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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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).
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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
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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
-------
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
-------
• 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
-------
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
-------
• 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
-------
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
-------
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
-------
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
-------
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
-------
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.
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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
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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
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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.
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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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