United States Offico of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-90/105
September 1990
&EPA
Superfund
Record of Decision
Fike Chemical, WV
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50272-101
REPORT DOCUMENTATION /1. REPORT NO. 2. 3. Reclpjenh Acceaalon No.
PAGE EPA/ROD/R03-90/105
4. TItle 8nd Subtl1l8 5. Report Date
SUPERFUND RECORD OF DECISION 09/28/90
Fike Chemical, WV
Second Remedial Action Final 6.
-
7. AuIhor(a) 8. Pertonnlng Organization Repe. No.
t. P8ff0nnlng Orgalnlzatlon Name and Addn.. 10. ProjecVTa8klWork Unit No.
1 t. Contract(C) or Grant(G) No.
(C)
(G)
12. SponeorIng Organization Name and Addle.. 13. Type 01 Report' Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Note.
18. Abatr.ct (Urnlt: 200 wolda)
The 11.9-acre Fike Chemical site is an abandoned chemical manufacturing facility in
Nitro, West Virginia. The site is comprised of an II-acre chemical plant and a
0.9-acre Cooperative Sewage Treatment plant (CST). Onsite features include several
chemical production areas, process control equipment, various onsite structures, drum
and waste burial areas, over 400 storage tanks, and 3 inactive waste lagoons. During
operating years, the CST facility treated the sewage and industrial wastewater generated
by the chemical manufacturing processes and onsite truck terminal operations. The CST
facility currently treats contaminated storm water generated onsite. From 1951 to 1988,
Fike Chemical manufactured more than sixty different chemicals. Hazardous wastes
generated from onsite operations were discharged onsite to the nearby Kanawha River. In
1983, EPA identified onsite dioxin-contaminated soil. In addition, asbestos was found
in several onsite structures and was used as insulation for onsite pipes, tanks, and
cooling towers. A 1988 Record of Decision (ROD) addressed the disposal of bulk
chemicals stored in onsite tanks and drums. In 1989, an Explanation of Significant
Differences modified the 1988 ROD, documenting that drum contents would not be
consolidated prior to disposal. In 1990, a Focused Feasibility Study (FFS) was
(See Attached Page)
17. Document Analyei. L De.crlplon
Record of Decision - Fike Chemical, WV
Second Remedial Action - Final
Contaminated Medium: debris
Key Contaminants: organics, asbestos
b. IdentiIler8lOpen-Encled Terms
Co COSA 11 ReIdIGroup
18. AvlilabiUty Slatement 19. Security Cia.. (This Report) 21. No. of P.ge.
None 43
20. Security Clsss (This Page) 22. Price
None
272 (4-77)
(See AHSl-Z3t.18)
See Insuucuons on Rev."",
(Formerly Nns.35)
Department of Commerce
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EPA/ROD/R03-90/105
Fike Chemical, WV
Second Remedial Action - Final
Abstract (Continued)
completed by EPA to evaluate remedial alternatives for the tanks, equipment, and
structures. This ROD addresses the tanks, equipment, and structures evaluated in the
1990 FFS report. Future RODs will address other onsite areas of concern including
contaminated soil and sludge. The primary contaminants of concern contained in the
waste/debris include organics and asbestos.
The selected remedial action for this site includes removing 5.5 tons of onsite asbestos
material from various site areas; dismantling and decontaminating 400 onsite storage
tanks, approximately 130 pieces of equipment, and 39 buildings and disposing of the
debris offsite; treating and if necessary, discharging the decontamination fluids; and
implementing site access restrictions including fencing. The estimated present worth
cost for this remedial action is $2,830,000, which includes an annual O&M cost -of $5,200
for 30 years.
PERFORMANCE STANDARDS OR GOALS: Any tanks, equipment, or structure identified as a
safety hazard and health risk and/or an obstacle to future investigation will be
dismantled, decontaminated, if necessary, and removed to an offsite facility for
disposal or salvaging. Any waste, which cannot be treated onsite will be removed to an
offsite facility for treatment.
.
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RECORD OP DECISION
PIKB/ARTEL CBBKICAL SITE
DECLARATION
SITB NAME AND LOCATION
Fike/Artel Chemical Site
Nitro, West Virginia
operable Unit Two
STATEMENT OP BASIS AND PURPOSB
This Record of Decision presents a selected remedial action for
the tanks, equipment, and structures at the Fike/Artel Chemical
site in Nitro, West Virginia, chosen in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended (CERCLA), 42 U.S.C. Section 9601
et. seq., and, to the extent practicable, the National
Contingency Plan (NCP). This decision is based on the
Administrative Record for this site.
The state of West Virginia concurs with the selected remedy.
ASSBSSMENT OP THE SITB
Pursuant to duly delegated authority, I hereby determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. Section 9606, that
actual or threatened releases of hazardous substances from this
site, as discussed in "Summary ot site Risks" on page 23 and 26,
if not addressed by implementing the response action selected in
this Record of Decision, may present an imminent and substan~ial
endangerment to public health, welfare, or the environment.
DESCRIPTION OP THE REMEDY
This remedy is 'the second major step in the process of
remediation of the Fike/Artel Chemical Site. This remedy
(Operable Unit Two) addresses safety hazards and health risks
associated with tanks, equipment, and structures by removing all
tanks, equipment, and the majority (or all) of the onsite
buildings. The objective of this remedy is to remove tanks,
equipment, and structures which may present safety hazards;
asbestos; contaminated residuals in tanks, equipment, and
structures; and obstacles to future site work. While the remedy
does address some of the principal known threats at the
Fike/Artel Chemical Site, future actions will involve continued
investigation and possible remediation ~f soil, groundwater I
surface water, a sewer system underlying the site, and waste
disposal areas.. Remedial actions for these areas will be
delineated in a future Record of Decision(s).
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The major components ~fthe selected remedy include:
. Dismantling of .al,l tanks, all equipment, and the majority
(or all) of the-buildings located onsite
. Decontamination, to the extent necessary and/or
practicable, of dismantled tanks, equipment, and buildings
utilizing best management practices
. Removal of asbestos from tanks, equipment, and dismantled
buildings, and disposal of asbestos in an offsite landfill
. Removal of decontaminated tanks and other decontaminated
facility components by sale as scrap, recycling, or
disposal in an offsite landfill for nonhazardous or
hazardous waste
.. Disposal of materials that contain a RCRA hazardous waste
(or a substance sUfficiently similar to a RCRA hazardous
waste) and that cannot be decontaminated in an offsite
landfill for hazardous waste
-,
. Maintenance of the existing perimeter fence
. Treatment of fluids resulting from decontamination by the
cooperative Sewage Treatment (CST) plant located on the
site.
STATUTORY DETERMINATIONS
This action is protective of human health and the environment,
complies with Federal and State applicable or relevant and
appropriate requirements directly associated with this action,
and is cost-effective. This action utilizes permanent solutions
and alternative treatment (or resource recovery) technologies to
the maximum extent practicable, given the limited scope of the
action, and satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a
principal element. Subsequent actions are planned to fully
address the other principal threats posed by the Fike/Artel
Chemical Site.
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Because subsequent site remedies should address remaining
hazardous substances above health-based levels, a review in
accordance with section 121(c) of CERCLA, 42 U.S.C.
Section 9621(c) is not required by this decision. However,
should those future site remedies not sUfficiently address
remaining hazardous substances within five years, a review will
be conducted at that time, and every five years thereafter, or as
required, to ensure that existing site remediation continues to
provide adequate protection of human health and the environment.
~~~i~ .~-
Regional Administrator
EPA Region III
SEP 2 8 1990
Date
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I.
DECISION SUMMARY
SITE NAME, LOCATION, AND DESCRIPTION
"
The Fike/Artel Chemical Site (hereafter referred to as
"Fike/Artel Site, II "Artel," or "the site") is located
approximately 500 feet northwest of downtown Ni tro, West
Virginia in the Nitro Industrial complex (see Figure 1). The
site contains a former chemical manufacturing plant and an
associated former waste-water treatment facility. The
Kanawha/Putnam County line bisects the site in an east-west
direction. The site is located on an access roadway off of
Viscose Road (also known as Plant Road), which is accessed from
WV Route 25. The site occupies approximately 11. 9 acres and is
bounded to the north by Vimasco Corporation (a chemical
manufacturer); to the east by Consolidated Rail Corporation
(railroad switching and maintenance yard); to the south by an
abandoned railroad sidingr to the west, by Miller Transport,
Inc. (on land owned by T.R. and C.L. Halloran), and also by Dana
. Container, Inc. , both tank wagon maintenance and washing
, facilities (see Figure 2). The site is approximately 2,200 feet
east of the Kanawha River. The Kanawha River, a major surface
water system, has been categorized under West Virginia Water
Quality Standards as suitable for water contact recreation;
industr ial and agr icultural water supply; propagation and
maintenance of fish; and transportation, cooling, and power.
The Kanawha River is not used for public water supply downstream
of Charleston, West, Virginia. Public drinking water in the
Charleston-Nitro area is provided by the West Virginia Water
Company using the Elk River as a source. The confluence of the
Elk and Kanawha Rivers is in Charleston, approximately 15 river
miles upstream of Nitro.
The Fike/Artel Si te is si tuated on the si te of a World War I
smokeless powder (munitions) plant. The original chemical plant
on the site began operation in 1951 as the Roberts Chemical
Company. In 1971, the name was changed' to Fike Chemicals, Inc.
In 1986, the name was changed to Artel Chemical Company. (All
three shall be referred to as Artel hereafter.) During plant
operation, more than 60 different chemicals were produced, all
by batch process on an as-needed basis, including
fluoroacetonitrile, ethyl fluoroacetate, sodium fluoroacetate,
ethylene thiourea, diphenylamine, allyl cyanide, N,N'-
diisopropyl carbodiimide, fluoroacetamide, sodium amide, sodium
ethylate, sodium methylate, sodium nickel cyanide, and
thioacetamide. The facility was abandoned in June of 1988.
The chemical manufacturing plant consists of 14 production
areas, in which various chemicals were manufactured;
39 buildings, which include offices, laboratories, warehouses,
storage bunkers, and process control buildings; over 400 storage
tanks; process reactors and process control equipment; 3 closed
waste lagoons; and drum and waste burial areas.
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COOPERATIVE SEWAGE
TREATMENT PLANT
SCALE IN FEET
BASE MAP IS A PORTION OP THE U.S.Q.S. SAINT ALBANS,* VA. QUAORANOUE (7.5 MINUTE SERIES 1998, PHOTO-
REVISED 1971 AND I976.1CONTOUR INTERVAL 20'.
FIGURE 1
SITE LOCATION MAP
FIKE/ARTEL SITE. NITRO. WV
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-."---"
...-----
CONRA:~ . ------...
J
0\
I
~
---
----...~..
PAR INDUSTRIAl.
PAR INDUS TRIAL
IOCCUPIED BY
NITRO CORP.)
NIT RO CITY PARK
~ ..
~~-=-~~
KANAWHA ---=-
.
,...., - -
- -
SCALI.un
FIGURE
SITE LAYOUT
FIKE I ARTEl SITE
, NITRO, WV
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The Cooperative Sewage Treatment, Inc. (CST) facility was formed
by Artel and a previous truck terminal operator (Coastal Tank
Lines, Inc.) to treat sewage and industrial wastewater generated
by the two operations. The CST plant occupies approximately
0.9 acres and is located on Viscose Road approximately 500 feet
west of the chemical manufactur ing facili ty. The Artel Si te
consists of both the chemicals plant and the treatment plant.
The CST plant consists of three treatment lagoons; a treatment
control building; a sludge drying bed; and various wastewater
treatment equipment and tanks. The CST plant was also abandoned
by the company in June 1988.
The topography of the site is generally flat, with local
drainage controlled by a drainage di tch located along the east
side of the plant and storm sewers located throughout the plant.
These storm sewers, along with three sump pump systems, transfer
drainage and process wastewater from the plant to the CST.
Elevations throughout the plant range from 596 to 603 feet above
r,nean sea level (amsl), which are well above the Kanawha River
laO-year flood plain elevation (586 feet amsl). The east
drainage ditch discharges to a storm sewer beneath Viscose Road.
The storm sewer eventually discharges into the Kanawha River
north of and downstream of the site.
The geology of the si te and adjacent study area consists of
alluvial deposits overlying predominantly shale and claystone
bedrock. The observed depth to bedrock at the si te ranges in
depth from approximately 55 to 60 feet, indicating that the
bedrock surface is relatively flat lying, with minor local
variations. As a result of this, the thickness of the
unconsolidated deposits is relatively uniform, ranging in
thickness from approximately 55 to 60 feet.
Four lithologic units were identified within the unconsolidated
deposits throughout the study area. In descending order, the
deposits consist of an upper noncontinuous layer of fill
materials composed of sands, silts, and clay; a second layer
which is described as a silty clay; a third layer consisting of
mostly a fine silty sand; and a basal unit consisting of a
fine- to medium-gr~ined sand. These units were identified based
on samples obtained, during monitoring well and soil boring
drilling operations.
The aquifer systems present at the site consist of an unconfined
alluvial aquifer and a semiconfined to unconfined bedrock
aquifer. The alluvial aquifer is composed mainly of f ine- to
medium-grained sand with some silt, and has a saturated
thickness of 29 to 40 feet. The dominant flow path is in a
northwesterly direction toward the Kanawha River. The alluvial
aquifer is in direct hydraulic connection with the Kanawha
River.
The bedrock aquifer
competent siltstone.
is a very tight formation composed of a
The thickness of this formation was not
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determined during this investigation.
groundwater flow direction is to the west,
toward the Kanawha River.
Bedrock aquifer
which is directly
Hydraulic conductivity values for the alluvial aquifer range from
0.027 ft/day to 530.6 ft/day with an average value of 71 ft/day.
The hydraulic conductivity values for the bedrock aquifer range
from 2.8 X 10.3 to 9.8 X 10.2 ft/day.
The hydraulic gradient for the alluvial aquifer, measured
parallel to the direction of groundwater flow, is 0.004 ft/ft.
Nitro, WV has a population of approximately 9,500. An estimated
1,500 to 2,500 people reside within a 1 mile radius of the
facility. In addition, the municipal swimming pool, ball fields,
and the local junior and senior high schools are situated within
1/2 mile of the site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The earliest documented enforcement action was resolved in a
September 12, 1978, consent decree filed by the state of West
Virginia and Artel, Coastal Tank Lines, and CST, requ1ring lining
of the treatment basins at the CST. Subsequent court findings
indicate that Artel, did not complete the actions required by the
consent decree in the time allowed.
In March of 1982, EPA issued a National Pollutant Discharge
Elimination system (NPDES) permit for wastewater discharges from
the CST plant.
In 1982, the site was evaluated via the Hazard Ranking System
Model to determine if the site should be placed on the National
Priorities List (NPL) established under Section 105 of CERCLA,
42 U.S.C. Section 9605. The resulting score was 36.3. The site
was proposed for addition to the NPL in December 1982. In
september 1983, . the site was promulgated as an NPL site.
Artel was sued by the EPA pursuant to the Clean Water Act (CWA)
and the Resource Conservation and Recovery Act (RCRA) for its
discharges to the Kanawha River and disposal of hazardous wastes
on site, resulting in a Consent Decree. entered into in November
. of 1982, between the U.S., Artel, and the now defunct Coastal
Tank Lines, Inc. .This Decree required the defendants to perform
diking and paving of process areas, covering of principal waste
disposal sites, and the pumping and treating of contaminated
groundwater.
In June 1983, an EPA Region III Field Investigation Team (FIT)
sampling survey was conducted to collect soil samples for dioxin
analysis (2,3,7, 8-TCDD) . Based on the results of this initial
screening, additional dioxin sampling and analysis was required.
In March 1984, EPA issued an order for dioxin sampling and
analysis to determine the extent of contamination at the site.
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Artel claimed to be unable to afford this work.
EPA FIT performed the sampling of concern.
In 1983, the West Virginia Department of Natural Resources
(WVDNR) issued Administrative Order No. 829, directing Artel to
stop placing waste in Lagoon 3, a waste evaporation lagoon
located in the south end of the chemicals plant.
As are suI t ,
In May of 1984, EPA issued a Complaint, Compliance Order and
Notice of Opportuni ty Hear ing for Artel. The complaint ci ted
violations of RCRA and specifically required Artel cease
acceptance and storage of containers of hazardous waste not
included in the RCRA Part A Permit Application of Artel; cease
storage of containers of hazardous waste in areas other than
those designated in the Part A Permit Application; remove
hazardous wastes not specified in the Part A Application; comply
with operating record requirements; and obtain a certificate of
liability insurance.
Artel filed a RCRA Part B Permit Application for the CST in
December of 1984. A Notice of Deficiency (NOD) was returned to
Artel in March of 1985. Artel responded to the NOD in June
of 1985. EPA issued a publ ic notice on November 29, 1985, of
its intent to deny a Part B Permit for the CST, as a result' of
the failure of Artel to correct deficiencies in its Part "B
Application. The EPA ultimately denied the permit on
March 14, 1986, and terminated the facility's interim status.
The permi t application was subsequently wi thdrawn by Artel. No
Part B permi t Application was ever submi tted for the chemicals
plant.
In January 1987, WVDNR issued an Order to Artel to agree to
describe materials accepted by the plant as RCRA hazardous
wastes; manage containers properly; submit site plans; develop a
plan to mark containers for identification purposes; and submit
an amended Part A Hazardous Waste Permit Application.
The chemicals plant was abandoned in June of 1988. Since that
time, an EPA Emergency Response Team (ERT) has been on site
performing work to control, stabilize, and/or eliminate
immediate hazards to the public health and the environment. On
September 29, 1988, a Record of Decision for the site was
signed, author izing EPA to utilize remedial funds to control,
stabilize, and/or eliminate such hazards (Operable Unit One or
OU-l). In August of 1989, an Explanation of Significant
Differences was issued by EPA, modifying the scope of work
descr ibed in the Record of Decision dated September 29, 1988.
The major modification of concern was a decision not to bulk
package the contents of drums on site for disposal. In
addition, it was determined that asbestos removal would be
conducted under a subsequent remedial action. The focus of the
ongoing remedial action remained the removal of bulk chemicals
stored in tanks and drums.
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Upon the planned completion of OU-l in
formerly storing bulk chemicals will
concern will (with several exceptions)
chemicals.
the fall of 1990, tanks
rema.in. The tanks of
still contain residual
The CERCLA Remedial Investigation was initiated in March
of 1988. The field activities included sampling of sludges from
CST lagoons and onsite storage tanks; sampling of residuals
accumulated within the sewer system; installation of groundwater
monitoring wells; collection of samples from existing and newly
installed wells; collection of soil samples from background
areas, areas adjacent to the CST and the chemicals plant, and
from the soil in the process area of the chemicals plant; and an"
evaluation of process and storm sewers used to convey wastewater
and storm water to the CST. In addition, a comprehensive
evaluation and inventory of tanks, equipment, process lines,
structures, and concrete pads was conducted. This evaluation of
the Process Facility and other field work of concern was
completed by December of 1989. Data from the investigation of
,the Process Facili ty components forms the basis of a Focused
Feasibility Study (FFS) for the Tanks, Equipment, and
Structures, completed in July of 1990. Additional Remedial
Investigation/Feasibili ty Study activi ties are underway at this
time.
.,
,.
Approximately 200 letters have been issued to parties associated
wi th the si te pursuant to Section 104 (e) of CERCLA. Twenty-six
(26) parties have been notified of their potential liability
under CERCLA for past and potential future actions taken at the
site. These parties were notified through general Notice
Letters issued in 1990. Twenty-two (22) of the parties are
generators and four (4) are owner/operators. .
HIGHLIGHTS OF COMMUNITY PARTICIPATION
Public participation activities have been conducted since the
commencement of the ERT work in June of 1988. Public meetings
were held on a weekly basis at the municipal building in
downtown Nitro to update the citizens on the progress of the
removal actions. A public meeting was held in August 1988 prior
to finalizing the ,Record of Decision for the removal actions and
to plan for the destruction of a cyanide gas cylinder on site.
A public meeting was held on August 6, 1990, at the Nitro Senior
High School specifically for eliciting public comments on the
proposed plan for addressing the tanks, equipment, and
structures. The comment per iod for the Proposed Plan extended
from July 25 through September 22, 1990. Through the above
actions, EPA has met the public participation requirements of
Sections 113, 117, and 121 ofCERCLA, 42 U.S.C. Sections 9613,
9617, and 9621.
SCOPE AND ROLE OF ACTION
The objective of this remedial action is to mitigate risks to
public health and the .envi ronment associated wi th tanks,
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equipment, and structures associated with the site. This
remedial action serves as a necessary, n~xt step in the
remediation of the si te and is considered Operable Uni t Two.
Addi tional si te features expected to be addressed under future
Operable Uni ts include soil, groundwater, bur ied wastes,
sludges, and the sewer system. Structures at the site consist
of 39 buildings and various concrete-paved areas, including
concrete pads (and associated dikes) underlying tanks and
equipment and foundations of buildings.
CHARACTERISTICS OF TANKS, EQUIPMEN'r, AND STRUCTURES
A summary of a building inventory and assessment conducted by
EPA is provided in Table 1. As noted in Table 1, the apparent
condition of the buildings at this time varies from poor to
good. Buildings which could collapse in the near future due to
serious structural problems were determined to be in poor
condi t ion. Buildings with signif icant st ructural problems bu t
not likely to collapse in the near future were determined to be
in fai r condi tion. In the major i ty of cases, the buildings of
concern are located in areas to be investigated due to burial of
wastes and/or the presence of stained soils. Soil sampling
within the northern half of the site has confirmed soil
contamination within many of the areas of concern. In addition,
in many cases chemical residuals generated dur ing onsi t.e
production are likely to have contaminated building materials.
A summary map of concrete pad and dike locations is provided in
Drawing A-l, Appendix A, of the FFS. Examination of histor ical
aerial photographs indicates that the majority of these pads
were placed after significant staining of underlying soils
occurred. Sampling of soils under the pads dur ing the RI has,
in fact, revealed significant soil contamination underlying the
pads of concern. In addition to building foundations, an
estimated 2.1 acres are covered with concrete which is estimated
to weigh approximately 5,260 tons.
One hundred thirty (130) pieces of equipment were identified
during the FFS, including reactor vessels, mixers, screening
equipment, heat exchangers, scrubbing and fractionating columns,
pumps, filters, centrifuges, air blowers, heaters, chillers, and
boilers. An inventory of the equipment of concern is provided
in Table 2. As noted in the inventory, an estimated one-half of
this equipment is projected to be contaminated with residual
contaminants associated with onsite production processes. While
unknown at this time, a significant portion of remaining
equipment may also contain residual contaminants. Virtually all
of the" equipment is located within areas of past chemical
processing. As noted, histor ical aer ial photos indicate
significant soil staining within these areas in past years.
An estimated 10,000 feet of process pipeline has been identified
(see Table 3) . An estimated 1,480 feet were used for chemical
product/material conveyance, while the balance was used for
utility-related purposes. Virtually all of the pipe is overhead
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TABLE 1
RESULTS OF THE BUILDING INVENTORY
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
Materials of Construction
Building Name or Use Area Height Condition
ID (Feet2) (Feet)
Wa 11 s Roof
A Laboratory 7,586 13 Concrete block Steel Truss, Good
Corrugated deck
Office 1,340 16 Concrete block Concrete Good
B (two-story)
C Loading Warehouse 1,830 16 Concrete block Steel truss, Good
Corrugated deck
D Process Control Shed 411 12 Concrete block Steel truss, Good
Corrugated deck
E Chiller Building 1,862 12 Concrete block Steel truss, Fair; bad roof
Corrugated deck
F Process Control Shed 321 10 Concrete block Steel plate Fair
G Unknown 128 8.5 Concrete block Concrete Fair
H Unknown 128 8.5 Concrete block Concrete Fair; bad roof
,
I .Unknown 144 8.5 Concrete block Concrete Fair
J Contains Boiler 140 9 Concrete block Steel truss, Good
Corrugated Deck
K 150 9 Concrete block Steel truss, Good
----
Corrugated deck
Kl 84 9 Concrete block Wood ; Fair
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I
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iN
I
TABLE 1
RESULTS OF THE BUILDING
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
PAGE TWO
INVENTORY
<..;
Materials of Construction
Building Area Height Condition
10 Name or U6e (Feet2) (Feet)
Wa 11 s Roof
252 11 Concrete block Steel truss,
L ---- Poor
Corrugated deck
IV Garage 800 11 Concrete block Steel truss, Good
M Area Corrugated deck
Warehouse 4,050 13 Concrete block Steel truss, Fair; bad roof
N Corrugated deck
o Blending Room 800 13 Concrete block Steel truss, Poor; bad roof
Corrugated deck
P Mill Room ---- ---- ---- --- Pile of debris
Q Shipping and 9,454 14 Concrete block Steel truss, roof
Receiving Warehouse Coccugated deck Poor; bad
R Warehouse No. 3 3,240 14 Concrete block Steel truss, Fair;
Corrugated deck bad roof
S Drying Building 3,558 12 Concrete, Steel truss,
Concrete block Corrugated deck Poor
T Storage Fac i li ty 1,023 8 Corrugated metal Steel truss, Fair
Coccugated deck
Ul, U2, Concrete Bunkers 1,150 8 Concrele, Reinforced
U3, U4 Concrete block concrete Good
V 91 7 Concrete, Reinforced
---- Not evaluated
Conc::rete block concrete
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I
TABLE 1
RESULTS OF THE BUILDING
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
PAGE THREE
INVENTORY
Materials of Construction
Building Use Area Height Condition
ID Name or (Feet2) (Feet)
Walls Roof
Bunker 240 8 Concrete, Reinforced Good
W Concrete block concrete
Bunker 480 8 Concrete, Reinforced Good
X Concrete block concrete
Bunker 230 8 Concrete, Reinforced Good
Y
Concrete block concrete
Boiler 5,985 17 Concrete block Steel truss, Fair; bad roof
Z House Cocru
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,
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U1
I
TABLE 2
SUMMARY OF PLANT EQUIPMENT
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
ID Numbed 1) Description Drawing Process Area or Dimensions Decontamination
D-l Area Building (2) Required?(3)
RI0055 Reactor 1 6A/PI 3.5-foot d x 4-foot h Yes
RI0056 Reactor I 6A/PI 2.5-foot d x 3-foot h Unknown
RI0057 Reactor 1 6A/PI 4-foot d x 4-foot h Yes
RI0060 Reactor I 6A/PI 3.5-foot d Ie 4-foot h Yes
RI0061 Reactor I 6A/PI 2-foot d x 2.S-foot h Yes
RI0062 Reactor 1 6A/PI 2.5-foot d x 3-foot h yes
HX3 Heat Exchanger 1 6A/PI 6-foot d x 6-foot h Unknown
RI0068 Reactor 1 6A/PI NA Yes
HXl Heat Exchanger 1 6A/Pl NA Unknown
HX2 Heat Bxchanger I 6A/PI NA Unknown
RIOOH Reactor I 6/P2 6-foot d x 6-foot h Yes
RIOOH Reactor I 6/P2 eO-inch d x 72-inch h Yes
RI0075 Reactor I 6/P2 80-inch d x 72-inch h Yes
RIDD8l Reactor I 6/P2 72-inch d x 48-inch h Yes
RI0092 Reactor I 6/P2 72-inch d x 72-inch h Yes
RI0093 Reactor I 6/P2 72-inch d x 72-inch h Yes
RI0083 Reactor I 6/P2 54-inch d x 72- inch h Yes
RIDD8S Reactor 1 6/P2 60-inch d x 84-inch h Yes
RI0086 Reactor I 6/P2 66-inch d II 96-inch h Yes
SCI Scrubbing Column I 6/P3 2-foot d x 3D-foot h Unknown
SC2 Scrubbing Column I 6/P3 1.5-foot d x IS-foot h Unknown
-------
I
......
0\
I
."
TABLE 2
SUMMARY OF PLANT EQUIPMENT
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
PAGE TWO
10 Numbed 1) Description Drawing Process Area or Dimensions Decontamination
0-1 Area Building(2) Required?()
SC3 Scrubbing Column I 6/P2 2-foot d It 30-foot h Unknown
SC4 Scrubbing Column I 6/P2 I.S-foot d x IS-foot h Unknown
---- )/4-Inch PUlip I 6/P2 NA Unknown
---- I-Inch Pump I 6/P2 NA Unknown
---- 1-1/2-Inch Pump I 6/P2 NA Unknown
---- 2-lnch Pump I 6/P2 NA Unknown
---- 2-Inch Pump I 6/P2 NA Unknown
---- ]-Inch Pump I 6/P2 NA Unknown
---- 2-Inch Pump I 6/D "A Unknown
VCI Vapor Condenser I 6/P2 NA Unknown
VC2 Vapor Condenser I 6/P2 NA Unknown
HXl Heat Exchanger I 6/P2 NA Unknown
812 Heat Exchanger I 6/P2 NA Unknown
HI3 Heat Exchanger I 6/P2 NA Unknown
814 Heat Exchanger I 6/P2 NA Unknown
RI0092 Reactor I 6/P2 NA Yes
RI009] Reactor I 6/P2 NA Yes
---- Plate Fi Iter I 6/P2 14-foot I Yes
HX Heat Exchanger I 6/P2 ]-foot d x 12-foot 1 Unknown
---- 4-lnch Roots Blower I E NA No
-- -- 200-hp Package Chiller I E NA No
-------
I
I-'
-..J
I
TABLE 2
SUMMARY OF PLANT EQUIPMENT
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
PAGE THREE
ID Numbed 1) Description Drawing Process Area or Dimensions Decontamination
D-l Area Building(2) Required?(3)
---- Drum ri Her I 6/P3 NA Unknown
---- IOO-hp Centrifuge I 6/D NA Unknown
RlOllO Reactor I 4/P4 6-foot d x 7-foot h Yes
RI01l9 Reactor I 4/P4 6-foot d x 8-foot h Yes
RI01l2 Reactor I 4/P4 7-foot d x 18-foot h Yes
RIOI08 Reactor I 4/P4 1-foot d II: 18-foot h Yes
HXl Heat Exchanger I 4/P4 1.5-foot d x 6-foot h Unknown
---- Drum Fi Her I 4/1' 2-foot d x )-foot 1 Unknown
---- 2-lnch Pump I 4/1' NA Unknown
---- 2-lnch Pump I 4/1' NA Unknown
---- 3-lnch Pump I 4 NA Unknown
---- J-Inch Pump I 4/1' NA Unknown
---- Pressure ri Her I ---- 1.5-foot d x 2-foot h Yes
-- -- Roots Air Blower I ---- NA No
---- 2-lnchPump I 4/p4 NA Unknown
RI0147 Reactor II Il/P5 42-inch d x 60-inch h Yes
RIOl49 Reactor II ll/P5 36-inch d x 54-inch h Yes
RIOl51 Reactor II ll/P6 24-inch d x 48-inch h Yes
RIOl55 Reactor II ll/p7 60-inch d x 75-inch h Yes
---- 1-1/2-lnch Pump II ll/P5 NA Unknuwn
HTRI0048 Process Heater II II/P5 3-foot d x 5.5-foot h Yes
-------
I
......
co
I
I .
~
TABLE 2
SUMMARY OF PLANT EQUIPMENT
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
PAGE FOUR
10 Numbed I) De8cdption. Drawing Process Area or Dimensions Decontamination
0-1 Area Build ing (2) Required?(J)
HI(I) Heat Exchanger II 1l/P6 8-inch d x 5-foot 1 Unknown
HI(2) Heat Excha~ger II 1l/P7 I-foot d x IO-foot 1 Unknown
HI(3) Heat Exchanger II U I-foot d x 6-foot I Unknown
RI017) Reactor II 10/PB 6-foot d x 7-foot h Yes
RI0175 Reactor II 10/PB 6-foot d x 6-foot h Yes
---- Process Heater II U/J 4-foot x 5-foot x 5-foot Unknown
HX(I) Heat Exchanger II II/P9 NA Unknown
---- Fractionating Column II U/P9 12-inch d x 15-foot 1 Yes
RI0160 Reactor II 11 4-foot d x 4-foot h Yes
RI0162 Reactor II U 5-foot d x 5-foot h Yes
RI0216 Reactor III 13A 4-foot d x 5-foot h Yes
RI0219 Reactor III 13A 4.5-foot d x B-foot h Yes
RI0214 Reactor III 13A B-foot d x 8-foot h Yes
RI0226 Reactor III 13A IO-foot d x ll-foot I Yes
RI0228 Reactor III 13A 6-foot d x 8-foot I Yes
HI(4) Heat Exchanger III 13A I-foot d x 12-foot 1 Unknown
---- Drum Fi Iter I II 13A 2-foot d x 3-foot 1 Yes
HI(I) Heat Exchanger III 13A/P 1 0 18-inch d x B-foot I Unknown
HI(2) Heat Exchanger III 13A/PI0 3-foot d x 8-foot I Unknown
81(3) Heat Exchanger III 13A/PIO 6-inch d x IO-foot 1 Unknown
-------
I
.....
\0
I
TABLE 2
SUMMARY OF PLANT EQUIPMENT
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
PAGE FIVE
ID Number ( 1) Description Drawing Process Area or Dimensions Decontamination
D-I Area Building(2) Required?(J)
FT Fractionating Column III lJA/P 1 0 14-inch d x 70-foot h Yes
RIOl8l Reactor I II lJA/PIO ('-foot d x 7-foot h Yes
Rl0182 Reactor III 1JA/P 1 0 4-foot d x 6-foot h Yes
RI018J Reactor III HA/PIO 7-foot d x 8-foot h Yes
1JA/PIO 7-foot, 4-inch d x
Rl0184 Reactor III 9-foot, 9-inch 1 Yes
RI0200 Reactor III 14B 4-foot d x 6-foot h Yes
RI0420 Reactor II Building L 4-foot d x I-foot h Yes
RI042J Reactor II Building L )-foot d x 2-foot h Ye:>
---- 2-Inch High Vac Pump II Building L NA Unknown
RI0021 Reactor IX 8/Pll 4-foot d x 6-foot h Yes
RI0004 Reactor IX 8/PII 8-foot d x IO-foot h Yes
RlOOl9 Reactor IX 8/Pll 7-foot d x IO-foot h Yes
RI0018 Reactor IX 8/Pll IO-foot d x ll-foot h Yes
RI0022 Reactor IX 8/Pll NA Yes
HX(I) Heat Exchanger IX 8/Pll 6-inch d x 24-inch I Unknown
HX(2) Heat Exchanger IX 8/Pll I-foot d x IO-foot h Unknown
HX(J) Heat Exchanger IX 8/Pll 1. 5-foot d x IO-'foot h Unknown
HX(4) Heat Exchanger IX 8/Pll 1.5-foot d x IO-foot 1 Unknown
HX(5) Heat Exchanger IX 8/PII I-foot d II IO-foot I Unknown
-------
I
'"
o
I
..:
TABLE 2
SUMMARY OF PLANT EQUIPMENT
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
PAGE SIX
ID Numbed 1) Description Drawing Process Area or Dimensions Decontamination
D-l Area Building( 2) Required?(])
HX(6) Heat EKchanger IX 8/Pll I-foot d x 10-foot I Unknown
HX(7) Heat Exchanger. IX 8/Pll I-foot d x 12-foot 1 Unknown
HX(8) Heat EKchangec IX 8/Pll I-foot d x 10-foot I Unknown
HX(9) Heat EKchanger IX 8/PH I-foot d x 8-foot 1 Unknown
SC (l) Scrubbing Column IX 8/Pll I-foot d x 20-foot h Yes
SC(2) Scrubbing Column IX 8/Pll I-foot d x 10-foot h Yes
SC(]) Scrubbing Column IX 8/Pll IO-inch d x ]0 foot h Yes
---- I-Inch Pump IX 8/Pll NA Unknown
-- -- 2-lnch Pump IX 8/PII NA Unknown
---- 4-lnch Pump IX 8/PH NA Unknown
PC(I) Process Column IX 8/Pll I.S-foot d x 10-foot h Yes
---- Roots Blower IX 8/Pll NA No
---- 2 Air Compressors VII Building 2 NA No
(SO-hp)
---- Boiler VII Building 2 NA No
2 Plate Filters VII Building BB 10 feet long
--- - Yes
(3 ft x 3 ft)
---- 3 Centrifugal VII Building AA 4-inch diamet'er Unknown
Cooling Tower Pumps
10409 Mixers (Screw) X Building S ]I)-inch d x 8-foot 1 Yes
-------
TABLE 2
SUMMARY OF PLANT EQUIPMENT
FIKE/ARTEL SITE
NITRO, WEST .VIRGINIA
PAGE SEVEN
ID Number(l) Description Drawing Process Area or Dimensions Decontamination
D-l Area Building(2) Required?(3)
---- Mixers (Tumbler) X Building S 60-inch diameter drum Yes
---- Mixer (Screw) X Building S 36-inch d x 36-inch 1 Yes
2 Suecco Vibrating VII Building Z 24-foot diameter Yes
----
Screens
NA
( 1 )
I
IV ( 2 )
....
I
( 3)
Not available
ID number are five-digit numbers preceded by an "R" refer to equipment included in
the tank data base; heat exchangers (HX), scrubbing columns (SC), and vapor
condensers (VC) are numbered consecutively within each process area.
Process area numbers are shown on Figure 1-2 of the Focused Feasibility Study (FFS);
buildings identified with a letter are located on Drawing D-l of the FFS.
The determination as to whether decontamination is required is tentative; based on
information collected to date for use in cost estimating purposes only; actual
decontamination requirements will be determined in the field.
The following basis was used in this table:
Decontamination is required (Yes) if equipment was observed to contain materials,
products, or residue during the course of the ERT or REM III field investigations;
or, if a positive OVA or LEL reading was obtained; or if oxygen concentration was'
less than 20.9 percent. Other equipment not surveyed for contents was determined to
require decontaminating if it could have been used for reacting, separating, or
processing chemicals or waste streams during plant operations.
Decontamination is not required (No)
waste storage or processing device.
if the equipment was not used as a chemical or
Unknown indicates insufficient data available to make determination.
-------
TABLE 3
OVERHEAD PIPING SUMMARY
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
-f
Length of Overhead Pipe (feet)
Pipe Diameter
(inches) Utility Service(l) Product/Material
Conveyance
6 410 --
4 1,095 --
3 370 --
2 425 --
1-1/2 4,425 1,200(3)
1 505 280(2)
3/4 905 --
1/2 330 --
TOTAL 8,465 1,480
( 1 )
( 2)
Utility service includes steam, condensate, brine
(refrigerant), air, and inert gas transfer
pipelines.
Methyl mercaptan transfer line between Areas III
and VI.
Carbon disulfide, ammonia, mercaptan, and xylene
transfer lines between railroad line and tank farm
adjacent to Building W.
( 3)
-22-
-------
in nature. A significant portion of the piping is unstable
and/or serves as an obstacle to investigation equipment
(e. g., dr illing rig). Pipes carrying chemical- product/mater ial
are likely to contain residual contaminants.
Approximately 425 tanks were used to store a variety of liquids,
solids, and gases. These vessels contained raw chemicals, waste
materials, and final products during operation of the facility.
As of June 1990, the tanks of concern contained an estimated
83, 000 gallons of chemical materials (see Table 4). While the
majority of these materials shall be removed under the authority
of the existing ROD for OU-l, the tanks and significant chemical
residuals will remain upon completion of this action. A
complete inventory of the tanks and their (former) contents
appears in Appendix D of the FFS. In addi tion to contaminant
residuals, the structural integrity of many tanks presents a
concern. Many of the tanks have corroding supports which may
result in tank collapse. The tanks also present a significant
obstacle to the safe investigation of underlying soils.
Finally, an asbestos survey has identified an estimated 5.5 tons
of asbestos on si te. Pertinent information is summar ized in
Table 5. Approxima tely 4.5 tons is friable and associated wi th
insula t ion for the tanks and process lines. The balance of the
asbestos is non-friable and primarily associated with t~e
buildings. In many cases, the friable asbestos is highly
deteriorated.
SUMMARY OF SITE RISKS
Based on observations made during the FFS, the hazards and risks
associated with tanks, equipment, and buildings have been
identified as follows: .
. Many of the facility structures are in poor condition and
could collapse in the near future, while many other
structures will collapse without continued maintenance.
This si tuation poses a safety hazard to people on site.
In addition, collapse of a tank containing chemical
residuals may present an unacceptable risk to residents.
.
Friable asbestos associated with the facility may be
released into the air and present an unacceptable short-
term health risk, while additional asbestos may be
released over a ~onger term and present an unacceptable
risk. Asbestos is a known human carcinogen.
. The facili ty components present an obstacle to potential
future si te work. Wi thout removal of the these
components, a comprehensive investigation of contamination
remaining at the site cannot be completed.
-23-
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TABLE 4
TANK WASTE VOLUMES
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
Waste Type( 1) Waste Volume Compatability
(gallons) (2) -Groups Included( 3)
Inorganic Acids 30 AL
Inorganic 12,836 BNL, BNSOL
Base/Neutrals
Cyanide 14,004 CNL, COCNL, ACNL, OCNL, FCOCNL,
CNSOL, FOCNSOL, OCNSOL
Flammable 94 FSOL, FAOL
Organics 16,627 OL, FCOL, COL, OSOL, COSOL,
FCOSOL
Oxidizers 60 AOXSOL
Reactive 5,042 R (SOL)
Sulfide 32,464 SL, FOSL, OSL, FSL, FSSOL, OSSOL,
SSOL
Unknown 1,691
Total 82,848
(1) Waste types categorized using compatability groups shown for
treatment technology screening. Does not include dioxin-
contaminated sludges in Tanks 10307 and 10342-351
(66,693 gallons).
(2) Volume calculations based on data collected dur ing
Remedial Investigation, October-November 1989
dimensions and depth of waste). Confirmed by
inspection, May 1990 and ERT inspection, June 1990.
(3) Compatabili ty groups determined by EPA Emergency Response
Team based on samples of tank waste. REM III tank survey
data used to determine phase of material (liquid or
sOlid/sludge).
REM III
(tank
REM III
Glossary of compatibility groups:
A
BN
CN
CO
F
L
Acidic
Base Neutral
Cyanide
Chlorinated
Flammable
Liquid
organic
o Organic
OX Oxidizer
R Reactive
S Sulfide
SOL Solid
-24-
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TABLE 5
ESTIMATED AMOUNT OF ASBESTOS-CONTAINING MATERIAL
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
Material Amount of ACM(2)
Pipe insulation(l) 623 LF
Tank insulation 302 SF
Roofing 3,900 SF ( 3 )
Cooling tower walls 800 SF(3)
Furnace gasket 10 SF
Bulk 54 CF
623 LF;
TOTALS 5,012 SF;
54 CF
623 LF;
TOTAL FRIABLE ACM 312 SF;
54 CF
( 1 )
( 2)
Pipes under 6-inch diameter.
Units:
LF = Linear Feet (small-diameter piping);
SF = Square Feet;
CF = Cubic Feet, insulation in piles around
This material is. considered as ACM but
friable.
site.
is not
( 3 )
-25-
-------
.
Contaminant residuals in tanks, equipment, and/or
structures may present an unacceptable he~lth risk through
direct contact pathways. In addition, a fire may release
the contaminants of concern to the local community, posing
an unacceptable risk to residents. Many of the
contaminants of concern are defined as hazardous under
RCRA or are otherwise known to be toxic.
While risks due to direct contact wi th contaminant residuals
cannot be quantified at this time, actual or threatened releases
of hazardous substances in the residuals, if not remediated, may
present an imminent and substantial endangerment to public
health, welfare, or the environment as set forth in Section 106
of CERCLA, 42 U.S.C. Section 9606.
REMEDIAL ACTION OBJECTIVES.
The objectives of remedial actions addressing
equipment, and structures are as follows:
the
tanks,
.
Eliminate safety hazards
components of the facility.
associated
with
unstable
.,
. Eliminate unacceptable health risks posed by asb~stos.
. Reduce obstacles to future site investigation.
. Eliminate unacceptable health and environmental risk posed
by contaminant residuals.
DESCRIPTION OF ALTERNATIVES
In the FFS, engineering technologies applicable to the remedial
action objectives were identified and evaluated. The
technologies determined to be most applicable were developed
into remedial alternatives. The remedial alternatives for
tanks, equipment, and structures are descr ibed below and are
numbered to correspond to the alternative numbers in the FFS
report.
ALTERNATIVE Dl - NO ACTION
This alternative will not include any remedial actions to
address the unacceptable risks associated with the tanks,
equipment, and structures at the former chemical processing
facility. Since existing safety and health risks would remain,
this alternative would not be protective of human health or the
environment. This alternative is required by the NCP and is
used as a baseline for compar ison with other remedial
alternatives for the tanks, equipment, and structures.
ALTERNATIVE D2 - FENCING
Under this alternative, portions of the existing perimeter fence
would be, replaced, as needed. The replacement would match the
-26-
-------
existing fence. The length of the section to be replaced is
estimated to be 1,100 feet. While this alternative would reduce
health and safety risks of concern, it would not be protective
of human health and the environment.
Fencing would not comply with action-specific ARARs.
Significant action-specific ARARs include those addressing RCM
tank closure. RCRA closure requirements are also applicable or
relevant and appropriate to the site equipment or structures
which contain RCRA hazardous waste or material sufficiently
similar to a hazardous waste, respectively. RCM closure
requirements include decontamination and/or secure disposal.
ALTERNATIVE D3 - TANK REMOVAL
This alternative involves dismantling and decontamination of
approximately 425 tanks. Approximately 240 cubic feet of
asbestos-containing tank and process line insulation (all
identified friable asbestos) would be removed and disposed in an
offsite landfill for nonhazardous waste meeting requirements of
40 CFR Section 61.156. Other facility components, such as
buildings and foundations, would not be removed. Decontaminated
tanks would be sold as scrap, recycled, or disposed in an
offsite RCRA Subtitle C or RCRA Subtitle D landfill. Tanks that
contain a RCRA waste and that cannot be decontaminated would be
disposed in an offsite RCRA Subtitle C landfill.
Decontamination fluids (estimated to be approximately
30,000 gallons) generated dur ing tank cleaning operations would
be treated at the CST plant. Decontamination fluids would be
stored in a tank prior to treatment by the CST plant. The
existing perimeter fence would be maintained.
This alternative will comply with RCRA tank closure standards,
OSHA standards, and West Virginia air pollution control
regulations. The RCRA closure standards for tanks
(40 CFR Part 265, Subpart J) would be applicable for any tanks
that contain or are contaminated wi th RCRA hazardous wastes.
RCRA tank closure standards are relevant and appropr iate for
tanks containing materials similar to RCRA wastes. RCRA tank
closure standards require decontamination and/or proper disposal
of tanks.
OSHA standards (see Table 6) are applicable for the remedial
activities of concern. The removal and disposal of asbestos are
regulated under the Clean Air Act (40 CFR Part 61, Subpart M).
State air pOllution control regulations in WVCSR 45-8, 9, 12,
and 17 are applicable and include requirements to prevent and
control particulate air pollution, including fugitive emissions,
from materials handling.
-27-
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TABLE 6
APPLICABLE OR
RELEVANT AND APPROPRIATE REQUIREMENTS
FOR SELECTED REMEDY
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
(ARARs)
.,
Action-Specific ARARs
Citation Description
29 CFR 1904(*) OSHA - Recordkeeping and reporting of
occupational injuries and illness.
29 CFR 1910(*) OSHA - Occupational, safety and health
standards for employees engaged in handling
hazardous materials.
20 CFR 1926(*) OSHA - Safety and health regulations for
construction.
40 CFR 258 Proposed minimum design standards for
location, design, operation, and closure of
municipal solid waste landfills. .'
40 CFR 262 Federal and state standards applicable to
WVCSR 45-45-8.6 generators of hazardous waste.
40 CFR 263 Federal standards applicable to
transporters of hazardous waste.
49 CFR 107 and DOT requirements for transport of hazardous
171-179(*) materials.
40 CFR 265 Federal and state standards for closure and
Subpart G and post-closure of hazardous waste facilities.
WVCSR 47-35-8.6
40 CFR 265 Federal and state standards for hazardous
Subpar.t J and waste tanks including closure and post-
WVCSR 47-35-9.8 closure requirements.
-28-
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c: Alternative D1 - No Action, or Alternative D2 - Fencing,
should be selected at this time. EPA and the state of West
Virginia should defer consideration of the Proposed Plan until a
full Remedial Investigation/Feasibility Study for the site is
complete.
R: The National Contigency Plan, Section 300.430 (a) (1) (ii) (A),
provides that "sites should generally be remediated in operable
units when early actions are necessary or appropriate to achieve
significant risk reduction quickly, when phased analysis or
response is necessary or appropriate given the size or complexity
of the site, or to expedite the completion of a total cleanup".
In this case, implementation of the selected alternative is part
of a phased remedial response which is appropriate for the
specific conditions of the site. In particular, removal of
facility components is necessary to provide access for the
Remedial Investigation of soils and buried. materials.
Furthermore, removal of obstacles to future investigation will
expedite the completion of full site cleanup.
In addition, unstable tanks, equipment and/or structures
constitute a safety hazard to personnel conducting on-site
investigation activities and chemical residuals within these
components present a potential, unacceptable risk to human health
in the event of a fire or release due to structural collapse.
Due to these conditions, it is necessary to implement the
selected remedy quickly.
-------
.,
Attachment A
Comments on U.S. EPA Region III
Proposed Plan
F1ke/Artel Chemical S1te
July 1990
1. The proposed plan 1s not consistent with the July 1990 Focused Feasibility
Study (FFS). On FFS Page ES-5 it is stated for Alternative D4, the
Preferred Alternative in the Proposed plan, "This Alternative, requires
1mplementations of tank waste remed1al alternative T3, T4, or T5". (See
also FFS page 6-18, paragraph 6). Tank waste remedial alternatives are
not discussed in the Proposed Plan. However, the Proposed Plan indicates
83.000 gallons of wastes contained in the tanks shall be removed during
work authorized by the September 1988 ROD. '
Are the 83,000 gallons of wastes mentioned in the Proposed Plan the same
wastes addressed under FFS Tank Waste Alternatives? If so, to what degree
w.i11 the tanks be cleaned out prior to implementation of Alternative 04?
What is the RCRA classification of any residual and the corresponding LOR?
2.
.
The present worth cost for Alternative 04 is given in the FFS as
$2.830.000 and is given in the Proposed Plan as $2,830,000 on Page 3 and
as $3.090, 000 on Page 4.
In Paragraph 2 of Page 2-8 of the FFS, it is stated that some wastes in "
the tank may be RCRA hazardous wastes and the debris that results from
tank and facility dismantling may also contain RCRA hazardous wastes
subject to LORs. The data available on the contents of the tank are
limited (See FFS, Page 4-6, Paragraph 5; and Page 4-13, Paragraph 5, and
Page 4-15, Paragraph 4). These data are not sufficient to properly
classify the wastes for toxicity characteristic (TC) or as California List
wastes. In addition, no information on the presence of RCRA listed wastes
is discussed in the FFS. A determination on compliance with ARARs cannot
be made nor can proper offsite treatment/disposal be specified without
proper RCRA waste classification. These data are typically obta1ned
during the Remedial Investigation and are required for use 1n the
Feasibility Study. Without proper characterization and classification of
the wastes the feasibility of the Proposed Plan cannot b. evaluated. More
work on the Remedial Investi,gation 15 warranted.
3.
4. The lack of data on. the tank contents a150 casts doubt on the feasibl1ity
of treat'ng decontam1nat10n fluids at the CST. In the absence of data, it
1s "assUl8dw in the FFS that decontamination fluids can be treated at the
CST (se. FFS Page 5-19, Paragraph 4). This assumption cannot be tested.
even conceptually, without further analysis of the wastes.
In Alternative 04, decontamination fluids are to be treated at CST. The
cost estimate conta1ns zero cost for dtsposal (see Appendtx E. Alternative
No. 04, Sheet 2 of 6). Why are there no disposal costs?
5.
6. Who will operate the CST?
7. Are permits requ1 red for d1scharge from CST to the Kanawha River? If so.
who ts the perm1ttee?
-------
Attachment A
Comments on U.S. EPA Region III
Proposed Plan
Fike/Artel Chemical S,te
July 1990
(Continued)
8.
Is CST 1n compl'ance with RCRA ARARs for TSD faci11t1es? The FFS
1nd'cates some wastes, and therefore, some decontaminat'on fluids may be
RCRA wastes. Three basins at CST are used for equalization (see FFS, Page
3-24 and Page 4-5, Paragraph 4). Are these basins in comp11ance w1th RCRA
Minimum Technology Requirements (MTR)?
The FFS 1nd'cates 66,693 gallons of d'oxin-contaminated material's stored
1n tanks but also 1nd'cate that no data beyond compat1b1l,ty test1ng are
ava11able on tank contents. How were diox1n-contam'nated materials
identified? How were other wastes ver'fied as dioxin-free? What data are
available on d'oxin concentrations at the site?
9.
10. Hill tanks containing dioxin-contaminated material be dismantled? If so,
what will be done with the dioxin-contaminated material? If not, the
Proposed Plan should specify that these tanks will remain.
JWV:sk
8247E
9/6/90
-------
Below is the response of EPA to comments in Attachment A (which
follows). EPA responses are numbered to correspond to the
comments of concern.
1. Removal of the contents of onsite tanks is authorized by the
ROD for Operable Unit One (OU-1) dated September 29, 1988. The
Focused Feasibility Study dated July 1990 evaluates technical
alternatives for removing materials remaining in tanks as of July
1990. However, since the removal of the remaining tank contents
has already been authorized by the ROD for OU-1, there is no
discussion regarding this technical alternative evaluation in the
Proposed Plan of July 1990.
The ROD for OU-2 authorizes the decontamination and removal of
the tanks of concern. The precise amount of residual chemical
removed during the decontamination stage will vary from tank to
tank. As noted above, removal of the tank contents is authorized
by the ROD for OU-1.
The Administrative Record for the site contains information
regarding the RCRA classification of the contents of the tanks. .-
The RCRA classification of a residual in a given tank will likely
be the same as the classification of the former tank contents.
Land Disposal Restrictions will be as specified for a particular
waste by RCRA.
2. The estimated present worth of the selected remedy is
$2,830,000.
3. The "Tank Waste Disposal Log" in the Adminstrative Record
contains information regarding the RCRA classification of the
tank contents. This information shall be utilized to help
address residuals in the tanks of concern. While residuals in
equipment and structures have not been characterized at this
time, the selected remedy for equipment and structures
anticipates contained residuals mayor may not contain RCRA
wastes.
4. Given the nature of materials in the tanks (see Appendix D of
the FFS) and the nature of the CST plant (see "Service Manual for
the cooperative Sewage Treatment Plant" dated March 1990 in the
Administrative Record), the CST apparantly can treat the majority
of liquid generated during tank decontamination. Should the CST
be unabie to treat particular decontamination fluids with current
equipment, the necessary equipment would be added or the fluids
would be treated/disposed off-site. If the fluids are treated
and/or disposed offsite, Land Disposal Restrictions under RCRA
may be applicable.
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5. The CST plant is operated daily at this time by EPA (as
authorized by the ROD for OU-1) to treat contaminated stormwater
generated onsite. The addition of decontamination fluids to the
plant influent is projected to have a minimal impact on the cost
of CST operation. As a result, for cost estimation purposes, it
was assumed that no additional cost would be incurred.
6. As noted above, current operation of the CST by EPA is
authorized by the ROD for OU-1. In the future, the plant may be
operated by the US EPA or consenting potentially responsible
parties.
7. Pursuant to Section 121 (e) of CERCLA, 42 U.S.C. section 9621
(e), no federal, state or local permit is required for remedial
work conducted entirely onsite. However, the EPA (or whichever
party performs the work) is required to meet the substantive
requirements of an NPDES permit for the CST plant. Current
requirements have been jointly developed by the West Virginia
Division of Water Resources and the US EPA. (See Table 2-3 of the
FFS)
8. Because the CST basins do not meet RCRA Minimum Technology
Requirements, fluids generated during decontamination of facility
components shall be stored in a tank prior to treatment:
9. An RI/FS Workplan for the site contains data on the estimated
66,000 gallons of waste stored in ten large tanks in the Waste
Area (as opposed to the Process Area) of the site. The Workplan
is included in the Administrative Record. As reflected by data
in the Workplan, each of these tanks contain waste contaminated
with dioxin. . The Workplan includes additional available data
which indicates other locations of dioxin contamination onsite.
10. The tanks containing waste contaminated with dioxin will not
be dismantled under the remedy for OU-2. The EPA is currently
evaluatinq alternatives for remediation of dioxin-containing
materials'onsite.
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II. RESPONSIVENESS SUMMARY
~ .
"', The public comment period for this Proposed Plan extended from
July 25, 1990 to September 22, 1990. Below is a summary of
comments on the Proposed Plan submitted to EPA during the public
comment period and provided verbally to EPA during a public
meeting held on August 6, 1990. Original written comments and a
transcript of the public meeting are included in the
Administrative Record. Also included below are EPA responses to
the comments of concern.
In many cases, comments submitted during the public comment
period of concern were regarding the FikejArtel Site, but not on
the Proposed Plan issued on July 25, 1990. These comments are
included in the Administrative Record but are not included in
this responsiveness summary for the subject Proposed Plan.
Comment (C): It is unclear how much asbestos is onsite.
Response (R): As noted in the Proposed Plan and the FFS, the site
contains the following aSbestos-containing material at this time:
pipe insulation (over 600 linear feet), tank insulation (300
square feet), cooling tower walls (800 square feet), roofing
(3,900 square feet) and bulk material (50 cubic feet). Pipe and
tank insulation is considered to be friable, as well as the bulk
material. All of the above figures are estimates based on
observations.
C: Many of the materials being removed from the site by EPA
under OU-1 are raw materials, finished products, in-process'
chemicals and by-products.
R: The EPA agrees this may be the case. Many of the materials
being removed, while not hazardous wastes under RCRA, present a
similar threat to public health and the environment given current
conditions at the abandoned facility.
C: The EPA should abandon the site. Used equipment should then
be sold and the proceeds used to satisfy liens for taxes,
employee wages and benefits, and other legitimate claims.
The procedures utilized for decontaminating should be consistent
with those being used in other plants in the Kanawha Valley.
Furthermore, this party has offered his services at no cost to
assist in the process of equipment decontamination.
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R: The EPA has evaluated the No Action (or abandonment)
alternative for tanks, equipment and structures at the site.
This evaluation has concluded that this alternative does not
address unacceptable risks identified on pages 23 and 26, and is
not protective of public health and the environment. Therefore,
this al~ernative has been rejected.
Used equipment from the site may be sold for the purposes noted
above. However, the equipment of concern must be decontaminated
per applicable or relevant and appropriate requirements under
RCRA (40 CFR Part 265, Subparts G and J) prior to sale.
Decontamination requirements for equipment in this case will
differ from those requirements for actively operating plants due
to facility closure requirements under RCRA and remedial
requirements under CERCLA.
EPA will cooperate with responsible parties with regard to the
'sale of equipment provided that associated activities do not
unduly interfere with the remedial action selected in this ROD.
A potentially responsible party may participate in the site
remediation. However, the terms of such participation may be
subject to a consent agreeement between the party of concern and
EPA.
"'
C: Does the selected alternative include
aSbestos-containing materials, as defined
in a disposal site operated in accordance
61.156.
disposal of all
by the Clean Air Act,
with 40 CFR Section
R:
Yes. The remedy includes such a requirement.
C: The only acceptable alternative for the continuation of the
cleanup process is Alternative D5 - Complete Facility Removal.
R: The EPA agrees that complete facility removal is necessary in
this case. However, at this time, the EPA and the state of West
virginia believe that concrete pads and building foundations
should be left in place to be addressed by a subsequent remedy.
The concrete of concern is known to cover highly contaminated
soil in many cases. Should the concrete be removed, the soil of
concern shall be exposed and resultant health risks to both
onsite workers and local residents may reach unacceptable levels.
Therefore, the concrete should be left in place until a remedy
for underlying soil is implemented.
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TABLE 6
APPLICABLE OR RELEVANT
FOR SELECTED REMEDY
FIKE/ARTEL SITE
NITRO, WEST VIRGINIA
PAGE TWO
AND APPROPRIATE REQUIREMENTS (ARARs)
Chemical-Specific ARARs
Citation Description
40 CFR 50(*) National ambient air quality standards for
carbon monoxide, lead, nitrogen oxides,
ozone, particular matter, and sulfur
dioxide.
WVCSR 45-8, 9, State ambient air quality standards for
and 12(*) sulfur dioxide, particulate matter, carbon
monoxide, ozone, nonmethane hydrocarbons,
and nitrogen dioxide.
wveSR 45-17(*) State regulations to prevent and control
particulate air pollution from materials
handling, preparation, storage, and sources.-
of fugitive particulate matter (material
handling), preparation and storage,
disposal areas, roads, haulways and parking
lots, vehicles, and construction and
demolition activities).
40 eFR 61(*) National emission standard for asbestos.
wveSR 46-2(*) Pollutant discharge eliminates system
regulations for point source discharges of
wastewater.
( * )
Indicates ARAR is known to be an applicable requirement to
the selected remedy at this time; other ARARs listed may be
applicable or relevant and appropriate requirements.
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Contaminated tanks containing a RCRA hazardous waste, if any,
would be transported to a hazardous waste landfill in compliance
wi th standards for hazardous waste generators and transporters
(40 CFR Parts 262 and 263) and DOT regulations pertaining to
transportation of hazardous materials (49 CFR Parts 107 and 171
through 179).
ALTERNATIVE D4 - PARTIAL FACILITY REMOVAL
.,
This alternative involves dismantling and decontamination of all
425 tanks, all. equipment, and all above-ground structures, with
the exception of a few bu~ldings which may be maintained as
storage facilities. Concrete slabs and foundations would not be
removed. Approximately 525 cubic feet of asbestos-containing
materials would be disposed in an offsite landfil~ for
nonhazardous waste meeting requirements of 40 CFR
Se~tion 61.156. Decontaminated tanks and other metal structures
would be sold as scrap, recycled, or disposed in a RCRA
~ubtitle C or Subtitle D landfill. Facility components that
contain a RCRA hazardous waste (or a substance sufficiently
similar to hazardous waste) and that could not be decontaminated
would be disposed at an offsi te RCRA Subti tIe C landf ill. The
existing perimeter fence would be maintained. Decontamination
fluids would be treated at the CST plant. Decontamination
fluids would be stored in a tank prior to treatment. Several
buildings may be left intact for use as storage during
remediation.
This alternative will comply with RCRA tank closure standards,
OSHA standards, and state air pollution control regulations.
The RCRA closure standards for tanks (40 CFR Part 265,
Subpart J) are applicable for any tanks and vessels that contain
or are contaminated with RCRA hazardous wastes. RCRA tank
closure standards are relevant and appropr iate . for tanks and
vessels containing materials sufficiently similar to a hazardous
waste. RCRA tank closure standards require decontamination
and/or proper disposal of tanks. RCRA closure standards (40 CFR
Part 265, Subpart G) are applicable for equipment and/or
structures containing a RCRA hazardous waste and relevant and
appropriate where ,equipment and/or structures contain a material
sufficiently similar to a RCRA hazardous waste.
OSHA standards (see Table 6) for
remedial acti vi ties of concern.
asbestos is regulated under the
Subpart M).
State air pollution control regulations in WVCSR 45-8, 9, 12,
and 17 are applicable and include requirements to prevent and
control particulate air pollution, including fugitive emissions,
from materials handling.
asbestos are applicable for the
The removal and disposal of
Clean Air Act {40 CFR Part 61,
Hazardous materials would be transported to off site facilities
in compliance with standares for hazardous waste generators and
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transporters (40 CPR Parts 262 and 263) and DOT regulations
pertaining to transportation of hazardous materials (49 CPR
Parts 107 and 171 through 179).
ALTERNATIVE D5 - COMPLETE FACILITY REMOVAL
This alternative involves dismantling and decontamination of the
entire chemical processing facility, including concrete slabs
and foundations. Asbestos-containing mater ials would be
disposed in an offsite landfill for nonhazardous waste meeting
requirements of 40 CFR Section 61.156. Decontaminated tanks and
other metal structures would. be sold as scrap, recycled, or
disposed in an offsite RCRA Subtitle C or Subtitle D landfill.
Facility components that contain a RCRA hazardous waste (or a
substance similar to a RCRA hazardous waste) and that could not
be decontaminated would be disposed at an offsite RCRA
Subtitle C landfill. The existing perimeter fence would be
maintained. Decontamination fluids would be stored in a tank
prior to treatment at the CST plant.
This alternative will comply with all identified ARARs,
including all RCRA closure standards, OSHA standards, and state
air pollution control regulations. The RCRA closure standards
for tanks (40 CFR Part 265, Subpart J) are applicable for any
tanks and vessels that contain or are contaminated wi th RCRA
hazardous wastes. Tank closure standards are relevant and
appropriate for tanks and vessels containing materials
sufficiently similar to a RCRA hazardous waste that are not
hazardous, as defined by RCRA. RCRA tank closure standards
require decontamination and/or proper disposal of tanks. RCRA
closure standards (40 CFR Part 265, Subpart G) are applicable
for equipment and/or structures containing a RCRA hazardous
waste and relevant and appropriate where equipment and/or
structures contain a mater ial sufficiently similar to a RCRA
hazardous waste.
OSHA standards (see Table 6) are applicable for the remedial
activities of concern. The removal and disposal of asbestos is
regulated under the Clean Air Act (40 CFR Part 61, Subpart M).
State air pollution control regulations in WVCSR 45-8, 9, 12,
and 17 are applicable and include requirements to prevent and
control particulate air pollution, including fugitive emissions,
from materials handling. . .
Hazardous mater ials would be transported to offsi te facili ties
in compliance wi th standards for hazardous waste generators' and
transporters (40 CFR Parts 262 and 263) and DOT regulations
pertaining to transportation of hazardous materials (49 CFR
Parts 107 and 171 through 179).
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SUMMARY OW COMPARATIVB ANALYSIS OW ALTBRNATIVBS
The NCP [40 CFR section 300.430(e) (9) (iii)]
alternatives be evaluated pursuant to the
criteria:
requires
followinq
that
nine
l)Overall Protection of Human Health and the Environment
Alternative 05 would include -the removal of the entire
facility, includinq concrete pads and foundations, and all
risks directly associated with the facility structures.
While all obstacles to future investiqations would be
removed, contaminated soil underlyinq the concrete would be
exposed with a resultant potential increase in risk.
Alternative 04 would siqnificantly reduce risks due to
direct contact, asbestos miqration, a~d structural collapse
by removinq all above-qround. stluctures of concern.
Concrete pads and foundations would remain in place to be
addressed by a future remedy. The majority of obstacles to
future investigation would be eliminated.
Alternative 03 would significantly reduce risks due to
direct contact and asbestos migration by removinq tanks and
associated residuals and asbestos associated with tanks and
process lines. Risks due to structural collapse would be
reduced by fencinq but would not be eliminated for onsite
workers. Many obstacles to future investiqation would
remain.
Alternative 02 would only reduce risks from direct contact
and injury to trespassers. Alternative 01 would not reduce
risks due to direct contact with tank residuals, miqration
of asbestos, or safety hazards from structural collapse.
In both cases, all obstacles to future investiqation would
remain.
2)Compliance with ARARs
Alternative 05 would meet RCRA clos~re ARARs under 40 CFR
Part 265.
Al ternati ve 04 would meet RCRA closure ARARs under 40 CFR
Part 265 for all portions of the facility, with the
exception of concrete pads and foundations, which would be
addressed in a subsequent remedial action.
Alternative 03 would meet all RCRA ARARs for tank closure
(40 CFR Part 265, Subpart J). However, RCRA closure ARARs
for the balance of the facility would be addressed in a
subsequent action.
Alternatives 02 and 01 would not be in compliance with RCRA
closure ARARs.
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3) Long-Term Effectiveness and Permanence
Alternative DS affords a high degree of long-term
effectiveness and permanence because all facility
structures would be removed from the site. However, soils
underlying excavated concrete will be susceptible to
offsite migration and may pose a direct contact risk until
addressed by a subsequent remedy. For Alternative D4, the
majority of above-ground structures and associated friable
and non-friable asbestos would be removed, but concrete
slabs and foundations would remain until addressed by a
subsequent remedy. For Alternative D3, only the tanks and
associated residuals and friable asbestos would be removed
leaving safety hazards associated with buildings and
significant obstacles to future investigation. Of the
action alternatives, Alternative D2 affords the lowest
degree of long-term effectiveness and permanence because
all of the facility components would remain in place.
4) Reduction
Treatment
of
Toxicity,
Mobility,
or
Volume
Through
Alternatives DS, D4, and D3 use surface cleaning to reduce
the toxicity of all nonporous materials, except for
piping, to be dismantled under the respective
alternatives. Decontamination fluids generated during the
surface cleaning operations would be treated at the CST
plant.
Alternatives Dl and D2 do not reduce
mobility, or volume of contaminants.
the
toxicity,
5) Short-Term Effectiveness
During the implementation of Alternative D2 there would
not be increased risks to the community or the
environment. However, existing' risks to workers due to
structural collapse would remain.
Alternatives D5, D4, and D3 are similar with respect to
short-term effectiveness. Measures would be required to
protect the public from potential air emissions during
dismantling and surface cleaning activities. Proper
adherence to safety practices would be required to protect
onsite workers. Measures would also be required to
protect the envi ronment from spills dur ing sur face
cleaning.
6) Implementability
No remedial
Alternative Dl.
actions
would
be
implemented
under
Alternatives D2
reconstruction.
through D5 require
The fencing would
fence repair
be reliable
and
in
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controlling
maintained.
unauthorized
access,
if
it
is
properly
Implementability considerations are similar for
Alternatives D3, D4, and D5, which involve removal of part
or all of the former processing facility. Construction of
the decontamination area and structural dismantling are
relatively straightforward. Decontaminated materials must
be tested to verify that they are clean. RCRA Subtitle C
and Subtitle D landfills are available.
7) Cost
The following are the estimated 30-year present-worth,
capital, and annual operation and maintenance costs of the
alternatives for the tanks, equipment, and structures:
-,
Annual
Alternative Present Capital Cost Operation &
Identification Worth Cost Maintenance
Cost
Dl $16,000 $0 $1,040
D2 $141,000 $61,500 $5,200 '-
D3 $1,130,000 $1,050,000 $5,200
D4 $2,830,000 $2,750,000 $5,200
D5 $6,465,000 $6,390,000 $5,200
8) State Acceptance
The State of West Virginia concurs with the selection of
Alternative D4.
9) Community Acceptance
Based on comments received during the public comment
period and at the public meeting, there is community
support for the selection of Alternative D4. See
Responsiveness Summary for a summary of public comments
and the response of EPA to these comments.
SELECTED REMEDY
Section 121 of CERCLA, 42 U.S.C. Section 9621, as amended by
SARA, and the National Contingency Plan (NCP) establish a
variety of requirements relating to the selection of remedial
actions. The selected remedy for remediating the tanks,
equipment, and buildings at the Fike/Artel Site is
Alternative D4 Partial Facility Removal. The estimated
present worth of this remedy is $2,830,000. Based on current
information, this alternative would appear to provide the best
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balance of trade-offs among the alternatives with respect to the
nine criteria that EPA uses to evaluate each alternative.
Alternative D4 involves dismantling and decontamination of all
tanks, equipment, and the majority (or all) of the onsite
buildings. Concrete slabs and foundations would not be removed.
Asbestos-containing materials could be disposed in an offsite
landfil~ for nonhazardous waste. Decontaminated tanks and other
decontaminated facility components would be sold as scrap,
recycled, or disposed in an offsite RCRA Subtitle C or
Subtitle D landfill. The Subtitle D landfill of concern should
meet minimum technology requi rements under Subti tIe D cr iter ia
proposed in 40 CFR 258.40 and 40 CFR 258.50. Any facility
components that contain a RCRA hazardous waste (or a substance
similar to such waste) and that could not be decontaminated
would be disposed at a RCRA Subtitle C landfill. The existing
perimeter fence would be maintained. Fluids resulting from
decontamination would be treated at the CST plant. These fluids
would be stored in a tank pr ior to treatment. Table 6 provides
a list of ARARs for the selected remedy.
STATUTORY DETERMINATIONS
Alternative D4 would achieve substantial reduction in. risks and
safety hazards through removal of the majority of facility
components. Risks associated with migration of asbestos, direct
contact with tank and equipment contaminant residuals, and
structural collapse. would be eliminated. Concrete pads and
foundations would remain and thus present some obstructions to
future site investigations. However, removal of these materials
would expose underlying contaminated soil resulting in potential
unacceptable increases in risk.
This action is not the final action for the site and does not
attempt to ensure compliance with ARARs for the entire site. It
will be consistent, however, with those .action-specific ARARs
addressing closure of tank systems containing RCRA hazardous
wastes (or similar materials) and equipment/structures
containing RCRA hazardous wastes (or similar materials).
This alternative is in full compliance wi th RCRA tank closure
standards. The RCRA closure standards for tanks (40 CFR
Part 265, Subpart J) are applicable for any tanks and vessels
that contain or are contaminated wi th RCRA hazardous wastes.
Tank closure standards are relevant and appropr iate for tanks
and vessels containing materials sufficiently similar to RCRA
hazardous wastes. RCRA tank closure standards require
decontamination and/or proper disposal of tanks. RCRA closure
standards (40 CFR Part 265, Subpart G) are applicable for
equipment and/or structures containing a RCRA hazardous waste
and relevant and appropr iate where equipment and/or structures
contain a material sufficiently similar to a RCRA hazardous
waste. Any tank, component, or residual that could not be
treated by the CST will be transported to offsite facilities in
compliance with standards for hazardous waste generators and
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transporters (40 CFR Parts 262 and 263) and DOT regulations
pertaining to transportation. of hazardous materials (49 CFR
Parts 107 and 171 through 179).
The selected remedy is protective of human health l~n0 the
environment. The overall effectiveness of this reffi~dJ is
proportional to the projected costs and provides th~. best
balance of trade-offs among the alternatives with respect to the
evaluation criteria. The local community and the state of W~st
Virginia are in support of the selected remedy. ~ .
.,
~.... ~'. -'
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