Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-88/042
March 1988
Superfund
Record of Decision:
Ordnance Works Disposal, WV
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50273 -101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R03-88/042
3. Recipient** Accession No.
4. Title end Subtitle
SUPERFUND RECORD OF DECISION
5. Re
Works Disposal, WV
ist Remedial Action
hor(s)
8. Performing Organization Rept. No.
9. Performing Organization Name end Address
10. Project/Task/Work Unit No.
11. Contraet(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Neme and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/000
14.
19. Supplementary Notes
16. Abstract (Ltmrt 200 words)
The Ordnance Works Disposal site, also known as the Morgantown Ordnance Works, is
located one mile south of Morgantown, West Virginia. The Monongahela River is adjacent
to the site with a fairly steep cliff separating the river from portions of .the site.
Remediation for this first operable unit focuses on the waste disposal area which
consists of an inactive landfill, two former lagoons and the surrounding impacted area,
d a scraped area of bare soil. These areas are located within an industrial tract of
r 800 acres of which 670 acres are owned by Morgantown Industrial Park Association, a
up of private individuals who joined together to purchase the Ordnance Works property
in 1982. Prior to this, the site was owned by numerous companies and used for a variety
of chemical production operations. The landfill covers a surface area of approximately
1.6 acres. The landfill was reportedly used from 1942 until 1962, for the disposal of
various solid chemical wastes. Waste materials identified included: construction
debris, slag, ash, and catalyst pillets. Arsenic and carcinogenic PAHs (CPAHs) were
detected in the soils at concentrations exceeding risk-based cleanup levels. The former
lagoon and the surrounding area, located adjacent to the landfill, cover a surface area
of 3 to 4 acres. This area is relatively flat with a cinder-like surface layer and
-sparse vegetation. Metal plating wastes were placed in the lagoon between
(See Attached Sheet)
WV
17* Document Analysis a. Descriptors
Record of Decision
Ordnance Works Disposal,
First Remedial Action
Contaminated Media: sediments, soil
Key Contaminants: inorganics (arsenic), organics (PAHs, PCBs)
b. Tdentlfien/Open-Ended Terms
c. COSATI Field/Group
lability Statement
(SeeANSI-Z39.18)
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
22. Price
See Instructions on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-3S)
Department of Commerce
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EPA/ROD/R03-88/042
^•nance Works Disposal, WV
^jst Remedial Action
16. ABSTRACT (continued)
1970 and 1976. The lagoons were excavated in 1981, by the responsible party, and the
contents were disposed of offsite. The metals present in the soil are currently below
the recommended cleanup levels. CPAHs have been identified at levels exceeding cleanup
standards in the area adjacent to the lagoons. An oily, stained cinder material was
observed in areas where CPAHs were detected. The scraped area, carving a surface area
of approximately 162 acres, was an active disposal area for solid wastes from 1942 until
1962. The waste materials identified include: construction debris, oil-like stained
soils, and catalyst pillets. Currently, arsenic and CPAHs exceed the proposed cleanup
levels. The primary contaminants of concern affecting the soil and sediments include
arsenic and CPAHs.
The selected remedial action for this site includes: consolidation of existing
landfill waste and application of a multi-layer RCRA cap; excavation and onsite
incineration of former lagoons and surrounding area, scraped area soil, and impacted
stream sediments with onsite disposal of treatment residuals in the landfill prior to
the installation of the cap (assuming the ash is not EP toxic); placement of clean fill
in the excavated area, followed by grading and revegetation; implementation of surface
management techniques for drainage and sediment control in the landfill area; ambient
air monitoring; and post-treatment monitoring. The estimated present worth cost for
^•s*remedial action is $6,718,000.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Ordnance Works Disposal Superfund site - Operable Unit One
Morgantown, Monongahela County, West Virginia
STATEMENT OF PURPOSE
This decision document represents the selected remedial action
for this site developed in accordance with CERCLA, as amended by SARA
and to the extent practicable, the National Contingency Plan.
The State of West Virginia has concurred on the selected remedy.
STATEMENT OF BASIS
This decision is based upon the administrative record (index
attached). The attached index identifies the items which comprise
the administrative record upon which the selection of a remedial
action is based.
DESCRIPTION OF THE SELECTED REMEDY
Operable Unit One consists of an inactive landfill, two former
lagoons, an area of bare soil where wastes were deposited (scraped
area), and a former drum staging area. Operable Unit Two will focus
on the Department of Defense industrial area for which only pre-
liminary information is presently available.
The selected remedy, On-Site Incineration and Containment, is
designed to treat, via incineration, soils of concern found in the
scraped area and former lagoon area, along with sediments from the
three streams that are located downgradient of the areas of concern.
The incineration process will be conducted on-site with a mobile
incinerator that will permanently destroy the organic contaminants.
The ash generated from the incineration process will be tested for
EP toxicity. Based on the level of inorganics present in the soil
and sediments, it is anticipated that the ash will not be EP toxic
and therefore, may be disposed in the on-site inactive landfill. Ash
that tests positive for EP toxicity will be disposed at an off-site
RCRA facility.
The selected remedy also includes the placement of a multi-layer
RCRA cap on the inactive landfill. The cap will be extended into
the subsurface clay to prevent surface water from infiltrating into
the landfill and leachate from seeping out of the landfill.
Other actions include placement of clean fill in the excavated
areas, surface management techniques for drainage and sediment control,
revegetation, ambient air monitoring and post-treatment monitoring.
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- 2 -
DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are applicable
or relevant and appropriate, and is cost-effective. This remedy satisfies
the preference for treatment that reduces toxicity, mobility, or volume
as a principal element. Finally, it is determined that th^s remedy utilizes
permanent solutions and alternative tre
technologies to the maximum extent pra
Date
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Site Disposition and Summary of Remedial
Alternative Selection for the Ordnance
Works Disposal Superfund Site
Operable Unit One
INTRODUCTION
The EPA investigation of the Ordnance Works Disposal site (aka
Morgantown Ordnance Works) focuses on three areas of concern: the waste
disposal area; the former drum staging area; and the Department of Defense
(DOD) industrial area. This Record of Decision (ROD) will summarize the
results of the Remedial Investigation/Feasibility Study (RI/FS) and will
present a permanent remedy for remedial action. The DOD industrial area
will be further evaluated and addressed as a second Operable Unit.
SITE LOCATION AND DESCRIPTION
The Ordnance Works Disposal site is located in Monongalia County on
the west bank of the Monongahela River approximately 1 mile south of
Morgantown, West Virginia (see Figure 1). The topography surrounding the
site is mountainous, dominated by the Chestnut Ridge, a long anticlinal
mountain in the Allegheny Mountain Range located seven miles east of
Morgantown. At the Ordnance Work Disposal site, the elevation of the
ground surface in the areas investigated ranged from 975 feet mean sea
level (msl) to 1010 feet msl. The Monongahela River is adjacent to the
site at 825 feet msl (see Figure 2), with a fairly steep clif-f separating^
the river from the waste disposal area and former drum staging area.
Approximately 4500 feet downstream of the waste disposal area the City
of Morgantown (population 31,000) operates a drinking water intake
which supplies the city with approximately 70% of its potable water.
"Die" areas investigated are located within an industrial tract of
over 800 acres of which 670 acres are owned by Morgantown Industrial Park
Association; 62 acres are owned by Borg-Warner Chemicals, Inc.; 24 acres
are owned by the Monongahela Railway Company; and 60 acres are owned by
various private companies and individuals. The waste disposal area is
located in the southern portion of the industrial development and consists
of an inactive landfill (2 acres), two former lagoons and the surrounding
impacted area (4 acres), and a scraped area of bare soil (2 acres). The
former drum staging area is located approximately 1800 feet north of the
waste disposal area and immediately west of the Borg-Warner South Plant.
The DOD industrial area is located approximately 1400 feet north of the
former drum staging area (see Figure 2).
Ground water at the Ordnance Works site occurs in the shallow
unconsolidated sediments in a discontinous localized perched condition
and in the deeper bedrock as a regional aquifer. The ground water flows
eastward toward the Monongahela River.
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Moraontown
Ordnanc*
Works
Site
FIGURE 1 REGIONAL SETTING
ORDNANCE WORKS SITE, MORGANTOWN, WEST VIRGINIA
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FIGURE 2 LOCATION OP INVESTIGATION SITES
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SITE HISTORY
The Ordnance Wbrks Disposal site has contained an active chemical
production facility since its construction in the early 1940s. This
facility was initially operated by private industries under agreement
with the United States government, which owned the property between
1943-1962. E.I. du Pont de Nemours first produced hexamine from ammonia
and methanol for the Department of War (now Department of Defense).
Sharon Steel subsequently operated a coke plant; Heyden Chemical operated
an ammonia production facility; and Olin Matheson later produced ammonia,
methyl achohol, formaldehyde, hexamine, and ethylene diamine at the
facility.
The United States government sold the property to Morgantown Ordnance
Wbrks, Inc. in 1962. This private corporation leased a portion of the
site to Sterling Faucet, which operated a chrome-plating facility until
1976. Borg-Warner Chemical Corporation purchased a 62-acre parcel in
1964 and began operation of an organic chemical production facility.
This chemical production facility is presently active.
«•
Princess Coals, Inc. acquired the property in 1978, but did not
actively lease or operate a chemical production facility. The Ordnance
Wbrks property was purchased by private individuals in 1982, who subse-
quently formed Morgantown Industrial Park, Inc. (MIP). MIP transferred
the property to Morgantown Industrial Park Associates, the current pro-
perty owner, in 1983.
Studies and remedial activities at the Ordnance Works Disposal site
began in 1981. Table 1 summarizes the major sampling and remedial
activities that occurred at the site prior to the RI/FS.
Table 1
Remediation/Sampling Chronology-Ordnance Works Disposal Site
Date Event
March-September 1981 Two lagoons used for chrome plating
waste disposal were excavated and
their contents disposed of in an ,
approved landfill by Rockwell
International Corporation.
April 1983 Site inspection and sampling was
undertaken by EPA's Region III
FIT Team Samples were obtained
from sealed and open drums. Also
collected were water, soil, and
sediment samples. Air samples
were collected at locations through-
out the site.
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March 1984 Soil sanples were collected by USES
Consultants, Inc. (contractor to
Morgantown Industrial Park Associates)
and analyzed for PCB contamination.
May-June 1984 Drums containing PCBs were staged
in a secure storage area on-site
and most were then disposed of at
an approved off-site facility.
This work was performed by MSES
under contract to Morgantown
Industrial Park Associates.
July 1984 Site inspection and sampling was
performed by EPA's Region V FIT
Team. Surface soils, surface
runoff, and sediments were sampled
during this program.
October 1984 PCB-contaminated soils were removed
and disposed of by MSES under
contract to Morgantown Industrial
Park Associates.
CURRENT SITE STATUS
•
The major conclusions of "the RI are summarized as follows:
Endangerment Assessment (EA)
An EA was performed to determine the potential impacts on public
health and the environment that may result from the release of hazardous
substances from the site. Risk-based cleanup levels for indicator chem-
icals were developed for arsenic (20 mg/kg), carcinogenic polynuclear
aromatic hydrocarbons (CPAHs: 26 mgAg)/ and mercury (175 mgAg) • A PCB
cleanup level of 5 mgAg was used based on EPA cleanup goals for industrial
sites.
Landfill
The landfill covers a surface area of approximately 1.6 acres and is
16 to 20 feet deep. The landfill was reportedly used from 1942 until
1962, during which time where various solid chemical wastes were disposed
of at this location by filling an existing ravine. Waste materials
identified on-site included construction debris, slag, ash, and catalyst
pellets.
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Arsenic and CPAHs were detected in soils at concentrations that exceed
risk-based cleanup levels of 20 and 26 mg/kg, respectively, in all test pits,
Average arsenic concentrations for each test pit were 24 mgAg for test
pit 1; 170 mgAg for test pit 2; and 28 mgAg for test pit 3. Average
CPAH concentrations for each test pit were 280 mgAg for test pit 1; 79
mgAg for test pit 2; and 33 mgAg for test pit 3.
Analyses of vertical profile samples within the landfill showed that
the upper 12 feet contain the highest concentrations of Hazardous Substance
List (HSL) organic and inorganic contaminants. The average arsenic
concentration decreased from 93 mgAg (0 to 12 feet) to 16 mgAg (12 to
20 feet). The average CPAH concentrations decreased from 219 mgAg (0
to 12 feet) to 3.6 mgAg (12 to 20 feet).
Former Lagoon Area
The former lagoons and the surrounding area, located adjacent to the
landfill, cover a surface area of 3 to 4 acres. This area is relatively
flat with a cinder-like surface layer and sparse vegetation. A subsidiary
of Rockwell International Corporation placed metal plating wastes in the
lagoons between 1970 and 1976. In 1981, Rockwell excavated the lagoons
and disposed of their contents in an approved landfill. That HSL metals
concentrations are presently below cleanup levels in the former lagoon
areas may be the result of Rockwell's efforts at this-location.
In the area adjacent to the two lagoons, CPAHs have been identified
at concentrations that exceed the risk-based cleanup level of 26 mgAg«
The area is approximately 0.7 acres and extends to a depth of 6 feet.
The maximum CPAH concentrations detected were 31,800 mgAg at test pit 8
and 750 mgAg at boring 7. An oily, stained cinder material was observed
in areas where CPAHs were detected.
Scraped Area
The scraped area covers a surface area of approximately 1 to 2 acres
and was an active disposal area for solid wastes from 1942 until 1962.
The waste materials identified (generally at depths of less than 4 feet)
are construction debris, oil-like stained soils, and catalyst pellets.
Chemical analysis of soil and fill in the scraped area revealed
concentrations of metals and CPAHs. Arsenic concentrations exceeded the
proposed riskbased cleanup level of 20 mgAg at only one sampling location
(114 mgAg in test pit 2), while total CPAHs equalled the proposed risk-
based cleanup concentration of 26 mgAg in an adjacent sanpling location
(test pit 3 composite).
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Drum Staging Area
Drums that were originally scattered throughout the site were collected,
staged, and sanpled in 1984 in the drum staging area. Prior to remediation,
one soil sample at this location contained 229 ppn PCBs. In October
1984, PCB-contaminated soils were removed and disposed of by MSES Consultants,
Inc. under contract to Morgantown Industrial Park Associates. The RI/FS
verified that all samples of the native soil and the slag backfill mate-
rial were below the cleanup level of 5 mgAg«
POD Industrial Area
The area surrounding the abandoned DOD process and utility buildings
were designated by EPA Region III as an area of concern based on reports
of chemical spills of both organic and inorganic materials in that area.
Mercury was detected at one sampling location at 455 mgAg (exceeding the
risk-based cleanup level of 175 mgAg)* CPAHs were detected at 30
at one location, slightly aboved the risk-based cleanup level of 26
Nearly 50 hand augered borings failed to reveal vapors containing volatile
organic constituents. Sampling in this area was limited to the surface
(maximum depth of 2 feet). Additional data to evaluate migration pathways
and potential source locations are required to complete the assessment of
this area.
Surface Water/Sediments
.Analytical data from surface-water sampling indicate that the concen-
trations of constituents of concern are below the EA risk-based cleanup
levels. As a result, this medium is not currently considered to be a
primary migration pathway for site contaminants.
CPAHs were detected at levels above the risk-based cleanup criteria
(26 mgAg) at four sediment sampling locations (stream 1: sample point 3,
280 mgAg; sample point 2, 37 mgAg* stream 2: sample point 6, 111 mgAg?
and stream 3: sample point 8, 318 mgAg)«
Arsenic was detected at levels above the risk-based cleanup criteria
(20 mgAg) at three sediment sampling locations (stream 1: sample point 3,
253 mgAg* sample point 9, 21.2 mgAg* and stream 3: sample point 8, 20.6
mgAg)-
Stream 1 is located downgradeent from the former lagoon area and the
scraped area. A seep from the scraped area feeds the stream at sample
point 9. Stream 2 is located downgradient of the scraped area, the source
of stream 2 is surface drainage from the scraped area, along with ground
water springs whose source is probably a localized perched ground water
zone. The maximum depth of streams 1 and 2 is three inches and the maximum
width is two feet and one foot, respectively. Stream 3 is located down-
gradient of the landfill. The source of stream 3 is a large seep from the
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northeast corner of the landfill and its flow is supplemented with ground
water springs at various downstream locations. This stream ranges from
four to six feet wide and has a maximum depth of four inches. All three
streams flow into the Monongahela River.
Ground Water
Ground water occurs in the sandstone bedrock under confined conditions.
The flow direction is easterly toward the Monongahela River. Ito direct
ground water users have been identified between the areas of concern and
the Monongahela River.
Iron and manganese were detected in ground water at levels above
drinking water standards. The EA indicated that the concentrations of
iron and manganese do not impact the drinking water source (the Monongahela
River), hence there is no indication that ground water is a migration
pathway of concern for site contaminants.
Contaminant-Specific Applicable or Relevant and Appropriate Requirements (ARARs)
Tables 2, 3, and 4 summarize the Federal and State contaminant-specific
ARARs relevant to the investigation of the Ordnance Works Disposal site.
The specific standards and criteria reviewed include Resource Conservation
and Recovery Act Requirements, Federal Drinking Water Standards, Federal
Ambient Water Quality Criteria, National Air Quality Standards, and the
West Virginia Water Quality Standards that have been established by the
Water Resources Board. The West Virginia Air Pollution Control Commission
has adopted regulations conforming to the National Ambient Air Quality
Standards for all contaminants except lead.
IDENTIFICATION OF EXPOSURE PATHWAYS
Based on a- review of data from the RI, several potential exposure
pathways were identified and evaluated. Separate exposure pathways are
considered for both a current use scenario and a future use scenario.
The current use scenario focuses on the potential impact of leachate
seeps, ground water recharge, and soil erosion on the Morgantown drinking
water supply, consumers of fish from the Monongahela River, and aquatic
species in the river. The future use scenario assumes that a building
will be constructed on-site and focuses on the risks to workers who may
be exposed to contaminated soils through direct contact or from the
generation of dust during construction activities. Exposure pathways for
the current use and future use scenarios are summarized in Table 5.
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9
TABLE 2
SIMMY of AHUCAM.E. MWOMIATC. AW nacvMir STMMIOS MO CUTHIA
'UM*ft( OttMICS
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-------
10
TABLE 2
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-------
11
TABLE 3
EPA AMBIENT AIR QUALITY CRITERIA
Chemical
Clean Air ACt NAAQS
(ug/cu m)
Carbon Monoxide
Hydrocarbons (nonmethane)
Lead*
Nitrogen Dioxide
Particulate Hatttr
Sulfur Dioxide
40,000 (1 hour)*
10,000 (3 hour)*
160 (3 hour)*'6
1.5 (90 day)
100 (1 year)c
260 (24 hour)*
75 (24 hour)d
365 (24 hour)*
80 (1 ye*r)c
Chemical
Code of Federal Regulations 40
Part 50.7
(ug/cu m)
Particle Matter
150 (24 hour) ,
60 (24 hour)a
•Annual maxiawa concentration not to bt •xcMdM more than once a year.
<=AJ a guide in devising lovlenentation plans for achieving oxidane
standards*
cAnnual arithmetic mean concentration.
dAnnual geometric mean concentration.
•sot adopted by the west Virginia Air Pollution Control Conussion.
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12
TABLE 4
WEST VIRGINIA WATER REGULATIONS APPLICABLE TO ORDNANCE WORKS SITE AREA
CONSTITUENT
L1HIT (tf/L)
COflHINTS
:Ar«tnie "
Barmt
Cadtiut (Soluolt)
Copptr (Tottl)
Cyanidt
(at frtt eyanidt HCN*CN-)
Htaayaltnt Chrotiut (Total)
Iron (Total)
Ltad
Htrcury (Total)
Nicktl
JCIt
Jntnolic nattrtalt
Stltniut
Silvtr
Zin,e
i
i
0.090
1.0
0.001
0.002
0.003
0.010
0.009
0.010
0.013
0.020
0.023
0.030
0.040
0.073
0.019
0.113
0.149
0.003
0.09
1.3
0.023
0.030
0.0002
0.0003
0.090
0.000001
0.002
0.009
0.010
.001
.004
.012
.024
.090
.100
.300
0.400
i ,
* ,
i ,
10-33 tf/L Hardnttt at Caleiut Carbonatt
! 34-73 tf/L Hardnttt as Calciu* Caroonat*
i 74-130 tfl/L Har0nt«t a« Caleiua Carbonitt
:>131 «fl/L Haronttt at Caleiu* Caraonatt
!0-30 if/L HardNMi at Calciua Caroonatt
131-10 •f/l> Mar4nt«« at Caleiua Caroonatt
181-120 tf/L Hardnttt at Calciu* Caraonat*
: 121*140 tf/U Hardnttt at Caleiua Caraonatt .
.'141-200 «f/L Hardnttt at Caleiu* Caroonatt •
1201-240 tf/L Hardnttt at Calciua Caroonatt :
: 241-210 «f/L Hardnttt at Caieiu* Caroonatt
: 211-300 M/L Hardnttt at Caleiut Caroonatt .
1301-320 tf/L Hardnttt at Caleiu* Caroonatt .
: 321-340 tf/L Hardnttt at Caleiut Caroonatt :
:>34l tf/L Hard^ttt at Caleiut Caroonatt :
i
i . i
i *
•
i
i
:»ay bt t«d:*ifd to 3.3 to. /I upon
iStatt and CM atfroval.
iO-100 tf/L Hardnttt at Caletut Caroonatt
:>101 tf/L Hardnttt at Calcmt Carttonatt
!In Ntttr
ilefy burdtn
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13
Table 5
POTENTIAL EXPOSURE PATHWAYS-ORDNANCE WORKS DISPOSAL SITE
Exposure
Medium
Potential
Contami nant
Source
Transport
Mechanism
Exposure
Point/Exposed
Population
Potential
Exposure
Route
Surface Water
Soil
Air
Leachate seeps,
surface soils,
ground water
Contaminated
soils
Contaminated
soils
Current Use Scenario
Surface-water
runoff, erosion,
ground water
recharge
Future Use Scenario
Direct contact
during construc-
tion
Dust generation
during construc-
tion
Drinking water
from the Monon-
gahela River,
consumers of
fish, aquatic
life
On-site
construction
workers
On-site
construction
workers
Ingestion of
river water,
ingestion of
fish, adverse
effects on
aquatic life
Ingestion of
soil, dermal
contact
Inhalation of
dust
RISK TO AFFECTED RECEPTORS
The EA addressed the contaminants identified at the site. Seven
inorganics (arsenic, cadmium, chromium, copper, lead, mercury, and zinc),
CPAHs, and PCBs were chosen as indicator chemicals based principally on
their on-site concentrations and toxicity relative to potential exposure
pathways. The risk to affected receptors can be summarized as follows:
1. The excess lifetime cancer risks assuming ingestion of drinking
water at the Morgantcwn intake and consumption of fish from the
Monongahela River are on the order of 10~*> and 10~8 for arsenic
and CPAHs, respectively, under average case exposure assumptions.
Under maximum plausible case assumptions, the corresponding
excess lifetime cancer risks are 10~4 for arsenic, 10~3 for
CPAHs, and 1Q-5 for PCBs.
2. Under the future use worker exposure scenarios the excess life-
time cancer risk due to arsenic is on the order of 10"5 for
the scraped area and landfill, and 10~7 for the lagoon area,
assuming maximum plausible exposure conditions. Corresponding
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14
risks due to CPAHs are 1Q-5 for the landfill, 10~4 for the
lagoons, and 10~7 for the scraped area. Risks due to PCBs
range from 10~7 to 10"9. Excess lifetime cancer risks
under average exposure conditions range from 10~6 to 10~8
for arsenic and CPAHs in the scraped area, landfill, and lagoon
areas.
3. CPAHs may pose an additional excess cancer risk under the future
use scenario due to dermal exposure. This risk cannot be
quantified due to lack of toxicological data for this exposure.
4. Estimated drinking water intakes of the noncarcinogenic site
contaminants (cadmium, chromium, copper, lead, mercury and
zinc) are below toxicity reference doses under average and
maximum plausible cases.
5. Estimated intakes of noncarcinogenic indicator chemicals under
the future use worker exposure scenario are below toxicity
reference doses.
6. The estimated concentrations of mercury in the Monongahela River
at the mixing level exceed EPA's Anbient Water Quality Criterion
(AWQC) for the protection of freshwater aquatic life under maximum
plausible case assumptions. This is attributed to the high mercury
concentration detected in the DOD area. Estimated concentrations
of all other indicator chemicals at the mixing level are below AW3C.
• 7. Estimated concentrations of contaminants at the Morgantown
drinking water intake runoff from the site do not exceed
applicable Federal drinking water standards or criteria under
average or or maximum plausible case exposure estimates.
Under maximum plausible exposure conditions, estimates of
mercury levels exceed the state water quality criterion for a
potable water supply. The maximum case is based on a single
soil sample with a mercury concentration one to two orders of
magnitude above satples taken elsewhere at the site and, there-
fore, may not be representative of site conditions. Further,
none of the indicator chemicals for which monitoring data are
available have been detected in the Morgantown drinking water
intake. The exposure models generally predict levels of
organics below standard detection limits.
REMEDIAL ACTION OBJECTIVES
Based on the RI and the EA, remedial action efforts at the Ordnance
Wbrks Disposal site should address the following:
1. Soils in the landfill that exceed either the arsenic (20 mg/kg)
or the CPAH (26 mgAg) EA risk-based cleanup levels: contaminant
concentrations for these parameters exceed the proposed cleanup
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15
levels at nearly every depth sampled. Since the landfill
materials are very heterogeneous, contaminant levels above
cleanup levels are likely to occur anywhere in the landfill.
As a result, the entire area is subject to evaluation for
remediation.
2. Soils in the former lagoon area that exceed the CPAH risk-based
cleanup level (26 mgAg): these soils occur at depths of 4 to
6 feet in an area of approximately 0.7 acres.
3. Soils in the scraped area that exceed either the arsenic (20
mgAg) or CPAH (26 mgAg) risk-based cleanup levels: such
soils occur from the surface to a depth of 8 feet in an area of
approximately 0.4 acres.
4. Sediments in the surface-water area that exceed either the
arsenic (20 mgAg) or CPAH (26 mgAg) risk-based cleanup levels.
Unacceptable levels of these contaminants occurred at five
sediment sampling locations and appear to occur in sediment
collection areas downstream from the waste management location.
ALTERNATIVE EVALUATION
Based on the above objectives and data from the RI, several general
response actions and associated remedial technologies were identified.
The technologies were screened using technical, environmental, public
health, institutional, and cost criteria. Institutional criteria were
used to insure that each technology attains the ARARs of local, state,
and federal statutes. The technologies that were retained for use in
developing remedial action alternatives are the following:
No action with security upgrade and monitoring
Low-permeability soil cap
Multilayer cap
Regrading, revegetation, and water diversion
Collection ditches and sedimentation basins
Complete or partial removal of wastes
Disposal in a secure on-site landfill
Disposal in a secure off-site landfill
Treatment using on-site incineration
Treatment using off-site incineration
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16
Remedial action alternatives were formulated by combining techno-
logies retained during the technology screening process in accordance
with guidelines established in the National Contingency Plan (NCP),
Superfund Amendments and Reauthorization Act (SARA), and the previously
developed remedial objectives. The Remedial Alternatives considered
are as follows:
Alternative 1 - No Action with Site Security
The purpose of presenting a no-action alternative is to provide a
basis for comparing existing site conditions with those resulting from
the implementation of the other proposed alternatives. Under the no-
action alternative, no additional measures will be used to remediate
contamination sources or their potential migration pathways. The two
major components of this alternative are:
0 Installation of a 10-foot high chain-link fence around the
scraped area, the former lagoon area, and the landfill.
0 Implementation of a quarterly ground water monitoring program
using six existing monitoring wells, and a semi-annual surface-water
monitoring program at four locations between the waste management
areas and the Monongahela River.
Technical Considerations
Activities associated with this alternative are limited to construc-
tion, operation, and maintenance of the chain-link fence.
Public Health and Environmental Concerns
8 Surface and subsurface soils would continue to exceed clean-up
levels for arsenic (20 mgAg) and CPAHs (26 mg/kg) in the three
waste management areas. Contaminant concentrations above these
levels represent a cancer risk to human receptors.
0 Without remediation, barriers would not exist to prevent site
runoff from contributing additional contaminants to sediments.
The risks presented by additional releases of CPAHs and arsenic
into the local environment would remain or increase.
Institutional Requirements
0 Does not meet remedial action objectives.
0 Does not meet RCRA guidelines for cover systems or containment
requirements for contaminants.
0 Future site use would be restricted to industrial activities.
0 Present site conditions would require improved erosion, sedimentation,
and runoff controls to protect future conditions.
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17
0 Provisions for long-term site security inspections and monitoring
would be required.
Garments
The no-action alternative does not attain APARs. The estimated
present-worth cost of this alternative is $787,000.
Alternative 2 - In-Situ Closure
Alternative 2 involves the in-situ closure of the landfill, the former
lagoon area, and the scraped area* Areas of concern would be capped,
regraded, and vegetated. The major components of this remedial alternative
include the following activities:
0 Capping (using a low permeability cap system) of locations in the
lagoon area in which elevated concentrations of CPAHs (greater
than 26 mgAg) were detected in subsurface soil samples.
0 Capping (using a low permeability cap system) of locations in the
scraped area in which elevated concentrations of CPAHs and arsenic
were detected.
0 Dredging of contaminated sediments found in settling zones downgra-
dient of the waste management areas, and disposal of the dredged
materials-in the landfill prior to placement of the cap system.
0 Consolidation of existing landfill waste and debris and applica-
tion of a multi-layer cap system which conforms to RCRA.
0 Grading and vegetation of cap systems covering the former lagoon,
scraped area, and landfill to promote positive drainage.
0 Extensive surface management for erosion and sediment control.
Placement of geotextile silt fences, sedimentation basins, and/or
diversion to control off-site soil transport and to divert
surface-water flow.
0 Ambient air monitoring.
0 Post-remediation monitoring.
Technical Considerations
0 Capping is a proven technology.
0 Potential for leakage of contaminants will be abated with a RCRA
multi-layer cap for the on-site landfill.
0 Cap installation in portions of the landfill may prove difficult
due to limited accessibility.
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18
Public Health and Environmental Concerns
0 Public health and environmental risks from direct soil contact
would be mitigated. Migration of contaminants by surface
percolation would be eliminated.
0 Dredging is anticipated to have a significant adverse short-term
impact on the local ecosystem. Restoration would include revege-
tation with endemic varieties.
0 Surface capping would reduce migration of contaminants via surface-
water runoff and sediment transport.
8 Long-term monitoring would be required.
Institutional Requirements
8 Multi-layer and low permeability cap systems must comply with RCRA
guidelines.
0 Erosion, sediment, and dust control measures must be implemented
during excavation and cap installation to comply with state
ordinances.
8 Safety protocols consistent with Occupational Safety & Health
Administration (OSHA) guidelines must be developed for excava-
tion and construction activities.
8 Excavation and construction activities must comply with local
regulations.
0 Land-use restrictions would be necessary to prohibit intrusive
activities in capped areas.
0 Provisions for long-term monitoring must be available.
Comments
This alternative does not reduce toxicity or volume of contaminants
but will reduce mobility. In-situ closure will meet all ARARs.
The estimated present-worth cost of this alternative is $1,707,000.
Alternative 3 - Partial Removal and Containment
Under alternative 3, contaminated soils near the scraped area,
existing landfill, and former lagoon area would be addressed. The specific
actions included in this alternative are as follows:
8 Excavation and on-site staging of all landfill wastes and debris.
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0 The existing landfill would be reconstructed to conform to RCRA
standards and would include a multi-layer cap and liner systems.
The reconstructed landfill would be used for the disposal of
excavated waste materials and soils from the landfill, soils
from the lagoon area and the scraped area, and sediments from
the stream.
0 Grading and vegetation of the cap system covering the newly
constructed landfill to promote positive drainage.
0 Excavation of soil with elevated concentrations of CPAHs and
arsenic located in the scraped area followed by placement in the
on-site containment area (landfill). Areas of concern correspond
to test pit locations SCA-02 (arsenic concentrations >20 mg/kg)
and SCA-03 (CPAH concentrations >26 mgAg)«
0 Excavation of soil with elevated levels of CPAHs located in the
lagoon area (CPAH concentrations >26 mgAg) followed by placement
in the on-site containment area.
0 Backfilling, regrading, and revegetation of the lagoon and scraped
areas impacted during excavation.
0 Dredging of sediments found in the settling zones dcwngradient of
the waste management areas and disposal of the dredged materials
in the landfill prior to placement of the capping system.
0 Extensive surface management for erosion and sediment control.
Placement of geotextile silt fences, sedimentation basins, and/or
diversion to control off-site soil transport and to divert surface
water flow.
0 Ambient air monitoring during remediation.
0 Post-remediation monitoring.
Technical Considerations
0 Combination of two proven technologies (partial removal and
containment) to achieve long-term remediation.
0 Effectively reduces potential mobility of contaminants.
0 Excavation of landfill wastes may be difficult to implement.
Public Health and Environmental Concerns
0 Addresses all environmental issues and contaminant pathways
identified in the RI.
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20
0 Reduces the areal extent of contamination, thereby minimizing
areas of concern on-site.
0 Partial removal/containment in an on-site RCRA landfill is
expected to reduce or eliminate public health risks and environ-
mental impacts resulting from contamination migration via surface
water runoff and sediment transport.
0 The added liner system will provide bottom control that is not
included in Alternative 2. The possibility of downward contaminant
migration appears to be insignificant, however, because of the
relative immobility of the contaminants.
0 Excavation activities may present short term public health risks
from dust and/or airborne volatile organics. These risks would
be evaluated by air monitoring and addressed appropriately.
0 Dredging is anticipated to have a significant adverse short-term
impact on the local ecosystem. Restoration would include revege-
tation with endemic varieties.
Inst i tut ipnal Requi rements
0 The landfill multi-layer cap and liner system are designed to
comply with RCRA guidelines.
0 Erosion, sediment, and dust control measures must be implemented
during excavation and construction activities to conply with
state ordinances.
0 Safety protocols consistent with OSHA guidelines must be developed
for excavation and construction activities.
0 Land use restrictions would be necessary to prohibit intrusive
activities in capped area. Restrictions would be less stringent
than under Alternatives 1 or 2 because of the decrease in areal
extent of contamination.
0 Provisions must be made for long-term leachate collection and
removal from the landfill.
0 Provisions must be made for long-term monitoring after remediation.
0 Excavation and construction activities must comply with local
regulations.
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21
Cements
This alternative does not reduce the toxicity or volume of contani-
nants but will reduce mobility. Partial removal and containment will
meet all APARs.
The estimated present-worth cost of this alternative is $3,517,000.
Alternative 4 - On-Site Incineration with Containment
The on-site incineration and containment option would be used to
treat, contaminated soils found in the scraped area and former lagoon
area, and sediments removed from the identified streams. A multi-layer
cap that meets RCRA design standards would be constructed on the inactive
landfill to prevent potential migration of organic and inorganic contami-
nants from that area. The components of Alternative 4 are the following:
0 Excavation and incineration of soils found in the former lagoon
and scraped areas and sediments removed from impacted stream
locations (CPAH concentration >26 mgAg» arsenic concentration
>20 mgAg) • Ash generated by this process will be placed in the
landfill prior to installation of the RCRA cap (assuming the ash
is not EP toxic).
0 Placement of clean fill in the excavated area, followed by grading
and revegetation of the area to provide controlled drainage patterns,
0 Consolidation of the existing landfill waste (i.e., the exposed
northern face of the landfill) and application of a multi-layer
cap system that meets RCRA design standards.
0 Implementation of surface management techniques for drainage and
sediment control in the landfill area. These measures will
include silt fences, sedimentation basins, and surface-water flow
controls.
0 Ambient air monitoring.
0 Post-treatment monitoring.
Technical Consideration
0 On-site treatment using a mobile incineration unit is well-suited
in this instance. The materials to be incinerated are fairly
homogeneous; presorting efforts would therefore be mimimal. The
system would probably require a mobile incinerator to operate 5
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22
to 7 months to complete this project (mobile unit capacity
is 100 cubic yards/day). A trial burn to illustrate contaminant
destruction and air quality would be necessary. Air pollution control
and ash handling equipment would be required.
0 Landfill capping is a proven technology. Cap installation in portions
of the landfill will be difficult because of the landfill's topography
and limited accessibility.
Public Health and Environmental Concerns
0 Public and environmental risks from direct soil contact would be
mitigated.
0 Surface capping would reduce migration of contaminants via surface
runoff and sediment transport.
0 This alternative addresses all of the environmental issues and
migration pathways presented in the RI.
0 Incineration of contaminants would eliminate the potential public
health risks resulting from contaminant migration via surface
runoff. Excavation and treatment activities may present short-
term public health risks from dust and/or airborne volatile
organics. These risks would be evaluated by air monitoring and
addressed appropriately.
0 Organic contaminants would be permanently destroyed in waste/soils
that are suitable for treatment. The environmental concern that
remains pertains to the unknown fate of inorganics in the ash.
0 Dredging is anticipated to have a significant adverse short term
impact on the local ecosystem. Restoration would include revege-
tation with endemic varieties.
Institutional Requirements
0 This alternative contemplates use of a destruction technique
applied to contaminants that may be easily fed into an incinerator.
Destruction techniques are viewedWery favorably as site remediation
alternatives under SARA.
0 Under SARA, permits may not be required for on-site incineration
or discharge of scrubber water. Regulatory agency approval
would be required for the construction and operation of the
incineration unit to ensure compliance with applicable state and
Federal regulations governing hazardous waste treatment facilities.
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23
0 A trial burn will be necessary to determine the performance of
the air emission controls and the efficiency with which organic
contaninants are destroyed. Scrubbers and/or baghouses may be
required to control particulate and residual chemical constituents.
Scrubber water must meet all Federal and state regulations prior
to discharge.
0 Ash generated from the incineration process will be stored in water-
tight bins approximately 20 cubic yards in size. A sample from
each bin will be collected and analyzed for EP toxicity. Ash
that is determined to be EP non-toxic will be placed in the
on-site landfill prior to capping. If the ash tests positive
for EP toxicity, it will be placed in an appropriate RCRA-approved
facility. Based on the present level of contaminants in the
soil/ it is anticipated that most, if not all of the ash, will
not be EP toxic.
0 Erosion, sediment, and dust control measures must be implemented
during excavation, construction, and treatment to comply with
local regulations.
0 Excavation and construction activities must comply with local
regulations.
0 Land use restrictions that prohibit intrusive activities in capped
areas would apply to future site use.
0 Provisions for a long-term monitoring program after remediation
must be provided.
Comments
This alternative reduces the mobility, toxicity, and volume of the
contaminants. On-site incineration with containment meets or exceeds all
ARARs.
The present-worth cost of this alternative is $6,718,000.
Alternative 5 - On-Site Incineration and Disposal
The on-site incineration and disposal option would permanently
reduce the toxicity of specified organic contaminants. Treatment would
be performed on contaminated soils taken from the scraped area, landfill,
and lagoon area, and on contaminanted sediments removed from the identified
streams. The components of Alternative 5 are the following:
0 Excavation of areas of concern in the former lagoon area and the
scraped area (CPAH concentrations >26 mgAg? arsenic concentrations
>20 mg/kg) and incineration of soils for organics destruction.
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24
tion A; Disposal of incinerator ash in a reconstructed, on-
site landfill. The reconstructed landfill would meet RCRA
requirements, including multilayer cap and liner systems. Option
B_: Assuming ash is nonhazardous, backfill in excavated areas.
0 Excavation of in-place waste material from the landfill and
collection of extraneous landfill debris. Separation of inciner-
able waste from unincinerable debris. Construction of an on-site
RCRA landfill with multi-layer cap and liner system. Incineration
of appropriate wastes for organics destruction. Option A: Dis-
posal of presorted and treated material in on-site RCRA landfill.
Option B; Backfill non-hazardous ash in excavated areas and dispose
or unincinerable debris in on-site RCRA landfill.
0 Grading and revegetation of all three waste management areas to
promote positive drainage.
0 Dredging and incineration of contaminated sediments found in the
settling zones downgradient of the waste management areas.
Option A; Disposal in on-site RCRA landfill. Option B; Backfill
with other treated soil.
0 Extensive surface management designed to address erosion and
sediment control. Placement of geotextile silt fences, sedimen-
tation basins, and/or diversion to control off-site soil transport
and to divert surface water flow.
0 Ambient air monitoring.
8 Post-treatment monitoring.
Technical Considerations
0 On-site incineration is a promising technology that has proven
successful in the past. Not all waste at the Morgantown site is
suitable for incineration; extensive presorting and a trial burn
of all potentially incinerable materials are necessary. Pollution
control and disposal of ash product is required.
0 Excavation/dredging for conventional applications is feasible and
common practice at site remediations.
Public Health and Environmental Concerns
8 This alternative addresses all of the environmental issues and
migration pathways identified in the RI.
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25
0 Reduces the areal extent of contamination, thereby minimizing
areas of concern onsite.
0 Treatment and on-site disposal is expected to significantly reduce
or eliminate the potential public health risks and environmental
impacts resulting from contaminant migration via surface water
runoff and migration of contaminated sediments.
0 Excavation and treatment activities may present short-term public
health risks from dust and/or airborne volatile organics. These
risks would be evaluated by air monitoring and addressed appro-
priately.
0 Organic contaminants are permanently destroyed in waste/soils
that are suitable for treatment. The environmental concern that
remains pertains to the unknown fate of the inorganics in the ash.
8 Dredging is anticipated to have a significant adverse short-term
impact on the local ecosystem. Restoration would include revege-
tation with endemic varieties.
Institutional Requirements
0 Under SARA, permits may not be required for on-site incineration or
discharge of scrubber waters. Regulatory agency approval
would be required for the construction and operation of the
incineration unit to ensure compliance with all applicable state
and Federal regulations governing hazardous waste treatment
facilities.
0 A trial burn will be necessary to determine the performance of
the air emission controls and the efficiency with which organic
contaminants are destroyed. Scrubbers and/or baghouses may be
required to control particulate and residual chemical constituents.
Scrubber water must meet all Federal and state regulations prior
to discharge.
0 Ash generated from the incineration process must be regularly tested
to determine the mobility of EP toxic metals. Classification of the
ash as hazardous or nonhazardous will determine if the ash should be
placed in the reconstructed RCRA landfill or backfilled in the
excavated areas.
0 Erosion/ sediment, and dust control measures must be implemented
during excavation, construction, and treatment to comply with
local regulations.
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26
0 Excavation and construction activities nust comply with local
regulations.
0 Funding must be available for a long-term monitoring progran.
Garments
This alternative reduces the mobility, toxicity, and volume of the
contaminants. On-site incineration and disposal exceeds all ARARs.
The present worth cost of this alternative is $16,891,000 for Option
A and $16,212,000 for Option B.
Alternative 6 - Removal/Off-Site Option
This alternative consists of excavation and removal of all sources
of significant contamination and disposal or treatment of the removed
materials at an EPA-approved off-site facility. The treatment alternative
would involve incineration while the disposal option would be a RCRA-
approved landfill. This removal/off-site option would apply to contami-
nated soils and wastes in the lagoon, landfill, and scraped areas, and
sediments in specified locations. The major components of this remedial
alternative include:
0 Complete excavation of the landfill, former lagoon area, and the
scraped area.
0 Dredging of contaminated sediments found frf'the settling zones
downgradient of the waste management areas for subsequent off-
site treatment/disposal.
0 Ambient air monitoring.
0 Backfill, regrading, and revegetation of excavated areas. The
landfill will not require extensive backfilling since it was
originally a natural ravine into which wastes were subsequently
disposed.
0 Off-site disposal/treatment options include the following:
1) Contaminated soils and materials that could be incinerated
would be transported to a commercial incinerator facility for
treatment.
2) The remaining materials would be disposed of in a RCRA-
approved secure landfill. Some materials deemed for disposal may
require stabilization prior to transportation to the disposal
facility.
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27
8 Ebst-remediation monitoring.
Technical Considerations
0 Excavation prior to off-site disposal/treatment is feasible for
conventional applications and uses cannon practices.
0 Technical considerations for the two off-site options:
1) Off-site incineration is a promising technology that has proven
successful in the past. Conmercial facilities are available to
implement this alternative. Representative samples of waste
must be accepted prior to material treatment; space must be
scheduled in advance. Most facilities impose a surcharge for
soils for ash disposal costs.
2) Off-site disposal in a RCRA-approved landfill is feasible and
is based on well developed techniques and standard engineering
practices. RCRA requirements provide for a secure area to dispose
of the hazardous materials. Timing is important since capacity
is limited and space must be scheduled.
Public Health and Environmental Concerns
0 Addresses all environmental issues and contaminant pathways
identified' in the RI.
0 This alternative calls for removal of the contamination. This
can be expected to significantly reduce or eliminate the potential
public health risks and environmental impacts resulting from
contaminant migration via surface-water runoff and sediments.
0 Dredging activities are expected to have significant short-term
adverse impacts on the local ecosystem. Restoration would include
revegetation with endemic varieties.
0 Excavation and treatment activities may present short-term public
health risks from dust and/or airborne volatile organics. Those
risks would be evaluated by air monitoring and addressed appro-
priately.
0 Additional public health and environmental issues specific to
the two treatment options:
1) Off-site incineration
0 Eliminates any long-term impacts to local public health and the
environment because hazardous materials are removed from the site
and are permanently destroyed.
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28
0 Potential short-term impacts are associated with transportation
of contaminated materials.
2) Off-site disposal in a RCRA landfill
0 Contaminated materials would be removed and placed in a more secure
location, therefore eliminating any impacts on local public health
and the environment.
0 Possibility of long-term impacts to the local area off-site if
landfill failure occurred because contaminated materials would
not be treated.
Institutional Requirements
0 Minimum public opposition is anticipated.
0 State erosion, sediment, and dust control ordinances require
compliance during excavation activities.
0 Approved licensed haulers for transport to the off-site
facility must be obtained in compliance with U.S. Department
of Transportation guidelines.
0 Long-term funding mugt_be made available for the post-remediation
monitoring program.
0 Additional institutional considerations specific to the off-site
options:
1) Off-site incineration
0 Repacking of bulk materials will likely be required prior to
shipment.
0 Incinerator time is limited and must be scheduled. Term of
project contingent upon acceptance of wastes at the facility.
2) Off-site disposal in RCRA landfill
0 Landfill capacity is limited. Success of this alternative is
contingent upon acceptance of the excavated wastes.
0 The disposal of material in a permitted landfill is governed
by State and Federal regulations.
0 Rstential liability remains in the the event of landfill
failure.
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29
Garments
This alternative provides for treatment/disposal at an off-site
facility and meets all applicable or relevant and appropriate requirements.
The present-worth cost of this alternative is $30,353,000.
Action Specific ARARs
Table 6 presents a summary of the action specific Federal and State
ARARs and the affected alternative(s).
Recommended Alternative
Section 121 of CERCLA establishes cleanup standards for site
remediation and articulates a preference for remedial actions in which
treatment permanently and significantly reduces the volume, toxicity, or
mobility of site contaminants. The provision notes that off-site transport
and disposal of hazardous substances without such treatment is least
favored where practicable treatment technologies are available. The
statute mandates selection of a remedial action "that is protective of
human health and the environment, that is cost effective, and that utilizes
permanent solutions and alternative treatment technologies or resource
recovery techniques to the maximum extent practicable".
EPA has reviewed and considered these statutory provisions and the
regulations contained in the National Contingency Plan in light of the
conditions present at the Morgantown Ordnance Works site and concludes
that Alternative 4 is most consistent with these guidelines. This
remediation alternative offers the best combination of effectiveness,
implementability, and cost efficiency and involves use of a permanent
solution (treatment of contaminated soils and sediments by incineration)
in conjunction with a containment feature (capping the existing landfill).
This remedy meets or exceeds all applicable or relevant and appropriate
requirements.
Alternative 1, No Action with Site Security, was rejected because
surface and subsurface soils would continue to exceed cleanup levels for
arsenic and CPAHs in the three waste management areas. This alternative
did not meet the remedial action objectives nor does it attain ARARs.
Alternative 2, In-Situ Closure, and Alternative 3, Partial Removal
and Containment, both meet all ARARs but do not permanently or significantly
reduce the toxicity or volume of contaminants.
Alternative 5, On-Site Incineration and Disposal, exceeds all ARARs
and similar to Alternative 4, will permanently and significantly reduce
the mobility, toxicity, and volume of contaminants. Although Alternative
5 is slightly more protective of the environment, Alternative 4 will
provide nearly the same protection to the environment for a significantly
reduced cost, therefore Alternative 4 is a more cost-efficient solution.
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TABLE 6
SUMMARY OF APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARa)
ORDNANCE WORKS SITE
MORCANTOMN, WEST VIRGINIA
ACTIVITY
RCRA Cap
-40 CTB aM.221,310
Virginia Hacardoua
Titl« 47.
Placanant of a cap ovar vaata
daaignad and conatructod to:
- Provida long-tarn migration nlninlsation
of llqulda through tha cappad araa.
- Function with ninlnun naintananca.
- Proaota dralnaga and nininisa aroaion or
abraaion of tha covar.
ita aattling and aubaldanca ao
that tha covar*a intagrity la naintainad.
- Hava a panaabllity laaa than or aqual to
tha pamaability of any bottoai ilnar
ayataa or natural aub-aoila praaant, or
1 x 10~7 cVaac. whlchavar ia laaa
(apaolfie.to Haat Virginia* Titla 47).
Ellainata fraa ligulda and atab!Ilia waataa
bafora capping.
Raatrlct poat-cloaura uaa of proparty aa
nacaaaary to pravant daaaga to tha covar.
Pravant run-on and run-off fro* daaaging
covar.
Protact and Maintain aurvayad banchnarka
uaad to looatf waata calla.
ALTEBNATIVK. IS\
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TABLE 6
Landfill
-4t CfB J44.300-310
ftvginla Haiardoua
AL.TKBMATI VK IB\
a A doubla linar daaignad to pravant nigration
of waataa at any tlna (including cloaura)
during tha oparatlon of tha landfill.
a A laachata collootion and ranoval
ayatan ivnadiataly abova tha linar.
During oonatruotlon, linara and covar
ayataaa nuat ba aiuuiinad for unifonity,
danaga and iaparfaotlona.
Propar aurvayina and raoord kaaping
(location and dinanaiona of aaoh call,
approxinat* location of aach hacardoua
waata typa in aach call).
Upon cloaura, a cap nuat ba provldad that
fulfills tha raoyiiraaants out-llnad
pravioualy (aa« ma* Cap).
On-Sita
Incinaratiott
-40 arm a«4.340-3*1
HfrMt Virginia Air
•ollution Control
14-20, Bagulatlona
VI, XV
a Analyaa tha waata faad. 4,5
a Oiapoaa of all hasardoua waata and raalduaa,
including aah, aorubbar watar, and acrubbar
aludga.
a Parfomanoa atandarda for Inoinaratoras
- Achiava a daatructlon and ranoval affioianoy
of 99.*M for aaoh principal organic hasardoua
oonatituant in tha waata faadt
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TABLE
ACTIVITY
BMtilBEHBMT
- Reduce hydrogen chloride •Missions to
l.t kg/hr or It of the MCI in the stack
gases before entering any pollution control
devices.
- lalt psrticulstee in levels not exceeding
thoee outllnsd in 40 era 2«4.344 and th«
Hsat Virginia Air Pollution Control
Regulations.
ALTKRIIATIVK t fi \
Monitoring of various parasjstsrs during
opsratlon of ths incinerator is required.
These parsjBeters include s
- CosjMistion tesperature
- Masts feed rate
• Cosjbustlon gss velocity
• Carbon •onoxlde.
u»
N>
Clsaa Closurs
(Masts Bsvoval)
40 era a«4.ii.aa)
General performance standards require
•InislsatioA of need for further and
•aintenanoe and oontrolt slislnatlon of
post-olosurs escape of hasardous waste,
hasardous constituente, leachate,
contaalnated run-off, and hasardous
vasts deoosposltion products.
Disposal or decontamination of equipsent,
structures« and soils.
2,3,4,5,4
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TABLE 6
ACTIVITY
fiTAVUTR/BBGULATIOM
ALTEBMATIVK SSI
Raaoval or dacontaaination of all wast*
raaiduaa, contaainatad containaant ayataa
coaponanta (a.g. llnara, dikaa), and
contaainatad aubaolla, aa wall aa atructuraa
and aguipaant contaainatad with waata and
laachata, and Banagaaant of thaa aa
haxardoua waata.
>t haaltn-baaad lavala at unit.
Waata
Tranaportation
40 era a«J.11-33
4t Cm 171-17*
EP* Idanti float ion Nuabar auat ba
obtainad froa tAa Adalnlatrator
Proparly uaad and Milntainad shipping
•anifaata.
•hipaants auat follow DOT ragulatlona
u>
paan
lfia
codlfiad in 49 era 171-179.
HPOM
40 era iaa.1
Waat Virginia Adalnlatratlva
Ragulatlona, Stata Natar
Maouroaa Board. Chaptar
20-SA.
Ragulraa paraita for tha diacharga of
•pollutanta* fro* any •point aourca*
(watar diaoharga from air pollution control
davica) into watara of tha Unitad Stataa.
4.5
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34
Alternative 6, Removal/Off-Site Option, was not chosen because
Section 121 of CERCLA notes that off-site disposal of hazardous substances
prior to treatment is the least favored alternative when practical
treatment technologies are available.
Alternative 4, On-Site Incineration with Containment is designed to
treat contaminated soils found in the former lagoon area and the scraped
area/ as well as sediments found in the settling zones of the three
streams downgradeent of the waste management area. A multi-layer cap
that meets RCRA design standards will be constructed on the inactive
landfill. The cap will be extended into the subsurface clay to prevent
both surface water infiltration and seeps out of the landfill area.
Test pits and soil borings in the landfill area identified a clay
layer at depths ranging from 12 to 20 feet and a thickness of 2 to 5
feet. Additional test borings in the landfill area will be required
during the remedial design to confirm the depth and thickness of the clay
and to conduct geotechnical testing for the design parameters.^
Since the source of contamination in the landfill will remain in-
place, the potential for release of contaminants into the environment
must be addressed. Such a release might occur from cap failure or from
the unforseen migration of contaminants through subsurface soils. If
the RCRA cap is properly installed, it is unlikely that cap failure would
occur and lead to contaminant release. Section 7 of the FS noted that
this technology is effective and has long-term durability. In addition,
the existing clay stratum beneath the landfill may be a sufficient bottom
liner; groundwater contamination was not detected during the RI and
CPAHs are, by nature, immobile. Geotechnical testing of the soil and
post-closure monitoring will be used to evaluate the performance charac-
teristics of this clay layer.
Alternative 4 also includes the removal and treatment of contaminated
soils and sediments found in the designated areas. Treatment by thermal
oxidation (incineration) should reduce the toxicity of organic contaminants
contained in the removed materials by neutralizing CPAHs to form carbon
dioxide and water.
The trial burns will determine the efficiency with which the organic
constituents are destroyed and the performance of the air emmission
controls. Effluent streams from the incinerator include gaseous emissions
and an ash product. Scrubbers and/or baghouses may be required to control
particulate and residual chemical constituents which result from inciner-
ation. If scrubbers are used, scrubber water must be monitored prior to
discharge. Since the Monongahela River is the likely recipient of the
scrubber water, the requirements of a NPDES permit must be implemented.
Ash generated during the trial burn must be tested for EP toxicity.
Based on the level of inorganic constituents present in the soils and
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35
sediments, it is anticipated that the ash will not be EP toxic and may
therefore be disposed on-site in the landfill prior to capping. Ash
that tests positive for EP toxicity will be transported to a RCRA-approved
facility.
This alternative includes a destruction technique applicable to
soils and sediments that can be readily excavated and fed into an incin-
erator. Destruction techniques are viewed favorably for site ranediation
under SARA since the toxicity and volume of the waste materials are
reduced.
The selected remedy offers the best combination of effectiveness,
implementability, and cost efficiency in comparison to the other alternatives
by combining a permanent solution (incineration of soils and sediments)
with containment (RCRA cap). In addition, this remedy meets or exceeds
all applicable ^r relevant and appropriate requirements.
The landfill contains a large amount of extraneous debris that would
require extensive presorting prior to incineration. The proposed RCPA
cap will be extended into the subsurface clay and will mitigate the
immediate public health and environmental risks from direct contact with
contaminated soils. In order to verify the anticipated long term relia-
bility and integrity of the cap, a ground water monitoring program for the
landfill will be developed during the remedial design. This monitoring
program will be in general conformity with the RCRA Ground Water Monitoring
Technical Enforcement Guidance Document, Septeatoer, 1986.
It is estimated that this alternative will take 2 to 3 years to
complete with actual field activities occuring during a 6 to 12 month
period. Remedial design activities should begin in the fall of 1988.
On-site monitoring will be conducted over a 30 year period.
Statement of Findings
As part of the recommended remedial action for this site, excavation
of soils in the lagoon area and sediments in the impacted stream locations
is proposed. Based on a wetland delineation conducted at the site on
April 1, 1986 by Ms. Libby Rhodes and Mr. Nels Barrett of the Environmental
Assessment Branch, there are significant wetlands associated with the lagoon
and streams on this site. It is our belief that any remedial action taken
in the lagoon area will impact the intermittent stream wetlands.
The total impact to the wetlands are unknown at this time and will not
be determined until during the remedial design. During the design, the impact
to the wetland area must be evaluated and the design must include all practical
measures that can be taken to protect all wetland areas and minimize damage to
the environment. This analysis must also include all necessary mitigative
measures.
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36
Future Activities
Review of analytical data from the DOD industrial area indicates the
presence of hazardous substances in concentrations exceeding background
levels. This data was generated from tests performed on surface soils
and surface water only. Subsurface soil conditions in this area have
not been investigated. The investigation will likely be difficult as a
result of abandoned buildings and concrete foundations of demolished
buildings which remain on-site. In addition, samples have not been
collected from the potential contamination pathways identified in this
area.
Additional testing is recommended to complete the investigation of
the DOD industrial area. The additional testing efforts should include,
but not be limited to:
0 Installation and sampling of ground water wells to evaluate
potential contamination pathways and the local hydrogeology
of this area.
0 Sampling of the four identified surface water streams leaving
this area to define potential contamination pathways.
0 Surface and subsurface soil sampling to define contamination
source areas.
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FINAL RESPONSIVENESS SUMMARY
MORGANTOWN ORDNANCE WORKS SITE
MORGANTOWN, WEST VIRGINIA
From February 16, 1988 through March 16, 1988, the U.S. Environmental
Protection Agency (EPA) held a public comment period on the Remedial
Investigation/Feasibility Study (RI/FS) and Proposed Plan for the Morgantown
Ordnance Works site in Morgantown, West Virginia. This document summarizes
the comments, both written and verbal, on the RI/FS EPA received during the
comment period by residents, local officials, and other interested parties;
and presents EPA responses to those comments.
This responsiveness summary is divided into two sections:
• Section I: Site Background. This section provides a
brief site history and discusses the EPA preferred
alternative for remedial action.
• Section II: Summary of Comments and EPA responses.
I. SITE BACKGROUND
A. Site History
The Ordnance Works site is located approximately one mile southwest of
Morgantown, West Virginia, on the west bank of the Monongahela River. The
site is east of Interstate Highway 79 and south of U.S. Highway 19.
In 1940, E.I. duPont DeNemours and Company (DuPont) built and operated an
ammonia production facility for the U.S. Department of War (now the Department
of Defense), the original owner of the Ordnance Works property. Between 1946
and 1950, the U.S. Army Corps of Engineers awarded lease agreements to Sharon
Steel Corporation to operate a coke plant on the property, and to Heyden
Chemical Corporation to rehabilitate and operate an ammonia production
facility. During the 1950's, the Olin Matheson Company leased the property
from the U.S. Army Corps of Engineers and operated the plant to produce
ammonia, methyl alcohol, formaldehyde, hexamine, and ethylene diamine.
In 1962, the property was purchased from the U.S. government by the
Morgantown Community Association with funds supplied by J.W. Ruby of Sterling
Faucet, Incorporated. The Morgantown Community Association turned title to
the property over to a new corporation called Morgantown Ordnance Works,
Incorporated, headed by J.W. Ruby. Sterling Faucet, Incorporated subsequently
operated a chrome-plating plant on the property between 1962 and 1976. In
1964, Borg-Warner Chemicals, Incorporated purchased a 62-acre parcel from
Morgantown Ordnance Works, Incorporated to operate an organic chemical plant
on the property.
The current owners, Morgantown Industrial Park Associates, Limited
Partnership (MIPA) bought the site from Princess Coals, Incorporated in 1982.
At present, MIPA owns approximately 670 acres and leases buildings and land
for industrial activities. Borg-Warner Chemicals continues to operate an
organic chemical production facility on 62 acres of the site. The Monongahela
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Railway Company and a number of private companies own the remaining 86 acres.
In October 1980, che State of Vest Virginia requested that EPA undertake
a Remedial Investigation/Feasibility Study (RI/FS) of the site. The Ordnance
Works site is currently classified by EPA as an enforcement lead site.
Investigations of the site by EPA and the West Virginia Department of Natural
Resources (WVDNR) have identified several areas of concern:
• A currently inactive landfill where various
solid and chemical wastes were disposed that
could potentially threaten human health and the
environment;
• A "scraped" area adjacent to the landfill where
solid wastes were buried, so called because the
area is flat and lacks vegetation;
• Two former lagoons (closed in 1981) used for
disposal of chrome-plating process wastes; and
• A former drum staging area where abandoned
drums, including two containing polychlorinated
byphenyls (PCBs) were collected during the
initial site remedial .activities. The drums
were subsequently removed off site for disposal
by a private contractor in compliance with EPA
guidelines.
As of March 1987, EPA had completed Phases I and II of the Remedial
Investigation (RI) to determine the extent and sources of site contamination;
identify contaminant migration pathways; and verify contaminant removal by
previous remedial actions. The feasibility study (FS) on the upper portion of
the site was completed during the spring of 1987. Some investigative work may
continue on the lower portion of the site because during the RI, samples were
taken at a depth of only two feet. EPA intends to conduct additional sampling
at greater depths.
The purpose of the RI was to determine the extent and sources of
contamination, identify contaminant pathways, and verify contaminant removal
by a previous remedial action conducted in 1984. RI activities included
taking surface and subsurface soil samples using boreholes, test pits and
sediment sampling; and sampling possible migration routes, including surface
water and ground water; installing monitoring wells at the site; analyzing
ground water; and taking air samples. The RI also included a study to assess
the possible affect on the environment and public health should a hazardous
substance from the site be released into the environment.
EPA developed the FS based on information obtained during the RI. The FS
described and evaluated various ways of rendering the site harmless to public
health and the environment. These alternatives, known as remedial
alternatives, were evaluated against several criteria including:
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• The technical feasibility of the alternative, including
performance, reliability and safety;
• How easily the alternative could be implemented;
• How successfully the alternative would protect public
health and the environment; and
• How much the alternative would cost.
EPA studied a variety of technologies for controlling the contaminants at
the Morgantown site to determine which technology could remediate the
contamination most effectively. The technologies judged to be the best for
the site were described in detail in the FS and summarized in the Proposed
Plan. The Proposed Plan also described EPA's preferred alternative for the
Morgantown site and the basis for choosing that alternative.
After carefully considering each of the remedial alternatives presented
in the FS, EPA's preferred alternative is Alternative 4, On-site Incineration
with Containment. Under this alternative, an on-site mobile incinerator would
destroy the organic compounds contained in the soil excavated from the scraped
area, former lagoons, and dredged stream sediment. Special systems to handle
the ash and exhaust from the incinerator would be used. The landfill would
receive a multi-layer cap.
II. SUMMARY OF MAJOR COMMENTS AND EPA RESPONSES
EPA held a public comment period on the"Morgantown site RI/FS and the
Proposed Plan from February 16, 1988 through March 16, 1988 and conducted a
public meeting at the Monongalia County Courthouse on March 3, 1988 at 7:30
p.m. EPA staff began the meeting by presenting a brief history of the site
and explained how the Superfund process works. In addition, the staff
presented the alternatives in the FS, and the basis for selecting Alternative
4 as the preferred alternative.
Only two questions were received during the meeting and the public
comment period. These comments are summarized below followed by EPA's
responses.
Question: When does the public comment period end?
EPA Response: The comment period is scheduled to end on March 16, 1988.
Question: One resident, a former Ordnance Works employee, commented he was
unhappy about the "condition" of the facility and urged EPA to quickly address
problems at the site.
EPA Response: For the area studied, the preferred alternative is fully
protective of human health and the environment, can be implemented within a
reasonable period of time, and is economically viable. Additional areas of
the site, which showed little or no contamination after initial sampling, may
undergo further subsurface sampling.
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