United States        Office of
          Environmental Protection   Emergency and
          Agency           Remedial Response
EPA/ROD/R03-92/140
March 1992
ŁEPA    Superfund
          Record of Decision;
          Fike Chemical, WV

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                                          NOTICE

The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document All supplemental material is, however, contained in the administrative record
for this site.

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50272-101
 REPORT DOCUMENTATION
        PAGE
                        1. REPORT NO.
                            EPA/ROD/R03-92/140
                                                                     3. Recipient's Accession No.
 4. Title and Subtitle
   SUPERFUND RECORD OF DECISION
   Fike Chemical,  WV
   Third Remedial  Action -  Interim
                                                                   S. Report Date
                                                                     03/31/92
 7. Author)*)
                                                                     8. Performing Organization Rept No.
 9. Performing Organization Name and Address
                                                                   10. Project/Task/Work Unit No.
                                                                     11. Contr»ct(C) or GrantfG) No.

                                                                     (C)

                                                                     (G)
 12. Sponsoring Organization Name and Addreaa
   U.S.  Environmental  Protection  Agenc\
   401 M Street,  S.W.
   Washington,  D.C.  20460
                                                                   13. Type ol Report & Period Covered

                                                                      800/000
                                                                     14.
 15. Supplementary Notes

    PB93-963908
 16. Abstract (Limit: 200 words)
   The  11.9-acre Fike Chemical  site is a  former chemical  manufacturing plant  and
   associated wastewater treatment facility located in  Nitro, West  Virginia.   Land use in
   the  area is predominantly  industrial,  with the Kanawha River located approximately
   one-half mile from the site.   The estimated 2,500 people who reside within 1  mile of
   the  site obtain  drinking water from a  treatment plant  located  15 miles upstream, which
   uses the Elk River as a source of water.   The facility is situated on the  site of a
   World War I munitions plant.   In 1951,  the original  chemical plant was constructed and
   began operating.   From 1978  to 1988, Fike Chemical manufactured  more than  60  chemicals
   at the site and  disposed of  drummed and containerized  wastes in  pits and trenches
   located throughout the facility until  the facility was abandoned in mid-1988.  There
   are  no known records regarding the contents of the drums and containers or details of
   their disposal at the site.   As a result of previous state and federal environmental
   enforcement actions, EPA conducted numerous investigations that  revealed VOCs,  other
   organics, metals,  and other  inorganics in buried drums and containers.  Previous RODs
   addressed the removal of bulk chemicals stored in surface drums  and tanks  as  well as
   the  dismantling,  decontamination, and  disposal of tanks, equipment, and structures

    (See Attached Page)
                                          WV
17. Document Anaiyaia a. Descriptors
  Record  of  Decision  -  Fike Chemical,
  Third Remedial Action - Interim
  Contaminated Medium:  debris
  Key Contaminants: VOCs (xylenes,  PCE, solvents),  other organics  (dioxins, pesticides,
                     phenols), metals,  other  inorganics
  b. Identifiers/Open-Ended Terms
    c. COSATl field/Group
  18. AvailabiBty Statement
                                                      19. Security Class (This Report)
                                                             None
                                                      20. Security Class (This Page)
                                                             None
                                                                               21. No. of Pages
                                                                                 56
                                                                                22. Price
 (See ANSI-Z39.18)
                                       See Instructions on Reverse
                                                                               OPTIONAL rvHM 272 (4-/1)
                                                                               (Formerly NTIS-3S)
                                                                               Department of Commerce

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EPA/ROD/R03-92/140
Fike Chemical,  WV
Third Remedial  Action - Interim

Abstract (Continued)

located onsite.  This interim remedy ROD addresses the removal of buried drums and
containers as OU3 to eliminate future or continued contamination of soil, ground water,
surface water,  and the atmosphere.  Future actions will address continued investigation
and possible remediation of soil, ground water,  surface water and the existing sewer
system.  The primary contaminants of concern in the buried waste pits are VOCs, including
PCE and xylenes;  other organics,  including dioxins, pesticides, and phenols; metals; and
other inorganics.

The selected remedial action for this site includes the excavation of between 7,000 and
17,000 buried drums and containers;  use of a self-supported portable structure to enclose
active excavation areas and to minimize organic vapor and dust emissions; and sampling,
testing, repackaging, and shipping of drummed waste; offsite incineration or other
equivalent treatment technologies for drums containing solids and liquids; onsite storage
of dioxin-contaminated wastes; treatment of cylinders with a cylinder recovery vessel;
and treatment of  any ground water collected during the excavation at the cooperative
sewage treatment  plant.  The estimated present worth cost for this remedial action is
$16,059,000.  There are no O&M costs associated with this remedy.

PERFORMANCE STANDARDS OR GOALS:  Although this interim action does not provide for
chemical-specific clean-up standards, it does provide for the removal of source
contamination in  accordance with state and federal requirements.  Performance standards
will be established in future OUs addressing site media contamination.

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                       Record of Decision
                    PiXe/Artel Chemical sit*
                           Declaration
Site Name and Location

Fike/Artel Chemical Site
Nitro, West Virginia
Operable Unit Three


statement of Basis and Purpose

This Record  of  Decision presents the selected  remedial  action
for the buried drums  and  containers at  the Fike/Artel Chemical
Site  in  Nitro,  West  Virginia,  chosen  in accordance with  the
Comprehensive   Environmental   Response,    Compensation   and
Liability Act of  1980,  as amended  (CERCLA), 42  U.S.C.  Section
9601  et seq,  and,  to  the  extent  practicable,  the  National
Contingency  Plan  (NCP).    This  decision  is  based  on  the
Administrative Record for this Site.

The State of West Virginia concurs with the selected remedy.


Assessment of the site

Pursuant to  the  duly delegated authority,  I hereby  determine,
pursuant to Section 106 of CERCLA, 42 U.S.C. Section 9606, that
actual or threatened, releases of hazardous substances from this
site, as discussed in "Summary of  Site Risks" on Pages  9  and
10,  if  not addressed  by  implementing  the  response  action
selected in  this Record of Decision,  may present an  imminent
and substantial endangerment to public  health,  welfare,  or the
environment.
Description of the Remedy

This  interim  remedy (Operable Unit. Three)  is the third  major
step  toward  the remediation  of  the Fike/Artel Chemical  Site.
Operable  Unit Three  (OU-3)  will  assure protection of  human
health and the environment from risks associated with  buried
2drums and containers by excavating and  removing them from the
site.    The  objective of OU-3  is to  eliminate  future  or
continued  contamination  of  soil, .ground  water,   air and/or
surface water from sources contained  in the buried  drums  and
containers; eliminate the  potential for  direct exposure of the
public  to  contaminants  contained   in  the  buried  drums  and
containers through subsurface collapses  or  future  excavations;
and eliminate risks associated with buried drums and  containers
for  future  site  work.    OU-3  does  not  address  all  risks
associated with  the  Fike/Artel  Chemical Site.  Future  actions
will  involve  continued investigation and possible remediation
of  soil,  groundwater,  surface  water,   and  a  sewer system

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underlying the site.  Remedial  actions  for  these areas  will be
presented in a future Record of Decision(s).

The Selected Remedy includes the following major components:

     •    Excavation of  between 7,000 and  16,000 buried  drums
          and containers

     •    Implementation of technologies to provide  protection
          to  the public  health and  environment, and  to  the
          workers   during   drum   excavation   and   handling
          operations

     •    Use of a self-supported portable structure  to  enclose
          active  excavation areas  and  to  minimize  vapor  and
          dust emissions

     •    Treatment of organic  vapor  emissions  with  Granulated
          Activated Carbon

     •    Sampling,  compatibility  testing,   and processing  of
          the drummed waste before incineration

     •    Shipment of bulked or drummed waste by rail or truck

     •    Off site incineration of drums containing  solids  and
          liquids

     •    Use  of  more cost-effective  treatment technologies
          that   are   equivalent  (achieve   remedial goals)to
          incineration where appropriate

     •    On site storage of dioxin-contaminated wastes

     •    Treatment  of  cylinders  with  a   cylinder recovery
          vessel

     •    Treatment  at the Cooperative Sewage  Treatment  Plant
          of ground water collected during  drum excavation


statutory Determinations

This  interim action is  protective  of  human  health  and  the
environment,  complies  with Federal  and State applicable  or
relevant and  appropriate requirements except for RCRA  closure
requirements which are. hereby waived  under  the  "interim remedy
waiver"  provisions  of  CERCLA  Section 121(d)  and  is  cost-
effective.   Although  this  interim action  is not intended to
address  fully   the  statutory  mandate  for   permanence  and
treatment  to  the  maximum extent  practicable,  this  interim
action  does utilize treatment  and thus  is in  furtherance of
that statutory mandate.   The* statutory  preference for remedies
that  employ  treatment  that  reduces toxicity,  mobility,   or
volume  as a principal element,  is partially addressed  in this
remedy  and  will  be more fully  addressed by the final response
action.   Subsequent actions are  planned to address fully  the

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threats posed  by the  conditions  at this  Site.   Because  this
remedy will  result in hazardous  substances remaining on  site
above health-based levels, a review will be conducted to  ensure
that  the  remedy continues  to provide  adequate protection  of
human  health   and  the  environment   within  5 years  after
commencement  of the   remedial  action.     Because  this  is  an
interim action ROD, review of this site  and of this  remedy  will
be  ongoing  as EPA   continues  to  develop   final   remedial
alternatives for the site.
 Q ^^   • s0^%c^             J////?
Edwin B. Erickson
Regional Administrator             Date
EPA Region III

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                      I. Decision Summary



Site Name, Location, and Description

The Fike/Artel  Chemical Site  (hereafter referred  to as  "the
site") is  located approximately 500 feet northwest  of downtown
Nitro,  West Virginia in  the Nitro  Industrial  complex  (see
Figure 1).   The Site contains a former chemical  manufacturing
plant and  an associated former waste-water  treatment  facility.
Other areas found  to have contamination associated  with  the
former operations at  the plant will also be considered as  part
of  the   site   for  purposes   of   remedial   action.      The
Kanawha/Putnam  County line bisects  the site  in an  east-west
direction.   The site  is  located on an  access roadway off  of
Viscose Road (also known as Plant Road),  which is accessed  from
WV Route 25.  The site occupies approximately  11.9 acres  and is
bounded  to  the  north  by  Vimasco  Corporation  (a   chemical
manufacturer);  to  the  east by  Consolidated  Rail  Corporation
(railroad  switching  and maintenance yard);  to the  south by an
abandoned  railroad  siding; to the  west,  by Miller Transport,
Inc.  (on  land owned  by T.R.  and C.L. Halloran) ,  and also  by
Dana Container,  Inc.,  both tank wagon maintenance  and washing
facilities  (see Figure 2).   The site  is  approximately 2,200
feet east  of the Kanawha  River.   The Kanawha River, a major
surface water system, has  been categorized  under West Virginia
Water  Quality   Standards  as   suitable   for  water  contact
recreation;   industrial   and   agricultural    water   supply;
propagation  and  maintenance  of   fish;  and  transportation,
cooling, and power.   The  Kanawha River is  not  used for  public
water supply downstream of Charleston,  West Virginia.   Public
drinking water  in the Charleston-Nitro area is provided  by the
West Virginia Water Company using the Elk  River as  a source.
The confluence  of the Elk  and Kanawha Rivers  is in  Charleston,
approximately 15 river miles upstream of Nitro.

The site  is situated  on  the  site, of a  World War  I  smokeless
powder  (munitions)  plant.   The original chemical plant  on the
site began operation in 1951 as the Roberts  Chemical Company.
In 1971, the name was changed to Fike Chemicals,  Inc.("Fike").
In  1986,  the  name  was   changed  to  Artel  Chemical Company
("Artel").   During plant  operation,  more than 60  different
chemicals  were  produced,  all  by batch process  on an  as-needed
basis, including fluoracetonitrile,  ethyl fluoroacetate,  sodium
f luoroacetate, ethylene thiourea, diphenylamine, allyl cyanide,
N, -N'-diisopropyl  carbodimide,  fluoroacetamide,  sodium  amide,
sodium ethylate,  sodium methylate,  sodium  nickel cyanide,  and
thioacetamide.  The facility was abandoned  in June  of  1988.

The  chemical manufacturing plant  consists  of 14 production
areas,  in which   various chemicals  were  manufactured;  39
buildings,  which  include  offices,  laboratories,  warehouses,
tanks; process reactors and process control equipment; 3  closed
waste lagoons;  and drum and waste burial areas.

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•ŁŁ:'V-
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                        POOR QUALITY

                          ORIGINAL

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The  Cooperative  Sewage  Treatment,   Inc.   (CST)  facility  was
formed by Pike and  a  previous truck  terminal operator (Coastal
Tank  Lines,  Inc.)  to treat  sewage  and industrial  wastewater
generated  by  the  two  operations.    The   CST  plant  occupies
approximately  0.9  acres  and  is  located  on  Viscose  Road
approximately  500  feet  west of  the  chemical  manufacturing
facility.   The site  consists  of both the  chemicals  plant and
the treatment plant.

The CST plant consists  of three  treatment  lagoons;  a treatment
control building; a sludge drying bed; and various  wastewater
treatment  equipment  and  tanks.    The  CST  plant  was  also
abandoned by Artel  in June  1988.

The  topography  of  the site  is  generally flat,  with  local
drainage controlled by  a  drainage  ditch located along the east
side  of the  plant  and  storm sewers  located  throughout  the
plant.  These storm sewers, along with three sump pump systems,
transfer drainage and process wastewater from the plant  to the
CST.   Elevations throughout  the plant range  from  596  to 603
feet  above mean  sea level  (amsl), which are  above  the Kanawha
River 100-year flood plain elevation  (586 feet amsl).  The east
drainage  ditch discharges  to a storm sewer beneath viscose
Road.   The  storm sewer eventually discharges into  the Kanawha
River downstream from the site.

The geology  of the site  and  adjacent  study area consists: of
alluvial deposits overlying predominantly  shale  and claystone
bedrock.  The  observed  depth to bedrock at the  site ranges in
depth  from  approximately  55  to 60  feet/  indicating  that the
bedrock  surface is relatively  flat lying,  with minor  local
variations.

Four lithologic units were identified within the unconsolidated
deposits throughout the study area.   In descending  order,  the
deposits  consist of  an   upper  noncontinuous  layer  of  fill
materials composed  of sands,  silts,  and  clay;  a second layer
which is described  as silty clay; a  third  layer  consisting of
mostly  a  fine silty  sand; and  a basal unit consisting  of  a
fine-  to  medium-grained  sand.   These units were  identified
based  on samples   obtained during  monitoring  well  and  soil
boring drilling operations.

The  aquifer  systems  present  at  the site  consist  of  an
unconfined alluvial aquifer  and a semiconfined  to  unconfined
bedrock aquifer.   The  alluvial  aquifer is composed  mainly of
fine-to medium-grade  sand with some .silt,   and has  a saturated
thickness of  29 to 40  feet.   The dominant  flow path is  in  a
northwesterly direction toward the Kanawha River. The alluvial
aquifer  is  in  direct  hydraulic connection  with the Kanawha
River. Hydraulic  conductivity values for the alluvial aquifer
range from 0.027  ft/day to 530.6 ft/day with an  average value
of  71  ft/day.    The  hydraulic conductivity values  for  the
bedrock aquifer range from 2.8 x 10'3 to 9.8 x 10~* ft/day.  The

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hydraulic gradient for the  alluvial  aquifer,  measured parallel
to the direction of groundwater flow, is 0.004 ft/ft.

The bedrock aquifer is  a very tight  formation  composed of  a
competent siltstone.   The thickness of this  formation was  not
determined  during this  investigation.   The bedrock aquifer
groundwater flow direction  is to the west, toward the Kanawha
River.

Nitro,  WV  has  a  population  of  approximately  9,500.    An
estimated 1,500 to  2,500 people reside within a l mile radius
of the facility.    In addition,  the municipal swimming  pool,
ball fields,  and the local junior and senior high schools  are
situated within 1/2 mile of the site.
Site History and Enforcement Activities

The earliest documented enforcement action  was resolved in  a
September  12,  1978,  consent decree filed by the state  of West
Virginia  and Artel,  Coastal Tank Lines, and CST,  requiring
lining  of  the treatment basins at the CST.    Subsequent court
findings  indicate  that Artel  did  not complete  the  actions
required by the consent decree in the time allowed.

In  March of  1982,  EPA issued a  National Pollutant  Discharge
Elimination System  (NPOES)  permit  for wastewater discharges
from the CST plant.

In  1982, the site was evaluated via the Hazard Ranking System
Model to determine if the site should be placed on the National
Priorities  List  (NPL)  established  under Section 105 of CERCLA,
42  U.S.C.  Section 9605.   The resulting score was 36.3.   The
site was proposed for addition to the NPL in December  1982.  In
September 1983, the site was promulgated as an NPL site.

Fike was sued by the  EPA pursuant  to the Clean Water  Act (CWA)
and the Resource Conservation and Recovery Act (RCRA)  for  its
discharges  to  the Kanawha  River  and disposal  of  hazardous
wastes  on  site,  resulting in a Consent Decree  entered  into in
November of 1982,  between  the U.S.,  Artel, and the now defunct
Coastal Tank Lines,  Inc.   This Decree  required the defendants
to  perform diking and paving  of process  areas,  covering of
principal waste disposal sites, and the pumping and treating of
contaminated  groundwater.  Artel did not comply with  the terms
of the  Decree.                      ,-

In June 1983, an EPA  Region III Field  Investigation Team (FIT)
sampling  survey was  conducted  to  collect soil  samples  for
dioxin  analysis,  (2,3,7,8-TCDD).   Based on the results of this
initial screening, additional dioxin sampling  and analysis  was
required.   In March 1984,  EPA issued an order  requiring dioxin
sampling and  analysis to determine the extent  of  contamination

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at the  site.   Fike claimed  to be unable to afford  this work.
Consequently,  EPA  FIT  performed  the  sampling  of  concern.
Results  of this sampling  revealed low  to  moderate levels  of
2,3,7,8- TCDD at the site.

In  1983,  the  West Virginia Department  of Natural Resources
(WVDNR)  issued Administrative  Order No.  829, directing Fike  to
stop  placing waste  in Lagoon  3, a  waste  evaporation  lagoon
located  in the south end of  the chemicals plant.

The Fike chemical manufacturing  plant  (plant)  and  Pike's CST
treatment  facility for this waste are situated on noncontiguous
pieces of  property  and are therefore subject to  seperate RCRA
permitting requirements.

In  May  of  1984,  EPA  issued  an  Administrative  Complaint,
Compliance Order and Notice of Opportunity Hearing for  the Fike
plant.  The complaint cited violations of RCRA and specifically
required that Fike  cease acceptance and storage  of  containers
of  hazardous waste  not included in the  RCRA  Part A  Permit
Application  for  the  plant;  cease  storage of  containers  of
hazardous  waste  in areas  other than those designated  in the
plant's  Part A Permit Application; remove hazardous  wastes not
specified  in  the  plant's  Part  A  Application;  comply  with
operating  record requirements;  and  obtain a  certificate  of
liability  insurance.

Fike  filed  a  RCRA Part  B  Permit  Application for  the CST
facility in December of 1984.  A Notice of Deficiency (NOD) was
returned to  Fike  for  CST in March of 1985.  Fike responded  to
the CST  NOD in June of 1985.   EPA  issued  a public notice  on
November 29, 1985,  of its intent to  deny a Part B  Permit for
the CST facility, as a result of the failure of Fike  to correct
deficiencies in the CST Part B Application.   The EPA  ultimately
denied  the  permit  on  March  14,  1986,  and  terminated the
facility's interim status.    The CST permit  application was
subsequently withdrawn  by Artel.  No  Part B Permit Application
was  ever  submitted for the  Fike chemicals  plant  and  RCRA
interim  status for  this facility  was  also terminated by EPA  on
March 14,  1986.

The  Fike  Chemical  Company changed  its  name  to  the  Artel
Chemical Company in 1986.

In January 1987, WVDNR issued an Order to Artel to specify RCRA
hazardous  waste  materials  accepted  by   the   plant;  manage
containers properly; submit  site  plans,  develop  a plan to mark
containers for  identification purposes;  and submit  an amended
Part A Hazardous Waste  Permit Application for the plant.

The chemicals  plant was abandoned by Artel  in June  of 1988.
Since that time, an EPA Emergency Response  Team (ERT)  has been
on site performing work to control, stabilize,  and/or eliminate
immediate  hazards to the public health and the environment.  On
September  29,  1988,  a  Record of Decision for  the  site was

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signed, authorizing  EPA to utilize remedial funds to  control,
stabilize, and/or eliminate such hazards  (Operable Unit  One  or
OU-1).    in  August  of  1989,  an  Explanation  of significant
Differences  was issued  by EPA, modifying the  scope  of  work
described in the  Record of Decision dated September 29,  1988.
The major modification  was a  decision not to bulk package the
contents of  drums on site for disposal.   In addition,  it was
determined that asbestos  removal  would be  conducted  under  a
subsequent remedial  action.  The focus  of  the ongoing  remedial
action remained the  removal of bulk chemicals stored  in tanks
and drums.  Upon the planned completion of OU-1,  tanks  formerly
storing bulk chemicals  would  remain on site and  (with several
exceptions)    contain   residual    chemicals    which    await
decontamination and  disposal as part of OU-2.

The  CERCLA Remedial  Investigation  was initiated  in March  of
1988.  The  field  activities included sampling of sludges from
CST  lagoons  and  onsite storage tanks;  sampling of residuals
accumulated   within  the  sewer   system;   installation   of
groundwater  monitoring wells;  collection  of   samples  from
existing and newly installed wells;  collection of soil samples
from  background  areas, areas  adjacent  to the CST  and the
chemicals plant,  and from the soil in the process area  of the
chemicals plant; and an evaluation of process and storm  sewers
used  to convey wastewater and stormwater  to  the  CST.    In
addition,  a  comprehensive evaluation and inventory of  tanks,
equipment, process  lines,  structures,  and  concrete pads. was
conducted.   This  evaluation of the plant and other  field work
of concern was completed by December of  1989.   Data  from the
investigation of the chemical plant  components forms the basis
of a Focused Feasibility Study  (FFS) for  the Tanks,  Equipment,
and  Structures,  completed in  July  of  1990  for  OU-2.    On
September  28,   1990  a  second Record  of  Decision  was  signed
calling for  the dismantling and decontamination of  all  tanks,
all  equipment,  and  the  majority of  the buildings located on-
site with subsequent disposal off-site.   It  also calls for the
removal  of  asbestos associated with  these items as  well  as
treatment of all  decontamination fluids  through the CST.   In
September  of  1991   a  Consent Decree  was  signed by  EPA and
thirteen of  the Potentially Responsible Parties  to conduct the
Remedial  Design  and Remedial Action  for  the  OU-2 work.
Additional Remedial  Investigation/Feasibility Study  activities
are underway at this time.

Approximately   200  letters  have   been  issued  to  parties
associated with the  site pursuant  to Section 104(e)  of CERCLA.
Twenty-six  (26) parties have  been notified  of their potential
liability under CERCLA  for past potential future actions taken
at  the site*   These-  parties  were notified  through general
Notice Letters  issued in 1990.  Twenty-two (22)  of the parties
are generators  and four (4) are owner/operators.

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Highlights of Community Participation

Public participation  activities  have been conducted since  the
commencement of the ERT work in June of  1988.  Public meetings
were  held  on  a  weekly  basis  at  the municipal  building  in
downtown Nitro  to update the citizens on the progress of  the
cleanup  actions.   A  public meeting  was held in August  1988
before finalizing the Operable Unit /I Record of Decision  for
the removal of surface drums and contents of  tanks and  to plan
for the  destruction of a cyanide gas cylinder on site  (OU-i).
A  public meeting was held on  August 6,  1990,   at  the Nitro
Senior High School  specifically  for eliciting public comments
on the proposed plan  for Operable  Unit  #2  that addresses  the
tanks, equipment, and structures  (OU-2).   The  proposed plan  for
addressing  buried  drums  and  containers  at  the  site   was
presented at a public meeting held  on  December 9, 1991, at  the
Nitro Senior High School.

Scope and Role of Action

OU-l  addressed  the  removal  of   surface  drums  and  wastes
contained  in  tanks  while  OU-2  will  address removal tanks,
equipment,  and  structures at the site.  The objective  of this
remedial action  is to mitigate risks to public health  and  the
environment associated with buried  drums and  containers at  the
site.  This remedial  action serves as a necessary,  next .step
toward the  remediation of the  site and represents OU-3.  OU-3
addresses a principal threat at the  site—the contents of  the
buried drums and containers. Additional  site  features expected
to  be addressed under  future  Operable Units  include soil,
groundwater, sludges,  and the sewer system.

Characteristics of Buried Drums and Containers

As reported in  interviews with  former plant personnel, still
bottoms  and various  reaction by-products,  both  liquids  and
solids, were placed in drums and  stockpiled or buried onsite in
the waste disposal area covering  the southern  half of the site.
The oldest  and  most worn drums  were used for waste disposal.
The standard procedure for drum burial was to  excavate a pit in
the southern half of  the site  and dump the drummed waste  into
the pit.

Facility personnel indicated that it was  common for drums to be
disposed of without tops or bungs and those that were  covered
often  ruptured  when  they  were   dropped  into  the  pits.
Sometimes,  after a pit  was filled,  a bulldozer was  used  to
crush the drums and backfill the pit with a  final soil cover.
A  daily  soil cover  was not used.   Many drums containing waste
would  rust  or  break  open before final  backfilling  and allow
wastes to flow into the pit (NEXC,  1980,  p. 10).

-------
Subsurface  waste  disposal  reportedly  ceased  in  1978  (NEIC,
1980, p. 20).  Surface  stockpiling  of  drummed waste  apparently
continued until the facility was closed down  in 1988.   A total
of 5,778  surface drums were  inventoried and removed  from  the
site by EPA between 1988 and 1990.

As part of the FFS for buried drums and containers, a review of
available information was performed to identify the most likely
locations of  buried drums,  estimate the  volume or  number  of
buried  drums,  and provide  some insight  as  to  their  possible
contents.   Potential  drum  burial   locations were  identified
through a review of aerial photographs, interviews with persons
familiar with  the facility,  and  geophysical and  magnetometer
surveys.

Figure  3   shows  the  potential   subsurface  disposal  areas
indicating  the probability  of each  containing buried drums.
Each  resulting  potential  subsurface  disposal  area has been
numbered and rated as  either 1 (possible), 2 (probable), or 3
(highly probable), pertaining to the likelihood of the presence
of buried drums.  The rating is based on the number and quality
of sources  used to  identify a potential  buried drum  area  as
outlined below.

     •    1 (possible):  The area was  indicated as a potential
          drum burial area by one of the following sources:

                    Geophysical data from  1988  survey
                    Geophysical data from  1990  magnetometer
                            survey
                    Geophysical data from  1990  EM-31 survey
                    A single interviewee
                    An aerial photograph

     •    2 (probable):  The area was  indicated as a potential
          drum burial area by two or more of the sources listed
          in 1 above.

     •    3 (highly  probable):   The area was  indicated as  a
          potential drum  burial area  by  three or more of  the
          sources  listed in  1  above,  including two geophysical
          sources.

The quantity of buried drums at the site was estimated based on
the  information  available  and several   assumptions.    These
assumptions are  detailed  in the FFS.   Using  these assumptions
and the potential  buried drum  rating system discussed above,  a
range of  estimates of-the number of buried  drums at  the site
was established.   The low estimate  assumes that 100  percent of
the  subsurface  disposal areas ranked as   "highly  probable"
contain  drums and no  other  areas  contain  any  drums.  This
method  produced an  estimate of  7,500 full  drums  and 14,900
empty,  crushed  drums.   The  maximum estimate assumes  that  100
percent  of  all  identified  subsurface  disposal areas  contain
drums.  This  method produced an estimate  of  16,300  full drums

-------
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-------
and 34,000  empty,  crushed drums.   A weighted  average  estimate
assumes that 100 percent of the subsurface disposal areas rated
as  "highly  probable"  contain drums,  67  percent  of  the  area
rated as "probable" contain drums, and 33  percent  of the areas
rated as  "possible" contain drums.   The  estimate produced  by
this  method is  12,600 full  drums and 25,100 empty,   crushed
drums.

There are no known records regarding the  contents  of drums and
containers  or  the details of their disposal  at the site.   No
manifests or files have been located,  nor  has  any documentation
been reported  that may have recorded information regarding the
number,  time,  location,  or  contents  of  drums  buried at  the
site.  Information concerning the  contents of  buried drums and
containers  at Fike has  been  gained through  interviews  with
former facility personnel and review of EPA removal files.

During the  period of  August 22 to 25  in  1977,  NEIC personnel
conducted  interviews  with  Elmer A.   Fike, president  of  Fike
Chemicals,  Inc.   The focus of the interview was the different
processes employed to  generate the products manufactured at the
site.  The raw materials used, byproducts  generated, and method
of  disposal  associated  with  each  process  were  identified.
Mr. Fike  indicated that  some  of  the byproducts and  even  raw
materials were disposed  of  underground.   These products  and
their associated raw materials and by-products are presented in
Table 1.  The  NEIC report does not specify whether underground
disposal  involves  drum  burial  or  simply dumping  the  waste
directly onto  the ground.  Underground disposal was reportedly
terminated  shortly after  the NEIC  interview.

Interviews  with  former facility personnel conducted by  NUS  in
1989  provided minimal  information regarding  burial areas  for
specific chemicals.   Several  sources indicated that sodium was
disposed of in Drum Burial Area No. 8.  The main trench in Drum
Burial  Area  No. 2  was  identified  as  a  disposal  area  for
alcohols.   A portion  of Drum  Burial Area  No.  6 may contain gas
cylinders of  hydrogen sulfide and phosgene.    Drum Burial Area
No. 12  was  identified by one source  as   a  disposal  area  for
drums of orthobenzophenol.

Materials found  in above-ground drums removed  from the site by
the  EPA  may  provide  possible   insight   as   to  the  type  of
materials contained in buried drums and containers at the site.
EPA  removal files  include  drum log data which tabulates  the
results of  compatibility  testing  performed on the above-ground
drums.  These  results are summarized, in Table  2.

NEIC  investigation reports  indicate  that  drum burial ceased in
1977  in accordance with requests made by the EPA as a result of
that  investigation.   At approximately  this time Fike ceased to
manufacture 27 of  the 50 chemical products  and added  12  new
chemical products.   These changes were also  in response to EPA
requests  regarding   the  reduction  of   priority  pollutant
discharges  to  the  CST.    Eight  of the eliminated  products

                               8

-------
TaM01
SUMMARY OP PRODUCTS AND ASSOCIATED RAW MATERIALS
AND BYPRODUCTS DEPOSED OF UNDERGROUND^
AT THE SHE
Pace 1 of 2
*^tMl'M
N-aceryl ethafiolanine
Allyl cyanide*
Aminoethyl SuUuoc Acid
o-Benzl Phenol (OBP)**
Bis isopropyl xanthogen (PXD)—
Sodium bucyl o-phenyi phenol (RWA-50)4*
Sodium fluoroacetate
N methylene piperidinium cydopenta-
methlene dithiocarbanate (R>2 oystais)*

MetaoxyuiftyoM acetate
I
l^proptnfdithiol
DinethylaninofthoiTdiplmylinethaoc"
(Bristamine Base)
Dimethykoadiazene thione (R-240)
Raw Material or
Bypfodoo
heptane
still residua
mfttttT^nf
suUDricadd
peretJoroethykne
n-tnlnpnf. tnlfr"'*'* «^w
jj ~.i— «.«^> •muiruM BW>
p4>entyi phenol
di-benzyl phenol
zyiene
ethaool
o-pbenyi phenol
sulAFloc
sodium soUate
methanol
ethanol
parafonnaldehyde
piperdine
carton bbulflde
methanol
methoxy triglyool
acetic anhydride
ivtoiucflc Yulfonic AcU
acetic acid
polysulflder
residue
heptane

Underground and CST
Underground
Underground
Underground
Air and underground
Underground
Underground
Underground
Underground
CST and underground
CST and underground
CST and underground
Underground
Underground
Evaporation lagoon and
underground
Evaporation lagoon and
underground
Underground
Underground
Underground
Underground
Underground
Underground
Underground
Underground
Underground
Underground
Underground
Buried
Air and CST and
underground

-------
SUMMARY OF PRODUCTS >
AND BYPRODUCTS D
Al
fYin 1 1
riuuuu
Ethyl fluoroacetate
(EH,/
Fluoroacetamide (Tat poison)
Dicthyi Qxadiazenc

ihione (R-235)
Benzyl mercaptan
Butyl phenyf phenol sodium suUbnate**
(RWA-375)
Chloronuldc Anhydride (CMA)*
TTiiftiffffmiiidf wd

yjng dibvty)4ithioc

•Major pMjp»
*MaBufac|gK«f
Source: •^•RM
•E*
uical toxic*
iftxmte fRntvl Zinm)

Tttto 1
^ifD ASSOOATED RAW M
ISPOSED OP UNDEROR01
"THESTTC
RjwMtteritlor
Dypfuduui
ethyl chloroaeettte
ethyl fluoroaceute
methanot
heptane
dibenzyl sulflde
sodium hydroxide
sodium sul&te
salkafloc
maleic anhydride
ferric chloride
acetonitrile
isopropuol
dimethyl cydoherylamine
carboo Mnlflde
zinc oxide
dibntyi amine
[ATERIALS
LJND
Page 2 of 2
Dtopojal
Evaporation lagoon and
underground
Air and underground
Air and underground
Air and CSTand
UiHJBigiVlUIiU
Underground and air
and evaporation lagoon
Underground
Underground
Underground
Underground
Underground and GST
Underground and GST
Underground
Underground
Underground
Underground and air
Underground
Underground
V IHawf JfVy IHI
Underground
T T I_L 	 .n 	 i
W UUvI^lWIUili
Underground
Hodoct disoontinaed in 1977
bmnr 1978, pp. 20-27
ael9aap.ll
POOR QUALITY
  ORIGINAL

-------
TaM02
SUMMARY OF DRUM LOO DATA
Compadbflfcy CbtnaaMe
Soli*
Liquids
Organic* '
Chlorinated Organic!
Acidic Solids (pH<4)
Acidic Liquid (pH<4)
Base Neatnl Solid
Base Neutral Liquid
pH<6
pH>8
Soluble in Water
Insoluble in Water
Soluble in Hezane
Insoluble in Heone
Soluble in Benzene
Insoluble in Bnwfuf
Soluble in DicUoromethane
Insoluble in Dfchloromethane
Peroxide
Ondizer
Cyanide
Sulphur
BieistnTett
"•f*
Reacitowtth Water
Shock Seositto
Reaction with Water and Shock Sensitive
Number of
to—^j^^^
romWB '
2413
2Ł45
1,850
612
439
129
642
604
2494
1,260
3461
2,001
2498
3,468
144
734
1,657
1408
47
182
817
197
1385
1,290
63
32
4
V^M^^M* ^M
. rttlttl Of
Total Number of
Dnai Sampled
46
54
34
11
8
X4
11.8
11
38
23
64
36
37
63
2.6
13
30
29
0.9
33
15
34
35
24
12
0.6
0.07
Source: O.R Materials, 1988 to 1990
POOR QUAU7Y
  o?r- '

-------
generated  waste that  reportedly was  buried underground  (see
Table 1).  Investigation reports also  indicate  that a majority
of the  drums removed  from above ground  storage areas at  the
site in 1988 to 1990  had been  placed in those  storage  areas
since   1977.     Therefore,   their   contents    may   not   be
representative  of  what is contained  in  the buried drums  and
containers.

Over  300  drums and  1,500  5-gallon  pails  containing  sodium
metals  were  found  in concrete  bunkers  located  in the  waste
disposal area at the site  by the EPA.   Sodium metal presents a
severe fire and explosion risk when introduced to water and dry
air and when heated  is  a strong caustic irritant to  tissue.
During an NEIC inspection conducted in 1977 a reported 2,300 to
4,600 kilograms of sodium metal were  stored in the  concrete
bunkers in drums.  During an NEIC investigation in August 1977,
sodium  metal lying on the ground in  the waste  disposal  area
reportedly exploded  only  10 minutes after NEIC  personnel  left
the area.


Summary of Site Risks

Based on observations made  during  the  ITS,  the  hazards  and
risks associated with buried drums and containers  at the site
have been identified by EPA  as follows:

     •    Contaminant  sources contained  in  buried drums  and
          containers may continue or begin to contaminate soil,
          groundwater, surface water,  and the atmosphere.

     •    Contaminant  sources contained  in  buried drums  and
          containers  present a  risk of direct contact to  the
          public   through   subsurface  collapses  or   future
          excavations.

     •    Buried drums and containers  are obstacles preventing
          the  subsurface   investigation of  the  waste disposal
          area.  Without removal of buried drums and containers
          a  comprehensive  investigation  of contamination  in
          these areas cannot be  performed.

A list  of  substances that could be found at the site based on
interview*  and past  surface removal  includes  perchloroethene
which is considered to be  a probable carcinogen by the Agency.
This  substance  is   mobile  in  the   environment   and  could
compromise the  water quality of  any impacted aquifer.   Carbon
bisulfide  is a  very toxic  liquid which is also  very mobile and
could compromise the integrity of the aquifer.  Also, some very
dangerous  gasses  such  as  phosgene,  hydrogen  sulfide,  and
chlorine were  reported to be buried at  this facility.   These
gasses  are  capable  of  causing death with even  very  short
exposures to sufficient concentrations that could occur if the
containers were somehow caused to leak or rupture.

-------
Ethyl fluoroacetate  is  an  ethyl  ester and sodium fluoroacetate
is  a  salt  of  fluoroactic  acid  and  are  part of  a family  of
rodenticides  that are  very  toxic and  must  by handled  with
extreme  caution.   They are also  very  water soluble and  will
impact water systems if given the opportunity.  Fluoroacetamide
is  also a  derivative  of  fluoroacetic  acid  and is also  very
toxic.

Zinc  dibutyldithiocarbamate  (Butyl Ziram)  is used  as a  seed
fungal protectorant.  It is moderately  toxic and there  are two
reports in the scientific literature that this substance caused
tumors in laboratory animals  (mice).  It has also been  reported
to  be a mutagen.   It is currently under test by the  National
Toxicology  Program and  appears  to be  suspected of having  a
carcinogenic potential.

In  addition  to   the   substances   listed  above,  many  other
substances  may  be present that  could  present risks to  human
health  and  the environment.    Other  hazards  such  as  fire,
explosion,  and  other chemical reactions  exist at the  site  in
its present state.

Although removing the buried drums from the subsurface  provides
a significant short term risk it will reduce significantly long
term  risks  as well as  preventing  short term risks which  could
arise  in   the  future  due  to  possible  chemical  reactions
involving the more volatile,  explosive,  and/or  toxic  chemical
which may be buried at  the  site.

Remedial Action Objectives

The remedial action  objectives for buried drums  and  containers
at the site are to:

      •    Eliminate  future or continued contamination  of  soil,
          groundwater,  surface water, and the atmosphere  from
          sources contained in the buried drums  and containers

      •    Eliminate  the potential for  direct exposure of  the
          surrounding   population  to   hazardous   substances
          contained  in  buried  drums    and  containers  (from
          subsurface collapses or  future  excavations)

      •    Remove  buried drums  and  containers  to  facilitate
          future site investigation and remediation.

Potential  releases  of  hazardous  substances  from  the  buried
drums and  containers,  if  not addressed  by  implementing  this
ROD,  may present an imminent and substantial endangerment  to
public health and the environment.
Description of Alternatives
                               10

-------
In  the FFS, remedial  technologies applicable to  the  remedial
action  objectives are identified and  screened  for suitability
based  on effectiveness,  implementability, and cost.   Remedial
alternatives  are  developed  by combining  those  technologies
selected in the screening  process.    These alternatives  are
further evaluated based on overall protection of  human health
and  the   environment;   compliance   with   ARARs;   long-term
effectiveness  and permanence; reduction of  toxicity,  mobility,
or   volume   through  treatment;   short-term   effectiveness;
implementability;  cost;  and state  and community acceptance.   A
total  of nine  alternatives were developed in the  FFS;  four of
the alternatives were eliminated because they did not meet some
critical evaluation  criteria  and  five of  these  nine  were
selected for detailed evaluation.   Therefore,  using the  same
numbering system used  in the  FFS,  the  selected  alternatives
include 1,  5,  7,  8, and  9 and are described below.

Alternative 1—No Action

Under  this  alternative,  no containment,  removal,  or  treatment
of  the  buried drums would be performed.  The drums would remain
in  place and  any discharge  of contaminants to the soil  and
groundwater would continue unmitigated. Buildings and equipment
that  exist on  site  would be  removed under the OU-2  remedial
action  since  there  would  be  no  interference  with  the  OU-3
activities.

This alternative would include continuance  of the present site
security, which consists of a perimeter fence and sign posting.
Deed restrictions would be employed to  restrict future use of
the site.  The no-action alternative  would  also include long-
term  monitoring consisting  of annual  site  inspections  and
sampling of water from the  existing wells at the site.

Under  this alternative,  contaminants would remain onsite  and
the site data would  be reviewed  every 5  years pursuant  to
CERCLA  Section 121,  42  U.S.C.  SECTION 9621.  If  justified by
the 5  year  reviews,  remedial  actions could be taken  in  the
future  to remove or contain the buried drums.

Alternative 5—Contamment With a RCRA Cap and Slurry Wall

This alternative does not involve the removal  of  buried drums
and containers but instead is designed to protect human health
and th« environment by  containing the wastes.   Components of
Alternative 5  consist  of  a RCRA  cap  placed  over the waste
disposal area  and   a  slurry  wall  constructed  around  its
perimeter.   The slurry  wall would be  constructed In  situ and
would   tie  into  the RCRA  Subtitle C cap  and  the  claystone
bedrock roughly 60 feet below grade.   This  alternative would
include demolition of bunkers and other buildings, and removal
of  the  railroad tracks and  sludge  storage tanks, within the
proposed cap area.   The resulting demolition debris  would be
mixed  with imported  fill and  used  for rough grading  for the

                               11

-------
area to  be capped.  In  order to provide an  adequate  base for
the  cap  and  eliminate  voids  that  would  result  in  future
settling,  the debris would have to be reduced to  a specified
minimum -size, mixed thoroughly with fill soil, and spread flat.
The  top 2 feet  of base  material  would be  void  of debris  to
prevent  damage to the  clay-synthetic cap.   The  cap  would  be
revegetated. with  a  healthy  stand  of grass  to minimize  soil
erosion.  Existing sub-surface sewer lines would be filled with
grout,  and  water  would  be  used  for  dust  control  during
construction.     Stormwater   management   and  erosion  control
process options  would  be used as needed.  Access  restrictions
and  administrative controls would  be used,  and a  groundwater
monitoring  program  using  existing  and  new  wells  would  be
established.   Buildings  and equipment left on  site  under this
alternative  would be addressed under the OU-2  remedial action
since  there would be  no interference with  the OU-3  remedial
action.

A  groundwater  monitoring/pumping  well  would  be  constructed
within the perimeter of the containment area near the northwest
(downgradient) corner.   This  well  would be used to monitor the
groundwater  level within the containment area and ensure that a
positive   inward   gradient  is  maintained.     If   pumping  is
necessary to maintain an inward flow, the extracted water would
be characterized  and discharged  to the CST or shipped off-site
for treatment.

Alternative 7—Removal and Off-site Incineration

This   alternative  consists  of  the  excavation   and  onsite
processing of  the buried drums followed by  incineration of the
wastes contained  in  the  drums at an off-site incinerator.  Due
to  the  possibility of  interference  with  the OU-2  remedial
action  because of the possibility that the  implementation  of
the OU-2 and OU-3 remediation nay overlap on a portion of the
south  process area  of  the  site,  any  buildings or equipment
which  cannot be  removed in the OU-2  action because  of those
actions taken  for OU-3 will be removed in a  subsequent action.
The  key  components  and  procedures  incorporated  into  this
alternative  are  shown  in Figure 4 and are discussed in detail
below.

Drum Removal aad Processing.   The excavation and processing of
the  buried drum*  would  be  conducted using  standard state-of-
the-art  drua removal,  handling  and processing equipment, and
procedures,   and  also   employs  a   self-supported  portable
structure  to  enclose  active  excavation  areas  and  to control
vapor  and  dust emissions.  The  specific  procedures that would
be  followed  for drum  removal,  drum  processing,   and related
activities are described below.
                 p
     •     Confirmation    of    drum   locations-The   potential
           subsurface disposal areas indicated in the FFS would
           be staked out and test pit(s)  would  be  excavated as


                               12

-------
U~

I**'*""' »
                                      tMMtoCSt
                                     fMM ••*•«•
                                                                             ALTERNATIVE 1

                                                                                   UquMtwitf
                                                                  **HtftHttt\m+
                                                                  MMtoOOl
       IlimtfianoflrtclM  I

         "-•-    I
=1
                                                                                              Sk»»Ml«»
                                                                           ALTERNATIVE •
                                                                       ALT! RMATIVE t
                                                           Flgura4
                                                           SCHEMATIC FOR REMOVAL. TREATMENT AND
                                                           DISPOSAL ALTERNATIVES 7.8. AND 9
                                                           FIKE CHEMICALS
                                                           NNro. West Virginia

-------
needed  at  each  area  to  confirm the  existence  or
absence of buried drums.  Test pits would be dug with
a track hoe equipped  with the protective  apparatus
discussed below.

Excavation  of  fill—Cover and backfill soil  would  be
excavated from around the areas determined to contain
buried  drums.    Excavation would  be conducted  with
standard  track-mounted  hydraulic hoes.    The  hoes
would be equipped with  the appropriate explosion and
fire protection/prevention equipment.  Hoe arms would
be a  minimum of  25  feet long.  Delicate  excavation
around buried drums would  be performed using a high-
powered vacuum truck (vector)  capable of  excavating
solids.  Earth would be moved using front-end loaders
and dump trucks.   Excavated soil would be stockpiled.
Surface soils  that  had been found to contain dioxin
during   previous   soil   investigations   would   be
segregated.    An estimated  26,000  cubic  yards  of
combined drums and soil would require excavation.

Excavation of drums and containers—Buried drums would
be excavated with standard, track-mounted  hydraulic
hoes  with   drum  grappler attachments.     In  some
instances,  drum-lifting attachments  requiring manual
assistance  could be required.   Excavated drums would
immediately  be placed  in  overpacks.   Contents  from
drums with  extremely poor integrity would  be placed
in new  metal or  fiber  drums.   Empty drums  would  be
placed  in  roll-off  containers for future  scrapping.
An estimated 12,000 drums  of waste and  25,100 empty
drums would be evaluated.

Excavation  of drums  on Holloran  property—Potential
Subsurface  Disposal  Area 8   is  located  beneath  a
section of  the existing Miller Transportation Garage
on  the  Thomas   Holloran property.     This  area
reportedly  was used  for  the  disposal  of drums  of
sodium  metal.    Further  investigation  during the
Remedial  Design  phase  must be done  to verify the
prescence  of these  drums.   The appropriate action
will  be  taken  after  the  investigation  has  been
completed.   If  drums  are determined  to be  present
they  vill  most  likely b« removed  from  under the
property .

Drum  transfer and staging—Overpacked drums  would  be
staged  for  opening, sampling, and temporary storage
using forklifts  with drum grippers or backhoes with
drum  grapplers.   Existing buildings located in the
process area, as veil  as new  temporary storage, areas
would  be used.   Because  all drums  would be over-
packed,  secondary  containment  areas  would  not  be
required.
                     13

-------
Drum opening and sampling—Drums would be opened using
a   remote,   nonsparking,   hydraulic  drum   plunger
attached to  a  backhoe arm.   Drum contents would  be
sampled using a sample thief for liquids and a coring
tool  for  solids,  and  drums   would  be   resealed.
Overpressurized  drums would  be  opened and  sampled
using a tube and spear device.

Gas cylinder opening, sampling,  and  disposals-Using a
Cylinder Recovery  Vessel (CRV), gas  cylinders  would
be sampled and identified,  and gases  would  be treated
onsite  by the  CRV  if  possible or placed  in new
containers for off-site disposal.

Compatibility  testing—Compatibility   tests  would  be
performed on samples  from  each drum  using  an onsite
analytical  laboratory.    Compatible   drums  would  be
stored together.  Drum contents will  also be analyzed
for dioxins.

Empty drum  scrapping—Empty drums would be  shredded
within the encapsulated  area, vapors will  be treated
by carbon absorption  and residue would  be  collected
for treatment, decon  fluids will be  sent to the CST,
and decontaminated metal would be disposed  of offsite
as  scrap.    An  estimated  25,000  drums   would  be
shredded.

Free liquids removal  and dewatering-free liquids and
groundwater   encountered    during   drum    removal
activities  would  be  removed  from   excavations  by
positive displacement pump*.   Free  liquids  would  be
placed in drums and treated with other drummed waste.
The  volume   of  free   liquids   encountered  during
excavation is expected to be minimal.  If groundwater
is encountered it would be collected  for treatability
testing prior to discharge to the CST.  If  analytical
results  indicate  that  contaminant  concentrations
exceedo the  treatment  capabilities  of  the CST, the
groundwater  would  be shipped   to  a  RCRA-permitted
treatment  facility.   If  the  amount  of  water to  be
treated  by  the CST causes a possible  exceedance  of
capacity for the sludges generated then those sludges
will be removed and  treated  or stored to  allow the
CST to continue operation.

Dust and vapor  control and treatmenfr-ouring remedial
activities,  dust and vapor emissions from  the site
would   b«   controlled.     Hater would be  applied
periodically  to  surface  soils to  suppress  dust.
Plastic covers or tarps would be placed on stockpiles
of  excavated soil  to control  both  vapors  and dust
emissions.   Vapor and  dust  emissions from active
excavations would  be  controlled by encapsulating the
                     14

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active  excavations and  work areas  and by  treating
exhaust air for participates and organic vapors.

A   self-supported,   portable   structure   would   be
constructed on  the site.    This  structure would  be
large  enough  to  enclose  the  largest  anticipated
excavation.   Upon completion  of  drum excavation  in
one area, the excavation would  be backfilled and  the
structure would be moved to the next location.   All
activities potentially involving significant releases
of  organic vapors would  be  conducted  within  the
structure.  This structure  would  be operated  under
negative pressure  and  would be equipped with an  air
filter  and vapor phase  granular  activated carbon
(GAC)   treatment  system  to  remove  dust and  organic
vapors   from   air    before   it    is    discharged.
Contaminated GAC and air filters will be  incinerated
off-site.

Air monitoring—Continuous,   real-time  monitoring  of
air for vapors and particulates would be  provided in
all work areas.   Monitoring instruments  would include
combustible gas indicators,  oxygen  meters,  toxic  gas
analyzers,   and   opacity   meters  and   standard
meteorological   equipment.      Up-   and   down-wind
conditions would be monitored on a  24-hour basis  and
would  be  documented  regularly  by  collecting  and
analyzing air samples  for vapors and particulates.

stormvater management  and erosion  control-  off-site
surface  water will  be  diverted from  the  site  by
diversion  dikes   and   ditches   installed  around  the
perimeter of the site.  Onsite  surface  water will be
collected  in  ditches  and diverted  to  the  existing
site  storm  sever  system.    Soil   erosion  control
measures will be used  to minimize sediment transport
to  the  sewer system.   The  CST  currently treats
surface runoff from the site.   Additional  runoff is
not  b«  expected  as   a  result  of Alternative  7
activities.

Management of open excavations—Completed  excavations
will be backfilled with the excavated soil.   Soils
known  to be  contaminated  with dioxin  will be  kept
segregated.  Where there  is insufficient  backfilling
soil, the excavations will be shored if necessary and
covered. • Contaminated soil will  be  handled  in  a
future  operable  unit.   An interim waiver will  be
invoked for RCRA closure requirements.

Explosion  and  fire  prevention/protection-fixplosion
and firs  hazards  may exist  and all activity must be
performed   with  , appropriate   health   and   safety
requirements.
                     15

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     •    Access -  Access  restricrtions will be placed  around
          the  site  to  deter  trespassing  during  and   after
          remedial action.

Treatment  of Wastes.    After the  drums  of waste  have  been
sampled and  characterized,  they would be transported  off-site
for treatment by incineration.  Any wastes encountered  that may
pose  a problem  for  off-site treatment  or disposal  will  be
stored  on site  until  a  future response  action.    Off-site
incineration would involve the following procedures.

     •    Waste  manifesting  and bulking—If  possible,  wastes
          would  be  bulked  for  transportation.     Compatible
          liquid wastes  would be placed in tanker trucks,  and
          solids  would  be   placed   in  roll-off   containers.
          Wastes would be  bulked within the encapsulated area
          or  other  location where vapors could be  contained.
          Wastes  that cannot be  bulked would  be  segregated
          according  to compatibility, overpacked,  and shipped
          together.   Before bulking and/or  shipping, composite
          waste  samples  from each proposed truckload will  be
          collected  and  analyzed for dioxins  and other  para-
          meters   required   to  characterize    wastes   for
          transportation manifests and incineration.

     •    Neutralization of  acid wastes-Acidic wastes will be
          pretreated  if  necessary  by  neutralizing  with  lime
          before    sending    off-site    for   incineration.
          Neutralization may  also be  used as a sole treatment
          in  instances where acidic  wastes are determined to
          contain no other contaminants of concern.

     •    Off-site  incineration-Wastes  will  most  likely  be
          .shipped to an off-site incinerator  by  truck  unless
          there  is   a   direct   rail   line   to  the accepting
          facility.

     •    Treatment  of  dioxin-contaminated wastes—Drums  found
          to  contain wastes contaminated by dioxins  would be
          stored  at  the  site  for   future  treatment.    Such
          treatment   would   likely   occur  along  with   the
          remediation of dioxin-contaminated soils and sludges
          presently on the site.  Currently, no incinerators in
          the  United States  are permitted  to handle dioxin-
          contaminated wastes;   however,  this may  not be  the
          case at  the time of remedial  action  implementation.
          If  permitted,  drums  containing  dioxins  would  be
          incinerated off-site with other wastes.

     •    Treatment   of  sodium   metal  waste-Drums  found  to
          contain sodium metal waste  would require repackaging
       .   before  being  shipped  off-site  for  incineration.
          Because  of its  extremely  reactive  characteristics,
          sodium  metal   waste  would  be  repackaged  in l-quart
          container*  (or smaller) and immersed in  an  oil such

                               16

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          as diesel  fuel.  Repackaging would be performed in an
          inert  nitrogen atmosphere to prevent ignition.  Site
          drum  removal  records  stated  that  approximately  5
          percent  of  the  drums  found   aboveground  contained
          sodium metal.    However,  a  large  amount  of  this
          material  was  left  over from the  Fike manufacturing
          operation.   It is assumed that  the relative volume of
          waste  sodium metal would be much  less.   One percent
          has been  used for estimating purposes.  This amounts
          to  an  estimated   126  drums.    Based  on  employee
          interviews,  it is assumed that the majority of these
          drums  are buried beneath the garage on the Holloran
          property.

     •    Recycling—All  chemicals contained in  drums  that can
          be  recycled cost-effectively will be  considered for
          recycling.

     •    Alternative   treatment   technologies—Following   the
          excavation,  removal,  and characterization  of  wastes
          contained   in   buried   drums  and  containers,   other
          treatment  technologies  capable  of achieving treatment
          levels equivalent to  the best demonstrated available
          technology  under  40  CFR  Part 268   (Land  Disposal
          Restrictions)  and  that will meet ARARs more cost-
          effectively, will  be  considered  by  EPA.   However,
          alternative   treatment  technologies   will  only  be
          employed   at   the   site   with  EPA   approval   and
          authorization.

Alternative 8—Removal and Onsite Incineration With    •
Off-site Disposal

This   alternative   consists  of  the excavation  and  onsite
processing of the buried drums followed by incineration with an
onsite rotary  kiln  incinerator.   Incinerator  ash would  be
disposed  of off the  site at a RCRA-permitted landfill.  The key
components  and procedures  incorporated  into this alternative
are shown in Figure 4 and are discussed  in  detail below.   Any
buildings or  equipment  that could  not be removed in  oy-2
because of this  action will be  removed at the appropriate time
under  this action.

Drum Rsaovml  and Processing.  The excavation and processing of
the buried drums would be performed as outlined in Alternative
7.  The methods outlined in Alternative 7 would also be used to
handle and  treat   free  liquids,  groundvater,   surface  water,
excavated soil,  vapor and dust  emissions, and empty drums.

Treatment and Disposal  of  Wastes.   After the drums  have been
excavated and processed,  the wastes would be  incinerated as
discussed below.
                               17

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     •    pnsite   incineration-During   compatibility  testing,
          wastes   would   be  analyzed  for  Btu   content   and
          classified  for incineration.   Incineration  could  be
          performed  using  a  mobile two-chamber  rotary kiln.
          Exhaust  gases  from the  incinerator  would be  cooled
          and   scrubbed   before  exiting   the  stack.     The
          incinerator  would   oxidize  organic   contaminants.
          However,  the  waste  ash would  have  to  meet  TCLP
          requirements  or  would require  disposal  in a  RCRA
          Subtitle C-permitted facility.

     •    Neutralization  of acidic wastes—Acidic wastes would
          be   neutralized . if   necessary   as  discussed   in
          Alternative 7.

     •    Treatment  of  dioxin-contaminated  waste—The  onsite
          would be capable of reducing dioxin concentrations to
          below land disposal restriction concentrations.

     •    Waste  manifesting—Incinerator  waste  ash  would  be
          sampled  and analyzed  for transportation and disposal
          requirements.

     •    Transportation   and  disposal-Waste  ash  would  be
          shipped  to an off-site  RCRA Subtitle C  permitted
          landfill in bulk by truck unless there is  a  direct
          rail line to the  disposal facility.

     •    Treatment  and  disposal of sodium  metal waste—Sodium
          metal  waste would  be treated  and disposed  of  as
          outlined in Alternative 7.

Alternative 9—Removal And Onsite Incineration and Stabilization With
Off-site Disposal

This   alternative   consists  of  the   excavation  and  onsite
processing  of the  buried drums  followed by onsite incineration
using  a  mobile  incinerator.    Incinerator  ash  would then  be
stabilized  at  the  site  with   pozzolanic   reagents  prior  to
disposal  at an  off-site RCRA  Subtitle C permitted landfill.
The  key  components  and  procedures  incorporated  into  this
alternative are shown in Figure 4 and  are  discussed in detail
belov.    Any buildings  or  equipment which  cannot  be removed
under  the OU-2  remedial action  because of  those  actions under
this operable unit will  be dealt with under this action at the
appropriate tin*.

Drus Removal mad Processing.  The excavation and processing of
the buried  drums would be conducted as outlined in Alternative
7.   The methods discussed  in Alternative 7  would also be used
to handle and treat free  liquids,  groundwater,  surface water,
excavated soil, vapor and dust  emissions,  and  empty drums.
                               18

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Treatment  and Disposal  of  Wast*.    Onsite  incineration and
treatment of  dioxin-contaminated  waste and sodium metal  waste
would  be conducted  as  discussed  in Alternative  8.    After
incineration,  the   resulting   ash   would  be  stabilized  as
described below.

     •    Stabilization   treatability  tests—Incinerator  ash
          would  be  analyzed   for   inorganic  content.    if
          stabilization  was  determined  to  be  necessary  or
          advantageous,  the  ash would  undergo  treatability
          tests to determine the reagent dosages and to  predict
          performance.

     •    Pozzolanic   stabilization—Pozzolanic   stabilization
          would be used to chemically stabilize insoluble  metal
          complexes,  inorganic  compounds,  and  some  soluble
          inorganic compounds.  If the results  of treatability
          tests  indicate  that  it  would be  effective and
          economically feasible, the incinerator  ash would be
          stabilized.  Because dust  and vapor emission would be
          a concern during this operation,  stabilization  would
          be  performed within  an enclosed  area  such  as the
          portable  structures  that  would  be  used  during
          excavation and incineration activities.

After stabilization  is complete,  the  stabilized  ash would be
manifested  and  transported  off the  site  for  disposal  as
outlined in Alternative 8.


         Summary of Comparative Analysis of Alternatives

The five  alternatives  were compared on  the basis of the nine
evaluation criteria to identify the relative benefits  of each
alternative.  These nine criteria are listed and defined below:
          Overall   protection   of   human   health   and  the
          environmento-This  is a check  to  assess  whether an
          alternative  meets   the  requirement   that  it  be
          protective of human health and the environment.  The
          overall  assessment  of  protection  is  based  on  a
          composite of factors assessed under  other  evaluation
          criteria,  especially  long-term  effectiveness  and
          permanence, short-term effectiveness,  and  compliance
          with ARARs.

          Compliance  with  ARARs-Chis  criterion  gauges  the
          degree  of  compliance  of  each  alternative   with
          applicable or  relevant and  appropriate federal and
          state requirements, as defined in CERCLA Section 121.

          Long-term effectiveness and permanence-This criterion
          gauges results of  a remedial action in terms of how


                               19

-------
much  risk   remains   at  the  site  after   response
objectives  have  been  met.    The  focus   of   this
evaluation is on the effectiveness of the controls  in
managing  risks  posed  by  treatment  residuals  or
untreated wastes.

Reduction  of  toxicity,  mobility,   and   volume-This
criterion reflects statutory preference  for  remedies
that permanently  and significantly reduce toxicity,
mobility/  or  volume of  the  hazardous   substances.
This preference  is  satisfied when treatment  reduces
the principal threats at the site  through destruction
of  toxic  contaminants,  irreversible  reduction  in
contaminant mobility, or reduction of total volume  of
contaminated media.

Short-tern  effectiveness—This  criterion gauges the
impact an  alternative will have during  construction
and  implementation,  up  until  the   time   remedial
response objectives  are met.   Under this criterion,
alternatives  are  evaluated with  respect  to  their
effects  on human health  and  the environment during
implementation  of  the  remedial  action and  until
protection is achieved.

Implementability—This criterion gauges technical and
administrative   feasibility   of   implementing   an
alternative and the  availability of  various  services
and materials required during its implementation.  It
also evaluates the compatibility of the alternative
with potential future  actions to  be  implemented  at
the  sit*  that address other areas  or sources  of
contamination.

Coste-This criterion  gauges  the capital costs, annual
operation  and  maintenance  (O&M)  costs,  and  total
present  worth  of   each  alternative.    The   cost
estimates are considered order-of-magnitude level and
are expected to be accurate within +50  to -30 percent
for the  identified  scop* of the remedial action.   A
cost sensitivity analysis may be performed to reflect
the    uncertainties    in   estimating   particular
parameters.

State    acceptance-This    criterion    takes    into
consideration  the position and  key concerns of the
state regarding the preferred alternative and  other
alternatives and the state's comments on ARARs or the
proposed use of waivers.

Community  acceptance-This criterion gauges  support,
opposition,  and reservations of interest persons  in
the   community   to   components   of  the   remedial
alternatives.
                     20

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These  nine  criteria  fall  into  three general  categories  as
outlined below:

     •    Threshold  factors:

               Overall  protection  of  human  health  and  the
               environment
               Compliance with ARARs

     •    Primary balancing factors:

               Long-term effectiveness and permanence
               Reduction  of  toxicity,  mobility,   or  volume
               through treatment
               Short-term effectiveness
               Implementabi1ity
               Cost

     •    Modifying  considerations:

               State acceptance
               community acceptance

The threshold  factors,  overall  protection of human  health  and
the environment, and compliance with ARARs were  evaluated, on a
yes/no basis.  The primary balancing factors were  evaluated as
a comparative  analysis.  The modifying considerations,  state
and  community  acceptance,   were   fully  evaluated   following
receipt of comments  on the Proposal Plan.

A comparative  analysis of the  five alternatives  is discussed
for each of the nine evaluation criteria.

Overall Protection of Human Health and the Environment

Alternative  1  (no  action) would not  protect human  health  and
the environment.  Therefore,  it is not considered any  further
in this analysis.   Alternative  5 (containment with  a RCRA  cap
and slurry wall)  would eliminate any  existing risk of direct
contact  with  the  waste  and  reduce  the   migration  of  the
contaminants by  significantly restricting infiltration and by
containing contaminants  horizontally  within an  in. situ slurry
wall.  However, percolation of any free phase liquids, possibly
existing in  the  drums, into  the  bedrock aquifer would not be
eliminated by  this  alternative.  .This  alternative  would  not
reduce the  volume or  toxicity  of  the waste.    Alternatives 7
(removal and  off-site incineration),  8  (removal and onsite
incineration),   and  9   (removal  and  onsite  incineration  and
stabilization)  all would provide long-term protection to  human
health and the environment at the site by removing the waste.
                               21

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Compliance With ARARS

Alternative 1 does  not meet ARARs pertaining to land disposal
of solid or hazardous  waste.   The other four alternatives are
expected to meet all  ARARs.   The ARARs  identified for these
alternatives  are  presented below.   Three  classifications of
ARARs  are  defined  by  EPA:     chemical-specific,  location-
specific,  and  action-specific.    ARARs  included  for  each
classification are presented below.

Chemical-Specific ARARs

Chemical-specific  ARARs  regulate  the release of  hazardous
substances  to  the  environment  having  certain  chemical  or
physical  characteristics  or  materials  containing  specified
chemical  compounds.    They are  important in  determining the
extent of  soil,  sediment,  and groundwater remediation as well
as  determining  the  residual  levels   allowed  for  hazardous
substances after treatment.

Chemical-specific ARARs associated with these alternatives are
concerned with  acceptable  discharge concentrations to the air
and surface water  during remedial action.  Clean-up standards
for groundwater, surface water, and soil are not ARARs because
the remedial  objectives of OU-3  only address  the removal or
containment of  a potential source of contamination and hazard
and not the remediation of contaminated media.

National  Ambient Air  Quality Standards.    The  Clean  Air Act
(CAA) governs air emissions  resulting from remedial actions.
Pursuant to the CAA,  EPA promulgated the National Ambient Air
Quality  Standards   (NAAQS)   (40  CFR  Part 50).    NAAQS  are
available  for six  pollutants, including airborne  particulates
(see Table 3).  The sources of the contaminants and the routes
of  exposure  were  considered  in  the  formulation  of  the
standards.    These standards  do  not  consider the  costs of
achievement or  the feasibility of  implementation.  The NAAQS
allow for  a margin of safety to  account for unidentified haz-
ards  and  effects.    The  NAAQS  apply  for  remedial  actions
involving direct or indirect emissions to the atmosphere.

National  Emission  standards  for  Easardous  Air   Pollutants.
Pursuant  to  Section  112  of  the  CAA,  EPA  has   promulgated
National  Emission  Standards  for  Hazardous   Air Pollutants
(NESHAPS)  (40 CFR  Part 61).   Significant sources  of hazardous
air pollutants  listed* as hazardous may be subject to NESHAPS.
Performance standards  for  incinerators are set  forth in 40 CFR
Part 60,  Subpart E,  and  apply   to  actions  involving cms its
incineration.

Federal  agencies  are  required to comply  with  federal, state,
and  local requirements  (especially  with State Implementation
Plans, or  SXPs),  for  control  and abatement of  air pollution.
If a proposed EPA  action may  adversely affect air  quality, the

                               22

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Iat4e3
FEDERAL AND STATE AMBIENT AIR QUALITY STANDARDS

wfff-.r
Carbon monoxide
Lead
Niirogen oxides
Nontnelnane
hydrocarbons
Ozone
Paniculate mailer
(expressed as PM-10)
Sulfur dioxide ':
National Ambient Air Quality Standards
Fltauqr Standard
0«K>
10000 (8-kourXI)
401000 (Ihoui MO
LSprXbyX?)
IOO(lyearX3)
None
23S (1 hour)(l)
ISO (24-hour)(l)
50(l-year)(3)
«0(lyear)(3)
36S (24-hour)(l)
Primary - proieciion of public health.
Secondary - protection of public welfare,
Secondary Standard
(/•^i1)
None
Same as primary
Same as primary
None
Same as primary
Same as primary
1,31)0 (3 bour)(l)
Wot Virginia Ambient Air Quality Stand***
Prtnuiy Standard
(JCAO
10.000 (8 hour)
40,000(1 hour)
None
I00(l-year)(3)
I60(3hour)(l)
(6 a.m. to 9 a.m.)
23S(l-ycar)(l)
I50(24-hour)(l)
50(lycar)(3)
80 (4 year)(3)
36S(24-hour)(l)
StHnodarr 
-------
responsible   EPA  official   is  required   to   consult  with
appropriate state  and  local agencies to determine whether  the
action conforms to the SIP.

west Virginia Ambient Air  Quality Standards.   West Virginia
Ambient  Air  Quality  standards  (West  Virginia  Code  of  state
Regulations; Title 45; Series 8, 9, and 12)  have been developed
for sulfur dioxide, particulate matter,  carbon monoxide,  ozone,
nonmethane  hydrocarbons,  and  nitrogen  dioxide  (see Table  4).
These standards are similar to the Federal NAAQS and apply  for
remedial actions involving direct or indirect emissions  to  the
atmosphere.

west Virginia Air Pollution control Regulations.  West Virginia
Air Pollution Regulations  (WVCSR 45-15 and 45-16) also  include
emission  standards  for  hazardous  air  pollutants   (same  as
40 CFR, Part  61-NESHAPS)  and  standards for performance  of  new
stationary  sources   (same  as  40  CFR,   Part 60).      These
regulations apply  for  remedial actions involving emissions to
the atmosphere.

West   Virginia    Pollutant    Discharge   Elimination    system
Regulations.  The West Virginia Department of Natural Resources
(WVDNR) has imposed effluent  limits for the  Cooperative Sewage
Treatment  (CST)  plant,  which discharges to the Kanawha  River.
The influent  to the CST plant originates  from the process area
of  the  Fike  Chemicals  site  as  surface  water  runoff  and
groundwater  infiltration into the sever  network.   Discharge
limits are presented in Table 4.  Many of the discharge limits
are based  on  West  Virginia Water Quality Standards (WVCSR  46-
1).    The discharge  limits  apply to  remedial  actions that
involve treatment  of wastes at the CST plant.

Location-Specific ARARs

Location-specific  ARARs  are   restrictions  placed   on   the
concentration of  hazardous   substances  or  the  conduct  of
activities  solely because they  are in  specific geophysical
locations.     Some  examples   of  special   locations   include
floodplains,  wetlands, historic places, and protected habitats.
No  known location-specific ARARs exist for this phase  of  the
remedial  activities  at the site.   The site is not located in
floodplains,   wetlands,   protected   habitats  or   areas  of
scientific, historic, or  archeological significance.

Action-Specie ARARs

Action-specific  ARARs are  requirements that are triggered by
specific  remedial  actions implemented at the site.   Important
action-specific  ARARs  that  may  affect  the  development  and
conceptual arrangement  of remedial alternatives  for the buried
drums  at  the site  are  discussed  below.   Potential  action-
specific  ARARs  are   summarized  by  remedial   technology   in
Table 5.

                               23

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TaMe4 !
GST PLANT DISCHARGE LIMITATIONS i
THE SITE
NTTRO, WEST VIRGINIA
Page 1 of 2

Panaeter
BOD-5
Total Suspended Solids
Oil A Grease
Phenol
2.4-Dichlorophenol
2,4-Dimethyiphenol
2-Nitrophenol
4-Nitrophenol
2,4-Dinitrophenol
2-Chlorophenol
Total Phenolics
Toluene
Benzene
Cyanide, Total
Lead, Total
Chromium, Total
Hexavaleat Chromium
Copper, Tool
Nidod.$tt»
Zinc, it*
Arsenic, Total
f*p/1fn\nifl Tntaf
Iron
Manganese, Total
Quantity (Ox/Day)
Avenge
Monthly
8
1 '
5
0.003
0.007
0.003
0.007
0.013
0.013
0.005
O.OS
0.005
0.006
O074
0.056
0.194
~
0.254
0.296
0.184
-
-
-
-
MflXBBB
D»fly
21
3
8
0.005
0.02
0.006
0.012
0.022
0.022
0.017
0.104
0.014
0.024
0.21
0.121
0.485
-
0.592
0.697
0.457
.-'•'•'—
-
-
-
Concentration (mg/L)1
Avenge
Monthly
45.7
5.7
2S_S
0.017
0.040
0.017
0.040
ao?4
a069
0.029
0.285
0.029
0.034
0.423
0320
1.108
-
1.450
1.690
L051
-
" -
-
-
rVtjnirmtH
Dairy
119.9
17.1
45.7
0.029
0.114
0.034
0.069
0.126
0.126
0.097
0.594
0.080
0.137
1.199
0.691
2.769
0.010
3.380
3.980
1609
0.44
0.049
8J
1.0

-------
Tabte4 !
CST PLANT DISCHARGE LIMITATIONS
THE SITE
NTTRO, WEST VIRGINIA
Page 2 of 2

Parameter
Mercuiy, Total .
Selenium. Total

Saver, Total
Chloride
Total Residual Chlorine
Nitrate (as N)
Aninonii fat N)

Total Organic Carbon
Chemical OXVMO Demand
• »
Dissolved Oxyfea
Quantity (On/Day)
Avenge
Monthly
-
-
-
-
-
-
-
-
~
-
MflBDBJB
Dafljr
-
-
-
-
-
-
-
-
-
—
Concentration (mc/L)1
Average
Monthijr
-
-
-
-
-
-
—
-
-
-
Dafly
0.0002
0.035
0.043
1.800
2.0
1.0
40
100
100
100
No limitation
'Based on a flow rate of 21,000 gallons per day
Source: Ebasco, 1990

-------
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RCRA   Solid wastes  in the buried  drums and other  containers
were generated and disposed  of before  the  effective date  of
RCRA (November 1980).  RCRA therefore does not apply unless  the
drums are  excavated.   RCRA requirements may be applicable  if
the wastes disposed of before November  1980  are  RCRA hazardous
waste  or relevant  and appropriate if  they are  sufficiently
similar to RCRA hazardous waste.

RCRA Landfill  Closure  Requirements.  RCRA requirements do  not
apply to existing drum burial areas, but they may be considered
relevant and appropriate to remedial alternatives not involving
excavation  or  management of  soil  or solid  wastes.   The more
significant RCRA  requirements include construction of a  cover
having a permeability less than or equal to the permeability of
the underlying natural bottom materials present.

RCRA   Land  Disposal  Restrictions.      RCRA   land   disposal
restrictions (LDRs), 40 CFR 268, prohibit land disposal of F006
listed wastes after August 8, 1988, unless constituents in  the
Toxicity Characteristic  Leaching Procedure  (TCLP)   extract  are
below the  maximum allowable concentrations.   Land  disposal  of
nonliquid materials is also prohibited if the materials contain
halogenated organic  compounds (HOCs)  greater than  1,000  mg/kg
(the California List  solid wastes).  Incineration  is required
as  treatment  for  California   List  wastes  before  landfill
disposal.

Other RCRA  Requirements.   RCRA Part 264  outlines  requirements
for remedial alternatives involving onsite treatment storage or
disposal of hazardous wastes.    RCRA Subtitle  C  requirements
will be potential ARARs for remedial  alternatives  that involve
transportation,   treatment,   storage,    and/or   disposal   of
hazardous  wastes.   The  Hazardous  and  Solid Waste  Amendments
(HSWA)  prohibit the continued land disposal of hazardous wastes
without  treatment beyond specified dates.   Wastes  treated  in
accordance with the treatment standards  set  by EPA pursuant to
RCRA Section 3004 (m)  are not subject to the prohibitions  and
may be land-disposed.

DOT  Regulations.    Department  of  Transportation  Rules  for
Hazardous Materials Transport (49 CFR Parts 107 and 171 through
179) regulate  the transport of hazardous materials,  including
packaging,  shipping equipment,  and placarding.   These  rules
apply to wastes  shipped  off the site for laboratory analysis,
treatment, or disposal.

OSHA   Regulations.-      Occupational    Safety    and  Health
Administration regulations  (29  CFR  Parts 1904, 1910,  and  1926)
outline  requirements  that apply  to workers  engaged  in onsite
investigative and remedial activities.

West Virginia Solid  and  Hazardous Waste Regulations.   West
Virginia Solid Waste Regulations (WVCSR 47-38) apply for onsite
disposal of solid  wastes and  contain  requirements  for  solid
waste facilities, permits and applications, and minimum perfor-

                               24

-------
mance  standards.    West Virginia Hazardous  Waste  Regulations
(WVCSR 47-35) contain  standards for generators;  transporters;
and  treatment,  storage,  and  disposal  facilities.    These
regulations  apply  for  remedial  actions  that  involve  the
handling of hazardous waste and may  be  appropriate and relevant
for handling nonhazardous waste.

West   Virginia   Pollutant   Discharge   Elimination    System
Regulation*.   West  Virginia Pollutant  Discharge  Elimination
System Regulations  (WVCSR 46-2) contain  procedures and rules
pertaining to point source discharges of pollutants to surface
water.   The regulations govern permits,  permit  applications,
permit   conditions,   and   effluent   limitations.      These
requirements apply  if  the- direct discharge of pollutants into
surface water is part of a remedial action.

West Virginia Air Pollution Control  Regulations.   West Virginia
Air  Pollution Control  Regulations  (WVCSR  Title  45)  contain
rules  pertaining  to  discharges of  pollutants  to  the  air
including:

     •    Prevention and control of  discharges of  objectionable
          odors (Series 4)

     •    Prevention and control  of particulate  air pollution
          from materials handling and other sources  of fugitive
          particulate matter (Series 17)

     •    Prevention   and   control   of   air   pollution  from
          hazardous waste TSD facilities,  including  performance
          standards for incinerators (Series 25)

Long-Term Effectiveness

Because   OU-3   is   an  interim  remedial   action  long-term
effectiveness is  not a necessary criteria.   However, because
long-term  effectiveness  is  an  important  criteria  for  the
overall  plan for the  site  it  is considered.   Alternative  l
would  provide  no additional  long-term protection from  risks.
The degree of long-term effectiveness provided by  Alternative  5
would  depend on the  quality of the cap and  slurry  wall and
would also rely heavily on future maintenance.   Alternatives 7,
8, and 9 would eliminate  all long-term risks associated with
the  drums,  although  dioxin-contaminated wastes  and possibly
some unknown wastes found  in this action would be  left  at the
site with Alternative 7.  These wastes would be addressed in  a
subsequent ROD.

Reduction in Tenacity, Mobility, or Volume Through Treatment

Neither  Alternative 1  nor  Alternative 5  proposes  any waste
treatment  and  would  therefore  not  reduce  the toxicity,
mobility, or volume through treatment.
                               25

-------
Alternatives 7,  8,  and 9 would reduce the volume  and  toxicity
of  organic contaminants  in  the excavated  waste by oxidation
through incineration.   Alternative 9 would further attempt  to
reduce the mobility of  any  inorganic contaminants present  in
the ash through stabilization.

Short-Term Effectiveness

Alternatives  7,  a,  and  9   would  present   short-term  risks
including  direct  contact,  inhalation,   fire,   explosion and
chemical   reactions   at  the   site  because   they   present
opportunities for exposure to the contaminants.   Alternative  9,
presents   short-term    risks   during   excavation,    onsite
incineration, and stabilization.  Alternative  8  presents short-
term  risks during  excavation and  onsite incineration,  while
Alternative 7  presents  short-term  risks during  excavation.
However, the  use of a portable structure  to encapsulate the
work area during excavation would  effectively eliminate short-
term  risks to  the  community,  and  the  proper  use  of  safety
equipment and personal protection  gear would minimize  risks  to
site workers.

Alternative  5  involves  some  risks  at  the initial  phases  of
construction due to the dioxin contamination  in  the  surface
soils and its potential to become airborne in  dust.  The use  of
dust  suppressants   and site  worker personal  protection . gear
would minimize these risks.

Estimated construction times for each alternative are:

     •    No   time   is   required   for   Alternative   1   (no
          construction)
     •    Approximately 6 months for Alternative 5
     •    Approximately 12 months for Alternative 7
     •    Approximately 18 months for Alternative 8
     •    Approximately 24 months for Alternative 9

Implementabflity

Alternatives 5,  7,  8,  and 9  use wall-developed  technologies
that  would be  readily available  and should be effective  in
treating or containing  the  waste.    Implementation  problems
could  be  encountered  with Alternatives 8  and  9  due to the
proposed use  of an  onsite  incinerator and  the anticipated
variability and  unknown quantity of  the waste.  In addition,
the numerous requirements associated with onsite  incineration
necessary to comply with local, state, and federal  requirements
would  significantly complicate the  implementability  of  these
alternatives.   Implementation  problems   are  anticipated  with
Alternative 7  due  to  the  unknown  volume,   location/  and
characteristics of  the waste.   The coordination, planning, and
costs of this alternative depends heavily on these parameters.
                              26

-------
Alternative  5  presents   the  most   favorable  implementation
scenario;  however,  significant  quality  control  problems  are
anticipated with  the construction of the 60-foot deep  slurry
wall due  to the difficulty of verifying  the  correct  placement
of the slurry or breaches  in the wall.  This  alternative would
not  be affected  by the  uncertainties regarding  the volume,
location, and type of waste.

Each  of  the  five  alternatives  is  anticipated  to  affect  the
implementation  of   future  remedial  actions  at  the   site,
particularly remediation of contaminated soils and groundwater.
Alternative 5 would preclude any further action to  remediate
the contaminated soil  and  onsite groundwater at the  south  end
of the site.

Alternatives 7, 8, and 9 would facilitate the  implementation of
future actions  to  remediate contaminated soil and groundwater
at the site.   Removal  of  the  buried drums will significantly
reduce the hazards associated with future work at the site.

Cost

Table 6 presents  a comparison of the estimated capital,  O&M,
and present worth costs for each of the five alternatives.
Trite 6
COMPARISON OP ESTIMATED COSTS FOR ALTERNATIVES UJA& 9

Estimated
Capital Costs
CStlfflifttOQ
Annual O&M
Costs
Estimated
Total Present
Worth Costs
Attenativea
1
NoActta
$0
S36J0001
$23,000*
$410,000
s
RCRACap
and ShoiT
Wall
$3,699,000
S47.0001
$31,000*
$4,245,000
7
OflMte
TIM-JIM J«IJM

$16459,000
$0
$16^59,000
8
Onsite
TiMjiMjMkm

$20,105,000
SO
$20,105,000
9
Onsite
Stabffizatfoa
$20594,000
SO
$20594,000
'Annual O&M costs tor flnt 5 yean of monitoring
:Annual O&M costs tot sixth through thirtieth year of monitoring
                               27

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State Acceptance

The State of West Virginia has reviewed the Record of Decision and concurs with the
selection of Alternative 7.

Community Acceptance

Based on comments received during the public comment period and at the public
meeting, there is  community  support for the selection  of  Alternative 7.   See
Responsiveness Summary for a summary of public comments and the response of EPA
to these comments.

Performance Standards

The selected remedy shall meet the following performance standards:

      •     All buried drums  and containers at the site shall be excavated, staged,
            sampled, and treated.

      •     The remedial action shall be conducted so as  to minimize risks to the
            community and onsite workers.

To implement the objectives previously set forth, on page 13, this action shall remove
the buried drums from their present location and characterize the  drums and their
contents to an extent where they may then undergo treatment or disposal  The
remedial technologies associated with  this  general response  action include both
excavation technologies and drum management technologies.  All work to be done will
comply with EPA's policy for Drum handling.

Confirmation of Drum Location in Remedial Design

Anticipated subsurface disposal areas have been identified through a number of sources
with varying degrees of certainty. Before beginning full scale drum removal activities,
the existence  of drums  in each of  these areas shall be  confirmed  so that  a
comprehensive sitewide excavation plan can be established.  Confirmatory methods
including geophysical techniques capable of identifying the  presence of drums with
certainty, while also ensuring worker safety, shall be used.

Test pits shall be used  to  provide the required degree of confirmation.  Test pit
excavation equipment and fire and explosion prevention apparatus could be the same
as that used for the actual soil and drum removal operation.

Construction of an Pnrinncd Structure to Control and Treat Dust and Vapors

Vapor and dust emissions from active excavations shall be controlled by encapsulating
the active excavations and work areas and by treating exhaust air for particulates and

                                     23

-------
organic vapors to applicable  federal  and state  standards.  Prior to the  start  of
excavation a self-supported portable structure will be constructed on-site to prevent
releases of vapors to the environment.  The size of the structure will be determined in
the Remedial  Design for this action.   Any activities potentially involving releases of
organic vapors or other emissions shall be  conducted within  this  structure.   This
structure shall  be equipped with an air filter and vapor phase granular activated carbon
(GAC) treatment system to remove dust and organic vapors from air before it is
discharged. This structure shall be operated under negative pressure.

Water shall be applied to surface soils periodically to suppress dust  Plastic covers or
tarps  shall be  placed on stockpiles of excavated soil to control  both vapor  and dust
emissions.

Free Liquids and Ground Water Removal and Dewatering

During excavation of the drums, free liquids and/or groundwater may be encountered
in pockets within the disposal areas or  may occur as a result of the rupture  of drums
containing waste.  These liquids will be removed by using pumps or vacuums or similar
equipment, characterized, and  discharged  to  the CST in accordance  with  NPDES
requirement or shipped offsite for management in accordance with applicable RCRA
requirements.

Drum Transfer and Staging

After the drums have been removed from the excavation, they shall be recontainerized
if leaking or in poor condition, overpacked, opened, sampled, possibly consolidated, and
temporarily stored to await final treatment or disposal. These staging/storage areas will
comply with all applicable RCRA storage requirements.  Any cylinders found on-site
will be removed, opened, and sampled using a cylinder recovery vessel

Compatibility Testing

Compatibility testing wfll be performed on samples collected from excavated drums in
order to broadly classify waste categories for disposal or treatment and determine
which drums may be safety consolidated or stored together.

Storing, Bulking, and Recontaincmng Wastes

Empty and full drums, drum wastes, free liquids, pumped groundwater, and excavated
soils will be bulked within the encapsulated area or other location where vapors could
be contained and possibly recontainerized or consolidated before treatment or disposal.
Any wastes which cannot be sent offsite for treatment or disposal will be staged on site
and addressed under a future operable unit   Drums found to contain sodium metal
waste shall be  repackaged in 1-quart (or smaller) containers and immersed in oil before
being shipped off-site  for incineration.  Repackaging shall be performed in an inert
nitrogen atmosphere.
                                       29

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Management of Open Excavations

It  is anticipated that the  removal of buried drums will  create a number of large
excavations. These open excavations would expose a significant area of soil, potentially
contaminated with VOCs, to the atmosphere, creating a source of vapor emissions.  In
addition, open excavations would present a safety problem at the site and complicate
remedial work  by limiting mobility  and access around  the  site.  The backfilling of
excavations with the excavated soil shall be managed to effectively address emissions,
safety  and  accessibility  concerns.    Although  the  backfilled soil is potentially
contaminated  it may  be  placed  back  into  an excavation within the  "area  of
contamination"  on  the site.   Stockpiled soils shall be managed in accordance with
applicable RCRA requirements for waste piles.

Empty Drum Scrapping

Empty drums that are excavated or generated during consolidation shall be crushed or
shredded, decontaminated, and/or shipped offsite in accordance with applicable RCRA
requirements.

Air Monitoring

Air monitoring for  weather  conditions, gases,  vapors,  and particulates  shall  be
conducted during drum removal operations throughout the work area and around the
perimeter of the site.  Both continuous real time monitoring and  periodic sampling
shall be implemented.

StonnwBtcr MaiMgBiyient and Erosion Control

Surface water,  erosion control, and sedimentation measures shall be implemented
during removal operations to reduce erosion, prevent contaminated sediment and
runoff from leaving the site or off-she surface water from entering the site, and to keep
surface water from entering open excavations.  Onsite surface water will be collected
and diverted to the existing site storm sewer system and discharged to the CST in
accordance with NPDES requirements.

Explosion and Fire Pifcvmliop/PiutectioD

Analyses of the contents of surface drums found at the Site indicate the presence of
sodium metal and other explosive, ignitable, and reactive wastes. These types of wastes
may.be encountered during buried drum removal operations.

For this reason, a primary site safety concern is the prevention of and protection from
fires and explosives.  A number of standard tools, accessories, and technologies are
available and are regularly used at hazardous waste sites. All appropriate  measures
shall be taken to ensure prevention of and protection from fires and explosives.
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Thermal Treatment of Drummed Waste

Drummed wastes and residues contained in excavated drums shall be treated using off-
site incineration.   The anticipated high organic content of the drummed wastes  is
amenable to  incineration.   Incineration  would also  be a  favorable  technology,
considering the lack of analytical data on the drummed waste and the anticipated wide
variety of organic and inorganic compounds.

Raw untreated Site waste shall  be transported off-site to a  permitted incineration
facility that  meets any applicable RCRA requirements.   Waste shall be  processed,
mixed with other wastes if necessary, and incinerated.

Prior to acceptance by an incineration facility, the waste stream shall be characterized
and must meet certain requirements dependent on the receiving facility's operating
permit limitations.   Waste characterization shall be  performed at  the  site.  Waste
characterization shall be combined with compatibility testing. Any waste which cannot
be shipped off site for treatment or disposal will be staged on site for a future action.

All Site wates shall be incinerated off-site with the exception of dioxin-containing waste.
Currently no  facility  within  the  United  States  is  permitted to  accept  dioxin-
contaminated wastes.  All actions  taken at the  site wfll comply with EPA's off-site
policy and other applicable requirements.
Chemical Treatment

Simple chemical treatment technologies, such as neutralization,  shall be used as a
treatment for acidic wastes that do not contain other contaminants or as pretreatment
prior to incineration for acidic wastes containing other contaminants.

Treatment of Free Ljcpnds and Groundwater

Free liquids and groundwater generated during drum removal may require treatment
Based on interviews with former plant employees some apparent drum burial areas are
below the water table. Consequently dewatering of excavation pits during removal may
contaminate groundwater. Free liquids leaking  from drums during removal may also
enter the groundwater.  Groundwater and free liquids may contain organics and some
metals.   Process options considered for treatment include discharge to the CST,
discharge to publicly owned treatment works  (POTW), granular activated carbon
(GAQ, in exchange, air stripping, and precipitation or any other required treatment

Disposal

Contents of excavated drums and drummed wastes shall be incinerated or disposed of
after treatment Demolition debris that contains hazardous waste shall be disposed of
off-site in accordance with applicable RCRA requirements.
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Transportation

Off-site disposal or incineration will require transportation of treated or untreated
drummed wastes.  Wastes will be transported by rail or by truck.  Hazardous wastes
transported off-site shall be transported in accordance with West Virginia's authorized
hazardous  waste  transporter  and  generator  requirements  and  Department  of
Transportation regulations.  Hazardous waste shall be manifested in accordance with
authorized generator standards.  Land disposal restricted waste shall be shipped with
notifications required by 40 C.F.R. Section 268.7(a).

Recycling

All wastes contained in drums that can be recycled cost-effectively shall be considered
for recycling.

Access

Access restrictions shall be placed around the site to deter trespassing during and after
remedial action.
Selected Remedy

Section 121 of CERCLA, 42 U.S.G Section 9621,  as amended by SARA, and  the
National Contingency Plan (NCP) establish a variety of requirements relating to  the
selection of remedial actions. The selected remedy for remediating the buried drums
and containers at the site is Alternative 7—Removal and Off-site Incineration. The
estimated present worth of this remedy is $16,059,000. Based on current information,
this alternative would appear to  provide the best balance of trade-offs among  the
alternatives with respect to the nine criteria that EPA uses to evaluate each alternative.

This alternative includes removal of all buried drums and containers. The removal of
buried drums and containers features standard state-of-the-art drum removal, handling
and processing equipment, and procedures, and also employs a self supported portable
structure to enclose active  excavation areas controlling  vapor and dust emissions.
Excavated drums win be treated thermally in an off-site incinerator.  Drums containing
acidic wastes wiD be neutralized onsite.  Drums containing wastes contaminated with
dioxins wfll be stored  onsite for future remediation that would occur with  the
remediation of the dioxin-contaminated soils and sludges found on the site. Currently,
ho incinerators in the U3. are permitted for dioxin-contaminated wastes; however, this
may not be the case at the time of remedial action implementation.  If possible, drums
containing dioxins wfll be incinerated with other wastes. Any material that will meet a
RCRA contaminated Debris definition win be treated as a debris and not as a listed or
characteristic waste.  Buried cylinders wfll be handled onsite with the CRV.  Organic
vapor  emissions generated during drum or cylinder removal, sampling, storage, or
treatment wfll be suppressed  or captured and treated  with vapor  phase  GAC
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Contaminated GAC will  be  incinerated off-site.   Groundwater generated from
excavation dewatering will be  collected and discharged to the CST.  However,  the
groundwater will be sampled before  discharge to the CST.  Any generated sludges
would be treated and disposed of in  a subsequent operable unit  If the quantity of
sludge generated exceeds the storage  capacity of the CST, the sludge will need to be
removed and treated or stored so it will not jeopardize the operation of the CST. If
analytical results indicate contaminant concentrations exceed the treatment capabilities
of the CST, the groundwater will be shipped  to  a RCRA-permitted wastewater
treatment facility.

Drums will be transported off the site by truck or rail, whichever is most appropriate
and acceptable at the time of remedial action.  Drums will either be shipped in bulk or
separate overpacks, depending upon compatibility test results.  Access restrictions  will
be placed around the site to  deter trespassing during and after remedial action.
Statutory Determinations

Alternative 7 will protect human health and the environment by excavating, removing
and treating the buried drums and containers at the site.  Because the waste will be
removed from the site, the risks of exposure from direct contact or the risk of off-site
migration of releases from the drums will be eliminated.  Waste treatment by incinera-
tion will oxidize a large percentage of organic compounds, which are anticipated to be
the main contaminants  in  the  waste.   Residual  hazardous waste in the resulting
incinerator ash will be contained by disposal in a RCRA Subtitle C-permitted landfill.
Potential short-term threats to human health and the environment during onsite drum
removal and handling activities  are significant Potential  exposure pathways  are air
emissions, surface water discharges, direct contact,  fire, explosion, and other chemical
reactions. Under this alternative,  a significant number of protection, prevention,  and
containment measures wfll be employed to eliminate or reduce all perceived short-term
exposure  risks  to  an  acceptable  level    No  unacceptable  short-term risks  or
contamination of other media will  be caused .by implementing this remedy.

This action  is not  the  final action  for the  site  and does  not attempt to  ensure
compliance with ARARs for the entire site. It wfll be consistent, however, with those
action-specific ARARs addressing  excavation, treatment, and disposal of buried drums
and containers containing RCRA hazardous wastes (or sufficiently similar materials).

Alternative 7  win comply with all  ARARs with  the exception of RCRA  closure
requirements.  The RCRA Part  264 Closure. Requirements are applicable for the
excavation/stockpile area. Since this is  an interim action operable unit  and further
remediation will be conducted in this area under a  separate operable unit, this closure
requirement wfll be waived in accordance with the interim measure waiver provisions
set forth in CERCLA Section  121(d).  This type of waiver may be used whan an
interim measure that does  not attain  an ARAR is expected to be followed by a
complete measure that wfll attain such ARAR.
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Transportation of hazardous wastes will be  in  accordance with  RCRA and  DOT
requirements.  Land disposal restrictions will  be  addressed  by incinerating the waste
and meeting applicable treatment standards or prohibition levels before disposal.  The
off-site incineration facility receiving the  tank wastes  must be in compliance  with
applicable  state  and  federal  permit  requirements relevant  to  hazardous waste
incineration facilities.

No location-specific ARARs have been found  to pertain to this site.

The selected remedy is protective of human health and the environment This remedy
is cost-effective because the overall effectiveness of this  remedy is proportional to the
projected costs and provides the best balance of trade-offs among the alternatives with
respect to the evaluation criteria. Of these criteria, overall protection of human health
and the environment; reduction of toxicity, mobility, and volume through treatment;
compliance with  ARARs;  implementabflity;  and  long-term effectiveness are  best
satisfied by the selected remedy. The local community and the State of West Virginia
are in support of the selected remedy.
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