United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R03-91/134
June 1991
Superfund
Record of Decision:
First Piedmont Quarry 719,
VA
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50272-101
REPORT DOCUMENTATION i. REPORT NO. z.
PAGE EPA/ROD/R03-91/134
4. TOe and SuMMe
SUPERFUND RECORD OF DECISION
First Piedmont Quarry 719, VA
First Remedial Action - Final
7. Authors)
9. Performing Organization Name and Address
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipienf 8 Accession No.
5. Report Date
06/28/91
6.
8. Perl o H I ill •$ Org&nizfttion Rcpt. No.
10. Projecl/Tssk/WoricUnHNo.
11. Contract(C) or Grant(G) No.
(C)
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EPA/ROD/RO3-91/134
First Piedmont Quarry 719, VA
First Remedial Action - Final
Abstract (Continued)
edge of the landfill. The Carbon Black Pile contains 100 cubic yards of a tire
reinforcement additive and contaminated soil, and the Waste Pile contains 10 cubic
yards of steel and nylon cords, glass, waste rubber strips, and contaminated soil. In
1972, the State ordered waste disposal operations to cease as a result of a fire on the
landfill. This Record of Decision (ROD) provides a final remedy for all site media
including the landfill material, leachate, the Carbon Black Pile and Waste Pile, and
the contaminated Northern Drainage soil and sediment. The contaminants of concern are
metals including antimony, arsenic, lead, barium, and zinc.
The selected remedial action for this site includes excavating and disposing offsite
1,080 tons of waste from the Carbon Black and Waste Piles along with the contaminated
soil and sediment from the Northern drainage areas; performing a TCLP of excavated
material to determine if it is RCRA characteristic waste, and if so, solidifying and
stabilizing the excavated material prior to offsite disposal; filling the excavated
Carbon Black and Waste Pile areas with clean soil; disposing of 30-40 drums from the
surface of the landfill at a RCRA Subtitle C treatment facility; decontaminating and
disposing of surface debris at an approved landfill; constructing a RCRA-cap and an
associated leachate collection system over the 2-acre landfill area; covering the cap
with 6 inches of soil and contouring soil to promote run-off, and revegetating the
area; constructing run-off control berms in the Northern Drainage areas to lessen
landfill cap run-offs; pretreating leachate, if necessary, prior to transporting to a
Publicly Owned Treatment Works (POTW), or constructing an onsite treatment system with
onsite discharge to surface water if the POTW will not accept the leachate; draining
the north and south ponds, and transporting and discharging pond water offsite to a
POTW; monitoring ground water and conducting bioassays to assess the effectiveness of
the removal of the Carbon Black Pile and Waste Pile on the reduction of contaminant
levels in the Southern Drainage; and implementing institutional controls including deed
restrictions, and site access restrictions such as fencing. The estimated present
worth cost for this remedial action is $2,154,000, which includes an annual O&M cost of
$66,200.
PERFORMANCE STANDARDS OR GOALS: No applicable.
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RECORD OF DECISION
FIRST PIEDMONT ROCK QUARRY/ROUTE 719
DECLARATION
SITE NAME AND LOCATION
First Piedmont Rock Quarry/Route 719 site
Danville, Virginia
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the
First Piedmont Rock Quarry site (the Site) in Danville, Virginia
which was chosen in accordance with the requirements of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Super fund Amendments and
Reauthorization Act of 1986 (SARA), and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP). This decision document explains the factual and legal basis
for selecting the remedy for this Site. The information supporting
this remedial action decision is contained in the Administrative
Record for this Site.
The Virginia Department of Waste Management concurs with the
selected remedy.
ASSESSMENT OF THE SITE
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 "Sw^TY of Site Risks.1* if not addressed by
implementing the response action selected in this Record of Decision
(ROD), may present an imminent and substantial endangerment to
public health, welfare, or the environment.
DESCRIPTION OP THE REMEDY
This remedy will address all of the media impacted by the
contamination at the Site. It is not warranted at this time to
split the Site into smaller components called operable units to
address individual media. Based on the information derived through
the Remedial Investigation, the Site does not pose any principal
threats to human health. Since wastes will be left in place, long-
term monitoring of the ground water must be performed. The ground
water monitoring must encompass the full range of RCRA Subtitle C
requirements because of the disposal of tetrachloroethylene, a
listed RCRA hazardous waste, into the landfill.
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The selected remedy includes the following major components:
• Excavation.and offsite disposal of the Carbon Black, Waste
Pile and the Northern Drainage soils and sediments.
• A RCRA Subtitle C cap on the landfill.
• Collection of leachate with treatment at a POTW.
• Washing and offsite disposal of surface debris.
• Ground water monitoring.
• Institutional controls.
DECLARATION OP STATUTORY DETERMINATIONS
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. This remedy utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable, and it satisfies the
statutory preference for a remedy that employs treatment that reduce
toxicity, mobility, or volume as their principal element.
Because this remedy will result in hazardous substances remaining
onsite, a review will be conducted no less often than each five
years after initiation of remedial action to ensure that human
health and the environment are being protected by the remedial
action being implemented.
• > _,
Edwin B. EricksonDate
Regional Administrator
Region III
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DECISION SUMMARY for the RECORD of DECISION
FIRST PIEDMONT ROCK QUARRY/ROUTE 719 SITE
1* Site y«m«f Tiocation* and Description
The First Piedmont Rock Quarry Superfund site (the Site) is located
along Route 719 in Pittsylvania County, Virginia near the
intersection with Route 360. It is approximately six miles north
of the city of Danville (see Figure 1).
The Site is an abandoned rock quarry located on a topographically
high ridge. The quarrying operation left a cut into the rock
outcrop bounded on three sides by the quarry highwalls. The fourth
side of the cut is open and slopes to the west.
The majority of the land use in the immediate Site vicinity is open
space/woodlands. Directly across Route 719 and south of the Site
is a residential area, the Beaver Park community. The closest home
is approximately 150 feet from the Site. All the homes in Beaver
Park obtain residential water from either wells or springs.
Approximately 455 people live within one mile of the Site;
approximately 1,893 people live within a two-mile radius of the
Site.
The Site is located within the Piedmont Physiographic Province in
southern Virginia. In general, the physiography of this region
consists of rounded uplands dissected by numerous streams. The land
surface in the immediate vicinity of the Site slopes gently westward
at a grade of 0 to 8 percent. Local relief between the uplands and
valleys in the vicinity of the Site is about 100 feet.
The regional geology of the area generally consists of weathered
residuum and saprolite overlying Precambrian metamorphic rocks.
Field investigation of outcrops at and near the Site indicate that
the bedrock is moderately fractured. Four major fracture trends
were observed in the outcrops (Figure 2). Most fractures are near
vertical with little parting displacement. Regional data indicate
that the shallow bedrock is fractured, but the occurrence of
fractures decreases with depth. Fractures probably do not occur at
depths much greater than 50 to 100 feet.
Most of the soils in the area are moderately to well-drained clay
to sandy loams. The soils range from silty sands to silty clays.
Soils are well developed on flat slopes and thin, poorly developed
on steep slopes. The soils have little sorptive capacity, with the
highest value found in the northern drainage.
Pittsylvania County has a temperate climate. The mean daily
temperature varies from 40 F in January to 77° F in July.
>
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tl
BASE MApt U.S.G.S.
GREENSBORO, N.C.
r x 2*
CONTOUR INTERVAL - 50 Ft.
fttOIOMAL SIT! LOCATION
Enrtranamtal
PPMO / ROOTI Tit f ITI
9AMVILLB. VA
4U&86-93O
/4SOQOO
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Precipitation averages 43.48 inches per year and is relatively
evenly distributed.
Ground water occurrence in the Piedmont Province is principally
limited to a depth of less than 150 feet; most ground water is found
within 30 feet of the surface. Most of the ground water within each
ground water basin discharges to the surface at low points in the
topography. The seeps and springs upgradient of the landfill and
south of the Beaver Park community are ground water discharge
points. The landfill is also a ground water discharge area for
local ground water. The majority of the ground water at the Site
discharges as leachate along the western edge of the landfill into
the north pond and then into the northern drainage. Surface water
data and observations indicate that most of the ground water
discharged from the north pond re-infiltrates or is lost to the
atmosphere via evapo-transpiration.
Drainage from the area is to Lawless Creek, which lies approximately
1400 feet to the northwest of the quarry. Lawless Creek is a
tributary of Fall Creek, which is a tributary of the Dan River.
As depicted in Figure 3, two small ponded areas/wetlands are located
within the landfill. The landfill is drained by two areas denoted
on Figure 3 as "Southern Drainage" and "Northern Drainage". Both
drainageways flow toward Lawless Creek; neither discharges directly
into the creek. The Northern Drainage contains three wetland areas:
a small cattail stand and a small phragmites stand in the upper
reaches and a larger cattail marsh located in the bottom land
hardwoods along Lawless Creek. Other than these wetlands, there are
no significant habitat, agricultural land, historic or landmark
sites directly or potentially affected. There are no endangered
species or critical habitats within close proximity to the Site.
There are approximately thirty to forty drums remaining on the
surface of the landfill.
2. aite History and Enforcement Activities
The Site was initially operated as a quarry for crushed stone. The
four-acre property which comprises the Site consists of the
abandoned quarry and the adjacent land. The Site was leased by the
First Piedmont Corporation to be used as a landfill for industrial
and agricultural waste from April 1, 1970 to April 1, 1975. Wastes
were disposed in the landfill from April, 1970 to July, 1972, at
which point the Virginia Health Department ordered waste disposal
operations to cease due to a fire on the landfill.
The landf illing operations were restricted almost exclusively to the
two-acre quarry area. The quarry was not filled in a systematic
fashion; no cells or segregated disposal areas were used for
specific wastes. Hundreds of drums were buried in the landfill in
random fashion with other solid waste. Upon arrival at the Site,
wastes were generally dumped at the highwall along the eastern edge
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220!
I-tO*
ROSE DIAGRAM OF FRACTURE
FREQUENCY (PERCENT)
FIRST PIEDMONT ROCK QUARRY
ROUTE 719 SITE
4112-88-904 A
J^'lifU-
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FIGURE 3
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of the landfill, where the quarry is approximately 35 feet deep, and
pushed down with a bulldozer. Wastes were not covered at the end
of each day.
The landfill contains approximately 65,000 cubic yards of industrial
and agricultural waste and approximately 3,000 cubic yards of soil
used as a cover when the landfilling was stopped. The industrial
wastes were generated by The Goodyear Tire and Rubber Company and
Corning Glass Works; the agricultural wastes were generated by
Southern Processors, Inc. The wastes from Goodyear consisted of
tires, general plant refuse, scrap rubber, rubber buildup and
approximately 15,000 gallons of a mixture of residual MS-20 (a floor
degreaser), water, carbon black and detergent. The MS-20 contained
ten percent by volume of tetrachloroethylene which is a listed
hazardous waste under the Resource, Conservation and Recovery Act
as amended, 42 U.S.C. 6901 et seq. (RCRA). The wastes from Corning
Glass Works consisted of paper, glass, cardboard and off-
specification batch materials which contained trace amounts of lead
oxide. The wastes from Southern Processors, a tobacco processing
company, consisted of soil removed from tobacco leaves, tobacco
scrap, paper and wood.
Separate and apart from the landfill are two other areas of waste
disposal on the site associated with the landfilling operation.
These two areas are denoted as the "Carbon Black Pile" and the
"Waste Pile" on Figure 3. The Carbon Black Pile consists of
approximately 100 cubic yards of carbon black (a reinforcement
additive used in tire manufacturing that is comprised almost
entirely of carbon) and contaminated soils. Zinc oxide bags were
reportedly observed in the pile during the construction of access
roads for the Remedial Investigation. The Carbon Black Pile is
approximately 150 feet from the most western edge of the landfill.
The Waste Pile contains approximately 10 cubic yards of waste
material consisting of steel and nylon cords, some glass, waste
rubber strips and contaminated soils. The Waste Pile is located
about 75 feet from the western edge of the landfill.
Another disposal area not associated with the landfilling operations
is located about 100 feet southwest of the Carbon Black Pile. This
area, denoted as the "Old Disposal Area" on Figure 3, contains
miscellaneous refuse including bottles, cans and metal debris.
Based on visual observations of this material, disposal in this area
is estimated to have occurred 20 to 30 years prior to the
landfilling operation and, as such, is not within the scope of this
Record of Decision.
In a letter dated June 1, 1981, the Goodyear Tire and Rubber Company
notified the First Piedmont Corporation that some of the wastes
deposited at the First Piedmont Rock Quarry landfill were hazardous.
The First Piedmont Corporation filed a "Notification of Hazardous
Waste Site" form with EPA on June 5, 1981, listing solvents as one
of the wastes disposed of at the- landfill. The EPA Field
Investigation Team subcontractor sampled the media in the landfill
vicinity in July, 1983 to provide data in order for EPA to determine
/
-3-
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whether the landfill should be proposed for listing on the National
Priorities List (NPL). Based on the results of this sampling, a
Hazard Ranking Score (HRS) of 37.85 was calculated in 1985 for the
Site. Based on comments received by EPA, the HRS was rescored to
30.16. The Site was listed on the NPL on July 21, 1987, pursuant
to Section 105 of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, as amended (CERCLA).
Pursuant to Section 122(e) of CERCLA, EPA sent Special Notice
Letters on May 6, 1986 to initiate negotiations with the First
Piedmont Corporation, Corning Glass Works, and The Goodyear Tire and
Rubber Company (the Potentially Responsible Parties or PRPs) to
perform a Remedial Investigation/ Feasibility Study (RI/FS) for the
Site. On December 31, 1987, EPA signed an Administrative Order by
Consent (Docket No. III-88-13-DC) with the PRPs to undertake
performance of the RI/FS for the Site. In February, 1988,
Westinghbuse Environmental and Geotechnical Services, Inc. was
contracted by the PRPs to perform the RI/FS.
3. Co""|>mii,tY Participation
The RI/FS and Proposed Plan for the First Piedmont Rock Quarry site
were released to the public in April, 1991. These documents were
made available to the public in both the administrative record and
an informational repository maintained at the EPA Docket Room in
Region 3 and at the Pittsylvania County Library in Chatham,
Virginia. The notice of availability for these documents was
published in the Danville Register-Bee and the Pittsylvania County
Star-Tribune. The purpose of the notice was to announce the
beginning of a 30-day public comment period on the Proposed Plan for
the site. The public comment period was held from April 10, 1991,
through May 9, 1991.
In accordance with Section 117(a)(2) of CERCLA, a public meeting
was held on April 16, 1991 at the Bethel Baptist Church on Route 36a
in Danville, Virginia. At this meeting, representatives from EPA
and the Virginia Department of Haste Management answered questions
about problems at the Site and the remedial alternatives under
consideration. The majority of the comments at the public meeting
were related to the extent of the groundwater contamination and
whether Site contamination would affect residential wells. A
response to comments received during this period is included in the
Responsiveness Summary, which is part of this Record of Decision.
4. Scope and Role of operable Onit er Response Action Within site
Strategy
The selected remedy will address all of the media impacted by the
low-level contamination at the Site; that is, the landfill material,
leachate, the Carbon Black Pile, the Waste Pile, the Northern
Drainage soils and sediments and the drums and debris on the surface
of the landfill. The Site does not appear to pose any principal
>t
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threats. EPA has determined that it is not warranted to split the
site remediation into separate operable units to address individual
media .
5. Summary of site Characteristics
The RI field activities and analytical program were designed to
define the extent of environmental media contamination, identify
contaminant migration pathways, and provide data to support an FS
of potential remedial actions. Samples from the leachate seeps,
surface soils, subsurface soils, surface waters, sediments,
bioassays, shallow and deep ground water, and residential wells were
analyzed to characterize the quality of these media. Sampling
locations are depicted in Figures 4, 5, and 6.
The following discussion summarizes the results from the RI sampling
program. Figures 7, 8, and 11, which are referenced below, contain
the results of the RI sampling data for the four main Site
contaminants: arsenic, barium, lead, and zinc.
Leaehate
The ground water flowing through the wastes in the landfill surfaces
as leachate along the western edge of the quarry. The leachate
discharges to the north pond and eventually to the Northern
Drainage. Sampling results indicate that contamination from the
landfill contents migrates to the north pond and Northern Drainage
via the transport and deposition of sediments in the leachate. In
general, the highest concentrations of contaminants detected in the
Northern Drainage were in the samples closest to the quarry; levels
decreased with distance from the quarry area. The contaminants of
concern found in the leachate are arsenic, lead (both of which are
carcinogens) , antimony, and barium.
Water
Surface water samples were collected from the south pond, north
pond, Southern Drainage, Northern Drainage, and Lawless Creek.
Figure 7 denotes the sampling locations as well as the concentration
of the major Site contaminants in surface water. These sampling
areas arc discussed below.
South Pond.
The sampling data of the water in the south pond indicate that this
water has not been adversely affected by the landfill. A very low
level of 20 micrograms/ liter (M9/L) of zinc was the only significant
heavy metal contaminant detected in the south pond. The zinc
concentration detected was below the background level for surface
water zinc concentrations.
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EXPLANATION
PIEZOMETER
MOIITOft WELL : *- SHALLOW WELL
• -DEEP WELL
SURFACE WATER AND SEDIMENT SAMPLING S
SURFACE WATER FLOW MEASUREMENT STATIC'
NOTESi
LOCATIONS FP-2B3A. FP-3B3A. FP-2B7.
FP-M7. FP-21B AND FP-3IB WERE SAMPLED
DURING THE SECOND ROUND ONLY.
TOPOGRAPHY PRODUCED FROM AERIAL
PHOTOGRAPHY JANUARY 24.1S8S.
CONTOUR INTERVAL * 2 Ft.
W\ Westinghouse Environment!
) and Geotechnical Services,
RICHMOND, VIRGINIA
FIRST PIEDMONT ROCK QUARRY
ROUTE 719 SITE
DANVILLE, VA.
CMC 11* »1
MONITORING/SAMPL ING
AND STUDY AREA TOPI
FIGURE 5
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N
EXPLANATION;
SAMPLING N0»
DESCRIPTIONi
SOUTH POND (*QJ
NOHTN rOC (AOJ
LAWLESS
LAWLESS CNCOC-OOWMSTRCAM MO)
poo CBCOLI
NORTH POMO CSOU
LAWLCS*
LAWLESS
soa. iocxc
SOJL-«ABTB»< (MM
PIU
saa.-fls.vorr OMT ru
HISTORICAL SITE SAMPLING LOCATIONS
PROJECT
FIRST PIEDMONT ROCK
QUARRY
DANVILLE, VA.
,W) Westinghouse
SCALE: N.T. s
JOB NO! 4112-88-904 F
F1G..NO U4
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Route 719
Empty
Unknown Tom Oteayt BM John
Roytttr Cbtomw Wlnbuth Moflty
V
Spring
\
X*
so
CO
CD
CO
Sample location/I
O Well, no access
O Well, manhole access
El Well, In housing
Not to Mate
PRIVATE WELL SAMPLING LOCATION MAP
Route 360
PROJECT
FIRST PIEDMONT ROCK QUARRY
ROUTE 7I9 SITE
DANVILLE, VA.
w) Westinghouse
SCALE:
N T. S.
JOB NO! 4H2-88-904D
FIG NO: 6
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North Pond
In the north pond, concentrations of arsenic, barium, cadmium, lead,
and zinc were detected in concentrations (58, 8420, 8, 21, and 219,
Mg/L, respectively) which are slightly above the Site background
levels.
Northern Drainage
The Northern Drainage receives flow from the leachate which
accumulates in the north pond. In the upper Northern Drainage,
which is closest to the landfill, arsenic, barium, iron, lead,
manganese, and zinc were detected at concentrations (13.7, 5600,
59,800, 4.1, 1540, and 48.1 Mg/L, respectively) which are above
background levels. The concentrations of these contaminants rapidly
decrease downstream from the landfill. In fact, where the Northern
Drainage meets the Lawless Creek floodplain, only very low levels
of barium, lead, and zinc (109, 2.4, and 32.8 Mg/L, respectively)
were detected.
Southern Drainage
Zinc and cadmium were detected in the Southern Drainage at the
maximum level of 111,000 Mg/L and 18.2 Mg/L, respectively. The
source of these high levels of zinc and cadmium is considered to be
the Carbon Black Pile because: the pile is located upgradient of the
Southern Drainage; the concentrations of zinc were higher
downgradient of the Pile than upgradient of the Pile; and the
reported sighting of empty zinc oxide bags during the construction
of access roads during the RI. Infiltration of precipitation and
surface water into the Carbon Black Pile may mobilize high levels
of zinc from the pile. The water then moves downgradient in the
shallow subsurface soil and discharges to the surface water in the
Southern Drainage. Sampling data indicates that the zinc
concentrations were inversely proportional to flow; in other words,
the lower the flow the higher the zinc, concentrations. This
indicates that the zinc levels are not due to surface water runoff
but to shallow subsurface flow. The highest zinc levels were
detected when there was no surface water runoff flow except at a
very small seep in the lower Southern Drainage. The Southern
Drainage also receives surface water runoff from the Waste Pile.
Lawless CreeX
As shown on Figure 7, three stations were sampled along Lawless
Creek: FP-312 (the background station), which is approximately 900
feet north (upstream) of the bridge at Route 719; FP-313, which is
approximately 200 feet below the bridge at Route 719; and FP-314,
which is approximately 1300 feet south of the bridge. At FP-313,
barium, iron, manganese, and zinc were detected at concentrations
(20.5, 647, 79, and 26.5 Mg/L, respectively) which are above the
background concentrations detected at FP-312. At FP-314, iron,
manganese, and zinc were detected at concentrations (604, 57.7, and
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16.3 Mg/Lf respectively) which are above the background
concentrations detected at FP-312.
Soils
Figure 8 depicts the level of the four major Site contaminants in
soil. Landfill soil samples have concentrations of arsenic, barium,
cadmium, chromium, lead, nickel, vanadium, and zinc above Site
background levels with barium, lead, and zinc found in the highest
concentrations.
The Waste Pile soil samples generally show concentrations of
arsenic, barium, cadmium, lead, and zinc at levels exceeding
background with barium, lead, and zinc found in the highest
concentrations. The concentrations range from twice the background
level for arsenic to ten times the background concentration for
lead. The Extraction Procedure (EP) Toxicity tests showed
detectable levels of barium and lead but only at concentrations
below the EP toxicity criteria. The Toxicity Characteristic
Leaching Procedure (TCLP) test has not been performed on this
material.
The Carbon Black Pile soil samples have concentrations of arsenic,
barium, cadmium, lead, and zinc above background levels. Lead
concentrations were about twice the background level while zinc was
detected at concentrations ten times the background level.
Ground Water
The shallow and deep ground water flow in the Site vicinity is to
the west, toward Lawless Creek, as shown in Figures 9 and 10.
Ground water at the Site occurs mostly in the bedrock, except in
areas of thicker overburden or ground water discharge areas such as
Lawless Creek and the Southern and Northern Drainages. Most of the
ground water is contained in the bedrock. It is locally controlled
by bedrock fractures; The shallow bedrock is probably sufficiently
fractured so that it acts as a nearly homogenous aquifer. Potential
contaminant transport via the ground water system is not a
significant process at the Site because the landfill occurs in an
area of upward shallow ground water flow. However, the ground water
chemistry data indicate that the landfill does have some effect on
the chemistry of the shallow ground water downgradient of the Site.
This effect is manifested mainly as a change in major ion chemistry
with only son* trace metals detected at levels slightly above
background. As depicted in Figure 11, zinc was detected in
monitoring wells FP-006B, FP-008A, and FP-008B at levels (504, 2050,
and 213 Mg/L, respectively) which exceed the background level of
61.3 M9/L. The ground water sample from monitoring well FP-008A had
the only level of lead (28.8 Mg/L), which exceeds the proposed
action level of 15 pg/L.
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\
4FP--10'
N
LEGEND:
^ SURFACE WATER h SEDIMENT SAMPLING STATIC,
SAMPLE DESIGNATION
ARSENIC
BARIUM
LEAD
_ ZINC
NOTE>
CONCENTRATIONS IN ug/L
BLANK INDICATES CONSTITUENT NOT
DETECTED ABOVE QUANTITATIVE LIMITS.
FICUKE 7
TOTAL rONrRNTRATTON9 POP
UPT»TO
-------
EXPLANATIOt,
SOURCE ARC* SAUPLI
S*MPI-E OtSIOHATION
(FT. ABOVE M.S.L
POTENTtOMCTRIC (
(FT. ABOVE MSL )
WHERE INFERRED
CONTOUR WTCRVAI
SUPPLEMENTAL C
GROUND* AT ER FLO
ARE* OF UPWARD
HYDRAULIC ORADI1
MOTE • POTENTIOMETRIC D
' K/29/89
LOCATIONS FP-tOM. FP-K
rp-soT.rr-t» AMD rp
•AMPLKO OMIM THE K(
TOPOARAPMT PHOOUCCO F
PHOTOMAPHt MM. M. Iff
CONTOIM MTCJMU. • t f 1
Westinghouse Environment!
mm ond Geolechnical Services,
RICHMOND, VIRGINIA
FIRST PIEDMONT ROCK QUARRY
ROUTE 719 SITE
DANVILLE. VA.
SHALLOW
GROUND-WATER
REV I /M/9O
KATCMFCCT
////// I (
///,' \ ». I
FIGURE 9
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N
LEGEND:
> SOIL SAMPLING LOCATION
I TEST PIT LOCATION
> SOURCE AREA SAMPLING LOCATION
SAMPLE DESIGNATION
ARSENIC
BARIUM
LEAD
ZINC
NOTE'
CONCENTRATIONS IN ug/L
BLANK INDICATES CONSTITUENT NOT
DETECTED ABOVE QUANTITATIVE LIMITS.
NOTES:
LOCATIONS FP-203A. FP-303A. FP-207. FP-307.
FP-210. AND FP-310 WERE SAMPLED DURING
THE SECOND ROUND ONLY.
Zn-OJ
FIGURE 8
SELECTED METAL CONCENTRATIONS IN SOIL AND SOURCE MATERIAL: 1" - lOO'-O"
-------
N
4- MONITOR WELL: A-SHALLOW. B-DEEP
SAMPLE DESIGNATION
ARSENIC
BARIUM
LEAD
ZINC
••-at.
Pk-13
Zn-4321
NOTE'
CONCENTRATIONS IN ug/L
BLANK INDICATES CONSTITUENT NOT '
DETECTED ABOVE QUANTITATIVE LIMITS.
FIGURE U
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Vtfp^pg
jMCrr-^^
SOURCE AREA S»MPLII
DESIGNATION
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Residential Walla
As depicted in Figure 6, EPA sampled the residential water sources
of ten homes in the Beaver Park community near the Site to determine
if the contamination from the Site was affecting the drinking water
of the residents. Only two of the ten residential wells sampled had
levels above drinking water standards. One well had a detection of
466 Aig/1 of iron, above the Secondary Drinking Water criterion for
iron of 300 Mg/1. The other well had a detection of 333 Mg/1 of
iron and 65.1 /ig/1 of manganese, above the Secondary Drinking Water
criteria for iron and manganese of 300 M9/1 and 50 Mg/1,
respectively. Because none of the major Site contaminants were
detected in the residential water, these results confirm that the
Site contamination has not affected any residential wells in the
Site vicinity.
Contaminants may be transported from the Site via the air as a
result of volatization or adsorption onto fugitive dust generated
at the Site. However, the few volatile compounds detected . during
the sampling were found in a small area at low concentrations.
Therefore, air transport of contaminants is insignificant, as most
of the landfill is covered by soil and most of the contaminants
detected are non-volatile.
Drums
Solid samples were collected from the contents of two of the drums
on the surface of the landfill. Low concentrations of chromium,
copper, and lead and higher concentrations of cadmium and zinc were
detected in one drum. Low concentrations of cadmium, chromium,
lead, nickel, selenium and vanadium and higher concentrations of
copper and zinc were detected in the other drum sampled.
6* Summary of Bite Risks
As part of the RI/FS process, a Baseline Risk Assessment was
prepared for the Sit* to characterize, in the absence of remedial
action (i.e., the "no action" alternative), the current and
potential threats to human health and the environment that may be
posed by contaminants migrating in ground water or surface water,
released to the air, leaching through the soil, remaining in the
soil, or bioaccumulating in the food chain at the site. Figure 12
provides a glossary of the key risk terms from the Baseline Risk
Assessment that are used in this section of the ROD.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
-8-
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FIGURE 12
KEY RISK TERMS
Carcinogen: A substance that increases the incidence of cancer
in humans.
Chronic Daily Intake (CDZ): The average amount of a chemical in
contact with an individual on a daily basis over a substantial
portion of a lifetime.
Chronic Exposure: A persistent/ recurring/ or long-term
exposure. Chronic exposure may result in health effects (such as
cancer) that are delayed in onset, occurring long after exposure
ceased.
Chronic Reference Dose (RfD): An estimate (with uncertainty
spanning perhaps an order of magnitude or greater) of a daily
exposure level for the human population/ including sensitive
subpopulations, that is likely to be without an appreciable risk
of deleterious effects during a lifetime. Chronic RfDs are
specifically developed to be protective for long-term exposure to
a compound (as a Superfund program guideline/ seven years to
lifetime.
Exposure: The opportunity to receive a dose through direct
contact with a chemical or medium containing a chemical.
Exposure Assessment: The process of describing/ for a population
at risk/ the amounts of chemicals to which individuals are
exposed, or the distribution of exposures within a population, or
the average exposure of an entire population.
Hazard Index (HI): The sum of more than one hazard quotient for
multiple substances and/or multiple exposure pathways. The HI is
calculated separately for chronic/ subchronic, and shorter-
duration exposures.
Hazard Quotient: The ratio of a single substance exposure level
over a specified time period (e.g./ subchronic) to a reference
dose for that substance derived from a similar exposure period.
Risk: The nature and probability of occurrence of an unwanted/
adverse effect on human life or health, or on the environment.
-------
Risk Assessment: The characterization of the potential adverse
effect on human life or health, or on the environment. According
to the National Research Council's Committee on the Institutional
Means for Assessment of Health Risk, human health risk assessment
includes: description on the potential adverse health effects
based on an evaluation of results of epidemiologic, clinical,
toxicologic, and environmental research; extrapolation from those
results to predict the types and estimate the extent of health
effect in humans under given conditions of exposure; judgements
as to the number and characteristics of persons exposed at
various intensities and durations; summary judgements on the
existence and overall magnitude of the public-health program; and
characterization of the uncertainties inherent in the process of
inferring risk.
Slop* Factor: The statistical 95% upper confidence limit on the
slope of the dose response relationship at low doses for a
carcinogen. Values can range from about 0.0001 to about 100,000,
in units of lifetime risk per unit dose (mg/kg-day). The larger
the value, the more potent is the carcinogen, i.e., a smaller
dose is sufficient to increase the risk of cancer.
Weight-of-Evidence Classification: An EPA classification system
for characterizing the extent to which the available data
indicate that an agent is a human carcinogen. Recently, EPA has
developed weight-of-evidence classification systems for some
other kinds of toxic effects, such as developmental effects.
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Human Health Risks
contaminants of Concern
The initial step of the Baseline Risk Assessment was to compile a
list of key indicator contaminants, those which represent the
highest potential risk to human health. The following 14 indicator
contaminants were judged to represent the major potential health
risks at the Site:
antimony lead
arsenic manganese
barium mercury
benzene nickel
bis(2EH)phthalate selenium
cadmium vanadium
copper zinc
Of these contaminants, only arsenic, benzene, bis(2EH)phthalate,
cadmium, lead and nickel are known to cause cancer in humans or
laboratory animals and thus are classified as carcinogens. Although
known to be disposed of in the landfill, sampling results have not
detected any levels of tetrachloroethylene that exceed health-based
standards .
Assessment
The goal of the exposure assessment is to determine the type and
magnitude of human exposure to the contaminants present at, and
migrating from, the Site. The exposure assessment was conducted to
estimate the Site risks if remedial action is not taken.
To determine if human and environmental exposure to the contaminants
of concern might occur in the absence of remedial action, an
exposure pathway analysis was performed. An exposure pathway has
four necessary elements: 1) a source and mechanism of chemical
release; 2) an environmental transport medium; 3) a human or
environmental exposure point, and; 4) a feasible human or
environmental exposure route at the exposure point. The potential
for completion of exposure pathways at the Site is described in the
following sections.
Transport Pathways
For any particular site, there may be a variety of potential
exposure routes, with either simple or complex pathways. The simple
pathways are of primary significance at the Site. Such simple
exposure routes for humans include consumption of ground water,
bathing in ground water, consumption of surface water, bathing or
play in surface water, ingestion of soil, dermal exposure to soil,
and inhalation of fugitive dust emissions. The ingestion pathways
are the most important at the Site, based on Site constituents and
contaminant distribution. Complex exposure routes are significantly
less important at the Site than simple pathways because the primary
•»
-9-
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contaminants, metals, do not bioaccumulate to the extent that many
organics do and they are not relatively mobile in the environment.
Furthermore, sampling data indicate that only minimal off-site
migration of contaminants has occurred in any environmental media
to date.
Four transport pathways were evaluated for the Site: ground water;
air; soil; and surface water. Although ground water and air are
potential migration pathways, the RI data indicate that the
potential extent of off-Site impacts via the ground water and air
pathways is limited. No significant levels of contamination were
detected in the ground water downgradient of the Site. The private
wells located in Beaver Park are upgradient of the landfill.
Potential exposure via the air pathway is minimal because the
transport of contaminants through the air is insignificant.
There is minimal potential for soil transport from the Site.
However, there is potential for erosion of sediment from the Site,
which would transport adsorbed contaminants from the Site to surface
water drainage in both the Northern and Southern Drainages.
Sampling data from both drainages indicate limited movement of
contaminants close to the landfill in these drainages.
The surface water migration pathways include the Northern and
Southern Drainages. Discharge from the north pond and from leachate
seeps enters the Northern Drainage while the Southern Drainage
receives discharge from the Waste Pile and the Carbon Black Pile.
Potential Exposure Points
The potential exposure level experienced by the receptor population
will be a function of the concentration of the contaminants at the
exposure point and the duration of exposure. Potential human
exposure to contaminants could be by five exposure routes: direct
exposure to source material, or direct exposure to ground water,
surface water, soil, and air.
Since it is not possible to rule out future uses of the Site, it is
appropriate to consider the possibility of residential development
of the land adjacent to the landfill. Under the no-action
alternative, such development could result in drinking water wells
in the leachate and direct contact of children and adults to site
contaminant sources such as drums, seeps, landfill pond water,
carbon black, and the waste pile. The potential points of exposure
to Site contaminants, assuming residential development, are shown
below:
• Direct ingestion of leachate;
» Direct contact or incidental ingestion of source material
by children during play and by adults during gardening;
• Incidental ingestion of surface water from the north and
south ponds by children during play;
• Ingestion of downgradient ground water;
s
-10-
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• Incidental ingestion of water or sediments from the
Northern or Southern Drainage by children during play;
• Use of Lawless Creek as a source of potable water by
residents;
• Incidental ingestion of quarry soil by children during
play and by adults during gardening;
• Incidental ingestion of soil in Northern Drainage or
Southern Drainage by children during play and by adults
during gardening;
• Inhalation of particulate matter.
The potential points of exposure described above are based on a
series of general assumptions as well as on specific assumptions for
the different scenarios. These assumptions are derived from the
following EPA guidance documents:
1) Superfund Public Health Evaluation Manual;
2) Supplemental Risk Assessment Guidance for the
Superfund Program, Draft Final;
3) Exposure Factors Handbook;
4) Risk Assessment Guidance for Superfund Volume if
Human Health Evaluation Manual (Part A).
The following assumptions, taken from the above guidance documents,
have been used in the Baseline Risk Assessment for the site:
• adults weigh 70 kg, adolescents weigh 36 kg, and children
weigh 20 kg;
•lifetime drinking water exposures are based on individuals
living an entire lifetime of 70 years, with 10 years childhood
exposure, 5 years adolescent exposure, and 55 years adult
exposure;
•lifetime exposures are based on individuals living an entire
lifetime of 70 years at the Site;
•concentrations of indicator chemicals below the detectable
limit were assumed to be one-half the detection limit if at
least one sample had detectable concentrations;
•if all samples of an indicator chemical had below detectable
concentrations, that chemical was assumed not to be present
in the sample;
•for the average case exposure, calculations are based on the
arithmetic mean concentrations of indicator chemicals;
•bioavailability of metals in ingested soil and sediments is
assumed to be 50 percent for the average case calculations;
The health criteria for comparison of exposures were obtained from
the EPA Superfund Public Health Evaluation Manual, personal
correspondence from EPA regional representatives or from the EPA
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Integrated Risk Information System (IRIS). The health criteria
utilized in the risk assessment are shown on Table 1.
Exposure Point Concentrations
Data gathered during the RI are adequate to predict potential
exposure concentrations if the Site has reached steady-state
conditions (i,e., when the rate of transport of contaminants is
stable and in^equilibrium with the environment). In the absence of
an established trend in historical data indicating the contrary, the
Site was considered to have reached steady-state conditions.
The maximum and average concentrations of the fourteen indicator
contaminants were derived for each of the affected media. The
average concentrations are the arithmetic means of sample
concentrations. The maximum concentrations are the lesser of the
upper 95 percent confidence interval or the maximum observed value.
Figure 13 depicts the maximum and average concentrations of ground
water and surface water for the indicator contaminants.
Toxicity Assessment
The risks estimated in the Baseline Risk Assessment are potential
risks, based on the assumption that the Site is developed or used
in the future such that there will be some degree of exposure.
Cancer potency factors (CPFs) were developed by EPA's Carcinogenic
Assessment Group to estimate excess lifetime cancer risks associated
with exposure to potentially carcinogenic chemicals. CPFs, which
are expressed in units of (mg/kg-day)"1, are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to provide
an upper-bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level. The term "upper
bound" reflects a conservative estimate of the risks an exposure to
a chemical for which a CPF has been developed. Use of this approach
makes underestimation of the actual cancer risk highly unlikely.
CPFs are derived from the results of human epidemiological studies
or chronic animal studies from which human factors are estimated
based on animal-to-human extrapolation and by applying uncertainty
factors which would not underestimate the potential for adverse
effects to occur.
Reference doses (RfDs) were developed by EPA to indicate the
potential for adverse health effects from exposure to chemicals
exhibiting non-carcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals, that is not likely to
be without an appreciable risk of adverse health effects. Estimated
intakes of chemicals from environmental media (e.g., the amount of
a chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological
studies or animal studies to which uncertainty factors have been
applied (e.g., to account for the use of animal data to predict
effects on humans). These uncertainty factors help ensure that the
•=12=
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TABLE 1
TOXICITY CONSTANTS
ORAL
INHALATION
Indicator
Chemical
Antimony
Barium
Cadmium
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Vanadium
Zinc
Arsenic
Benzene
Bis(2eh)
Phthalate
Reference
Dose
4e-4
5e-2
5e-4
3.7e-2
1.4e-4
5e-l
2e-3
2e-2
2e-3
9e-3
2e-l
NA
NA
2e-2
Cancer
Potency
Factor
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.75e
2 . 9e-2
1.4e-2
Reference
Dose
4e-4
1.46-4
5e-4
. le-2
4.3e-4
5e-l
5.le-5
2e-2
le-3
9e-3
le-2
NA
NA
20-2
Cancer
Potency
Factor
NA
NA
e.ieo
NA
NA
NA
NA
1.1960
NA
NA
NA
5e+l
2.9e-2
NA
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FIGURE 13
Ground Hater Surface Hater
(Concentrations in ug/1)
Indicator
Cheaucal
Average MaxiauB Average Heziaua
Antimony
Arsenic
Bariiia
Benzene
Bis (2 -EH)
phthalate
Cadniuo
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Vanadium
Zinc
1.117
BOL
120.9
BOL
7.5
BOL
4.867
BDL
595.6
BOL
BOL
BDL
BOL
140.0
1.317
BDL
139.4
BOL
9.306
BOL
6.73
BDL
1245
BOL
BOL
BOL
BOL
223.3
1.717
17.16
1646
BDL
BDL
23.22
14.21
3.932
901.7
BOL
20.07
BOL
BOL
15546
2.59
30.56
2786
BDL
BDL
41.11
19.85
6.36
1312
BDL
25.11
BOL
BDL
29619
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RfDs will not underestimate the potential for adverse non-
carcinogenic effects to occur.
The Baseline Risk Assessment is based on a series of conservative
assumptions that, taken together, provide a significant margin of
safety for estimating potential risk from the Site. These
assumptions include the following:
• The Site will be developed for residential purposes in the
future.
• Children play, or adults garden, daily or every other day for
nine months of the year.
• Children play, or adults garden, in source areas or in known
contaminated areas of the Site.
• Exposed individuals have an average lifespan of 70 years.
• Contaminated soil concentrations do not account for the
presence of clean soil placed over the contaminated material.
• Individuals will be maximally exposed to contaminants; that
children and adults are exposed to source material or to quarry
soil; that children play in the Northern and/or Southern
Drainages every day that they play outside; and that exposure
is always to contaminated environmental media.
Based on the exposure assumptions, exposure scenarios, sampling
data, and health criteria, the human health risks were calculated
for. the maximum and average case exposures. However, only the
average case exposure levels were utilized by EPA in determining
whether remedial action would be warranted for any of the media.
These risk scenarios are depicted in the Baseline Risk Assessment.
Excess lifetime cancer risks are determined by multiplying the
intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g., 1x10 or 1E-6). An excess lifetime cancer risk of 1x10
indicates that, as a plausible upper bound, an individual has a one
in one million chance of developing cancer as a result of site-
related exposure to a carcinogen over a 70-year lifetime under the
specific exposure conditions at a site.
The excess lifetime cancer risk determined under the average case
exposure is 6.46 x 10 from the ingestion of quarry leachate due to
arsenic contamination. In other words, if no remedial action is
taken, six additional people per one thousand have a chance of
contracting cancer as a result of exposure to the arsenic if, in the
future, the quarry leachate is used as a residential water source.
Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) (or the ratio of the estimated intake derived from the
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contaminant concentration in a given medium to the contaminant's
reference dose). The Hazard Index (HI) is calculated by adding the
HQs for all contaminants within a medium or across all media to
which a given population may reasonably be exposed. The HI provides
a reference point for gauging the potential significance of multiple
contaminant exposures within a single medium or across media.
To determine the human health effects from the non-carcinogenic
contaminants, EPA uses the HI. Any media with a cumulative HI
greater than 1.0 is considered to pose a risk to human health. With
His of 3.39, 11.66, and 193.88, respectively, antimony, barium, and
lead also pose human health risks through ingestion of quarry
leachate.
The Baseline Risk Assessment identified lead as a contaminant which
represents a risk to human health assuming incidental ingestion of
soil by children playing in source material because it has an HI
of 1.58. The exposure to lead by children playing in quarry soil
equates to a HI of 1.39.
10'4 or have an HI equal to or greater than 1.0 are summarized on
The Site media which exceed the EPA acceptable risk range of 10"* to
10"& or h
Table 2.
Environmental Risks
Habitat areas influenced by surface water or animals that might come
into contact with contaminated surface water or soils within the
Site itself have the highest potential to be adversely affected.
Although an intensive ecological risk assessment was not conducted,
an indication of potential risk to wildlife and the environment can
be assessed from toxicity testing (bioassays) and the human health
risk assessment. Because there is the potential for contamination
of surface water in the immediate vicinity of the landfill, samples
of surface water and sediments were collected along the Northern
Drainage and Lawless Creek for aquatic toxicity testing. The
samples collected underwent the following tests:
• Four 7-day chronic toxicity tests, using Ceriodaphnia and
fathead minnows, were conducted on the surface water
samples. Three of the tests were undiluted samples and
one contained a full set of serial dilutions.
• Four 7-day chronic toxicity tests, using Ceriodaphnia.
were conducted on the sediment elutriate. All of these
tests were full serial dilutions.
The test results indicate that the surface water in the Northern
Drainage and in Lawless Creek were not acutely toxic to the test
organisms. However, surface water from the upper reaches of the
Northern Drainage did result in significant decreases in growth
among fathead minnows and reproduction among Ceriodaphnia at
concentrations above 30 percent dilution.
-14-
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TABLE 2
MEDIA OF CONCERN
Medium
Quarry Leachate
Source Material
Quarry Soil
Contaminant
Antimony
Barium
Lead
Arsenic
Lead
Lead
HI Cancer Risk
3.39
11.66
193.88
NA
1.58
1.39
NA
NA
NA
6.46e-3
NA .
NA
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Significant Sources of Uncertainty
Discussion of general limitations inherent in the risk assessment
process as well as the uncertainty related to some of the major
assumptions made in this assessment are included below:
1. The Baseline Risk Assessment is based upon the data collected
during the RI and uses RI results of limited sampling to represent
environmental concentrations over large areas. This extrapolation
contributes to the uncertainty of the risk assessment.
2. The Carbon Black Pile is considered to be the source of the zinc
found in the Southern Drainage. If the levels of zinc are not
significantly reduced after remediation of the Carbon Black Pile,
the source of the zinc may have to be investigated further.
3. Environmental risks are assumed to occur in the Southern
Drainage because the levels of zinc greatly exceed the Virginia
water quality standard. However, the extent of the toxicity is not
known because toxicity tests were not performed on the water or
sediments since this contamination was identified late in the RI.
7. Description of Alternatives
In accordance with 40 C.F.R. $ 300.430, remedial response actions
were identified and screened for effectiveness, implementability,
and cost during the FS to meet the remedial action objectives at the
site. The technologies that passed the screening were assembled to
form remedial alternatives. The developed alternatives were then
evaluated and compared to nine criteria required by the National Oil
and Hazardous Substances Contingency Plan, 40 C.F.R. Part 300 (NCP).
The FS evaluated a variety of technologies used in the development
of alternatives for addressing the landfill wastes, the Carbon Black
Pile, the Waste Pile, the Northern Drainage soils and sediments, and
the landfill leachate. The technologies and approaches contained
in the alternatives listed below have been determined to be the most
applicable for this Site. The description of the alternatives
reflect the descriptions in the FS.
Common Elements
Except for Alternative 1 ("No Action"), each remedial alternative
for the Site includes the following elements:
Ground Water Monitorlag. Ground water monitoring will be used to
evaluate the protectiveness of the remedial action because waste
will be left in place. Exact monitoring points will be determined
during the remedial design phase and will be in accordance with the
requirements of the Virginia Hazardous Waste Management Regulations
(VHWMR), Section 10.5. The ground water monitoring will be
performed for at least thirty years in accordance with the VHWMR.
Because tetrachloroethylene was disposed of in the landfill, the
monitoring must comprise the full priority pollutant list. When it
is demonstrated that only a limited number of contaminants are
«f
-15-
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detected over a period of tine, a request can be made to limit the
monitoring to those contaminants.
Institutional Controls. Institutional controls, including fencing
and a deed restriction will prevent access to the Site and prohibit
future development of the Site.
Leachate Treatment. Leachate will be treated until the contaminant
levels meet a 10*6 risk level and an HI less than 1. At present, the
length of time required for treatment of leachate is not known,
however, a longer treatment period is anticipated for Alternatives
7 and 8 in which the ground water flow through the landfill will be
reduced than for Alternatives 3 through 6 in which the ground water
flow is not reduced. In order to evaluate the alternatives on the
same basis, the present worth costs developed in the FS for
Alternatives 3 through 9 include 30 years of leachate collection and
treatment.
Alternative l- No Action
The NCP, 40 C.F.R. Part 300, which regulates Superfund response
actions, requires that a "no action" alternative be evaluated at
every NPL site in order to establish a baseline for comparison.
Under this alternative, EPA would take no further action at the Site
to prevent exposure to the contaminated media or to reduce risk at
the Site.
Alternative 2- Institutional Controls
Capital Cost: $44,200
Annual O&M Cost: $15,690
Present Worth: $285,400
Months to Implement: 4
.Alternative 2 consists of the implementation of institutional
'controls and long-tern ground water monitoring. The institutional
controls include complete fencing of the Site to restrict access and
a deed restriction to prohibit future development of the Site.
Alternative a- Excavation and Off-Site Disposal of Non-Landfill
Wastes, Landfill Cap, and Leachate Treatment.
Capital Cost: $1,258,000
Annual O4M Cost: $56,110
Present Worth: $2,120,500
Months to Implement: 6-8
The major features of Alternative 3 include implementation of the
institutional controls as described in Alternative 2, excavation and
off-site disposal of the estimated 800 cubic yards from the Carbon
Black Pile, Waste Pile, and the Northern Drainage soils and
sediments; off-site disposal of the surface drums and debris;
installation of a RCRA Subtitle C cap over the landfill;
*
-16-
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construction of a passive leachate treatment unit; and long-term
ground water monitoring.
After the material from the Carbon Black Pile, Waste Pile, and the
Northern Drainage is excavated and removed, the effectiveness of
this action on the zinc level in the Southern Drainage surface water
and zinc mobility in drainage sediments would be assessed. The
excavated areas will be backfilled with clean soil, contoured to
promote run-off, and planted with vegetation to control erosion.
Run-off control berms will be constructed in the Northern Drainage.
The berms will act as retention structures to reduce peak run-off
flows from the quarry cap and minimize erosion in the Northern
Drainage. The surface drums would be disposed of at an approved
off-Site hazardous waste facility in accordance with the VHWMR.
To facilitate the landfill cap construction, the water in the north
and south ponds will be pumped to tanker trucks for transport to a
Publicly Owned Treatment Works (POTW) for treatment and discharge.
The water must be tested to determine if it meets the pretreatment
requirements of the POTW. The cap will include a passive leachate
treatment system which will consist of a tee-shaped trench system
constructed at the head of the Northern Drainage. The top of the
tee will act as an interceptor trench with the stem of the tee
constituting the treatment area with filter zones and adsorptive/ion
exchange zones.
Alternative 4- Excavation, Treatment and On-8ite Disposal of Non-
Landfill Wastes/ Landfill Cap, and Leachate
Treatment.
Capital Cost: $1,173,000
Annual O&M Cost: $56,110
Present Worth: $2,035,000
Months to Implement: 6-8
The major features of this alternative include implementation of the
institutional controls as described in Alternative 2; excavation,
stabilization/solidification treatment (if required) and on-site
disposal of the Carbon Black Pile, Waste Pile, and the Northern
Drainage soils and sediments; off-site disposal of the landfill
surface drums and debris; installation of a RCRA Subtitle C cap over
the landfill; construction of a passive leachate treatment unit; and
long-term monitoring.
This alternative is identical to Alternative 3 with one additional
element. Prior to disposal, the excavated material, soils, and
sediments from the Carbon Black Pile, Waste Pile, and the Northern
Drainage will be tested utilizing the Toxicity Characteristic
Leaching Procedure (TCLP) to determine if they are RCRA
characteristic wastes. If such wastes are determined to be RCRA
characteristic, they will be treated with the stabilization/
solidification process and disposed of on-Site in the landfill prior
to capping the landfill. If the wastes are determined not to be
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RCRA characteristic, they will be disposed of in an off-Site solid
waste landfill, as described in Alternative 3.
Alternative 5- Excavation/ Treatment and either On-site or Off-site
Disposal of Non-Landfill Wastes/ Landfill Cap, and
Leachate Treatment at a POTW
Capital Cost: $1,136,000
Annual O&M Cost: $66,200
Present Worth: $2,154,000
Months to Implement: 6-8
The major features of this alternative include implementation of the
institutional controls as described in Alternative 2; excavation,
stabilization/solidification treatment (if required) and either on-
Site or off-Site disposal of the Carbon Black Pile, Waste Pile, and
the Northern Drainage soils and sediments; off-Site disposal of the
landfill surface drums and debris; installation of a RCRA Subtitle
C cap over the landfill; collection of leachate with treatment at
a POTW; and long-term monitoring.
The elements of this alternative are identical to Alternative 4
except one: the landfill leachate would be collected and transported
to a POTW for off-Site treatment and disposal rather than treated
on-Site in the passive treatment system constructed under the cap
as in Alternative 4. It is estimated that 3,000 gallons of landfill
leachate would be generated on a average daily basis. To maximize
leachate collection, the collection system would be constructed
under the landfill cap. If, during operation, this collection
system does not collect all of the leachate, a second collection
trench would be constructed outside of the landfill cap.
Alternative 6- Excavation, Treatment and either On-Site or Off- Site
Disposal of Non-Landfill wastes, Landfill cap, and
On-Site Leachate Treatment
Capital Cost: $1/211,000
Annual O&M Cost: $73,270
Present Worth: $2/340,000
Months to Implement: 10-12
The major features of this alternative include implementation of the
institutional controls as described in Alternative 2; excavation,
stabilization/solidification treatment (if required) and either on-
Site or off-Site disposal of the Carbon Black Pile/ Waste Pile, and
the Northern Drainage soils and sediments; off-Site disposal of the
landfill surface drums and debris; installation of a RCRA Subtitle
C cap over the landfill; collection of landfill leachate with on-
Site treatment; and long-term monitoring.
The elements of this alternative are identical to Alternative 5
except one: the landfill leachate would .be treated on-Site in a
wastewater treatment plant and discharged to Lawless Creek. The
discharge to Lawless Creek must meet the Virginia Pollution
t
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Discharge Elimination System (VPDES) effluent discharge limits as
established by the Virginia State Water Control Board (VSWCB).
Bench-scale tests of the leachate treatment system would be required
during the design phase.
Alternative 7- Excavation, Treatment and either On-Site or Off-site
Disposal of Non-Landfill wastes/ Landfill cap,
Construction of Slurry Walls/ and Leachate Treatment
either On-Site or at POTW
Capital Cost: $1,282,000
Annual O&M Cost: $39,450
Present Worth: $1,889,000
Months to Implement: 8
The major features of this alternative include implementation of the
institutional controls as described in Alternative 2; excavation,
stabilization/solidification treatment (if required), and either on-
Site or off-Site disposal of the Carbon Black Pile, Waste Pile, and
the Northern Drainage soils and sediments; off-Site disposal of the
landfill surface drums and debris; installation of a RCRA Subtitle
C cap over the landfill; construction of slurry walls around the
inside perimeter of the quarry highwall; leachate collection with
treatment either on-Site or at a POTW; and long-term monitoring.
The elements of this alternative combine the leachate treatment
options of Alternatives 5 and 6 and are identical to the other
elements of these two alternatives except one: slurry walls would
be constructed around the inside perimeter of the quarry highwall
in order to prevent the horizontal flow of ground water into the
landfill, thus reducing the total amount of leachate flowing from
the landfill. However, leachate production cannot be completely
eliminated by the slurry walls because ground water enters the
bottom of the landfill due to the fractured bedrock and flows upward
through the landfill.
Alternative 8- Excavation/ Treatment and either On-Site or Off-Site
Disposal of Non-Landfill Wastes, Consolidation of
Landfill Waste including a Liner and aa Underdrain
System/ Landfill Cap, and Leachate Treatment either
On-Site or at POTW
Capital Cost: $4/015/633
Annual O&M Cost: $28/150
Present Worth: $4/450/000
Months to Implement: 8
The major features of this alternative include implementation of the
institutional controls as described in Alternative 2; excavation,
stabilization/solidification treatment (if required); and either on-
Site or off-Site disposal of the Carbon Black Pile/ Waste Pile, and
the Northern Drainage soils and sediments; off-Site disposal of the
landfill surface drums and debris; excavation and consolidation of
all of the landfill wastes onto a liner and under drain system in the
t
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quarry area; installation of a RCRA Subtitle C cap over the
landfill; leachate collection with treatment either at a POTW or at
an on-Site treatment plant; and long-term monitoring.
The elements of this alternative are identical to Alternative 7
except one: prior to installing the landfill cap, the landfill
wastes would be excavated, consolidated, and placed on top of a
liner in the quarry area to remove the wastes from the ground water,
thus reducing the production of leachate from the landfill.
Alternative 9- Excavation, Treatment and either On-8ite or Off-site
Disposal of Non-Landfill Wastes, In-Situ
Stabilisation of Landfill Wastes, and Landfill Cap
Capital Cost: $4,573,000
Annual O&M Cost: $23,750
Present Worth: $4,940,000
Months to Implement: 6-8
The major features of this alternative include implementation of the
institutional controls as described in Alternative 2; excavation,
stabilization/solidification treatment (if required), and either on-
Site or off-Site disposal of the Carbon Black Pile, Waste Pile and
the Northern Drainage soils and sediments; in-situ stabilization or
solidification of the landfill wastes; installation of a RCRA
Subtitle C cap; and long-term monitoring. Prior to implementation
of this alternative, treatability tests would have to be performed
in order to determine the proper stabilization/solidification
reagents.
The elements of this alternative are identical to Alternatives 3
through 8 except that most of the landfill contents would be
stabilized or solidified in place. The 3,000 cubic yards of soil
cover and the 65,000 cubic yards of landfill wastes would be
stabilized or solidified in place, thereby reducing the solubility
of the metallic contaminants (metals) and producing a waste which
is of low permeability and leachability such that leachate
production, and the need to collect or treat leachate, is
eliminated. The buried drums and tires would not be stabilized or
solidified because the drill mechanism cannot penetrate and properly
blend them. Therefore, the drums and tires would be excavated and
disposed of off-Site at a hazardous waste facility in accordance
with the VHWMR.
8.
The nine remedial action alternatives described above were assessed
in accordance with the nine evaluation criteria as set forth in the
NCP at 40 C.F.R. S 300.430(e) (9). These nine criteria are
categorized below into three groups: threshold criteria, primary
balancing criteria, and modifying criteria.
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THRESHOLD CRITERIA
1. Overall protection of human health and the environment; and
2. Compliance with applicable or relevant and appropriate
requirements (ARARs).
PRIMARY BALANCING CRITERIA
3. Long-term effectiveness and permanence;
4. Reduction of toxicity, mobility, or volume through
treatment;
5. Short-term effectiveness;
6. Implementability; and
7. Cost.
MODIFYING CRITERIA
8. State acceptance; and
9. Community acceptance.
These evaluation criteria relate directly to requirements in Section
121 of CERCLA, 42 U.S.C. Section 9621, which determine the overall
feasibility and acceptability of the remedy.
Threshold criteria must be satisfied in order for a remedy to be
eligible for selection. Primary balancing criteria are used to
weigh major trade-offs between remedies. State and community
acceptance are modifying criteria formally taken into account after
public comment is received on the Proposed Plan. A summary of the
relative performance of the alternatives with respect to each of the
nine criteria follows. This summary provides the basis for
determining which alternative provides the "best balance1* of
tradeoffs with respect to the nine evaluation criteria.
1. Overall Protection of Human Health and the Environment
A primary requirement of CERCLA is that the selected remedial action.
be protective of human health and the environment. A remedy is
protective if it reduces current and potential risks to acceptable
levels within the established risk range posed by each exposure
pathway at the Site.
Alternatives 1 and 2 accomplish none of the above. Because
contaminants are migrating and contaminant levels already exceed
health-based levels, Alternatives 1 and 2 would not be protective
of human health or the environment. Since protection of human
health and the environment is a threshold criteria for any Superfund
action, these two alternatives cannot be selected and thus will not
be evaluated any further with regard to the nine criteria.
The selected alternative. Alternative 5, is protective of human
health and the environment because it would reduce the risks
associated with direct contact of the Site contaminants to within
the EPA acceptable risk range by excavation of and, if required,
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stabilization/solidification treatment of the non-landfill wastes;
off-Site disposal of the non-landfill wastes, surface drums and
surface debris; installation of a RCRA Subtitle C cap over the
landfill; and collection and treatment of leachate. Alternative 9
is the most protective of human health and the environment because
it entails treating all of the contamination at the Site, including
the landfill wastes which would eliminate the production of
leachate. Alternatives 3, 4, 6, 7, and 8 would provide adequate
protection of human health and the environment by eliminating,
controlling or reducing Site-related risks through a combination of
treatment, engineering controls, and institutional controls. The
slurry walls installed under Alternative 7 and the consolidation of
the landfill wastes in Alternative 8 do not provide any additional
protection because their purpose is to reduce, but not eliminate,
leachate production, thus leachate treatment would still be
required.
2. Compliance with ARARs
This criterion addresses whether or not a remedy will meet all of
the Applicable or Relevant and Appropriate Requirements (ARARs) of
other environmental statutes and/or provide grounds for invoking a
waiver under the NCP at 40 C.F.R.300.430(f)(1)(ii)(c).
All alternatives will meet the respective ARARs of Federal and State
laws. Prior to disposal in an off-Site solid waste facility in
accordance with the VSWMR, the non-landfill wastes will undergo a
TCLP to determine if they are RCRA characteristic wastes. If such
wastes are determined to be characteristic, they will be treated by
stabilization/solidification. The cap construction in Alternatives
3 through 9 will meet the action-specific ARARs, including a RCRA
Subtitle C cap and the full range of monitoring for thirty years
because tetrachloroethylene was disposed into the landfill.
Although the landfill contains RCRA-regulated wastes
(tetrachloroethylene), the RCRA Land Disposal Restrictions (LDRs)
are not applicable requirements to Alternatives 3 through 9.
Alternatives 3 through 7 do not provide for treatment or placement
of the landfill wastes. Although Alternative 8 includes the
excavation and placement of landfill wastes, the LDRs are not
applicable requirements because the wastes are consolidated in the
same Area of Contamination and the wastes are not treated. The LDRs
are not applicable to Alternative 9 because the wastes are treated
in place and no placement of treated waste occurs.
In all alternatives, the water from the north and south ponds will
be tested prior to discharge to the POTW to assure compliance with
the pretreatment requirements of the POTW. In Alternative 5, and,
possibly Alternatives 7 and 8, the leachate will also have to be
tested for compliance with the pretreatment requirements of the
POTW. Any water to be discharged which does not meet the
pretreatment requirements must be pretreated on-Site to meet these
requirements. Alternative 6, and, possibly Alternatives 7 and 8,
will to meet the VPDES effluent discharge requirements established
" -22-
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by the VSWCB. The residuals of any on-Site treatment will be
disposed of in a hazardous waste facility because the water was in
contact with the landfill wastes.
The loss of the wetland areas of the north and south ponds and the
small stands of cattail and phragmites in the Northern Drainage
will be mitigated by replacement with plantings of additional
wetland species in the berms along the Northern Drainage.
3. Lona-Term Effectiveness and Permanence
This evaluation criterion addresses the long-term protection of
human health and the environment once remedial action clean-up goals
have been achieved, and focuses on residual risks that will remain
after completion of the remedial action.
The selected alternative, Alternative 5, would reduce the risk posed
by the contaminated media. Even though the landfill contents would
not be treated, the risk of exposure would be reduced to the EPA
acceptable risk range by installing a RCRA Subtitle C cap and
implementing institutional controls to prohibit development of the
Site. Because Alternative 9 incorporates solidification/
stabilization treatment of the landfill wastes, it does not require
long-term management of waste on-Site. As such, Alternative 9 would
have a greater degree of permanence than Alternatives 3 through 8
where the landfill wastes are left in-place without any treatment.
Bench scale testing would be required to confirm the effectiveness
of Alternative 9's treatment system. Alternatives 3 through 9 all
provide for the off-site disposal of the surface drums and debris
as well as the excavation and disposal of the Carbon Black Pile,
Waste Pile, and the Northern Drainage soils and sediments, thus they
are all equal with respect to the lack of residual risk from
contaminated materials.
Alternative 5, with collection and discharge to a POTW, has a
greater degree of permanence than Alternatives 3 and 4, which rely
on passive treatment systems on-Site. Alternative 5 would also
allow the natural flow of ground water through the landfill contents
in order to continue the flushing of contaminants from the landfill,
which should decrease the total period in which contaminated
leachate is produced and requires treatment. By reducing the time
needed for leachate treatment, Alternative 5 offers a higher degree
of long-term effectiveness than Alternatives 7 and 8 which reduce,
but not eliminate, the flow of ground water through the landfill.
The on-Site leachate treatment system of Alternative 6 and,
possibly. Alternatives 7 and 8 (if on-Site treatment is utilized)
have the least long-term effectiveness. Since the treatment system
would be on a remote unmanned location, a malfunction could go
undetected and cause a release of inadequately treated water to the
environment.
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4. Reduction of Toxicitv. Mobility, or Volume through Treatment.
This evaluation criterion addresses the degree to which a technology
or remedial alternative reduces the toxicity, mobility, or volume
of a hazardous substance. Although Section 121(b) of CERCLA, 42
U.s.c. Section 9621(b), establishes a preference for remedial
actions that permanently and significantly reduce the toxicity,
mobility, or volume of hazardous substances, EPA expects to use a
combination of treatment and engineering controls to achieve
protection of human health and the environment, as set forth in the
NCP at 40 C.F.R. S 300.430(a)(iii). EPA's expectations are that
treatment should be utilized whenever principal threats occur and
that containment will be considered for wastes that pose a
relatively low long-term threat or where treatment is impracticable.
Alternative 5 is in conformance with these expectations since the
low-level risks associated with the landfill wastes will be
contained and the non-landfill wastes, surface drums and landfill
leachate will be treated.
Alternatives 4 through 9 provide for treatment of the Carbon Black
Pile, Waste Pile, and the Northern Drainage soils and sediments
should such material be determined to be RCRA characteristic wastes.
Such treatment would be solidification/stabilization, which reduces
toxicity and mobility, but increases volume. Because the
contaminants of concern in these areas are metals, this treatment
should effectively render the wastes non-characteristic by binding
the contaminants,. If these wastes are determined to be RCRA
characteristic, Alternative 3 would not reduce the mobility of the
contaminants because it does not provide for any treatment of the
wastes. Alternatives 3 through 9 all address the toxicity and
mobility of surface debris by providing for the off-site disposal
of the surface drums in an approved RCRA facility.
Alternative 9 would markedly reduce the volume of leachate by
immobilizing the landfill wastes in the solidification/
stabilization process, thus eliminating the need to treat leachate.
Alternative 8 would reduce the leachate volume to a greater extent
than Alternatives 3 through 7 by raising the landfill wastes above
the ground water and placing the wastes on a liner. Alternative 7
would also reduce the amount of leachate produced, although to a
lesser extent than Alternative 8, via use of slurry walls around
the landfill. Alternatives 3 through 8 all reduce the mobility and
toxicity of leachate by collecting and treating the leachate.
5. Short—Term Effectiveness
This evaluation criterion addresses the period of time needed to
achieve protection of human health and the environment, and any
adverse impacts that may be posed during the construction and
implementation period of a remedy, until cleanup goals are achieved.
Alternatives 3 through 9 provide for the excavation of the Carbon
Black Pile, Waste Pile and the Northern Drainage soils and
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sediments; thus, these alternatives are equal in terms of the
associated short-term impacts. Environmental impacts will be
minimized by installing erosion and sedimentation controls such as
runoff control berms in the Northern Drainage and siltation fencing
as needed.
Alternatives 3 through 6 have the least potential to adversely
affect the community or Site workers during remedial activities
because these alternatives do not involve any disruptive activities
on the landfill wastes except for the removal of the surface drums
and debris. Conversely, the implementation of Alternatives 7, 8,
and 9 require the excavation of landfill waste. Alternative 7
includes the excavation of approximately 1,500 cubic yards of
landfill waste to install a slurry wall around the quarry perimeter.
Excavation could uncover and bring to the surface potentially
contaminated materials that could pose a health risk to the Site
workers. Also, a water management system will be required to
collect potentially contaminated run-off and sediment from the
excavation zone to prevent release to the environment. Alternative
8, which provides for the excavation of 68,000 cubic yards of
material, would require an extensive run-off and sediment management
system and would be far more disruptive than the excavation
associated with Alternative 7. In addition, it would be very
difficult to move this large quantity of waste because of the quarry
highwall and the surrounding steep slopes. The auger ing and mixing
action of the solidification/stabilization treatment under
Alternative 9 would be less disruptive than the excavation
associated with Alternatives 7 and 8. However, because the
equipment cannot penetrate and mix the buried drums and tires, these
items must be excavated prior to initiating the treatment process.
Such excavation would be complicated to perform due to the
difficulty in determining the location of drums and tires below the
surface of the landfill and conducting work on the unstable landfill
surface.
Alternative 5 would have the fewest short-term effects of all the
alternatives with regard to leachate. Discharging to an existing
treatment plant would result in proper leachate treatment in the
shortest amount of time. The passive treatment system of
Alternatives 3 and 4 and the on-Site treatment plant of Alternative
6 would necessitate a start-up time until leachate was being
properly treated. These plants then would allow the discharge of
partially treated leachate until such time as when they were fully
operational and meeting discharge limits.
6. Imolementabi1itv
This evaluation criterion addresses the technical and administrative
feasibility of a remedy, including the availability of materials and
services needed to implement the chosen remedy.
Alternative 5 would be the most technically feasible to implement
because it entails discharge to an existing wastewater treatment
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plant. The leachate would be properly treated by meeting the
pretreatment requirements of the POTW.
Alternatives 3 through 9 all provide for the excavation and disposal
of the non-landfill wastes as well as installation of a RCRA
Subtitle C cap over the landfill. These activities could be
implemented easily, using readily available materials and equipment
such as front-end loaders and roll-off boxes or tarpaulined dump
trucks. Cap construction is a known technology. The confined
nature of the landfill, however, with the quarry walls on three
sides, may present implementation difficulties which would have to
be taken into account during the design phase. Alternative 8 would
be complex to implement because of the difficulty of determining
appropriate engineering controls to prevent or minimize the
production of contaminated water and sediment which would occur from
precipitation falling onto the open face of the landfill during the
excavation of the landfill contents. Alternative 9 would be the
most difficult alternative to implement because the buried drums and
tires would have to be excavated prior to the blending of the
columns to prevent jamming the drill rig.
Alternative 3 could not be implemented if the non-landfill wastes
are determined to be RCRA characteristic wastes because these wastes
would then have to be treated prior to disposal.
7. Cost
CERCLA requires selection of a cost-effective remedy that protects
human health and the environment and meets the other requirements
of the Statute. The alternatives are compared with respect to the
present worth cost, which includes all capital costs and the
operation and maintenance costs incurred over the life of the
project. Capital costs include those expenditures necessary to
implement a remedial action, including the construction cost.
'The present worth costs developed in the FS for comparing the
alternatives included 30 years of leachate collection and treatment.
At present, the length of time required for treatment is not known,
however, a longer treatment period is anticipated for Alternatives
7 and 8 in which the ground water f low is reduced.
Of Alternatives 3 through 9, Alternative 7 has the lowest present
worth cost. However, because it includes the installation of cut-
off walls to reduce the amount of leachate produced, Alternative 7
will incur higher treatment costs than Alternatives 3 through 6.
In other words, leachate will have to be treated for a longer period
of time in Alternative 7 than for Alternatives 3 through 6.
Alternatives 8 and 9 are the most costly with present worth costs
of $4,450,000 and $4,940,000, respectively. The difference in cost
among Alternatives 3 through 6 is minimal; costs range from
$2,035,000 to $2,340,000. The cost of the selected alternative,
Alternative 5, is $2,154,000. A breakdown of the costs of the
selected alternative is provided in Table 3.
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TABLE 3
Alternative 5
Capital Cost Summary
O
Institutional Control $ 44,200
Remove and treat carbon black,
waste pile and northern drainage
soil and assess removal action $ 210,020
Cap Construction $ 745,107
Testing and Design Cost . $ 113,426
Leachate Collection system S 23.700
TOTAL CAPITAL COST $ 1,136,453
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8. state Acceptance
The Commonwealth of Virginia has concurred with the remedy selected
in this Record of Decision.
9. Community Acceptance
On April 16, 1991, a public meeting was held at the Bethel Baptist
Church on Route 360 in Danville, Virginia to discuss EPA's preferred
alternative as described in the Proposed Plan. A public comment
period for the Proposed Plan was held from April 10, 1991, through
May 9, 1991. Comments received during the public meeting and the
public comment period are discussed in the Responsiveness Summary
attached to this ROD.
9. Selected Remedy
EPA has selected Alternative 5 with some modifications (as indicated
below) to remediate the contamination at the Site. Based on the
findings in the RI/FS and the nine criteria listed in Section 8 of
this Decision Summary, Alternative 5 represents the best balance
among the evaluation criteria.
Performance Standards
The remedy selected addresses all of the contaminated media at the
Site and consists primarily of excavation and off-Site disposal of
the non-landfill wastes, off-Site disposal of the surface drums and
debris, installation of a RCRA Subtitle C cap over the landfill, and
collection and treatment of leachate. By instituting all of these
components, the Site risks (exposure to leachate, source material,
and quarry soil) would be reduced to within the EPA acceptable risk
range. The major components of this alternative include the
following:
• To reduce the risks to human health and the environment
attributed to the source material, approximately 1080 tons of
material from the carbon Black Pile, Waste Pile, and the.
Northern Drainage soils and sediments shall be excavated and
disposed of off-Site. The Carbon Black Pile and the Waste Pile
shall be excavated down to the bedrock. To determine if the
soils and sediments from these three areas are RCRA
characteristic wastes, a TCLP shall be performed on these
materials prior to disposal. If it is determined through the
TCLP that the soils and sediments are characteristic wastes,
they shall be solidified/stabilized prior to disposal. EPA
will determine the specific treatment during the design phase.
Disposal shall be in a solid waste landfill in accordance with
the VSWMR. All excavated areas shall be filled with clean
soil, contoured to promote run-off, and planted with vegetation
to control erosion. Run-off control berms shall be constructed
in the Northern Drainage to lessen peak run-off flows from the
landfill cap and shall be planted with wetland-type vegetation
to mitigate the loss of the Site wetland areas. In addition,
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the effectiveness of the removal of the Carbon Black and Waste
Piles on the reduction of the zinc levels in the Southern
Drainage shall be assessed, including sampling and bioassays.
• To reduce the risk to human health attributed to the source
material, the drums on the landfill surface shall be disposed
of in a RCRA Subtitle C treatment facility because
tetrachloroethylene, a RCRA listed waste, was placed in the
drums. It is estimated that there are approximately thirty to
forty drums on the surface of the landfill and along the quarry
highwall. To help maintain the integrity of the landfill cap,
the surface debris shall be decontaminated and then disposed
of in a landfill approved by the Virginia Department of Waste
Management.
• To reduce the risks to human health attributed to the quarry
soil, a RCRA Subtitle C cap shall be constructed over the
landfill area, which is approximately 2 acres in size. The
north and south ponds shall be drained and the water
transported to a POTW for treatment and discharge. Prior to
discharge, the water shall be analyzed to determine if it meets
the pretreatment requirements of the POTW. Clean fill shall
be placed onto the existing surface of the landfill before
constructing the cap to fill in the north and south ponds and
to establish the requisite slopes for the cap. A 6-inch layer
of topsoil shall be placed on top of the cap and vegetated to
control erosion. As part of the cap construction, a leachate
collection system shall be installed under the cap to
effectively capture all of the leachate generated through the
landfill. If, during operation, EPA determines that this
collection system does not capture all of the leachate, another
collection trench shall be constructed outside of the landfill
cap.
• To reduce the risk to human health attributed to the
leachate, the leachate shall be transported to a POTW for
treatment. The leachate shall be analyzed prior to transport
to the POTW to determine whether the leachate meets the
pretreatment requirements of the POTW or whether pretreatment
is required. EPA, in consultation with the POTW, will determine
if pretreatment is needed and whether it may be conducted at
an on-site facility or at an industrial user's facility. If
a POTW does not agree to accept the leachate or if the leachate
cannot be pretreated to meet the pretreatment requirements of
the POTW, a treatment system shall be constructed on-Site to
treat the leachate, with discharge to Lawless Creek. On-site
treatment of leachate shall meet the VPDES effluent discharge
limits set by the VSWCB. Collection and treatment of leachate
shall continue until the contaminant levels meet a 10 risk
level and an HI less than 1.
• To ascertain that the remedy is protective of human health
and the environment, long-term post-closure ground water
monitoring shall be performed. Ground water monitoring,
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including the full list of priority pollutants specified in
TCL/TAL, shall be conducted after the cap is constructed. The
ground water monitoring shall be performed for thirty years or
as long as leachate is collected and treated, whichever is
longer. EPA will determine the appropriate number and location
of monitoring wells during the design phase. If continued
monitoring over a period of time indicates the existence of
only a limited number of contaminants, a request may be made
to limit the monitoring to those specific contaminants.
• To restrict access and development of the Site, institutional
controls shall be implemented, including fencing of the Site
and implementing deed restrictions to prohibit residential
development of the Site.
EPA may modify or refine the selected remedy during the remedial
design and construction. Such modifications or refinements, if any,
would generally reflect results of the engineering design process.
The estimated present worth cost of the selected remedy is
$2,154,000. Details of the costs for the selected remedy are shown
in Tables 4 through 8.
10. Statutory Determinations
EPA's primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the
environment. In addition, Section 121 of CERCLA, 42 U.S.C. 9621,
establishes several other statutory requirements and preferences.
These specify that, when complete, the selected remedial action for
this Site must comply with applicable or relevant and appropriate
environmental standards established under Federal and State
environmental laws, unless a statutory waiver is justified. The
selected remedy must also be cost-effective and utilize permanent
treatment technologies or resource recovery technologies to the
maximum extent practicable. The statute also contains a preference
for remedies that employ treatment as a principal element. The
following sections discuss how the selected remedy for the Site
meets these statutory requirements.
Protection of, Iftflyan Health and the Environment.
In order to meet the remedial objectives outlined in the FS, the
risks associated with exposure to the contamination at the Site must
fall within the acceptable risk range for carcinogens and non-
carcinogens. Removal of the Carbon Black Pile, Waste Pile and the
Northern Drainage soils and sediments, capping the landfill, and
leachate collection will assure the Site risks fall within this
range. The selected remedy protects human health and the
environment by:
1. Reducing contaminant levels in the Carbon Black Pile,
Waste Pile and the Northern Drainage soils and sediments
»«
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TABLE 4
Alternative 5
Capital Cost
Institutional Controls
Material and Labor Cost
Survey fence line 3000 Ft. @ $1.00 /Ft. $ 3,000
Prepare Plat 500
Galv. Fence 6 Ft. high 3000 Ft. @ $13.40/Ft. . 40,200
File Deed Restriction ' 500
Total $44,200
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TABLE 5
Capital Cost
EXCAVATE CARBON BLACK, WASTE PILE AND NORTHERN DRAINAGE SOILS
CARBON COST
80 hrs. @ $75/hr.
100 hrs. @ $42/hr.
100 hrs
16 hrs
32 hrs.
§ $32/hr.
@ $100/hr.
@ $75/hr.
Site Supervisor
Equipment Operator
Technician
Project Manager
Project Manager
Secretarial
Expenses
EQUIPMENT AND MATERIAL
Mixer
Dump Truck
Track Excavator
Pressure Washer
Wind Meter
Water Tanker
Level. D Equipment
X-Met Analyzer
X-Met Analyzer
Trailer
Delivery & Removal
Telephone
Power
Toilet
40' X 100' X 6 ML Polyethylene @ $140/roll X
Geotextile Silt Fence 1000 Ft. @ $1.35/LF
Seeding 1000 SY § $1.16/SY
Mulch 1000 SY @ $180/1000 SY
Subtotal
4 hrs. § $30/hr.
Subtotal
10 days § $200/day
10 days § $300/day
10 days € $300/day
10 days § $75/week
2 week @ $50/day
2 week @ $350/wk
10 days @ $45/lay
Training
Rental
2 week 8 $150/wk
$ 6fooo
4,200
3,200
1,600
2,400
120
3.600
$21,120
$ 2,000
3,000
3,000
750
100
700
450
450
1,400
300
500
50
100
50
560
1,350
1,160
180
$14,900
Treatability Testing
8 Samples Total Zinc f $50/ea.
6 Samples TCLP Metals i $350/ea.
Treatment 1080 Tons § $50/ton
Subtotal
ASSESSMENT OF REMOVAL ACTION
TOTAL
$17,500
400
2,100
54.000
$74,000
$100.000
$210,020
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TABLE 6
ALTERNATIVES 5
CAPITAL COSTS
CAP CONSTRUCTION
MATERIALS AND LABOR
Clear Light Trees
Grub Stumps
Clearing (debris and trash)
Dewater Ponds Pump
Tank Truck Rental
Disposal Cost POTW
Fill For Quarry
Haul Fill 5 Miles
Compact Fill
Clay, Select Fill
Haul Fill 5 Miles
Bentonite
Spread Bentonite
Compact
Drainage Layer
Haul 5 Miles
Topsoil
Haul 5 Miles
Grass Seeding
Mulch
2 acres i $2, ISO/acre
2 acres @ $l,025/acre
2 areas § $2,100/acre
2 days @ $ 100/day
2 days § $ 320/day
25,000 gal@ $1.5/1000 gal
15,000 cy e $ 7.00/yd
15,000 cy § $ 2.79/5 miles
15,000 cy § $ 6. 25/cy
8,000 cy @ $10. 85/cy
8,000 cy § $ 2. 79/cy
800 cy e $ 6.75/cy
800 cy § $ 3. 25/cy
8,800 cy 6 $ 6. 25/cy
2,000 cy § $10. 85/cy
2,000 cy § $ 2. 79/cy
2,000 cy 6 $14.70/cy
2,000 cy @ $ 2. 79/cy
15,000 sy § $ 1.16/sy
15,000 sy @ 5 1.80/1000 sy
$ 4,300
2,050
4,200
200
640
37
105,000
41,850
93,750
86,800
22,320
5,400
2,600
55,000
21,700
5,580
29,400
5,580
17,400
2.700
Subtotal $506,507
EQUIPMENT RENTAL, HEALTH AND SAFETY, MANAGEMENT AND EXPENSES
Pressure Washer
Trailers
Delivery and Removal
Telephone
Power
Toilets
Water Tanker
Health and Safety
Level D
Site Supervisor
Secretary
Expenses
4 months 9 $
4 months 6 $
400/mo
300/mo
4 months
4 months
4 months
4 months
120 days
120 days
120 days
120 days
120 days
§ $ 100/mo
8 $ 150/mo
@ $ 200/mo
e $l,700/mo
8 $ 900/day
§ $ 45/day
8 $ 600/day
8 $ 240/day
8 $ 100/day
Subtotal
$ 1,600
1,200
1,000
400
600
800
6,800
108,000
5,400
72,000
28,800
12.000
$238,600
Materials, Labor and Equipment
TOTAL
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TABLE 7
ALTERNATIVE 5
capital cost
Leachate Collection
Excavate Trench
Geotextile
Stone
Sump Pumps
Piping
Storage Tank
Containment
Design
Installation
30 cy rock § $75/cy
60 sy 6 $3/sy
70 cy § $20/cy
100 ft @ $7.50/ft
10,000 gallon
$ 2,250
ISO
1,400
500
750
6,000
2,500
2,700
7.420
TOTAL
$23,700
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TABLE 8
ALTERNATIVE 5
s O & M COST
Cost sane as Alternative 3 less treatment system $20,750
LEACHATE COLLECT AND HAUL
Haul 170 trips @ $125 ea. 21,250
Discharge fee $1.5/1000 gallon 1,500
Testing annual 1,700
Monthly monitoring 12 x 250 3,000
Labor 4 hrs x 180 x $25/hr. is.OOP
Subtotal $45,450
O & M COST $66,200
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by excavating, treating (if required), and disposing of
these wastes in an approved off-site facility;
2. Eliminating direct contact with the landfill wastes by
constructing a RCRA Subtitle C cap over the landfill,
meeting the RCRA landfill closure requirements, and
implementing deed restrictions to prohibit residential
development of the Site. Landfill closure will also
reduce the likelihood of contaminant migration; and
3. Reducing the contaminant levels in the landfill leachate
by collecting the leachate and treating it at a POTW. it
is not known at this time how long the leachate will
remain contaminated.
Of all of the alternatives evaluated, Alternative 5 provides the
best protection to human health without significant adverse impact
to the environment. No unacceptable short-term risks or cross-
media impacts would be caused by implementing this remedy.
Compliance with Applicable or Relevant and Appropriate
Requirements.
The selected remedy will comply with all Applicable or Relevant and
Appropriate Requirements (ARARs) as depicted in Table 9.
Chemical-Specific ARARs: The selected remedy will achieve
compliance with chemical specific ARARs related to the non-landfill
wastes. Specifically, the Carbon Black Pile, Waste Pile and the
Northern Drainage soils and sediments would undergo a TCLP test to
determine if they are RCRA characteristic wastes in accordance with
40 C.F.R. Part 261.
Action-Specific ARARs: If the non-landfill wastes are determined
to be RCRA characteristic wastes, they will be treated (either
' solidified or stabilized) prior to disposal. The surface drums will
be sent to a RCRA facility for disposal. The surface debris will
be decontaminated on-Site and sent to a solid waste landfill in
accordance with the VSWMR. Transportation to a RCRA-permitted
treatment/disposal facility would conform with RCRA regulations at
40 C.F.R. Parts 262 and 263, the Department of Transportation
regulations of Title 49 of the U.S. Code and Part VII of the VSWMR.
Capping of the landfill with a RCRA Subtitle C cap will conform with
the requirements set forth at 40 C.F.R. Part 264 and Part 10 of the
VSWMR. The substantive requirements of the Virginia Erosion and
Sediment Control Law will be achieved. The landfill leachate will
be treated at a POTW if it meets the pretreatment requirements.
Location-specific ARARs: To mitigate the loss of wetlands that will
be filled in or excavated as part of the remedial action, plantings
of wetland vegetation will be made in the newly constructed berms
in the Northern Drainage.
Other Criteria, Advisories or Guidance To Be Considered: None
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Standards,
Requirements,
Criteria,
or Limitations
Solid Waste
Management Act
(SWMA)
SWMA
Citation
40 C.F.R.
Section 261
40 C.F.R.
Section 268
(Subpart D)
SWMA
40 C.F.R.
Section 268
(Subpart D)
SWMA
40 C.F.R.
Section 268
(Subpart D)
TABLE 9
ACTION-SPECIFIC ARARs
Description
Hazardous Waste
determinat ion
requirements
Applicable/
Relevant and
Appropriate
yes/no
Land Disposal yes/no
Restrictions
for off-site
disposal of
non-landfill
wastes, if RCRA
characteristic waste.
Land Disposal yes/no
Restrictions
for on-site
disposal of
non-landfill
wastes, if RCRA
characteristic waste.
Land Disposal no/yes
Restrictions
for on-site
consolidation of
landfill wastes.
Discussion
Alternatives 4-9.
Non-landfill wastes
will undergo TCLP to
determine if RCRA
characteristic
waste.
Alternative 3.
Alternatives 5-9.
Alternatives 4-9.
Alternative 8.
-------
Standards,
Requirements,
Criteria,
or Limitations
Clean Water Act
(CWA)
TABLE 9 (continued)
ACTION-SPECIFIC ARARs
Citation
40 C.F.R.
Section
122.44(a)
Description
Discharge of
treatment system
effluent to
Lawless Creek.
Applicable/
Relevant and
Appropriate
yes/no
CWA
CWA
40 C.F.R.
Sections
125.100,
125.104,
122.41(1),
136.1-136.4
40 C.F.R.
Part 230,
33 C.F.R.
Parts 320,
and 330
Discharge of
treatment system
effluent to
Lawless Creek.
Discharge of fill
material into
wetlands.
yes/no
no/yes
Discussion
Alternatives 6-9.
Best available
technology
economically
achievable and best
conventional
pollution control
technology required
to control toxic and
nonconventiona1
pollutants and
conventional
pollutants,
respectively.
Alternatives 6-9.
Best Management
Practice Program
to prevent release
of toxic
constituents to
surface waters.
Alternatives 3-9.
-------
Standards,
Requirements,
Criteria,
or Limitations
CWA
Virginia Water
Quality Standards
Virginia Erosion
and Sedimentation
Control Law
Virginia Hazardous
Haste Management
Regulation (VHWMR)
VHWMR
Citation
40 C.P.R.
Section
122.44
Virginia
Regulation
680-21-00
VA Code
Sections
10.1-560
et seq.
VHWMR
Section 10.5
VHWMR
Section 10.6
TABLE 9 (continued)
ACTION-SPECIFIC ARARs
Description
Ambient Water
Quality Standards
for discharge of
treatment system
effluent into
Lawless Creek.
State Water Quality
Standards for
discharge of
treatment system
effluent to
Lawless Creek.
Applicable/
Relevant and
Appropriate
yes/no
Ground water
monitoring
requirements
for closure.
Closure and
post closure
requirements for
hazardous waste
facilities.
yes/no
yes/no
yes/no
yes/no
Discussion
Alternatives 6-9.
Alternatives 6-9.
Alternatives 2-9.
Alternatives 2-9.
-------
Standards,
Requirements,
Criteria,
or Limitations
VHWMR
Citation
VHWMR
Section
10.13.K
TABLE 9 (continued)
ACTION-SPECIFIC ARARS
Description
Landfill closure
requirements.
Applicable/
Relevant and
Appropriate
yes/no
Discussion
Alternatives 2-9.
-------
Standards,
Requirements,
Criteria,
or Limitations
Safe Drinking
Hater Act
Virginia Water
Quality Standards
Citation
40 C.F.R.
Section
141.11
Virginia
Regulations
680-21-00
TABLE 9 (continued)
CHEMICAL-SPECIFIC ARARs
Description
Maximum Contaminant
Levels for discharge
of treatment system
effluent to Lawless
Creek.
Site specific limits
for discharge of
treatment system
effluent to Lawless
Creek.
Applicable/
Relevant and
Appropriate
yes/no
yes/no
Discussion
Alternatives 3-9,
Alternatives 3-9.
-------
Standards,
Requirements ,
Criteria,
or Limitations
Executive Order
11990 (Wetlands
Protection)
Citation
40 C.F.R.
Part 6
(Appendix A)
TABLE 9 (continued)
LOCATION-SPECIFIC ARARs
Description
Wetland protection
and restoration.
Appl icable/
Relevant and
Appropriate
yes/no
Discussion
Alternatvies 3-9.
Clean Water Act
40 C.F.R.
Part 230,
33 C.F.R.
Parts 320,
and 330
Discharge of fill
material into
wetlands.
no/yes
Alternatives 3-9.
-------
Cost-Effectiveness
The selected remedy is cost-effective because it mitigates the risks
posed by the Site contamination within a reasonable period of time.
Section 300.430(f)(ii)(0) of the NCP requires EPA to evaluate cost-
effectiveness by first determining if the alternative satisfies the
threshold criteria: protection of human health and the environment
and compliance with ARARs. The effectiveness of the alternative is
then determined by evaluating the following three of the five
balancing criteria: long-term effectiveness and permanence;
reduction of toxicity, mobility or volume through treatment; and
short-term effectiveness. The selected remedy meets these criteria
and is cost-effective because the costs are proportional to its
overall effectiveness. The estimated present worth cost for the
selected remedy is $2,154,000.
Utilization of Permanent Solutions and Alternative Treatment
(or resource recovery) Technologies to the Maximum Extent
Practicable fMEPl.
EPA has determined that the selected remedy represents the maximum
extent to which permanent solutions and treatment technologies can
be utilized in a cost-effective manner for remediation of the Site.
Of those alternatives that are protective of human health and the
environment and comply with ARARs, EPA has determined that the
selected remedy, Alternative 5, as modified, provides the best
balance of trade-offs in terms of long-term effectiveness and
permanence; reduction in toxicity, mobility or volume through
treatment; short-term effectiveness; implementability; and cost;
while also considering the statutory preference for treatment as a
principal element and considering state and community acceptance.
Alternative 5 was selected because it offers a higher degree of
long-term effectiveness, implementability, and short-term
effectiveness than the other alternatives. The strategy for
remediating the leachate is to allow the natural flow of ground
water through the landfill contents with collection and treatment
of leachate. By maintaining the natural flow conditions, it is
projected that the leachate will meet health-based levels in a
shorter period of time than reducing the flow as in Alternatives 7
and 8. Utilizing a POTW offers more long-term effectiveness for the
treatment of leachate than the on-Site treatment plants contained
in Alternatives 3, 4, and 6 and, possibly, 7 and 8. Alternative 5
was selected over Alternatives 3, 4 and 6 because the use of a POTW
to treat the leachate has greater reliability than a small on-Site
treatment system since the POTW would have close monitoring of the
plant operations while the on-Site plant would be unmanned in a
remote area. In addition, utilizing an existing POTW would
eliminate the need for a start-up period for the treatment of
leachate.
Although Alternative 9 would be more protective and have greater
long-term effectiveness than the other alternatives, it was not
selected because it may not be implementable. The in-situ
• i
-31-
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stabilization/solidification of the landfill contents in Alternative
9 would require the excavation of all of the buried drums and tires
which, at best, would be very difficult to locate. It would also
be difficult to perform this removal work on the surface of the
landfill.
Alternative 8, and, to a lesser extent, Alternative 7 would have
short-term effects from the excavation of the landfill material,
Alternative 7 in placing the slurry walls around the landfill and
Alternative 8 in consolidating all of the landfill material onto a
liner. Alternative 9 would also have short-term effects from the
excavation of the buried drums and tires, although to a lesser
extent than Alternatives 7 and 8.
The Virginia Department of Waste Management has concurred with the
selected remedy. The Proposed Plan for the Site was released for
public comment on April 10, 1991. The Proposed Plan identified
Alternative 5 as the preferred remedy. As a result of public
comment, EPA decided to modify the preferred remedy described in the
Proposed Plan to include the option of leachate pretreatment at an
industrial user's facility prior to discharge to the POTW. The
Proposed Plan included only pretreatment in an on-site treatment
plant. This change allows a choice between either the on-site plant
or an existing industrial user's facility. If a determination is
made that pretreatment is required, EPA, in consultation with the
POTW, will determine during the design phase how and where to
pretreat.
Preference for Treatment as a Principal Element.
The selected remedy satisfies, in part, the statutory preference for
treatment as a principal element. The major human health risk
associated with the Site is from ingestion of landfill leachate.
The selected remedy reduces the levels of arsenic, antimony, barium
and lead in the leachate by using the POTW to remove these
contaminants in the treatment process. Also, if the Carbon Black
Pile, Waste Pile or the soils and sediments of the Northern Drainage
are determined to be RCRA characteristic wastes, they will be
treated by either solidification or stabilization so that they no
longer constitute characteristic wastes.
11. Doctfi|<^T^jfttion of significant Changes
The Proposed Plan, which identified Alternative 5 as EPA's preferred
alternative for the Site, was released for public comment on April
10, 1991. EPA reviewed all written and verbal comments submitted
during the public comment period and determined that no significant
change to the remedy identified in the Proposed Plan was necessary.
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