Your first thought is that it could be anywhere--anywhere, that is, except Avtex. The wetland is a peaceful, reed-ringed pool, full of birdsong and unruffled by late summer breezes.

It's easy to imagine the pond in the middle of a wild meadow until you look beyond the water's edge. On one side is the railroad tracks - on the other, the tall, red-brick towers that once belched out the breath of Avtex.

Now some local leaders are concerned that the wetland, which has attracted a population of turtles, ducks, herons, and other water birds, may be dredged for a landfill to hold contaminated building debris from the Avtex site.

The pond was formed many years ago, when drainage pipes carried runoff from the plant to the low-lying area. In the intervening years, and especially since the shut-down of the plant, water-loving animals, birds, and plants adopted the former drainage pond as their home. "It is the last place on the site that I think should be used for disposal of the buildings," Ed Ward, executive vice president of the Friends of the Shenandoah River, told the Front Royal Town Council recently. "I think that ruining that beautiful wetland is the worst possible solution."

Ward said the wetland would be a significant addition to the wildlife preserve that has been envisioned as the best use of the areas near the river and in the floodplain.

Andrew Palestini, Superfund project coordinator at the U.S. Environmental Protection Agency's regional office in Philadelphia, told the council at its Aug, 28 meeting that the wetland site is appealing "because it is further away from the river' than other sites west of the railroad tracks, an area which has been deemed unsuitable for industrial reuse.

Fly ash, the dust from a coal-fired power plant at Avtex that was deposited years ago one the site of the wetland, would be used to help cushion the bottom of the landfill before being lined with a high-density polyurethane liner. The ash would prevent punctures in the liner, Palestini said.

The wetlands site, known as lagoon number 6, was proposed because, after dredging the wetland, the fly ash earlier deposited there would provide a good base for the plastic liner, Ward said last week.

A better alternative for the disposal site would be a mountain of fly ash at Avtex, which is well above the floodplain, Ward said. It could be excavated and used, without moving it, to provide the same cushion for a liner, he explained.

Another possibility is to line the basements of the deteriorated buildings with concrete and implode them into the resulting sealed basin, Ward said.

At the council meeting, Palestini said it would take abut 17 months to dig the landfill and seal it. However, he saw no danger of the high-tech landfill design failing and leaking harmful chemicals into the surrounding soil.

"If it was a landfill without any lining, we feel it would be cause for concern," Palestini told the council.

At the abandoned Avtex site, dried acid and dried caustic substances are caked onto the buildings and are causing the structures to deteriorate, he said.

The disposal option for building debris is seen as a cheaper, quicker alternative at a time when the Superfund budget before Congress hangs in limbo. Onsite disposal would cost some $24 million, compared to $138 million to haul the debris offsite.

Fred Foster, head of the Warren County Redevelopment Corporation, said the organization supported the EPA’s plan.

"We thought it could work as long as EPA is locked into monitoring this forever."

But that is not the case. Palestini said EPA plans to monitor the landfill for 30 years, to make sure it is secure and that toxic substances on the debris do not seep into ground water.

"We don't know what's going to happen in 30 years," Foster told the council. "We were told it was outside the floodplain when we made our decision."

At the meeting, a citizen in the audience asked Palestini about the stability of the landfill under conditions of a 100-year flood.

"That's a real concern we need to address," Palestini replied. "We need to know for certain where the floodplain is. Most of it is not in the

floodplain."

Councilman Walter Duncan noted that the Shenandoah River rose 51 feet in 1942 adding that he was certain a lot of the river bottom areas were covered with water.

Directing his remarks to Palestini, Mayor Stan Brooks, Jr., said, "We're trying to figure out how the town fits in. Where do we fit in?"

Palestini replied that EPA will "ask for your concerns."

Brooks then asked, "What if the town council voted that we weren't happy with this?"

Palestini answered, "It would depend on why, and if you had a cost-effective alternative."

Referring to Ward's remarks about leaving the wetlands alone. Brooks said, "There may be 15 acres of land that might be good for something else. Before we'd say anything, we'd want more technical background."

Brooks added later, that of the council's position, "I don't think we're anywhere near making a recommendation. I have a lot of concerns."

Contacted this week, Palestini said no new developments or reviews have surfaced over the landfill option.

Thomas Modena, Superfund project coordinator for the Virginia Department of Environmental Quality in Richmond, said Wednesday that the state has not yet taken a position on the wetlands issue or whether to endorse onsite burial versus offsite disposal. The project must meet both state and federal environmental regulations, he noted.

"So far, EPA hasn't really provided us with any information yet, We really can't have a position until we know more about it. We don't

know enough to know any specifics."

Palestini said that EPA plans to hold a private meeting with the town council about the landfill option, and a separate meeting for the public.