United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-88/038
March 1988
&EPA
Superfund
Record of Decision
Celanese Fibers Operations, NC
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, 11;;".t..~; 4 i -
. .,
REPORT DOCUMENTATION /1; REPORT NO. 12. 3. Recipient's Accession No.
PAGE I EPA/ROD/R04-88/038
4. Title and Subtitle 5. Regort Date
SUPERFUND RECORD OF DECISION 03/23/88
Celanese Fibers Operations, NC 6.
First Remedial Action
---\ Author(s) 8. Performine Oraanization Rept. No. - -
9. Performin. Oreaniution Name and Address 10. Project/Task/Work Unit No.
- -. --- ----
11. ContraclCC) or GrantCG) No.
CC)
CG)
-- ---- - -------
12. Sgonsorin. Orlanization Name and Address 13. Type 0' Report & Period Covered
U.S. Environmental Protection Agency
401 M Street, S.W. 800/000
\'lash ington, D.C. 20460 .-
14.
15. Supplementary Notes
16. Abstract (Limit: 200 wordSl Fiber Operations (CFO) site is occupied by polyester
The 450-acrece anese a
raw-material production facility, and is located in Cleveland County, mile north of I
one
,
Earl, Nor~h carolina. The plant facil i ties consist of the plant production area, 1
wastewater trea tmen t area, ~ormer waste disposal areas, land farm area, and recreation :
and tree farm areas south of the main plant. The plant began operations in 1960 as ;
Fibers Industries, Inc. and manufactured polyester polymer chip and filamen t yarn using I
.. , ,
~he cnemlca1s dlmethyl terephthalate and ethylene glycol. Celanese Corporatlon bougnt
1e facility in 1983. The CFO waste treatment plant was constructed in phases
;oncurrent with the manufacturing plant. This resulted in the disposal of chemical
wastes directly into a drainage ditch during the early years of operation prior to
completion of the waste treatment plant. Treated effluent has been discharged to
Buffalo Creek since the mid-l960s, when CFO completed construction of the treatment
plant. In addition to the discharge from the wastewater treatment plant, CFO also
discharges alum-treated bandcaster water directly to Buffalo Creek. Several areas
around the plant have been used for waste disposal, including old burning pits for
normal plant wast~s (polyester and trash), a glycol recovery unit sludge burial area,
and a former drum storage and staging area (drums contained solutions that failed to
(See Attached Sheet)
r lReDc?8'mnbt"a~~~ i~i~r1Ptors
celanese Fibers Operations, NC
First Remedial Action
contaminated Media: gw
Key Contaminants: VQCs (benzene, PCE), organics (phenols), metals (chromium)
b. Identlfiers/Open.Ended Terms
c. COSATI Field/Group
'.vailability Statement
19. Security Class (This Report)
None
21. No. ot P.ges~
75
-- ----- --
20. Security Class (This Page)
None
22. Price
(See ANSI-Z39.18)
See Instructions on RevetSe
OPTIONAL FORM 272 (4-n)
(Formerly NTlS-35)
Department ot Commerce
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EPA/ROD/R04-88/038
~elanese Fibers Operations, NC
irst Remedial Action
16.
ABSTRACT (continued)
polymerize) excavated and backfilled in the mid-1960s, and two soak-away ponds formerly
containing treated sanitary sewage. In addition, 4 areas of buried waste are located to
the north and outside the main plant perimeter fence: a polymer and fiber landfill, a
construction debris landfill, a 2l-acre sludge disposal area, and a drum storage area
which temporarily stored 2,000 to 3,000 drums of waste chemicals and solvents, including
lab packs, from 1970 to 1978. The drums were removed and disposed of offsite by 1978.
The primary contaminants of concern affecting the ground water include: VQCs including
benzene and PCE, organics including phenols, and metals including chromium.
The selected remedial action for this site includes: ground water pump and treatment
using air stripping, biological treatment, and carbon adsorption (if necessary),
followed by discharge to the onsite wastewater treatment plant. If the treatment system
effluent contains metals, such as chromium, above allowable discharge levels, the
effluent will be treated using chemical precipitation. The estimated present worth cost
for this remedial action is $2,032,000 with estimated present worth O&M of $1,069,230.
.
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DECIARATICN FOR THE ENFORCEMENT RECORD OF DECISICN
SITE: CELANESE FIBERS OPERATICNS
SHELBY, NORTH CAROLINA
Statement of Purpose:
This decision docuroent represents the selected r~edial action for this site
developed in accordance with CERCLA as amended by SARA, and to the extent
practicable, the National Contingency Plan. The State of North Carolina
concurs wi th the selected remedy.
StateITent of Basis
This decision is based upon the adIT-inistrative record for the Celanese Fibers
Operations Site. The attached index identifies the iterr.s which carprise the
adIT.inistrative record upon which the selection of a reITedial action is based.
Description of Selected Rerr.edy:
- This is Operable Unit One of the Rerredial Actions to be undertaken at the
Site. It is a control measure to ITitigate the threat of off-site
migration (via groundwater) of contaITination by organic cOITpounds. The
Feasibility Study (FS) for the contaITinant source control is in progress.
- Groundwater ContaITination
o Installation of extraction wells into bedrock at the periITeter of the
site.
o Installation of shallow extraction wells directly downgradient of
source area.
o PLurping of contaIT:inated water from interior wells to camon holding
tank then to the air stripping tower.
o All contaminated water transported frOIT the air stripping tower to the
biological treatIT-ent systerr\.
o Water requiring additional treatment p~ped to carbon adsorption
filtration unit.
o All water is to be discharged to the existing wastewater treatITent
systeIT as long as current NPDES perIT:it l~.itations are not violated.
-------
1-
-2-
Declaration
The selected remedy is protective of human health and the environroent, attains
Federal and State requir~,ents that are applicable or relevant and appropriate,
and is cost-effective. This remedy satisfies the preference for treatment that
reduces toxicity, mobility, or volume as a principal element. Finally, it is
dete~.ined that this remedy utilizes permanent solutions and alternative
treatIT,ent technologies ~o the waxllr.uro. extent practicable.
3 - :z3 - 4'8 .
cil C~
Lee A. DeHihns, III
Acting Regional AdITcinistrator
~
Date
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TABLE OF CCNl'ml'S
PAGE NUMBER
1.0 INImWCTIOO
1
5
2.0 SITE HISTORY
3.0 ~ CCNI'AMINANTS
4.0 DIsaJSSICN OF CLEANUP CRITERIA (ARARS)
18
20
5.0 SUMMARY OF PUBLIC HEAL11i E.VAU7ATI~
21
7.0 ALTERNATIVE EVALUATIOO
19
22
6.0 ENFORCEMENT ANALYSIS
8 .0 RECCMMENDED ALTERNATIVE
31
39
9.0 c:c:MMUNITY RELATIOOS HISIDRY
ATIA01MENTS
ATIACHMEm' NUMBER
1 .0 RESPOOSIVENESS SUMMARY
1
2.0 ArMINISTRATIVE RECORD INDEX
2
3 .0 STATE COOCURRENCE
3
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ENFORCEMENT RECX>RD OF DECISIOO
smt1ARY OF REMEDIAL ALTERNATIVE SELECTIOO
CELANESE FIBERS OPERATIOOS SITE
SHELBY, CLE.VEINID caJNTY, NO.Rm CAROLINA
1.0 INmXXJCI'ICN
The Celanese Fibers Operations Site was proposed far inclusion on the National
Priori ties List (NFL) in October 1984. A RE!It'.edial Imestigation (RI) and
Feasibility Study (FS) have been conducted at the site. . I)Je to unusual waste
characteristics at the site, more information will be required in order to
select a permanent remedy for the contaminated soils and the source material.
As a result, this site has been separated into Operable Units. Operable Unit
1, Groundwater Remediation, will be addressed 11QI. A remedial alternative for
the source and soils remediation will be selected in approx~ately one year.
The RI report for the whole site was finalized and presented to the public on
July 21, 1987 in a public meeti~. The FS, which develops and exarrines
alternatives for remediation of the site was issued in draft forn. to the public
on January 19,1988. A public rreeting to present the results of the FS was
held on February 3, 1988 in Shelby, North Carolina.
This Record of Decision has been prepared to sumrarize the rerredial alternative
selection process and to present the selected reIT.edial alternative for the
groundwater at the site.
Site Location and Descriotion
The Celanese Fibers Operations (CFO) site is a 450-acre property occupied by a
polyester raw-rnaterial production facility (Figure 1-1). The site is located
in south-central Cleveland County on North Carolina Highway 198. It is
approximately one mile north of Earl, North Carolina and six miles south of
Shelby. The nearest major city is Charlotte, North Carolina, 35 miles east of
Shelby.
The plant facilities consist of the plant production area, wastewater treatment
area, forn.er waste disposal areas, land farn. area, and the recreations and tree
farm areas to the south of the main plant.
The majority of the land surface reflects cultural modification by
'construction, and by cutti~ and filling. The original soil profile has
probably been either truncated or covered across much of the site, and was
never conclusively identified as undisturbed during the field imestigations of
the RI. The plant production area is predcrr.inantly covered wi th buildings and
paved or gravelled areas. However, to the east, toward the waste water
treat:Irlent area, the site becaties rrore open, with the majority of the land
covered by mpoundments, with grass and access roads in between. The sludge
land farm is north of the plant production area and overgrown with coarse
grasses. The recreation area and tree fam to the south have no facilities
related to the plant processes.
-1-
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FIGURE 1-1
SITE LOCATION MAP
CFO/ SHE1.BY,N.C.
S& ME JOB NO.117S-aS-OSOA
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1.0 Site History
Fiber Industries, Inc., a joint venture of Celanese Corporation and Irr.perial
Chemicals, Inc., was the original owner of the plant and operated it frat'. 1960
until 1983 when the Celanese Corporation bought out the facility. Celanese now
operates it as Celanese Fibers Operations (CFO).
Operations at the 'Shelby facility began in April of 1960. Manufacturing
operations included the production of polyester polymer chip and filament
yarn. The principal chemicals involved in polyrrer production are diJr:ethyl
terephthalate and ethylene glycol. Other small quantity additives include
titanium dioxide and antUnonY.
The CFO wast~ treatment plant was constructed in phases cOncurrent with the
manufacturing plant. ~ing part of the early years, chemical wastes were
discharged through a ditch draining in a generally easterly direction. The
ditch began near the western edge of what is nCM knCMn as the former drum
storage area, and travelled east to the northeast corner of the present
~.ergency spill ponds. The ditch was replaced with pipes when the waste
treatment plant became fully operational in the mid-1960's. In 1973, the plant
was expanded with the addition of a polishing pond, two emergency spill ponds,
and an additional aeration basin. The treated effluent fr~. the waste
trea~\ent plant is piped to a discharge point on Buffalo Creek.
The concrete-lined portions of the waste treatment facility include a chrCITate
reduction pond which is no longer in use, a digester, three equalization
basins, two aeration basins, and two clarifiers. The unlined plant units
include the three polishing ponds, two sludge ponds, and two emergency spill
ponds. .
In addition to the discharge frCIT, the wastewater treatnent plant, the Celanese
facility also discharges alum treated bandcaster water directly to Buffalo.
Creek. Bandcaster water is used to cook the polymer products. Both of these
discharges are covered by per.mits fram the North Carolina Department of Natural
Resources.
Several areas around the plant have been used for waste disposal. Nonr..al plant
wastes (pri~marily polyester and miscellaneous trash) were disposed of in old
burning pits located just north of the aeration basins. North and east of the
burning pits, Glycol ReCOIlery Unit (GRU) sludge was buried during the early
1960's in trenches. West of the GRU sludge burial area is a former drUIt'.
storage and staging area. Solutions which failed to polymerize were stored
here during the early 1960's. The drurT'.s were rar,Oled in the rr.id-1960's and the
storage area was backfilled. 1\10 soak-away ponds located west of the existing
aeration basins were used to contain treated sanitary sewage during the period
fram 1960 to 1969.
Four areas of buried waste are located to the north and outside of the main
plant perDT:eter fence. The polYITer and fiber landfill contains priJrarily
non-hazardous inert rr.aterials such as excavation spoil, polyrrer, and waste
yarn. The construction debris landfill contains it~s such as old cinder
-3-
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8 SINGLE VrUl. LOCATIONS
+ 10M. T1?LE VrUl. LOCATIONS
. ROc!( WONTTOR VrUl.S
LETTERS RE?REStNT WD..L DES1GNATIONS
Figure 3-1
-4-
F1GURE
WONITOR WEU.
LOCATION M"t,p
ero I s;£LBy, N.C.
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BOUNDARY
WEL.L.
NO.
1 L.AKE WURRAY PLASTICS. INC.
2 WOCRE T. PARK
:3 GRAHAM & MOORE T. PARK
1~ KAY COBB (GENE BETTIS)
19 BCB DovER
. 21 B. OF EO. NO.3 SCHCCl
30 JOE HOPSON
3~ WINFORD CLIVER
38 CLAUDE CLIVER
39 W.X LONG
S3 HARVEY LEE TOM
69 LINDA HART
79 JAMES ROBERT EL.L.IOTT
80 LARRY STEIN
81 JACKIE LAMBERT
82 CHIL.DREN'S HOME
100 BESS W. LAVENDER
101 NEW HOPE BAPTIST CHURCH
102 CLAUDE LAVENDER
OWNER
LEGEND
". SAMPLED WEL.L. LOCATION
8:A.I CPII'n
o ,. \0600
l ~... 1
Figure 3-2
-5-
FIGURE
OFF SITE WELL LOCAilON MAP
CFO / SHELBY, N.C.
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blocks and steel strappirg bands. Approximately 21 acres of the northwest
quadrant of the pr~rty have been issued permits by the North Carolina
Department of Natural Resources for sludge disposal since 1978.
IOl the period frem 1970 to 1978, approximately 2000 to 3000 drums of waste
chemicals and solvents, including lab packs, were stored temporarily in the
area known as the drun storage area near the former burnirg pits. All drums
were rem~ed from-the area by 1978 and sent to outside disposal facilities.
Investigation of the Celanese Fibers Operations Site began in October 1981 when
CFO contracted with the firm Soil & Material Engineers, Inc. (S&ME) to install
23 groundwater monitor wells. In conjunction with the ground'water monitor well
installation prograD'., SME also conducted a . hydrogeologic evaluation.
Subsequently, CFO initiated a groundwater sampling and analysis program under
the supervision of Davis & Floyd Laboratories, Inc.
Soil & Material Engineers, Inc. also conducted an electracragnetic survey and
excavated test pits at the site.
In October 1984, CFO was proposed for EPA's National Priorities List. Also in
October 1984, there were a series of meetings between the U. S. Emirom"ental
Protection ~ency (EPA) and cro to discuss the preparation of a W:)rk Plan for a
ReIT-.edial Imestigation (RI) and Feasibility Study (FS) by CFa's contractor,
S&ME. Concurrent with this, EPA's contractor, Carrp Dresser & McKee, Inc. (
-------
(concentrations to 90 ug/l). Of these groupi~s, members of the phthalate and
ketone groups were measured more frequently and at higher concentrations.
Examination of the groundwater quality data shows that the deeper wells in the
nests frequently have the higher concentration of organic car.pounds, suggesting
introduction of the carpounds to the groundwater in a recharge zone or thrcogh
the relic fracture system in the saprolite. Figures 3-1 and 3-2 show the
locations of on and off-site monitor wells used in this analysis. Table 3-1
summarizes the groundwater quality data.
Monitor wells in the waste-water trea~,ent plant area and the western terrace
of the lawn, however, generally have higher concentrations of contaminants in
the shallow wells. This is apparently due to the wells' locations within or
near the probable source areas. Groundwater quality data for monitor wells J,
ee, 0, and K within the probable source area most clearly indicates this
occurrence .
Elevated chranilml levels were reported at several on-site monitor wells during
the Phase II and IIA sarr.pling events. It appears that plant operations have
contributed to the chranilml potential, however, naturally occurring chrar.i1.lt\ in
the soil and rock are also possible sources.
Groundwater contamination is predar.inantly in the area underlying the western
terrace of the lawn and wastewater trea~ent plant based on the analytical
saIT,pling results. However, there are volatiles, semi-volatiles and ITetals 'Nhi~~
appear to trend frar. this area to the south-southeast tcward ITonitor '....ell nest
T, and are reported at other areas on certain sampling events.
Off-Site Monitor wells and Supply wells
Groundwater quality was measured at 19 off-site locations shown on Figure 3-2,
during the Phase I and IA groundwater sampling episodes. Concentrations of
volatile organic ccmpounds (VOCs) were measured in seven of the off-site wells
during the.Phase II' groundwater sampling episodes. Phase II saITpling consisted
of re-sarrpling seven of the wells showing higher concentrations of VOCs.
During Phase I saITpling, phthalate cocr-pounds were detected in eleven of the
off-site wells at concentrations typically ranging between 10 and 40 ug/l.
Exceptions were the Hopson and Tar. wells which reported di-N-butyl phthalate at
83 ug/l and bis (2-ethylhexyl) phthalate at 440 ug/l, respectively. None of the
phthalate compounds detected exceeded EPA water quality criteria.
Car,parisen of Volatile organic em,pound (VOC) analysis for both sarrpling
ep~sodes showed inconsistencies in both detected ~pounds and concentrations.
Phase I detected Hazardous Substance List (HSL) VOCs in 11 of the 19 wells
sampled at concentrations generally less than 80 ug/l. Exceptions were noted
at the Dover well where methylene chloride and acetone were reported at 680
ug/l and III ug/l, respectively, and at the Long well where methylene chloride
was reported at 967 ug/l. The phase II saITpling detected VOCs in four of the
seven wells in concentrations ranging frar. 5 to 14 ug/l. With the exception of
JaIT,es Elliott's well, which consistently detected trichloroethene (TeE), no HSL
volatile organic compounds were detected during Phase II above proposed or
existing standards.
-19-
-------
4.0 Discussion of Cleanup Criteria (ARARs)
Safe Drinking Water Act Maximum Contaminant Levels (MCLs) are the Applicable or
Relevant and Appropriate Standards (ARARs) for gt'oundwater at the federal
level. In a project meeting April 16, 1987, EPA indicated they would probably
defer to state criteria when more stringent than federal. Maxlmlm\ contaminant
levels were established by the State of North Carolina as given in 15 NCAC 2L.
These amendments established It\Ore stringent criteria for 5a1\e canpounds with
federal MCLs and add 46 additional canpounds. For the purposes of this
document, the North Carolina criteria are considered the ARARs for groundwater.
In discussions with personnel of the North Carolina Division of Environmental
Management, they have indicated that specific requests It'ay be needed for
canpounds for which standards have not been set.
Carparison of Groundwater to ARAR.s
The water quality standards for North Carolina groundwater were adopted fraT\
the Enviro~ental Protection Agency Standards.
The groundwater quality documented duriNJ the RI indicated that the follawiNJ
paIaIT',eters exceeded the standard in at least one monitor well during sarrpling
Phase II or I IA.
Substances
Total No. of Occurrences Ab:ve
Existina or Prcoosed Star.darc..s
-
*
*
l,l-dichloroethene
l,l-dichloroethane
trans-1,2-dichlorothene
benzene
methylene chloride
vinyl chloride
chloroform
chlorobenzene
carbon tetrachloride
1
2
1
10
17
1
9
5
2
*
*
*
*
*
*
*
Substances
Total No. of Occurrences Nx:Ne
Existing or Prop:)Sed Standards
o
o
o
o
o
o
o
o
o
o
phenols
tetrachoroethylene
chlordane'
chratlium
bar i lm\
iron
manganese
nickel
seleniurr.
chlorar,ethane
2
1
2
40
2
4
4
13
1
2
-20-
-------
'I11e majority of the ccnpounds, detected duril'XJ the RI abo.1e the standard,
occurred in wells loCated in the vicinity of the wastewater treatment area,
predarlinantly in D\Onitor well nest CC, and in the monitor well nest at location
T south southeast of this area.
5.0 Summary of Public Health Evaluation
A suite of indicator parameters was chosen, accordil'XJ to the guidelines put
forth in the Superfund Public Health Evaluation Manual (EPA, 1986), for
toxological interpretations and review purposes. Generally, this process
directs the selection of chemicals which best represent the hazards associated
with the site based on concentration in the emiromental medium of concern and
a relative toxicity constant. Application of this process, which is discussed
in detail in the Public Health Assessment in Appendix A of the FS report,
resulted in the selection of benzene, trichloroethylene (TCE),
bis(2-ethylhexyl) phthalate, lead, and chrallium as the indicator chemicals.
'l11ese were developed by considering the primary routes pf exposure as
groundwater and contact wi th surface and near surface soils.
Several assumptions were rr.ade in perforning the health evaluation. It was
assumed that chemicals present at the site could be transported off-site in
groundwater and be consurr,ed by persons within a I-mile radius of the site.
Further, .it was assumed that off-site ground',o/ater concentrations of indicator
chemicals would equal the mean concentrations present at the site.
1
,
A cCIT.parison of the total daily indicator chemical intakes for an adult and
child was made by assuming a daily water ingestion of 2 liters/day for adults
and 1 liter/day for children~ With the exception of bis(2-ethylhexyl)
phtryalate, this resulted in the est~ated total daily intakes of indicator
chemicals exceeding that allowed by ARARs for both children and adults.
The greatest non-carcinogenic health risks associated with potential indicator
chemical exposure are due to ingestion of lead. In Particular, young children
(less than 6 years old) may be very sensitive to the neurotoxic effects of lead
and should be considered the receptor population at greatest risk of developing
lead intoxication (EPA, 1984).
The non-carcinogenic health risks associated with the calculated exposures to
benzene, bis(2-ethylhexyl) phthalate, and trichloroethylene are considered
. minimal. There is no human evidence to suggest that exposure to these
chemicals at the calculated mean concentrations in groundwater wo.Jld cause
chronic health effects.
Trichloroethylene, benzene and bis (2-ethylhexyl) phthalate are considered
potential carcinogens. Est~~tes of the cancer risk associated with potential
exposure to these car,pounds are considered low. However, the calculated risk
due to exposure to benzene is higher than the risks associated with exposure to
bis (2-ethylhexyl) phthalate and trichloroethylene. It is noted that the
concept of "acceptable riskw due to chemical exposure is subject to ~uch
controversy, but the calculated cancer risks for exposure to trichloroethylene
and benzene are somewhat above the level considered acceptable by the EPA,
while the risk for bis(2-ethylhexyl) phthalate is below this level.
-21-
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The public health e'Jaluation concluded that there is the potential for exposure
to the indicator chemicals at levels above accept~le concentration levels and
some potential for carcinogenic risk above the 10 risk level by
down-gradient users based on a conservative scenario. Due to this potential,
the No Action alternative is considered not viable at the CFO/Shelby site.
6.0 Enforcement Analysis
The Celanese Site was added to the NFL in June of 1986 and EPA assumed lead
responsibility for the site at that time. The Celanese Company has operated a
plant on that site since 1960. Celanese initiated groundwater studies in
1981. Negotiations for the RI/FS consent agreement were concluded with the
signing of the document by both EPA and Celanese on March 10, 1986.
Informal negotiations to de'Jelop a consent decree for Celanese to perform the
Remedial Design/Rerr.edial Action are under way. Forn.al negotiations will
commence shortly after the ROD is signed.
7.0 Groundwater Remedial Alternatives
Rerr.ediation of the groundwater can be initially divided into two areas of
rerredial effort: those areas with high Total Organic Carbon (TCC)
concentrations near the suspected sources, and those with lower TCC
concentrations which are ffiore remote fram the source and near the property
boundary .
Rerredial technolcgies for controlling groundwater contardnation problars
generally utilize one of the following techniques:
! .
A.
Capping - involving an irr.pern,eable ccver to reduce infiltration of
water. .
B.
Groundwater pUIT.ping - involving extraction of water fr~ and possibly
injection of water into wells to capture a plume or alter the
direction of groundwater ~ovement.
C.
Subsurface drains - consisting of gravity collection systerrs designed
to intercept groundwater.
D.
Subsurface barriers - consisti~ of a vertical wall of low
permeability materials constructed underground to divert groundwater
flow or minimize leachate generation and plume IToverr.ent.
E.
In-situ treatment to biolcgically or chemically remove or attenuate
contaminants in the subsurface.
F.
Surface treatment of contaIT\inated groundwater after it has been
rerroved.' This includes air-stripping, activated carbon treatrr,ent,
etc.
G.
The "No Action: alternative involves monitori~ only, .no active
treatment.
-22-
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These technologies can be used singularly or in ccnbination to control
groundwater contamination.
A.
Capping
The use of capping as a groundwater remediation technique is
detrimental to moqing the residual contaminants to a r~\oval point.
Due to the high water solubility of ethylene glycol and other
compounds present in the contaminated soil, they lend th~selves to a
soil leachirYJ technology and subsequent collection through groundwater
pumpirYJ stations. Precipitation will serve as a oontinuirYJ natural
solvent to sustain this leachirYJ action. In addition the potential
for utilization of supplemental spray irrigation of either treated or
recycled groundwater would prov ide .for acceleration and increased
efficiency of the soil leachirYJ program. Therefore, the utilization
of capping would interrupt the ability of either natural or rna~ade
systems to enhance the leaching, and cappiD;J is not being considered
further in conjunction with the groundwater remediation.
B.
Groundwater PuIT~irYJ
Groundwater pUIT;ping techniques involve the active ITanipulation and
ITanagement of groundwater in order to contain or reIT~e a plUIT~ or to
adjust groundwater levels in order to limit formation of a pl1JI'C\e.
Types of wells used in reanageIT,ent of contaITinated groun6~ater include
wellpoints, vacuum wells, and deep wells. The selection of the
appropriate well type depends upon the depth of contaIT'.ination and the
hydrologic and geologic characteristics of the aquifer involved.
well systeITS are versatile and can be used to contain, reIT.ove, divert,
or limit devel~.ent of plUIT.es under a variety of site conditions.
Groundwater pUITping is most effective at sites where underlying
aqUifers have high intergranular hydraulic conductiv i ty. However, it
has been used with varying effectiveness at sites with moderate
hydraulic conductivities and where pollutant mov~ent is occurring
along fractured or jointed material.
Where plUIT.e containment or removal is the objective, either extraction
wells or a ccrobination of extraction and injection wells can be used.
The use of extraction wells alone is best suited to situations where
contaminants are soluble with water, where the hydraulic gradient is
sufficiently steep, the hydraulic conductivity is adequate, and where
quick removal is not necessary.
A COITbination of extraction and injection wells is frequently used in
containIT~nt or recrloval where the hydraulic gradient is relatively flat
and hydraulic conductivities are moderate, or to accelerate the
ranoval time frame. Groundwater pumping systeITS are the most
versatile and flexible of the groundwater control technologies.
Operational flexibility is high since pumping rates can be modified to
adjust to changes in flow rate. System perforITance is generally good
provided the wells are properly designed and maintained.
-23-
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At the CFO/SHELBY facility, groundwater pUITl.pi~ prO/ides a viable
control and "remediation technology for clean-up of the grouncr,.,ater
contamination present. Its utilization in conjunction with treatment
of contaminated groundwater"pr~ides the potential for a remediation
program allawing for containment of the existing contardnation to its
present boundaries. This technology is, therefore, retained for
further consideration.
C.
Subsurface Barriers
D.
The term subsurface barriers refers to a variety of methods whereby
law pern.eability cut-off walls or diversions are installed belCM
ground to contain, capture, or redirect groundwater flaw. The rrost
ccmr.only used subsurface barriers are slurry walls, particularly the
soil-bentonite type slurry wall. Less ~on are cement-bentonite or
concrete slurry walls, grouted barriers, and sheet pile cut-offs.
This technology is eliminated, as other, more permanent rar.edies are
readily available.
Subsurface Collection Drains
Subsurface collection drains include any type of buried conduit used
to collect and corney discharge by gravity flCM. Subsurface
collection drains essentially function like an infinite line of
extraction wells and can perforrr. rrany of the SaIT.e functions as wells.
They can be used to contain or rE!n'.~e a plume, or lower the
groundwater table. The decision to use drains or purr.ping is generally
based on cost effectiveness and irrplementability analysis. For
shallow contaIT,ination problars, drains can be more cost effective than
purr.ping. The biggest drawback to the use of subsurface drains is that
they are norrrally lirr,ited to shallow depths.
Again, due to the geologic conditions, topography of the site, extent
o~ contamination and availability of rrore technically feasible and
cost effective technologies, subsurface collection drains are not
being considered further.
E.
In-Situ Treatment
In-Situ treatI'llent of the contaminated ground water does not
appear to offer a potential for technologically or cost effectively
treating the groundwater conditions. The physical difficulty and high
costs associated with pr~iding the nutrients and oxygen required to
stimulate and sustain aerobic biological activity withih the existing
groundwater would be extensive. Therefore, this technology is
eliminated fran further discussion.
F.
Surface Treatments
Air Stripping
Air stripping is the rr.ass transfer process in which volatile
contaIT:inants in water or soil are transferred from their carrbined
state to a gaseous state. Four c~reonly used rrethods for air
stripping liq\Jids are the packed colurrU1, cross-flow tower, coke tray
aerator, and diffused air basin procedures.
-24-
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Air strippiTXJ is most cam.only aCCCITiplished in a packed tower equipped
with an air blower. The packed tower works on the principle of
counter-current flow where .the water stream flows down through the
packi~ while the air is blown upward, and is exhausted through the
top. Volatile, soluble CCITiponents have an affinity for the gaseous
phase and tend to leave the aqueous stream for the gaseous phase. In
the cross-flow tower, water flows down through the packi~ as in the
counter-current packed column: however, the air is pulled across the
water flow by a fan. The coke tray aerator is a simple, low
II'.aintenance process requiring no blower. The water being treated is
allowed to trickle through several layers of trays. This produces a
large surface area for gas transfer. Diffused aeration stripping and
induced draft strippi~ use aeration basins sLmilar to standard
wastewater treatment aeration basins. Water flows through the basin
fran top to bottan or fran one side to another with the air dispersed
through diffusion at the bottan of the basin. The air to water ratio
is significantly lower than in either the packed col~~ or the
cross-flow tower units.
Air stripping is normally utilized to r~~e volatile organics frccr.
aqueous waste strearr.s. Generally carponents with Henry's Law .
constants greater than 0.003 can be effectively reIT.oved by air
stripping. The waste feed streaI'll. It'-USt be lCM in suspended solids and
may require pH adjustment to reduce solubility and iITprove transfer to
the gaseous phase.
Stripping is sCIT~tiITes only partially effective in groundwater
treatIT,ent and ITust be followed by other processes such as biological
treatITent and carbon adsorption. The cccrbined use of air se;ipping
followed by other applicable processes can be an effective ~eans of
rar.oving the contarrinants frCIT. groundwater.
In recent years, air stripping has gained increasing use. It has been
used cost effectively for the treatment of low concentrations of
volatiles or as a pre-treatment step prior to subsequent treatIT,ent
technologies. EquipIT.ent for air stripping is relatively siITple,
start-up and shut-down can be accCIT,plished quickly, and the ITodular
design of packed towers makes them saT,ewhat mobile in their
application.
An ~portant consideration in the utilization of the air stripping
technology is the llrplications of the air pollution which IT~Y result
fran the stripping operation itself. The gaseous stream generated
duri~ air stripping IT.ay require collection and subsequent treatIT~nt.
Because of the concentrations of volatile organics present in the
contaminated groundwater at the site, air stripping IT3Y be applicable
both as a priIT.ary and supplarental remediation technology. Therefore,
this treatment technology will be retained for further consideration.
-25-
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Activated Carbon TreatIr.ent
The process of adsorption onto activated carbon involves contacting a waste
stream with the carbon, normally by.flow through a packed bed reactor. The
activated carbon process can be designed to selectively adsorb hazardous
constituents by a surface attraction phenomenon in which organic molecules are
attracted to the internal pores of the carbon granules.
Adsorption depends upon the strength of the molecular attraction between
adsorbent and adsorbate, molecular weight, type and characteristics of the
absorbent, electrokinetic charge, pH, and surface area. Once the micropore
surfaces are saturated with organics, the carbon is spent and must either be
replaced with virgin carbon or reroO'Jed, thoroughly regenerated, and replaced.
The time to reach breakthrough or exhaustion is the single ITOSt critical
operating parameter. Carbon longevity balanced against influent concentration
gO'Jerns operating econanies. In the event that the carbon is regenerated
on-site, the supernatant from this process will be processed through the system
constructed for treating the site groundwater.
Activated carbon adsorption is a well-developed technology which is widely used
in the treatment of hazardous waste steams. It is especially well suited for
the rerrlO'Jal of mixed organics frar. aqueous wastes. Since carbon adsorption is
an electrical interaction phenomenon, the polarity of the waste carpounds will
determine the effectiveness of the adsorption process. The Ifore hydrophobic
( insoluble) a molecule is, the It'ore readily the car.pound is adsorbed. As a
result, low solubility hUIf.ic and fulvic acids which are present in G~e
groundwater can adsorb to the activated carbon more readily than If4ny waste
contaIf.inants and result in rapid carbon exhaustion. Also, sar.e Ifetals and
inorganic species have shown excellent to good adsorption potential. These
include antirrony, arsenic, bisrr.uth, chrar.iUIfl' tin, silver, mercury, cabal t,
zirconiUIf., chlorine, brar,ine and iodine. Activated carbon can also be utilized
in the powdered form which offers the advantages of greatly increased surface
area availability and reduced costs.
Carbon adsorption technology can be used either in conjunction wi th or
following biolCXJical treatment and/or gravity filtration. Its purpose in this
application is to remO'Je the refractory organics which cannot be biologically
degraded. The biolCXJical treatment and/or granular media filtration steps
prior to carbon adsorption reduce the organic and suspended solids load to the
carbon adsorption units. Reduction of organic and suspended solid load
minimizes carbon usage and regeneration costs. Air stripping has also been
applied prior to carbon adsorption in order to reduce a portion of the volatile
contaminants and reduce the organic load to the carbon adsorption units.
Activated carbon usage is easily implemented into or along with other treatment
systeros. The process is well suited to mobile units as well as to on-site
construction. Space requireITcents are small and start-up and shut down are
rapid. '.
-26-
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Regeneration of spent carbon for reuse is the highest operating cost associated
with the utilization of carbon adsorption technology. In addition, high
capital costs can be associated with its use. Both capital and operating costs
can be substantially reduced through pretreatIr,ent of the waste pr ior to its
treatment with carbon adsorption.
Activated carbon treatment will not be utilized in a pri1r.ary ratledial
technology role at the site, but may be used as a supplatlentary technique in
conjunction with other clean-up technologies. This technology will be retained
for further consideration.
Precipitation/Flocculation
Precipitation is a physiochemical process where same or all of a substance in
solution is transformed into a solid phase. The technology is based upon
alteration of the chemical equilibrium relationships affecting the solubility
of an inorganic species. R~al of metals as hydroxides or sulfides is the
most cammon precipitation application in wastewater treatment.
Precipitation is applicable to the ratlOJJal of most metals frar\ wastewater,
including zinc, cadrr.ium, chrat\ium, copper, lead, manganese, and rr,ercury.
Certain anionic species such as phosphate, sulfate'and fluoride can also be
remOJJed by precipitation. The technology is useful for most aqueous hazardous
waste strearrs. However, organaretallic carplexes with metals can inhibit
precipitation. Cyanide and other constituents ~ay also ccrr,plex wi~~ rretals,
thereby, reducing the treatrrent efficiency of precipitation.
Precipi tation and flocculation are well-established technolcgies. Ii.
disadvantage is that precipitation is non-selective and that ccrrpounds other
than those targeted rr,ay be rar.OJJed. Both precipitation and flocculation are
non-destructive and generate a large volume of sludge which rrust be disposed of
ultirr.ately.
This technology will be retained for further consideration.
Biological Treatment
Biological treatrr.ent is utilized to remOJJe organic matter fram a waste strearr
through microbial degradation. The most canr.on type of biological treatrrent is
aerobic (in the presence of oxygen). A number of biological treatrr.ent
processes exist which are used for the treatment of aqueous hazardous wastes.
They include conventional activated sludge, modifications of the activated
sludge process, pure oxygen activated sludge, extended aeration, and contact
stabilization. Fixed-film systatls include rotating biological discs and
trickling filters.
In the conventional activated sludge process, waste flows into an aeration
basin where it is aerated for several hours. tXlring this tirr,e, a suspended
active microbial population aerobically degrades the organic rratter in the
waste stream along with producing new cells. A siffplified equation for this
process is:
-27-
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Organics + 02 ~> C02 + H20 + new cells
The cells produced during aeration along with other precipitated ~aterials form
a sludge which is settled out in a clarifier. The clarified water then goes to
disposal or further treatment.
Fixed-film systems irwolve contact of the aqueous waste stream with
microorganisms attached to sane inert medium such as rock or spec'ially designed
plastic ~~terial.
Biological treatment has considerable flexibility due to the variety of
processes available and the adaptability of the microorgani~s themselves.
Most organic chemicals are considered biodegradable, although the ease of
biodegradation varies widely. Several general observations can be made with
regard to the ease of treatability of organics by aerobic biological treatment:
o
Unsubstituted non-arar.atics or cyclic hydrocarbons are preferred CNer
unsubstituted arCIT-atics.
o
Materials with unsaturated bonds such as alkenes are preferred CNer
~aterials with saturated bonds.
o
Soluble organics are usually more readily degraded than insoluble
materials. Biological treatment is more efficient in reIT.CNing
dissolved or colloidal ~aterials, which are readily attacked by
enzYIT.es. This is not true for fixed-film treatITent systeITS which
preferentially treat suspended matter. .
o
The presence of optional groups effects biodegradability.
aldehydes, acids, esters, arrides, and arr,ino acids are ITore
biodegradable than corresponding alkanes, olefins, ketones,
dicarboxylic acids, nitrites, and chloroalkanes.
Alcohols,
o
Halogen-substituted compounds are the most refractory to
biodegradation.
Industrial type wastes ~3Y not be readily amenable to biological treatITenti
however, ~.icroorganiSIT.s can be accliIr.ated to degrade rr.any car,pounds that are
initially relatively non-biodegradeable.
Additionally, heavy metals may be inhibitory to biological treatment, but the
biomass can be acclimated, within limits, to tolerate elevated concentrations'
of metals.
The cCIT-pletely mixed activated sludge process is the most widely used with high
organic loads, and high purity oxygen systems have advantages for hazardous
waste site remediation. However, a nUITber of other parameters influence the
perfornance of the biological treatITent systar-. These pararr,eters are the
concentration of suspended solids, oil and grease, organic load variations,
and teITperatures. .
-28-
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Biological treatment has not been as widely used in hazardous.waste site
remediation as activated carbon adsorption, filtration and
precipitation/flocculation. However, the process is well established for a
wide variety of organic contaminant~.
Although biological treatment can effectively treat a wide range of organics,
it has several disadvantages in conjunction with hazardous waste site
applications. The reliability of the process can be impaired by "shock" loads
of toxics. In addition start-up times can be slow if the organisrr,s need to be
accl~ated to the wastes and the detention time can be long for cOIT,plex
wastes. The existence of an accl~ted culture can dr~atically decrease
start-up and detention time.
Rotating biological contactors have the advantages for use at hazardous waste
treatrr,ent sites in that they are carpact, can handle large flow variations and
high organic shock loads. In addi tion they- do not require the. use of
mechanical aeration equipment.
The sludge produced in biological waste treatment process It'ay be a hazardous
waste itself due to the sorption and concentration of toxic and hazardous
COIT,poundS contained in the wastewater. If the sludges are hazardous, it rr,ust
be disposed of in a RCRA-apprO\led manner. If the sludge is non-hazardous,
disposal should confo~, with state sludge disposal guidelines. Biological
treatrr,ent has been screened and determined to be a viable treatrr,ent alternative
for the site contamination present. A more detailed discussion of its use is
included in the remedIal action portion of ~~is report.
Ion Exchange
Ion exchange is a process where the toxic ions present in a waste strearr are
remO\led by being exchanged with relatively harrr.less ions held by the ion
exchange material. Ion exchange resins are priITarily synthetic organic
materials containing ionic functional groups to which exchangeable ions are
attached. These synthetic resins are structurally stable (can tolerate a range
of temperature and pH), exhibit a high exchange capacity, and can be utilized
to selectively exchange ions.
Ion exchange can be used to remO\le a wide range of inorganic species frOIT. water
such as:
o
all metallic elements when present as soluble species, either anionic
or cationic
o
inorganic anions such as halides, sulfates, nitrates, cyanides, etc.
o
organic
acids
such as carboxylics, sulfonics, and same phenols
o
organic amines
-29-
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Sorptive resins can also rar,O'Je a broad range of polar and non-polar organics.
A practical upper limit for ion exchange is about 2,500 to 4,000 mg/l (ppr).
Suspended solids in the feed stream should be low, less than 50 rrq/l (ppr,) to
prevent plugging the resin, and the waste stream must be free of oxidants.
Ion exchange is a well established technology for heavy ~etal remO'Jal and
hazardous anion remO'Jal fran dilute waste solutions. A problE!fl\. which exists
with the ion exchange technology is the disposal of contaminated regeneration
solutions. Consideration should be given to selection of these solutions when
evaluating the technology.
Based on the data available for this screening, the contaminants present,
amenability of other treatment technologies, and costs, ion exchange is not
being considered for further evaluation. as a rE!fl\.edial technology at CFO/SHELBY.
Filtration
Filtration is a physical process where suspended solids are remO'Jed frar.
solution by forcing a fluid through a porous medium. Granular ~edia filtration
is norrrlilly used for treating aqueous waste strea11ls. '111e filter media
(generally sand) is contained within a basin and is supported by an underdrain
system which allows the filtered liquid to be drawn off while retaining the
filter media in place. As the wastewater laden with suspended solids passes
through the filter media, the solids becCIT'.e trapped on top of and within the
bed. To prevent plugging, the filter is backwashed at high velocity to
dislodge the solids. The backwater produced contains high concentrations of
solids and requires further tream.ent. .
The granular media filtration process is only Irarginally effective in treating
colloidal size particles. Filtration equiprent is relatively siIrple, readily
available, easy to operate and control, and to integrate with other treatrrent
technologies. There is also extensive experience with the operation of
granular media filters at hazardous waste sites.
Although granular media filters are a cost effective and efficient tream,ent
technique in a wide variety of applications, filtration as a priIrary rE!fl\edial
technology does not appear to be needed. Therefore, this technology is
eliminated fram further consideration.
G.
NO AcrIOO ALTERNATIVE
A number of consideration must be made in evaluating the effects of
choosing a No Action Alternative. Under the No Action Alternative,
groundwater would remain contaminated with substances that rray be
regulated by local, state, and federal laws. The No Action
Alternative would not prO'Jide rar,edial action to reduce rrobility,
toxicity or vol~.e of contaminated soil. Possible socioeconomic
icr,pacts of the No Action Alternative include the following:
*
*
Decline in property values
Expenditure for legal services
Depressed area growth
Restricted access to site
Public and environrr.ental exposures
*
*
*
-30-
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The Remedial Investigation concluded that groundwater contamination
had not migrated past the 5i te boundaries at that tUr,e. HCJWe'.1er, the
investigation did not identify a constraint to off-site migration if
the measured groundwater contamination was not abated.
The Public Health Assessment was presented in Appendix A of the
Feasibility Study and evaluated the effects of exposure to selected
indicator car.pounds at the average concentration measured in the site
rr.onitor wells. [)Je to the fact that four out of five indicator
compounds were above acceptable contaminant levels, and due to the
proximity of off-site private wells' used for residential drinking
water supplies, the health assessment concluded that the No Action
Alternative was not viable at the site.
8.0 Recarrnended Alternative
The recamended alternative for remediation of groundwater contamination at the
Celanese Fibers Operations Site includes extraction of contaroinated water and
treatment in an on-site treatment system. This alternative will cost
approxtmately $2 million, including operation and maintenance costs for an
estimated 30 year period (Table 8-1).
The groundwater rer!'.ediation prograrf will consist of rer.cv ing the groundwater
through two tiers of extraction wells, and subsequently treating the water with
a cCIT-bination of treatment techniques in a specified sequence. . The first tier
of wells will be constructed near the eastern periIreter of the property as
shown on Figure 8-1. A second tier of extraction wells will be installed in
the area of highest contaminant concentration within the interior of the plUIT.e,
also shown on Figure 8-1. The first tier of extraction wells will be located
in a zone of lower contaIT.inant concentration than the second tier of w~115, and
therefore, the treatITent of the pumped groundwater will not need to be as
extensive or carplex as that associated with the interior plUIi.e groundwater
reIT.ediation effort.
The areal and vertical extent of the plume to be removed was developed frar, the
total organic carbon (TOe) concentrations. A review of the data indicated that
the bulk of the contamination in the groundwater appeared to be in the
intermediate depths (30 to 50 feet) to rock (50 to 80 feet). FurtherIT.ore, the
total organic carbon plUIT'.e in general incorporates most of the areas showing
elevated metals concentrations. Thus, the groundwater extraction system
proposed for remcving the total organics present should also be capable of
remcving the metals involved.
The groundwater treatment alternatives being proposed can initially be divided
into two'areas of rer.edial effort. Those areas with high TOe concentrations
near suspected contaminant sources, and those with lower TOe concentrations
more rerficved frat\ the sources.
Table 8-2 lists sat\e of the constituents identified in the groundwater at the
site, and applicable priIr.ary and secondary treatment technologies. The priIr,ary
treatment technologies proposed for treating the extracted groundwater are air
stripping and biological treatIT.ent.
-31-
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Table 8-1
Cost Estimate
Ground-Water Extraction System
Objectives:
To intercept
ground water
area.
a.nd trea t
emanating
the existing contaminated
from the primary source
Ground Water Extraction System
Installation
A. Well Installation (maximum of 16 wells)
B. Trenching/Electrical
C. All Weather Road
D. Ground-Water Treatment System
Subtotal
D. Enginee~ing Fees (10% capital costs)
E. Permitting (5% Capital Costs)
. C8ntingency (20% ca~ital ccs~s)
S-..:btotal.
G. Ope~aticn and Maintenance
(30 year pe:-iod)
Total
-32-
.I
$177,820
$160,000
$125,000
$250,000
$712,820
$72,000
$36,000
S2.42,000
$962,820
Sl,06?,2JO
$2,032,050
-------
o
NOTE'
"If. BURN PITS. GLYCOl RECOVERY
SI.UOGE PITS NlO MEA OF' GRU SLUDGE
I "'ACKING WERE TN<£N FROM IISTORICIt,
: N:/U~ PHOTOS.
" 1-
"'" ' -
, PROPERTY
LINE
~~"-
/"f" ~ "- ~ ~
"-~
'''-.
GG.
,
,
1
\
\
~
,
'~
''''1_'1 -
"" .....
.
M
LEGum
. EXISTlIIG MOUlTOn WELL
~ DURN PIT
I' GI. YCOL RECOVERY
SLUDGE Plr
~ NIE" or Gnu ~LUOGE
V'TRACKING ISMENtING)
E - EQUNJZATION DASIN
C - CLNlInER
o - DIGES rER
NJ - o'fRATION BASIN
SP - SLUDGE POND
EP - EMF.RGENCY rOND
,PP - POLlSIIIUG rOllo
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-------
Table 8- 2
Primary/Secondary Treatment Technologies For
Selected Compounds Found in Extracted
Ground Waters
Constituent
Chromium
Acetone
Other Ketones
Car~on Tetrachloride
Chloroform
1,1 - Dichloroethene
1,1 - Dichloroethane
Trans-1,2-Dichloroethene
Me~hylene Chloride
Methyl Chloride
Trichloroethene
Benzene
Chlorobenzene
Toluene
Vinyl Chloride
Phenol
DowTherm
Penanthrene
Anthracen~
Chrysene
Nitro-Di-N-Propylamine
Di-N-Butyl Phthalate
Bis (2-Ethyl hexyl
Phthalate)
Chloroethane
1,2-DichlorQethane
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Bromodichloromethane
Tetrachloroethene
1,2 Dichloropropane
Bromoform
1, 1,2, 2-Tetrachloroethane
2-Chloroethylvinyl ether
Dibromochloromethane
Ethyl benzene
1,2-Dichlorobenzene
Styrene
*
Wl'~~ ~Q ~. -- t
'-.. :-u al....J us ,-_.en
Primary Method
of Treatment
Secondary Method
of Treatment
Precipitation *
Air Stripping
Air Stripping
~ir stripping
Air stripping
Air Stripping
Air Stripping
Air stripping
Air Stripping
Air stripping
Air Stripping
Air stripping
Air stripping
Air stripping
Air stripping
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air stripping
Air Stripping
Air stripping
Air stripping
Air stripping
Air Stripping
Air stripping
Air Stripping
Air Stripping
Biological
Biological
Biological
Biological
Biological
None Known
Biological
, Biological
Biological
Air Stripping
Air Stripping
Air Stripping
Air Stripping
None Known
None Known
Biological
-34-
-------
Table 8-2 indicates that the constituents present in the groundwater are
amenable to either one or more of the proposed treatIT,ent technologies being
considered.
The groundwater treatment alternative. recommended for the areas with high total
organic carbon concentrations (interior wells) will consist of air stripping
and biological treatment, follONed by carbon adsorption, if needed. The
extracted groundwater will be pumped freIT-. the interior tier of wells to a
cammon equalization/sedimentation tank where suspended solids will be r~.cwed.
Utili~ation of the equalization/sed~.entation tank will minimize the suspended
solid material present, and will pr~ide a blended stable flON stream from the
four extraction wells for the subsequent groundwater treatment
The equalized flON will then be p~.ped to the air stripping tower where the
volatile organic fraction will be removed or reduced.
Volatiles present in the groundwater such as vinyl chloride: methylene
chloride: l-l-dichloroethene, l,l-dichloroethane: trichloroethene: etc. should
be reduced 90 to 98 percent by air stripping. Serri-volatile rer,~al should
range between 30 to 80 percent at aIT'bient air temperatures.
The stripping tower effluent will then be pUITped to ~ biological trea~~ent
syster. No specific biological treatIT.ent process has been selected. As the
data from the p~.ping test are evaluated in the te~,s of expected variations in
concentrations, flow variations, constituents, etc., a decision will be ITade
regarding the preferred method of biological treatIT.ent.
The effluent frCIT the biological treatIT:ent will be discharged to a carbon
. adsorption unit designed for this anticipated flew. This unit will be used as
a final treatIT,ent step to rerove refractory organics that may reITain after
biological treatIT.ent.
Effluent frCIT: the treatITent syster. will be discharged to the existing
wastewater treatIr.ent plant for discharge under the existing North Carolina
NPDES discharge permit. In cases where metals, such as chromium, are present
in the treatment systecr: effluent ~e allowable discharge levels, the effluent
will be passed through a cheIT\ical precipitation step prior to final. discharge.
The groundwater treatment alternative proposed for the areas of lower total
organic carbon concentration (periIT,eter wells) will consist of air stripping
followed by carbon adsorption. Because of the ION concentration of
constituents expected in this area and their general aIT,enability to the use of
air stripping for rem~al, the utilization of biological treatIT,ent is not
anticipated. Thus, the effluent from the air stripping unit will be discharge
to a carbon adsorption unit for final treatment prior to discharge. The carbon
unit will be designed to handle the anticipated maxiITum flON from the periIT,eter
well system. Again, should problerrs with ITetals be encountered, a
precipitation step will be added to the treatIT,ent sequence being er.ployed.
Treated water fram the groundwater treatIT.ent syster. will be discharged in the
SaIT,e manner as discussed previously for the groundwater fram the interior of
the plUIT:e.
-35-
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This recamIT,ended alternative meets the requirements of the Natlonal Oil and
Hazardous Substances Pollution Contingency Plan (NCP) 40 CFR, 300.68(j) and the
Superfund Amendments and Reauthorization Act of 1986 (SARA). This alternative
pe~anently and significantly reduces the mobility of hazardous contaminants in
the area groundwater. The recamended alternative for the source material will
be' determined at the end of the additional studies.
Technical ElJaluation
Performance of a remedial action is determined basically by its effectiveness
and its life expectance in performing its specified function. Effectiveness
refers to the degree to which an action will meet the rar.ediation goal, which
is a reduction of toxicity, mobility, or volume of cont~.ination or the rar.oval
of exposure routes. The effective life is the length of time this level of
effectiveness can be maintained.
Both the groundwater extraction system and groundwater treatment system
proposed can be considered to be effective in their remedial efforts. They
address the questions of reduction of toxicity, ~obility, and volUIT.e of
contamination in a very positive manner. In addition, they also have a
positive effect on the reIT.oval of a potential exposure route, the ground water.
Reliability is the degree of assurance that the particular reIT,edial action
being considered will rreet or exceed the e~ctations for its perfo~ance, the
likelihood that ~echanical and process failure.will occur, and the consequences
of such failures. This is directly related to the carplexi ty of the equiprent
and process selected for the remediation effort. IITportant considerations
concerning reliability are operation and rraintenance requireIT.ents, and the
deIT,onstrated performance of siITilar applications.
In the case of the groundwater reITediation, the siIT.plicity of the grouncr~ater
extraction system provides it with a high reliability factor. Also, the
trea~,ent technologies selected for subsequent treatment of the ground water
are all well known, tested, and accepted technologies which provides
reliability to the proposed treatIrent plan.
Health and safety takes into account the potential threat to health and safety
of site personnel both during the iIT,pleITentation of the reITedial action
alternative and during its operation.
ReIT.edial technologies were evaluated with respect to a nurrber of safety risks
including the need for personnel to handle contaminated or hazardous rraterials
and the possibility of the production of toxic gases or airborne contaminants.
Operating conditions for the processes were also considered along with their
effect on safety.
Construction of the interior tier of wells presents the greatest potential for
encountering contarr.inated materials. The work area will be monitored with air
rronitoring equipIT:ent to identify the need for respiratory equipIT.ent, and derrral
protection will be provided during the field operations. Construction of the
perirreter line of wells is expected to produce a lesser potential for exposure
because of the lower concentration of groundwater contarrinants in that area.
However, health and safety considerations similar to those for the interior
tier of wells will be ~aintained.
-36-
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Trenching activities for pipe and electrical supply line construction, where
used, and general grading for the treatment facility construction are not
generally expected to encounter contaroinated ~~terials. However, operations in
the area adjacent to the former disposal areas may encounter contaIT:inated
soils. These operations will be monitored similar to the interior well
construction activities to identify proper safety procedures.
All personnel involved in construction and operation of the extraction and
treacment system will be trained in accordance with the g~erning OSHA
pr~isions contained in 29 CFR 1910.120.
The extraction and treatment alternative was evaluated with regards to its
implementability. These considerations include such things as difficult
engineering requirements, availability of equipment, and per~mit, treatability,
or pilot study requirements. Also included is the tiITe required to attain the
desired results for the particular remedial alternative being proposed. The
groundwater extraction and treatment alternative uses available technologies
that do not require unusual engineering specialities for design and does not
require specialty equi~.ent to iIT:plement. However, pUIT.p testing of the aquifer
is planned to pr~ide input for the extraction well design and bench scale
treatability studies are anticipated to verify the tream.ent techno1cgies to be
used. The iIT.pleITentation of this alternative will continue for several years
with the carpletion of the activity identified by ~.onitoring that verifies that
the contaminant levels have been reduced to the ARARs specified by the
regulatory agencies. The duration of the cleanup can be shortened by ~~e
successful reIT.~al and tream.ent/destruction of the source, and by accelerated
leaching by irrigation.
This cCITbination of tream.ents is the ~ost efficient and cost-effective re:.edy.
It is also the ~ost technically feasible of the groundwater reIT.edial .
alternatives discussed in Section 7.0 of this docUIT.ent.
Consistency with Other EnvironIT.ental Laws
* Occupational Safety and Health Administration (OSHA)
A health and safety plan will be developed during reIT.edial design and
will be followed during field activities to assure that regulations of
OSHA are followed.
* Endangered Species Act
The recommended reIT.edial alternative is protective of species listed
as endangered or threatened under the Endangered Species Act.
Requirements of the Interagency section 7 Consultation Process, 50
CFR, Part 402, will be met. The Deparbr.ent of the Inter ior, Fish and
wildlife Service, will be consulted during the '~eITedial design and
additional source characterization studies to assure that endangered
or threatened species are not adversely iITpacted by iITpleIT.entation of
this reIT\edy.
-37-
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*
Aa~ient Air Quality Standards
The groundwater treatment system will be designed and monitored to
assure that air emissions meet all state and Federal standards.
*
National Pollutant Discharge Elimination Syst~ (NPDES)
Discharge from the treatment system will flow into the existing
wastewater treatIT,ent system. This practice will continue only so long
as the discharge from the wastewater trea~.ent system stays within the
existing NPDES permit.
*
Safe Drinking Water Act (SWDA)
Maximum Contaminant Levels (MCLs) established under the SI:MA were
found to be releV'ant and appropriate to remedial action at the
Celanese Fibers Operations Site and will be considered the cleanup
criteria except in instances where the North Carolina State MCLs are
more stringent.
*
Resource Conservation and Reccvery Act (RCRA)
The rec~.ended rer.edy for groundwater contaIT,ination is not regulated
under RCRA, therefore it does not apply.
*
Floodplain Managerr.ent Executive Order .11988
The CERCLA areas do not lie within a floodplain, and, thus are not
subject to the requireIT.ents of E.D. 11988.
*
Deparbr.ent of Transportation (car)
Transport of hazardous substances is regulated by the car. We do not
anticipate this alternative requiring transportation of materials
off-site. .
*
State Drinking Water Standards
Maximum Contaminant Levels established by the State of North Carolina
as given in 15 NCAC 2L were found to be releV'ant and appropriate in
all instances where the state MeL is more stringent than the SDWA MCL.
Specifically, for the purposes of this remedy, all CCITpoundS detected
in the groundwater which are not naturally occurring rr.ust be rer.cved
from groundwater until the concentration of that CCIT,pound has fallen
below the lowest analytical rr,ethcd detection 1m,it published by EPA
for that particular compound.
-38-
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9.0 Community Relations
A public meeting was held on September 24, 1985 to present the draft RI/FS work
plan to interested parties.
TWo information repositories have been established for the site, one in Earl,
North Carolina and one in Shelby.
A public meeting was held on July 21, 1986 to present the findings of the
Remedial Investigation to interested citizens.
On February 3, 1988, a public meeting was held to discuss the results of the
Feasibility Study with interested citizens. At that t~e, EPA also presented
the preferred rE!I'.edial alternative.
Numerous questions were asked at the meeting and a number of cCJmlents have been
received. Few caroIT.ents were on the selected alternative. The majority of the
comments received were actually requests to have private wells s~pled. These
requests are being handled by the Cleveland County Health Department in concert
with the North Carolina Department of HUIT.an Services.
The public did show a.desire for recr,ediation of the site. No opposition frOIT
the public is expected if the recOITmended raredial alternative is irrpler:ented.
A Responsiveness SUITITary has been prepared to sUITIT.arize cCITITunity concerns and
EPA's cOITITunity relations activities.
-39-
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ATrACHMEN'I'
1.0 RESPCNSlVENESS SUMMARY
-------
Celanese Fibers Operations Site, Shelby, North Carolina
ResponsIveness SUIm':ary
This community relations responsiveness summary is divided into the following
sections:
Section I.
Section II.
Section III.
Section IV.
OJerview.
This section discusses EPA's preferred alternative
for remedial action ~nd likely public reaction to this
alternative.
Background on CCITITunity Involv~ent and Concerns.
This section
provides a brief history of cCITITunity interest and concerns
raised during reIT.edial activities at the Celanese Fibers
Operations site.
Surm.ary of rrajor ccmrents received during the Public Cament
Period and the EPA responses to the camroents.
Both the cam'.ent
and EPA' s response are prov ided.
Reu~ining Concerns.
This section describes ret'aining carnunity
concerns that EPA should be aware of in conducting the reITedial
design and reIT.edial action at the Celanese Site.
-------
-2-
OJerview
1.
At the time of the public rreeting and the begiMing of the public carment
period, EPA presented its preferred alternative to the public.
alternative specified in the Record of Decision (ROD) includes:
This
extraction of contaminated groundwater and treatJt\ent of the contarr.inated
water.
The cQITIT.unity favors reIT.edial action though few citizens expressed a
preference for a particular process.
2.
History of Camunity Concerns
Citizens of the Earl/Shelby area have expressed great interest in
activities relating to the Celanese Fibers Operations site.
The citizens
of Earl, North Carolina, with the assistance of Diana Travis and other
staff ffieITbers of the Clean Water Fund of North Carolina, organized the
United Neighbors For Cleanup at Earl because of their concern about the
~ality of water for their faIT,ilies.
Les Brown, Conservation Chair of
the Broad River Sierra Group of Boiling Springs, has also expressed an
interest in the site.
Many newspaper articles have been written by Donna
CleITIT-er of the The Shelby Star concerning contaITination at the site.
-------
-3-
3.
Summary of Public C~.ents Received During Public C~ent Period and .
Agency Respc:>r1.Ses
Comments raised during the February 3, 1988 Celanese Public Meeting are
summarized briefly below:
Questions and c~ents by participants fell into five general areas:
the
adequacy of the proposed conceptual remedy to protect hUI'l'an health and
the environment, the current potential iITpact upon area residents and
their property, the potential for cleanup activities to adversely iIT-pact -
nearby residents, the desire to be info~ed of test results on indiv~dual
wells, and finally, the availability of an EPA Technical Assistance Grant
(TAG) to the cOITIT.unity.
The COITITlents and questions frar\ the pub:ic and
from representatives of Celanese Fibers Operations who attended the
rr.eeting are sumrarized below, followed by EPA' s response to each rrajor
point or question.
A.
Adequacy of Proposed Rerredy to Protect HUIT'.an Heal th and the
Environment
Citizens raised numerous questions and concerns about how the
proposed remedy would ensure that air and water quality were
protected.
Specific issues raised included:
-------
-4-
How will metals like lead, chratliUIt' and other potential
carcinogens be reff~ed from contaminated ground water?
EPA:
Air Strippi~ will be the first step followed by
biological treatrrent and, if needed, activated carbon treatIrent
and precipitation.
The water would then receive additional
treatment in the CFO wastewater treatrrent facility. . Any water
discharged fratl the facility must continue to ~eet current
perni t standards.
Will an ion exchange alternative be considered in.treatITent?
EPA:
This is part of the cherdcal action involved in carbon
absorption.
Will the air-stripping unit siIrply rem
-------
-5-
EPA:
Yes.
The air stripper will ratl.OJe contartlinants to
achiENe quality safe for drinking. The air stripping tower
remCNes volatile and sar.e extractable organic CaTlpounds by
blO\liing air through water. This will result in SQ'I'.e discharge
to air, however they will quickly disperse so as to be
undetectable in the atI'!'.osphere.
What standards will be applied to ensure air quality, since
North Carolina has no air toxic regulations?
Participants
asked if EPA would adhere to North Carolina's proposed
regulations.
In stressing the need for a standard, one citizen
suggested EPA follorw the National Acadery of Sciences (N.~)
recOITITended air quality standards.
EPA:
EPA will look at North Carolina's proposed regulations
and the NAS suggested standards but will rely on Federal air
quality regulations to ensure protection of hUITan health.
What action will be taken to IT-onitor and ensure that air
quality standards are enforced; would stack tests, for exarrple,
be done 00 the air stripper?
-------
-6-
EPA:
The actual system to monitor and protect air quality will
be- develq:>ed in the design stage of this process.
EPAwill
present the design to citizens and seek public comment.
will additional off-site properties be tested to ensure that
contamination does not migrate to them?
EPA:
Yes.
At the design stage: in July, EPA will have a
clearer picture of which wells would be best to saITple.
Citizens will have an opportunity at that tDr.e to CCIT~ent on -
the design.
. Me the proposed groundwater purrp tests experDrental or a
procedure that has been tried in sDr,ilar circurrstances?
EPA:
Pump tests are perfo~.ed as a matter of routine at other
sites in order to design extraction systeITS that will gather
all the contaminated ground water without adversely affecting
private wells in the area.
Since the more contaminated interior ground water fla.¥s ta.¥ard
and eventually would ITix with exterior levels, will EPA's
two-tiered well extraction systeIT misrepresent groundwater
treatITent results?
-------
-7-
EPA:
That might hav~ been the case if the results were used to
measure contaminant reductions in one location or the other,
however the water will be judged as a whole.
Both areas will
be subjected to treatment and ~ust be cleaned up to acceptable
standards.
One citizen recam\ended that a carber adsorption unites} should
be part of the ground-water treatment design to ensure its
capability to remove contaIT.inants that ~ay not have settled out
or been reIT:oved by the air stripping unites).
EPA:
The carbon treabTent unit (s) will be part of the
treatment design.
Water at that stage of the process ITay
already have been cleaned up and the carbon treatITent would be
redundant at that Point.
Nevertheless a carbon treatIT.ent
unites} will be installed.
How often will the effluent fram the wastewater treatIT.ent plant
be tested? Can the facility's current system handle the water
that will COTe frar. groundwater treatn"ent and still protect the
streams where discharge will occur?
-------
-8-
EPA:
This has not been deternined as yet~ EPA would welcar.e
suggestions as to the frequency of testing or an appropriate
monitoring schedule.
It could be continuoos for a period of
time.
How will residue from the thermal trea~:ent of soils and
sludges be handled and how will air quality be assured?
EPA:
Because more infornation is needed on, the best rrethods
for physically extracting the soils and sludges, ,as well as
treating therr, EPA has not yet decided the specifics of how
residues from therrral processes will be handled. This will be
determined after further ~aterials testing and during the
design stage for this phase of the cleanup.
B.
Current Potential I~pact on Health and Property of Area Residents
Residents raised the following questions or observations about how
the site ltIaY already have iIr-pacted or will iIrpact their health or
property:
Is our water safe for drinking, for other uses?
-------
-9-
EPA:
EPA is confident that the RI/FS studies are thorough and
that the source of the contamination has been found.
One
off-site well that has demonstrated contaminant levels of
concern, possibly starming frar: contareination frat'. the site,
will be treated at the company's expense.
For peace of [t\ind
any resident who wishes could use bottled water for drinking,
but EPA is not recarmending this as necessary.
Several residents stated that they had not received results
fram prior tests of their well water and requested that testing
be done.
EPA:
Most of the tests referred to were conducted by the
Cleveland County Health DepartITent.
Citizens were encouraged
to write to the County and ask for the results.
EPA would also
request copies of these test results and will assist residents
who inquire, in interpreting the test results.
The point was
also stressed to residents requesting tests to be done, that
requests should be directed to the Cleveland County Health
DepartIrent in writing.
record of the request ~ay later help
EPA assist residents in receiving or interpreting inforITation.
-------
-10-
One resident questioned the current standards applied to the
di~charges of Celanese wastewater into the creek.
The person
noted that there was no life in the creek, and that aniIrals had
died.
EPA:
The discharges are regulated under a permi t issued by the
State of North Carolina.
Concerned residents can request a
copy of the pern,it frar, the State Department of Hurran Reswrces
or Mr. Hanke at EPA. would send a copy of the pend t upon
written request.
In addition, citizens can provide input to -
the standards to be rret under the pernit at the tiIre of its
renewal.
It was believed that the renewal date was 1990.
Residents asked about Celanese's current waste handling rrethods
and the possibility of future probleIT,s of the sarr,e nature.
Williarr, Mayrose, CFO/Shelby Plant Manager:
Wastes currently
generated are not stored on-site.
They are transported to a
licensed waste facility.
C.
Potential Adverse Irrpacts on Adjacent Prooerties fram the Cleanup
Activities
-------
-11-
In addition to concerns about air quality mentioned earlier in this
document, residents expressed concern about the iIrpact of waste
cleanup activities on their water supplies or nearby strearr.s and
ponds.
These concerns were addressed as follows:
Will pumping to rerr,Otle ground-water decontamination cause a
drop in the water table and potentially cause wells to go dry?
EPA:
This is a matter EPA has weighed carefully and in order
to dete~.ine the means to protect area wells, a p~,p test will-
be conducted.
This will involve digging a test well, puITping
at various rates, and ~onitoring area wells to see .the effects
of the p~ping.
The extraction syst~ will be designed based
on info~.ation gained fram this test.
Will excavation cause erosion and the run-off of contaIT,inated
water down the hillsides and onto adjacent properties?
EPA:
No.
Sto~ater diversion and collection systems will be
part of the cleanup design so that no releases of IToaterials
being cleaned up will occur.
-------
i .
-12-
D.
Availability of Technical Assistance Grants (TAGs)
Several meeting participants expressed interest in receiving
technical assistance grants and the following questions were raised:
What is the tirr.ing for start-up of the TAG program: will that
be sufficient tLme for the c~unity to be involved in shaping
the decision on the CFO cleanup?
Is there anything the
~unity can do to speed up the process? Can EPA re-open its
decision process once, or if, cCITITcunity succeeds in getting a -
grant?
EPA:
A National workshop in Dallas the second week of February
is expected to resolve safe lingering questions about
iff'pleIT.enting the TAG program, for example questions regarding
financial arrangements.
The process of applying for TAGs is
expected to be in place in about six weeks.
EPA Region IV will
distribute fact sheets on how to apply.
The design phase for
the CFO site will not have been decided by that tUr.e.
EP.lI.
anticipates having a proposed reff'edial design by July 1988.
EPA's policy and that of Congress is not to hold up Superfund
cleanups for technical assistance grants.
EPA Region IV will
do everything possible to see that this cCITIT.unity receives
priority attention when applying for the TAG.
-------
-13-
WOUld it be feasible for Celanese to award a TAG to the
~.unity?
EPA:
Celanese would have to respond to that. William Mayrose,
CFO Plant Manager:
Celanese has a technical resource on the
project and is hiring Clean Sites, Inc. as a second independent
resource.
'!he cmpany sees no reason to bring in a third
technical resource.
For further deta~l and clarification on all CQITIT.ents raised during the -
~eeting, interested persons can refer to the public ITeeting transcript.
The CQITIT:ent periOd on the Feasibility started on February 3, 1988 (the day of
the public ITeeting) and closed on February 24, 1988.
One set of carn.ents was
received on February 25, 1988.
These will be addressed here wi th the other
written c~ents received:
1.
Thirteen residents wrote to request their wells be saITpled.
EPA Response:
A saITpling effort is underway under the initiative of the
Cleveland County Health DepartIT-ent.
'!he Health DepartIT,ent, in
conjunction with the State of North Carolina, have begun sampling wells
as requested by these citizens.
-------
2.
3.
4.
5.
-14-
Two citizens wrote to express concern over possible changes in air
quality near- the site due to the air stripping process.
EPA Response:
The groundwater treatment system will conforn. to
applicable or appropriate and relevant air quality standards.
Three citizens wrote to express concern about possible waste burial sites
near the site.
EPA Response:
A nUIT,ber of off-site burial areas have been investigated ~
by the State of North Carolina.
These reports are available frOIT the
State.
Any infornation on burial sites ~ previously investigated
should be forwarded to the state superfund office.
Three people wrote to request additional infornation on Technical
Assistance Grants.
EPA Response:
These requests were handled directly by the US EPA Region
TV Public Affairs Branch with a letter giving current inforIT~tion on the
status of the TAG.
Two people wrote to request inforwation concerning the site in aeneral.
EPA Response:
These people were referred to the two site repositories.
-------
-15-
6.
One resident wrote to ask "with the sludge removal, and the well water
treatment,' is it the opinion the in sar.e number of years, water treatrr.ent
will no longer be required?"
EPA Response:
Yes. The Agency's plan is to iIrplerr.ent a permanent rerr.edy
at the subject site.
Therefore, at Satle time in the future, we
anticipate 11':oving frar. active treatment to monitoring of groundwater.
7.
A representative frat'. the Sierra Club wrote to ask the following
questions:
"How about taking the water fram the carbon adsorption unit -
back to the ground via irrigation, etc.
This will loop the waste for
re-cleaning and will restore groundwater levels."
EPA responses:
The preferred alternative will resul t in the water being
cleaned" to the applicable or appropriate and relevant standards,
therefore, no "re-cleaning" will be necessary.
Additionally, recharge in
the area is fairly slow, therefore a discharge to the surface would
probably not iIrpact water table levels significantly.
8.
One family had the following three questions/carrnents:
A.
"Our main concern is long-range testing of off-site wells to
ensure safety of drinking water for citizens."
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-16-
EPA Response:
This question will be answered as part of the
Remedial Design.
B.
RHow will the water table be effected by p~ping groundwater in
the cleanup process"Cair stripping)?R
EPA Response:
The effect of the pumpi~ on the water table
level in the surrounding wells will be deterIT,ined as part of
the purrp test at the site. The system will be designed so as
to rniniIT,ize this possibility.
c.
The third question concerned Technical Assistance Grant
availabilitv.
"
EPA Response:
This question was answered with a letter to the
questioner explaining the current status of these grants.
9.
A letter was received on February 25, 1988 frCIT the United Neighbors for
Cleanup. They had the follCMing questions/cOffi\.ents:
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-17-
A.
All neighboring drirlking water wells should be tested now for a
full range of organic and inorganic ch~.icals, and the results
should be explained in an informal rr.eeting between the users of
those wells and representatives of EPA and/or other agencies.
These representatives should have the expertise to answer
questions about potential health effects of individual
ch~;icals and synergistic effects of cOITbined cheITicals.
EPA Response:
It is our understanding that a progracr has been
set up in conjunction with the Cleveland County Health
Departrr.ent to have private wells sarr,pled as requested.
We
would be happy to assist in the evaluation of any analytical
results frOIT. this prograrr, and to speak or rreet with any well
owners about those results.
As before, we are also .available
for such assistance in formal or informal public meetings to
discuss these results as they becarre available.
Also, the
results of any such analyses roay shed SOITe light on the
groondwater hydrology of the area, and we would be eager to
review any results on that basis as well.
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-18-
B.
A regular well testing schedule should be instituted, with
wells in each neighborhood tested .CNer a period of years to
monitor any m~ement of contamination off-site.
Even if the
proposed groundwater pLDTIping and treatment operates to prevent
further ~CNement off-site, there has not been enough testing to
assure that the contamination has not already passed the site
boundaries.
EPA Response:
It has been determined that a randCIT selection
of off-site wells will be included as part of the operation and
ITaintenance (O&H) sarrplirq plan.
The O&H Plan is cOrlsidered
part of the Rerredial Design and will be available for public
carn.ent in IT:id-July.
C.
During the February 3 ~eeting, we were told that Celanese plans
to clean up Mr. JaITes Elliott's well.
However, at that tiITe,
Mr. Elliott had never been inforIT-ed of that prarrise.
We
request written confi~ation of the promise, including
inforrration about the procedure for cleanup and a tiITetable for
impler.entation.
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-19-
. EPA response:
The agreement with Celanese to remediate the
E~liott well was confirned in writing the day of .the public
rr.eeting .
written oonfi~ation of the agree«-ent will be
forwarded to both information repositories
D.
The Record of Decision should include a provision for the
supplying of drinking water at the expense of Celanese to any
neighbors whose wells are contaITinated by ch~icals fr~ the
site.
The burden of proof should be on the o..mers of the site
-
to prove that any cont~inants did NOT CCIT-e frCIT the Suoerfund
site, not on the neighbors to Drove they did.
EPA Response:
It will be difficult for CFO or their
consultants to positively "prove" that any cont~ination found
at SOITe future date in a nearby private well did not originate
frClT'. the site.
This is the situation that currently exists
with the Elliott well; it will be extrerr.ely difficult and
costly for CFO to demonstrate, with reasonable certainty, that
contamination found in this well is not site specific.
In
.. these situations, the best that can be done is to evaluate the
existing data, and try to come to a reasonable conclusion based
on that data as to whether or not any observed contaIT.ination is
-------
"
I
-20-
site specific.
The selected remedial action will be designed
to prevent further contardnant transport from the site, and
since groundwater movement and cont~.inant transport is
relatively slow, the t~e between now and the ~.pleIT'entation of
the remedial action should not be sufficient to allow
widespread further contamination.
'Iherefore, the concern
regarding future contaIT.ination, while understandable, is based
on events that are unlikely to occur.
E.
Arty level of grouncr,...ater contaIT.ination attributable to the site
should be cleaned up, even if it does not exceed current
drinking water standards.
Scientific knowledge of the effects
of long-terIT exposure to low levels of contaITinants is
incarplete, and the coopany should be resoonsible for rerrev ing
any cont~ination it caused.
EPA Response:
Groundwater clean-up goals ~ay be set in a
number of ways, SOfie of which are consistent with the concept
of remediation to background levels.
Often, however, clean-up
goals for extraction wells located on-site are set at drinking
water standards or sare other health-based criteria.
In such a
case, contaminant transport from the waste site to any off-site
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-21-
water supply wells will further reduce concentrations and
prOvide an additional rrargin of safety.
Finally, £FA
regulations allow far setting of alternate concentration lUr.its
under appropriate cir~stances, and it is therefore not
possible f~ EPA to rule out such a possibility.
The
detern,ination of grcundwater clean-up goals will be based on
site-specific application of applicable or relevant and
appropriate regulations in a manner that is protective of
public health and the enviro~ent.
Therefore, the 15 NCAC 2L
standards of the State of ~rth Carolina are considered the
appropriate clean-up criteria for this site.
F.
Surface water exits the site in several streaITs.
Each streaIT
and its sediIreot should be tested, (Ner tiITe, to ensure that
contaIT.ination is not leaving by that route.
In addition, the
recreation pond on-site should be tested (or, if tests have
been conducted, we request that they by rrade available), and
the discharge fr~ the pond that passes through adjacent
property should be rronitored CNer tiIre.
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-22-
EPA RespOnse: Testing of these media was conducted during the
~ial Investigation eRI) at the site.
This info~~tion is
currently available to the public in the RI report located in
the two site info~ation repositories.
G.
The Record of Decision should include a provision far modeling
of any pump and treat system for groundwater to deternine the
effect it "~y have on supplies in neighboring wells.
If the
treatITent lowers the water table or causes any adverse effects,
the cCIT:pany should pay far providing an alternate suooly of
water to affected neighbors to avoid creatine a new orobleIT
while
<:/"'\1,,;PV""r
-.......... ""4~
~P"'to ".........,'- -
"'" e",....:>...ltig vne.
EPA Response:
The concern expressed regarding the effects of
any groundwater extraction system installed at the site on
nearby private wells is a valid one.
The remedial design will
take into account aquifer characteristics and hydrologic
response to stress as determined by the proposed pump test to
be conducted a t the site.
Agency review will also help insure
that the pump and treat system will not adversely affect water
quality or yield in private wells in the vicinity.
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-23-
H.
Community air should not be used to clean a Superfund site.
Any air stripping of groundwater should be done in a closed
systE!!t\.
S~ply ~eeting current North Carolina air toxic
regulations is not enough, since such regulations do not
exist.
The company should be required to use measures that
avoid ANY degradation of community water or air quality.
EPA Response:
Rerredial Design will take into account the
potential for exposure to volatile organics fr~ operation of a
trea~.ent systeff which includes air stripping of .cont~inated ~
groundwater.
In general, the exposure via this route is
expected to be ITiniITal, due to the high degree of dispersion
available relative to the ITass of volatile organics rEIToved
fr~. the groundwater.
When the relatively low yield of the
surficial aquifer at the site is taken into account, the volUITe
of water to be treated on a daily basis will be SITall, and the
quantity of volatiles emitted likewise small.
We are not sure
what is intended in this comment by reference to a closed
system in an air stripper: a closed system will result in the
-buildup of volatile organics in the air used to strip the
contaminated water so that
the stripper will be rendered
ineffective.
The only way to cOITpletely el~inate SCIT-e air
-------
-24-
emissions would be to treat the air leaving the stripper
column, and it is extreroely unlikely that the risk associated
wi th the eR'.issions frCJ1\ the stripper would warrant such
sophisticated treatment.
I.
A plan needs to be in place for controlling potential etrissions
caused by disturbance of the soil during the ~aterials handling
investigation.
This plan needs to be available for public
COITITent and EPA response before the work baains.
The carnunitv
should not be re-eXPOSed during this process.
C"''01\ 'C""',..""",...----
~,r n .L,t;~t-"--" 1~~.
This concern will be addressed as part of the
Operable Unit II Feasibility Study to be conducted at the site.
J.
we request written answers to COITITents raised in earlier
~eetings.
(Specifically, see the transcript of the July 21,
1987, public ~eeting on the Celanese ReITedial Investigation,
which contains nUIT.erous questions and camITents.)
EPA Response:
Questions and CQITIT.ents raised at the July 21,
1987 Public Meeting to present the RI report were, for the
large part, addressed at that tiIT:e.
Four written COITITents were
received by the RPM and each CQITIT,ent had a written response.
-------
-25-
K.
There have been reports of additional off-site burial areas.
The Record of Decision should include a provision for
investigation of any of these reported to the EPA in the
future.
EPA Response:
The State of North Carolina has responded
diligently to requests for investigation of additional
suspected hazardous waste burial areas.
These requests will
continue to be forwarded to the State for action, therefore it
is inappropriate to include such a provision in the Record of -
Decision for the site.
L.
Proposed r~edies that discharge treated water to surface water
stre~.s should not increase the level of contaITination in those
strearrs.
The existing NPDES permit should be reviewed to
ensure that all ch~icals found in the groundwater will be
~onitored, that perIT.itted levels avoid any deterioration of
surface water quality, and that ffonitoring by the EPA or the
state is adequate to ensure that the pernit conditions are rret.
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-26-
EPA Response:
Any ren;e~:Hal action which would involve
dtscharge of treated groundwater to a surface streaIT\, either
through the existing NPDES discharge to Buffalo Creek or to
same other stream, wlll be coordinated with the NPDES prograITS
at the State and Federal levels.
we would expect that any flow
fram a groundwater extraction and treatment systeIT-. will not
significantly increase flow through the present NPDES
discharge, which is perITitted 850,000 gallons per day.
The
pernit rr.onitoring conditions may need to be revised to reflect
the possible presence of groundwater contarrinantsi it should be
noted, however, that if treated groundwater is to be discharged
through an NPDES discharge, effluent rronitoring will be done by
the facility and not by the State or EPA.
A schedule for the
rronitoring will be included as part of the rerredial design at
the site.
10.
General COITITents were rrade concerning the following:
A.
Notice of meetings and availability of docurrents for review
prior to meetings has been poor.
-------
-27-
EPA Response:
All statutory community relations requir~ents
hall e been met.
However, in light of the dissatisfaction of the
~.unity, future planning will include additional notification
and rev iew times.
B.
The citizens request that EPA tell them whether or not their
water is safe to drink,~ that if contamination occurs that
Celanese will clean it up at the expense of the cOITpany and
that the ROD contain all of this.
EPA Response:
A letter was sent to seventeen residents whose
wells were saITpled during the RI interpreting the results.
This letter stated that, based on currently available
inforITation, all the wells but four could be presUIT.ed to be
"safe".
Those four were re-saITpled by the Agency in August
1987.
TCE was confirIT~ in one well abave MCLs and, as a
result, it has been remediated.
Two wells were found to have
unacceptable levels of methylene chloride.
These results are
believed to be probable analytical artifacts and not
contamination eITanating fr~ the site.
The fourth we 11
reportedly had unacceptable concentrations of arsenic.
The
footnote to the data reported an "R" which indicated unreliable
-------
c.
-28-
data.
Additionally, wells upgradient and around the site have
been abandoned due to high levels of arsenic.
It is believed
that these concentrations of arsenic are a naturally occurring
phenar,ena in the Shelby area.
The ROD is only a decision document, therefore, questions of
liability cannot be incorporated.
Questions were raised.concerning the availability of Technical
Assistance Grants and a reauest "that any decision ITade on the-
~ ....
clean-up options at this point include a provision for changes
on additional public cOITITent~"
EPA Response:
The current inforIT~tion available on Technical
Assistance Grants was reiterated as well as the current EPA
policy that Records of Decision not be delayed or postponed
while awaiting the Technical Assistance Grants.
The public has
been inforITed that they will be given an opportunity to COITITent
on the detailed reIT.edial design.
.-
-------
-29-
4.
Remaining Concerns
The only raraining concerns at the site are, drinking water quality and
Technical Assistance Grants.
The water quality concerns will be addressed
as soon as sampling results are received.
The concern CNer TAGs will be
addressed as soon as the mechanism for awarding these is in place.
-------
A'ITACHMENT
2.0 ArMINISTRATIVE RECORD INDEX
~~.
-------
ATTACHMENT
3.0 STATE CONCURRENCE
-------
James G. Martin, Governor
David 1. Flaherty, Secretary
23 March 1988
Ronald H. Levine, M.D., M.P.H.
State Health Director
Ms. Michelle Glenn
SUperfurrl Project Manager
Envirormantal Protection kJercy
345 Courtlan:l Street, N.E.
Atlanta, Georgia 30365
RE:
Record of Decision
Celanese Fibers ~tions NFL site
Shelby, North Carolina
Cear Ms. Glenn:
We have reviewed the Record of recision for Celanese Fibers
Operations in Shelby/North Carolina. '!his office concurs with the
selected remedy.
Sincerely,
/ -...-1 ' , 1
/ '/1' ...--J..,J . /
{,.../'<:~ '-<..~n'-, ..' //"::7../''-''
william L. Meyer, all.ef
Solid waste Management Section
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