginia said Waste Management
Regu~ (V8MJR). The oxIdadonI88tdJng pond, the wetland and the neutralization bed would be
constructed and openIt8d according to VHWMR « VSWMR (lndudlng minimum . technology
requirements). The Commonwlallh at VirginIa is a ReAA delegated State.' AI RCAA authority has been
delegated to the COmmonw9a1th at Virgiria except thole LRier the 1984 Hazardous and Solid Waste
Amendments (HSWA).
. AJI costs and Implementation Urnes are estimated.
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18
Alternative WT -3: Active Water Treatment
. Capital Costs:
Annual 0 & M Costs:
Months to Implement:
$2. 735 000.
. .
$181,300
18.
The system would consist of a series of ponds and tanks used for oxidation, neutralization,
mixing, aeration, and solids separation. The ferrous ions would be oxidized to ferric ions and the
resulting acidity neutralized. Sludge from the solids separation operation would be subjected to EP T ox.
testing to determine if its disposal should foJlatv the VHWMR and the LeAs or the VSWMR. . The effluent
from the active treatment system must also me&! the discharge requirements established by the \/WCB.
AREA 1
Alternative A 1-3: Clav Cao
Capital Costs: $486,000.
Annual 0 &; M Costs: $3,000.
Months to Implement: 12.
The copperas and contaminated soil would be left in place and a new clay cap would be
installed over the existing cap. The present surface would be graded and compacted. The cap would
consist of a three foot thick clay layer, a one foot thick drainage layer, and two feet of soil to support
a vegetative cover. Th8 cap could reduce the production of leachate from the burial pit by over 90
percent.
Routine maintenance to repair erosion damage, cracks, and subsidence in the cap would be
required consistent with the requirements of RCRA as long as the copperas remains in the burial pit.
The cap would be constructed and maintained in accordance with the VSWMR, including minimum
technology requirements. Deed restrictions would also be apptied. .
Alternative A 1-4: Imcermeable Cao
Capital Costs: $511,000.
Annual 0 . M C08I8: $3,000.
Months to Implement 12.
Thi8 aII8mIIMt is similar to A1-3. The cap structur8 would consi8t tJ a two foot thick clay layer,
a synthetic memIW8I. liner, a one foot thick drainage lay., a geot8Xtile filter fabric, and a tWo foot thick
vegetative CCMr. ThII cap could r8duc8 the production tJ 188ch8t8 from the burial pit by nearty 100%
during the 30 Y88' .. ~ the ~11d'wJtio membrane.
Routine maintenance to repair erosion damage, cracks, and "aidence in the cap would be
required consistent with the requirements tJ ReRA as long as the copperas reman in the burial pit.
The cap woutd be constructed and maintained in accordanc8 with the VSWMR. including minimum
technology requirements. Deed restrIction8 would also be applied. .
.
All costs and implementation time8 are estimated.
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19
Alternative A 1-8: Above-Grade Wet Neutralization
capital Costs: . $10,779,000.
Annual 0 & M Costs: $434,000.
Months to Implement: 18 (4.5 yrs total treatment time).
The alternative would consist at the following major steps: (1) excavation of the soil/copperas
. mixture from the burial pit; (2) dissolution of the copperas from the soil; (3) oxidation of the ferrous
ions to ferric ions; (4) neutralization at the acidity resulting from the oxidation step; (5) disposal of
precipitated solids generated in the neutralization step. This treatment would result in th, destruction
of ~he copperas and neutralization of the resulting acidity~ ~n addition,. the concentration of
contaminated groundwater routed to the groundwater tr~ system. would be greatly reduced.
The effluent from the treatment system must meet the discharge requirementS established by
the YWCB. Solids generated by the process would be subjected to EP Tox testing to determine if its
disposaJ should follow the VHwMR and the LDRs or the VSWMR. .
Alternative A 1-9: Neutralization and CaooinQ
Capital Costs:
Annual 0 & M Costs:
Months to Implement:
.
$1,234,000
$3,000.
18.
The existing clay cap would be removed. Soda ash. a neutralization agent, would be mixed
with the soiVcopperas waste to a depth of flye feet. A clay cap identical to that described in Altemative
A 1-3 would then be installed. The cap could reduce the production of leachate from the burial pit by
over 90 percent. The soda ash would provide some neutralization of any leachate generated.
RCRA Subtitle D closure standards, Virginia Department of Waste Management's Solid Wastes
Regulations, and deed restrictions would be applied. Routine maintenance to repair erosion damage,
cracks, and subsidence in the cap would be required consistent with the requirements of RCRA as long
as the copperas remains in the burial Pil
Alternative A 1-10: In-Situ Dissolution and Treatment
Capital Co888:
Annual 0 . M Co888:
MonIh8 80 Implement
$3,457,000.
S21 0,000.
3D*
The - nIIMt would consist c1 the following major st&pl: (1) d...1tion c1 copperas inside
the burial pit; (2) recovery c1 resulting leachate from the pi; (3) complete tJ'edb..erIt c1 the leachate
using physical 81d chemiaII processes; (4) sludge disPOSal Instead c1 steps 3 and 4, product
r8CCNery from the coGected ~e would also be expknd. The specific details c1 the processes
would be det8Tnined In the Remedial Design phase through .1gIn8811i1g design and analysis. The
altematiY8 would result In the destruction c1 the copperas and neutnIIizadon c1 the resulting acidity.
In addition, the concet Ibation c1 contaminated groundwat. ~ to the groundwater treatment system
would be gready reduced.
.
All costs and Implementation times are estimated.
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..
20.
The pertormance of the copperas. dissolution step woul.d be verified by taking core or split
spoon sampleS from the burial pit and analyzing them for total soluble content. The efficiency of the
leachate removal system would be evaluated through a water balance that takes into account the level
of water in the burial pits, the amount of water introduced and the amount recovered.
The termination of in-sitU. dissolution and leachate collection would be determined using the
results of soil boring tests. and fate and transport modeling to estimate the potential of' groundwater
contamination that could result from the migration of residual contaminants in the soil.' The leaching
process shall be stopped when (1) soil boring tests show that no significant amount of copperas
remains in the pits, and (2) the residual acidJty in thetonnation is such that if leached into groundwater
and discharged into the Piney River would ~ violate the ARARs for the river..
To evaluate the efficienCy 01 the treatment plant. influent and effluent samples would be taken'
and analyzed. Water to be r.injected into the burial pit would be analyzed for pH, sulfate and iron.
In addition, water to be discharged from the treatment process would be analyzed for the specific
metalS listed in the water quality standards for the site.
Discharge into the wetland from Area 1 would only be allowed when the water to be discharged
is comparable to the quality of influent water into the, wetland and provided such additional discharge
capacity would not adversely affect the performance Of the wetland. In any case, no discharge would
be allowed until the dissolution process is near completion.
Solids generated by the process would be subjected to EP Tex testing to determine if it'
disposal should follow the VHWMR and the LDAs or the VSWMR.
AREA 2
Alternative A2~: Surface Reoair of Unveaetated Areas
Capital Costs: $83,000.
Annual 0 & M Costs: $4,100.
. .
Months to Imptement e
Contaminated groundwat. seeps at the base of the slope in Area 2, which resulted in
destruction of the vegetative cover, would be cotIected using sub8uIface drains and routed to the
groundwat. bMb.W1I system. Iron"'. deposits . the base of the slope would be removed.
Regrading. IirI*1g d acidiIIed soli. and seeding would be done to re iii stab&18h a vegetative cover where
necessary. TNlII8mIIIYe would prevent precipitation of iron suIfat. salts at the base of the slope, and
therefore, reduce corurninart loading d surface water runoff from tni8 area. Routine maintenance
would be reqund.
AltematJve A2-S: ImoermeabI8 C8DDina
CapitaJ Costs: $1,888,000.
Annual 0 & M Costs: $9,000.
Months to Imptement 12.
. All costs and implementation times are estimated.
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21
The cap Sb'UCture! w~uId consist of a two foot thick clay layer, a symhetic membrane liner, a
one foot thick drainage layer. a geotextile filter fabric, and a two foot thick vegetative cover. This cap'.
could reduce the production of leachate from this area by nearly 100% during the 30 year life of the
symhetic membrane. VSWMR would be applied. Routine maimenance to repair erosion' damage.
cracks, and other damage to the cap would be required. .
. .
AREA 3
Alternative A3-3: Imorave Surface Drainaae
Capital Costs:
Annual 0 & M Costs:
Months to Implement:
$86,000.
$1,300.
3.
The surface of Area :3 would be regraded. limed. and seeded to establish a vegetative cover.
Regrading would imprave. surface water runoff from the area, and a vegetative caver would improve
evapotranspiration. Both help to reduce infiltration of rain water and subsequem comamination of
groundwater under this area Routine maimenance. would be required. .
Alternative.6.3-4: Clav Caocina
Capital Costs:
Annual 0 & M Costs:
Months to Implement:
$352.000.
$3.000.
12.
The cap structure would consist of a two foot thick clay layer and a two foot thick vegetative
cover. This cap would reduce the infiltration of water by 50%. VSWMR would be applied. Routine
maimenance to repair erosion damage. cracks, and other damage to the cap would be required.
Alternative A3-5: Imcermeable' Caooina
Capital Costs:
Annual 0 & M Costs:
Months to Im~
$505.000.
$3,000.
12.
. .
The cap structure would consist of a two foot thick day layer. a synthetic membrane liner, a
one foot thick dr.nag_layer, a geotextile filter fabric, and a two foot thick vegetative cover. This cap
would reduce the production of leachate from this areatJIJ neaI1y 100% during the 30 year life of the
synthetic mernbr8... VSWMR wouJd be applied. Routine maintenance to repair erosion damage,
cracks, and 0ChIr damage to the cap would be required.
. All costs and Implementation times are estimated.
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22.
AREA 4
Alternative 4-3: On site DisoosaJ in a Secure Landfill
Capital Costs: $1,452,000.
Annual 0 & M Costs: $2.600.
Mo~hstolmp~me~: 1~
This alternative would consist of excavating ~,OOO cubic yards of acidified, unreacted ore and
placing the material in a landfill in Area 3. The area would be regraded, "limed, and seeded to establish
a vegetative cover. Im~mentation would greatly reduce the contamination of groundwater and erosion
of acidified material in surface water runoff from this area. VSWMR and deed restrictions would be
applied. Routine mai~enance of the landfill cap would be required consiste~ with the requirements
ofRCRA.
Alternative~: Drainaae Controf and Reveaetation
Capital Costs: $183,000.
Annual 0 & M Costs: $1,300.
Months to Imptement: 6.
This alternative involves diverting surface water flow around this area, regrading the unreactec'
ore pile, covering with two feet of soil cover, and establishing a vegetative cover. Imptementation woulc..
reduce infiltration of water through the waste with subsequert contamination of groundwater by
improving drainage and increasing evapotranspiration in the area. Routine mai~enance of the
vegetative cover would be required.
Alternative A4-5: Imoermeable CaDDina
Capital Costs:
Annual 0 & M Costs:
Months to Imp&ement
$401,000.
$2.800-
12-
The cap structure would consist of a two foot thick day layer, a synthetic membrane liner, a
one foot thick drainage layer, a gect8Xtile filter fabric, and a two foal thick vegetative cover. This cap
would reduce ......., of .... to a rnininuTI and prevent erosion of acidic materials. VSWMR and
deed restricti0n8 would be appIed. Routine maintenance to repair erosion damage, cracks, and other
damage to the CIp would be required.
Alternative A4-7: AbcMt4r8de Dry Neutralizatton
Capital Costs: $702,000-
Annual 0 & M Costa: $1,300-
Months tol~ 8-
This alternative consisIs of the talowing steps: (1) ex~ of acidified, unreacted ore; (~,
addition of a neutralizing agd under dry condJtions; (3) compaction of the mixed material in p\aC8; (4)
-
AU COStS and Implementation times are 88timabd.
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.'23
.'
place two foot soli cap over material and establish a vegetative cover. . Implementation would neutralize. ,
leachate produced by infiltrating water while the vegetative cover would prevent erosion and promote
evapotranspiradon. VSWMR and deed restrictions would be applied. Routine maintenance of the
vegetative cover would be required.
AREA 5
,
Altemative A5-4: Drainaae Control and . Revecietation.
Capital Costs: $748.000*
Annual 0 & M Costs: $3.300*
Months to Implement: 6*
This altemative invotves diverting surface water flow around this area, regrading the sediment.
covering with two feet. of soil. and establishing a vegetative cover. Imptementation would reduce
infiltration of water through the waste with subsequent contamination of groundwater by improving
drainage and increasing evapotranSpiration in the area. This alternative would also reduce the erosion
of acidic sediment from this area into the Piney Rivet which has been identified as a major cause of
severe lowering of pH in the river.
Routine maintenance of the vegetative cover and diversion ditches would be required. Since
this area lies within a floodplain, a 100-year flood protection berm would be constructed around it in
accordance with the Executive Order 11988 (40 CFR 6, Appendix A ' Protection of Floodplains).
Altemative A5-5: Imcermeable Caootna
Capital Costs:
Annual 0 & M Costs:
Months to Implement:
*
$1,564.000
$7.000*
12.
The cap structure would consist of.a two foot thick clay layer. a synthetic membrane liner, a
one foot thick drainage layer, a geotextile filter fabric, and a two foot thick vegetative cover. This cap
would reduce infiltration of water to a minimum and prevent erosion of acidic materials. VSWMR and
deed r~ would be applied. Routine mairtenance to repair .-osion damage, cracks, and other
damage to the cap, and a 1~... ftood prctection berm would be required.
Altern.e M-7: AbcJve.Grade DfV Neutralization
Capital ColIs: $5.027,000.
Annual 0 & M Costs: $3.300.
Months to Implement 18-
This alternative consisIs of the following steps: (1) excavation of acidifted. unreacted ore; (2)
addjtjQn of a neutralizing agent under dry conditions; (3) compaction of the mixed material in place; (4)
p&acement of a two fact sol layer CNer the material and ~ of a vegetadve cover.
Impktmentation would n8W'81ize leachate produced by infiltrating Wlter while the vegetative cover would
- AM costs and implementation times are estimated.
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..
24
prevent erosion and promote .evapotranspiration. VSWMR and deed restrictions would be applied.
Routine maintenance of the vegetative cover and a 100-year flood protection berm would be required.
AREA 6
Alternative A6-1: No Action
Because no contamination was found in thit area. the no action alternative is appropriate for
this area of the site.
AREA 7
Alternative A7-3: On site Disoosal in a Secure landfin
Capital Costs:
AnnuaJ 0 & M Costs:
Months to Implement:
*
51,205,000
$2.600*
12*
This alternative would consist ~ excavating 15,000 cubic y.cts c:A acidified soil and placing the
material in a landfill constructed in Area 3. The area would be regraded, limed, and seeded to establish
a vegetative caver. Implementation would reduce the contamination c:A groundwater flowing through
this area and the erosion of acidified material in SUIface water runoff from this area. VSWMR and deed
restrictions would be applied. Routine maintenance ~ the vegetative cover and the landfill cap would
be required consistent with the requirements of RCRA.
Alternative A74: Drainaae Control and Reveaetation
Capital Costs: . $158,000*
Annual 0 & M Costs: $1 ,1 oct
Months to ImpIemetE 8*
This altematiYe inYoIve8 diverting surface -- and groundwat. fkM around this area,
regrading the uf8c8. . cov-*"g wiIh two felt of soil cover. and estab08hing a' vegetative cover.
Im~ wauId reduce ._tdb"I 01_. ttlrough the sol with subsequent contamination of
groundwater bf Improving drainage and increasing evapotranSpiration in the area. This alternative
would aJ80 redUce the .08I0n of acidic sectirnert.from this area into the Piney River. Routine
maintenance of.. ~ cover and diversion ditches and a 1QO.y.. ftood protection berm would
be required
Alternative A7-5: Imcermeable C8DDinQ
Capital Costa:
Annual 0 & M Co8t8:
Months to ImpIemetE
$348,rDJ*
$2.800*
8*
* All costs and im~ times are esttmaed.
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- 25
!
The cap SlnJeture would consist of a two foot thick clay layer, a synthetic membrane liner, a ,
one toot thick c:IraW1age layer, a geotextile filter fabric, and a two toot thick vegetative cover. This cap
would reduce infiltration of water to a minimum and prevent erosion 01 acidic materials. VSWMR and
deed restrictions would be applied. Routine maintenance to repair erosion damage. cracks, and other
damage to the cap, and a 1 OO-year. flood protection berm would be required.
Alternative A7.7: Above-Grade Drv Neutralization
Capital Costs $286,000.
AnnuaJ 0 & M Costs $1,100.
.
Months to Implement:, 6
. This alternative would be implemented in conjunction with the wetland process for ~reating
groundwater. It consists of the following steps: (1) excavation of acidified soil; (2) addition .of a
neutralizing agent under dry conditions; (3) compaction of the mixed material; (4) placement of mixed
material around the wetland as a berm and (5) estabUshment of a vegetative coYer. Surface water run.
off would be diverted ~ay from the area. Implementation of this alternative would neutralize leachate
produced by infiltrating water while the vegetative cov.er would prevent erosion. Routine maintenance
of the vegetative cover and a 100-year flood protectio!" berm would be required.
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26
SUMMARY OF COMPARATIVE ANALYSIS OF AL1CRNA11VES.
This section summarizes the comparative analysis of alternatives presented in the analysis
section of the RIIFS report and its addenda. The definitions of the nine point criteria used in the
evaluation are presented in Appendix II.
Overall Protection
The In-Situ Dissolution and Treatment (A 1-10) and the Above-Grade Wet Neutralization (A 1 -8)
alternatives would be protective of human health and the environment by providing permanent and
complete treatment of the waste in Area 1, the area of the site contributing the greatest percentage of
contamination to groundwater. as identified. in the SRI. All the other alternatives examined for Ar~a 1
would not be protective because they involve the continual presence of copperas in the soil. Copperas
in Area 1 accounts for two thirds of the acidic problem at the site.
The alternatives of Capping, and Drainage Controls and Revegetation examined for the
remaining areas of the site would be protective by reducing the amount of contamination reaching-
groundwater and eliminating erosion of acidic material by surface water run-off from the site.
Groundwater collection and treatment alternatives woutd also be protective of human health and the
environment.
The No Action alternative would not be protective of human health and the environment
because contaminant levels in the soil and groundwater would continue to exceed levels protective of
the shallow aquifer (which discharges into the Piney River) and the Piney River (Table 1). .
Comcliance with ARARs
The In-Situ Dissolution and Treatment. and the Above-Grade Wet Neutralization alternatives for
Area 1 would meet chemical, location and action specific AAARs. The disposal 01 solid wastes from
these alternatives would comply with the VHWMR and the RCRA-LCRs or the VSWMR. All applicable
or relevant and appropriate requirements (ARARs) of FederaJ and State laws for surface water would
also be met. Monitoring of the efftuent from the groundwater treatment system and any discharge from
the chemical treatment systems for Area 1 would be required to assure compliance with the discharge
limits estabUshed bV the YWca. Remedial alternatives - for Areas 5 and 7 would also comply with
F ederaJ and s... Laws for the protection of ftoodpfalns.
Lona-term E~ and Permanence
The In-Situ Dissolution and Treatment, and the Above-Grade WfIt Neutralization alternatives for
Area 1 would provide for permanent treatment of the most contaminated waste on the site. By
completety treating the waste in Area 1, the maior source of groundwater contamination would be
eliminated. .
Capping the waste would not provide for a permanent solution. The cap installed previously
has not functioned property allowing water to infiltrate the waste. eeca, ase a substantial amount 01
water has entered the burial pit. compaction of the waste to support the new cap may no longer be
possible. Beca'1M of the high solubility of the copperas waste, the possibility of the cap failing would
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.. .27
.'
aJways exist as long as the waste remains in the burial pit. An aggressive maintenance program .
beyond the pcop
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..
28
\/WCB should not creareany delays because of the agency,s extensive involvement at the ,site in the
paSt. No other 8dmin~e difficulties are anticipated. Contractors and materials to pecform the worK
are readily availabkt. No special equipment or supplies should be required.
Costs
A summary of costs for the remedial alternatives is shown in Table 2. Costs shown are in
$1,000's and represent the total of capital costs and 30 year present worth of annual 0 & M costs.
The '. No ActiOn costs would apply to the entire site. not just Area 1. .
SUDDort Aaencv Acceotance .
The Commonwealth of Virginia accepts the recommended alternative as presented in this
document.
CommunitY Accectance
The Community expressed a very strong acceptance at the setected remedy at a Public Meeting
held on August 9. 1989. The comments receiY8d during the public comment period which are
summarized in the ResponsiveneSS Summary section also show that the public Is very pleased with the
selected remedy. .
-------
Table 2. SWlllllary of costs. for Detailed Remedial Alternatives
Area of Site
Reaedial Alternative Area 1 Area 2 Area 3 Area 4 Area 5 Area 6 Area 7 GW Coll. GW Tr~at.
No Action $ 388"
pas.ive GW Collection $ 173
Passive GW Treataent $ 431
Active GW Treataent $5,560'
Clay Capping $ 533 $399
I.paraeable capping $ 558 $2,017 $552 $ 444 $1,674 $ 389
.
.
Above-Grade Wet Neut. $12,567
Neutralization/Capping $ 1,281
Diaaolution/Treataent $ 3,962
Drainage Control/
Revegetation $ 141 $106 $ 202 $ 814 $ 175
On aite Landfill $1,493 '$1,246
Above-Gracie Dry Heut. $ 121 $5,018 $ 303
.
All costa are in $1,000'8 and include 30 year present worth of 0 & H.
Cost for Ho Action includes all areas of the site, not just Area 1.
..
N
.\0
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30
SElECTED REMEDY
Based upon consideration of the requirements of CERClA, the detailed analysis of the
atternatives, and pubtic commentS, both EPA and the Commonwealth of Virginia have determined that
the following combination of atternatives is the most appropriate remedy for cleaning up the site:
-, -nEAlUENT COMPONENT
ESnMATED
COST
Groundwater:
Collection: Passive Collection System (GW-2)
173,000
Treatment:
Passive Treatment System (WT-2)
431,000
Area 1: In-situ Dissolution and Treatment (A 1.10)
Area 2: Surface Repair of Unvegetated AreaS (A2-4)
. 3,962.000
Area 3: Improve Surface Drainage (A3-3)
Area 4: Drainage Control and Revegetation (A4-4)
. 147,000
106,000
202,000
Area 5: Drainage Control and Reveget8tion (A5-4)
Area 6: No Action (A6-1)
874,000
o
Area 7: Above-grade Dry Neutralization (A7-7)
(in combination with wetland)
o
TOTAL: .
5,895,000
The selected remedy consists of dissoludon and ~ of copperas waste in Area 1.
Drainage co.lboll and ~ would be implemented in At8a8 2, 3.4 and 5. Area 6 requires no
remedial action. AcicIfted 801 In Area 7 would be mixed with lime to neutralize any leachate.
Groundwat. wauId be coI8ct8d by using subsurface drains and trenches with treatment in a
constructed w I1IIUd. 'The wedand treab,..lt would be supplemented with active treatment processes
necessary to .... .. di8ch8rge requirements. . .
Some change8 may be made to the selected remedy as a ~ of the remedial design and
constructJon procell"
Remediation Goals
The purpose of this response action is to co.~01 ri8kI posed by actdiC discharge imo
groundwat. and the Piney RIver. By eIIrnnIing moll of the 8CUC88 of acidic di8charge into the river.
the remedial action wiD prevent future fish killl and stop further I88ctW1g of metals and continued
degradation of the Piney Riv.. This remedy wiI addr8s8 aI the six area of the site that have been
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. 31
.
found to be the sources of contamination.
Since no Federal or Stme ARARs exist for soils, the action level for the in-situ dissolution and
leachate collection remedy for Area 1 would be detennined using fate and transport modeling to
determine the level to which acidic producing potential of the soil should be reduced in order to ensure
that the leaching of contaminants to groundwater and surface water above levels protective of the
Piney River as determined by the SWCB would not continue. At a minimum, the leaching shall not
cause the Piney River to exceed State Water Quality Standards.
,
The termination of in-situ dissolution and leachate collection would be determined using the
results of soil boring tests, and fate and transport modeling to estimate the potential of groundwater
contamination that could result from the migration of residual contaminants in the soil. The leaching'
process shall be stopped when (1) soil boring tests show that no sigl"!iflcant amount of copperas
remains in the pits, and (2) the .residual acidity in the formation is such that if leached into groundwater
and discharged into the Piney .River would not violate the ARARs for the river. .
Discharge from Area 1 into the wetland would only be allowed when the water to be discharged
is comparable to the quality of influent water into the wetland and provided such additional discharge
capacity would not adversely affect the performance. of the wetland. In arty case, no discharge -Nault!
be allowed until the dissolution process is near comPletion. Any discharge into the Piney River must
meet the discharge limits set forth in Appendix I.
All solid wastes generated during the remediation process would be subjected to EP Tox
testing and then disposed of according to VHWMR and RCRA-LDRs (Federal) or the VSWMR.
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..
32
STATUTORY DETERMlNA110NS .
Under its legal authOritIeS. EPA's primary responsibility at Superfund sites is to undertake
remedial actionS that achieve adequate protection of human health and the environment In addition.
section 121 of CERCLA establishes several other statutory requirements and preferences. These
specify that when compklte, the seleCted remedial action for this site must compty with applicable or
relevant and appropriate environmental standards established under Federal and State erivironmentaJ
laws unless a statutory waiver is justified. The selected remedy also must be cost-effective and utilize
permanent sofutiOnS and alternative treatment tech~ieS or. resource recovery technologies to the
maximum extent practicable. . Finally, the statute includes a preference for remedies that employ
treatment that permanently and significantly reduce the volume, toxicity, or mobility of hazardous waste$
as their principal element. The folJowi~ sections discuss how the selected remedy meets these
statutory requirementS.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment through treatment of the
copperas waste in Area 1, the area of the site contributing the greatest percentage of contaminatiort
to groundwater; stabilization of other areas by implementing drainage. controls and establishing
vegetative covens; and collection and treatment of contaminated groundwater. These measures would
reduce the amount of contamination reaching the Piney River and eliminate erosion of acidic material
by surface. water run-off from the site. .
AJI sofid residuals and wastes that result from the implementation of the selected remedy would
be property classified and disposed of and would not pose any environmental or health hazard. There
are no shoft-tenn threats associated with the selected remedy that cannot be readily controlled. In
addition, no adverse cross-media impactS are expected from the remedy.
Comcliance With AoDlicable or Relevant and ADDrODriate
Reauirements
The selected remedy wiD compty with all applicable or reIewnt and appropriate chemicaJ-,
action-, and Iocation-specific requirements (ARARs). All ReRA authority has been detegated to the
Commonwealth 01 VIrginia except thOse under the 1984 Hazardou8 and Solid Waste
Amendmera(HSWA). The ARAR8 are preser«ed bebw. Monitoring of the effluent from the
groundw..- b....... 8y8t8m wiI be required to 8S8Ur8 compli8nce with the discharge limits
established ~ .. VWCB. AI aI8m8Iive8 wouJd be imptemented and maintained until surface water
standard8 .. ....... In the PIney River, and toxicity to the ~ ~ community in the Piney River is
eliminated.
AdIarHpecIIc ARAA8:
Implementation 01 the selected remedy wiI inYoIv8 the disct\Irg8 of treated eftIuent into the
Piney River. Section 402 of the Federal W.. Pollution Control ~ requires tt.- a point source
discharge 01 pollutants into surf8c8 wat. be done pursuant to a Nadonal Pollution Discharge
Elimination System (NPDES). The NPOES system In Virginia is adminiStered by the W/CB
under its penna Regulation VR-680-14-01. Etftuert Ilmbtions and other discharge requirements
have been develOped by the VWCB and are presented in AppendiK I.
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33
! "
The site was associated with mining operations in the past. Virginia Departmem of Mines.
Mineral and Energy regulations contain closure requiremems for surface mining of minerals"
other than coal. "
The selected remedy would require soil excavations particularty during the construCtion of the
wetland. Soil & Sedimem Erosion Comrol of Nelson County, Virginia, and the Virginia
Departmem of Conservation and Historic Resources, Division of Soil and Water Conservation
require erosion comrol plans for. excavations and earth moving of areas greater than 10,000
square feet.
ChernicaHpeciic MARs:
The chemical-specific ARARs for the selected remedy have been provided by the w.lCB and
are presented in Appendix I. These satisfy the Federal Water poliutio"n Control Act (Section 33
U.S.C. 1251 et seq.) and the Virginia State Water Control Law (Section 62.1-44.14(3) '-of the
Code of Virginia). "
location-specific ARARs:
location-specific ARARs include 'Executive Order 11988 (40 CFR 6, Appendix A - Protection 01
FlOOdplains). Areas 5 and 7 lie within a 100-year floodplain.
Land ~aI Restriction
The Land Disposal Restrictions (lORs) of the Hazardous and Solid Waste Amendments (HSWA)
to RCRA place" restrictions on the land disposaJ of RCRA hazardous wastes. At present there
are no RCRA Subtitle C wastes at the site and as such the restrictions do not apply. However.
should any of the wastes resulting. from the remedial action be classified as a RCRA Subtitle
C waste, the lORs would become applicable. LDRs" also prohibit the use of any waste or
sludge from the treatment process as a backfilling material. . .
Other Crt8ia. AOrisories or Guidance To Be CoIasidered for This Remedial Action (TBCs)
Local deed restriction to prohibit excavation at any of the contaminated areas 01 the site and
the wetland to be constructed even atter the remedial action is complete unless all residual
contamination is known to have been eliminated.
OSHA requirements th8t regulate worker safety and employee records during all site work
(OSHA 011970, 29 U.~.C. 651).
All ""..... remaining" on site would comply with all ARARs as required by CERCLA Section
121 (d)(2)(A)(I) and 00.
Cost-Effectiveness
The selected remedy is cost-effective because it has been determined to provide overall
effectiveness proportional to its cost. the net present worth being $5,895,000. The estimated cost of
the selected remedy is less than twice the cost associated with neutralization and capping the waste
in Area 1 ($3,214,000), and yet the selected remedy assures a much higher degree of permanence and
long-term effectiveness since the ma;or source of contamination at the site would be permanently
destroyed. The current cap on the waste has failed in many areas and nt-capping the waste would
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..
34
not provide a permanent solution. The selected remedy will effectively reduce the current hazards
posed by the site by significantly reducing acidic and toxic metal .discharges into the Piney. River.
Utilization of Permanent SolutionS and Alternative Treatment
Technoloaies (or Resource Recoverv Technoloaies) to the Maximum Extent Practicable
EP A and the Commonwealth of. Virginia have determined that the selected remedy represents
that maximum extent to which permanent solutions and treatment technologies can be utilized in a
costJeffective manner for the final source control at the site. Of those alternatives that are protective
of human health and the environment and comply with ARARs, EPA and the Commonwealth of Virginia
have determined that the selected remedy prQ\'ides the best balance of trade-offs in terms of lon9..
term effectiveness and permanence, reduction in toxicity, mobility, or volume achieved through
treatment, short-term effectiveness, implementability, cost, also considering the statutory preference for
treatment as a principal element and considering State and community acceptance.
The selected remedy will significantly reduce the inherent hazards posed by the presence of
acidic producing wastes at the site and thus offer a high degree of long-term effectiveness and
permanence for the site. The selection of a treatment optiOn for the waste in Area 1 is consistent witl1
program expectations which indicate that priority corisiderarion for treatment of highly mobile wastes
is often necessary to ensure the long-term effectiveness of a remedy. The selected remedy has
therefore been determined to be the most appropriate solution for the U. S. Titanium site.
Preference for Treatment as a PrincicaJ Element
By treating the waste in Area 1, the selected remedy addresses a principal source of threat
posed by the site through the use of treatment technologies. Therefore, the statutory preference for
remedies that employ treatment as a principal element is satisfied.
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35
APPENDIX I
EFFLUENT UMITATIONS AND MONITORING REQUIREMENTS
Effluent limits for discharge from the groundwater treatment system into the Piney River are
required at this time for pH and Total Iron for which substantial effluent data exist. Iron isa principal
. contaminant of the wastewater and must be control~ in order to meet water quality standards, reduce
the toxicity impact of the discharge, and minimize the solubility of any toxic metals present in the
discharge. .
In addition, a Toxic Management Program (TMP) incorporating effluent biological toxicity
monitoring, effluent chemical monitoring for seleCted priority pollutant metals, and benthic surveys in .
the Piney River shall be maintained. . . .'
The required limits for discharge and TMP are as follows:
Total Iron
The effluent limit for total iron is 97,583 micrograms per liter (10.7 kg/day, monthly average and
21.4 kg/day, daily maximum). This is based on a design flow of 0.0288 million gallons per day.
Monitoring shall be conducted twice a month, Grab.
QI:i
The effluent limit for pH is 6.0 to 9.0. The discharge shall be mOnitored once a day, Grab. (A
reduction in the monitoring frequency wiU be consider8d after suftIdent data have been collected and
evaluated by the 'MCB). The efftuent Umit is equal to the pH range specified in the Water Quality
Standards (Was) for Piney RIver. Controt 01 pH is crucial to assuring maintenance of the WQS in
the receiYing stream which has essentially no buffering capacity. Maintaining effluent pH in the
proposed range wiN also reduce the solubility of 8nJ toxic metals present In the discharge and the toxic
impact on the receMng stream.
Chemical Oxvaen Demand
No .... ImI 18 proposed for Chemical Oxygen Demand (COD) tU monitoring shall be
conducted twlc&a.rnonIh, Grab, In order to determine whether the discharge of reduced species, e.g.,
ferrous iron. ....,- be exerting an immediate oxygen demand in the rtYer. Should evidence of a
sign~ oxygen demand In the di8charge be ~8d. additional efftuent limitations would be
imposed to mairUin was.
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c.
d.
..
36
Toxic Manaaement Proaram
The key elementS of the Toxic Management Program (TMP) for the U. S. Trtanium site are as
follows:
Semiannual acute toxicity tests on starmwater runoff discharge for a period at two years using
Dachnia outex and Pimeohales. DrOfT18Ias. .
. ,.
Quarterty acute toxicity tests on the wetJands treatment system effluent for a period of one year
using Dachnia culex and Pimeohales DromeIas. .
Semiannual priority pollutant metals. anaJyses in conjunction with semiannual toxicity testing and
quarterly priority pollutant metals analyses in conjunction with quarter1y toxicity testing. .
An initial priority pollutant and non-priority pollutant extractable and volatile organics chemical
analysis of the wetlands treatment system effluent concurrent with the first acute toxicity test.
Semiannual benthic macroinvertebrate surveys in the Piney River shall include the same station~
as have been used in the surveys previouslY conducted by the State Water Control Board.
Copies cA these surveys may be obtained upon. request. .
The following presents the details at the Toxic Management program.
1.
Bio'oaical Monitocina:
a.
Commencing within three months of the effective date cA the wedands treatment system
operation, quarterty acute toxicity tests shall be conducted for a period of one year on 24-hour
composite samples cA effluent from the wetlands outfall and conduct semiannual acute toxicity
tests for a period of two years on grab samples cA stormwater runOff from the site. The acute
tests shall be 48-hour static tests using Oachnia DUIex and ~ static tests using
Pimechales cromeIa8. boIh conducted in such a manner and at sufficient dilutions for
calculation of a valid LC50. Technical aaistance in developing the procedures for theses tests
shall be provided by the State Water Control Board staff, if requested by the discharger. Test
protocol8 and the use of alemative species shall be approved by the State Water Control
Board .." prior to ~ d. testing.
If the LCIO .. ~ than or equal to 1~ eIIkJent in 6 or men d the total of 8 acute toxicity
tests CGldICt8d on the W8dandI emuer.. the operator shall continue acute toxiCity testing of
wedandI ....... annually. The h annuaa tests shaM be conducted wittin ttvee months d the
last q&Mt8rtf t.... The t.. org8I1iIrM shall be those ide8 dI8d as the most sensitive sPecies
from the qu8t8rty acute t8ltl or alternative spedes approved by the State W.er Contra Board
staff.
b.
If the LC50 is greater than or equal to 1 ~ eftIuent in 6 or more of the tOtaJ of 8 acute toxicity
tests conducted on the stormwater runoff, the runoff shaM be consider8d to be uncontaminated
an no further testing shall be required.
If the LC50 is less than 1 ~ efftuent in 3 or more out of the total of 8 acute toxicity tests for
either eftIuent. a toxicity reduction evaluation wiU be required for that efftuent.
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b.
c.
37
e.
If, in the testing according to (b) above. any of the annual acute toxicity tests yields an LCSO
of less than 100% effluent, the test shall be repeated within 3 months. If the retest also
indicates an LCSO of less than 100% effluent. quarterty toxicity testing as in (a) above shall
commence within three months. The results. of these tests will be included in the evaluation
of the need for toxicity reduction. If the retest does not confirm the results of the first test, then
annual testing shall resume.
2.
Chemical Monitorina: .
a.
Within three months of the effective date of the wetlands treatment system operation, the
operator shall collect one 24-hour comJ)9Site sample of the effluent from the wetlands treatment
system outfall, except in the cases of volatile organics, phenols and cyanide analyses. where
grab samples are required. These samples shall be analyzed for the following: .
(1) Priority pollutant and non-priority pollutant extractable and volatile organics using EPA's gas
chromarography-mass spectrometry methods 624 and 625, or other equivalent EPA approved
methods. The operator shall report all priority poUutant organics present at the method
detection limits established in methods 624 anti 625. In addition, for each sample, the operator
shall tentatively identify a maximum of thirty organic substances which are detected but are not
listed as priority pollutants. All of the non-priority substances of greatest apparent
concentration for each volatile fraction, to a maximum of 10, and all of the non-priority
substances of greatest apparent concentration for the combined baselneutrallacid fraction, to
a maximum of 20, shall be tentatiVety identified.
(2)
Pollutant
Minimum Detection
limit (matn
Total phenols
Total cyanide
0.010
0.020
Within three months of the effectNe date of the wetlands treatment system operation and
continuing quarterty for a period of one year, the operator shall collect 24-hour composite
samples of the efftuent from the wetlands treatment sv.tem outfall
Within thr8 rnonIh8 of the effectIye date of the wetlands ~I" system operation and
contirU1g eemiamuaIIy for a period of two years. the operator shall collect grab samples of
the ... from the stormwater discharge outfall
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.
38
d.
The samples collected in (2.b.) and (2.c.) shall be analyzed for the following pollutarits:
Pollutant
Total recoverable antimony
Total recoverable aluminum
Total recoverable arsenic
'. Total recoverable beryllium
Total recoverable cadmium
Total recoverable hexavalent chromium. .
Total recoverable chromium .
Total recoverable cob8Jt
Total recoverable copper
Total recoverabte lead
Total recoverable manganese
Total recoverable mercury
Total recoverable nick..
Total recoverable selenium
Total recoverable silver
Total recoverable thallium
Total recoverable zinc
Minimum Detection
limit (main
0.010
0.010
0.010
0.010
0.001
0.010
0.010
0.010
0.001
0.001
.0.010
0.0002
0.010
.0.010
.0.0002
0.010
0.010
The chemical analyses in (2-d.) shall be conducted using EPA approved methods. The
operator shall obtain approval from the Stare Water Control Board staff before using non-EP A
approved test methods, or detection limits other than those required in this special condition.
e.
The sampling requirements in (2.b.) and (2.c.) shall be conducted in conjunction with the
biologicaJ monitoring required in (1) whenever possible. When the results of biological testing
at the wetlands treatn I8f'1t system effluent indicate the necessity for resuming quarterty toxicity
testing. the quarterty sampling and chemical analyses described in (2.b.) and (2.d.) ,
respectiYefy, shall also resume. .
Benthic MacroinY8rtebra-. Survev:
f.
3.
The ope.tIIOt shall conduct 8niannuaI macroirMMtebr8te surveys at the Piney River during
April and 88pIember for 1h8 first thr88 years at the W8dands ~ ....-. system operation. The
SUMIV ~~ shall be designed In accord8nc8 with EPA publication EPA-87014/73-001 , July
1973, WDIDgtcaI FIeld and Laboratory Methods for M..urtng the Quality at Surface Waters and
EfftuenI8.8 TIChtIical 888i8tance in deYeIoping the procedures for this SUMIV shall be provided
by the s.. W.. CcdroI Board staft, if requested by the discharger. Survey protocols shall
be approved by the St88 w.. Contra Board staff prior to initiation at the survey.
a.
The macroinvertebnb surveys shall include the same stations as have been used in the
surveys preyiousIy conducted by the State Wat81 Control Board. Copies at theSe surveys may
be obtained upon reqlJlll
b.
Data required In the survey shaI include station number, statiOn location, disscWed oxygen, pH,
temperature. habitat description. organism identification, number of organisms, diversity
calculations, and appropriate comments.
c.
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III5I1YI
GrO&ntlMlter
GrO&ntlMlter
surface "ter
Surface lunoff
W8UMd Tr..t-
8Mt Sy8t-
SoU.
lot..:
1-
2.
3.
...1 '''1116 SCIIEDUlE
LGClltl-.
,
'er.-eters
F reauenc:v
1/Qtr. for 2 years1
Wett. 1,2, 5, 6,
1, 8, EPA-I, l'A-2,
lPA-3, l'A-4, EPA-5,
, SOl, 5-5, 5-8, '-9
pH. conductivity, sulfote
tot. di.. Fe. acidity
GW eley.tlon
... .. 8bov8
2/Yr. for 2 yeer.3
AI. 8e, Cd. Cr. cU2 CN.
Pb. Hg. Se. Ag, Zn
Piney liver
Ste- 1. 3, 5, 6
1/Mo. for yeers'
pH. conductivity. 8ulfate,
tot. dl... Fe, acidity
Ite. 1, 8
S.. effluent li.ltatlons and 8ORitoring'requlre.ent.
provided ..rller In thi8 Appendix. .
"
Influent & Effluent
See effluent ll.itations and 8onitorfng requfr88eRt8
provided eerl,er In thl8 Appendix.
Are.. I, 2, 3, 4,
5, 1
Sufficient to deter.lne fertilizer
& ll.. requlr-.nta
I/Yr.
A requnt for recU:tlon In fr..-ncv lIi1l be considered .fter 2 ye.n of dat. hev. been evaluated.
Thl. ll.t of per_tera -y hev. to be reviled pending r..olution of the queation ral.ed .arller
r8l8rdlng the GWQS .. AlAI'..
A requnt for recU:tIon in fr..-ncy end ......r of per_ten IIi II be considered .fter 2 y.era
of date have been ev.luated.
~
,0
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39 '
4.
Toxicitv Reduction Evaluation:
a.
11 the results of this Toxic Management Program or other available information indicate that the
wastewaters are discharged in toxic amounts, the operator shall submit a toxicity control plan
and an accompanying implementation schedule within 120 days of the notification of such a
determination by the State Wciter COntrol Board. This plan shall be. designed to evaJuate
effluent toxicity and assure that no toxic- substances are released into State waters in
concentratiOnS that will affect survival, growth or reproduction of any species which would
reasonably inhabit those waters. . --
The control plan shall include an evaluation of appropriate measures, bOth immediate and .Iong .
range, such as additional waste treatment or changes in the operation of the facility I to reduce
the toxicity of the wastewater discharge to acceptable levels. .
b.
'.
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41
.. INsPeCT10N AND MAINTENANCE SCHEDULE
Area
Freauencv
Groundwater Collection System
Inspect once/qtr. for 1 st yr.; 2/yr thereafter. Perform
. maintenance as indicated by inspections. :
Groundwater Treatment System
Inspect at least as frequently as. monitoring is
performed. Perform maintenance as indicated by
inspections. .
Area 1
If All AJ-8 is implemented, this is N/A, although.
monitoring and other requirements will be required for
the treatment facilities.
Area 2
Inspect 2/yr. Performance maintenance as indicated
by inspections.
Area 3
Inspect 2/yr. Performance maintenance as indicated
by inspections.
Area 4
InspeCt 2/yr. Performance maintenance as indicated
bY inspections.
Area 5
If All A5-4 is implemented, inspect one/qtr. for 1st yr.;
2/yr. thereafter. Perform maintenance as indicated by
inspections. .
Area 6
None
Area 7
Inspect 2/yr. Perform maintenance as indicated by
inspections. Applicable to part ~ Area 7 not included
in wedand treatment system.
Make an initial evaluation of structural integrity and
capability ~ providing representative samples.
Inspect for same thereafter in conjunction with
groundwater monitoring.
Monitoring Wells
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42
APPENDCX A:
" "
DESCRIPTION OF EVALUAT10N CRITERIA
Overall Protection of Human Health and the Environment - addresses whether or not a remedy will:
cleanup a site to within the risk range; result in any unacceptabte impactS; control the inherent hazards
(e.g., toxicity and mobility) associated with a site; ~ minimize the short-term impactS associated with
cleaning up the site.
Comcliance with ARARs - addresses whether or not a remedy will meet all of the applicable or relevant
and appropriate requirements of other enVironmental statutes and/or provide grounds for invoking a
waiver.
Lona-term Effectiveness and Permanence - refers to the abUity d a remedy to maintain reliable
protection of human health and the environment over time once cleanup goals have been met.
Reduction d Toxicitv. Mobilitv. or Volume throuah Treatment - refers to the anticipated performance of
the treatment technologies that may be employed in"... remedy. -
Short-term Effectiveness - refers to the period 01 time needed to achieve protection, and any adverse
impacts on human health and the environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
Imclementabilitv - describes the technical and administrative feasibility d a remedy, including the
availability d materiaJs and seMces needed to imp&ement the chosen solution.
Cost - includes the capital for materials, equipment, etc. and the operation and maintenance costs.
Succort Aaencv Acceotance - indicates whether, based on its review d the SRI, FS, and Proposed
Plan, EPA concurs with, opposes, or has no comment on the preferred alternative.
CommunitY Acceotance - is ass9S8ee1 here in the Record of Decision following a review 01 the public
comments received on the SAI, FS, and the Proposed Plan.
i"
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43
PART C
RESPONSIVENess SUMMARY
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.
..
44 .
RESPONSIVENESS SUMMARY
I. OVERVIEW
A pubUC meeting was held in Levingston. Virginia on August 9, 1989 to discuss the Proposed
Plan for Cleanup at the U.S. Titanium Superfund site in Piney River. The pubtic comment period for
written and oral comments on the Proposed Plan e~ended from July 31 through September 29, due
to a" request granted by the Virginia Department 01 Waste Management to extend the comment period
by 30 days.
. The Preferred Altemative specified by the Department 01 Waste Management at the' public
meeting, and throughout the Comment period. addresses both groundwater and soil contamination at
. the site. The Preferred Altemative involves in-situ dissolution of the copperas/soil mixture in Area 1, the
copperas landfill; above-grade dry neutralization of acidic soils in Area 7; and surface repair and/or
revegetation throughout the other areas identified on site as needing remediation. Groundwater would
be collected through a series of subsurface drains and trenches, and channeled to a wetlands
treatment system on-site.
Judging from comments received during the public meeting and throughout the public comment
period. the residents and Nelson County Administration strongly support the remedy proposed by the
Department of Waste Management. The interested community, composed largety of members of the
local Blue Ridge Sierra Club. adamantly expressed their desire for a long-term, treatment technology
to be used in remediating acidity at the site. A very small minority of community residents. composed
mainly of former American Cyanamid employees, as wetl as the PRP itself, ob;ect to the long-term
treatment technology proposed by the State. The PRP. American Cyanamid, favors a clay cap for Area
1. The small contingent of residents that oppose long-term treatment favor either the clay cap
proposed by the PRP, or do not feet atrf action is necessary at all. The vast ma;omy of the community
and community officials oppose capping due to the failure of the cap placed on Area 1 in 1980, and
a general preference for permanent treatment.
The following sections comprise this Responsiveness Summary:
. Overview
. Background on Convnunily Involvement
. SwnmIry of Comments Received During Public Comment
Period and the Departrner«'s Responses
. Appendix A: Community Relations Adivitie8 Conducted at
the U.S. Tbnium site comrntriy
. Appendix B: SuppIementaIlnfonnation
. Appendix C: Citizen letters submitted to VDWM
. Appendix D: Glossary of Superfund Terms
. Appendix E: Index 01 Documents for the AdministratIve Record FUe
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. 45
II. BACKGAOUN) ON COMMUNrTY INVOlVEMENT .
I
I -
While the U.S. Trtanium site is located in a predomin8nt1y rural area, there has 'been
considerable interest among residents since the late 1970's fish kills. The local Blue Ridge Chapter of
the Sierra Club was formed after the fish kills to monitor site-related activities. Many of the membership
live along the Piney or Tye Rivers, and strongly support the use of the rivers for recreational activities
and tourism lures. Since American Cyanamid was once the ma;or employer in the area. there are
several former employees that support the remed~ option suggested by American Cyanamid.
In 1980, a local attorney took action representing several people who resided along the Piney
and Tye Rivers. This attorney actively solicited information from the State'Water Control Board and the
State Department 01 Health, Division 01 Hazardous Waste Management. All in all, correspondence
indicates that there was considerable concern about the Impacts 01 the contaminants of river life, and'
a good degree of interest in the remediation of the site. This group closely followed activities lea~ing
to the installation of the clay cap over Area 1, the copperas burial pit, and hired their own environmental
engineering consultant to review the option. They expressed concern that the project must be carried
out according to the specffications if it were to be successful. The correspondence also indicated that
the attorney representing residents did not feel that the Agencies' response to information requests was
adequate at that time. . . .
Many of the same residents that were interested in site remediation early in the process
continue to be very active now. The same concerns surfaced at the public workshop, meeting, and
during the comment period, by and large, that surfaced in the beginning at the process. Upon
receiving information on the process and the technologies proposed, the public responded with interest
and asked in-depth questions. The local media have followed site activities consistently.
Activities sponsored by the Virginia Department of Waste Management have gotten good
response, and workshops and public meetings have drawn between 25 and 75 peopte. A list of
community relat~ activities can be found in the Appendix A.
III. ~.RY OF COMMENTS AK) RESPONSES
The attendance . the pubic meeting was approximately 75 people, including residents, local
government oIIIci8II. State 1'8p'888rUtJYes, EPA representatiYe8 American Cyanamid representatives,
and media. The mlBtltlQ lasted .. and a half hours, and there wai considerable interest exhibited by
the public. ou. than 81 the meeting, very few comments arrived by mail or by telephone. All of these
comments .. unmartzed and responded to in this docurner-..
The p(.m8y concema held by citiz- and local officiIII8 IrwoIve the following:
. Adverse impact 01 the site contamination on the future economic development of
the County, and on recreatIon8I use of the rivers.
. Acidic seepage leaching metals from the sol Into the groundwater, and into
the Piney River.
. Monitortng the groundwater and surface waler for acidity and heavy metals.
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46
. The integrity at a contractor that is selected by PRP to do RD/RA wor1(.
. The availability of ongoing public participation opportunities.
. The implementation of a permanent, treatment-oriented. cleanup plan.
Strong support haS been voiced for the Proposed Plan issued by the State, with the
concurrence of EPA. due to its permanent, treatment-oriented direction. The people of the community, .
who t)ave been very active throughout site remediation history, voiced a desire to have the problem
eliminated "once and for air. There is strong support from the public for extensive monitoring, including
residential wells and the Piney and Tye Rivers, to ensure the effectlv~ of the treatment systems.
There is also concern about heavy metaJs from the soil leaChing into ground and surface water with.
the acidic runoff. The public at large also showed a good deaJ of concern about the PAP selection of
the contractor to do the wortc. and urged the State and EPA to screen and monitor the ~hoice very
closely to ascenain that the job is done correctly. The. public wants to continue being included in the
infonnation clrde with regards to these activitieS.
The ma;ortty of commentOf'S adamantly opposed the plan - forth by Hydrosystems. on behalf
at American Cyanamid, one of the PAPs, to cap the copperas burial pit that is Area 1. Opposition to
the capping proposal stems from the failure of the cap'installed in 1980 and the resultant environmental
problems, and the desire for a permanent solution. .
A representative for the PAP stressed that American Cyanamid was only one of a number of
Potentially Aesponsible Parties, and was so far the only PAP that was willing to step forward and take
pan in the remedial process for this site. The State concurs with this fact.
The general areas of comment and concern, with responses, follows. Supplemental information
for some of the comments can be found in Appendix 8, and letters fOcwarded by citizens are compiled
in Appendix C. .
iliA Gene8a1 Co..8.aerD
Comment: Mr. Stephen Lamanna. a local citizen, wrote two letters to the depaI1ment saying that
the buried material . the Piney Riv. site now is essentia11y water insotuble residues. Mr.
Lamama hotd8 that ~ is no problem, and there is no chance that a fish kiD can occur
~.. tt88. isn't enough f8rrou8 .... In the ... area.' Mr. Lamama alSo referred to his
own ~ .... of th8 PIney RIver which, he said. !ndk*ed that the pH kMIIs are fine.
Ae8()O(- T.-Jng tJII the State and EPA has shown residual acidity . the site that continues
to ~ . h8z81d to the -- Ind surroundIngerwtrormert. T8Iting tJII Hyclro8ystems on
behaI of Am8rtcan Cyanamid shOwed a drop in pH I8YeI8 In 5 of 180 samples. In these tests,
low pH .... occurred aft. h8Ivy raN. Several citiz.. aIIo cited that t8ltlng may have been
done during the drougtt condJtions thai were predon'1ir1d during the RllFS.
Aesoonse: Dr. John T. Novak. Virginia Polytechnic Institute and State University School of
Engineering. aft. receiving a copy of Mr. Lamama's letters. wrote that testing has indeed
indicated that ther8 Is a problem . the Piney RIver sit.. and that Mr. Lamanna's information was
erroneous.
Com~ One resident wanted to know what the Hazard Rankk1g System score for the Piney
AIv8' site was. .
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. 47
!
RSSDOlM: Th8 HAS score for the U.S. Trtanium site at Pin8y Riv~ was 34.8, done in 12182: ~
Comment.. One resident asked what the pH levels were of the seepage, groundwater, and
surface water. ..
ResD0nS8: pH testing at the site revealed the following ranges:
seepage/leachate: 2~; runoff: 5-6; and river: 5-7.
Comment: A large group of r8sidents, including some local officials, supported .the following
comment: -rhe evidence is clear that there is a problem here, just ai1aJyze it as if you lived
downstream from the Piney River...FoIks around here on the Piney and Tye Rivers don't want
the Piney River tuming into Iemonade...use that sort at criteria when.you determine what is the
best solution.' . . .'
groundwater: 3-6;
ResD0nS8: The recommendation set forth by the State, with the concurrence of EPA, takes into
account the concerns of the citizens regarding the economic future of the area. and the mariy
uses of the river for recreation, fishing. and nature watching. With these criteria in mind, the
State and EPA propose a permanent, tr~-oriented solution.
10.8. Co....*118 on the Propoeed PI81
...
Comment: The Blue Ridge Sierra Club 'generally favors8 the State/EPA proposed alternatives
over the recommendations of Hydrosystems, Inc. on behalf at American Cyanamid. The Club
'strongly supportS the intent at CERCLA and the NCP in choosing remedial actions which are
permanent and which prevent or minimize the release at hazardous substances to the
environment (and) also reaJlzes that the remedial action chosen must be practicable and cost
effective. '
Comment: There is widespread concern about the monitoring at residential drinking water wells
along the Piney and Tye Rivers, as weU as testing the various waters for the heavy metal
content which r8JII8 from acidic leachate trtckIIng through the soils.
Resoonse: By newaIizIng the acidly in Area 1. the leaching at heavy metals into the
groundwater wiD be gready reduced to ~ occurrtng I8YeIs. In addition. testing will be
done on aI water prior to discharge to meet water quaIIy standards. The frequency and type
at ~. surf8c8 water, and river and residendaI wel water monitoring wiU be determined
during ... RemedIal DesIgn actMty. The State wiI also review the possibility and interest for
a pubIa. wortcIhop to review and disQ ass the Remedial Design Study prior to the initiation of
the RImIcIII ActIon stage.
Comment There 18 also considerable concern ~ during In-SIu. Di88c* Ition in Area 1. the soil
under the pi may allow leaching at the dis80IYecI solution into the groundwater. Citizens
questioned wheCher enough hydrogeology. has been done under the pit to ensure that
groundwater wiI not be coruminated.
Resoonse: Hydrogeological studieI wiI be performed cUIng the RemedIal Design stage. prior
to implementation at the cleanup plan. In addition. II ~ In this ... wtI be rerouted
through a series at sub8uIface drains and trenchei, and tre8t8Clln the grotRttvat. treatment
~~~. .
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..
48
Comment One resident asked whether adding a synthCatic liner in area 3 would keep'
- contamW1ants from leaching, and what the cost of such a _liner would be.
Resoonse: The cost of a synthetic liner in Area 3 would be an estimated $552,000. The State
rejects the idea of placing a liner in Area 3 beCause it would interfere with the effectiveness of
the groundwater collection and treatment system.
Comment: ResidentS were interested in knowing where the Proposed options - have been
utilized.
Resoonse: In-Situ Dissolution of leachate, as well as revegetation and groundwater collection
and treatment. have been studied in-depth by the U.S. Bureau- of Mines. In addition, these
remediaJ technologieS have been used Colorado, Alabama, Pennsylvania, Tennessee, an~ West
Virginia, and in rnanyacid mine drainage rectamation programs. -
Comment: Several residents asked what chemicaJs, if necessary, would be used in the In-Situ
Dissolution process and the wetlands treatment system; and what will the byproducts of
neutralization be.
'"
Resoonse: Umestone will be used to achi~ the proper pH, or neutralize the acidity in the
soils and water. The byproduct of neutralization is water.
Comment: Two residents questioned whether there would be a lot of land moving, and who
would do this work.
Resoonse: The amount of land moving In the remedial action proposed by the State and EP A
would be minimal. Any WOC'k that is required for the remedial action, provided that the site
remains an enforcement-lead site, will be done by contractors hired by the PRPs. The State
and EPA will supervise efficiency, effectiveness, and compliance with regulations and the Record
'of Decision (ROO).
Comment: A representative of Hydrosystems. Inc. indicated that the proposed alternatives
supported by the State and EPA at the public meeting were not the alternatives that
Hydrosystems -selectect during the feasibility study and that -rhey- have been, in some cases,
upgraded slightly to more extensive alternatives.. The representative of Hydrosystems, Inc.
commented thai, for Ar8a8 3, 4, and 8, -whMt the State and EPA proposed reveg..ion,
Hydrosyltems proposed no action bec8 8M vegetation has come in naturaIy.
Resoo.lI8& ThI8 18 correct. The State and EPA setected the P.ele.T8d AlternatiVes because,
aft. . I'8VI8w 01 aI recommendations set for1h in the feasibility study, and a review of the
probIImI . the II.. the agencies felt that a more extensive and permanent response was
nee8:t to b88t meet the nine evaJlaatian criteria set forth in Superfund. Revegetation of these
areas wtI be revi8w8d on a case by case basil. Where areas have a thick vegetative cover,
~ ant not reqund for L88 during remedial action, the existII V ~ covers will be left
as is.
Comment: The representative 01 Hydrosystems, Inc. indicated th.- the firm monitored the river
(Net a period 01 S8YeraI month8. did fNet 180 pH measurwnenI8, and-only on five occasions
did the rtver drop below a pH 01 * (8). and this was cUtng storm ..,.....
Resoonse: The plan proposed by the State and EPA wiI help to avoid such tIuctuations in the
pH level 01 ground and surface water during storm events (heavy rains and snow), or periods
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- 49
of drough, wher1 groundwater discharge could have a greater effect on the Piney River.
Comr1W1l: The following comment was set forth by a representative of Hydrosystems, Inc.,
during the ~Ic meeting, 8/9: "One of the important points that haS never been brought up
here is that there are no hazardous wastes on the site. Ferrous Sulfate is no hazardous waste.
The pH of the material, of the water coming. off the site, is no higher than that of lemon
juice...We're not dealing with something that if you jump into it, you are going to dissolve, it's
just not going to foam ftay, it is no more acidic than lemon juice.'
Citizen Resoonse: The response of the citizh to this particular comment was widespread and
strong. One resident, with considerable applause by other residentS, contributed the following:
-. 'The fact that there is no hazardous waste on that site is an insult to our. intelligence. It is very
important to the economic development of Netson County that we rid ourselves of this blight.
Also, we may want to use the river or gr~ater for a public water system, which this county .
desperately needs.' ..
State Resoonse: It is true that copperas is not a problem by itself, but when interacted with
water and oxygen, it. produces an acidic solution, sulfuric acid. That acid, when leaching
through the soil, releases metaJs from the soil that are added to the groundwater and surface
water. For these reasons, a more permanent. treatment-oriented technology is recommended
by the State and EPA.
Comment: Several inquiries were made into the production of sludge during In-Situ Dissolution,
what the volume will be, will it be toxic, and what will be don8 with it.
Resconse: The sludge, or filter cake, resulting from the process of In-Situ Dissolution in Area
1 is not expected to be acidic or toxic. The substance wil~ however, be tested to ascertain that
it is of a composition that can be disposed of as a non-hazardous waste. If the substance has
residual toxicity, it will be transported and disposed cI or treated . a RCRA-permitted facility.
Specific information on the exact volume or composition will be determined during Remedial
Design and Remedial ActIon. It is unlikely that the material produced win be more toxic than
it currently is because, broken down, we will stili be dealing with iron and sulfur.
Comment: Was there any consideration given to an impermeable cap in Area 1?
Resoonse: Yes, the State 81d EPA considered Impermeable capping among the alternatives
reviewed, but prefer a more permanert. trUblMh"lt-oriented remedy, as all capping has a lifespan
limit and the waste ... 8XisI8.
~. 0.......... questIoi1ed whether 8ITf lIIempt was made to see if there is any
migrIIIGIfW cr.»ppera8 laden or acidic water off the Piney RIver site.
..
R88DOI'" The palhwaya cI migration were nMewed to delermine if and where contaminants
were mo-~ off cI the sa.. In addition, sampling was conducted to delermine the specific
problem - and rtsk8 cI the site.
Comment One resident asked if the St3a and EPA plan.. the same as the on proposed
by Hydrosyatems. Inc., only fast..
Resoonse: The plan .. forth ~ the sua and EPA haI sinIarttIe8 to the plan .. fortn by
Hydrolystema. Inc. on b8h8I cI 8 PAP, AmerIcan Cyanamid. However, the &.elEPA p&an has
marked diff8r81C88 In the recomnendation8 for the proper h8ndIIng cI the waste In Area 1, the
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..
50
copperas burial pit. The State and EPA propose a permanent treatment of the mixture,
eliminating the possibility of Mure contamination occurrences. As compared with the capping
option recommended by the PRP, In-Situ Dissofution is a permanent sotution, and capping is
not. In-Situ Dissolution neutralizes the acidic waste source, while capping places a barrier over
the waste.
III.C. ColIs. FwD1g. and Schedule
'. Comment: The Sierra Club indicated that membership felt that the StatelePA plan better meets
Supeffund Criteria. and that it is cost effective 'especially when viewed in light of the $30-40
million price tag for the average cleanup of an NPL site in the U.S. tOday.' "
Comment: One Piney River resident and one Chartottesville resident commented that they did"
not feet that the taxpayers should have to pay for the cleanup.
Resoonse: The first priority of the Superfund law is to encourage those parties responsible for
generating the waste that leads to contamination to pay for and undertake cleanup measures.
If no responsible party can be identified, or" if the responsible party is not financially capable
of undertaking the cleanup in an efficient manner, the site may be cleaned up as a 'fund-leact
using the Superfund Trustfund that is made up.of'taxes on petroteum and chemical companies.
The Superfund Trustfund is not generated from a tax incr8ase for individuals at this time.
Comment: Several residents asked about the timeframe for Remedial DesignIRemediai Action,
completion. "
Resoonse: Various componentS of the State plan wiI take diff8r8nt times to implement. The
components, such as revegetation or In-Situ Dissolution, can also be implemented
simultaneously. The current timeframe expected for the completion of the most time consuming
vanables is approximately three years from now. Monitoring will continue beyond that time.
III.D. P\dc PaIticipaIkIn
Comment: The Blue Ridge Sierra Club" wanted to know where in the Administrative Record
could they find the rationale for the State'. proposed plan.
R88DOI- The comp8rison c:I options c:onsid8r8d ~ the State and EPA for cleaning up the
U.S. T18rUn Superfund site can be found in the Proposed Plan document, several copies of
which C8n be fcu1d at the Netson County Memorial UbraIy and County Administration Office
Admi ...... Record FiI8I. The Stat8/EPA proposed ....,.. was seleCted as best meeting
the ".. crbfIa III forth ~ Superfund; th888 criteria are 0fJtIin8d In the Proposed Plan.
Comment The POtentiallv R88po.asib18 Party CUTW1tIy working with the State and EPA to clean
up the site, American Cyanamid, requested an extension of the pubic comment period due to
the volume of docum8nt8 in the Administr8IJve Record file.
Resoonse: The State and EPA granted a 3O-day ext8n8ion, extending the comment period from
July 31 through September 29, as a matt. of routine procedure.
Comment: There was widespread support for contInu8d communicallon between the State and
the community. Several residera asked about having representation at meetings on the
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. 51
- -
Remed181 DesighIR8mediaJ Action activities, and being kept abreast of studies and resultS.
R8SOOI~ Pubfic participation is an integral part of the SuPerfund pr0c8ss. While Technical
Assi8tara Grants were reviewed with community members, the Sferra Club determined that
going through the TAG procedure at this time was not their action of choice. The TAG process
does. however, remain open to the community as an option for funding their own technical
advisor.
In addition, the State will continue to host meetings with individuals or workshops with the
community to provide updates and answet questIonS. Fact sheets will aJso be" distributed
throughout the ROO and Remedial Design/RemediaJ Action stage. Interested citizens and
offIciaJs should continue to dlr~ any -questions, concerns or suggestions to the community
liaison, Jamie WaJt~ at (804) 22s.3268 or at the Department of Waste Management, 101 N.
14th Street, 18th FIooi', Richmond, Va. 23219. AJI information that - is not confidential will be
added to the Administrative Record Files for review by interested community members, "
Comment: One resident asked whether the State and EP A would make the final decision of
the cteanup option, releaSe the Record of Decision, and then provide additional time for the
citizens to review the options.
" "
Resoonse: The Superfund process includes time for the public to receive, review and comment
upon alternatives and arguments considered bV the State and EPA prior to selecting a cleanup
option. The proposed plan, a summary and comparison of the options considered, is
introduced to the public at a public meeting or through the Administrative Record File. At this
time, citizens are provided a comment period at least 3O-days long. to review the State's
recommendation. Comments and concems generated during the comment period are
summarized and responded to in" a document called the Responsiveness Summary, which is
a part of the ROO. Once the ROO is signed and issued, the selection of the cleanup option
for the site is tinaJ, and no longer subject to negotiation. The next process is the Remedial
DesignlRemedlal Action stage, when the option for cleanup is implemented.
Comment. Several inquiries were made by a gentleman at the public meeting regarding a letter
sent to the VOWM by Mr. Stephen L.amama. and whether th.- letter would be made public.
Resoonse: Mr. Lamanna'. letter, as well as II other comments received during the public
~ period. are summarized and Included In this ResponsiYeness SummaIy document.
The Resp0nsiYenes8 Summary Is included. with the Record of Decision. in the Administrative
Record File for review by 8nf and II members of the public.
IlL E. ElD{ I ~18nd P-Q1IaInIy --
Comm..~ Mr. Jerome Muya. Esq., on behaI of Amertcan Cyanamid. wanted to make sure that
the pubic ~ ~ while the PAP did make tect1nical arguments with some of the
State'. pn:lpDlai for deanup, the PAP was in no way trying to walk NRf from the problem.
Mr. Muys str8I8ed th8I American Cyanamid Is only 2DI of several PAPs for this site, and is
" currentty the only PAP th.- has been wiUing to panicipate in the prOC8S8 to clean up the U.S.
TitanJum site.
Resoonse: There are sevn Potentially Responsible Parties (pAPs) for the U.S. Titanium site,
of which AmerIcan Cyanamid Is the only one currentty cooper8ing wtth the State and EPA for
this cteanup procesa.
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52
Comment There is widespread concern in the community .about th8 selection by the PRPs of
the contraCtor to carty out the Remedial Design/Remedial Action work. Many members of the
public were concerned thai, this being the case, the cleanup win not be carried out with
maximum effectiveness and with a "sincere desire- to clean up the site.
Resoonse: There are many safeguards in place to ascertain whether the. contractor
recommended by the PRP(s) is capabte and willing to do the RD/RA according to the ROD and
Superfund regulations. While the priority of Superfund is to encourage PRPs to undertake and
fund the necessary cteanup, the State and EPA have oversight over all work conducted. The
State and EPA also have the authority to re;ect the PAPs recominended contractor if there is
8YidenCe that the contraCtor win be unable to perform the necessary wort<. .
Comment: Will there be agency staff on site during the RD/RA activities. to ensure that work .
is being done correctly?
Resoonse: Yes. there will be staff members from the State and EPA on site, but the number
01 staff and the duration 01 their on site work win vary per activity. For example, some
operations will only require agency personnel on site once a week. while others (such as the
work proposed for Area 1) may require a fu1t.time stall member on site regularly for a period .
01 two years. The wetland treatment system. becallS8 it II a gradual activity, may only require
a monthly on site visit by agency personnel The size of on site stall. and on site review
schedule, wi" be determined In Remedial Design.
Comment: There was concern among S8Y.-aI residents that the differences between the State's
plan and the PAPs plan would lead to a court case. and whether such a court dispute would
deCay the project.
Resconse: Once the Record 01 Decision (ROD) is signed. the selected altematJve(s) for cleanup
are no longer subject to negotiation. There are negotiations that win occur with all Potentially
Responsible Parties (pAPs). The negotiations will determine who wUl pay for and undertake the
Remedial DesignIRemedJaI Action. work, not whether it wit occur. As with all Superfund
negotiations. there II the possibility that no Consent Agreernert. or cooperation with PRPs, will
be reached. The PAPs have 9O-days after the ROO II _led to agree to undertake and finance
the cleanup. If they don't. the site remediatian may become a Fund-Iead, and RD/RA win be
undertaken by the StIle and EPA. Whenever Superfund moni88 are spent on Fund-lead
projecC8. the agend8I can take the PAP to court and t8COV8f the cost 01 the deanup.
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'53
rI. RESPONSES TO COMMENTS FROM AMERICAN CYANAMID COMPANY ON PROPOSED
REMEDIAL ACT10N PlAN FOR THE U. S. TITANIUM SITE
Responses to comments from American Cyanamid Company are presented below. The
comments as submitted by American Cyanamid are presented in Appendix C:
COMMENT 1:
The Administrative Record does not Support the Selection of a Treatment Alternative for Area
1.
RESPONSE:
The Administrative Record, which includes the Remedial Investigation and Feasibility Study
reports and the two Addenda to the Feasibility Study, wholly supports the selection of a treatment
alternative for Area 1. .
The remedial alternatives examined for Area 1 can be broadly ctassified into two, containment
remedies and pennanent (treatment) remedies. Only permanent remedies are appropriate for this area. .
. A containment remedy was applied in 1980 when the waste was buried in Area 1 and capped.
This cap has failed in many areas resulting in acidic leachate that is impacting groundwater and the
Piney Aiver, and destroying the vegetation. .
The most significant emphasis of the Su~nd Amendments and ReauthoriZation Act (SARA)
is on risk reduction through destruction or detoxification of hazardous waste by employing treatment
technotogies which reduce toxicity, mobility, or volume rather than protection achieved through
prevention of exposure to such wastes. Section 121 of CERCLA (Cleanup Standards) states a strong
statutmy preference for remedies that are highly reliable and provide long-term protection.. In addition
to the requirement for remedies to be both protective of human health and the environment and be.
cost4ective, additional remedy selection considerations in Section 121(b) include a preference for
remedial actions that ~ tnNiIb ...,-. th8 permanently and signiftcandy reduc88 the volume, toxicity I
or mobility of hazardou8 subItance8, poIh Itant8, and contaminants as a prtncip8 element.
While .... lmited design data .. needed for the selected alternative of in-situ dissolution and
treatment, and would be allowed for during the remedial design phase, there is sufficient information
available at the plilent moment to justify the selection of the alternative (see response to comment 4).
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..
54.
COMMENT 2:
Treatment alternatives were not subject to necessary laboratory and field studies.
RESPONSE:
According to EPA's Guidance for Conducting Remedial Investigations and Feasibility Studies
(RI/FS) under CERCLA (OSWER Directive 9355.3-01, October 1988), treatability investigations can be.
done during the RIIFS or may be postponed unt!1 the remedial design phase. The decision to conduct
treatability studies during the RIIFS or to. postpone it until the remedial design phase is made by
weighing the cost and time required to complete the investigations against the potential value of the
information in resolving uncertainties associated with selection of a remedial action. Such a decision
is made on a case by case basis. The desire to want to remove all uncertainties before a remedy is
selected has to be balanced with the Superfund program's mandate to perform cleanups. within
designated schedules. .
"The objective of the RIIFS is not the unobtainable goal of removing all uncertainty, but r&thee
to gather information sufficient to support an informed risk management decision regarding which
remedy appears to be most appropriate for a given site- (OSWER Directive 9355.3-01, Section 1.1).
The information currently available is sufficient to support the recommended remedy for this site. The
collection of field and pilot plant data necessary to fully design the selected remedial alternative for the
site would be done during the remedial design phase.
COMMENT 3:
The In-situ Dissofutfon and Treatment of leachate altematJve was not subject to the required
comparative analysis of alternatives.
RESPONSE:
The compIr tINe an8IysII W1dertaken in the RllFS ide.1tIft8d and evaluated the key tradeoffs
between clay ClPPiIg, ~'8bIe capping 81d abcJve.grade wet neutralization. Above grade wet
neutralization .. the only aItImadve of these three that would meet the SARA mandated requirement
to select. to ... II8imun extent prac:dr;atM, a remedy oIet*1g . permanert - dIon to the cleanup
problem (CEACtA. Section 121 (b)). Despite the pararnourt importance of selecting a permanent
cleanup I~. the RIIFS IdeIdIed the punned alern8dv8 to be day capping. Cost-effectiveness
was identifted In the RllFS . the key tradeoff between clay capping and aboYe-grade wet neutralization.
The only factor In whIctI abcM grade wet neutraIizaIion was questioned was implementability. The
uncertainties in this case are nsociated with the d8taiI8 of the treatment methodology and are best
resolved during remedial design.
Following the clay capping recommendation in the RllFS, in-situ dissolution was identified as
a potential remedy and was SUbmitted by Hydrosystems on b8haI of American Cyanamid Compan"
as a second addendum to the FS. This second addendum presented the elements needed to do
comparative anatysis d the in-situ dissolution and treab.18I1t alternative. The submission discussed the
performanc8, risk reduction, reliability, IrnpIementabiJit, safIty, environmental analysis, public health,
institutional anaIy8ia and COSt analysis d the altematiY8.
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55
A fonn8I. comparative analysis between in.situ and clay capping (the remedy recommended
in the FS) W88 naI required at this point to identify and evaluate the key tradeoffs betWeen the two
alternatives. CI8y capping was determined to be deficient in a most crucial factor, that of permanence.
In-situ disSoCutioA offered permanence, thereby making it a viable alternative under SARA, and was
substantially less expensive than above-grade wet neutralization. It should be pointed out that an
analysis 01 alternatives, incfuding in-situ disSoCution and treatment, is presented in the Summary of
Comparative Analysis of Alternatives section at the ROO. .
CO-MMENT 4:
The secdon 121 remedy setecting ciiteria were misappU8d: . (1) The proposed remedial .
alternative for area 1 is not necessary to protect human health and the environment 0( satisfy ARARs.
(2) The proposed remedial .aJtematlve for area 1 is not cost-effective (3) The proposed remedial
alternative for area 1 Is not practicable.
RESPONSE:
.
(1 )
The proposed remedial alternative for area 1 Is necessary to protect the environment and satisfy
ARARs for the site. CERCLA SectIon 121 (b)(1) states that. .remedial actions in which treatment
which permanently reduces the volume, toxicity 01 mobility of the hazardous substances,
pollutants, and contaminants as a principal element. are to be preferred eNer remedial aCtions
not involving such treatmenr. Again. the in-situ tii8soLution and treatment alternative will meet
all of these requirements by permanently eliminating the copperas waste, while clay capping
does not.
The ARAAs for the site are not limited to pH and Iron COf'IC8f Ib ation but include the following:
~ ARAR8:
Implementation of the selected remedy wiI Involve the discharg8 of treated efftuent into the
Piney RIver. SectIon 4Q2 of the Federal W.. PotUion COntrol A/:;t requires that a point source
discharge of poIh It8nt8 InIo ufac8 water be done ~ to . N8tIanaI Pollution Discharge
~ ~ (NPDES). The NPOES syst8m In VIrgInIa is admIr1ist.-ed by the '/WCB.
undIr .. PermIt AIgIRdon VfW8O.14-01. enur.1ImitIIIon8 and adw discharge requirements
hIM .. d8\. II oped by the VWC8 and .. pn81rted In AppendIx I.
The -.. III DdIt8d wIIh n*1i1g oper8IIon8 In the p8It. VIrgInia Department of Mines,
MIn8rII8Id en.gy resp IIf'Itv18 corUi1 do8c.n requirImenIs for surface mining of mineraJs other
ttWI COlI.
The sellcted remectI would requn soil ~ panJc:uIarty cUIng the constructiOn of the
W8dand. Sol & SecIrnIr-. EroIian Control of Nilian Ccu1ty, VIrgInIa. and the Virginia
Department of ecn.v.Jan and Hi8taric ReIourc88. DM8ion of Sol and W.. Conservation
requn erosion co.lbol plans for ~ and 88I1h moving of ... greater than 10,000
square feet.
-------
I
I
I .
56
ChemkJ' IpICiic ARARs:
The chemicaJ-specific ARARs for the selected remedy have. been provided by the VWCB and
are presented in Appendix I. These satisfy the FederaJ Water Pollution Control Act (Section 33
U.S.C. 1251 et seq.) and the Virginia State Water Controf Law (Section 62.1-44.14(3) of the
Code of Virginia). .
L.ocadotrspecific ARARs:
'. Location-specific ARARs include Executive Order 11988 (40 CFR a, Appendix A . Protection of
Floodplains). Areas 5 and 7 lie within a 100-year floodplain.
Land DispJ6aI Restriction:
The Land Disposal Restrictions (LORs) of the Hazardous and Solid Waste Amendments (HSWA)
to RCRA place restrictions on the land disposal of RCRA hazardous wastes. At present there
are no RCRA Subtitle C wastes at the site and as such the restrictions do not apply. However,
should anv of the wastes resulting from the remedial action be classified as a RCRA Subtitle
C waste, the LDRs would become applicable. LDRs also prohibit the use of anv waste or sludge
from the treatment process as a baCkfilling material.
0It8 ClI8rta. AcMsaI1es or Guid8a To Be Car 1Sidered. for This RemedIal Action (TBCs)
Local deed restriction to prohibit excavation at anv of the contaminated areas of the site and
the wetland to be constructed even after the remedial action is complete unless all residual
contamination is known to have been eCiminated.
OSHA requirements that regulate worker safety and employee records during all site work
(OSHA of 1970, 29 U.S.C. 651).
All pollutants remaining on site would comply with aJl ARARs as required by CERCLA Section
121(d)(2)(A)(i) and QQ.
(2)
The setectec:l remedy for tnis site is cost48ctive beCa'lSe it has been determined to
provide overall effecdYeness proportional to its cost. the. net present worth being $5,895,000.
The 8fItIr1W8d CC8t of the selected remedy is less than twice the cost associated with
neutPlP8IOn and capping the waste in Area 1 ($3,214,000). and yet the selected remedy
as&ur88 . nu:h higher degree d permanence and long-term. eff8ctiveness since the major
source of ~ . the site would be permanently deStroyed. The current cap on the
wast8 h8 failed In many areas and re-capping the waste would not provide a permanent
sohJtIan. The 'eleeted remedy wiI eff8ctiveIy reduce the ~ hazards posed by the site. by
signiftcanlt/ reducing acidic and toxic metal di8charg8llrto the Piney RIver.
CERCLA plaCes an emphasis on 8Y8Iuadng long-term eff8ctIv8n8ss and related
consideratIon8 for pater4iaI remedial actions (CERCLA Section 121 (b) (1) (A)). These statutory
consideratIon8 indud8 long term maintenance costs and the potential for future remediaJ action
costs if the alternative remedial action in question w.. to fai (CERCLA Section 121
(b)(1)(E)&(F»).
-------
(3)
. 57
The s81ectitd remedy is very practicable. What needs to be determin8d is the most
efficient W8J to 'implement it. This will be adequately addressed during the remedial design' .
phase. .
A report submitted by I~itu Inc. to American Cyanamid enumerated three feasible in-
situ leaching techniques that could be explored during the RD/RA phase. These are:
Installation 01 a network of injection and extraction wells throughout area 1 with spacing
based upon the hydraulic ~ 01 the copperas/soil for the intrOduction. of water
and ~ (by either. pumping or' collection by gravity into drainage trenches) of the
acidic FE~04 solution .
Cyclic saturation and drainage 01 the area by means of surface trenches dug to
progressively deeper depths .
Surface irrigation by sprinklers of area 1 with coIJectton 01 the solutions by means of
drainage trenches or drains. In areas where the cap is an effective barrier to flow, the
cap may need to be remoVed or penetrated.
According to 1~1tu Inc., provision CGuId be made to allow recirculation of the leach
solution back to the injection wells, irrigation system, or surface trenches prior to final colleCtion.
All \each solution distribution and collection systems, other than collection by pumping from
recovery wells, would be passNe in their method 01 operation. Each 01 these in-situ leaching
alternatives was further dfsQ lSSed by In-Situ Inc.
On the treatment 01 the leachate collected from the dissolution process, considerable
experience exists In the chemicaJ and mining industry. At a meeting held in Richmond on July
12, 1989, Mr. W. E. Trees 01 Kernira InC. disclosed that his company has considerable
experience in treating wastewaters containing high concentrations 01 ferrous iron in a weak
sulfuric acid solution. Kernira Inc.'s operates a chemical plant in Savannah, Georgia that utilizes
the sulfate process in connection with its titanium dioxide operations.
In a recent leU.. to American Cyanamid dated September 26, 1989, Mr. Trees explains
~ K8mira proceI8 for treating this type 01 aqueous waste as follows. "Kernira used a two step
process to tnNIt the 8Cidic proc:;ess wastes. The first step consisted 01 neutralizing the
wastewaters withlmeltone. to 8 pH in the range 01 2 to 3, to precipitate gypsum. The second
step irNoM8d treaIi ~ the gypeum sIuny with slaked lime and aerating the slurry to oxidize and
plec1pM'- f8rrtc tr,di0ldde (or hydrated fen1c oxide) and gypsum (calcium sulfate dihydrate) as
the pH IpplI08Ct18 r8b81..
1b8 option ~ product rect:N8t'f from the leachate is consistent with the selected
~ '*'*'" ~ In.situ dissolution and tr.-.18I1t. In this case, the leachate. would be
tr88t8d n . WIlt 1hIt would allow for recovery ~ mar1cetable prodIlCtS
A remedial action th8 1nd18de8 8 ~ sauuon. and th8 predudeS future risk 01 failure,
is ctear1y superior in muting the crbrIa for ... and pubic acceptance. Furth8rm0r8, with regard to
long term maintenance COII8 and the potential for future remedial' action costs if an alternative action
fails, the history ~ day cappi1g . the site leads to the condusion ~ in-situ dissolution should be
considered a pr8ferred alernatiw OWl day capping.
The in-situ dlssoWtlon and ~...... altemattYe. when measured agaIn8t statutory guidelines
for setecting a remedial action alern8iYe , proY8I to be a prefened alternative t:N.. the other
-------
58.
aJternatives considered. The prOcedure for evaluating and comparing all identified alternatives was done
in accordance with the Statutory requirements and EPA guidance. The administrative record adequately
supports the setection of the in-situ aJternative for Area 1.
COMMENT 5:
-- Comments on passive groundwater collection and treatment
RESPONSE:
AJs presented in the Feasibility Study and the Proposed Remedial Action Plan, the components
of the groundwater treatment system would include an.oxidation/settling pond, a constructed wetland,
and a limestone neutralization bed. The oxidation/ settling pond would promote formation of insoluble
iron hydroxides and settle out entrained sediments. Wetland vegetation would work in conjunction with
anaerobic bacteria to remove iron and sulfur species from the water. The limestone bed would act as
a final polishing step for pH adjustment before diScharge ~ the effluent to the Piney River. Any. .
discharge from the entire treatment system has to meet the ARARs for surface water discharge into the
Piney River. A viotation ~ ARARs for five years as suggested by Amertcan Cyanamid is not acceptable
and would not be necilSlary since the performance ~ the wetland can be synchronized with the
operations ~ the other two units.
-------
59
"
APPENDIX A
, .
Cornrru1ity R B I ado. .. Acdvties CondI8Cted
wiIh the U.S. "1"t8Un SIB Cornrru1ity
-------
.'
. COMMUNrTY REl.A11ONS ACTMT1ES
U.S.. TITANIUM SrTE
60
The following community relations activities have occurred or
have peen scheduled to occur in the u.s. Titanium site community
during the course of remedial activity.
AcnyrTY
Site Update Fact Sheet
Community Relations Plan Revised
CR Interviews Conducted: locaJ govemment
and Sierra Club representatives
EPA Briefed by VDWM on Proposed Plan
Proposed Plan Completed
Public Notice of Availability of Proposed Plan, CRP, and
Administrative Record File and Public Meeting
Public Notice Distributed to Mailing USt
Public Comment Period Commences
Proposed Plan Sierra ClublPublic Workshop
Public Meeting on Proposed Plan
Public Comment Period Extended
Public Notice c:A Comment Period Extension
P 'Jblic Notice to Mailing List
Public Com.".. PerIod Ends
Responsiv--. Swnmary Prepared
Public Notice of ROD AvailabMy
ROD Fact Sheet Distributed to Mailing List
Telephone/MaiVMeeting Communications
CAP Revised for RDIRA
RDIRA Kickoff Activities
DATE
4/20/89
5/12189
5/18/89
7/18/89
7/31/89
7/31/89
7/31/89
7/31/89
7/31/89
8/9189
8130189
8130189
8129/89
9129/89
10/15189
10/15189
10/20/89 .
Ongoing
11/01/89
11/15189
-------
..
APPENDIX B
61
~ IrIorr11atiOO
.',
'"
-------
62'
PERFORMANCE AND PAYMENT BONDS
U.S. TIIaniun Res po. asNeness Summary
QUESTION:
Are the contractors that do the remedial work required to be bonded?
RESPONSE:
Whether performance and/or payment bonds are required is dependent on several
things: is the site is a fund-lead or an enforcement-Jead; has a PotentiaJlyResponsible
Party (PRP) been identified; or is the contract a construction or service contract. The
definition of a construction contract. under the Federal Acquisition Regulations (FAR)
can include remedial activity. ' , ,
While there is' no specific language in the Superfund laws that require bonding for,
remedial activity contractors, the concept of bonding can be generally construed in
several sections. .
CERClA 1119 (a) states that a response action contractor is not liable under any federal
law for injuries, costs, damages, expenses, or other liability which results from any
release of hazardous substances; it does not except contract
-------
. .63
APPENDIX C
Ctizen Lsaers and Corrmera R:Iuding .
Corrmera Submitted by AmeI ican CyalI8I11id Company
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SWIDLER & BERlIN .,
..
CKAJlT!UD
3000 K 5T1lEET. N. '\'IV.
SUtTE 300
WASHINGTON. D.C. 10007.3851
JEROME C. MUYS. }1l.
A nOINlY.AT-IA"
August 16, 1989
DIUCTDw.
(202) 944-4947
T!LO, -:'0113 t
TWCOPlD, (202) 944-4296
VIA FEDERAL EXPRESS
Ms. Jamie Walters
Community Relations Coordinator
Department of Waste Management
18th Floor, Monroe Building
101 N. 14th Street
Richmond, VA 23219
Timothy Longe, Ph.D.
Remedial Project Officer
Department of Waste Management
18th Floor, Monroe Building'
101 N. 14th Street.
Richmond, VA 23219
Re: U.S. Titanium Site,
Piney River, Virginia
Dear Ms. Walters and Dr. Longe:
I am writing on behalf of American Cyanamid Company to
request a fourteen-day extension of the public comment period
(until September 13, 1989) on the "proposed remedial action plan"
for the u.S. Titanium Site in Piney River, Virg~nia. This request
is prompted by our tecent receipt of the administrative record
file index of documents for this site, which is forty pages in
length.
Section 117(a)(2} of CERCLA requires that the State provide a
"reasonable8 opportunity for the submission of written comments
regarding any plan for remedial action. By our count, the
administrative record in this matter contains approximately
fifteen volumes of documents containing thousands of pages of
information, including a large number of internal agency documents
of which we previouly were unaware or which were unavailable to
us. While it is not our intention to delay the remedy selection
process for the site, we do not think it is reasonable for the
State to expect us to prepare meaningful comments in thirty days,
particularly in light of the fact that the proposed remedial.
action plan for the site departs in significant respects from the
"recommended remedial action" contained in the Feasibility Study.
-------
.Ms. Jamie Walter
Dr. Timothy Longe
August 16, 1989
Page 2
.'
I ask that you advise me as soon as possible on the
disposition of our request. Thank you for your attention to this
matter.
Sinc~rely,
---r C f0;r.- ;;-
,-J~ . f. 7
Jerome C. Muys, Jt. (,-,
- .
cc:
Philip F. Koren, Esq.
Mr. Raymond Merrell
Margaret R~ Tribble, Esq.
-------
BLUE RlDG;E GROup.
..
h
",'
oJ.... -'
..
-
-
--
Department of Waste Management
18th Floor Monroe Bldg.
101 North 14th St.
Richmond, Virginia 23219
-
,.
<..-
- .
~ . ~ .
. - . .
..:....:.....~.
AT T i';: Lv. s .
Jamie Walters
August 25, 1989'
Re: U.S. Titanium Superfund Site Public Comment.
Dea:- i'~s.
i-t"alters:
~his ?u~lic comment is submitted by the Blue Ridge
Gro~p of the Sierra Club, Nelson County, Virginia. The
su~ject of this letter is the EPA preferred alternatives for
the c 1 e a n up 0 f the N P L sit e "k now n as U. S. Tit ani u m .
Our Blue Ridge Group has been actively involved in this
site for the past several years and continues to be very
concerned about its proper clean up.
we .ould li~e to begin our comment by saying that
generally we favor the EPA proposed alternatives over the
:-ecommendations of Hydrosystems, Inc., which are made on
behalf of Ameri~an Cyan acid. We strongly support the int~~~
of C~RCLA and the NC? in choosing remedial actions .hich are
permanent and which prevent or minimize the release of
hazardous substances to the environment. We also recognize
tha~ the remedial action chosen must be practicable and'
cost-effective.
It is our position that the EPA/Virginia proposed
alternatives for the seven (7) identified sites meet thes~
stated criteria much more effectively than the proposal set
for~h by American Cyanamid. The cost of the EPA plan is
roughly $5.8 million dollars, the cost of the American
Cyanamid plan is $2.3+. For the EPA plan we see a permanent
solution to the environmental problems previously caused by
these sites next to the Piney River. The same cannot be
said for the American Cyanamid capping propos&ls. The cost
is reasonable especially when viewed in light of the $30-40
million dollar price tag for the average clean up of an ~PL
site in the U.S. today.
Although we strongly support the existing EPA/Virgini
preferred alternatives, we would like to raise some
questions which are.of concern to a number of our members,
inclu~ing people who live near the Piney River, use the
river for fishing or just enjoy its natural beauty.
I
~
, ""',
~,
t
-------
Firs~ is the question of where in ~h~ adminis~ra~ive rec=r~
do we citizen's find the rationale for the E?A D-lan? i;e find
~he backup studies for the American Cyanamid pian, but
nothing that says where E?A came up wi~h its .preferred
alternatives. There is also a concern that-no drinking
water _wells have been monitored off the site of the property
and none are scheduled for future monitoring after or during
the remedial action.
Another major concern of our members is what is going to
happen to the runoff collect~d as a result of the div~rsion
of surface water which is discussed, but for which no
treatment if indicated. It seems logical that if one
collects runoff from ground which is admittedly acid~c that
one would treat that water prior to ~ntr04ucing it into the
Piney River. This needs to. be clarified on the schematic of
preferred alterQatives handed out at the public meeting;
A further concern over the EPA proposal arises in Area
1. The preferred alternative is to dis.solve ~he Copperas
with water, remove the solutio~ and treat it on site. A
member of our group is a soil~ scientist employed by
Virginia Tech. He has recently mapped the soils in Nelson
County and expresses a concern that the soil under the pit
may allow leaching of the dissolved solution into the
groundwater. We question whether enough hydrogeology has
been done under the pit to assure that.groundwater will not
be contaminated.
We would like to be assured that this NFL site will
never again cause fish kills, stop animals from drinking the
water of the Piney River, or cause loca~ citizens to worry
about contamination in their wells. To accomplish this we
want the EPA/Virginia plan to ens~re proper monitoring of
groundwater both on and off the sites, and to treat diverted
surface water prior to placement in the river.
~e be11eve that the EPA/Virginia proposal is a cost-.
effective, per~anent solution which if properly engineered
and monitored '01111 ~arry out the needs of the community; and
the environment, and the requirements of law.
Sincerely,
~&c,/I:'~
, .'
c.-
1-
I ,.. . ,
/' ." '/'/
(.... ."'''''''''''.,.:''.-'' ~
Richard M. Cornelius
Member of Exec. Comm.
Blue Ridge Sierra Club
-------
..
Ms. Jamie Walters
Community Relations Coordinator
Depar-tment of Waste Management
18th Floor, Monroe Building
101 N. 14th Str-eet
Richmond, Virginia 23219
August 28, 1989
Dear Ms. Walter-s,
I would like to expr-ess my appr-eciation to you and Dr.Longe
for the excellent meeting you conducted on what the State plans
to do at the U.S. Titanium Superfund Site in Piney River-. Your
pr-esentation was very clear and complete. You also did an
excellent job of r-unning the meeting and answer-ing the many
questions. .
I would like to go on r-ecord as being very much in favor- of
the alter-native for cleaning up the site as set forth by the
Virginia Department of Waste Management and very much opposed to
the plan proposed by American Cyanamid. I believe the idea of
eliminating the problem once and for all is. the right one,
particularly as this site has alreadY been ucleaned UpM once. In
my view a clay cap will never provide a solution to the proclem
- it will just delay the leakage for some years. Eventually the
copperas will leak out and pollute the river once again.
I am especially concerned about the heavy metals which
r-esult one. the copperas dissolves with water and oxygen and
becOmes sulphuric acid. ThIs seems to me an equally severe
pr-oblem. A suggestion was made at the meeting that the test
wells on the site be tested several tImes a year for these
metals as well as certain other wells in the immediate vicinity
and the results of these tests be released to the pUblic. I
think this Is an excellent suggestIon and I would like to
for-mally request that my well be tested. I live downstream fr-om
the plant on the Piney River just before it merges with the Tye.
Finally, I would like to express my concern about the
possibility of barrels which are buried on the plant site on t
Amherst County side. While I am aware that testing in this are~
did not result in any evidence of potentially harmful
material,this situation may change drastically with any kind of
construction In the area which might disturb these barr-else 1
w.,ulc1 hnp~ your office would be able to follow the leads given
. . .
-------
.'
Again my thanks for the information you presented at the
meeting and your wi I lingness to take the time to explain your
procedures and the clean-up plan to the public. I would
appreciate receiving information on how the plan is proceeding
and i£ at any time the publIc Is al lowed to partIcIpate I would
like to be informed..' .
SIncerely,
~fU 1t'atb'()
Popie Martin
Rt. 4, Box 392
Amher~t, Virginia
804-277-5510
24521
-------
COlLEGE OF E~GINEERlr-;G
(~~'~
:~:I :.:. '~
,,. ..."
'~~J1;~
, '.
VIRGINIA ..POLYTECHNIC INSTITUTE AND STATE UNIVER
-{
Bl4cJub"rg, V;rg;lI~ 24061-0246
THE CHARUS EDWARD VIA. JR.. DEP AR TMENT OF QVIL ENGINEERING
ENVIRONMENTAl ENGINEERING AND ENVIRONMENTAL SCIENCES (703) 961-6131
september 12, 1989
Ms. Jamie Walters
Community Relation Officer '
Department of Waste Management
101 N. 14th Street 18th Floor
Richmond, VA 23219
Dear Ms. Walters:
I have just received a copy of the letter to you from Mr.
stephen A. Lamanna regarding pH levels at Piney River. Based on
my measurements and a review of the materials provided by others,
I believe that there is no possibility that his pH measurements
are correct.
I appreciate the interests in citizens to limit the
expenditure of money for unnecessary cleanups but in this case,
widespread contamination of the groundwater, soil, and the Piney
River have been demonstrated by the state, EPA, and several
private contractors representing all parties involved in the
cleanup program. If the material presented by Mr. Lamanna
becomes an issue, I am willing to provide technical assistance to
show that the information he provided is erroneous.
Sincerely, / .::-;,/ /'
C~ ~i ' ./ - //,.: f-N./
-/e.., ~/-(....--. . ,. ... .,., .,.,. -
, .JohnT. Novak
: Nick Prillaman Professor
of Environmental Engineering
,
I
I
,-'
JTN/bpw
-------
Jamie Walters
Communi~y Relation O££icer
Department o~ Waste Management
101 N. 14th Street 18th £loor
Richmond, Va. 23219
24521
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Miss Walters
On Wedne8day AUgU8t 23, 1989, I made a 8urvey o£ the Piney River:
the area surrounding the residue area and the top o~ the residue'
pile. Results are as £0110W8:
o
Piney RiverUp-8tream o£ Plant
"
Water Clear,
pH :I 7.0
o
Piney River
we.t o£ Rt.
- Discharge Point o~ Creek Drain ( wet
1~1 - old spring - Cyanamid drinking water)
area
Water Clear,
pH :I 7. 0,
Flow = 20-30 gpm
o
Down River o£ Plant
Water Clear,
pH :I 7.0
o Pond in Road Beloy Residue Pile
Water Slight Amber, pH . 6.9~
0 Ditch along old R.R. bed below Residue .dump.
No ~loY,
pH . 7.0
o
Flow ~ro. area where Copperas ya. originally stored
Flow to River. 8-10 gpm,
Water Clear,
pH . 7. 0 '
(This 1. the 4.~ acre tract
Any 8eepage from the buried
thi8 area. )
.hown in the attached report.
Copperas re.idue would drain t~
o
Top of Re.idue Top
Water .tanding in eroded ditch,
Color Amber,
pH . 6.8
-------
.'
The lower part o~ the buried re.idue area ~s exposed as a result
of wash1ng. From the 8urface 1t appear. to be more eros10n and
very 11ttle 1f any solut10n.
The plant and re.idue burial area. are overgrown w1th h1gh
weed. and the road. have either been blocked off. or eroded to the
p01nt that access i. almost 1mposs1ble. Walk1ng 1n to the river
and the re81due burial areai. the only way. Copperas (FeS04.
7H20> Wh1Ch is readily water .olub1e doe. not exi.t in the .buried
material. It i. primarily product. o~ the dehydrat16n and
oX1dation of the material stock piled. I am attach1ng a report
issued in April, 1971 which .how. the re.ult. of a drilling
program where we were trying to evaluate the material in the 4.5
acre Copperas dump. At that time Copperas sale. exce.ded our
copperas production and we were .eeking another source of
Coppera.. On the ba.i. of th.~ poor quality of the material-in
the dump, the po..ible recovery program va. di.continued. Th.
analysis of the drilling .hov. how the material degrade. and
become. Ie.. water .oluble. Sear in mind there ha. not been any
Copperas added to this .y.te. in the pa.t 18 y.ar.. What
buried now i. ...entially yater in.oluble re.idue.. .
The report .hov. that the Copperas dump area covered 4.5
acres - 196,200 .quare ~eet. Thi. large .urface during heavy
rains yashed off a large amount of yater .oluble ferrous sulfate
which, yhen not controlled re.ulted in a drop in river pH which
caused. fish kill. That i. Yhat happened in 1977.
The data collected and condition. a. they noy exi.t shows
that it i. not a problem. With no chance. at all that a fish
kill can Q~~Y!. There i. not enough .oluble ferrous .ulfate in
the entire are. to cau.e. fi.h kill, even.Yith the moat severe
weather conditions. The data alao ahova that due to no liquid
~loY or s.epag. fro. the re.idue area that ground yater ia not in
any yay at~ected.
I repeat you really have to know Yhere to look to find the
buried re.~due. It i. time to quit ho11ering volf and pick a
qualified technical com8ittee to review the .ituation and put
this proble. to bed.
S~ncerely,
~ ~.. ~ ~. ~ e...,- . ---.. ~
~-, -..:
Stephen A. La.anna
-------
~--€~..-;.T_"T;',~
I! '!"iE ~~O ;-;: [C E CO!'~r~ ES~ iO i\! D E I\! C t
P.in~y River, Va.
(I.pril 29, 1971
OF F. C ~
POl.Oc;/TUtlE RM.
t>AT,"
TO:
Piney River Office
~1 r . J. F. Hop kin s
COpy TO:
~~ r. J. J. F f t z Cj era 1 d.
~1 r . E mil H 1 a d I~ Y
Dr. C. P. P r i e sin 9
..
- I.
- r!
- t:
ATT'N. OF:
'.
SUCJECT:
COP PEP. A SliD U ~1 P II
\ .
. .
REFERENCE:
'"
The Piney river Plant started stockpiling copperas July, 194~.
.
Since that time all copperas not ~old was hauled ~o the coprer~s
"dump".
The top 0 f the p 1. e s e n t d II iii P con t a ; n s . 4 . 5 a c I' e s .
The dur,1p has been surveyed and drilled to determine the
quality and quantity of coppel.C:'s contained.
It has been estimated that the a~ca contains approxim~tely
.c200,OOO tons of material. Analysis taken at various depths fl'om
ten drill holes show that the material contains from 7.8 to 36.0%
tot a 1 a c i d a s I! 2 S 0 'i ( \..' ate r s v 1 II h 1 e ) . The pel' C E: n t ; n s 0 lu b 1 e
"' ate ria 1 c a 1 c u 1 il t e d a s F e SO 4 v a r ; e.s fro m 1. 3 2 to 7 7 . It 7 ~(: . X - ray
d; f f r act; 0 n a n a 1 y s ; s s h 0 \'1 the II p i 1 e II t 0 con t a i n F e SO 4' F e SO 4 . H20,
FeS04'~ H20 and FeS04.7H20.
At t a c h e d are tab'l e s' c on t a. i n i n 9 the ~ n a 1 y s i s 0 f the d r i 11
samples. the results of the x-ra~ analysis and ~ map of the pile
showing the area and elevations.
.
.~ -:I:s,-y\~'.''- I\..."f. "--""~,~,,,-
Stephen A. Lamanna
'SAL/jes
.
..»- Ct{a/!
-------
COPPErAS DUMP "AS IS"
I Total Acid Total I nso 1. % Inso1.
i
Sample Hole Depth As S H~S04 '~ater Sol. Iron Iron Insol. Iron
tlo. No. Ft, Water 01. As S FeS04 As FeS04 As FeS04 FeS04 :Basis As t Fe20:
1 1 10 28.2 43.74 53.3 9.56 17.94 5.03
2 1 15 29.4 45.6 48.9 3.3 6.75 J. 74
3 2 10 wet 36.0 55.84 5'3.7 -
4 2 12 W 17.4 26.99 54.2 27.21 50.2 14.32
5 3 10 32.4 50.26 53.7 3.44 6.41 . 1.81
6 3 20 W 18.0 27.92 47.4 19.48 41 . 1 10..25
7 4 10 34.8 53.98 54.7 0.72 1 .32 . 0.38
~ 8 4 15 W 32.4 50.26 38. 1
I 9 5 10 12.0 lr..61 52.8 34 . 19 64.75 17.99
10 5 15 W 32.4 50.26 61 . 1 10..84 17.74 5.11
,
I 1 1 6 10 32.4 . 50.26 53.7 3.44 6.41 1.F-1
12 6 15 W 22.2 34." 3 64,4 . 29.97 . 46.54 15.17
r 13 6 20 W 8.4 13.03 st. G 39.77 75.32 20.93
14 .7 10 7.8 ' 12. 1 53.7 41 .6 77.47 21 .89
15 7 15 W 21.6 33.5 65.1 31.6 48.54 16.63
16 7 20 W 18.6 2P..85 71.8 42.95 59.82 22.6
17 8 10 33.0 51.19 54.6 3.41- 6.25 L19
18 8 20 34.2 53.05 54.6 1. 55 2.84 0.82
19 8 25 25.B 40.02 49.8 9.78 19.64 5. 15
20 8 30 W 22.8 . 35.37 ' 45.9 10.53' 22.94 5.54
21 9 10 32.4 50.26 53. 1 2.84 5.35 1. 49
22 9 20 33.0 51.19 53. 1 1 .91 3.6 1.0
23 9 30 32.4 50.26 53. 1 2.B4 5.35 '1 . '49
24 9 35 30.6 47.46 52.6 5. 14 9.77 2.71
25 9 40 W 21.0 32.57 42.9 10.33 24.08 5.44
26 . 10 10 30.0 4fi.~3 54.1 7.57 13.99 3.98
27 . 10 20 30.0 46.53 48.8 2.27 4.65 '1 .19
10 30 34.2 53.05 52.6 . - ., -
28
29 10 40 W 28.2 43.74 51.3 7.56 14.74 ,3 :9B
-------
..
..
X-RAY DIFFRACTION ANALYSIS
Hole Depth
No. Ft. FeS04 FeS04.H20 FeS04.4H20 ' Fes04.7H20
1 15 little little little mostly
2 10 little littl~ little lTlo$tly
3 10 little little little mostly
4 10 little little so~e some
5 10 little some some lot
6 10 little little some some
7 10 little 1 i t t 1 e. some some
8 25 little little mostly some
9 30 little little mostly some
10 30 little little mostly little or nonE
Any oxides present were in such small amounts that their
major lines were obscured by the minor lines of the sulfates.
-------
SHCET.KO • Oe
JO,': NO
llrl.SUBJECT
-------
..
PE~DLETO~. GA~1BLE. M.'\RTI~
HENDERSON. & G.'\RRETT
..\TTORNEYS AT LAW
P.O. Box 1226
AMHERST. VIRGINIA 2452 1
DOSALD G. PE."IDL£TON
J. MICHAEL GAMBLE
ROsALD D. HE."'DERSON-
MICHAEL T. G."RRE1T
STEPHEN C. MARTIS
609-61 1 MAIN STREET
September 15, 1989
TELEPHONE:
."MHERST 18041946-7192
LVNCHBl.'RG (804) 845'4218
Ms. Jamie Walters
community Relations Officer
Department of Waste Management.
10~ N. 14th St., 18th Floor'
Ricnmond, virginia 23219
Re:
American Cyanamid
River, Virginia
Plant,
Piney
Dear Ms. Walters:
I attended the meeting involving the American Cyanamid
clean-up at Piney River that was held this summer under the
auspices of the Waste Management Department and the EPA. I was
pleased that such thoughtful scientists had been involved in the
process of developing the clean-up proposal. I was concerned,
however, that American Cyanamid might be placed in charge of the
actual clean-up since I don't believe that they have ever
expressed an opinion that there is a serious problem at the site
and do not appear to be committed to cleaning it up. Rather they
will probably do the minimum necessary to avoid sanctions under
the law.
I believe the better approach to solving this problem would
be for the EPA to clean up the site and send the bill to. American
Cyanamid. .
I also Delieve tha~ the solution proposed by the E?A
scientists at the meeting appears to be a proper solution, except
that I think that there should be increased monitoring of wells
installed around the site. Monitoring should include a number of
private wells of homes in the area which can be used as base line
test wells to determine if any of the material is leaking off the
site. If you have a half a dozen to ten homes that you are
monitoring which show no acid or hazardous metals in their water
today, then if' we keep monitoring them we will notice any change
for the worse. If in fact they have acid or hazardous metal in
their water today then we know that the problem from the
American Cyanamid plant is far more serious than we had
anticipated.
I hope that you will
ensure that
these
suggestions
are
-------
Ms. Jamie Walters
September 15, 1989
paqe 2
factored into the final decision as to. the type of remedial
action to be taken and the methods used to monitor the results.
. ,
I trust your orqanization will continue to oversee the
clean-up and that there will be sufficient supervision, bondinq,
etc. to ensure that the contractors that actually do 'the work to
implement the plan do it properly so that we have a permanent
solution. . '
Thank you for your help in this matter.
sinc~ly,
/.
,/' .
"'--- -~/'{ t--(7l/(at L-::.-
~ Stephen C. Martin .
SCM: bh
-------
Q
1ELEPHONE MEMORANDUM
JAMIE WALTERS
NAME OF CAL1ER: Robert Forman
P.M.
CA1EITt.E: 8/11/f!B, 3:2D
ADDRESSIPHONE: 106 Wendover Lane, Charlottesville, Va. 22901/804-293-6628
SUBJECT MATTER: U.S. Titanium Proposed Plan for Cleanup
SUMMARY OF CAL1..= Mr. Forman called me earlier in the day, I returned his call, and then he called
me back at 3:20 p.m. He said he is a former employee of the Department at Waste Management, an~
worked on the U.S. Trtanium site. He said he wrote a good number of negative reports and memos
about the U.S. Titanium site. At that time, he said he and WaJt Gulevich wrote reports. and
investigations that said the copperas, when interacting with water, would turn to sulfuric acid and that
would eat through any clay liner/cap. He said that William Gilley approved the cap in 1980 anyway,
despite their reports that it would get eaten and fail. .
-
He said he was last out at the site in 1987; he claims the burial pit is abOut 100ft. wide and
8 ft. deep. According to him, Area 3 residue was also put in the landfill in area 1, atter the lagoon was
allowed to evaporate.
Mr. Forman claims that if the cap had been done correctfy, there would have been no problem.
But the cap was built incorrectly, not according to proper specifications, and wasn't maintained.
He read abOut the "lemon juice" comment from the public meeting. and was "furious" because
he said if you put a fish in lemon juice, it'll die.
He said that the Amherst side lagoons were tested and found not to be a problem. Herbert
Bryant bought those and used the residue for fertilizer.
He called primarily to let us know that he agrees totally with Hydrosystems/American Cyanamid
, that the area has been leached so much that not much at danger remains. He thinks it would be a
waste of money to spend $6 million when a good cap would do the job.. He said the site isn't that big
of a deal, and shouldn't waste taxpayers money.
He said he was famiH8r with Woody Greenberg. Sierra Club member whO is now running for
Board at SupeMsQs and attended the 819 meeting. and that Mr. Greenberg didn't have any experience
whatsoever to bale his opinions on Where it concerns technical matters at the site and the actual
dangers. He said Mr. Greenberg just wants to make a big deal out of it because he's running for
Supervisor. '
He wanted to let us know that he wouJd support Cyanamid in court with his "experience with
the site." He spoke &artier today with a Hydrosystems staff person who said that "you couldn't
understand a word that Longe. the guy from EPA, said.' I let him know that the presenter was from our
staff. not EPA. He said it didn't matter. the same was stiU true.
AJI in 81'. he plans on working with Cyan8mid ,in any wtlf. -some but8acrat didn't do his job
right when he picked the cap for 1980. and now someone else is taking the blame for it..
-------
..
SWIDLER & BERLIN
CHAan&ao
3000 K STIl!ET. N W.
. sum 300
. WASHINGTON. D.C. 1000'.~'1
JEROME C. MtJYS. ]'I.
ATTOINIY.AT.l,AW
September 28, 1989
olua DIAL
(1011 "4-4"~
nux, ~OIIH
T!UCO'IU. (2021 944..296
VIA FEDERAL EXPRESS
Timothy Longe, Ph.D.
Remedial Project Manager.
Department of Waste Management
18th Floor, Monroe Building
101 N. 14th Street
Richmond~ Virginia 23219
Re: u.S. Titanium Site,
Piney River, Virqinia
Dear Dr. Longe:
The enclosed document, together with the accompanying
submissions by Hydrosystems, Inc. In-situ, Inc., Mr. Michael
Nawrocki and Albert C. Hendricks, Ph.D., and Mr.. William Trees,
constitute the comments of American Cyanamid Company on the
"Proposed Remedial Action Plan" for the u.S. Titanium Site in
Piney River, Virginia. We ask that these comments be included in
the administrative record for the site.
As explained more fully in the enclosed comments, the
only remedial measures supported by the administrative record for
this site are those recommended in the Feasibility Study.
Assuming negotiation of a satisfactory settlement document, we are
prepared to implement those measures as soon as agreement can be
reached with the necessary parties.
First, in accordance with the Feasibility Study, we
propose to collect and treat, via a wetland t~eatment system,
groundwater originating in the vicinity of areas containing
copperas and/or acidified soils (Areas 1,2, 3, and 4). To that
end, we have retained Albert C. Hendricks, Ph.D. and Michael A.
Nawrocki, experts in the field of wetland treatment system design
and operation, to advise regarding the construction of such a
system at the U.S. Titanium Site.
Second, we propose to implement drainage controls and
construct a vegetated soil cover on the sedimentation ponds (Area
-------
(!)
Timothy Longe, Ph.D.
September 28, 198~
Page 2
5). This measure would eliminate impacts to the Piney River
associated with the erosion of acidified sediments in this area
and any violations of water quality standards which might result
therefrom. .
Third, we propose to construct an impermeable cap on the
copperas burial pit (Area 1). This measure would virtually.
eliminate infiltration into the burial.pit,. providing a level of
protection equivalent to that .afforded by dissolution alterna-
tives. ..., .
In sum, these measures would satisfy the remedial
objectives for the site by reducing the acidic and iron-bearing
discharges to levels that would not have significant adverse
impacts on the aquatic life downstream of the site. The.
recommended actions also would achieve, compliance with "applica-
ble, relevant and appropriate req~irements" by eliminating the
potential for violation of water quality standards.
In addition, the remedial measures recommended in the
Feasibility Study could be implemented relatively quickly. In
contrast, should the agencies rej ect the recommended containmen.t
alternative for Area 1, it would be necessary to conduct extensive
laboratory, bench-scale, and field studies to evaluate the
feasibility, cost, and overall effectiveness of the dissolution
alternatives. A further significant consideration would be the
fact that the dissolution alternatives (with the possible
exception of the resource recovery option) would generate
substantial amounts of sludge that would need to be landfilled on
site. This would render such alternatives no more "permanent"
than the containment option recommended in the Feasibility Study.
In light of the foregoing and the enclosed comments, we
would ~ike the. opportunity to meet with you .as soon as possible.
We will be contacting you shortly to discuss the scheduling of' a
meeting. .
Sincerely,
f~ c, ~. f..
Jerome c. MU~S, Jr.
JCM/lc
Enclosure
cc: Philip F. Koren, Es~.
Ms. Jamie Walters vi
James T. Heenehan, Esq.
Mr. Paul Leonard
-------
----- -
-.--
--. .
4 .
.,
5WIDLER & BERLIN
,
.' .
.~.
... - -- .
-
- .
, -. .. .
.. .., -
_.
CHA&"IUID
;000 K mEEI'. N.W.
ST..'I1'! JOO
WASHINGTON. D.C. 20007.JI41
12031 944-4500
.-:: -'~'~- .:' .~~,- ~~'>:~"\:'
". ': : -:,::"~":" ,"'..w...
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~; JOIIH
'!!uCOPID (3031 944-4296
COMMENTS OF AMERICAN CYANAMID. COMPANY ON THE PROPOSED
. REMEDIAL ACTION PLAN FOR THE U.S. TITANIUM SITE,
PINEY RIVER, VIRGINIA
T
- .
INTRODUCTION
This document and the accompanying submissions by
Hydrosystems, Inc.. In-Situ, Inc ~.. Mr. Michael A. Nawrocki and'
Albert C. Hendricks, Ph.D. and Mr~ William Trees (which are
incorporated herein by reference) constitute the comments of
American Cyanamid Company ("American Cyanamid", on the."Proposed
Remedial Action plan" for the U.S. Titanium Site in piney River.
Virginia. We ask that these comments be included in the
administrative record for this site.
American Cyanamid is concerned about site conditions and
their potential impact on the Piney River. The Company has
demonstrated this through its agreement to conduct the Supple-
~ental Remedial Investigation ("RI") and the Feasibility study
("FS") for the site, and through its voluntary efforts to
implement temporary repair measures at the site pending completion
0f the studies. .
The RI/FS, which was conducted by Hy~rosystems. Inc..
focused on seven areas of the site which had been identified by
earlier investigations as potential sources of iron and acidic
discharg.. to the Piney River. Consistent with the conclusions of
the prior investigations, the RI found that the acidic soils.,
surface water and groundwater at the site do not present any risk
to human health, but that there had been impacts to the aquatic
community in the piney River as a result of the acidic and iron-
bearing discharges. .
In light of the earlier studies and the data collected
during the RI, the FS identified the remedial objective for the
site to be the elimination and/or reduction of the acidic surface
water and groundwater discharges to the piney River to a level
which would not have significant adverse impacts on the aquatic
life downstream of the site. The FS identified an additional
-------
..
remedial objective .to be reduction of the flux of iron ~~ the
?iney River to a level which would minimi~e impacts on aquatic
life.
Based on the findings of the previous investi;~~ions and
o~ t~e remedial objectives which were identified in the ~!.
potential technologies were screened during the FS and remedial
action alternatives were formulated. Screening of alternatives
was conducted on the basis of implementability, effectiveness, and
cost. . .
Significantly, the State and EPA would not authorize. .
Hydrosystems to conduct as.pait of the FS the laboratory and field
scale studies which Hydrosystems had concluded were necessary. to
evaluate alternative remedial approaches for the site. As
explained below, this decision, occasioned by the desire of EPA
and the State to expedite the FS process, has resulted in a major
gap in the technical data supporting the State's proposed remedial
action plan for the site." . -
In the absence of laboratory and field data, a.detailed
analysis of the remedial alternatives was conducted during the FS
based primarily on available literature. Each alternative was
evaluated based on analysis of performance, risk reduction,
reliability, implementability, safety, environmental considera-
tions, Dublic health, institutional issues, and cost. A
comparative analysis was then performed, in.which the alternatives
were compared to identify and evaluate the key trade-offs between
the alternatives.
Based on the comparative analysis, a comprehensive
remedial program for the site was recommended in the FS. The
recommended remedial program included installation of a passive
groundwater collection and treatment system (to be located in
"Area 7"), capping of the copperas burial pit:' ("Area 1"), repair
of the unvegetated areas surrounding the groundwater seeps along
the base of the recla~ed slope ("Area 2"), and construction of
drainage controls and placement of a vegetated soil cover in the
area of the former sedimentation ponds ("Area 5"). No additional
action was recommended for Areas 3 and 4 (beyond collection and
treatment of acidic groundwater originating in those areas),
because of the min~al contribution of those areas to acidic
conditions at the site. "No action" was recommended for Areas 6
and 7, because Area 6 had been determined to be non-acidic and
Area 7 would receive incidental remediation as a result of the
installation of the groundwater collection and treatment system.
The FS, including the recommendation for remedial
action, was submitted to the state and EPA on or about November
20, 1988. On Harch 15, 1989, the state provided written comments
on the FS to Hydrosystems. Hydrosystems responded to the comments
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..
and supplemented the FS by letter dated April ~8. 1989. .Shortly
thereafter. Hydrosystems was advised that th~ State Dlanned to .
announce its "Proposed Remedial Action Plan" for the. site on July
31, :"989.
Less than two months before the State's planned
announcement of a cleanup plan for the site (and approximately
seven months after Hydrosystems' submission of the FS to the,
State), Hydrosystems was advisgd that the State was considering a
remedial technology for Area 1 which had not been addressed in the
FS and had never been suggested as a possible approach in any of.
Hydrosystems' discussions, with the State. As explained be~ow.
Hydrosystems reluctantly agreed to assess this additional' .
alternative, referred to as "in-situ dissolution and treatment'of.
leachate". under very tight time constraints and without a full
opportunity to evaluate the feasibility 'of the approach or to
compare this approach with other treatment alternatives. This
resulted in the submission of an "addendum" to the FS on July 18.
1989. . -.
The "Proposed Remedial Action Plan" announced by the
state on July 31. 1989 incorporated the passive groundwater
collection and treatment approach recommended in the FS, as we1
as the remedial alternatives recommended for Areas 2 and 5.
However, the state rejected the recommendation in the FS that Area
1 be capped. electing instead the "in-situ dissolution and
treatment" alternative which had been identified only weeks
before. The State also proposed "improved surface drainage" for
Area 3. "drainage control and revegetation" for Area 4, and
"above-grade dry neutralization" for Area 7.
We. strongly support the State's selection of a passive
groundwater collection and treatment system. as well as its
concurrence in the remedial alternatives recommended in the FS for
the recla~ed slope and the former sedimentation ponds. However,
we do have a number of comments on the establishment of effluent
limitations and/or other performance standards for the discharge
from the wetland treatment system. and we have been advised that
we will have a full opportunity to provide such comments during
the remedial design/remedial action phase of the cleanup.
Enclosed for inclusion in the administrative record are cooies of
correspondence between American Cyanamid and state representatives
confirming this understanding.
We do. however. take issue with other remedial measures
proposed by the state. With respect to the in-situ dissolution
and treatment alternative proposed for Area 1. the record is
grossly inadequate and incomplete. Because of the extremely s' t
time frame within which this alternative was identified and ha. .0
be evaluated, it was not subjected to the required "comparative
analysis of alternatives" set forth in the FS with respect to the
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..
other alternatives, and was selected withou~ benefit of ~he
laboratory and' field scale studies which are necessary to
determine whether treatment alternatives (including resource
recovery) are feasible and cost effective at this site. Moveover.'
the studies conducted by the state and EPA, as well as the RI
conducted at their direction. support the conclusion that ~he site
does not pose a significan~ threat to the environment and that
remediation of Area 1 beyond .that recommended in the FS is not
necessary or cost-effective. .
. .
We also take issue with the remedial alternatives
proposed for Areas 3. and 4. However, as explained below. if
remediation of those areas is .to be undertaken (beyond groundwater
collection and treatment), .it should be limited to those locations
where natural revegetation has not yet occurred. There is no. .
reason to disturb areas which have already revegetated naturally.
Comments on each of these sDecific issues are set:orth
more fully below. As previously discussed, we expressly reserve
the right to comment on any effluent limitations and/or per-
formance standards for the wetland treatment system at the
appropriate time.
.II.
COMMENTS ON IN-SITU DISSOLUTION AND TREATMENT OF LEACHATE AS
THE PROPOSED REMEDIAL ALTERNATIVE FOR AREA 1 .
A.
The Administrative Record does not Support the Selection
of a Treatment Alternative for Area 1
Section 121{a) of the Comprehensive Environmental
Response, Compensation, and Liability Act ("CERCLA"), added to the
statute by the Superfund Amendments and Reauthorization Act of
1986, provides that "(tJhe President shall select appropriate
remedial actions determined to be necessary. . . which are in
accordance with this section and, to the extent practicable, the
national contingency plan, and which provide for cost-effective
response." pending revision of the national contingency plan to
conform to the 1986 amendments, EPA published a document entitled
It Interim Guidance on Superfund Selection of Remedy," dated
December 24, 1986, which constituted EPA's interpretation of the
new statutory requirements on the CERCLA remedy selection
process .1:/
1/ This document (copy attached) 1s hereinafter referred to as
"Interim Guidance." The Interim Guidance was expanded in EPA's
"Interim Final Guidance on Preparing Superfund Decision Documents"
dated June 1989 ("ROD Guidance") and in its "Guidance for
Conducting Remedial Investigations and Feasibility Studies Under
CERCLA" dated August 1988 ("RI/FS Guidance").
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According" to the Interim Guidance, the 1986 amendments
required a number of changes in the procedures under which"CERCLA
remedial actions would be selected. For examDle, the Interim
Guidance provides that remedial investigations may need to be
conducted in at least two phases to allow for bench-scale or
pilot-scale testing of treatment technologies.~/ :'he second
ohase, the post-screening field investigation, focuses on the
collection of data sufficient to make a well-substantiated remedy
selection decision, and may inv~lve the testing of a par~icular .
technology on the waste site itself.il "
According to the RI/FS Guidance, "d~t~ collected during
site characterization may not always be adequate for assessing the
feasibility of remedial technologies," and, in fact, the need for" .
detailed data from treatability tests may not become apparent
until the initial screening of alternatives has been completed."!/
" Treatabili ty testing is deemed unnecessary where "technologl"eS
have been demonstrated sufficiently so that site-specific
information collected during Sit~ characterization is adequate -to
evaluate and cost those technologies without conducting treatabil-
ity testing."il Treatability testing may not be necessary where
"[a] developed technology is well proven onsimilar aDDlications"
and where "Wubstantial excerience exists with a technology
employing treatment of well-documented waste materials."~/
The RIfFS Guidance further provides that "(w]here
treatment performance is difficult to predict, an actual testing
of the yrocess may be the only means of obtaining the necessary
data."! Moreover, "in some situations it may be more COSt-
effective to test a process on the actual waste than it would be
to characterize the waste in sufficient detail to predict
performance."~1 In sum, "[t]reatability testing performed during
an RI/FS is used to adequately evaluate a specific technology,
2/
31
Interim Guidance at 2; RI/FS GUidance at 6-2.
Interim Guidance at 3: RI/FS Guidance at 7-4 - 7-6.
41
RI/FS Guidance at 6-4.
51
RI/FS Guidance at 6-6.
6/
Id.
Id.
(emphasis added).
7/
8/
Id.
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..
including evaluating performance, determining process sizing, 3nd'
estimating costs in sufficient detail to support the remedv-
selection process." z./ - -
With reSDec~ to bench-scale treatabilitv s~udies. t~e
~I/FS Guidance states that these "are typically perf:>rmed for
proj ec~s involving treatmen~ or destruction technologies.,":i. 0 /
Bench-scale tests "may also be conducted for well-develoo-ed and
documented technologies that are being applied to a new ~aste.,,:i.l/
"Alternatives involving treatment or destruction technologies-
~equire some form _of treatability testing, if-their use represents
first-of-its-kind applications on unique or heterogeneous
wastes. "1£/ - -.
with resDect to the final selection of a remedial
program. the various EPA guidances conclude ~hat CERCLA requires
the selection of a remedial alternative which meets the following
four criteria:
(1) the remedy is protective of human health and the
environment;
(2) the-remedy satisfies applicable or relevant and
appropriate requirements;
(3) the remedy is cost-effective:
(4) the remedy utilizes permanent solutions and
alternative treatment technologies or resource
recovery technologies to the maximum exten~
practicable.ll/
As explained in detail below, the administrative record
for this site is inadequate to support the selection of a
treatment alternative for Area 1 because the-State and EPA did not
permit the conduct of the laboratory and field studies necessary
to evaluate treatment alternatives, because the "in-situ
dissolution and treatment" alternative was not subjected to the
required "comparative analysis of alternatives," and because the
section 121 remedy selection criteria were misapplied.
9/ RI/FS Guidance at 6-7.
10/ Id.
11/ RI/FS Guidance at 6-8.
12/ RI/FS Guidance at 6-11.
11/ Interim Guidance at 4; ROD Guidance at 2-14; RI/FS Guidance
at 5-10 - 5-12.
-n-
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3 .
Treatment Alternatives were not Subject to Necessary
Laboratorv and Field Studies
As discussed above, the Interim Guidance and other EPA
guidance construing the 1986 amendments to CERCLA provide for the
conduc~ of bench-scale and pilot-scale studies where necessary to
evalua~e alternative treatment technologies. Shortly after the
enactment of the 1986 amendments, EPA directed its regional
offices (in conjunction with the appropriate state agencies) to
examine ongoing projects (such as the U.S. Titanium matter) and
draft a list of potential changes that would be necessary to
satisfy the new statutory prqvisions .l!/ The regional offices. .
were directed to no~ify potentially responsible parties conduc~ing
RI/FSs of the new requirements and to discuss with them any
necessary modifications of their work plans.~/
Consisten~ with the Interim Guidance, EPA set forth in a
letter dated February 6. 1987 (copy attached), a discussion of the
:'lew requirements as they applied.to the FS for the U.S. Titanium
Site. The letter provided, in pertinent part, that "American
Cyanamid and their contractor Hydrosystems will be required to
evaluate permanent solutions, alternative treatment technologies
or resource recovery technologies during the FS process" and "that
Ita continuation of the Laboratory and Bench Scale studies
presen~ed in the [remedial investigation]" may be necessary.
In accordance with the February 6, 1987 letter from EPA,
Hydrosystems submitted to the state and EPA, on October 16, 1987,
a draft FS work plan (copy attached) which provided for ~e
conduc~ of post-screening field investigations (to define
poten~ial acidity in direct runoff from the site and to determine
acidity in the Piney River) and treatabil~ty. testing (to evaluate
technologies for neutralizing the soil/copperas mixture in Area 1
and to evaluate biological treatment alternatives). At that time,
the State and EPA were" advised that the re~ired laboratory and
bench scale studies would add at least 210 days to the originally
scheduled 90 day study' period. Additional information regarding
the treatability testing and the expected time frame for the
testing was provided to the state and EPA by letter dated November
25, 1987 (copy attached).
Because of the additional time associated with the
proposed t~eatability testing, the State and EPA insisted that any
such testing be deferred until after issuance of the Record of
Decision. However, as explained in the attached report by In-
situ, Inc., laboratory and field testing is necessary to generate
14/
Interim Guidance at 2.
15/
Id.
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information sufficient to evaluate the feasibility and c~st-
effec~ivenessof ih-situ dissolution alternatives (andpo$sibly
other ~=eatment al~ernatives) as opposed to containment options.
For example, before dec.iding whether in-situ dissolution
is the aoorooriate aooroach for Area 1, it is critical to
determine-if"such an-approach would exacerbate site conditions by
promoti~g the formation of high conductivity pathways for the
copperas leachate, thus .creating a mechanism for increased
transoort of the leachate to groundwater. As discussed. in rn-
situ,-rnc.'s reoort, the. likelihood of such an occurrence could ce
evaluated by, f;r example, the installation Qf approximately 10 .
piezome~ers in Area 1 to monitor water levels during field ::ials.
In the absence of.precipitation, the steady state water level.
decline would give an indication of the leakage ~ate from the
burial ?it during the field study.
~
Moreover, laboratory and field studies are necessary to
determine whether the handling aqd disposal of the sludge that -
would be generated as part of the in-situ dissolution and
treatment of leachate option would be so problematic that it would
render ~he entire approach infeasible. As explained in the
attached letter from Mr. William Trees of Kemira, Inc., a .major
titanium dioxide processor, the high liquids content of the sludge
can be expected to pose serious obstacles and necessitates
examination of possible approaches for stabilizing the"material.
In addition, In-Situ, Inc. points out that it is
necessary to evaluate dissolution efficiencies during field
studies before it can be determined whether such an aooroach is
appropriate to this site. It obviously would not be c;st
effective to Dnplement the in-situ dissolution approach, only to
find that, because of the nature of the soil/copperas matrix or
for other reasons, the material cannot be uniformly dissolved.
Finally, laboratory and field studies are imperative to
allow for full evaluation of resource recovery options. As
explai~ed in its report, In-situ, Inc. has concluded that an in-
situ dissolution approach followed by recovery of product may hold
great promise, and could help mitigate the cost of remediation.
This approach could involve in-situ extraction of a low value
product followed by an upgrading process to produce a higher value
product such as ferrous sulfate or ferrous ammonium sulfate. If
the necessary studies show this approach to be feasible and cost-
effective, it clearly would be preferable to neutralization of the
copperas solution followed by burial of the resulting sludge on
site, particularly in light of the statutory requirement for
assessment of "resource recovery technologies that, in whole or in
part, will result in a permanent and significant decrease in the
toxicity, mobility, or volume of the hazardous substance,
pollutant, or contaminant." See CERCLA section 121(b)(1).
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--.
~ -... ,
Because the chemical and .hydrologic parameters involved
in the in-situ leaching approach are very .site ~pecific. ~t is
essential to complete the necessary studies prior to comparing/the
remedial alternatives and the selecting the fi~al remedy.
Accordingly, there is at present inadequate support in the Record
for concluding that in-situ dissolution and t:eatment of leachate
(or other treatmen~ alternatives) would provide greater. or even
equivalent, protection of the environment compared to containment
options. The attached report by. In-situ, Inc. identifies the.
types of laboratory and field scale studies necessary to evaluate
treatment alternatives. including possible application of resource
recovery technologies. ...
C.
The "In-situ Dissolution and Treatment of Leachate"
Alterna~ive was not Subject to the Required "comparatt"ve.
Analvsis of Alternatives"
According to the RIfFS Guidarice, the "detailed analysis
of alternatives" required as part of the remedy selection process
in section 300.68(h) of the National Contingency Plan entails.
among other things. "a comparative analysis. . . to evaluate the
relative performance of each alternative in relation to each
specific evaluation criterj;on."l~/ This is perhaps the most
critical component of the feasibility study. given that it
provides a procedure for identifyinQ and evaluating the key
tradeoffs between the alternatives.!!/
As previously discussed. because of the circumscribed
process by which the State identified "in-situ dissolution and
treatment of leachate" as a potential remedial alternative for
Area 1, that alternative was not subjected to the required
comparative analysis. and thus was not evaluated against other
treatment and non-treatment alternatives which may provide an
equivalent or superior level of performance at a lesser cost. ~
40 C.F.R. 5300.68(i). This analysis must be.conducted before an
informed decision can be made regarding remediation of Area 1.
For example. as discussed above. there are significant
feasibility and cost implications associated with the handling and
disposal ot the sludge that would be generated as part of the in-
situ dissolution and treatment of leachate approach (as well as
part of the "above-grade wet neutralization" alternative). Those
considerations should have been part of the comparative analysis,
which might well have shown the dissolution alternative to be less
desirable than containment options. The absence of a comparative
evaluation of the "in-situ dissolution and treatment of leachate"
16/
17/
RI/FS Guidance at 7-31.
Id.
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-'
alternative renders the administrative record inadeaua~e ~~
suooort the selection of that option as t~e preferred remedial
al~~rnative for Area -1.
:"'I
0.1.
The Section 121 Remedy Selection Criteria We~e
Misaoolied
The Proposed Remedial Alternative for Area 1 ~5 ~ot
Necessary to Protect I1uman Health and the EnVl=cnment or
to Satisfy ARARs
Section 121(b)(1) of CERCLA contains the general
requirement that CERCLA cleanups must be protective of human
health and the environment. According to EPA guidance. -:his,
requirement is satisfied if the remedy meets or exceeds applicable'
or relevant'and appropriate requirements ("ARARs") or health-based
levels established through a risk assessment when ARARs do not
exist.~1 ,
,
... .
i
, '
The Remedial Action Plan proposed by the State. as well
as the Feasibility Study, identify Federal and State laws
regarding surface water quality as the ARARs for the U.S. ::tanium
Site. The Feasibility Study identifies the key ARARs as the State
Water Quality Standard for pH of 6.0 to 9.0 and the State Water
Quality Criteria for iron of 1.0 mg/l.
According to piney River water quality data generated in
connection with RI over- a period of several years, the pH or the
river was observed to be below 6.0 on only five occasions cut of a
total of 180 samples which were collected. No exceedences of the
iron criterion were detected. The five occasions during which pH
excursions occurred were associated with rainfall events which
caused acidic sediments from Area 5 to erode and discharge to the'
river. Accordingly, it was concluded in the FS that the passive
collection and treatment of acidic and iron-bearing groundwater
originating from Areas 1, 2,3, and 4, together with measures
designed to prevent the erosion of Area 5 during storm events,
would prevent potential excursions of applicable water quality
standards and criteria. These measures, in conjunction with the
preventative measures of capping Area 1 and regrading and
revegetating of Area 2, were determined in the FS to be protective
of human health and the environment and were recommended as the
appropriate remedial alternatives for the Site.
, However, EPA and the State apparently concluded that.
notwithstanding the determinations in the, FS, it was necessary t=
select a "t~eatment. alternative for Area 1 which, although it
would provide no greater protection for the piney River, could be
characterized by the State as a "permanent" remedy. In fact. as
,181
Interim, Guidance at 4.
-, n..
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..
explained in the attached report f=om Hydrosystems. Inc.. wha~ ~~e
proposed plan would do is substitu~e one landfill for another. at
an enormous expense and without commensurate environmen~al benefit
or "permanence." (This flaw is shared by the "above-grade wet
:leutralization" alternative.) For that reason, the proposed
remedial ac~ion Dian is inconsistent with CERCLA and EPA cuidance.
"~ -
2.
The ProDosed Remedial Alternative for Area 1 is not
"Cos~-Effective"
Section 121 of CERCLA also require$ that CERCLA cleanups
be cost-effective. According" to the Interim Guidance. "this"
[cost-effec~ivenessJ finding requires ensur.ing that the resill":s of
a par~:=ular alternative cannot be achieved by less costly "
methods."l2/ In addition, the Conference Report to the 1986
Suoerfund Amendmen~s and Reauthorization Act stated that. i~
de~erminina the cost-effectiveness of a remedial action. EPA must
fi.rs-:=etermine the "appropriate" level of environmental and
health orotection to be achieved ~nd then select a cost-efficient
means cf achieving that goal.20/ "
with resoect to the U.S. Titanium Site, EPA and the
State determined the "appropriate" level of environmental and
health protection to be compliance with State water quality
standards and criteria for the piney River. The cost-efficient
means of .achiav1ng that goal, as set forth in the FS, is the
collection and treatment of contaminated groundwater, together'
with the installation of a vegetative cover on Area 5, capping of
Area 1. and regrading and r~vegetation of Area 2. However. EPA
and the state selected a far more costly program which provides
essentially the same level of protection. For this reason. the
State has proceeded in violation of the requirements of section
121 of C~CLA and EPA guidance.
The Proposed Remedial Alternative f~r Area 1 is not
"Practicable"
3 .
S.c~ion 121(b)(1) of CEaCLA calls for .the selection of
remedies that utilize "permanent solutions" and "alternative
treatment technologies" or "resource recovery technologies" to the
"maximum extent practicable." EPA guidance provides that "(t)his
19/
-"
!nterim GUidance at 4.
~/ See H. Rep. No. 962, 99th Cong., 2d Sass. (1986) (hereinafter
"Conference Report") at 245.
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..
determination ~s interrelated to the cost-effectiveness finding'.
and includes consideration of technological feasibility and
availability. "Zl/ ,
The legislative history' of SARA confirms that permanent
remedies are only required to the extent "practicable", and
practicability subsumes consideration of cost. The legislative
history reflects congress' "intent that the Administrator take
into account several factors in ~etermining whether a solution is
Rracticable, including technical feasibility, cost, state and'
public acceptance of the remedy, and other appropriate cri-
teria."Z2/ Thus, "[a] technology may be available but not be a
cost-effective remedial action und~r the cirCumstances, and would:
therefore, be ineligibl.e for consideration under section 121."~1/
Accordingly, "[u]rilike a' 'feasible and achievable' standard,'this
[practicabili ty] standard requires consideration of 'both technical
and nontechnical factors."Z4f
Moreover, the RI/FS Gu19ance expressly recognizes that
CERCLA does not mandate "treatment" in cases where it would not be
cost-effective. The RI/FS guidance provides that:
(t]he use of treatment technologies and,
therefore, the development of a complete range
of options, may not be practicable at some
sites with large volumes of low concentration
wastes (e.g., large municipal landfills or
mining sites). Remedies involving treatment
at such sites may be prohibitively expensive
or difficult to implement.2S/
. This "exception" to the general rule favoring treatment alterna-
tives is directly applicable to the copperas landfill at the U.S.
Titanium site~ which consists of large volumes of low concentra-
tion "wastes" resulting from mining-related activities conducted
at the site.
21/
Interim Guidance at 4.
~/ 132 Congo Rec. H9566 (daily ed. Oct. 8. 1986) (remarks of
Rep. Lent).
23/ Id. at H9589 (remarks of Rep. Eckert).
24/
Id.
25/
RI/FS Guidance at 1-14.
-12-
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In selecting in-situ dissolution and treatment as ~h~'
remedial alternative for Area 1, EPA and the State have selec~ed a
"permanent" remedy without the requisite. considera~ion ot .
"practicability," including cost. Therefore, the selection of the
alternative is inconsistent with section 121 of CERCLA.
III. COMMENTS ON PASSIVE GROUNDWATER COLLECTION AND TREATMENT
SYSTEM
. .
o We strongly endorse the proposal to install a passive
groundwater collection and treatment system at the site. However,
we do have the following preliminary .commen~s regarding the.
timetable for imposition of any effluent limitations and/or other
performance standa~ds for. the system. We understand that there
will be a full opportunity to comment on any such requirements
after the ROD has been issued.
As explained in the enclosed report by Michael A..
Nawrocki and Albert C. Hendricks, Ph.D, after installation of-the
wetland treatment system, a period of time is necessary to conduct
field observations and to make adjustments in order to ensure the
long term health and effectiveness of the system. Observations of
and adjustments in water depths, flow patterns, inflow and outflow
controls, and plant growth patterns, among other parameters, mt'
be made throughout a number of growing seasons and hydrologic
conditions.
According to Mr. Nawrocki and Professor Hendricks, based
on past field experience, as many as three growing seasons may be
required to establish plant viability and allow replanting in
order to account for some expected plant mortality. Additional
time - perhaps two years - may be needed to adjust flow patterns
within the wetland. This has been found to be necessary in order
to correct possible short circuiting caused by selective growth of
mature plant groups and natural, nonhomogeneous decay of the
organi~ substrate.
In sum, a five-year transition period may be necessary
to make required adjustments to prevent any degradation in removal
efficiencies due to variance in water depths, overall organic
substrate decomposition, short-circuiting of flow, storm damage,
erosion, or other conditions. Accordingly, effluent limitations
and/or other standards for judging the perfo~ance of the wetland
treatment system should not take effect until the end of the
transition period.
IV. Conclusion
The data generated in connection with the supplement
remedial investigation show that excursions of the pH standard r1
the Piney River attributable to the U.S. Titanium are associated
-11-
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with storm events. which cause erosion of acidified soils in Area
5. ~hronic impacts are a~tributable to an elevated level of iron
in the site discharge. which. although it. does not result "in
violation of water quality standards or criteria. impac~s the
ben~hic community in the river. these impacts are addressed by
the remedial program recommended in the FS. Assuming t~e
participation of other PRPs and negotiation of a satisfactory
settlement document. American Cyanamid remains willing and ready
to imclement remedial measures recommended in the FS. We believe
t~at continued discussions among the interested parties can :ring
abou~ a mutually satisfactory approach to.site remediation. .
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..
APPENDIX D
GIos9gry c:A ~ Terms
-------
. C'p'Amonwealth of Virginia
Department of Waste Management
F al\fMnter 1989
Superfund Glossary
This glossary defines terms often used by the Department of Waste
Management and the U.S. Environmental Protedion Agency (EPA).
staff when describing activities that take place under the
Superfund law, CERClA. The definitions apply specifically to the
Superfund Program and may have other meanings when used for
other types of programs. Italicized words included in \farious
definitions are defined separately in the glossary. If you still
tiave questions about Superfund Program terms, you can contact
. your Superfund Program Community Relations Uaison at the
Department of Waste Management or the EP A.
-------
Iministnitive Order on CoIIS8f1t:. A l~aI
,nd enforceable agreement signed between
. EPA and Potentially Raponsib/e Parties
(PRPs) whereby PAPs agree to perform or
pay the cost of a site cleanup. The
agreement describes actions to be taken at
a site and may be subject to a public
comment period. Unlike a consent decree,
an administrative order on consent does
not have to be approved by a judge.
IUr Stripping: A treatment system that
removes. O( 'strips' , volatile organic
compounds from contaminated groundwater
or surface water by forcing an airstream
through the water and causing the
compounds to evaporate.
Aquifer: An underground rock formation
made of materials like sand, soil. or gravel
that can store and supply groundwater to
wells and springs. Most aquifers used in
. the U.S. are within a thousand feet from the
earth's surface.
Carcinogen:
cancer.
A substance that causes
,
arbon Adsorption: A treatment system
h'here contaminants are removed from
groundwater or surface water when the
water is forced through tanks containing
activated carbon, a specially treated
material that attracts the contaminants.
Cleanup: Actions taken to deal with a
release or threatened release of hazardous
substances that could affect publJc health or
the environment 'Cleanup- Is often used
broadly for various response actJOtJI or
phases of the remedial responses.
Comment Period: A tm8 period CUtng
which the public can rwwI8w and commenI
on various dOCUlT1ll1l8 and proposed
cleanup plans. A comment pertod Is
provided when EPA ploposel to add sk.
to the National Priorities Ust (NPL).
Also, a minimum 3O-day comment period 18
held for community members to review and
comment on a draft feasibility study.
Community Relalions (CR): The State and
EPA's program to inform and iovotve the
public in the Superfund process
and respond to c;ommunity
concerns.
CERCLA: (Comprehensive
Environmental Response,
Compensation and Uability Act) A
Federal law passed in 1980 and
modified In 1986 by SARA. The
acts created a special tax that goes
into a uust fund, commonly known
as Superfund, t8 Investigate and
clean up abandoned or
uncontrolled hazardous waste sites.
Under the program, EPA can either:
. Pay for site' cleanup when parties
responsible for the contamination
cannot be located or are unwilling
or unable to perform the work.
. Take legal action to force parties
responsible for sit~ contamination to
clean up the site or pay back the
Federal government for the cost of
the cleanup.
Consent Decree: A legal document.
approved and Issued by a judge,
that formalizes an agreement
reached between EPAIState and
potentially responsible parties
(PRPs) where PAPs will perform all
or part of a Superfund site cleanup.
The consent decree describes
actions that PAPs are required to
perfonn and Is subject to a pubUc
comment period. .
Ccnr8:t lab PluQI_.1o Laboratories
under contract to EPA which
anaIyz. sol. water, and waste
sampIe8 taken from Superfund
Sites.
COIt-Br8dfve AI8rn8IJve: The
cleanup altemattve setected for a
sit. on the N8tionaI Priorltiu Ust
(NPL) based on tec:t.1icaI feasibfllty, .
performance, reUabiUty, and cost.
The selected altematJve does not
requn EPA to choose the least
expesl8lv8 alternative, but require8
that If several altematJves are
. available that deal effectively with the.-
problems at the . site, EPA or the State
mUSt choose the remedy on the basis
of permanence, reliability and cost
Cost Recovery. A legal process where
PRPs can be required to pay back the
Federal government for money it
spends on the cleanup program.
Enforcemeut EPA~s efforts, through
legal action if necessary, to force PRPs
to perform or pay for a superfund
cleanup.
Enforcemett Decision Document:. A
public document that explains the
State's and EPA's selection 01 a
cleanup alternative at a Superfund si.te
through an enforcement action. Similar
to a Record of Decision (ROD).
Environmental Response TeCUJ'l (ERT):
EPA hazardous waste experts who
provide 24-hour technical assistance to
EPA regional offices and States during
an types of emergencies involving
releases at hazardous waste sites or
toxic spills.
Fell&itIi8y Study (FS): A study done
after the remedial investigation that
reviews options for cleaning up the site.
Grou1dwater: Water found beneath the
earth's surface that pores between
materfafs like sand, soi~ or gravel In
aquifers, groundwater occurs in
sufficient quantities that it can be used
for drinking water, irrigation and other
purposes.
H8z8d R8*k1g System (HRS): A
scoring system that is used to evaluate
potential reCatJve risks to public health
and the environment from releases or
threatened releases Of hazardous
substaneu. EPA and States use the
HAS to c.3ctdate a site score, from 0 to
100, baNd on the actual or potential
re1eaS8 of hazardous substances from
a site through air. surface water, or
groundwat. to affect people or the
envtronmenL The HRS score
-------
determines whether a site will be acjded to
the National Priorities Ust (NPL).. !.
Hazardous Substance: Any material that
poses a threat to public health and/or the
environment. Typical hazardous substances
are materials that are toxic, corrosive,
ignitable. explosive, or chemically reactive.
Hydrology: The science dealing with
properties, movement, and effects of water
on the earth's surface, in the soil and rocks
below, and ir\ the atmosphere. .
Incineration: Burning of certain types of
solid. liquid. or gaseous materials under
controlled conditions to destroy hazardous
waste. .
Information Repository: A file containing
current information, technical reports, and
reference documents regarding a Superfund
site. The information repository is usually
located in a public building that is
convenient for local residents - like a
library, city hall, or public school.
Leachate: A contaminated liquid resulting
when water trickles through waste ma\erials
and collects components of those wastes.
Leaching may occur at landfills and may
result in hazardous substances entering soil,
surface water, or groundwater.
Monitoring Wells: Special wells drilled on
or near a hazardous waste site where
groundwater can be sampled to determine
the direction in which groundwater flows,
and the types and amounts of contaminants
present.
National Oil and HcK.aIdouS Subs1anC8S
Contingency Plan (NCP): The Federal
regulation that guid8' the Superfund
program.
National Prioriies Ust (NPl): EPA's list
of the most seriou8 uncontrOlled or
abandoned hazardoul wast. sites that
qualify for cleanup using Federal funds.
National Response Carter. The center
operated by the U.S. Coast Guard that
receives and evaluates reports of 01 and
hazardouS substance releases. into
the environment and notifies the
appropriate agencies. The NRC
can be contacted 24-hours a day,
toll-free at (800) 424-8802.
National Rt=iyUllS8 Team: Repre-
sentatives of 12 F8deral agencies
that coordinate Federal responses
to nationally significant pollution
incidents and provide assistance to
the responding agencies.
On-Scene Coordinator (OSC): The
Federal official who coordinates and
directs SuperfundremovaJ actions.
Operable' Unit: An action taken as
one part of an overall site cleanup.
Operations and Maintenance
(O&M): Activities conducted at a
site after a response action occurs,
to ensure that the. cteanup or con-
tainment system is lunctioning pro-
perly. .
Parts Per BBDon (ppb)/Parts Per
Mi1Iion (ppm): Units commonly used
to express low concentrations of.
contaminants. For example, 1
ounce of a chemical in 1 million
ounces 01 water Is 1 ppm; 1 ounce
of the chemical In 1 billion ounces
of water is 1 ppb. II one drop of the
chemical is mixed in a competition-
size swimming pool, the water wiD -
contain about 1 ppb of the
chemical
Potenlaly RRt-.stie PartieS
(PAPs): Any indMduaI or company
(such as owners. operators.
transporters, or generators) poten-
tially responsible lor, or c0ntribu-
ting to, the contamination problems
at a site. WheneVer possible, EPA
and the State require PAPs to dean
up hazardouS waste sites they have
contaminated. .
P".h'.f MS .,. (PA): The
process of collecting and reviewing
available information abOut a known
or suspected hazardous waste ...;.~.-
EPA and States. use this infOrmal"
determine il the site requires fI.. _l
study. If so, a site inspection' (SI) is
performed.
Quality Assurance/Quality Control (OAJ
QC): A system of procedures. checks. ~
audits, and corrective actions used to
ensure that field work and laboratory
analysis during the investigation and ..
cleanup of Superfund sites meet esta-
blished standards: .
'Record of Decision (ROO): A public
.document that explains which cleanup
alternative (s) will be used for a National
Priorities Ust (NPL) site~ The ROD is
based on information generated during
the Remedial InvestigationfFeasibilil
Study and the Community Relations Pro-
gram lor the site. .
Regional RespoIlSe Team: ReQresenta-
tives of Federal, State, and local
agencies who may assist in
coordination of activities at the request
of the On-Scene Coordinator or
Remedial Project Manager bef' and
during response actions.
Remedial Action (RA): The actual con.
struction or implementation phase that
loIlows the remedial design 01 the
selected cleanup alternative at a site.
Remedial Design (AD): An engineering
phase that lollows the Record o( Deci-
sion when technical drawings and
specificationS are developed lor the
subsequent remedial action at a site.
RemedallnveStIgaIIorVFeasDIity Study
(RIIFS): Two distinct but related studies.
They are usually performed at the same
time, and referred to as the RifFS. The
RVFS Is Intended to:
. Gather the data necessary te
determtne the type and extent 01 con
tamInaUon at 8 Superfund site.
. Establish criteria for cleaning up th!
site; .
-------
Identify and screen cleanup alternatives
jf remedial action; and . •
« Analyze in detail the technology and
costs of the alternatives.
Remedial Project Manager (RPM): The EPA
or State official responsible for overseeing
remedial response activities.
Remedial Response: A long-term action
that stops or substantially reduces a release
or threatened release of hazardous
substances that is serious, but does not
pose an immediate threat to the public or
the environment.
Removal Action: An immediate action taken
over the short-term to address a release or
threatened release of hazardous substances.
Resource Conservation and Recovery Act
(RCRA): A Federal law that established a
regulatory system to track hazardous
substances from the time of generation to
disposal. The law requires safe and secure
procedures to be used in treating,
transporting, storing, and disposing of
azardous substances. RCRA is designed
10 prevent new uncontrolled hazardous
waste sites.
Response Action: A CERCLA-authorized
action at a Superfund site involving either a
short-term removal action or a long-term
remedial response that may include, but is
not limited to, the following activities:
» Removing hazardous materials from a she
to an EPA-approved, licensed hazardous
waste facility for treatment, containment, or
destruction.
» Containing the watt* safely orvstte to
eliminate further problems.
« Destroying or treating the waste orvsite
using incineration or other technologies.
* Identifying and removing the source of
groundwater contamination and preventing
further movement of the contaminants.
Responsiveness Summary: A summary of
oral and/or written public comments
received by the State or EPA during
a comment period on key
recommendations for site cleanup,
and the State/EPA response to
those comments. The
Responsiveness Summary
highlights key community concerns
and public involvement.
Risk Assessment An evaluation
performed as part of the remedial
investigation to assess conditions at
the site and determine the risk
posed to public hearth or the
environment
Site Inspection (SO: A technical
phase that follows a preliminary
assessment designed to collect
more extensive information on a
hazardous waste site. The infor-
mation is used to score the site
with the Hazard 'Ranking System
(HRS) to see if a response act/on is
needed.
Superfund: The common name
used for the Comprehensive
Environmental Response,
Compensation, and Liability Act
Also referred to as the trust fund.
Superfund Amendments and
Reauthorization Act (SARA): Modifi-
cations to CERCLA, enacted on
October 17, 1986.
Surface Water. Bodies of water
that are above ground, such as
rivers, lakes, and streams.
Treatment, Storage, and Disposal
FacSties (TSDs): Any building,
structure, or installation where a
hazardous substance has been
treated, stored, or disposed. TSO
facilities are regulated by EPA and
States under the Resource Conser-
vation and Recovery Act (ROM).
Trust Fund: A fund set up under
the Superfund Law (CERCLA) to
help pay for the cleanup of
hazardous waste sites and to take legal ,
action to force those who are"
responsible for the sites to clean them
up.
Volatile Organic Compound: an organic
(carbon-containing) compound that
evaporates (volatizes) readily at room
temperature.
Superfund Acronyms
CERCLA Comprehensive Environmental
Response, Compensation, and Liability
Act of 1980.
CR: Community Relations
FS: Feasibility Study
HRS: Hazard Ranking System
NCR: National Oil and Hazardous Sub-
stances Contingency Plan
NPU National Priorities List
OSC: On-Scene Coordinator
O&M: Operations & Maintenance
ppm/ppb: Parts per Million/Pans Per
Billion
PRP: Potentially Responsible Party
PA: Preliminary Assessment
ROD: Record of Decision
RD/RA: Remedial Design/Remedial
Action
Rl: Remedial Investigation
RPM: Remedial Project Manager
SARA: Superfund Amendments and
Reauthorization Act of 1986.
-------
..
APPENDIX E
Index c1 DoamenIs fa' the Adrni. itIb.6e Record FIe.
-------
u.s. T!~ANIUM SIt!
. ADMINISTRATIVE RECORD FILE *'
INDEX OF DOCUMENTS -
! .
SITE IDENTIFICATION
4 )
5)
Report: Water Well Completion ReDort, prepared by
the Division of Mineral Resources, Commonwealth of
Virginia, 9/15/66. P. 100001-100003. -
1)
Letter to Mr. David Olson, American Cyanamid
Company, from Mr. Frank DeLuca, Geraghty & Miller,
Inc., re: Results of river contamination
. investigation, 11/1~/71. Po. 100004-100013. The
following are attached: .
2)
3)
a)
b)
c)
d)
a test-interceptor well locations map:
-the ph value samples results:
an American Cyanamid Company map:
an American Cyanamid Company sampling
stations map. . .
Report: Documentation of Fish Kill Investigation at
the Pine River Plant, prepared by the Commonwealth
of Virginia, 8 31 71. P. 100014-100202. The
following are attached:
a Fish Kill Investigation Report:
a letter requesting payment for the cost
of the fish kill;
a Fish Kill Report including expense
sheets;
three Fish Kill Reports;
a memorandum regarding another fish kill.
Report: Evaluation of Copperas Contamination at the
American CY~id C9mpany Plant ~, prepared by
Geraghty' Miller, Inc., 5/72. P. 100203-100225.
Report: Final Report on Evaluation of Environmental
Pollution Con.!.rol Mf!asures for Copperas Pile Run-
~f, prepared by American Cyanamid Company, 7/27/72.
P:-100226-100240. .
*
Administrative Record File available 1/26/89.
a)
b)
c)
d)
e)
N0t.e: Company and organizational affiliation is identified
in ~he index only when it appears in the file.
. ."-
-------
6)
7)
8 )
9)
10)
11 )
12)
. .
Letter to Mr. D.C.,' P raeger, Virginia State Water
Control Board,' from Mr. J.:'. Hopkins, American
Cyanami~ Company, re: Transmittal of the plan ~=r
abatement of pollution due to run-off, 10/31/72; 2.
100241-100244. .,' '
Letter to Mr. J. F. Hopkins, American Cyanamid,' from'
Mr. Millard Robbins, Bureau of Applied Technology, .
re: Approval of run-off plan in accordance with the
March 12, 1973 memorandum, 4/10/73. P. 100245-
100247. The memorandum regarding the run-off of
waste at the site is attached.
Letter to Mr. Tedd H. Jett from Mr. V~nce Wilkins,
Jr., re: Transmittal of the Application for a State
No-Discharge Certif~cate, 10/21/74'.P. 100248-
100251. The applicatio~ and two site maps are,
attached~ .
Letter to Mr. Fred L. Fox,
Jett, Virginia State Water
of a water well completion
100252-100255. The report
Geonics, from Mr. Tedd
Control, re: Transmittal
report, 1/17/79. P.
is attached.
Letter to Mr. Henry A. Williams, Onited States
Titanium, from Mr. Fred Fox, Geonics, re:
Preliminary Evaluation of Proposed Copperas Disposal
Area, 1/7/79. P. 100256-100257.
Letter to Mr. Tedd H. Jett, Virginia State Water
Control Board, from Mr. Fred Fox, Geonics, re:
Authorization from 0.5. Titanium to have a copy of a
report sent, 2/12/79. P. 100258-1002G9. A letter
regarding logs for five test borings and ten test
hole loqs are attached.
Letter to Mr. Henry A. Williams, 0.5. Titanium, from
Mr. Fred Fox, Geonics, re: Site Evaluation Study
for Proposed Copperas Disposal, 5/1/79. P. 100270-
100273. Two maps of the proposed site are attached.
2
-------
14 )
15 )
16)
17)
18 )
, .
..
13 )
Letter to Mr. Rober: H. Forman, Virgini~ Sta~e
Department of Health, from Mr.. Tedd Jett
Virgin~a Water Con~rol Board, re: Tran~mit~al of
two CoPies of the aoolication by Geonics for a
permit on a proposed-disposal site, 8/5//9. P.
100274-100288. A letter regarding the evaluation of
the proposed copperas disposal site, the site
evaluation form, the application for a permit to
opera~e a solid waste disposal site, a le~ter
regarding the site evaluation study and two si~e
maps are attached.
Letter to Mr.. ~.A. Williams, U.S. Titanium Corp
[sic] from Mr. William F. Gilley, re: Burial waste
material permit, 3/11/80. P. 100289-100298. The
following are attached:. .
..
a)
.a memorandum regarding the copy of the
. permit certificate; .
. a recommendation for the permit to be
issued;
a letter rega~ding the need for monitoring-
wells and fertilizers at the proposed
site; .
a copy of the Application For A Permit to
operate a solid waste disposal system:
a letter regarding the proposed plan of
disposal.
b)
c)
d)
e)
Letter to Mr. John Drew, 0.5. Titanium, from Mr.
Fred Fox, Geonics, re: .Installation of two monitor
wells and excavation of a test cell and burial of
copperas, 5/13/8~. P. 100299-100301. A site map
is attached.
Letter to Mr. John Drew, 0.5. Titanium, from Mr.
Fred Fox, Geoni~s, re: Completion of test cell,
6/2/80. P. 100302-100303.
Letter to Mr. William F. Gilley, Virginia Division
of Solid and Hazardous Waste Management, and Mr.
Robert Forman, Commonwealth of Virginia, from Mr.
Stephen C. Martin, re: Residents' concern of .
copperas burial, 7/25/80. P. 100304-100305.
Letter to Mr. John Drew, Mason, Drew' Dragat, from
Mr. Stephen C. Martin, re: Public concerns for
proper copperas burial, 8/8/80. P. 100306-100308.
3
-------
19)
, .
20)
21)
22 )
. 23)
24)
25)
26)
Lette: to Mr. Fred L. Fox,
Jett,.Virginia State Water
monito~ing at the Coppe:as
P. 100309-100310.
Geonics, from M:. Tedd H.
Control, re:: Routin~ .
burial site, 10/30/80.
Repoit: A Preliminary Assessment of O.S. Titahium,
prepared by Ecology and Environment, Inc., 11/30/80.
P. 100311-100348. .
Msmorandum to File, from Mr. Tedd H. Jett, Virginia
S~ate Water Control Board, re: Summary of the O.S.
Titanium Corporation project, 11/12/80. P. 100349~
100352. ' .
Letter to Mr. John Drew, Mason, Drew., Dragat, from.
Mr. Fred L. Fox, .Geonics; re: Leveling and removal
of Copperas and calculating costs, 11/17/80. P..
100353-100353.
Letter to Mr. Fred L. Fox,
Jett, Virginia State Water
Geonics proposed course of
100354-100357. .
Geonics, from Mr. Tedd H.
Control Board, re:
action, 11/25/80.. P.
Memorandum to Mr. W.F. Gilley, Virginia Department
of Health from Mr. Robert Forman, Virginia
Department of Health, re: Weekly and bi-weekly
inspections, 2/20/81. P. 100358-100361. Two site
maps are attached.
Report: Fish Kill Report/Notification, prepared by
the Virginia State Water Control Board, 5/22/81. P.
100362-100378. The following are attached:
.a)
b)
c)
d)
e)
a memorandum regarding the fish killed;
a Replacement Cost of Fish Summary;
a Total Cost Summary;
a laboratory costs form;
a memorandum regarding the fish
kill complaint;
a summary of fish;
four area maps;
a statement on the fish kill;
four expense reports.
f)
g)
h)
i)
Report: Fish Kill Report/Notification, prepared by
the Virginla State Water Contror-Board, 6/23/81. P.
100379-100397.
4
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27)
28)
29)
30)
31 )
32 )
33)
I .
Report: Field Trio Summary Reoort, prepared by U.S.
EPA, 7/81. P. 100398-100408. "A Preliminary
Assessment is at:tached. "
Memorandum to Mr. Walter Gulevich, Virginia
Department of Health, from Mr. Robert H. Forma~,
Virginia Department of Health, ore: Investigat:ion
Leachate problems, 9/9/81. P. 100409-100409,
of
Letter to Mr. R. Bradley Chewning, Virginia State
Water Control Board, from Mr. Robert Murphy, Nelson
County Board of Supervisors, re: Resolution by
Nelson County urging proper action maintenance of
Copperas burial site, 11/13/81. P. 100410-100412",
The resolution is attached. "
Letter to Mr. Robert M. Murphy, Nelson County Board
of Supervisors, from Mr. Tedd H. Jett, Virginia"
State Water Control Board, re: Results of well
monitoring, 12/16/81. P. 100413-100421. The
following are attached:
a) a map of the site showing monitoring
wells;
b) the chemical analysis reports for well 11,
5, 6A, 7A;
c) the chemical analysis reports for Piney
River 11 and '2.
Report: Proposal for Establishing an Vegative Cover
Critical Eroding Area, prepared by U.S.D.A. [sic]
Soil Conservation Service, 3/82. P. 100422-100426.
Letter to Mr. Tedd H. Jett, from Mr. Mark H.
Kroeniq, Envirodyne Enqineers~ re: Transmittal of a
paper on scientific methods in industrial waste
disposal projects, 5/13/82. P. 100427-100449. The
paper is attached.
Letter to Mr. Ted [sic] Jett, Virqinia Water Control
Board, from Hr. Gerald D. McCart, Virginia
Cooperative Extension Service, re: Recommendations
based on sludqe analysis, 5/19/82. P. 100450- .
100453. The sample analysis results are attached.
5
:.....
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.~ ---
36)
37 )
38 )
I .
34)
Letter to Mr. Ted [sic] Jett, Virginia 'Water Con~=o~
Board, ~rom Mr. G.C. McCart, Virginia Cooperati~e
Extension Service, re: Transmit~al of soil test
results, 5/26/82. P. 200454-100457. The Soil Test'
Reports for Samples HST 1, HST 2, HST 3, HST 4,
H5T 5, H5T 6, HST 7, HST 8, HST 9, HST 10, HST' 11,
H5T 12, and H5T 13 are attached.
35)
Memorandum to Mr. Howard Wilson, 0.5. EPA, f=om Mr.
H. Ronald Peterson, 0.5. EPA, re:Transmittal of
the results of metal analyses, 8/23/82. P. 1D0458-
100471. The followin~ are attached:
a)
b)
c)
d)
e)
a Chain of Custody Record:
a Federal Express receipt:,
a Routing 'and Transmittal Slip:
a sample tag: '
the Analysis Request and Result Forms for
- Sample Numbers 05T-W2, OST-W5, OST-W6,
05T-W8, OST-R2, 05T-R1, 05T-L1, OST-W7,
and 05T Blank: W8.
Memorandum to Mr. Ron Preston, 0.5. EPA, from Mr.
Howard Wilson, 0.5. EPA, re: Request for metals
analyses of two sediment samples, 8/25/82. P.
100472-100477. The following are attached:
a)
the Analysis Request and Result Forms for
5amples 05T-55 and 05T-53:
a memorandum regarding the transmittal of
sample metals analysis results:
the Analysis Request and Result Forms for
5ample$ 05T-5-3 and 05T S-5.
b)
c)
0.5. EPA Site Inspection Report, 8/25/82.
100478-100487.
P .
Letter to Mr. Frank J. Quirus, Ecology' "
Environment, Inc., from Mr. K. R. Hinkle, Virginia
State Water Control Board, re: Transmittal of
information on depth to bedrock at the 0.5. Titanium
Site, 8/22. P. 100488-100490. The monitoring well
'data is attached.
6
-------
39)
Memorandum to ~s. Janet E. Roberson, U.5. EPA, from
Mr.. H. Ronald Preston, U.5. EPA, re: Transmitta} c:
the res~lts of metals analyses, 9/8/82. P. .100491-
100506. The following are attached:
a)
a letter regarding request for additional
quantitative metals analyses;
the Analysis Request and Result Forms for
5ample Numbers U5T-55, U5T-53, U5T-5-3,
U5T-5-S, U5T-W2, U5T-WS, U5T-W6, UST-W8,
U5T-R2, U5T-R1, U5T-L1, U5T-L2, U5T-W7,
and UST Blank: W8.
b)
40)
Memorandum to File from Mr. Howard O. Wilson, U.5.
EPA, re:Lagoon sediment samples, ~/23/82. P.
100S07-100512. A Case History-Land Application/
Treatment of Residue Produced in the manufactureot
. Titanium Dioxide is attached.
41 )
Handwritten cover page re: Sample Traffic Reports,
11/10/82. P. 100513-100534. The Inorganics Traffic
Reports for Sample Numbers MC 9630, MC 9631, MC .
9632, MC 9633, MC 9634, .MC 9635, MC 9446, MC 9648,
MC 9649, MC 9650, MC 9651, MC 9652, MC 9653, MC
9654, MC 9655, MC 9656, MC 9657, MC 9658, and MC
9662 and two Chain of Custody Records are attached.
Report: ~O~igg Logs, (no author cited), 11/16/82.
P. 10053 -10 541.
42)
43)
Report: Site Inspection Report: U.S. Titanium
Property, Piney ~iver, Virginia, prepared by Mr. .
Howard O. Wilson, Mr. GeorgeH. Houghton, and Mr.
Eric Johnson, O.S. EPA, 11/19/82. P. 100542~100S76.
44 )
Handwritten site diagram, 0.5. Titanium Site, piney
River, Virginia, 11/29/82. P. 100577-100712. The
following are attached:
a)
b)
c)
a Monitoring Well Physical Data Table;
the results of groundwater sampling;
the graphical representations of
groundwater quality results;
a table showing ph versus Depth of hand
Auqering;
an analysis of sedimentation pond
material;
a boring loq;
d)
e)
f)
7
. ....)
-------
45)
46)
'.
47)
48)
g)
h) ,
i)
j)
k)
an analysis of leachates and auger hole
water; "
the soil testing results;
the effluent analysis from permeability
. testing; .
the site drainage and Piney River water
ctuali ty data;
a graphical representation of
neutralization requirements for selected
soil samples. . .
Report: Interim Report for 0.5. Titanium, prepared
by Mr. Douglas Taylor,and Mr. Joseph G. McGovern,
Ecology and Environment, Inc., 12/10/82. P. 100713~
100825. .
Letter to Dr. Malcolm Tenney, Jr., from Mr. R.
Bradley Chewning, Virginia State Water Control
Board, re: Transmittal of the dr~ft Site Inspection
Report for the 0.5. Titanium Site, 1/4/83. P. .
100826-100861. A letter regarding the draft Site
Inspection Report and the report are attached.
Pesticide Analysis Data, 2/12/83.
Report: Case Summar Qualit
prepared by WCTS, Inc., 4
The following are attached:
a)
b)
c)
d)
e)
f)
g)
h)
i)
j)
k)
P. 100862-100882.
a Chain of Custody Record:
three quality control reports:
a case review quality control reports
summary of outliers;
a cross reference table:
a volatile internal standard areas sheet;
a semivolatile internal standard areas
sheet;
a GC screen data sheet; .
the quality control reports for Sample
Numbers: C2737, C2737MS, C2737MSD, C2745,
C2745MS, C2745MSD, C2746, and C2747 M.B.:
the organics analysis data sheets for
blank samples;
the volatile initial calibration data:
an I.T. Analytical Servi~es Quantitation
Report for Sample: 50 UG/L 6582 VOA
Screening Standard;
8
,""--..c.
-------
. u)
v)
1)
an I.T. Analytical Services Quanti~at~on
Report for Sample: 25 UG/L 6582 VOA
Screening Standard; .. .
an I.T. Analytical Services Quantitation
Report for Sample: 2000 UG/L 6582 VOA
Screening Standard; .
a mass list and mass spectrum for sample
number '50 NG BFB;
a VOA calibration check compounds sheet;
two VOA standard check forms;
anI.T. Analytical Services Quantitation
Report, Sample: 50 UG/L 6582 VOA
Screening St~ndard;
a FSCC Initial Calibration Data;
a GC/MS Performance Standard;
a mass ch~omatograms, mass spectrums, and
mass list for Sample: Fused silica
. selectivity:
. a Quantitation Report for Sample: 50
UG/ML 6582B/N/A/P Screening Standard:
a Quantitation Report for Sample: 25 .
UG/ML 6582 BIN/AlP Screening Standard:
a Quantitation Report for Sample: roo
UG/ML 6582 BIN/AlP Screening Standard:
a Quantitation Report for Sample: 200
UG/ML 6582 BNA Screening Standard:
a Quantitation Report for Sample: 200
UG/ML 6582 HAZ-P-B(K)FL Screening
Standard:
a GC /MS Performance Standard:
a mass chromatograms, mass spectrums, and
mass list for sample: Fused silica
selectivity:
a Quantitation Report for Sample: 50
UG/ML 6582 BiNIAIP Screening Standard;
eight I.T. Analytical Services
Quantitation Reports for Sample Numbers
Lab Blank, C2737, C2737 Matrix Spike,
C2737 Duplicate Spike,C2745, C2746 (1:10
Dilution), C2747, and C2747 (1:100
Dilution) :
seven Quantitation Reports for Sample
Numbers Method Blank, C2737, C2745,. C2745
Matrix Spike, C2745 Duplicate Spike,
C2746, and C2747;
a Capillary Pesticides Data.
mf
n)
0)
p)
q)
.r)
s)
t)
w)
x)
y)
z)
aa)
bb)
cc)
dd)
ee)
9
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49)
'50)
51 )
52)
.,53)
54)
55 )
I I
WCTS Sample Log-in Sheet-Waters for Sample Numbe=s
C2737, C~745, C2746, and C2747: 2/25/83.- P. 101212-
101217: A description of laboratory proced~res is
attached. ..
GC Screen Data Sheet for Samples MB, C2737, C2745,
C2746, and C2747, 2/26/83. P. 101218-101230. Test
results of BNA screens are attached.
TCDD Raw Data Summary Sheet for Sample Numbers
STANDARD, METHOD BLANK, C2737, C2737MS, C2737MSD,
C2745, C2746, ~nd C274],3/20/83. P. 101231-101247.
A mid mass chromatograms and a mid mas~ spec~rums
are attached. .
Report: Biological Monltoring Report, (no author
cited), Virginia, 6/6/83. P. 101248-101260. A .
Draft Statement of Work for the Supplemental
Remedial .Investigation is attached.
Report: Site Inspection of U.S. Titanium, prepared
by NUS Corporation, 7/27/83. P. 101261-101325.
References are listed on P. 101324.
of U.S.
NUS
Sample Data Summary: Target Compounds, Inorganic,
for Sample Numbers MC-1653, MC-1654, MC-1655, MC-
1656, MC-1657, MC-1658, MC-1659, MC-1660, MC-1661,
MC-1662, MC-1663, and MC-1664, 11/9/83. P. 10135.8-
101404. The following are attached:
a)
a Sample Data Summary: Target Compounds,
Organic, for Sample Numbers C3409, C3410,
C3411, C3412, C3413, C3414, C3415, C3416,
C3417, C3418, C3419, and C3420;
Organic Analysis Data Sheets for Sample
Numbers C3409, C3410, C3411, C3412, C3413,
C3414, C3415, C3416, C3417, C3418, C3419,
and C3420;. .
Quality Assurance Notices for Samples
C3409, C3410, and C3420;
Inorqanics Analysis Data Sheets
Samples MC1653, MC1654, MC1655,
MC1657, HC1658, HC1659, MC1660,
MC1662, MC1663, and MC1664.
b)
c)
d)
for
HC1656,
MC1661,
10
-------
58)
59)
60)
56)
Report: A Study of The u.5~ Titanium Site in Nelsen
County, Virginia, prepared by.. Virginia Polytechn-i.c
Insti~ute & State University, 3/84. P. 101405-.
101438. References are listed on P. 101415.
57)
Report: Evaluation of The Hazardous- Waste Site at
The U.S. Titanium Plant in Piney River, prepared by
Mark S. Morris, Virginia Polytechnic Institute and
State University, 7/84. P. 101439-101618.
References are listed on P. 101521~
Memorandum to Mr. Daniel K. Donnelly, U.S. EPA, from
Mr. Kirby K.F. Worthington, U.S. EPA, re: .
Transmittal of the results of energy dispersive X-
ray fluorescence scans of samples,- 8/16/84~ P.
101619-101643. The-following are attached:
a)
a memorandum regarding testing of samples
- for pesticides and/or PCBs;
the Analysis Request and Result Forms for
Sample Numbers U5T-W8,UST-51, U5T-52,
U5T-R1, U5T-~2, U5T-01, U5T-53, U5T-54,
UST-W5, UST-S6, UST-W2, UST-W6, UST-S5,
UST-L2, UST-R01, and UST-W7;
three James River Basin Forms;
a Piney River Data Form;
b)
c)
d)
Letter to Mr. Don Neal, GCA Inc., from Mr. Tedd H.
Jett, Virginia State Water Control Board, re:
Background flow and water quality data, 8/28/84.
101644-101650. The following are attached:
P .
.
a gage records for water years 1981-1983;
a letter regarding transmitta~ of the
results of a cursory benthic survey;
two biological monitoring reports of the
Piney River in Virginia.
Letter to Mr. Don Neal, GCA Inc., from Mr. Tedd H.
Jett, Virginia State Water Control Board, re:
T~ansmittal of a qualitative biological survey
report for the Piney River, 9/27/84. P. 101651-
101663. The report is attached.
a)
b)
c)
11
.:..,
-------
61)
62)
63)
64)
65)
66)
67)
. .
Letter to Ms. Carol Stokes, U~S. SPA, "from Mr. ~edd
H. Jet~, Virginia Stace Watei Cancrol ~oard, ":i: "
Transmittal of two Masters Theses written "at
Virginia Polytechnic Institute," 10/25/!4. P.
101664-101797. The Thesis ~f Ms. Jaleh Moslehi is
attached. ~eferences are listed on P. 101794~
101796.
Memorandum to Mr. R.F. Tesh, from Mr. R.W. Bolgiano,
Virginia State Water Control Board, re: A cursory
benthic survey conducted on the Piney River,"
6/27/85. P. 101798-1p1809. The Qualitative Benthic
Survey, Piney River, Nelson County, James River
Basin is attached. "
Letter to Mr. James M. Seif, U.S. EPA, from Mr."W.R.
Meyer, Virginia State Air Pollution Control Board, "
re: Request for an EPAField Investigation Team at
the U.S~ Titanium Site, 10/10/85. P. 101810-101815.
The following are attached: "
a)
a letter regarding transmittal of sample'
analytical results; "
the analytical results for samples
collected at Piney River Plant Site;
a handwritten site diagram.
b)
c)
Report: A Field Trip Report for the U.S. Titanium
Corporation, Draft, prepared by NUS Corporation,
2/19/86. P. 101816-102166.
Report: Review of Proposed Environmental Protection
Agency (EPA) Stuay of the U.S. Titanium Site, Nelson
County, Virginia, prepared by the U.S. Geological
Survey, (undated). P. 102167-102173. References
are listed on P. 102173. "
Assorted handwritten notes on the U.S. Titanium
Site, (undated). P. 102174-102177. "
Inventory Sheet of U.S. Titanium, (undated).
102178-102220. The following are attached:
P.
a)
b)
a Technical Direction Document;
a Technical Direction Document with a
record of telephone call attached;
a Dumpsite Summary Sheet;
c)
12
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,
I .
I
.e)
d)
the handwritten not~s regarding site
burial work;
a Preliminary Assessment of U.'S. Titanium.'.
6 a)
Inventory Sheet of u.S. Titanium, (undated).
102221-102401. The following are attached:
P.
five Technical Direction.Documents;
a handwritten sampling plan for drill~ng
activities; .
a Site Safety Plan for a site visit;
a Site Sa'fety Plan for well drilling and
sampling; .
an equipm~nt list;
the boring logs for boring numbers 8-1, 2,
. 3, 8-4, and 8-5;
h) . a Federal Express receipt;
i) the Inorganics Traffic Reports for Sample
Numbers MC 9446, MC 9630, MC 9631, MC .
9632 , MC9 633, MC 9634, MC 9635, MC 9648, -
MC 9649, MC 9650, MC 9651, MC 9652, MC
9653, MC 9654, MC 9655, MC 9656, MC 9657,
MC 9658, and MC 9662;
two Chain of Custody Records;
a Regional Internal Distribution List;
a letter regarding the transmittal of
subcontract documents;
an Agreement between Ecology and
Environment, Inc. and Girdler foundation &
Exploration Company;
a memorandum regarding verification of an
attached invoice; .
an invoice from Girdler foundation &
Exploration Co. for monitoring well
installation;
a memorandum regarding EPA subcontract
approval; .
a Request for FIT subcontract approval;
a memorandum regarding the selection of a
dr.illing subcontractor;
a memorandum regarding the selection and
recommendation of a subcontractor;
a Regional Internal Distribution List;
a memorandum regarding the selection of a
subcontractor and changes in the Scope of
Work; .
a memorandum regarding changes in the
Scope of Work;
a)
b)
c)
d)
f)
g)
j)
k)
1)
m)
n)
0)
p)
q)
r)
s)
.t)
u)
v)
, .
13
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a letter regarding the transmittal of tes~
borings logs;
five Test Hole Logs; .
a letter regarding additional monitoring
wells; .
a letter regarding the diameter of the
proposed monitoring wells;
aa) a letter regarding additional information
on existing wells;
bb) a letter regarding funding and
specifications of the monitoring wells;
a map of the Piney River, .V~rginia, area;
a handwritten site sketch;
a letter regarding the transmittal of
background information;
ff) the physical data for monitoring wells;
gg) -the soi1 sampling data;
hh) the ground water monitoring data;
ii) two letters regarding the transmittal of
monitoring well information;
jj) a price quotation sheet from Falwell Well
Corporation;
kk) a site map;
11) a letter regarding a site evaluation study
of the proposed copperas disposal;
a map of the Piney River, Virginia, area;
a handwritten site sketch;
a letter regarding the preliminary
evaluation of the proposed copperas
disposal area;
five site sketches;
handwritten field notes;
a map of flood prone areas near Piney
River;
ss) a Chain of Custody Record;
tt) a request from Regional FIT for NPMO/EPA
approval;
uu) a memorandum regarding the transmittal of
data on the proposed subcontract;
vv) a memorandum reqardinq the transmittal of
four Technical Direction Documents.
w)
x)
y)
z)
cc)
dd)
ee)
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nn)
00)
pp)
qq)
rr)
, '
14
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I .
II.
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5 )
6)
7)
8)
9)
10)
REMEDIAL ENFORCEMENT PLANNING
1)
Chart": Acid Recovery Plant Production Calculati6ns
Based on Analysis of Grab Samples, prepared by'Mr.
Stephen A. Lamanna, 2/5/48. P. 200001-200001.
2 )
~eport: Acid Recovery Pilot Plant, prepared by Mr.
Stephen A. Lamanna, 3/14/49. P. 200002-200038.
3 )
Memorandum to Mr. J.F.' Hopkins, American Cyanamid
Company, from Mr. Stephen A. Lamanna, re: "
Production cost estimate, Hydrated-Yellow Iron Oxide
"Hyferox", 1/26/65. P. 200039-200045. The
Production and Cost "Report are attached.
Letter to Mr. E". Hladky from Mr. Stephen A. Lamanna,"
re: Piney River Copperas-Acid Recovery, 8/23/67.
P. 200046-200047. -
4 )
Memorandum to Mr. J.F. Hopkins, Piney River Office,
from Mr. Stephen A. Lamanna, re: Waste acid
recovery, 8/20/68. P. 200048-200051. Two flow
charts are attached.
Report: End Liquor Concentration Acid Recovery
Operating Procedure Volume XI, prepared by Mr.
Stephen A. Lamanna, Plant Chemical Enqineer,
American Cyanamid Company, 3/69.P. 200052-200079.
Memorandum to Mr. John B. Baer from Mr. Stephen A.
Lamanna, re: Production of copperas, 5/8/69.P.
200080-200081. ~ Copperas Table is attached.
Memorandum to Mr.J.F. Hopkins, from Mr". Stephen A.
Lamanna, re: Waste acid recovery Savannah Plant,
10/2/69. P. 200082-200086. The technical details,
an end liquor (waste acid) analysis, and a flow
chart for the Savannah Plant are attached.
Memorandum to Mr. S.A. Lamanna, Piney River Office,
trom Mr. Richard L. Bennett, re: Dilution of 98'
~SO. with recovered Acid to form 93' Acid, 1/9/70.
P. 200087-200088. A flow chart of the dilution
process is attached.
Memorandum to Mr. S.A. Lamanna, Piney River Plant, from
Mr. Richard L. Bennett American Cyanamid Company, re:
Waste Acid Recovery Plant, 3/20/70. P. 200089-200090.
A flow chart ot a proposed pilot plant is attached.
15
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11 )
12 )
13 )
14 )
15 )
16)
17)
18 )
19)
. .
- . ~ . .
Letter to Mr. J.J. Fitzgerald from Mr. J.F. Hopki~s,.
re: Waste Acid Recovery and Neutralization,
4/29/70. P. 200091-200096. A comp~rison of capital
costs and profit or loss for alternatives at the
Piney River Plant is attached.
Memorandum to Mr. J.F. Hopkins from Mr. Stephen A.
Lamanna, re: Waste Acid Neutralization, 7/28/70.
P. 200097-200098. A flow chart of a design Of a
was~eacid neutralizat~on plant is attached.
Memorandum to Mr. J. Smodish, Mr ~ .F. J. Stamm, and
Mr. J.S.' Saer from Mr. Stephen A. Lamanna, re:
Copperas analysi~, 9/10/70. P. 200099-200099.
Memorandum to Mr. Fred Stamm from Mr. Stephen A.
Lamanna,-re: Copperas Solution, 4/22/71. P. .
200100-200102. A Specific Gravity - F~S04 chart and
a handwritten table are attached.
Map:
Copperas Dump Contour Map.
,
P. 200103-200103.
Memorandum to Mr. J.F. Hopkins, Piney River Office,
from Mr. Stephen A. Lamanna, re: Copperas "Dump", ,
4/29/71. P. 200104-200107. A drill sample analysis
table, an X-ray diffraction analysis table, and a
contour map are attached.
Letter to Mr. J.F. Hopkins, from Mr. W.R. Whately,
re: Copperas Pile Effluent, 3/9/72. P. 200108-
200108.
Memorandum to Mr: V.P. Langone, American Cyanamid
. Company, from Mr. R.N. Kelly, American Cyanamid
Company re: Copperas Status Report and a September
9, 1972 phone request, 8/17/72. P. 200109-200111.
A letter regarding a phone conversation on dry
copperas is attached.
Letter to Mr. Jim Heenehan, U.S. EPA, from Ms. Marie
C. Shultie, Delaware Department of State, re:
United States Titanium Company, 6/~/82. P. 200112-
200113. A list of officers, directors, and
registered agents is attached.
16
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20 )
21 )
22 )
23)
24)
25 )
26)
27)
. .
Letter, to Mr. Edward R. Parker, American Cyanamid'
Company, from Mr. Thomas C. Voltaggio, 0.5. EPA, re:
Request for all documents relating to wastes
generate~ by American Cyanamid Company, 1/7/83! ~.
200114-200117. Two certified mail receipts are
attached.
Letter to Mr. Ronald penque from Mr. Thomas C.
Voltaggio, 0.5. EPA, re: Request of all documents
relating to wastes gen~rated by American Cyanamid
Company, 1/7/83. P. 200118-200121. Two certified
mail receipts are attached.
Letter to Mr. Paul Turner, Christian, Barton, Epps,
Bunt and Chappell, from Mr. Thomas C. Voltaggio,.
U.5. EPA~ re: Request for all documents relating' to
waste generated by American Cyanamid Company,
1/7/83. P. 200122-200125. Two certified mail
receipts are attached.
.
Letter to Mr. 5. Vance Wilkens from Mr. Thomas C.
Voltaggio, 0.5. EPA, re: Request for all documents
relating to wastes generated by American Cyanamid
Company, 1/7/83. P. 200126-200129. Two certified
mail receipts are attached.
Letter to Mr. Henry A. Williams, II from Mr. Thomas
C. Voltaggio, U.5. EPA, re: Request for all
documents relating to wastes generated by American
Cyanamid Company, 1/7/83. P. 200130-200133. Two
certified mail receipts are attached. .
Letter to Mr. James Heenehan, U.S. EPA, from Mr.
Paul G. Turner, re: United States Titanium
Corporation Request for Documents, 1/20/83. P.
200134-200136. An envelope is attached.
Letter to Mr. James Heenehan, U.S. EPA, from Ms.
Margaret R. Tribble, American Cyanamid Company, re:
Virginia Request fo'r Documents, 3/2/83. P. 200137-
200137.
Letter to Mr. James Heenehan, U.S. EPA, from Ms.
Margaret R. Tribble, American Cyanamid Company, re:
Virginia Request for Documents, 3/2/83. P. 200138-
200138. .
17
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28)
29)
30 )
31 )
32)
33 )
34 )
35)
I .
Letter!t6 Mr. Russell H. Wyer, U.S. EPA, fiom Ms.
Margeret R. Tribble, American Cyanamid Company, =e: '
Virginia Amendment to National Contingency Plan,
3/7/83. P. 200139-200149. A monitoring well
analysis, a monitoring well analytical variability
table, and a mitre model groundwater worksheet are
attached.
Letter to Mr. Paul Turner, Christian, Barton, Epps,
Bunt and Chappell, frqm Mr. Stephen R. Wassersug,
U.S. EPA, re: Notification of action which EPA
believes should be performed at U.S. Titanium Site,
7/1/83. P. 200150-200154. Two cert~fied mail
receipts are attached. .
Letter to Mr. Ronald penque from Mr. Stephen R.
Wassersuq, U.S. EPA, re: Notice of Corrective
Action needed at U.S. Titanium Site, 7/5/83. P.'
200155-200159. Two certified mail receipts are
attached. .
Letter to MI. S. Vance Wilkens from Mr. Stephen R.
Wassersug, U.S. EPA, re: Notice of Corrective
Action needed at U.S. Titanium Site, 7/5/83. P.
200160-200164. Two certified mail receipts are
attached. '
Letter to MI. Henry A. Williams, III, penque-
Williams, Inc., from Mr. Stephen R. Wassersug, U.S.
EPA, re: Notice of corrective action needed at U.S.
Titanium Site, 7/5/83. P. 200165-200169. Two
certified mail r~ceipts are attached.
Letter to MI. Edward R. Parker, American Cyanamid
Company, 'from Mr. Stephen R. Wassersuq, 0.5. EPA,
re: Notice of Corrective Action needed at U.S.
Titanium Site, 7/7/83. P. 200170-200174. Two
certified mail receipts are attached.
Letter to Mr. Eric W. Johnson, U.S. EPA, from Mr.
Henry A. Williams, III, re: Penque-Williams .
interest in U.S. Titanium Site, 7/9/83. P. 200175-
200175. .
Letter to Mr. Eric W. Johnson, U.S. EPA, from Mr.
Paul G. Turner, Christian, Barton, Epps Bunt and
Chappell, re: United States Titanium Site in Nelson
and Amherst Counties, Virqinia, 7/26/83. P. 200176-
200178. An envelope is attached.
18
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40)
41)
42)
. .
36)
Letter'to' Mr. Eric W. Johnson, U.S. EPA, from Mr.
Robert C. Wood, II!, Edmunds & ,WilliamS,re: s.
Vance Wilken's liability with regard to U.S.
Titanium Site, 7/29/83. P. 200179-200180.
37)
Letter to Mr. Eric W. 'Johnson, U. S. EPA, from Ms.
Margaret R. Tribble, American Cyanamid Company, re:
Correctiv.e action at U.S. Titanium Site, Piney
River, Virginia, 8/3/83. P. 20018,1-200181. '
,
38)
Letter to Mr. Robert E. Desmond from Mr. Stephen R.
Wassersug, U.S. EPA, re: Potentially responsible
party for release ~r threatened release of hazardous
substances at U~S. Titanium Site, 10/4/85. P.,
200182-200186. Two certified mail receipts are
attached..
Letter to Mr. Barry L. Malter', Holland & Knight,
from Mr. Stephen R. Wa,~sersug, U. S. EPA, re:
Potential responsible party for release or
threatened release or threatened release of
hazardous substances at U.S. Titanium Site, 10/4/85.
P. 200187-200191. Two certified mail receipts are
attached. .
39)
Letter to Mr. Ronald penque from Mr. Stephen R.
Wassersug, U.S. EPA, re: Potential responsible
party for release or threatened release of hazardous
substances at U.S. Titanium Site, 10/4/85. P.
200192-200196. Two certified mail receipts are
attached. .
Letter to Mr. Paul Turner, Christian, Barton, Epps,
Bunt and Chappell, from Mr. Stephen R. Wassersug,
U.S~ EPA, re: Clients are potential responsible
parties for release or threatened release of
hazardous substances at U.S. Titanium Site, 10/4/85.
Ie 200197-200201. Two certified mail receipts are
attached.
Letter to Mr. S. Vance Wilkens from Mr. Stephen R.
Wassersuq, u.S. EPA, re: Potential responsible
party for release or threatened release of hazardous
substance at U.S. Titanium Site, 10/4/85. P.
200202-200206. Two certified mail receipts are
'attached.
19
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43)
44)
45 )
46)
47)
48 )
49)
50 )
51)
52)
53)
I'
Letter! to ~r. Henry A. Williams, III, penque-
Williams, Inc., from Mr. Stephen R. Wassersug, u~s.
EPA, re: . Potential responsibl~ party for rel~ase or .
threatened release of hazardous substance at U.S.
Titanium Site, 10/4/85. P. 200207 -200211. Two
certified mail receipts are attached.
Letter to Mr. Robert E. Desmond from Mr. James
Heenehan, U.S.. EPA, re: Postponement of PRP.
meeting, 10/11/85. P.' 200212-200212. .
Letter to Mr. Ronald penque from M~. James Heenehan,
U.S. EPA, re: Postponement. of PRP meeting, . .
10/11/85~ P. 200213-200213.
Letter to Mr. S. Vance Wilkens from Mr. James
Heenehan; u.S. EPA, re: Postponement of PRP
meeting, 10/11/85. P. 200214-200214. .
Letter to Mr. Robert WOod, Evans' Williams, from
Mr. James Heenehan, U.S. EPA, re: Postponement of
PRP meeting, 10/11/85. . P. 200215-200215.
Letter to Mr. Barry L. Malter, Holland' Knight,
from Mr. James Heenehan, U.S. EPA, re: Postponement.
of PRP meeting, 10/11/85. P. 200216~200216.
Letter to Mr. Paul Turne~, Christian, Barton, Epps,
Bunt and Chappell, from Mr. James Heenehan, U.S.
EPA, re: Postponement of PRP meeting, 10/11/85. P.
200217-200217.
Letter to Mr. He1'1ry A.. Williams, III, penque-
Williams, Inc., from Mr. James Heenehan, U.S. EPA,
re: postponement of PRP meeting, 10/11/85. P.
200218-200218.
Flow Chart:
(undated) .
Chart: Solubility of FeSO in Water and Acid~
Solubility of FeCL, in Water, (unda~ed). ~. 00220-
~.
2 Sta e,
Letter to Hr. Thomas C. Voltaqqio, U.S. EPA, from
Mr. Henry A. Williams, III, re: Documents
pertaininq to U.S. Titanium Site, (undated). P.
200221-200221.
20
-------
54 )
55 )
56)
57)
58 )
I .
Letter. to Mr. Eric W. Johnson, U.S. EPA, from Mr.
John Butcher, Commonwealth of Virginia, .re:
Transmittal of data generated in U.S. Titanium Site,
2/29/84. P. 200222-200353. The following are.
attached: .
a)
b)
the results of the Groundwater Sampling;
a graphical Representation of Groundwater
Quality Results;
the data of ph versus Depth of Hand.
Augering;
the Analysis of Sedimentation Pond
Material;
fifteen borinqlogs;
. the an~lysis of leachates and Auger Hate
. Water;
-the soil testing results;
the Effluent Analysis from Permeability
Testing; . .
the site drainage and Piney River Water
Quality Data;
the Neutralization Requirements for
Selected Soil Samples; .
Letter to Mr. James T. Heenehan, 0.5. EPA and Mr.
John R. Butcher, Commonwealth of Virginia, from Mr.
Barry Malter, Breed, Abbott & Morgan, re: Comments
on the Focused Feasibility Study, 12/16/85. P.
200354-200357.
c)
d)
e)
f)
q)
h)
i)
j )
Letter to Mr. Barry Malter, Breed, Abbott & Morgan,
from Mr. John Butcher, Commonwealth of Virginia, re:
Response and comments to the December 6, 1985 letter
of Mr. James Heenehan, 12/19/85. P. 200358-200360.
Letter-to Mr. Jerome Muys, Breed, Abbott & Morgan,
from Mr. John Butcher, Commonwealth of Virginia, re:
Draft Statement of Work for the measures that
American Cyanamid Company proposes, 2/27/86. P.
200361-200365. A cover sheet and a letter regarding
comments on the Draft statements of work are
attached.
Letter to Mr. John Butcher, Assistant Attorney
General, from Mr. John Novak, Virginia Polytechnic
Institute and State University, re: Curren~ Study
of Water at Piney River, 2/26/86. P. 200366-200367.
The sampling data is attached.
21
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59)
60 )
61 )
62)
63)
64)
; .
Stipura~ion and Order In "The Matter of Viiginia for
Commonwealth of Virginia v. United States Titanium"
Corporation, 5/9/86. P. 200368-200377.
Letter to Mr. Philip Koren, Commonwealth of
Virginia, from Mr. Jerome Muys,/Swidler & Berlin,
re: Hydrosystem's submittal of addendum to the
Feasibility Study, 7/17/89. P. 200378-200379.
Letter to Dr. Tim Lonqe, Virginia Department of
Waste Management, from Mr. Jeffrey Sitler, .
Hydrosystems, Inc., re: Transmittal of Addendum to
the Feasibility Study, 7/18/89. P.200380-200392.
The Addendum is "attached. .
Letter to Mr. Jon Horin, Virginia Department of
Waste Management, from Mr. Thomas Voltaggio, U.S.
EPA, re: Preferred Alternatives of the Proposed
Plan, 7/24/89. P. 200393-200394.
Trial Memorandum In The Matter of Commonwealth of
Virginia v. United States Titanium, (undated). P.
200395-200443.
Bill of Complaint In The Matter of Commonwealth of
Virginia, vs. United States Titanium Corporation,
American Cyanamid Company, Penque-Williams, Inc.,
(undated). P. 200444-200453.
22
-------
II:. REMEDIAL RESPONSE PLANNING
1)
Repo7t: Evaluation of Ferrous Sulfate Disposal Site
at P~ney River, Virginia, prepared by Mr. John T.
Novak, Virginia Polytechnic Institute and State
University, 12/29/82. P. 300001-300028.
2 )
Report: Remedial Action Master Plan, U.S. Titanium
Site, Nelson and Amherst Counties, Virginia, "
prepared by NUS Corporation, 8/83. P. 300029-
300175. References are listed on P. 300117-300128.
3 )
Letter to Mr. Gene Lucero, 0.5. EPA,from Mr. Bruce
Blanchard, U.S. Departmerit of the Interior, re:"
Preliminary natural resources survey of the U.S. " ..
Titanium.Site, 1/4/84. P. 300176-300176.
4 )
Memorandum to Mr. Pablo Huidoboro, Mr. Robert Hall,
Mr. Michael Jazinski, a~d Mr. Steve Konieczny from -
Mr. David Coglay, re: Leachate from Ferrous Sulfate
Waste Piles, 1/29/85. P. 300177-300178.
5)
"Report: Addendum to the Endangerment Assessment/
Feasibilit Stud: U.S. Titanium Site, Pine River,
Virginia, prepared by GCA Corporation, 9 5. P. .
300179-300255. References are listed on P. 300246.
6)
Letter to Ms. Carol E. Stokes, U.S. EPA, from Mr.
Robert C. Wood, III, Edmunds' Williams, re: u.S.
Titanium Site meeting of October 30, 1985, 10/23/85.
P. 300256-300257. An envelope is attached.
Report: Focused.Feasibility Study for the U.S.
Titanium Site, prepared by PRC Engineering,
~ 300258-300269."
7)
8)
Letter to Ma. Carol Stokes, U.S. EPA, from Mr. Barry
L. Malter, Holland' Knight, re: Comments of
American Cyanamid Company on the Endangerment
Assessment/Feasibility Study, 11/26/85. P. 300270-
300280.
9)
23
-------
10)
11 )
12)
13 )
14 )
15)
16)
17 )
. .
..
Letter to Mr. James T. Heenehan, .U.5. EPA, and Mr.
John R. Butcher, Commonwealth of Virginia, from Mr.
Lyle R. Silka, Hydrosys~ems Inc., re: Pioposed
locations for additional monitoring wells, 1/13/86.
P. 300308-300313. .
Letter to Mr. Joel Jerome, American Cyanamid
Company, from Ms. Carol Stokes, U.5. EPA, re: .
Comments on American Cyanamid's site proposed,
1/22/86. P. 300314-300315. .
Report: ghed~le for.Additiona~ies at the U.5.
Titanium Site in Piney River, Virginia, f728/86. P.
300316-300318. .
Letter to Mr. John R. Butcher, Commonwealth of
. Virginia, - from Mr. Jerome C. Muys, Jr., Breed, .
Abbott & Morgan, re: American Cyanamid Company's
Draft Statement of Work, 2/19/86. P. 300319-300330..
The Draft Statement of Work is attached.
Letter to Mr. Jerome C. Muys, Jr., Breed; Abbot &
Morgan, from Mr. John R. Butcher, Commonwealth of
Virginia, re: Response to American Cyanamid
Company's site proposal, 2/27/86. P. 300331-
300335. A cover sheet and a letter regarding the
Draft statements of work are attached.
Report: Focused Feasibility Study for theO.S.
Titanium Site, prepared by PRC Engineering,
3/5/86. ~00336-300349.
Letter to Mr. Jerome C. Muys, Breed, Abbott &
Morgan, from Ms. Carol Stokes, U.S. EPA, re:
Proposed measures to be undertaken by American
Cyanamid, 3/31/86. P. 300350-300359. The following
are attached: .
a)
b)
a letter regarding qroundwater tables;
an analysis of water in contact with grey
material;
a letter regarding commentts on the States
Draft Consent Decree;
a Site Borinq Hap.
c)
d)
Report: !!1dan?~rmen~ Asse!!Sment/Feasibility Study:-
0.5. Titanium S te, Piney River, vrrqrnla, prepared
by GCA Corporation, 4/86. P. 300360-300771.
24
-------
18 )
19)
20 )
21 )
22)
23 )
24 )
- 25)
Report~ . Statement of Work, Suoolement Remedial -
Investigation at the U.S. Titanium Site, Piney Rive=- .
Virginia,prepared by Hydrosystems, Inc., 4/24/86.
P. 300772-300794. -
Report: Work Plan for the Supplemental Remedial
Investigation at the U.S. Titanium Site, Piney
River, Virginia, Revision No.3, prepared by
Hydrosystems~ Inc., 9/12/86. P. 300795-300963.
References are .listed 'on P. 300854-300855.
Letter to Mr. Joel Jerome, American Cyanamid
Company, from Mr. John R. Butcher, .Commonwealth of
Virginia, re: Condi"tional approval of the American
Cyanamid Company .work plan, 12/24/86. P. 300964~.
300968. A letter regarding EPA concerns about the
work plan is attached.
Memorandum to Mr; R.F. Tesh, Virginia Water Control -
Board, from Mr. R.W. Balgiano, Virginia Water
Control Board, re: Transmittal of the U.S.
Titanium/Piney River Benthic Survey, 1/8/87. P.
300969-300979. The survey is attached. .
Report: Work Plan for the Supplemental
Investi ation at the U.S. Titanium Site, Pine
River, Virginia, Revision No. , Addendum No.1, .
prepared by Hydrosystems, Inc., 1/9/87. P. 300980-
301016. .
Letter to .Mr. Tedd Jett, Virginia Water Control
Board, from Mr. Dennis P. Carney, U.S. EPA, re:
0.5. ~itanium Site, Supplementary Remedial
Investigation (SRI) Workplan, Revision No.2,
Addendum No.1, 2/25/87. P. 301017-301019.
Letter to Mr. Michael Bass, U.S. EPA, from Mr. Lyle
R. S1lka, Hydrosystems, Inc., re: EPA comments on
the Supplementary Remedial Investigation Work Plan,
4/10/87. P. 301020-301024. A letter concerning the
work plan is attached.
Report: .
Titanium
prepared
301055.
25
-------
26)
27)
28)
29)
30 )
31 )
32)
33 )
. ~
,
Report:
Titanium
prepared
301287.
Supplemental Remedial Investigation, U.S. .
Site, Piney River, Vir inia, Volume 2 of 5,
by Hydrosystems, Inc.., 9/1 /87. P. 30~056-
Report: Supplemental Remedial Investigation, U.5.
Titanium Site, Piney River, Virginia, Appendixes A -
G, Volume 4 of 5, prepared by Hydrosystems, Inc.,
9/17/87. P. 301288-301449.
Report: Supplemental Remedial Investigation, U.S.
Titanium Site, Piney River, Virginia, Appendixes H -
Z, Volume 5 df 5, p~epared by Hydrosystems, Inc~,
9/17/87. P. 301450-301591. .
Letter to Dr. James R. Miller, U.S. EPA, from Mr.
Paul A. Hughes, Alliance Technologies Corporation,
re: Comments on the Supplemental Remedial
Investigation, 10/5/87~ P. 301592-301615. The
Comments are attached. .
Letter to Mr. James Miller, O.S. EPA, from Mr.
William B. Schmidt, U.S. Department of the Interior,
re: Comments on the proposed Feasibility Study Wor)
Plan, 11/5/87. P. 301616-301655. A Mine Water
Research Report is attached.
Letter to Mr. Joel Jerome, American Cyanamid
Company, from Mr. Tedd H. Jett, Virginia State Water
Control Board, re: Draft Supplemental Remedial
Investigation Report, 11/25/87. P. 301656-301668.
The Comments are attached.
Letter to Mr. Garth Conner, U.S. EPA, from Mr.
William B. Schmidt, U.S. Department of the Interior,
re: Comments on the Supplemental Remedial
Investiqation Report, 12/1/87. P. 301669-301672.
Letter to Mr. Joel Jerome, American Cyanamid
Company, from Mr. Tedd H. Jett, Virqinia State Water
Control Board, re: Craft Feasibility Study Work
Plan, 12/7/87. P. 301673-301677.. A letter.
reqardinq a study of P.iney River and a sketch of
qroundwork profile at the tailinq pond are attached.
26
-------
34)
35)
-, 36)
37)
38)
39)
40 )
41)
Letter! to Mr. Lyle R. Silk-a, Hydrosystems, 'Inc.,
from Mr. Tedd °H. Jett, Virginia State Water Control'
Board, reo: Transmittal of a letter report
summarizing the findings at site, 12/18/87. pO.
301678-301678.
Report: Feasibility Study Work Plan, u.S. Titanium'
Site, Piney River, Virginia, prepared by
Hydrosystems, Inc., 1/15/88. P. 301679-301697.
.
Report: Response to Comments Submitted by the
Commonwealth of Virginia and the U~S. Environmental
Protection Plan for the U.S. Titanium Site, prepared
by Hydrosystems, ,In~., 1/15/88. P. 301698-301704.
Report: Response to Comments Submitted by the
Commonwealth of Virginia Concerning the Supplemental
Remedial Investi ation of the,D.S.Titanium Site~
prepared by Hydrosystems, Inc., 1 15 P. 3 1705-
301709.. .
Report: Response to Comments Submitted by the U.S.
Environmental Protection Aqency Concerning the
Supplemental Remedial Investigation of the u.S.
Titanium Site, prepared by Hydrosystems, Inc.,
1/15/88. P. 301710-301742.
Letter to
Virginia,
& Morgan,
1/18/88.
Mr. John R. Butcher, Commonwealth of
from Mr. Jerome C. Muys, Jr., Breed, Abbot
re: Revised Feasibility Study Work Plan,
P. 301743-301744.
Memorandum to Mr: Richard N. Burton, Virginia
Department of Waste Management, from Ms. Cynthia V.
Bailey, Virginia Department of Waste Management, re:
Notification of Department of Waste Management's
assumption of lead agency for the site clean-up,
1/21/88. P. 301745-301745.
Memorandum to Ms. Cynthia V. Bailey, Virginia State
Water Control Board, from Mr. Richard N. Burton,
Virginia State Waste' Control Board,' re.: Concurrence
on Department of Waste Management's assumption of
lead agency for the site, 3/7/88. P. 301746-301746.
27
-------
42)
43)
44)
45)
46)
47)
48)
49)
, .
.' . .
Memorandum to Mr. R.F. ~esh, Virginia Water Con~=cl .
Board, from Mr. R.W. Bolgiano, Virginia Water'
Control Board, re: Transmittal of the Spring 1988
Biological Monitoring Results, 6/2/88. P. 301747-
301750. .
Letter to Mr. Joel Jerome, American Cyanamid
Company, from Mr. Richard N. Burton, Virginia
Water Control Board, re: Rev~sed Feasibility
Work Plan, 6/15/88.. P. 301751-301752..
.State
Study
Report: Volume 1 of
Titanium Site, Piney
Summary, prepared by
P. 301753-301773.
3, Feasibility Study, U.S.
River, Virginia, Executive.
Hydrosystems, Inc., 11/10/88.
Report: Volume 3 of 3, Feasibility Study, U.S.
Titanium Site, Pine River, Vir inia, prepared by
Hydrosystems, Inc. 11/10/8. P. 01910-302107.
References are listed on P. 302083-302084.
Memorandum to Mr. R.F. Tesh, Virginia Water Control
Board, from Mr. R.W. Bolgiano, Virginia Water
Control Board, re: Transmittal of the Fall 1988
Biological Monitoring Results, 11/16/88. P. 302108-
302113. The results are attached.
Letter to Mr. Brad Chewning, Virginia Water Control
Board, from Mr. ~ohn Kauffman, Virginia Department
of Game and Inland Fisheries, 11/21/88. P. 302114-
302115. .
28
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i -
50)
51 )
52 )
53 )
54)
55 )
56)
, .
Letter to MI. Garth Connor, U..S. EPA, from Mr. J-ames
A. Barclay, u.s. Department of the Interior Bureau
of Mines, re: Transmittal of comments on the
Feasibility Study Report on the U.S. Titanium Site,
12/16/88. ~. 302121-302125. The following are
attached:
the comments on the Hydrosystems
Feasibility Study;
a handwritten soil diagram;
an excerpt on acid mine drainage f~om
Minerals and Materials, April/May 1988.
Report: Documents Reviewed, Feasibility Study, u.S.
Titanium Site, Piney River, Virginia, prepared by .
Hydrosystems, Inc., 12/29/88. P. 302126-302129;
a)
b)
c)
Report: Health Assessment for u.s. Titanium Site,
Piney River, Amherst and Nelson County, Virginia,
prepared by U.S. Public Health Service, 1/19/89.
302130-302135. .
Po.
Letter to ~. Joel Jerome, American Cyanamid
Company, from Mr. Richard N. Burton, Virginia State
Water Control Board, re: Comments on the Draft
Feasibility Study Report, 3/15/89. P. 302136-
302138. The comments are attached.
Report: Addendum to Feasibility Study for the U.S.
!itanium Site, Piney River, ,Virginia, prepared by
Hydrosystems, Inc., (undated). ~02139-302176.
Report: Comments of American Cyanamid Company on
Endangerment Assessment/Feasibility Study: U.S.
Titanium Site, Piney River, Virginia, prepared by
Holland' Knight, (undated). P. 302177-302395. A
report entitled "Review of the Draft 0.5. EPA
Endanqerment Assessment/Feasibility Study" is
attached.
Letter to Hr. Tedd H. Jett, Virginia State Water
Control Board, from Mr. John E. Drew, Mason, Drew
and Draqat, re: Transmittal of a report on waste
copperas burial at Piney River, Virqinia, 8/18/81.
P. 302396-302401. The report is attached.
29
.
-------
57)
5 a)
59)
60 )
61 )
62)
63)
, .
Memorandum to File and Mr. T.H.Jett, Virginia State'
Wate~ Control Board, from J.A. Fromal, III, Vi~ginia
State Water Control Board, re:. Information on the
toxicity of. iron salts Qn fresh water fish,
10/16/81. P. 302402-302402.
:etter to Mr. Ted (sic] Jett, Virginia State Water
Control Board, from Mr. Gerald D. McCart, Virginia
Cooperative Extension,Service, re: Analysis. of
sludge samples and recommendations for treatment,
5/19/82. P. 302403-302412. The following are
attached: ..
a) . the ground water characterization data; .
b) a memorandum regarding the biological
monitoring results;
c) - the biological monitoring results and
narrative.
Letter to Mr. Benton G.. Tinder, Sr., from Mr. Tedd
H. Jett, Virginia State Water Control Board, re:
Transmittal of the modified Soil Conservation
Service (SCS) plan and construction specifications,
5/24/82. P. 302413-302419. The plan and the
specifications are attached.
Letter to Mr. Tedd H. Jett, Virginia State Water
Control Board, from Mr. Benton G. Tinder,. Sr., re:
Transmittal of information regarding the proposed
use of municipal sewage sludge at the U.S. Titanium
site, 5/24/82. P. 302420-302422. A table of Sludge
Characterization Data is attached.
.
Summary of a Soil Investigation, 5/29/82. P.
302423-302424. A sketch of the 50il investigation
is attached.
Memorandum to File from Mr. Tedd H. Jett, Virginia
State Water Control Board, re: Site visit to the
0.5. Titanium Corporation site, 7/25/83. P. 302425-
302430. The background surtace water data and four
Field and Laboratory Data sheets are attached.
Memorandum to File trom Mr. Tedd H. Jett, Virginia
State Water Control Board, re: Notes of meeting
held to review preliminary findings of the VPI
Study, 9/1/83. P. 302431-302432.
30
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64)
65)
66)
67)
68)
. .
Repoi~:' Evaluation of the Hazardous Waste' Site at
the U.S. Titanium Plant in Piney River, . Virginia,
prepared.by Mr. Mark S. Morris, 7/8~. P.302433-
302744. References are listed. on P. 302514. 'A
letter regarding the transmittal of two masters
theses and an additional thesis report are attached.
Memorandum to Mr. R.F. Tesh, Virginia State Water
Control Board, and the File from Mr.R.W. Bolgiano,
Virginia State Water ~ontrol Board, re: A cursory
benthic survey at the U.S. Titanium site, 9/25/84.
P. 302745-302756. The following are attached:
a)
b)
c) -
a StanQard Rating Table:
a Diversity/Density Table:
a map of Piney River and survey
area:
the biological field data sheets:
two Biologic~l Monitoring Reports.
d)
e)
Memorandum to Mr. R.F. ~esh, Virginia State Water
Control Board, from Mr. R.W. Bolq1ano, Virginia
State Water Control Board, re: Results of a cursory
benthic survey conducted on the Piney River,
6/27/85. P. 302757-302768. A report entitled,
"Qualitative Benthic Survey," is attached.
Report: Eval~atio~ of ~eutr~izat~n Requ~
for the ..2..S. T~tanium Si~e, P~ Virginia,
prepared by GCA Corporation, 1 8. P. 302769-
302795. References are listed on P. 302795.
.
Report: Draft Statement of Work, Temporary Source
~ tor Area ~Titanium S;te, Pin~iver,
~, prepared by Hydrosystems Inc., 2/14 6.
~6-302798.
69) ~tter to Mr. Jerome C. Muys, Jr., Breed, Abbott'
Norqan., from. Mr. Tedd H. Jett, Virginia State Water
COntrol Board, re: Deadline tor a Revised Work
Plan, 8/26/86. P. 302799-302802. A memorandum
re9ardin9 comments on the Dratt Work Plan is
attached.
Report: Focused Feasibilit Stud tor the U.S.
Titanium Site Revised Work P an, prepared by
A ~ance Tec no og~es Corporat~on, 12/5/86. P.
302803-302816.
70)
31
-------
71 )
72 )
73)
74)
75)
76)
"
Memorandum to Mr. R.F. Tesh, Virginia Water Control'
Board, from Mr. R.W. Bolgiano, Virginia Water,
Control Board, re: Results of'a cursory benthic
survey conducted on the Piney River, 1/8/87. P.
302817-302827. The Qualitative Benthic Survey is
attached.
Letter to Mr. Lyle R. Silka, Hydrosystems Inc'., from
Mr. Tedd H. Jett, Virginia State Water Control
Board, re: Transmittal of information' relevant to
O.S. Titanium site work, 12/7/87. 'P. 302828-302834.
The following are attached: "
a)
b)
c)
a Routing and Transmittal slip;
three hydrographs;
two water level data tables.
Letter to Mr. Lyle R. Silka, Hydrosystems Inc" from
Mr. Tedd H. Jett, Virginia State Water Control
Board, re: Transmittal of a letter report
summarizing the findings of recent site
investigations, 12/18/87. P. 302835-302838. A
letter regardinq the findinqs of recent site
investiqations and a sketch of the groundwater
profile at the Tailinq Pond are attached.
Memorandum to Mr~ R~F. Tesh, Virginia Water Control
Board, from Mr. R.W. Bolgiano, Virqinia Water
Control Board, re: Transmittal of the results of
Spring 1988 Bioloqical Monitorinq and narrative,
6/2/88. P. 302839-302842. The results are
attached.
Letter to Mr. Tim Lonqe, Virqinia Department of
Waste Manaqement, from Mr. Jeffrey A. Sitler,
Hydrosystems Inc., re: Information on possible
remedial a~tions, 6/26/89. P. 302843-302853.
Letter to Mr. Jeffery [sic] A. Sitler, Hydros-ystems
Inc., from Dr. Timothy Lonqe [sic], Virqinia
Department of Waste Manaqement, re: Details of
remedial action alternatives, 6/29{89. P. 302854-
302855. '
32
-------
IV.
.
1)
Memorandum to Mr. Gene A. Lucero, 0.5. E?A, from.Mr.
Stephen R. Wassersug, 0.5. E?A, reo ~tion .
Memorandum for the 0.5. Titanium Site, 7/19/83. ?
400001-400006. A memorandum regarding the
authOrization to proceed with a remedial
investigation. and feasibility study at the 0.5.
Titanium Site is attached.
REMOV~
.
33
-------
V.
.
COMMUNITY INVOLVEMENT/CONGRESS!ONAL
CORRESPONDENCE/!MAGERY
1)
2)
I"
Transcript In Re: Public Hearing of the Virginia
State Water Control Board, 3/16/78. P. 500001-
500006.
Letter to Ms. Kristina Stein, 800z, Allen & .
Hamilton, !nc., from Mr. James R. Miller, U.S. EPA,
re: Transmittal of the Draft Community Relations
Plan for the 0.5. Titanium Site, 1/12/88. P.
500007-500029. The Draft Community Relations Plan
is attached.
34
-------
2) -,
3) ,
4)
5)
6)
7)
8)
9)
10)
..
, SITE-SPECIFIC GUIDANCE
1)
Report: Mine Water Research, Catalytic Oxidation of
Ferrous Iron in Acid Mine Water by Activated Carbon,
prepared by Edward A. Mihok, U.S. Depa~tment of Interior,
1969. :
Article entitled "Microbial Dissimilatory Sulfur Cycle in
Acid Mine Water", by Jon H. Tuttle, Patrick R. Dugan, .
Carol B. MacMillan, and Chester ,I. Randles, 2/69.
Report: Evaluation of Copperas Contamination at the: ,
American Cyanamid Company Plant Site, Piney River,
Virginia, prepared by Geraghty & Miller, Inc., 5/72.
Report: Evaluation of Environmental Pollution Control
Measures for Copperas Pile Runoff, prepared by David A.
Olson, American Cyanamid Company, 7/27/72.
Report: Studies in the Treatment of Coal Mine Drainage
by BiochemichalIron Oxidation and Limestone
Neutralization, prepared by H.L. Lovell, Colleqe of Earth
and Mineral Sciences, The Pennsylvania State University,
2/28/74.
Report: Evaluation of Prototype Crushed Limestone
Barriers for the Neutralization of Acidic Stream,
prepared by Frank H. Pearson, Institute for Research on
Land and Water Resources, The Pennsylvania State
University, 6/74. .
Article entitled "Limestone Barriers to Neutralize Acidic
Streams", by Frank H. Pearson and Archie J. McDonnell,
6/75. ,
Article entitled "Studies of Lime-Limestone Treatment of
Acicf-Mine Drainaqe", by David G. McDonald, Harry Yocum,
and Alten F. Grandt, Peabody Coal Company, 1976.
Table of Normals, Means, and Extremes of Outdoor
Temperatures from Lynchburq and Norfolk, Virqinia, 198'0.
Report: ~ecifications' Contract tor the Excavation and
Burial of Copperas Waste, prepared~y Geonics, ~
. .
3S
-------
16)
17)
18)
19)
11)
. ,
Report: P r'o . ect Surr..mar~: Limestone, - Lime T=eatment of' ,
Acid Mine Drainage - Full Scale, prepared, by David G.
McDonald and Alten F. Grandt, 6/81., .
12)
Article entitled "Modificati'on of
Freshwater Wetland", by R. Kelman
Lang, Department of Biology, West
6/26/82.
Acid Mine Drainage in a
Wieder and Gerald E.
Virginia University,
13)
Report: A Study of the ~nteractions of Limestone and
' Various Acidic Solutions Containing Metal Ions, prepared
by Richard L. Ranich, Department ,of Mineral Engineering,
The Pennsylvania State University, 8/82.
14 )
Proposal: Engineering Evaluation of Remedial Actions at
the U.S. Titanium Corporation, Piney River Site,
submitted by ~.L. Yu and J.M. Hamrick, Department of
Civil Engineering, University of Virginia, 12/82.
Proposal: Evaluation of Fe~rous Sulfate Disposal Site at
Piney River, Virginia, submitted by Dr. John T. Novak,
Department of Civil Engineering, Virginia Polytechnic
Institute and State University, 12/29/82. .
15)
Article entitled "Biological Catalysis of the Oxidation
of Iron (II) in Acid Mine Waters in a Sequencing Batch
Suspended Film Reactor", by Thomas L. Theis and Lloyd H.
Ketchum, Jr., Department of Civil Engineering, University
of Notre Dame, and William H. Engelmann, O.S. Department
of the Interior, 12/5/82.
Letter to John R. Butcher, Esq., Assistant Attorney
General, Commonwealth. of Virginia from Jim Heenehan,
Esq., O.S. EPA, re: the Case Development Plan for the
U.S. Titanium Site, 4/19/83. The Case Development Plan
is attached.
Article entitled "Influence of Wetlands and Coal Mining
on Stream Water Chemistry", by R. Kelman Wieder and
Gerald B. Lang, Department of Biology, West Virginia
University, 11/7/83.
Article entitled "Use of Collection Lysimeters in
Monitorinq Sanitary Landfill Performance", by Peter Kmet
and David E. Lindorff, Wisconsin Department of Natural
Resources, 12/8/83.
, .
..
36
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20)
21)
22)
23)
24 )
25 )
26)
27)
Article -en~itled "Induced Alkaline Recharge Zones to
Mitigate Acidic Seeps", by Frank T. Caruccio and
Gwendelyn- Geidel, Department of Geology, University of
South Carolina and Ray Williams, DLM Coai Company, -
12/2/84.
Report: Evaluation of an Acidic Waste Site Cleanuc
Effort, by John T. Novak, William R. Knocke, Mark S.
Morris and Gregory L. Goodman, Virginia Polytechnic
Institute and State University, and Tedd Jett, Virginia
State Water Control Board, 5/14/85.
Report: The -Hydrogeology of the Ferrous Sulfate Waste
Site, Pipey River, Nel~County, Virginia, by Steven
Col ton, Depar_tment of Environmental Sciences, Uni versi ty
of Virginia, 5/1/86. -
Report: Some Industrial Applications of Inorganic -
Microbial Oxidation in Japan, by T. Imaizumi, Universit~
of Tokyo, 1986. -
Article entitled "Reclaiming Abandoned Mine Lands Using
Controlled Release Bactericides: A Case Study", by Vijay
Rastogi and Andrew A. Sobek, The SF Goodrich Company,
8/15/86. - - -
Article entitled "Mic-robial Ecology and Acidic Pollution
of Impoundments", by Aaron L. Mills, Department of
Environmental Sciences, University of Virginia, and Alan
T. Herlihy, 1985.
Memorandum to Lyle Silka from Gerald Lang, West Virginia
University, re: arti~le presented at the Symposium on
Wetlands of the Unglaciated Appalachian Region, 01/10/86.
An article entitled "Modification of Acid Mine Drainage
in a Freshwater Wetland", by R. Kelman Wieder and-Gerald
E. Lang, Department of Biology, West Virginia University,
5/26/82 is attached. -
I .
37
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28 )
29)
30 )
31 )
32 )
33 )
34)
35 )
36)
37)
Report: Re~ort on the Results of Filed Testing The
Environmental Pro~ection Agency's Interim Final Wetland
Identification and Delineation Manual During 1987, -by
William S. Sipple, Office of Wetlands Protection, U.S.
EPA, 4/01/88. '
Article entitled "Theoretical Assessme~t and Design
Considerations for Passive Mine Drainage Treatment
Systems", by J. David Holm, Colorado Department qf
Natural Resources and deForest Guertin, Colorado School
of Mines, (undated).
'Article entitled "Constructed Wetlands for Acid Drainage
Control in the Tenne~see Valley", by Gregory A. Brodie,
Donald A. Hammer, and David A. Tomljanovich, Tennessee
Valley Authority, (undated). '
An
Article entitled "Passive Mine Drainage Treatment:
Effective Low Cost Alternative", by J. David Holm,
Colorado Mined Land Reclam~ion Division and Scott
Snowmass Coal Company, (undated).
Article entitled "Influence of Wetlands and Coal Mining
on Stream Water Chemistry", by R. Kelman Wieder and
Gerald E. Lang, Department of Biology, West Virginia
University, (undated).
Jones', '
Article entitled "Aquatic Plant Systems -- An
Unconventional Approach to Removal of Toxic Materials",
by Ray Dinges, (undated).
Article entitled "Observations on Iron-Oxidation Rates in
Acid Mine'Drainage Neutralization Plants", by Roger C.
Wilmoth, James L. Kennedy, and Ronald D. Hill, U.S. EPA,
(undated) .
Article entitled "Treatment of Acid Mine Water by
Wetlands", by Robert L.P. Kleinmann, Bureau of Mines,
Pittsburgh Research Center, (undated).
Article entitled "Alkaline Injection:, An Overview of
Recent Work", by Kenneth J. Ladwig, Patricia M. Erickson,
and Robert L.P. Kleinmann, Bureau of Mines, Pittsburgh
Research Center, (undated).
Article entitled "Acidic Mine Drainage: The Rate-
Determining Step", by Philip C. Singer and Werner Stumm,
Division of Engineering and Applied Physics, Harvard
University, (undated).
I .
38
..
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38)
39)
40)
41 )
42)
C9
A%ticle enti~led "Passive Mine Dra~naqe Treitment:.
Selected C~se Studies", by J. David Holm, Color~do
Department of Natural Resources and Michael B. Bischop, .
(undated) .
Article entitled "Use. of Limestone In AMD Treatment", by
Charles T. Ford, Bituminous' Coal Research, Inc.,
(undated) . .
Report: The Potential Imoortance of Sulfate Reduction
Processes in Wetlands Constructed to Treat Mine Drainage,
by Robert S. Hedin, Richard Hammaclr and David Hyman,
(undated) . .
Report: Treatment of Acid Coal Mine.Drainage with.
Constructed Wetlands,. by Robert S. Hedin, U. S. Bureau of
Mines, (undated).
Report: Control of Acid Mine Drainage, Preceedings of a
TechnologY-!ransfer Seminar~ by Staf~, Bureau of Mines, -
(undated) . .
" .
, .
. 39
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• GENERAL GUIDANCE DDCixrvrg *
1) "Promulgation of Sites frcm Updates.1-4," Federal Register, dated 6/10/86.
2) "Prcoosal of Update 4," Federal Register, dated 9/18/85.
3) Memorandum to U. S. EPA from Mr. Gene Lucero regarding community relations
at Superfund Enforcement sites, dated 8/28/85.
' " - .''."'* '
4) Groundvater Contamination and Protection, undated by Mr. Donald V.
Felicianp on fl/28/85. .
5) Memorandum to Toxic Waste Management Division Directors Regions I-X from
Mr. William Hedeman and Mr. Gene Lucero re: Policy on Flcodplains and
Wetlands Assessments .for CERCLA Actions, 8/6/85. '
6) Guidance oh Remedial Investigations under CERCLA, dated 6/85.
7) Guidance on Feasibility Studies under CERCLA, dated 6/85.
85 "Proposal of Update 3," Federal Register, dated 4/10/85.
9) Memorandum to Mr. Jack McGraw entitled "Community Relations Activates
at Superfund Sites -Interim Guidance," dated 3/22/85.
10) "Proposal of Update 2," Federal Register, dated 10/15/84
11) SPA Ground%ater 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 8/20/84.
13) "Proposal of Update 1," Federal Register, dated 9/8/83.
14) Community Relations in Superfund: A Handbook (interim version), dated
9/83.
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 Hazardous Waste Site Ranking System: A User's Manual
(undated).
19) Field Standard Operating Procedures - Air Surveillance (undated).
20) Field Standard gyrating Procedures - Site Safety Plan (undated).
* 'Located in EPA Region III of "ice.
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