ar30l*78u - · pdf fileolin chemicals group - saltvllle ou-2 miscellaneous technical data...

Olin Chemicals Group - Saltvllle OU-2Miscellaneous Technical Data

FLUOR DANIEL:——————————————————————————————————————————

APPENDIX D-1Settlement Versus Ammonia-Soda Ash Waste Thickness

B752APPD FS9 - FEB 1994 r TL D-2 Feasibility StudyAR30l*78U

Olin Chemicals Group - Saltville OU-2Miscellaneous Technical Data

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FIGURE D-1

SETTLEMENT VERSUS ASAW THICKNESS (P5, ST-1)

(Source: Golder Associates, 1993)

2.0-

HZUJSUI-J

is1-0-CO

Q.O.5-

_ j ( ( ( j ^1O 2O 30 40- 50 60

THICKNESS OF ASAW (FEET)

C = 0.32

883-6174LAS

N/A12/08/89

.w VA01-261

Golder Associates

SETTLEMENT vs ASAWTHICKNESS (P-5, ST-1)

OLIN CORPORATION £3-28

This sample was located in the eastern portion of Pond 5, about 420 ft from intersection of Route 611 and Swale 2. See Figure3-26 in the Remedial Investigation Report'(Golder Associates, 1993) for exact location.

B752APPD.FS9 - FEB 1994 D-3 • n <i n j ~J A c" Feasibility Study

OHn Chemicals Group - Saltville OU-2Miscellaneous Technical Data

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FIGURE D-2

SETTLEMENT VERSUS ASAW THICKNESS (P8, ST-3)

(Source: Golder Associates, 1993)

1O 20 30 40 50THICKNESS OF ASAW (FEET?

C = 0.32C

EQ = 1.44

JOB NO. 883-6174

LASN/A

t>*TE 12/08/89VA01-262

Colder Associates

SETTLEMENT vs ASAWTHICKNESS (P-8, ST-3)

OLIN CORPORATION 3-29

This sample was located in the western portion of Pond 5, about 400 ft from the outlet structure. See Figure 3-26 in the RemedialInvestigation Report (Golder Associates, 1993) for exact location.

B753APPD.FS9 - FEB 1894 D-4 HR30I4786

Olin Chemicals Group - Saitvllle OU-2Miscellaneous Technical Data

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APPENDIX D-2HELP Model Analyses

B752APPD.FS9 - FES 1994 D-5 Feasibility StudyftR30f4?87


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ALTERNATIVE F: GROUNDWATER MANAGEMENT AND MULTI-LAYER CAPWITH SYNTHETIC LINER, OLIN WASTE DISPOSAL SITESALTVILLE, VIRGINIA RUN DATE: 12/01/92

*

LAYER 1

VERTICAL PERCOLATION LAYERTHICKNESS = 18.00 INCHESPOROSITY = 0.4530 VOL/VOLFIELD CAPACITY = 0.1900 VOL/VOLWILTING POINT = 0.0850 VOL/VOLINITIAL SOIL WATER CONTENT = 0.4530 VOL/VOLSATURATED HYDRAULIC CONDUCTIVITY = 0.000719999953 CM/SEC

LAYER 2

LATERAL DRAINAGE LAYERTHICKNESS = 1.00 INCHESPOROSITY = 0.4170 VOL/VOLFIELD CAPACITY = 0.0210 VOL/VOLWILTING POINT = 0.0200 VOL/VOLINITIAL SOIL WATER CONTENT = 0.4170 VOL/VOLSATURATED HYDRAULIC CONDUCTIVITY = 0.009999999776 CM/SECSLOPE = 0.02 PERCENTDRAINAGE LENGTH = 1300.0 FEET

B752APPD.FS9 - F=EB 1994 °"6 flR30^788 Feasibility Study


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LAYER 3

BARRIER SOIL LINER WITH FLEXIBLE MEMBRANE LINERTHICKNESS - 48.00 INCHESPOROSITY . = 0.4530 VOL/VOLFIELD CAPACITY - 0.1900 VOL/VOLWILTING POINT - 0.0850 VOLA°LINITIAL SOIL WATER CONTENT = 0.4530 VOL/VOLSATURATED HYDRAULIC CONDUCTIVITY - 0.000099999997 CM/SECLINER LEAKAGE FRACTION = 0.00060000

GENERAL SIMULATION DATA

SCS RUNOFF CURVE NUMBER = 90.00TOTAL AREA OF COVER - = 3484800. SQ FTEVAPORATIVE ZONE DEPTH = 18.00 INCHESUPPER LIMIT VEG. STORAGE = 8.1540 INCHESINITIAL VEG. STORAGE = 8.1540 INCHESINITIAL SNOW WATER CONTENT = 0.0000 INCHESINITIAL TOTAL WATER STORAGE INSOIL AND WASTE LAYERS = 30.3150 INCHES

SOIL WATER CONTENT INITIALIZED BY USER.

CLIMATOLOGICAL DATA

SYNTHETIC RAINFALL WITH SYNTHETIC DAILY TEMPERATURES ANDSOLAR RADIATION FOR ASHEVILLE NORTH CAROLINA

MAXIMUM LEAF AREA INDEX =2.00START OF GROWING SEASON (JULIAN DATE) = 110END OF GROWING SEASON (JULIAN DATE) - 296

NORMAL MEAN MONTHLY TEMPERATURES, DEGREES FAHRENHEIT

JAN/JUL FEB/AUG MAR/SEP APR/OCT MAY/NOV JUN/DEC

35.10 37.40 45.70 56.40 64.50 71. 6075.70 74.80 68.40 57.10 47.00 38.30

8752APPD.FS9-FEB 1994 D~7 B n O fi I, 7 Q Q Feasibility Study


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AVERAGE MONTHLY VALUES IN INCHES FOR YEARS 1 THROUGH 10


PRECIPITATION

TOTALS 2.78 3.69 3.10 2.71 4.92 3.534.49 3.77 3.03 2.93 3.02 3.16

STD. DEVIATIONS 1.41 1.43 1.42 0.95 3.21 1.321.80 1.59 1.51 1.83 1.66 1.03

RUNOFF

TOTALS 0.370 1.039 0.517 0.286 1.168 0.2270.194 0.284 0.179 0.158 0.282 0.119

STD. DEVIATIONS 0.445 1.495 0.501 0.252 1.458 0.3080.230 0.265 0.222 0.244 0.365 0.165

EVAPOTRANSPIRATION

TOTALS 1.530 1.758 3.076 2.650 3.772 5.3955.802 3.896 2.682 1.963 1.794 1.395

STD. DEVIATIONS 0.133 0.214 0.367 0.880 1.368 0.7241.494 1.269 1.242 0.775 0.567 0.316

LATERAL DRAINAGE FROM LAYER 2

TOTALS 0.0016 0.0014 0.0017 0.0015 0.0014 0.00100.0003 0.0002 0.0001 0.0001 0.0002 0.0005

STD. DEVIATIONS 0.0012 0.0006 0.0005 0.0003 0.0003 0.00030.0002 0.0001 0.0000 0.0000 0.0002 0.0004

PERCOLATION FROM LAYER 3

TOTALS 0.0745 0.0734 0.0821 0.0781 0.0799 0.07330.0674 0.0649 0.0622 0,0641 0.0642 0.0698

STD. DEVIATIONS 0.0123 0.0052 0.0036 0.0024 0.0029 0.00310.0027 0.0011 0.0003 0.0002 0.0031 0.0054

B752AppD.Fse.FE81994 D-8 Q P Q {] fi 7 Q fl Feasibility Studyrl 11 *-• w *"? / 3 i)


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•fc'fc-Jeie-A'fe f'ft'fffr fff fff fffJffe- 'Jf : •*•&•& •&•&•&

AVERAGE ANNUAL TOTALS & (STD. DEVIATIONS) FOR YEARS 1 THROUGH 10

(INCHES) (CU. FT.) PERCENT

PRECIPITATION 41.13 ( 6.008) 11942992. 100.00

RUNOFF 4.821 ( 3.447) 1400109. 11.72

EVAPOTRANSPIRATION 35.713 ( 4.833) 10370954. 86.84

LATERAL DRAINAGE FROM 0.0100 ( 0.0028) 2905. 0.02LAYER 2

PERCOLATION FROM LAYER 3 0.8539 ( 0.0291) 247982. 2.08

CHANGE IN WATER STORAGE -0.272 ( 1.864) -78958. -0.66

'&&& & ic&&i:&if& i; &&&&-kitit-k'&it'&'&-!fc-};-&'&it-j(-&i;'k&

PEAK DAILY VALUES FOR YEARS 1 THROUGH 10

(INCHES) (CU. FT.)

PRECIPITATION 2.20 638880.0

RUNOFF 1.683 488600.4

LATERAL DRAINAGE FROM LAYER 2 0.0013 367.7

PERCOLATION FROM LAYER 3 0.0029 828.2

HEAD ON LAYER 3 19.1

SNOW WATER 1.82 528180.1

MAXIMUM VEG. SOIL WATER (VOL/VOL) 0.4530

MINIMUM VEG. SOIL WATER (VOL/VOL) 0.0847

*:V:&*-£:£**

B75aAPPD.FS9 - FEB 1994 D-9 R 3 0 U 7 Q ! Feasibility Study


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FINAL WATER STORAGE AT END OF YEAR 10

LAYER (INCHES) (VOL/VOL)

1 5.44 0.3019

2 0.42 0.4170

3 21.74 0.4530

SNOW WATER 0.00

******************************************************************

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B752APPD.FS9 • FEB 1994 D-10 $ D Q f> h 7 G O Feasibility Study

Olin Chemicals Group • Saltviile OU-2Miscellaneous Technical Data

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ALTERNATIVE G: GROUNDWATER MANAGEMENT, FRACTURE SEALING, SURCHARGING,AND CAPPING WITH DIKE AND POND MATERIAL

OLIN WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA RUN DATE: 12/01/92

LAYER 1

VERTICAL PERCOLATION LAYERTHICKNESS = 18.00 INCHESPOROSITY = 0.4530 VOL/VOLFIELD CAPACITY = 0.1900 VOL/VOLWILTING POINT = 0.0850 VOL/VOLINITIAL SOIL WATER CONTENT = 0.4530 VOL/VOLSATURATED HYDRAULIC CONDUCTIVITY = 0.000719999953 CM/SEC

LAYER 2


B752APPO.FS9 - FEB 1994 D-11 ft Q 0 f i 7 Q Feasibility StudyH ft O U 41 / -2O


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LAYER 3

BARRIER SOIL LINERTHICKNESS = 30.00 INCHESPOROSITY = 0.4790 VOL/VOLFIELD CAPACITY = 0.3710 VOL/VOLWILTING POINT = 0.2510 VOL/VOLINITIAL SOIL WATER CONTENT = 0.4790 VOL/VOLSATURATED HYDRAULIC CONDUCTIVITY = 0.000000100000 CM/SEC


SCS RUNOFF CURVE NUMBER = 90.00TOTAL AREA OF COVER = 3484800. SQ FT •EVAPORATIVE ZONE DEPTH = 18.00 INCHESUPPER LIMIT VEG. STORAGE = 8.1540 INCHESINITIAL VEG. STORAGE = 8.1540 INCHESINITIAL SNOW WATER CONTENT = 0.0000 INCHESINITIAL TOTAL WATER STORAGE INSOIL AND WASTE LAYERS - 22.9410 INCHES


CLIMATOLOGICAL DATA


MAXIMUM LEAF AREA INDEX =2.00START OF GROWING SEASON (JULIAN DATE) = 110END OF GROWING SEASON (JULIAN DATE) = 296



35.10 37.40 45.70 56.40 64.50 71. 6075.70 74.80 68.40 57.10 47.00 38.30

B752APPDFS9 FEB 1994 D-12 ft R 9 f} ii 7 Q I, Feasibility Study£


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PRECIPITATION

TOTALS 2.78 3.69 3.10 2.71 4.92 3.534.49 3,77 3.03 2.93 3.02 3.16

STD. DEVIATIONS 1.41 1.43 1.42 0.95 3.21 1.321.80 1.59 1.51 1.83 1.66 1.03

RUNOFF

TOTALS 0.319 0.981 0.472 0.257 1.075 0.2160.189 0.282 0.179 0.158 0.2-84 0.116

STD. DEVIATIONS 0.356 1.473 0.474 0.217 1.376 0.3050.227 0.260 0.222 0.244 0.365 0.164

EVAPOTRANSPIRATION

TOTALS 1.531 1.759 3.109 2.657 3.756 5.4375.578 3.848 2.653 1.967 1.767 1.397

STD. DEVIATIONS 0.132 0.214 0.360 0.877 1.416 0.7221.663 1.288 1.213 0.781 0.563 0.316


TOTALS 0.0018 0.0014 0.0016 0.0014 0.0013 0.00090.0003 0.0001 0.0001 0.0000 0.0002 0.0005

STD. DEVIATIONS 0.0011 0,0006 0.0005 0.0003 0.0004 0.00030.0002 0.0001 0.0000 0.0000 0.0002 0.0004


TOTALS 0.1228 0.1362 0,1536 0.1448 0.1468 0.13190.1149 0.1089 0.1038 0.1025 0.0705 0.0863

STD. DEVIATIONS 0.0501 0.0144 0.0110 0.0071 0.0088 0.00930.0070 0.0022 0.0008 0.0112 0.0466 0.0589

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B752APPD.FS9 - FEB 1994 D-13 ft P *3 fl It 7 Q ^ Feasibility StudyL


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*************************************************************************



PRECIPITATION 41.13 ( 6.008) 11942992. 100.00

RUNOFF 4.527 ( 3.235) 1314701. 11.01





***************** *******************************-5V **********************

***********************************************************************


(INCHES) (CU. FT.)


RUNOFF 1.586 460638.6




SNOW WATER 1.82 528180.1



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B752APPD.FS9 - FEB 1994 D-14 R 3 0 k 19 6 Feasibility study


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FINAL WATER STORAGE" AT END OF YEAR 10

LAYER (INCHES) (VOL/VOL)

1 5.23 0.2908

2 0.42 0.4170

3 14.37 0.4790

SNOW WATER 0.00

***********************************************************************

B752APPD.FS9 - FEB 1994 D-15 8 P 7 H ft 7 Q 7 Feasibility StudyHHOU4/.3/


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ALTERNATIVE H: GROUNDWATER MANAGEMENT, FRACTURE SEALING, SURCHARGING,AND CAPPING WITH SYNTHETIC LINER

OLIN WASTE DISPOSAL SITE, SALTVILLE, VIRGINIA RUN DATE: 12/01/92

**/****************•**************************************•***************

LAYER 1

VERTICAL PERCOLATION LAYERTHICKNESS - 18.00 INCHESPOROSITY = 0.4530 VOL/VOLFIELD CAPACITY = 0.1900 VOL/VOLWILTING POINT = 0.0850 VOL/VOLINITIAL SOIL WATER CONTENT = 0.4530 VOL/VOLSATURATED HYDRAULIC CONDUCTIVITY = 0.000719999953 CM/SEC

LAYER 2


B752APPD.FS9 - FEB 1994 D-16 QR30^798 Feasibility Study


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LAYER 3

BARRIER SOIL LINER WITH FLEXIBLE MEMBRANE LINERTHICKNESS - 6.00 INCHESPOROSITY - 0.4790 VOL/VOLFIELD CAPACITY - - 0.3710 VOL/VOLWILTING POINT = 0.2510 VOLAOLINITIAL SOIL WATER CONTENT = 0.4790 VOLAOLSATURATED HYDRAULIC CONDUCTIVITY = 0.000010000000 CM/SECLINER LEAKAGE FRACTION = 0.00060000


SCS RUNOFF CURVE NUMBER = 90.00TOTAL AREA OF COVER = 3484800. SQ FTEVAPORATIVE ZONE DEPTH = 18.00 INCHESUPPER LIMIT VEG. STORAGE = 8.1540 INCHESINITIAL VEG. STORAGE = 8.1540 INCHESINITIAL SNOW WATER CONTENT = 0.0000 INCHESINITIAL TOTAL WATER STORAGE INSOIL AND WASTE LAYERS = 11.4450 INCHES


CLIMATOLOGICAL DATA


MAXIMUM LEAF AREA INDEX =2.00START OF GROWING SEASON (JULIAN DATE) = 110END OF GROWING SEASON (JULIAN DATE) = 296



35.10 37.40 45.70 56.40 64.50 71.6075.70 74.80 68.40 57.10 47.00 38.30

B752APPD.FS9-FEB 1994 D-17 A D A 11 7 Q Q Feasibility Study


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PRECIPITATION

TOTALS 2.78 3.69 3.10 2.71 4.92 3.53'4.49 3.77 3.03 2.93 3.02 3.16

STD. DEVIATIONS 1.41 1.43 1.42 0.95 3.21 1.321.80 1.59 1.51 1.83 1.66 1.03

RUNOFF

TOTALS 0.437 1.150 0.588 0.326 1.273 0.2470.199 0.288 0,179 0.159 0.287 0.126

STD. DEVIATIONS 0.548 1.499 0.523 0.271 1.505 0.3160.233 0.271 0.222 0.245 0.368 0.168

EVAPOTRANSPIRATION

TOTALS 1.528 1.756 3.065 2.606 3.706 5,3686.093 3.961 2.719 1.968 1.766 1.393

STD. DEVIATIONS 0.133 0.213 0.385 0.863 1.420 0.7301.267 1.245 1.299 0.765 0.565 0.316


TOTALS 0.0013 0.0016 0.0018 0.0016 0.0016 0.00110.0004 0.0002 0.0001 0.0001 0.0003 0.0006

STD. DEVIATIONS 0.0008 0.0006 0.0004 0.0002 0.0003 0.00030.0002 0.0001 0.0000 0.0000 0.0002 0.0004


TOTALS 0.0180 0.0194 0.0222 0.0204 0.0205 0.01680.0104 0.0080 0.0072 0.0074 0.0093 0.0127

STD. DEVIATIONS 0.0063 0.0037 0.0022 0.0016 0.0020 0.00200.0021 0.0013 0.0003 0.0001 0.0027 0.0045

**********************

B752APPO.FS9 - FEB 1994 D-18 flR30U800 Feasibility Study


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PRECIPITATION 41.13 ( 6.008) 11942992. 100.00

RUNOFF 5.259 ( 3.574) 1527177. 12.79





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(INCHES) (CU. FT.)


RUNOFF 1.728 501731.9




SNOW WATER 1.82 528180.1



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B752APPDFS9 - FEB 1994 D-19 „ __ ~ „ . _ - Feasibility Studyf\ R % I I LI R fl IH f\ U u 4 O U I


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FINAL WATER STORAGE AT END OF YEAR 10

LAYER (INCHES) (VOLAOL)

1 5.70 0.3167

2 0.42 0.4170

3 2.87 0.4790

SNOW WATER 0.00

*****•&•**•***** ***************************************** ************************************************************•***********************'*****

B752APPD.FS9 - FEB 1994 °-20 fi P Q H It P O O Feasibility Study

Olin Chemicals Group - Saltvllle OU-2Miscellaneous Technical Data

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APPENDIX D-3Calculation of Mercury Loadingfrom Former Chlorine Plant Site

B752APPD.FS9 - FEB 1994 D-21 Feasibility Study

CHEMICALSP.O. BOX 248. LOWER RIVER ROAD. CHARLESTON. TN 37310

Phot**: (615) 336-4000

August 7, 1990

John RolandBureau of EnforcementState Water Control BoardP.O.Box 11143Richmond, Virginia 23230

Re: Continued MonitoringFormer Chlorine Plant SiteSaltville, Virginia

Dear Mr. Roland:

I am enclosing the April 1990 results of the long-term monitoring of wells at the formerplant site. The results are presented as updates to Table 1*4 of our 1984 Supplement toGeohydrological Study transmitted under % cover letter to Martin Ferguson dated July 20, 1984.In that report we explain the formula for calculating the mercury discharge to the river. Foryour convenience, that formula is:

W * BKiACwhere:

W » mercury discharge, ppd (pounds per day)B « a constant for consistency of units, 6.238 x 10~*K * average site hydraulic conductivity, 0.71 ft/dayi * representative flow gradient, ft/ft (calculated by subtracting

elevation of well 6 from elevation of Well 13 and dividing by 430ft. distance between them)

A » cross-sectional flow area, 500 ft. flow width x 10 ft, effectiveaquifer thickness - 5000 ft1

C - average mercury concentrations of Wells 6, 9, 11, and 12 ppb

As can be seen from Table 1, the mercury flux to the river has remained essentiallyconstant since the plant site was capped. The 1990 results show a slight increase in mercuryflux to the river. The increase is caused by a higher than normal result in Well 12. The fluxwould result in * river water concentration of 0.008 ppb at the 7Q10 of 23 cfs and 0,0007 ppbat the average flow of 289 cfs. These are below the water quality standard.

Please let me know if you have any quest Jo as.

Sincerely,

OLIN CORPORATION

J/C. BrownManager, Environmental Affairs

jmmEnclosures

O L I N C O R P

cc: N. CarrikerP. LeonardT. LongeD. McKinneyA. D. Rheingold

D. Sizemore

flR30l»8

TABLE I

ESTIMATED MERCURY DISCHARGE VIA GROUNDWATERFORMER CHLORINE PLANT SITE

SALTVTLLE, VIRGINIAppd

ESTIMATEDDATE DISCHARGE

1/82 0.002

3/82 0.002

7/82 0.001

3/84 0.001

7/85 0.0005

3/86 0.0001

3/87 0.0004

3/88 0.0005

3/89 0.0006

4/90 0.0010

3014806

TABLE 2

GROUNDWATER ELEVATIONSFORMER CHLORINE PLANT SITE

SALTVILLE, VIRGINIAft MSL

__________________________DATE__________________________WELLNO. 3/82 7/82 3/84 7/85 3/86 3/87 3/88 3/89 4/90

6 1687.3 1685.1 1685.2 1684.0 1685.7 1686.8 1684.1 1686.3 1686.1

7* 1688.1 1685.1 1686.1 1683.6 1686.4 1687.9 1685.3 1686.4 1686.8

9 1689.0 1686.9 1688.6 1685.3 1689.8 1690.2 1686.1 1689.6 1689.3

11 1688.7 1686.7 1688.8 1684.6 1689.6 1689.7 1686.1 1689.4 1688.2

12 1689.7 <1689.6** 1689.8 <1687.6** 1693.5 1693.2 1695.7 1696.7 1692.6

13 — -- 1697,7 1697.0 1697.5 1698.3 1697.0 1697.7 1697.9

* Bedrock well** Well dry. Elevation is bottom of well.

TABLE 3

GROUNDWATER MERCURY CONCENTRATIONSFORMER CHLORINE PLANT SITE

SALTIVLLE, VIRGINIAppb

DATE

3/82 7/82 3/84 7/85 3/86 3/87 3/88 3/89 4/90

6 34 22 2 56 3 5 13 2.8 3.3

7* 2 8 4 15 22 6 2 28 6.1

9 694 455 439 139 31 253 85 250 294

11 9 18 5 24 6 3 .5 15 6.9

12 110 —** 23 -.-** 23 36 220 170 339

13 — -- <1 <1 <1 <1 <1 <1 <1

* Bedrock well** Well dry

TABLE 4

QUALITY ASSURANCE RESULTSFORMER CHLORINE PLANT SITE

SALTV1LLE, VIRGINIAPPb

FIELD DUPLICATEFIELD FIELD SPIKE

DATE BLANK Cl C2 % RECOVERY

3/86 <l 6 7 99

3/87 6 4 150

3/88*

3/89 <1 28 27 100

4/90** <1 6 6 103

* No field QC samples collected. Analytical QC results maintained at CharlestonLaboratory, Olin Corporation, Charleston TN

** 1990 samples analyzed by American Analytical Laboratories, Cleveland TN

Oiin Chemicals Group - Saltville OU-2Miscellaneous Technical Data

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APPENDIX D*3aSource: Quarterly Data Report #7

Saltville Waste Disposal Site

B752APPD.FS9 - FEB 1934 D-29 A H o f v j s\ Feasibility Study

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O O O H t - H « H O O O O O OI I I I I I I I I I I I


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APPENDIX D-3b

Source: Monthly Progress Report #47.Saltville Waste Disposal Site


RR30I*8I3

'12/92 Saltville Groundwater Analysis Page

Analyte Concentration Units CommentsWell No. CP-06

Sample Type: TotalSample Date: 3/03/92

Mercury .0013 mg/1

Well No. CP-07Sample Type: TotalSample Date: 3/03/92

Mercury .0025 mg/1


Mercury .0203 mg/1


Mercury .0076 mg/1


Mercury .0080 mg/1


Mercury 0.0000 mg/1 Det. limit = <0.0002 mg/1

Well No. EDDSample Type: TotalSample Date: 3/04/92

Mercury 0.0000 mg/1 Det. limit = <0.0002 mg/1


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APPENDIX D-3cSaltville Groundwater(1)

ConcentrationWell Number Sample Type Report Date Analvte (malt}

CP-06 Total 07/26/91 Mercury 0.0134CP-07 Total 07/26/91 Mercury 0.0031CP-09 Total 07/26/92 Mercury 0.7087CP-11 Total 07/26/91 Mercury 0.007CP-12 Total Not CollectedCP-13 Total 07/26/91 Mercury <0.0002

NOTE (1): Data from reports provided in Quarterly Data Report No. 9, Volume 1. Saltville Waste Disposal, Saltville, Virginiaissued by Olin Corporation.

B752APP&FS9 - FEB 1994 D-33 Feasibility StudyflRSOUS ! 5


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APPENDIX D-3d/Calculation of Mercury Loading from FCPS to NFHR

(Golder Associates, May, 1993)

8752APFD.FS9 - FEB 1994 D-34 m n i n i . n i r Feasibility StudyAR30U8I6

Olin/Saltville OU-2/VA________________________________ 833-6174.14

REVISED ESTIMATE OF LOADING TO NFHR AT THE FCPS

Mercury Loadings to the North Fork of the Holson River (NFHR) were estimated by Harza(1976) and Hiltgen (1982) and have since been calculated by Olin and included in the annualmonitoring reports to the VASWCB. The formula used in these calculations expresses the loadingin pounds of mercury per day and is based on the following:

• a 10-foot thickness for the alluvium and assumes that it extends the entire length of theFCPS along the river;

• lateral gradient determined from water level measurements in wells CP-13 (theupgradient well) and well CP-6;

• average mercury concentration in wells CP-6, CP-9, CP-11 and CP-13;

• Assumed low flow conditions (7Q10) in the NFHR.

Based on a review of the parameters used in the calculation, it is considered appropriate to modifythese parameters to better reflect estimated loadings to the river from the FPCS. This revisedapproach has been applied to re-estimate loadings from the FCPS for the period from January,1982 to March, 1993. The modifications to the above parameters are as follows:

• The saturated thickness of the aquifer used for flow calculations should be based onthe ground water levels measured at the time for which the loading calculations aremade;

• Flow through the bedrock should be ignored based on Harza's calculation that thebedrock contributions were considered only a "trace" contribution to the low overallloading;

• The permeability of the aquifer is approximated as equal to the geometric mean of thehydraulic conductivity values measured in wells completed in the fill above thebedrock. These wells were installed during the RI for Ponds 5 and 6;

• The flow calculations should be based on flow through a vertical plane through thewells from which the data used for the flow calculations were derived. This planewould terminate, in both directions, at the hydraulic boundaries that form the limits ofthe flow field width. The wells used in this calculation are CP-6, CP-7, CP-9, CP-11and CP-12;

• The concentration of mercury and the saturated thickness of the aquifer should beweighted by the linear distribution between the bounds of the flow field and betweenthe wells, not simply by an averaged value, (i.e. half the distance to an adjacent well orthe distance to the limit of the flow field)

The loading calculations based on this revised approach is provided on the following calculationsheets and supporting documents.

1/28/94 @ 11:16 AM River Loading Calculations 883-6174.14

LocationCulvertCP-6CP-7CP-9CP-11CP-12Rt634

Distance fromCulvert (tt)

60130190310440506

Total Flow Width:

Estimated FlowWidth (ft) '"•-.••

956590125130

SOS

Mean HydraulicConductivity ofFill (cm/sec)

3.79E-043.79E-043.79E-043.79E-043.79E-04

Elevation ofBase of Fill(ftmsl)

1685,241687,601684.411686.681693.23

•'•'••••••• - . Comments' ' , , . ••,,,,,,,, ••••••••;••;;•--'•"Western End of Line

Geometric Mean Fill Hydraulic Conductivity, Table 5-3, R.I.Geometric Mean Fid Hydraulic Conductivity, Table 5-3, R.I.Geometric Mean Fill Hydraulic Conductivity, Table 5-3, R.I.Geometric Mean Fill Hydraulic Conductivity, Table 5-3, R.I.Geometric Mean Fill Hydraulic Conductivity, Table 5-3, R.I.

Eastern End of Line

.:,•;: Dafe-'-Jan-32Mar-£2Jul-82Mar-44JuI-84Mar-36Mar-87Mar-88Mar-33Apr-90Jul-30Mar-31Jul-91Mar-32Mar-93

•s.''$te$$''&%!:-f*f'\ :;'":; vi: >:£;£ :•:•>: iSi SS -i i'SSx ^ ^ ^ ^ ^ ^ ^:'$:':';:'.'f;'-::'t:'f.-i:,,f*ssfr^^•;..i:;\-x-.-r.-.4ffttt*f-&xftffKf- ^: ••: iSrSuha" Water Elevations (ft mil) <FronK <Sotd«r Aisoclatei,

CP-61687.31687.31685.11686.21684.01685.71686.61684.11686.$1686.11684.891687.521685.191686.461686.99

CP-71688.11688.11685.11686.11683.61686,41687.91685.31686.41686.81685.101688.201684.401688.001689.72

CP-31689.01689.01686.91688.61685.31689.81690.21686.11689.61689.31686.931690.731687.161690.091690.56

CP-111688.71688.71686.71688.81684.61689.61689,71686.11689.41688,21686.661690.231686.S81689.491630.35

% ^ &i5S S4S vH S> '••'1694, Feasffatniy StudW "

CP-121689.71689.71687.fi1683.81687.61693.51693.21635.71696.71692.61638.281697.581688.281696.171637.78

CP-13#N/A#tt/A#N/A1697.71697.01697.51698.31697.01637.71697.91695.731701.131698.091638.82WJ/A

Approximatef' y uiieX'if•' Oriicliirtt''1'

2.84E-022.84E-O22.84E-022.91 E-023.02E-022.74E-022.67E-023.00E-022.65E-022.74E-022.52E-023.17E-023.00E-022.87E-022.34E-02

:'i| § : &£ W$$$*ffiS& $ %3$'Usa Mean Historical GradientUse Mean Historical GradientUc< Mean Historical Gradient(CP-13 minus CP-6J/430 ft(CP-13 minus CP-6K430 ft(CP-13 minus CP-6)/430 ft(CP-13 minus CP-6V430 It(CP-13 minus CP-6V430 ft(CP-13 minus CP V430 ft(CP-13 minus CP-6V430 ft(CP-13 minus CP-6V430 ft(CP-13 minus CP-6V430 ft(CP-13 minus CP-6)/430 ft(CP-13 minus CP-6V430 ft

Use Mean Historical Gradient

DateJan*82Mar-82Jul-32Mar-84Jul-84Mar-66Mar-87Mar-88Mar-83Apr-90Jul-90Mar-91Jul-91Mar-92Mar-93

Ground Water Flow Volume Through Flow Zone (ff S/dayl :'•'•' -••••• • ;-CP-6

S.37E+005.97E+OO

1.29E+004.25E+00

2.87E+OO2.41E+OO

7.38E+00

3.57E+00S.07E+00

CP-79.92E-019.92E-01

6.S9E-01

1.33E+OO

8.02E-014.20E+00

CP-91.26E+011.26E*016.84E+OO1.18E+012.60E-KX)1.43E+011.49E+O14.90E+001.33E+011.30E-KJ16.14E+001.94E+017.38E+001.S8E+011.69E+01

CP-117.70E+007.70E+007.63E-028.29E+00

1.07E+011.08E+01

9.68E+005.59E-HXI

1.63E+018.06E-011.08E+011.40E+01

CP-12

1.03E+00

1.04E+O11.28E+01

1.93E+01

1.18E+011.80E+01

Comments (Blank = No Saturated Alluvium/Fill) -;r :::

Well CP-12 was dry

Well CP-12 was dry

Note: 1 cm/sec = 2335 ft/day

[OLIN.XLWJHg Loading Calculations H il O U u? U I U Pago 1 of 2_

1/28/94@ 11:16AM Rivor Loading Calculations 883-6174.14

DateJan-82Mar-82Jul-32Mar-84Jul-S4Mar-86Mar-87Mar-33Mar-89Apr-90Jut-90Mar-91Jul-31Mar-92Mar-93

Mercury Concentrations .in Ground Water from Well (iig/i) ;{Fr Golder ;!';.•• Associates. Oct '93. Remedial I nvestf nation. Table '7J5V- ••• •••• :.:::':>.:<•

CP-627342225635132.83.33.6Z113.41.31.4

CP-7182841522G2286.13.31.43.12.60.6

CP-941069445543913931253852502344962197092054

CP-11275918524635166.913.353377.63.2

Note: 1 ug/L e 6.243E-08 Jb/ftA3

CP-12131110

23

2336220170339

87

870

' . • ;•' ••: • •' "... .-.: Comments ::::: :f :'•>••. -:; .: Yf-f:?^-,

Well CP-12 Was Not Sampled




Arithmetic Mean:

;M:$§!:-t&§i$&;^li :'£sftmitM &

7Q10 Flow (cfs):Average Loading Value (Ib/day):

Concentration of Hg fn River from Site (ug/l):

.; .Total•P: 'Mercury"1;1;>-: Loading :t:ii ID/day}*-

4.66E-045.63E-041.94E-043.26E-042.26E-053.34E-052.39E-041.63E-043.63E-042.42E-041.90E-048.80E-043.64E-C43.12E-OS1.39E-042.80E-04

' M&<8$:tioW FioWS ii:;.;

232 0E-042.24E-03

Note: ug/lb = 4.S4E+08ftA3/1rtar a 0.035sec/day = 86400

9.00E-04

-. 8.00E-04

^ 7.00E-04

a 6.00E-04

1 5.00E-04St 4.00E-043

| 3.00E-04£n 2.00E-04a

O.OOE400Jan

Estimated Loading From Former Chlorine Plant SiteInto the North Fork of the Holston River

*i

•

* •

-82 Jan-33 Jan-84 Jan-35 Jan-86 J

••

•

•

•

•

*

e

an-37 Jan-88 Jan-39 Jan-90 Jan-91 Jan-92 Jan-93 Jan-34Sampling Event Date

* Hg Loading (Ib/day)

Notes:See Figure D-1 for Distance to Culvert MeasurementsFlow Width = 1/2 trie Distance between Wells + Outside End Length for Wells at End of Line

*N7A= Data Not AvailableFlow Volume = Hydraulic Conductivity x Hydraulic Gradient x Flow Width x Saturated Thickness

Loading = Flow Volume x Hg ConcentrationRow Zone = The Portion of the Aquifer whose Properties are Represented by Data from the

Respective Monitoring Well

[OUN.XLWJHg Loading Calculation* R \\ *-' « " w * Poc« 2 of 2

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TabIe5-3Permeability Values - Previous Results

Well

C-2UC-2LC-6C-16

C-3C-5LC-7

C-4C-5UC-8C-10C-12C-15C-l

C-9C-llC-14

W-2W-3

Permeability(cm/sec)

<8.0E-052.6E-039.0E-079.4E-05

2.4E-046.6E-051. IE-05

I.4E-021.7E-049.4E-056.0E-04<1.6E-05l.OE-035.2E-04

1.9E-03l.OE-023.5E-03

l.OE-05l.OE-05

Lithology

Harza, 1976Weathered shaly LimestoneWeathered shaly LimestoneWeathered shaly LimestoneWeathered shaly Limestone

Jointed fresh shaly LimestoneJointed fresh shaly LimestoneJointed fresh shaly Limestone

Fined grained FillFined grained FillFined grained FillFined grained FillFined grained FillFined grained FillFined grained Fill and Concrete

AlluviumAlluviumAlluvium

Wehran, 1981ASAWASAW

NOTE: ASAW denote* Ammonia Soda Ash W«tc

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TABLE 2

GROUNDWATER ELEVATIONSFORMER CHLORINE PLANT SITE

SALTVILLE, VIRGINIAft MSL

WELLNO.HB BW B

6

7*

9

11

12

13

3/82

1687.3

1688.1

1689.0

1688.7

1689.7

--

7/82

1685.1

1685.1

1686.9

1686.7

<1689.6**

/--

3/84

1685.2

1686.1

1688.6

1688.8

1689.8

1697.7

7/85

1684.0

1683.6

1685.3

1684.6

<1687.6"

1697.0

DATE

3/86

1685.7

1686.4

1689.8

1689.6

1693.5

1697.5

3/87

1686.8

1687.9

1690.2

1689.7

1693.2

1698.3

3/88

1684.1

1685.3

1686.1

1686.1

1695.7

1697.0

3/89

1686.3

1686.4

1689.6

1689.4

1696.7

1697.7

4/90

1686.1

1686.8

1689.3

1688.2

1692.6

1697.9 -z.)* Bedrdck well** Well'dry. Elevation is bottom of well.

TABLE 3

GROUNDWATER MERCURY CONCENTRATIONSFORMER CHLORINE PLANT SITE

SALTIVLLE, VIRGINIAppb

___________________________DATE _______________________WELLNO. 3/82 7/82 3/84 7/85 3/86 3/87 3/88 3/89 4/90

6 34 22 2 56 3 5 13 2.8 3.3

7» 2 8 4 15 22 6 2 28 6.1

9 694 455 439 139 31 253 85 250 294

II 9 18 5 24 6 3 5 15 6.9

12 110 --•• 23 --** 23 36 220 170 339

13 — — <1 <1 <1 <l <1 <1 <1

* Bedrock well* Well dry

R3Qii830

Table 1.8.4.1-1Summary of Mercury Concentrations in Groundwater

Former Chlorine Plant Site

Well Number» ^

Jan-82 27 18 410 275 131Mar-82 34 2 694 9 110JuI-82 22 8 455 18 ——** <1Mar-84 2 4 439 5 23 <1Jul-85 56 15 139 24 ——** <1Mar-86 3 22 31 6 23 <1Mar-87 5 6 253 3 36 <1Mar-88 13 2 85 5 220 <1Mar-89 2.8 28 250 15 170 <1Apr-90 3.3 6.1 294 6.9 339 <1Jul-90 3.6 3.3 496 13.3 —— <1Mar-91 2.1 1.4 219 533 87 <1Jul-91 13.4 3.1 709 7.0 —— <1Mar-92 1.3 2.5 20 7.6 8.0 <1Mar-93 1.4 0.5 54 3.2 70 <1

Former Chlorine Ptent SltoGroundwater

WeU Data of Depth Top of Water MercuryNo. SampGng to Wafer Pipe Bwatton Concentration

CP-6 07 9 90 20.35 1705.24 1684.88 4CT>-7 07K&BO 19.00 1704.10 1685.10 3CP-6 07/00 0 16.46 1703.41 1686.83 496CP-11 07/09*90 16.82 1703.38 168656 13CP-12 07/09/90 14.95 170323 168a26 DryCP-13 07/09*90 9.48 1706.19 1695.73 <1

Former Chtorine Plant SfoaGroundwatar Measurements

Wel Date of Depth Top of Water MercuryNo, Sampling to Water Pipe Bevatian Concentration

CP-8 03 V91 17.72 1706.24 1687.52 2CP-7 CS/04/91 15,90 1704.10 168a20 1CP-9 03»W91 1Z68 1703.41 169a73 218CP-11 03/04»l 13.10 1703,38 1890J28 533CP-12 03/04 1 S.GS 1703.23 1 7.58 87CP-13 03»V91 4.06 1705.19 1701.13 <1

o

Former Chtorin* Ptant SfceGroundwater Measurements

Wetl Date of Depth Top of Water MercuryNo. SampBng to Water Pipe Elevation Concentration

CP-6 07/08/91 20.05 170534 1686.19 13CP-7 07/08/91 1970 1704.10 1684.40 3CP-9 07/08/91 1625 1703.41 1687.16 709CP-11 07/06/31 16.50 1703.38 1686.88 7CP-12 07A»91 14.95 1703.23 1688J28 Dry.CP-13 0708/91 9.10 1705.19 189609 <|

Former Chkxin* Plant SRsGnxrxlwatBr Measurements

r - ss.CP-6 Q3AB/92 18.78 1705.24 1686.46CPL7 0303/92 16.10 1704.10 1688.00CM 03TOS2 13.32 1703.41 169a09CP-11 03TO3«2 1S.89 1703.38 1689.49CP-12 03«af92 7.06 1703.23 1696.17

6.37 1705.19 1698.82

O o r*-i *NJ D

TELEPHONE MEMORANDUM

INCOMING___ OUTGOING

JOB: OL3T/J //TS / uftr / ROUTE TO:

PERSON:FIRM-'

PHONE NO: GO 3 668

JOB NO: &83-&l74.J*£DATE: /-IS-^4TIME:BY:

REMARKS : J<L.^<\?

P-i -703,23___________/&<}?* 78

/Jfi

ACTION REQUIRED:

3 n (4 R 3Golder Associates


FLUOR DANIEL——————————————————————————————————————————

APPENDIX D-4

Calculated Loading of Mercury from Pond 5, Pond 6 for 1988-1990


Olin Chemicals Group - Saltville OU-2FLUOR DANIEL:______••—___________———_____Miscellaneous Technical Data

1988 DATA SUMMARY FOR POND 5HvwRo* FfchU Row HG TDS HG Lotdrglawn) («.) (gp"i) to*)

No. RMctogi 368 128 250 249 51 366To* 46614 32 29242 5611 1201106 1JMWei iledTofcl 41323 02475 2.00Mnrraxn ID 0.00 15 2 6472 0,000000Uronum 1730 157 00 85 38384 OO52150Avtrtgt 136 0 11 23 2S134 O.Q04S50

Frequency CWriboSoo for Row (spffl) torn Pond 5Q(gpffi) Frequency %

0- 20 218 0+2 0 - 4 0 5 24 0 - 0 0 30 126 0 - 8 0 6 2>80 0

TOTAIS 25i 100

Fraqumcy Dbtritxtbon for HG pb) n Pcnd 5 Eflumt

0- 20 157 632 0 - 4 0 34 1440- 80 27 1100- BO 30 1200- 100 1 0>100 0

Freqwney Brtribufanter TDS (pprn) h Pond 5 EflumtTDS Fwquiftqf %

0- 10000 1 210000- 33000 T7 3920000- 30000 13 2530000- 40000 20 30>40000 0 0

TOTALS 51 WO

1988 DATA SUMMARY FOR POND 6Ha» HQ TDS BGUadng

(BPB) |K> (flpn.) t>pt» I*/**)Mo R«< 9> »S 13 35 27 20 300To* *B6U 32 1376 13 J 174330 0.01

14391.1 188.4 00718 0.00 O 0 100 0.000000

Mwnwm 1730 1ST 200 4 8728 0.001441Amp 138 0 30 1 0012 0.000014

Frvqumy CMUxrtonta flow (jpn torn Pond 9

0 - 2 0 21 802 0 - 4 0 8 174 0 - 0 0 0 08 0 - 8 0 1 3>00 7 20

TOTALS 35 100

Frequtncy Ctatibutton tor HG (ppb) ta Pcndl 5 EfluintHGfppto) Raqumcy %

0- 5 27 1005 - 1 0 0 0I D - 1 5 0 01 5 - 2 0 0 02 0 - 2 5 0 0> 2 5 0 0

TOTALS 27 100

Frtqjoncy Dutribukon for TDS (ppm) in Pond 5 EtltMntTDS FracpMnof %

0- 2000 1 32000- 4000 4 144000- 0000 B 280000- 0000 * 31>0000 7 24

°~47 R R '3 n I. ft Q R Feasibility Study

OHn Chemicals Group - Saltville OU-2Miscellaneous Technical Data

FLUOR DANIEL—————————————————————————————————————————1989 SUMMARY DATA FOR POND 5RverRow Rantal Bow HG TDS HG loading(gpn) (in.) (gpm) Jppb} frpm) (*/day)

Ho, Readings 365 1B4 ZSO 252 54 365Total 123328 44.79 10920.S 17063 773710 880WeightedTctal 15342.5 24911,0 14,37Minimum 50 0.00 2.2 4 14+4 OrOOOOOQMaamum 398B 1.78 85.3 205 37904 0130900Average 340 0.24 42 68 14328 0.027030

1989 DataFrequency Ojfibutkxi lor Row (gpcnj torn Pond 5Q (gpm) Frequency *

0- 20 220 042 0 - 4 0 5 240- 80 30 118 0 - 8 0 6 2>80 0

TOTALS 201 100

Frequency Dttibution lor HG (ppb) in Pond 5 EfluentHG &*)) Frequency %

0- 20 161 0420- 40 3* 1340- 80 27 1100- 80 30 128 0 - 1 0 0 1 0>100 0

TOTALS 253 tOO

Frequency Oteffbuton tor TD5 fngrt} hPoodSETlwentTDS Frequency %

o- laooa 4 710000- 20000 17 3120000- 30000 13 2430000- 40000 20 37>40000 0 D

TOTA15 54 100

1989 DATA SUMMARY FOR POND 6HwRaw HeWtl Row HG TDS HG Lutingfcpmf (h.) fepm) ***) (#/<%)

Ho. Rndng* *85 184 51 48 51 386ToM 123028 44.78 4482 22J 1B4837 0.03We((ftMToW 32077.1 185.6 0.24MWmum 5 9 0,00 0 0 0 0.000000Iteemum 3000 1.78 250 12 0022 0.021617Average 340 0 88 0 3ei6 oooooea

Frequency DUtfcutton tor Flow (gpm) torn Pond 0Q Ispm) Aequency %

0 - 2 0 a 1 82 0 - 4 0 6 124 0 - 8 0 5 108 0 - 8 0 5 10>80 20 51

TOTALS 51 100

Frequency Ctstibuton tor HG (ppb) in Pond 5 EtluernHGtopb) ftequency %

0- 5 48 905 - 1 0 0 01 0 - 1 5 1 21 5 - 2 0 0 02 0 - 2 5 0 0>25 0 0

TOTAIS «8 100

Frequency attribution te TDS $pm) n Pond 5 EttucntTDS Frequency %

0- 2000 5 102000- 4000 20 304000- 0000 21 410000- 8000 5 10>8000 0 0

TOTALS 51 100

D-48 Feasibility StudyflR30U839


FLUOR DANIEL————————————————————————————————————————1990 SUMMARY DATA FOR POND 5

HG Lowing(*'«V)

30536.915700

0000000t 0522330.101114

1990 EM*Frequency Dirtitxrian far Row (gem) torn Pond 5Q (gpm) Frequency %

0- 20 80 2420- 40 27 1140- 80 32 136 0 - 8 0 10 48 0 - 1 0 0 27 U100- 200 24 9>200 74 M

TOTALS 254 100

Frequency aifrtwtton tor HG (ppb) in Pond 5 EfluentHG bob) Frequency %

0 - 2 0 2 120- 40 22 040- 00 35 1580- 80 105 440 0 - 1 0 0 40 21>100 23 10

TOTALS 238 100

Frequency OmsUSon tor TDS topm) h Pond SEtluerrtTDS Frequency %

0- 10000 79 5410000- 20000 08 4520000- 30000 1 130000- 40000 0 0>4oooo o a

TOTALS 148 100

1990 DATA SUMMARY FOR POND 6RverFkw PttnM How HG TDS HGUedngfgpn>> W (gpm) topb) (f/dty)

NaAeedngi 985 124 28 41 40 385JOUt 151118 54.85 5045 9.0 85845 0.01Wei bdToW 83458.7 56.5 0,12Mnmum 12 O.O1 0 0 0 0000000ttoemum 8230 2,0 700 1.1 4400 0001081Avenge 414 0 229 0 2141 0,000038

Frequency Ctertbutwn far flow (gpm) bom Pertd 6Q(gpm) Frequency %

0 - 2 0 2 82 0 - 4 0 2 84 0 - 0 0 3 120 0 - 8 0 1 4>80 IB 88

TOTALS 26 100

Frequency Dttibufen tor HG (ppb) ii Pond 5 EfluentHG topo) Frequency %

0- 5 41 1005 - 1 0 0 01 0 - 1 5 0 01 5 - 2 0 0 02 0 - 2 5 0 0> 2 5 0 0

TOTALS 41 100

Frequency Ortitxrton tor TDS (ppm) in Pond 5 EtluentTDS Frequency %

0- 2000 10 452000- 4000 21 534000- 8000 1 38000- 8000 0 0>OOOO 0 0

TOTAIS 40 tOO

0-49 AR30^8UQ Feasibility Study

Olin Chemicals Group - Saltviile OU-2Miscellaneous Technical Data

FLUOR DANIEL——————————————————————————————————————————

APPENDIX D-5Site Water Balance

The following text, tables, and figure are taken directly from the RemedialInvestigation (Rl) Report by Goider Associates (1993). Appendix T of the Rlis referenced in the text, but not included here. Please refer to the Rldirectly for further details and supporting documentation.

B752APPD.FS9 - FEB 1994 D-50 „ Feasibility StudyA R o U U S U I

April 1993______________________6-13____________________883-6174

6.2.4.3 North Fork Holston RiverThe North Fork Holston River is identified as Operable Unit3 and is the sub j ect of its own Remedial Investigation. Abrief description of the hydrology of NFHR follows. Flow inthe NFHR increases in the downstream direction through theriver reach which contains the Pond 5 subwatershed due tocontributions from tributaries (Robertson Branch Creek andthe Brinefield discharge) runoff and seepage. The NFHRresponds predictably to regional precipitation events.However, those events that are large enough or of sufficientduration to generate high flows in the Pond 5 DecantStructure outlet discharge are typically sufficient to raisethe flow in the NFHR to an elevation where flooding of theDecant Structure outlet culvert occurs. As a result,monitoring of the highest discharges from the outlet havenot been possible, and detailed correlations with NFHR stagehave not been established.

6.3 Site Water BalanceAn overall monthly water balance was formulated based ondata supplied by the existing monitoring network. Theobjectives of the monthly water balance were to:

o Identify the flows into and out of the Pond 5system;

o Estimate the order of magnitude of each flow;

o Quantify unknown flows to achieve annual waterbalance over a water year (October to September)within a 10 percent error range (90 percentconfidence interval).

The monthly water balance was based on a simple reservoirstorage equation applied to the pond as a "groundwaterstorage reservoir" and assuming no net change in storageover an average wateryear. This simple approach facilitatedidentification of flow components and permitted the

April 1993____________________6-14 _________________883-6174

reservoir storage component to be solved for netcontributions to or from groundwater beneath Pond 5 as thesingle unknown flow.

The monthly water balance model is presented in Appendix T.The Appendix includes the model formulation, results, andsensitivity studies. Sensitivity analyses were completed toidentify the most important parameters, and estimate theorder of magnitude of the error possible with the variousassumptions required by the lack of data.

The simplest water balance for Pond 5 incorporates onlydirect precipitation, evapotranspiration, and directoutflow, for which good volume estimates are known. Initialtotal annual volume estimates for these quantities, based onmonthly totals of daily data, are +86.8, -60.3, and -60.2million gallons (MG), respectively. Assumptions were addedto this overly simplified formulation to account forinterflow into the pond from the 150 acres of LittleMountain within the sub-watershed.

The gauging station in Swale 3 provides a record of thesurface water flowing in the upper section of the swale.The cistern that brings groundwater to the surface upstreamfrom the flume is the source of much of this flow. However,under all but high intensity or very long duration rainfall,much of the flow re-enters the local groundwater systembefore reaching State Route 611. Based on these conditions,an assumption was made that the flow monitored in the flumein Swale 3 represents a minimum estimate of the availablegroundwater that may reach Pond 5, and that similar flows(expressed as gpm per acre of contributing area) exist inthe other 4 swales. This assumption implies that thehydrogeology of the other swales is very similar to that ofSwale 3. The resulting volume estimate is assumed to flow

ar\ «™i r* i f*5 1 OR 3 0 k 8 M. 3

April 1993______________________6-15____________________883-6174

underground above State Route 611 and enter the pond asinterflow.

However, it has been observed that not all of the f lowpassing through the Swale 3 flume flows underground aboveState Route 611. Some flow is accumulated by the culvertinlets and passed to the Western Diversion Ditch, evenduring moderate precipitation events. Field observations offlows in the swales and the diversion ditch (see Table 6-5)and evaluation of the discharge hydrograph for the Swale 3flume were used to reconcile the reported observations ofhigh flows in the Western Diversion Ditch, and arrive at a"best estimate" for diversion ditch flows.

A careful review of the discharge record at the flumeindicated that peak flows over 100 gpm were rare but ofsufficient volume to account for the observations of highflow in the dissipator structures. Subsequent calculationsshowed that diversion of all flows above 95 gpm to theWestern Diversion Ditch corresponded to a total of 20percent of the estimated annual minimum volume available onLittle Mountain, derived above. The 20 percent value islower than the 33 percent estimate shown in Table 6-5, butis based upon a longer, more accurate series ofmeasurements.

The assumption that 20 percent of the total estimated annualflow from Little Mountain enters the diversion ditch leavesthe remaining 80 percent, or +36.8 MG, as inflow to Pond 5.The resulting water balance now has inflow from directprecipitation on the pond and interflow from LittleMountain, and outflow through evapotranspiration and directdischarge, or +86.8, +36.8, -60.3, and -60.2 MG,respectively. The resultant is an annual volume of +3.1 MGinflow, implying an offsetting volume of -3.1 MG as

April 199_3______________________6-16___________________883-6174

groundwater seepage loss from the pond. This was considereda successful overall annual balance. This seepage volume isapproximately 1 percent of the total annual precipitationvolume falling over the entire 213.8 acre sub-watershed (289MG) , or 2.5 percent of the estimated inflows. An overallannual water balance using a monthly time step wasconsidered to be acceptable if the result was within 5percent of the. total annual precipitation falling on thesub-watershed. Calculations for the water balance aresummarized in Table 6-6. A schematic diagram of the Pond 5water balance is presented in Figure 6-1.

6.4 Site Conceptual Hvdrolocric Flow Model6.4.1 Flow Through the Little Mountain Sub-WatershedThe dipping bedrock strata underlying the entire sub-watershed may be viewed as jointed and fractured rock beds,tipped up at an angle of 30 degrees to form Little Mountain.Regional vertical joint sets comprise weak zones along whichwater flows preferentially, forming the swales on LittleMountain. The exposed bedding layers are also eroded andtruncated by large cuts, forming State Route 611 and theformer river cut bench immediately below the WesternDiversion Ditch. These cuts, at nearly right angles to thedominant joint set, undercut the support of the rock up-slope, allowing large sub-vertical fractures paralleling thestrike of the strata to open. As a result, blocks ofunsupported rock slowly migrate downhill. In addition,some of the exposed bedding layers are relatively porous(e.g., the Price Formation sandstone).

The hydraulic response of the sub-watershed is controlled bythese conditions. Low or moderate intensity rain of anyduration falling on Little Mountain is first intercepted byvegetation, and then captured by surface depressions andsurface soil porosity. If enough rain falls to exceed this

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DIRECT PRECIPITATION(ESTIMATED FROM MEASUREMENTS)

INTERFLOWFROM LITTLE MOUNTAIN

(EST.MATED FROM MEASUREMENTS) (EST.MATED FROM REGIONAL DATA)

rEVAPOTRANSPIRATION

POND 5: ASAW + ALLUVIUM

+ COLLUVIUM + FILL

GROUNDWATER SEEPAGETO (FROM) BEDROCK

(UNKNOWN)

DISCHARGE FROM DECANTOUTLET TO NFHR

(ESTIMATED FROM MEASUREMENTS)

R 2:- 1393883-6174

DRAWN; EAMN.T.S.

DATE: 07/22/91VA01-251

SCHEMATIC DIAGRAM OFPOND 5 WATER BALANCE

GoJder Associates OLIN CORPORATION *"** 6-1


FLUOR DANIEL——————————————————————————————————————————

APPENDIX D-6

Calculations on Anticipated Mercury LoadingFrom Pond 5 to NFHR

B752APPD.FS9 - FEB 1994 _ ._ _ - _ - — D-58 fl p» o n i FI i n Feasibility Studyn K "I I i n H n MHflUUH-UHj


FLUOR DANIEL——————————————————————————————————————————

APPENDIX D-6Calculations on Anticipated Mercury Loading

From Pond 5 to NFHR

B752APPD.FS9 - FEB 1994 D-58 s n o A i Q cr r\ Feasibility Study


FLUOR DANIEL——————————————————————————————————————————

Calculations on Anticipated Mercury Loadingfrom Pond 5 to NFHR

The anticipated loading of mercury from Pond 5 to the NFHR is tabulated below for five scenarios.

Scenario

Average Flow and ConcentrationSince Completion of EDDAnticipated Discharge fromInterim Treatment PlantAnticipated Discharge fromVariable Rate Treatment with IonExchange (Alternative C-1)

Anticipated Discharge fromConstant Rate Treatment withpH Adjustment (Alternative C-2)Anticipated Flow from Outfallafter Capping (Alternatives F, G,andH)

Average Flow(gpm)54.4

54

54

54

4.53

Typical AnticipatedMercury Concentration

(ppb)75.3

101

0.42

1-24

17.43

Mercury Loading(Ibs/year)

18.0

2.4

0.10

0.43

0.35

1 Plant was designed to produce effluent with mercury concentrations below 20 ppb. Treatabiiity Studies yielded muchlower results. 10 ppb is anticipated as typical.

2 Literature indicates that these limits can be achieved, but Treatabiiity Studies would be required for verification.3 These values are averages for the period 1988 through Fall 1991. The low flow data during that period was condiered

to be the closest analogy to flows following installation of a cap. On those days, in 1988-Fall 1991, when flows werebelow 10 gpm, the flows actually averaged 4.5 gpm and the associated average mercury concentraiton was 17.4 ppb.

4. The Treatabiiity Study showed that with pH = 4±, an average of 1.7 ppb could be achieved using carbon adsorption.

As a basis for comparison, Fluor Daniel calculated the maximum allowable annual loadingconcentration of mercury in the Pond 5 discharge flow based on the following assumptions:

• Mercury from the FCPS contributes 0.0024 ppb to the flow in the NFHR (see calculation on nextpage). ^

• The allowable contribution of mercury from the Pond 5 discharge is equal to the chronic criteriain the NFHR (0.012 ppb) minus the contribution from the FCPS (0.0024 ppb), which leaves0.0096 ppb.

S752APPD.FS9 - FEB 1994 D-59 & r* o n I o r* i Feasibility Study


FLUOR DANIEL——————————————————————————————————————————

• Flow in the river, at the point of discharge, is approximately 23 cfs.

The calculated loading is approximately 23 cfs x 0.0096 ppb, or 0.435 Ibs/year. The figure belowpresents the results based on concentration.

O l i n SaItv I I leNFHR: 23 CFS, 0.0096 ppb Limit

90

80

70

2 SOQQ.W 50isL 4DJ

30

20

10

12 16 2010 14 18 22 26

Flowrate

B75ZAPPD.FS9 • FEB 1994 D-60 n n o n J ft" r *"> Feasibility Study


FLUOR DANIEL—————————————————————————————————————————————

Unit Cost of Mercury Removal by Pond 5 Effluent Treatment

Calculation consists of three steps:1) Determination of pounds of mercury migrating from Pond 52) Determination of present worth of the Pond 5 effluent treatment system3) Determination of cost per unit weight of mercury

Determination of pounds of mercury migrating from Pond 5General Assumptions:

Average Pond 5 effluent flow (prior to capping)95 gpm (average flow for 1988-1991, Treatabiiity Study - Fluor Daniel 1991, pg.2-1). A41% reduction in flow is projected due to the Eastern Diversion Ditch and modificationsto the Western Diversion Ditch (OU-1 Design Basis Review Meeting, March 24, 1992).95 gpm x (1-0.41) = 56 gpm - 80,710 gpd

Anticipated flow after capping of Pond 550,029 to 413,223 cu.ft. per year (HELP model, Appendix D of this document), so 6 gpm(413,223 cu.ft. per year) will be used for calculation. 6 gpm = 8640 gpd

Mercury concentration before treatment58 ppb (average concentration for 1988-1991, Treatabiiity Study - Fluor Daniel 1991, pg.2-3). 58 ppb = 4.84x10'7

Anticipated treatment efficiency of the Pond 5 treatment facility93.7% (Treatabiiity Study - Fluor Daniel 1991, pg.4-34)

Capping Assumptions:Preliminary procedures occur in first two years.Cap construction takes place in increments over the next four years as shown in the AlternativeP5G cost estimate earlier in Appendix C (37.5%, 37.5%, 12.5%, 12.5% in years 3, 4, 5, and 6respectively).Mercury concentration (before treatment) is assumed to drop from 58 ppb to acceptable level(20 ppb or less) after two additional years.

First Year: 365 days x 80,710 gpd - 29,460,000 galSecond Year: 365 days x 80,710 gpd = 29,460,000 galThird Year: 365 days x 80,710 gpd = 29,460,000 gal

B752APPO.FS9 FEB 1994 D-61 Feasibility Studyft EJ 3 (t J * w *-T OH n0 U4G Do


FLUOR DANIEL——————————————————————————————————————————

Fourth Year: 365 days x {0.625[80,710-8640]+8640} gpd = 19,647,000 galFifth Year: 365 days x {0.250[80,710-8640]+8640} gpd = 14,848,200 galSixth Year: 365 days x {0.125[80,710-8640]+8640} gpd = 6,442,000 galSeventh Year: 365 days x 8640 gpd = 3,154,000 galEighth Year: 365 days x 8640 gpd = 3,154,000 galTOTAL: 135,625,000 gal

135,625,000 gal x 4.84x10"7 Ib/gal = 65.7 ib.

Determination of present worth of the Pond 5 effluent treatment system

Year

12

3

4

5

6

7

8

Capital Expenses(1992 Dollars)

2,710,000

O&M(1992 Dollars)

240,000

240,000

240,000

240,000

240,000

240,000

352,000

240,000

TOTAL, 8 Years

Present Worth

2,950,000

234,000

229,000

224,000

218,000

213,000

306,000

204,000

4,578,000

Notes: 5% inflation and 7.5% investment return assumed.

Determination of cost per unit weight of mercury

$4,578,0007(0.937*65.7 Ibs) = $74,400/lb.

B752APPD.FS9 - FEB 1994 D-62 8 p Q fi It P. C! f, Feasibility StudyH t i w U H Q u H

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Olin Chemicals Group - Saltville OU-2Feasibility Study

FLUOR DANIEL—————————-——————-—————————————————————

FEASIBILITY STUDY

APPENDIX ECORRESPONDENCE WITH EPA

Table of Contents

Item

• Correspondence with EPA

B752TCA.FS9 g r» o ri i. o c r Table of ContentsAppendix EOU8

February 4, 1994 -i- Olin Saltville OU-2 FSResponse to October 28, 1993 Comments

RESPONSES TO THE OU-2 FEASIBILITY STUDYREVIEW COMMENTS OF OCTOBER 28, 1993

SALTVILLE WASTE DISPOSAL PONDS SUPERFUND SITE

A Feasibility Study (FS) Working Meeting was held on December 16, 1993, with representatives'of Olin, the EPA and the Virginia DEQ to discuss these comments and progress on the FS.Reference is made in these responses to decisions regarding specific comments which were madeduring the meeting. A summary of discussions at the meeting is attached.

Comment: No. 1, 1-24.Please modify the discussion in paragraph 6 concerning the Pond 6 outfallconcentrations. The only comparison that is relevant is to water quality criteria,not to the outdated Pond 5 target concentrations.

Response: The reference to the performance requirement of the First ROD has beendeleted from the text.

Comment: No. 2, 1-25.Soil/waste discussion says no TAL/TCL parameters were detected above blankconcentrations. However, metals are typically detected above blankconcentrations in soil even at background levels. Please clarify the discussion.

Response: The text has been revised as requested.

Comment: No. 3, 1-28.The discussion on the rest of this section reflects a risk assessment on one of thealternatives (institutional control). Please revise to reflect the revised riskassessment on the no-action alternative.

Response: A summary of the revised risk assessment has been provided. It addressesthe EPA's required no-action scenarios For Ponds 5 and 6 and for the FCPS.

Comment: No. 4, 2-1.The last paragraph needs to be modified to reflect the revised no-action riskassessment.

Response: Section 2-1 has been revised to reflect the EPA mandated "No Action"scenarios for Ponds 5 and 6 and for the Former Chlorine Plant Site (FCPS).

FN: FSCOMRES.DOC

February 4, 1994 -2- Olin Saltville OU-2 FSResponse to October 28, 1993 Comments

Comment: No. 5, 2-3.Demonstrate (first in the Rl report and then in summary in this section) what thefuture conditions of the water from Pond 6 would be. If the water is expectedto be clean, explain why in light of the similarities between Ponds 5 and 6. Thestatement in the Pond 6 discussion is insufficient in detail. If the futureconditions are unknown, indicate the probable conditions and identify reasonabledeviations to those conditions. Alternatives will be developed to addresspossibilities.

Response: Additional discussion on Pond 6 has been added to Section 1. Discussion ofknown characteristics and uncertainties have been expanded. As discussedduring the December 16 meeting, the text has been expanded to describe theuncertainties of predicting the potential for mercury migration via the Pond6 outfall discharge and the groundwater beneath Pond 6. The revised FSaddresses the uncertainty of these predictions with contingent components formigration control.

As agreed during the December 16 meeting, the objective/base actions forPond 6 also include:

• Provide pH adjustment/neutralization of the effluent;

• Prevent direct contact with the pond material by receptors; and

• Provide consideration of the potential for migration of the mercuryassociated with the Former Chlorine Plant debris deposited in Pond6.

Comment: No. 6, 2-4.Top of the page. The soil, waste, and groundwater at FCPS is very much afuture concern. The contamination is great in this area and there is nomaintenance of the existing containment options in the future no-actionalternative. Please revise all statements in the report that indicate the FCPS isnot of concern. Treat this site as the most contaminated area (it is) with thegreatest potential for future development (structurally stable). Through theevaluation of alternatives, the FS will show if the existing containmentremediation effort is sufficient or if more action is needed. EPA will make thisdecision.

Response: As agreed during the December 16 meeting, the discussion of the FCPS hasbeen revised to state that, under current conditions, there is no significantrisk to human health or the environment. Further, the text has been revisedto reflect that conditions at the site could deteriorate under the "No Action"scenario. The EPA mandated "No Action" alternative will include future

FN: FSCOMRES.DOC

R30«*858


industrial development of the site. As requested, additional alternatives weredeveloped to address the potential for mercury migration at the site.

Comment: No. 7, 2-5.Expand the objectives to include soil/waste and groundwater for FCPS.

Response: The objectives have been revised to address conditions which could result inmigration of mercury from the site (i.e. the potential for mercury-containingsoil/waste to release mercury to the groundwater which could then potentiallymigrate to the river).

Comment: No. 8, 2-8.Add maintenance of the Eastern Diversion Ditch to the no-action alternative.

Response: In the last submittal of the FS, maintenance of the Eastern Diversion Ditchwas deleted from the no-action alternative as requested in the commentsreceived in the first submittal of the FS. The "No Action" Alternative, aspresented in this submittal, assumes that the EDD and the OU-1 TreatmentFacility will be maintained.

Comment: No. 9, 2-8.Please delete limited action as a response action throughout this section. Limitedaction is an alternative; institutional controls and monitoring are the responseactions that are frequently used in limited action alternative.

Response: The "Limited Action" terminology was used in the December 1992 submittalin the place of "No Action", since the "No Action Response Action" includedcontinuation of existing remedial measures. AH use of "Limited Action" termhas been deleted from the text and tables in the revised FS.

Comment: No. 10, 2-9,Capping discussion for Pond 6 are not appropriate since there is uncertaintyabout future Pond 6 water quality. Either remove the discussion or revise toreflect the uncertainty.

Response: The potential for future changes in the Pond 6 water has been addressed.An expanded monitoring program has been added as a key component toprovide data to evaluate water quality over time. Contingent componentsare presented in consideration of the potential need for higher level ofprotection if mobilization of mercury occurs in the future.

FN: FSCOMRES.DOC 3 A I A r~ r\U4859

February4, 1994 -4- Olin Saltville OU-2 FSResponse to October 28, 1993 Comments

Comment: No. 11, 2-11.The second paragraph under "Removal", mention is made of risks to humans asbeing manageable and lower than industrial hygiene levels. The mention ofindustrial hygiene levels should be eliminated since those standards are notprotective of the general population in many instances and has no relevance inthis type of evaluation.

Response: The discussion in this paragraph refers to risks to construction workers, thusthe reference to industrial hygiene is pertinent.

Comment: No. 12, 2-13.Other response actions, technologies and process options to be included in thetechnology screening for the FCPS are capping-maintain existing cover, removal,vertical barriers, treatment, and onsite disposal. (Alternatives such as includingupgrading and containment action, removal and treatment, and consolidation onPond 5 need to be developed.)

Response: The FS has been revised to include the technologies and process options asrequested and as agreed at the December 16, 1993 meeting.

Comment: No. 13, Table 2.0-1.Add air regulations, both state and federal, and both chemical specific and action-specific.

Response: The air regulations have been reviewed. The regulations have been addedto the Table 2.0-1.

Comment: No. 14, Table 2.3.2-1.Add no-action response action. Remove limited action response action (not aresponse action).

Response: Please refer to the response to comment No. 9. Ail use of the term "LimitedAction" has been deleted from the text and tables.

Comment: No. 15, Table 2.3.2-1.Use of clean clay and use of sludges is not the same process option. Pleaseseparate into two process options.

Response: The table has been revised. Clay and sludges are discussed separately.

FN: FSCOMRES.DOC


Comment: No. 16, Table 2.4.2-1.More technologies need to be considered for Pond 6. There is no informationgiven to support the conclusion that future water discharge from Pond 6 will notcontain elevated levels of mercury. Similar technologies must be considered forPonds 5 and 6. Likewise, similar alternatives need to be developed.

Response: The potential for future release of mercury has been addressed as discussedin the response to comment No. 5. Table 2.4.2-1 has been revised to indicatethat technology options similar to those selected for Pond 5 have beenconsidered for Pond 6. Contingent components have been included forfuture implementation in the event that the expanded monitoring programindicates that mercury is migrating from Pond 6.

Comment: No. 17, Table 2.4.2-1.Clarification/gravity thickening is more of a water treatment process than adewatering process. Please delete.

Response: This process option has been deleted from the table as requested.

Comment: No. 18, Section 2 tables.There were a number of process options retained that were not developed intoalternatives: belt filter press, HEAP leaching, offsite landfill, resource recovery,hydraulic barrier extraction wells, special trench, and in-situ water chemicaltreatment. These options either need to be screened out, represented by otheroptions, or developed into alternatives. Please clarify.

Response: Filter presses are used as a process component of the ex-situ chemicaltreatment facility (Alternative P5K). Heap leaching has been screened out.Specialty trenches could be utilized at the FCPS as an upgradientgroundwater control measure. The selection of the actual interceptionsystem will be made during completion of the final design. In-situ watertreatment is a component of Alternative P5I since treatment will extend intothe saturated zone of the pond material.

Comment: No. 19, Section 2 tables.Add permeable ground cover (soil cover), surcharging and pH adjustments to thelist of process options screened. These were developed into alternatives and needto be included in Section 2.

Response: Natural soil caps are included. Surcharging is not a process option. It is aprocedure used to facilitate the implementation of the process option. Due

FN: FSCOMRES.DOC


to the addition of neutralization of the Pond 6 effluent, pH adjustment hasbeen added as a process option.

Comment: No. 20, Section 3.Capping Scenarios. Expand the effectiveness discussions on all cappingalternatives to include a discussion of the performances of each particular cappingscenario relative to RCRA Subtitle C requirements.

Response: The effectiveness discussion of each capping option addresses the ability ofthe cap to achieve the remedial action objectives.

Comment: No. 21, Section 3.Figure for this alternative is incorrectly identified.

Response: The references in the text to figures have been coordinated and correctlyidentified.

Comment: No. 22, p. 3-15.Figure for this alternative is incorrectly identified.

Response: The references in the text to figures have been coordinated and correctlyidentified.

Comment: No. 23, 3-22 and 3-25.Please clarify the difference between P5I and P5J. If there is a limiteddifference, please combine into one alternative. It appears that I is just acontingency if J is ineffective (p. 4-53 describes J as, "it may be necessary toapply reagent to chemically reduce the solubility of the mercury and additives torender the soil/waste physically stable"). If so, there should not be twoalternatives, just one with a contingency.

Response: Alternative P5I includes chemical fixation of the pond material (includingpond water) to an average depth of 25 feet. The intent of this alternative isto treat all of the pond material in the upper layer of Pond 5. Due to theuncertainty of vertical extent of mercury, treatment to a depth of 35 feet wasincluded as the high range cost scenario. The discussion of implementabilitystates that, due to the low bearing capacity, measures such as physicalsolidification might he utilize to provide a stable working surface for themixing equipment.

FN: FSCOMRES.DOC

R30«4862


Alternative P5J includes only physical solidification of the upper 20 feetwithout consideration of the mercury contained in the pond below thatdepth. The discussion on effectiveness included the reference to potential useof chemical fixation in the event that solidification was not effective.

The text has been revised to provide a clearer understanding of thecomponents of each of these alternatives.

Comment: No. 24.Develop an alternative with the same criteria as P5J (identified as P5J-1) forstabilizing the eastern, northern, and western perimeter to a depth of 20 feet.The concentration on Pond 5 consistently emphasizes that this is the area ofhighest mercury contamination. The lateral limit of stabilization will be basedon process knowledge, historical documentation, intervene, aerial photographyor whatever other resource Olin has available to base these decisions. Resourceswill be listed within the text of this alternative.

In the response package of the draft OU2 FS from Olin" dated May 7, 1993,comment No. 19, Olin states, ".... The alternative of solidification or fixation inlimited areas or throughout the pond was considered to be ineffective as a stand-alone remedy." The agency agrees, but feels that improved reliability andeffectiveness can be gained by capping and treating.

EPA also recognizes that there are uncertainties relative to appropriate reagent(s)and/or inert additive(s), and implementability. The uncertainty is not a basis fordisregarding treatment as Olin's response implies. The NCP states that ..."Eachremedial action shall utilize permanent solutions and alternative treatmenttechnologies or resource recovery technologies to the maximum extentpracticable." NCP 300.430(f)(ll)(E). Therefore, address the uncertainties byidentifying contingency alternatives.

Response: Alternative P5J-1 has been developed in response to this comment. TheHARZA data was utilized to identify the areas with the most significantmercury concentration.

Comment: No, 25, 3-25.Reference is made to studies completed by ENRECO and VFL Technology Corp.Please expand on the results of these studies or provide copies to EPA andVDEQ.

Response: The results of these tests are now discussed in greater depth in the text. TheENRECO report was previously presented in Appendix C. The VFL report

FN: HSCOMRES.DOC

B r* On h D rU M- b D


has been added to the report. These reports are now presented in AppendixF and so referenced in the text.

Comment: No. 26, 3-31.Although the concentrations of Hg at the Pond 5 outfall are not reflected in thePond 6 outfall analytical results, the ponds have been shown to be very similarin terms of the geologic and hydrogeologic characteristics. Therefore, developan alternative for Pond 6 that incorporates; continuation of monitoring,construction and maintenance of surface water diversion ditches, interceptorsystem of the shallow aquifer, and a multi-layer cap that would meet therequirements of RCRA Subtitle C.

Response: An expanded monitoring program has been added as a major component toall Pond 6 alternatives (with the exception of the "No Action" Alternative).Contingent components are presented in the FS in consideration of thepotential for future mobilization of mercury. These contingent componentsinclude construction and maintenance of upstream surface water diversionditch(s) and a multilayered'cap. Upgradient groundwater diversion has notbeen considered since it appears that the fracture flow from Little Mountainsurfaces before it reaches the pond.

Comment: No. 27, 3-33.A full evaluation, as required by the NCP, cannot be conducted at the FCPS onthe No-Action, Limited Action alternatives provided in the FS. The riskassessment shows under no-action that the FCPS is a potential future soil andgroundwater risk. There is also significant uncertainty on the ground water

. impacts on the river, (re-contaminated sediments do not support Rl conclusions).Develop an alternative considering the following components; (a) Upgradientground water control, (b) Downgradient ground water control, (c) Upgradeexisting cap and (d) Excavate and consolidate the soils and sediments of theFCPS with the material in Pond 5. (Specifics discussed at meeting).

Response: As agreed during the December 16 meeting, these technologies have beenincorporated into FCPS alternatives:

• Alternative FCPSC includes groundwater controls.

• Alternative FCPSD includes an improved, multilayed cap andgroundwater controls.

• Alternative FCPSE-1 includes removal and consolidation on Pond 5.

FN: FSCOMRES.DOC


Comment: No. 28, 4-28.The overall protection discussion of Alternative P6A must discuss the results ofthe revised no-action baseline risk assessment. Do not include the effects ofinstitutional controls in discussions of no-action alternatives.

Response: The "No Action" Alternative for Pond 6 has been revised to reflect the EPArequirements that in-place remedial measures will be neglected, the siteabandoned and the site used for residential development. The effects ofinstitutional controls will not be included in the "No Action" alternatives.However, for Pond 5 the "No Action" Alternative will include continuationof operation of the treatment plant and continued maintenance of theWestern Diversion Ditch as per the First ROD.

Comment: No. 29, 4-32.Please clarify how waters passing through the FCPS waste do not contribute toa groundwater aquifer. Aquifer has a regulatory definition that needs to beincluded in the discussion. The groundwater at the FCPS has a potential

" unacceptable future risk. (See comment 6.)

Response: The groundwater beneath the FCPS is not considered a viable aquifer basedon the potential yield and the unlikelihood of its being used as a potablewater source. The anticipated yield is too low for the area to be classifiedas an aquifer. The groundwater passes through the site and discharges intothe North Fork Holston River. To address potential unacceptable risks, anexpanded monitoring program has been added to appropriate alternatives tomonitor flow and provide data to evaluate groundwater quality over time.Additional alternatives to control groundwater have been developed.

Comment: No. 30, 4-33.Maintenance of the cap is not part of the no-action alternative and should not bediscussed as part of the effectiveness evaluation. This effectiveness discussionneeds to include a discussion on the risk from the soil/waste when the capdegrades.

Response: The no-action alternative has been revised to reflect the potential fordegradation of the existing cap.

Comment: No. 31, 4-34.Remove from this overall protection evaluation section and ail other sections thestatement that the "Risk Assessment considers the maintenance of fencing andother institutional controls will be sufficient to maintain risk to human receptors

FN: FSCOMRES.DOC


at an acceptable level." The risk assessment does not conclude which alternativesprovide suitable protection.

Response: The inference that the Risk Assessment concludes the effectiveness ofalternative measures has been deleted from the text.

Comment: No. 32, FCPS and Pond 6 Alternatives.Only the FS can conclude what alternative is sufficient after the alternativeevaluation. For instance, the evaluation to determine if the permanence andlong-term effectiveness of removal outweighs the cost is needed. The range oralternatives developed for both the FCPS and Pond 6 is insufficient.

Response: Additional alternatives for the FCPS and Pond 6 have been developed in therevised FS. See responses to comments No. 5, 6, 16 and 26.

Comment: No. 33, Table 4.3-1.This table would be clearer with a descriptive title for each alternative.

Response: The table has been modified to include the full titles of each alternative.

Comment: No. 34, 4-35.Compliance with ARAR's discussion mentions that a location specific variancefrom standards would need to be obtained. Clarify if this variance is theequivalent of the NCP waivers (if so, which one), or if it is the intent to meet theARAR but a Virginia variance has been obtained (or could be) for thesealternatives. If this is a regulation variance, please describe more fully.

Response: The intent is that a variance from the Virginia Water Quality Standards maybe needed for the particular alternative. Calculated mercury concentrationat 7Q10 may exceed the WQS but actual instream mercury concentrationsmay not since both flows and mercury concentration are related toprecipitation.

Comment: No. 35, 4-36.Redo the effective comparative analysis to reflect the true risk reduction of eachalternative and effectiveness of long-term effectiveness of each alternativeincluding a discussion on the impact on workers and the community duringconstruction and implementation.

Response: The comparative analysis has been revised to reflect the risk reductionprovided by each alternative. The effectiveness discussion of the comparative

FN: FSCOMRES.DOCR*"i f"l t t~\ S"30*486


analysis is divided into short term effectiveness and long term effectiveness.A discussion of impacts on workers and the community during constructionand implementation has been included in the discussion on short termeffectiveness.

Comment: No. 36, 4-36 2nd paragraph.A capping system does not make treatment unnecessary. Treatment improveslong-term effectiveness and permanence by reducing residual risk should the capfail. Removal statement and reflect the added long-term effectiveness thattreatment provides.

Response: The statement has been revised to indicate that treatment improves long termeffectiveness of capping options should the cap fail.

Comment: No. 37, 4-37.Implementability discussion. All alternatives have major uncertainties to theirsuccess, primarily as a result of the nature of the waste. Treatment alternativesmust not be downrated as a result of the uncertainty. The implementation of allalternatives will have to include the management of uncertainty, contingenciesare developed and evaluated as part of the uncertainty to control the uncertainty.

Response: The implementability discussion has been revised to identify the majoruncertainties of other alternatives.

Comment: No. 38, 4-38.Cost discussion. The fact that the treatment plant may have to operateindefinitely does not distinguish these alternatives from the others. In fact, allalternatives have operation and maintenance components forever. The caps willhave to not only be maintained but will probably also have to be replacedrepetitively. Modify the text to indicate all alternatives have long-term costs.

Response: The revised FS has been modified to recognize long-term costs for allalternatives.

Comment: No. 39, 4-39.Overall protection discussion. This discussion indicates that only P6C providesoverall protection. It is insufficient to only have one viable alternative. Thereis no reason to develop alternative P6B since it must meet this threshold criteria.

FN: FSCOMRES.DOCRon! £"> r ™»OUH867


Response: Additional alternatives, plus contingent components for Pond 6, have beenadded to the FS. Alternative P6B has been modified to meet Pond 6threshold criteria.

Comment: No. 40, 4-39.ARAR's discussion. Please discuss all ARAR's in this discussion (or at leastmention that all other ARARs are met).

Response: Alternative P6B has been revised to meet the threshold criteria for Pond 6.Additional alternatives and contingent components have been developed forPond 6.

Comment: No. 41, 4-39.Effectiveness discussion. There is a difference between the effectiveness (riskreduction) between Alternatives P6B and P6C. Ecological risk is not controlledby P6B, but is by P6C; therefore, P6C provides more effectiveness that must bereflected in this discussion.

Response: The discussion of long term effectiveness has been revised to state thatAlternative P6C is more effective than Alternative P6B for controllingecological risks.

Comment: No. 42, 4-41.Effectiveness discussion. The risk assessment did not conclude that the FCPSdoes not present an unacceptable risk to human health or the environment underthe no-action alternative. Finally, the need to continue monitoring andmaintenance is not a conclusions drawn in the effectiveness evaluation. It is anoverall conclusion of the FS and is presented in the proposed plan.

Response: The text has been modified to indicate the results of the revised riskassessment for the "No Action" Alternative. The discussion of continuingmonitoring and maintenance is not presented as a conclusion of theeffectiveness evaluation.

Comment: No. 43, Table 4.3-1.Short-term effectiveness needs to also address worker/community impact duringimplementation.

Response: These items has been addressed.

FN: FSCOMRES.DOC

R3Qi*868


Comment: No. 44, Table 4.3-1.Alternative P5F does not reduce toxicity, mobility, or volume through treatment.Modify the discussion to reflect this. Reduction of mobility through containmentis not relevant to this evaluation criteria.

Response: The text has been modified to indicate that only Alternatives P5I, P5J, andP5J-1 reduce mobility.

Comment: No. 45, Table 4.3-1.Explain why alternatives P5I and P5J may not meet ARAR's. Using this logicon all alternatives, none of the other alternatives would meet ARARs because oftheir inherent uncertainties. If no clearer explanation can be given why P5I andP5J do not meet ARARs, modify discussion to reflect their meeting ARARs.

Response: The text tables have been modified to indicate that these alternatives willpotentially comply with the ARARs.

Comment: No. 46, Table 4.3-1.The need for treatability studies is not a long-term effectiveness issue but rathera cost, or short-term effectiveness issue. Please modify table.

Response: The need for treatability studies have been removed from the long termeffectiveness section on Table 4.3-1.

Comment: No. 47, Table 4.3-1.Please include total present worth costs on the table to make comparison easier.Percentage increases are only relevant when the absolute costs are understood.

Response: The total capital costs, annual operating costs and present worth have beenadded to the tables that present the comparative analysis of alternatives.

Comment: No. 48, Table 4.3-1.Typically, public and agency acceptance are not addressed in FS's since theirinput has not yet been obtained. The comment here is to be aware that the FSassessment of these criteria and what the proposed plan and ROD presents couldbe very different.

Response: The discussion on public and agency acceptance has been removed from theFS text and tables. The introduction to Section 4 has been modified toindicate that public and agency acceptance can not be addressed at this time.

FN: FSCOMRES.DOC

R30l*369


Comment: No. 49, Table 4.3-2.An assessment that the benefit does not justify the cost does not belong in thecomparative analysis. This is a conclusions that EPA makes in the proposed planand ROD. Please remove all judgement about the cost-effectiveness from thistable and the rest of the document.

Response: Judgements concerning cost effectiveness have been removed from the FS.

Comment: No. 50, Table 4.3-3.There is the potential for significant future risks that the revised risk assessmentreflects. This table will need to be revised (as will the rest of the FS) to reflectthe new conclusions for the risk assessment.

Response: The text and tables in the FS have been revised to reflect the "no action"risk.

Comment: No. 51.Cost estimates. How often is it assumed that the cap would have to be replacedor require significant maintenance? Typically, every 20 or 30 years a capvirtually needs replacement, and this needs to be reflected in the present worthcost estimate.

Response: There are no data that we are aware of that support the conclusion that capsmust be replaced every 20 to 30 years. Some data available suggest that theprojected life of buried HDPE is over 700 years. Obviously, the testingconducted for this purposes is an accelerated aging test and cannot beverified by case histories. Finally, it should be recognized that the same capmaterials are used to line hazardous waste landfills, the liners of which arenot slated for replacement every 20 to 30 years.

FN: FSCOMRES.DOC

R3QWO

FILE COPYI¥ UNFTED STATES ENVIRONMENTAL PROTECTION AGENCY

VTxT REGION III841 Chestnut Building

Philadelphia, Pennsylvania 19107-4431

November 23, 1993

Mr. Keith D. RobertsPrincipal Environmental SpecialistOlin ChemicalsP.O. Box 248, Lower River RoadCharleston, TN 37310

Re: Meeting Minutes for Saltville OU2 Feasibility StudyReview Comment Meeting of 11/8/93

Dear Mr. Roberts:

Attached is a summary of the discussions during theFeasibility Study (FS) review meeting held at Saltville.Although few agreements were reached at the meeting, and we didnot have the opportunity to discuss every comment, I believethere was meaningful discussion on the more significant issuesinvolving Operable Unit 2. These issues are detailed in theattached minutes.

As our meeting concluded it was suggested that we meet againmid way through the revision process, I have tentativelyscheduled this meeting for December 16, 1993. I believe thiswill be beneficial to Olin, VDEQ and EPA, and expedite ourefforts to complete the FS. Please contact me after you have hadan opportunity to review the attached document. At that time Iwould like to discuss the schedule for the revised FS submission.

Sincerely,

Russell H. FishRemedial Project managerVA/WV Superfund Remedial Section

cc: Juiie Pfeffer CH2M HillJeffrey Howard VDEQGwen Pospisil 3RC23

"">//

Meeting Minutes

Attendees: John Gervais/Fluor DanielPeter Ingraham/GolderKeith Roberts/OlinJohn Burns/OIinRussell Fish/EPAJeff Howard/State of VirginiaJulie Pfeffer/CH2M HILL

Meeting Date: November 8, 1993

Meeting Location: Saltville Construction Trailer

Meeting Subject: Operable Unit 2 Feasibility Study Comment Resolution

Russ was held up by a canceled flight so Jeff began the meeting at 1:00 p.m. Juliespent a few minutes reviewing Russ' approach to this meeting. The intent was todiscuss the uncertainties at the three areas of the site and the potential means ofdealing with the uncertainties. In addition, the necessary range of alternatives at eacharea would also be discussed along with the level of detail needed in the evaluation.The hope was that upon completion this discussion would have clarified most of thecomments.

Julie mentioned that there are three ways to deal with site condition uncertainties:(1) select a worst case alternative to cover any reasonable condition, (2) select analternative whose base action covers the most probable condition but which alsoincludes contingencies for reasonable deviations, or (3) collect more data in a Phase 2Remedial Investigation (Rl).

Julie, Jeff, and Russ, over the course of the afternoon, identified some of theiruncertainties with Pond 6. There is uncertainty as to why the effluent from the pond isfairly clean compared to the effluent from Pond 5. There is also uncertainty in thequality of the groundwater in light of limited data. Pete explained why the hydrologyand geometry differences between the ponds is probably causing the differences ineffluent quality. Pete also explained that since the hydrogeology between the ponds issimilar and since there is probably a fairly impermeable bottom to the pond, anycontaminated groundwater is probably not migrating at levels of concern. Since noamount of data can ever confirm these interpretations, the group recognized that theseuncertainties may remain even after further data collection.

After the discussion of the uncertainties of Pond 6 site conditions, the conversationmoved to the addition of Feasibility Study (FS) alternatives for both Pond 5 and 6.

OROR50/OS3.WP5

The specific alternatives to be added are in the comments. Olin expressed a concernthat once an alternative was added to the FS, the alternative may be selected.Although Jeff and Julie pointed out that for the most part the purpose for addingalternatives was to provide reasonable high end alternatives to justify the selection oflower end alternatives, Jeff commented that there were no guarantees that addedalternatives would not be selected. Julie added (and Russ reiterated later) that EPAwas seriously looking at focused treatment for Pond 5 materials. Later in the day, Russtold Olin that the alternatives requested would be added to the FS, either by Olin or byEPA. Keith indicated that he would take this message to his management.

A discussion then began on the FCPS uncertainties. Jeff indicated that he wasuncertain about the long-term effectiveness of the existing cap while Julie indicated shewas uncertain with the conclusion that the groundwater from the site was not impactingthe river. Pete explained how the groundwater impact conclusion was reached. JohnB. then relayed how no groundwater was seen seeping into the open river channelwhen the sediment excavation work was being conducted in the early 1980s. It wasagreed that since the construction period extended through two flood events that ifsignificant quantities of groundwater were migrating from the FCPS to the river that itwould have been noticeable during construction. This additional piece of informationplus clarification on the location of various sediment sampling points eased theuncertainty of the groundwater impact conclusion. Also, Pete further described thegroundwater flow at the FCPS and indicated that there would be less gradient to theside, along the river. Therefore, the flow direction presented in the report would resultin the greatest loading to the river. Again, this discussion was helpful. Jeff felt thatthere is still some uncertainty on the issue of the effectiveness of the cap. (Russ laterexpanded on Jeffs concern in that in light of the long-term effectiveness uncertainty ofthe existing cap, future loadings to the river were uncertain and could worsen.)

At this point in the meeting, Russ arrived. He went over his major points for eacharea of the site.

Pond 5

• Add in situ treatment alternative.

• Use existing information to determine location for focused treatment andexpand the treatability effectiveness discussion.

FCPS

• Develop a full range of alternatives including the use of upgradient anddowngradient controls.

• Add an alternative to upgrade the existing cap.

• Add an alternative to remove contaminated waste and soil.

OROR50/053.WP5

• Discuss the uncertainty of the future groundwater impact on the river.

Pond 6

• Develop a full range of alternatives similar to the Pond 5 alternatives.

• Recognize the uncertainties at the pond due to limited data. Thepotential exists to make Pond 6 a separate Operable Unit (OU).

Russ then added an additional comment for FS revision. He asked for a betterdescription of where the buried waste was located and what was buried. Also if anydata exists on the levels of contamination of the material, it needs to be included in theFS also.

Another comment that will apply to the OU 3 Rl is to add a map of the river thatincludes sampling locations. Of particular importance are the sampling locationsupgradient, adjacent to, and immediately downgradient of all three site areas.

Comment 27 was clarified at Keith's request. The comment does not imply that onlyone alternative containing the listed components should be developed. Rather a rangeof alternatives using the listed components is to be developed. The specific selection ofa process option is to be done by Olin since they have the most knowledge about thesite. John B. then wanted to know if a treatment alternative would be requested laterby EPA since treatment was not listed in the comment. Russ responded that EPA wasmost concerned about treatment for Pond 5, not Pond 6. There was also discussionconcerning consolidating FCPS material onto Pond 5. Russ, Jeff, and Julie raised twopoints. First, offsite disposal options can be considered instead of onsite consolidation,if appropriate. And second, a CAMU approach can be adopted for the entire site,thereby not triggering LDRs for waste movement between the site areas.

The other issue brought up around comment 27 was that technologies have to he-added to the newly developed alternatives to make them effective. For instance,downgradient groundwater controls would not be effective without some means ot"reversing the hydraulic gradient.

More discussion around FCPS alternatives developed. Although Russ feels thatremoval is the highest end alternative to be considered in the FS, he did mention thatif treatment was being selected for Pond 5, then treatment of the removed andconsolidated material may need to be considered. Keith expressed some concern or,how to develop and evaluate alternatives that would be dependent on what wasselected for other site areas. Julie mentioned that usually site-wide alternatives arcdeveloped for the evaluation portion of the FS and that this may be one means . tshowing any necessary dependency between site area activities.

John B. then raised a concern about identifying contingencies to put into : he-alternatives. He did not want to supply contingencies for every possible

OROR50/053.WP5

Julie explained that if probable conditions and the most significant reasonabledeviations to those conditions could not be identified, then insufficient data exists. Itwas ultimately decided that the group needed to work together to identify thesignificant uncertainties, contingencies to the deviations, and trigger levels to identifywhen to implement the contingency. The group would then present their findings totheir respective managements for concurrence. The group's ability to develop a limitednumber of focused contingencies may be the best indicator of sufficient data.

Russ said EPA was concerned with the limited deep waste data and groundwater datain Pond 6 which led to uncertainties around the Rl conclusions. He also indicated thathe does not view Pond 6 as an immediate threat and delaying the remedy 3 years to doa Phase 2 Rl and FS may be acceptable to EPA. After some discussion to clarify thata full Rl and FS would probably need to be conducted as opposed to quickly collectingsome more information after the ROD is signed, Keith indicated that Olin would prefernot to do another Rl and FS. Russ indicated that while EPA decided, Olin needed tocomplete the OU 2 FS as the comments directed.

Russ and Jeff expressed concern over the results of ground water samples from wells 8and 9 reported in a recent Milestone Report and the RL The data may indicateground water contamination migrating to the NFHR.

Jeff indicated that the high pH and alkalinity values of the pond effluents exceed statestandards. John B. indicated that he felt the soon-to-be-built or a new packagetreatment plant could reduce the levels to allowable limits. Though not directed to doso, Olin may need to address this issue in the FS.

Clarification that the last sentence of comment 32 is the key element of the commentwas provided.

John B. expressed concern over the amount of work that needed to be done and thatsufficient information may not be available to evaluate the alternatives fully. Russindicated that although there was considerable work to be performed, much of theengineering had been done. However, he did not specify a schedule since he realizedthat the comments would require significant reworking of the FS. Keith agreed to giveRuss a estimate of the time required once he had met with his management.

Russ then expressed concern over continually revising reports. All agreed that ameeting part way through the report revision would help make the next version the last,At the next meeting, resolution on how to proceed considering the decision made byEPA on whether or not to break out Pond 6 as a separate OU would be reached. Theresolution could then be presented to management or lawyers as needed.

At the end of the meeting, Russ agreed to sharing with Olin any treatabiiityinformation that he receives from ORD. The meeting concluded at about 6:00 p.m.

OROR50/OS3.WP5 4 SR30U87S

UNFTED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107-4431

October 28, 1993

Mr. Keith RobertsPrincipal Environmental Specialist Olin ChemicalsP.O. Box 248, Lower River RoadCharleston, TN 37310

Re: Notice of Deficiencies; Review of OU2 Draft FeasibilityStudy, Saltville Waste Disposal Ponds Superfund Site

Dear Mr. Roberts:

EPA has completed it's review of the Draft OU2 FeasibilityStudy dated May 1993. The review comments responding to thisdocument has been delayed to allow the for the review of therevised OU2 Remedial Investigation and Risk Assessment text.Additional information as outlined in the review comments isrequired to finalize the Feasibility Study.

In general the comments fall into two categories. First,the report continues to draw conclusions based on severaluncertainties surrounding the site. The uncertainties need to beclearly identified throughout the report. Further, contingenciesneed to be developed to account for the uncertainties. Thecontingencies are addressed in the attached review comments asadditional alternatives or additional components to alternativesthat need to be developed and evaluated. Although there areuncertainties with respect to each of the three areas of OperableUnit 2, the uncertainties are more prevalent in the Pond 6 andFCPS area.

Secondly, the discussions on effectiveness and permanencethroughout the document are incomplete. The discussions lacksufficient level detail and appropriate elements to permit a fullevaluation of alternatives. Specifics are discussed in thecomments.

As we have agreed, a meeting has been scheduled to discussthe review comments for November 8, 1993. The meeting will beheld in Saltville and will convene at 1:00 PM. Should you haveany questions regarding these comments, please contact me at(215) 597-9023.

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Sincerely,

Russell H. FishRemedial Project ManagerVA/WV Superfund Remedial Section

cc: Gwen Pospisil, 3RC23Julie Pfeffer, CH2M HillJeffrey Howard, VDEQ

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OU2 FEASIBILITY STUDY REVIEW COMMENTSSALTVILLE WASTE DISPOSAL PONDS SUPERFUND SITE

1. p. 1-24. Please modify the discussion in paragraph 6concerning the Pond 6 outfall concentrations. The onlycomparison that is relevant is to water quality criteria,not to the outdated Pond 5 target concentrations.

2. p. 1-25. Soil/waste discussion says no TAL\TCL parameterswere detected above blank concentrations. However, metalsare typically detected above blank concentrations in soileven at background levels. Please clarify the discussion.

3. p. 1-28. The discussion on the rest of this sectionreflects a risk assessment on one of the alternatives(institutional control). Please revise to reflect therevised risk assessment on the no-action alternative.

4. p. 2-1. The last paragraph needs to be modified to reflectthe revised no-action risk assessment.

5. p. 2-3 Demonstrate (first in the Rl report and then insummary in this section) what the future conditions of thewater from Pond 6 would be. If the water is expected to beclean, explain why in light of the similarities betweenPonds 5 and 6. The statement in the Pond 6 discussion isinsufficient in detail. If the future conditions areunknown, indicate the probable conditions and identifyreasonable deviations to those conditions. Alternativeswill be developed to address possibilities.

6. p. 2-4. Top of the page. The soil, waste, and groundwaterat FCPS is very much a future concern. The contamination isgreat in this area and there is no maintenance of theexisting containment options in the future no-actionalternative. Please revise all statements in the reportthat indicate the FCPS is not of concern. Treat this siteas the most contaminated area (it is) with the greatestpotential for future development (structurally stable).Through the evaluation of alternatives, the FS will show ifthe existing containment remediation effort is sufficient orif more action is needed. EPA will make this decision.

7. p. 2-5. Expand the objectives to include soil\waste andgroundwater for FCPS.

8. p. 2-8. Add maintenance of the Eastern Diversion Ditch tothe no-action alternative.

9. p. 2-8. Please delete limited action as a response actionthroughout this section. Limited action is an alternative;institutional controls and monitoring are the responseactions that are frequently used in limited actionalternative.

10. p, 2-9. Capping discussion for Pond 6 are not appropriatesince there is uncertainty about future Pond 6 waterquality. Either remove the discussion or revise to reflectthe uncertainty.

11. p. 2-11. The second paragraph under "Removal", mention ismade of risks to humans as being manageable and lower thanindustrial hygiene levels. The mention of industrialhygiene levels should be eliminated since those standardsare not protective of the general population in manyinstances and has no relevance in this type of evaluation.

12. p. 2-13. Other response actions, technologies and processoptions to be included in the technology screening for theFCPS are capping-maintain existing cover, removal, verticalbarriers, treatment, and onsite disposal. (Alternativessuch as including upgrading the containment action, removaland treatment, and consolidation on Pond 5 need to bedeveloped.)

13. Table 2.0-1. Add air regulations, both state and federal,and both chemical specific and action-specific.

14. Table 2.3.2-1. Add no-action response action. Removelimited action response action (not a response action).

15. Table 2.3.2-1. Use of clean clay and use of sludges is notthe same process option. Please separate into two processoptions.

16. Table 2.4.2-1. More technologies need to be considered forPond 6. There is no information given to support theconclusion that future water discharge from Pond 6 will notcontain elevated levels of mercury. Similar technologiesmust be considered for Ponds 5, and 6. Likewise, similaralternatives need to be developed.

17. Table 2.4.2-1. Clarification/gravity thickening is more ofa water treatment process than a dewatering process. Pleasedelete.

18. Section 2 tables. There were a number of process optionsretained that were not developed into alternatives: beltfilter press, HEAP leaching, offsite landfill, resourcerecovery, hydraulic barrier extraction wells, specialtrench, and in-situ water chemical treatment. These optionseither need to be screened out represented by other options,or developed into alternatives. Please clarify.

19. Section 2 tables. Add permeable ground cover (soil cover),surcharging and Ph adjustment to the list of process optionsscreened. These were developed into alternatives and needto be included in Section 2.

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20. Section 3. Capping Scenarios Expand the effectivenessdiscussions on all capping alternatives to include adiscussion of the performance of each particular cappingscenario relative to RCRA Subtitle C requirements.

21. p. 3-10. Figure for this alternative is incorrectlyidentified.

22. p. 3-15. Figure for this alternative is incorrectlyidentified

23. pp. 3-22 and 3-25. Please clarify the difference betweenP5f and P5J. If there is a limited difference, pleasecombine into one alternative. It appears that I is just acontingency if J is ineffective (p. 4-26 describes J as, "itmay be necessary to apply reagent to chemically reduce thesolubility of the mercury and additives to render thesoil\waste physically stable"). If so, there should not betwo alternatives, just one with a contingency.

24. Develop an alternative with the same criteria as P5J(identified as P5J-1) for stabilizing the eastern, northern,and western perimeter to a depth of 20 feet. -Thedocumentation on Pond 5 consistently emphasizes that this isthe area of highest mercury contamination. The laterallimit of stabilization will be based on process knowledge,historical documentation, interviews, aerial photography orwhatever other resource Olin has available to base thesedecisions. Resources will be listed within the text of thisalternative.

In the response package of the draft OU2 FS from Olin datedMay 7, 1993, comment No. 19, Olin states, ". . . . Thealternative of solidification or fixation in limited areasor throughout the pond was considered to be ineffective as astand-alone remedy." The agency agrees, but feels thatimproved reliability and effectiveness can be gained bycapping and treating.

EPA also recognizes that there are uncertainties relative toappropriate reagent(s) and/or inert additive(s), andimplementability. The uncertainty is not a basis fordisregarding treatment as Olin's response implies. The NCPstates that ..."Each remedial action shall utilize permanentsolutions and alternative treatment technologies or resourcerecovery technologies to the maximum extent practicable."NCP 300.430(f)(ii)(E). Therefore, address the uncertaintiesby identifying contingency alternatives.

25. Page 3-25. Reference is made to studies completed by ENRECOand VFL Technology Corp. Please expand on the results ofthese studies or provide copies to EPA and VDEQ.

26. p. 3-31. Although the concentrations of Hg at the Pond 5outfall are not reflected in the Pond 6 outfall analyticalresults, the ponds have been shown to be very similar interms of the geologic and hydrogeologic characteristics.Therefore, develop an alternative for Pond 6 thatincorporates; continuation of monitoring, construction andmaintenance of surface water diversion ditches, interceptorsystem of the shallow aquifer, and a multi-layer cap thatwould meet the requirements of RCRA Subtitle C.

27. p. 3-33. A full evaluation, as required by the NCP, cannotbe conducted at the FCPS on the No-Action, Limited Actionalternatives provided in the FS. The risk assessment showsunder no-action that the FCPS is a potential future soil andgroundwater risk. There is also significant uncertainty onthe ground water impacts on the river, (re-contaminatedsediments do not support Rl conclusions). Develop analternative considering the following components; (a)Upgradient ground water control, (b) Downgradient groundwater control, (c) Upgrade existing cap and (d) Excavate andconsolidate the soils and sediments of the FCPS with thematerial in Pond 5. (Specifics discussed at meeting).

28. p. 4-28. The overall protection discussion of AlternativeP6A must discuss trie results of the revised no-actionbaseline risk assessment. Do not include the effects ofinstitutional controls in discussions of no-actionalternatives.

29. p. 4-32. Please clarify how waters passing through the FCPSwaste do not contribute to a groundwater aquifer. Aquiferhas a regulatory definition that needs to be included in thediscussion. The ground water at the FCPS has a potentialunacceptable future risk. (See comment 6.)

30. p. 4-33. Maintenance of the cap is not part of the no-action alternative and should not be discussed as part ofthe effectiveness evaluation. This effectiveness discussionneeds to include a discussion on the risk from thesoil/waste when the cap degrades.

31. p. 4-34. Remove from this overall protection evaluationsection and all other sections the statement that the " RiskAssessment considers that maintenance of fencing and otherinstitutional controls will be sufficient to maintain riskto human receptors at an acceptable level." The riskassessment does not conclude which alternatives providesuitable protection.

32. FCPS and Pond 6 Alternatives. Only the FS can conclude whatalternative is sufficient after the alternative evaluation.For instance, the evaluation to determine if the permanenceand long-term effectiveness of removal outweighs the cost isneeded. The range of alternatives developed for both the

FCPS and Pond 6 is insufficient.

33. Table 4.3-1. This table would be clearer with a descriptivetitle for each alternative.

34. p. 4-35. Compliance with ARAR's discussion mentions that alocation specific variance from standards would need to beobtained. Clarify if this variance is the equivalent of theNCP waivers (if so, which one), or if it is the intent tomeet the ARAR but a Virginia variance has been obtained (orcould be) for these alternatives. If this is a regulationvariance, please describe more fully.

35. p. 4-36. Redo the effective comparative analysis to reflectthe true risk reduction of each alternative andeffectiveness of long-term effectiveness of each alternativeincluding a discussion on the impact on workers and thecommunity during construction and implementation.

36. p. 4-36. 2nd paragraph. A capping system does not maketreatment unnecessary. Treatment improves long-termeffectiveness and permanence by reducing residual riskshould the cap fail. Remove statement and reflect the addedlong-term effectiveness that treatment provides.

37. p. 4-37. Implementability discussion. All alternativeshave major uncertainties to their success, primarily as aresult of the nature of the waste. Treatment alternativesmust not be downrated as a result of the uncertainty. Theimplementation of all alternatives will have to include themanagement of uncertainty. Contingencies are developed andevaluated as part of the uncertainty to control theuncertainty.

38. p.4-38. Cost discussion. The fact that the treatment plantmay have to operate indefinitely does not distinguish thesealternatives form the others. In fact, all alternativeshave operation and maintenance components forever. The capswill have to not only be maintained but will probably alsohave to be replaced repetitively. Modify the text toindicate all alternatives have long-term costs.

39. p. 4-39. Overall protection discussion. This discussionindicates that only P6C provides overall protection. It isinsufficient to only have one viable alternative. There isno reason to develop alternative P6B since it must meet thisthreshold criteria.

40. p. 4-39, ARAR's discussion. Please discuss all ARAR's inthis discussion (or at least mention that all other ARARsare met).

41. p. 4-39. Effectiveness discussion. There is a differencebetween the effectiveness (risk reduction) between

Alternatives P6B and P6C. Ecological risk is not controlledby P6B, but is by P6C; therefore, P6C provides moreeffectiveness that must be reflected in this discussion.

42. p. 4-41. Effectiveness discussion. The risk assessment didnot conclude that the FCPS does not present an unacceptablerisk to human health or the environment under the no-actionalternative. Finally, the need to continue monitoring andmaintenance is not a conclusion drawn in the effectivenessevaluation. It is an overall conclusion of the FS and ispresented in the proposed plan.

43. Table 4.3-1. Short-term effectiveness needs to also addressworker/community impact during implementation.

44. Table 4.3-1. Alternative P5F does not reduce toxicity,mobility, or volume through treatment. Modify thediscussion to reflect this. Reduction of mobility throughcontainment is not relevant to this evaluation criteria.

45. Table 4.3-1. Explain why alternatives P5I and P5J may notmeet ARAR's. Using this logic on all alternatives, none ofthe other alternatives would meet ARARs because of theirinherent uncertainties. If no clearer explanation can begiven why P5I and P5J do not meet ARARs, modify discussionto reflect their meeting ARARs.

46. Table 4.3-1. The need for treatability studies is not along-term effectiveness issue but rather a cost, or short-term effectiveness issue. Please modify table.

47. Table 4.3-1. Please include total present worth costs onthe table to make comparison easier. Percentage increasesare only relevant when the absolute costs are understood.

48. Table 4.3-1. Typically, public and agency acceptance arenot addressed in FS's since their input has not yet beenobtained. The comment here is to be aware that the FSassessment of these criteria and what the proposed plan andROD presents could be very different.

49. Table 4.3-2. An assessment that the benefit does notjustify the cost does not belong in the comparativeanalysis. This is a conclusion that EPA makes in theproposed plan and ROD. Please remove all judgement aboutthe cost-effectiveness from this table and the rest of thedocument.

50. Table 4.3-3. There is the potential for significant futurerisks that the revised risk assessment reflects. This tablewill need to be revised (as will the rest of the FS) toreflect the new conclusions for the risk assessment.

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51. Cost estimates. How often is it assumed that the cap wouldhave to be replaced or require significant maintenance?Typically, every 20 or 30 years a cap virtually needsreplacement, and this needs to be reflected in the presentworth cost estimate.

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V lin CHEMICALSP.O. BOX 248, LOWER RIVER ROAD. CHARLESTON. TN 37310

Phone: (615) 336-4000

May 7, 1993

Mr- Russ H. FishVA/WV Remedial Response SectionUnited States Environmental Protection AgencyRegion HI841 ChestnutPhiladelphia, PA 19107

Re: Responses to CommentsDraft Feasibility StudyOperable Unit 2Saltville Waste Disposal Site

Dear Mr. Fish:

EPA recently provided Olin with comments on Olin's draft Feasibility Study forOperable Unit 2 at the Saltville Waste Disposal Site. We have reviewed EPA's comments and.have prepared a response for each comment. The responses reflect discussions from the jointOlin-EPA-Virginia meeting held in Philadelphia on April 6.

The Feasibility Study is presently under revision. Our responses to your comments arebeing incorporated into the revised Feasibility Study.

We plan to submit the revised Feasibility Study for OU-2 on May 13 as requested byEPA. The purpose of this submittal of these responses is to provide the opportunity to EPA toflag any concerns which EPA may have on this revised Feasibility Study.

If you have any comments on these responses, please call me at 615-336-4388.

Sincerely,

Keith D. RobertsPrincipal Environmental Specialist

KDR/lh144

O L I N C O R P O R A T I O N

OU-2 FEASIBILITY STUDY REVIEW COMMENTSSALTVILLE WASTE DISPOSAL PONDS SUPERFUND SITE

Comment: No. 1, Ch 1The Eastern Diversion Ditch appears to be misplaced on Figure 1.3.1-3.Also provide information on the condition of the cap at the plant area.

Response: The Figure presented in the Draft Feasibility Study represents the initialalignment contemplated for the Eastern Diversion Ditch (EDO). It willbe updated to reflect the as-built alignment.

Section 1.4 will be expanded to include additional Informationdescribing the remedial action design, conditions, and maintenanceprogram for the former chlorine plant site (FCPS).

Comment: No. 2, 1-10At the Chlorine Plant, describe the thicknesses of the units mentioned hereand their relative elevation with respect to the River. Indicate depth togroundwater. Provide estimates of hydraulic conductivity and transmissivrtyin the alluvium/weathered rock zone for comparison with bedrock valuesgiven on page 1-11. This information is important to understanding therelationship of the hydrogeologic units to the transport pathway of infiltrationto groundwater.

Response: A detailed discussion of past investigations at the FCPS is presentedin the Previous Data Summary, Milestone Report No. 1. The Final DraftFeasibility Study (FS Report) will include an expanded review of datarequested and references to relevant data presented In previouslysubmitted documents.

Comment: No. 3, 1-19Increased airborne concentrations of mercury were observed duringprocessing of river sediments. How do the mercury concentrations in thesediments compare to concentrations in the sludges now being consideredfor processing?

Response: The materials processed as part of the River Remediation Operationsand the materials contained In the ponds are vastly different in materialproperties and the forms of mercury contained in the materials. Theponds comprise ammonia soda ash waste (ASAW) with mercuryadsorbed to the fine material particles. The remediated river sedimentsconsisted of sands, slits and gravels containing elemental mercury.

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During the river sediment processing, the sediments were excavatedand screened to remove the coarse fraction of the sediments during thescreening, mercury vapor emissions were noted to be high on only oneoccasion.

No measurable airborne concentrations of mercury were noted withinthe excavation or the breathing zone of workers during field testexcavations nor during the construction of the eastern diversion ditch(This fact was noted on page 3*12). Likewise, during grading studiesrecently completed, most volatile mercury readings were non-detect.When detected, the readings were well below acceptable industrialwork levels. Prior to Implementation of the selected remedy, a healthand safety plan will be prepared. One component of the plan will beair monitoring for mercury.

Comment: No. 4, 1-20Concentrations of mercury found in soil samples as high as 11,471 ppmwere found, in addition, there has been found a gradual increase ingroundwater contamination towards the river from the former plant site, itis unclear why no further discussion regarding this phenomenon ispresented. Additional discussion is needed to justify the exclusion ofgroundwater treatment from the former plant site.

Response: The Previous Data Summary, Milestone Report No. 1, containsInformation regarding the measurements of groundwater mercuryconcentrations at the FCPS. The data indicates that since thecompletion of the closure activities completed in 1983, the mercuryconcentration in the groundwater samples has decreased by an orderof magnitude. A summary table of the mercury concentrationsrecorded since 1982 will be prepared and added to Section 1.4.Additional discussion of this data will be provided in the FS Report.

Mercury loading from the former chlorine plant site to the North ForkHolston River is monitored annually. The data are ported to the SWCB.This data will be summarized and added to the appropriate section ofthe FS Report

The data indicate that the groundwater flow passing through the formerchlorine plant site has greatly diminished (as a result of the cappingand construction of an upgradient surface water diversion ditch) andsubsequently diminished groundwater discharges to the river; thus,significantly reducing mercury loading to the river.

Additional text will be provided relative to these facts and supportingelimination of the former chlorine plant site from consideration of

ar% O fi I r> O "7R30H887

further remediation other than continued maintenance of existingremedial measures and institutional controls.

Comment: No. 5, 1-21"The highest Pond 5 mercury contamination reported in the FS was 93.75ppm (p. 1-21). However, the 1981 report by Roberts and Berry "In-SituStabilization of Mercury in Saltville Pond Sludge - Site Test1 cited a peakconcentration of 170 ppm (p. 24). Is the difference indicative ofheterogeneity in the sludge, or is "rt an indication of losses of mercury(downward/lateral migration, volatilization, etc.)?

Response: The data presented in the FS Report was taken from the Rl Report andare a conglomeration of several data sets. It appears that the data setpresented in the 1981 report by Roberts and Berry was omitted. Theavailable data indicate that the difference between apparent peakconcentration Is due the heterogeneity of the pond mass anddistribution of mercury in the pond. There are no data to support atheory that the mercury is migrating either downward or laterally, otherthan by the mechanism of flow of water through the pond via fractures,seams and cracks toward the outfall structure. Factors that effect theheterogeneity of the mercury concentrations in Pond 5 are ASAWparticle size, discharge points of mercury bearing waste streams, anddevelopment of fractures within the upper portion of the ASAW duringsettling within the ponds. Another factor affecting the location of thepredominant mercury bearing wastes within the ponds is the period ofchlorine plant operation. The data developed during the remedialinvestigation and previous investigations suggest that mercury isstrongly attracted to ASAW being adsorbed to the very fine particles orheld in the interstitial pore water. The mercury concentration isexpected to vary both in depth due to the period of operation of theformer chlorine plant (the source of the mercury) and areally due tothe varied points of mercury bearing wastewater discharge onto thesurface of Pond 5. Pond 5 was constructed in 1926, but received wastefrom the former chlorine plant only from 1951 to 1972. Thus based onvolumetric calculations these mercury bearing wastes would be presentwithin the upper 20 ± feet of the pond solids. The HARZA Report(March, 1980) supports this conclusion; however, mercuryconcentrations exceeding 1 ppm were observed in 15 of the 19readings recorded at a depth interval of 20.0 to 21.5 feet; 4 of 19 at25.0 to 26 5 feet and 1 of 19 at 30.0 to 31.5 (Split spoon samples werecollected on 5 feet intervals commencing at the surface). Preferentialflow of pond water through fractures and seams toward the pondoutfall as well as the affect of the rising and receding water table mayhave caused the mercury to have migrated to greater depths in theinterim from November 1979 (date of sample collection) to present.

3f"S t £"} i™> fll i l t K X XU H O O O

Comment: No. 6, 1-21It is unclear how much actual contamination exists at Pond 5. Varyingestimates (4 million cubic yards, 2 million cubic yards, and 7.5 million cubicyards) are presented. In addition, much discussion is presented regardingareas where mercury contamination is as deep as 17.5 feet. A plan shouldbe provided by Olin showing concentrations gradients at Pond 5 sludgesto better ascertain whether the contamination appears over the entire Siteor in smaller concentrated areas.

Response: A plan location of sampling points and a tabulation of sample mercuryconcentrations are presented in the previous data summary.Operational data indicates that the majority of the mercury wasdeposited along with the ASAW during the period that the top 20 ± feetof pond material was accumulated. The mercury concentration variesirregularly within this zone. Typically, the higher concentrations dooccur in the top 15 to 20 feet Areally, there appears to be apredominance of higher mercury concentration In the western, northernand eastern sections of Pond 5.

Due to the variability of the depth to which mercury contamination Ispresent, the variability of the concentration of the mercury and thevariability of the soil/waste mass, it will be necessary to complete fieldTreatability Studies to determine the appropriate reagent/additive, themethod of application and the limits (depth and area) of treatment Theadditional characterization of the pond materials as to mercuryconcentration and location would be required in conjunction with theTreatability Studies in order to define the limits of treatment. Also referto response to Comment No. 5.

As requested, figures showing mercury concentration for samplescollected (HARZA, March 1980) at various depths throughout Pond 5will be prepared. However, caution should be exercised when usingsuch a plan which is based on minimal data points. The maze offissures, cracks, seams and fractures make It unfeasible to collectsufficient test data to fully characterize the total pond mass.

The volumes presented are for pond mass and are based simply ondepth and area. The text in Section 3.3 will be expanded to include thebasis for the calculation of each volume.

Comment: No. 7, 1-22Clarify the implied "target concentrations" for Pond 5 outfall and discusstheir basis.

Response: The "target concentration" for Pond 5 outfall as well as for Pond 6outfall was selected based on the discharge limits specified in first

ROD. This ROD requires that a mean 24 hour concentration of 20 ppbof mercury In the discharge be achieved, it Is our understanding thatnew acute and chronic criteria for mercury have been adopted byVirginia and that these criteria will become an ARAR for Operable Unit2 unless a waiver is granted by the Agencies.

Comment: No. 8, 1-22Provide a map showing location of wells and soil borings in Pond 5, Pond6, and the.Chlorine Plant; indicate wells where samples exceed 0.002 mg/land borings where samples exceed 0.020 mg/kg. In particular, illustratewells located between the ponds/plant and the river and the contaminationfound in these wells.

Response: A map showing the locations of wells and soil borings and samplemercury concentrations is presented in the Remedial Investigationreport Similar plans have been prepared for the chlorine plant and arepresented in the previous data summary. These plans andcorresponding data summaries will be appended to the FS Report

Comment: No. 9, 1-22A discussion of contaminant ranges is given (0,30 ppm to 78.3 ppm),however, no volume of contaminated soils above any health based level isgiven. On page 2-3, a value of 20 ug/g is used as a criterion for Pond 5.Clearly, this level is exceeded at Pond 6. An explanation as to why Pond6 soil/waste material is not included for remediation is needed.

Response: The primary remedial objective for Operable Unit 2 as presented onpage 2-1 of the FS Report is ..."Prevent the assimilation of mercury bythe public or the environment resulting from contact with or ingestionof mercury." Likewise, the criteria presented on page 2-3 pertains topreventing ingestion/direct contact with soil/waste having mercury inexcess of 20 //g/g. The presence of mercury at this site atconcentrations exceeding this value has not been established as a riskto human health or to the environment According to the RiskAssessment (ABB 1993), the only significant source of mercury posinga potential threat is the effluent from Pond 5 as long as the existing siteaccess controls of Pond 6 and the former chlorine plant site aremaintained. This is stated in Section 2.1. This discussion (Section 2.1)will be expanded to include specific excerpts from the RiskAssessment.

Comment: No. 10, 1-23The contaminant fate and transport section is insufficient. The potentialvolume and concentrations of mercury in groundwater seeping through the

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dike must be provided. Provide calculations showing estimates of seepageof groundwater to the effluent weir and seepage of groundwater throughthe effluent dike. Discussion is needed of why the fractures are attributedto desiccation when they are described as meandering from the swaies andhave little or no circumferential fracturing.

Response: The Rl Report contains an extensive section dealing with contaminantfate and transport from Pond 5 and a water balance for the Pond 5watershed system. A summary of these data is presented in Section1.4.5. This discussion will be expanded as requested to include moredetail from the Rl Report. The water balance study conducted duringthe Rl indicated seepage through the dike is very small. The findingsof the water balance will be added to the FS. It Is considered that thedetermination of the volume and mercury concentration of seepagethrough the dike can not be determined finitely. The water balanceindicates that the potential seepage is negligible. There are no visibleseeps along the bank or other indications of leakage through the dike.The dike is a massive structure comprised of material with permeabilityin the range of 10"7 to 10"9.

Although, there is a prevalent meandering of surface fractures towardthe outfall structure; there is also circumferential fracturing asevidenced by photographs of Pond 5.

Comment: No. 11, 1-23If mercury concentration in the discharge goes up with increasing flow atthe outfall, and if this occurs because of vadose zone leaching, thencouldn't the lower mercury concentrations at depth in the ponds result fromleaching during the initial saturation and earlier flushing? If so, it indicatesthat most of the mercury is mobile, albeit at a slow rate, and that there's apotential for future reaccumulation in the river sediments.

Response: The waste containing mercury was deposited in the upper 20 ± feet ofPond 5. Available data does not support a theory that the mercury isleaching. Rather there is an indication that the primary water flowpattern Is through the seams, cracks and fractures. The mechanism fortransport of mercury is theorized to be by erosion of particles. Mercuryis adsorbed to surface of the particles or contained In the Interstitialpore water. Since the permeability of the pond material Is relativelylow, the preferential pathway is toward the outfall via the seams andfractures. The water table within the Pond 5 varies as much as 20 feetduring the year (typically from 10 to 30 feet below the pond surface).This phenomenon probably has eroded mercury bearing particles fromthe upper reaches downward and toward the outfall structure. It is not

possible to accurately quantify the extent of this erosion due to theirregularity of the seams and fractures.

There would not be potential for future accumulation in the riversediments if the mechanism for transport (the water flowing throughthe pond) is eliminated.

Comment: No. 12, 1-24Title of Section 1.5 is incorrectly identified in the FS Table of Contents.

Response: The title of Section 1.5 will be corrected In the FS Table of Contents.

Comment: No. 13, 2-1In setting remedial action objectives consider future migration or exposurepathways from OU-2; wastes may present a future potential risk notaddressed under OU-3. Consider the following pathways and determineobjectives for these at all three source areas.

• Direct excavation into waste ponds or fill.• Continued direct groundwater discharge to River in excess of an

appropriate criteria.• Leaching of contaminants from soil into groundwater

Response: Direct Excavation into WasteAll feasible present and future migration or exposure pathways wereconsidered in establishing the remedial objectives. As noted in ourmeeting of April 6, 1993, the site is currently subject to site securitymeasures including fencing. Institutional controls such as deedrestrictions can be effectively utilized to prevent intrusive site activities.Funds can be established for perpetual care of fencing and drainagefeatures. As such, direct excavation into pond wastes or fill can becontrolled without additional implementation of remedial measures.

Groundwater Discharge to River Exceeding Appropriate CriteriaThe only established source of mercury of significance is from thePond 5 outfall (previously stated on page 2-2 of the FS Report).Continued direct discharge of pond water to river in excess of anappropriate criterion is not considered a likely exposure pathway.According to the periodic reports submitted to the EPA, the existingmercury loading attributable to the former chlorine plant site is notconsidered a threat to human health or the environment. Datasupporting these conclusions Is presented In the OU-2/OU-3 RiskAssessment Appropriate excerpts will be included in the FS Report.

8

If Rl indicates that Pond 5 and Pond 6 are not discharging mercurybearing pond water to the groundwater flow system beneath the ponds.

Leaching of Contaminants from Soil Into GroundwaterLeaching of contaminants from soil Into groundwater is similarlyconsidered an unlikely exposure pathway. Recent laboratory testindicate that the potential for leaching (ASTM 3987) mercury from theASAW Is very low. Detectable leached mercury was measured in onlyone of the eight samples tested (maximum of 2.9 //g/kg leached).

Therefore, further consideration of these pathways was considered notwarranted.

Comment: No. 14, 2-2Clarify statement that there are no discharges of Hg from Pond 6; note thatpage 1-22 indicates discharges in excess of 0.010 mg/l. Also clarifystatement that there are no discharges of Hg from the Chlorine Plant; notethat page 1-20 indicates discharges up to 0.684 mg/l. A criterion fordischarge of groundwater through the subsurface and/or through the outfallneeds to be set to evaluate the significance of these discharges.

Response: The comment misquotes the report in stating that the report hasindicated there are "no discharges" of mercury from former chlorineplant site. Further, the report does not state that there are dischargesof up to .684 mg/l of mercury. The value presented was the highestrecorded concentration of mercury recorded on samples from aspecific FCPS monitoring well. The report stated..."the Former ChlorinePlant Site has been capped and revegetated and no significantmigration toward the North Fork Holston River has been identified." Therelevant criterion is the loading of mercury to the river. Please refer toresponse to Comment No. 4 concerning the calculated loadings to theriver from the respective sources.

An appropriate ACL relevant to discharges to the river which addressesthe new Virginia acute and chronic water quality criteria will bedeveloped and presented as part of the FS Report. It should be notedthat during the months of October and November, 1992, the outfalldischarges from Ponds 5 & 6 appear to have met (without treatment)the new Virginia water quality criterion with respect to mercuryconcentration.

Comment: No. 15, 2-3Clarify these criteria with respect to Pond 6 and the Chlorine Plant. Thehuman health criterion for soils is stated as 20 mg/kg. .Average Hgconcentration in Pond 6 is stated on page 1-22 as 22 mg/kg, up to 78

mg/kg. Average concentration in Chlorine Plant soils is not stated, but ahigh is given on page 1-19 in excess of 11,000 mg/kg. If the criterion iscorrect (provide more information on how it was developed as we were notable to achieve the same number), Pond 6 and the plant site must beincluded in the feasibility study and full alternatives must be developed toaddress these areas also.

Response: As discussed In our April 6 meeting, Pond 6 and the plant site wereeliminated from detailed remediation development based on their "norisk" status identified In the Risk Assessment. In particular with regardto soil ingestlon and contact, the FCPS was considered remediatedbased on the fact that the site has been capped and Is subject toinstitutional controls comprising site security measures (fencing), deedrestrictions, and maintenance of the cap cover and other previousremedial action components. The discussions regarding existing sitecontrol measures and risks posed to human health and theenvironment by various site components will be expanded and clarifiedIn the FS Report.

Comment: No. 16, 2-3Discuss and provide an ACL for the groundwater discharges to the river.Without it, it is not possible to evaluate the alternatives. Include referencesto previous reports regarding ACL's if applicable.

Response: The only natural groundwater flow to the river that passes through thesite is that flow which passes through the FCPS. Pond 5 water as wellas Pond 6 water are isolated flow systems and do not contribute to aknown aquifer. Both ponds were utilized as surface impoundments forliquid residue from a manufacturing process and the waters containedare not considered as groundwater in the classical sense. Fractureflow from Little Mountain has been identified as a source of water tothe ponds (mostly to Pond 5). The Clean Water Act water quality andVirginia water quality standards (as revised) are relevant andappropriate for these discharges into the river. Since the RiskAssessment indicates that there is no endangerment to human healthor the environment from the discharges from the FPCS or Pond 6outfall, it is unnecessary to consider these discharges further. Anappropriate ACL for Pond 5 effluent discharges to the river will bedeveloped as part of the FS Report.

Comment: No. 17, 2-4It is stated that "In this section, technologies which apply to groundwaterare specifically aimed at groundwater moving through material in Pond 5and water within Pond 5 material..." Contaminated groundwater exists in

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other places and therefore this statement is not acceptable. Anygroundwater exceeding the remedial action objective must be included inthe alternatives.

Response: Please refer to response to Comment No. 16. The Feasibility Studyaddresses remediation of waters that have been identified as apotential risk to human health or the environment The point ofcompliance for the discharge from Pond 6 as well as for the subsurfacewater attributable to the former chlorine plant site Is the North ForkHolston River. Groundwater ARARs are not appropriate; rather theClean Water Act and new Virginia acute and chronic standards fordischarges into surface waters are relevant Groundwater that doesnot present a risk to human health or the environment was thereforenot addressed.

Comment: No. 18, 2-7This discussion of the transport pathways from the ponds treats the effluentfrom the ponds as groundwater. Clarify the nature of contaminatedsediments in runoff as a potential transport pathway. This is important inunderstanding how technologies, such as filling of desiccation cracks(fracture zones), will prevent or leave unchanged future contaminantdischarges in runoff through the effluent outfall weirs.

Response: A detailed discussion of the mechanisms of contaminant fate andtransport was presented in the Rl Report. As presented In responseto Comment No. 10, an expanded discussion of these mechanisms willbe added to the FS Report. The expanded discussion will clarify themechanism of erosion of colloidal particles containing adsorbedmercury and limited leaching within the ASAW fractures, andmechanisms of flow through intact ASAW pore spaces.

Comment: No. 19, 2-7Clarify the rationale for eliminating in-situ solidification/fixation. Theheterogeneity of the waste does not preclude implementation ofsolidification. In-situ solidification will improve the stability of the waste tosupport construction equipment. If the waste is primarily within the upper20 feet of the pond (as stated in Chapter 2), in-situ solidification to a depthof 20 feet is readily impiementable.

The effectiveness of in-situ solidification in reducing contaminant mobilityboth in particulate movement and in leaching transport pathways must bedemonstrated and evaluated. There is no mechanism available for notconsidering in-situ stabilization as an alternative in the FS as it is feasibleand more effective and less costly than other treatment alternatives

11developed. Therefore, retain an alternative featuring in-situ stabilization withsoil augers or equivalent providing the mixing.

Response: In-situ solidification/fixation was discussed in the Feasibility Study butwas screened out based on engineering judgment and our knowledgeof the site conditions (Refer to Table 2.4.2-1). The technology wasconsidered to be difficult to implement due to anticipated depth ofcontaminants (potentially 80 feet) and potential loss of mixing reagentsthrough the fractures and seams. If the waste Is primarily within theupper 20 feet of the pond, in-situ solidification may be implementabie.However, it is not possible to state with any degree of certainty thatstabilization of the top 20 feet will effectively eliminate the migration ofmercury from the pond. It is probable that some distribution ofmercury has occurred via the network of seams, fissures and fractures.Due to the size of Pond 5 and the varied methods of disposition of themercury bearing waste into the pond and the network of seams,fissures and fractures, it is not feasible to fully characterize the pondmass and locate "hot spots". The alternative of solidification or fixationin limited areas or throughout the pond was considered to beineffective as a stand-alone remedy. There is no basis for thestatement that stabilization is "...feasible and more effective and lesscostly than other treatment alternatives developed..." for this site.Furthermore, it Is not possible to demonstrate the effectiveness ofsolidification in reducing contaminant mobility both In partlculatemovement and in leaching transport pathways if it is notimplementabie. Measures to address settlement and cracking of the"crust" created by the stabilization operation would be required as wellas controls to collect or divert fracture flow from Uttle Mountain.Grading of the surface would be required to prevent ponding of waterwhich could infiltrate the crust through the settlement cracks anderode/convey mercury bearing material through the crust andeventually to the outfall. Capping would be required due to theanticipated "imperfections" in the "crust". Thus the stabilizationbecomes a redundant add-on technology without additional benefitwhereas capping can be effective without In-situ stabilization.

In accordance with your request, an alternative will be developed withIn-situ stabilization as the primary remedial component

Comment: No. 20, 2-7It appears that soil treatment technologies are llwritten off1 without adequatejustification. For example, it appears that the stabilization and solidificationalternatives are assumed to occur over the entire 75 acres at Pond 5. Thismay not be the case, as the contaminant concentrations may vary. It maybe feasible to consider treatment of "hot spots" of contamination. Again, afigure or discussion of soil contamination gradients would be useful in

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identifying "hot spots" and may reduce the estimated volume of soil needingtreatment. (Reference Comment #6)

Response: Refer to Response to Comment

Comment: No. 21, 2-7Clarify which technologies are eliminated and which are retained. Alsoclarify on Table 2.3.1-2. Each technology retained is to be used in analternative. For instance, a slurry wall appears to have been retained butnot developed into an alternative. No reason has been given for notconsidering vertical barriers placed between the ponds and the River formitigating groundwater discharges direct to the River.

Response: An explanation of which technologies were eliminated as well as thoseretained is provided in Section 2.4.3. Tables 2.4.2-1 & 2 will modifiedto indicate whether a technology process option is to be retained oreliminated.

Slurry wails were being considered for potential application at theFCPS; however, after the Risk Assessment indicated that the presentconditions posed "No Risk", no further consideration was required.

There has not been a need established that would Indicate that verticalbarriers should be considered between the ponds and the river. Theexisting dike structures are massive and have very low permeabilities.The comment assumes measurable flow through the dikes; however,no data support this assumption.

Comment: No. 22Table 2.4.2-1 indicates that a multi-barrier cap would only be used ifinfiltration must be kept to an absolute minimum, which the table thenconcludes is not necessary. This conclusion is not supported. Additionally,the multi-barrier cap contributes to long-term effectiveness, which is criticalto this site. Without more complete justification for no further evaluation,develop an alternative with a multi-barrier cap.

Response: It appears, based on our discussions on April 6, the comment refers toa capping system comprised of a barrier zone consisting of multipleand dissimilar materials. This is generally referred to as a compoundcap and typically is composed of a flexible membrane liner placed overa clay liner. The actual benefit is unquantifiable; mainly provides asafety factor in the event field QA/QC Is substandard. The HELP Modelcalculations indicate that the reduction in infiltration desired isachievable by the capping systems proposed with only a single-barrier.

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Furthermore, the pond mass has a low permeability and retards theflow acting essentially as a second barrier zone. Therefore, a multi-barrier is considered redundant and need not be carried forward as acomponent of a remedial alternative.

Comment: No. 23, Ch 2Include groundwater disposal technologies in the table and in thedescriptions.

Response: Groundwater disposal technologies do not appear to be relevant to thisproject The upgradient interception system proposed utilizes theexisting catchment and drainage system to convey the waterintercepted around Pond 5 to the river. This is stated in the descriptionof the alternative.

Comment: No. 24, Ch 2Table 2.0-1 only includes action-specific ARARs. Please include chemical-and location-specific ARARs including those for the disposal of treated oruntreated water to the river. Also the groundwater action-specific ARARslisted are not relevant to groundwater, only to waste. Please revise byevaluating regulations such as RCRA groundwater protection strategy, theSafe Drinking Water Act, the Clean Water Act, and action-specific ARARsconcerning the disposal of treatment residue. These are only examples, allother pertinent regulations must also be discussed.

Response: Many of the requested ARARs are presented in the tables. The tablesare currently labeled as action-specific, but contain other applicable orrelevant and appropriate regulations. The Clean Water Act wasinadvertently omitted and will be included In the FS Report togetherwith other ARARs as requested. The ARARs will also be listed as toaction/chemical/or location specific.

Comment: No. 25, 2-7The effectiveness and suitability of recompacted waste as a cappingalternative is questionable. Refer to comments on Chapter 4.

Response: The material Is proposed as a component of a capping system.Treatability studies are being conducted on Pond 5 with regard toreusing pond/dike materials as structural/grading fills and whethercompacted pond/dike materials can function as a barrier to surfacewater infiltration. The results of these studies will be supplied to theAgencies at the completion of the studies. In the interim, the suitabilityof these materials for such use is considered conditional (as stated inthe FS Report) pending the results of the treatability studies.

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We recognize and appreciate the reviewer's concern about utilizing theASAW as a component of a capping system; however, if readilyimplementabie, this measure wouid be Innovative, efficient and costeffective. The FS text properly points out the concerns regardingimplementability. Preliminary data support the feasibility • ofconstructing a barrier zone utilizing the pond/dike material; however,additives may be required to improve the handling characteristics ofthe pond/dike material. The pond/dike material can be used as fill butit now appears, due to the very high moisture content encountered, thatit would be more cost effective to utilize a flexible liner as the primarybarrier zone within the capping system. The text will be modified toreflect the preliminary findings of the treatability studies including thecontinuing monitoring of settlement

At the meeting of April 6, concern was expressed over handling theASAW contaminated with mercury and not providing a physical barriersuch as a synthetic membrane over the contaminated material toprevent erosion of the mercury. As proposed, the barrier composed ofASAW would be covered by a geocomposite consisting of a geogrid(highly efficient drain mechanism) sandwiched between two geotextilefabrics. Recent lab data indicates that the mercury is not waterteachable and the flow along the geocomposite should not inducescouring since the flow will have a very low velocity without sufficientenergy to erode the soil liner. The function of the geotextile is toseparate the drainage from and prevent erosion of the underlyingmaterial.

Concerns over handling the ASAW containing mercury have proven tobe unfounded. Three separate construction activities have beencompleted without detection of mercury above a safe work level.Working the material is considered to be a manageable risk.

Comment: No. 26, 2-9This page should indicate that the three technologies presented are VerticalBarriers, Horizontal Barriers, and Gradient Control.

Response: The title will be corrected to reflect that the three technologiespresented are Vertical Barriers, Horizontal Barriers, and GradientControl.

Comment: No. 27, 3-1Institutional controls are not accepted as the only alternative for Pond 6 andthe Chlorine Plant. Both soil and groundwater samples exceed the remedialaction criteria stated on page 2-3. Develop a full range of alternatives forsource control and groundwater control for both areas.

flR30U899

15

Response: The remedial action objective as stated on page 2-3 calls for preventingingestion and contact with soils/pond solids containing mercuryconcentrations In excess of the human health criterion. Because theexisting institutional controls comprising deed restrictions, fencing,daily site surveillance, maintenance of site security measures, and inthe case of the former chlorine plant site maintenance of a clay cap andvegetative cover, both sites were considered secure with regard tohuman health risk. Based on the risk assessment findings that theformer chlorine plant site did not pose an unacceptable risk to humanhealth or the environment with regard to minor groundwaterdischarges, and the continued maintenance of the previous siteremedy, groundwater was not considered a potential exposure pathwayand additional site remedies were not evaluated.

Based on our meeting of April 6, Olin and USEPA have agreed to tablethis issue pending further discussion.

Comment: No. 28, 3-3Clarify and more fully demonstrate conclusions of the risk assessment thatthe only significant source of Hg migration is through the Pond 5 outletweir. The effectiveness of proposed alternatives is highly dependent uponthis conclusion. Demonstrate whether the following are true:

• Hg migration in water is primarily associated with particulatemovement in surface water discharging through the outlet weir, andnot associated with dissolved Hg in groundwater.

• The concentration of Hg in groundwater is several orders ofmagnitude less than in surface waters discharging through the weir.

If Hg migration through the outfall weir is associated with groundwaterseepage to the weir, then it is not reasonable that groundwater seepagethrough the dike direct to the River is insignificant. Groundwater qualitywould not be preferentially concentrated around the weir structure, andhydraulic flows to a point discharge would not be greater than to a linedischarge.

Response: The conclusions of the Risk Assessment and the Feasibility Study arebased upon the findings of the remedial Investigations discussed inprevious responses. The mercury migration through the pondmaterials is primarily associated with fine ASAW particle movement inwater flowing through the fractures and discharging through the Pond5 outfall as effluent Mercury concentrations In groundwater beneaththe pond and beneath the dikes have been found to be very low ornon-detectable. A plan of the Pond 5 and the Pond 6 monitoring wellswill be appended to the FS Report that Illustrate this fact

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As discussed in our April 6 meeting, seepage through the dike isdifficult if not impossible to quantify. The water balance for the Pond5 flow system developed as part of the Remedial Investigation will beappended in the FS Report. Based on this water balance, seepagethrough the dike; if it is occurring, is equal to or less than thedifference between actual measured flows and predicted flows usingthe water balance. Because the water balance Is very close, seepagethrough the dike Is considered to be insignificant. Further, the flowthrough the pond has preferentially followed the seams and fractureswithin the ASAW to Pond 5 outfall. Flows maintain these channels byerosion. Porous media flow through the upstream shale blanket of thePond 5 dike discharging to the North Fork Holston River is consideredunlikely.

Comment: No. 29, 3-4Alternative A is not an acceptable alternative. The no action alternative mustassume that the ROD for OU 1 is still implemented and includes benefitsfrom the diversion ditch and the treatment plant, The no action alternativeis Alternative B and it must be retained for the final evaluation. Analternative without the treatment plant is not acceptable for anyconsideration since the ROD for the treatment plant has been signed. Thealternatives should only address when the treatment plant can be turned off.Likewise, all cost estimates for the alternatives must not include capitalcosts for the OU-1 activities. These costs were included in the OU 1 FSand ROD and will be implemented regardless of which alternative isselected for OU 2. The only modification between alternatives can be thelength of time required for O&M of the treatment plant if it can bedemonstrated that at a point in the future the treatment plant is no longerrequired.

Response: The Saltville site is relatively unique and is not considered whollyapplicable to the guidance document-type analysis of alternatives inthat an existing first ROD has been Issued for the site, initial remedialactions have been undertaken prior to and subsequent to issuance ofthe ROD, and existing institutional controls, deed restrictions, and sitesecurity measures are being implemented and maintained. For thisreason, the consideration of a no-action alternative wherein no risksare presented, no site security measures or remedies are undertaken,and the site could potentially be sold and "walked away from by Olin"does not apply. Some of these measures are not required by theexisting ROD. For this reason, Alternative A was presented asrepresenting existing conditions and Alternative B representsconditions after implementation of the interim measures required by thefirst ROD.

17

Studies for remedial investigation and feasibility study have suggestedthat the Pond 5 system functions as an Isolated reservoir system andthat mercury migration from the pond to the North Fork Holston Riveris driven by precipitation events which erode fine particles containingmercury. Water flows through the pond fracture system and out thepond outfall. Analyses of the pond discharge versus time andcomparison of these discharges with mercury concentrations andprecipitation events have indicated that for dry antecedent conditions,the pond outfall discharge concentrations are below the interim RODrequired discharge limit of 20 ppb for extended periods of time, andthat the new acute and chronic limits established by the state ofVirginia are similarly met during dry periods in the year; (e.g., Octoberand November, 1992). Based on these data, Olin and its consultantshave suggested to EPA that the Implementation of source controlthrough containment will likely meet the discharge criteria for OU-2.Based on these evaluations, elimination of the OU-1 treatment plantinterim remedy, which will not meet the OU-2 treatment criterion, hasbeen suggested.

Comment: No. 30, 3-4Why has the criterion been developed that is not included in the remedialaction objectives?

Response: The criterion cited refers to the interim MCL of 20 ppb established forthe OU-1 treatment plant (page 36 of ROD).

Comment: No. 31, 3-10A definition or diagram for "geocomposite" should be provided.

Response: The definition of geocomposite Is presented in a glossary of termspresented in Appendix B and is shown diagrammaticaily in the capfigures.

Comment: No. 32, 3-10In the effectiveness discussion of Alternative E, it is stated that thealternative will reduce flow to such an extent that the mercury concentrationin the discharge will be "below treatment objectives" and that the treatmentplant will no longer be necessary. This assumption is based on adischarge limit of 20 ppb which was set based on an ambient water qualitystandard of 0.05 ppb. This standard has been revised since the Record ofDecision for Operable Unit 1 was signed. The new water quality standardis 0.012 ppb mercury. This revised standard will be an applicablerequirement for OU-2 and the remedial alternatives will need to meet thislimit.

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Response: We recognize that the revised criteria will be an applicable requirementfor OU-2 and the remedial alternatives will need to meet this limitunless a waiver is approved or an ACL is developed.

Comment: No. 33, 3-11Alternative F involves the use of "excavated dike materials" for creation ofthe barrier zone. Please discuss the source of these materials; will existingdike material be removed or reconstructed? If so, this material should beanalyzed to make sure that it contains no material that is hazardous tohuman health. Further characterization of this dike material would be ahelpful addition to this text.

Response: The existing dike system has upwards of 25 feet of freeboard for thedrained pond structure. The structure is massive rising 100± abovethe river with several terraces on the outboard side. The amount ofmaterial is relatively insignificant compared to the total mass of thedike to remain.

It was recognized that preparation of a cap subgrade would requireImportation of large quantities of fill. Therefore, alternative fill sourceswere considered. The freeboard dike materials were considered basedon their ready availability to the site. These materials are currently thesubject of a treatability study to establish whether they can bereworked and used as fill materials or cap materials. The use of thesematerials was noted as being conditional based upon the results ofongoing treatability studies. The results of the treatability studies willbe provided to the Agencies upon completion of the study. Preliminaryfindings confirm the viability of utilizing the dike material as fill.

Comment: No. 34, 3-15What is the basis for the 25 ppb criterion?

Response: The basis for the 25 ppb criterion is that this treatment methodologycan only achieve removal of mercury to 25 ppb. Reference will beprovided for the source of information.

Comment: No. 35, 3-15The implementability discussion states that 80% of the mercury is containedin the upper 20 feet. This contradicts statements made on page 1-21.Approximately 92% of the mercury in contained in the upper 17.5 feet of thepond according to the 1980 Harza report.

Response: Due to the nature of the analytical data that are available for the siteand the uncertainty with regard to the precise extent and

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concentrations of mercury within the upper pond solids, the uncertaintywas reflected in the statement that 80% of the mercury is contained inthe upper 20 feet of pond solids. See responses to Comments No. 5and 6. In the FS Report, all of the statements will be made to beconsistent and cite the source of the data. Uncertainties with regardto the precision of these data will be discussed in greater detail In thedescription of the alternatives presented in Sections 3 and 4.

Comment: No. 36, 3-16The effectiveness states that removal of mercury to 20 ppb in Pond 5 wasteis feasible, yet there is no discussion as to why this limit is appropriate. Italso is different from the treatment criteria mentioned in Alternative I. Thetreatment criteria for the waste in Pond 5 should be established, justifiedand used to evaluate all treatment options.

Response: The removal of mercury to 20 ppb In the Pond 5 waste represents thelimits achievable by the Alternative I treatment technology. Referencewill be provided for the source of information.

Comment: No. 37, Section 3.4Ex-situ treatment alternatives have been eliminated from detailed evaluationbased on preliminary cost estimates for the alternatives presented inAppendix C of the Feasibility Study. These preliminary cost estimatesindicate that treatment alternative costs are an order of magnitude greaterthan the various capping alternatives. However, questions exist regardingthe preparation of these estimates.

First, the amount of waste requiring treatment is debatable. This is due tothe fact that the Feasibility Study does not provide any definite treatmentlimits and does not tie this into the volume of waste to treat. According tothe Harza study, approximately 70% of the mercury in the waste pond iscontained in the upper 17.5 feet of the waste within three distinct areasencompassing approximately 29 acres of the pond. If removal of thismercury (alone or in combination with other action; i.e., environment, thetreatment volume is reduced from the 2 million cubic yard minimum citedin Appendix C to roughly 800,000 cubic yards. The associated costs totreat this volume of waste would be significantly less than the figures usedin the Feasibility Study. Further investigation of the distribution of mercurywithin the Pond 5 waste could reduce the volume to be treated, dependingon the treatment standard established.

Response:Ex-sitU treatment of only a portion of Pond 5 would not accomplishsource control. Other measures would still be required in order toinsure protection to human health and the environment A large range

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was presented for Implementation costs because of the uncertainty.Even if the projected quantity of material treated is in the order of800,000 cubic yards, the total implementation cost would be at leasttwice the cost of the alternatives utilizing capping as the primaryremedial component. It seems unnecessary to consider alternativeswhen their cost is exorbitant and their effectiveness can not bepredicted with a high degree of confidence.

The cost support data presented will be reviewed for clarity; however,we consider the accuracy to be suitable for screening purposes.

Comment: No. 38, Section 3.4The manner in which the capital cost and operation and maintenance costwere calculated is not clear. It appears that the costs for twenty years ofoperation of the treatment plants were included in capital cost estimates.More detailed evaluation of the treatment alternatives (as provided inAppendix E for the capping alternatives) may resolve these questions.

Response: Some of the capital cost figures were transposed between columns.These tables will be rechecked and corrected as appropriate.

Comment: No. 39, Ch 4It is agreed that seepage from the hillside contributes to the water in Pond5 and that some form of upgradient diversion could have some benefit.However, how will other contributors of water be controlled? Clarify theeffectiveness of an upgradient groundwater interceptor in mitigatingcontaminated groundwater seepage beneath or through the dike direct tothe River. Provide calculations estimating groundwater levels within thewaste in the ponds before and after the upgradient groundwater interceptorhas been installed. Provide calculations estimating the contaminant flux(discharge x concentration) before and after the interceptor has beeninstalled. Use this and other information to answer the question of how adry weather flow of less than 5 gpm was achieved.

Response: The Rl report describes in detail the hydrogeologlc and hydrologlcsystems affecting the site and environs. There are only twodeterminate sources of flow into the pond: rainwater and fracture flowfrom Uttle Mountain. Runon from Little Mountain is diverted aroundPond 5 and maintenance of the existing diversion ditches is acomponent of all of the alternatives considered. Rainfall directly on thepond will be controlled by grading to promote lateral drainage and acap to reduce infiltration.

Depending on the water table within Pond 5, the fracture flow couldpass through the probable mercury bearing layer (top 15 to 25 feet) or

21

below (see response to Comment No. 4). During extended dry periodsthe Pond 5 effluent flow rate drops to less than 5 gpm.Correspondingly, during these dry periods, the water table dropsapproximately 20 feet. When these conditions occur, the mercuryconcentration typically drops below 10 ppb. The dry weather flow ofless than 5 gpm and the corresponding mercury concentrations arebased on ten years of historical data. Suitable graphs will beappended to the FS Report to depict this relationship.

The reviewer's comment appears to assume that the water table InPond 5 is primarily controlled by the influx of the fracture flow fromLittle Mountain and the pond is part of a groundwater regime. This isnot the case; rather, the pond is an isolated "holding pond" and Itswater table varies with precipitation. The data presented in the RlReport indicates that there is little If any flow of groundwater into thepond from the aquifer below.

However; the fracture flow from Little Mountain Is part of the transportmechanism for conveyance of mercury from the pond. The fractureflow also varies with precipitation increasing as the fractured rockapproaches saturation. We predict that the interceptor system will beapproximately 85% efficient (based on experience and judgement).

There are no indications that there is significant seepagethrough/under the dike. The pond water Is characterized by high pHand high dissolved solids. If there were measurable seepage, theseparameters would have been detected in the extensive testing of theriver water adjacent to the site.

Comment: No. 40, Ch 4What effects will blasting for these collectors have on seepage in adjacentareas? What negative effects could the blasting have and how likely arethey to occur? Why were excavated trenches not considered?

Response: It Is anticipated that control blasting techniques will be used toconstruct the counterfort drains. Blasting was selected based on thehardness of the quartzose sandstones comprising the Price Formation(nearly a meta quartzite) and the need to construct narrow counterfortdrains to avoid dip slope Instability problems. It is anticipated that pre-split curtain drain construction and excavation of the counterfort drainswill not impose any negative effects to the site and/or abuttingproperties.

Excavated trenches were considered but due to the steep slope andfractures the proposed design was preferred.

22s

Comment: No. 41, Ch 4Geogrids alone are considered to be inadequate to protect cap materialsin the long term from large voids. They may be effective for small voids orarea settlement. Descriptions in the FS indicate that the voids are large.In the alternative evaluation, present more accurately the likelihood of capfailure using geogrids.

Response: Geogrids were included because fractures as wide as one to two feetwere observed in the 80's (verbal Olin Personnel). It now appears thatthese fractures have sloughed in and at least partially filled the voids.The presence of large voids has not been substantiated in the Rl or FSstudies. Currently, the largest voids observed comprise fractureswithin the ASAW that are on the order of 6 to 8 inches wide. Based onthese findings, observed settlements, and behavior of access roadsconstructed for Rl investigation activities, preliminary analyses havebeen conducted to assess the need for geogrid or other reinforcementof cap materials placed over the existing grades within Pond 5. Basedon these analyses, the effects of long-term settlement did not produceunacceptable strains for a FML placed over woven geotextile andlimited grading fill. Further, strains associated .with the collapse oflinear fractures up to one-foot wide were within ranges consideredacceptable for RCRA Subtitle C and Subtitle D FML liners.

During field activities associated with the Treatabiiity Studies,surcharge pads were constructed on the surface of Pond 5, withoutsudden subsidence which could be indicative of a collapsed void.Preliminary findings of the field activities suggest that geogrids are notrequired.

Comment: No. 42, Ch 4The FS indicates that cap components will be installed once primarysettlement has occurred. How long will this take? Please modify thealternative evaluation if this is estimated to take longer than a year or so.Secondary consolidation (long-term creep settlement) of gypsum materialscan be significant. How will this be taken into account in developinggrading and maintenance plans?

Response: Several cap alternatives were presented In the Feasibility Study. Thesewere presented to show various options with regard topreconsoiidation, variation of cap materials used and suitability ofexisting grades for support of a flexible membrane cover system. Asdiscussed in the previous response, the existing subgrade isconsidered acceptable for a relatively light cap, and unacceptablestrains to liners induced by settlement and collapse of existing wastefractures are not developed. Settlement curves, developed as part ofthe Rl studies are presented in the draft Feasibility Study report.

flR3Qi*9Q7

23

As part of the Feasibility Studies, two surcharge pads were constructedon the surface of Pond 5. Settlement is being monitored with over fourmonths of data having been collecting. These data indicate that theprimary settlement will take in the order of six to twelve months. Longterm settlement is not considered a problem relative to liner integrity.

Comment: No. 43, Ch 4None of the alternatives proposed are permanent. The evaluation for long-term effectiveness must not claim permanence. Also, according to the NCPand the RI/FS Guidance Document, reduction of toxicity, mobility, or volumeis considered only through treatment. Again, none of the alternativesachieve this.

Response: The language in the Feasibility Study will be modified to reflect the factthat capping alternatives, while not considered "permanent" are long-term remedies to effect source control under Subtitle D and Subtitle C.Although the Ri/FS Guidance Document may state that reduction ofmobility can only be achieved by treatment, the mobility would bereduced by consolidation and elimination of the major seams andfractures.

Comment: No. 44, Ch 4The lack of less protective, less effective, or less expensive alternativesmake the justification for capping the pond difficult to demonstrate.Similarly, the lack of a treatment (e.g., in-situ stabilization) alternative makesunderstanding that capping will provide sufficient protection also difficult todemonstrate. An insufficient range of alternatives has been developed.Conversely, there is no need to develop so many capping options; capvariations given are details for consideration during the design.

Response: Further to our discussion of April 6,1993, additional alternatives will bepresented in Feasibility Study report and will include treatmentalternatives for the pond solids as requested. However we believe thatthe CERCLA process does allow limited consideration of alternativeswhen an appropriate action is obvious.

The alternatives which include capping and interception of fracture floware protective, effective and cost effective. In-situ stabilization will notprovide equal protection without including the interceptor system forfracture flow, grading and capping to minimize Infiltration (In particularthrough anticipated settlement cracks) and prevent erosion of thesurface.

It has been our experience that when a feasibility study looks only atgeneral technologies and does not consider all feasible processoptions ("details") it is difficult to consider concepts that could be

24

innovative and cost effective but were not introduced as a viabletechnology In the FS Report.

Comment: No. 45, Ch 4In general, the evaluation provides little justification for statements made.An attempt has been made to identify specific comments, however, the levelof detail provided is insufficient to review in depth and additional commentsmust be made on the revised alternatives. Additional concerns maybecome apparent after the alternatives have been modified and theevaluation enhanced to demonstrate the rationale and justification. Whereestimates of volumes, concentrations, or engineering feasibility are made,calculations demonstrating the basis of such estimates must be provided.Where statements or conclusions regarding effectiveness, reliability,implementabiiity, or other evaluation criteria are made, they should besupported by appropriate discussion of the rationale and the justification forsuch professional opinion.

Response: As discussed in our April 6 meeting and in the previous response, theexpanded discussions with regard to site conditions and findings of theRemedial Investigation and Risk Assessment should enhance the abilityof the final FS document to stand alone.

Comment: No. 46, Ch 4Where uncertainties exist, a range or the uncertainty must be identified. Ifthe uncertainties impact the alternative, contingency plans are to beincluded and evaluated as part of the alternative. For instance, what will bedone if the waste material is unstable enough that a proposed liner tears?

Response: Uncertainties are discussed and reflected in the cost estimates. Thediscussions of these uncertainties associated with the existing dataand difficulties with implementing the various alternatives will bereviewed and expanded to provide requested clarification wherenecessary.

Comment: No. 47, 4-6Clarify how the HELP model, which estimates quantity of percolationthrough waste to groundwater, predicts the quality of the dischargesthrough the Pond 5 outfall weir. Concentrations of Hg at the weir maycurrently vary with flow through the weir, since transport may be associatedwith particulate movement in water flowing through subterranean voids.However, it is unclear how concentrations in groundwater, as implied byuse of the HELP model, would decline; concentrations in groundwater

SR30I49Q9

25

seepage to the outfall weir or through the dike may be unchanged followingcap construction.

Response: The HELP model has been used in estimating the amount of water thatwill flow Into the Pond 5 system via infiltration. It Is recognized that theHELP model will not predict concentrations of analytes In leachate orgroundwater. The concentrations were predicted based on flowspredicted by the HELP model and correlation with ten years ofhistorical Pond 5 outfall discharge quantity and concentration data.

Comment: No. 48, 4-9The effectiveness and suitability of recompacted waste as a cappingalternative is questionable.

• Capping alternatives are intended to reduce the amount of rainfallpercolation into the waste, as well as reduce the amount of leachateout of the waste. Use of waste material as a cap, therefore, doesnot provide protection against the percolation into the waste. WhatARAR waiver would be used since RCRA and the State of Virginiaregulations require protection against water contacting the waste?

• The reliability of a recompacted waste cap is improved bysurcharging. However, there is concern that compaction of a low-permeability silty clay waste cap is unimplementable over materialthat is currently so unstable that it cannot support constructionequipment in many areas. There is concern that permeability of thecap would not be achieved due to improper compaction, or thatcracks may form in the cap due to future desiccation or settlement.

Response: Utilization of ASAW As Component of CAPAs stated in the FS Report and verified by recent ongoing TreatabilityStudies, the material can be effective as a barrier cap. The material,with proper conditioning, can be molded into a liner of (relatively lowpermeability, thus effectively reducing infiltration. A vegetation coveris proposed over the liner to separate and protect it from erosion bysurface water. Further discussions will be presented in the FS Report.

ImplementabilltvPreliminary findings of the ongoing Treatability Studies indicate that itIs feasible to use the dike material as fill for grading and forsurcharging. Surcharge pads were constructed on the surface of theponds; one in an area believed to be representative of poorer bearingsubgrade. Some difficulty in spreading the dike material wasencountered due to the high moisture content; however, it did notrender the operation unimplementable.

nu

26

Preloading the pond soils by surcharging will improve the subgrade forsupport of the cap and long-term settlement will be significantlyreduced. The improved subgrade will allow the necessary effort forproper compaction. It is stated in the FS Report that extensive qualitycontrol would be required to insure that the desired parameters areachieved during construction of a barrier zone utilizing recompacteddike/pond material.

The design proposed includes 18 inches of vegetative cover over thebarrier; therefore desiccation of the barrier zone Is not anticipated.

Comment: No. 49, 4-10Statements on pages 4-10 and 4-12 concerning shear are contradictory.Surcharging should not induce shear. There is concern that injecting slurryto plug existing fracture zones may have undesirable consequences. Ifthese fractures are currently key to collecting groundwater at the outfallweir, then plugging these fractures would decrease the effectiveness of theweir as a drainage point, thereby increasing the phreatic surface inside thepond and increasing the seepage of contaminated groundwater through thedike to the River. In addition, the injected slurry in the fractures would likelynot consolidate similar to the mass of soil around the fracture; the slurrymay therefore create "mud waves" during surcharging or remainunconsolidated.

Consider inducing the collapse of fracture zones by "dynamic compaction"at the leading edge of the finger dikes during surcharging. The compactionprocedure could be modified to cause collapse of the material bridging overthe top of the fractures, not to cause compaction of the waste itself.

Response: We agree that it is not desirable to intentionally induce shear at thissite. Rather, the surcharging should be staged to promoteconsolidation without shear failure. It is recognized that if the pond isto be completely sealed via fracture sealing that the effectiveness of theexisting outfall structure as a drain will be reduced. However, the factthat the fractures are endemic throughout the pond and that only apercentage of the fractures will actually be filled, some drainage willlikely still occur. Fracture sealing as proposed would only beemployed in the vadose zone.

Because of the sensitive nature of the pond waste materials, dynamiccompaction Is not a reasonable alternative for densificatlon of the pondsolids.

27

Comment: No. 50, 4-8Verify O&M cost of cap maintenance for Alternative E. There is concernthat without surcharging the waste or collapsing the fracture zones, the capgeomembrane would be highly susceptible to excessive settlement andrupture. Cap repairs relative to Alternatives F and G would be anticipatedto be much greater than stated.

Response: Based upon our preliminary calculations of settlement and potentialliner strains associated with pond fracture collapse, support of the linerbeyond placement of a woven geotextile and grading fill as a subgradebeneath the FML is not required. Liner strains are predicted to be wellwithin tolerances considered acceptable for closure of RCRA SubtitleD Landfills and RCRA Subtitle C facilities where ongoing consolidationsare considerable. As such, the O&M costs presented in the DraftFeasibility Study report are considered reasonable.

Comment: No. 51, Ch 4The effectiveness of maintaining the effluent outfall weir as a single point ofgroundwater extraction from the pond is questionable. Include analternative that evaluates use of multiple extraction points and/or verticalbarriers along the dike to mitigate groundwater discharge to the River.

Response: As presented in the Rl report and reviewed in our April 6 meeting, thefracture system within the pond mass functions effectively to channelthe pond waters to the outfall structure. As such, multiple extractionpoints are considered less effective.

Extraction wells are considered to be inappropriate for this site,particularly in the vicinity of the dike due to the low permeability ofsoil/waste mass.

Comment: No. 52. Ch 4For Alternative E on page 407, an estimate of 645,300 cubic yards ofborrow material is needed to accomplish an acceptable grading scheme.What impact would this have in terms of additional load to the strength ofthe Pond 5 dike.

Response: The Rl Report contains an extensive section on Pond 5 dike stability.The dike has been the subject of two stability reports conducted byHarza in 1986 and Golder Associates in 1991. The latter reportconsiders the static, and pseudostatlc (dynamic) stability of the dikewith respect to various loading scenarios including raising the pondelevation to within several feet of the dike freeboard. Further, theGolder Associates stability report considers the variability of strengthparameters In the dike materials through a stochastic model that

28

considers the probability of failure given the distribution of strengthvalues within the dike and the probability of the design (magnitude 6)earthquake occurring within a 30 year period.

Please refer to the conceptual grading plans presented with the FSReport. The proposed grading scenario should impose little netloading to the structure. Appropriately, this axiom will be verifiedduring the design phase.

Comment: 53, Appendix ERCRA Subtitle C requirements for maintenance of a cap system on asurface impoundment specifies 30 years of post closure care. Costs for allcapping alternatives should be prepared for construction plus 30 years.

Response: We disagree that RCRA Subtitle C Is relevant to capping this site;however, O&M costs for all capping alternatives will be prepared forconstruction plus 30 years of maintenance.

29

Furthermore, it Is possible that highly concentrated mercury wasteswere discharged directly into Pond 5. These waste could haveremained as a concentrated pool of mercury and, due to their density,settled to significant depth by displacing the lighter material; or thismass could have "mixed" with the ASAW.

The probable cost to fully characterize the Pond 5 contents couldactual cost more than the implementation cost of the remedialalternatives considered In Chapter 4.

R3QU9II*

Olin Chemicals Group - Saltville OU-2Feasibility Study

FLUOR DANIEL———————————————————————————————————————

FEASIBILITY STUDY

APPENDIX FPRELIMINARY STABILIZATION STUDIES

Table of Contents

item

ENRECO, Incorporated

• VFL Technology Corporation

B752TCA.FS9 * fl R 3 fi Li Q ! Table of Contentsrtl%*i,?W*lY.f|\J • i. *-Appendix F

Olin Chemicals Group - Saltville OU-2Preliminary Stabilization Studies

FLUOR DANIEL————————————————————————————————————————————

ENRECO, Incorporated

B752BLUEFS9-FEB 1994 ...._.._:.____ •---—-—Feasibility StudyAppendix F

Project Proposal Olin Chemical - Saltville, Virgina

STABILIZATIONPROJECT PROPOSAL

Prepared for:

OLIN CHEMICALJohn BurnsSaltville Virginia SiteP.O. Box 248Charleston, TN 37310

Submitted BY:ENRECO, IncorporatedSteven M EarlansonEastern Regional Manager2431 Crof ton LaneSuite 13ACrof ton, MD 21114

304917

Project Proposal Olin Cheiical - Saltville, Virgina

This proposal is PROPRIETARY AND CONFIDENTIAL and has beenprepared for your use soley for considering the purchaseof the services described, Transiission of all or part ofthis information to others is unauthorized without writtenconsent,

RSOUS

ENRECQ, Inc. Statement of Qualifications

Project Summaries

Illinois Environmental ProjectA chemical plant in Illinois had an impoundment (600 feet x 200 feet x

30 feet) with approximately 130,000 cu. yds. of non-hazardous sludge. Theowner developed a plan to close the site by covering the sludge with soiland impermeable clay, but experienced problems placing the soil over anunstable base.

ENRECO was contacted to investigate the feasibility of solidifying thetop 10 feet of sludge to serve as a support for the soil and clay cover.ENRECO Laboratories conducted bench scale tests that led to the develop-ment of a solidification process that produced a high strength, low densitysolid which floated on the underlying sludge.

ENRECO was awarded a contract for the project, and we used ourinjector system to solidify the top 10 feet of sludge (approximately 30,000 0"?cu. yds.) which was sufficient to support the heavy equipment that placed ^ 1TVand compacted the soil and clay cover. The contract value was approxi-mately S1.0 million.

Pennsylvania Environmental ProjectAn oil refinery in west central Pennsylvania produces an acidic sludge

from a process that uses sulfuric acid to remove impurities from raw materi-als. Over the past forty years the sludge was deposited in excavations froman old coal strip mine. Throughout the years several attempts were madeto dose the the disposal area by covering the sludge with soil and otherrubble. Rainwater that permeated through the sludge became acidic anddissolved metals from the underlying soils which caused a toxicity problemwith the groundwater.

As part of a remediation plan ENRECO was awarded a contract to con-struct a diversion and sedimentation control system, to stabilize the sludgein several lagoons located throughout the plant site, and to place thestabilized material on a flat area where it was capped with a synthetic liner.We began work in May of 1987 and completed the project in November ofthe same year. During this time approximately 100,000 cu. yds. of sludge

ENRECO

014913

Project Proposal Olin Cheiical - Saltville, Virgina

TREATABILITY STUDY

ENRECO Inc took samples of sludge from Olin Chemical site locatedin Saltville, VA. The samples of sludge were taken from the lagoonand a area where the drainage pipe is to be located.

Treatability testing procedures utilized by ENRECO Laboratories arecomprised of three sequences. Phasel consists of research throughour library of journals, technical papers and conferenceproceedings concerned with stabilization of similar wastes. ENRECOLaboratories maintains a database of stabilization reagentsthroughout North America. These are compared to the geographiclocation of the site and the types of contaminants involved todetermine a baseline of potential reagents.

Phase 2 consists of gross screening techniques. Stabilized samplesof waste were prepared by mixing 1OO gram samples of sludge withvarious ratios of reagents and cured in airtight containers. Thesludge and reagents were allocated by weight for ease of laboratorymix control. Initial screening tests for this study consisted ofstrength testing. This was measured by a pocket penetrometercorrelated to unconfined compressive strength in pounds per squareinch.

The final phase consists of detailed analysis of the preferredreagent(s) and mix ratios. Samples which passed the screening testwore submitted for additional testing to determine the optimum mixratio that achieved the project objectives. these tests includethe percent of volume increase and the wet weight density asmeasured in pounds per cubic foot. The test results from ENRECO'sstabilization testing procedures, are summarized on the attachedstabilization study. After analyzing various reagents at variousmix ratios, ENRECO recommends a mix design of .45 tons of reagentfor every cubic yard of sludge to be solidified in the 80 acrelagoon and .45 tons per cubic yard of sludge for the Drainage pipearea.

This recommendation is based upon the results of the testing whichhas shown that the samples show an unconfined compressive strengthof greater that 15 psi as measured by a pocket penetrometer, witha volume increase of less that 20%. The low mix ratio will increaseproduction rates and expedite the excavation. The cost is lowerthan with other alternate reagents.

We would also like to bring to your attention that the material weare recommending is a by pjrpduct and at times we may have a limitedsupply. Due to this we have an alternative reagent for the SO acrelagoon. We also have other material available by rail roaddelivery. We are also testing other reagents at this time and asthe results become available we will forward them to you.

ESMKEGO

Project Proposal Qlin Cheiical - Saltville, Virgina

STABILIZATION

ENRECO will utilize our patented Injection system to stabilize thewaste in-situ. The Injector consists of assembly of four parallelvertical tubes mounted in place of the bucket on a Caterpillar 215,225 or 235 excavator. This provides the system with completemobility and allows the injector to thoroughly mix thestabilization reagents with the sludge in a raking fashion. As thereagents flow out the bottom of the tubes, the operator rakes theInjector through the sludge to homogenize and mix the reagents andwaste. The ends of the tubes are protected to prevent underlyingsoils and /or clays from plugging the tubes.

To maintain the specified mix ratio of reagents to sludge in thefield, a simple mathematical formula is applied in the case of theNon Hazardous Ponds, the ratio is .45 ton of reagent per cubic yardof sludge. Given the weight of the reagent contained in eachtruckload, de 1 ivery rates and stabi 1 ization area may be f iguredinsuring that field results will equal laboratory findings.

As the sludge is stabilized, the Injector moves laterally aroundthe perimeter of the impoundment. This requires a "bench" aroundthe perimeter for the Injector's first pass. Once the first passis complete, the Injector moves onto the stabilized area and beginsanother pass. This process is repeated until the entire pond hasbeen stabilized.

With sludge in the lagoon and drain pipe area, ENRECO willstabilize a cap on the lagoon. We will also stabilize a cap in thearea of the drain pipe, that is 100 X 70 X 15 feet deep. Thisshould allow Olin enough area to excavate and place the drain pipe.

The pneumatic trucks require an access road approximately 15 feetwide and free of sharp turns. This road must be within 50 to 100feet of the impoundment. If truck access is restricted, apneumatic storage tank can be utilized at an additional charge.

The Injector system is operated by a crew of two: one personoperates the excavator and the second person monitors the pumpingand mixing operation, conducts the quality control and reportingprograms, coordinates deliveries of reagents and acts in a generalservice position.


REPORT OF SLUDGE SOLIDIFICATION

Project No.; ELS89Q2QQLaboratory No.: S 89-1084Date Received: 10/16/89

Project Name: OLIN CHEMICAL COMPANY

UnconfinedAdditive Comp. St. psi Volume Wet Weight

Saaple No. Date wt. gas. Iday 3day Sdav 7day Increase Density pcf1 10/25/89 .15 0.3 38.9 -4.9 87.9*2 10/25/89 .25 2.2 >62.5 5.2 86.43 10/25/89 .35 5.6 >62.5 5.4 93.24 10/25/89 .20 <0.1 2.7 -2.8 89.85 10/25/89 .40 1.5 16.6 16.7 87.36 10/25/89 .60 3.6 >62.5 24.8 93.27 10/25/89 .20 <0.1 -1.9 4.1 83.88 10/25/89 .40 <0.1 26.4 94.0 92.99 10/25/89 .60 1.0 >62.5 X7?T*2Q.9 96.310 10/25/89 .20 1.2 5.5 VjJ/ 7.6 81.111 10/25/89 .40 13.9 >62.5 12.7 90.312 10/25/89 .60 55.6 >62.5 30.1 89.5

PHASE II

10/25/89 .20 <0.1

*ALTERNATIVE REAGENT

••••HI EUSEREOO

RR30U922



Project No.: ELS 890200Laboratory No.: S 89-1083Date Received: 10/16/89

Saiple Identification: DRAIN PIPE SOIL "SLURRY" SALTVILLE, VIRGINA

UnconfinedAdditive Co»p. St. psi Volume Wet Weight

Sample No. Date wt. EMS. Iday 3day 5day 7day Increase Density pcf1 10/25/89 .15 0.72.8 3.5 80.92 10/25/89 .25 0.8 3.6 12.3 83.03 10/25/89 .20 < 0.1 <0.1 5.2 83.04 10/25/89 .40 < 0.1 0.2 15.8 88.05 10/25/89 .20 0.60.8 3.7 84.26 10/25/89 .40 20.9 25.0 13.9 89.4

PHASE II

10/25/89 .20 < 0.1

•••••I EMREGO

301*923



Project No..-ELS 890200Laboratory No. :S 89-1084Date Received: 10/16/89

Project Name; OLIN CHEMICAL COMPANY

Sample Identification: 80 ACRE LAGOON "AS IS" SALTVILLE, VIRGINA

UnconfinedAdditive Comp. St. psl Volume Wet Weight

Sample No. Date wt. gas. Iday 3day 5day 7day Increase Density pcf1 10/25/89 .15 8.3 38.9 0.6 83.2*2 10/25/89 .25 41.7 >62.5 4.8 86.83 10/25/89 .35 >62.5 >62.5 11.8 87.94 10/25/89 .20 2.0 2.7 1.2 86.35 10/25/89 .40 7.016.6 19.7 85.16 10/25/89 .60 62.5 >62.5 26.6 92.07 10/25/89 .20 0 . 1 5 . 5 -3.7 90.78 10/25/89 .40 9.7 >62.5 16.2 87.79 10/25/89 .60 41.7 >62.5 31.0 88.910 10/25/89 .20 3.9 5.5 -6.7 93.611 10/25/89 .40 >62.5 >62.5 16.9 87.112 10/25/89 .60 >62.5 >62.5 25.0 93.1

PHASE II10/25/89 .20 2.6

* ALTERNATIVE REAGENT

ENREOO


PRICING OPTIONS

ENRECO's pricing is based on samples taken Olin Chemical. Thepricing is as follows:

ACTIVITY PRICE

Mobilization/Demobilization $10,000.00 LS per systemStabilization 80 acre lagoon $20.00 per yard

alternative 80 acre lagoon $22.50 per yarddrain pipe soil $22.50 per yard

ENRECO's Prices include the following:* Equipment * Reagent* Labor * Supervision* Level D Health & Safety Protection

Terms:

1. Invoices due net 30 days.

2. Any delays or failures of performance by the materialsupplier's under this quotation shall not constitute defaultor give rise to any claim or damage during any period in whichsuch is reasonable beyond ENRECO"s control, this includes but,is not limited to: fire, windstorms, strikes, work stoppages,riots, unavailability of transportation, materials supplies ornecessary equipment, acts of God, acts of public enemy and actsof government authority.

3. Our proposal is based upon a 10 hour day 6 days a week, withthe option to work Sundays to make up for rain days.

4. There will be a standby charge of $1500.00 per day per systemif ENRECO is shutdown for any reason beyond our control.

5. Our prices do not reflect any maintenance or construction ofroads.

6. Our prices do not include sales and/or use tax if applicable.

7. Our prices do not include any air monitoring.

8. Our prices do not include bonds, engineering, layout, oranylitical testing.

9. Our pricing is based upon level D. If personnel have toupgrade to a higher level of protection, there will be aadditional charge.

ENREGO

Olin Chemicals Group - Saltville OU-2Preliminary Stabilization Studies

FLUOR DANIEL—————————————————————————————————————————

VFL Technology Corporation

B752BL.uE.FS9- FEB 1994 Feasibility StudyAppendix F

COPYVFL TECHNOLOGY CORPORATION

42 LLOYD AVENUE • MALVERN, PA 13355 • (215)290-2233 • FAX (215) 2S6-9545

September 7, 1993 RECEIVED

SEP 1 3

KEITH ROBERTSMr. John M. BurnsEngineeringOlin CorporationP.O. Box 248Charleston, TN 37310

Dear Mr. Burns:

VFL Technology Corporation (VFL) has completed a treatability study onstabilization of sludge and dike material at the Saltville, VA facility. The -purpose of thisresearch was to determine if a suitable cap could be constructed by stabilization to limit thepercolation of precipitation into the sludge which contains residual mercury.

VFL has isolated several mixes with acceptable strength characteristics, but anexamination of likely full-scale remediation costs is likely to be too expensive. VFL has,therefore, examined other options and a recommended alternative is proposed followingreview of the treatability study results.

An unusual number of treatability studies and new projects delayed the completion < <this report This significant increase in activity was related not only to the economy'srebound, but also to a large emergency contract that VFL had an opportunity to acquire.Hopefully, this delay did not inconvenience Olin or Fluor Daniel.

SITE INFORMATION

The Olin Saltville, Virginia Site has t\vo lagoons with surface areas of 50 and 75acres. They contain a sludge resulting from the Solvay, or ammonia soda} process andcalcium chloride is a major constituent. The sludge resembles a phosphate tailing and ishighly thixotropic with a moisture content varying between 50 and 200 percent. The sludgemay appear solid at the surface, but heavy equipment can sink in it and settling causescracks that allow water to infiltrate.

The lagoon sludge is non-hazardous, but the percolation of precipitation from eachlagoon results in leaching of mercury in total quantities that concern regulators. The goal <this VFL treatability study and conceptual plan is to identify an affordable approach tocapping the lagoons so the mercury remains within its non-hazardous disposal location.

flR30l»927SECURING OUR ENVIRONMENT THROUGH COMPREHENSIVE WASTE MANAGEMENT SERVICES

Mr. John M BurnsOlin CorporationPage 2September 7, 1993

A loader can only push an 18 inch lift for approximately 150 feet and subsequentsecond and third lifts are difficult to move. Dike material located on the perimeter isconstructed of the Solvay sludge, fly ash, slaker sludge, etc. and it may be more suitable forcreating a contoured base for a cap.

TREATABILITY STUDY

VFL originally hoped that stabilization using inexpensive fly ash or industrial by-products might offer a cost effective cap solution. This approach was examined in partbecause of calcium in the sludge which can initiate a pozzolanic stabilization when certainforms of calcium are present.

VFL procured two 5-gallon buckets of sample for the study. One contained arepresentative collection of dike samples, while the other container involved sludge fromseveral areas within the larger lagoons.

Rather than a full treatability study, it was decided that this preliminary researchwould focus primarily on preparation of varied types of mixes on both samples, followed byobservations of initial consistency wet and dry densities, percent solids and unconfmedcompressive strength testing.

Ash was procured from several local sources and 2 types were incorporated into mixesafter pozzolanic reactivity was noted. Type I Cement was also utilized.

Two cylinders were prepared for each mix test and the UCS reading represents anaverage value of the two breaks. Mixes were subjected to UCS testing at various timeintervals so that the effect of curing, or continued bond formation, can be evaluated.

Usually regulators request a cap strength of 50 psi for stabilized caps, but 30 psi offerssatisfactory characteristics if regulators will accept it.

Results

Treatability study data is listed on the following Stabilization Work Sheets. Forstabilization of the sludge, a 5% cement and 20% fly ash mixture produced the best results at65 psi at 28 days of cure. For the dike wall material, 5% cement produced 47 psi at 28days, whereas 10% produces 102 psi.

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Mr. John M. BurnsOlin CorporationPage 3September 7, 1993

Interpretation

To generate a cap over the 75 acres at the Saltville site with stabilized sludge and dikematerial will cost approximately $10 million if fill, top soil and revegetation phases areincluded. This obviously is not the price Olin wants to spend on this lagoon, so VFL hasdesigned an alternative with more reasonable costs, which is delineated in the next section.

One consideration that added appreciable cost is the need for a low permeability. Toachieve I x 10~7 cm/sec permeability or close to it, VFL must average approximately four feetdepth of stabilization. Also, the greater the ash content, the more difficult it is to reachdensity and permeability specifications.

Lime was not tested as a reagent because it does not generate the samestrength!density as cement and its reaction does not proceed as fast.

If VFL were to implement this type of stabilization, we would utilize in-situ processingequipment probably stiffening the surface with fly ash and then mixing in the dike material.A pug mill would not be used since is will increase the plasticity of the sludge.

Some of these observations are the result of a similar project VFL completed earlierwhich had a borderline plastic compactable sludge that we stabilized in-place.

GEOTEXTILE/CLAYMAXALTERNA TIVE

A more affordable option is to construct a cap utilizing a bentonite clay mat product.One benefit of this approach is that the contractor does not have to compact the clay toachieve high density and low permeability. VFL can simply unroll and place the mat.

If a break develops due to settlement of the basin sludge, the bentonite clay will swelldramatically when it comes into contact with water, self-sealing the break or water accesspoint.

The cap is most easily constructed in several stages, in part due to the unstable base.These recommended stages are listed below, beginning with the initial phase:

geotextile12" fillgeogridbentonite clay mat18" fill6" top soil

seed SR30I493!

•* Mr. John M. BurnsOlin CorporationPage 4September 7, 1993

The cost for this type of cap to be constructed is approximately $6 million. VFL iswilling to construct according to alternate cap designs that Fluor Daniel and Olin mightspecify. The above option was devised to allow reliability despite some settlement that willoccur. Use of on-site fill was incorporated into this projection.

Feel free to contact me if VFL can assist with other project details or cost estimates.

Sincerely,

Michael F. RobertsAccount Representative

MFRIplh

Mr. Keith D. Roberts - Olin CorporationMr. John Geivay - Fluor Daniel

301*932

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