U.-l !FA Headquarters Library
                            .Mill code 3404T
                                              NW
    United States
    Environmental Protection
    Agency
Waihingten, Bfi%2046fi-        •-  -      <  •*•     .     .
    iol466.rJSautting-Edge'  Techniques
           Proposed  for  Nease  Cleanup
 For moreMorraatfon..!
 If-yo« am4ateres*ed ia flic ^ease
 ChemJeai ckaaup,, please sitend
 te upo«>tt«n^p«|jlic" taeetiag otf
 Wednesday, June 22, at fee Salem'
^Public library, 821B, S^{£^.» froia
 Wriltea osRanejas on die proposed plan -
jshould b? si&mJtted fwa !«»« J~ V
 June3&    „......'     " ' "
                •.            ^
  * QfaOy or m wrfdng at the public.^
  " via fax to
   (3)2)353-1155
 Contact EFA
      Pastor
         10 a.m,  r
 Mary Logan,       " x
.EE'ARmedial' Project Manager
           a.m. - 5:30
'As this p-ejeet is being done in
 can also be i
 Sheila Abraham  v
 Obb EPANorfeeasl Disaicl Office ,
 (330)953-1290     "     :*;
                                     Nease Chemical Site
                                     Columbiana County, Ohio
                                                                June 2005
           Mease Chemical site plan
           (not ail of the Middle Fork of Little Beaver Creek Li shown)

           Innovative techniques could be used to clean up the Nease Chemical site under
           a plan1 proposed by U.S. Environmental Protection Agency.  The proposal will
           be discussed at a public meeting on Wednesday, June 22, and area residents
           will have 30 days to comment on the proposal. Based on those comments and
           documents in the administrative record (see back page), EPA will select the
           option, modify the proposal, or pick another one.
           This is the first of two planned cleanup proposals for the site (referred to as
           Operable Unit 2, see map). It addresses ground water (water that collects
           underground in the spaces between dirt, gravel, and rock), the old plan? facility
           and soil. A later proposal \vil5 address Feeder Creek and the Middle Fork of
           Little Beaver Creek.
           After extensive study, EPA - working closely with Ohio EPA and Ruetgers

           1  Section Il7(a) of the Comprehensive Environmental Response, Compenseuion, and
             Liability Act (CERCI-A) requires publication of a notice and a proposed plan for the
             site remediation.  The proposed plan must also be made available io the public for
             comment.  This proposed plan is a summary of information contained in the remedial
             investigation, feasibility study, and other documents in the admin'tstralive record far the
             Nease Chemical site. Please consult those documents for more detailed information.

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 Organics Corp. - has developed five possible ways to clean
 up the site. The recommended option (Option B) involves
 "nano-technology" to clean the ground water under (he site.
 The traditional cleanup method for ground water is to pump
 it out, treat it and return it to the aquifer (an underground
 water-bearing rock formation) from which it came. Bui
 this  is expected to be less effective and more costly than the
 recommended option at this site.
 A unique method is also recommended for cleaning up two
 areas that once were ponds but have become partially filled
 in with waste and other solid material. The plan is to "sirip"
 most of the chemicals from the ground and solidify the
 remaining soil with a cement-Hke substance.

 About the Nease site
 The  Nease Chemical Superfund siie consists of 44 acres
 along slate Route 14, two and one-half miles northwest of
 Salera on the Columbiana-Mahoning county line. The site is
 surrounded by lightly developed land on three sides and an
 industrial plant on the northeast. The area is partially fenced
 to prevent access. Railroad tracks intersect the northern
 portion of the site near the fence.
 Most of the site has been taken over by plants. Trees border
 the eastern and western sides of the fenced area.  The land
just north of the fence is swampy, with a small stream called
 Feeder Creek running through it.  Feeder Creek empties into
 the Middle Fork of Little Beaver Creek, which is north and
 east  of the site.
 Between J961 and  1973. Nease Chemical  produced various
 household cleaning compounds, fire relardants and pesticides
 —• some of which contained mirex.
 Banned in the United States in 1978, mirex breaks down
 slowly in the environment.  It may remain in soil and water
 for years.  The effects of mirex on people's health is not
 certain. At high levels it may cause damage to the skin, liver,
 nervous system or reproductive system.
 In 1977, Ruetgers Organics Coip. acquired the Nease property
 but never operated at the site.  In 1983, the site was placed on
 EPA's Superfund list, also referred io as the National Priorities
 List. Since then, Ruetgers Organics Corp,, with oversight
 from EPA and Oliio EPA, has studied the type and extent, of
 contamination.
 The  Nease company used unlincd ponds to treat waste
 from the manufacturing process. The "ponds" however, no
 longer contain much water: in fact mey are often referred to
 as former ponds.  The pond areas are not large. They take
 up about 6 Vz acres of the site. Over the years, the ponds
 were filled in with waste and soil. What was once a pond
    What is Nanoscale Zero-valent Iron?
    Iron nanoparticles are emerging as a leading cutting-
    edge technology to clean up ground water. Ultra-
    small particles of iron can destroy contaminants
    based on chemical reactions similar to rusting.  Zero-
    valent means Ihe iron is in metallic form and ready
    to react with other chemicals. When conditions are
    right, the iron nanoparticles react with ground-water
    contaminants, which are converted into harmless
    byproducts.
    The microscopic iron particles are  especially useful
    because of their size — a human hair is 500 to 5,000
    limes wider. At that size, they can flow with Ihe
    ground water into tiny spaces in soil and rock and
    reach contaminants that, other cleanup methods cannot.
    After cleanup, the iron particles settle and become
    part of the soil.
is now a boggy area, solid in some places and spongy in
others. The primary contaminants in the ponds are mirex and
volatile organic compounds, known as VOCs (chemicals that
evaporate or dissolve into water easily).
Contaminants seeped into me soil and ground water from
these ponds, as well as from buried drums (hat eventually
leaked. The leaky drums formerly located in Exclusion Areas
A and B (see map on Page 1} were dug up and taken off site.
Chemical coniaroioation remains, especially in Ponds 1 and
2.  These ponds contain very high levels of mirex and VOCs.
The primary contaminant in the ground water is VOCs.  The
mosi severely contaminated ground water is found near Ponds
I and 2.
Surface water runoff from the waste-treatment ponds and
nearby soil flowed into creek branches that run through the
site, moving mirex contamination into the Middle Fork of
Little Beaver Creek. Surface water and sediment control
structures were built on-site to prevent contaminant movement
until the final cleanups are complete.

Summary of  site risks
One of the main pollutants EPA found on the site is mirex.  It
is in the soil and in and around the former ponds. It is also
in the Middle Fork of Little Beaver Creek and  in the fish
that live in the creek. Other contaminants include VOCs in
ground water and the former ponds.
A document called an "endangermerrt assessment" considers
what the risk to people or the environment would be if the site

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   Evaluating the options                  \
 „  EPA ussd the foibwitsg nine criteria ia evaluate each
 '  of die options. ;Ths table oa Page,5 compares each one
                        '
    ^ €h*?ml/ PivteciiQriqfHwiwi Heafyh mdiks Kw&vrtm&it
     addresses wiuste m option adequately protects human
                   VHXsam^t^ This criteria m be met fey    .
                tainaong contaminants,' $r fey reducing      '
    'exposures to them.
    , Omplmtes witk Applicable or &?/eva??J and Appropriate
                , isfiared to as A&A&s, assures lhat each*
~  " buii&ag and operating Cite cleanup system snd wMher-
 - materials and s$tvic$$ are available to eait}> oMthe -;-'";
   project,  -      ,-^>,   ,  ,          ' " ' ;, -  ',  ;  -
7<- Coat isehfd® estimated capital or stsrt-up c^s, As
   example is the costpf bmldinga, treatment systems and
   monilorijig \velk~ It-alio considers c&sts to impfenitsM the
   cleanup aad operate aad ^aititaia it ov«r (toe, Exatajjlss.
   inclado laboratory ansJyw, f<^ij$ atid personuef Mtcd to
   operate cqaiptneat. A cleanup is considered cost effective
   if its cos.es sffi prcpoflionate to its Overall dTecttveae&sl
   3. Loitg-tsfm E^tivgfKiss attdPwmmettw, evaluates how
     well m option \vill work in the long term,, including how
     safely remaining coBtaiQinanfs. woi be managed.
   4 RsdscfitfR of &&d&\Mabil)$> or Vbfame through
                           «,ell U« optiosa reduces tl)e
                 s, moves»(Stt saA atsmniofcemtaminaais,
                          i$ how qw&ly the 0|?ti?.«oi «M fee
    ^ done, as well as its |>Qt«fttkl liarai to ft'ork'ers, residents
                                                              agency, ui ila$ ca&e Oteo EPA, agrees wjtli E?A's
°.
                           uates how wel fee community
       the site accepts die option, BPA and Ohio EPA will
   evaluate community acceptance after the pubJio coraroeiii
is not cleaned up.  There are no current risks to people living
near the site because the worst contamination is confined to
Ihe Nease property, which is off {imiis to the public. There is
some contamination in ground water, but nobody is drinking
that water today. Small animals that live on-site might be at
risk from contaminated soil.
In the future, if people were exposed to the contaminants,
the highest risk would be for those who use polluted ground
water.  People could also be exposed lo pollution by touching
dirt a( the site. Future health risks could include an increased
risk of cancer and other diseases, mainly from prolonged
exposure. People  who live or work in the area would be
most at risk because they have a greater chance of coming in
contact with contamination consistently over a period of time.
The less often people are exposed to the pollution, the lower
(he risk.

Cleanup options
EPA considered five options for cleaning up the Nease site,
each of which was evaluated against nine criteria as required
by law (see box above).  Each option has four parls because
the site has  four distinct areas, each of which has a different
contamination problem or physical condition, which may
require a different cleanup approach.  The areas are: Ponds 1
and 2, remaining ponds and soil, and shallow and deep ground
water.

Here are details on the five options
Option A:
No further action. Nothing additional would be done to
clean up, monitor or manage the contamination. However,
the existing systems that collect shallow ground water would
continue to run. These systems were originally built to collect
the worst ground-water contamination near Ponds 1 and 2.
Estimated cost: $4.7 million
Option B; (EPA recommends thfe optfon.)
Ponds I and 2 would be treated with a process called
"slripping/stabilizatioa/'soHdification," or S/S/S, This is
a unique combiaalion of methods io which a device wilh
rotating metal plates - similar to a large garden tiller turned
on its side - is sunk 15 to 20 feet beneath the surface of the
ponds. As the plates rotate, they chum up the chemicals
and bring them to the surface as air is injected through a
long lube. The chemicals are captured, treated and properly
disposed of before they can evaporate into the air. The device
cannot treat all the waste at once, so it will be used io  several
different places within Ponds 1 and 2. When most of the
contamination has been removed from the former ponds, the

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device would be used to mix a cement-like substance into the
ground. This prevents any remaining contamination from
spreading,
Remaining ponds and soil would be covered with (hick plastic
sheets and a layer of clean soil.  This plasttc-and-soil cover
will prevent rain from soaking thaiugh and spreading the
remaining contaminants.  It wiH cover Ponds 1,2 and 7 and
Exclusion Areas A and B.  Other areas, such as Ponds 3 and
4, will be covered with clean soil only to prevent contact with
the contaminants.
Shallow ground water on the eastern side of the site would be
collected in a trench, pumped above the ground and treated
to remove the contamination.  The plastic sheets over the
ponds and contaminated soil will reduce the  amount of rain
that soaks through the dirt so there will be less contaminated
ground water.  If studies show it will work, the trench design
may be changed to allow treatment inside the trench with
some  combination of iron, biological treatment or carbon in a
series of treatment cells rather than pumping the water out.
Deep  ground water and (he southern area would be treated by
injecting a substance known as "nanoscale zero-valent iron."
These microscopic particles of specially treated iron clean the
ground water chemically. The advantage of this innovative
technology is that the iron particles flow with the ground
water, cleaning the underground aquifer as the water flows.
There are cracks in the bedrock under the site, and these tiny
iron particles will  reach into the smallest cracks.  Because of
the conditions at the Nease site,  this method is expected to be
more effective than traditional techniques used for cleaning
ground water.
Estimated cost: $19 million
Option C:
Ponds ! and 2 would be treated with a process called
"thermal desorption." In this approach, heaters are inserted
into the former ponds and the entire area is covered with a
temporary protective metal layer. Heat from the electrical
current causes the contaminants to evaporate. The vapors are
captured and treated.
Remaining ponds and soil would be covered with a layer
of clean soil to keep the contaminants in place and prevent
people or animals from coming into contact with them.
Shallow ground water would be treated by a series of cells in
the ground similar to Option B,
Deep ground water and the southern area would be treated by
injecting nanoscale zero-valent iron, the same as  in Option B.
Estimated cost: S24.7 million
                         fair captured Sfid ttestoKt} *
                                      m-sr*  ,/    >•--<-
                                 ,x  j ; va ',.  '
                               ^   '\">"% t*~
                                               /aonrf^

Option B ' /fjr Slripping/Sutbilizatum'Soluli/ication ofFt)rnief-Pr>nfb I itrtd2

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Option D:
Ponds I ami 2 would be covered with thick plastic sheets or
clay and clean soil, A cement-like substance would be poured
around the edges of the former ponds and injected below the
bottom of the ponds.  This would keep the contamination in
place, and the area would be monitored to ensure it does not
harm people or the environment.
Remaining ponds and soil would be covered wilh clean soil,
the same as in Option C.
Shallow ground water on the eastern side of the site would be
collected in a trench,  pumped above the ground and treated
to remove the contamination. This is similar to Option B,
without allowing treatment inside the trench because ground
water flow is expected to be too high.  Shallow ground water
in the southern area would be treated by nanoscale zero-valent
iron.
Deep ground water would use standard pump-and-treat
technology using a series of extraction wells. Water would
be pumped through these wells above the ground and treated
to remove the contamination. While pump-and-treat has been
used often, it may not work here because it is difficult to
pump contamination caught in bedrock cracks.
Estimated cost: $21.4 million
Option £:
Ponds 1 and 2 would be treated by the S/S/S process, the
same as in Option B.
Remaining ponds and soil would be covered with clean soil,
the same as in Option C.
Shallow ground water would be treated by a series of cells in
the ground, the same as in Option C,
Deep ground water and the southern area would be treated by
injecting nanoscale zero-valent iron, the same as in Option B.
Estimated cost: S13.8 million

Common features
Each option (except A) includes what EPA calls "institutional
controls." These include such measures as fences to limit
access to the site and deed restrictions to keep anyone from
building anything on the site in the future that would require
digging in restricted areas.  In addition, use of contaminated
ground water will be prohibited.  If new buildings are
constructed on the site, measures will be taken to prevent soil
vapors from seeping into them.
Each option (except A) also includes a cover or cap over the
former ponds and contaminated soil.  These areas would be
monitored after fee cleanuo to ensure that the cover continues
Evaluation of cleanup options for the Nease
Evaiution Criteria
1. Overall Protection o' Human Health and the Environment
2. Compliance with ARARs
3. Long-term Effectiveness and Permanence
4. Reduction of Toxiciiy, Mobility, or Volume Through Treatment
5, Short-term Effectiveness
6. Implementabiiiiy
7. Cost
8. State Acceptance
9. Community Acceptance
Chemical Site
Option A
No further
Action
D
D
D
B
[•\
B
$4.7 million
Option B
B
B
B
B
B
l*l
$19 million
Option C
B
B
B
B
S
I*]
$24.7 million
Option D
B
B
0
B
B
B
$21.4 million
Option E
B
B
B
B
B
B
$13.8 million
Ohio EPA supports EPA's proposed option, but will consider public comments
before final determination of state acceptance.
Community acceptance of the recommended option w;!! be evaluated after the
public comment period.
B ru!!y meets criteria Qj] Partially meets criteria CD Does not meet criteria
The recommended option, 6, is expected to give the best results by treating the waste and ground water. It is the option thai best meets the evaluation
criteria above.

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oEPA
      United States
      Environmental Protection
      Agency

      Region 5
      Office of Public Affeire (P-19J)
      77 W, Jackson Blvd.
      Chicago. IL 60604
                                    FIRST CUSS
                                        RETURN SERVICE REQUESTED
             x:t;|f::7^
              'Cutting-Edge' Techniques Proposed for Nease Cleanup
                                7'Ws fact sh&et is printed on paper made of racydad fibers.
to keep the contamination from harming people or the
environment. In some areas, natural processes such as
dilation, decay and evaporation will be allowed to clean
the ground water. Ground water will be monitored until
the cleanup is done.
Options C, D and E don't include a plastic cover. This
means more rain would soak into the ground, making
these options less effective on shallow ground-water
treatment.

Next steps
EPA and Ohio EPA will consider comments received
during the public comment period before choosing a
final cleanup plan. EPA will address: comments in a
document called a "responsiveness summary." This is
attached to die record of decision, which will outline the
final cleanup plan.
Risks from the contamination in the Middle Fork of
Little Beaver Creek will be discussed iu a future cleanup
proposal.  The actions already taken and those proposed
in this plan (except Option A) wifl ensure that no more
contamination reaches the creek.
Site-related documents may bs reviewed at:
EPA Region $JRecar3X>nt$r           s  *  ;
77 W. JsK&soaBlwC 76 Hoc   ''',, '' '
2 110 B. Aurora Road
           io -
Lepper Library %                  ^
303 K Lincoln. War
Lisbon, Ohio  -   -     -
Salem Public Library  ">    V  N  -  -
m £* Scale St,         " ; " -  ,    ~
Sa3cm,Ohio %  '%         \  '
CeitaJc EPA iDfoitsatiW), iocludiug this fa«t s
reviewed clectropicaUy at >www.epa,gov/regbt)5Mtes,  ^  -
AJI adDMisifativ« tecord, ^Mcb co«Jain$ detailed iaformatiloa
u|)0fl which the selection of& c]catiH|>,j>lan will be based,
is also located a* the-Salem Public Library and at &e EPA
Cbkago eSice.          ,     - « -    "  "   - >    ^ -

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Comment Sheet
U.S. Environmental Protection Agency is interested in your comments on the proposed cleanup plan for the Nease
Chemical site.  EPA will consider public comments before selecting a final cleanup for the site. Please use the space
beiow to write your comments, then fold and mail this form. Comments must be postmarked by Thursday, June 30.
If you have any questions, please contact Susan Pastor at (312) 353-1325 or through EPA's toll-free number at
(800) 621-8431. This comment sheet may also be faxed to her at (312) 353-1155. Those with electronic capabilities
may submit their comments via the Internet at epa.gov/region5/publiccomment.
                                                    Name
                                                    Address'
                                                    City	
                                                    Zip	
State"

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               (j s EPA Headquarters Library
                      Mail code 3404T
               1200 Pennsylvania Avenue NW
                   Washington, DC 20460
                        202-566-0556
Fold on Dashed Lines, Tape: Stamp, and Mail
Name	
Address
City	
Zip	
State.
                                          Susan Pastor
                                          Comruutiily Involvement Coordinator
                                          Office of Public Affairs (P-19J)
                                          EPA - Region 5
                                          77 W. Jackson Blvd.
                                          Chicago, 1L  60604

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