United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R03-89/082
September 1989
EPA Superfund
Record of Decision
Ordnance Works
Disposal Areas, WV
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50272-101
REPORT DOCUMENTATION /1. REPORTNO.
PAGE EPA/ROD/R03-89/082
2.
3. A8dpien1'8 A~ No.
4. 11.. 8nd Subtile
SUPERFUND RECORD OF DECISION
)rdnance Works Disposal Areas, WV
First Remedial Action
7. AuthClf(8)
5. A8port em.
09/29/89
L
,
L "'fo""11I1 0rpnIz8tI0n Alp!. No.
8. Pwfonnlng Orgalnlzatlon N8nw 8nd AddNu
10. IfraIIc:tITlIIIIWorII UnIt No.
11. ConIr8ct(C)« Gr8ne(G) No.
(C)
12. ~ Orgenlzatlon N8nw 8nd Addr888
U.S. Environmental Protection
401 M Street~ S.W.
Washington, D.C. 20460
(Q)
13. Type of Report . PwIod CoWNd
Agency
800/000
14.
15. Suppl8m8nl8ty No..
16. Ab8tr8ct (LImIt: 200 _1'118)
The Ordnance Works Disposal Areas site is on the west bank of the Monangahela River in
Morgantown, Monongolia County, West Virginia. Several chemical facilities have operated
at the site since the early 1940s, producing substances such as h~xamine, ammonia,
methyl alcohol, formaldehyde, ethylene diamine and coke. This operable unit addresses'
onsite contamination found in the following areas: an inactive landfill where solid and
~~emical wastes were disposed of; a scraped area which consists of bare soil adjacent to
~ landfill where solid wastes were buried; two former lagoon areas which were closed
~vllowing a cleanup action in 1976; and several streams located in the southern portion
of the site. This Record of Decision (ROD) supersedes a 1988 ROD which was rescinded
after public comments prompted further investigation. The primary contaminants of
concern affecting ~he soil and sediment are carcinogenic PAHs, and metals including
arsenic and lead.
The selected remedial action for this site includes excavation and onsite treatment of
"
approximately 425 cubic yards of inorganic contaminated soil from hot spots in the
scraped area and lagoon area using solidification, followed by pL~~~~~n~..of the treated
soil in the landfill before capping; installing a multimedia RCRA SUDtitI~ C cap on the
landfill and regrading and revegetation; excavating approximately 13,460 cubic yards of
(~pp At-t- ' C::h......t-\
17. Ooc-t An8Iy8Ia .. D88crIpIoI8
Record of Decision - Ordnance Works
First Remedial Action
Contaminated Media: soil, sediment
Key Contaminants: organics (PAHs) ,
Disposal Areas, WV
;1
,.
metals (arsenic, lead)
t, ~.
b. k»nIl1l8r8l0pen-End8d T-
Co CooA 11 FleldlGroup
18. AYlU8b1lty StatenwnI
18. SeCI8'Ity CI- (1hI8 Report)
None
20. SeCI8'Ity CI- (1hI8 P8ge)
Nnn...
21. No. of P8,..
68
I
22. PrIce
(SH ANSl-Z38.18)
SH IMItUCIi- on Re-
272 (4-771
(Fornwrty NTlS-35)
Dtp8rtm8nt of Cornm8f'C8
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~
EPA/ROD/R03-89/082
Ordnance Works Disposal Areas, WV
First Remedial Action
16.
Abstract (Continued)
organic-contaminated soil and sediment from the lagoon area, scraped area, and streams,
with onsite treatment by bioremediation in a treatment bed; ground water, surface water,
and sediment monitoring; and implementing deed restrictions to prohibit residential and
industrial construction at the site.' A contingency remedy has been selected which would
include soil washing of contaminated soil as the principal treatment. The estimated
present worth cost for this remedial action is $8,332,000, which includes annual O&M
costs of $88,200 for 4 to 10 years.
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RECORD OP DZCISIOB
POR
ORDNAlICZ WORlCS DISPOSAL AUAS SITE
OPBRABLB UJlIT BO. 1
KORGAN'rOD, nST VIRGIBIA
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RECORD OF DECISIOB
ORDNANCE WORltB DISPOSAL AREAS SITE
OPERABLE UBIT BO. 1
DECLARATIOB
Site Name and Location
Ordnance Works Disposal Areas site
Operable unit No.1
Morgantown, West Virginia
Statement of Basis and PurDOS8
This decision document presents the Preferred Remedial Action and
Contingency Remedial Action for a portion of the Ordnance Works
Disposal Area Site referred to as Operable Unit No.1 and further
described herein. This document was developed in accordance with
the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended; and, to the extent
practicable, the National Contingency Plan, 40 C.F.R. Part 300.
The decisions contained herein are based on information contained
in the administrative record established for this site.
The State of West Virginia has concurred on the Preferred
Remedial Action and Contingency Remedial Action.
Recision of Previous Record of Decision
This document supersedes the March 31, 1988 Record of Decision
developed for Operable Unit No.1 of the Ordnance Works Disposal
Areas Site.
,
Assessment of the site
'\..,~. "
Actual or threatened releases of hazardous substances ~om
Operable Unit No.1 of the Ordnance Works Disposal Areas Site, if
not addressed by implementing the response actions selected in
this ROD, may present a current or potential thre~t to public
health or the ,nvironment.
)
ScoDe of this Record of Decision
"
a, -.
The Preferred Remedial Action and contingency Remedial Action
selected herein address contamination present at a portion of the
Ordnance Works Disposal Areas site referred to herein as Operable
Unit No.1. Additional studies may be conducted in areas of the
site outside the operable Unit No.1 area. This document is not
intended to select a remedy or remedies for portions of the site
outside the Operable unit No.1 area, and issuance of this
1
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document shall in no way affect EPA's authority to conduct
response actions in~such areas.
DescriDtioD of the Remedv
EPA has selected, and the state of West Virqinia has concurred in -
the selection of, a Prefe~red Remedial Action and Continqency
Remedial Action for operable Unit No.1 of the Ordnance Works
Disposal Areas site from among the alternatives considered in the
Focused Feasibility Study. Both the Preferred Remedial Action and
Continqency Remedial Action are considered comparable in
remediating contamination and reducinq risks associated with
exposure to contaminated materials present within Operable Unit.
No.1.
The major components of the Preferred Remedial Action and
Continqency Remedial Action are as follows:
Preferred Remedial Action:
Alternative 8B
- Installation of a multi-media RCRA Subtitle C cap on the
landfill and reqrading/revegetation to control surface run-on and
run-off. .
- Excavation of contaminated inorganic hotspots exceedinq risk-
based cleanup levels from the laqoon area and scraped area before
bioremediation.
- Onsite treatment of soils excavated from inorqanic hot spots
using solidification and placement of non-hazardous treated
material in the landfill before cappinq.
- Excavation of orqanic contaminated soils and sediments
exceedinq risk-based cleanup levels from the scraped area, laqoon
area, and streams. /
- Treatment of excavated soils and sediments'with.\Qt~a~~c
contaminants usinq bioremediation in a treatment bed w1t~in the
associated area of contamination. . .
- Short-term environmental monitorinq to ensure tne effectiveness
of the remedia~ action. .;
- Groundwater monitorinq in the immediate vicinity of the
landfill. a,--
- Deed restrictions to prohibit residential and industrial
construction in the landfill area and residential construction in
the remaininq areas.
2
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Continaencv Remedial Action:
Alternative 6
- Installation of a multi-media RCRA Subtitle C cap on the
landfill and regrading/revegetating to control surface run-on and
run-off.
- Excavation of contaminated soils and sediments exceeding risk-
based cleanup levels in the scraped area, lagoon area, and
streams.
- Onsite treatment of excavated soils and sediments using soil
washing. Excavated areas will be backfilled with remediated non-
hazardous soils, regraded, and vegetated. .
- Short-term environmental monitoring to ensure the effectiveness
of the remedial action.
- Groundwater monitoring in the immediate vicinity of the
landfill area.
- Deed restrictions to prohibit industrial and residential
construction in the landfill area and residential construction in
remaining areas.
Conditions Triaaerina Implementation of Continaencv Remedial
Action
The Preferred Remedial Action selected by EPA for
implementation at Operable Unit No.1 is Alte~ative 8B.
however: ,
If,
1. Predesign studies show that treatment l~vels,spec~fied in the
ROD cannot be achieved using bioremediation techrit'qaes ."within a
reasonable time frame; or .
2. Responsible parties elect to design, implement, and finance
Alternative No.6 at Operable Unit No.1; or
~
3. Information received during the bidding pro~ess suggests that
the costs of implementing Alternative No. 8B are significantly
higher than originally estimated; a,-.
then Alternative NO.6, the Contingency Remedial Action, shall be
the remedial action selected by EPA for implementation at
Operable Unit No.1 of the Ordnance Works Disposal Areas site.
3
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statutorY Determinati2n!
. The Preferred Remedial Action (Alternative 8B) and Contingency
Remedial Action (Alternative 6) are protective of human health
and the environment, comply with Federal and State requirements'
that are leqally applicable or relevant and appropriate to the
remedial action, and are cost-effective. The Preferred Remedial
Action and Contingency Remedial Action utilize permanent
solutions and alternative treatment technologies to the maximum
extent practicable and satisfy the statutory preference for
remedies that employ treatment that reduce toxicity, mobility, or
volume as a principal element.
Because implementation of either the Preferred Remedial Action or
the Contingency Remedial Action will result in hazardous
substances remaining onsite above health based levels, a review
will be conducted within five years after commencement of
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
,
£l13~
Edwin B. Erickson
Regional Admin;strator
'\.., o'i. ". "of
~
Date
4
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I.
II.
III.
IV.
V.
VI..
VII.
VIII.
IX.
X.
XI.
XII.
COII'rBII'rS
Site Name, Location, and Description
Site History and Enforcement Activities
Community Relations History
Scope and Role of Response Action
site Characteristics
Summary of Site Risks
Documentation of Significant changes
Description of Alternatives
Comparative Analysis of Alternatives
The Selected Remedy
Rationale for Remedy Selection
Statutory Determinations
5
Page
6
6
9
9
10
13
18
18
25
43
49
51
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'\..:.... ~'I'P""
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RECORD OP DECISION
ORDNANCE WORD DISPOSAL AREAS SITE
. OPERABLB UHIT 110. 1
DECISIOII SUXHARY
I.
SITS HAKB, LOCATION, AND DESCRIPTION
The Ordnance Works site is located in Monongalia County on
the west bank of the Monongahela River in Morgantown, West
Virginia (see Fiqure 1). The site is situated in and around a
tract of property formerly owned by the United Scates and used
for the production of various chemical substances. Significant
features include an industrial complex (largely abandoned) in the
northern and central portions of the property and waste disposal
areas--including a landfill, "scraped" area, former lagoons, and
several streams--located at the southern end of the tract. This
Record of Decision identifies remedial actions selected for
implementation at the waste disposal areas, which areas are
collectively referred to herein as "Operable Unit No.1," at the
southern portion of the site.
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 the City
of Morgantown. Surface elevations at area$ within the site
investigated by EPA range from 975 feet mean sea level ("msl") to
1010 feet msl. The Monongahela River is adjacent to the site at
825 feet msl. A fairly steep cliff separates the river from the
waste disposal areas at the site.
Ground water at the Ordnance Works site occ~rs in shallow,
unconsolidated sediments in a discontinuous localized perched
condition and in the deeper bedrock as a reqional\aquifer.
Ground water flows eastward toward the Monongahela~~ive~. The
City of Morgantown (population 31,000) operates a drinking water
intake one mile downstream of the site which supplies the city
with approximately 70% of its potable water.
..
"
J
8IH HISTORY AND SHPORCBMBNT ACTZVITIES
II.
The Ordnance Works site has contain~a an active chemical
production facility since the early 1940's. In December 1943,
the United States purchased approximately 850 acres at this
location from E.I. duPont de Nemours and Company ("DuPont").
Through 1945, DuPont operated a facility it had constructed on
the site to produce hexamine from ammonia and methanol for the
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SITE lOCATION MAP
MORGANTOWN ORDNANCE WORKS SITE
MORGANTOWN, WEST VIRGINIA
FIGURE 1
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Department of War (now Department of Defense). From 1945 to
1962, when the United states sold the tract to the Morgantown -
Community Assocation; Inc. (which subsequently sold the property
to Morgantown Ordnance Works, Inc.), a succession of private
companies including Sharon Steel, Heyden Chemicals, and Olin
Matheson produced such substances as ammonia, methyl alcohol,
formaldehyde, hexamine, ethylene diamine, and coke at the
facility. .
In 1964, Weston Chemical Company purchased a small parcel
from Morgantown Ordnance Works, Inc. Weston Chemical Company
subsequently expanded it operations at the site. This expansion
continued after 1969, when the Borg-Warner Corporation purchased
Weston Chemical Company, with the result that Borg-Warner
ultima~ely operated two plants (identified in Figure 1 a~ the
"North" and "South" plants) on company-owned property amounting
to approximately 62 acres. In 1988, General Electric purchased
Borg-Warner's operations at the site. The General Electric
facilities are currently active.
Much of the property in and around the industrial complex in
the northern and central portion of the site and the waste
disposal areas located in the southern portion of the property is
presently owned by Morgantown Industrial Park Associates, Limited
Partnership ("MIPA"). From May-October 1984, MIPA conducted a
response action during which drums containing PCBs and
contaminated soils were removed from the property and disposed at
an approved disposal facility.
In January 1988, EPA completed a Remedial Investigation and
Feasibility Study ("RIjFS") during which 200 samples from soil,
sediment, ground water, and surface water were collected and
analyzed. The majority of these samples were taken from the
waste disposal areas at the southern end of the site. In March,
1988 EPA issued a Record of Decision ("ROD") sel~cting a remedy
for implementation at these waste disposal areas. The ROD
additionally announced EPA's intention to conduct\~her studies
in the industrial complex areas in the northern ancf .centtal
portions of the site.
Subsequent to siqninq this ROD, EPA opened a comm~nt period for
responsible parties. In response to comments r~ceived from
several partie~, EPA performed a Focuse~ Feasib!lity Study to re-
evaluate the remedial action alternatives considered in the March
1988 ROD and to perform a risk-based an~y'sis of cleanup levels.
This study was completed June 1989.
8
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."
III.
eOMKUHITY RBLATIONS HISTORY
EPA held ~ public comment period on the RI/FS (released
January 1988) and first proposed plan from February 16, 1988
through March 16., 1988. EPA issued a Record of Decision on March
31, 1988, selecting a remedy for implementation at Operable Unit
No.1.
In November/December 1988, EPA opened a limited comment
period for responsible parties associated with the Ordnance Works
site. In response to comments received from several parties, EPA
performed a Focused Feasibility Study (FFS) to re-evaluate the
remedial action alternatives considered in the March 1988 ROD and
to perform a risk-based analysis of cleanup levels. The FFS was
completed June 30, 1989 and a new proposed plan for Operable Unit
No.1 was issued thereafter. A public comment period was held
July 3 through August 2, 1989, and a public meeting was held in
Morgantown, West virginia on July 12, 1989 at the Morgantown
Public Library. At this meetinq, representatives from EPA and
the State of West Virginia answered questions about problems at
the site and the remedial alternatives under consideration. A
response to the comments received durinq this period is included
in the Responsiveness Summary contained in this Record of
Decision.
All documents predicatinq the remedy se~ection decisions
contained in this Record of Decision are included in the
Administrative Record for this site and can be reviewed or
referred to for additional information. .
IV.
seop. UID ROLB O. aSPONS. ACTIO.
This Record of Decision .elects a Preferr~d Remedial Action
and Contingency Remedial Action for a portion at ,the Ordnance
Works Disposal Areas Site referred to aa Oper~l. Unit No.1.
The January 1988 RI/FS performed at the aite docume~ts the
release/threatened release of hazardous substances ..J.Dt'Q..~e
environment at locations outside the Operable Unit No. 1 area.
These releases/threatened releases, which have not been studied
in a comprehensive tashion, may be the subject at further
response actiona at the site and are not address~d by this Record
of Decision. - J
The contaminated areas within Operable Unit/No.1 were
determined to be a principal threat beca'" of the potential for
direct dermal contact and ingestion at soil and sediments. The
remedial objectives are to remediate contaminated soil and
sediments through combined containment and treatment
alternatives, to prevent current and future exposure, and to
prevent contaminant migration to surface waters.
9
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EPA considers the entire Operable unit No.1 study area to
be contaminated with the same contaminants, i.e., carcinogenic
polynuclear aromatic hydrocarbons (CPAHs), arsenic, and other
inorganic metals. 'For the purposes ot evaluating remedial'
alternatives and developing cost data, the soil and sediment
volume of areas with contaminant levels exceeding recommended
cleanup levels was determined based on data available in the
Remedial Investigation (Weston 1988). These "base case"
remediation volumes are shown in Table 1. A total ot 43,000
cubic yards ot contaminated soils and sediments (13,885 cubic
yards outside the landfill) will be remediated.
v.
8ITZ CBARACTBRI8TIC8
The contaminants of concern tor Operable Unit No.1 are
carcinogenic polynuclear aromatic hydrocarbons (CPAHs), arsenic,
lead, copper, chromium, mercury, zinc and cadmium. The CPAHs and
arsenic are carcinogens. The other inorganic compounds are
systemic toxicants. The affected media are soil, sediments, and
onsite surface water.
The waste management areas ot concern that will be
remediated are described as tollows:
"Scraped Area"
The scraped area consists ot bare soil, adjacent to the
landfill, where solid wastes (construction debris, oil-like
stained soils, and catalyst pellets) were buried. Chemical
analysis of soil and fill in the scraped area getected
concentrations of arsenic at a concentration ot 114 mg/kg in test
pit 2, and CPAHs at concentrations ot 50.7 mg/kg
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~
TABLE 1
Summary of Contaminant Volumes
Contaminant Volume., Cubic Yards
CPAHs and
Source Area CPAH. Inorganics Inorganics
Scraped Area 2,010 360
Landfill 29 , 150
Lagoon Area 10,950 65
Stream Sediment. 500
TOTAL 13,460 29,150 425
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Former Lagoon Area ~ ,
Two former lagoons located adjacent to the landfill were
used for waste disposal until the lagoon residues were removed
and the lagoons were closed as part of a cleanup action in 1976.
This area is relatively flat with a cinder-like surface layer and
sparse vegetation. Metals concentrations are found in relatively
low levels in the former lagoon areas. Cadmium and lead were
found above the action levels in one location (soil boring 09)
with concentrations of 1,400 mg/kg and 2,300 mg/kg, respectively.
CPAHs have been identified at this location at very high ,
concentrations. The concentration of CPAHs ranged from 4.6 mg/kg
to 47,~00 mg/kg. An oily, stained cinder material was observed
in areas where CPAHs were detected.
Surface Water/Sediments
Analytical data from surface water indicate that the
contaminants of concern (i.e., CPAHs, arsenic, lead, copper,
chromium, zinc, cadmium, and mercury) are relatively low in
concentrationi therefore, this medium is not currently a primary
migration pathway for site contaminants. CPAHs were detected at
relatively high concentrations at sediment sampling locations'
downgradient of the scraped area and landfill: stream one, 37 .
mg/kg and 280 mg/kg CPAHi stream two, 111 mg/kg CPAHi stream
three, 318 mg/kg.
Groundwater
Several , small perched aquifers that exist throughout the
site were not sampled, due to their small volumes. However,
these perched aquifers surface as streams, which were sampled and
found not to be contaminated. Groundwater occur. in the
sandstone bedrock under confined conditions.Th. flow direction
is easterly toward the Monongahela River. No di~eot groundwater
users have been identified between the waste mana~..nt'.areas and
the Monongahela River. Only iron and manganese were detected in
groundwater at levels above drinking water standards. The
Environmental Ass....ent (EA) conducted by EPA (Weston 1988)
indicates that the concentrations of these consuituents do not
affect the drinking water source (i.e." the Mon~ngahela River)
and that groundwater is not a migration pathway~f concern for
site contaminants.
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VI. SUMMARY OP SITI: RISKS
Risk Assessment
The March 1988 ROD tor the Ordnance Works site established
remedial action objectives which identitied contaminants and
media ot concern, potential exposure pathways, and cleanup levels
and remediation qoals. A risk assessment was pertormed tor both
present and future potential exposure pathways. The principal
threat to human health and the environment was determined to be
soil and sediment contamination. Ground water was not determined
to be a contaminant exposure pathway. The selected remedy, onsite
incineration and containment, tocused on source controlot soils
and sediments. The remediation qoal was to achieve a risk-based
cleanup level tor soils and sediments ot 20 mq/kq arsenic and 26
mq/kq CPAHs based on a tuture exposure scenario tor onsite .
construction workers.
Since no new Remedial Investiqation was conducted, EPA
believes it is appropriate to use the same media ot concern and
potential exposure pathways to evaluate remedial alternatives and
conduct a risk assessment to determine remediation qoals in this
ROD. EPA has increased the ranqe ot remedial alternatives
investiqated and amended cleanup levels to be achieved tor source
control of soils and sediments in this ROD based on the Focused
Feasibility Study (NUS, June 1989) and Proposed Plan issued in
July 1989.
As part ot the Focused Feasibility Study, EPA
performed a new risk assessment to re-evaluate the potential
impacts on public health and the environment that may result from
release ot contaminants trom Operable Unit No. l~at the Ordnance
Works site. As part ot the risk assessment, EPA evaluated
cleanup levels tor eiqht contaminants because ot'~eir hiqh
concentrations in soil/sediment and toxicity relat1ve ~o
potential exposure pathways: seven inorqanic compounds (arsenic,
cadmium, chromium, copper, lead, mercury, and zinc) and.
carcinoqenic polynuclear aromatic hydrocarbons (C~AHs). CPAHs
and arsenic are carcinoqens. The other contamiyants are systemic
(non-carcinoqenic) toxicants. '
.,
Selection ot cleanup levels requir~~_.consideration ot
exposure conditions (i.e., physioloqical characteristics ot
individuals exposed, circumstances and extent ot exposure, etc.)
and exposure _edia. Potential exposure pathways are shown in
Table 2. Potential exposure in non-residential areas such as the
Ordnance Works site occurs throuqhditterent pathways than in
residential settinqs. While inqestion may be the principal
exposure pathway ot concern in residential settinqs due
13
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to the potential for regular contact by children who may consume
quantities of soil,: in most non-residential areas there is less'
opportunity for this type of regular exposure by small children
to occur. Because the contaminated areas are located within an
industrial park, EPA based its risk analysis on a future use
scenario for protection of construction workers who would be
exposed to soils and sediments during the construction of an
industrial facility following completion of site remediation.
Three exposure pathways were considered appropriate for this
exposure scenario: ingestion of soil, dermal contact, and
inhalation of dust. Construction workers were assumed to make
100 visits to the construction site and ingest 100 mg of 80il per
visit. Dermal exposure assumed 10 percent of total adult surface
area exposed per visit. Workers were assumed to inhale 20 cubic
meters 'air per site visit with a ratio between soil and air
concentration of 1.SxlO+6 mg/kg soil per ug/cubic meter air. All
three exposure routes were considered in combination. Carcinogen
exposures were averaged over a 'O-year lifetime.
Excess lifetime cancer risks for carcinogens were determined
by multiplying the intake contaminant level with the cancer
potency factor. These risks are probabilities generally
expressed in scientific notation (i.e. 1xlO-6 or 1.00E-06). An,
excess cancer risk of 1xlO-6 indicates that an individual has a
one in one million chance of developing cancer as a result of
site related exposure to a carcinogen over a 'O-year lifetime
under specific exposure conditions at the site. Potential
concerns for effects from noncarcinoqens is expressed by
calculating a hazard index. The hazard index provides a useful
reference point for determining the potential significance of
contaminant exposure. A hazard index that exceeds 1.0 is
unacceptable. A summary of the risk assessment calculations is
shown in Table 3. Since cleanup levels are fo~ protection of
workers during construction of an industrial fac~lity, and mayor
may not provide equivalent protection under residential exposure
conditions, deed restrictions are considered necessary to prevent
the development of a residential area in this loc.~Gri. '''"
14
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.....
TABLE 2
.
Exposurl Potlntia' Tran~ Potlntial Exposurl Pot,nti al
Contaminant PoimlExpoMd
Medium Sourc. MlChanism Population Exposurl Routl
POTENT1AL EXPOSURE PA THWA YS
MORGANTOWN ORDNANCE WORKS SITE
MORGANTOWN, WEST VIRGINIA
Cu",nt-Ute Sctnario
Sedimenu Ll8Chatl MIps, Surlac.-water ConsumtrS of fish, Ingestion 0#
SUrlacl SOils runoff, lfOIion aquatic lif, Mdimem or of
fish, advtrw
Ifftcts on Iquatic
lif,
Soil ~minatld Direct Contact Unauthorized Ingenion of Soil,
soils persons dermal contact
Futur.Ute SclNrio
Soil ~minatld Direct contact 0nIite constructiOft Ingenion of soi',
soil. during wort... dermal com.ci
construction
Air Contaminated Dust g8n1r8tiOft 0nsit8 constructiOft Inn.Mion of dust
soi.. during wort...
consvuctiOft
15
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TABLE 3
CALCULA 110N OF THE SPECF'C CLEANUP LEVELS FOR THE AREAS OF CONCERN
MORGANTOWN ORDNANCE WORKS ~TE
MORGANTOWN, WEST VIRGINIA
~rci n0gen,
.
Chemica' Concentration of RftiMd Ceanup
Indicator Chemica's 1.00 E-06 Risk in Absence of
Other ContamiNnts Acceptable Risk &.ev.fs
(mglkg) (mpg)
Arwnic 8.8& .01 1.00&-01 e.. + 01
CPAHs 4.47E + 01 1.ooE-oi 4.471 + 01
Total Risk to the Area 1. OOE-GI
Systemic Tolicants (Noncarcinogens)
Chemical Concemr8UOft of ItewiI8d a--.p
IndicatOr Chemicals 1.00 E-ol Risk in Absence of
Other Com.ImiNntl Hazard ,,,.. .....
(m91cg) (mgtkg)
Cadmium 1.71 + 02 1.001 +00 I.GI + 02
Chromium 3.(ME + 03 1.00E +00 1.111+0.
eop,. 2.251 + 0. 5.001-01 4.111+0.
Le8d HlA - NlA ~.OOE +02
Mercury 1.821 + 02 5.001-01 3.321 .02
Zinc 1.281 +05 5.001-01 2:.r.05"'0(
Total H8Z8rd.lndex 1.001 +00
for the Are8
,
Not..:'- J
(1) The overall risk 88OCi8tld wiU'I the sit8 is 1 E-oI, a t81istic future lC8Nrio due to the site's
current use.
(2) Because oral e...... to inorpnic 8IMftic h8s been 8UOCi.lH" wiU'I nonI8th8I forms of
skin cancer only, EPA presumes that the risks MSOCi-.d with CPAHs and 8It8nic .,. not
additive.
(3) EPA h8S evidence that le8d and mercury a~ the ..me t8tg8t orpns in nm8ls;
th.,efore, their risks should be additive.
(.) EPA has evidence that copper and zinc attack the ..me target orpns in ani ruts; thetefcn,
their risks should be additive.
(S) The exposure of systemic toxicanu is -time-weightld. - This is th8 e...... that should
occur over a period of 1 year. .
(6) Because lead and mercury in:.;.' ~t in 'animals, the lead cleanup level
L: calculat=c ,= . 500 mg/kg :: . . . . - than 1,000 mg/kg 0,000 mg/kg is
E?A policy fc~ 1~~strial s-
-------
Cleanuc Levels
Cleanup levels for soil and sediments for five indicator
contaminants are shown in Table 4. Cleanup levels are not
proposed for mercury, zinc, and chromium (see Table 3) because
the maximum concentrations detected durinq the Remedial
Investiqation are ,at concentrations that are below the risk-based
cleanup levels. The cancer risk from exposure to CPAHs and
arsenic will be 1x10-6 and is within EPA's acceptable exposure
ranqe of 10-4 to 10-7.
TABLE 4
Contaminant
Cleanuc Level (ma/ka)
Carcinoqenic Polynuclear Aromatic
Hydrocarbons
44.7
Arsenic
88.8
Cadmium
642
Lead
500
Copper
41,100
Remedial Action Goals
The specific remedial action qoals for source control of
soils and sediments are: I
<
o
Reduce or eliminate orqanic contaminants in surface and
subsurface soils and sediments that exce~~.. risk-based
,.,""
cleanup level for CPAHs of 44.7 mq/kq. .
Reduce or eliminate inorqanic contaminants in surface and
subsur~ce soils and sedim.nts that exceed risk-based
cleanup levels for arsenic (88.~ mq/kq), cadmium (642
mq/kq); lead (500 mq/kq); copper (41,100 mq/kq).
I.
o
o
Reduce or eliminate the threat of~iqration of
contaminants from the landfill.
17
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VII.
DOCUMENTATION OP SIGNIPICAHT CBAHGES
PROM PROPOSID PLAB
EPA has selected a Preferred Remedial Action and Contingency
Remedial Action from among the two alternatives announced in the
Proposed Plan as p~eferred remedial alternatives.
VIII. DBSCRXPTIOB OW ALTBRKaTIVZ8
Alternatives were evaluated to select a permanent source
control remedy for Operable unit No.1 of the Ordnance Works
Disposal Areas site consisting of an inactive landfill, two
former lagoons and the surrounding area, a waste disposal area'
referred to as the "scraped" area, and sediments from three small
streams that transect the area. The alternatives describe final
remedial actions for contaminated soils and sediments. The
alternatives that were evaluated and net present worth costs are:
Alternative 1:
Bo Action with site Control (All Area.)
$3,053,000
Install fence around entire area.
Deed restrictions to prevent future deve~opment.
Implementation of a long term monitorin~ program.
The no action alternative does not provide adequate
protection of human health and the environment. CUrrent and
future environmental risks would still exist from site runoff and
access to the site by wildlife. The no action alternative would
not permanently and significantly reduce the volume, toxicity, or
mobility of hazardous waste at the site; would/not meet
applicable or relavant and appropriate federal a~d state
standards, requirements, criteria, or limitations: and does not
utilize permanent treatment technologies to. the maximum extent
practicable as mandated by COCLA. The no action\ ..)t:8.t:nati ve
furthermore does not meet cleanup levels ~ased on EPA guidance,
criteria, and advisories.
18
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Alternative 2:
cappinq with Surface-Water Controls (All Areas)
$4 ,!7~3, 000 .
"RCRAn (Resource conservation and Recovery Act) equivalent cap
over the contaminated areas.
Dredqe and dewater co~taminated sediments and place in.onsite
existinq landfill prior to cappinq.
Surface manaqement for erosion and sediment control.
Monitorinq proqram for qroundwater, surface water, and
sediments.
Deed restrictions to prevent future development.
Alternative 2 includes installation of a cap over
contaminated areas not meetinq recommended cleanup criteria; the
cap would comply with recommended RCRA desiqn guidance for
hazardous waste land disposal facilities. This total area is
estimated to be four acres.
Surface water controls, such as drainaqe ditches, and
reqradinq of the surroundinq area and cap, would be implemented
to control run-on of surface water. Contaminated stream areas
would be dredqed and placed in the landfill before cappinq. A
short-term toxicity monitorinq program (bioassays) would be
conducted before, durinq, and after the remediation as one
measure of effectiveness. Because waste is left onsite, a
monitorinq proqram for qroundwater, surface water, and
sediments is recommended after cap installation. Deed
restrictions are proposed to prevent future residential and
industrial development.
Alternative 2 does not permanently and significantly reduce
the mobility, volume or toxicity of hazardous waste at the site,
does not utilize permanent treatment technoloqies ~o the maximum
extent practicable, and does not satisfy CERCLA's\~ef~~ence for
remedies that employ treatment as a principal element. ~
19
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Alternative 3:
Soil .ashinq (All Areas)
$17,308,000
- Excavate contaminated soils for soil washing (all areas).
- Onsite treatment and disposal of soils and sediments using ,soil
washing techniques.
- Toxicity testing (bioassays) for streams 1,2, and 3
before, during, and after remedial action.
- Deed restrictions to prevent future residential
development.
This alternative is a permanent treatment technology based
on a commercially available soil washing process which uses
solvent extraction to remove contaminants from soil.
contaminated soil and sediments (approximately 42,610 cubic yards
total) would be treated onsite via soil washing and the treated
material returned to the original excavated areas (assuming that
EP toxicity testing shows that the treated soil is not
hazardous). Since all areas would be remediated, no long-term
site monitoring is required. The soil washing process generates
two liquid waste streams for disposal. A concentrated liquid
organic residue waste stream would be disposed by offsite
incineration. The wastewater stream would be treated onsite
using a chemical/physical treatment process and any sludge also
disposed offsite. A treatability study will be conducted to
determine design criteria for the soil washing and waste
treatment processes.
Alternative 4:
Soil .ashinq (Landfill and
and Sior..ediation (Laqoon
orqanic Bot spots)
$1',124,000
Inorqanic Bot spots)
Area, Sediments, and
"
- Excavate landfill soil, inorganic hot spots in the former
lagoon area, and inorganic hot spots in the scrape~' a~.a for
soil washing. '
- Excavate lagoon area
stream sediments.
disposal of soils from landfill and
using soil washing techniques.
J
and scraped area, and dreqge and dewater
- Onsite treatment and
inorganic hot spots
'"
., .'
- Onsite treatment of soils/sediments from lagoon area, scraped
area, and streams using bioremediation techniques.
- Toxicity testing (bioassays) for streams 1, 2, and 3 before,
during, and after remedial action.
20
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.....-
- Deed restrictions to prevent future residential development.
Soil washing of. the landfill and inorganic hot spots
(approximately 29,575 cubic yards) would be conducted as
described in Alternative 3. Bioremediation in this instance
would involve biological degradation of polynuclear aromatic
hydrocarbons (PAHs) in a treatment bed constructed within the
area of contamination. The untreated soil would be combined in
the treatment bed with nutrients and clean soil and rototilled
periodically to aerate the mixture and accelerate the naturally
occurring biodegradation process. Excavated areas will be
backfilled and revegetated as the project proceeds. The
treatment bed containing the remediated soil will remain intact
and be revegetated after complete remediation. A treatability.
study will be conducted to determine design criteria for
bioremediation.
Alternative SA and SB:
Soil ..shinq (Landtill, Inorqanic Bot
spots) and On.ite Incineration (SA) or
Offsite Inciner.tion (SB) ot Sediments,
Laqoon Are., and scraped Area
SA: $28,590,000
SB: $44,1'7,000
Excavate contaminated landfill soils and inorganic hot
spots (425 cubic yards) from the laqoon area and scraped
area. Soil wash excavated soils onsite and dispose of
treated soils onsite.
Excavate sediments, lagoon area, and scraped area and
incinerate either onsite or transport to an offsite RCRA
incineration facility for treatment.
For option involvinq onsite incineration, test incinerator ash
for EP toxicity and dispose of ash onsite in ~xcavated areas
if not hazardous, or offsite at a RCRA hazardous waste
landfill followinq treatment it determined tO,be h~zardous by
EP toxicity testinq. \.., 4' "'''...
Deed restrictions to prevent future residential
development.
-
..
Toxicity testinq (bioassays) for streams 1,~, and 3
before, durinq, and after remedial action.,
The soil washinq of the landfill a~' inorqanic hot spots
will be conducted as described in Alternative 3. Treated soil
would be returned to oriqinal excavated areas. after verification,
by EP toxicity testinq, that the treated soil is not hazardous.
Offsite incineration can be accomplished by excavation and
transportation of organic contaminated soils/sediments to an
21 .
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offsite permitted RCRA hazardous incinerator facility. The
excavation process would comply with RCRA requirements for the.
clean closure of landfills. The resulting ash would be properly
disposed of by. the RCRA facility. For onsite incineration, a
mobile incinerator would be brought to the site. The ash would
be used as backfill, following EP toxicity testing to verify that
ash is not EP toxic. The excavation and backfilling process
would comply with RCRA requirements for clean closure of
landfills. Any ash determined to be a RCRA hazardous waste would
require treatment and disposal in a RCRA hazardous waste
facility.
Alternative 6:
Capping (Landfill) and soil Washing (Remaining'
Areas)
$9,393,000
RCRA equivalent cap over existing landfill.
Surface management for erosion and sediment
control.
Deed restrictions to prevent future development of the.
capped area, and residential development in other areas.
Excavate contaminated soils (outside landfill) for soil
washing.
Onsite soil washing and disposal of treated
soils and sediments for lagoon area, scraped area, and
dredge and dewatered stream sediments.
Monitoring program for groundwater, surface water, and
sediments as described in Alternative 2.
Alternative 6 combines containment and treatment. It is
similar to Alternative 3 except that the contents ot the landfill
would remain in place, and the landfill would be CQv.are~with a
RCRA equivalent cap as described in Alternative 2. Soil washing
would be conducted as described in Alternative 3 for the
sediments, lagoon area, and scraped area (approximately 16,700
cubic yards). Treated soil would be returned t~ ariginal
excavated areas after verification, by ~P toxic~y testing, that
the treated soil is not hazardous.
a, ..
22
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~
Al~8rnative 7A and 71:
Capping (Landfill), Onsite Incineration
(7A) or Offsite Incineration (78) of
Lagoon Area, Sediments, and Scraped
Area, and Solidification of Inorganic
Hot spots (Lagoon and Scraped Areas)
7As
78:
$21,221,000
$37,562,000
RCRA equivalent cap over existing landfill. Provide
surface water management for erosion and sediment
control.
Excavate inorganic ho~ spots from lagoon area and
scraped area and solidify onsite.
Excavate sediments, lagoon area, and scraped area
and incinerate either onsite or transport to an
offsite RCRA incineration facility for treatment.
For option involving onsite incineration, test
incinerator ash for EP toxicity and dispose of ash
onsite at a RCRA hazardous waste landfill if ash is
determined to be hazardous by EP toxicity testing.
Toxicity testing (bioassays) for streams 1, 2, and 3
before, during, and after remediation.
Monitoring program for groundwater, surface water, and
sediments.
Alternatives 7A and 7B employ the same inQineration
technology as alternatives SA and 5B. Alternati~e 7 will consist
of placing a RCRA equivalent cap over the landfill and
solidification of inorganics excava~ed from the hot, spots (425
cubic yards) using cement or fly ash methods. Solid!fiGation
requires mixing excavated soils onsite witp a fixation agent to
form a solidified mass. The solidified soil will be placed in
the existing landfill before capping, after testing to determine
that the solid!fied soils do not exhibit hazardous waste
characteristics. Alternately, soils may be tradsported offsite
for disposal in an approved RCRA landfill. Deed, restrictions
would be necessary to prevent construction on the capped area and
to prevent development of a residential krea onsite.
23
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~~
Alternative 8A and 81: .
Landfill Capping, lior..e4iation
Atop the Landfill (8A) or in a
Separate Treataent Bed (81) and
SOlidification.
8A:
8B:
88,058,000
$8,332,000
RCRA equivalent cap over existing landfill.
management for erosion and sediment control.
Excavate inorganic hot spots from lagoon area and scraped
area and solidify onsite.
Surface
Excavate organic contaminants from the lagoon area, scraped
area, and sediments and treat using onsite bioremediation
in a treatment bed.
Monitoring program for groundwater, surface water, and
sediments.
Deed restrictions to prevent future residential
development and to prevent construction on the' capped
area.
This alternative will consist of installing a treatment bed
to conduct the bioremediation of the organic contaminants present
in the lagoon area, stream sediments, and the scraped area
(13,460 cubic yards).
The treatment bed will be installed overlying the area of
the existing landfill for Alternative SA. This will allow the
treatment bed to also act as a RCRA equivalent c~p for the .
landfill. The solidification of the inorganic hot spots (425
cubic yards) would have to be conducted first and s~~idified
waste placed in the landfill prior to capping. Ai~~a~ive 8B
will be the same as Alternative SA, except that the
bioremediation treatment bed will not be located over the
landfill, although it will be placed within the associated area
of contamination. A RCRA equivalent cap will b~ placed over the
landfill. Bioremediation of the lagoon area, s.diments, and
organic hot spots from the scraped area will be conducted as
described in Alternative 4. Solidifica~on of the inorganic hot
spots will be conducted as described in Xlternative 7A/7B. Deed
restrictions would be necessary to prevent construction on the
capped area and to prevent development of a residential area on
site.
24
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~
IX.
COKPARATIVB ANALYSIS OP ALTERNATIVES
The eiqht remedial action alternatives described above were
evaluated usinq the followinq nine evaluation criteria presented
in "Guidance for Conductinq Remedial Investiqations and
Feasibility studies Under CERCLA" (EPA, October 1988) and EPA
Directive 9355,3-02, "Draft Guidance on Preparinq Superfund
Decision Documents: The Proposed Plan and Record of Decision."
These nine criteria can be further cateqorized into three qroups:
threshold criteria, primary balancinq criteria, and modifyinq
criteria.
Threshold criteria
-Overall protection of human health and the environment
-Compliance with applicable or relevant and appropriate
requirements
primarv Balancina criteria
-Reduction of toxicity, mobility,
-Implementability
-Short-term effectiveness
-Lonq-term effectiveness
-Cost
or volume
Modifvina Criteria
-Community acceptance
-State acceptance
These evaluation criteria relate directly/to requirements in
section 121 of CERCLA which measure the overall teasibility and
acceptability of the remedy. Threshold criteria 'must be
safisfied in order for a remedy to be eliqiDle fot s~lection.
Primary balancinq criteria are used to weiqh majorWtrade-offs
between remedies. State and community acceptance are modifyinq
criteria formally taken into account after public comment is
received on the Proposed Plan. The evaluations are as follows:
-
25
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1) Protection of Human Health and the Environment
A primary requirement of CERCLA is that the selected
remedial action be protective of human health and the
environment. A remedy is protective if it reduces current and
potential risks to acceptable levels posed by each exposure
pathway at the site.
~l Washing. Bioremediation. Incineration. Solidification
Remedies employing soil washing, bioremediation, and incineration
of soils and sediments (Alternatives 3, 4, 5A and 5B) would
provide the greatest degree of protection of human health and the
environment because of the elimination of contaminants from these
media. Both organic and inorganic contaminants would be
permanently treated to risk-based cleanup levels. Public and
environmental risks from direct soil contact and ingestion would
be mitigated. Excavation and treatment activities may present
short-term public health risks from dust and/or airborne volatile
organic. These risks would be evaluated by air monitoring and
addressed appropriately. To minimize long-term risks, deed
restrictions will be necessary to prevent residential
construction.
Combined containment (Landfill CaDDina) and Treatment
Alternatives 6, 7, and 8, which use landfill capping in
addition to a treatment technology as a component of the remedial
action, also provide a high degree of protection. Migration of
contaminants and direct exposure to soils and sediments would be
mitigated. Both organic and inorganic contaminants outside the
landfill area would be treated to risk-based c1eanup levels as
previously discussed. Deed restrictions will be
-------
""
2) .ComDliance with ADDlicable or Relevant and ADDroDriate
Reauirements . .
Section 121(d) of CERCLA requires that remedial actions at
CERCLA sites at least attain legally aDDlicable or relevant and
aDDrocriate Federal and State standards, requirements, criteria,
and limitations (which are collectively referred to as "ARARs").
ADclicable requirements (requirements which must be satisfied
unless one of CERCLA's waiver provisions is justified) are those
substantive environmental protection requirements, criteria, or
limitations promulgated under Federal or State law that
specifically address hazardous materials found at the site, the.
remedial action to be implemented at the site, the location of
the site, or other circumstances at present at the site.
Relevant and aDDrocriate requirements are those substantive
environmental protection requirements, criteria, or limitations
promulgated under Federal or State law which, while not
aDDlicable to the hazardous materials found at the site, the
remedial action itself, the site location, or other circumstances
at the site, nevertheless address problems or situations
sufficiently similar to those encountered at the site that their
use is well-suited to that site.
The ARARs and other non-promulgated advisori~s and guidances
issued by Federal and State governments ("To-Be-Considered") or
"TBCs") for the Preferred Remedial Action and Contingency
Remedial Action are discussed below. Table 5 provides a list of
potential ARARS and TBCs considered for each alternative
reviewed.
Resource c~nservation and Recoverv Act ("RCRAn)
RCRA regulates the generation, transportation, treatment,
storage~ and disposal of hazardous wastes. Haza;dous substances,
pollutants, and contaminants found at CERCLA sit~s are hazardous
wastes potentially triggering RCRA requirements oply ~f they are
RCRA-listed wastes (40 C.F.R. Part 261, Subpart Dt~or i£such
substances exhibit certain physical characteristics (40 C.F.R.
Part 261, Subpart C). EPA has determined that the contaminated
soils and sedi~ents found at Operable Unit No.1 of the Ordnance
Works site are neither RCRA-listedwastes nor characteristic
wastes and that, as a result, RCRA requirementsAare not legally
applicable. Portions of RCRA may nevertheless be relevant and
appropriate and are further discussed below.
a, h.
RCRA Subtitle C Closure Reauirements
Excavation, consolidation, and other similar actions that
move RCRA hazardous wastes so as to constitute disposal of such
wastes will trigger closure requirements for the unit into which
27
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""...
the wastes are placed. RCRA closure requirements may be
sat,isfied by implementing clean closure (under which all
hazardous wastes and 'residues and contaminated system components,
soils, structures, and equipment are removed or decontaminated)
or discosal or landfill closure (under which hazardous wastes are
covered with a RCRA cap and the site subjected to post-closure
care and maintenance). Under several alternatives considered for
implementation at Operable Unit No.1, contaminants exceeding
risk-based cleanup levels established in this ROD will remain
onsite. EPA has reviewed records supplied by companies that
operated at the site and found no evidence that RCRA listed
hazardous waste was disposed at Operable Unit No.1. In
addition, the hazardous constitutents and concentrations detected
at Operable Unit No.1 are not indicative of the levels found in
RCRA hazardous waste. Therefore, EPA has determined that such
contaminants are not RCRA hazardous wastes and that, as a result,
RCRA requirements are not legally applicable. EPA nevertheless
concludes that the RCRA closure requirements are relevant and
appropriate to the former landfill because wastes that are
generally similar to listed wastes (and which may have been,
generated from manufacturing operations at the site) will (under
Alternatives 1, 2, 6, 7, and 8) remain at this location in
concentrations above the cleanup levels established in this ROD.
Accordingly, a RCRA-type cap will be used for the landfill for
such alternatives. Groundwater monitoring is not expected to be
extensive, however, as groundwater is not a primary contaminant
migration pathway. Deed restrictions preventing residential
development will also be employed since areas outside the
landfill will neither be completely decontaminated (though they
will be remediated to within the selected cleanup levels
established for an industrial-use scenario) nor capped.
Land Discosal Restrictions
The 1984 amendments to RCRA establish sched~les for
promulgation of regulations restricting land disposal of
hazardous wastes. The statute and land disposal ~es~rictions
promulgated thereunder are not applicable in this rn~t~rtee
because none of the contaminants found at Operable Unit No.1 are
RCRA hazardous wastes. If, after treatment, 'the waste exhibits
hazardous characteristics, the residuals will be managed in
accordance witb,.hazardous waste requirements undj!r Subtitle"C of
RCRA. Treatment standards for characteristic w~te will be
established in May 1990. If treatment standards'lcan not be met,
a treatability variance will be consider,~
Clean Water Act
The Clean Water Act requires a National Pollutant Discharge
Elimination System (NPDES) permit for any discharge from a point
source to navigable waters of the United States. The Clean Water
Act also requires that any discharge to a publically owned
:3
-------
treatment works (POTW) meet Federal pretreatment standards. The
We~t Virginia Department of Natural Resources has adopted water'
quality regulations for the Monongahela River. '
None of the alternatives evaluated in this ROD involve
discharges to the Monongahela River, and, accordingly, Clean
Water Act NPDES regulations and West Virginia water quality
regulations are not ARARs. Alternatives 3,4,SA/5B, and 6
(involving soil washing) would generate a wastewater stream that
would be treated onsite. The treated water would be used for
dust control, and any excess treated wastewater would be
. discharged to the Morgantown Municipal treatment plant via the
sanitary sewer at the Ordnance Works site. Any excess water
generated from the bioremediation process (Alternatives 8A and,
8B) w01,lld also be discharged to the Morgantown Municipal plant.
Federal pretreatment requirements governing such discharges must,
under such circumstances, be satisfied.
Clean Air Act
West Virainia Air Pollution Control Reaulations
The Federal Clean Air Act and West Virginia Air Pollution
Control Regulations identify and regulate pollutants that could
possibly be released during the course of remediation. For
alternatives involving excavation of soils and sediments
(Alternatives 3,4,5A/5B,6,7A/7B, and 8A/SB, air monitoring will
be required to ensure compliance with Federal and state air
emission regulations.
OccuDational Safetv and Health Administration Act (OSHA)
During remedial action a health and safety program for
onsite workers will be implemented to comply with OSHA
requirements.
criteria for Offsite Disposal
,
Alternatives involving soil washing wiil ge~~ate, a
concentrated liquid organic residue waste to be dispose~of by
offsite incineration. Offsite disposal will be performed in
accordance with the requirements of EPA's Offsite Policy, which
prohibits the use of a facility that has siqnific~nt outstanding
Class I violations under RCRA. All vehicles us~d for
transportation from the site will be properly labeled in
accordance with Department of Transportation (DOT) regulations
and decontaminated before leaving the si~! to prevent residual
contaminants from being transported offsite.
Protection of Wetlands
Executive Order 11990, Protection of Wetlands (40 CFR Part
6, Appendix A) requires Federal agencies conducting remedial
29
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activities to minimize adverse impacts to wetlands. No wetlands
have been identified alonqstream banks on the site. Any .
wetlands identified!onsite in other areas will be restored to
existinq conditions. .
criteria. Advisories. or Guidance To Be Considered
Risk-based cleanup levels in Table 4 in this ROD were
developed usinq the followinq advisory levels and quidelines that
are "to be considered" (TBC):
-EPA-established action level of 500 mq/kq for lead.
-EPA-established Reference Doses (RfDs) used to develop risk-
based c~eanup levels for cadmium and copper.
-EPA-Carcinoqenic Potency Factors to develop risk-based cleanup
levels for arsenic and CPAHs.
30
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~
.-
TAP.LE 5
ooa....TATION Of AIIA88
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3) ReductioD of Tox~itv. MOb!1jtv. or Volume
This evaluation criteria addresses the deqree to which a
technology or remedial alternative reduces toxicity, mobility, or
volume of hazardous substance. Section 121(b) of CERCLA
establishes a preference for remedial actions that permanently
and siqnificantly reduce the toxicity, mobility, or volume of
hazardous contaminants over remedial actions which will not
result in such reductions.
Soil Washina. Bioremediation. Incineration. Solidification
Incineration and soil washinq (Alternatives SA and 5B)
provide, the qreatest deqree of permanent reduction of toxicity
and mobility of contaminated soil and sediments. Incineration
will achieve qreater than 99 percent reduction of contaminant
levels: soil washinq will achieve 95 percent reduction of orqanic
contaminants, and the inorqanics will be removed as soluble
constituents. Bioremediation is expected to reduce orqanic .
contaminants in soils and sediments 65 to 95 per cent each year
that the bioremediation process is operated. Solidification of
inorganic hot spots would completely immobilize the waste as a
solid cement product.
Combined containment (Landfill CaDcina) and Treatment
The combined containment/treatment remedies which propose
both cappinq and treatment technoloqies (Alternatives 6, 7A,7B,
and 8) reduce mobility but provide less reduction of toxicity
than those alternatives featurinq treatment alone. These
containment/treat~ent alternatives satisfy the CERCLA preference
for use of a permanent remedy since treatment will be a principal
element of the remedies and will be applied to remediate those
portions of the operable unit (laqoon area and sc~aped area) with
hiqhest concentrations of CPAHs and inorqani~ metals. .
No action and Containment
, .
\...r.4 ','to...
Both the no action alternative (Alternative 1) and in-place
containment by cappinq (Alternative 2) are remedia~ actions that
do not use treatment technoloqies. The toxicity, mobility, and
volume of the contaminants would not be reduced since the
physical, chemical, or bioloqical characteristic~ of the waste is
not altered throuqh treatment.
38
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4) IaDl...ntabilitv
Implementability refers to the technical and administrative
feasibility of' a remedy, from design through construction,
operation, and maintenance.
Soil Washina. Bioremediation. Incineration. Solidification
Implementation of any of these treatment technologies is not
expected to present any major problems in terms of equipment
skilled labor, or operation and maintenance. All are feasibie
technologies. The availability of treatment, storage, and
disposal services is not expected to hinder implementation of any
of those technologies. Because of the large quantity of debris'
within.the landfill, permanent treatment of the contents of the
landfill would be difficult to implement and is not considered
feasible for this site. These concerns would make implementation
of Alternatives 3, 4, SA, and 5B non-feasible.
Bioremediation is the easiest technology to implement. The
equipment used to rototill the soils is commercially available
farm equipment, and specialists will not be required to operate
the system on a continuous basis. The treatment bed can be
constructed within the Operable unit and no offsite disposal
services are required. Bioremediation has been demonstrated in
laboratory and field pilot scale operations and has been proposed
for at least a dozen other Superfund sites contaminated with
wastes similar to those found at the Ordnance Works.
Treatability studies will be necessary to establish final design
requirements. The time required to complete bioremediation would
be at least three years longer than other treatment technologies
and is dependent on the rate at which bioremediation occurs.
Soil washing is also considered feasible to implement and is
based on a treatment process used successfully I for many years in
the chemical manufacturing industry. Soil washi~g in this
instance would utilize a commercially available proprietary
solvent extraction process which would require th, assistance of
specialists provided by the vendor. At least one known"''''
commercial soil washing process cannot handle solids greater
than one-inch in size, requiring that contaminated soils be
screened to segregate larger particles. The expe~ted small
quantity of screened material would be disposed;offsite at a RCRA
landfill (assuming the waste is not EP toxic). Treatability
studies will be necessary to establish final de~ign requirements.
Soil washing has been implemented and ef~@ctively operated at the
General Refining Superfund site in Garden City, Georgia.
Incineration is a relatively complex technology but has been
successfully implemented at other Superfund sites. Both onsite
and offsite incineration capacity is adequate to treat the volume
of soils at Ordnance Works. Offsite incineration would require
39
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transportation to an out-of-state incineration facility. The
eff~ct of incineration on catalyst pellets found throughout the
site are unknown. The pellets do not presently leach heavy
metals, but post-incineration testing would be required to
determine if .the ash exhibited hazardous characteristics. A
trial burn to determine if treatment standards under RCRA would
be met would also be required before the remedy is implemented.
Caccing
The technologies proposed for capping, excavation, grading,
and surface-water diversion are all well-demonstrated. Long-term
site monitoring is proposed, and deed restrictions preventing
future construction on top of the capped area would be required.
Maintaining a multi-media cap is not anticipated to be a major
concern. Landfill capping and any of the permanent treatment
technologies may be implemented simultaneously, but inorganic hot
spots must be solidified and placed in the landfill before it is
capped as described in Alternative 8A and 8B.
5) Sbort-Tera Effectiveness
Short-term effectiveness addresses the period of time needed
to achieve protection of human health and the environment and any
adverse impacts that may be posed during the construction and
operation period until cleanup goals are achieved.
The no action alternative (Alternative 1) can be implemented
in the shortest period of time since no construction activities
are required, but provides no protection of the environment.
Alternatives involving excavation and subsequent management of
contaminated. soils through treatment would present the greatest
opportunity for exposure to contaminants by onsite workers.
Protective measures including use of protective qlothing for site
workers, dust control, and air monitoring w~ll minimize the
impact to site workers and the surrounding commun~bY~ '.
,. I '.'..
Soil Washina. Bioremediation. Incinerator. Solidification
Alternatives 3, 5B, 6, and 7B will require approximately 2.5
years to complete. Alternatives SA and 7A will ~e completed in
2.5 to 3.5 years (additional time is required for an incinerator
test burn). Alternatives 4 and 8, involving bioremediation, will
take at least 5.5 years to implement. T~$e time frames include
predesign, design, and construction activities.
Alternatives involving soil washing of the landfill
(Alternatives 3, 4, SA and 5B) will require greater time to
implement because of large quantities of debris and metal buried
in the landfill that must be removed and screened before soil
washing.
40
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Bioremediation (Alternatives 4, 8A and 8B) implementation'
time is largely imp~cted by the time required to biodegrade the-
polynuclear aromatic hydrocarbons (PAHs). It will take about 4
years if the initial concentration is 4000 mg/kg and only 1 year
if the initial concentration is 500 mg/kg. A CPAH concentration
of 500 mg/kg or less is typical of that found at the Ordnance
Works. During the implementation period the treated soil would
be kept wet (minimizing dust), workers would wear Level C
protective clothing, and perimeter air monitoring would be used
to measure air emission. A lined treatment bed would minimize
migration of contaminants during implementation.
Alternatives SA and 7A, involving onsite incineration,
provide the potential for the greatest risk of air pollution
through incinerator stack emissions. However, this concern is
expected to be mitigated effectively by typical air pollution
equipment. All alternatives that require offsite transport of
contaminated material (Alternatives 3, 4, SA, 5B, 6, and 7B) also
pose the potential for adverse exposure to the community. This
concern is also expected to be mitigated, barring any unusual
circumstances, by normal operating procedures that are applied to
the transport of hazardous material.
Landfill Caccina
Capping of the landfill or other contaminated areas of the
site will be reliable in the short-term and construction should
be completed within three months. As with the other
alternatives, workers will wear Level C protective equipment and
perimeter air monitoring will be employed during excavation and
construction activities.
6) Lona-Term Effectiveness and Permanence
,
Long-term effectiveness and permanence addresses the long-
term protection of human health and the environme~b~9.Dge cleanup
goals have been achieved, and focuses on residual risk 'that will
remain after completion of the remedial acti~n.
No Action and Containment
Alternative 1 (no action) does not'provide\ong-term
effectiveness and permanence as contaminants will neither be
eliminated through treatment nor contain.~ in any fashion.
Implementation of this alternative, without more, may eventually
allow ground water to become contaminated. No protection of
human health and the environment will be provided with this
remedy. Alternative 2, in-place containment using a cap for the
entire site, provides a low degree of long-term effectiveness,
permanence, and risk reduction since wastes will be contained.
41
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Frequent inspection and maintenance of the cap would be required,
including mowing and repair. Long-term ground water monitoring."
would be necessary to verify that ground water is not
contaminated by wastes left in place. Deed restrictions would be
necessary to prevent disturbance of the cap.
Soil Washing. Bioremediation. Incineration. and Solidification
Alternatives 3, 4, and 5B provide the greatest degree of long-
term effectiveness as contaminants are eliminated and long-term
operation and maintenance is minimized. While Alternative 5A
(onsite incineration and disposal) may also provide a high degree
of long-term effectiveness, the effects of incineration on the'
catalyst pellets located throughout the operable unit will have
to be determined.
Alternatives 6,7A,7B and 8 will permanently reduce the
toxicity of contaminated soils/sediments left onsite to risk-
based cleanup levels. contaminated soi1s associated with the
landfill will remain onsite, however, and will require long-term
monitoring and maintenance. These alternatives can provide a
long-term effectiveness and minimize future exposure to
contaminants if deed restrictions are implemented and enforced.
7) Cost
CERCLA requires selection of a cost-effective remedy (not
merely the lowest cost) that protects human health and the
environment and meets other requirements of the statute. Project
cost includes all construction and operation and maintenance
costs incurred over the life of the project. An analysis of the
present worth value of these costs has been completed for each
alternative described in this Record of Decision, and is
summarized in Table 6. Capital costs include th~se expenditures
necessary to implement a remedial action. ~riual operating costs
are included in the present worth cost. '\.;,., '" '''0(
The costs of the eight alternatives range from 3.0 million
to 44.1 million dollars. The degree of protection provided by
the alternatives also varies. Comparison of diff~rent levels of
costs for different levels of protectiveness an~ permanence of
treatment is a primary decision criteria in the cost-
effectiveness evaluation.'
.--
Alternatives 1 and 2, although lowest in cost, are less
protective and do not provide permanent treatment as do other
alternatives, and are therefore not considered cost effective.
Alternatives 6 and 8 are next lowest in cost, at 9.3 million and
8.3 million dollars respectively, and provide 95 percent removal
of contaminants treated. The remaining alternatives would
increase cost by at least 100 percent with only marginal
42
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TABLE 6
Summary of Remedial Action Alternatives Cost and Implementation Times
Remedial Action
Ai ternathe
(Implementation Time)
Capital Cosu. $
O&K Coat. $
Present
Worth Cost.$
....
1- No Action 144.000 185.600 3,053,000
(3 month.)
2-Capping 3,230.000 92,800 4,713,000
(1.3 years)
3-Soil Wa.hing 17,308,000 -0- 17,308,000
(2.6 Years)
4-Soil Washing &
Bioreaediation
(5.3 to 10.3 years) 16,124,000 -0- 16,124,000
SA-Soil Washing & 28,590,000 -0- 28,590,000
Onaite Incineration
(3.5 years)
5B-Soi1 Washing & 44,167,000 -0- 44,167,000
Offsite Incineration
(3 years)
6-Soi1 Washing & 7,982,000 88,200 ' 9,393,000
Landfill Capping
(2.5 years) \ '''I:';,
I '!'..-
7A-Onsite Incineration 19,810,000 88,200 21,221,000
& Landfill Capping
(2.75 years)
-
7B-Offsite Incineration 36,155,000 88,200 ) 37,562,000
& Landfill Capping
(2 years) a,~,
8A-Bioreaediation and 6,686,000 88,200 8,058,000
Landfill Capping,
(4.5 to 9.5 years)
8B-Bioreaediation and 6,960,000 88,200 8,332,000
Landfill Capping
(4.75 to 9.75 years)
-------
increases in the level of protection provided. Alternatives
inv.olving incineration, for example, range in cost from 21.2"
million to 44.1 million dollars. Considering the cost and
relatively high degree of protectiveness compared with other
alternatives. Alternatives 6 and 8 are are considered to be the
most cost-effective.
8) Community Acceotanc.
A public meeting on the proposed plan was held July 12, 1989
in Morgantown, West Virginia. Comments received from the public
at that meeting are referenced in the Responsiveness Summary
attached to this Record of Decision.
9) stat. Acc.otanc.
The State of West Virginia has concurred with the selection
of the Preferred Remedial Action and contingency Remedial Action.
x.
THE SBLECTBD REMEDY
EPA has selected, and the State of West Virginia has
concurred in the selection of, a Preferred Remedial Action and
contingency Remedial Action for implementation at Operable Unit
No.1 of the Ordnance Works Disposal Areas site. Both remedies
are protective of human health and the environment, are cost-
effective, can meet or exceed ARARs, and utilize treatment
technologies to the maximum extent practicable. The preferred
and contingency remedies are summarized as follows:
Preferred Remedial Action--Alternative 8B--Soils and sediments
with organic contaminants from the lagoon area,' scraped area, and
streams will be excavated and treated via biorem.diation;
inorganic hot spots will be excavated and the soils solidified
and consolidated into the landfill; the landfill ~~l ~~ capped.
~
Contingencv Remedial Action--Alternative 6--Soils and sediments
from the lagoon area, scraped area, and streams will be excavated
and treated vi~ soil washing; the landfill will ~e capped.
EPA has selected Alternative 8B over Alterlative 6 as the
Preferred Remedial Action because Alternative 8B'is more cost-
effective than Alternative 6. While EPAa~s determined that both
alternatives are, in theory, comparable in remediatinq
contamination at Operable Unit No.1 and in reducing risks
associated with exposure to such contamination, the Agency
recognizes that there are circumstances under which, in practice,
Alternative 6 might provide a better balance among the nine
Superfund remedy selection criteria. Accordingly, EPA has
43
-------
selected 6 as a Contingency Remedial Action to be implemented at
Operable Unit No. ~ under the following circumstances: ' .
1) Design studies show that treatment levels in the ROD can not
be achieved within a reasonable time frame (such as approximately
five years or less); or
2) Responsible parties elect to design, implement, and finance
Alternative 6 at Operable Unit No.1; or
3) Information received during the bidding process suggests that
the costs of implementing Alternative SB are significantly higher
than originally estimated (such as approximately 50 percent or'
greater).
The remediation goals are to (1) contain wastes in the
landfill area by construction of a RCRA-type cap over the
landfill that will reduce the threat of migration of
contaminants, and (2) provide treatment of contaminated soils and
sediments in the scraped area, former lagoon area, and streams'
(drainage ditches) that transect the study area. Cleanup goals
for carcinogens (CPAHs and arsenic) are based on a 1 x 10-6
cancer risk level for a future exposure scenario of construction
workers at the site following remediation. In addition, because
Alternative 6 uses soil washing and Alternative SB uses
bioremediation to eliminate the principal threat at the site,
each remedy satisfies CERCLA's preference for remedies which
utilize treatment as their principal element to reduce toxicity,
mobility, or volume.
The flow charts in Figures 2 and 3 provide an illustration
of the details of each remedy. Both the Preferred Remedial
Action and the Contingency Remedial Action contemplate
construction of a multi-media RCRA-type cap orl the landfill. The
cap will be approximately 65,000 square feet in,~ize and will be
designed to eliminate contaminant migratio~ and will minimize
risks associated with ingestion and dermal contaq~/~i~~ landfill
soils. Deed restrictions will be necessary to prevent tuture
development of the landfill area. EPA has concluded that
treatment of soils within the landfill using incineration, soil
washing, or bioremediation techniques is impractical because of
the presence of large amounts of metal,and de~~s w~ich would
have to be screened and removed from those s011s pr10r to
treatment. I
44
-------
ORGANIC Rt:SIOU£
TO 11£ INaNOIA 1£0 AT
AN OffSiK RCRA fACIlIIY
t
CAP lNIIIfU. TRUT
8tH A 61.000 SO n CONTAMlNATm SOI.S
.... IWDIA CAP, .-at .GIIAO( AND (XCAVAI( SJJCfAM USING SOl. WASHING IIAOCIIt l Rl..LDlA 1(0
II„.l ....Z£ IoIGRA nON IfWGnATE S£OIWt.NT~ EQtJPU£HT 8tH A ~lS ~ [XCAVAIED
Of CON T,....,.,. TS AND CAI'ND SCRAPED AAU. AND 100 QJ m/'OAY AHLAS. II(GRADf. '
POJDnlAl INCfSnoN 011 AMA fOAwOt LAGOON III„.A CAPAaTY (BAS( CAS() AND RtIot:G£lAK
IIt:AWAl CONTACT Of ' OM A lSO CO mft)AY AHEA
CONTMl8tAD SOI.S CAPAOJY (IIIOfIST CAS()
. 13.185 OJ YO BAS( CAS( I '-
. I..QHG- TfIY OIIM . 24.~26 OJ YO WOItST CAS(
- CI# "'lDcatTY
- C;W -.oM TOII8IG Ua.SS WA TEN 10 II(
hlU KD ON SIll AND
. DUD'lI($mJC'nONS USt:O fOM
OUST CONTROl
. 10lAl 1161(01110 noN
1.. 2.~ YUHI>
~
\Jt
. t:p IOIllClTY ltS...G
....5T II( ~TtO
TO Iot:IIIfY THA T
8tORGNlCS III„.
I108:OIA 1m.
. SOl. WASHING ~
ACMO£ A 1810'" "$1(
. .ASlIN
NaOIT-IIIOfIT" COSTS - '''.J''J.OOO
FIGURE 2
-------
~
(7\
DCAI/AI( II08GNIC SCIIJIIf1CA 11(11 Of f'lAU 5B.DflfD CON:> IItUCI A
HOT 51'01$"" ~ MASS IH lAHIIfU I CAP lNIDflU. I J60.000 50 n
I.AGOON lIMA HOT 8'01$ TO I'IIOWI IRU IW'" IIU)
(t.S QI 'iI) (.u Q.I WI) f\JItfHPt NOTrcflOH I IIIIH A .~.OOO SO n I '0
AHO SCJIN'O AMA '0 II(JIUa AGA8fS' CON'M8INI' WIJl1lUE0IA CA#. CONOUC r
(.)10 QI 'III) IilCaJtY MlQtA lION IIIOII£W iliA lION
' .
.~ J(Itw GIN
- ClIP IHItCRIIY
- CW -'OIIIHC
. DUO II(STlllCfIONS
.""U -A fIOH Of
CONY_IS AND
IIQ.SfION 011 P(IIMAI.
CON'AC' Of
c:aH1-An:D $O&.S
.CIIICUt.A It: WA 'U '0
NMI'AIN MOISJUIIf CQN1I:N'
DCAVA1( I'tAC[ £llCAI/A1m SOIlS IIIU ..
AI'PI8C»IIIA 1n Y IG&S II _A""" UCAVAItD '--"AU.Y R(Io\Gt IAI(
.. JCII QI 'to KD ... AND 1'lAC(0 IH IIth-IWtHI
Of tCIO QI 'III Of IHf JRfAMM' 81.0
CDlTMl8lA1ID MANUM AIC) ... .0 '0.
IGU IiCIL SQI-MDNIHI. Y 1IOII68(0IA f(D I
.5OD Q.I 'Ie .... SWAM .CDl1tNU£ to [XCAVA1( . '0' AI. IIOIWIA TION 1IW(
I. I. NID J IiClLS .... lAGOON .., TO ..5 '11:""5, IIO't:NDItIC
.31110 QI . \80' ~ ell ~ (1100 Q.I .~) Cft VOUIWI: AIC) CONCOI1IIA lION
JIDD QI 'iI _T ) f8CIM UN" AU. SOLS Of c:aHT_A1(D SOL
sc:aAND .. ,. .wOtAtrD. . A' COW't£1ION Of
.,400 QI '8 ~ .110 QI WI . . CiIIW'lE1WIN ...: taL IIOII£MCOIA 110M, SClLS
.... ~ Il1O - OUSS IlAIfJI ..... nID ~ fClt II 1R[A!WIt, 1m
' (8ASI CA5f VOUIWI:) AIC) taL ~ A
f 10 t.OCJIl fou. 'll:AIIS (..sf CA5f , . 10' ...
f'OIW 100....) ... fI. AU. . 8A5£UN(
fell 1IIL\"'" CCft'M8IAQ SOI..S AlII "'5OIT-"1H COSIS - ".JJ2.0u0
.. JII£A 'IUUfT KD.
. "
. (AQf SCIL III IIIU I(
MWIllA1(O 8fJIUN 1 10 .
'11:""5, IIUI:""" ON
COIICfIIIb 1ION
-
r.
~
FIGURE 3
-------
Alternative 8B!, ,the Preferred Remedial Action, contemplates
excavation of soils and sediments in the lagoon area, scraped
area, and streams for treatment using bioremediation. Treatment
may be conducted in a lined treatment bed as described in the
Focused Feasibility study, or, alternatively, in an unlined
treatment bed if, under this option, no leaching of excess water
through the treatment bed will occur (one purpose of the bed
liner is to collect any excess water and recirculate the water
back to the treatment bed). Alternative 8B will locate the
treatment bed within the area of contamination but in a location
other than atop the landfill. EPA has selected Alternative 8B
over Alternative 8A (treatment bed atop the landfill) because of
the possibility of uneven settlement of the landfill and the
possibility that the conduct of bioremediation a~tivities on top
of the cap may puncture the liner. Alternative 8B will require
site preparation and grading prior to installation of the cap and
treatment bed.
The inorganic hot spots (i.e., areas with high metal
concentrations considered inhibitory to the bioremediation
process and exceeding cleanup levels) from the scraped area (360
cubic yards) and the lagoon area (65 cubic yards) will be
excavated and solidified and placed in the landfill before the
landfill is capped.
Initially, approximately one-half of the contaminated soils
and sediments will be placed in the bioremediation treatment bed.
Manure or similar material will be added to provide sufficient
nutrients for biological treatment. The bed will be rototilled
periodically to mix the bed contents and to aerate the mixture to
accelerate the biological treatment process. The treatment bed
will be spray irrigated as necessary to maintain optimum moisture
content. Additional untreated soil and nutrients will be added
as biodegration proceeds and CPAH levels are redu~ed. Following
treatment, the treatment bed containing remediated soils will
remain in place and be revegetated. Excavated ar~,,~~ll be
backfilled with clean soil and revegetated as the projec~
proceeds.
Total tim~ for completion of the bioremediati~n component of
the Preferred Remedial Action is in the range of'5.5 years,
depending on the time required to biodeqrade thetCPAHS present in
the soil. Bioremediation has been proposed as a 'treatment
technology at several other Superfund si~~! and has been
successfully demonstrated at the Burlington Northern Superfund
site in Brainerd, Minnesota. A 65 to 95 percent reduction of
contaminants is anticipated for each year the bioremediation
process is operated.
47
-------
Alternative 6" the Contingency Remedial Action, involve"s
excavation of approximately 16,700 cubic yards of sediments and
soils from the lagoon area, scraped area, and streams and
treatment of these soils/sediments using soil washing techniques.
Soil washing will be completed in 170 working days based on using
equipment with a 100 cubic yard per day capacity. The remedial
action, exclusive of operation and maintenance for the cap, will
be completed in 2.5 years. A 95 percent reduction in
contaminants is anticipated.
Soil washing is a commercially available treatment process
that has been successfully demonstrated at the General Refining"
Superfund site in Garden City, Georgia. Equipment will be
mounted on a concrete pad within the area of contamination for
operation. Treated soils will be returned to excavated areas
after verification by EP toxicity testing that the treated
material is not hazardous. The area would then be regraded and
vegetated. "
Any wetlands identified onsite will be restored to existing
conditions, including original grade and drainage patterns, and
revegetated with suitable indigenous species. Therefore, "the
remedial action is not expected to impact the functional value of
the area. The actual extent of potential wetlands affected by
remediation will be determined during the remedial design phase.
Oceration and Maintenance
Both the Preferred Remedial Action and Contingency Remedial
Action require operation and maintenance (O&M) of the landfill
cap and vegetative cover for areas outside the landfill.
Operation of a limited groundwater monitoring program is needed
to identify potential groundwater release from/the landfill, and
short-term environmental monitoring (bioassays) ~ill be conducted
to measure the effectiveness of remediation of surface water and
sediments. An O&M plan will be developed arid imp~em~nted which
provides a schedule and description of maintenance~actlV1ties.
Groundwater monitoring will be conducted for an initial
period of five years following installation of the landfill cap.
During this period sampling and analysis data w;1i be reviewed to
determine wheth~r the remedy provides adequate ~rotection of
human health and the environment. Groundwater monitoring will be
discontinued if groundwater contaminati0P-r~s not detected at the
end of the five year period. More extens1ve groundwater
monitoring is unnecessary since groundwater is not a primary
contaminant migration pathway.
48
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%1. , RATIONAL!: J'OR REMEDY SELECTION
This analysis focuses on EPA's rationale tor selecting both
the Preferred Remedial Action and Contingency Remedial Action
over other alternatives, using as a basis the Superfund
evaluation criteria. A ~omparison between alternatives follows.
Alternative 1:
No Action with Site Control
Alternative 1 does not achieve threshold criteria for
adequate protection of human health and the environment, and does
not comply with applicable or relevant and appropriate federal
and state standards, requirements, criteria, or limitations.
Current and future environmental risks would still exist from
site runoff and access to the site by wildlife. Cleanup levels
based on EPA guidance and criteria would not be met since
contaminants would receive no treatment. The no action
alternative would not permanently and significantly reduce the
volume, toxicity, or mobility of hazardous waste at the site, and
does not utilize permanent treatment technologies to the maximum
extent practicable as mandated by CERCLA. The Preferred Remedial
Action and Contingency Remedial Action satisfy all of the above
criteria.
Alternative 2:
CaDDina all Areas
Alternative 2 includes installation of RCRA cap over
contaminated areas not meeting recommended cleanup criteria.
Alternative 2 does not permanently and significantly reduce the
volume, toxicity, or mobility of hazardous waste at the site, and
does not utilize permanent treatment technologies to the maximum
extent practicable. Containment using a cap tor the entire site
provides a low degree ot protection of human h~alth and the
environment, permanence, and long-term effectiveness since wastes
will be contained. Alternative 2 will not afford:the high level
of long-term protection provided by Alternatives 88. and 6, both
of which utilize permanent treatment remedies. '\...,;0. ". 'Po(
Alternative 3:
Soil Washina (All Areas)
Alternati~e 3 involves soil washing of all,contaminated
areas, including the landfill. EPA ha~ determi.ed that treatment
of the soil within the landfill using soil washing (or
bioremediation or incineration) is impractical and cannot
reasonably be implemented because otthe-presence of large
amounts of metal and debris which would have to be screened and
removed from the soil prior to treatment.
49
-------
Alternative 4: Soil Washina (Landfill and Inoraanic Hot SDotS)-
and Bioremediation (Laaoon Area. Sediments. and Oraanic Hot
SDotS)
As with Alternative 3, Alternative
of the landfill and is also impractical
of metal and debris which would have to
from the landfill prior to treatment.
Alternative SA and 5B: Soil Washina (Landfill) and Onsite
Incineration (SA) or Offsite Incineration (5B). and
4 involves soil washing
because of the presence
be screened and removed
Alternative 7A and 7B: CaDDina (Landfill) and Onsite
Incineration (7A) or Offsite Incineration (7B)
Alternatives 5 and 7 are considered together for purposes of
this analysis because both alternatives use incineration as a
treatment technique for the lagoon area, sediments, and scraped
area. The Preferred Remedial Action and Contingency Remedial
Action have been selected over alternatives employing thermal
treatment because (1) incineration is significantly more
expensive to implement than the other treatment technologies to
be applied in these areas, but will not achieve a correspondingly
higher reduction of contaminants, and (2) there are waste
management and cost uncertainties associated with alternatives
employing incineration because of the possibility that the
resulting ash may exhibit hazardous waste characteristics.
The cost of Alternatives SA and 7A (onsite incineration) is
about three times the cost of Alternative 6 or 8B, while the cost
of Alternatives 58 and 7B (offsite incineration) is five times
the cost of Alternatives 6 or 8B. IncineratiQn achieves only a
marginal increase in contaminant reduction over ~oil washing and
bioremediation (99' or greater reduction with iricineration
compared to 95' reduction with soil washinq or bioremediation).
As mentioned earlier, ashes resulting from the ined.era~ion .
process would have to be examined to determine whether they
exhibited hazardous characteristics. Ashes exhibiting such
characteristics would have to be managed as hazardous wastes and
would, as a result, increase costs. There is a, significant
possibility that ashes would in fact be hazardoUs because of the
presence of numerous "pellets" containing inorg,nic metals in the
soils at the site. .
a--
In addition, Alternatives SA and 5B contemplate soil washing
of the landfill as described in Alternative 3. As mentioned
earlier, soil washing of the landfill contents is not technically
feasible or implementable because of the large amount of debris
and metal in the landfill that would have to be removed prior to
soil washing.
50
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XII.
STATUTORY DETERMINATIONS
Both the Preferred Remedial Action and the Contingency
Remedial Action satisfy the remedy selection requirements of
CERCLA and the National Contingency Plan. Each remedy provides
protection of human health and the environment, achieves
compliance with applicable or relevant and appropriate
requirements, utilizes permanent solutions to the maximum extent
practicable, is cost effective, and satisfies the statutory
preference for treatment as a principal element.
Protection of Human Health and the Environment
The Preferred Remedial Action and Contingency Remedial
Action protect human health and the environment through treatment
of contaminated soils and sediments in streams, the former lagoon
area, and the scraped area, and by capping the landfill area.
Treatment of contaminated soils and sediments using soil washing
or bioremediation and solidification will eliminate the threat of
exposure from direct contact or ingestion. The cancer risk from
exposure will be reduced to 1 x 10-6 for construction workers who
would be exposed to soils during construction of an industrial
facility after the remedial action is completed. By capping and
closing the landfill area in accordance with RCRA landfill
closure requirements, the risks of exposure through direct
contact and ingestion and the likelihood of contaminant migration
will be further reduced. There are no short-term threats
associated with the selected remedies that can not be readily
controlled. Deed restrictions will be necessary to prevent the
long-term development of a residential area in this location.
ComDliance With ADDlicable or Relevant and ADDroDriate
Reauirements I
.,'
Each of the selected remedies will comply'with all applicable
or relevant and appropriate chemical-, action-, a~~lo~~tion-
specific ARARs as described below and shown in Table 7. ~
o Action-Scecific ARARs - RCRA Subtitle C closure requirements
will be met for capping of the landfill area. Wastewater
generated during the soil washing process will .e treated onsite
and discharged to the municipal sewer system in accordance with
Clean Water Act general pretreatment regulation.' Wastes
transported offsite will meet EPA offsi~,disposal policy and
comply with DOT rules for materials transport. During site
excavation and treatment, air monitoring will be performed to
ensure that any air emissions comply with Federal and State Air
Pollution Control Laws and Regulations, and OSHA requirements
will be met for workers engaged in remedial activities. Wastes
51
-------
treated by solidification or soil washing will be tested to
confirm that the tr,ated waste is not hazardous before being'
returned to ex~avated areas or placed in the onsite landfill.
o Chemical-SDecific ARARS - Air emissions during remedial
activities will be monitored for compliance with Clean Air Act
and West Virginia rules a~d regulations.
o Location-SDecific ARARs - None
o Other criteria. Advisories. or Guidance To Be Considered
In developing risk-based cleanup levels, EPA has used advisory ,
levels and guidelines that are "to be considered" for the '
remedial actions. These are:
- EPA-established action level of 500 mg/kg for lead.
- EPA-established Reference Doses (RfDs) used to develop risk-
based cleanup levels for cadmium and copper.
- EPA carcinogenic Potency Factors to develop risk-based cleanup
levels for arsenic and CPAHs.
Cost-Effectiveness
The present worth cost of Alternative 6 is $9,393,000. The
present worth cost of Alternative 8B is 8,332,000. The selected
remedies are cost-effective because they provide overall
protection in proportion to cost and meet all other requirements
of CERCLA. Both remedies are 50 percent of the cost of
Alternative 4 (combination of soil washing and bioremediation)
and 21 percent of Alternative 5B (offsite incineration).
Remedies 1 and 2 may be implemented at lower costs but do not,
provide for permanent treatment, do not meet ARARs, and do not
provide as effective a level of protection Qfhuman health and
the environment. '\ ~/.' ." '..
0(
. ,.
Preference for Treatment as a PrinciDal Element
The selected remedies satisfy the statutory preference for
remedies that employ treatment as a principal e~ment to
permanently reduce the volume, toxicity', or mobIlity of hazardous
substances. By treating soils and sediments contaminated with
CPAHs and inorganic metals using soil washing or bioremediation
and solidification, the remedies address the principal threats
posed by the site through use of treatment technologies.
52
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Utilization of Permanent Solutions and Alternative Treatment
Technoloqies to the Maximum Extent Practicable
EPA has determined that the Preferred Remedial Action and
Contingency Remedial Action represent the maximum extent to which
permanent solutions and treatment technologies can be utilized
while providing the best. balance among the other evaluation
criteria. Of those alternatives evaluated that are protective of
human health and the environment and meet ARARs, the selected
remedies provide the best balance of tradeoffs in terms of long-
. term and short-term effectiveness and permanence; cost;
implementability; reduction in toxicity, mobility, or volume
through treatment; state and community acceptance; and preference
for treatment of soils and sediments by using soil washing or
bioremediation and solidification.
Bioremediation and soil washing address the principal
threats posed by contaminants in soil, achieving a significant
reduction in CPAHs and inorganic metals (95 percent). The
bioremediation process will require a longer implementation time
since it involves biological treatment compared with the
mechanical soil washing process. containment by landfill
capping, which is part of the selected remedies, does not reduce
toxicity, mobility, or volume of the hazardous wastes.
Therefore, ground water monitoring and maintenance of the cap
will be required. Implementation of a treatment remedy for the
landfill wastes is not considered practicable and probably would
fail because of the large amount of contruction debris and metal
placed in the landfill over many years. Such debris and metal
would have to be carefully screened and removed before any
treatment technology could be employed. Both remedies are
protective of human health and the environment and are more cost
effective than incineration which achieves only slightly higher
degree of reduction of toxicity.
53
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Action/ARAR
1. Landfill
closure with waste
, in place
2. Air emissions
from soil
excavation
3. Wastewater
discharge to local
municapal
treatment system
4. Activity within
a wetlands
5. OSHA
requirements
during onsite
activities
work
.-
6. Offsite
disposal of wastes
Table 7
'ARARs Matrix
Alternative 8B
will meet RCRA
landfill closure
requirements with
RCRA cap (40 CFR
264.300)
Air emissions will
be monitored for
compliance with
Clean Air Act and
State Air
Regulations
Discharge will be
treated to comply
with Federal
pretreatment
standards (40 CFR
403.5)
Any activity in
wetlands area will
comply with
Executive Order
11990
Onsite workers
will meet OSHA
training and
medical monitor~ng
requirements (40
CFR 1904, 1910,
1926)
.--.
Will comply with
EPA offsite
disposal policy
and DOT
regulations
54
Alternative 6
Will meet RCRA
landfill closure
requirements with
RCRA cap ( 4 0 CFR
264.300)
Air emissions will
be monitored for
compliance with
Clean Air Act and
State Air
Regulations,
Discharge will be
treated to comply
with Federal
pretreatment
standards (40 CFR
403.5)
,Any activity in
wetlands area will
comply with
Executive Order
11Qg,Q, " '.
. '...
Onsite workers
will meet OSHA
training and
~edical monitoring
requirements (40
CFR 1904, 1910,
1926)
Will comply with
EPA offsite
disposal policy
and DOT
regulations
-------
7. Cleanup levels
for soil/sediment
Will meet for
areas outside
landfill.
Will meet for
areas outside
landfill.
55
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MORGANTOWN ORDNANCE WORKS SITE
OPERABLE UNIT NO.1. DISPOSAL AREAS
MORGANTOWN, WEST VIRGINIA
RESPONSIVENESS SUMMARY
A.
Overview
At the time of the public comment period, EPA had already selected two equally effective alternatives
to address the areas requiring remediation at Operable Unit NO.1 of the Morgantown Ordnance
Works Site. These areas include the inactive landfill, "scraped" area, former lagoon area, 'and
streams. . The two alternatives outlined in the Record of Decision (ROD) were (1) capping and soil
washing or (2) capping, bioremediation, and solidification.
Judging from the comments expressed at the public meeting and during the public comment period,
the residents and local officials accepted both alternatives with no preference for either alternative.
The potentially responsible parties (PRPs) had some technical comments that are addressed later in
this document.
This responsiveness summary is designed to summarize community concerns and activities at the
Morgantown Ordnance Works Site and the EPA responses to those concerns. The responsiveness
summary includes the following sections:
. Background on Community Involvement.
. Summary of Public Comments and Agency Response.
,
. Attachment: Community Relations Activities at Morgantown Ordnance Works Site.
'\''''J~' ..
j "'.
B.
Backaround on CommunitY Involvemerrt
The Ordnance Work" Site lies adjacent to the communi~ies of Mor,ntown and Westover, in
north-central West Virginia along the banks of the Monongahela River. ~estover is a small town of
approximately 5,000 residents. Morgantown has ayear"ou'1~J)opulation of approximately 30,700
and is the home of West Virginia University, one of the area's largest employers. Other major
employers include the coal mining industry and various types of local industrial concerns, including
glass, chemical, and pharmaceutical manufacturers.
The Monongahela River has long been central to the area's history, economy, and identity. The
Monongahela joins the Allegheny River 75 miles to the north at Pittsburgh to become a major
D338916
-------
headwater of the Ohio River. Fifty percent of Morgantown's drinking water is pumped from the
riv.er; the rest is obtained from a smaller stream. The city's water treatment plant is located slightly
downstream and across the~ river from the Ordnance Works Site. In addition to being a major source
of drinking water for both the Town of Westover and the City of Morgantown, the "Mon" is used for
barge transport of coal, sand, and limestone. The river also is a popular recreation spot among area
residents, who use the river for fishing and boating. According to city officials, the City of
Morgantown is currently planning a river-front park, approximately three-quarters of a mile
downstream from the Ordnance Works Site. The park will include a walkway, picnic tables, and a
dock for boating and fishing. At present, a citizen task force is working to obtain Federal, state, and
private funding for development of the park.
Most residents and community officials interviewed during the preparation of the Community
Relations Plan characterized current public interest in the Ordnance Works site as fairly low.
According to newspaper reports and statements from local officials, however, there were sporadic
reports during the 1940s and 1950s from residents of unpleasant odors emanating from the plant and
of paint on houses being discolored by plant emissions. Since then, local officials claim there have
been no major complaints about the Ordnance Work Site until 1984. In January of that year, MIPA.
and West Virginia University announced a joint venture to develop a research park on the site
property to attract corporate tenants. Almost simultaneously, EPA released a report indicating that
PCBs had been found on the site. Following these two announcements, numerous articles about the
EPA findings and development plans for the Ordnance Works Site appeared in the local press.
Subsequently, MIPA hired a private contractor to remove barrels and soil contaminated with PCBs
under the supervision of EPA.
.,~
During this sample period, several local citizens and community groups (in.cluding the league of
Women Voters in Morgantown, the Monongahela Group of the West Vi~grntl'Si~rl'8 Club, and the
West Virginia Public Interest ReSearch Group [WVPIRG]) became concerned about water quality in the
Morgantown area. In particular, these groups expressed concern about. pollution threats to the
Monongahela River, ene of Morgantown's two principal ~urces of drjnking water. According to
residents interviewed for the preparation of the Community Relations Pt.n, a small but vocal group
of residents was concerned about possible health risks if toxi.. ~ached from the Ordnance Works Site
into Morgantown's drinking water via the Monongahela River. In addition, residents feared that the
Borg-Warner Company was discharging contaminants into the river.
Group members reported that the league of Women Voters and the Sierra Club devoted several
meetings during 1984 and 1985 to water quality issues associated with the Ordnance Works Site.
. league members wrote letters to variou~ pt;blic officials and talked to WVDNR officials requesting
D3389~c
2
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that the state sample area water. A well-attended public meeting, sponsored by the League of
W0"TIen Voters, was held in Morgantown to discuss water quality in the Morgantown area. Lo~'al
newspapers provided coverage 'of the meeting and related citizen activities. In response to citizen
requests, WVDNR sampled water in Morgantown but found nothing significant. According to
residents interviewed for the preparation of the Community Relations Plan, the level of community
interest in the site has declined since 1985, and there have been few press reports about the
Ordnance Works Site.
C.
Summary of Public Comments and Aaencv ResDonse
On July 12, 1989, a public meeting was held to present the results of the Focused Feasibility Study
(FFS) prepared for Operable Unit NO.1 of the Morgantown Ordnance Works Site. Comments raised
during the public meeting and during the public comment period, which ran from July 3,1989 to
August 2, 1989, are summarized below. The comments are categorized by relevant topics.
Concerns about Remedial Alternatives
1.
A member of the public questioned whether the two remedial alternatives chosen were
actually equally effective.
.
EPA ResDonse - The EPA technical representative at the meeting explained that the agency
had not expressed a preference for either alternative. Both alternatives were permanent
treatment technologies, and the cost difference was S 1 million or less, the representative
stressed .
.'
2.
A member of the public asked whether the work at the site would~J:ip~ .~y the Federal
Government or by a private company.
.
EPA Resoonse - The EPA explained that it could no~ answer the ,uestion because the work
had not been contracted at that time.
D3389'6
3
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3.
A member ofthe public questioned how long the cleanup would take.
.
EPA ResDOMse. The EPA technical representative reiterated the approximate cleanup times
of the two alternatives and referred the public to the fact sheet distributed at the meeting.
4.
A member of the public questioned how much liquid waste would be generated by soil
washing and how the waste would be handled. Would there be risk involved in shipping the
waste off site for treatment?
.
EPA ResDonse . The EPA technical representative explained that soil washing would
. generate several thousand gallons a day of waste. One stream of concentrated solvent
would be transported off site for incineration. Another more dilute stream would be
treated on site and discharged through the city sewer system. The offsite transportation
would present no more of a risk than ordinary truck traffic in the industrial park does now.
Environmental Concerns
1.
During the development of the community relations plan a major public concern that was
identified was migration of site contaminanu to the Monongahela River. This concern was
taken into account during the development of remedial alternatives. The concern was brought
up again during the public meeting. A member of the public questioned whether the drainage
ditches led to the river and whether contaminanu could be washed into the water supply.
.
EPA ResDonse . The EPA technical representative pointed out th~ the ditches were actually
intermittent drainage channels and that the remedial alternative ,w041d prevent future
\ 'CJ ~~ 'J 'I'
contamination via runoff to the Monongahela River. "'
2.
A member of the public questioned whether there was a commu~ity watchdog organization
that would oversee the cleanup. )
"
.
EPA Resoonse . The EPA public affairs representAtiVe explained in detail the Technical
Assistance Grant process and invited anyone interested in the program to contact him
directly.
0338916
4
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Additional Concerns
1.
A member of the public questioned whether the EPA was responsible for Superfund sites only.
Several other sites across the river from the Morgantown Ordnance Works Site concern local
residents.
.
EPA ResDonse . The EPA public affairs representative explained those areas over which the
EPA has jurisdiction and suggested that concerned residents contact their local and state
authorities.
D338916
5
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. The followinq written comments were received subsequent tQ"
the publicmeetinq~ -
Comments Prom Woodward-Clvde Consultants Reoresentina the PRP
Committee
1. The risk asse..ment-for the recommended alternative .hould
be weighted more toward the lack of .iqnificant current-use
pathways or receptors rather than a hypothetical future-use
scenario for construction worker..
EPA is required to consider both current and future exposure
routes/pathways. A component of the risk analysis performed by
EPA in the Focused Feasibility Study (FFS) is the exposure
analysis in which potential future exposure pathways and routes
of exposure are identified and expected level of exposure
calculated. A consideration of expected land use (i.e.,
residential versus industrial) is identified and the necessary
cleanup levels to ensure protection of human health calculated.
Because the contaminated areas are located within an industrial
park, a future use scenario for protection of construction
workers exposed to soils and sediments durinq construction of an
industrial facility is considered a plausible scenario and was
used in developing cleanup levels. This approach is considered
reasonable and consistent with Superfund policy.
2. The cleanup level for CPAB .hould be 100 ag/kq. This cleanup
level was proposed by BPA Region IV for the Live Oak, rlorida,
Superfund site.
Clea~up levels should be based on individual site-specific
risk assessments. Cleanup levels for contaminants at one
Superfund site can not be simply transferred tor use at another
Superfund site where site conditions, exposure ~utes,
physiological conditions, etc. will vary. . '
3. The eztent of .ite r..ediation .houl4 be ba.~8'6nl1~on the
concentration. of CPAB an4 ar.enic that esceed cleanup levels.
Target cleanup level. for chroaiwa, .ercury, sinc, copper, an4
lea4 shoul4 not be u..4 a. a ba.i. for .it. r...~iation.
. -
. The ROD es~ablishes cleanup levels for cpKks, arsenic,
cadmium, lead, and copper. All of these contaminants have been
identified in soil or sediments at conc,~~rations t~at exceed
risk-based cleanup levels, and therefore site remed1ation is
required. Cleanup levels are not proposed for mercury, zinc, and
chromium because the maximum concentrations detected during the
Remedial Investigation sampling are below the proposed cleanup
levels. Cleanup levels for all contaminants of concern,
including metals, were established based on the revised risk
assessment in the FFS.
6
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, 1W"'" ~ "
~,
4. Wetlands are not present at the .ite, as supported by a soil
survey of the three streams conducted by Woodward Clyde
Consultants. proposed alternatives affected by potential
wetlands should be reviewed and revised. por esample, the
biotreatment alternative 'should be modified by eliminatinq the
protective liner.
Wetlands have not been identified in the ROD as being
located alonq the stream banks on the site. Any wetlands
identified onsite in other areas will be restored to existing.
conditions. The actual extent of wetlands affected by
remediation will be determined during the remedial design phase.
The Preferred Remedial Action states that bioremediation may be
conducted in either a lined or unlined treatment bed.
5. The most appropriate remedial action alternative would be
offsite disposal of "hot spots" from the .craped area and former
laqoon, capping of the scraped area and former laqoon area,
cappinq the landfill, and deed re.triction..
The remedy proposed by Woodward-Clyde would involve offsite
disposal of "hot spots" with a total volume of about 1,000 cubic
yards of soil. Hot spots are defined as 80il containing more
than 300 mg/kq CPAH. (Reference: December 14, 1988 Woodward-
Clyde Report, "Assessment of the RI/FS/ROD for the Ordnance Works
Site, Morgantown, West Virginia.) The remaining areas of .
contamination would be capped. This volume of 1,000 cubic yards
to be treated compares with a total of 13,885 cubic yards of soil
and sediments contaminated with CPAHs and metals that will be
permanently treated using bioremediation or soil washing
techniques. Removal offsite of a small quant~ty of waste
material and capping the remaining contaminated ~reas, as
suggested in the Woodward-Clyde comments, does riot permanently
and significantly reduce the volume' or toxicity of. hazardous
waste at the site, does not utilize permanent tre'a't1tent,~
technologies to the maximum extent practi~able, and does not
satisfy CERCLA's preterence for remedies that employ treatment as
a principal element. .
fa. If the alternative involvinq r..oval ot "h~ .pots," cappinq,
and institutional control. i. not recommended, ~hen biotreatment
is a potentially appropriate r..e4ial technology.
t. ~.
Alternative 8B, bioremediation and containment, is selected
in the ROD as the Preferred Remedial Action.
7
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7. Extrapolation ot re.ult. tro. other biotreataent .tudies to
the xorqantoVD .its,..uch a. the Burlinqton Horthern Supertund .
site, i. ri.ky.
EPA acknowledges that site-specific design conditions are
important and has recommended design studies prior to .
implementing the Preferred Remedial Action. It is appropriate,
however, to identify other Superfund sites and to reference
literature studies where bioremediation has been used.
.8. A lined treataent bed .hould not be u.ed tor bioremediation
because ot increased cost and the tact there are-no vetlands at.
the site.
The ROD states that bioremediation may be conducted in
either a lined or unlined treatment bed for Alternative 8B.
9. Soil vasbinq va. previously not recommended a. a remedial
alternative in tbe earlier peasibility study CWeston, 1988) and
is an unproven techDoloqy.
The Focused Feasibility Study included identification and
screening of all applicable treatment technologies in light of
revised cleanup levels, costs, compliance with ARARs, and other
site specific conditions. Recent EPA policy directives advocate
the use of new and innovative technologies which have the
potential to provide similar treatment performance compared to
demonstrated technologies at comparable costs. EPA therefore
considers it entirely appropriate to consider soil washing even
though this technology was previously not evaluated in detail.
10. Tbere i. no documentation or data pre.ented indicatinq that
tbe soil va.binq .olvent extraction proce.. CaB treat tbe .oil
matrix at tbe Ordnance Work. .ite. The .uqqeste~ process (BEST)
vas developed for treatment of orqanic .ludqe., aot beteroqenous
soil. containinq CPAB.
''\ ..., ~f .'1 't..,..
Soil washing is. a commercially available process and is
marketed by several vendors. As stated on page 4-18 of the
Focused Feasibility study, the BEST process was selected as a
representative process for discussion and cost estimating
purposes, and other soil washing processes may ~e equally viable.
"
8
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11. The BEST proce.. i. de.iqned for particle. le.. than l~incb
in-diameter. Larqer.aqqreqate. at the KorqaDtwon .ite would
require expensive pre-.creeninq aDd crushinq, aDd would be
difficult to implement.
Discussion in the Focused Feasibility Study acknowledqes
that prescreeninq of large material would be required and
includes this technoloqy in the cost estimate for Alternative 6.
Screeninq, qrindinq, or crushinq are all considered demonstrated
materials handlinq operations.
12. The .tated cost. in Alternative' are hiqh aDd not
adequately detailed.
Costs are considered reasonable for an initial enqineerinq
estimate and are presented in detail in the Appendix to the
Focused Feasibility study.
13. If the .olvent extraction proce.. fail., QO other
alternative techDoloqie. have been con.idered a. backup
t8chnoloqie..
soil washinq (solvent extraction) is considered to be
technically feasible and has been selected at other Superfund
sites. EPA has selected Alternative 88 (bioremediation) as the
Preferred Remedial Action and Alternative 6 (soil washinq) as the
Continqency Remedial Action.
Comments from Booe Gas. Inc.
The amount of airborne particulate. .hould be reduced,
and nearby worker. aDd re.ident. .hould be advi.ed of action
taken to ainiai.e the relea.e of air cont..in~t..
Both the Preferred Remedial Action and continqency Remedial
Action provide for monitorinq of air emissions for _compliance
with Federal and State air pollution requlations.,....A;. r-i-Sik
assessment usinq this data will determine the risk to onsite and
o.ffsi te receptors.
. .
.-
Comment fro. Baker' Arai.tead. Attorney at Law~
I
The Focu.ed Fea.ibility study erroneou.ly refer. to the current
owner as KorqaDtoVD Industrial Park. a-~-
The Record of Decision states that the current owner is
MorqantoWn Industrial Park Associates, Limited partnership
("MIPA").
9
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Comment fr08 GB 8DecialtvCb..ical.
Tbe Propo.ed Plan provide. an inaccurate de.cription of Borq-
Warner'. and GB'. pre.ence at tbe .ite.
The Record ot Decision has corrected any inaccuracies in the
description ot Borq-Warner's and GE's presence at the site.
10
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ATTACHMENT
COMMUNITY RELATIONS ACTIVITIES
AT MORGANTOWN ORDNANCE WORKS SITE
Community relations activities condtJcted at the Morgantown Ordnance Works Site to date have
included the following:
0338916
.
U.s. EPA Contractor conducted interviews with local officials and interested residents
(January 1988).
.
EPA prepared community relations plan (February 1988).
.
EPA established five information repositories.
established at the Morgantown Public Library.
The repository of public record was
.
EPA released the RifFS to the public (February 1988).
.
EPA established a public comment period on the RVFS (February 16, 1988 to
March 16, 1988).
.
EPA issued a Fact Sheet summarizing the RVFS for the site (March 1988).
.
EPA held a public meeting on the RVFS (March 1988).
. The first Record of Decision (ROD) was signed (March 31, 1988).
. Additional comments received from the PRPs resulted in a Focused Feasibility Study (FFS).
~
.
EPA rel.ased the FFS to the public. A copy of the FFS w~s sent to the Information
I
Repository of Record (July 3, 1989).
a. ~.
.
EPA developed and released a Fact Sheet summarizing the FFS and sent Fact Sheets to five
information repositories (July 3, 1989).
.
EPA ran an advertisement in the Morgantown Dominion-Post summarizing the FFS,
announcing the public meeting, and announcing the public comment period (July 3, 1989).
-------
D338916
.
EPA set a public comment period on the FFS (July 3, 1989 to August 9, 1989).
.
EPA held a public meeting July 12,1989, at the Morgantown Public Library to answer
questions about the selected alternatives for the site.
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