Un::ad states
Environmental P,"""chon
Agency
Office of
Emergency and
Remedial Response
EPA/ROOR03-90rt)85
March 1990
Superfund
Record of Decision
C & R Battery, VA
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502"1'2.101
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/R03-90/08S
2.
3. Recipientl ACC8Mion No.
.. Title Ind SUbtitle
~TTPERFUND RECORD OF DECISION
& R Battery, VA
~'irst Remedial Action - Final
5. Report 0118
03/30/90
IS.
7. AutI1or(l)
8. Perlonnlng Orgenlzation Re~ No.
8. Perlonning Orgainlzation H8nw end Add.....
10. Proj8ctIT ull/Woril Unit No.
11. Contrec1(C) or GnnI(G) No.
(C)
12. Sponeoring Orglnlzallon H8nw end Addr8M
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
(G)
13. Type o' Report . Period Covered
Agency
800/000
14.
15. Supplementuy No..
1 IS. Abeerlct (Umlt: 200 WOrdl)
The 11-acre C & R Battery site is a former battery-sawing and shredding facility in
Chesterfield County, Virginia. Open fields and woods border the site on the north,
south, and west, a small fuel oil distributor borders the site on the east, and the
James River is approximately 650 feet north of the site. From the early 1970s to 1985
~he facility was used to recycle discarded batteries. Site operations included
raining battery acids into onsite ponds, recovering and stockpiling lead and lead
compounds from the batteries, and shredding and stockpiling battery casings onsite.
The State began monitoring the site in the late 1970s and detected elevated lead
levels in the soil, surface water, and ground water. An OSHA inspection revealed
indoor air levels of lead to be more than twice the OSHA standards of 50 ug/m3. Also,
facility employees were found to have elevated lead levels in their blood. In
response to public health concerns, EPA conducted a removal action in 1986, which
included extracting acidic liquid from onsite lagoons and raising the pH level of the
liquid before discharging the neutralized liquid into onsite ditches. Lagoon sludge
was neutralized and returned to the lagoon, and surface soil was also neutralized. In
addition, shr~dded battery casings, soil, and debris, found east of the drainage
ditch, were consolidated into two debris piles and remain on site. This remedial
(See Attached Sheet)
17. Document Anely8i. L Deecrtptora
Record of Decision - C & R Battery, VA
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, sw
Key Contaminants: metals (lead, arsenic)
-
b. Identlfl.r8l0pen-End8d Tanna
r-
~. COSATI Raid/Group
illbitity St.tament
18. Security CI... (TItII Report)
None
20. Security CI... (TItI. Page)
None
21. No. 0' P.g..
6S
22. PrIce
(See ANSI-Z38.18)
SH In8truct/on. on RI-
(4-17)
(Formerfy NTlS-35)
Deperlrn8ntO'COnwTMWce
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EPA/ROD/R03-90/085
C & R Battery, VA
First Remedial Action - Final
Abstract
(continued)
action addresses the former acid pond area, the debris piles, and a drainage ditch.
The primary contaminants of concern affecting the soil, sediment, debris, and surface
water are metals including lead and arsenic.
The selected remedial action for this site includes the demolition of a concrete pad
and dismantlement of a storage shed followed by offsite disposal of the debris, and
offsite treatment, if necessary, of surface water from the drainage ditch prior to the
excavation of contaminated soil and sediment: excavation and stabilization of
approximately 36,800 cubic yards of contaminated soil, sediment, and debris piles
followed by offsite disposal in a permitted landfill: backfilling of all excavated
areas: soil cover over all areas with lead contamination above background: hybrid
closure (soil cover) for residual contamination of lead-contaminated soil outside the
acid pond area: clean closure of the acid pond area: offsite treatment and disposal of
350 batteries: ground and surface water monitoring: and implementation of institutional
controls including site use restrictions. The estimated present worth cost for this
remedial action is $15,572,000 which includes an annual O&M cost of $14,550.
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RECORD OF DECISION
C'R BATTERY COMPANY, INC. SITE
DECLARATION
SIT! NAME AND LOCATION
C&R Battery company, Inc. site
Chesterfield County, virginia
STATBDN"l' OP BASIS AND PURPOSB
This decision document presents the Remedial Action selected for
the C&R Battery Company, Inc. (C&R Battery) site. This document
was developed in accordance with the Com~rehensive Environmental
Response, compensation, and Liability Act of 1980, as amendecl
(CERCLA) ; and, to the extent practicable, the National
contingency Plan (NCP), 40 CFR Part 300. The decisions contained
herein are based on information contained in the administrative
record for this site.
-
The Commonwealth of Virginia has concurred with the selection of
this remedy.
ASSBSSXBN"l' OP TBB SIT.
Pursuant to duly deleqated authority, I hereby determine,
pursuant to section 106 of CERCLA, 42 U.S.C. Section 9606, that
actual or threatened releases of hazardous substances from this
Site, as discussed in "Summary of site Risks," section VI, if not
addressed by implementing the response action selected in this
Record of Decision, may present an imminent and substantial
endanqerment to the public health, welfare, or the environment.
1
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1
I
D!SCRI~IO. 0" THB REMEDY
EPA has selected, and the Commonwealth of Virginia has concurred
on. the selection of the following Remedial Action for the C&R
Battery site. The major components of the. Selected Remedial
. Action are as follows:
Selected Rem.dial Action:
Alternative 4(a)
. Excavation of surface and subsurface soils containing lead
above the 1,000 mg/kg action level (approximately 36,800
cubic yards).
. Excavation of drainage. ditch sediments. containing
above the 450 mg/kg action level.
lead
. Stabilization of the excavated 36,800 cubic yards of soil,
sediments, and debris piles using a cement/pozzolan-based ~
or other similar stabilization process that provides
equivalent protection.
. Disposal of the stabilized
industrial or sanitary landfill~
material
in
an
~pproved
. Clean closure of the former acid pond area, according to
RCRA closure requirements.
. Backfilling of all excavated areas with soil and placement
of a layer of topsoil (approximately 6 inches) followed by
revegetation over all area~ having lead levels above
120 mg/kg (background).
. Removal, treatment, and disposal of the onsite
nickel/cadmium batteries in an approved RCRA facility.
2
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.
Implementation of an environmental monitoring plan to
ensure the effectiveness of the Remedial Action and to be
protective' of the environment, particularly the
environmental receptors in the James River.
. Removal and offsite treatment of any contaminated surface
water in the drainage ditch.
.
Dismantlement and
discarded tires
landfill.
removal of storage shed and removal of
for offsite disposal at an approved
. No remedial action for groundwater is necessary, however,
monitoring will continue at the site at least until the
first 5-year review of the Site required under
section 121(c) of CERCLA, 42 U.S.C. section 9621 (c), is
completed.
. Appropriate Site use restrictions will be placed for
future use scenarios to ensure protection of public health
and the environment.
STATUTORY DBTBRXIKaTION.
The Selected Remedial Action (Alternative 4a) is protective of
human health and the environment, complies with Federal and state
requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective.
3
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The Remedial Action utilizes permanent solutions and alternative
treatment .technologies to the maximum extent practicable and
satisfies the statutory preference for a remedy to employ
treatment that reduces toxicity, mobility, or volume as a
principal element.
Because this remedy will leave hazardous substances on Site, a 5-
year review- under" Section 121(C) of CERCLA, 42 U.S.C. 9621(c),
will be conducted for the site to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
~~?~
~dwin B. Erickson.
~R;qional Administrator
"3- 3 c; - 70
Date
4
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RECORDOP DECISION
C'R BATTBRY COMPANY, INC. SITE
DECISION SUHHARY
I.
SIT. HAMB, LOCATION AND DESCRIPTION
The C&R Battery Company, Inc., site (C&R Battery site-or Site) is
located in an industrial area in Chesterfield County, Virginia
approximately 6 miles southeast of Richmond, Virginia{see Figure
1). The Site (approximately 11 acres) is rectangular in shape
and is bordered on the north, south, and. west by open fields and
woods.. A small fuel-oil distributor, Capitol oil Company,
borders the site on the east. The James River is located
approximately 650 feet north of the site.
Groundwater beneath the site is classified as a class 2A aquifer,
a current and potential source of drinking water, and flows in a
northwesterly direction towards the James River.
II.
SIT. HISTORY AND ENFORCEMENT ACTIVITIES
\.
The C&R Battery sit. was a battery-sawing and shredding facility
designed to recover lead from discarded auto and truck batteries.
It operated from the early 19705 until'1985. The battery breaker
was a mobile unit', and operations were moved throughout the site.
The site received bulk shipments of discarded batteries. The
first step in recycling was to cut the batteries open and drain
the battery acids into onsite ponds. The batteries were then
broken open and the lead and lead compounds were recovered and
stockpiled for later shipment. The battery casings were
subsequently shredded and stockpiled on the site. Crushed
battery casings have been observed on the site surface and buried
throughout the site. No other activities that may have produced
t
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1
II
..j~
/..-1 !YlIIGI"~
QUAQIIAHGt,£ LOCATION
,
\)
~
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additional contaminants are known to have o~curred on the Site.
The Virginia State Water Control Boara:began monitoring the Site
in the late 1970s. The Board conducted several rounds ot sampling
for lead in soil, surface water, and groundwater. These samplings
revealed elevated levels of lead in all media. Several
reclamation plans were proposed -and permit applications were made
by the operator, but state approval was never authorized for such
plans or permits.
virginia Occupational Safety and Health Administration (OSHA)
first inspected the site in 1983 while the battery processing
facility was still in operation. Air monitoring of the breathing
zone at several work stations measured lead at concentrations up
to 112 ~g/m3, well above the existing OSHA standard of 50 ~g/m3.
Employees were found to have elevated levels of lead in their
blood.
In response to potential public health concerns, EPA conducted a .
removal action at the Site under section 104 of CERCLA,
42 U.S.C. section 9604, in the summer of 1986. After verifying
the presence of elevated metals in the soils and sediments at the
site, EPA removed the acidic liquid from onsite lagoons, raised
its pH, and discharged the neutralized liquid into ditches on
site. The lagoon sludge was blended with hydrated lime and
returned to the lagoon. Soils were dusked and mixed with lime to
a depth of 2 feet. However, when intact batteries .were found in
the northern potion-. of the Site,. a decision was made to apply
lime only to the soil surface in this area. At the same time, a
large amount ot shredded battery casing material was found east
of the drainage ditch. The shredded battery casings, soil, and
debris were brought back onto the Site and remain on site in the
debris piles (refer to Figure 2), whereas the excavated area was
subsequently backfilled to reduce hazards to Capitol oil Company
employees. The drainage ditch was graded, and riprap channels
and dams were installed to reduce erosion. A 6-foot-tall, chain
link fence was installed inside the tree line to minimize the
2
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can** »**WL
-6;Utt^^oH
IN
fl*l *°*
r ^
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potential for direct contact with contaminated materials on Site.
From the time of the EPA removal action until present, EPA has
identified several - PRPs, all of whom, until present, have
declined to participate in any of EPA's actions.
III.
COMKUHITY RELATIONS HISTORY
- '
In accordance with -Sections 113 and 117 of CERCLA, 42 U.S.C.
sections ~613 and 9617, EPA held a public comment period from
January 25, 1990 through February 23, 1990 for the - Remedial
Actions described in the Remedial Investigation/Feasibility Study
(RI/FS) (released January- 1990) . The notice of availability was
published in the Richmond Times Dispatch on January 25, 1990.
The RI/FS anc;l Proposed Plan were made available to the public in
the Administrative Record maintained in the Region III office and
at the Chesterfield County Public Library. A public meeting was
held on February 7, 1990 to outline the Preferred Remedial Action
and to accept comments from the attendees. A transcript of the
public - meeting was maintained in accordance with
section 117(a) (2) of CERCLA, U.S.C. section 9617(a) (2). Written
comments were received and are addressed. in the Responsiveness
Summary which is attached.
All documents supporting the remedy selection 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.
SooP. AND ROLl OP RESPONSB ACTION
This Record of Decision selects a Remedial Action for the C&R
Battery site. The January 1990 RI/FS for the Site documents the
release/threatened release of hazardous' substances into the
environment and the endangerment posed by the site. Surface soil
and sediment were determined to be a principal thre~t because of
3
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. the potential for direct dermal contact and ingestion of soil,
sediments, and surface water. The potential for the inhalation
of fugitive dust also poses a threat to human health and the
environment. Lead poses the largest threat at the Site.
According to the Centers for Disease control, lead and soil.
containing lead dust generally appear to be responsible for
elevated bloo~ levels in children when the lead concentration in
the soil exceeds a range of 500 to 1,000 mg/kg. EPA has adopted
this recommendation to establish the 1,000 mg/kg in an OSWER
directive memo dated September 7, 1989 level as being' protective
of. human health for areas which will not be frequented by
children. The remediaL action objectives for the Site were
developed to protect human health and the environment. These
'objectives are:
1..
2.
3.
Prevent exposure (inhalation, ingestion) . to soil having
a lead concentration greater than 1,000 mg/kg and
concentrations of the other indicator chemicals greater
than their respective action levels (See Table 1).
Prevent. migration of lead that would result in
groundwater contamination in excess of 0.05 mg/l (MCL)
and the migration of the other indicator chemicals in
excess of their respective MCL levels.
Prevent migration of lead that would result in drainage
ditch sediment contamination in excess of 450 mg/kg,
and the migration of the other indicator chemicals in
excess of their respective action levels (See Table 1).
Based on data. available in the Remedial Invest; gation
(January 1990), a total ot approximately 36,800 cubic yards of
contaminated material will need to be excavated and remediated.
v.
SIT. CHARACTERISTICS
The contaminants of concern for the C&R BatterY site are lead,
4
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cadmium, arsenic, antimony, nickel, silver, and zinc. Lead was
present" in high concent~ations (orders of magnitude higher)
compared to the other contaminants. Arsenic is a carcinogen
while the other contaminants are systemic toxicants. The
affected media are soil, sediments, and onsite surface water.
See Figure 2 for the general site layout.
The areas of the site to be remediated are described as follows:
poraer Acid Pond Area
The acid pond area is approximately 1/4 acre in size and was used
during the operation of the C&R Battery Company to hold the
discharged sulfuric acid from-the batteries. Chemical analysis
of the soils in this area revealed the highest concentrations of
. lead (>12 percent) and lead concentrati~ns exceeding the remedial
action level to the furthest depth (15 feet).
Debris pi1e.
There are two debris piles located on Site which consist of soil
and battery pieces. These piles were placed wi thin the fenced
area of the site during the removal action in 1986.
contaainated soi18
The entire area of the C&R Battery site has been contaminated
with lead at concentrations which exceed the remedial action
level (1,000 mg/kg). The depth of contamination at the site
varies, with the south portion of the site having the deepest
contamination and the north portion of the Site the shallowest.
Figure 3 through Figure 6 and Table 2 show how the extent of
contamination decreases with depth.
Drainaae Ditch surtace Water/Sediments
Sediments in the drainage ditch along the Site were found to
5
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TABLE 1
REMEDIAL AcnON LEVELS
C&R BATTERY SITE
CHESTERFIELD COUNTY, VIRGINIA
Medium
Contaminant
.Surface Soil Sediment
(mg/kg) (mg/kg)
Anti mony 77.4 ' ..
/
Arsenic 10. 57 j
Cadmium 84. 5 /
Lead 1,000 450 '
,
Nickel 600. ..
. 10-6 Cancer Risk Level
.. Levels already within acceptable risk range
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UAD c:oaNta"1ICIN (~f1ION . .
"" ....181 Of ~d $Oa. (IJ -IS)
~ ====- J~n: $III. (I)'-IS')
PIt ~"1ICIN c.cIIIlCIUII
ID!- 8C8t5 lOC,,1IQII
pl8Sl/ILUO ./11)
(
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TABLE 2
VERTICAL DISTRIBUTION OF LEAD CONTAMINA TJON IN SOILS(1)
(ONSITE AND OFFS'TE) .
C&R BAmRY SITE
CHESTERFIELD COUNTY, VIRGINIA
Interval Percent of Cumulative Percent of Cumulative
Depth Total Lead Ptrcent of Total Volume Ptrcent of
(feet) . in Interval Total L.ad in tnterval Total Volume
in Inttrval
0-2.5(2) 80.5 80.5 46.5 46.5
2.5 - 5.5 12.6 93.1 28.6 75.2
5.5-8.5 6.4 99.5 16.1 91.2
8.5 - 1 2 0.3 99.8 5.5 96.7
12-15 0.2 100 3.3 100
(1) Based on soil containing lead above 500 mglkg. Percentages based on
- 120 mglkg level should be similar.
(2) Does not include sedimenu and debris piles.
, -
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- contain high-concentrations of lead exceeding the-action level.
Surface water in this drainage ditch is a potential transport
mechanism to the James River for the sediments and contained
slightly elevated levels of contamination.
Groundwater
Groundwater at the site is located at a depth of between 40 and
50 feet. The subsurface soils are rich in clay. Sampling of the
wells which were placed during the RI field investigation
revealed no concentrations of contaminants above primary drinking
water standards. In a further effort to define the possible
transport of contamination from soils to groundwater, an EPA:--
developed multi-media transport model was run in conjunction with
a metal speciation model. The- results of this modeling effort
indicate that transport of contamination from the soils tq
groundwate-r would take thousands of years - under the no action
scenario. Therefore, only continued monitoring of the
groundwater is required under this Record of Decision.
VI. SUMXARY OP SITB RISKS
The objective of this section is to estimate the potential
incidence of adverse health or environmental effects under the
exposure scenarios present at the Site. EPA guidelines for the
use of dose-additive models are used to combine the risks for
individual chemicals to estimate cumulative risks for the
mixtures found on Site, assuming that the toxicologic endpoints
(effects) are the same. This section characterizes the potential
noncarcinogenic, carcinogenic, and environmental risks associated
with the C&R Battery Site.
Noneareinoqenie Btteets
The potential for health effects resulting from exposure to
noncarcinogenic compounds is estimated by comparing a time-
weighted daily dose to an acceptable level such as a Chronic
6
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Reference Dose (RfD). - - If the ratio exceeds one, there is a
potential health risk associated with exposure to that particular
chemical. The ratios can be summed for exposures to multiple
contaminants. This sum, known as a Hazard Index, is not a
mathematical prediction of the severity of toxic effects: it is
simply a numerical indicator of the transition from acceptable to
unacceptable levels. Table 3 presents a summary of the total.
potential Hazard Indices. EPA considers any Hazard Index which
is greatet" than one to... present an unacceptable risk to human
health and the environmen~.
Air -- Fugitive Dust
Noncarcinogenic health effects would not be expected to result
from the exposure to lead. in fugitive dust emissions from the
site. The Hazard Index determined for children is 0.003 and that
for adults is 0.0008, using the annual average lead
concentrations determined during modeling.
80il -- Accidental Ingestion
Lead is the maj or contributor to the Hazard Index' for this
exposure scenario for both the- soil and the debris piles. Total
Hazard Indices range from 3.3 to 120, using a range of soil
ingestion rates (0.05 and 0.25 g/day) and the average and maximum
soil concentrations. The Hazard Indices for the debris piles
show a similar range in values, from 12 to 73.
carcinoaeaia Health Risk.
The following discussion contains the calculated carcinogenic
risk for each exposure scenario for the site and its associated
media. A summary of total potential carcinogenic health risks is
presented in Table 4.
It should be noted that EPA now considers lead to be a probable
7
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TABLE 3
SUMMARY OF TOTAL POTENTIAL HAZARD INDICES
C&R BATTERY SITE
CHESTERFIELD COUNTY, VIRGINIA
Source Area Concentration Fugitive Dust Accidental Ingestion
Emissions .. of Soil
Soil Averag. 3.3 (0.05 g/day)
to
17 (0.2S g/day)
Maxi mum 0.003 24 (O.OS g/day)
to
120 (0.2S g/day)
Debris Piles Average 12 (0.05 g/day)
to
S9 (O.2S g/day)
Maximum 0.003 17 (O.OS g/day)
to
7S (0.2S g/day)
me maximum fugitive dust emission rates were calculated for both annual average and seasonal
maxima. Emission rates were baMd on isoconclntration contours for suriac. soils, tnerefore, results
art shown only for one ~t of input conclntrations.
TAILIC
SUMMARY OF TOTAL POTENTtAL CARCINOGENIC RISKS
C&R IAmRY SITE'
CHESTERFIELD COUNTY, VIRGINIA
Sourc. Arta Conctntration Fugitiv. Dust Accid.nullngtstion
Emissions. of Soil
Soil Averag. 9.0x10-7 (0.05 glday)
to
4.Sxt~ (0.25 Q/day)
Maximum S.1x10-5 3.3x1~ (0.05 glday)
to
1. 6x t 0-5(0.25 glday)
O.bris Pil" Averag. 1.Bx 1 Q-6 (0.05 glday)
to
9.3xt~ (0.25 glday)
Maximum S.1x10-S 3.4x 1 Q-6 (0.05 glday)
to
t . 7x t O-S (0.25 g/day)
m. mnimumfugitiv. dust emission rates w.re calculated for both annual average and seasonal
maxima. Emission rates wer. baMd on isoconclntration contours for surfact soils, tntr.lfort, result"
art shown only for on. SIt of input conClntrations.
-------
human carcinogen via the oral route of exposure. At this time, a
carcinogenic potency factor has not been established. for lead so
a cancer risk calculation is impossible to perform. For purposes
of this Record of Decision only the non-carcinogenic risks
associated with lead will be used.
Air -- pugitive Dust
Erosion of contaminated surface soils by the wind and transport
to a downwind receptor susceptible to the maximum annual average
concentrations will result in an average potential incremental
risk of 5.1 x 10-5. This risk was calculated for only arsenic,
which is the primary carcinogen present in site soils. Arsenic
has a very high carcinogenic potency factor via inhalation
exposure. EPA has classified lead as a probable human carcinogen
via the inhalation route of exposure. However, because a potency
factor is not yet available, the carcinogenic risk for lead can
not be quantified.
80il -- Accidental Ingestion
As with fuqitive dust. exposures, all the estimated risks fall
within the established risk range (10-4 to 10.6) .
Of all the metals found in the soils, only arsenic is
carcinogenic via oral exposures. With the hiqh potency factor,
even the offsite concentrations of arsenic will result in a risk
qreater than 10.6 via the accidental inqestion route. Usinq a
range of inqestion rates (0.05 and 0.25 q/day) and both the
maximum and average soil concentrations, the estimated risks
ranged from 9.0 X 10.7 to 1.6 X 10-5.
~iroD8ental Risks
Concentrations of lead, cadmium, and zinc in the surface water
samples from the drainaqe ditch exceeded acute and chronic
Ambient Water Quality criteria.
8
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Concentrations 6f lead and cadmium exceeded the range of
sediment quality values used for the protec'tion of aquatic and
benthic life. Results of sediment elutriate bioassays conducted
on sediments from the surface water pathway indicated toxicity
which correlated to elevated levels of trace metals, particularly
of lead, in the drainage ditch sediments. There is a potential
for transport of toxic contaminants in both sediments and surface
water from the site to the environmental receptors in the James
River via the drainage ditch. The presence of the rip rap dams
have minimized the transport during low flow periods. However,
the potential for transport of contaminants in sediment and"
surface water to the James River exists during high flow periods.
since lead is present in such high concentrations and causes the
most threat to public health and the environment, the-discussion
throughout the ROD w-ill speak only about lead. The other
" .
contaminants and their respective action levels also were
incorporated in the decision-making process.
Action Levels
Aside from lead, the indicator contaminants for the C&R Battery
site are antimony, arsenic, cadmium, and nickel. These
contaminants were found to be present in soils and sediments at
elevated levels. "For this reason, action levels were developed
for each of these contaminants based on risk assessment modeling.
The soil action levels were developed using the 10.6 risk
scenario. The sediment action levels were derived from the Puget
Sound Estuary Program which conducted a study to establish the
effects of contaminants on the environment and recommend levels
of concern which would cause adverse effects to- the environment.
These levels were considered in establishing sediment action
levels for the C&R Battery site. Both" the soil and sediment
action levels are listed in Table 1.
9
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VII.
DOCUMENTATION OF SIGNIFICANT CHANGES FROK PROPOSED PLAN
The proposed Plan for the C&R Battery Site was released for
comment in Janua"ry, 1990. The Proposed Plan identified
Alternative 4 (a), from the Feasibility Study as the preferred
alternative. - EPA reviewed all written and verbal comments
submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the
remedy as it was originally identified in the Proposed Plan, were
necessary.
VIII.
DESCRIPTION OF ALTERNATIVES
In the FS, several soil action levels were evaluated. An action
. .
level of 1,000 mg/kg lead was determined to be appropriate fo~
this site. This level is in accordance with EPA guidance of
September 7, 1989 for cleaning soils in residential areas and is
based on a recommendation from the Centers for Disease Control.
Although several action levels were evaluated as separate
alternatives in the FS, only the alternatives applicable to the
1,000 mg/kg action level will be presented in this"
ROD(alternatives 3 and 6 have b~en screened out since they do not
incorporate the 1000 mg/kg level). To reach this goal, EPA has
identified eight Alternatives. A description of these
alternatives follows. Based on sampling performed at the Site, a
120 mg/kg value for lead will be used to represent background
levels. Several of the alternatives listed below include a soil
and vegetative cover over areas of the Site which contain lead
concentrations between 120 mg/kg and 1000 mg/kg.
In an effort to support our decision-making and to define
treatment alternatives as early as possible, several treatability
studies were conducted during the RI/FS in order to evaluate the
. .
applicability of treatment technologies to the soils and
sediments at the site. The results of these treatability studies
showed that either stabilization or soil washing could achieve
10
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all remedial. action goals. These studies also gave
data for each of .these technologies. The results
studies are outlined in the RI/FS.
good cost
of these
Alternative 1:
No Action
This -alternative is considered in the detailed analysis to
provide a baseline to which the other remedial alternatives can
be compared. This alterna~ive involves takinq no action at the
C&R Battery site to remove, remediate, or contain the
contaminated soils, Ni/Cd batteries, and other debris. Under the
"no action" scenario, periodic groundwater monitoring would be
conducted throughout the area of potential groundwater
contamination. In addition to groundwater sampling, periodic
surface. water/sediment samplinq would be conducted to monitor
offsite transport of contaminants via surface water runoff anc;l.
erosion. This action will not reduce the. risks to the public
health and the environment 'outlined in Section VI.
Alternative 2:
RCD CaD
This alternative involves containment of the surface and
subsurface soils under a low-permeability synthetic membrane cap.
Under this alternative, a RCRA landfill closure would be
implemented for the site. The cap would cover an area of
approximately 3 acres. The surface and subsurface soils
containinq lead above the 1,000 mq/kq tarqet action level for
this ROD (approximately 11,700 C.Y.) and the drainaqe ditch
sediments (approximately 350 C.Y.) would be excavated and placed
in the area to be capped. In addition, the onsite soils
(9,400 C.Y.), above the 120 mq/kq level (used to represent Site
backqround levels) and located outside o( the area to be capped,
would be consolidated with the other soils in the area to be
capped. The desiqn objectives of the cap would be to minimize
miqration of water throuqh the cap into the contaminated
materials and to prevent direct exposure to the soils. This
alternative would reduce the risks outlined in Section VI to
11
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below the established risk range (10'10 to 10.6).
take approximately 3 months to implement.
The cap would
Alternat~ve 4: On.ite Treatment - 1.000 malka Action Level. Soil
Cover OVer Res~dual contam~on. Removal and Treatment of Ni-
Cad Batteries.
Alternative 4a: stabililation 1,000
Offsite Disposal in sanitary/Industrial
Cover OVer Residual contaaination
mq/kq
Waste
Action Level,
Landfill, Soil
This alternative involves excavating the surface and subsurface
soils, containing lead above the 1,000 mg/kq action level, and
sediments above their action levels, treating them with a
stabilization process, and then disposing of the soils in an
offsite landfill. Approximately 36,800 cubic yards of soil
(includes surface and subsurface soils, sediments, and debris\
piles) would be excavated and stabilized using a cement/pozzolan-
based or similar stabilization technology. A local industrial
~aste (or sanitary) landfill or an offsite RCRA-approved
hazardous waste landfill would be used to dispose of, the treated
soil. Under this alternative, a RCRA clean closure would be
implemented for the former acid pond area. For the residual
contaminated soil between 120 mg/kg(Site background) and
1,000 mg/kg lead, located outside of the former acid pond area, a
hybrid closure would be implemented which would consist of
placement of a layer of topsoil (approximately 6 inch) after
backfilling with clean- fill followed' by revegetation. These
soils would not be disturbed during implementation of the hybrid
closure. This alternative will reduce the risks at the site to
below 10.4 to 10.6 risk (the established risk range). This
alternative would take 6 to 18 months-to implement.
Alternative 4b: soil Wa8hinq - 1,000 mq/kq Action Level, onsite
Nonhalardou8 Di8posal, Soil Cover OVer Residual contamination
This alternative involves excavating and treating the surface and
subsurface soils, which contain lead above the 1,000 mg/kg action
12
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level, and sediments above their action levels, us ing a soil
washing technology and disposing them on site into their
respective excavated areas. Approximately 36,800 cubic yards of
soil (includes surface and subsurface soils, sediments, and
debris piles) would be excavated and treated to the 120 mg/kg
level (as a minimum) in a soil washing unit using an acid
solution. Under this alternative, a RCRA clean closure would be
implemented for the former acid pond area. For the residual
contaminated soil, located outside of the former acid pond area,
a hybrid closure would be implemented which would consist of
placement of a layer of topsoil (approximately 6 inch) after
backfilling with clean fill followed by revegetation. These
soils would not be disturbed during implementation of the hybrid
closure. This alternative will reduce risks to below the
established risk range and would take 6 to 18 months to
implement. (excluding pilot-scale testing)
Alternative 4c: In situ vitrification - 1,000 mq/kq Action
Level, 80il Cover Over Residual contamination
Approximately 36,800 cubic yards of soil and sediment above
action levels (includes surface and subsurface soils, sediments,
and debris piles) would be vitrified in-situ. The soils would be
vitrified using a grid of electrodes placed into the ground.
After one area is vitrified, the electrodes are moved to the next
grid to repeat the process. To achieve efficient vitrification,
some staging and consolidation of the soils would be required.
This would involve excavation of contaminated surface and
subsurface soils in some of the outer areas (approximately
6,900 C.Y.) followed by placement of the soils on top of the soil
areas to be vitrified. Under this alternative, a RCRA clean
. -
closure would be implemented for the former acid pond area. For
the residual contaminated soil, located' outside of the former
acid pond area, a hybrid closure would be implemented which would
consist of placement of a layer of topsoil (approximately 6 inch)
after backfilling with clean fill followed by revegetation.
These soils would not be disturbed during implementation of the
13
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hybrid closure. This alternative will reduce risks from the Site
to below the established risk range and is estimated 'to take 8 to
30 months to implement. '
Alternat;ve 5: Onsite Treatment - 1.000 mq/kc:r Action Level.
Offsite Disoosal of Residual contamination in Sanitary/Industrial
Waste Landfill. Removal and Treatment of Hi-Cad Batteries.
Alternatives Sa, 5b, and 5c are identical to Alternatives 4a, 4b,
and 4c, respectively, except for the manner in which the residual
contaminated soils are handled. Under Alternative 5, the
residual contaminated soils, containing lead above the 120 mg/kg
level and below the 1,000 mg/kg action level, would be
transported to a local sanitary or industrial waste landfill for
disposal rather than contained on site under a cover, as included
in Alternative 4. Thus, under Alternative 5, a clean closure
would be implemented for the C&R Battery Site, rather than a
landfill closure as included in Alternative 4. These
alternatives will reduce site risks to below the established
range of 10.4 ,to 10'6 risks.
. Alternative Sa: stabili.ation- 1,000 mq/kq Action Level,
Offsite Disposal in sanitary/Industrial Waste Landfill, Offsite
Dispo.al of Re.idual Contaaination in sanitary/Industrial wast.
Landfill
This alternative involves excavating the surface and subsurface
soils, containing lead above the 120 mg/kg level, treating the
soils which contain lead above the 1,000 mg/kg action level and
the sediments above action levels with a stabilization process,
and then disposing all of the soils in an offsite landfill.
Approximately 36,800 cubic yards of soil (includes surface and
subsurface soils, sediments, and debris piles) would be excavated
and stabilized using a cement/pozzolan-based or similar
stabilization technology. An industrial waste (or sanitary)
landfill or an offsite RCRA-approved hazardous waste landfill
would be used to dispose of both treated and untreated soil.
Under this alternative, a RCRA clean closure would be implemented
14
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for the Site. this alternative would take approximately 6 to 18
months to implement.
Alternative 5b: Soil Washinq - 1,000 mq/kq Action Level, Onsite
Nonhazardous Disposal,. Offsite Disposal of Residual contamination
in sanitary/Industrial Waste Landfill
This alternativ. involves excavatinq the surface and subsurface
soils which contain lead above the 1,000 mq/kq action level, and
sediments above thier action levels, treating them usinq a soil
washing technology, and disposing them on. site into their
respective excavated areas. Approximately 80,300 cubic yards of
soil (includes surface and subsurface soils, sediments, and
debris piles) would be excavated and treated to the 120 mq/kq
level (as a minimum) in a soil washing unit usinq an acid
solution. The residual contaminated s011 (approximately
43,500 C.Y.), which contains lead above the 120 mq/kq level
(backqround) and below the 1,000 mq/kq action level, would be
excavated and transported to a local sanitary or industrial waste
landfill for disposal. Under this alternative, a RCRA clean
closure would be implemented for the site. This alternative
would take 6to 18 months to implement~ (excluding pilot-scale
testing)
AlteZ'D.~iv. 5e: In .itu vitrification -
Level, Off.it. Di.po..l of Residual
sani~ary/In4u.~rial .a.~e Landfill
1,000 mq/kq Action
Con~amination in
Approximately 36,800 cubic yards (1,000 mg/kq action level) of
soil ( includes surface and ..sUbsurface soils, sediments above
their action levels, and debris piles) would be vitrified in-
situ. Under this alternative, a RCRA landfill closure would be
implemented for the Site. The vitrified material would serve as,
an impermeable cap for the RCRA unit. The residual con~aminated
soil (approximately 43,500 C.Y.), which contains lead above the
120 mg/kq level and below the 1,000 mg/kq action level, would be
15
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excavated and transported to a local sanitary or industrial waste
landfill.
The soils would be vitrified using a grid of electrodes placed
into the ground. After one area is vitrified, the electrodes are
moved to the next grid to repeat the process. To achieve
efficient vitrification, some staging and consolidation of soils
would be required. This would involve excavation of contaminated
surface and sUbsurface soils in some of the outer areas
(approximately 6,900 C.Y.) followed by placement of the soils on
top of the soil areas to be vitrified. The excavated areas would
be filled in using clean fill. This alternative would take 8 to
30 months to implement.
IX.
COXPARATIVB ANALYSIS O~ ALTERNATIVES
The eight remedial action alternatives described above were
. .
evaluated under the nine evaluation criteria in the NCP 40 C.F.R.
Part 300.430 (e) (9) as set forth in "Guidance for conducting
Remedial Investigations and Feasibility Studies under CERCLA"
(EPA, October 1988), EPA Directive 9355.3-02 "Draft Guidance on
Preparing Superfund Decision Documents: The Proposed Plan and
Record of Decision," and "Guidance on Preparing Superfund
Decision Documents: The Proposed Plan~ The Record of Decision,
Explanation of Significant Differences, and the Record of
Decision Amendment" (EPA/540/6-89/007), July 1989 Interim Final.
These nine criteria can be further categorized into three groups:
threshold criteria, primary balancing criteria, and modifying
criteria.
Threshold criteria
. Overall protection of human health and the environment
. Compliance with applicable or relevant and appropriate
requirements (ARARs)
16
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PrimarY Balancina criteria
. Reduction of toxicity, . mobility,
treatment
. Implementability
. Short-term effectiveness
. Lonq-term effectiveness
. Cost
or
volume
through
Modifvina criteria
. Community acceptance
. State acceptance
These evaluation criteria relate directly to requirements in
section 121 of CERCLA, 42 U.S.C. section 9621, which measure the
overall feasibility and acceptability of the remedy. Threshold
criteria must be satisfied in order for a remedy to be eligible
for selection. Primary balancing criteria are used to weigh
major trade-offs between remedies. State and community
acceptance are modifying criteria formally taken into account
after public comment is received on the Proposed Plan: The
evaluations are as follows:-
1)
protection of the Huaan 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 under the established risk range posed by each
exposure pathway at the Site.
Stabilization. Soil Washina. and In-Situ Vitrification
The remedies which employ either soil washinq, stabilization, or
in-situ vitrification would achieve all remedial action
17
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objectives. . Public and environmental risks from inhalation,
ingestion, and dermal contact would be mitigated. Excavation and
treatment could potentially present short-term public health
risks from dust generation. These risks would be evaluated using
an air monitoring program. Appropriate site use restriction will
be placed to ensure protection of the public health and the
environment.
No Action
The no-action alternative does not achieve any of the three
remedial action goals and, therefore, would continue to present
an unacceptable risk to human health and the environment. No
provisions would be made to treat wastes or to control offsite
migration of soils and sediments. Based on this determination,
the no~action alternative will not be subjected to further
evaluation.
RCRA caccincr
Although the RCRA capping alternative would achieve all three
remedial action objectives, it would not comply with the goal of
section 121 of CERCLA, 42 U.S.C. Section 9621, to permanently-
reduce the volume, toxicity, or mobility of the contaminants at
the site.
2) C08Dlianc8 with A~Dlicab18
Recruir_8Dta
or
R8levaDt
aDd Aoorooriate
Under section 121(d) of CERCLA, 42 U.S.C. Section 9621(d), and
EPA guidance, remedial actions at CERCLA sites must attain
legally applicable or relevant and appropriate Federal and state
environmental standards, requirements, criteria, and limitations
(which are collectively referred to as "ARARs"). Applicable
requirements are those substantive environmental p~otection
requirements, criteria, or limitations promulgated under Federal
18
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or state la~ that specifically address hazardous material found
at the Site, the remedial action to be implemented at the Site,
the location of the Site, or other circumstances at the Site.
Relevant and appropriate requirements are those substantive
environmental protection requirements, criteria, or limitations
promulgated under Federal or state law which, while not
applicable to the hazardous materials at the Site, the remedial.
action, site location, or other circumstances, nevertheless
address problems or situations sUfficiently ~imilar to those
encountered at the site that their use is well suited to that
site.
The ARARs and other nonpromulgated advisories and- guidances
issued by Federal, state, and local governments ("To-Be-
Considered") for the Remedial Action are discussed below.
Resource Conservation and Recoverv Act (40 CFR Parts 261-270)
RCRA requlates the generation, transportation, treatment,
storage, and disposal of hazardous wastes. Hazardous substances,
pollutants,. and contaminants found at CERCLA sites may be
hazardous wastes as defined by RCRA and may trigger RCRA
requirements if they are RCRA-listed wastes (40 CFR Part 261,
Subpart C) or if such substances exhibit certain physical
characteristics (40 CFR Part 261, Subpart C). EPA has determined
that some of the soils and sediments found during the Remedial
Investigation are characteristic hazardous wastes by use of the
Extraction Procedure Toxicity (EP Tox) test for lead. As a
result, RCRA is applicable to the former acid pond area where the
wastes were actively managed. Portions of RCRA may be relevant
and appropriate to the soils and sediments located outside of
this area and are further discussed below.
RCRA Subtitle C Closure Reauirements
Excavation, consolidation, or other active management action!
that move RCRA hazardous wastes so as to constitute disposal of
19
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such wastes .will trigger closure requirements for the unit into
which the wastes are placed. RCRA closure requirements 40 CFR
Part 264 ,Subpart G will be achieved for the former acid pond
area by removing all soils whose leachate exceeds the appropriate
leaching procedure (i.e., EP Tox). For the residual
contamination located outside the former acid pond area, EPA has
determined that RCRA (40 CFR Part 264, Subpart G) is relevant and
appropriate, and a hybrid closure (soil cover) will be
implemented to satisfy closure requirements.
Land Dis90sal Restrictions
The 1984 amendments to RCRA (HSWA), 40 CFR 268 establish
schedules for promulgation of regulations restricting land
disposal of hazardous wastes. Treatment standards for
characteristic wastes will be established in May 1990. All o~
the excavated soils which are subsequently treated will attainn
these standards. If these standards cannot be met, a soil and
debris treatability .variance will be considered. The
Treatability Variance levels for site contaminants are listed in
Table 5.
Clean Water Act
The Clean Water Act (and Virginia) require 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 tha~ any discharge to a
publicly owned treatment works (POTW) meet Federal pretreatment
standards. only the soil washing alternative would generate a
waste water stream. The water generated would be of sufficient
quality (i.e., would meet any NPDES standards) to be discharged
directly to the James River via a drainage ditch. Any onsite
surface water discharge will comply with the substantive
requirements of both the Clean Water ~ct and Virginia NPDES
Standards (NPDES requirements 40 CFR Part 122 and Virginia Water
Quality Standards VR 680-21-00.)
20
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TABLE 5
AL TERNA 1'£ TREA TABIUTY VARIANCE lEVELS FOR SOIL/DEBRIS(1)
C&R BATTERY SITE
CHESTERFfELO COUNTY, VIRGINIA
Concentration Thresnojct . Percent ReduCtion
Indicator Contaminants Concentration
Range(2) (ppm)(J) Rangel])
Anti mony O. '-0.2 2 90-99
Arsenic 0.27-1 16 90-99.9
Cadmium 0.2-2 40 95-99.9
Lead 0.1-3 300 99-99.9
Nicke' 0.5.1 20 95.99.9
(I) From: Superlund LOR Guide 16A, Directive 9347.3.06F5.
(2) Conclntration in TCI.P extract
(3) if tne contaminant concentration in tne untreated soil/debris is greater tnan tne tnresnold
concentration, tnen tn. soil/debris nHd only ~ trllted to tn. minimum 01 tne perc.nt r~uCtion '~jJ
rang..
-------
Clean Air Act/V~a Air Pollution Reaulations
The Federal Clean Air Act National Ambient Air Quality Standards
(NAAQS) (40 CFR Part 50) and New Source Performance Standards
(40 CFR Part 60) and the Virginia Air Pollution Regulations
(Chapter 120, Parts I-VIII) identify and regulate pollutants that
could possibly be released during the course of remediation. For
alternatives involving the excavation ot soils and sediments, air
monitoring will be required to ensure compliance with Federal and
Virginia air emission regulations.
OccuDational Safety and Health Administration Act (OSHA)
During remedial action a health and safety program. for onsite
workers will be implemented to comply with OSHA requirements
(29 CFR Parts 1910, 1926, and 1904).
ViraiDja Erosion and Sediment Control Law
Alternatives which involve
Virginia Erosion and Sediment
21-89.1 et. seq..
excavation must comply with the
Control Law, Virginia Code section
Criteria for Offsite DisDosal
Alternatives involving stabilization will involve offsite
disposal of the st~ilized material. This disposal will be
performed in accordance with the requirements of RCRA
(40 CFR Part 241) and state regulations (VR 672-20-10) for
sanitary/industrial waste landfills. EPA's offsite disposal
policy (outlined in a 11-13-87 OSWER memo) will also be followed
for hazardous wastes and hazardous substances. This disposal
must also comply with the requirements for RCRA hazardous waste
generator and transportation regulations (40 CFR Parts 262 and
263) and with Federal (49 CFR Parts 107, 171-179) and state
Department of Transportation regulations. If untre~ted soils are
21
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transported to a treatment facility for stabilization, the
facility must comply with RCRA (40 CFR Parts 264, 265~and 270)
and state treatment, storage, and disposal facility (T~DF)
operating standards.
Onsite Treatment
Alternatives 4 (a), (b), (c) and 5 (a), (b), (c) may involve
onsite treatment.- of contaminated material. . This treatment will
comply with RCRA and state TSDF operating standards.
Endanaered Scecies Act of 1978. Fish and Wildlife Coordination
Act. Fish and wildlife Imcrovement Act of 1978. and Fish and
Wildlife Conservation Act of 1980
Alternatives which involve
discharge must comply with the
acts.
excavation and/or surface water
standards set forth in these four
....
criteria. Adv~ies. or Guidance to be Considered
The action levels for contaminants in soil and sediments
obtained from the following advisory levels.
were
. EPA-established cleanup level of 500-1, 000 mg/~g for lead
for residential areas. The 1,000 mg/kg lead level was
chosen as the action level since the Site is located in an
industrial area and is not frequented by children.
. EPA-established Reference Doses (RFDs)
risk-based cleanup levels for inorganics.
used to develop
. EPA-established carcinogenic potency. factors
develop risk-based cleanup levels for arsenic.
used
to
22
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II
Reduction of Toxicitv. Mobili'tv. or Volume
This evaluation criteria addresses the degree to which a
technology or remedial alternative reduces toxicity, mobility, or
volume of hazardous substance. Section 121 (b) of
CERCLA, 42 U.S.C. section 9621 (b), establishes a preference for
remedial actions that permanently and. significantly reduce the
toxicity, mobility, or volume of hazardous substances over
remedial actions which~will not result in such reduction.
Stabilization. Soil Washina. In-situ Vitrification
All three technologies would significantly and permanently reduce
. the mobility of the contaminants. Soil washing would -also
permanently reduce the toxicity of the contaminants by removing
the contaminants from the matrix. vitrification would achieve ~.
higher reduction in mobility and toxicity of contaminants than
would stabilization. Both soil washing and vitrification would
reduce the volume (10-30 percent) of the contaminated material
while solidification would increase the volume of the material by.o.
approximately 100 percent.
RCRA Caccina
The RCRA capping alternative would not reduce the mobility,
toxicity, or volume of the contamination.
4)
ImDl..eDta):)ilit~
Stabilization. Soil Washina. In-situ vitrification
The stabilization technology has been the most widely implemented
process of the three technologies. It also utilizes equipment
which is widely available and simplest to operate. The offgas
and effluent treatment requirements for stabilization are not as
extensive as with the other . technologies. Vitrification is
considered to be an innovative technology and may require more
23
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sophisticated equipment. and. highly skilled operators. Since
vitrification would be done in situ, much less ~aterial handlin9
would be required with this technol?gy than with the others.
Soil washing would require very complex equipment. Since there
are no mobile soil washing systems available that .can handle
strong acids, a treatment plant would most likely' have to be
constructed at the Site. Both soil washing and vitrification
would also require. pilot scale. treatability testing to better
assess implementability.
RCRA Caccinq
The technologies associated wi th RCRA
demonstrated and can be implemented readily.
capping
are
well
.5)
Short-T8ra Itt8ctiv8n8.8
Short-term effectiveness addresses the period of time needed to 1
achieve protection ot human health and the environment and any
adverse impacts that may be posed during the construction and'
operation period until cleanup' goals are achieved.
Alternatives involving excavation and subsequent management of
contaminated soils through treatment would present the greatest
opportunity tor exposure .to contaminants by onsite workers.
Protective measures including use of protective clothing for Site
workers, dust control, and air monitoring will minimize the
impact to Site workers and surrounding areas. Groundwater
monitoring will be included in all alternatives. .
St3bilization. Soil Washina. In-situ Vitr~ication
Stabilization could be implemented in the shortest period of
time. Soil washing could also be implemented in a similar time
trame as solidification but would necessitate an additional
period of approximately 6 months for pilot-scale testing prior to
actual implementation. Vitrification would take the longest
24
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amount of time to implement with regard to the protection of
workers, community, and the environment during remedial
activities. Stabilization would present the lowest risk to these
receptors as the amount of hazardous chemicals and the quantity
of effluent discharged would be the lowest of the three treatment
alternatives. The soil washing alternative uses strong acids
which are dangerous to handle and could potentially release toxic
substances to the air and surface water if a spill occurred or
the equipment malfunctioned. The vitrification process generate~
aqueous and gaseous effluents and could present a danger if
the system fails.
RCRA caccincr
RCRA capping could be implemented in a relatively short period of
time but would not utilize any treatment.
!.l.
Lona-Tera Effectiveness
Long-term effecti veness and permanence addresses the long-term
protection of human health and the environment once remedial.
action cleanup goals have been achieved, and focuses on residual
risk that will remain after completion of the remedial action.
RCRA Caccina
The RCRA capping alternative provides a low degree of long-term
effectiveness, permanence, and r~sk reduction, since wastes will
be contained. Frequent inspection and maintenance of the cap
would be required. Long-term groundwater mo.nitoring would be
necessary to verify that groundwater is not contaminated by the
wastes which are left in place. Deed restrictions would be
necessary to prevent disturbance of the cap.
25
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Stabil~ion. Soil Washina. In-situ Vitrification
soil washing will permanently remove the contaminants from the
soil and sediments. Vitrification would create a glass-like
product whi~h would be more resistant to physical/chemical
deteriorization than the matrix created by stabilization.
7)
Cost
CERCLA requires selection of a cost-effective remedy (not merely
the lowest cost) that protects human health and the environment
and meets the other requirements of the statute. Project costs
include 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
summariz~d in Table 6. Capital costs include those expenditures
necessary to implement a remedial action. Annual operating costs
are included in the present-worth cost.
The costs of the eight alternatives range from $265,000 to
- .
$35,720,000. The degree of protection provided by the
alternatives also varies. Comparison of different levels of
costs for different levels of protectiveness and permanence of
treatment is a primary decision criteria in the cost-
effectiveness evaluation.
The RCRA capping alternative, although low in cost, is less
protective and does not provide permanent treatment as does other
alternative., and. is therefore not considered cost effective.
The stabilization alternative is the next lowest in cost and
provides 97 percent removal of. contaminants treated. The
remaining alternatives would increase cost significantly while
providing a similar level of _protection (for example,
alternatives involving soil washing would increase costs by
approximate~y 100 percent, when compared to stabilization, while
also providing 97 percent ,removal of contaminants treated).
26
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T 4BlE 6
COST SUMMARY fOM REMEDIAL Al TERNA JIVES
C&R BATTERY SITE
CHESTERfiELD COUNTY. VIRGINIA
Alternative Alternative Title Capital Cost O&M Cost Present-Worth Cost
Number ($I,OOOs) ($I,OOOs) ($ I,OOOs)
1 No Action 0 13.6 annually 265
20 every 5 years
2 RCRA Cap - 120 mglkg Action level 2,351 18.6 annually 2,698
20 every 5 years
4 Onsite Treatment - 1.000 mglkg Action level, Soil Cover
Over Residual Contamination (untreated soil> 120
mglkg) "
4a Stabilization, Offs;te Disposal in Sanitary/Industrial 15,292 14.6 annually 15,5j2
Waste landfill 20 every 5 years
,
4b Soil Washing, Ons;te Nonhazardous Disposal 30,380 14.6 annually 30,660
20 every 5 years
4c In-s;tu Vitrification 22.111 14.6 annually 23,051 .
20 every 5 years
5 Onsite Treatment - 1.000 mglkg Action level, Offs;te
Disposal of Residual Contamination (untreated
soil> 120 mglkg) in Sanitary/lndustrialWaste landfill
5a Stabilization, Offs;te Disposal in Sanitary/Industrial 20.642 20 every 5 yearsC I) 20,697
Waste landfill I
5b Soil Washing, Onsite Nonhazardous Disposal 35,665 20 every 5 years( 1) 35,720
5c In-s;tu Vitrification 29,058 14.6 annually 29,339
20 every 5 years
(I) May not be required because a clean closure would be implemented.
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8)
community AcceDtanc.'
A public meeting on the Proposed Plan was held February 7, 1990
in Chesterfield county, Virginia. Comments received from the
public at that meeting and during the comment period are
referenced in the Responsiveness summary attached to this Record
of Decision.
9)
state Acceatance
The Commonwealth. of virginia has concurred with this selected
Remedial Action.
x.
SBLBCTBD REXBDY
Alternative 4a: stabililatioD 1,000 mq/kq ActioD Level,
Offsite Disposal in sanitary/Industrial waste Landfill, Soil
Cover Over Residual contaainatioD .
Based on the findings in the RI/FS and the nine criteria listed
above, the USEPA has selected Alternative 4(a). In the judgement
of EPA, Alternative 4 (a) represents the best balance among the
evaluation criteria and satisfies the statutory requirements of
protectiveness, compliance with ARARs, cost effectiveness, and
the utilization ot permanent solutions and treatment to the
maximum extent possible.
This alternative involves excavating the surface and subsurface
soils containing lead above the 1,000 mq/kq action level,
treating them with a cement/pozzo1an-based or similar
stabilization process, and then disposing of the soils in an
offsite landfill. A local. industrial waste (or sanitary)
landfill or an offsite RCRA-approved hazardous waste landfill
would be used to dispose of the treated soil. Under this
alternative, a hybrid closure (soil cover) would be implemented
for the residual contamination (soil above 120 mq/kg lead)
27
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outside of the acid pond area. For the acid pond area, a RCRA
clean closure would be implemented. Analyses 'of the seven
evaluation criteria' for the two disposal options (sanitary and
hazardous waste landfill disposal) are very similar and to avoid
redundancy, only factors which differ between the two options
will be highlighted.
Approximately 36,800 cubic yards. of soil (includes surface and
subsurface soils, sediments, and debris piles) would be excavated
and stabilized using a cement/pozzolan-based or s{milar
stabilization technology. Based on the results of the
treatability study conducted by Hazcon, 1989, the stabilization
mixture that meets the EP toxicity criteria and produces the
smallest percent volume increase consists of a 1:0.6:0.03
soil/cement/sodium silicate ratio (by weight). The stabilization
blend ratio could be optimized further durinq the remedial
design. The use of sodium silicate, and other soluble silicates,
in the stabilization process is currently patented (U.S. Patent
3,837,872) by Chemfix Technologies, Inc. until September, 1991.
Excavation of the subsurface soil in the area located adjacent to
the southeast corner of the former facility will require
dismantlinq the existinqstorage shed located in that area.
Dismantled material would be transported to a local sanitary or
construction/demolition/debris. landfill. Excavation of onsite'
surface and subsurface soil will require demolition/excavation of
the existinq concrete pad (approximately 150 feet by 150 feet) in
the southern portion ot the site. The demolished concrete slabs
. .
( 833 C. 'i . ) would then be transported to a local sani tary or
construction/demolition/debris landfill for disposal. In
addition to the concrete pad, the old tires present on Site and
in adjacent offsite areas, as well as any other miscellaneous
debris, would be disposed in a sanitary landfill prior to
excavation of the soils.
The Ni/Cd batteries present at the site (approximately 350) could
potentially be transported to..an offsi.te recyclinq facility where
28
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they would then be shipped offsite and recycled into their nickel
and cadmium components. However, for costing purposes, it is
. assumed that the Ni/Cd batteries would be treated at an offsite
RCRA-approved hazardous waste treatment facility prior to
disposal in an offsite RCRA-approved hazardous waste disposal
facility. The cost of this option is slightly higher than the
recycling option. The batteries would not need to be drained but'
would most likely need ~o be packed in drums prior to shipment.
At the treatment facility, the Ni/Cd batteries would be broken
open and drained. The b.attery fluid would be treated using a
hydrolysis process. The Ni/Cd plates would be transported to a
RCRA-approved hazardous' waste disposal facility. The plastic
battery casings would be either sent to a recycling facility or
disposed along with the Ni/Cd plates.
Any surface water present on site in the drainage ditch would be
drained prior to excavation of the sediments. . The drained water
could possibly be pumped onto the site and allowed to evaporate
(if it complies with Land Disposal Restrictions) or could be
pumped into tanker trucks and transported to an offsite RCRA-
approved treatment facility if necessary. For costing purposes,
it will be assumed that any surface water will. be pumped into
tanker trucks and transported to a RCRA-permitted hazardous waste
treatment facility. Following excavation of the sediments, the
onsite drainage ditch (1,250 feet) would be left in place to
allow water that collects in the roadside ditch, along the
southern boundary of the site, to flow through the Site to the
James River. .
A pug. mill would most likely be used to mix the stabilizing
reagents with the contaminated soil in a continuous or batch
operation. Prior to the addition and mixing of the stabilizing
reagents, the soil would be screened first to remove any large
rocks, soil clumps, battery casing fragments, and any other
debris. The oversized material would then. be fed to a
crusher/shredder chamber followed by another screening. stage.
This pretreatment stage would ensure optimal contact of the
29
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contaminants with the stabilizing reagents and better product
.
uniformity. For this alternative, it is assumed that the
shredded battery casing fragments would be mixed in and
stabilized with the soil, which would be the most cost-effective
remedial action for the casings.
other remedial options for the screened battery casings include
offsite incineration and acid washing in an offsite RCRA
treatment facility. followed by' offsite disposal. An analysis
will be completed during Remedial Design to identify the most
appropriate and cost-effective option.
The soil would be stabilized either on Site or at a landfill.
Since a sanitary landfill cannot accept a hazardous waste,
material going to a sanitary landfill would. require onsite
treatment to eliminate the characteristic prior to transportation
to the ~anitary landfill. The volume of soils for hauling and
disposal would increase approximately 100 percent: 20 percent due
to. excavation and 80 percent due to the stabilization process,
thus increasing the total soil volume to 73,600 cubic. yards.
Because a RCRA-approved hazardous waste landfill can accept
hazardous wastes, untreated soils could potentially be loaded
onto trucks, hauled in bulk shipments to an offsite hazardous
waste landfill, and then stabilized at the landfill prior to
disposal. The volume of subsurface soils for hauling would
increase by 20 percent due to swelling during excavation, and
another 80 percent upon stabilization. Stabilization of the
soiis at the landfill would most likely be the more cost-
effective approach because less material would be transported.
For costing purposes, however, the onsite treatment scenario will
be used.
Once the area of the former acid pond has been excavated to
1,000 mg/kg, a representative number of samples of the remaining
soil will be tested using an appropriate leach test (TCLP) to
satisfy regulatory requirements. If the soil still exhibits
characteristics of hazardous waste the area will be further
30
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evaluated to determine the appropriate. additional actions to be
taken in order that a clean closure may be implemented for the
area.
For. the residual contaminated soil containing lead between the
120 mg/kg and the 1,000 mg/kg action level, a hybrid closure
would be implemented, which - would consist of backfilling .with
clean soil and. placement of a layer of topsoil. (approximately
6 inches) followed by revegetation. _These soils would not be
disturbed during implementation of the hybrid closure.
As in Alternative 1, periodic groundwater monitoring would be
conducted throughout the area of potential groundwater
contamination for this alternative. As required by Virginia
(VR 672-10-1, Part X) and RCRA (40 CFR Part 264, Subparts G,F),
. .
four new monitoring wells would be installed (one upgradient and
three downgradient) to evaluate migration of contaminants from
. .
subsurface soils to groundwater. A quarterly sampling frequency
is required for the first year and semi-annual sampling for the
followinq years. This samplinq will continue until at least the
.first 5-year review of the site. A monitorinq program including
. chemistry and toxicity testinq will be implemented to monitor
short- and l?nq-term impacts of the remedial action on the
surface water and sediments in the drainaqe ditch as well as to
evaluate oftsite transport of contaminants via the drainage ditch
to the James River. The monitorinq will assure that the remedy
will be effective in controllinq releases and will be protective
of the aquatic environment. Appropriate site use restrictions
will be placed to ensure protection of human health and the
environment in the future.
Short-term Effectiveness
Dust may be generated durinq excavation and handlinq. activities.
Dust control procedures would be required. Perimeter air
monitorinq may be needed to determine whether steps are needed to
protect the community from adverse air. emissions.
31
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Workers will be required to wear protective respiratory equipment
(i.e., dust mask) during activities where they may be exposed to
hazardous materials. Air monitoring could be performed in work
areas to monitor the breathing zone if required.
Because this alternative may involve offsite transportation of
untreated soils, there is a potential expos.ure - risk to the
community if a spill occurred as a result of a transportation
accident. The major exposure route associated with the soils is
ingestion, however. Thus, there would be minimal health risks
posed by a spill of this material through dermal contact or
inhalation, which are the most likely exposure routes associated
with a spill. Furthermore, any spilled material could be
relatively easily controlled and cleaned up compared .to a spill
of liquid or gaseous wastes.
Once the onsite remedial activities begin, stabilization and
transportation of the treated soils to the sanitary/industrial
waste landfill and covering of the residual contamination would
take approximately 1 year, during which time the risks previously
'identified would be presept at the site.
Lona-term Effectiveness
Because soils containing lead above the risk-based 1,000 mg/kg
action level would be stabilized and removed from the Site, there
would be no remaining long-term risks at the site, associated
with these soils, to human health or to the environment upon
completion of remedial actions. Furthermore, installation of the
soil cover would eliminate the direct exposure route to residual
contamination (soil containing lead above 120 mg/kg but below
1,000 mg/kg). Therefore, no risks would be anticipated if long-
term management, considerations mainly include periodic
inspection and maintenance of the soil cover, is, maintained.
If the disposal facility receiving the soils is properly designed
32
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and operated according to RCRA and state regulations for-
industrial waste/sanitary or hazardous waste disposal facilities,
the long-term risks posed by disposal of these items in an
offsite landfill should be minimized.
since the leachate generated by a sanitary landfill is typically
acidic (pH of about 5.0), if the- stabilized soils are placed in a
sanitary landfill and are allowed to come into contact with the
. .~. *
other municipal waste, the acidic environment would accelerate
the breakdown of. the stabilized material which would in turn
increase the mobility of the contaminants. Degradation of the
stabilized material could be minimized by placing it in a
separate cell in the landfill (preferably a top cell) where the
material would be fully enclosed by a clay/soil liner. The
environment in an industrial waste or hazar.dous waste landfill
could also be acidic, depending on the type of wastes placed i~
the cell, and therefore the use of a separate cell would also
maximize long-term effectiveness..
Reduction of Toxicitv. MobilitV. or Volume.'
With respect to the C&R Battery Site, this alternative provides a
permanent remedial action which reduces the overall toxicity and
volume of contamination at the Site by completely. removing the
soils, which contain lead above the 1,000 mg/kg action level, and
sediments containinq levels of contaminants exceeding their
action level, from the site (approximately 36,800 cubic yards).
Approximately 97 percent of the' total lead (above background
levels) would be removed from the site. In addition, the
mobility of the contaminants in the soil would be substantially
reduced by the stabilization process as well as by placement in a
lined landfill with a leachate detection and collection/treatment
system. With reqard to the volume of contaminated soils, . this
alternative would not reduce the volume of soils and would
actually increase the volume of material by appr~ximately
100 percent. If the lapdfill is properly maintained over time,
stabilization of the soils followed by disposal in an offsite
33
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landfill
would
provide
a
permanent,
irreversible
form' of
treatment.
Residuals remaining on site mainly include the residual
contaminated soils, which contain lead above the 120 mg/kg but
below the 1,000 mg/kg action level. Installation of the soil
cover-would reduce the mobility of the residual contaminants by
controlling erosion due to wind and surface water runoff. other
residuals r~maining after remedial activities include
decontamination. fluids. For costing purposes, it will be assumed
that all contaminated water, generated during onsite activities,
will be collected and transported to an offsite facility for
treatment and disposal.
Imclementabilitv.
The technologies proposed for excavation, material handling,
stabilization, and offsite landfilling are demonstrated and
commercially available. There are currently no RCRA-permi tted
hazardous waste landfills in the Commonwealth of Virginia.
Because some states may restrict the importation of hazardous
waste for disposal, the availability of RCRA-permitted hazardous
waste landfills may be limited. Two landfills hav~ indicated
that they could potentially stabilize and dispose of the soils at
their facility. A RCRA-permitted hazardous waste landfill that
could potentially accept the soil is located approximately
460 miles away in Model City, New York. The nearest industrial
waste/sanitary landfill that could potentially accept the treated
soil is located about 15 miles away but within Chesterfield
county, Virginia. Typically, in the Commonwealth of Virginia, a
sanitary landfill will only accept waste from the county in which
it is located. Therefore, if a landfill in Chesterfield County
is unable to accept the treated soil, the material may have to be
transported to either an industrial/sanitary or hazardous waste
. .
landfill out of state. An industrial/sanitary landfill in the
Commonwealth of Virginia may receive the stabilized soil only
with specific approval of the Executive Director or by specific
34
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provisions within the facility permit.
A staging area would be required to set up any equipment and
store any supplies needed to treat the soils as well as to
stockpile both treated and untre~ted soils. Allor part of the
staging" area would need to be located in an adjacent area
(approximately 4 acres), as space at. the C&R Battery site is
limited, due to its narrow geometry. Implementation of the
staging area would require access to this land, clearing of trees
and br1.:lsh, and installation of temporary diversion ditches and
fencing. site topography should not interfere with remedial
activities and all areas of the site are accessible.
Five-year Site reviews, pursuant to section 121(c) of CERCLA,
42 U.S.C. S 9621 (c), would be required to monitor the
effectiveness of this alternative. Hazardous waste generato;"
status for the site must be obtained, and the waste and treatment
residuals must be manifested and transported' by a licensed
hazardous waste transporter. The receiving disposal facility
must be also be RCRA permitted.
Cost
The estimated capital and annual operation and maintenance costs
for this alternative are summarized below. The present-worth
cost estimate is $15,572,000 for disposal of the treated soils in
an industrial waste/sanitary landfill.
capital Cost
($1.000s)
O&M Cost Present-Worth Cost
($1.000s) ($1.000s)
15,292(1)
(1)For disposal
waste/sanitary
14.6 (annually)
20 (every 5 years)
of treated soils in a local industrial
landfill.
15,572(1)
A more detailed breakdown of costs is presented in Table 7.
35
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TABLE 7
eSTIMATED COSTS OF SELECTED REMEDV
C&R BA TTERV SITE
CHESTERFIELD COUNTY, VIRGINIA
CAPtTAL COSTS
... -
Construction Component Quantity Unit Cost Estimated
Cost
,. Excavation, Site Clearing -- -- S 1 55.300
2. Building Dismantlement, Debris Disposal - - 157.000
3. Waste Soil Stabilization $44,113 cy(1) S71.67 $Icy 3,161.400
4. Stabilized Soil Disp~1 117,635 ton~ 38.03 Slton 4.473,100
5. Site Reclamation -- - 1.112,500
-
6. Ni/Cd 8attery Disposal -- - 37,100 '
7. Burden, Labor, Material - -- 881,000
8. Indirects, Profit, Health and Safety -- - 1,969,400
Monitoring
9. Contingency @ 20% - - 2,389.400
10. Engineering @ 8% - .- 955,800
Total Cipital Costs - -- S 15,292,000
OPERA T10N AND MAINTENANa COSTS
Operation and Maintenance Component Estimat~ Cost
1. Sampling and Analysis, Report (annual) S 12,550
2. Site Maint8nance (annual) 2,000
3. Analysis Review (8VIf'Y 5 yea,,) 20,000
TOTAL COST
Net PrtHnt Worth calculated using a S% discount value
S 15,572,000
(1) Indud8S volume increase during excavation
-------
Comoliance with ARARs
For the acid pond area, this alternative must comply with the
RCRA (40 CFR Part 264, Subpart G) and Virginia (VR 672-10-1,
Part 10.6) standards for clean closure. General performance
standards for clean closure (removal) require elimination of the
need for further maintenance and control... The closure 'must
eliminate post-closure escape of hazardous waste, hazardous waste
constituents, leachate, contaminated run-off, or hazardous waste
decomposition products.
For the soils not located in the former acid pond area, for which
.RCRA closure requirements are relevant and appropriate, a hybrid
closure will be implemented.
Post-closure use of the property must be restricted, as necessary
to prevent damage to the soil cover, to comply with VR 672-10-1,
Part X and 40 CFR Part 264, Subpart G. Groundwater monitoring'
for at l~ast 5-years will be done, to satisfy these regulations
(40 CFR Subpart F).
During site work, Clean Air Act and Virginia air emission
requirements (Virginia Air Pollution Regulations Chapter 120
Parts I to VIII) must be considered. The air standards most
applicable to the soils are National Ambient Air Quality (NAAQ)
standards (40 CFR Parts 50) for lead (lead emissions would be in
the form of particulate matter) and particulate matter. If these
limits are exceeded, dust suppressants must be applied to control
fugitive dust emissions.
Offsite trans~ortation of untreated soils must be done in
compliance with RCRA regulations applicable to generators and
transporters of hazardous wastes (40 CFR Parts 262 and 263) as
well as with Virginia regulations (VR 672-20-10, Part VII). In
addition, offsite transportation of the untreated soil mus~
comply with Federal (49 CFR Parts 107, 171-179) and Virginia
Hazardous Waste Management Regulations (VHWMR)' pertaining to
36
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transportation of hazardous materials.
If untreated soil, which is a RCRA hazardous waste, is
transported to a hazardous waste landfill for treatment and
disposal~ the facility receiving the soil must be in compli~nce
with RCRA (40 CFR Part 264) and VHWMR for owners and operators of
hazardous waste treatment, storage, and disposal facilities and
must be properly permitted (40 CFR Parts 265 and 270). .
If treated soil (or untreated soil which is not a hazardous
waste) is shipped to a sanitary or industrial waste landfill, the
facility receiving the soil must be in compliance with RCRA
(40 CFR Part 241) and Virginia Solid Waste Management Regulations
(VR 672-20-10) for sanitary and industrial waste landfills.
During the Remedial Design, an evaluation of the most co~t7'
effective method for stabilizing the soils (either on or off
Site) will be determined and the appropriate requirements
outlined above will be followed.
OSHA standards (29 CFR, Parts
standards governing worker
operations (29 CFR ~art 1910),
all site work.
1910, 1926, and 1904), especially
safety during hazardous waste
would have to be followed during
Overall Protection
This alternative would achieve remedial action objective number 1
by protecting the public health from current and future exposure
risks (ingestion and inhalation) associated with the soils. This
alternative would virtually eliminate the potential for migration
of lead and other indicator contaminants to groundwater (remedial
action objective number 2) and would eliminate migration of
contaminants to surface water and sediment (remedial action
objective number 3). This alternative complies with one ,of the
goals of CERCLA to utilize treatment that permanently reduces the
volume, toxicity, or mobility of the contaminants at the Site.
37
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XI.
RATIONALB FOR REMEDY SELECTION
This analysis focuses on EPA's rationale
Remedial Action over other alternatives.
for
selecting
the
Alternative 1:-
No Action
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 risks would still exist from site runoff, direct
exposure to the soils on Site and inhalation of fugitive dust.
The cleanup levels based on EPA quidance and criteria would not
be met since contaminants would receive no treatment. The no
action alternative would not permanently reduce the volume,
toxicity, or mobility of hazardous waste at the Site, and does
not utilize permanent treatment tec~nologies to the maximum
extent practicable as mandated by CERCIA. The Selected Remedial ,~'<
Action satisfies all of the above criteria.
Alternative 2:
RCD CaD
Alternative 2 includes installation of a, RCRA Cap over
contaminated areas. This alternative does not permanently and
significantly reduce the volume, toxicity, or mobility of
hazardous waste present at the site, and does not utilize
permanent treatment technologies to the maximum extent
practicable. containment using a cap for the entire Site
provides a low deqree of protection of human health and the
environment, permanence, and long-term effectiveness. Since
wastes will be contained, Alternative 2 will not afford the high
level of long-term projection provided by Alternative 4(a), which
. .
utilizes a more permanent treatment remedy.
38
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Alternat~v. 4Cb):
soil ..ashiner
Alternative 4 (b) involves the excavation of contaminated soil
with subsequent soil washing with a strong acid solution to
remove the contamination from the soil. This alternative would
require extensive pilot scale testing which would result in a
significantly longer,.. implementation time than the' selected
remedy. This alternative would require highly skilled operators.
No mobile soil washing systems tha~ can handle strong acids are
available, and therefore, a treatment plant would most likely
have to be constructed at the site. This alternative has not
been utilized in full scale operation, whereas 'stabilization has
been utilized. The cost for Alternative 4 (b) is significantly
higher (approximately 100 percent) than for stabilization.
Alternative 4(0):
In-8itu V~ficatioD
This alternative involves a process in which electricity is
passed through electrodes placed in the ground, heating and
melting .the soil, and forming an inert, glass-like product. This
alternative would take the longest period ot time to implement of
the three treatment alternatives and would cost significantly
more (approximately 32 percent) than stabilization. A limitation
of in-situ vitrification is the capacity of the off-gas system to
handle the combustion products ot the battery casing fragments.
This technology would require pilot-scale testing prior to full
scale operation since this technology has not been typically
applied to soils with high inorganic contamination. The
vitrification process would require approximately 4 megawatts of
power to generate the high temperatures needed to melt the soils
which creates another safety concern.
39
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Alternative -5(a) stabilization: 5(b) Soil Wash~na: and 5(0) In-
situ vitrification v~th Offsite D~Sgosal of Residual
Contamination above 120 ma/ka Lead in San~tarv/Industrial Waste
Landfill
The three treatment alternatives listed under Alternative 5
involve the same respective treatment processes associated with
Alternative ~-- with the additional-removal and offsitedisposal
of soils which have lead values between 120 mg/kg and
1,000 mg/kq.
These alternatives would not involve any additional treatment of
,
the soils in this range and would not afford any significant
increase of protection to human health and the environment than
would Alternative 4(a). Alternative 5 would also cause a
significant increase in cost for each of the treatment
alternatives.
%11.
STATUTORY DBTERMINATIONS
.The Selected Remedial Action which was previously outlined
satisfies the remedy selection requirements of CERCLA - and the
NCP. The 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 tor treatment as a principal element.
Protection ot Human Health and the Environment
The Selected Remedial Action protects human health and the
environment through the treatment of contaminated soils and
sediments in the drainage ditch with offsite disposal of
stabilized material. - The soils and sediments will be stabilized
in order to eliminate the threat of exposure from direct contact, .
ingestion or inhalation. In addition, no risks are anticipated
from the soils left onsite containing lead between 120 mg/kg and
40
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1000 mg/kg since these soils will be covered with a soil and
vegetative cap. This cap will eliminate all routes of exposure to
the lead. There are no short-term threats associated with the
selected remedy that cannot be readily controlled using
established construction methods. Evaluation of alternatives for
land use restrictions will be accomplished during remedial design
and remedial action.
Comoliance with
Reauirements
A-pclicable
or
Relevant
and
Aoorocriate
The selected remedy will comply with all applicable or relevant
and appropriate chemical-, action-, and location-specific ARARs
as described below and shown in Table 8.
. Action-specific ARARs. RCRA Subtitle C closure
requirements (40 CFR Part 264 Subpart G) will be met for
the former acid pond area. Materials transported off site
will meet EPA offsite disposal policy and comply with DOT
regulations (40 CFR Parts 262 and 263, 49 CFR Part 107,
171-179) and VHWMR (VR 672-10-1) for material 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 (29 CFR Parts 1910, 1926, and 1904)
requirements will be met for workers engaged in remedial
activities. Wastes treated by stabilization will be
tested to confirm that the treated waste is not hazardous
and meets BOAT requirements to be established in May 1990,
before being disposed of at an approved facili ty.
Excavation activities shall be in compliance with the
Virginia Erosion and Sediment Control Law, Virginia Code
section 21-89.1 et. seq.
. Chemical-specific ,ARARs - Air
activities will be monitored for
Act (40 CFR Parts 50 and 60)
emissions during remedial
compliance with Clean Air
and virginia rules and
41
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fl ._~~ v
SUMMARY MA TRIX FOR ALTERNI' olE COMPARISON
C&R BATTERY SITE, CHESTERFIEL 'UNTY, VIRGrNIA
Alternative 4 Alternative 5
Alternative' Alternative 2 Onsite Treatment-I,OOO mglkg Onsite Treatment-I.000 mglkg
No A(tion RCRA Cap-120 mg/kg I Action Level, Soil Cover Over Action level, Offsite Disposal of
Action level Residual Contami'lation(1) Residual Contamination (1) in
Industrial (2) Waste landfill
COMPLIANCE WITH ARARs: CONTAMINANT-SPEOFIC
None applicable. Fugitive emissions during Fugitive emissions during Fugitive emissions during
remedial action mUst comply remedial action must comply remedial action must comply
with: with: with:
. Clean Air Act 8 Clean Air Act 8 Clean Air Act
8 Virginia Air Pollution 8 Virginia Air Pollution 8 Virginia Air Pollution
Regulations Regulations Regulations
Discharges to surface waters Discharges to surface waters
must comply with: must comply with:
8 Virginia Water Quality 8 Virginia Water Quality
Standards Standards
COMPLIANCE WITH ARARs: LOCATION-SPECIFIC
None applicable. None applicable. Air emissions and surface water Air emissions and surface water
discharge must comply with: discharge must comply with:
8 Endangered Species Act of 8 Endangered Species Act of
1978 1978
8 Fish and Wildlife 8 Fish and Wildlife"
Coordination Act Coordination Act
8 Fish and Wildlife 8 Fish and Wildlife
Improvement Act of 1978 Improvement Act of 1978
8 Fish and Wildlife 8 Fish and Wildlife
Conservation Act of 1980 Conservation Act of 1980
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,IiLL 4.1
,MMARY MA fRIX FOR AL TERNA fiVE COMPARISON
toR BA "ERY SITE. CUESTERFIElD COUNTY. VIRGIN'A
iGE TWO
Alternative 1
No Action.
Alternative 2
RCRA Cap-120 mglkg
Action Level
Alternative 4
Onsite Treatment -1,000 mglkg
Action Level, Soil Cover Over
Residual ContaminationC I)
Alternative 5
Onsite Treatment-1,OOO mglkg
Action Level, Offsite Disposal of
Residual Contamination CI) in
Industrial (2) Waste Landfill
I
)MPUANCE WITH ARARs: AC110N-SPEORC
oes not comply with RCRA Complies with RCRA landfill.
~an closure or landfill closure closure requirement (4OCFR
-quirements (40 (fR Part 264, Part 264, Subpart G).
,bpart G).
Complies with RCRA clean
closure requirement (4OCFR
Part 264, Subpart G) for acid
pond area.
Hybrid (soil cover) closure for
. residual contamination outside
acid pond area.
Complies with RCRA clean
closure requirement (40 CFR
Part 264, Subpart G)
(Alternatives Sa and 5b).
Complies with RCRA landfill
closure requirements (40 CFR
Part 264, Subpart G)
(Alternative 5<).
Worker protection during onsite Worker protection during onsite Worker protection during onsite
activities must comply with OSHA activities must comp1y with OSHA activities must comply with OSHA
health and safety requirements. health and safety requirements. health and safety requirements.
Offsite transportation must
comply with:
. RCRA hazardous waste
generator and
transportation regulations.
. Federal and state DOT
transportation regulations.
Offsite transportation must
comply with:
. RCRA hazardous waste
generator and
transportation regulations.
. Federal and state DOT
transportation regulations.
Onsite treatment must comply
with RCRA and state TSOF
operating standards.
Offsite transportation must
comply with:
. RCRA hazardous waste
generator and
transportation regulations.
. Federal and state DOT
transportation regulations.
Onsite treatment must comply
with RCRA and state TSOF
operating standards.
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.r<>. ..' I H ;,
tABlE 8
SUMMAR'i MA TIlIX fOR AL TEIINAT1VE COMPARISON
C&" BA fTfR V CHESTERFIELD COUNTY. VIRGIN_A
PAGE THREE
Alternative 4 Alternative 5
Alternative 1 Alternative 2 Onsite Treatment-1,OOO mglkg Onsite Treatment -1,000 mglkg
No Action RCRA Cap-120 mglkg Action level, Soil Cover Over Action Level, Offsite Disposal of
Action Level Residual ContaminationCl) Residual Contamination (I) in
Industrial (2) Waste Landfill
COMPliANCE WITH ARARs: ArnON-SPEORC (Continued)
Onsite surface water discharge Onsite surface water discharge
must comply with: must comply with:
, 8 Clean Water Act NPDES 8 Clean Water Act NPOES
discharge regulations. discharge regulations.
8 Virginia NPDES discharge 8 Virginia NPDES discharge
regulations. regulations.
(xcavated soil that is 8 placed 8 (xcavated soil that is 8placed8
must comply with RCRA land must comply with RCRA land
Disposal Restrictions (40 CFR Disposal Restrictions (40 CFR
Part 268). Part 268).
Treatment/disposal facilities Treatment/disposal facilities
must comply with RCRA and must comply with RCRA and
state TSDF operating standards if state TSDF operating standards if
untreated soil is transported to a untreated soil is transported to a
hazardous waste landfill. for hazardous waste landfill. for
treatment and disposal. treatment and disposal.
If treated soil is shipped to a If treated soil is shipped to a
sanitarylindustrial waste landfill., sanitarylindustrial waste landfill,
the facility must comply with the facility must comply with
RCRA and state regulations for RCRA and state regulations for
sanitary/industrial waste sanitary/industrial waste.
landfill.s. landfill.s.
-------
regulations (Virginia Air Pollution Regulations
Chapter 120, Parts I-VIII). The air standards' most
applicable to the soils are NAAQ standards for lead and
particulate matter. If these limits are exceeded, dust
suppressants must be applied to control fugitive dust
emissions.
.
Location-specific ARARs - None.
. 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 to 1,000 mg/kg for
lead (OSWER Directive Memorandum 09-07-89)
- EPA carcinogenic potency factors to develop a risk-
based cleanup level for arsenic
Cost Effectiveness
The present worth cost of Alternative 4(a) is $15,292,000. The
selected remedy is cost effective because it provides overall
protection in proportion to cost and meets all other requirements
of CERCLA. Stabilization is 32 percent less than the cost of in-
situ vitrification and is 49 percent less than the cost of soil
washing which are the other treatment' technologies available for
this Site. The no-action alternative and the RCRA capping
alternative can be implemented at lower costs but do not provide
for permanent treatment and do not provide as effective a level
of protection of human health and the environment. In addition,
the no-action alternative does not meet ARARs.
Preference for Treatment as a princical Element
remedies
treatment
as
statutory preference
a principal element
for
to
that
remedy
employ
satisfies
the
The
selected
42
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permanently.reduce the volume, toxicity, or mobility of hazardous -
.substances. By treating soils and sediments contaminated with
lead and other inorganic metals using stabilization, the remedy
addresses the principal threats posed by the site through use of
treatment technologies.
Utilization of Permanent Solutions and Alternative
Technoloaies to the Maximum !xtent Practicable
Treatment
EPA has de.termined that the selected remedial action represents
the maximum extent to which. permanent solutions and treatment
technologies can be utilized while providing the best balance
among the other evaluation criteria. Of t~ese alternatives that
are. protective of human health and the environment and meet
~s, the selected remedy provides the best balance of trade-
offs in terms of long-term and short-term effectiveness an~
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 stabilization.
."..Y
Stabilization addresses the principal threats posed by
contaminants in soil and sediments, achieving a significant
reduction in lead (97 percent). The remedy is protective of
human health and the environment and is more cost effective than
soil washing or in-situ vitrification.
43
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U8PONSIVEHES8 SUMMARY
C&. BATTERY COMPANY, INC. SITZ
1.0
OVBRVIn
As set forth in the Proposed Plan and newspaper notice issued in
accordance with Section 117 of CERCLA, 42 U.S.C. Section 9617, in
January 1990, the EPA identified a preferred alternative for the
remediation of contaminated soils and sediments at the C&R
Battery Company, Inc. Site (C&R Battery Site or Site) in
Chesterfield County, Virginia. The preferred alternative
specified in the Proposed Plan called for stabilization of
contaminated soil and sediment and offsite disposal ot the.
stabilized material in a sanitary/industrial waste landfill.
Residual soil contamination would be covered with a soil cap.
The EPA and the Commonwealth of 'Virginia have decided that no
remedial actions are necessary for groundwater at this. time. .
Limited comments were received during the public comments period.
One commenter expressed a preference for capping the soils in
. place, or if stabilization was implemented, disposal in a
construction/demolition/debris landfill. No other comments
regarding the preferred alternative were received. The Virginia
Department of Waste Management and the Chesterfield County.
Planning Commission concur with the selected alternative. No
comments were received from Potentially Responsible Parties
(PRPs).
2.0
BACSQJt01DID O. COMKUHIn INVOLVBHBH'f
Accordinq to the intormation available from the files, from
interview. with industrial neighbors of the C&R Battery Site, and
from public inpu~ during the public comment period, there has
been lit~le community interest in the site. This may be because
the Site is loca~ed in an industrial area, and there are few
nearby residence..
The only apparent community interest in the C&R Battery Site
reflected in the files prior to remedial planning activities
occurred in lat. 1979. According to letters in the files, the
county was considering a C&R Battery request to rezone the Site.
An out-of-state resident whose mother lived behind the site
contacted the county and expressed her concerns. During a visit
1
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to her mother, she had noticed activities at the Site and wa~
concerned about contaminants migrating to the James River or
washing into the river during flooding and about chemical-
smelling smoke from fires on the Site. Earlier, the family we.-
and other wells in the area had been sampled: however, results o.
the sampling are unknown. At the time, one family whose well wa~
sampled reported that the water was dark and stained the sink.
Sampling conducted by EPA during the RI showed that residential
wells are not affected by Site contamination.
Except for this past concern, local and state officials reported
that community awareness of the Site is "virtually nonexistent."
Further, there has been little public interest in the Site.
Although several environmental groups are active in the Richmond
area, they have not registered concern at this time.
The media, however, have followed the Site closely in the past.
Details of the operations at C&R Battery were published during
enforcement actions, and the actual levels of lead in the soil
were announced when the emergency removal plans were made public.
Media coverage has continued intermittently during the conduct of
. remedial planning activities. . .
3.0
SUKJGJtY O. COJOlEN'l'S RECEIVED
DURIHG PUBLIC COHMEN'l' PERIOD
Comments received during the C&R Battery site public comment
period on the Proposed Plan and during public meeting held
February 7, 1990 are listed below. The comment period was held
from January 25, 1990 to February 23, 1990.
1.
One commenter at the public meeting inquired about
future site ownership and long-term responsibility for.
the site.
2.
BPa ..SPaRS., EPA's enforcement activities are
ongoing, therefore responsibility for future .
maintenance has not yet been determined. During the
enforcement process, EPA tries to identify PRPs and
offers thea the opportunity to perform the remedial
action, including future maintenance. EPA can seek to
have PRPs perform the work, or EPA can perform the work
itself. EPA also tries to recover costs from the.
Potentially Responsible Parties.
One commenter asked whether dust suppression and air
monitoring would be implemented during remedial action.
-2
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4.
BPA ReseoDse: Both dust sUppression and air monitoring
will be implemented during construction and will
continue through the conduct of the remedial action
3 .
One commenter inquired about groundwater contamination,
while another commenter asked about residential well
contamination.
BPA R.seODS.: Monitoring wells installed on Site show
no levels of contaminants that cause concern.
Likewise, residential well sampling showed no
contamination. Ground water monitoring will continue
during remedial action and at least until the first
five-year review is conducted in accordance with
section 12 (c) of CERCLA, 42 U.S.C. 9621 (c).
Another commenter requested clarification of the type
of landfill in which the stabilized soil will be'
disposed. In later correspondence, this commenter
expressed a preference for disposal in
construction/demolition/debris landfill, whereas the
selected alternative calls for disposal in a
sanitary/industrial waste or hazardous waste landfill.
Another commenter strongly opposed disposal of the
stabilized soil in a specified local landfill.
BPA R.seODS.: The disposal of the stabilized soil is
governed by Federal and state regulations. The
Commonwealth of Virginia has indicated that treated
soils from a CERCLA site would not be permitted to be
disposed ina construction/demolition/debris landfill.
However, because the stabilization process will render
the soil nonhazardous, disposal in a local
sanitary/industrial waste landfill may be permitted.
Any landfill chosen tor disposal ot the Site's
stabilized 80il must be in compliance with all
appropriate Federal and state design and operating
requirements.
3
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