AR I 01*810 · 2020. 8. 23. · e. sata investigated location -of the' stack ventilation ,, .channels which will be sealed to prevent dust penetration inside buildings during stack

TO: MICHAEL TOWLE / GEORGE ENGLISHTO: GROUP RRCTO: GROUP REGION03-TAT

SUBJECT: AVTEX SITE - POLREP 821POLREP #822AVTEX FIBERS FRONT ROYAL404 KENDRICK LANE ' - -^FRONT ROYAL, WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTN: CHARLIE KLEEMAN and RRC

CC: WAYNE WALTERS (3RC21)CC: BONNIE GROSS (3HW23) ,

I. SITUATION (AS OF 1800 HOURS, WEDNESDAY, OCTOBER 22, 1997)A. OSCs TOWLE AND ENGLISH ONSITE TO COORDINATE REMOVAL ACTIVITIES.B. SITE REMOVAL ACTIONS CONTINUE.C. 24-HOUR SECURITY CONTINUES.D. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE). .E. BANKRUPTCY COURT-APPOINTED TRUSTEE CONTINUES SITE

MAINTENANCE. . 'F. PERSONNEL ON SITE: EPA-2, ERCS-20, SATA-2G. WEATHER: SUNNY, TEMPERATURE RANGE FROM 30s-703H. REMOVAL COSTS TO DATE (COB 10/22/97):

ESTIMATED CEILINGEPA DIRECT COSTS 448,671 • 519,161EPA INDIRECT COSTS 771,093 980,824TAT (EfiE) (11/27/93) 1,070,650 1,607,000

' SATA (WESTON) • '. 509,007 600>000ERCS (OHM) (4/7/92) ' 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000ERCS (ETI-088) 7,261,746 9,254,753USCG (10/1/91) 197,515 -. 197,515UNALLOCATED REMOVAL , 2,617,762

TOTAL REMOVAL COSTS 17,784,165 23,495,015

I. REMEDIAL COSTS TO DATE (COB 6/5/96):TOTAL REMEDIAL COSTS 9,565,624 10,260,960 •

TOTAL PROJECT COSTS 27,349,789TOTAL PROJECT CEILING 33,755,975ERCS IS AT 78.47% OF CEILINGSATA IS AT 84,83% OF CEILING

J. TEN PERCENT STATE SHARE 914,837

K~. ENFORCEMENT (106) COSTS (2/2/92-8/12/93)

TOTAL ENFORCEMENT COSTS 183,263 183,263

L. AN EARLY NOVEMBER START DATE IS ANTICIPATED FOR.INITIATION OFDEMOLITION ACTIVITIES IN SUPPORT OF FURTHER REMOVAL ACTIVITIES.THE START DATE IS DEPENDENT UPON COMPLETION OF SITE PLANNING •(DEMOLITION PLAN, HEALTH AND SAFETY PLAN, DUST CONTROL, AIRMONITORING, ETC.) AND IMPLEMENTATION OF SPILL CONTROL SYSTEMSAND AIR SAMPLING SYSTEMS. ADDITIONALLY, 'EPA SHALL COORDINATEWITH AND NOTIFY STATE AND LOCAL OFFICIALS AND THE COMMUNITYPRIOR TO DEMOLITION ACTIVITIES.

M. VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY (VA DEQ)REPRESENTATIVES ONSITE TO MEET WITH OSC AND DISCUSS SITEOPERATIONS ALONG WITH EPA BRANCH CHIEF DENNIS CARNEY.

N. COST INFORMATION INDICATES THAT IT IS MORE COST EFFECTIVE TO

AR I 01*810

REMOVE (VIA DEMOLITION) THE VENTILATION STACK RATHER THANARRANGE FOR A NEW POWER FEED. THE STACK DEMOLITION WILL LIKELYOCCUR NOVEMBER 1, 1997 IN ORDER TO ENABLE SEVERANCE OF SITEPOWER AFTERWARDS., THE OSC SHALL COORDINATE ACTIVITIES WITH"NORFOLK SOUTHERN, STATE-AND LOCAL OFFICIALS, AND THE LOCALCOMMUNITY. " •

II. ACTIONS, TAKEN: • •A. ERGS CONTINUED PREPARING WEST SIDE OF FACILITY FOR FUTURE

STAGING OF MATERIALS TO BE GENERATED FROM FACILITY DEMOLITION;ACTIVITIES INCLUDED HAULING AND SPREADING GRAVEL, ANDINSTALLING DRAINAGE CONTROL DITCHES; ERCS ALSO CONTINUEDPREPARING THE EAST SIDE STAGING AREA BY GRADING, COMPACTING ANDSPREADING STONE. ' '

B. ERCS BEGAN DEMOLITION OF THE COOLING TOWER LOCATED ON THE WESTSIDE OF THE FACILITY; CREWS UTILIZED EXCAVATORS TO KNOCK DOWNWOOD STRUCTURE AND REMOVE DEBRIS FROM UNDERLYING PIT WHICH 'CONTAINS SLUDGES SCHEDULED FOR SOLIDIFICATION.

C. ERCS PERSONNEL CONTINUED TO BREAK UP THE SODA TANK FOUNDATIONS;RCRA CHARACTERISTIC SLUDGES (D008) WHICH HAD BEEN CONTAINED INTHE SODA TANK FOUNDATIONS WERE REMOVED AND STAGED FOR FUTUREDISPOSAL. ' THE FOUNDATIONS WERE THEN PRESSURE WASHED.

', D. OSCfl TOWLE AND ENGLISH MET WITH DEMOLITION PROJECT MANAGER -ANDREPRESENTATIVE OF TRUSTEE TO DISCUSS DEMOLITION OPERATIONS AND

. STEEL/SCRAP PROCESSING DURING THESE OPERATIONS; DISCUSSEDPOTENTIAL VOLUMES OF MATERIALS AS WELL AS LOGISTICS TO BECONSIDERED. - ,

III1. FUTURE ACTIONS ' ' -A. ERCS TO CONTINUE TO PREPARE EAST AND WEST SIDE STAGING AREAS, WHICH WILL BE" USED FOR HAZARDOUS MATERIAL ' STORAGE IN SUPPORT OF. DEMOLITION AND DISMANTLEMENT OPERATIONS.

B. OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.C. SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE.D. SATA AND ERCS ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS

REGARDING ENGINEERING ASPECTS OF THE FUTURE DEMOLITIONOPERATIONS ' •E. OSC EXPECTING REPORT OF FlSH AND WILDLIFE STUDY IN THE ,UPCOMING WEEKS.

F. ELECTRICAL POWER TO BE DISCONNECTED AND RE-ROUTED TO ENSURETHAT BUILDINGS ARE DE-ENERGIZED PRIOR TO DEMOLITION, OSC TOCONTINUE TO COORDINATE WITH FMC ON THIS MATTER.

G. OSC TO FINALIZE DEMOLITION WORK PLAN AND SUPPORTING PLANS,(E.G. DUST CONTROL, AIR MONITORING, SPILL CONTROL, HEALTH ANDSAFETY) PRIOR TO ANTICIPATED INITIATION OF DEMOLITION INEARLY NOVEMBER.H. OSC TO ATTEND PUBLIC MEETING ON 28 OCTOBER 1997 TO NOTIFY AND

. ' BRIEF LOCAL OFFICIALS ON SCHEDULED DEMOLITION ACTIVITIES.I. OSC TO COORDINATE DEMOLITION OF THE VENTILATION STACK.

MIKE TOWLE, OSCU.S. EPA REGION IIIPHILADELPHIA, PA

AR 101*811

TO: MICHAEL TOWLE / GEORGE ENGLISHTO: GROUP RRCTO: GROUP REGION03-TAT

SUBJECT: AVTEX SITE - POLREP 823POLREP #823 . , . , . 'AVTEX FIBERS FRONT ROYAL 1404 KENDRICK LANEFRONT ROYAL,- WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTION ' " , - . 'ATTN: CHARLIE KLEEMAN and RRC

CC: WAYNE WALTERS (3RC21) , •CC: BONNIE GROSS (3HW23)

I. SITUATION (AS OF 1800 HOURS, WEDNESDAY, OCTOBER 29, 1997)A. OSCs TOWLE, ENGLISH, KELLY AND FAS MCDONALD ONSITE.B. SITE REMOVAL ACTIONS CONTINUE. ,C. 24-HOUR SECURITY CONTINUES.D. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE ' '.

ORDER (AO) TO AVC AND AVTEX (TRVSTEE).E. PERSONNEL ON SITE! EPA-4, ERCS-20, SATA-3F.. WEATHER: SUNNY, TEMPERATURE RANGE FROM 30s-60sG. REMOVAL COSTS TO DATE (COB 10/29/97): .

. ESTIMATED CEILINGEPA DIRECT COSTS 454,294 519,161EPA INDIRECT COSTS 780,821 980,824TAT (EfcE) (11/27/93) 1,070,650 1,607,000SATA (WESTON) 518,944 1,107,052ERGS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000ERCS (ETI-088) 7,336,129 15,254,753USCG (10/1/91) 197,515 197,515UNALLOCATED REMOVAL 29,326,854


H. REMEDIAL COSTS TO DATE (COB 6/5/96):TOTAL REMEDIAL COSTS . 9,565,624 10 260,960

TOTAL PROJECT COSTS 27,349,789 " ' . • ' . 'TOTAL PROJECT CEILING 66,972,119ERCS IS AT 48.09% OF CEILINGSATA IS AT. 46.87% OF CEILING

I. TEN PERCENT STATE SHARE 914,837

J. ENFORCEMENT (106) COSTS (2/2/92-8/12/93)


K. A MID-NOVEMBER START DATE IS ANTICIPATED FOR INITIATION OFDEMOLITION ACTIVITIES IN SUPPORT OF FURTHER REMOVAL ACTIVITIES.THE START DATE IS DEPENDENT UPON COMPLETION OF SITE PLANNING(DEMOLITION PLAN, HEALTH AND SAFETY PLAN, DUST CONTROL, AIRMONITORING, ETC.) AND IMPLEMENTATION OF SPILL CONTROL SYSTEMSAND AIR SAMPLING SYSTEMS.

L. OSCs TOWLE, ENGLISH, AND KELLY, ALONG WITH OPA PAT GAUGHN, RPM' BONNIE GROSS, AND ORC WAYNE WALTERS, CONDUCTED A PUBLIC MEETING

ON 28 OCTOBER 1997 TO NOTIFY LOCAL RESIDENTS AND COMMUNITYOFFICIALS OF PLANNED DEMOLITION ACTIVITIES AT THE SITEINCLUDING MATERIALS HANDLING, PROPOSED FUTURE LANDFILLLOCATION, RISK AND REDEVELOPMENT ISSUES; IN ADDITION,REPRESENTATIVES FROM VA DEQ ATTENDED THE MEETING TO PROVIDEFURTHER INFORMATION.

AR 10(43 I 2

M. COST INFORMATION INDICATES THAT IT IS MpRE COST EFFECTIVE TO. ' REMOVE (VIA DEMOLITION) THE VENTILATI6N STACK RATHER THAN

• ARRANGE FOR,A NEW POWER.FEED. THE STACK DEMOLITION WILL LIKELYOCCUR NOVEMBER 11, 199*7 IN ORDER TO ENABLE SEVERANCE OF SITEPOWER AFTERWARDS. THE STACK INTERIOR HAS A COATING OFCORROSIVE MATERIAL AND SIGNS OF DETERIORATION (I.E. SPALLING

. AND CRACKING) ARE VISIBLE. STACK DEMOLITION WILL ELIMINATE THENEED.FOR FUTURE OPERATION (LIGHTS) AND MAINTAINENCE TO AVOIDUNCONTROLLED RELEASES OF HAZARDOUS MATERIALS. THE OSC SHALLCOORDINATE ACTIVITIES W^TH NORFOLK SOUTHERN, 'STATE AND LOCAL .OFFICIALS, 'AND THE LOCAL COMMUNITY.

II. ACTIONS TAKENi_

A. ERCS CONTINUED PREPARING EAST AND WEST SIDE OF FACILITY FORFUTURE.STAGING OF MATERIALS TO BE GENERATED FROM FACILITYDEMOLITION. , , , ,

B. ERCS FINISHED DEMOLITION OF THE COOLING TOWER LOCATED ON THEWEST SIDE OF THE FACILITY AND'BEGAN SOLIDIFYING THEAPPROXIMATELY 25,000 CUBIC YARDS OF SLUDGE CONTAINED IN THEUNDERLYING PIT.

C.. ERCS BEGAN DRAINING WATER FORMERLY CONTAINED IN BAKER TANKSINTO THE ONSITE SEWER SYSTEM FOR TREATMENT AT THE ONSIfETREATMENT PLANT; AFTER NOTIFICATION, FMC AGREED TO THISDISCHARGE. : ,

D. ERCS SECURED SELECTED MANHOLES LOCATED AT THE WEST SIDE STAGINGAREA TO PREVENT THEIR STRUCTURAL DAMAGE DURING STACK' DEMOLITION.

E. SATA INVESTIGATED LOCATION -OF THE' STACK VENTILATION ,, .CHANNELS WHICH WILL BE SEALED TO PREVENT DUST PENETRATION

INSIDE BUILDINGS DURING STACK DEMOLITION.F. SATA ENGINEER INSPECTED CURRENT TECHNICAL CONDITION OF THEVENTILATION STACK STRUCTURE. THERE ARE VISUAL INDICATIONS OF.

DETERIORATION OF THE MASONRY INSIDE AND OUTSIDE THE STRUCTUREINCLUDING SURFACE SPALLING AND CRACKING.: DIFFERENCESOF OUTSIDE TEMPERATURE DURING WINTER TIME CAN CAUSE ADDITIONAL ,DEGRADATION OF THE MASONRY AND RESULT IN FURTHER STRUCTURALFAILURE. SOIL SUBSIDENCE WAS PREVIOUSLY OBSERVED WITHIN CLOSE

. PROXIMITY TO THE STACK (SECTION III) AND NEW INDICATIONS OFSOIL MOVEMENT HAVE BEEN NOTED SOUTH OF THE FAN HOUSE WALL.SINKHOLES OR OTHER GEOTECHNICAL CONDITIONS DEVELOPING WITHINTHE FOUNDATION ZONE OF INFLUENCE OF THE STACK COULD LEAD TO ITSCOLLAPSE. . • . •

III. FUTURE ACTIONS 'A. ERCS TO COMPLETE EAST AND WEST SIDE STAGING AREAS WHICH WILL BE

USED FOR DEBRIS STORAGE IN SUPPORT OF DEMOLITION ANDDISMANTLEMENT OPERATIONS., A CONTAINMENT AREA WILL ALSO BEPREPARED ON'EACH SIDE TO HANDLE GENERATED SLUDGES.

B. OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS,

C. SATA TO INSTALL FOUR AIR SAMPLING STATIONS SURROUNDINGFACILITY TO MONITOR POTENTIAL AIR CONTAMINATION DURINGDEMOLITION ACTIVITIES.

D. SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE.E. SATA AND ERCS ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONSREGARDING ENGINEERING ASPECTS OF THE FUTURE DEMOLITIONOPERATIONS (F. OSC EXPECTING REPORT OF FISH AND WILDLIFE STUDY IN THEUPCOMING WEEKS.

G. ELECTRICAL POWER'TO BE DISCONNECTED AND RE-ROUTED TO ENSURE.THAT BUILDINGS ARE DE-ENERGIZED PRIOR TO DEMOLITION. OSC TO

AR 101(813

CONTINUE TO COORDINATE WITH FMC ON THIS MATTER. : .H. OSC TO FINALIZE DEMOLITION WORK PLAN AND SUPPORTING PLANS, -—. '. (E.G. DUST CONTROL, AIR MONITORING, SPILL CONTROL, HEALTH AND • ,SAFETY) PRIOR TO ANTICIPATED INITIATION OF DEMOLITION IN \ JNOVEMBER. * - - ^-^

I. OSC TO COORDINATE DEMOLITION OF THE VENTILATION STACK ANDNOTIFY COMMUNITY IN ADVANCE OF DETONATION.

J. OSC TO COMPLETE EMERGENCY CONTINGENCY PLAN WITH LOCAL EMERGENCYMANAGEMENT OFFICIALS TO INCLUDE RESPONSE ACTIVITIES IN CASE OFRELEASE OF HAZARDOUS MATERIALS TO THE SURROUNDING COMMUNITY.


AR I Q143II4

TO: MICHAEL TOWLE / GEORGE ENGLISH . /TO: GROUP RRC . ' 'TO: GROUP REGION03-TAT '

SUBJECT: AVTEX SITE - POLREP 824POLREP #824 . •' • ' ,-AVTEX FIBERS FRONT ROYAL '404 KENDRICK LANEFRONT ROYAL, WARREN COUNTY, VA 22630.CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTN: CHARLIE KLEEMAN ,and RRC - , .

. CC: WAYNE WALTERS. (3RC2I) ''CC: BONNIE GROSS (3HW23) , •, . •

I. SITUATION (AS OF 1800 HOURS, WEDNESDAY, NOVEMBER 5, 1997)A. OSCs TOWLE, ENGLISH, AND KELLY ONSITE ALONG WITH FAS McDONALD.fl. SITE REMOVAL ACTIONS CONTINUE. ' ;C. 24-HOUR SECURITY CONTINUES.D.'ENFORCEMENT ACTIVITIES.CONTINUE PER ADMINISTRATIVE1 ORDER (AO) TO AVC AND AVTEX (TRUSTEE).E. PERSONNEL ON-SITE: EPA-4, ERCS-20, SATA-3F.. WEATHER: SUNNY, TEMPERATURE RANGE FROM 30s-60s; RAINS OVER

WEEKEND •G. REMOVAL COSTS TO DATE (COB 11/05/97): ' . ,

ESTIMATED CEILINGEPA DIRECT COSTS 459,542 519,161 'EPA INDIRECT COSTS 789,781 980,824TAT (E&E) (11/27/93) , 1,070,650 1,607,000 . ' .-SATA (WESTON) . 539,042 1,107,052ERCS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000ERCS (ETI-088) 7,411,636 15,254,753

;' USCG (10/1/91) f 197,515 197,515UNALLOCATED REMOVAL 29,326,854

TOTAL REMOVAL COSTS ,. ' 17,993,649 56,711,159

H. REMEDIAL COSTS TO DATE (COB 6/5/96):TOTAL REMEDIAL COSTS ; 9,565,624 10,260,960

TOTAL PROJECT COSTS ' '• 27,559,273TOTAL PROJECT CEILING " , • • • • 66,972,119ERCS IS AT 48.58% OF CEILINGSATA IS AT 48.69% OF CEILING

I. TEN PERCENT STATE SHARE L. 914,837



II. ACTIONS TAKEN: ' '

A. ERCS CONTINUED PREPARING EAST AND WEST SIDE OF FACILITY FORFUTURE STAGING OF MATERIALS TO BE GENERATED FROM FACILITYDEMOLITION.

B. ERCS- FINISHED SOLIDIFYING APPROXIMATELY 25,000 CUBICYARDS OF SLUDGE CONTAINED IN THE COOLING .TOWER UNDERLYING PIT;THE MATERIALS WERE STAGED BENEATH THE CANOPY IN THE COAL YARDON THE EAST SIDE OF THE BUILDING.

C. ERCS FINISHED DRAINING WATER FORMERLY CONTAINED IN BAKER TANKSINTO THE ONSITE SEWER SYSTEM FOR TREATMENT AT THE ONSITE -.TREATMENT PLANT; UPON NOTIFICATION, FMC HAD AGREED TO THIS

AR 101*815

DISCHARGE. ,• ; , v ,P. ERCS CONTINUED TO SECURE SELECTED MANHOLES LOCATED AT THE WEST -

SIDE STAGING AREA TO PREVENT THEIR STRUCTURAL DAMAGE DURING .STACK DEMOLITION.

E. ERCS COMPLETED SEALING OF THE STACK VENTILATION CHANNELS INORDER TO PREVENT DUST PENETRATION INSIDE BUILDINGS DURING STACK ,DEMOLITION. - , .

F. SATA INSTALLED FOUR AIR SAMPLING STATIONS ALONG THE PERIMETER OFTHE FACILITY AND BEGAN COLLECTING BACKGROUND AIR SAMPLES..

G. OSC KELLY CONTACTED CHUCK JOHNSON (NORFOLK & SOUTHERNREPRESENTATIVE) REGARDING THE PRESENCE OF THEIR RAIL CARS ON THETRACKS DURING STACK DEMOLITION. OSC KELLY INFORMED HIM OF THEPOTENTIAL FOR THESE CARS TO BE HIT BY DEBRIS DURING OPERATIONS.CORRESPONDENCE REGARDING THIS MATTER WAS FAXED TO MR. JOHNSON ONFRIDAY, 31 OCTOBER 1997.

H. U.S. ARMY CORPS OF ENGINEERS (ACOE) REPS ONSITE TO MEET WITHOSCa TO DISCUSS PROPOSED RCRA CELL PLANS.

I. OSCs WET WITH WARREN COUNTY FIRE AND RESCUE CHIEF RICHARD MABIEREGARDING PREPARATION OF EMERGENCY OPERATIONS PLAN; PLAN WASPREPARED AND APPROVED, AND HAS BEEN ADDED AS AMENDMENT TO HEALTHAND SAFETY PLAN AS WELL AS DEMOLITION PLAN. (

. J. ERCS DISMANTLED THE CONTAINMENT POND IN THE NORTH PORTION OFTHE STAPLE DEPARTMENT AND MOVED IT Tp #4 SHIPPING (EAST SIDE OFFACILITY) FOR'USE IN TREATING LIQUIDS/SLUDGES DURING DEMOLITIONOPERATIONS. ' - '

III. FUTURE ACTIONS

A..ERCS TO COMPLETE EAST AND WEST SIDE STAGING AREAS WHICH WILLBE USED FOR DEBRIS STORAGE IN SUPPORT OF DEMOLITION ANDDISMANTLEMENT OPERATIONS; • , •

B. ERCS TO CONTINUE PUMPING WATER FROM THE FILTER HOUSE POND TO THE .SOFT WATER PUMPHOUSB TANK FOR USE IN DUST CONTROL; ERCS ALSO TO ' ,ARRANGE FOR NECESSARY HOSES AND PUMPS FOR SPECIFIC DUST CONTROL V JDURING STACK DEMOLITION .(TEST RUN TO BE HELD ON FRIDAY. 7 ^^NOVEMBER 1997). • - , . *

C. ERCS TO FLUSH FORMER DIMETHYLAMINE AND CARBON' DISULFIDE LINESWHICH RUN BETWEEN CHURN & MIX #1 AND #2 ALONG THE SOUTHCORRIDOR IN ORDER TO VERIFY THAT THEY ARE EMPTY.

D..ERCS TO FINISH DEMOLISHING AND BACKFILLING SODA TANK.FOUNDATIONS AFTER REMOVAL OF REMAINING PIPING.

E\ OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.

F. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION. ,

G. SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE.H. SATA AND ERCS ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS

REGARDING ENGINEERING ASPECTS OF THE FUTURE DEMOLITIONOPERATIONS. • . • , . • " ,

. I. OSC EXPECTING REPORT OF FISH AND WILDLIFE STUDY IN THE . ...UPCOMING WEEKS. , * -

J. ELECTRICAL POWER TO BE DISCONNECTED AND RE-ROUTED TO ENSURETHAT BUILDINGS ARE DE-ENERGIZED PRIOR TO DEMOLITION. OSC TOCONTINUE TO COORDINATE WITH FMC ON THIS MATTER,

K. OSC TO FINALIZE DEMOLITION WORK PLAN AND SUPPORTING PLANS,(E.G. DUST CONTROL, AIR MONITORING, SPILL CONTROL, HEALTH ANDSAFETY) PRIOR TO ANTICIPATED INITIATION - OF DEMOLITION IN .NOVEMBER.

L. OSC TO COORDINATE DEMOLITION OF THE VENTILATION STACK ANDNOTIFY COMMUNITY IN ADVANCE OF DETONATION; DATE IS SET FOR 11NOVEMBER 1997. .

ARIOt»8l6

MIKE TOWLE, OSC ,oU.S..EPA REGION IIIPHILADELPHIA, PA

AR101*8 I 7

TO: MICHAEL TOWLE / GEORGE ENGLISH 'TO: GROUP RRC .TO; GROUP REGION03-TAT

SUBJECT:.AVTEX SITE - POLREP 825 , .POLREP #825 -AVTEX FIBERS FRONT ROYAL .404 KENDRICK LANE , . ...FRONT ROYAL, WARREN COUNTY, VA 22630 „CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTION .ATTN: CHARLIE KLEEMAN and RRC .

CC: WAYNE WALTERS (3RC21)CC: BONNIE GROSS (3HW23) . • : .

I. SITUATION (AS OF 1730 HOURS> WEDNESDAY, NOVEMBER i2, 1997)A. OSCS TOWLE AND ENGLISHONSITE.B. SITE REMOVAL ACTIONS CONTINUE.C. 24-HOUR SECURITY" CONTINUES, ,D. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AOj TO AVC AND AVTEX (TRUSTEE).E, PERSONNEL ON SITE: EPA-2, ERCS-26, SATA-3F. WEATHER: CLOUDY, TEMPERATURE RANGE FROM 30s-40s; RAINS OVER '

WEEKEND ,G. REMOVAL COSTS TO DATE (COB 11/05/97): . " ; • •

ESTIMATED CEILING .EPA DIRECT COSTS 465,109 519,161EPA INDIRECT COSTS 799,189 . 980,824TAT .(EfiE) (11/27/93) 1,070,650 1,607,000SATA (WESTONJ 546,515 1,107,052: .ERGS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000ERCS (ETI-088) 7,519,795 15,254,753 .USCG (10/1/91) 197,515 197,515 .UNALLOCATED REMOVAL . 29,326,854 ' I J

TOTAL REMOVAL COSTS 18,124,256 56,711,159 ' ,

H. REMEDIAL COSTS TO DATE j(COB 6/5/96):TOTAL REMEDIAL COSTS 9,565,624 10,260,960

TOTAL PROJECT COSTS 27,689,880TOTAL PROJECT CEILING 66,972,119ERCS IS-AT 49.29% OF CEILING 'SATA IS AT 4,9.36% OF CEILING ;


J. ENFORCEMENT (106) COSTS (2/2/92-8/12/93) ,


II. ACTIONS TAKEN: ! '

A. ERCS CONTINUED PREPARING EAST ANp WEST SIDE OF FACILITY FORFUTURE STAGING OF MATERIALS TO BE GENERATED FROM FACILITYDEMOLITION. ,

B. ERCS PERSONNEL FLUSHED THE DIMETHYLAMINE AND CARBON DISULFIDE ,PIPELINES ASSOCIATED WITH CHURN AND MIX #1 AND #2 WITH WATER INORDER TO VERIFY THAT THEY WERE EMPTY PRIOR TO THE START OF ,DEMOLITION OPERATIONS.

C. CONTROLLED DEMOLITION, INC. (CDI) REPRESENTATIVES ARRIVEDONSITE AND PREPARED THE VENTILATION STACK FOR DEMOLITION/ ONTUESDAY 11 NOVEMBER 199?, THE STACK WAS BROUGHT TO THE GROUND

A R I D 1*31 8

• VIA DETONATION SUCCESSFULLY. AIR MONITORING DURING THE .STACKDEMOLITION REVEALED NO RELEASES ABOVE BACKGROUND LEVELS OFDUST/PARTICULATES. SITE PERSONNEL WERE SUPPORTED BY WARRENCOUNTY FIRE FIGHTING 'PERSONNEL WHO ARRIVED ONSITE AND PROVIDEDDUST CONTROL IN ADDITION TO MEASURES WHICH HAD BEEN INSTALLEDPRIOR TO STACK DEMOLITION, FEDERAL AVIATION ADMINISTRATION

' (FAA) OFFICIALS WERE NOTIFIED PRIOR TO DEMOLITION.,. REPRESENTATIVE FROM NORFOLK'SOUTHERN RAILROAD ON SITE TO

WITNESS DETONATION AND ENSURE NO DEBRIS ON RAILROAD. PRIOR TODETONATION DAY, NOTIFIED AND COORDINATED WITH FRONT ROYALSCHOOL DISTRICT SUPERINTENpENT ON BEST.DETONATION TIME.ELECTRIC POWER TO THE SITE HAD BEEN SHUT DOWN ON MONDAY.

D. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR'FOR POTENTIALRELEASES OF SITE CONTAMINANTS; TO DATE, NO RELEASES ABOVEBACKGROUND LEVELS HAVE BEEN DETECTED.

E. U.S. ARMY CORPS OF ENGINEERS (ACOE) 'REPS ONSITE TO MEET WITHOSCs TO DISCUSS PROPOSED'RCRA CELL PLANS. ,

F. ERCS CHEMIST ARRIVED ONSITE -TO ADDRESS HIGH PH WATER CONTAINEDIN SPRAY POND; PERSONNEL ADDED 10 DRUMS OF SULFURIC ACID WHICHHAD BEEN RECOVERED FROM' THE ACID LINE WHICH FORMERLY LED TO THEOLD ALLIED CHEMICAL ACID PLANT.

III. FUTURE ACTIONS

A. ERCS TO COMPLETE EAST AND WEST SIpE STAGING AREAS WHICH WILLBE USED FOR DEBRIS STORAGE IN SUPPORT OF DEMOLITION ANDDISMANTLEMENT OPERATIONS.

, B. ERCS TO COMPLETE REMOVAL OF SODA TANK FOUNDATIONS.C. OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TO

COORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.D. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THE

OSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION.E. SATA ENGINEER TO INVESTIGATE AND PREPARE INFORMATION ABOUT TANK

LOCATIONS AND CONTENTS IN SECTION,III OF THE FACILITY FORPROPER REMOVAL" AND STORAGE OF THE CHEMICALS DURING DEMOLITION

' OPERATIONS. . .F, SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE.G. SATA AND ERCS ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS

REGARDING ENGINEERING ASPECTS OF THE FUTURE DEMOLITIONOPERATIONS. ' ... : .

H. OSC EXPECTING REPORT OF FISH AND WILDLIFE STUDY IN THE.UPCOMING W E E K S . ' ' . - . - ' •

I. OSC TO FINALIZE DEMOLITION WORK PLAN AND SUPPORTING PLANS,(E.G. DUST CONTROL, AIR MONITORING, SPILL CONTROL, HEALTH ANDSAFETY) PRIOR TO ANTICIPATED INITIATION OF DEMOLITION INNOVEMBER. : , - ' • • - .


AR 101*819

TO: MICHAEL TOWLE 7 GEORGE ENGLISH .TO: GROUP RRCTO: GROUP REGION03-TAT . .

SUBJECT: AVTEX SITE - POLREP 826 ,POLREP #826 , .AVTEX FIBERS FRONT ROYAL .404 KENDRICK LANE • ..FRONT ROYAL, WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTN: CHARLIE KLEEMAN and RRC

CC: WAYNE WALTERS (3RC21) ,CC: BONNIE GROSS (3HW23)

1. SITUATION (AS OF 1730 HOURS, WEDNESDAY, NOVEMBER 20, 1997)A. OSCa TOWLE AND ENGLISH ONSITE; FAS MCDONALD ONSITE.B. SITE REMOVAL ACTIONS CONTINUE. 'C. 24-HOUR SECURITY CONTINUES.D. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE).E. PERSONNEL ON SITE: EPA-3, ERCS-27, SATA-3 ,F. REMOVAL COSTS TO DATE (COB 11/19/97): .

ESTIMATED' CEILING 'EPA DIRECT COSfS 469,188 519,161EPA INDIRECT COSTS 806,133 980,824TAT (E&E) (11/27/93) 1,070,650 1,607,000SATA (WESTON) 553,436 1,107,052

-ERCS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) ,30,984 33,000 'ERCS (ETJ-088) 7,695,649 15,254,753USCG (10/1/91) 197,515 197,515UNALLOCATED REMOVAL 29,326,854

TOTAL. REMOVAL COSTS 18,318,054 56,711,159

G. REMEDIAL COSTS TO DATE (COB 6/5/96):TOTAL REMEDIAL COSTS 9,565,624 10,260,960

' TOTAL PROJECT COSTS . '27,883,678TOTAL PROJECT CEILING 66,972,119 .ERCS IS AT 50.44% OF CEILINGSATA IS AT 49.99% OF CEILING • ; .

H. TEN PERCENT STATE SHARE 914,837

; I. ENFORCEMENT (106) COSTS (2/2/92-8/12/93)


II. ACTIONS TAKEN:

A. ERCS CONTINUE PREPARING EAST AND WEST SIDE OF-FACILITY FORFUTURE STAGING OF MATERIALS TO BE GENERATED FROM FACILITYDEMOLITION. A HOPE LINER WAS INSTALLED INTO RUNOFF COLLECTION -TRENCH AND SUMPS. COMPACTION AND STONE COVER CONTINUES.

B. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIALRELEASES OF SITE CONTAMINANTS DURING DEMOLITION; TO DATE, NORELEASES ABOVE BACKGROUND LEVELS HAVE BEEN DETECTED. , :

C, ERCS CHEMIST ONSITE TO ADDRESS HIGH PH WATER AND OTHER CHEMICALCONCERNS. PH OF SPRAY ?OND WATER ADJUSTED TO LESS THAN 9.5 INPREPARATION OF DISCHARGE TO SITE WASTE WATER TREATMENT PLANT.

D. ERCS DECONTAMINATED ALL RUBBLE FROM STACK DEMOLITION BY WATERWASH. THIS RUBBLE WILL BE USED IN BACKFILL OPERATIONS. > ,

E. ERGS COMPLETED: SLUDGE AND DEBRIS CLEANUP/TREATMENT BASIN(SPLOOGE PIT; FORMER COOLING TOWER) BY INSTALLING A SUMP TOCOLLECT CONTAMINATED WATER GENERATED DURING CLEANUP,OPERATIONS.

, ALL RCRA HAZARDOUS AND CONTAMINATES DEBRIS WILL BE CLEANED ORTREATED IN THIS BASIN. . ,

F. ERGS CONTINUED REMOVAL OF SODA TANK FOUNDATIONS AND BEGAN TO. - BACK .FILL THE AREA; SATA COLLECTED A SAMPLE OF THE AREA PRIOR TO

BACKFILLING. NEUTRALIZED WATER FROM THE SODA ROOM WAS PUMPED TOTHE SPRAY POND FOR LATER DISCHARGE TO ONSITE SEWERS. INADDITION, HIGH PH (APPROXIMATELY 10.5) STORM WATER, WHICH HADBEEN FLOWING OUT OF MANHOLE A-6i AND INTO THE SODA TANKFOUNDATIONS DUE TO A CEMENT PLUG IN THE SEWER LINE, WAS PUMPEDINTO THE ONSITE CAUSTIC .SEWER SYSTEM.

. G. ERCS FINISHED THE EQUIPMENT DECON AREA NORTH OF THE WESTSTAGING AREA. ' . .

, H. ERCS'ASSEMBLED WATER LINE FROM THE FILTER HOUSE POND TO THEEAST SIDE STAGING AREA FOR FUTURE DUST^CONTROL OPERATIONS.

• • I.. ERCS DEMOLISHED TWO SECTIONS OF A NONBEARING WALL IN #4SHIPPING BUILDING IN ORDER TO INSTALL 4 BAKER TANKS TO CONTAINCONTAMINATED WATER FROM EAST SIDE OPERATIONS. - '

.J. ERCS CONTINUE TO PLUG MANHOLES AS NECESSARY.K. SATA COLLECTED SAMPLES FROM EAST AND WEST-STAGING AREAS IN

ORDER TO CHARACTERIZE PRE-DEMOLITION CONDITIONS IN THE AREAS.L. ERCS DEMOLISHED ZINC BUILDING AND CLEANED UP DEBRIS; PERSONNEL

ALSO BEGAN DEMOLITION OF THE FAN HOUSE NEAR THE FORMERVENTILATION STACK. THESE .AREAS ARE CONSIDERED LOW HAZARD AREAS.

M. OSC FINALIZED DEMOLITION WORK PLAN AND SUPPORTING PLANS,(E.G. DUST CONTROL, AIR MONITORING, SPILL CONTROL, HEALTH ANDSAFETY) 1 .:

III. FUTURE ACTIONS

A. ERCS TO COMPLETE EAST AND WEST SIDE STAGING AREAS WHICH WILLBE USED FOR DEBRIS STORAGE IN SUPPORT OF DEMOLITION ANDDISMANTLEMENT OPERATIONS;. ERCS TO CONTINUE'DEMOLITIONOPERATIONS AS DIRECTED BY OSC. , ,

B. OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TO' COORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.

C. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION.

D. SATA TO INVESTIGATE AND PREPARE INFORMATION ABOUT TANKLOCATIONS AND CONTENTS IN SECTION III OF THE FACILITY FORPROPER REMOVAL AND STORAGE OF THE CHEMICALS DURING DEMOLITIONOPERATIONS.

E. SATA TO-EDIT VIDEO TAPE ABOUT THE AVTEX SITE.F. SATA AND ERCS ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS

REGARDING ENGINEERING ASPECTS OF THE FUTURE DEMOLITIONOPERATIONS.

G. OSC EXPECTING REPORT OF FISH AND WILDLIFE STUDY IN THEUPCOMING WEEKS•

H. U.S. ACOE EXPECTEl) ONSITE TO ASSIST IN DEMOLITION COORDINATIONOF PROPOSED LANDFILL AND TO ASSIST OSC WITH LANDFILL DESIGNINFORMATION.

MIKE TOWLE, OSCU.S. E P A REGION I I I . , . ' • 'PHILADELPHIA, PA ,

AR 101*821

TO: MICHAEL TOWLE / GEORGE ENGLISH .T01 GROUP RRC, ATOi GROUP REGION03-TAT ^C^ ^

SUBJECT: AVTEX SITE - POLREP 827POLREP #827 .AVTEX FIBERS FRONT ROYAL404 KENDRICK LANE . -^FRONT ROYAL, WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTN: CHARLIE KLEEMAN and RRC

CC: WAYNE WALTERS (3RC21) .CC: BONNIE GROSS (3HW23)

I.' SITUATION (AS OF 1730 HOURS, MONDAY, NOVEMBER 24, 1997)A. OSCs TOWLE; FAS MCDONALD ONSITE. ,B. SITE REMOVAL ACTIONS CONTINUE.,C. 24-HOUR SECURITY CONTINUES.D. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE).E, PERSONNEL ON SITE: EPA-2, ERCS-25, SATA-3F. REMOVAL COSTS TO DATE (COB 11/19/97):

ESTIMATED CEILINGEPA DIRECT COSTS 472,423 519,161EPA INDIRECT COSTS 811,701 980,824TAT (EfiE) (11/27/93) 1,070,650 1,607,000'SATA (WESTON) 558,812 ^ 1,107,052ERCS (OHM) (4/7/92) 7,494,49? 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000ERCS (ETI-088) 7,850,796 15,254,753USCG (10/1/91) 197,515 197,515UNALLOCATED'REMOVAL 29,326,854TOTAL REMOVAL COSTS ' 18,487,380 56,711,159

G. REMEDIAL COSTS TO DATE (COB 6/5/96): , ,TOTAL REMEDIAL COSTS: 9,565,624 10,260,960TOTAL PROJECT COSTS 28,053,004TOTAL PROJECT CEILING 66,972,119.ERCS IS AT 51.46% OF CEILINGSATA IS AT 50.47% OF CEILING

H. TEN PERCENT STATE SHARE 914,B37 .I. ENFORCEMENT (106) COSTS (2/2/92-8/12/93)

TOTAL ENFORCEMENT COSTS - 183,263 183,263

U. ACTIONS TAKEN: 'A. ERCS CONTINUE PREPARING EAST AND WEST SIDE OF FACILITY FOR

FUTURE STAGING OF MATERIALS TO BE GENERATED FROM FACILITYDEMOLITION. COMPACTION AND STONE COVER CONTINUES. ,

B. ERCS BEGAN DEMOLITION OF THE .NORTHWEST PART OF SECTION III;PERSONNEL CONTINUE TO SEGREGATE CONTAMINATED MATERIALS FROMCLEANED DEBRIS FOR PROPER STAGING AND DISPOSAL.C. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIAL

•; - RELEASES OF SITE CONTAMINANTS DURING DEMOLITION; TO DATE, NORELEASES ABOVE BACKGROUND LEVELS HAVE BEEN DETECTED.

D. ERCS CHEMIST ONSITE TO ADDRESS HIGH PH WATER AND OTHER CHEMICALCONCERNS. AFTER ADJUSTING THE PH OF THE SPRAY POND WATER TOAPPROXIMATELY 7.5, THE WATER WAS DISCHARGED TO ONISTE SEWERS AND ' ,

f f

ULTIMATELY.TO THE ONSITE WASTEWATER TREATMENT PLANT.-'E. ERGS CONTINUED TO BACKFILL-THE AREA OF THE FORMER SODA TANK -

FOUNDATIONS; IN ADDITION, APPROXIMATELY 9,000 GALLONS OF CAUSTICWATER WAS PUMPED FROM THE SODA ROOM BASEMENT TO THE SPRAY PONDFOR PH ADJUSTMENT AND ULTIMATE DISCHARGE TO ONSITE SEWERS.

F. ERGS INSTALLED FOUR BAKER TANKS IN #4 SHIPPING BUILDING FOR USEIN CONTAINING LIQUIDS GENERATED DURING DEMOLITION OPERATIONS ONTHE EAST SIDE OPERATIONS.

G. EPA HEADQUARTERS REPRESENTATIVES ONSITE TO INSPECT SITE ' 'OPERATIONS AND .DISCUSS ACTIVITIES WITH OSCs TOWLE AND ENGLISH.

III. FUTURE ACTIONS'A. ERGS'TO COMPLETE E ST AND WEST SIDE STAGING AREAS WHICH WILL

BE USED FOR DEBRIS STORAGE IN SUPPORT OF DEMOLITION ANDDISMANTLEMENT OPERATIONS; ERGS TO CONTINUE DEMOLITION .OPERATIONS AS DIRECTED BY OSC. ' . .

B. ERCS TO COMPLETE CLEANING, PLUGGING AND REBUILDING MANHOLESIN ORDER TO PREVENT THE UNCONTROLLED RELEASE OF STORM WATER

• ' RUNOFF FROM THE WEST SITE STAGING~AREA. ADDITIONAL W6RK ONTHESE MANHOLES RESULTED FROM THE VENTILATION STACK DEMOLITION.C. OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.D. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THE

OSC; RESULTS TQ BE POSTED FOR PUBLIC INSPECTION.E. SATA TO INVESTIGATE AND PREPARE INFORMATION ABOUT TANK

LOCATIONS AND CONTENTS IN SECTION III OF THE FACILITY (VISCOSECELLAR 6B) FOR PROPER REMOVAL AND STORAGE OF THE CHEMICALSDURING DEMOLITION OPERATIONS.

F. SATA TO .EDIT VIDEO TAPE ABOUT THE AVTEX SITE.G. SATA AND ERCS ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS.REGARDING ENGINEERING ASPECTS OF.THE DEMOLITIONOPERATIONS. , •-,. - ,H. OSC EXPECTING REPORT OF FISH AND WILDLIFE STUDY IN THEUPCOMING WEEKS. .


ARIOU823

TO: MICHAEL TOWLE / GEORGE ENGLISH ' .y\ rvTO: GROUP RRC v .V* \)TO: GROUP REGION03-TAT

SUBJECT:-AVTEX SITE - POLREP 828POLREP #828"AVTEX FIBERS FRONT ROYAL404 KENDRICK LANEFRONT ROYAL, WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTION .ATTN: CHARLIE KLEEMAN and RRC

CC: WAYNE WALTERS (3RC21) .CC: BONNIE GROSS (3HW23)

I. ", SITUATION {AS OF 1730 HOURS, WEDNESDAY,, DECEMBER 3, 1997)A. OSCs TOWLE, ENGLISH AND FAS MCDONALD ONSITE.B. USACOE ON SITE TO VIEW DEMOLITION PROCEDURE AND ASSIST WITH

PREPARATION OF MATERIALS FOR FUTURE LANDFILL OPERATIONS.C. SITE REMOVAL ACTIONS CONTINUE. - ~ .

1 D. AIR SAMPLING RESULTS FOR METALS COLLECTED ON THE 13TH, 15TH,17TH,-18TH,.AND 19TH OF NOVEMBER INDICATED CHROMIUM WAS PRESENTRANGING FROM 0.025 UG/M3 TO 0.055 UG/M3, ALL WHICH ARE ABOVE THESTATED BACKGROUND OF 0.0243 UG/M3 AND THE REMOVAL ACTION LEVEL -OF 0.021 UG/M3. ON THE 13TH THE MONITORS WHICH SHOWED RESULTS

, WERE UPWIND OF SITE ACTIVITIES WHICH WOULD SUGGEST THAT THELEVELS FOUND WERE NOT A RESULT OF SITE OPERATIONS. ON THE 15THAND 17TH THE MONITORS THAT RECORDED LEVELS OF CHROMIUM WEREDOWNWIND OF SITE ACTIVITIES. ON THE 18TH ALL MONITORSREGARDLESS OF THERE LOCATION WITH RESPECT TO WIND DIRECTION ANDSITE ACTIVITIES REPORTED LEVELS OF CHROMIUM. ON THE 19TH WINDSWERE VARIABLE AND ONLY TWO OF THE FOUR MONITORS INDICATEDCHROMIUM. IT SHOULD BE NOTED THAT THE BACKGROUND SAMPLE FORCHROMIUM WAS TAKEN ON CONSECUTIVE DAYS .PRIOR TO THE START OFDEMOLITION. THIS WOULD SUGGEST THAT THERE IS CHROMIUM PRESENTREGARDLESS OF SITE OPERATIONS. ON THE 2ND AND 3RD OF DECEMBER,LEVELS ABOVE BACKGROUND FOR ASBESTOS, WHICH IS 0, WAS DETECTEDAT .001 CC. ON THE 2ND THE MONITORS WHICH SHOWED LEVELS WEREDOWN WIND OF THE SITE. ON THE 3RD THE MONITOR WHICH DETECTEDASBESTOS WAS UPWIND OF SITE OPERATIONS,. THESE CONDITIONSSUGGEST THAT NON-DEMOLITION RELATED CONDITIONS MAY RESULT INELEVATED READINGS,AT DUST MONITORING STATIONS. WORK WAS SLOWEDAND WATER INCREASED TO FURTHER MINIMIZE DUST ON SITE.

E, 24-HOUR SECURITY CONTINUES.E*. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE).G. PERSONNEL ON SITE: EPA-3, ERCS-26, SATA-2H. REMOVAL COSTS TO DATE (COB 11/19/97): ,

ESTIMATED CEILINGEPA DIRECT COSTS : 475,202 519,161EPA INDIRECT COSTS 816,373 980,824TAT (E4E) (11/27/93) 1,070,650 1,607,000 'SATA (WESTON) . 566,264 1,107,052ERCS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064r (10/8/93) 30,984 33>000ERCS (ETI-088) NO/AVAILABLE 15,254,753USCG (10/1/91) 197,515 197,515UNALLOCATED REMOVAL 29,326,854

TOTAL REMOVAL COSTS 56,711,159

ft. REMEDIAL COSTS TO DATE (COB 6/5/96): 'TOTAL REMEDIAL COSTS 9,565,624 10,260,960

TOTAL PROJECT COSTS -

TOTAL PROJECT CEILING, , ;0v£6,972,119 .ERCS IS AT OF CEILINGSATA IS AT 51.15% OF CEILING ,- .

I. TEN PERCENT STATE .SHARE 914,837

J. ENFORCEMENT (106) COSTS (2/2/92-8/12/93) ;

TOTAL ENFORCEMENT, COSTS 183 263 183,263 '

II. ACTIONS TAKEN: '••.'. , ^ .

A. ERCS, MAINTAINED INTEGRITY OF SPILL CONTAINMENT MANHOLES INORDER TO PREVENT THE UNCONTROLLED RELEASE OF WATER RUNOFF FROM•THE FACILITY. ADDITIONAL WORK ON THESE MANHOLES RESULTED FROMTHE VENTILATION STACK DEMOLITION. ERCS AND SATA ENGINEERCOMPLETED LOCATING THE MANHOLES WHICH DRAIN SECTION III AND

' ENSURING THAT THEY ARE PLUGGED'UP SO AS NOT TO ALLOW DRAINAGEFROM THE AREA TO MIGRATE OFFSITE. , . ' ,

B. ERCS CONTINUE DEMOLITION OF THE NORTHWEST PART OF SECTION III.' 15% OF THE SECTION III IS .DEMOLISHED UP TO DATE. PERSONNELCONTINUE TO SEGREGATE CONTAMINATED MATERIALS FROM CLEANEDDEBRIS FOR PROPER STAGING AND DISPOSAL. .WATER IS USED TOCONTROL DUST. - -

C. ERCS .REMOVED FIRST TRANSFORMER FROM THE ROOF OF SECTION III ANDMOVED IT INTO THE TRANSFORMERS STORAGE BUILDING.

D. DURING REMOVAL OPERATIONS OF VENTILATION DUCT LOCATED ON TOP OFBUILDING AT SECTION III, A SAW CAUSED A FLASH FIRE WHEN IT GAVE

'. OFF SPARKS AND CAME INTO CONTACT WITH THE DUST INSIDE THE DUCT' AS A RESULT SULFIDES WERE RELEASED INTO THE AIR AS DETECTED BY

MONITOR INSIDE THE DUCT. SATA AIR MONITORED PERIMETER FORSULFIDES. NO DETECTION WAS FOUND. ACTION INDICATES THAT DUST

, MAY.BE IGNITABLE/REACTIVE IN ADDITION TO HAVING CHARACTERISTICSOF TOXICITY (CHROMIUM)., - - - •

E. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR,POTENTIALRELEASES OF SITE CONTAMINANTS DURING DEMOLITION; TO DATE,LEVELS ABOVE BACKGROUND FOR CHROMIUM, NICKEL, ZINC AND ASBESTOSHAVE BEEN DETECTED. THE RESULTS DO NOT NECESSARILY POINT TODEMOLITION AS A SOURCE OF INCREASED LEVELS SINCE UPWINDMONITORS WERE ALSO IMPACTED.,

F. TRENCHES WERE FOUND UNDERNEATH THE NORTH-WEST SECTION OF SECTIONIII. SATA SAMPLED THE WATER IN THE TRENCHES TO BE ANALYZED FORACCEPTABLE WATER TREATMENT STANDARDS TO DETERMINE IF THE WATERIS SUITABLE TO DISCHARGE WATER INTO THE WATER TREATMENT PLANT.

G. FISH AND WIL0LIFE INFORMATION RECEIVED BY EPA-RPM. RESULTS DONOT AFFECT REMOVAL OPERATIONS. • '

H. SODA TANK FOUNDATION AREA WAS COMPLETED. AREA IS BACKFILLEDWITH CLEANED INERT RUBBLE (BRICK FROM STACK AND CONCRETE FROMSODA FOUNDATIONS). SOIL HAS HIGH PH AND ACCUMULATED WATER FROMRAINS RESULT IN CAUSTIC PUDDLES. A SUMP WAS CONSTRUCTED TODETERMINE IF COLLECTION OF CAUSTIC FROM FORMER SPILLS ISFEASIBLE.

I. SLUDGE ACCUMULATION FROM SPRAY POND (RESULTING FROM TREATMENT< OF CAUSTIC WATER WITH SULPHURIC ACID) REMOVED AND STAGED.

III. FUTURE ACTIONS .

'• A. OSC TO CONTINUE TO PLAN AND SCHEDULE, REMOVAL-OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.

B. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC/ RESULTS TO BE POSTED FOR PUBLIC INSPECTION.

C. SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE. ,D. SATA TO SAMPLE VENTILATION TUNNELS FROM FANHOUSE TO BOX SHOPS

TO DETERMINE DEMOLITION PROCEDURE IN THIS AREA.SATA TO INVESTIGATE AND PREPARE INFORMATION ABOUT TANKLOCATIONS AND CONTENTS IN SECTION III OF THE FACILITY (VISCOSE , 'CELLAR 6B) FOR PROPER REMOVAL AND STORAGE OF THE CHEMICALS \ JDURING DEMOLITION OPERATIONS. . ' x*—SSATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONSREGARDING ENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS.


AR

TO: MICHAEL TOWLE / GEORGE ENGLISHTO: GROUP RRC - •TO: GROUP REGION03-TAT ' t

\SUBJECT!.AVTEX SITE - POLREP 829 - J>POLREP #829 , , of y* wxAVTEX FIBERS FRONT ROYAL \) ^40:4 KENDRICK LANEFRONT ROYAL,'WARREN COUNTY, VA 22630 ,CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTION ' . < "ATTN: CHARLIE KLEEMAN and RRC . '

CC: WAYNE WALTERS (3RC21)CC; BONNIE GROSS (3HW23)

I. SITUATION (AS OF 1730 HOURS, WEDNESDAY, DECEMBER 10, 1997)A. OSC ENGLISH ONSITE. , :B. SITE REMOVAL ACTIONS CONTINUE. ,

, C. AIR SAMPLING RESULTS FOR METALS COLLECTED ON THE'20TH, 21ST,22ND, AND 23RD OF NOVEMBER INDICATED CHROMIUM WAS PRESENTRANGING FROM 0.026 UG/M3 TO 0.052 UG/M3, ALL OF WHICH ARE ABOVETHE STATED BACKGROUND OF 0.0243 UG/M3 AND THE REMOVAL ACTIONLEVEL OF 0.021 UG/M3. IT SHOULD BE NOTED THAT THE BACKGROUNDSAMPLE FOR CHROMIUM WAS TAKEN ON CONSECUTIVE DAYS PRIOR TO THESTART OF -DEMOLITION. THIS WOULD SUGGEST THAT THERE IS CHROMIUMPRESENT .REGARDLESS OF SITE OPERATIONS. IN THE SAME PERIOD OFTIME, SAMPLING RESULTS SHOWED,ZINC WAS PRESENT RANGING FROM8.32 UG/M2 TO 34.5 UG/M2 WHICH IS ABOVE BACKGROUND 0.00 UG/M2.ON THE.20TH, 22ND ~AND 23RD OF NOVEMBER AIR SAMPLING RESULTSINDICATED THE PRESENCE OF COPPER RANGING FROM 0.152 UG/M2 TO0.342 UG/M2, ALL OF WHICH ARE ABOVE STATED BACKGROUND OF 0.141UG/M2. SAMPLING RESULTS COLLECTED ON 20TH OF NOVEMBERINDICATED SILVER PRESENT AT 0.019 UG/M2. THE MONITORS THATRECORDED LEVELS OF SILVER ON 20 NOVEMBER AND LEVELS OFCOPPER ON THE SAME DAY WERE DOWNWIND OF SITE ACTIVITIES.

' D. 24-HOUR SECURITY CONTINUES.E. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE).F. PERSONNEL ON SITE: EPA-1, ERCS-28, SATA-2 'G. REMOVAL COSTS TO DATE (COB 11/19/97): . * •

V ESTIMATED CEILING .EPA DIRECT COSTS 479,631 519,161-EPA INDIRECT COSTS 823,765 980,824'TAT (E&E) (11/27/93) 1,070,650 1,607,000SATA .(WESTON) . 573,587 1,107,052 .ERCS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000ERCS (ETI-088,) NOT AVAILABLE 15,254,753USCG (10/1/91) 197,515 .197,515UNALLOCATED REMOVAL ' •' 29,326,854 ;

; TOTAL REMOVAL COSTS 56,711,159

H.( REMEDIAL COSTS TO DATE (COB 6/5/96) :TOTAL REMEDIAL COSTS 9,565,624 10,260,960

TOTAL PROJECT COSTS ,TOTAL PROJECT CEILING 66,972,119ERCS IS AT ' OF CEILINGSATA IS AT 51.15% OF CEILING

I. TEN PERCENT STATE SHARE . 914,837



ARI 01*827

II. ACTIONS TAKEN!

A. ERCS MAINTAINED INTEGRITY OF SPILL CONTAINMENT MANHOLES INORDER TO PREVENT THE UNCONTROLLED RELEASE OF WATER RUNOFF FROM, -THE FACILITY. ADDITIONAL WORK ON THESE MANHOLES RESULTED FROMTHE VENTILATION STACK DEMOLITION. -

B. 21% OF THE SECTION III IS DEMOLISHED UP TO DATE. ERCS CONTINUEDEMOLITION OF THE STACK FOUNDATION. 95% OF THE STACK ,FOUNDATION IS DEMOLISHED TO DATE.PERSONNEL CONTINUE TO SEGREGATE CONTAMINATED MATERIALS FROMCLEANED DEBRIS FOR PROPER STAGING AND DISPOSAL. WATER IS USEDTO CONTROL DUST. ,-, '

C. SATA SAMPLED VENTILATION TUNNELS FROM1 FANHOUSE TO BOX SHOPS ANDCAKE CAB ROOMS TO DETERMINE DEMOLITION PROCEDURE IN THIS AREA. .

D. ERCS WAS INFORMED BY FORMER AVTEX CHIEF OF ENGINEERS ABOUTLOCATION AND LENGTH OF TRENCHES FOUND UNDERNEATH THE NORTH- .WEST SECTION OF SECTION III. THIS INFORMATION WILL SIMPLIFYDEMOLITION ACTIONS OF THE WEST PART OF SECTION III.

. E. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIALRELEASES OF SITE CONTAMINANTS DURING DEMOLITION. , , . -

, F. FISH AND WILDLIFE INFORMATION RECEIVED BY EPA-RPM. RESULTS DONOT AFFECT REMOVAL OPERATIONS.

III. FUTURE ACTIONS

A. OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.

B. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION.

C. SATA TO BEGIN AIR MONITORING IN DEMOLITION ZONE TO OBSERVEEFFECTIVENESS OF THE DUST CONTROL METHODS IN THE HOT ZONE.

D. SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE. . . ,E. SATA TO INVESTIGATE AND PREPARE INFORMATION* ABOUT TANK . ' '

LOCATIONS AND CONTENTS IN SECTION III.OF THE-FACILITY (VISCOSE ' i JCELLAR 6B) FOR PROPER REMOVAL AND STORAGE OF THE CHEMICALS , , \**/DURING DEMOLITION OPERATIONS. . . - ' " -

F. SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDING ,ENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS.. . . -


ARI 014323

TO: MICHAEL TOWLE / GEORGE ENGLISH ' ' 'TO: GROUP RRC , : ' . . • .,. ,< ,TO: GROUP REGION03-TAT ' ; '. - '

. . " • • • . . i • ' • '

SUBJECT: AVTEX SITE - POLREP 830 : ' ,' ,;VPOLREP #830 - - , ' • ' • • ' * - " -AVTEX FIBERS FRONT ROYAL ' , , , •'. \404 KENDRICK LANE ^ • , ,FRONT ROYAL, WARREN COUNTY, VA 22630 .CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTN: CHARLIE KLEEMAN and RRC ...

CCi WAYNE WALTERS (3RC21), CC: BONNIE GROSS (3HW23) ,

I. SITUATION (AS OF 1730 HOURS, WEDNESDAY, DECEMBER 17, 1997)A. OSC ENGLISH, TOWLB, KELLY AND FAS MCDONALD ONSITE.B. SITE REMOVAL ACTIONS-CONTINUE.C. AIR SAMPLING RESULTS FOR METALS COLLECTED ON NOVEMBER .24, 25

. AND DECEMBER 1 AND 3,: INDICATED CHROMIUM WAS PRESENTRANGING FROM 0.0248,UG/M3 TO 0,0374 UG/M3, ALL OF WHICH AREABOVE THE STATED BACKGROUND OF 0.0243 UG/M3' IN THE SAME PERIODOF TIME, SAMPLING RESULTS SHOWED ZINC WAS PRESENT RANGING FROM7.49 UG/M^ TO 34.2 UG/M3,WHICH IS ABOVE BACKGROUND 0.00 UG/M3. ONTHE 24TH, 25TH OF NOVEMBER AND 1, 2,3, 4 DECEMBER AIR SAMPLINGRESULTS INDICATED THE PRESENCE OF COPPER RANGING FROM 0.130 .

: UG/M3 TO 0.262 UG/M3' SAMPLE RESULTS ABOVE 0.141 UG/M3 ARE ABOVE- THE STATED BACKGROUND LEVEL FOR COPPER. SAMPLING RESULTS

COLLECTED ON 24TH AND 25TH OF NOVEMBER INDICATED NICKEL PRESENTAT 0.0362 UG/M3 TO 0.0423 UG/M3, BOTH OF WHICH ARE ABOVEDETERMINED BACKGROUND LEVELS OF 0; 032 UG/M3. 7HE SAMPLES TAKENON 3 AND 5 DECEMBER SHOWED LEAD RESULTS ABOVE THE 0.0928 UG/M3

' BACKGROUND WITH READINGS OF 0.0957 UG/M3 TO 0.216 UG/M3..ANTIMONY WAS PRESENT IN THE SAMPLES TAKEN ON 1 DECEMBER WITHREADINGS OF 0.0110 UG/M3 WIflCH IS ABOVE BACKGROUND OF 0.00

i i ' UG/M3. ON 4, 5 AND 6 OF DECEMBER, BERYLLIUM WAS PRESENT IN\_/ SAMPLES RANGING FROM 0.0021 UG/M3 TO 0.00430 UG/M3 WHICH IS,

, ABOVE BACKGROUND LEVELS OF 0.00 UG/M3. IT SHOULD BE NOTED THATSTATIONS WHICH WERE UPWIND OF SITE OPERATIONS WERE AMONG THESTATIONS WHICH RECEIVED HITS. THIS TAKEN INTO ACCOUNT.ONECOULD CONCLUDE THAT THESE HITS MAY NOT BE ATTRIBUTABLE TO SITE

, OPERATIONS AND ARE PRESENT REGARDLESS OF DEMOLITION. EPA OSCTAKING STE.PS TO RE-EVALUATE BACKGROUND DETERMINATIONS AND HAS,INCREASED WATER SPRAY REQUIREMENTS.

D. 24-HOUR SECURITY CONTINUES.. E. .ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

' ORDER (AO) TO AVC AND AVTEX (TRUSTEE).F. PERSONNEL ON SITE: EPA-1, ERCS-28, SATA-3G. REMOVAL COSTS TO DATE (COB,12/17/97):

' . < . . ' . , ESTIMATED CEILINGEPA DIRECT COSTS , 484,078 519,161EPA INDIRECT COSTS '831,636 980,824TAT (EiE) , (11/27/93) 1,070,650 1,607,000SATA (WESTON) 599,878 1,107,052ERGS (OHM) (4/7/92) 7,494,499 7,685,000ERGS (ETI-064) (10/8/93) . 30,984 -33,000ERCS (ETI-088) 8,289,546 15,254,753USCG (10/1/9,1) 197,515 197,515UNALLOCATED REMOVAL 29,326,854

TOTAL REMOVAL COSTS 18,998,786 56,711,159i. • '

H» REMEDIAL COSTS TO DATE (COB ,6/5/96):, TOTAL REMEDIAL COSTS ; 9,565,624, 10,260,960 s , .

TOTAL PROJECT COSTS 28,564,410TOTAL PROJECT CEILING 66,972,119

AR 101*8 2 9

ERGS IS AT 54.34% OF CEILINGSATA IS AT 54.18% OF CEILING r

I. TEN PERCENT STATE SHARE . 914,837: . -

J. ENFORCEMENT (106) COSTS (2/2/92 8/12/93)


II. ACTIONS TAKEN:

A. 30 % OF THE SECTION III IS DEMOLISHED UP TO DATE. ERCSCOMPLETED DEMOLITION OF THE STACK FOUNDATION. STAPLE AREA ISDEMOLISHED FROM NORTH CORRIDOR TO DUCTWORK ON THE ROOF. '

B. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIALRELEASES OF SITE CONTAMINANTS DURING DEMOLITION.

C. LEAD AND ASBESTOS CONTAMINATED DEBRIS (LIGHT STEEL, ROOF ,, DEBRIS, ETC.) IS DECONTAMINATED BY HIGH PRESSURE WASHING IN THE

DEMOLITION AREA. CLEANED DEBRIS IS REMOVED TO THE SCRAP AREAIN WEST" STAGING. RESIDUE FROM THE CLEANING PROCESS ISCONSIDERED CONTAMINATED BY LEAD AND ASBESTOS AND IS STAGED INTHE ACM AREA. , ,

D. RESULTS OF WATER SAMPLE COLLECTED FROM OLD FAN HOUSE TUNNELSINDICATES ELEVATED LEAD CONCENTRATIONS. THIS WATER WAS PUMPEDAND USED TO DECONTAMINATE THE DEBRIS FROM-THE NORTH END OFSTAPLE LINES. RINSE WATER IS COLLECTED FOR FUTURE DISPOSITIONOR RE-USE IN THE SPILL CONTAINMENT AREA. >

E. 40,000 GALLONS OF HYDRAULIC OIL AND OILY WATER WAS REMOVED FROMLARGE RESERVOIRS, PIPE AND VALVE AREAS IN, THE NORTHEAST CORNEROF SECTION III. OILY LIQUIDS WERE PUMPED INTO BAKER TANKS FORFUTURE DISPOSITION.

F. ERCS INITIATED REMOVAL OF TANKS FROM CAKE WASH AREA OF SECTIONIII. TANKS WERE DEEMED TO BE CLEAN.

G. SALVAGE OPERATORS CONTINUE ON BEHALF OF THE TRUSTEE.H. ERCS CONSOLIDATED MATERIALS IN THE BONEYARD TO MAKE MORE ROOM

FOR FUTURE OPERATIONS IN THIS AREA.

III. FUTURE ACTIONS . ^

A. OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIE3 WITH FEDERAL, STATE, AND LOCAL OFFICIALS.

, B. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION*

C. SATA TO CONDUCT AIR MONITORING IN DEMOLITION ZONE TO OBSERVEEFFECTIVENESS OF THE DUST CONTROL METHODS IN THE HOT ZONE.

D. SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE.E. SATA TO INVESTIGATE AND PREPARE INFORMATION ABOUT TANK

LOCATIONS AND CONTENTS IN SECTION III OF THE FACILITY (VISCOSECELLAR 6B) FOR PROPER REMOVAL AND STORAGE OF THE CHEMICALSDURING DEMOLITION OPERATIONS.

F. SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDINGENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS.

G. EVALUATE POSSIBLE CONTAMINATION OF BUILDING AREAS NORTH OF THENORTH CORRIDOR. •

H. EVALUATE DEMOLITION METHOD FOR VENTILATION DUCT WORK AND #3ACID HEAT AREA. . :

MIKE TOWLE, OSC .U.S. EPA REGION III ,PHILADELPHIA, PA

ARI Qt4830

TO: MICHAEL TOWLE / GEORGE ENGLISHTO: GROUP RRC ? ;V.,, .;•;-*.-,'TO: GROUP REGION03-TAT . ' '"''•"' ".'••'.SUBJECT: AVTEX SITE - POLREP 831POLREP #831 . = - , ' .AVTEX FIBERS FRONT ROYAL T404 KENDRICK LANEFRONT ROYAL, WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTNi CHARLIE KLEEMAN and KRC

, CC: WAYNE WALTERS (3RC21),CC: BONNIE GROSS (3HW23)

I. SITUATION (AS OF 1730 HOURS, MONDAY, DECEMBER 22, 1997)A. OSC ENGLISH ONSITE. , ^ - ,B. SITE REMOVAL ACTIONS^CONTINUE. .C. AIR SAMPLING RESULTS AT THE AIR STATIONS LOCATED DOWNWIND OF

SITE:RESULTS' FOR METALS AND PCBs SAMPLES COLLECTED ON 8, 11, 12, 13AND 14 DECEMBER: • ' . ' , • " -

ANALYTE

ARSENICANTIMONYBERYLLIUMCADMIUMCHROMIUMCOPPERLEADMERCURYNICKELSELENIUMSILVERTHALLIUM ~-ZINCPCBs

BACKGROUNDCONCENTRATION

NO DETECTION• NO DETECTION

, NO DETECTIONNO DETECTION

0-0.0243 UG/MJ0-0.141 UG/M"0-0.0928 UG/M-0-0.0036 UG/M"0-0..032 UG/MJ

NO DETECTIONNO DETECTIONNO DETECTIONNO DETECTIONNO DETECTION

RESULTS -RANGEOF

CONCENTRATION..0121UG/MJBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUND

D. 24-HOUR SECURITY CONTINUES.E. ENFORCEMENT ACTIVITIES-CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO,AVC AND AVTEX (TRUSTEE).F. PERSONNEL ON SITE: EPA-1, ERCS-30, SATA-2G. REMOVAL COSTS TO DATE (COB 12/17/97):

- .. ESTIMATED, CEILINGEPA DIRECT COSTS • 487,971 519,161EPA INDIRECT COSTS 837,557 980,824TAT (EfiE) (11/27/93) 1,070,650 1,607,000SATA (WESTON) 587,783 1,107,052ERGS (OHM) (4/7/92) 7,494,499 7,685,000

, ERGS (ETI-064) (10/8/93) 30,984 33,000ERGS (ETI-088) 8,441,279 15,254,753.USCG (10/1/91) 197,515 197,515UNALLOCATED REMOVAL ' 29,326,854

TOTAL REMOVAL COSTS ; 19/148,238 56,711,159

H. REMEDIAL COSTS'fO DATE (COB 6/5/96):TOTAL REMEDIAL COSTS 9,565,624 ,10,260,960

TOTAL PROJECT COSTS 28,713,862 'TOTAL PROJECT CEILING 66,972,119ERGS IS AT 55.33% OF CEILINGSATA IS AT 53.00% OF CEILING

A R I D 1483!

I, TEN PERCENT STATE SHARE c , > 914,637

. J. ENFORCEMENT (106) COSTS (2/2/92-8/12/93) ,

TOTAL ENFORCEMENT COSTS, 183,263 183,263

11. ACTIONS TAKEN: . ,

A. 32 % OF THE SECTION III IS DEMOLISHED TO DATE. STAPLE AREAIS DEMOLISHED FROM NORTH CORRIDOR TO DUCTWORK ON THE ROOF, ANDPARTLY TO THE NORTH WALL OF VISCOSE CELLAR 6B.

B.. EVALUATION OF DEMOLITION METHOD FOR VENTILATION DUCT WORK AND#3 ACID HEAT AREA WAS PERFORMED. ERCS REMOVED VENTILATION DUCTAND THE THIRTEEN TANKS LOCATED IN ACID HEAT #3 ON THE ROOF OFBUILDING OF SECTION III. THE TANKS WERE MOVED TO STAGING AREA.

. ERCS BEGIN #3 ACID HEAT SUPERSTRUCTURE DEMOLITION. 90% OF THE :STRUCTURE WAS DEMOLISHED TO DATE.

C. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIALRELEASES OF SITE CONTAMINANTS DURING DEMOLITION." .

D. SATA STARTED AIR MONITORING IN DEMOLITION ZONE. HIGHER THANBACKGROUND CONCENTRATION OF 1.27 MG/M3 WAS DETECTED, BUT DURINGMINIMAL RANGE OF TIME (1-2 MIN). THEREFORE, DUST CONTROLPROVED TO BE EFFECTIVE.IN THE DEMOLITION ZONE.

E. SATA FINISHED INVESTIGATION OF BUILDINGS LOCATED NORTH OF THENORTH CORRIDOR FOR FUTURE SAMPLING .

F. LEAD AND'ASBESTOS CONTAMINATED DEBRIS (LIGHT STEEL, ROOFDEBRIS, ETC.) 'IS CONTINUOUSLY DECONTAMINATED BY HIGH PRESSUREWASHING IN THE DEMOLITION AREA. CLEANED DEBRIS IS REMOVED TO.THE SCRAP AREA IN WEST STAGING. RESIDUE FROM THE CLEANING

" .PROCESS IS CONSIDERED CONTAMINATED BY LEAD AND ASBESTOS AND ISSTAGED IN THE ACM AREA. , ,

G. ERCS CONTINUE CAKE WASH STRUCTURE DEMOLITION. APPROXIMATELY60% OF THIS SECTION IS DEMOLISHED TO DATE.

H. SATA SAMPLED SOIL UNDERNEATH SLAB LOCATED AT CAKE WASH PIT AREATO DETERMINE POTENTIAL CONTAMINATION THROUGHOUT CONCRETE FLOOR.

I. SALVAGE OPERATORS CONTINUE ON BEHALF OF THE TRUSTEE. . -J. ERCS CONSOLIDATED MATERIALS IN THE STAGING AREA TO MAKE.MORE

ROOM FOR FUTURE DEMOLITION IN SECTION III OF FACILITY.

III. FUTURE ACTIONS

A. OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL; STATE, AND LOCAL OFFICIALS.

B. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION.

C. SATA TO CONTINUE AIR MONITORING IN DEMOLITION ZONE TO OBSERVEEFFECTIVENESS OF THE DUST CONTROL METHODS IN THE HOT ZONE.

D, SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE., E. SATA TO INVESTIGATE AND PREPARE INFORMATION ABOUT TANK

LOCATIONS AND CONTENTS IN SECTION III OF THE FACILITY (VlSCOSECELLAR 6B) FOR PROPER REMOVAL AND STORAGE OF THE CHEMICALSDURING DEMOLITION OPERATIONS.

F. SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDINGENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS,

G. EVALUATE POSSIBLE CONTAMINATION OF BUILDING AREAS NORTH OF THENORTH CORRIDOR. .

MIKE TOWLE, OSC ' ' * .U.S. EPA REGION IIIPHILADELPHIA, PA , '

ARI 01*832

TO: MICHAEL TOWLE / GEORGE ENGLISHT O : GROUP R R C : , - ^ - H • ' . ' , •,TO: GROUP REGIQN03-TAT ,...". ' /

SUBJECT: AVTEX.SITE - POLREP 832 -POLREP #832 . 'AVTEX .FIBERS FRONT ROYAL ' ,.* -404 KENDRICK LANE , S , •FRONT ROYAL, WARREN COUNTY, VA 22630 -fryCERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTION '• . 'ATTN: CHARLIE KLEEMAN and RRC "'' . • ' ;

CC: WAYNE WALTERS (3RC21)CC: BONNIE GROSS ,(3HW23) ,

I. SITUATION (AS OF 1730 HOURS, WEDNESDAY, JANUARY 7, 1998)A. OSC ENGLISH ONSITE*B. SITE REMOVAL ACTIONS CONTINUE. 'C. AIR SAMPLING RESULTS AT THE AIR STATIONS LOCATED DOWNWIND OF

SITE: ,RESULTS FOR METALS AND PCSB SAMPLES COLLECTED ON 15 TO 21 DECEMBER:

ANALYTE

ARSENICANTIMONYBERYLLIUMCADMIUMCHROMIUMCOPPERLEADMERCURYNICKELSELENIUMSILVERTHALLIUMZINCPCBs


NO DETECTIONNO DETECTIONNO DETECTIONNO DETECTION

0-0.0243 UG/M00-0.141 UG/M"0-0.0928 UG/tf0-0.0036 UG/M^0-0.032 UG/MJ

NO DETECTION .NO DETECTIONNO DETECTIONNO DETECTIONNO DETECTION

, RESULTS-RANGEOF

CONCENTRATION.BACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUND

0.1730.132

BACKGROUND0.066

BACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUND

RESULTS .FOR ASBESTOS SAMPLES COLLECTED FROM 15 TO 21 DECEMBER:

DATEASBESTOS

12/15BCKGN

. D ,

12/160.001

• (1) '0.001(2)

0,002(3)

12/170.001U)

0.002. (4>

, '

. 12/180.001(1)

0.001<2)

0.001 '(4)

12/190.001

. (2)/

12/20SAMPLESOVERLOADEDNOT ANALYZE

/

12/210.001(1)

0.001(2)

BACKGROUND CONCENTRATION IS NON DETECT FOR ASBESTOS.NUMBERS IN PARENTHESES.INDICATE AIR SAMPLING STATION NUMBER.

'• . . • • ' . -.(' • ' . , ' - ,D. 24-HOUR SECURITY CONTINUES. • ,E. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE).F. PERSONNEL ON SITE: EPA-1, ERCS-26, SATA-3 : -

AR I 01*833

• . G. REMOVAL COSTS TO DATE (COB 1/7/97): ,

ESTIMATED CEILINGEPA DIRECT COSTS 491,480 519,161EPA INDIRECT COSTS 843,541 980,824TAT (EfiE) (11/27/93) 1,070,650 1,607,000-SATA (WESTON) 590,, 971 1,107,052ERGS' (OHM) (4/7/92) ; 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000ERGS (ETI-088) , . 8,628,475 15,254,753USCG (10/1/91) 197,515 197,515UNALLOCATED REMOVAL. - 29,326,854


H. REMEDIAL COSTS TO DATE (COB 6/5/96):TOTAL REMEDIAL COSTS : .9,565,624 10,,260,960

TOTAL PROJECT COSTS 28,921,739TOTAL PROJECT CEILING • '." 66,972,119ERCS IS AT 56.56% OF CEILINGSATA IS AT 54.1% OF CEILING


J; ENFORCEMENT (106) COSTS (2/2/92-8/12/93)


II. ACTIONS TAKEN: . , r. . . • • ' " , ' " \ / . '

A. 38 % OF THE SECTION III IS DEMOLISHED TO DATE. STAPLE AREA .IS DEMOLISHED FROM NORTH CORRIDOR TO THE NORTH WALL OF VISCOSECELLAR 6B.

B. ERCS FINISH #3 ACID HEAT SUPERSTRUCTURE DEMOLITION. REMAININGDEMOLITION OF FLOORING IS PLANNED FOR THE FUTURE DUE TO RCRAWASTES ON STRUCTURE. -

C. SATA CONTINUED PERIMETER AIR' SAMPLING TO MONITOR FOR POTENTIALRELEASES OF SITE CONTAMINANTS DURING DEMOLITION.

D. SATA CONTINUES AIR MONITORING IN DEMOLITION ZONE. A HIGHER THANBACKGROUND CONCENTRATION OF 1.27 MG/M3 TOTAL DUST WAS DETECTED,BUT DURING MINIMAL RANGE OF TIME (1-2 MIN) . THEREFORE, DUSTCONTROL PROVES,TO BE EFFECTIVE IN THE DEMOLITION ZONE.

E. LEAD AND ASBESTOS CONTAMINATED DEBRIS (LIGHT STEEL, ROOFDEBRIS, ETC.) IS CONTINUOUSLY DECONTAMINATED BY HIGH PRESSUREWASHING IN THE DEMOLITION AREA. CLEANED DEBRIS IS REMOVED TOTHE SCRAP AREA IN WEST STAGING. RESIDUE FROM THE CLEANINGPROCESS IS CONSIDERED CONTAMINATED BY LEAD AND ASBESTOS AND ISSTAGED IN THE ACM AREA. .

F. SALVAGE OPERATORS CONTINUE ON BEHALF OF THE TRUSTEE. .G. ERCS CONTINUE TO CONSOLIDATE MATERIALS IN THE STAGING AREA TO

MAKE MORE ROOM FOR FUTURE DEMOLITION IN SECTION III OF ,FACILITY.

H. ERCS REMOVED ASBESTOS COATED PIPING AND STRUCTURAL STEEL FROMTHE WEST CORRIDOR AND DEMOLISHED 100% OF WEST CORRIDORSTRUCTURES

I. ERGS DEMOLISH THE SODA DISSOLVING BUILDING AND THE GARAGEBUILDING LOCATED IN SECTION IV. V . . . .

J. OSC, ERCS AND SATA IN SECTION III TO LOCATE SENSITIVE AREAS OFUPCOMING DEMOLITION AND REVIEW PROPER AND SAFE REMOVAL OF RCRAWASTES.

K. OSC TEMPORARILY DEMOBES COSTLY CRANE AND OPERATOR DUE TO LACKOF NEED IN UPCOMING WORK. -

L. SATA INVESTIGATED AND PREPARED INFORMATION ABOUT TANK

AR 101*831*

LOCATIONS AND .CONTENTS IN SECTION III OFvTHE FACILITY (VISCOSECELLAR 6B) FOR PROPER REMOVAL AND STORAGE OF THE CHEMICALSDURING DEMOLITION OPERATIONS.

^ J III. FUTURE ACTIONS>—' • . • » • ' ' ,A. OSC TO CONTINUE TO PLAN AND SCHEDULE REMOVAL OPERATIONS AND TO

COORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.B.; SATA TQ CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THE

• OSC; RESULTS TO BE POSTER FOR PUBLIC INSPECTION.C. SATA TO CONTINUE AIR MONITORING IN DEMOLITION ZONE TO OBSERVE

EFFECTIVENESS OF THE DUST CONTROL METHODS IN THE HOT ZONE.D. SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE.E. SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDING

ENGINEERING ASPECTS OF THE DEM6LITION OPERATIONS.F. EVALUATE POSSIBLE CONTAMINATION OF BUILDING AREAS, NORTH OF THE

NORTH CORRIDOR. ,G. SATA TO INVESTIGATE AND PREPARE RECOMMENDATIONS REGARDING

DEMOLITION OF VISCOSE CELLAR 6A AND RECOMMENDATIONS TO SEALSEWAGE SYSTEM WHICH CONTROLS SECTION IV OF FACILITY.

MIKE TOWLE, OSCU.S. EPA REGION IIIPHILADELPHIA, PA ,

ARIOd835

- . . • ' • • ' ' ATO: MICHAEL TOWLE / GEORGE ENGLISH vA 'TO: GROUP RRC • \ \MTO: GROUP REGION03-TAT

SUBJECT: AVTEX SITE - POLREP 833POLREP #833 *0 . { JAVTEX FIBERS FRONT ROYAL ' V«X404 KENDRICK LANEFRONT ROYAL, WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTION'ATTN: CHARLIE KLEEMAN and RRC

CC: WAYNE WALTERS (3RC21)CC: BONNIE GROSS (3HW23), :

I. SITUATION (AS OF 1730 HOURS, WEDNESDAY, JANUARY 14, 1998) .A. OSC ENGLISH AND FAS MCDONALD ONSITE.B. SITE REMOVAL ACTIONS CONTINUE.C. AIR SAMPLING RESULTS AT THE AIR STATIONS LOCATED DOWNWIND OF

SITE:SAMPLES WERE NOT COLLECTED OVER HOLIDAY. SAMPLING BEGAN AGAINON 1/4/98. HAVE NOT YET RECEIVED METAL RESULTS.

RESULTS FOR ASBESTOS SAMPLES COLLECTED FROM 04 TO 07 JANUARY:

DATEASBESTOS

01/04BCKGND

01/05BCKGND

01/06BCKGND

01/070.001(4)

01/08RAINNO

SAMPLING

01/09RAINNO

SAMPLING

01/10NO

SAMPLING

BACKGROUND CONCENTRATION IS NON DETECT FOR ASBESTOS.NUMBERS IN PARENTHESES INDICATE AIR SAMPLING STATION NUMBER. .

D. INTERNATIONAL TECHNOLOGIES COMPANY REPRESENTATIVES ON THE SITETO TAKE OVER REMOVAL ACTION ON THE SITE FROM PRESENTCONTRACTOR.

E. 24-HOUR SECURITY CONTINUES. ' jF. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE . \J

ORDER <AO) TO AVC AND AVTEX (TRUSTEE). . ""G. PERSONNEL ON SITE: EPA-2, ERCS-29, SATA-3H. REMOVAL COSTS TO DATE (COB 1/14/97): .

ESTIMATED CEILING. -EPA DIRECT COSTS 494,500 519,161EPA INDIRECT COSTS , 848,597 980,824TAT (E&E) (11/27/93) 1,070,650 1,607,000SATA (WESTON) 608,320 1,107,052ERCS (OHM) (4/7/92) 7,494,499 7,685,000 ,ERCS (ETI-064) (10/8/93) 30,984 33,000ERCS (ETI-r088) 8,800,928 t5>254r-753-USCG (10/1/91) 197,515 197,515UNALLOCATED REMOVAL 29,326,854 - ,


I. REMEDIAL COSTS TO DATE (COB 6/5/96): ' .TOTAL REMEDIAL COSTS 9,565,624 10,260,960

TOTAL PROJECT COSTS 29,111,617TOTAL PROJECT CEILING 66,972,119ERCS IS AT 57.7 % OF CEILINGSATA IS AT 54.9% OF CEILING / :

J. TEN PERCENT STATE SHARE 914,837

K. ENFORCEMENT (106) COSTS (2/2/92-8/12/93).


ARIO(t836

II. ACTIONS TAKEN: , -

. A. 44ft OF THE SECTION III IS DEMOLISHED TO DATE. ' ,B. ERCS BEGAN DEMOLITION OF RCRA CONTAMINATED CONCRETE FLOOR OF

ACID HEAT #3 BUILDING. ERCS SEPARATED STRUCTURAL STEEL ANDPIPES FROM CONCRETE DEBRIS, PRESSURE WASH AND REMOVED IT TO THESCRAP AREA IN WEST STAGING. CONCRETE FLOOR DEBRIS IS BEINGKEPT TEMPORARILY IN THE SAME LOCATION FOR FUTURE TREATMENT. '

C. UNKNOWN UNDERGROUND EMPTY STEEL TANK WAS FOUND WEST OF GARAGELOCATION (SECTION VI) AND REMOVED TO WEST STAGING AREA.

. D. ERCS REMOVED AND SECURED RCRA WASTE FROM THE TRENCH LOCATED ATSPINNING AND CUTTING SECTION EAST OF VISCOSE.6B EAST WALL.,

E. LEAD AND ASBESTOS CONTAMINATED DEBRIS (LIGHT STEEL, ROOFDEBRIS, ETC.) IS CONTINUOUSLY DECONTAMINATED BY HIGH PRESSUREWASHING IN THE DEMOLITION AREA. CLEANED DEBRIS IS REMOVED TOTHE SCRAP AREA IN .WEST STAGING. RESIDUE FROM THE CLEANINGPROCESS IS CONSIDERED CONTAMINATED BY LEAD AND ASBESTOS AND ISSTAGED IN THE ACM-AREA., - . • '

F. SALVAGE OPERATORS CONTINUE ON BEHALF OF THE TRUSTEE.G. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIAL

RELEASES OF SITE CONTAMINANTS DURING DEMOLITION. .H. SATA CONTINUESSAIR MONITORING IN DEMOLITION ZONE. ALL

MONI.TORING INDICATES LEVELS BELOW BACKGROUND (TOTAL DUST) ..1. SATA EVALUATED POSSIBLE CONTAMINATION OF BUILDING AREAS NORTH

OF THE NORTH CORRIDOR (SECTION I AND II) AND PRESENTEDRECOMMENDATION FOR SAMPLING IN THESE LOCATIONS. '

J. OSC, ERCS AND SATA CONTINUE TO LOCATE SENSITIVE AREAS OFUPCOMING DEMOLITION IN SECTION III AND REVIEW PROPER AND SAFEREMOVAL OF RCRA WASTES. .

III. FUTURE ACTIONS

A. OSC TO CONTINUE TO PLAN AND SCHEDULE .REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.

B.. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION.

C. SATA TO CONTINUE,AIR MONITORING IN DEMOLITION ZONE TO OBSERVEEFFECTIVENESS OF THE DUST CONTROL METHODS IN THE HOT ZONE.

D. SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE.E. SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDING

ENGINEERING ASPECTS OF THE DEMOLITION 'OPERATIONS.F. SATA TO SAMPLE IN BUILDING AREAS NORTH OF THE NORTH CORRIDOR

(SECTION I AND II).G. SATA TO INVESTIGATE AND PREPARE RECOMMENDATIONS REGARDINfS

DEMOLITION OF VISCOSE CELLAR 6A AND RECOMMENDATIONS TO SEAL; SEWAGE SYSTEM WHICH CONTROLS SECTION VI OF FACILITY.

MIKE TOWLE, OSCU.S. EPA REGION III ,PHILADELPHIA, PA . .

ftR10l»837

TO: MICHAEL TOWLE / GEORGE ENGLISH /TO: GROUP RRCTO: GROUP REGION03-TAT

SUBJECT: AVTEX SITE - POLREP 834POLREP #834 .AVTEX FIBERS FRONT ROYAL404 KENDRICK LANE : 'FRONT ROYAL, WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTN: CHARLIE KLEEMAN and RRC

C C : WAYNE WALTERS (3RC21) , . . ' - • ' .CC: BONNIE GROSS (3HW23)

I. SITUATION (AS OF 1730 HOURS, WEDNESDAY, JANUARY 21, 1998)A. OSC,TOWLE, KELLY, AND FAS MCDONALD ONSITE.B. SITE REMOVAL ACTIONS CONTINUE.C. AIR SAMPLING RESULTS AT THE AIR STATIONS LOCATED'DOWNWIND OF' SITE:

RESULTS FOR METALS AND PCBs SAMPLES COLLECTED ON 4 TO 7 'JANUARY.:

ANALYTE .

ARSENICANTIMONYBERYLLIUMCADMIUM . -CHROMIUMCOPPERLEAD.MERCURYNICKELSELENIUMSILVERTHALLIUMZINCPCBs


NO DETECTIONNO DETECTIONNO DETECTIONNO DETECTION

0-0.0243 UG/MJ0-0.141 UG/tt10-0.0928 UG/M^0-0.0036 UG/^0-0.032 UG/W

NO DETECTIONNO DETECTIONNO DETECTIONNO DETECTIONNO DETECTION

RESULTS-RANGEOF

CONCENTRATION.0.0116 UG/M*BACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUND0.212 UG/M*.BACKGROUNDBACKGROUND

. BACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUND

\J

RESULTS FOR ASBESTOS SAMPLES COLLECTED FROM 12 TO 19 JANUARY:

DATEASBESTOS

01/12-14BCKGND

01/15NO

SAMPLING(SLEET)

01/16NO

SAMPLING(RAIN)

01/17BCKGND

01/18o.ooi m0.001 (2)

01/190.001 (I)0.001 (3)

BACKGROUND CONCENTRATION IS NON DETECT FOR ASBESTOS. ,NUMBERS IN PARENTHESES INDICATE AIR SAMPLING STATION NUMBER,

D. INTERNATIONAL TECHNOLOGIES COMPANY REPRESENTATIVES ON THE SITETO TAKE OVER REMOVAL ACTION ON THE SITE FROM PRESENTCONTRACTOR.

E. 24-HOUR SECURITY CONTINUES.F, ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE). ,G. PERSONNEL ON SITE: EPA-2, ERCS-29, SATA-3 .H. REMOVAL COSTS TO DATE (COB 1/21/98):

' ESTIMATED CEILINGEPA DIRECT COSTS 499,774 519,161EPA INDIRECT COSTS 857,429 980,824TAT (E&E) (11/27/93) . 1,070,650 1,607,000SATA (WESTON) 617,265 1,107,052 V j

ftR 101*838

ERCS (OHM) (4/7/92) 7,494,499 7,685,000, .ERCS (ETI-064), (10/8/93) 30,984. -^ •- 33,000

ERCS (ETI-088). 8,985,227 " 754,753ERCS (IT-006) ' '• i • . 2,000,000USCG (10/1/91) 197,515 197,515.UNALLOCATED REMOVAL ' . . ;32,826,854

TOTAL REMOVAL COSTS , 19,726,343 56,711,159

I. REMEDIAL COSTS TO DATE (COB 6/5/96):TOTAL REMEDIAL COSTS 9,565,624 10,260,960

TOTAL PROJECT COSTS . 29,291,967TOTAL PROJECT CEILING , 66,972,119ERCS IS AT 92.1 % OF CEILINGSATA IS AT 55.7 % OF CEILING ;

J. TEN PERCENT STATE SHARE , 914,037

K. ENFORCEMENT (106) COSTS (2/2/92-8/12/93)

183,263 183,263

L. APPROXIMATELY 8,000 LINEAR FEET OF ASBESTOS INSULATED PIPELINES IS LOCATED ON THE TOP OF THE ROOF OF SECTION III (ABOVE

. SOUTH CORRIDOR AND DOUBLE' DECK SPINNING). INSULATION ISSIGNIFICANTLY DETERIORATED AND LOOSE ASBESTOS IS SPREAD ON THETOP OF THE ROOF. THIS MAY EXPLAIN POSITIVE ASBESTOS SAMPLINGRESULTS OBTAIN FROM THE AIR MONITORING STATION LOCATED ON THEFACILITY PERIMETER,. - ' . . , . ' •

M. 1,140,000 GALLONS OF WATER IS COLLECTED PRESENTLY IN VISCQSECELLAR 6A. AFTER CHECKING FOR CONTAMINANTS WATER MAY EITHER BEUSED-FOR DUST CONTROL OR BE RELEASED TO WATER TREATMENTPLANT AFTER NOTIFICATION.

N. USACOE ON SITE TO ADVISE ON PREPARATION OF DEMOLITION 'MATERIALS FOR FUTURE LANDFILL.

II. ACTIONS TAKEN: ' • ' . ' ' , ' t

-A. 51% OF SECTION ,111 IS DEMOLISHED TO DATE, " . , . •• •DEMOLISHED AREA INCLUDED SPACE BETWEEN NORTH CORRIDOR AND NORTHWALLS OF THE CAKE CABS AND BETWEEN THE EAST AND WEST, CORRIDOR.

B. OSC STOPPED DEMOLITION ACTION IN SECTION III UNTIL THE MUD AND, LOOSE DEBRIS LOCATED ON .THE CONCRETE PAD IS REMOVED TO THE

, . WEST STAGING AREA. :C. ERCS FINISHED DEMOLITION OF RCRA CONTAMINATED CONCRETE FLOOR OF

ACID HEAT #3 BUILDING AND CONTINUE TO WASH DEBRIS INCOOLING TOWER CONCRETE ?IT. ! WATER USED FOR THIS PROCESS WILLBE TREATED LATER.

D. SATA ENGINEER AND ERCS INSPECTED ALL PLUGGED MANHOLES.CONTROLLING SECTION III. NO LEAKS WERE OBSERVED FROM SEWAGE

• '.PIPES. . .'•',- -'• - . - . •• ' .E. SALVAGE OPERATORS CONTINUE ON BEHALF OF THE TRUSTEE.F. SATA ENGINEER PREPARED AND PRESENTED RECOMMENDATION REGARDING

DEMOLITION OF VISCOSE CELLAR 6A LOCATED 25 FEET BELOW GROUNDLEVEL.. OSC AGREES THAT DEMOLITION SURFACE WILL PROCEED TOLOWER GRADE FROM CAKE CAB TO VISCOSE 6A.

G, SATA CONTINUED PERIMETER AIR. SAMPLING TO MONITOR FOR POTENTIALRELEASES OF SITE CONTAMINANTS DURING DEMOLITION,

H..SATA CONTINUES AIR MONITORING IN DEMOLITION ZONE. ALLMONITORING INDICATES LEVELS BELOW BACKGROUND (TOTAL DUST).

I. .OSC, ERCS AND SATA CONTINUE TO LOCATE SENSITIVE AREAS OFUPCOMING DEMOLITION IN SECTION III AND REVIEW PROPER AND SAFEREMOVAL OF RCRA WASTES.

J. 250 GALLONS OF BRINE WERE DRAIN FROM VISCOSE 6B'AFTER THE NORTH

ARW'839

WALL WAS DEMOLISHED. , . .K; DEMOLITION HAS PROGRESSED INTO AREAS OF SECTION III

CONTAMINATED BY RCRA WASTE. THE DEBRIS IS STAGE6 WITHIN THEDEMOLITION AREA. HEAVY STEEL IS WASHED AND REMOVED TO THESTAGING AREA. . . j

• . - . ' - - . ' . ' , - « ^

III. FUTURE ACTIONS • " ',' ' . '


B. ERGS TO PREPARE REMOVAL ACTION PLAN OF ASBESTOS LOCATED- ABOVESOUTH CORRIDOR OF SECTION III.

C. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION. ,

D. SATA TO CONTINUE AIR MONITORING IN DEMOLITION ZONE TO OBSERVEEFFECTIVENESS OF THE DUST CONTROL METHODS.IN THE HOT ZONE.

E. SATA TO EDIT VIDEO TAPE ABOUT THE AVTEX SITE., F. SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDING

, : ' ENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS.G. SATA TO SAMPLE IN BUILDING AREAS NORTH OF THE NORTH CORRIDOR

(SECTION I AND II) AND LIQUID LOCATED IN VISCOSE 6A.H. SATA TO INVESTIGATE AND PREPARE RECOMMENDATIONS-REGARDING

PLUGGING OF SEWAGE SYSTEM WHICH CONTROLS SECTION VI OFFACILITY. . •

I. ETR TO MEET OSC AND SATA TO OBSERVE ONGOING AIR MONITORING.

MIKE TOWLE, .OSC,U.S. EPA REGIONMIIPHILADELPHIA, PA

&RIOWO

TO: MICHAEL TOWLE / GEORGE ENGLISHTO: GROUP RRC - ,TO: GROUP REGION03-TAT

f - • - ' • " • ' • - , ' , ' t[ ; SUBJECT: AVTEX SITE - POLREP 835 ' . J\ _ y ' ' ' . ' . . POLREP #835 ' , - . • - • • , . h * f

AVTEX1FIBERS FRONT ROYAL404 KENDRICK LANE •FRONT ROYAL, WARREN COUNTY, VA 22630 'CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTN: CHARLIE KLEEMAN and RRC

, CC: WAYNE WALTERS (3RC21) ' . •CC: BONNIE GROSS (3HW23)

I. SITUATION (AS OF 1730 HOURS,, WEDNESDAY, JANUARY 28,.1998)A. OSC TOWLE, ENGLISH, AND FAS MCDONALD QNSITE.B. SITE REMOVAL ACTIONS CONTINUE.

: C. AIR SAMPLING RESULTS AT THE AIR STATIONS LOCATED DOWNWIND OFSITE: • . • - ' " • • ' •• • • • . .

• RESULTS FOR METALS AND PCBs SAMPLES COLLECTED ON 11 TO 16JANUARY: , ' v ' '' \

ANALYTEi

ARSENICANTIMONY ,BERYLLIUMCADMIUMCHROMIUMCOPPERLEAPMERCURYNICKELSELENIUMSILVERTHALLIUMZINCPCBs


- NO DETECTIONNO DETECTIONNO DETECTIONNO DETECTION

0-0.0243 UG/M"0-0.141 UG/Mi0-0.0928 UG/M"0-0.0036 UG/MJ0-0.032 UG/M-1NO DETECTIONNO DETECTION ,NO DETECTIONNO DETECTIONNO DETECTION

RESULTS -RANGEOF -

CONCENTRATION.BACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUND0.144 UG/tf

, BACKGROUNDBACKGROUND

. BACKGROUNDBACKGROUND .BACKGROUNDBACKGROUNDBACKGROUND ,BACKGROUND

D.. INTERNATIONAL TECHNOLOGIES COMPANY TOOK OVER REMOVAL ACTION ONTHE SITE FROM PRESENT CONTRACTOR. ,

E.' 24-HOUR SECURITY CONTINUES. , ,F. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE).G. PERSONNEL ON SITE: EPA-3, ERCS-30, SATA-3H. REMOVAL COSTS TO DATE (COB 1/28/98):

: •, ' ' ESTIMATED CEILING,EPA DIRECT COSTS .: 504,078 519,161EPA INDIRECT COSTS 864,917 980,824TAT (EfiEJ (11/27/93) . 1,070,650 1,607,000

. SATA (WESTON) k ' 627,398 1,107,052ERGS (OHM) (4/7/92) 7,494,499 7,685,000

. ERCS (ETI-064) (10/8/93) 30,984 33,000ERGS (ETI-088) 9,133,756 9,754,753ERCS (IT--006) NO AVAILABLE 2,000,000 'USCG (10/1/91) 197,515 197,515UNALLOCATED REMOVAL " . 32,826,854


I/REMEDIAL COSTS TO DATE (COB 6/5/96):

TOTAL REMEDIAL COSTS - 9,565,624 10,260,960

TOTAL PROJECT COSTS 29,489,421 •TOTAL PROJECT CEILING . 66,972/119

A ERCS IS AT 93,6 % OF CEILING ,SATA IS 'AT 56.7 % OF CEILING ' ' , . v , .

J. TEN PERCENT STATE SHARE , ' . . 914,837

K. ENFORCEMENT (106) COSTS (2/2/92-8/12/93)


L. 1,700,000 GALLONS OF WATER IS COLLECTED PRESENTLY IN VISCOSECELLAR 6A. WATER WAS SAMPLED FOR CONTAMINANTS AND RESULTSSHOULD BE RECEIVED IN FOUR WEEKS. WATER MAY EITHER BE USED FORDUST CONTROL OR BE RELEASED TO WATER TREATMENT PLANT AFTERNOTIFICATION. ; . ."'

M. U.S.EPA/ERT ROD TURPtN ON SITE TO ADVISE ON AIR MONITORING ANDAIR SAMPLING DURING DEMOLITION ACTION. IT WAS RECOMMENDED TOINSTALL TWO MORE DATARAM INSTRUMENTS TO MONITOR DUST INDEMOLITION ZONE AND ON NUMBER 4 AIR MONITORING STATION LOCATEDON FACILITY PERIMETER. SATA WILL INSTALL WEATHER STATION TODETERMINE CORRELATION BETWEEN WIND PARAMETERS, DATARAM ANDSAMPLES ANALYSIS. . :• .

II, ACTIONS TAKEN:

'' A. 58% OF SECTION III IS DEMOLISHED TO DATE WHICH INCLUDED VISCOSECELLAR 6 B. ,DEMOLISHED AREA INCLUDED SPACE BETWEEN NORTH CORRIDOR AND NORTHWALLS OF THE CAKE CABS AND BETWEEN THE EAST AND WEST CORRIDOR.

B ERCS IS REMOVING MUD AND LOOSE DEBRIS LOCATED ON THE SECTIONIII CONCRETE.PAD TO THE WEST STAGING AREA.

C. SALVAGE OPERATORS CONTINUE ON BEHALF OF THE TRUSTEE.D. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIAL

RELEASES OF SITE CONTAMINANTS DURING DEMOLITION,E. SATA CONTINUES AIR MONITORING IN DEMOLITION ZONE. ALL . • .

. . - . . MONITORING INDICATES LEVELS BELOW BACKGROUND (TOTAL DUST).1F. OSC, ERCS AND SATA CONTINUE TO LOCATE SENSITIVE AREAS OF

UPCOMING DEMOLITION IN SECTION III AND REVIEW PROPER AND SAFEREMOVAL OF RCRA WASTES. ,

G. DEMOLITION HAS PROGRESSED INTO AREAS OF SECTION -III- CONTAMINATED BY RCRA WASTE. THE DEBRIS IS STAGED WITHIN THE •DEMOLITION AREA. HEAVY STEEL IS WASHED AND REMOVED TO THE,STAGING:AREA, v

H. SATA FINISHED SAMPLING IN BUILDING AREAS NORTH OF THE NORTHCORRIDOR (SECTION I AND II) AND IN VISCOSE 6A.

III. FUTURE ACTIONS ,


B. ERCS TO REMOVE ASBESTOS INSULATION,LOCATED ABOVE SOUTH CORRIDOROF SECTION III. THIS ACTION NEEDS TO BE COMPLETED BEFORE ACIDHEAT # 1 DEMOLITION.


D. SATA TO CONTINUE AIR MONITORING IN DEMOLITION ZONE TO OBSERVEEFFECTIVENESS OF THE DUST CONTROL METHODS IN THE HOT ZONE.

E. SATA PRESENTED TO THE OSC THREE OPTIONS OF FINAL VIDEO EDITIONOF AVTEX SITE. OSC TO DECIDE WHICH OPTION HAS TO BE FINALLYPRODUCED.

F, SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDING

rVJil. M |i II'IU •=*

ENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS.G. SATA TO INVESTIGATE AND PREPARE RECOMMENDATIONS REGARDING

PLUGGING OF.SEWAGE SYSTEM WHICH CONTROLS SECTION VI OFFACILITY. ' . : ' , • . ,


077TO: MICHAEL TOWLE / GEORGE ENGLISH ;.TO: GROUP RRC .TO: GROUP REGION03-TAT

1 • ', ' > s~ ' ~SUBJECT: AVTEX SITE - POLREP 836 . . , • \POLREP #836 - \JAVTEX FIBERS FRONT ROYAL - !404 KENDRICK LANE •FRONT ROYAL, WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTN: CHARLIE KLEEMAN and RRC .

CC: .WAYNE WALTERS (3RC21)CC: BONNIE GROSS (3HW23)

I. SITUATION (AS OF 1730 HOURS, WEDNESDAY, FEBRUARYS, 1998) 'A. OSC TOWLE, ENGLISH, AND FAS MCDONALD ONSITE.B. SITE REMOVAL ACTIONS CONTINUE. . .C. SINCE 30 JANUARY 1998 DEMOLITION ACTION IS SUSPENDED DUE " • *

TO HEAVY EQUIPMENT REPLACEMENT BY THE ERCS. ' -D. AIR SAMPLING RESULTS! (

ALL RESULTS PREVIOUSLY POSTED WERE PRELIMINARY RESULTSWHICH HAD NOT UNDERGONE QUALITY ASSURANCE/QUALITY CONTROL(QA/QC) REVIEWS BUT WERE POSTED TO ENSURE THAT THECOMMUNITY WAS AWARE OF SITE ACTIVITIES. QA/QC IS AMETHOD USED'TO VERIFY ANALYTICAL RESULT VALIDATION. IT

• IS BASED ON A REVIEW OF THE LABORATORYPROCEDURES/PARAMETERS, SUCH AS INSTRUMENTATION 'CALIBRATION, SPIKED DUPLICATE ANALYSES AND LABORATORYSTANDARDS. THE ANALYTICAL RESULTS MAY BE QUALIFIED ORDISQUALIFIED IF THE LABORATORY PROCEDURES/PARAMETERS ORINSTRUMENTATION DO NOT MEET DESIGNATED STANDARDS OR .PARAMETERS. AFTER REVIEW OF THE QA/QC REPORTS, THEVALIDATED RESULTS FROM 11/11/97 (BEGINNING. OFDEMOLITION) TO 1/14/98, WHICH MAY EXCEED BACKGROUND

, CONCENTRATIONS, ARE AS FOLLOWS: . '' "A j

DATE(WEEKLY)

11/11/97 TO .11/15/9711/17/97 TO11/23/9711/24/97 TO11/30/9712/01/97 TO12/07/97

12/08/97 TO12/14/9712/15/97 TO12/21/97

1/5/98 TO,1/7/98

1/12/98 TO1/14/98

ANALYTE

NICKELANTIMONYCOPPER

COPPERNICKELANTIMONYBERYLLIUMCOPPERLEADANTIMONYCOPPERCOPPERLEADNICKELANTIMONY.LEAD , • ; '

BERYLLIUM

RESULTS-RANGE OFCONCENTRATION

UG/M30.039 - 0.04860.03450.244 - 0.342

0.1750.0362 - 0.04230.01100.0028 - 0.00430.154 - 0.2360.0957 - 0.2160.1210.029 - 0.165O.1730.1320.0660.0211 (BAISEDHIGH)0.196 - 0.2120,0055

SAMPLING RESULTS SHOWN ARE FROM THE AIR MONITORING STATIONS LOCATEDDOWNWIND O F SITE OPERATIONS. - , - . . . - . .

ARID 1*81* <t

RESULTS FOR METALS AND.PCBs SAMPLES COLLECTED ON 1/12/98 TO 1/14/98:

ANALYTE

ARSENICANTIMONYBERYLLIUMCADMIUMCHROMIUMCOPPERLEADMERCURYNICKELSELENIUMSILVER'THALLIUMZINCPCBs • - . . .


NO DETECTIONNO DETECTIONNO DETECTION ,NO DETECTION

0-0.0243 UG/MJ0-0.141 UG/tt*0-0.0928 UG/M"0*0.0036 UG/M^0-0.032 UG/M"

NO DETECTIONNO DETECTIONNO DETECTION ,NO DETECTION ,NO DETECTION

RESULTS-RANGE .OF '

CONCENTRATIONUG/M3

BACKGROUNDBACKGROUND- 0.0055BACKGROUNDBACKGROUND

- BACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUNDBACKGROUND

SAMPLING RESULTS SHOWN ARE FROM THE AIR MONITORING STATIONSLOCATED DOWNWIND OF SITE OPERATIONS.

E. THE "ASBESTOS"'RESULTS WHICH ARE POSTED TO SHOW IF DEMOLITIONACTIVITIES ARE POTENTIALLY RELEASING ASBESTOS FIBERS TO THE AIRARE REPORTED AS TOTAL FIBERS. THIS MEANS THAT FIBERS MAY ORMAY NOT BE ASBESTOS. EPA WILL BEGIN TO ANALYZE POSITIVELYDETECTED FIBERS TO DETERMINE IF THEY ARE IN FACT ASBESTOS.ANALYSIS WILL BE PERFORMED USING TEM, (TRANSMISSION ELECTRONMICROSCOPY) ANALYSIS.

F. A MEETING WAS HELD 4.FEBRUARY 1998 BETWEEN EPA, USAGE, AND, LANDFILL DESIGN CONTRACTOR GANNETT FLEMING. EPA WAS INFORMED

THAT DESIGN WILL BE HELD UP FURTHER DUE TO POOR QUALITY OF DATASUBMITTED BY EARTH TECH SUBCONTRACTOR (FAR). DESIGN WILL BE ONHOLD UNTIL DATA CAN BE CONFIRMED BY ARMY CORP. GANNETT FLEMINGWILL ATTEMPT TO EXTRACT QA/QC INFORMATION FROM FfiR.

G. ON 23 JANUARY 1998, SITE WAS VISITED BY MS. ERICA DAMERON, DIV.DIRECTOR OF FEDERAL FACILITIES, VADES. OSC PROVIDED MS.DAMERON WITH TOUR OF SITE. MS. DAMERON WAS PLEASED WITH ON-GOING ACTIVITIES AT THE SITE. THE ISSUE OF THE CONSTRUCTION OFA DISPOSAL UNIT AT ?HE SITE WAS DISCUSSED AND SHfi STATED SHEWAS WAITING FOR ADDITIONAL INFORMATION. SHE ALSO TOURED THEALLIED CHEMICAL SITE ADJACENT TO AVTEX FIBERS AND'-NOTED THECONDITIONS AT THE SITE.

H. 24-HOUR; SECURITY CONTINUES. >I. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE). ' ' , • . 'J. PERSONNEL ON SITE: EPA-3, ERCS-30, SATA-2 :K. REMOVAL COSTS TO DATE {COB 1/28/98): ,

.' . ESTIMATED CEILINGEPA DIRECT COSTS 509,297 519,161

_ EPA INDIRECT COSTS 873,781 980,824TAT (E&E) (11/27/93) 1,070,650 1,607,000SATA (WESTON) i 634,060 1,107,052ERCS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064) UO/8/93) 30,984 33,000ERCS (ETI-088) , 9,135,268 .9,754,753ERCS (IT—006) ' ' ' = ' 105,498 2,000,000USCG (10/1/91) , 197,515 197,515UNALLOCATED REMOVAL 32,826,854


ARIOW5

L. REMEDIAL COSTS TO DATE (COB 6/5/96): ,. . TOTAL REMEDIAL COSTS - . 9,565,624 10,260,960

TOTAL PROJECT COSTS 29,617,176 , .TOTAL PROJECT CEILING . 66,972,119ERCS (ETI-088) IS AT 93.6 % OF CEILING ,ERCS (IT-006) IS AT 5.3 % OF CEILINGSATA IS AT 57.3 % OF CEILING :

M. TEN PERCENT STATE SHARE 914,837

N. ENFORCEMENT (106) COSTS (2/2/92-8/12/93)

TOTAL ENFORCEMENT COSTS -183,263 183,263 -

I I . ACTIONS TAKEN:. . \ ' , . ' ' . " '

A. 58% OF SECTION III IS DEMOLISHED TO DATE. DEMOLISHED AREAINCLUDES VISCOSE CELLAR 6 B.

B. ERCS BEGAN REMOVING LOOSE ASBESTOS AND SECURING WITH POLY FILMTHE ASBESTOS INSULATED PIPELINES LOCATED. ABOVE SOUTH CORRIDOROF SECTION III. THIS ACTION NEEDS TO BE COMPLETED BEFORE ACIDHEAT # 1 AND,DOUBLE DECK SPINNING (SECTION III) DEMOLITIONBEGINS. REMOVING AND SECURING ASBESTOS INSULATION ON THE PIPELINES WILL PREVENT AN INCREASE IN THE POTENTIAL FOR RELEASE OFFIBERS AT THE FACILITY PERIMETER. 35 BOXES OF ASBESTOS WERECOLLECTED AND REMOVED TO SHIPPING ft 2 BUILDING UP. TO DATE.

C. SALVAGE OPERATIONS CONTINUE OR BEHALF OF THE TRUSTEE.D. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIAL

RELEASES OF SITE CONTAMINANTS DURING DEMOLITION.E, SATA STOPPED AIR MONITORING IN DEMOLITION ZONE UNTIL DEMOLITION

ACTIVITIES RESUME. .F.. OSC, ERCS AND SATA CONTINUE TO LOCATE SENSITIVE AREAS OF

UPCOMING DEMOLITION IN SECTION III AND REVIEW PROPER AND SAFEREMOVAL OF RCRA WASTES. CURRENTLY, ALL RCRA MATERIALS ARELOCATED AT THE SITE "OF THEIR DEMOLITION OR WITHIN THE RCRADECONTAMINATION AREA IN WEST STAGING.

III. FUTURE ACTIONS ' - ' . .

A. OSC TO CONTINUE Tp PLAN AND SCHEDULE REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.

B. SATA TO INSTALL WEATHER STATION TO DETERMINE CORRELATION .BETWEEN WIND PARAMETERS, DATARAM AND SAMPLE ANALYSIS.


D. SATA TO CONTINUE AIR MONITORING IN DEMOLITION ZONE TO OBSERVEEFFECTIVENESS OF THE DUST CONTROt METHODS IN THE HOT ZONE.

E. SATA TO PRESENT TO THE OSC THREE OPTIONS OF FINAL VIDEO EDITIONOF AVTEX SITE. OSC TO pECIDE WHICH OPTION HAS TO BE FINALLYPRODUCED.

F. SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDINGENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS.

G. SATA TO INVESTIGATE AND PREPARE RECOMMENDATIONS REGARDINGPLUGGING OF SEWAGE SYSTEM WHICH CONTROLS SECTION VI OFFACILITY.

H. DEMOLITION OPERATIONS EXPECTED TO RESUME THE WEEK OF 16FEBRUARY 1998.


ARI Ol»8«f6

.•TO: MICHAEL TOWLE / GEORGE ENGLISH 'TO: GROUP RRC . /, ' , .; ,'•.:'<• ''TO: GROUP REGION03-tAT •

SUBJECT: AVTEX SITE - POLREP 837 ' 'POLREP #837 'AVTEX FIBERS FRONT ROYAL404 KENDRICK LANE .FRONT ROYAL, WARREN'COUNTY,, VA 22630 ,

. CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTION . ,ATTN: CHARLIE KLEEMAN and RRC '

CC: WAYNE WALTERS (3RC21)'CC: BONNIE GROSS (3HW23I

I. SITUATION (AS OF 1730 HOURS, WEDNESDAY, FEBRUARY 11, 1998)A. OSC TOWLE, KELLY, AND FAS MCDONALD ONSITE.B. SITE REMOVAL ACTIONS CONTINUE., 'C. SINCE 30 JANUARY 1998 DEMOLITION ACTION IS SUSPENDED DUE

TO HEAVY EQUIPMENT REPLACEMENT BY THE ERCS.D..AIR SAMPLING RESULTS AT THE AIR STATIONS LOCATED DOWNWIND OF

SITE:: ,RESULTS FOR ASBESTOS SAMPLES COLLECTED FROM 20 JANUARY TO 8FEBRUARY:

DATEFIBERS

.01/300.001(2), •

02/020.001(1,2,4)

02/03-08NO

SAMPLING(RAIN ORSNOW)

BACKGROUND CONCENTRATION IS. NON DETECT FOR ASBESTOS.,"NUMBERS IN PARENTHESES INDICATE AIR SAMPLING STATION NUMBER.SAMPLING RESULTS SHOWN ARE FROM THE AIR MONITORING STATIONSLOCATED DOWNWIND OF SIT5 OPERATIONS. • , ...

E. THE "ASBESTOS" RESULTS WHICH ARE POSTED TO SHOW IF DEMOLITIONACTIVITIES ARE POTENTIALLY RELEASING ASBESTOS FIBERS TO THEARE REPORTED AS TOTAL FIBERS. THIS MEANS THAT FIBERS MAY ORMAY NOT BE ASBESTOS. ,EPA WILL BEGIN TO ANALYZE POSITIVELYDETECTED FIBERS TO DETERMINE IF THEY ARE IN FACT ASBESTOS.ANALYSIS WILL BE PERFORMED USING TEM (TRANSMISSION ELECTRONMICROSCOPY) ANALYSIS.

F. 2,260,000 GALLONS OF WATER IS COLLECTED PRESENTLY IN VISCOSECELLAR 6 A. WATER MAY EITHER BE USED FOR DUST CONTROL OR BERELEASED TO WATER TREATMENT PLANT AFTER NOTIFICATION DEPENDENTUPON ANALYSIS. , .

G. 24-HOUR SECURITY CONTINUES.H. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE). ,It, PERSONNEL ON SITE! EPA-3, ERCS-19, SATA-3 ••- .J. REMOVAL COSTS TO DATE (COB 2/11/98):

' ESTIMATED CEILING .•EPA DIRECT COSTS 514,154 519,161EPA INDIRECT COSTS 882,069 980,824TAT (EfiE) (11/27/93) , 1,070,650 1,607,000SATA (WESTON) 621,333 1,107,052

' '. . (SATA COSTS AFTER CORRECTION) ;, . .ERCS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000

• ERCS iETI-088) - 9,135,268 9,754,753ERCS (IT—006) 151,188 3,500,000USCG (10/1/91) 197,515 197,515UNALLOCATED REMOVAL , 31,326,854


K. REMEDIAL COSTS TO DATE (COB 6/5/96): f

TOTAL REMEDIAL COSTS 9,565,624 10,260., 960

TOTAL PROJECT COSTS 29,663,284TOTAL PROJECT CEILING ' 66,972,119 'ERCS (ETI-088) IS AT 93.6 % OF CEILING <

- ERCS (IT-006) IS AT 4.3 % OF CEILING . , •SATA .IS AT 56.1 % OF CEILING •

" L. TEN PERCENT STATE SHARE 914,837

M. ENFORCEMENT (106> COSTS (2/2/92-8/12/93) ('

TOTAL ENFORCEMENT COSTS 183,263 , 183,263

II. ACTIONS TAKEN;

A.,58% OF SECTION III IS DEMOLISHED TO DATE. DEMOLISHED AREA .INCLUDES VISCOSE CELLAR 6 B. ;

B. ERCS CONTINUE REMOVING LOOSE ASBESTOS AND SECURING WITH POLYFILM THE ASBESTOS INSULATED PIPELINES LOCATED ABOVE SOUTHCORRIDOR OF SECTION III. THIS ACTION NEEDS TO BE COMPLETEDBEFORE ACID HEAT # 1 AND, DOUBLE DECK SPINNING (SECTION III)DEMOLITION BEGINS. REMOVING AND SECURING ASBESTOS INSULATIONON THE PIPE LINES WILL PREVENT AN INCREASE IN THE POTENTIAL FORRELEASE OF FIBERS AT THE FACILITY PERIMETER. 39 BOXES AND 258BAGS OP ASBESTOS WERE COLLECTED AND APPROXIMATELY 4000 LINEARFEET OF PIPE LINES WAS SECURED UP TO DATE.

C. ERCS BEGAN SEARCHING FOR MERCURY AND REMOVAL OF TANKS ANDDEBRIS IN THE FILTER HOUSE. ."

Dv SATA INSTALLED WEATHER STATION TO DETERMINE CORRELATIONBETWEEN WIND PARAMETERS, DATARAM AND SAMPLE ANALYSIS.•

E. SATA FINISHED SAMPLING STORAGE TANKS ON SOUTH EAST PERIMETER OFSITE. EAST TANK CONTAINS APPROXIMATELY 20,000 GALLONS OF #6FUEL OIL WHILE WEST TANK CONTAINS BETWEEN 100,000 TO 200,000GALLONS OF WATER WITH SOLIDIFIED OIL PARTICLES. STORAGETANK NEAR AVTEX WATER TOWER CONTAINED APPROXIMATELY 10,000GALLONS OF OIL.

F. SALVAGE OPERATIONS CONTINUE ON BEHALF OF THE TRUSTEE..G. SATA CONTINUED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIAL

RELEASES OF SITE CONTAMINANTS DURING ASBESTOS REMOVAL LOCATEpSOUTH CORRIDOR OF SECTION III AND REMOVAL ACTION IN 'THE FILTERHOUSE.

H. SATA STOPPED AIR MONITORING IN DEMOLITION,ZONE UNTIL DEMOLITIONACTIVITIES RESUME,

I. OSC, ERCS AND SATA CONTINUE TO LOCATE SENSITIVE AREAS OFUPCOMING DEMOLITION IN SECTION III AND REVIEW PROPER AND SAFEREMOVAL OF RCRA WASTES. CURRENTLY, ALL RCRA MATERIALS ARELOCATED AT THE SITE OF THEIR DEMOLITION OR WITHIN THE RCRADECONTAMINATION AREA IN WEST STAGING.

J. SATA PRESENTED TO THE OSC THREE OPTIONS OF FINAL VIDEO EDITION .OF AVTEX SITE. OSC TO DECIDE WHICH OPTION HAS TO BE FINALLYPRODUCED. -

III. FUTURE ACTIONS


B. ERCS TO MOBE HEAVY EQUIPMENT TO THE SITE AND BEGAN DEMOLITIONOPERATION.

C. SATA TO INVESTIGATE UNDERGROUND PIPING SYSTEMS LOCATED INSECTION I AND SECTION III TO PREVENT UNNECESSARY DAMAGE DURINGDEMOLITION WORKS.

D. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION.

-

ARIQW8

E. SATA TO CONTINUE AIR MONITORING IN DEMOLITION ZONE TO OBSERVEEFFECTIVENESS OF THE DUST CONTROL METHODS IN THE HOT ZONE.

F. SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDING• ENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS. '

G. SATA TO'INVESTIGATE AND PREPARE RECOMMENDATIONS REGARDINGPLUGGING OF SEWAGE SYSTEM WHICH CONTROLS SECTION VI ANDSECTION I OF FACILITY.

H. DEMOLITION OPERATIONS EXPECTED TO RESUME THE WEEK OF 16FEBRUARY 1998.

I. RECEIVE AND REVIEW ANALYTICAL RESULTS OF ACCUMULATED WATER INVISCOSE CELLAR (6A) . DISCHARGE WATER TO FILTER PONDS (DUST.CONTROL) OR,SEWER (WWTP) DEPENDENT UPON RESULTS.

J. DETERMINE POSSIBLE DISPOSAL OPTIONS FOR OIL AND OILY LIQUIDSTORED IN STORAGE TANKS ALONG SOUTHERN PERIMETER OF SITE. ; ,

K. EVALUATE DATA RECEIVED/FROM BUILDINGS NORTH OF THE NORTHCORRIDOR AND DETERMINE WHAT, IF ANY, CLEAN UP IS NECESSARY.

L, DETERMINE DISPOSAL OPTIONS FOR SMALL CONTAINERS CORRECTLYSTOCKPILED IN PULP STORAGE AREA AFTER THESE CONTAINERS ARECHARACTERIZED.

MIKE TQWLE, OSCU.S. EPA REGION IIIPHILADELPHIA, PA

T O : MICHAEL TOWLE / GEORGE ENGLISH . , ' . ' • •TO: GROUP RRCTO: GROUP REGION03-TAT . ' • •

SUBJECT: AVTEX SITE - POLREP 838POLREP #838 . , '- • .AVTEX FIBERS FRONT ROYAL404 KENDRICK LANEFRONT ROYAL, WARREN COUNTY, VA 22630CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTIONATTN: CHARLIE KLEEMAN and RRC

CCt WAYNE WALTERS (3RC21) ,C C : BONNIE GROSS (3HW23) • , . ' . . - -

I. SITUATION (AS OF 1730 HOURS, THURSDAY; FEBRUARY 18, 1998) .A. OSC TOWLE, KELLY, ENGLISH AND FAS MCDONALD ONSlTE.B. SITE REMOVAL ACTIONS CONTINUE.C. SINCE 30 JANUARY 1998 DEMOLITION ACTION IS SUSPENDED DUE

TO HEAVY EQUIPMENT REPLACEMENT BY THE ERCS.D. AIR SAMPLING RESULTS AT THE AIR STATIONS LOCATED DOWNWIND OF

SITE: - ' - •THERE WERE NO FIBERS DETECTED IN THE SAMPLES COLLECTED FROM10 FEBRUARY TO 16 FEBRUARY.

E. 2,400,000 GALLONS OF WATER IS COLLECTED PRESENTLY IN VISjCesE"CELLAR 6 A* ANALYTICAL RESUL£&£F THE WATER SAMPLES SflOWN HIGHCONCENTRATION OFJXM&& (259 MG^Ll, ZINC (17,800 JW/I/rAND CARBONDISULFIDE (3200 MG/En EXISTING WATER LEVEL PRESENTS POTENTIALDANGER OF UNCONTROLLED OVERFLOW OUT OF THE WEST END OF THESOUTH CORRIDOR. THE WATER LEVEL IS ABOVE THE CEILING OF VISCOSECELLAR 6A AND NOW LESS THAN SIX INCHES FROM OVERFLOWING THESTAIRWELL. OSC DECIDED TO PUMP WATER FROMVISCOSE 6A TO THE SPRAY POND "A" (WHICH CAN COLLECT UP TO3,670,000 GALLONS OF LIQUID) TO ELIMINATE OVERFLOW POTENTIAL.

F. 24-HOUR SECURITY CONTINUES.'G. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (A0> TO AVC AND AVTEX (TRUSTEE). V j- H. PERSONNEL ON SITE: EPA-4, ERCS-19,.SATA-3 X-XI. REMOVAL COSTS TO DATE (COB 2/19/98):

ESTIMATED. CEILING . .EPA DIRECT COSTS 517,591 519,161EPA INDIRECT COSTS 887,765 980,824 .TAT (EfiE) (11/27/93) 1,070,650 1,607,000*SATA (WESTON) 651,317 1,107,052

(SATA COSTS AFTER CORRECTION)ERCS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000ERCS (ETI-088) 9,135,268 9,754,753ERCS (IT--006) 291,445 3,500,000USCQ (10/1/91) 197,515 197,515UNALLOCATED REMOVAL 31,326,854


J. REMEDIAL COSTS TO DATE (COB 6/5/96):, . ' •_ TOTAL REMEDIAL COSTS 9,565,624 10,260,960 " ,

TOTAL PROJECT COSTS 29,663,284TOTAL PROJECT CEILING 66,972,119ERCS (ETI-088) IS AT 93.6 % OF CEILING , ^ERCS (IT-006) IS AT 8.3 % OF CEILINGSATA IS AT 58.8 % OF CEILING

K. TEN PERCENT STATE SHARE 914,837 /

L. ENFORCEMENT (106) COSTS (2/2/92*8/12/93)TOTAL ENFORCEMENT COSTS 183,263 183,263 i

ARIOU850

I I . ACTIONS TAKEN: _ • ' < _ ' • ' £ ' " ' ; . / ' . " • ' ' ; • " . " , • " ' . ' . 'A. 58% OF SECTION III IS DEMOLISHED TO DATE. DEMOLITION IS

CURRENTLY SUSPENDED WHILE EPA AWAITS MOBILIZATION OF DEMOLITIONEQUIPMENTB. ERRS FINISHED REMOVING LOOSE ASBESTOS AND SECURING WITH POLY

FILM THE ASBESTOS INSULATED PIPELINES LOCATED ABOVE SOUTH, CORRIDOR OF SECTION III. 40 BOXES AND 403 BAGS OF ASBESTOS .WERE COLLECTED AND APPROXIMATELY 8000 LINEAR FEET OF PIPE LINESWERE SECURED. .

C. ERRS FINISHED REMOVAL OF TANKS, DRY CHEMICALS AND DEBRIS FROMTHE FILTER HOUSE. THE EXTERIOR ACID TANK REMAINS.

D. SATA COLLECTED .DUST SAMPLES FROM RING TWISTING, SLASHING,SHIPPING # 1, SHIPPING,* 5, AND BEAM STORAGE OF SECTION II.THE CONING ROOM WAS NOT SAMPLED BECAUSE IT HAD STANDING WATER,, AND WILL BE SAMPLED WHEN IT DRIES UP. . ,

E. ERRS BEGAN REMOVING THE CONCRETE SLAB AND THE UNDERLYING NON-ESSENTIAL UTILITIES OF SECTION III. ,SATA SUBMITTED TO THE ERRS DRAWINGS CONTAINING INFORMATIONABOUT PIPE LINES UNDERNEATH THE CONCRETE SLAB.DRAWINGS INCLUDED PIPE DIMENSIONS, LOCATIONS AND DEPTHS FROMTHE CONCRETE SURFACE. ALL DRAIN LINES CONVEYING LIQUIDS FROM.SECTION I SHALL REMAIN AT. THIS TIME.F. SALVAGE 'OPERATIONS CONTINUE ON BEHALF OF THE TRUSTEE.

G. SATA SUSPENDED PERIMETER AIR SAMPLING TO MONITOR FOR POTENTIALRELEASES OF SITE CONTAMINANTS UNTIL DEMOLITION OPERATION WILLRESUME. - • - - . . • • - • • ' . ,

H. OSC, ERRS AND SATA CONTINUE TO LOCATE SENSITIVE AREAS OFUPCOMING DEMOLITION IN SECTION III, AND SECTION I AND REVIEWPROPER AND SAFE REMOVAL OF RCRA WASTES. CURRENTLY, ALL RCRAMATERIALS ARE LOCATED AT THE SITE OF THEIR DEMOLITION OR WITHINTHE RCRA DECONTAMINATION AREA IN.WEST STAGING.

,1. ERRS CLEANED AND REMOVED ALL STOCKPILED STEEL, METAL,EQUIPMENT, AND OTHER DEBRIS,FROM THE DEMOLITION AREA WITH THEEXCEPTION OF RCRA CONTAMINATED MATERIAL.

J. SATA, COLLECTED SAMPLES FROM AREA SOUTH OF "LEAD SHOP" NEARWATER TOWER. AREA IS CHARACTERIZED BY SLAG-LIKE DEBRIS ANDLEAD SHAVINGS. , . , ; . . ,

III. FUTURE ACTIONS , - '" •'

A. OSC TO CONTINUE TO PLAN AND SCHEDULE - REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.

B. ERRS TO MOBE HEAVY EQUIPMENT TO THE SITE TO REINITIATEDEMOLITION OPERATION. ..

C. INVESTIGATE UNDERGROUND PIPING SYSTEMS LOCATED INSECTION I AND SECTION III TO PREVENT UNNECESSARY DAMAGE DURINGDEMOLITION WORKS. , ,

D. SATA TO SURVEY CONCRETE "TANKS" NEAR COOLING TOWER TO DETERMINETOTAL CAPACITY. THESE TANKS CAN BE USE TO STORE LIQUIDSDURING DEMOLITION ACTION. '

E. TO PUMP RAINWATER COLLECTED IN .SPRAY POND "A" TO THE FILTERHOUSE POND. SPRAY POND "A" WILL BE USED TO COLLECT WATERFROM THE VISCOSE CELLAR 6 A.

F. CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION.

G. SATA TO CONTINUE AIR MONITORING IN DEMOLITION ZONE TO OBSERVEEFFECTIVENESS OF THE DUST CONTROL METHODS IN THE HOT ZONE.

H. SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDING/ ENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS,I. IMPLEMENT PLUGGING OF SEWAGE SYSTEM WHICH CONTROLS SECTION VI

AND SECTION I OF FACILITY. - , •J. DEMOLITION OPERATIONS EXPECTED TO RESUME THE WEEK OF 23

FEBRUARY 1998. OPERATIONS WILL COMMENCE AT VISCOSE CELLAR 6C.K. DETERMINE POSSIBLE DISPOSAL OPTIONS FOR OIL AND OILY LIQUID

AR 101*85 I

STORED IN STORAGE TANKS ALONG SOUTHERN PERIMETER OF SITE..L. EVALUATE DATA RECEIVED FROM BUILDINGS NORTH OF THE NORTH

CORRIDOR AND DETERMINE WHAT, IF ANY, CLEAN UP IS NECESSARY.M. DETERMINE DISPOSAL OPTIONS FOR SMALL CONTAINERS STOCKPILED IN

PULP STORAGE AREA AFTER THESE CONTAINERS ARE CHARACTERIZED.

MIKE TOWLE, 'OSC.U.S. EPA REGION III.PHILADELPHIA, PA

ARI 01*852

POLREPS39SPECIAL BULLETINAVTEX FIBERS SITE • , ' • .404 KENDRICK LANEFRONT ROYAL, VA 22630 . ,

DATE: 24 FEBRUARY 1998

ATtN: RRC,C.KLEEMANCC:W. WALTERS . - . • - 'CC:B.OROSS

PRIOR TO DEMOLITION ACTIVITIES, EPA ARRANGED FOR THE TEMPORARY PLUGGING OF DRAIN LINESCONVEYING WATER FROM SECTION m OF THE FACILITY AND FOR THE COLLECTION OF CERTAIN STORMWATER. THIS ACTION PREVENTS THE UNCONTROLLED RELEASE OF WATER POTENTIALLY CONTAMINATEDDURING REMOVAL ACTIVITIES TO THE LAGOON S YSTEM/WWTP AND THE SHENANDOAH RIVER. THIS ACTIONALSO ALLOWS FOR CONTROLLED RELEASE AND "PRE-TREATMENT* OF ALL STORED WATER AS NEEDED.ALTHOUGH THE MAIN DRAINAGE LINE FROM VISCOSE CELLAR 6A WAS APPARENTLY PLUGGED BY OTHERSDURING THE OPERATION OF THE AVTEX FACILITY, THE EPA-INSTALLED DRAIN PLUGS HAVE CONTRIBUTED/RESULTED IN THE ACCUMULATION OF APPROXIMATELY 2.4 MILLION GALLONS OF WATER IN VISCOSE CELLAR6A (INCLUDING THE BOX CELLAR AND STAPLE CELLAR AT THIS LEVEL). THIS WATER RESULTS SOLELY FROMRAINWATER WHICH PASSES THROUGH THE FACILITY AND POTENTIALLY MIXES WITH RESIDUAL CHEMICALSIN THE FLOODED AND TRIBUTARY AREAS. ANALYSIS OF THE"VISCOSE 6AW WATER REVEALS LEVELS OF LEAD(259 UO/L), ZINC (17,800 UG/L), WHICH EXCEED THE ESTABLISHED DISCHARGE CONCENTRATION LIMITS FORTHE WWTP, AND CARBON DBULFIDE (3200 UO/U VISCOSE CELLAR 6A IS FULL OF WATER AND OTHER TANKS,PITS, AND DRAIN LINES USED TO STORE SITE WATERS ARE ALSO FULL. TO AVOID THE UNCONTROLLEDRELEASE OF THIS WATER FROM OVERFLOW INTO THE SOUTH CORRIDOR AND OUT THE DEMOLISHED WESTWALL. OF THE FACILITY, THE OSC DIRECTED REMOVAL OF SEVERAL HUNDRED THOUSAND GALLONS OF THE"VISCOSE 6A" WATER INTO SPRAY POND A (NORMALLY USED TO STORE LARGE LEVELS OF WATER REQUIRINGTREATMENT BEFORE DISCHARGE AND THE LOCATION FOR EPA EMERGENCY STORAGE). CONTINUED WETWEATHER HAS NOW RESULTED IN THE LOSS OF MOST OF THE STORAGE CAPACITY OF WATERS GENERATED .DURING THE REMOVAL ACTION (E.G., DUST SUPPRESSION WATER) AND THE ACCUMULATED STORM WATERWHICH OTHERWISE WOULD FLOW TO THE LAGOONS (E.G., "VISCOSE 6A" WATER). VISCOSE CELLAR 6A ALSOCONTINUES TO FILL AS WATER FROM THE AREA OF THE POWER PLANT, SOUTH CORRIDOR, AND SODAPRESSING AREAS FLOWS IN. THUS, WATER MUST SOON BE DISCHARGED FROM THE FACILITY AREA TO THELAGCON/WWTP TO AVOID AN UNCONTROLLED RELEASE OF UNTREATED WATER OR WATER REQUIRINGTREATMENT BEFORE REACHING THE WWTP/RIVER. THE OSC HAS CONFIRMED THAT THE WWTP CAN TREATTHE ELEVATED CONTAMINANT LEVELS IN THE VISCOSE 6A WATER. THERE IS NO WRITTEN UMTTFORCARBON DISULFIDE LEVELS IN THE DISCHARGE. THE OSC WEX DIRECT DISCHARGE OF THE "VISCOSE 6A"WATER WITHOUT TREATMENT SINCE THIS WATER WAS NOT GENERATED BY THE REMOVAL ACTION AND HASNOT ALREADY MIGRATED TO THE LAGOON/WWTP SOLELY BECAUSE EPA HAS PLUGGEQ THE DRAIN LINE.AFTER NOTIFICATION TO FMC, EPA WAS INFORMED THAT THE WATER COULD BE DISCHARGED AS IS.HOWEVER, EXCESS WATERS NOW IN THE LAGOONS RESULT IN EXCEEDANCES OF FREEBOARDREQUIREMENTS AND FMC/WWTP PERSONNEL REQUEST THAT EPA'S WATERS NOT BE DISCHARGED UNTILFREEBOARD (CAPACITY) IS GAINED IN THE LAGOONS. THE OSC SHALL WAIT UNTIL THE LAST POSSIBLEMOMENT BEFORE DISCHARGING, AND SHALL NOTIFY THE WWTP OF SUCH DISCHARGE. EPA WILL CONTINUETO REUSE AND/OR TREAT WATERS GENERATED BY THE REMOVAL ACTION. !

MICHAEL TOWLE, OSCEPA REGION HIPHILADELPHIA, PA 19107

AR I 01+853

TO! MICHAEL TOWLE / GEORGE ENGLISHTO: GROUP RRCTO: GROUP REGION03-TAT ,

SUBJECT: AVT.EX SITE - POLREP 840POLREP #840AVTEX FIBERS FRONT ROYAL404 KENDRICK'LANEFRONT ROYAL, WARREN COUNTY, VA 22630 'CERCLA ENFORCEMENT/REMOVAL/REMEDIAL ACTION,ATTN: CHARLIE KLEEMAN and RRC

CC: WAYNE WALTERS (3RC21) ' , , 'CC: BONNIE GROSS (3HW23)

I. SITUATION (AS OF 1730 HOURS, WEDNESDAY, FEBRUARY 25, 1998)1 A, OSC TOWLE, ENGLISH AND,FAS MCDONALD ONSITE.

B. SITE REMOVAL ACTIONS CONTINUE. ,C. SINCE 30 JANUARY 1998 DEMOLITION ACTION IS SUSPENDED DUE

TO HEAVY EQUIPMENT REPLACEMENT BY THE ERRS. • 'D. DUE TO ERRS CONDUCTING NON-DEMOLITION OPS,'METAL AND ASBESTOS

SAMPLES WERE ONLY COLLECTED ON 2/24/98. RESULTS-HAVE NOT YETCOME BACK. • . . • • - ' ' •

E. 430,000 OF TOTAL 2,400,000.GALLONS'OF WATER COLLECTED IN •VISCOSE 6A WAS PUMPED TO THE SPRAY POND "A" TO AVOID THEUNCONTROLLED OVERFLOW INTO THE SOUTH CORRIDOR AND OUT THEDEMOLISHED WEST WALL OF THE FACILITY. pH READING OF WATER INTHE POND RESULTED IN 5.

F. THE OSC (PATRICK GAUGHAN) EPA COMMUNITY RELATIONS, MEMBERS OFTHE TOWN COUNCIL, WARREN COUNTY BOARD OF SUPERVISORS, ECONOMICDEVELOPMENT AUTHORITY AND COUNTY REDEVELOPMENT CORP. AS WELL ASMEMBERS OF THE PRESS TOURED THE SITE ON 25 FEBRUARY 1998.

G. 24-HOUR SECURITY CONTINUES.H. ENFORCEMENT ACTIVITIES CONTINUE PER ADMINISTRATIVE

ORDER (AO) TO AVC AND AVTEX (TRUSTEE).I. PERSONNEL ON SITE: EPA-4, ERCS-19, SATA-3J. REMOVAL COSTS TO DATE,(COB 2/25/98):

ESTIMATED 'CEILINGEPA DIRECT COSTS 522,791 519,161EPA INDIRECT COSTS 896,853 980,824TAT (E&E) (11/27/93) 1,070,650 1,607,000SATA (WESTON) 639,814 1,107,052

(SATA COSTS AFTER CORRECTION) 'ERCS (OHM) (4/7/92) 7,494,499 7,685,000ERCS (ETI-064) (10/8/93) 30,984 33,000ERCS (ETI-088) 9,135,268 9,754,753ERCS (IT--006) 442,266 , 3,500,000 'USCG (10/1/91) 197,51$ 197,515UNALLOCATED REMOVAL , 31,326,854


K. REMEDIAL COSTS TO DATE (COB 6/5/96):TOTAL REMEDIAL COSTS 9,565,624 10,260,960

TOTAL PROJECT COSTS 29,996,264TOTAL PROJECT CEILING - 66,972,119ERCS (ETI-088) IS AT 93.6 % OF CEILINGERCS (IT-006) IS AT 12.6 % OF CEILINGSATA IS AT 57.8 % OF CEILING

L. TEN PERCENT STATE SHARE ' 914,83?

M. ENFORCEMENT (106) COSTS (2/2/92-8/12/93)TOTAL ENFORCEMENT COSTS 183,263 183,263

U

II.'ACTIONS TAKEN: ', .- ,

... A. 58% OF SECTION in is DEMOLISHED TO DATE.. DEMOLITION isCURRENTLY SUSPENDED WHILE EPA AWAITS MOBILIZATION OF .DEMOLITION EQUIPMENT • , . • " • •

B. REMOVAL OF.RCRA CONTAMINATED DEBRIS AND SOIL FROM THE CONCRETEPAD OF SECTION III AS WELL AS CLEAN DEBRIS CONTINUE. THECONTAMINATED SOIL IS BEING STORED SEPARATELY ON THE WESTSTAGING AREA AND COVERED'WITH TARP. THE RCRA DEBRIS IS BEINGCLEANED WITH WATER IN THE COOLING TOWER SLUDGE PIT ANDPILED AS CLEAN DEBRIS. , , '

C. SATA COLLECTED WATER, SOIL AND OIL SAMPLES FROM THE SODA -ANDMERCERIZING BUILDING.. THE/SOIL AND OIL SAMPLES CAME UP

, NEGATIVE ON THE CLOR-N-SOIL/OIL TEST KITS. SATA MONITORED FORHYDROGEN SULFIDE IN BASEMENT, NO DETECTION WAS FOUND.

D. ERRS CONTINUE REMOVING THE CONCRETE SLAB OF SECTION III ANDREMOVING REMAINING STRUCTURES IN THE SLAB, AREA.

E. SALVAGE OPERATIONS CONTINUE ON BEHALF OF THE TRUSTEE.F. SATA LOCATED ALL LABORATORIES ONSITE AT FACILITY. ERRS ,

CONDUCTING A FINAL ROUNDUP OF SMALL CONTAINERS IN THE 'LABORATORIES. , .

G. OSC, ERRS AND SATA CONTINUE TO LOCATE SENSITIVE AREAS OFUPCOMING DEMOLITION IN SECTION III, SECTION VI, SECTION I ANDREVIEW PROPER AND SAFE REMOVAL OF RCRA WASTES.

Ill1, FUTURE ACTIONS ' . .

A. OSC TQ CONTINUE TO .PLAN AND SCHEDULE REMOVAL OPERATIONS AND TOCOORDINATE ACTIVITIES WITH FEDERAL, STATE, AND LOCAL OFFICIALS.

B, ERRS TO CONTINUE TO MOBE HEAVY EQUIPMENT TO THE SITE TOREINITIATE DEMOLITION OPERATIONS ON 3/2/98 AT VISCOSE 6C.

C. INVESTIGATE UNDERGROUND PIPING SYSTEMS LOCATED INSECTION I AND SECTION III TO PREVENT UNNECESSARY DAMAGE DURINGDEMOLITION WORKS. , .

D. REMOVE ALL TRANSFORMERS LOCATED IN SECTION I AND STORE IN, SEPARATE PLACE FOR FUTURE DISPOSITION. .

x E. SATA TO CONTINUE AIR MONITORING AND SAMPLING AS DIRECTED BY THEOSC; RESULTS TO BE POSTED FOR PUBLIC INSPECTION.' .

P. SATA TO-CONTINUE AIR MONITORING IN DEMOLITION ZONE TO OBSERVE'EFFECTIVENESS OF THE DUST CONTROL METHODS IN THE HOT ZONE.

G. -SATA ENGINEER TO CONTINUE TO PREPARE RECOMMENDATIONS REGARDINGENGINEERING ASPECTS OF THE DEMOLITION OPERATIONS.

H. IMPLEMENT PLUGGING OF .SEWAGE SYSTEM WHICH CONTROLS SECTION VI-AND SECTION I OF FACILITY. ,

I. DETERMINE POSSIBLE DISPOSAL OPTIONS FOR OIL AND OILY LIQUIDSTORED IN STORAGE'TANKS ALONG SOUTHERN PERIMETER OF SITE.

J. EVALUATE DATA RECEIVED FROM BUILDINGS NORTH OF THE NORTHCORRIDOR AND DETERMINE WHAT, IF ANY, CLEAN UP IS NECESSARY.

K. DETERMINE DISPOSAL OPTIONS FOR SMALL CONTAINERS STOCKPILED INPULP STORAGE AREA AND COLLECTED FROM LABORATORIES AFTER THESECONTAINERS ARE CHARACTERIZED.


ARIOlf855

Documents

AR I 01*810 · 2020. 8. 23. · e. sata investigated location -of the' stack ventilation ,, .channels which will be sealed to prevent dust penetration inside buildings during stack