Whether to bury it or move it -- that is the question.

Town officials and local business leaders are grappling with options proposed by the U.S. Environmental Protection Agency for disposal of millions of tons of building debris once non-reusable buildings at Avtex are demolished.

Front Royal Town Councilmen at a work session Monday night agreed they needed more information before taking a position on either option, burial versus off-site disposal.

Local officials plan to meet with representatives of the U.S. Environmental Protection Agency Region III and the state Department of Environmental Quality to gather more facts.

Meanwhile, EPA has told the area's congressman that the agency is committed to keeping local officials and the public abreast of new developments.

In a letter to Rep. Frank Wolf (R-10th), EPA Acting Regional Administrator Stanley Laskowski stated that he shares Wolf's desire "to assure that the local community has an opportunity to evaluate the EPA proposal to demolish the buildings and dispose of the debris in an on-site landfill."

The cost of demolition with on-site disposal is estimated at $23 million, compared to $138 million for offsite disposal.

"EPA and the Virginia Department of Environmental Quality are aware of the geology of the site and the proximity of the Shenandoah River and its floodplain. We would not consider construction of a landfill in an area and not provide for safe disposal of the building debris," Laskowski's letter added.

Additionally, EPA will send an update every two weeks to Fred Foster, president of the Warren County Redevelopment Board, about new proposed and actual developments.

A site fact sheet will also be mailed to the community in mid-July, explaining waste containment, the letter stated. Laskowski noted that the Front Royal community has expressed concern that an on-site landfill would delay reuse of the Avtex site. But the area west of the railroad tracks "will not be available for reuse for a very long time, if ever-- whether or not an on-site landfill is constructed in this area. This area received most of the waste generated the facility during its years of operation," Laskowski said.

Laskowski's letter did not address specific environmental concerns about possible leakage from a landfill.

But even with the best state-of-the-art technology to line and cover a proposed landfill at Avtex, some leakage is to be expected, said a U.S. Environmental Protection Agency regional hazardous waste program specialist in Philadelphia.

The EPA has proposed to construct the 14-acre landfill on property of the defunct rayon manufacturing plant. The landfill would contain the remains of demolished buildings on that portion of the site.

The landfill construction would rely on several layers of clay and plastic to prevent contamination from seeping into the surrounding soil and into groundwater. A seal of two to three feet of clay, along with high-density polyethylene liners, would provide the best available protection on the bottom and top of the landfill, according to Mary Beck, an EPA Region III environmental engineer and specialist in the Resource Conservation and Recovery Act program.

RCRA is the federal statute which would govern the proposed landfill at Avtex, although the site as a whole falls under the Superfund toxic waste law, the Comprehensive Environmental Response, Compensation and Liability Act.

With the double clay and plastic liners lining and capping the landfill, "There will still be something leaking, but very little," she added.

Under the hazardous waste "Subtitle C" program of RCRA, hazardous waste landfills like the one being eyed for Avtex would be required to have ground water monitoring systems. Treatment would be required if the landfill would be found to be leaking hazardous constituents into soils or ground water, she added.

The landfill would further be required to have a "leachate" collection system involving pipes in the landfill that would collect rain water and funnel it to a pumping station where it would then be treated, Beck said.

With construction debris, "There is generally nothing hazardous ," said Andrew Uricbeck, EPA Region III coordinator of RCRA's Subtitle D non-hazardous solid waste program. Much of the materials, he said, could potentially be recycled such as iron in rebar and wood from buildings.

Under the Subtitle D program, no caps or liners are required, Uricheck said.

But EPA Avtex site coordinator Andy Palestini said that because some buildings at Avtex have been found to be chemically contaminated, the construction debris would be considered hazardous waste for the purposes of regulation under the Subtitle C program.

"It would have to be lined. We don't see this as a Subtitle D" landfill, Palestini said.

A final decision on whether to consider it Subtitle C or D has not been made, he said, because testing to assess contamination of the construction materials has not yet completed.

"We know some of it's contaminated," he said. "We know what’s there. The main problem is acids on the concrete floor."

Due to their corrosive properties, acids are considered a characteristic hazardous waste under RCRA, as opposed to one of the several listed wastes.

Even equipment and debris that could potentially be hauled off as scrap could contain residual amounts of hazardous waste, he said.

"It's going to be impossible to decontaminate the material" he said, whether decontamination efforts are taken before or after buildings at Avtex are demolished.

"Most of it won't be contaminated, but it will be difficult to segregate the contaminated from the non-contaminated material," Palestini said.

"Rather than saying it's 70-percent clean, we have to worry first about the 30 percent that's not clean," he added. The landfill would be dug about eight feet deep over 14 acres at Avtex, under the option officials are most closely considering.

To demolish the buildings, build a Subtitle C landfill and provide clay and plastic liners and caps would cost roughly $23 million, Palestini said. Under a more expensive alternative option, the debris would be hauled offsite at a cost of $137.8 million, he said.

EPA official's are leaning toward the landfill option, he said, but added, "It's not a done deal yet."

Cost, he conceded, "is one factor we take into account." In spite of ongoing efforts for the government to recoup costs from potentially responsible parties, "We don't have $137 million available to us now," Palestini noted.

Beck noted that at Superfund sites like Avtex, "Money and costs are something that need to be considered. The final remedy is most often the most cost-effective. If it is cheaper to keep it on site, that would be the remedy. It also has to be protective of health and the environment," she added.

While costs of remedies are a concern, the age of Avtex facilities is also a concern to officials. "The thing that's moving us now is deterioration," Palestini said. "We don’t want the buildings to collapse on their own," he said.