United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R03-88/054
September 1988
&EPA
Superfund
Record of Decision
Fike Chemical, WV
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,50272, 101
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/R03-88/054
I~
3. Recipient's Accession No.
4. Title end Subtitle
SUPERFUND RECORD OF DECISION
Fike Chemical, WV
First Remedial Action
5. Report Dete
09/29/88
So
.- -
7. Author(s)
D
a. Performin8 O'8anization Rept. No-
9. Performln8 O'88nlzation Name and Address
10. Project/Task/Work Unit No.
-
-_. -- ---
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11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsorin8 Or8anizatlon Name and Address
U.S. Environmental Protection
401 M street, s.w.
washington, D.C. 20460
--.--- -'-----.-- -.--
13. Type of Report & Period Covered
Agency
. -
"
8001000
'-
14. -
15. Supplementary Notes
16. Abstrect (Umit 200 words)
The Allied Chemical site is located in the City of Ironton, Lawrence County, Ohio.
This remedial action addresses the Goldcamp Disposal Area (GDA) operable unit of the
site. The other operable unit, comprised of the coke plant, lagoons, and the tar plant,
is addressed in a separate remedial action. The GDA is a four-acre disposal pit located
in a mixed industrial/ business/residential area bounded by Third Street on the east and
the Ohio River on the southwest. Several businesses and institutions are within 100
feet of GDA. Allied Chemical and Dye Company has owned the property-since 1955. The
GDA was a sand and gravel pit used for disposal of various chemical wastes from three
sources between 1945 and 1977. The wastes include: anthracene residue, anthracene
salts, phthalic anhydride residue, and miscellaneous process wastes from the Tar Plant;
foundry sand containing heavy metals, phenolics, and oils from the Dayton Malleable Iron
Company; and wastes disposed of by the Goldcamp Gravel Company. In 1977, Allied decided
to discontinue use of the GDA for disposal of chemical wastes. Allied and its
contractor, in consultation with the Ohio Environmental Protection Agency (OEPA),
completed a closure project at the site in August 1980, which involved removal of
standing liquids and filling and capping the site with clay. Subsequent hydrogeologic
and water quality investigations indicated that there is ground water contamination at
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Fike Chemical, WV
First Remedial Action
Contaminated Media: gw, soil, sw
Key Contaminants: inorganics (acids,
b. Identifiers/Open-Ended Terms
asbestos, cyanide), metals, organics (PCBs)
Co COSATI FIeld/Group
L Availability Statement
19. Security Class (This Report)
None
21. No. of Pa8"
45
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20. SecuriJ:y Class (This Palle)
None
22. Price
(5.. ANSI-Z39.18>
See Instructions on Rever.e
OPTIONAL FORM 272 (4-77)
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16. Abstract. Include a brief (200 words or less) factual summary of the most s'ignificant information contained in the report. If the
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17. Document Analysis. (a). Descriptors. Select from the Thesaurus 01 Engineering and Scientific Terms the proper authorized terms
that identify the major concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.
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ended terms written in descriptor form for those subjects for which no descriptor exists.
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18. Distribution Statement. Denote public releasability, for example "Release unlimited", or limitation for reasons other than
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22. Price. Enter price in paper copy (PC) and/or microfiche (MF) if known.
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~PA/ROD/R03-88/054
Fike Chemical, wv
First Remedial Action
16.
ABSTRACT (continued)
the site which may pose a threat to public health through migration. The volume of the
disposal area is approximately 300,000 yd3. In addition to this primary area of
contamination, there is a zone of nonaqueous-phase contaminants which have migrated
through the aquifer to the underlying impermeable bedrock layer. The extent of the
contaminated area is uncertain, but the volume is estimated to be 156,000 yd3. The
surface of the GDA is also a source of contamination because many substances have oozed
up through the existing cap. The primary contaminants of concern affecting the soil and
ground water are VOCs including benzene, other organics including phenols and PAHS,. and
inorganics including cyanide.
The selected remedial action for this site includes: construction of a slurry wall
around the disposal area from ground surface into the low permeability bedrock:
installation of a multi-media RCRA cap over the surface of the disposal area: extraction
and onsite treatment of ground water from inside and outside the containment system:
provision of an alternate water supply for the Ironton Iron Company until ground water
cleanup levels are met: imposition of deed restrictions to limit future uses of the
property: and preparation of a supplemental RI/FS to identify the extent and nature of
the nonaqueous-phase contaminant layer with implementation of the Agency-approved remedy
for this contamination, if different from the present containment alternative. The
~stimated present worth cost for this remedial action is $13,130,000 with annual O&M
costs of $515,000 for approximately 30 years.
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Record of Decision
Declaration
site Name and Location
Fike (Artel) ChEmicals site Nitro, West Virginia
Statement of Basis and Purpose
'!'his decision docmtent presents the selected remedial action for the
. Fike (Artel) ChEmicals site in Nitro, West Virginia, developed in
accordance with CERCLA, as anended by SARA, and, to the extent practicable,
the National Contingency Plan. '!'his decision is based on the
aduinistrative record for this site. The attached iaiex identifies the
items that canprise the acininistrative record upon which the selection of
the remedial action is based.
The State of West Virginia has concurred in the selected remedy.
Description of the Selected REmedy
The remedy selected for remediation of the Fike ChEmicals site is
Alternative 2: Control, Stabilization and Elimination of IDmediate Hazards
to Hlman Health and the ntviroanent. 'rhis remedy is an action needed to
redlJ:e the iDminent hazards currently existing onsi tee It is also the
first phase of a long tem remediation of this site and will not be
inconsistent with the final remedy.
The major canponents of this remedy are as follow:
a)
b)
c)
d)
Rsnoval and disposal of the tank of methyl mercaptan~
RsDoval and disposal of the dr\1DS of metallic sodi\D~
RIE!mOval, bulking, and disposal of dr\JDS on the ground surface;
RsDoval, bulking,. and disposal of the materials found in various
tanks, lines, and vessels located onsite~
~packing and disposal of certain laboratory containers found onsite~
Drainage aDd 8tabilization of the onsite and CST !'aCility lagoons~
treatmeDt of the drained liquids frail the lagoons ~ and discharge of
those treated liquid8 to the DnaW1a River;
Excavatioa, bulking, and disposal of buried dr\Da~
Proper stabilization and/or removal and disposal of asbesto8
containing insulation material found in process lioes ~
Proper removal and disposal of the cylinder (8) of hydrOCJen cyanide.
e)
f}
g)
h)
i)
Declaration
The selected remedy is protective of h1.JDan health and the emrirOtlDeDt, attains
Federal and State requirEments that are applicable or relevant and appr~priate
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for this remedial action and is cost-effective. '111is remedy satisfies
the statutory preference for remedies that employ treatment that reduces
toxicity, mobility, or vol\JDe as a principal element and utilizes
petmanent solutions and alternative treatment technologies to the maxim\ID
extent practicableo
7-;)i-£t
Date
~;~.
Acting Regional Administrator
Region III
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ReCOrd of cecision
ROD cecision Smmary
Site Name, Location, and Description
Fike Chemicals, Inc. (Fike) , now Artel Chemicals, is an active, small-
vol\JDe, batch fomulator that specializes in the developuent of new
chemicals, custan chemical processing, and specialty chemicals. The.
facility, (Figure 1), is located in the Nitro Industrial ecmplex, Nitro,
west Virginia, and is situated approximately 2,299 feet east of the
Kanawha River. Coastal Tank Lines, Inc. (Costal), fomerlyoperated a
truck teminal located adjacent to Fike, fran which finished and raw
chemical materials were hauled. The empty tank trailers were cleaned and
repaired at the teminal.
COOperative Sewage Treatment, Inc. (CST), was fomed as a joint venture
by both caupanies to treat their industrial wastes. CST is located
between Fike and the Kanawha River.
rhe Fike Chsnicals Site, for the purpose of this study, consists of the
Fike and CST properties.
SITE HISTORY
The plant and disposal area are located on the site of a WOrld war I
SIOOkeless pow:!er plant. The original chemical plant on the Fike
Chemicals site began operation in 1953 as the Roberts Chemical Ccrnpany.
. In 1971, Fike Chemicals, Inc. began operations and operat~ until 1986,
when the name and prinicpal ownership changed to Artel. During Fike's
operation, over 69 different chemicals were prod\X:ed, all by batch
reaction on an as needed basis.
Fike and Coastal fomed CST soon after catlDencement of Fike's operations.
Aerial photographs indicate the presence of two basins on the CST property
as early as 1968. Coastal stopped treating waste at CST and sold its
interest in CST to Fike in 1978; CST began treating wastewater fran
National Industrial Services, Inc. (NIS, fomerly Maine Coastal), a
cleaner of railroad tank cars' located on the eastern border of Artel' s
main plant. The West Virginia DepartIDent of Natural Resources (WVADNR)
granted NPDES Permit No. wvg99l65l to CST on DecEmber 13, 1979, which was
valid until March 31, 1981. The pemit was renewed for a s-year period
~K:ing in Marcb 1982. Pemit violations were noted frequently by the
DNR, based on caapliance inspections and reviews of discharge monitoring reports.
WVDNR subseqaently, declined to reissue a pemit, to CST because of the
history of none. .-oII.t11 iance.
, There .is a docunented history of groundwater and surface water contamination
at the Fike Chemicals Site. In 1989, EPA filed a civil suit against Fike and
CST pursuant to the Clean water Act (CW) and the Resource Conservation
'cud ReCOvery Act (RCRA) for its discharge of pollutants into the Kana\liba
, Ri ver and its disposal of hazardous wastes on site.
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That action resulted in a Consent DeCree entered in Novenber 1982 with
USEPA which required extensive . remedial work be performed by Fike
including diking, ground cover of principal waste disposal sites, and the
pumping and treating of groundwater. Additionally, in JUne 1984, EPA
performed sampling and analysis to detemine the extent of dioxin
contamination, if any, at the site based on a 1983 screening for dioxin.
The EPA discovered low levels of dioxin at the site. The 'Consent Decree's
requirement for a ground cover was deteanined to be sufficient protection
against dioxin. Fike eventually installed the earthen portion of this
cover. Although it is possible that sane areas of identified dioxin
contamination may be disturbed during the proposed REmedial Action, it is
not anticipated that such disturbances would pose any threat of their own
to h\mlal1 health or the envirorment.
In response to a RCRA part B Hazardous waste pennit application submitted
by Fike for CST, a Notice of Deficiency (NOD) was sent to Fike by the EPA in
March 1985. The NOD indicated to Fike that the Part B for CST was
inadequate and that a Part B for the Fike facil i ty should also be Sutmi tted .
BeCause of Fike's failure to sutnit acceptable Part B'S for Fike and CST as
well as Fike and CST's noncanpliance with the interim status certification
requirements of section 3995 (e) (2) of RCRA, interim status for Fike and
CST was terminated on November 8, 1985.
GENERAL SITE FEA'roRES
The Fike Chemicals Site consists of an active chemical manufacturing
plant which operated fram 1968 until JUne 1988 when workers were laid off,
utilities shut off, and the plant apparently was abandoned by its owners.
The chemical plant (Figure 2) covers an area of approximately 11 acres.
The northern half of the plant is covered by plant process apparatus, .
whereas the southern half has historically ~ used for various waste
disposal operations. .
Based on the information obtained fram historical records, aerial
photographs, discussions wi th employees and si te visits, a total of 13
potential source areas of envir01'lDental contamination have been
identified. 'lbese areas inclu:ie:
i .
* Cooperative 5ewige Treatment, Inc.
* Fike O1emicals Proda::tion Area
* Fike Chemicals Disposal Area
- Buried Dr\ID Area 1/1977 Liquid Disposal Trench
- Buried Drma Area 2
. - Buried [X\JD Area 3
- Buried DND/BOttle Area 4
- ReClaimed Lagoon 1
- ReClaimed lagoon 2 ,
- 1977 Lagoon (Coastal Tank Lines property)
- Lagoon 3 .
- Sl\d)e storage Tanks
* Drainage Di tch north and east of Fike
* plant Saers
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The CST plant is located approximately 409 feet northwest of the site.
CST is designed to treat plant surface runoff and process wastewater
delivered fran Fike Chemical via separate sewer systems. The CST facility
layout is sho~ in Figure 3. Raw wastewater enters Basin NO. 1 which is
used for flow equalization and pH adjustment. SOdi\.1U hydroxide, sulfuric
acid, or a1\D is added to the wastewster prior to discharge into the
primary clarifier , an 8-foot-diameter conical tank. The primary clarifier
is by-passed during periods of high flow, and the wastewater is discharged
to basin NO.2, an aerated activated sludge treatment basin. Basin 2
effluent enters the final clarifier, a 15-foot diameter, 2l-foot-deep conical
bottan steel tank. Sludge settled in the secondary clarifier is recycled
into Basin 2 as required. When sludge is wasted fran the secondary clarifier
it is placed on sludge drying beds along with wasted primary clarifier
sludge. The sludge drying beds are rectangular concrete tanks consisting
of a drain tile underdrain beneath la}'ers of sand and pea~avel that
collects filtrate and returns it to Basin 2.
The secondary clarifier discharges to a portable carbon adsorption unit,
prior to discharge to the Kanawha River. Basin 3, an ova~ oxidation
ditch which was part of the original treatment process built between 1965
and 1967, was taken out of service in 1986 1::ecause of process control
problems. Basin 3 was constructed with a concrete bottan, but with rip-rap-
covered, native earthen sides. It is likely that exfiltration fran this
basin has occurred over the 29 }'ears it was used for wastewater
treatment. Groundwater monitoring results indicate contanination in the
vicinity of the CST site.
The production area sho~ on Figure 2 was utilized for over 35 }'ears in
processing and manufacturing various organic caupounds. until recently
the majority of the ground surface was unpaved. As a result, spills or
leaks could have entered the soil. Subsequent precipitation may have
transported these constituents into the groundwater system.
Buried Dr\D1 Area 1 and the 1977 Liquid Disposal Trench are located in the
southeastern portion of the si te, bounded by a Conrail railroad track to
the east .and a Fike railroad siding to the west. Aerial photographs
taken between 1957 and 1986 indicate waste disposal activities occurred
in this area. Buried Dr\D1 Area 2 is a long, narrow area sOuth of the
current dr\D1 storage pad. Reportedly, this area was used aroum 1971 for
disposal of dr\D1s.
Buried Dr\D1 Area 3 is located in the south end of the Fike property,
southeast of and adjacent to waste Lagoon 3. This area was also
reportedly used around 1971.
The Buried ~\IDIBott1ed Area 4 is located in the southwest corner of the
Fike property. In addition to wste disposal activities supposed to have
been practiced here daring 1975, a drainage ditch fran Reclaimed lagoon 1
bisected the area bet'lleen 1973-1989. 'Ibis drainage ditch directed
discharge of excess liquid in the lagoon towrd drainage swales along the
railroad track.
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4
Reclaimed tagoon 1 was used fran 1973 to 198(jJ for disposal of sanisolid
and liquid wastes fran the plant manufacturing area that were unsuitable
for treatment at CST. The lagoon was constructed without a liner. This
reclaimed lagoon is located in the southwestern portion of the property,
contiguous with the property boundary. fot)ni toring wells in the vicinity
of the lagoon have been found to contain organic priority pollutants.
Reclaimed tagoon 2 is located in the south-central portion of the plant
property, east of concrete bunkers and the remains of a WOrld war I era
muni tions plant. This area was used as a disposal lagoon prior to 1983
for wastes deeDed unsuitable for treatment at CST. The lagoon was
constructed without a liner. In 1979 the waste material fran Lagoon 2
was transferred to Lagoon 3 as required by a 1978 Consent Decree.
Likewise, the waste contents of Lagoon 1 were transferred in 1981. The
lagoons were backfilled to grade following transfer of their contents.
Aerial photography interpreted by the EPA indicated a lagoon located west
of reclaimed Lagoon 1 in what is now Coastal Tank Lines parking area.
This lagoon is suspected of being used for diSposal/storage of wastes
around 1977.
Lagoon 3 is a 27(jJ, (jJ"(jJ-gallon capaci ty waste disposal impounanent located
in tne southwest portion of the plant property. The lagoon was constructed
in February 1979 with a low-penoeability clay liner. Its intended use
was for storage and evaporative treatment of waste materials fran Lagoon
3 was taken out of service in March 1983 pursuant to administrative order
No. 829, issued by WVDNR. Precipitation occurs in excess of evaporation
in this area of the country, and it is likely that the majority of liquid
losses fran this lagoon have infiltrated into the ground. .
Ten sludge storage tanks are located in the south central portion of the
site. The tanks reportedly contain sludge fran Lagoon 1 excavated during
reclamation of the lagoon in 1981, and liquid fran Lagoon 3. The tanks
are estimated to be 12 feet in diameter and 15 feet high, with closed
tops. The tanks are rusting and in poor condition. The spill
. contaianent dike is lined With concrete and contains green liquid and
solids.
The drainage ditch between Fike's fence and the Conrail railroad tracks
parallels Fike's north and east property line. High levels of cyanide in
this ditch were previously detected. The ditch contained a green,
stagnant liquid at a location adjacent to the northeast corner of the
Fike property. .
The plant sewr system ws segregated into stom sewers (which receive
surface runoff) , and wstewater se..ers (which receive process wastewater)
in 1979. Both sewr systems discharge to the CST. original construction
records for the sewer systems are incaaplete and it is suspec:ted that
interconnections still exist. Many of the drain inletS are currently
clogged with sediments. Additionally, rm:h of the site is underlain by a
stOaD sewer built for a WOrld war I-era muni tio~ plant that discharged
to the Kanawha River. ..
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5
TOPOGRAPHY, SURF~E WATER, and DRAImGE
The Fike Chemicals Site is located the Kana~ River. Topographic relief
on the si te is minor, varying in elevation between 592 and 694 feet above
- mean sea level. The KanaWa River is a major surface water systEm in
Putnan County. It drains the lower portion of the Kanawha. River Basin as
it flows toward the Ohio River, 43 miles northwest of Nitro, west Virginia.
Topography within the Kanawha River Basin is typical of a mature, dissected,
unglaciated Appalachian plateau, with deep-sided valleys and narrow winding
ridges.
The investigation areas are very flat. Little local drainage fram the
plant area flows off-site. The exception is the area east of the plant
warehouse and dr1.1l\ storage area. Drainage in this area flows eastward
onto the railroad property, where it is intercepted by a north flowing
drainage ditch. This ditch extends along the east side of the Fike
property, turns westward north of the vimasco property and extends to
viscose Road where it ends, apparently discharging to the soil.
Surface water fran the Fike Chemical plant is generally locally
controlled. plant drainage is collected in a mnber of floor drains and
catch basins. These appurtenances discharge to one of the two sewer
systEms described above, which convey the collected surface water to the
treatment plant.
GEOLOGY, SOILS, and HYDROGEX>LOGY
The Nitro Industrial Canplex is located on the flood plain of the Kanawha
River. The soil survey of Putnan County classifies this area as urban
Land (Uh). This unit consists of nearly level areas where more than 85
percent of the surface is covered by' asphalt, concrete, buildings, or
other impervious materials.
The si te is underlain by alluvial deposi ts of Pleistocene and Recent Aqes
that are approximately 6IIJ feet- thick. These deposits consist of three
zooes: (1) fill, (2) loan, and (3) sand and gravel. The fill ranges in
canposi tion fran a reddish yellow, moist, sandy loan to a whi te, coarse
sand to silt. The loan is generally a moist reddish yellow to yellowish
red, sandy to silt loam having thin stringers of brown clay. Sand and
sand wi th gravel becaDes daDinant wi th depth. These deposits are
lenticular in structure and are general! y shades of brown. The sand and
gravel deposit is the thickest and is the water-bearing zone.
The bedrock belongs to the Conemaugh Group of the Pmmsylvania SystEm.
This fol:iDatioo consists of red and vari-colored sandy shale; gray, green,
and broWl sandstone; minor beds of coal, fire clay, black carbonaceous
shale, and limestone. 'ftH! sandstOne and shale is interbedded with
nunerous coal seas aDd thin (~ly less than one foot thick)
limestones. The sandstone and shale units vary considerably in thickness
fran laminated beds of less than one inch to massive sandstone and
continuous shales in excess of 31 feet. The bedrock beneath the Fike
ChBDicals Site is shale. -
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6
HYDROG!X)LCX;Y
Groundwater ocCurs at a depth of approximately 15 feet. 'ft1e unconfined,
alluvial aquifer has a saturated thickness of approximately 45 feet. An
average transnissivity value for the Kanawha River valley alluvi\D is
18,999 gpd/foot and thus an approximate hydraulic conductivity is 499
gp:!/ft2. The direction of groundwater flow is west-northwest, toward
the Kanawha River.
Groundwater in the alluvial aquifer has been used primarily for cooling
processes by local industry. Industrial and public-supply wells tapping'
the alluvial deposits of the IQInawha River valley have an average yield of"
68 gpn. In more recent years, industrial water supplies have been changed
fran groundwater to the Kana\1ti1a River and a private water canpany (west
Virginia water Co.) W:1ich obtains its water fran the Elk River near
Charleston. Public water is supplied by the west Virginia water CaDpany.
In Putnam County, there are sane water wells that wi tbiraw groundwater.
fran the bedrock. These wells have a much lo~r yield averaging only 6
to 9 gPD. Groundwater within the bedrock is derived fran infiltrating
precipitation. Although the bedrock is not confined, only a small
percentage of the 42 inches of annual precipi tat ion penetrates the
bedrock because the petmeability of the bedrock is 7 to 11 times less
than that of the unconsolidated sediments.
CLn~TE
The site cl imatology is characteri zed using data obtained fran the
National Climatic Data Center in Asheville, North Carolina, for the
National weather Station at the IQIna\1ti1a Airport near Charleston, west "
virginia, located approximately 19 miles' southeast of the Fike Chemicals
Site. The period of record is 1947 through 1986. .
The weather in this area is highly variable, especially fran mid-autmm
to Spring. S\.IIIDer and early Autumn have more day-to-day consistency in
the weather. The mean annual temperature is 55<7, with monthly notmals
ranging fran 32.9~ in January to 74.50F in JUly. Early morning fog
is ccmnon fran late JUne through October 0 .
Average annual precipitation is 42.43 inches, with JUly the wettest month
(5.36 inches) and o:tober the dryest (2.93 inches). Droughts severe
enough to limit water use are scarce. The maximml 24-hour rainfall for
the period of record is 5.6" inches, which occurred in July of 1961. 'ft1e
. precipi tatioo of the l8-year 24-hour rainfall event is 4 inches. The
mean annual snow fall is 32.2 inches per year. Heavy snowstODDS are
infrequent and most snowfalls are less than 4 inches. '1'be mean annual
lake evaporation (based on the period 1946-1955) is 34 inches. .
Prevailing winds are fran the southwst; however, winds fran the south
are CCIIIDOn during the period JUly through October, while during the.
winter months, the winds originate fran the west-southwest. Mean wind
speed in 6.4 mph.
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POPULATION and ENVIRONMENl'AL RESOURCES
The area around Fike O1emicals is predaninately used as industrial lands.
The site itself is located northwest of Nitro, west Virginia and
approximately 2,299 feet east of the Kana~ River and within the
floodplain. 'ftte Kanawha River has been categorized un1er west Virginia
Water QUality Standards as suitable for water contact recreation,
industrial and agricultural water supply, propagation and maintenance of
fish, along with water transport, cooling and power. Nitro has a
population of approximately 9,599, and an est~ted 1,599-2,599 people
reside wi thin 1 mile of the Fike facility. In addition, as well as the
local swimning pool, the junior and senior high schools are situated
wi thin one half mile of the si te.
Site History and EnforCEment Activities
A brief summary of investigative activities which have previously occured
at the site follows:
A. Groundwater Monitoring
-1976 - Groundwater study cond\X:ted wi th fire well sanpling events
at three wells.
-1977 - National ~forcsnent Investigations Center (NEIC) cond\X:ted
sanpling of three monitoring wells.
-1981 - JRB Associates performed a study to determine the effects
of waste disposal practices at Fike, coastal, and CST on
local groundwater quality.
-1983,- Monitoring wells installed to check canpliance with 1982
1984 consent order.
-1985 - Canprehensive groun1water sanpling and analysis cond\X:ted
by Fike Chemicals.
-1985 - EPA sampled wells associated with CST.
-1986 - WVDNR sanpled selected wells.
B. Soil Analysis
-1983,- le1ion III Field Investigation Team cond\X:ted air inspection
1984 and collected samples for dioxins.
C. Surface water
-1977 - NEIC SlJIIIpled CST Lagoon 1
-1983 - EPA' s Technical Assistance TeaD (TAT) collected surface
water samples fran a drainage swale adjacent to the Fike
Chemical property boundary.
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-1979 -NEIC sanpled CST effluent and the storm sewer bypass.
-1984 - ~ineering - science collected surface water sanples
fran the CST treatment basins.
HISTORY of CERa.A !m'01CEMENT ACTMTIES AT THE SITE
Attached to this Record of Decision are two tables showing a 9\m11arY of
enforCEment activities at the Fike ChEmical site. Table I is titled
"History of RCRA and NPDES Inspections at Fike ChEmical and CST," and table
II is titled "History of RCRA Enforcement Actions."
COPMJNITY RELATIONS HIS'roRY
'rt1e ca1IDuni ty surrounding the Fike ChEmicals Site has been well awre and
kept infonned of EPA and State actions at the site. . since JUne, 1988,
press briefings have occured on an almost daily basis, and two public meetings
have been held in the ccmnuni ty. 'ftlis entire matter of CCIIIIIuni ty
relations is addressed in more detail in the responsiveness slJllllary,
which is attached to and made part of, this record of decision.
CURRENT SITE ACTIVITY
Q1 JUne U, 1988, EPA was asked by WVDNR, to evaluate conditions at the
site due to the apparent abandonnent of the facility by the owners. As a
resul t of that evaluation, EPA deteanined the site to be a potential
hazard to h\IDan health and the envirorment and began an inmediate
stabilization of the site. Since that time various site areas have been
secured, dr\Ds and chenicals have been sanpled for caapatabili ty, leaking
dr\DS have been overpacked and staged, and the site has been stabil i zed
to the greatest extent possible sinof the beginning of EPAI s actions.
The addi donal work described in this record of decision is needed,
however, to fully stabilized this site aDd remove the inmediate threat to
h\IDan health and the envirorment.
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SCOPE OF OPERABLE UNIT WITHIN SITE STRAT!XiY
'Ibe action proposed in the Record of Decision will red~ or eliminate
the most threatening hazards to hmaan health and the envirorment at the
Fike ChEmical Site. This acti~n will be an operable unit, or first
phase, of a long-tem remediation of all threats posed to public health
and the envirorment by the Fike ChEmical Site. This action will be
consistent with any future Remedial Action taken at the site. A RI/FS
is currently underway to investigate potential soil and groundwater
contamination as well as other potential affected media. The result of
the RIIFS will be used to identify additional remediation activities t«tich
may be necessary.
5mfoo\\RY OF SITE OiARACTERISTICS AND SITE RISKS
AtProximately 3"" bulk storage and process tanks are present on site, in
various stages of dilapidation, with a variety of waste streams
incl\J3ing acids, bases, flanmables, and cyanides. A minimun of 2"""
surface drums are also present onsite and are in uncontrolled storage
around the si te and in warehouses. sane of the waste materials fran
these drmas are incanpatible and, if mixed, could result in the formation
of dangerous canpouods. Also present onsite are approximately 8,"""
laboratory containers of known and unknown contents. ~roximately 199"
drmas are buried onsi te, as are an undetemined mlllber of additional
laboratory containers. Metallic sodilDt is contained in approximately 39"
of the drlDts onsi te, drmas which are in very poor condition. A
pressurized tank, of questionable integrity and filled with methyl
. mercaption , is also at the si te.
At the south end of the plant, a large, unlined lagoon contains waste
water that CST is incapable of treating. At the CST facility itself,
three lagoons are present. 'tt1ese lagoons were used in the wast~ter
treatment operations t«ten the manufacturing plant was active. .
A more detailed description of the characteristics and hazards at the site
is given below. .
I . Methyl Mercaptan Tank
LoCated oo-si te is a tank of methyl mercaptan, which is uncontrolled and
a threat to the CCI'IIDunity. Methyl mercaptan is an extrE!'llely flamaable,
poisonous material which has been found to have mutagenic effects. Nine
thousand gallons of this material has been found at the Artel/Fike Site,
stored as a liquid under pressure, in a rusted tank of questionable
integrity. The DDDediately Dangerous to Life and Health Level (IDLH)
of this caDpound is "9 parts per million (PPM), and would threaten public
health if a release occured. The site is located directly in the heart
of Nitro, west Virginia, aDd the estimated population of a ten mile radius
of the site is 25,111. EPA is currently monitoring the tank and taking
measures to ensure its stabilization. However, it is imperative that the
material be rEmOved to eliminate the threat to h\DaD health and the environ-
ment.
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II.
Surface Drun 9:moval q;,eration
The surface drun removal operation, being very canplex due to the variety
of waste streams found on si te, has required careful planning and organi-
zation and will continue to require a high level of proper planning to
ensure j!fficient and safe ranoval of surface dr\JDs on-site.
Open druns have been sampled and analyzed for caapatibility characteristics.
The analysis has categorized them into the following waste streams:
Acids, base/neutral liquids, base neutral solids, base/neutral organics,
c~nide liquids, cyanide solids, chlorinated organic liquids, £launable .
liquids, flcmnable solids, metals, air reactives, PCB's, oxidizers, and
peroxides. once the remainder of the druns have been sampled and
categorized, the materials will be bulked according to caapatibility
characteristics. At this point, the different waste streams will be
sampled and sent for disposal analysis pending the type of final
disposal. The bulking will be undertaken utilizing several different
methods. For the solids, the materials will first be sanple bulked into
a roll-off box to test for reaction, and then the canpatible materials
will be bulked into the separate lined 29 cubic yard roll-off boxes. For
the liquids, the canpatible materials will again. be sample bulked into a
bulking chanber to test for reaction. '1be caapatibles. will then be
bulked into the bulking chamber and removed with a 5909 gallon vaCU\D
truck. At that point, the materials will be properly shipped to the
final disposal facility, pending the type of final disposal.
III. Tanks, Lines and vessels
Assessment and sanpling of the tanks, lines and vessels is ongoing.
Ini tial estimates indicated that there are approximately 399 tanks and
vessels and extensive above ground lines onsi te. Total prod~ quanti ty
frao the tanks, lines and vessels is estimated to be 759,999 gallons.
After sanpling of each of the tanks, lines and vessels, the analytical
data will be used to bulk small cOmpatible waste streams into 5,999
gallon quantities for on-site treatment or for off-site treatment or
disposal 0 Bulking is estimated to take 29 days at a cost of $299,099 in
labor, equipnent and materials. Any large quantity (greater than 5999
gallons) of materials will be p.mped out of its container and either
treated or shipped off-site for treatment and disposal.
IV. Metall ic Sodi\D
An estimated 111, III pounds of metall ie sod i\D ex ists at the site. The
material is contained in approximately 299 dr\DS and approximately 1699
five gallon pails in a concrete bunker ~ich is presently being fed
nitrogen, but is not being effectively purged. Thedisp:>sal and handling
of large CIDOunts of metallic sodi\D presents several problEms. The dr\DS
appear to be in a deteriorated condition and moving these ~\DS will
require unusual care. Prior to disposal, the sodi\D will need to be
effectively staged and sampled.
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v. Laboratory packages
At the site, there are two primary laboratory areas which appear to have
been a quality assurance/quality control lab and a research/pilot plant
area. The bulk of the chemicals are found in a storage roan in the back
of the labs. Conditions in the storage roan and in the lab area in
general are congested. '!here is no segregation of incanpatible chemicals
on shelves and many containers are stored along walkways on the floor and
piled haphazardly on one another. The chsnicals range fran acids and
baseS to organic ethers, which can fOl1D explosive peroxides. Also found
in the lab area were various cyanide canpounds with the potential to fOl1D
c}9nide gas. Additionally there are nmterous samples, many with unlegible
or missing labels. Initial estimates indicate that there are 8,~99 chemicals
containers, ranging in size fran two ounces to five gallons, stored in
the lab areas. It is estimated that approximately 69% of the containers
are identifiable Imowns are 49% are canplete unknowns, based on walkthrough
assessments of the lab areas.
VI. The Lagoon and CST Facil i ty
The lagoon and Cooperative Sewage Treatment (CST) Facility are also areas
of considerable concern as each are leaking contaninated wastes and
discharging to the ground and (ultimately) the Kanawha River, respectively.
The CST Facility, when operational, was intended to treat liquid wastes
fran the plant. The CST, an activated sludge system, was designed to
treat surface runoff and process water fran the plant. The caDbined
vol \me of the ponds in the CST is 3S~,~99 gallons. The lagoon is a
surface impouncinent lined with low pel1Deability clay and located near the
southern border of the plant which holds approximately 2S9,~91rJ gallons.
Both systens are believed to be contaminated with volatile organics and
heavy metals. . .
VI I . Bur ied Dr\mS
An EPA Field Investigative Team (FIT) study of the Fike Chemical Site in
84 inclooed an investigation of buried dr\ms and bottles at the Artel
(Fike Chemical Site). Four areas of concern, covering an estimated
27,999 square feet, were reported to contain approximately 1S1rJ~ bUried
druns and lab bottles of unknown characteristics. .
1983-
DeSCription of Alternatives
using infollDation collected by EPA I son-scene. coordinators (0SCs) and the
findings of past and preseot investigations and data analysis. EPA has
developed the alternatives described below for an early action ROD
at the Pike QBDical Site. !PAis preferred alternative is based on !PAis
REmoval. Because !PA' s rEIDOval program may not have sufficient resources
to ccmplete site stabilization work in a timely manner, !PAis rEliiedial progran
has been activated to ensure the timely ccmpletion of site stabilization. since
time is of the essence, only the following two alternatives were considered.
Alternative 1 - No Action
with the No Action alternative~ EPA would not implement any measures to
protect either hunan health or the envirorment fran the uisting threats
at the Fike Chemical Site. Existing chemicals would be allowed to remain
onsi te wi th continued unsafe and improper storage and handling.
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12
This alternative would not minimize or eliminate, to any extent, the
iumediate, and possibly catastrophic, threat to h\Dan health and the
envirot'lDent that currently exists; In addition, this alternative does
not satisfy the mandate to utilize peananent solutions, nor does it canply
wi th other statutory requirEments.
Alternative 2 - Control, Stabilization, and Elimination
of Inmediate Hazards to Public Health
iiXi the Enviroanent
under this alternative, the most: threatening hazards existing at the Fike
Chemical Site would be redlDad or eliminated. This action would be an
operable unit at the site, the first phase in what will eventually be a
canplete remediation of other potential hazards at the site.
The fOllowing actions are proposed to be accanpl ished:
of)
a)
REmoval and disposal of the tank of methyl mercaptan tank;
b)
REmoval and disposal of the dr\IDs of metallic sodi\D1;
REmoval, bulking, and disposal of dr\IDS on the ground surface;
c)
d)
Rs'DOval, bulking, and disposal of the materials found in various .
tanks, lines, and vessels located onsite;
e)
.
Lab--packing and disposal of certain laboratory containers found
onsite;
g)
h)
Drainage and stabilization of the onsite and CST facility
lagoons; treatment of the drained liquids fran the lagoons; .
and discharge of those treated liquids to the Kanawha River;
Excavation, bulking, and disposal of buried dr\IDS;
Proper stabilization and/or rEmOval and disposal of asbestos -
containing insulation materials found in process lines;
i)
Proper removal and disposal of cyanides.
Although sane of the above listed actions may be accaaplished by the
removal problems, they are incl\X1ed in the scope of this ROD to ensure
that the work i8 c:ampleted. This initial phase of the Fike ChDical Site
remediation 18 aD interim measure necessary to stabilize the most: iDmediate
hazards at the site. ldditiooal remedial activities will likely be necessary
in the. future to address soil and/or ground_tar contamination.
. ,
screening of Technologies
A short discussion of the selected remedial methods considered for the various
hazards at the site follow. .
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Methyl Mercaptan:
onsi te flaring or incineration had been proposed for methyl mercaptan
but has been discounted for several reasons. 'ft1e caubustion prodtX:ts,
sulfur dioxide and sulfuric acid are poisonous and extremely corrosive
respectively. This makes onsite incineration impractical without a
canplete scrubber system. In addition, due to the high percentage of
sulfur in the canpound, burning must be a slow, am tedious period.
prodtX:ts of inCClllplete CCIIIbustion (PIC's) are also a problem. The odor
emitted fran methyl mercaptan is very noxious, even at the parts per
billion level. The most important factor is the proximity of the
ccmnunity which prohibits onsite incineration due to health risks.
treatment, as removal of this material would eliminate one of the most
severe threats presented by this site.
Off-si te incineration is recatmended as the option for disposal of the
methyl mercaptan. Aqain, due to the high sulfur content of mercaptan,
burning of the material must occur slowly. However, it can be shipped
offsite within two days of disposal approval to await incineration. This
option has a much lower risk to the surrounding ccmnuni ty than onsi te
treatment, as removal of this material would eliminate one of the most
severe threats presented by this site.
Surface Dr\DIS:
For Surface dr\.IDs, incineration is the recuulln:Y1ded disposal option for the
unknown organics, PCB's and flarrmables, as this method has proven itself
to be cost-effective and environnentally sound. The organic cyanides can
be incinerated, or disposed of wi th the inorganic cyanide wastes listed
below. The inorganic cyanides and sulfides can either be treated - through
-ion exchange cohmns or chenical oxidation off site, with both of these
methods cost effective due to the large cmounts of cyanide present.
Nonorganic acids and bases, and the air/water reactives (sodilDl addressed
later in this dOC\l'DE!nt) can. be treated offsi te through chenical reaction
. on a cost effective manner. ChEmical stabilization or fixation of the
base/neutral solids and metals will have to be initiated due to the lam
ban. .
Tanks, Lines, Vessels:
with respect to material in tanks, lines, and vessels, on -site treatment,
such as carbon adsorption for base neutral liquids which are not grossly
contaDinated with organics, cyanides or metals, is rec......~Jded. Initial
indications are that 35' of the tank waste is wash and rinse water freD
processes aDd could be treated on-site through carbon adsorption. Carbon
absorption is an effective technology for these waste streans.
Off-si te treatment is also reo ~.._ded for certain waste streams found on- .
site. Acids and bases can be neutralized off-site econaoically, since
they are estimated to account for only S% of the waste beUeYed to be
contained in the tanks, lines and vessels. Cyanide waste streams
require extensive off-site treatment and stabilization before dispoSal.
Ion exchange and chemical oxidation are just two methods of disposal
frequently used for the treatment of cyanide waste streams. Five percent
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of the waste quantity found in the tanks, lines and vessels is estimated
to be organic cyanide canpounds, which can be incinerated. Taking into
account that the last products made at the si te were cyanide based, it is
estimated that 29' of these. wastes are inorganic cyanide and require off-
site treatment mentioned earlier. The cost of treating cyanide waste
streams depends on the concentrations of cyanide waste. At this time,
these concentrations are unknown but are believed to vary fran almost
pure to very dilute.
Fifty percent of the waste found in tanks, lines and vessels is believed
to be incinerable wastes such as organics and flanmables. Incineration
is the disposal method reccmnended for these wastes.
Mettallic SocU\D:
If the sodi\.ID is to be disposed of off-site the druBS need to be removed
fran the bunker (or collected fran the surface) ~re currently staged,
and overpacked into shippable containers. As available disposal facilities
(\1i1ich will accept the sodi\D in dr\.DIs) have limited reactor space, the
shiIJUents off-site for disposal will have to be spaced over several months.
This will make it necessary to maintain a sodi\D1 dr\.DI staging area until
the sodi\D is disposed of. Due to lower costs and lower risk to the
surrounding caununi ty, off site treatment is the preferred method of disposal.
The sodi\D can be treated onsite by reacting the metal with excess water
in a tank or cage. The sodhm dr\.DIS must first be removed fran the
b\Z1ker (or the surface of the site) and properly staged. There are
differing methodologies for this reaction, however, as long as a provision
to deal with the fire and explosions likely to occur exists, and there is
a way to contain or restrict the fomation of pl\lDeS, t;he advantages of
this procedure are that it is cost-effective and is that it proceeds well
wi th small pieces of sodi\D. The sodilm can be treated canpletely leaving
only basic (high pH) Wlter. The main expenses are the personnel costs
associated wi th the handling and treatment of metal, and the costs of
sizing or shredding the dr\.DIS of sodi\D. This method has been successfully
utilized at previous Superfund Ienoval Actions. This method has sane
disadvantages. The reaction of metallic sodi\D and water is violent,
highly exothemtic, and produces large clooos of caustic particulates
(NaOX, NaOH), and flanmable hydrogen gas. Also, the handling of the
sodi\D metal represents a hazard to personnel handling the wastes. The
formation of hydrogen gas represents a fire and explosion hazard, and the
fomation of caustic particulates mandates the need for fog or water
spray to supress these clouds. The reaction of sodita with water is not
time effective when very large vol\lDeS need to be neutralized. To mobilize
and set up a systa that could effectively neutralize the amount of sodi\m1
at the site would take fraa five to ten days. The neutralization operation
could be ace- IMplished in 39 to 35 days.
The metallic sodita can
be dissolved into alcohol to fom sodima ethoxide or sodi\J8 methoxide.
The advantages of this is that the waste stream US\DeS the characteristics
of a flcmoable, reactive liquid," instead of an unstable, air and water.
reactive solid. This makes the waste p.mpable, pourable, and suitable
for shipuent and handling in standard dr\m1s. Disadvantages of this method
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. -. . .
15
are that the dissolution of metalic sodium in alcohol is a ttme consuming
process. The volume of the resulting wastestream will increase considerably
over the volume of the sodium metal. The dissolution of sodhm in alcohol
is not without risk, and can liberate significant anounts of heat (depending
upon impurities in the sodium). The resulting sodium methoxide (or ethoxide)
is costly to dispose of as it is an extranely strong base. This technique
requires significant vol\JDe5 of alcohol if large anounts of sodium are to
be treated. The duration of a dissolution operation is difficult to
estimate, the mobilization and set-up of the necessary apparatus, and the
refinement of the dissolution process being the limiting factors. It is
not unreasonable to aSS\De that the dissolution of the sodi\D will take
approximately as long as neutralization of the sodi\D with water; hcNever,
the dissolution of the sodil.lD will be more expensive than the sodhm
neutralization.
Laboratory Chemicals:
KnOwn laboratory chemicals are segregated according to compatibility class,
and are packed in fiber drums filled with absorbant and then can be sent
for incineration.
unknown lab containers cannot be easily identified and therefore must be
remotely opened. With the quantity of unknown lab containers on the site
(approximately 3,8"">, this will entail crushing the containers, mixing
the waste wi th inert material, storing the mixture in rolloff boxes,
sanpling the mixture, and final treatment and disposal of the waste material.
Disposal will be either by treatment, landfill or incineration, depending
on analytical results. The unJmowns will have to be segregated fran the
knowns and prepared for crushing during the lab pack operations. Prepar-
ations of crushing area wil~ take approximately one week and crushing
operations approximately two weeks. .
. ..
-
Lagoons and CST Facility:
The most cost effective option available for the Lagoon & CST facility
would be to develop an on-site Water treaOment plant for volatile
organics and cyanides, and CST Facility. The treated effluent would be
punped into the Kanawha River, in accordance wi th the NPDES pemai t issued
by WVDNR. The resulting contaminated slOOges and soils would be sent
off-site for incineration or treatment.
Bur ied wastes:
Assessment of the four areas of buried wastes will be condu::ted by TAT to
detemine actual excavation locations, depth of burial and vol\DeS of
soil to be excavated aDd wastes to be rBDOved. Sanpling and characterization
of the drUDDed wastes for bulking and disposal will be according to the
scope of work for surface dr\JDs.
~ OF COMPARATIVE ANALYSIS OF ALTERNATIVES
1)
OVerall protection of H\Dan Health and the Fnvironnent
The No Action alternative provides no protection of either 1uDan health
or the envirorment. It does, in fact continue to pose existing, and even
create new, threats at the site.
The Control and Stabilization alternative will reda::e and/or eliminate
the most iDminent threats to hmian health and the environnent by
removing, neutralizing or destroying the hazardous substances associated
-------
16
with those threats. Risks associated with direct contact, fire, and
explosion hazards would be eliminated.
Canpliance with Applicable or Relevant and Appropriate Requirements (ARMS).
The ARARs considered for this interim remedy are only those which pertain
to the action being taken to stabilize the site and eliminate the .
imninent hazard to hanan health and envirorment. The ARARs for the
entire site will be addressed in a subseqUent Record of Decision.
The control and Stcibilization Alternative would meet the ARARs identified
in the attached ARARs canpliance matrix (Table III). Specific parameters
for a discharge of treated water to the Kanawaha River are shown in Table
IV; should these parameters be revised by the WtDNR, the revised
standards will take precedence and will be met through treatment.
Long 'rem Effectiveness and pennanence
The control and stabilization alternative will provide reliable
protection of h\Dan health and the envirorment over time by eliminating
hazards at the si te which are both current and future risks. 'rhis .
alternative will also allow the long tem remediation process to proceed
without any iominent threats to h\Dan health. Mditionally, no long tem
management of the wastes addressed in this Record of Decision will be
needed .
Reduction of Toxicity, MJbility, or vol\De
The No Action alternative provides no red\X:tion of either toxicity, .
mobility, or voltDle of the waste at the site.
The control and stabilization alternative will provide for visually total
red\X:tion in the toxicity, mobility, and voltDle of wastes since these
wastes will be either destroyed, neutralized, and/or rEmOVed canpletely
from the site. Residuals fran treatment process will be disposed of offsite.
Short-tem Effectiveness
Under the No Action Alternative, a continuing severe and iominent threat
continues to be imposed on both h\.l1lal1 health and the envirorment, a
threat which would not be abated in any fom until canpletion of a
REmedial Investigation,lFeasibility Study and lBDedial DeSign.
The control and Stabilization alternative will allow remediation of
existing threats in 6 to 12 IDOnths with little, if any, adverse impacts
on h\Dan health and the eaviroaaent. SaDe minor impacts may occur during
implementatioa of this alternative due to fugitive dust, vapors/odors,
and offsi te tran8p)rtatioD of wastes; howver, these impacts are
considered almost insignificant and would be controlled and monitored
to the extent. possible through implementation of appropriate ARARs.
.. .'" . . , ' .' . -.' ;-, . ~ . -...
-------
Implementability
Altho\J;Jh services required for treatment and disposal of sane wastes at
this site are not readily available, they do exist and will be obtained
for use in this remediation. NO technical or administrative obstacles to
implementation appear to exist.
Cost
The No Action alternative would have no costs associated with it since no
Remedial Action would occur until canpletion of the RI/FS.
TOtal costs of the Control and Stabilization alternative are estimated to
be $8 million. There costs are capital costs for project implementation
and, since it is anticipated that the Renedial Action will be canpleted
in 6 to 9 months, these costs may be considered the sane as present worth
costs for this action. There will be no operation and maintenance costs
associated with this alternative. Operation of the treatment system for
CST and the lagoon is considered part of the interim remedy and not
subject to operation and maintenance. Final disposition of the lagoon
area and the CST will be addressed in the next 10). The costs estimated
for this action may be adjusted to take into accoWlt either work canpleted
by other parties before, during, or after this action or by the discovery
of presently Wlkno~ quantities or types of wastes at the site. It is
not expected however, that the actual cost will vary significantly frau
the estimated amoWlt.
State Acceptance
The State of West Virginia, Department of Natural Resources, has reviewed the
info~tion available for this site and has concurred in this Record of Decision.
Carmuni ty AcCeptance
A public meeting was held in JUly, 1988 to inform local" residents and
businesses of the nature and purpose of EPAIs activities at the site, and
site, and a subsequent public meeting was held on September 14, 1988 to
describe actions pro{X)sed to be taken. as described in this record of
decision. Although an extremely high level of concern exists over the
removal/remedial actions at the site, callDWli ty support for the Federal
and State action appears high. Refer to the res{X)nsiveDeSS S\DDary attached.
The Selected REmedy
After consideration of infomation available for the FiJce CbDical Site,
inclu:iing the doc\JDeDts available in the Idministrative Record, aDd an
evaluation of the risks currently {X)sed by the site, and ca'llDunity input,
EPA has selected Alternative 2, Control, Stabilization and Elimination of
the DDDinent Hazards as the al ternati ve to be implemented at this site.
This alternative will eliminate virtually all current and iDmediate threats
to public health and the envirorment and allow for caapletion of the
RI/FS process. This alternative will remove a real and iDminent threat
to the safety of the people of Nitro, west Virginia, and the adjacent and
surrounding properties.
As required by Section Ul of CElCLA, Alternative 2 is protective of
h\Dan health and the envirorment, red\D!S the vol\De, toxicity, and
mobility of contanination, Will attain ARARa, and utilizes pe~t
solutions to the maxim1D extent practicable. This alternative is cost
effective in that it achieves imPlementable objectives and offers an
effective, implementable remedy which provides long tem remediation by
destroYing or removing contaminants of concern frau the site.
-------
~-.._.~
ARARs
COmpliance Matrix
Fike Chemicals Site
Table III
Alternative 1
Action/ARAR
No Action
1. Di~ge of treated
water into Kanawha
River.
N/A
2. Release of air Emissions fran N/A
soi 1 movenent dr\D\ stag ingj
disposal/treatment operations
3. Offsite shipment of
hazardous waste
N/A
4.. QlSi te trMtment of
contaminated wstewter
fraa CS'r aDd lagoon..
N/A
5.. REmoval/Disposal of
asbestos wastes
N/A
Alternative 2
Control/Stabilization
Direct discharge of treated
CST and lagoon wastewater
into the Kanawha River
must satisfy substantive
standards of the clean
Water Act {3S4, {3S2, and
4S CFR {{ U2, 125, and 136.
Additionally, specific discharge
limitations for parceeters listed
in the NPDES discharge pemit
issued by WVDNR for the CST
facility will be achieved (Table
IV) 0 If these standards are
revised by WVDNR before
initiation of the rEmedy, the
revised staooards will take
precedence and wi 11 be achieved
through treatment.
Any air Emission generated by
the Rsuedial Action will not
exceed National linbient Air
Quali ty Standands.
Any shipoent of hamrdous waste
offsite for treatment/disposal
must satisfy the provisions of
!PAis offsite policy.
oruess UEmpt under 41 CPR { 264
as a wastewater treatment Wli t, .
tanks must be constructed
operated, in accordance with.
the applicable requirEments
of 48 CPR ( 264.1 - .178 and
subpart J.
Asbestos must be handled in
accordance with the National
envirormental Standards for
Hazardous Air pOllutants (NES'..1)
41 CPR 61.14 SUbpart M.
.'.' ~, ,_. . '.. ~,~
-------
'.. .-:,' ~ ..' .' '.'.' .
ARMs
Canpliance Matrix
Fike Chemicals. Site
Table III
Al temative 1
No Action
Action/ARM
6. a) Removal of Methyl
Mercaptan Tank
b) RemOval, bulking and
disposal of material fran
tanks, lines, and vessels.
N/A
7. a) Rsnoval and disposal of N/A
dr\IDs of metallic sodi\JD.
b) RemOval, bulking, and dis-
posal of dr\JDs on ground
surface.
c) Lab packing and disposal
of laboratory containers.
d) Excavation, bulking," and
disposal of buried dr\JDs.
8. Drainage and stabilization N/A
of the onsite and CST facility
lagoons. Treatment
of liquids and discharge.
~ ...., '., -.' . .
Alternative 2
Control/Stabilization
All appropriate sections of
SUbpart J, Tank systems
stamards. 49 CFR 264.199-199
All appropriate sections
of subpart I-Use and
managenent of containers. .
49 CFR 264.179-178
All appropriate sections
of Subpart K-surface
rmpourdnent Standards.
49 CPR 264.229-231
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TABLE I
History of RCRA and NPDES Inspections at Fike Chemical and C.S.T
Date of
Inspection
November 29, 1989 (lA)
Condu:ted
By
violations
EPA
violations were not cited, as RCRA
was effective as of November 18, 1989.
The Inspection specifically noted that
both the Fike and C.S.T. facilities
were poorly prepared for the RCRA
regulations.
Eight month reinspection found Fike and
found Fike and C.S.T. had made no
progress in canpliance. A copy of West
virginia's proposed regulations and
sent again on DeCEmber 21, 1981. Nine
specific violations at C.S.T., including
poor operational records, hazardous
waste managenent areas in poor cordition,
the lack of freeboard and no groundwater
monitoring. at C.S.T.
July 28, 1981 (2)
WVDNR
December 29, 1981 (3)
WVDNR
A copy of this inspection was sent to
Respondents on March 5, 1981. The
inspection noted virtually all the
violations as in the JUly 28, 1981
inspection.. . .
December 21, 1982 (7)
WVDNR
'ft1is inspection, condu:ted after EPA and
Respondents had entered a Consent Decree,
found again that the previous violations
continued, citing eight at Fike and
twelve at C.S.T. A copy of the inspectiol
was sent to Respondents on February 4,
1983.
February 28, 1983 (9)
WVDNR
'b inspection concentrated on major vio-
lations of Pike and noted only three .
inches of freeboard for the mDber three
lagoon, leaking dr\IDS, damaged dikes, and
a previously cited hole in the fence that
had not been repaired.
Inspection of Fike condu:ted SUbsequent
to issuance of State acDinistrati ve
- order on March 18, 1985. Certain druns
had been r8DOved and dike repair initiate
howver, freeboard was only one foot at
lagoon nauber 3.
May 11, 1983 (11)
WVDNR
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TABLE I
History of R:RA and NPDES Inspections at Fike O1enical and C.S.T
Date of
Inspection
CorKi\X:ted
By
WVDNR
violations
August 16-17, 1983 (58)
February 23, 1984 (14)
WVDNR
NPDES inspection.
Inspection of Pike corKitrted by anerqency
Response section. 'lt1e inspection concen-
trated on dr\JDS, whicl'i had no waste
analysis corKiu::ted and were in deterioratl
corKii ticm, many of which were leaking.
March 28, 1984 (15)
WVDNR
CorKiu::ted a followup to February 24, 1984
inspection and found no action had been
taken to rElDOve leaking dr\JDs of Fike.
'l'his inspection specifically noted poor
security and the continued lack of free-
board.
June 14, 1984 (29)
WVDNR
In response to canplaints, representa-
tives of the west Virginia Air pOllution
Control Ccmnission cited Fike for open
burniD;J of hazardous waste under the
applicable state 1CRA regulations.
August 16, 1984 (69A)
August 21, 1984 (21)
WVDNR
Oil spills.
August 22, 1984 (22)
EPA
Inspection corKiu::ted of Respondents' fac-
ilities to detenuine canpliance with EPA
canpl iance canplaint. 'lt1e inspection .
ci ted that waste analysis was not properl ~
performed, that the container storage are
was still in poor corKii tion and that poor
security existed. 'ft1e inspection also
stated that there was not RCRA qroumwate
monitoriD;J systsD for C.S.T. and an impro-
perly monitoring and possibly inadequate
systsD for Fike.
A research saapling inspection on release
of volatile organics by surface impourKi-.
ments at Respondents' facilities was con-
da:ted by EPA's Office of Air ()1ality and
Planning Standards in Res~-rch TriaD;Jle
Park, North" Carolina.. 'ft1e saapling resul
indicate that hazardous wastes and con-
sti tuents are in the impourdDents. Also
the report noted the freeboard ~Emen
were less than two feet for all three
EPA
-------
-. - '--.~ -.' - -,. - .
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TABLE I
History of lCRA and NPDES Inspections at Fike O1emieal and C. S. T
Date of
Inspection
Condu=ted
By
violations
October 29-39, 1984 (23 & 24)
EPA
surface impoundments. This was not a
canpl iance inspection.
EPA condu=ted ext:ensi ve groundwater .
monitoring for C.S.T. showed many hazardc
wastes and waste constituents were in thE
nonpeanitted impoundnents. The inspectie
and sanpling of the Fike well system indi
cated that hazardous wastes were present
in the groundwater because of release fre
the Fike site. The -inspection also note:
that the sl u3ge had a high cyanide conter
but Respoooent did not manifest it as a
hazardous waste. .
March 14-15, 1985 (63)
April 8, 1985 (31)
WVDNR
NPDES .
EPA
Evaluation of the C.S~T. facility to
deteanine canpliance for the Loss o~
Interim Status requirements. Ins~ \on
noted that wells were installed at __~SoT.
howver, no survey was condu=ted. The
C.S.T. hazardous waste units were capable
of receiving hazardous waste, however,
due to lack of recordkeeping and wi thout
continuous sampling it is difficult to
demonstrate if hazardous wastes are
entering the impounciDent.
Evaluation of the Fike facility for LOIS.
January 7, 1986 (41)
February, 1988
EPA
EPA
Fast-Track limited sanpling for R:RA
evaluation.
-------
Date
5-29-76
4-15-81
9-28-82
11-9-82
11-16-82
3-18-83
1"-17-83
Action
oov
Consent
Order
t«)V
NOV
Consent
Decree
Admini-
strative
Order
JlJlDeldDent
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TABLE II
History of RCRA &'1forcenent Actions
EPA/WVDNR
EPA
WVDNR
EPA
EPA
EPA
WVDN.R
WVDHR
violations
NPDES
NPDES
For C.S.T. Failure to
sutmit RCRA required
financial docunents due
July 15, 1982.
For C.S.T. Failure to
sutmit quarterly ground-
monitoring reports.
Required actions to
prevent continued re-
leases of contaminants
into surface and ground-
waters and remedial
action to delineate and
contain and/or rEmOve
contaminations. Included
provision to canply with
all applicable environ-
mental requirements such
as RCRA..
To both Fike and C.S.T. for
continued operational and
recordkeeping violations.
Order incl \z3ed lack of
freeboard .
Allowed time extensions for
certain parts of 3-18-83
Order. Specifically dis-
allowed Respondent's plan
to . achieve freeboard and
required i.omediate removal
of.excess liquid.
I J',
Resolution
Deficiencies in docunents
sut:mitted, included in ~
sequent EPA canplaint.
Facility has not met all
financial requirements.
NOT RESOLVED.
RCRA required reports have
not been sutmitted. C.S.T.
proposed to install RCRA
systaD in March 1983, how-
ever, never implemented.
NOT RESOLVED.
Many orig inal requirements
extended, however, certain
requirements have not been
met. Respondent has fai led
to delineate contaminate
pI \De. Respondent has not
canplied with many environ-
mental requirements such as
NPDES and RCRA.
Al though sane violations wer
initially canplied with, the
have reoccurred.
!Or RESOLVED>
Certain violations have re-
occurred .
!Or RFS>LVED.
-------
TABLE I I
History of RCRA Enforcement Actions
Date Action EPA/WDNR violations Resolution
5-9-84 { 3f1f1 (a) EPA To Fike, required rEmOval The dr\.l11S were removed, the
Caapl iance of danaged leaking, uni- 'financial doc\Dents have not
CaDplaint dentified drllDS stored in been corrected. Respondent
nonpetmitted area. CaD- has refused to. pay a penal ti'
plaint included proper Administrative Law Judge
wording of financial doc- hearing is scheduled for
\Dents. October 3, 1985.
5-23-84 OOV . EPA Fail ure to sut:mi t annual Respondent did not sutDi t
ground water report for any required ground water
C.S.T. reports for C.S.T. as no
wells had been installed,
even though Respondent
claimed would install
I wells and caDplete a years
sanpling in January 21,
1983 response to EPA' s
November 9, 1982.
I ~ RESOLVID.
Notice To both Fike andC.S.T. 'ft1e deficiencies have not
I U-26-84 WVDNR
of Non for deficiencies in been addressed.
canpli- closure plans. NO'!' RESOLVID.
ance
3-12-85 NOV EPA To C.S.T. for an incanplete Respondent sut:mi tted a
and Part B Application. response on JUne 6, 1985
Notice Incanplete due to nunerous and a groundwater plan on
of De- deficiencies ,in appli- May 3f1, 1985. 'ft1e response
ficiency cation. was evaluated and as of
August 29, 1985, n\Rerous
deficiencies continue to
exist.
8-7-85 t:JN EPA To both Fike and C.S.'!'. Response was due no later
for failure to sul:l'Dit re- August 26, 1985. No
quired infomation on report response received to
solid waste management date.
units.
11-15-85 Notice EPA To C.S.T., due to failure ~t period allowed until
of in- to adequately respond to January 17, 1986. No
tent to the March 12, 1985 NCD/ C-U-Its received.
NOV and failure to subDit
SWHU infomaation.
I ".
, ,
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TABLE II
History of RCRA ntforcsnent Actions
Date Action EPAfttM)NR violations Resolution
12-12-85 { 3998 EPA To Fike ChBnical, Respon- Payment has been made and
(a) Final dent admitted as fact, the Order initially complied
Order basis of the May 9, 1984 wi th al tho~h it appears
and Con- CaDplaint and 19reed to fran follow-up inspections
sent canply with the CaDpliance that FiJce is not coDtinuing
Agree- Order and pay a $5,999 wi th recordJceeping.
ment penal ty.
3-14-86 Ter- EPA To Fike and C.S.T. for Respondents' cauPliance in
mination failure to ccmply with issue.
Interim LOIS or suklni t and adequate
Status Part B.
Denial EPA To C.S.T. C.S.T.' s
of RCRA canpl iance in issue.
Permi t to
store and
treat haz-
ardous
waste.
1-8-87 Consent WVDNR RCRA-primarily dr\m storage.
Order
7- -87 Civil EPA RCRA/NPDES NONE
Action
1- -88 . .Inj UDC- WVDNR RCRA NONE
tion
-------
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Table rv
CUrrent NPDES Parameters
. Discharge Limits
for CST Inc.
parameter Penni t Limitation (pounds/Day)
AVG. l1JN'IHLY M.\X. DAILY
Chemical Qcygen Demands 598 2999
BeDS 137 273
Total Suspended Solids 27 54
oil and Grease 5 8
Phenols .3 .7
ADmOnia 16 23
Chloride 5999 69"9
Arsenic .1 .2
Surfactants 5
Nitrates 7 14
Sulfates 529 975
Total Sol ids 8999 9299
Al \.JIIin\D 19 16
Total Ckganic Carbon 359 799
Iron 5 19
Barb. .5 .1
CaciDi\ID .92 ."5
Lead 1 2
Mercury . .1 .2
Hexavalent Chrcmi\D .1 .2
-------
~._...-_._,-<._'._..-....._..~.~ .~
ENFORCEMENT CONFIDENTIAL
ENFORCEMENT CONFIDENTIAL
EPA'S September, 1988 early action Record of Decision (ROD)
provides for the Region III Superfund Branch to assist the
Region III Emergency Response and Preparedness Section (ERPS)
in their stabilization of the Artel (Fike) Chemicals site.
Because of the extensive and costly nature of the ERPS
removal action, additional resources are needed to complete site
stabilization activities. The Region's early action ROD
parallels the ERPS removal plan and ensures that the plan will
be completed jointly by ERPS and the Superfund Branch.
The ROD provides for site stabilization of the facility
surface. Contaminated soil and groundwater will be addressed
in a subsequent ROD.
The number of PRPs that will ultimately be identified for
the contamination which is the subject of the early action ROD
are currently unknown. Notice letters hav ae been sent to the
owner/operators of the site including those entities which
control the decision-making of Artel Chemical through their
majority stockholder interests.
. The only companies that have peen identified to date as
having sent their wastes to the site are Union Carbide corporation
and Polaroid corporation. Union Carbide Corporation"will
shortly be sent a notice letter. While POlaroid Corporation is also
a PRP, their liability for the surface stabilization work is
unclear as Polaroid voluntarily removed some or all of their
drummed waste from the site in 1986. The Agency has not determined
whether Polaroid's waste was ever recycled or treated at the
CST facility which would provide an independent basis for PRP
liability. A decision on when to send POlaroid a notice ~etter
will be made shortly.
Although general notice letters have been and will be
sent to various PRPs, these parties will not be sent special
notice letters. Rather, EPA will notify the PRPs that because
the site's environmental problems must be addressed
immediately by the Superfund Branch due to the limited funding
available to ERPs and the dangerous nature of the Site, EPA cannot
activate the negotiating moratorium provided for in Section 122(e)
for special notice letters. Rather, EPA will send such parties
letters outlining the above concerns and stating that a
negotiating moratorium WOUld not be in the public interest. This
procedure is set forth in Section 122(a). In addition, the
Section 122(a) letters to the various owner/operators will
also specify that EPA nad determined that a special notice
letter would be inappropriate for them because EPA has determined
they are unable to stabilize the site as outlined in the ROD.
-------
It should be noted that joint and several liability only
attaches to PRPs whose wastes at a site were comingled with
the wastes of other parties. However, since much of this ROD'~
site stabilization concerns labeled drums and cylinders, certain
companies may be able to identify and isolate their wastes .
and therefore limit their liability to those containers.
This defense will not be available for companies whose wastes
were sent to CST treatment system or the lagoons since these
wastes were intermingled with other wastes places in such container:
The major defenses the Agency can expect in a future cost
recovery include:
a.
Did the Agency act in an arbitrary and capricious
manner in declining to send special notice
letters out to the PRPS?
b.
Did the Agency act in an arbitrary and capricious
manner in analyzing only two alternatives for the ROD
Did the Agency act in an arbitrary and capricious
manner in handling an emergency removal action
under the remedial ROD process?
c.
d.
For those companies which sent waste to the site,
is their liability joint and several or
identifiable and limited?
These issues were all discussed by appropriate Regional
personnel and a decision was made to proceed with the ROD procb~s
to stabilize this site. The brief rebuttal to the PRPs anticipated
defenses are:
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a.
The decision to send Section 122(a) letters instead
of Section 122(e) special notice letters was
necessary to ensure timely site stabilization
and is not subject to jUdicial review.
See Section l22(a).
b.
Due to the time constraints and the emergency
nature of the site, the need to act swiftly to
stabilize the site outweighs the benefit of
studying a number of alternatives for cost-benefit
purposes. Also, the alternative chosen is the same
as recommended by EPA's ERPs which, were ERPs to
implement the alternative as part of the removal
action, would not be subject to an alternative
analysis defense by the PRPs. .
+
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c.
There is nothing in the NCP prohibiting
removal-type actions from being handled as
remedial-type actions pursuant to a ROD.
The joint and several liability issue will be
addressed when EPA has a greater knowledge
about the wastes sent to the site by the PRPs.
d.
-------
',:"_..~' :'.-.-$'
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.ID CDJIICAL 8IH
BI'!RO, n8'! VIRGIBIA
.IDL
RJl8POB8IVDIII88 8UIIIGRY
8BPnJlBB. 1988
This Responsiveness Summary documents public
comments expressed during the public comment
summary also documents EPA's responses to the
concerns that were received. Information is
follows:
concerns and
period. The
comments and
organized as
OVerview
Summary of Community Involvement
Summary of Comments and Responses Regarding the Removal
Action and Proposed Plan for Interim Remedial Action
4.0 Other Concerns and Responses
5.0 Additional Remedial Alternatives
6.0 Remaining Concerns
Attachment:
. Community Relations'Ac~ivities at the Fike Chemical Site
1.0
2.0
3.0
1.0
OVBR'nn
The public comment period for the Fike Chemical Site began on
August 27, 1988, and extended to September 25, 1988. To
facilitate commenting, EPA briefed community officials in a
meeting at City Hall and held a public meeting at Nitro Junior
High School on September 14, 1988.
At the meeting, EPA discussed the removal actions in progress at
the site and explained the EPA's Proposed Plan for interim
remedial actions. The discussion included an explanation of the
financial constraints of the removal program and the need to
initiate interim remedial measures so that efforts to stabilize
chemical hazards at the site can continue without interruption.
EPA's preferred alternative for interim remedial action involves
the control and stabilization of the site and the elimination of
immediate hazards to public health and the environment by the
initiation of the following measures: removal and disposal of a
methyl mercaptan tank and drums of metallic sodium: removal,
bulking, and disposal of drums on the ground surface and of the
materials found in various tanks, lines, and vessels on site:
lab-packing and disposal of certain laboratory containers
1
-------
onsite:drainage and stabilization of onsite lagoons and
treatment of the drained liquids: excavation, bulking, and
storage of buried drums: proper stabilization and/or removal and
disposal of aSbestos-containing insulation materials found in
process lines; and proper removal and disposal of cyanides.
Officials of the West Virginia Department of Natural Resources
(WVDNR) participated in the public meeting and supported EPA's
preferred remedial alternative. Local officials and residents
were also in agreement with EPA's Proposed Plan at the time of
the meeting. The only dissenter who spoke out during the
comment period was a former Fike-Artel employee who appeared to
be objecting to the presence of' EPA's out-of-state removal
contractor at the site, rather than commenting on the Proposed
'.' Plan.
2.0
StJJOlARY 01' colOltJllzn ZIlVOLVBKBIrl'
Although residents of Nitro, West Virginia, the community
surrounding the Fike-Artel facility, were well aware of the
facility's status as a National Priorities List (NPL) hazardous
waste site, most were not alarmed by the site. Many residents
are financially dependent upon chemical manufacturers and
processors operating in the Kanawha Valley and, according to
local officials, generally perceive the chemical industry as
quite safe.
Despite numerous air emissions and fires that occurred at the
site during its operation, State and Federal officials reported
little community interest in the site, although local officials
did receive some concerned inquiries regarding air emissions
from the plant. .
When the.EPA Community Relations Plan was being developed, both
residents and local officials said they welcomed the Federal
Super(und investigation. One official said the " community was
"relying on the experts" to determine whether the facility posed
a significant health threat and whether it should be closed.
Several people indicated a belief that Fike-Artel might have
caused unnecessary risks because of careless work and storage
habits at the plant.
The level of concern about the site remained low until July 1988
when the site owners/operators walked off the job after the
facility's utilities were cut for non-payment of bills. Angry
workers, who had not been paid for 2 months prior to the
walk-out, reportedly watched the site for 2 weeks because they
did not want assets removed from the site until they were
compensated. v
2
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On July 28, 1988, EPA conducted a public meetinq to discuss the
Aqency's plans to stabilize danqerous conditions at the
abandoned site. Three hundred residents and former workers
attended. Three former Fike-Artel employees who were present
said that EPA was overreactinq reqardinq risks posed by the site
and recommended that the Aqency solicit former workers to help
at the site.
A second public meetinq, held by EPA on September 14, 1988, was
attended by approximately 70 people. Overall, the proposed
evacuation of the community durinq some removal actions was the
primary topic of discussion. Immediately prior to the meetinq,
EPA representatives received a copy of a public opinion survey
from the mayor of Nitro. Althouqh the mayor had no knowledqe of
who was responsible for the survey, it had been conducted by a
reputable Charleston public affairs firm. The survey concluded'
that, in qeneral, the local community supported the EPA's
presence at the site and was pleased with the .EPA's work to
date. .
On September 22, 1988, approximately 100 local residents met
with EPA to discuss plans to evacuate 5000 residents over the
weekend while a removal contractor, OH Materials, removed a tank
of hydroqen cyanide (HCN) from the site. Aqain, the issue of
whether EPA was overreactinq reqardinq risks was raised, as was
a complain~ that the planned evacuation would complicate the
return of Boy Scouts attendinq a jamboree.
On September 23, 1988, shortly before the implementation of
evacuation plans, OH Materials announced that it would not
remove the HCN tank, apparently because of renewed liability
concerns. Subsequently, EPA issued a press release and held a
press conference to explain the cancellation of the HCN removal
and evacuation plans to the community. The Mayor of Nitro also
held a press conference, durinq which he withdrew his support of
EPA activities at the site as a resu~t of the evacuatiOn
cancellation.
3.0
smacaay 01' COIlllBftS UD USPO.SBS
The comments and responses summarized in this section were made
durinq the public comment period held in late Auqust and early
september 1988. They reflect concerns reqardinq both the
removal proqram activities and the Proposed Plan interim
remedial actions because the interim remedial actions are the
continuation of actions undertaken by the removal program which
the removal proqram is not funded to complete. Comments
numbered 1 throuqh 9 were presented at a public meetinq held
locally on September 14, 1988. All other comments were
submitted to EPA in writinq.
1.
Five questions were asked reqardinq emerqency evacuation.
Residents wanted to know if EPA is confident that the site
3
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BPA ..SDODS.S:
does not pose a hazard sufficient to cause
ev~cuation of local schools now. They also asked
how long it would take to evacuate the schools
and the immediate vicinity in a worst-case
scenario and whether the required time would be
sufficient to save lives. One resident, who
stated that she had no idea where her child might
be sent during an evacuation, suggested that a
trial evacuation should be considered to test
emergency preparedness.
The EPA is confident that there is no need to
evacuate the local community and schools at this
time. Also, any operations that EPA considers to
involve high-hazard activities will be conducted
when schools are not in session. The activities
being conducted during school hours are pr~marily
normal drum sampling, staging, segregating, and
moving activities.
EPA met recently, with the school principals and
representatives of Putnam and Kanawha Counties,
the emergency planning commission, and the City
of Nitro and any evacuation that might be needed
was discussed, and the responses were planned.
County representatives in the audience added to
EPA's response as follows:
In the event of an emergency, school district
buses and radio-equipped, pUblic transit buses
would respond to any call for help.
Consequently, buses would begin arr~ving at the
schools minutes after a call is issued. Under
the best conditions, most buses would arrive in
. under 15 minutes; under the worst-case scenario,
it might take 45 minutes to get the buses into
the area. If things went well, approximately
3,500 people would be evacuated per hour.
Depending on the specific circumstances at the
time, an evacuation may include from 4,000 to
12,000 people. If evacuation of 3,500 people per
hour occurs under optimum circumstances, then,
it's probably going to take four to six hours to
get everyone out in a large scale evacuation.
Whether this is adequate timing depends on the
specific occurrence. Kanawha County conducts
tests of the plan in different areas,
periodically, to see that. it works well.
The schools, the planning commission, and the
counties have also considered that evacuation 'may
not be the best answer to an emergency at the
Fike Chemical site. Depending on the type of
chemical involved and the chemical concentration
4
-------
level, it may be preferable to shelter the
students in the schools and to ask residents to
stay indoors. In some instances, sheltering may
actually be a better solution than going out into
a contaminated environment.
In the past, the schools have attempted to
shelter students in emergencies, but parents,
trying to locate their children, breached the
security of the shelter by opening the doors and
letting in the contaminated air. Parents must
understand that in such a situation, they should
not come to the schools until the environment is
declared safe.
Four questions asked pertained to EPA's knowledge of
hazardous substances present at the site. Residents
wondered whether EPA reviewed available files for possible
hazardous substance identification before going onsite and
. if so, why the stabilization was taking so long. They also
wanted to know if the most dangerous substances onsite were
those named in the press: phosgene, mercaptan, and metallic
sodium.
2.
BPA ..aDona.:
Whenever EPA is investigating a hazardous waste
site, all available records are reviewed to
determine what substances of concern may be
present on site. The available files. were
examined for this site, and EPA also talked to
people, including Elmer Fike, who were expected
to have knowledge of the site. The problem is,
that record-keeping and housekeeping at the Fike
Chemical Site was inadequate. In 1984, a law,
known as the ResourceC known as
Act (RCRA), was amended to require anyone
involved in a business that handled, produced, or
stored hazardous substances to apply for a RCRA
permit (known as a Part B permit). Had
Fike-Artel done this, an investigation of
conditions at the facility would have been
conducted, and the resultant information would
have been very helpful, but EPA is still involved
in lengthy litigation with Fike-Artel concerning
the company's failure to comply with the RCRA
requirement. .
Because of the incomplete nature of the files and
the careless manner in which materials were
stored and inventoried at the site, EPA has no
choice but to exercise caution. Also, there have
been instances where information provided to EPA
has been incorrect, and this has underscored the
need to be cautious with materials at the site.
5
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3.
EPA is aware that some extremely toxic substances
were legally manufactured at this site, and as a
result, workers on site know to look for certain
compounds. However, they may not know where to
look for them, and many materials on site are
stored in unlabeled containers. .
There are many chemical compounds at the site, in
addition to methyl mercaptan, metallic sodium,
and phosgene, although they may not pose the
immediate threat to human health that these three
compounds represent. currently, EPA's highest
priorities are the stabilization and removal of
methyl mercaptan, a highly toxic, highly
flammable and odorous organic compound, and
metallic sodium, a substance that is highly
. reactive to water. There have been reports that
phosgene is also at the site, but so far, non&
has been located. Phosgene is a compressed gas,
and approximately 20 unidentified gas cylinders
have been found. However, because of their
deteriorated condition, identification of
contents has not been made. If phosgene is
positively identified, it will also be considered
a top priority for cleanup.
Six questions addressed the matter of legal and financial
impacts associated with the site. Questioners inquired
about the liability of the Fike Chemical Site owners and
former operators, the potential liability of neighboring
property owners whose properties may be affected by offsite
contamination emanating from the site, and also who
determines liability. They wondered if the current cleanup
will address offsite contamination and if such
contamination will affect property values. .
Under Superfund law, there is a provision known
as joint and several liability. This provision
allows that anyone associated with the ownership
or operation of a hazardous waste site can be
held liable for the cleanup of that site.
Decisions regarding whom to sue are made jointly
by EPA and the Department of Justice, although
the issue of liability is ultimately determined
by the courts. Investigators are involved in
responsible party searches associated with
practically every Superfund site on the National
Priorities List.
When potentially responsible parties (PRPs) are
identified, EPA requests their cooperation in the
site remediation. If cooperation is not
SPA a.SDons.:
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6
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-------
forthcoming, EPA can resort to legal actions.
The best ~ituation is to find a cooperative party
and enter into a consent agreement. Another
possibility is to issue a unilateral order
against a financially solvent entity capable of
performing or financing a cleanup. Civil
litigation, and sometimes criminal litigation may
also be initiated.
At the moment, the extent of contamination from
the Fike Chemical Site is not known because
conditions at the site must be stabilized before
a full-scale remedial investigation (RI) and
feasibility study (FS) can be conducted. Once
the RI begins, 18 to 24 months may elapse before
EPA can provide any definitive information
concerning contaminant migration from the site.
The RI is not limited to the site boundaries,
and is also concerned with air emissions,
contaminated groundwater plumes, surface water
runoff, leachate streams, and things of that
nature.
4.
If contamination emanating from Fike-Artel has
contaminated other properties, that contamination
will be considered part of the Fike Chemical Site
cleanup program, but liability of the prope~ty
owner should not be assumed or dismissed. The
law is very broad in terms of liability for a
Superfund cleanup. Decisions regarding whom to
sue are made jointly by EPA and the Department of
Justice, although the issue of liability is
ultimately determined by the courts. ,The effect
of the site on the value of neighboring
properties cannot be determined at this time.
Three residents raised questions about the timing of the
removal of hazardous substances from the site. They wanted
to know if a time table for the removal of methyl mercaptan
and metallic sodium had been developed and if EPA could
project when th~ site would cease to pose an imminent
threat to the community.
BPA ..SDOliS.:
No specific dates for removal have been
established, but EPA is working to ensure that no
life-threatening situations develop at the site.
In the last 3 or 4 months, there has been
considerable progress toward stabilization of
site conditions. Approximately 2600 drums and
about 300 tanks have been sampled. Numerous
storage drums, in various stages of
deterioration, have been overpacked, or sealed
7
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.,'-,.
-------
into larger, structurally sound drums, and then.
the drums have been staged, or segregated, into
chemically compatible groups to await removal.
Some dilapidated warehouses have also been
dismantled.
Currently, EPA is negotiating with American
Cyanamid for the removal of the methyl
mercaptan. The company performed ultrasound
tests on the mercaptan tank earlier this week to
determine the structural integrity of the tank
and to quantify the volume of mercaptan.
American Cyanamid owns an incinerator facility
capable of destroying the methyl mercaptan, but
the mercaptan will have to be sampled first, and
sampling can not be performed until the mercaptan
is transferred to a tank truck for transport.
This will probably occur in early October 1988.
EPA is confident that the mercaptan is stable
enough to warrant the wait, in order to assure
that all necessary precautions have been taken to
protect pUblic health during the transfer
operations and the actual transport of the
materials.
5.
The unidentified gas cylinders found on site will
also be addressed in the very near future. One
way to deal with them may be to transport them to
a remote location and handle them there. The
possibility is under consideration, at this time.
Two questions concerned the funding available for cleanup
activities at the site. One inquirer wondered what would
happen if EPA reached the initial $2 million removal action
limit and could not secure additional funds. Another
individual inquired if funding problems were anticipated
for the long-term site remediation.
6.
Removal funding is limited to $2 million. To go
beyond this amount, EPA Headquarters must approve
an exemption or waiver, or the work will stop.
An additional $3 million was requested and
approved for the Fike Chemical Site. This money
will sustain the removal activities until
remedial funds can be applied to si~e
stabilization efforts. No funding problems are
anticipated at this site.
One resident inquired about the ~vailability of
site-related information. Another asked how site-related
information, particularly scheduling information, would be
announced to the public and whether members of the
BPA Resaonse:
8
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community miqht serve as advisors to EPA reqardinq local
concerns. .
SPA R.sDons.:
There is an information repository at the Nitro
Public Library and finalized reports will be sent
there as soon as they become available. Reports
can not be placed in the repository if they are
in draft form, but EPA is aware of the level of
interest at this site and will make every effort
to qet completed reports out as soon as possible.
In addition to the repository, interested parties
can request materials through the Freedom of
Information Act. EPA is required to respond to.
any requests for material, if the material is in
finalized form or not part of any litigation
procedures.
EPA will issue press releases and public
announcements, as needed, to the local news
media, including radio, television, and the major
local newspapers. No formal citizens' advisory
board has been established. However, EPA is
always interested in public input, and concerned
residents may call or write to EPA
representatives on site or in the EPA Region III
offices in Philadelphia, Pennsylvania.
An official of the Nitro Midget Football Program requested
scheduling information about proposed weekend evacuation
plans. The information. was needed to schedule events for
the Program's 175 participants who use the local junior
high school playing field.
7.
It is possible that one or more evacuations will
be conducted while onsite workers properly move
or dispose certain compounds at the site.
However, these plans are still being discussed.
EPA will make its plans known as soon as the
decisions are reached. The Agency realizes the
importance of this information to your program
and will consult with you before finalizing
plans. .
One former Pike-Artel employee inquired whether the united
steel Workers' union had an injunction aqainst Fike-Artel
that prevented the removal of chemicals from the site. He
also asked if he could come onto the site and remove
things. In addition, this individual expressed anger
because the workers performing the removal activities on
site were not West Virginians.
SPA R.sDons.:
8.
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SPA R88DOD.8:
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EPA is not aware of any court injunction, and the
Agency h~s the authority to remove hazardous
substances from the site. Unauthorized
individuals cannot remove anything from the
property and may not come onto the property.
The removal work being conducted at this site is
being done under a contract system that requires
a preset contract with contractors capable of
responding at a moments notice to a call from any
location within Region III. These contractors
must be properly trained, and they must be able
to be in place within two hours after receiving a
request for services.
A local shopkeeper expressed the opinion that the
. evacuation of residents during cleanup activities would
affect his business and that EPA should compensate his
losses.
9.
The evacuation of residents is a preplanned
activity of very short duration. As a result,
community members have plenty of time to conduct
local business, and shop owners should not
experience any financial hardships.
One local family wrote to EPA emphatically stating
objection to the No-Action Alternative described in the.
Proposed Plan. The writers requested information about
public participation and awareness and whether Fike-Artel
was in compliance with applicable state and Federal laws.
The writers also wanted to know if Fike-Artel would be
prosecuted, if violations were committed.
SPA R8sDoD.e:
10.
SPA R8.~oDse:
EPA is not advocating the No-Action Alternative
described in the Proposed Plan. However, the
Agency is always required to look at the
consequences of a No-Action Alternative, in order
to determine what would occur if nothing was done
at a given site.
As stated in the Proposed Plan, the No-Action
Alternative would allow unsafe and potentially
catastrophic conditions to continue at the Pike
Chemical Site. In addition, the No-Action
Alternative would not comply with current
statutory requirements, nor would it meet EPA's
goal of providing a permanent cleanup solution.
EPA is always receptive to public input regarding
Superfund sites and actively solicited public
comments on the Proposed Plan during the public
10
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11.
comment period. Local radio and television
stations, as well as major local newspapers, will
periodically receive information from EPA
reqardinq the Fike Chemical Site throuqhout the
entire cleanup proqram. In addition, Superfund
information and site-related documents will be
made available to the public at the local
information repository established at the Nitro
Publ~c Library.
Decisions reqardinq whether to sue the owners and
operators of the Fike-Artel facility will be made
jointly by EPA and the Department of Justice,
althouqh the issue of liability will ultimately
be determined by the courts. . .'
A Responsible Party (RP) submitted several comments
reqardinq the Proposed Plan. One comment stated that the
Proposed Plan erred in describinq the Fike Chemical Site as
"abandoned". The comment also said that, althouqh hourly
employees were laid off, surveillance staff was retained,
and supervisory personnel continued to work toward securinq
operatinq capitol by liquidatinq inventory or arranqinq
refinancinq aqreements so that production could be resumed
at the facility.
BPA R.SDOD..:
12.
In EPA's judqement,' the plant was abandoned with
respect to qeneral caretakinq and to proper
storaqe and handlinq of chemicals. EPA
determined that the prevailinq onsite conditions
posed a serious potential hazard to the community
and to the environment.
The RPalso said that the chemicals on site should not all
be reqarded as hazardous wastes and estimated that 80 to 90
percent of the compounds present were salable items, some
of which were already packaqed for shipment. In addition,
the RP stated that disposinq of all the materials at the
site as thouqh they are hazardous wastes will inflate
disposal costs unnecessarily.
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Some of the chemicals on site may not be disposed
as hazardous substances,' but that determination
cannot be made until the chemicals have been
sampled. Many containers and drums at the site
are unlabeled, and many have been found to be
mislabeled. As a result, EPA must sample the
chemicals to identify the compounds present and
to determine if they are compatible, prior to
disposal. All materials determined to be salable
will be staqed and retained separately for
disposition. .
11
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The RP disaqreed with the proposed Plan's description of
the CST laqoon as an unlined laqoon and also questioned the
statement that CST was incapable of treatinq the "laqoon
contents. The RP said that the laqoon was lined "in
accordance with the standards at the time it was built in
the late 1970s" and stated that a wastewater treatment plan
submitted to EPA by Pike-Artel was rejected without
explanation. "
13.
Reqardless of the exact nature of the CST laqoon
lininq or the status of the treatment plan, the
CST facility is not operational at this time.
Consequently, the laqoon has exceeded its
capacity, and the overflow must be treated.
The RP questioned the need to conduct a qroundwater
investiqation at the site and objected to EPA's
"assumption" that many drums are buried there. Accordinq
to this source, EPA conducted a qroundwater investiqation
at the Fike Chemical Site in 1981 and 1982 and installed
additional monitorinq wells in 1984 and 1985, yet found no
evidence of "siqnificant" qroundwater contamination.
Similarly, the RP said EPA excavated or bored at several
onsite locations durinq 1982 in an attempt to locate buri~
drums, but discovered no orqanic vapors and located only
one drum which contained water.
SPA aeaDoDse:
14.
"\
SPA aeaDoDae:
No conclusions have ever been reached reqardinq
the extent of qroundwater contamination at the
Fike Chemical site. Testinq, to date, has been
primarily directed toward priority pollutants or
specific parameters, and some samples have shown
certain chemicals to be present at elevated
levels at some locations. Given this
information, and knowinq the types of compounds
used and produced at the Pike-Artel facility, EPA
believes that additional qroundwater study is in
order.
Information currently available to EPA from
several sources indicates the presence of buried
drums on the site. Consequently, this issue must
be investiqated.
The RP stated that the most serious problem EPA has found
at the Pike-Artel facility is a laboratory-sized cylinder
of hydroqen cyanide.
15.
SPA aeaDODae: .
Several serious problems have been identified at
the Fike Chemical Site, in addition to hydroqen
cyanide. These problems include metallic sodium,
methyl mercaptan, sulfuric acid, and numerous
unlabeled or mislabeled drums and containers.
12
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4.0
O'l'DR COIICBU8
A resident said that he and several neighbo~s live directly
across the river from the Fike Chemical Site. He and his
neighbors are concerned that they will be trapped in their homes
if an emergency occurs because there is only one road into the
area, and it comes directly across the river into Nitro. In
addition, the road is often blocked tor long periods of time by
railroad cars parked on the tracks that cross the road. . The
speaker came to the meeting to request that an EPA
representative attend a community meeting to discuss this
problem. He also asked whether people in his area were going to
be included in evacuation planning.
IIPA R.sDons.:
EPA may not have any authority over the access
road to your property, but the complaint and
' petition presented earlier this evening will be
passed on to the appropriate authorities, and
perhaps they will attend the community meeting.
In the event of an emergency, the location of the
neighborhood would determine whether it is
considered part of an evacuation action.
.
5.0 ADDITIORaL RllXBDIAL ALTBRRaTIVII8
An RP submitted a written suggestion to EPA. The suggestion
urged the Agency to consider completing the requirements of a
1982 Consent Decree between Fike Chemicals/CST and EPA or to
arrange adequate funding, through Federal loan programs, to
allow the site owners to complete the work themselves. This
individual felt that by complying with the decree, the site
could resume production under current, or new, management and
would then be able to provide additional jObs to the region.
'.0
JUDlAIIIIIIG COIICBU8
Concerns not conclusively addressed during the comment period
include the following:
o
The concern ot residents living across the
the Fike Chemical Site 'who fear they may be
an emergency because of the single-road
their neighborhood.
river from
trapped in
access to
I. " "
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13
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A'rl'ACHMENT
COJIKUIIZTY RBLATIO.. ACTIVITIB. AT TO "ID CBBJaCAL .ID
Community relations activities conducted to date:
o.
EPA conducted a community assessment, in August 1987,
during which residents and local officials were
interviewed.
o
A local information repository was established by EPA,
in late 1987, at the Nitro Public Library.
EPA conducted a public meeting at Nitro Junior High
School on July 28, 1988, to discuss EPA plans to
stabilize and. secure the abandoned Fike Chemical
Site. About 300 people attended.
o
o
EPA published an announcement in local newspapers of a
public meeting concerning the EPA's Proposed Plan for
interim remedial actions at the site, in August 1988.
EPA produced a Proposed Plan and distributed it to
about 70 residents who attended an EPA public meeting
at Nitro Junior High School on september 14, 1988.
o
o
On September 22, 1988, EPA held a meeting to discuss
plans to evacuate 5000 residents during the removal of
a hydrogen cyanide tank from the site. Approximately
100 people attended.
o
EPA issued a press release and held a press conference
. on September 23, 1988, to explain to the community the
events that led to cancellation of the planned removal
and evacuation.
o
From June 1988 to the present, EPA community relations
specialists have been available to the public at the
site several days each week.
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