UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
841 Chestnut Building
Philadelphia, Pennsylvania 19107
SUBJECT-
FROM:
TO:
Kanawha Valley Overview Report Revisions
DATE: W>R 3 01986
.John Ruggero, Chief
Environmental Programs Section (3ES12)
Greene A. Jones, Director
Environmental Services Division (3ESOO)
With the help of Rich, Deena, and Jim, the KVO Report
revisions are finally complete with one exception — the FIFRA
portion, which has not yet been reviewed by the WV Dept. of
Agriculture or approved by Larry Miller. Any changes to the
FIFRA portion will not substantially affect the document, so
I am providing a copy for your review now.
f -
Attachment
cc: James Newsom (3ES10) w/attc.
-------
6OOR860O5
ENVIRONMENTAL OVERVIEW
KANAWHA VALLEY, WEST VIRGINIA
Libfsry
1, $k Environmental Protection Agency
Region HI
Centra! Regional Laboratory
S39 Bestgats KOBO ^^
R30052
U.S. ENVIRONMENTAL PROTECTION A6ENCX
REGION III
841 CHESTNUT BUILDING
PHILADELPHIA. PENNSYLVANIA 1910')
APRIL 1986
SHADED COUNTIES
-PUTNAM COUNTY
KANAWHA COUNTY
-------
Acknowledgments
The Region appreciates the efforts of all those who helped write
this document. Elizabeth Rhoads (Environmental Services Division)
and Robert Kramer (Hazardous Waste Management Division) coordinated
report preparation. Daniel D. Sweeney (Water Management Division),
Joseph W. Kunz (Air Management Division), Dennis Carney (Hazardous
Waste Management Division), Dr. Roy L. Smith (Environmental Services
Division), and Elizabeth Rhoads wrote individual sections of the
report. John Ruggero (Environmental Services Division), Elizabeth
Rhoads and Richard Fetzer edited the final report. W. Deena Bradley
typed the numerous drafts and final document.
The Region also extends its appreciation to the State of West
Virginia for reviewing the draft of this report and for implementing
many of the environmental protection programs discussed in this report,
-------
Kanawha Valley, West Virginia
Environmental Overview
Table of Contents Page
Acknowledgments i
Executive Summary ill
1.0 Summary and Recommendations 1
2.0 Introduction 4
2.1 Background and Purpose
2.2 Geographic Area
3.0 Program Summary 7
3.1 Introduction
3.2 Program Description
3.3 Delegation Status
4.0 Environmental and Regulatory Program Status 12
4.1 Permits
Water
RCRA
Multimedia Summary
4.2 Compliance
Water
Air
RCRA
TSCA
FIFRA
Multimedia Summary
4.3 Ambient Water Quality
4.4 Ambient Air Quality
4.5 Spills and Releases
4.6 CERCLA
5.0 Air Toxicants 24
6.0 Conclusions ...26
7.0 Appendices
A. Permits 28
B. Compliance 31
C. Ambient Water Quality and Monitoring 58
D. CERCLA 96
E. Environmental Issues 98
ii
-------
Executive Summary
This report assesses the regulatory and environmental issues
that are pertinent to the Kanawha Valley in West Virginia. Three
major topics were considered in each EPA program. The conclusions in
each topic are summarized below.
1. Status of Permit Issuance and Compliance
0 Permit issuance and compliance enforcement are being
managed effectively by EPA and the State for all media.
Industry non-compliance with RCRA and NPDES permits are
the primary focus of EPA and State enforcement actions.
All but one major water discharge permit will contain BAT
effluent limit by the end of 1986. An important feature
of many of these permits is a bloassay requirement to
detect toxic pollutants in effluents.
2. Salient Issues
0 Effluent guidelines for the organic chemical industry have
not been promulgated. Therefore, it has been difficult to
issue comprehensive and consistent NPDES permits.
Fish tissue contamination by dioxin has resulted in the
issuance of a fish consumption advisory by the Governor of
West Virginia for the lower 45 miles of the Kanawha River.
0 Chronic and acute releases of toxic airborne pollutants
require more comprehensive regulation.
140 potential hazardous waste dumpsites have been identified
by aerial photography. Resource limitations have prevented
EPA from immediately verifying the existance of these sites.
As in many areas of the nation, the extent and severity of
groundwater contamination in the Kanawha Valley is not well
known. EPA's authority to require corrective action and
to prevent releases to groundwater was acquired only in
1984 and guidance is not yet complete.
iii
-------
3. Current and Future Actions
Because of the lack of effluent guidelines for the organic
chemical industry, the State has been issuing NPDES permits
with BAT limits based on best professional judgement.
Additional fish and sediment samples are being analyzed
in order to characterize the extent and severity of dioxin
contamination in the Kanawha River and to identify the
source of contamination.
0 Several initiatives to prevent releases of toxic airborne
pollutants are being implemented. EPA is implementing its
National Strategy for Toxic Air Pollutants. The State is
implementing a comprehensive emissions inventory program
and a Community Right to Know Act. EPA and the State are
performing a multi-media study to model ambient concentrations
of airborne pollutants based on current emissions, to
estimate risk to human health, and to identify possible
source controls.
0 Potential hazardous waste dumpsite are being investigated
in accordance with a plan which establishes a schedule to
investigate the highest prioirty sites first. All sites
will be investigated by the end of 1987.
0 Facilities receiving permits under the Resource Conservation
and Recovery Act will be required to correct known groundwater
problems by 1988. The extent of groundwater contamination
at potential hazardous waste dumpsites is being evaluated
under Superfund.
iv
-------
1.0 SUMMARY AND RECOMMENDATIONS
-------
1.0 Summary and Recommendations
This report discusses environmental issues and programs pertaining
to the industrial region of the Kanawha Valley in West Virginia. This
report describes the status of environmental regulatory programs and
responds to questions raised in an August, 1984 publication of the
EPA National Enforcement Investigation Center (NEIC). The information
presented here (1) explains the status of permit issuance and of compliance
with existing permits, (2) Identifies remaining environmental issues
and constraints to their solution, (3) outlines plans for corrective
actions, and (4) updates information presented in the NEIC report. The
report includes the following findings and recommendations.
1. Water discharges - The Kanawha River receives treated industrial
wastewater discharges from 19 major facilities, all of which have National
Pollutant Discharge Elimination System (NPDES) permits. Fifteen of these
permits are based on Best Available Technology Economically Achievable
(BAT). Five permits are scheduled for reissuance with BAT limits by
West Virginia in 1986. Three of these replace permits that currently
contain non-BAT limits. The last remaining non-BAT permit will expire
in 1987. Where necessary, the permits include bioassay and best management
practices (BMP) conditions. However, EPA has not promulgated BAT
guidelines for the organic chemical industry, so issuing complete and
consistent permits for chemical companies is difficult. Two of the
facilities violated permit limits significantly during the last quarter
of 1985. In both cases, enforcement actions are being taken. Timely
enforcement actions and permit reissuance, consistent with State/EPA
Agreements, will be high priorities.
EPA and West Virginia will ensure that toxic substances discharges
are controlled by reviewing permits when ambient toxicity is observed,
by giving enforcement actions a high priority, and by assisting the
State with applying the EPA toxic pollutant control policy to include
water quality-based effluent limits in new permits. Reissued BAT
permits are providing more comprehensive coverage of toxicants than in
the past and include more effective limitations. This is a result of
the increased amount of background data on toxic pollutants available
in the permit application submitted by each facility, the forthcoming
effluent guidelines for the organic chemical industry, and implementation
of a toxicant control strategy.
In order to detect and reduce the number of leaks and spills, many
reissued permits require implementation of best management practices
(BMP) to better prevent such leaks and to detect them more quickly.
In addition to actions under NPDES, EPA will continue to respond to
these incidents as described below under Spills and Releases.
2. Ambient Water Quality - Statistical analyses of fish and benthic
populations did not show significant temporal trends, however, data were
sparse. The industrial area affected benthos significantly. Although
ambient concentrations of arsenic, cadmium, copper, cyanide, lead,
silver, and zinc decreased significantly since 1970, silver and arsenic
-------
have continued to exceed EPA's water quality criteria frequently.
Water quality criteria were also exceeded frequently in the Kanawha
River above the Industrial area, suggesting major inputs from nonpoint
sources. High concentrations of dioxin in fish tissue were cause for
the State to issue a fish consumption advisory for the Kanawha below
its confluence with the Coal River.
Although the Kanawha is well-monitored compared to similar waterways,
monitoring priorities were recently reviewed and modified. Investigations
are underway to determine ambient levels of benzene, toluene, methanol,
and vinyl chloride, and to find sources of dioxin, silver, arsenic,
and selenium. The incidence of fish liver tumors is also being studied
by West Virginia DNR under grants from EPA.
EPA expects to receive Federal Energy Regulatory Commission license
applications for hydropower projects for review in 1986. EPA will
review the cumulative impacts of these proposed projects to ensure
that dissolved oxygen concentrations and other environmental factors in
the River will not be affected adversely.
3. Air emissions - Of 19 major facilities in the Kanawha Valley, one
is in violation of visible emissions standards. Federal regulations under
§112 of the Clean Air Act presently include process and ambient standards
for only six pollutants. EPA Headquarters has issued a Notice of Intent
to list 10 toxic air pollutants under §112, which would increase EPA's
authority to regulate emissions. West Virginia is implementing a
comprehensive emissions inventory program and Community Right to Know Act.
Although present EPA regulations do not comprehensively address either
chronic or acute releases of toxic air pollutants, West Virginia and EPA
are jointly developing and implementing regulatory mechanisms to control
and reduce such emissions to levels which protect human health. One such
measure is West Virginia's recently announced voluntary reduction program.
This joint program between West Virginia and industry in the Kanawha
Valley, will reduce, in the very near future, current levels of air toxics
emissions. One goal of such a program should be to investigate possible
control measures that do not require the lengthy procedures required -
by §112 of the Clean Air Act for the control of hazardous air pollutants.
In addition, EPA announced its National Strategy for Toxic Air Pollu-
tants on June 4, 1985. The Strategy will enhance national regulation,
expand State programs, and develop multi-media control methods. EPA's
Strategy emphasizes giving technical assistance to State programs. Accord-
ingly, EPA is accelerating its efforts to establish health criteria and
carcinogenic risk values for those substances believed to be most toxic.
The purpose of criteria development is to enable State and local agencies
to assess the risks to individuals and populations affected by specific
facilities and to establish control limits necessary to reduce risk.
4. Ambient Air Quality - Air in the Kanawha Valley meets the National
Ambient Air Quality Standards (NAAQS) for total suspended particulates
(TSP), sulfur dioxide (S02), ozone (03), carbon monoxide (CO), and oxides
of nitrogen (NOX); TSP, S02, and lead concentrations have decreased, CO
has remained stable, and N02 and 03 have increased slightly.
-------
Emission rates and ambient concentrations of unregulated airborne
toxicants are unknown. To obtain data to assess this issue, EPA and
the State are collaborating on a multi-media study with emphasis on
airborne pollutants which will (1) model ambient concentrations based
on current emissions, (2) estimate relative risks among various chemicals
and sources, and (3) identify possible source controls.
5. RCRA - Three facilities have received final RCRA permits, one
applicant was denied a permit, and 7 more have been requested to submit
detailed Part B applications. All permits are expected to be issued
by January 1988, and EPA intends to review noncompliance cases and
consider enforcement. Four facilities were out of compliance with
ground water monitoring regulations in 1985.
EPA's authority to require corrective action for releases to
groundwater was acquired only in 1984, and guidance is not complete.
All facilities receiving a RCRA permit will be required to take corrective
actions at all solid waste management units where necessary by 1988.
Assessing the extent of groundwater contamination is a concern nationally.
WV and many other states have applied for grants under the Clean Water
Act to increase their ability to study and solve groundwater problems.
The extent of groundwater contamination at individual sites will also
be evaluated under the CERCLA investigations discussed below.
6. CERCLA - EPA conducted a detailed search for hazardous waste
dumpsites in response to the NEIC report. The search found 140 potential
dumps!tes, which nave been categorized as follows: 34 (highest
priority), 83 (medium), and 23 (low). This report presents a schedule
for investigating these sites, which EPA and the State are implementing.
7. FIFRA - All 11 pesticide production sites were in compliance.
EPA intends to continue inspections at the current level.
8. TSCA - Five facilities are listed as handling PCBs. Two have
been inspected, one of which was out of compliance. That facility is
under a consent decree to comply with TSCA regulations.
9. Spills and Releases - Enforcement actions have been taken for
all enforceable violations. However, only 52% of reported spills and
releases have been documented as exceeding a reportable quantity, and
89% of those which do exceed a reportable quantity are not enforceable
violations. The reason is that most releases are of CERCLA hazardous
substances to the atmosphere. These substances are usually not
considered hazardous under the Clean Air Act, so EPA's only authority
is under applicable emergency procedures. Because these procedures
may be used only if specific criteria are met, enforcement is usually
impossible. Regional Orders governing internal procedures for spill
response enforcement have been revised to improve the thoroughness of
follow-up actions. Fast emergency response to spill incidents has
been achieved through West Virginia's spill alert program.
-------
2.0 INTRODUCTION
-------
2.0 Introduction
2.1 Background
In August 1984, the Environmental Protection Agency's (EPA)
National Enforcement Investigation Center (NEIC) published a report
titled, "Overview of Environmental Pollution in the Kanawha Valley."
The report presented data on air and water pollution from the major
industrial facilities in the Valley and on hazardous waste sites in
the Valley. Environmental improvements and potential environmental
issues were identified. Because the report raised many questions, EPA
Region III decided to write a follow-up report. The purposes of this
report are:
1. To describe the status of permit issuance and compliance
with EPA's regulations for major industries;
2. To identify the remaining environmental issues and the
constraints on studying and/or resolving them;
3. To outline action plans to study and resolve environmental
issues; and
4. To update the status of the environmental Issues raised by
the NEIC report.
2.2 Geographic Area
The area covered by this study was identical to the study area
used by NEIC for their study. Specifically the study encompassed
the narrow developed valley of a 60-mile reach of the Kanawha River
extending from Winfield Dam to Alloy (Figure 1). This area includes
major industrial facilities at Alloy, Belle, South Charleston,
Institute, and Nitro. A list of the major industrial facilities can
be found in Table 1.
-------
Flgurt 1. Location Hap - Kanawha Valley Study Arta
Taken From: NEIC Report, EPA 1984
-------
Table 1
LIST OF MAJOR* INDUSTRIAL SOURCES
OF TOXIC SUBSTANCES
Facility Name
1. Allied Chemical
2. Appalachian Power-Amos Plant
3. Appalachian Power— Kanawha R. Plant
4. Avtex Fibers3
5. Chemical Leaman Tank Lines
6. Coastal Tank Lines
7 . Diamond Shamrock
8 . DuPont
9. Elkem Metals
10. FMC
1 1 . FMC
12. Fike Chemicals/GST
13. Hatfield-Henson
14. Kincaid Enterprises
(Chemical Formulators)
15. Mason & Dixon Tank Lines
16. Monsanto
17. S. Charleston Sewage Treatment Co.
18. Union Carbideb
19. Union Carbide-Technical Center0
20. Union Carbide
City
Nitro
St. Albans
Glasgow
Nitro
Institute
Nitro
Belle
Belle
Alloy
Nitro
S. Charleston
Nitro
Dunbar
Nitro
St. Albans
Nitro
S. Charleston
Institute
S. Charleston
S. Charleston
a. Plant closed.
b. Includes Goff Mountain Landfill and private trucking operations.
c. Includes Ward Hollow and Holz Pond waste disposal area.
* Classification based on a rating system used by the National Enforcement
Investigation Center, August 1984.
-------
3.0 PROGRAM SUMMARY
-------
3.0 Program Summary
3.1 Introduction
The Environmental Protection Agency regulates environmental pollu-
tants through the Clean Water Act, Clean Air Act, Resource Conservation
and Recovery Act, Toxic Substances Control Act, and Federal Insecticide,
Fungicide and Rodenticide Act, and the Comprehensive Environmental
Response, Compensation and Liability Act. This chapter summarizes the
various regulations and programs under these Acts as they apply to the
Kanawha Valley. In many program areas, responsibility for permit
issuance and enforcement has been transferred to the State of West
Virginia. A description of the delegation status of each of these
programs is also provided.
3.2 Program Description
Clean Water Act
The Federal Water Pollution Control Act Amendments of 1972,
specifically §402, created the National Pollutant Discharge Elimination
System (NPDES). Under this section, Congress authorized EPA or its
delegated State agency to issue permits for discharges of pollutants
to waters of the United States. This Act and the subsequent 1977
amendments, known as the Clean Water Act (CWA), require municipalities
and industries to meet effluent limitations based on accepted treatment
technology and to comply with water quality standards of the receiving
stream. Discharging without an NPDES permit or in violation of permit
conditions constitutes a violation of the CWA, subject to enforcement
by EPA and its delegated State agency.
Routine ambient water monitoring is also required by the CWA. In
the Kanawha River, the State monitors chemical, physical, and biological
parameters in order to assess the status of water quality.
Clean Air Act
The Clean Air Act.of 1970 (PL 91-604) gave air quality management
a national focus. The Act under §109 required the EPA Administrator
to establish National Ambient Air Quality Standards (NAAQS) which would
be set at levels to protect human health (primary standard) and welfare
(secondary standard). NAAQS have been set for six criteria pollutants:
total suspended particulate matter (TSP), sulfur oxides, ozone, carbon
monoxide, nitrogen oxides, and lead.
Under §110, the Act requires preparation of State Implementation
Plans (SIP's) under which the States, subject to approval by the EPA
Administrator, set emission standards for existing sources in order to
achieve primary and secondary national air quality standards.
-------
The Act under §111 and §112 also requires the Administrator to
establish national emission standards for significant new pollution
sources and for all sources emitting hazardous substances. §111
requires EPA to promulgate New Source Performance Standards (NSPS)
for new and modified industrial plants. These standards have been
issued for many industrial categories, including industrial and
electric utility boilers, smelters, petroleum refining and storage,
and synthetic organic chemical manufacturing.
Besides setting National Ambient Air Quality Standards for the
criteria air pollutants, §112 requires EPA to control any other air
pollutants which "may reasonably be anticipated to result in an
increase in mortality or increase in serious irreversible, or
incapacitating reversible, illness." The Act requires EPA to list
each air pollutant suspected of being hazardous to human health, and
then, within one year of listing, either set emission standards for
point sources emitting the hazardous pollutant or determine that it
is not hazardous to human health. Currently six substances have
been listed as hazardous air pollutants under §112: asbestos, benzene,
beryllium, mercury, radionuclides, and vinyl chloride.
In 1976 EPA began to develop a national methodology for screening
potentially hazardous air pollutants. After evaluating exposure and
health data, EPA developed an informal list of 37 hazardous air
pollutants which, based on the data available at that time, seemed
likely candidates for more extensive analysis and future emissions
control. Since only a fraction of the total number of chemicals
emitted by industrial facilities have been tested for possible health
effects, it is likely that some hazardous substances have been omitted
from the list. Because most of the 37 potentially hazardous substances
are either particulate or volatile organic compounds (i.e., ozone
precursors), they are controlled indirectly to varying degrees by
controls of TSP and VOC's.
The indirect control of potentially hazardous substances through
mandated control of TSP and VOC's is neither comprehensive nor uniform.
Areas that achieved the ozone (03) standard by 1982, such as the Kanawha
Valley, are not required to adopt additional control measures for
various major VOC source categories as was required for those areas
that did not attain the 03 standard. Therefore, VOC sources in the
Kanawha valley are not subject to an 03 SIP requirement for an ozone
non-attainment area.
In November 1983 EPA committed to review approximately 25 indivi-
dual chemicals, primarily from the list of 37 hazardous air pollutants,
and to decide by December 31, 1985 whether to list them as substances
EPA intends to regulate under the Clean Air Act. Through that process
10 substances have been identified in a Federal Register notice of intent
to list as explained in Chapter 5.
-------
A correlative function of the Act (§309) gives the Administrator
the responsibility to review and comment upon the environmental
impact of any Federally-funded project or activity. Thereafter, if
those actions are found unsatisfactory, remedies can be sought through
mitigation, modification, or referral to the Council on Environmental
Quality. The criteria by which projects and activities are evaluated
are found in the other environmental statutes and regulations. The
authority of this section is the basis for EPA's review of hydropower
project environmental impact statements prepared pursuant to the
National Environmental Policy Act. The potential effects of these
projects are discussed in Section 4.3 below.
Resource Conservation and Recovery Act
Under Subtitle C of the Resource Conservation and Recovery Act
(RCRA), permits are to be issued to facilities which treat, store or
dispose of hazardous wastes. These permits are issued to ensure
that hazardous wastes are handled in accordance with technical standards
promulgated by EPA. Specific units or processes which are subject
to a permit include: above ground containers or underground tanks
used to store or treat hazardous waste, surface impoundments, waste
piles, land treatment, landfills, and incinerators.
The RCRA permit application consists of two parts, Part A and
Part B. The Part A application requires a minimum level of information
concerning the facility while the Part B requires a detailed narrative
description of the facility, its processes and wastes handled. For
new facilities, both the Part A and Part B must be submitted to EPA
or an authorized State agency at least 180 days before construction
of the facility.
For existing facilities, a notification that a facility will
treat, store or dispose of hazardous waste must be filed within 90
days after the specific waste is listed as a hazardous waste.
Furthermore, within 6 months after the listing, an existing treatment,
storage, or disposal (TSD) facility handling the waste must file a
Part A application. These submittals enable the TSD facility to
operate under the provisions of interim status. Under interim status,
a facility is treated as if it had a RCRA permit. Existing facilities
can operate under interim status until such time as it is withdrawn
for failure to comply with specific requirements or when a final
action is taken on a permit application.
Toxic Substances Control Act
In accordance with the Toxic Substances Control Act (TSCA),
industrial and non-industrial facilities which have stored, used or
disposed of polychlorinated biphenyls (PCB's), are monitored for
compliance with EPA's requirements. Compliance monitoring is accom-
plished through facility inspections. The inspections are scheduled
-------
where a specific cause exists. A cause is determined based on complaints
received, a computer based random selection process, or targeted by
EPA-Headquarters. In the absence of an inspection, a decision cannot
be made on the compliance status of a facility.
Federal Insecticide, Fungicide and Rodenticide Act
In accordance with the Federal Insecticide, Fungicide and Roden-
ticide Act (FIFRA), facilities which produce and/or hold pesticides
for distribution are monitored for compliance with EPA's requirements.
Inspections are used to monitor compliance. By statute, the inspections
are limited to those.areas where pesticides are stored in finished
product form. Inspections do not review intermediate manufacturing
activities.
Spills/Releases
Releases and spills of hazardous substances in excess of defined
reportable quantities are required to be reported in accordance with
§103(a) of CERCLA and §311 of the CWA. Furthermore, §311 specifies
enforcement actions which EPA can take should the spill exceed a report-
able quantity and reach a navigable waterway. Although CERCLA requires
that releases be reported, §103(a) does not provide specific enforcement
authority to pursue penalties merely because a release occurred.
3.3 Delegation Status
Clean Water Act
The NPDES permitting authority was delegated in May 1982 to the
West Virginia Department of Natural Resources. Under this authority,
the State has primacy for permit issuance and compliance. The State
receives and reviews all applications, establishes effluent limitations,
and issues all permits. They are responsible for reviewing discharge
monitoring reports, providing inspections and initiating enforcement
action where appropriate. EPA's primary role is one of overview to
ensure compliance with NPDES regulations. EPA reviews and approves
permits issued or reissued to all major dischargers and to certain
categories of minor dischargers, such as coal mining operations, which
are considered to be primary industries. The Agency also provides
quarterly reviews of discharge monitoring reports and State compliance
activities for all major permits. The State and EPA communicate
frequently about permit issuance and compliance activities and related
developments in NPDES regulations and program policies.
Clean Air Act
Federally enforceable West Virginia Air Pollution Control Commission
(APCC) regulations, required by §110 of the CAA, set stationary source
emission standards for TSP, sulfur oxides, and ozone.
10
-------
As allowed under the CAA, the NSPS and National Emission Standards
for Hazardous Air Pollutants (NESHAPS) programs were delegated to the
State of West Virginia on July 24, 1984. This delegation is consummated
in the APCC regulations XVI and XV for NSPS and NESHAPS, respectively.
The NSPS regulation is applicable to the new Union Carbide - South
Charleston methyl chloride unit while the NESHAPS regulation is applicable
to its vinyl chloride emissions. There are no other known sources in
the Kanawha Valley which are subject to regulations XVI and XV.
Delegation of the Prevention of Significant Deterioration (PSD)
program to the State has been proposed. It is expected to be Federally
approved in the near future.
Resource Conservation and Recovery Act
In accordance with the Resource Conservation and Recovery Act
(RCRA), active hazardous waste management facilities are monitored for
compliance with existing permit conditions or interim status requirements.
West Virginia has obtained final authorization for their RCRA program
in phases. The State performs Inspections and takes enforcement actions
against facilities which are currently operating under the provisions
of interim status. EPA monitors the State's performance and initiates
enforcement actions where necessary.
j
West Virginia is responsible for "calling in" (requesting facilities
to submit) and reviewing Part B permit applications. West Virginia is
also authorized to issue storage, treatment and incineration permits
and permits for land disposal. However, as a result of the Hazardous
and Solid Waste Amendments (HSWA) of 1984, it will be necessary for
West Virginia to undergo new authorization efforts to ensure that the
additional requirements in the HSWA are incorporated into the State
program.
Toxic Substances Control Act
The PCB compliance program is managed by EPA and there is no
delegation to the State of West Virginia.
Federal Insecticide, Fungicide, and Rodenticlde Act
The FIFRA compliance/enforcement activity in West Virginia is
fully delegated to the West Virginia Department of Agriculture (WVDOA)
and EPA performs oversight of State performance.
Spills/Releases
The spill response program is not delegated to any state in Region
III, however all of the States, including West Virginia, have their
own spill response capability.
11
-------
4.0 ENVIRONMENTAL AND REGULATORY PROGRAMS STATUS
-------
4.0 Environmental and Regulatory Programs Status
v.»
This chapter describes the status of the environmental control programs
within the Kanawha Valley. Specifically, it addresses the following:
1) Status of permitting for the major facilities under EPA
permit programs;
2) Status of the major facilities' compliance with EPA regulations;
3) Ambient water quality;
4) Ambient air quality;
5) Review of Regional procedures for responding to industrial
spills and releases;
6) Status of hazardous waste site investigations.
4.1 EPA Permit Programs
Water Permits
NPDES permits were issued for five-year maximum periods to. Kanawha
Valley chemical plants and other industries requiring Best Practicable
Control Technology Currently Available (BPT) effluent limits by July 1,
1977. BPT primarily limits BOD (organic waste), suspended solids, pH,
metals, and certain other known pollutants for specific industrial
categories. By July 1, 1984, industries were required to meet Best
Available Technology Economically Achievable (BAT) limits for toxic
pollutants. Because of the complexity of the organic chemical industry
and different viewpoints of EPA and industry representatives, effluent
guidelines are not expected to be issued by EPA before mid-1986.
Consequently, BPT and BAT permit limits are based on best professional
judgment (BPJ). Permits reissued after BAT effluent guidelines are
promulgated must contain guideline limits.
Under its delegation agreement with EPA the State has been issuing
BAT permits based on BPJ with five year duration periods since 1984.
Currently, 15 of the 19 facilities listed in Table 1 have BAT limits.
By the end of 1986, 18 facilities are expected to have BAT limits in
effect. The remaining non-BAT permit (CST/Fike) will expire in 1987.
The permit issuance status for each facility is summarized in Table 2
and more fully described in Appendix A, Table A-l.
The BPJ permit limits for chemical industries are based on a
number of factors including: proposed effluent guideline limits for
conventional and toxic pollutants, EPA treatability studies describing
removal efficiencies for different toxic pollutants, statistical analysis
of current treatment levels, and a review of data reported in permit
applications for 129 toxic pollutants. The proposed discharges are
also evaluated to ensure that they do not violate water quality standards.
Efforts are made to be as consistent as possible considering the absence
of effluent guidelines and the diversity of plant characteristics.
In most cases, few toxic pollutants are specifically limited,
because they were not found in significant amounts in the processes
or discharges. To control toxic discharges, BAT permits for chemical
12
-------
plants include requirements for best management practices (BMP) plans,
periodic bioassays, and toxic pollutant testing. BMP plans are intended
to help prevent releases of toxic and other pollutants through leaks,
spills and incidental plant runoff. When bioassays indicate toxicity,
the State normally requests information from the permittee on possible
pollutant sources and steps taken for toxicity reduction. Most permits
reissued in 1986 will require the permittee to provide the State with
this information upon discovering toxic bioassay results.
In 1984, EPA issued a policy for development of water quality
based permit limits for toxic pollutants. To support implementation,
EPA guidance was released in September 1985. The guidance describes
more effective and uniform screening and permitting of toxicants through
bioassays and evaluation of water quality criteria. West Virginia
will be developing and implementing a toxicants control strategy in
1986 based on EPA policy and the guidance document.
RCRA Permits
In August 1984, EPA issued a National Permit Strategy for RCRA
which establishes some guidelines for scheduling the issuance of RCRA
permits. Working with DNR and considering the priorities established
in the National Permit Strategy, EPA has developed a schedule for the
issuance of RCRA permits for the major facilities. The schedule targets
all major RCRA permits in the Kanawha Valley to be issued by January
1988. This schedule reflects the large number of facilities that
require permits and the time required for a sound permit review which
are problems influencing the National Permit Strategy. The specific
permit status for each of the major facilities is outlined in Table
A-2 in the Appendix. Four of the 11 facilities considered as major
facilities under RCRA have been issued a final RCRA permit or have
been denied a permit. Permits were issued to FMC in Nitro and to two
Union Carbide plants in S. Charleston. A permit was denied to CST,
Inc. in Nitro. Until final permits are issued, existing facilities
will operate under interim status provisions as explained in Section 3.2.
Multimedia Summary of EPA Permit Programs
Table 2 on the following page summarizes the status of permitting
under the two covered programs, RCRA and NPDES. Facilities which are
listed as "Not Applicable" under the column with the RCRA status heading
are not considered major facilities under the RCRA program criteria.
All facilities have 6 months to submit their Part B application after
EPA or the State requests or "calls in" the application.
The NPDES columns identify expiration dates and control types for
existing permits and target dates and control types for proposed
permits.
4.2 Compliance with EPA Regulations
Statements made in this report about the compliance of particular
facilities with certain laws or regulations are based only on the
13
-------
TABLE 2
MULTI-MEDIA PERMIT SUMMARY
FACILITY/LOCATION
Allied Chemical/Nitro
Appalachian Power/St. Albans
Appalachian Power/Glasgow
Chemical Leaman/Institute
Coastal/Nitro
CST Inc. ,/Fike Chemicals/Nitro
Diamond Shamrock/Belle
E.I. DuPont/Belle
Elkem Metals/Alloy
Fike Chemical/Nitro
FMC/S. Charleston
FMC, Nitro
Hatfield & Henson/Dunbar
Kinkaid/Nitro
Mason & Dixon/St. Albans
Monsanto/Nitro
S. Charleston STP, S. Charles.
Union Carbide/Institute
Union Carbide/S. Charleston
Union Carbide Tech
R & D Laboratory/S. Charleston
RCRA
STATUS
Not applicable
Not applicable
Not applicable
Not applicable
Not applicable
CST, Inc. Permit
Denied; 3/86,
Fike Part B
received
Not applicable
Part B called in
Not applicable
Part B received
Part B called in
Permit issued
Not applicable
Not applicable
Not applicable
Part B received
Not applicable
Part B received
Permit issued
Part B received
EXISTING
EXP. DATE
1/3/89
8/16/90
11/8/89
1/21/86
11/18/90
3/5/87
1/26/91
9/23/86
3/8/87
3/5/87
6/30/81
(extended)
1/31/81
(extended)
11/13/90
9/16/86
3/12/91
3/10/91
1/4/80
(extended)
10/30/86
6/13/89
12/17/90
NPDE
PERMIT
TYPE
BAT
BAT
BAT
BAT
BAT
BCT*
BAT
BAT
BAT
BAT
BPT
BPT
BAT
BAT
. BAT
BAT
BPT
BAT
BAT
BAT
:s
REISSUANCE
TARGET DATE TYPE
. — —
5/86 BAT
8/86 BAT
5/86 BAT
9/86 BAT
5/86 BAT
*Best Conventional Treatment; no toxicants limited
14
-------
writers' information and understanding. Such statements should not be
relied on as definitive findings of the Agency as to either compliance
or non-compliance.
Water
NPDES permit compliance data are derived primarily from self-
monitoring reports submitted by all permitted dischargers to the State.
Monitoring reports for major dischargers are also sent to EPA Region
III. Quarterly non-compliance reports are prepared and submitted to
EPA Region III by the State. These reports identify all violations by
major dischargers and subsequent enforcement actions taken. All major
dischargers are inspected and sampled at least yearly with follow-up
inspections where violations are discovered.
The most recent compliance status for the major Kanawha Valley
industrial discharges is shown on Table 3. As indicated, two dischargers
violated effluent limitations significantly during the last quarter of
1985, and eight dischargers had minor violations. For the purposes of
this report, violations are considered significant if they are about
twice the permit limit or occur on a frequent basis. Enforcement
actions are being taken for the two dischargers having significant
violations: EPA with State support is preparing Federal Court action
against CST/Fike for chronic effluent violations, primarily involving
oil and grease, phenols and BOD limits. The State has imposed a compliance
schedule for S. Charleston Treatment Company for providing, adequate
disinfection facilities to eliminate large and frequent violations of
effluent limits for fecal coliform bacteria concentrations.
A comprehensive summary of compliance status for the past three
years is shown in Appendix B. This includes parameters violated,
causes, corrections, and enforcement actions for each industry. In
most cases where violations were noted, the permittee was contacted by
the regulatory agency regarding the causes and planned or completed
corrections. Regulatory agencies did not generally issue administrative
orders or take other enforcement actions for noncontinuous violations
which did not threaten the environment or human health.
Each year, EPA and the State sign a formal agreement which outlines
procedures and actions to be followed in enforcing environmental laws.
The current State/EPA enforcement agreement requires the State to take
enforcement action within 180 days when a major discharger has been in
significant non-compliance for two consecutive quarters. This significant
non-compliance appears in the quarterly report submitted to EPA Region
III by the State. If the State does not take enforcement action, it
is incumbent upon EPA Region III to do so. Where human health is
threatened, EPA may take immediate enforcement action.
Air
Of the nineteen major facilities located in the Kanawha Valley,
only one facility is clearly in violation of any applicable Federal
or State regulations. Elkem Metals in Alloy is currently in violation
15
-------
of standards governing visible emissions from the facility's boilers. The
WV APCC is actively pursuing correction of the violations with the company.
All the remaining facilities are in compliance with both particulate
and sulfur emissions. Some questions arise as to the compliance status
of these facilities with regard to VOC emissions. Insufficient data
exist upon which a judgement of either compliance or non-compliance
for these facilites can be made.
RCRA
EPA and DNR have performed a compliance review of the 11 facilities
in the Kanawha Valley classified as major facilities under RCRA. The
review indicated that at this time, 6 of the 11 RCRA permitted facilities
are not in compliance with interim status or permit requirements.
Appropriate enforcement actions to improve compliance are currently
being taken or considered by DNR and EPA. Table B-3 in the Appendix
lists the major RCRA facilities in the Valley and their current compliance
status, and reasons for any non-compliance.
TSCA
Of the 19 major facilities in the Kanawha Valley listed in
Table 1, only 5 are listed in EPA's master list of facilites which may
use PCB's. This master list and a neutral selection process are used
to schedule PCB inspections. Union Carbide - Institute was inspected
in December, 1984. No additional PCB inspections in the Kanawha Valley
were scheduled in FY 85. The only other facility which was inspected
by EPA is the Union Carbide - S. Charleston facility in 1982. As a
result of the inspections, the Institute plant was found to be in
compliance and the S. Charleston plant was found to be out of compliance.
In April 1984 a consent order was issued to Union Carbide - S. Charleston
bringing the facility into compliance.
FIFRA
A review of the compliance data gathered by routine State inspections
for the 11 pesticide production sites in the Kanawha Valley was performed
by EPA during a mid-year review in April 1985. Seven facilities are
listed among those in Table 3 which are of multi-media significance.
The review found that all of the facilities were in compliance with
FIFRA requirements. Table B-4 lists the specific facilities along
with specific compliance activities.
Multimedia Compliance Summary
Table 3 on the following page summarizes the compliance status in each
program area for the major facilities. Additional information on the
compliance status can be found in the previous sections and Appendix B.
Statements made in the following Table about the compliance of
particular facilities with certain laws or regulations are based on
the writers' information and understanding. Such statements should
not be relied on as definitive findings of the Agency as to either
compliance or non-compliance.
16
-------
TABLE 3
MULTI-MEDIA COMPLIANCE PROGRAM SUMMARY
FACILITY
Allied Chemical,
Nitro
Appalachian Power,
St. Albans
Appalachian Power ,
Glasgow
Coastal Tank Lines,
Nitro
Chemical Leaman,
Institute
CST/Fike Chemical,
Nitro (2 RCRA Permits)
Diamond Shamrock,
Belle
DuPont ,
Belle
El kern Metals ,
Alloy
FMC,
Nitro
FMC,
S. Charleston
Hatf ield-Henson,
Dunbar
Kinkaid,
Nitro
Mason & Dixon,
St. Albans
Monsanto,
Nitro
S. Charleston,
Sewage Treatment Plant
Union Carbide,
Institute (2 RCRA Pemits)
Union Carbide, (2 RCRA
S. Charleston Permits)
Union Carbide, Tech.
^Ctr., S. Charleston
AIR
(TSP & S02
Only)
IN
COMP.
X
X
X
N/A
N/A
N/A
N/A
X
X
X
N/A
N/A
N/A
X
N/A
X
X
X
OUT OF
COMP.
X
WATER
4th Qtr 1985
IN
COMP.
X
X
X
X
X
X
X
X
N/A
OUT OF
COMP.
X
X
major
X
X
X
X
X
X
major
X
X
RCRA
IN
COMP.
N/A
N/A
N/A
N/A
N/A
N/A
X
N/A
X
N/A
N/A
N/A
X
N/A
X
X
OUT OF
COMP.
X,X
X
X
X
X
TSCA
IN
COMP.
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
X
X
N/A
OUT OF
COMP.
FIFRA
IN
COMP.
N/A
N/A
N/A
N/A
N/A
X
N/A
X
N/A
N/A
X
N/A
X
N/A
X
N/A
X
X
N/A
OUT OF
COMP.
P
17
-------
4.3 Ambient Water Quality
This assessment of ambient water quality is based on analyses of
the quality and quantity of biota, sediment toxicity, aquatic toxicity,
and ambient pollutant concentrations in the Kanawha River. Trends in
water quality were examined to determine if pollution controls have
improved water quality and to search for variations in water quality
related to flow, river mile, or seasonal changes. The effectiveness
of water quality monitoring in the Kanawha was evaluated to answer
two questions: (1) Has the Kanawha been as well-monitored as other
water bodies with high inputs of similar discharges, and (2) Are all
potentially important pollutants presently being measured? Appendix C
contains tables which present and summarize water quality data.
Based on statistical analyses, populations of macroinvertebrates
and fish in the Kanawha have not changed significantly since the mid
1970's. However, all statistically nonsignificant correlations
between abundance and year were positive, which suggests that signifi-
cant improvements in macroinvertebrate and fish populations may emerge
as more data become available.
There is a concern however that future hydropower and other power
generation activities (i.e. fossil fuel) on the Kanawha and its tri-
butaries may reduce dissolved oxygen (DO) concentrations which, in
turn, may adversely affect these populations. Under authority of
§309 of the Clean Air Act, EPA has been evaluating the potential water
quality impacts of hydropower facilities, several of which are proposed
on the Kanawha River= In January 1985, EPA completed the first phase
of a special study which reviewed the impacts of hydropower development
on the Upper Ohio and Lower Monongahela and Allegheny Rivers. EPA
found that dissolved oxygen concentrations may decrease if hydropower
facilities are operated in series in a basin. Cumulative impacts
of non-point sources and organic loadings may also be related to
hydropower development. These findings are relevant to the Kanawha
River where similar facilities are being proposed. EPA's review of .
all Federal Energy Regulatory Commission license applications will
require applicant certification of nondegradation, routine monitoring
and reaeration devices for each hydropower facility proposed.
Sediments sampled in the Kanawha midstream were coarse and are
unlikely to be a repository for toxic pollutants. Moderate toxicity
of sediments and ambient water to aquatic life was observed between
St. Albans and Charleston, but sediments in the remainder of the
Kanawha appeared to have no toxicity. The observed toxicity of sediments
is probably the result of point discharges, which also showed toxicity.
Ambient river water at six of eleven locations sampled between
St. Albans and South Charleston was chronically toxic to fathead
minnows and water fleas. The source of this toxicity appeared to be
point source discharges, which also were toxic. Observed toxicity
above South Charleston may have resulted from point source discharges
with a combination of high volume (which this analysis did not consider)
and only moderate toxicity.
18
-------
Pollutant concentrations in the Kanawha appear to have improved
significantly during the last 10-15 years. Arsenic, cadmium, copper,
cyanide, lead, silver, and zinc all declined significantly between
1970 and 1984 (Figures C-8 to 14). Although some of these differences
may have arisen from refinements in analytical techniques, these trends
indicate that water quality in the Kanawha, at least from a chemical
perspective, has improved. Exceedances of water quality criteria, in
particular silver and arsenic, have continued to occur, however.
Concentrations of five toxic pollutants, silver, cadmium, copper,
cyanide, and zinc, have exceeded EPA water quality criteria* designed
to prevent acute toxicity to aquatic life (EPA, 1980) since 1970
(Table C-14). Frequency of criteria exceedances has decreased for
all since 1980. Of these, silver was most frequently above criteria
levels. Concentrations of four carcinogens (chloroform, carbon
tetrachloride, dichloroethene, and arsenic) occasionally exceeded
water quality criteria associated with an incremental lifetime cancer
risk of 10~5 for average rates of consumption of fish and drinking
water (Table C-15). Of the four carcinogens, only arsenic concentrations
in water exceeded the 10~5 criterion for fish consumption only.
Fish tissue has not been analyzed for arsenic in the Kanawha, however
the State intends to begin tissue arsenic analyses in FY86.
Several carcinogenic substances including chlordane and PCB's have
been detected in some fish samples collected from the River at Winfield
between 1978 and 1984. The numbers and types of samples collected did
not permit an evaluation of potential adverse health effects. However,
a fish consumption advisory was issued by the Governor of West Virginia
on March 3, 1986 for a stretch of the River because of the presence of
dioxin in fish samples collected in 1985. This advisory extends from
the confluence with the Coal River to the mouth of the Kanawha River,
approximately 45 miles.
Hardness varied inversely with flow (Figure C-l), a predictable
effect of dilution at high flows. The only toxic pollutants which varied
significantly with flow were zinc (Figure C-2) and phenol (Figure C-3).
The increase in zinc concentration at high flow may be due to significant
nonpoint zinc sources; conversely, the decrease in phenol at high flow
may indicate that point sources of phenolic compounds are most important.
Because concentrations of other toxic pollutants did not show significant
trends with flow, their loadings to the Kanawha must increase as flow
increases. This suggests that upstream water quality may be impacted by
both nonpoint and point sources of these pollutants.
Lead decreased with travel downstream (Figure C-6) , suggesting that
upstream sources were significant, but concentrations were reduced by the
effects of sedimentation and dilution. Selenium concentrations increased
*Note that these conclusions are based on criteria published in 1980.
However, EPA revised its aquatic life protection criteria for several
inorganic pollutants after this analysis was completed (50 Federal
Register 30784, July 29, 1985).
19
-------
sharply between St. Albans and Winfield (Figure C-7), perhaps due to a
significant point or tributary source. The absence of other corre-
lations with river mile suggests that metals and cyanide may enter
the industrial region of the Kanawha from upstream and tributaries in
significant amounts. Total pollutant loading increased with travel
downstream, however, suggesting that point sources were nevertheless
significant contributors.
Only phenol varied seasonally (Figure C-4), with higher concen-
trations from July to December. This result indicates that phenol
concentrations are influenced more by low summer flows (Figure C-5)
than by biodegradation (which is also greatest in summer). The absence
of significant correlations between month and concentrations of other
organic pollutants suggests that these compounds are relatively
unaffected by seasonal changes in rates of biodegradation, photolysis,
and volatilization.
Water quality in the Kanawha is better-monitored than In other
similar areas. A list of toxic pollutants potentially present in
the Kanawha (Table C-16) was compared with actual parameter coverage.
Of the 46 toxic pollutants on the list, 27 are routinely monitored.
Among unmonitored pollutants, the most important are probably benzene,
toluene, methanol, and vinyl chloride. Monitoring could be improved
by analyzing for additional toxic pollutants believed to be present
but not currently monitored.
4.4 Ambient Air Quality
The Kanawha Valley in West Virginia is designated as meeting the
primary National Ambient Air Quality Standards (NAAQS) for all criteria
pollutants, which includes total suspended particulates (TSP), S02, 63,
CO, and N02, and Pb. The area is designated as not meeting the secondary
NAAQS for TSP, even though the current monitoring data are showing
attainment. A redesignation of the area has been submitted by the
State of West Virginia and EPA will approve the redesignation in the
Federal Register in the near future.
The West Virginia Air Pollution Control Commission (WVAPCC)
operates the following monitoring network in the Kanawha Valley:
Nine TSP monitors, five S02 monitors, four Pb monitors, one CO monitor,
one 03 monitor, and one N02 monitor. Over the past five years the
TSP levels at these monitors have decreased 15-20%, S02 decreased
30-70%, CO levels remained approximately the same, and N02 increased
about 10%. An increased number of exceedances of the ozone standard
have been recorded in the Valley.
The Kanawha Valley has not experienced a major shift in production
levels over the past five years. There have been no major shutdowns,
major modifications, or new sources built for the past several years.
Due to the high concentration of chemical processes in the Kanawha
Valley there has been some fluctuation in production levels, but nothing
of major significance which would impact the air quality of the Valley.
20
-------
The reason for improved air quality in the Valley over the past several
years has more than likely been WVAPCC's aggressive program to bring
facilities into compliance with the applicable regulations governing
emissions of criteria pollutants and state odor regulations. Also,
the decreased levels of lead are probably attributable to the phasing
out of leaded gasoline in automobiles.
4.5 Spills/Releases
Spill histories were evaluated for a selected number of industries
in the Region. The industries were chosen based on the professional
judgment of personnel knowledgeable in the area of spill reporting by
industry in the Region. The evaluation resulted in a review of 12
companies, 6 of which were located in the Kanawha Valley. The six
companies in the Kanawha Valley are: Diamond Shamrock, duPont (Belle),
FMC (S. Charleston), Monsanto, Union Carbide (Institute), and
Union Carbide (S. Charleston).
The review indicated that in all cases where an enforceable
violation under §311 was documented, an enforcement action was taken.
The review also highlights however, that the release of a reportable
quantity was documented in only 52% of the spill/release reports
received. Finally, the review noted that a very high percentage
(89%) of releases which exceeded a reportable quantity were not
enforceable violations. Some of these spills were not enforceable
because it could not be documented that the substance reached a
navigable waterway. A majority of those releases however were air
releases of CERCLA-designated hazardous substances which require
reporting but are not listed as hazardous air pollutants under the
Clean Air Act. In the absence of Agency rulemaking which regulates
a specific substance regarded as an "air toxicant", the Agency's
best authority to deal with such releases comes from the emergency
provisions of the various statutes. The criteria for taking action
under such provisions must be met before such action can be taken.
The Region has recently reviewed procedures used in handling
spill and release reports received, focusing on internal coordination
and enforcement follow-up actions. The review, while finding that
proper and timely actions are taken when spill reports are received,
did identify some areas where more formal procedures could enhance
the Region's internal coordination and follow-up action. Formal
Regional procedures in the form of Regional Orders have been revised
to improve internal coordination.
4.6 CERCLA
As a follow-up to the findings of the NEIC Report, EPA initiated
an effort to evaluate existing source information and identify all
potential hazardous waste dump sites within the Kanawha Valley. A
potential hazardous waste site is any identified site where hazardous
substances may have been released or where the potential exists for a
release which could result in a danger to human health or the environment.
21
-------
A potential site must be technically evaluated to determine the actual
seriousness. Very few sites have actual impacts significant enough
to warrant a ranking on the National Priority List (NPL) of hazardous
waste sites, and it is estimated that only approximately 4-5% of the
potential hazardous waste sites discovered will result in placement
on the NPL. EPA currently limits its remedial cleanup efforts (funding
and enforcement) to sites on the NPL.
For the Kanawha Valley area, EPA's existing inventory as listed
in the Emergency and Remedial Response Information System (ERRIS)
contains 56 potential hazardous waste sites. The NEIC Report however
suggested that 92 potential sites exist. Although EPA has already
performed 44 preliminary assessments (PA) and 23 site investigations
(SI) at the 56 sites in ERRIS, a number of those PA's and Si's were
performed prior to 1983. Since the earlier reviews may not conform
with current guidance, it was decided that all potential sites
including those already listed in ERRIS would be evaluated against
the same criteria and new PA/SI's prioritized for those sites.
An evaluation was performed for the Region by the Field Investi-
gation Team (NUS Corporation). The evaluation consisted of a review
of source information including a report from EPA's Environmental
Photographic Interpretation Center (EPIC), EPA and West Virginia DNR
files, records of the U.S. Soil Conservation Service, the NEIC Report,
and interviews with State and local officials. The investigation
process actually uncovered 140 (not 92 as previously suggested)
potential hazardous waste dump sites including the 56 sites previously
identified in ERRIS.
To guide future follow-up site specific investigations, all 140
sites were categorized. The categorization involved the development
of 6 classes of sites. The 6 classes are made up of 3 priority
divisions (A, B and C) in each of 2 basic groups: an ERRIS group
consisting of those 56 sites already known to EPA, and a non-ERRIS
group consisting of those additional 84 potential sites discovered
from this evaluation. The priority divisions were developed based
on a comparison of available data on each potential site against
pertinent environmental parameters such as: population within 1/2
mile of site, proximity to floodplain, ground water use, proximity
to public water supply sources, site security, and type and quantity
of hazardous waste. Sites in Division "A" are considered the highest
priority for site specific follow-up activities, then Division "B"
followed by Division "C." The categorization resulted in the following
breakdown:
ERRIS Group
Division "A" - 16 sites
Division "B" - 36 sites
Division "C" - 4 sites
Non-ERRIS Group
Division "A" - 18 sites
Division "B" - 47 sites
Division "C" - 19 sites
Table 4 identifies the implementation strategy for future investi-
gations at all these sites. The tables in Appendix D identify specific
implementation strategies for each of the two basic groups, ERRIS and
non-ERRIS.
22
-------
STRATEGY FOR IMPLEMENTATION
KANAWHA VALLEY SPECIAL REPORT RECOMMENDATIONS
ERRIS & NON-ERRIS SITES
S.D.
P,A.
*A*ti
S.I.
(*1Uai
ERRI8
NOM-
ERM8
ERRI8
NON-
ERRI8
ERRI8
NON-
ERIII9
GROUP A
TO BE COMPLETED
6 MONTHS
0
84
. 6
16
4
4
M,
20
8
GROUP B
TO BE COMPLETED
1 YEAR
0
0
10
28
8
. 8
0
35
12
GROUP C
TO BE COMPLETED
2 YEARS
0
0
8
f
2
8
0
5
7
84
60
27
)- ALL P.A. AND 8.1. NUMBERS ARE ESTIMATES.
<*!)- EPA WILL CONDUCT P.A.I AND S.I.* TO REACH THE PLANNED GOALS.
August 1985
23
-------
5.0 AIR TOXICANTS
-------
5.0 Air Toxicants
As discussed in Chapter 4, although current ambient air standards
are being met in the Kanawha Valley, emissions and ambient levels of
unregulated air toxicants are largely unknown. The NEIC report identified
the need for an evaluation of air quality in the Kanawha Valley. The
Administration has also recognized the need for new air toxicant efforts,
and in February 1985 the Hazardous Air Pollutants Amendments Act of
1985 (H. R. 967) was referred to the House Committee on Energy and
Commerce. This chapter summarizes Region Ill's plans for an air toxicant
assessment in the Valley and outlines the direction of the air toxicant
program identified in EPA's National Air Toxics Strategy.
A 1984 Kanawha Valley emissions inventory is now under preparation
by the West Virginia Air Pollution Control Commission. Based on this
inventory, EPA and WV have initiated a study which focuses on air
toxicants. The study is a multi-media screening analysis and will
attempt to identify chronic human health and environmental risks resulting
from routine chemical exposures in the Valley.
In the study, the screening analysis will model ambient concentra-
tions of pollutants using the 1984 updated emissions data and on-site
meterological data, and then estimate relative exposure risks. Risk
assessment air analyses will be performed in 4 distinct Valley zones:
Belle, Institute, S. Charleston and Nitro. EPA has also sponsored a
limited 45-day fixed-station ambient monitoring program to gather data
near various facilities in Belle and Institute. Using the preliminary
risk estimates, EPA and WV will compare pollutants, exposure routes
and sources, and identify locations for additional ambient air monitors.
Also, as part of the first phase of the study, potential exposures
from hazardous waste sites, drinking water, and surface water pathways
will be assessed. If significant exposure routes are identified,
possible source controls will be examined during a later phase of the
study. A status report which describes the results of the screening
work and plans for any necessary additional work is tentatively scheduled
for completion in August 1986.
.EPA's other efforts in the area of air toxicants are described in
the National Strategy for Toxic Air Pollutants, released June 4, 1985.
The Strategy includes a redirected Federal regulatory program and
enhanced Federal support to State air programs for routine and sudden
accidental releases. Information on this policy was excerpted from a
statement by Lee M. Thomas, EPA Administrator, before the House Sub-
committee on Health and the Environment on June 11, 1985.
Necessary actions which are planned in the National Strategy
for routine releases include enhancing national regulation, expanding
State programs, and developing multi-media control methods. As discussed
in Chapter 3, emissions of six toxic air pollutants are covered under
24
-------
§112 of the CAA. Twenty to twenty-five additional chemicals have been
considered for regulation under §112. Ten of those were included in a
Federal Register notice of intent to list these pollutants pursuant to
§112. Entire emissions streams from various source categories which
contain a mixture of toxic chemicals are candidates.for regulation.
Consistent with the Strategy, the aforementioned study which is underway
in the Kanawha Valley is the first step in the anticipated development
by the State of a regulatory program covering routine releases of air
toxicants. EPA is also providing programmatic assistance to West Virginia
in establishing appropriate responses to sudden accidental releases
through the mechanism of the Chemical Emergency Preparedness Program.
In addition, EPA is currently developing a proposed National Accident
Prevention Program in which WV participation will be encouraged.
Implementation of a pre-treatment program for sewage treatment
plants is also expected to reduce evaporative losses of toxic chemicals.
Other Federal regulatory mechanisms proposed are the use of §111 (NSPS)
to control area sources, and the use of RCRA and TSCA to control toxic
emissions from hazardous waste facilities. EPA will also strengthen
State capabilities to ensure that each State has an air toxics program
in place by the end of FY 86 to facilitate enforcement. In addition
to State regulatory aid, the Federal program calls for enhancing the
technical capabilities at the State level. Because a number of pollu-
tants and source types are of local concern, a Federal air standard
may not be warranted. To reduce exposures in these situations, EPA
will be assisting State agencies technically and financially. One
separate State initiative is West Virginia's Voluntary Reduction
Program. This is a joint program between the State and industry in
the Valley and is expected to reduce, in the very near future,
current levels of air toxic emissions.
As discussed in Chapter 3, sudden accidental spills or releases
may be enforced under the CWA if a spill reaches a navigable waterway
or under the CAA if the substance released is one of the six hazardous
substances covered under §112. CERCLA also requires that these releases
be reported to EPA. As with routine releases, EPA will enhance States'
capabilities to respond to accidental releases by increasing State
training, providing technical support, and coordinating national policy
and planning for emergencies. At the local level, the West Virginia
Department of Health has recently adopted a community Right-to-Know
program. Regulatory programs to deal with accidental releases will
also be enhanced and expanded. TSCA and CERCLA recordkeeping and
reporting procedures will be revised and enhanced to attain a higher
level of comprehensive reporting. Additional civil enforcement
authorities under CERCLA have been requested by the Administration.
Another action being planned by EPA for accidental spills and releases
involves developing an Acute Hazards list. The list will identify
those substances most likely to cause health effects from a short-term
high level exposure. This list will be used to develop follow-up
actions, target emergency response efforts, and aid in developing
Right-to-Know programs.
25
-------
6.0 CONCLUSIONS
-------
6.0 Conclusions
Statements made in this chapter regarding the compliance of
particular facilities with certain laws or regulations are based
only on the writers' information and understanding. Such statements
should not be relied on as definitive findings of the Agency as to
either compliance or non-compliance.
Water
NPDES permits with BAT effluent limitations have been issued to
15 of the 19 major facilities in the Valley. Revised permits with BAT
effluent limits have been drafted for three of the remaining four.
The non-BAT permit will expire in 1987. Relatively few toxic pollutants
are specifically limited in permits. Therefore, bioassays have been
used to detect effluent toxicity. When bioassays have indicated signi-
ficant toxicity, EPA and the State have usually obtained additional
information on causes and corrective actions. Periodic spills and
leaks of toxicants and process upsets may be affecting water quality.
Toxicity to aquatic life has also been observed in ambient water and
sediments in the industrial section of the Kanawha River.
Two of the 19 major industries in the Kanawha Valley violated
effluent limitations significantly during the last quarter of 1985.
In each case, the problem has been corrected or the State has initiated
regulatory action.
Ambient Water Quality and Water Monitoring
Silver and arsenic concentrations often exceeded water quality
criteria, a significant point source of selenium may exist, and nonpoint
sources may contribute important pollutant loads. Dioxin concentrations
in fish tissue have exceeded the levels of concern for consumers.
Although ambient water monitoring in the Kanawha has been effective,
West Virginia and ORSANCO should review monitoring priorities in the
Kanawha River.
Air
Elkem Metals is the only major facility listed in this report
that is not in compliance with air regulations. The facility boilers
violated visible emissions standards. The West Virginia Air Pollution
Control Commission is actively pursuing correction of these violations
by the company.
Ambient Air Quality and Air Monitoring
The air quality in the Kanawha Valley, in general, has improved
significantly over the past several years. The.monitoring network
operated by the WVAPCC presently shows all the National Ambient Air
Quality Standards (NAAOS) being met. Two potential problems may
be the CO and 63 levels in the Valley. Because there is only one
monitor for each of these pollutants, the data collected may not be
representative of the CO and 03 levels in the entire Valley.
26
-------
RCRA
For the major facilities in the Kanawha Valley, RCRA permits have
either been issued or the.Part B permit applications have been called in
by DNR or EPA. Permits are being issued in accordance with the priorities
established in the RCRA National Permit Strategy. All permits are
currently targeted for issuance by January 1988.
Four facilities are currently not in compliance with RCRA's interim
status requirements. The most recurring problems are with violations of
ground water monitoring requirements.
TSCA
All facilities are in compliance, however, only a limited number
of inspections have been done.
FIFRA
All major pesticide producers in the Kanawha Valley are in compli-
ance with FIFRA. Furthermore, regular inspections to ensure continued
compliance are being conducted by the West Virginia Department of
Agriculture with EPA oversight.
CERCLA
Detailed site discovery resulted in the identification of 140
potential hazardous waste sites. Of those, 84 were not included in
EPA's previous inventory of potential sites. The implementation
schedule developed to investigate these sites is being followed.
Spills/Releases
Enforcement actions were taken on spills/releases where enforceable
violations were documented. To enhance the Region's efforts, formal
procedures were revised in 1985. The revised procedures address follow-up
actions and internal coordination on spill/release reports.
A substantial percentage of the releases reported as exceeding
a reportable quantity are air releases of substances not listed as
hazardous under the CAA.
27
-------
APPENDIX A
PERMITS
-------
TABLE A-l
PERMIT ISSUANCE STATUS
Facility/NPDES No.
Location/Waste Contributing Activity
Existing Permits
Issued Expires
Re Issuance
Target Date
Bases for Permit Limitations
Allied Cheraical/WV0002542
Nitro, WV/Inorganic Chemicals
Appalachian Power/WVOOO1074
St. Albans, WV Power Plant
Appalachian Power/WV0001066
Glasgow, WV/Power Plant
Chemical Leaman/WV0002372
Institute, WV/Chemical Transporter
Coastal/WV0050130
Nitro, WV/Chemical Transporter
CST (Fike)/WV0001651
Nitro, WV/Organic Chemicals
Diamond Shamrock/WV0002313
Belle, WV/Inorganic Chemicals
E.I. DuPont/WV0002399
Belle, WV/Inorganic & Organic Chemicals
Elkem Metals/WV0000167
Alloy, WV/Ferroalloys
01-04-84 01-03-89
08-16-85 08-16-90
11-08-84 11-08-89
01-21-81 01-21-86
11-18-85 11-18-90
03-05-82 03-05-87
01-26-86 01-26-91
09-23-81 09-23-86
03-08-82 03-08-87
05-86
BPJ for BAT (Facility recently
closed except for storage area)
1982 power plant gdlns for BAT.
1982 power plant gdlns for BAT
BPJ for BAT
BPJ for BAT
BPJ for BCT (Conventional
pollutants) (Toxiclty limited
by bioassay)
BPJ for BAT
BPJ for BAT
BPJ for BAT
28
-------
TABLE A-l (Continued)
PERMIT ISSUANCE STATUS
Facility/NPDES No.
Location/Waste Contributing Activity
Existing Permits
Issued Expires
Reissuance
Target Date
Bases for Permit Limitations
FMC/WV0000400
Nitro, WV/Organic Chemicals
FMC/WV0000442
S. Charleston, WV/Inorganic
& Organic Chemicals
Hatfleld & Henson/WV0002381
Dunbar, WV/Cooling Water
Kinkaid/WVOOOOlOS
Nltro,WV/Inorganic & Organic Chemicals
Mason & Dixon/WV0001708
St. Albans/Chemical Transporter
Monsanto/WV0000868
Nitro, WV/Organic Chemicals
S. Charleston Sewage Tr. Co./WV0023116
S. Charleston, WV/Primarily Chemical Waste Tr.
Union Carbide/WV0000086
Institute, WV/Organic Chem & Pesticides
Union Carbide Tech Center WV0000124
S. Charleston/R & D Laboratory
Union Carbide/WV0000078
S. Charleston, WV/Chem. Plant Cooling Water
01-31-80 01-31-81 05-86
(extended)
02-21-81 06-30-81 08-86
(extended)
11-13-85 11-13-90
09-16-81 09-16-86 09-86
03-12-86 03-12-91
03-10-86 03-10-91
12-04-74 01-04-80 05-86
(extended)
10-30-81 10-30-86
12-17-85 12-17-90
06-14-84 06-13-89
Existing-BPJ for BPT
Proposed-BPJ for BAT
Existing-BPJ for BPT
Proposed-1982 inorg. gdln for BAT
- BPJ for BAT (organic)
BPJ for BAT
BPJ for BAT-Exist and Proposed
BPJ for BAT
BPJ for BPT
Existing-BPJ for BPT
Proposed-BPJ for BAT
BPJ for BAT
BPJ for BAT
BPJ for BAT
NOTE - Extended NPDES permits due to (1) timely reapplication or (2) existing valid State permit.
29
-------
Table A-2
RCRA Permit Status
Name/Address
of Facility
1) duPont
Belle, WVA
9^ PCT Tnr»
Nitro, WVA
3) Fike Chemicals
Nitro, WVA
4) FMC
S. Charleston, WVA
5) FMC
Nitro, WVA
Nitro, WVA
7) Union Carbide
Agricultural Products
Institute, WVA
(Plant 514)
S. Charleston, WVA
9) Union Carbide - PTO
Institute, WVA
0) Union Carbide - Holz
S. Charleston, WVA
1) Union Carbide ~ Tech Ctr
S. Charleston, WVA
Permit Application
Submission Date
6/85
1 9/84
12/84
6/85
10/84
6/85
6/85
Permit Issuance
Target Date
1/90
3/86
9/86
12/87
9/84
Q /Q f.
y I oo
10/87
A /oo
12/87
1/88
f, /ft ^
O/ O J
Comments .
Per RCRA Nat ' 1
Strategy
Per RCRA Nat'l
Strategy
Permit does not
cover entire
facility
Per RCRA Nat'l
Strategy
Per RCRA Nat'l
Strategy
Per RCRA Nat'l
Strategy
30
-------
APPENDIX B - COMPLIANCE
Statements made in these tables about the compliance of
particular facilities with certain laws or regulations
are based only.on the writers' information and under-
standing. Such statements should not be relied on as
definitive findings of the Agency as to either compliance
or noncompliance.
-------
COMPLHWCE REVIEW
Facility:
Location:
Period
Allied Chemical NPDES Permit No.: WV0002542
Nitro, WV - • Activity: Inorganic Chemicals
- NPDES Enforcement Lead: WVDNR
Regulatory Actions
Compliance Status Non-Compliance Causes & Corrections & General Comments
... - . . •
Jan -
Apr -
Jul -
Oct -
Jan -
Apr -
Jul -
Oct -
Jan -
Apr -
Jul -
Oct -
Jan -
Apr -
Jul -
Oct -
Mar 82
Jun 82
Sep 82
Dec 82
Mar 83
Jun 83
Sep 83
Dec 83
Mar 84
Jun 84
Sep 84
Dec. 84
Mar 85
Jun 85
Sep 85
Dec 85
No Violations Reported (NVR)
NVR ' ' ' , .
. . NVR-.. • • - '•'•'- . ' • , :• •.•;-._. • .
NVR \ • \ ; ' ''• ..
.NVR ' . '
NVR ! , " • ^ '• ,
NVR ' • • - , .. .' ,
NVR .."'..•
NVR ' .. '
NVR ' • ' " Facility closed except
. . for storage area; runoff
monitored
NVR -
, NVR .
NVR ;. •'.•'.-.' '
NVR " . ; „ J .
NVR . ! '
NVR
31
-------
COMPLIANCE REVIEW
Facility:
Location:
Period
Appalachian Power-Amos Plant . NPDES Permit No.: WV0001074
St. Albans Activity: Power Plant
* NPDES Enforcement Lead: EPA
Regulatory Actions
Compliance Status Non-Compliance Causes & Corrections & General Comments
i
Jan
Apr
Jul
Oct
Jan
Apr
Jul
Oct
Jan
Apr
Jul
Oct
Jan
Apr
Jul
Oct
- Mar 82
- Jun 82
- Sep 82
- Dec 82
- Mar 83
- Jun 83
- Sep 83
- Dec 83
- Mar 84
- ' Jun 84
- Sep 84
-Dec 84
- Mar 8.5
- Jun 85
-Sep 85
- Dec 85
No Violations Reported (NVR) ' . '
NVR -'•••'*.'.
NVR ' . .
NVR - . •; - •
' NVR
NVR • • ' ,
NVR ; • '
NVR ' . ' - '
NVR . ' . • ' , '
NVR .''.',."
,NVR ' ' ' -.'.'•
NVR
NVR . . . , _ • ."'•'..
NVR
; NVR
NVR ;
. 32
-------
COMPLIANCE REVIEW
Facility:
Location:
Period
Appalachian Power-Kanawha River Plant NPDES Permit No.: WV0001066
Glasgow, WV Activity: Power Plant
••'.•••• NPDES Enforcement Lead: WVDNR
. • . Regulatory Actions
Compliance Status Non-Compliance Causes & Corrections & General Comments
Jan -
Apr -
Jul -
Oct -
Jan -
Apr -
Jul -
Oct -
Jan -
Apr -
Jul -
Oct -
Jan -
Apr -
Jul -
Oct -
Mar 82
Jun 82
Sep 82
Dec 82
Mar 83
Jun 83
Sep 83
Dec 83
Mar 84
Jun 84
Sep 84
Dec 84
Mar 85
Jun 85
Sep 85
Dec 85
No Violations Reported (NVR)
NVR
NVR
*
NVR ' '
NVR " ' ' -
- NVR ' •, ' ' ' .
NVR .
NVR
NVR . .
• NVR
NVR' ' ' . ... '••-.".
NVR -..'•• : '." ; . '
"NVR . „ ; •
NVR . •
NVR ' " •
NVR • '-• : ' - •
33
-------
COMPLWJCE REVIEW
Facility:
Location:
Period
Chemical Leaman Tank Lines
Institute, WV
Compliance Status
NPDES Permit No.: WV0002372
Activity: Chemicals Transporter
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Jan - Dec 82
Jan - Mar 83
Apr
Jan
Apr
Jul
Dec 83
Mar 84
Jun 84
Sep 84
No Violations Reported (NVR)
Moderate TKN, oil & grease
violation
No Violations Reported (NVR)
Minor oil & grease viol.
NVR
Moderate oil & grease
violation in September
Raw water contained unusually high
amount of imine & amine products
upsetting plant
Cold weather effects on treatment
Unusually high oil & grease raw
waste loading
Returned to compliance
Returned to compliance
Oct - Dec 84
Jan - Mar 85
Apr - Dec 85
Oil & grease violations
(Apparent violations)
Oil & grease Minor TKN,
phenols
No Violations Reported"(NVR)
No sheen detected; company suspects
testing error gave false readings
for violation
Testing error confirmed
Company requested future
splitting of samples with
State to check testing
procedures
0 & G samples sent
to new lab, returned to
compliance.
34
-------
COMPL^RCE REVIEW
Facility: Coastal Tank Lines
Location: Nitro, WV
Period
Compliance Status
Non-Compllance Causes & Corrections
NPDES Permit No.: WV0050130
Activity: Chemical Transporter
NPDES Enforcement Lead: WVDNR
Regulatory Actions
& General Comments
Jan
Oct
Sep 82
Dec 82
Jan - Jun 83
Jul - Dec 83
Jan - Mar 84
Jul - Sep 84
Oct
Jan
Dec 84
Mar 85
Monitoring reports not received
Minor COD, oil & grease, ammonia
violations
Minor COD, oil & grease, ammonia
violations
Minor COD, oil & grease, ammonia
violations
COD, oil & grease, ammonia,
phenol, BOD, pH violations
Apr - Jun 84 Oil & grease viol, Apr 84
Phenol, ammonia violations,
Aug 84
Oil & grease, COD violations
Oil & grease, COD, phenols
violations
No causes given
Biomass upset; company re-established
sludge mass and reviewed waste loading
procedures
Company hired trained operator to improve
treatment; company plans to haul out
troublesome waste
Company attempted to correct problem
by segregating wastes
Inspection indicated inadequate 0 & M
Toxic bioassay results; plant overload.
Apr - Jun 85 Oil & grease violation, Apr
Jul - Sep 85 No violations reported
Oct - Dec 85 COD, ammonia, Oil and grease Toxic bioassay results
Enforcement action
deferred
Enforcement action
deferred
State issued Notice to
Comply
State issued warning
letter
State issued Notice to
Comply
Order issued requiring
compliance
Minor violation; returned
to compliance
Oil and Grease returned
to compliance
State study initiated to
reduce toxicity
35
-------
Facility: CST/Fike Chemical
Location: Nitro, WV
Period
Compliance Status
NPDES Permit No.: WV0001651
Activity: Chemical Transporter
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Apr - Jun 82
Jul - Mar 83
Apr - Jun 83
Jul - Sep 83
Oct - Dec 83
Jan - Jun 84
Jul - Sep 84
Large phenols violation in June
No Violations Reported (NVR)
Large phenols violations
Minor pH violations
No Violations Reported (NVR)
Oil & grease, phenols, pH, COD,
BOD, TSS violations
Oil & grease, phenols, pH, COD,
BOD, TSS violations
Suspected storm flushing of accumulated,
phenolic substances out of sewer line
pH upset killed off .treatment microbes;
plant reseeded
High hydraulic loading caused biomass
washout and severe plant upset
Biomass not recovered; aeration tank
reseeded. Grease problems caused by
washout of accumulated deposits in
sewer line
Company submitted plan for activated
carbon "treatment, diatomaceous earth
filter and process improvements.
EPA issued warning letter;
returned to compliance
Returned to compliance
State issued Notice to
Comply
State issued Order for
compliance
Oct - Dec 84
Jan - Mar 85
Apr.- Jun 85
Jul
Oct
Sep 85
'Dec 85
TSS, oil & grease, phenols, BOD,
COD violations
Oil & grease, phenols, BOD, COD
violations
Oil & grease, phenols, BOD, COD
violations
Phenols, 0 & G sulphate viol.
COD, BOD, 0 & G violations
Start-up problems with carbon
regeneration system
By-passing activated carbon system
By-passing activated carbon system
State granted time exten-
sion until Mar 85 for full
complaince
Filter & act carbon up-
graded; effluent improve-
ment expected
Effluent improved during
summer; under close review
by State
EPA preparing Federal
Court Action
-------
- REVIEW
Facility:
Location:
Period
Diamond Shamrock
Belle, WV , ,
Compliance Status
Non-Compliance Causes & Corrections
NPDES Permit No.: WV0002313
Activity: Inorganic Chemicals
NPDES Enforcement Lead: WVDNR
Regulatory Actions
& General Comments
Jan - Mar 82
Apr - Jun 82
Jul - Sep 82
Oct - Dec 82
Jan - Mar 83
Apr - Jun 83
r»
Jul - Sep 83
Oct - Dec.83
Jan - Mar 84
Apr - Jun 84
Jul - Sep 84
Oct - Dec 84
Jan - Mar 85
Apr - Jun 85
Jul - Sep 85
Oct - Dec 85
No Violations Reported (NVR)
NVR
NVR'
NVR
NVR
NVR ^
NVR
pH violation, 004, Dec. 1983
NVR
- NVR
NVR
NVR
NVR
NVR
NVR
NVR
Sulfuric acid leak through
cracked drain valve in dike, repaired
Returned to compliance
37
-------
COMPLIANCE REVIEW
Facility:
Location:
Period
DuPont
Belle, WV
Compliance Status
NPDES Permit No.: WV0002399
Activity: Organic & Inorganic Chemicals
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Jan - Jun 83
Jul - Sep 83
No Violations Reported (NVR)
TOC, BOD, pH, f. coliform
violations
TOC viol, from pump seal failure;
repaired. BOD viol from aeration
blower failure; repaired.
Returned to compliance
Oct - Dec 83
Jan - Mar 84
Apr - Jun 84
Jul - Sep 84
Oct - Dec 84
Jan - Mar 85
Apr - Jun 85
Jul - Sep 85
Oct - Dec 85
TSS violation, outfall 062, Oct
TOC violation, outfall 043, Nov
TOC violation, outfall 013, Dec
Minor pH viol, outlet 017, Mar
Moderate TSS violation,
outfall 062, May
Minor BOD violation,
outfall 062, June
NVR
TOC violation
BOD vio, outfall 062, Feb
BOD vio, outfall 062, Jun
TSS vio, outfall 062, May
NVR
TOC vio, outfall 043, Oct
High nitrogen loading affected settling
Valving error; corrected
Organic material on ground entered
drain; remaining material cleaned up
Heat exchanger leak; repaired
Sludge bulking in clarifier; treatment
modified to stabilize system
High loading while one unit down;
temporary problem
Possible contamination of cooling
water; temporary problem
Organic & hydraulic overload;
returned to compliance
Forming caused TSS carry-over
Sludge coagulation caused BOD excess
Returned to compliance
Returned to compliance
Returned to compliance
Line plugged; cleaned and returned
to compliance
Returned to compliance
Closer monitoring of
waste loading
Non-continuous; returned
to compliance
BOD, TSS returned to
compliance
Short term violation
38
-------
COMPllW&CE REVIEW
***PAGE 1 OF 2
Facility:
Location:
Period
Elkem Metals
Alloy, WV
Compliance Status
Non-Compliance Causes & Corrections
NPDES Permit No.: WV0000161
Activity: Ferroalloys
NPDES Enforcement Lead: WVDNR
Regulatory Actions
& General Comments
Apr -Jun 82
Jul - Sep 82
Oct - Dec 82
Jan - Mar 83
Apr - Jun 83
Jul
Jan
Dec 83
Mar 84
Apr - Jun 84
Jul - Sep 84
Oct - Dec 84
TSS violation in June
TSS violations, outfalls 003, 004
in Sept. Raw sewage spill in Sept.
Monitoring frequency violation
No Violations Reported (NVR)
TSS violations, outfalls 004, 007
Fecal coliform violations in
April .
NVR
No monitoring for outfall 005, Feb.
TSS viol, outfall 004, 0.05, Jan. .
Minor manganese violation, outfall
007, April ,
TSS viol, outfalls 002, 003, 004,
005, July -
F. coli viol, outfall 102, Aug.
TSS viol, outfall 003, Aug.
Process changeover and heavy rains
Sewer line break; repaired
Company monitoring monthly; permit
requires weekly monitoring
Runoff from heavy rain
Temporary malfunction of
chlorination system; repaired
Plant labor strike
Contaminated surface runoff
Runoff from heavy rain
Unknown reasons
Chlorination system malfunction,
repaired
TSS viol, outfalls 102, 005, Sept. Startup problems at steam plant
TSS viol, outfalls 102, 005, Oct.
TSS viol, outfalls.004, 005, 008,
Nov.
Startup problems
Heavy rainfall runoff
Returned to compliance
Returned to compliance
Company advised to comply
with permit monitoring
requirements
Violations under State
review
State issued Notice to
Comply
Violations under State
review
Returned to compliance
CONTINUED
• 39
-------
COMPLIANCE REVIEW
***PAGE 2 OF 2
Facility:
Location:
Period
Elkem Metals
Alloy, WV
Compliance Status
NPDES Permit No.: WV0000161
Activity: Ferroalloys
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Jan - Mar 85
Apr - Jun 85
Jul - Sep 85
Oct - Dec 85
No Violations Reported (NVR)
TSS Viol, outfall 004, Apr.
pH, outfall 008, July, Aug.
pH, outfall 006, Nov.
TSS, outfalls 002, 003, 004 Dec.
Unknown reasons
Unknown reasons
Runoff problems caused by
heavy rains
Minor; returned to
compliance
Minor; returned to
compliance
Minor violations;
returned to compliance
40
-------
:E REVIEW
Facility:
Location:
Period
FMC
Nitro, WV
Compliance Status
Non-Compliance Causes & Corrections
NPDES Permit No.: WV0000400
Activity: Organic Chemicals
NPDES Enforcement Lead: EPA
Regulatory Actions
& General Comments
Jan - Sep 82
Oct - Dec 82
Jan - Mar 83
Apr - Jun 83
Jul - Sep 83
Oct - Dec 83
Jan - Mar 84
Apr - Jun 84
Jul - Sep 84
Jan - Mar 85
Apr - Jun 85
No Violations Reported (NVR)
BOD violation in Dec. 82
NVR
pH violation
Minor arsenic violation
Minor ph Violations
Moderate BOD violations
Large BOD violations
Moderate BOD violations
No Violations Reported (NVR)
pH violation, July
pH violation, August
pH violation, Sept.
Arsenic violations (3) Sept.
pH violation, Jan
Minor arsenic violation
Packing Failure in stripping column,
packing replaced
Returned to compliance
Spillage from accidental acidic drum breakage Returned to compliance
Returned to compliance
Problems with reaction/distallation
system; system was cleaned and no
subsequent violation;occurred
Packing failure; replaced. Heat exchange
leak; repaired. Activated carbon system
failed; replaced
Returned to compliance
Organic overload; seeded to increase biomass. Returned to compliance
Activated carbon system failed; replaced.
Moderate toxicity indicated by blomonitoring inspection
Leak in diked process area; repaired
Collection trench leak; repaired
Temporary process line leak; repaired
Entire plant initially shut down to
investigate; scrubber tank identified as
source; it was taken out of service and
analyzed for problems
Acidic overflow due to instrument
malfunction; Backup instrument installed
Condenser plugging caused inefficient
separation in distillation system
Returned to compliance
Short term violation;
Returned to compliance
Condenser unplugged;
Returned to compliance
Jul - Dec 85
No Violations Reported (NVR)
-------
COMPLIAHE REVIEW
Facility:
Location:
Period
FMC
South Charleston, WV
Compliance Status
Non-Compliance Causes & Corrections
NPDES Permit No.: WV0000442
Activity: Inorganic & Organic
Chemicals
NPDES Enforcement Lead: EPA
Regulatory Actions
& General Comments
Jan
Jul
Oct
Jun 82
Sep 82
Dec 82
Jan - Mar 83
Apr - Jun 83
Jul -
Oct -
Jan -
Oct
Sep 83
Dec 83
Sep 84
Dec 84
Jan - Mar 85
Apr - Dec.85
No Violations Reported (NVR)
Ammonia violation in Sept.
pH violation, outfall 004
Moderate TKN violations
Moderate TKN violations
Minor chlorine violations
ph violations
NVR
Minor pH violation, outfall
018, Oct.
TSS & TKN violations, outfall
029, Oct.
Minor pH violation, outfall 018
Minor pH violation
Valve stuck, repaired,, alarm fixed,
pH controller replaced.
Unknown problem at ammonia production
unit '
Ammonia gas scrubber and valve; situation
corrected and back up' treatment system
installed •
Treatment unit plugged; problem corrected
and neutralization increased
pH control improvements completed
Hose rupture; replaced
Flyash pond overflowed; equalization
pond operation improved
Frozen water line in pH controller
Unknown
Returned to compliance
,EPA issued order to
correct problem and
prevent recurrence
Enforcement action
deferred
Returned to compliance
Returned to compliance
EPA issued order to comply
with pH limits; returned
to compliance
Returned to compliance
Returned to compliance
Returned to compliance
Returned to compliance
42
-------
COMPLlbMK REVIEW
***PAGE 1 OF 2
Facility: Hatfield - Henson
Location: Dunbar, WV
Period
Compliance Status
NPDES Permit No.: WV0002381
Activity: Power plant cooling pond
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Jan - Sep 82
Oct - Dec 82
Jan - Mar 83
Apr - Jun 83
Jul - Sep 83
Oct. - Dec 83
Jan - Mar 84
Apr - Jun 84
Jul - Sep 84
Oct - Dec 84
No Violations Reported (NVR)
TSS, copper, barium, arsenic
violations
TSS, copper, nickel, TSS
violations, Jan :
Barium violation, Feb
Copper violation, Mar
Barium violation
Barium, arsenic violations
Barium violation, Oct, Nov
Arsenic violation, Oct
Copper, nickel violations, Nov
No metal analysis, Dec
Copper violation, Jan & Feb
Arsenic violation, Jan & Mar
Barium violation, Mar
Barium, arsenic, copper
violations
Barium, arsenic, nickel, zinc
violations
Barium, copper, arsenic violations
Boiler blowdown is source of metals
Metals limits based on
stream standards for very
small receiving stream
State Notice to Comply
issued
Company indicated plans to
request stream standards
variance for metals
State issued Notice to
Comply
State issued Order to
initiate compliance action
Company requested variance
from stream standards
43
-------
***PAGE 2 OF 2
COMPLIANCE REVIEW
Facility: Hatfield - Henson
Location: Dunbar, WV
Period
Compliance Status
NPDES Permit No.: WV0002381
•Activity: Power plant cooling pond
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Jan - Mar 85
Apr - Jun 85
Jul - Sep 85
Barium, copper, arsenic
violations
Barium, copper, arsenic
violations
Barium, copper, nickel
violations
Oct - Dec 85 No Violations Reported (NVR)
Discharge must equal stream standards;
Board considering variances.
Discharge will be required to meet
new, less stringent stream standards
Discharge will be required to meet
new, less stringent stream standards
State Order to comply with
stream standards
Permit to be issued with
less stringent limits.
Permit to be issued with
less stringent limits.
Reissued permit contains
less stringent limits.
44
-------
COMPLIA
REVIEW
Facility:
Location :
Period
Kinkaid (Chemical Formulators) NPDES Permit No.: WV0000108
Nitro, WV Activity: Organic and Inorganic Chemicals
. „ NPDES Enforcement Lead : WVDNR
Regulatory Actions
Compliance Status Non-Compl lance Causes & Corrections & General Comments
Jan
Apr
Jul
Oct
Jan
Apr
Jul
Oct
Jan
Apr
Jul
Oct
Jan
Apr
Jul
Oct
- Mar 82
- Jun '82
- Sep 82
- Dec 8,2
- Mar 83
- Jun 83
- Sep 83
- Dec 83^
- Mar 84
- Jun 84
- Sep 84
- Dec 84
- Mar 85
- Jun 85
- Sep 85
- Dec 85
No Violations Reported (NVR)
NVR ;
NVR •."..•'"' .
NVR ' " .
NVR
NVR *
NVR , Toxic bioassay results due to high TDS.* TDS is not limited in
effluent; WQS not violated
NVR
NVR
NVR ' ' •
NVR ' . ' . .
NVR . ,
NVR Toxic bioassay results* High chlorides suspected
NVR ' , •
NVR ' • f Toxic bioassay results*
NVR . > .. " '
*The permit requires that toxic bioassay results be followed up with evaluation of sources; they are not specific permit
violations.
45
-------
COMPLIANCE REVIEW
Facility:
Location:
Period
Mason & Dixon Tank Lines
St. Albans, WV
Compliance Status
NPDES Permit No.: WV0001708
Activity: Chemicals Transporter
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Jan
Oct
Sep 82
Dec 82
Jan - Mar 83
Apr
Oct
Jan
Apr
Sep 83
Dec 83
Mar 84
Jun 84
Jul - Sep 84
Oct - Dec 84
Jan - Mar 85
Apr - Jun 85
Jul - Dec 85
No Violations Reported (NVR)
BOD, TSS, TKN, Color violations
Color, TKN violation
Color, TKN violation
Color, TKN violation
Color, BOD, F Coli, TKN viol.
Color, F. Coli, TKN violations
Color violation
No Violations Reported (NVR)
No Violations Reported (NVR)
F. Coli, viol., May
No Violations Reported (NVR)
Company hired consultant to recommend
remedy by Oct. 83
Company ceased using ammonia nutrient;
TKN violations stopped
Enforcement Action
deferred
State issued Notice to
Comply
State issued Notice to
Comply with F.Coli, TKN
limits
State plans to modify
color limit to achievable
level
Permit modified to remove
color limit. Bioassay
indicates non-toxicity
Non-continuous; returned
to compliance
46
-------
COMPLIANCE REVIEW
Facility:
Location:
Period
Monsanto . NPDES Permit No.: WV0000868
Nitro, WV Activity: Organic Chemicals
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Compliance Status Non-Compliance Causes & Corrections & General Comments
Jan
Apr
Jul
Oct
Jan
Apr
Jul
Oct
Jan
Apr
Jul
Oct
Jan
Apr
Jul
Oct
- Mar 82
- Jun 82
- Sep 82
- Dec 82
- Mar 83
- Jun 83
- Sep 83
- Dec 83
- Mar 84
- Jun 84
- Sep 84
- Dec 84
- Mar 85
- Jun 85
- Sep 85
- Dec 85
No Violations Reported (NVR)
NVR
NVR
NVR .
NVR
NVR •
NVR
NVR
Minor TSS violation Upset due to organic overload Returned to compliance
NVR
NVR
NVR
NVR
NVR
NVR
NVR
47
-------
Facility: Union Carbide
Location: Institute, WV
Period
Compliance Status
COMPLIANCE REVIEW
*** PAGE 1 OF 2
NPDES Permit No.: WV0000086
Activity: Pesticides & Organic Chemicals
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Jan - Mar 82
Apr - Jun 82
Jul - Sep 83
Oct - Dec 83
Jan - Mar 84
Apr - Jun 84
Jul - Sep 84
TOC violations 004, Jan, Feb
TOC violations 004, Mar
TOC violations 006, Mar
pH violations 005, Feb
TOC violation, 004, Apr
No violations reported (NVR)
TSS violation, outlet 001, Oct
TOC viol, outlet 003, Nov & Dec
Ammonia viol, outlet 002,
Nov & Dec
TKN, TOC, pH viol, outlet
002, Dec
TKN, ammonia, pH viol; 002 Jan
TSS viol, 008, Mar
TSS viol, outlet 008, Apr 84
TOC, pH viol, outlet 005 Apr 84
TOC viol, outlet 003, Apr 84
TSS viol, outlet 002, Apr 84
F. coli viol, outfall 001, Aug
pH viol, outfall 005, Sep
Cold weather treatment upset
Suspected small leak in acetone unit;
not confirmed
Suspected small leak in Napthol unit
Neutralization problems; investigation
started, problems ceased
Process line rupture; repaired
Leak; repaired
Brief occurrence
Condenser leak; repaired
Start up problems for ash treatment
pond
Brief occurrence
Undetermined cause
pH returned to
compliance
TCC returned to
compliance
Short term violation
of returned to
compliance
TKN, pH returned to
compliance
TSS returned to
compliance
Returned to
compliance
CONTINUED
48
-------
COMPLIANCE REVIEW
***PAGE 2 OF 2
Facility: Union Carbide
Location: Institute, WV
Period
Compliance Status
NPDES Permit No.: WV0000086
Activity: Pesticides & Organic Chemicals
NPDES Enforcement Lead: WVDNR
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Oct - Dec 84
Jan - Mar 85
Apr - Jun 85
Minor TOG violation, Nov
Isophorone violation, 001, Nov
Large toluene violations,
outfall 005, Dec
Large toluene violations,
005, Jan
Isophorone violation
Jul - Sep 85
Isophorone violation
TOG Violations
BOD, TSS Violations, outfall
001, July
Brief 001 occurrence; unknown cause
Toluene condenser leaked into cooling
water; shut down and reparied upon
detection
Leak in toluene cooling unit and process
sewer line; repaired.
Power failure caused process upset and
overload
Overflow of production unit still;
modifications made; problem ceased
TOC - storage tank leak; repaired
BOD, TSS - 47 undetermined cause
Oct - Dec 85
pH violations, outfall 005, Oct Leak in caustic line; repaired.
EPA issued § 308 letter
requiring complete report
of Dec & Jan toluene
incidents.
Company response received,
and under review.
Isophorone - Process upset
safeguards provided.
Toluene - modified permit
will require increased
monitoring.
Isophorone, BOD, TSS, TOC
returned to compliance
49
-------
COMPLI1
REVIEW
***PAGE 1 OF 2
Facility: South Charleston Treatment Company
Location: South Charleston^ WV
Period
Compliance Status
NPDES Permit No.: WV0023116
Activity: Treats 90% Industrial, 10% Municipal Wastes
NPDES Enforcement Lead: EPA
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Jan - Mar 82
Apr. -
Jul -
Jun 82
Sep 82
Oct - Dec 82
Jan - Mar 83
Apr - Jun 83
Jul -. Sep 83
Large fecal coliform violations
Minor TSS violation
BOD, COD violation
Large F. coli violations "
Minor BOD, COD ammonia viol.
.Large F. coli violations
Minor BOD, TSS chlorides viol.
Large F. coli violations
Minor chlorides violations
Large F. coli violations
Large BOD, COD ammonia viol.
Mod. TSS, phenols, TKN viol.
Large F. coli violations
Large BOD, chloride, ammonia
viol.
High F. coli violations
High BOD, COD, phenol,
chlorides violation
Chlorination unit inadequate for treating
municipal waste contribution.
Motor failure & rising solids; repaired
Cold weather upset •
Inadequate chlorination unit
Inadequate chlorination unit
Inadequate chlorination unit
Inadequate chlorination unit
Biological unit upset due to large sludge
buildup; operation improved after sludge
removal, aeration increase & nutrient
addition. ,
Inadequate chlorination unit
High municipal loading suspected; company
investigating
Inadequate chlorination unit
Residual sludge problems; clarifier cleaned
and 0 & M consultant hired
Industrial wastes are
primarily from Union
Carbide's organic chemical
plant. EPA Order was
issued on Feb 82 for
upgrading chlorination
unit. Permittee had
applied for construction
grant funds to provide
adequate chlorination or
to pump municipal portion
to proposed regional
sewage treatment plant.
Enforcement Action
deferred
Enforcement Action
deferred
Enforcement Action
deferred
C 0,N T'I-N U E.D
50
-------
COMPLIANT REVIEW
***PAGE 2 OF 2
Facility: South Charleston'Treatment Company
Location: South Charleston, WV
Period
Compliance Status
NPDES Permit No.: WV0023116
' • * Activity: Treats 90% Industrial, 10% Municipal Wastes
*>-. NPDES Enforcement Lead: EPA
Regulatory Actions
Non-Compliance Causes & Corrections & General Comments
Oct - Dec 83
Jan- - Mar 84
Apr - Uun 84
Jul - Sep 84
Oct - Dec 84
Jan -
Apr -
Jul -
Mar 85
Jun 85
>
Sep 85
High F. coli violations
High BOD, phenols, mod.
chlorides viol.
High F. coli violations
High BOD, .phenols violations
«
High F. coli violations ,
Minor BOD, chlorides violations
High F. coli violations
Minor BOD, chlorides violation
High F. coli violations
Oct - Dec 85
High F. coli violations
Minor chloride violations
High F. coli violations
BOD violations
High F. coli violations
Minor ammonia violations
High F. coli violations
Minor ammonia, phenols,
violations
Inadequate chlorination unit
Inadequate chlorination unit
Tr. plant upset; unknown causes
Inadequate chlorination unit.
Inadequate chlorination unit.
Compliance correction plan submitted
by company.
Inadequate chlorination unit.
Inadequate chlorination unit
Inadequate chlorination unit
Treatment problems
Inadequate chlorination unit
Inadequate chlorination unit
Enforcement Action
deferred
Enforcement Action
deferred
Enforcement Action
deferred
State issued Notice to
Comply; BOD returned
to compliance,
Grant funds for chlor-
ination unit upgrading
considered unlikely;
State compliance schedule
requires upgrading by 1987
Same as above
Same as above
Same as above
Same as above
51
-------
COMPLIANCE REVIEW
Facility:
Location:
Period
Union Carbide - Technical Center , NPDES Permit No.: WV0000124
S. Charleston, WV Activity: R & D Laboratory
, NPDES Enforcement Lead: WVDNR
Regulatory Actions
Compliance Status Non-Compliance Causes & Corrections & General Comments
Jan -
Apr -
Jul -
Oct -
Jan -
Apr -
Jul -
Oct -
Jan -
Apr -
Jul -
Oct ,-
Mar 82
Jun 82
Sep 82
Dec 82
Mar 83
Jun 83
Sep 83
Dec 83
Mar 84
Jun 84
Sep. 84 ;
Dec 84
No Violations Reported (NVR) , . ' .
NVR . -' ' " ' ' • •""" °
NVR
NVR * .
NVR • :
NVR . . ' .-.'-.
NVR - - .
NVR -.-'•. ' •' • " ' - .
NVR ; ' . ' ;
: NVR ' --.'••. .
NVR . ,
COD, TSS violations Rainfall runoff problems; limits were Notice to Comply issued
Jan - Mar 85
Apr - Jun 85
Jul - Dec 85
based on dry weather conditions.
COD violations
COD, 0 & G violations
«*
NVR
Runoff problems
for State permit; State
considering response -
blaming wet weather
conditions.
Short,term violations.
52
-------
:E REVIEW
Facility:
Location:-
Period
Union Carbide
South Charleston, WV
Compliance Status
Non-Compliance Causes & Corrections
NPDES Permit No,: WV0000078 •
Activity: Cooling water
discharge from chemical plant
NPDES Enforcement Lead: WVDNR
Regulatory Actions
& General Comments
Jan
Jan
Jan
Jul
Dec 82
Dec 83
Jun 84
Sep 84
Oct - Dec 84
Jan - Mar 85
Apr - Jun 85
Jul - Sep. 85.
Oct - Dec 85
No Violations Reported (NVR)
No Violations Reported (NVR)
No Violations Reported (NVR)
pH violation, outfall 032,
Aug
Minor pH violation
TOG viol, outfall 014, Jan
TOC viol, outfalls 015, 016
036, 076, Feb
Methyl acetate, acetone
discharges Mar
TOC concentration violation
TOC viol, outfalls 016,
TOC viol, outfalls 016, 017
pH violation, outfall 009
Intermittent blowdown prob.
-Process line rupture; repaired
-Process waste overflows to cooling
discharges; -corrected ;
-Line rupture; repaired
Non-containment in unit area
TOC - unknown cause; possible low
background flow resulting in
higher TOG concentrations
TOC - same as above
pH - caustic line leak; repaired
Returned to compliance
EPA Section 308 infor-
mation request sent
for Mar violations;
returned to compliance
Dike walls built around
unit area. Satisfactory
308 response received
TOC limited by concen-
tration, no evidence of
increased loading
53
-------
TABLE B-2
AIR PROGRAM COMPLIANCE
STATUS
BY REGULATED POLLUTANT
Name/Location
of Facility
Allied Chemical
- Nitro
Appl. Power Co.
- John E. Amos
App. Power Co.
- Kanawha River
Chemical Leaman
- Institute
Coastal Tank Lines
- Nitro
Diamond Shamrock
- Belle
DuPont
- Belle
Elkem Metals
- Alloy
Fike Chemical
- Nitro
FMC
- Nitro
FMC
- S. Charleston
Hatfield & Hanson
- Dunbar
Monsanto
- Nitro
Compliance Status
by Pollutant
TP
I C
I C
I C
c
c
b
I C
I V
b
b
I C
b
I C
S02
I C
I C
I C
b
b
b
I C
I C
b
b
I C
b
I C
VOC
a
a
a
c
c
b
a
a
b
b
a
b
a
Compliance
Activity
none needed
none needed
none needed
Inspect
Inspect
none needed
none needed
none needed
114 letter 6/15/85
NOV 7/05/85
In Compliance
Lead
Agency
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
WV
(continued)
54
-------
Table B-2
(Continued)
AIR PROGRAM COMPLIANCE
STATUS
BY REGULATED POLLUTANT
Name /Location
of Facility
Kinkaid Enterprises
- Nitro
Mason & Dixon
- Halbaus
S. Charleston Sewage
Treatment
- S. Charleston
Union Carbide
. - Institute
Union Carbide
- S. Charleston
Union Carbide
- Tech Center
Compliance Status
by Pollutant
TP
c
c
b
I C
I C
I C
SO?
b
b
b
I C
I C
I C
r voc
c
c
b
a
a
a
Projected
Compliance
Status
Inspect
Inspect
Inspect
none needed
none needed
none needed
Lead
Agency
WV
WV
WV .
WV
WV
WV
DEFINITIONS
1C — In compliance with applicable Federal and State Regulations for the pollutant
specified.
IV — In violation with applicable Federal and State Regulations for the pollutant
specified.
a — Sources may be subject to regulations governing VOC emissions from petroleum
refineries bulk gasoline terminals or stored petroleum liquids.
b — Discussions with the State indicate sources do not have any processes in
operation which are subject to Federally approved regulations. Status of
these facilities would therefore be judged as in compliance.
c — Discussions with the State indicate sources do not have any processes which
would emit particulate (TSP) or sulfur (S02> pollutants. Based purely on
facility name it is possible, sources may be subject to regulations
governing VOC emission from gasoline bulk storage tanks. Information
contained in available files, however, is not sufficient to make a
determination.
55
-------
APPENDIX C - AMBIENT WATER MONITORING
-------
Table B-3
RCRA Compliance Status
Name/Location
Inspection Date
Compliance
Status*
Compliance
Activities
Lead
Agency
1) duPont
Belle, WVA
WVD005012851
2) GST, Inc.
Nitro, WVA
WVD030143960
3) Fike Chemicals
Nitro, WVA
WVD047989207
4) FMC
South Charleston, WVA
WVD005005079
5) FMC
Nitro, WVA
WVD005005087
6) Monsanto
Nitro, WVA
WVD039990965
7) Union Carbide
Agricultural Products
Institute, WVA
WVD005005509
8) Union Carbide
(Plant 514)
S. Charleston, WVA
WVD005005483
9) Union Carbide (PTO)
Institute, WVA
WVD000739722
10) Union Carbide (Holz)
S. Charleston, WVA
WVD980554885
11) Union Carbide (Tech Ctr)
S. Charleston, WVA
WVD060682291
In Compli ance
Out of Compliance
Out of Compliance
Out of Compliance
In Compliance
In Compliance
(as of 3/10/86)
In Compliance
(as of 3/10/86)
Out of Compliance
Not reported
Out of Compliance
Not reported
In Compliance
Out of Compliance
Inspected 7/25/85
Inspected 12/12/85
Enforcement Pending
Inspected 1/7/86
2/6/86
Enforcement Pending
Inspected 2/27-28/86
Enforcement Pending
(Administrative Order
for late notification
2/12/86)
Inspected 3/15/85
Inspected 9/25/85
Inspected 2/4/86
9/19/85
Inspected 2/4/86
9/25/85
Enforcement Pending
Inspected 9/12/85
DNR
EPA/DNR
EPA
EPA
DNR
DNR
DNR
DNR
DNR
EPA/DNR
DNR
rNote: Compliance Status is current and does not reflect situations where a facility
may have been out of compliance and then returned. For those facilities out of
compliance, DNR and EPA are monitoring the situations to determine if appropriate
enforcement measures should be taken.
56
-------
Table B-4
FIFRA Compliance Status
Name/Address
of Facility
1) Albaris Labs, Inc.
'
2) duPont
Belle, WVA
3) Fike Chemicals
Nitro, WVA
4) FMC
S. Charleston, WVA
5) Kincaid Enterprises
Nitro, WVA
6) Monsanto
Nitro, WVA
7) Union Carbide
Institute, WVA
8) Union Carbide
S. Charleston, WVA
9) WV Dept. of Agriculture
Charleston, WVA
10) PB & S Chemicals
St. Albans, WVA
11) Southern Labs
Charleston, WV
Compliance Status*
In Compliance
In Compliance
In Compliance
In Compliance
In Compliance
In Compliance
In Compliance
In Compliance
In Compliance
In Compliance
In Compliance
Compliance
Activities
Inspection to be
conducted in next
6 months
Inspected 8/84
Inspected 6/84
Inspected 10/84
Inspected 10/84
Inspected 10/84
Inspection to be
conducted in next
6 months
Inspection to be
conducted in next
6 months
Inspection to be
conducted in next
6 months
Inspected 10/84
Inspected 3/85
Lead
Agency
WVDOA
WVDOA
WVDOA
WVDOA
WVDOA
WVDOA
WVDOA
WVDOA
WVDOA
WVDOA
WVDOA
57
-------
Ambient Water Monitoring :
Methods
The part of the Kanawha selected for study includes the industrial
complex extending from Eleanor, WV to the head of navigation at Alloy,
WV (river mile 31 to 90; the confluence of the Kanawha and Ohio Rivers
is river mile 0). The same section of the river was considered by the
NEIC Report. This section of the river receives discharges from chemical,
trucking, primary metals, and municipal facilities, and is believed to
be significantly impacted by numerous landfills. A list was compiled
of toxic pollutants potentially present in toxic concentrations in
ambient water, using information in EPA (1984 and 1981), Dalton et al.
(1983), and SCS Engineers (1979). In order to restrict the size of
the study, but keep a high probability of identifying toxic problems,
analyses of water quality data were restricted to the pollutants on
this list.
Information in EPA's STORET national water quality database was
used to obtain locations of stations on the Kanawha, and means and
sample sizes for parametric data taken at those stations. STORET was
also accessed for comparable information on two other water bodies
with high concentrations of chemical and primary metals dischargers:
Buffalo Bayou (Houston, TX) and the Delaware River (south of
Philadelphia, PA).
Other data from the Kanawha were obtained from the West Virginia
Department of Natural Resources (DNR) and the Army Corps of Engineers
(COE), Huntington WV District and the Wheeling Office of EPA Region
III. These data included macroinvertebrate and fish abundance, particle
sizes of dredged material, pollutant concentrations in elutriate from
dredged material, toxicity of elutriate, effluent, and ambient water
samples, and concentrations of pollutants in fish tissue.
STORET was again accessed for all available parametric data from
Kanawha River stations for potentially significant toxic pollutants.
Data were analyzed using SAS (Statistical Analysis System, SAS Institute,
Gary, NC) by the following process: (1) Descriptive statistics for
each parameter were obtained. (2) Each chemical parameter was tested
for significant correlations with the independent variables flow,
month, river mile, temperature, and year. (3) Where significant
correlations were observed, analyses of variance were used to test for
significant differences among means. (4) Trends were plotted where
data were sufficient. (5) Chemical data were compared with current
EPA water quality criteria (EPA, 1980) for protection of aquatic life
and for an incremental lifetime cancer risk of 10"^ for drinking
water and fish consumption.
58
-------
Results
1. Biomonitoring. Analyses of macroinvertebrate and fish data
from the Kanawha (Tables C-l and C-2) were mostly inconclusive. The
only significant trend observed was a decline in the number of fish
species sampled at river mile 83 between 1975 and 1984 (r=-0.72, p=0.04),
although this appears to have resulted from an abnormal sample. No
other significant trends in abundance of fish or macroinvertebrates
were found, and the upstream and downstream stations were not
significantly different (p>0.05, ANOVA).
A recent study (COE, in preparation) suggests that macroinvertebrate
population diversity, number of taxa, and community diversity decline
downstream of the industrial area. This study, although still in
draft form, contains more complete macroinvertebrate data than those
in Table C-l. This suggests that point source discharges to the Kanawha
significantly degrade the raacroinvertebrate community.
2. Sediments. Particle size of dredged sediments in the Kanawha
(Table C-3) was very large, with a median sieve size of > 0.25 inches
at 4 of 6 stations. Concentrations of toxic pollutants in sediment
elutriate (Table C-4) were mostly similar to concentrations in ambient
water (Table C-8, discussed later), although zinc and cyanide were
somewhat more concentrated in elutriate. No measurements were available
of organic compounds in sediment elutriates.
3. Aquatic toxicity. Elutriates from four sediment samples (Table
C-5) were not toxic to fathead minnows (Pimephales promelas). Toxicity
to larval midges (Tanytarsus dissimilis) was greatest at river miles
47 and 57; toxicity to water fleas (Daphnia magna) was greatest at
river mile 47. Ambient water in most- of the 50-mile industrial section
of the Kanawha appears to be free of chronic toxicity, but significant
effects to water fleas (Ceriodaphnia sp.) and fathead minnows (Table
C-6) were observed between river miles 47 and 61. Toxicity of discharges
to the Kanawha (indicated by low LCSOs in Table C-7) was greatest
between river miles 44 and 52.
4. Ambient water data. Descriptive statistics for parametric
data from STORET are in Table C-8. Results of correlation analyses
of inorganics, fish tissue, and organics are in Tables C-9, 10, and
11, respectively. Significant correlations with flow, month, year,
and river mile were further subjected to testing by ANOVA (Table
C-12), and well-supported trends in the data were plotted. Hardness
varied inversely with in flow (Figure C-l), a predictable effect of
dilution at high flows. The only toxic pollutants which varied
significantly with flow were zinc (Figure C-2) and phenol (Figure
C-3). Correlation analysis using month and concentrations of toxic
pollutants was used to search for seasonal events. Only phenol varied
seasonally (Figure C-4), with higher concentrations from July to December.
59
-------
Most of the organic compounds (except phenolic compounds) were
monitored only at.St. Albans, WV, so correlations between river mile
and concentrations of organics could not be calculated. Concentrations
of two metals, lead and selenium, changed significantly with river
mile. Lead decreased with travel downstream (Figure C-6). Selenium
concentrations increased sharply between river miles 46 and 32 (Figure
C-7).
Concentrations of many toxic pollutants changed significantly
with year. Among inorganics, arsenic, cadmium, copper, cyanide, lead,
silver, and zinc all declined significantly between 1970 and 1984
(Figures C-8 to 14). The organic pollutants phenolic compounds,
chloroform, carbon tetrachloride, and trichloroethene have also
declined significantly (Figures C-15 to 18) since monitoring began in
the late 1970s. Two pollutants in fish tissue showed significant
trends: chromium decreased since 1978 (Figure C-19) and copper increased
(Figure C-20). Additional data (Table C-12a), which were not analyzed
statistically, suggest that contamination of fish tissue by priority
pollutants increases with travel downstream.
5. Effectiveness of monitoring. A comparison (Table C-13) of
ambient water monitoring in the Kanawha River, the Delaware River, and
Buffalo Bayou (the Houston Ship Channel) shows that approximately the
same number of stations were sampled in each area during the last two
years. The Kanawha is second in-number-of water parameters analyzed
per station, but first in number of fish tissue parameters analyzed
per station. Total analyses per station, a measure of sampling frequency
combined with parameter coverage, is far greater in the Kanawha than
in the other areas.
6. Comparison of ambient data with criteria. Concentrations
of five toxic pollutants (silver, cadmium, copper, cyanide, and zinc)
have exceeded EPA water quality criteria designed to prevent acute
toxicity to aquatic life (EPA, 1980) since 1970 (Table C-14). Frequency
of criteria exceedances has decreased for all since 1980. Of these,
silver was most frequently above criteria levels.* Concentrations of
four carcinogens (chloroform, carbon tetrachloride, dichloroethene,
and arsenic) sometimes exceeded water quality criteria associated with
an incremental lifetime cancer risk of 10~5 (EPA, 1980)(Table C-15).
7. Other potential threats to water quality. A list of toxic
pollutants potentially present in the Kanawha (Table C-16) was compared
with actual parameter monitoring coverage. Of the 46 toxic pollutants
on the list, 27 are routinely monitored. Also monitored are numerous
parameters not on the list (and not addressed by this study), which
may nevertheless be present in toxic amounts.
*Note that these conclusions are based on criteria published in 1980.
However, EPA revised its aquatic life protection criteria for several
inorganic pollutants after this analysis was completed (50 Fed. Reg.
30784, July 29, 1985). Therefore, this analysis will be revised in
the near future.
60
-------
References
Dalton, Dalton, Newport (consultants). 1983. Detailed water
quality analysis for the organic chemicals and plastics
industry on the Kanawha River. U. S. EPA Monitoring and
Data Support Division, Washington, DC. 228 pp.
SCS Engineers. 1979. Section 12, Charleston, West Virginia
Dilution Study, pp. 10-1 - 10-72, In Water quality
analyses; ten area-specific dilution studies. SCS Engi-
neers, Reston, VA.
U.S. Army COE. In preparation. Kanawha River navigation
Study, Winfield Lock Replacement. Appendix D, Vol.
2, Environmental System Studies. U.S. Army Corps of
Engineers, Huntington, WV District.
U.S. EPA 1984. Overview of environmental pollution in the Kanawha
Valley. U.S. EPA Office of Enforcement and Compliance Moni-
toring, National Enforcement Investigations Center, Denver,
CO. 163 pp.
U.S. EPA 1981. Summary of priority pollutant data collected between
October 1977 and September 1980 by the Surveillance and
Analysis Division, U.S. EPA, Region III. Draft. 16pp.
U.S. EPA. 1980. Water quality criteria documents; availability.
Federal Register 45(231): 79318-79379.
61
-------
Table 1. Kanawha River, West Virginia. Macroinvertebrates captured with
artificial substrate samplers and identified to genus. Data provided cour-
tesy of Dr. Eli McCoy, West Virginia Department of Natural Resources.
.Station River
Mile
London Locks 83
Winfield Lock 31
Year
1975
1976
1977
1979
1980
1981
1982
1983
1975
1976
1977
1979
1980
1981
1982
n
1
3
2
2
3
3
3
3
2
3
2
2
3
3
2
Mean
individuals/
sample
75
26
71
9
23
129
37
106
28
94
157
32
31
108
100
Mean
taxa/
sample
9
8
12
5
13
20
9
19
10
9
13
6
6
15
14
Table 2. Kanawha Riverj West Virginia. Fish captured in navigation locks.
Data provided courtesy of Dr. Eli McCoy, West Virginia Department of Natural
Resources.
Station
River
Mile
Year
Individuals
sampled
Species
sampled
London Lock
83
1976
1977
1978
1979
1980
1982
1983
1984
833
238
2615
201
643
203
1060
116
27
25
26
18
19
17
24
13
Winfield Lock
31
1979
1980
1981
1982
1983
253
424
2532
3708
1043
13
16
21
17
17
62
-------
Table 3. Kanawha River; West Virginia. Particle sizes of.dredged material,
1981. Data courtesy of Col. Robert B. Wilson, U. S. Army Corps of Engi-
neers, Huntington, WV District.
Station
Name
Eleanor
Winfield Lock
DuPont City
Marine t
London
London Lock
River
Mile
30
31
67
68
82
83
50th percentile
sieve size (inches)
0.014 - 0
1.0 - 1
1.5 -
0.020 -
1.5
0.25 -
.020
.5
2.0
0.025
2.0
0.38
Table 4. Kanawha River, West Virginia. Analyses (in ug/1) of elutriate of
material dredged at the confluence of the Kanawha and Ohio Rivers, April
1981. Data courtesy of Col. Robert B. Wilson, U. S: Army Corps of Engineers,
Huntington, WV District.
Parameter Receiving water Elutriate
concentration concentration
Arsenic
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Phenols
Selenium
Silver
Zinc
< 1
2.0
< 1
< 5
< 50
< 2
< 1
< 5
< 2
2
< 0.1
57
< 1
< 1
< 1
< 5
< 50
< 2
< 1
6
< 2
2
< 0.1
75
Table 5. Kanawha River, West Virginia. Mortality (in %) in undiluted elu-
triate from dredged sediments, April 1981. Data courtesy of Col. Robert B.
Wilson, U. S. Army Corps of Engineers, Huntington, WV District.
River
Mile
88
57
47
31
fathead minnows
Pimephales
promelas
0
0
0
0
larval midges
Tanytarsus
dissimilis
25
45
45
30
water fleas
Daphnia
magna
20
0
95
5
63
-------
Table 6. Kanawha River, West Virginia. Toxicity of ambient water, August,
1984. Column 1 = Ceriodaphnia mean number of young per female, 2 = Cerio-
daphnia mean survival, 3 = Pimephales larval weights, 4 = Pimephales larval
mean survival. *** = significantly lower than other stations, p<.05, modified
Tukey's HSD procedure; - = no significant effect. Preliminary data, courtesy
of Dr. Donald Mount, EPA Duluth Environmental Research Laboratory.
River Mile 1
90.1 ***
88.7
86. 4R
86. 4L
82.8
78.0
73.6
71.0
69.6
67.7
65.4
63.2
61.0
58.5
57. 5R ***
56.2
54. 7R
54. 7L ***
54. 3R
54. 3L
53.5
53.3 (Davis Ck.) ***
52.5
50.0
47.3
44.2 . -
42.5
41. OR
41. OL
38.1 ***
32.2
2 3-4
_ ^ -.
_
_
_
_
_
_
_ _ _
-
_
_
- ***
_
-
'_ _
_
_ _ _
_ *** -
- *** - •
_
- ***
_
_
_ *** -
_
_
_
_
_
_
64
-------
Table 7a. Kanawha River, West Virginia. LCSOs of industrial discharges in
% effluent (NT = no toxicity). Tests are 24-hr static tests with fathead
minnows unless otherwise noted. Data provided courtesy of Dr. Eli McCoy,
West Virginia Department of Natural Resources.
Facility, Location,
River Mile
Allied Chemical, Nitro, 44
Chemical Leaman, Institute, 49
Coastal Tank Lines, Nitro, 44
Diamond Shamrock, Belle, 69
DuPont, Belle, 69
Elkem Metals, Alloy, 90
Fike Chemical, Nitro, 44
FMC, Nitro, 44
FMC, S. Charleston, 52
Kincaid Enterprises, Nitro, 44
Markay Chemicals, Amandaville,
Mason-^Dixon Truck, St Albans,
Monsanto, Nitro, 44
South Charleston STP, 52
Union Carbide, Charleston, 57
Union Carbide, Institute, 49
Union Carbide, S. Charleston,
Monsanto Polymer, Nitro, 44
Outfall
002
003
001
001
001
062
017
046
003
001
001
018
022
029
025
023
001
45 001
47 001
001
001
003
009
008
002
003
005
52 023
025
032
035
074
001
Year:
1981 1982
19. 71*2 5.2
35. 51 42
32. 01
5.61 77.8
47.6
57. 01
NT1
NT1
12. 31
NT1
<5.6!
80.01,2 NTl
56.0
; NT
NT 3
.NT3
NT3
NT
NT
NT
NT
NT
1983
NT
83
64.7
NT
27.0
12. 23
NT3
38. 43
30. 03
14.0
75. 03
1984
47.0
23.5
60. 83
NT3
NT3
21.8
59.0
17.53
54.93
7.03
NT3
NT3
42.02
44.0
NT 2
33. 63
1 test with Daphnia pulex.
2 48-hr static test.
3 96-hr static test.
65
-------
Table 7b. Kanawha River, West Virginia. LCSOs of industrial and municipal
discharges in % effluent (NT = No Toxicity). Tests are 48-hr static test
(D = Daphnia, F = fathead minnow). Data courtesy of H. Ronald Preston,
Wheeling Office, EPA Region III.
Year:
Facility, Location
River Mile Outfall 1981 1982 1983 1984 1985
Charleston STP, 55
Chemical Leaman, Institute, 44
Coastal Tank Lines, Nitro, 44
DuPoint, Belle, 69
Fike Chemical, Nitro, 44
FMC
Hatfield Henson
Kincaid Enterprises, Nitro, 44
Mason Dixon Truck, St. Albans, 47
001
001
001
062
001
001
001
001
001
001
001
001
D-NT
F-NT
D-35 D-7
F-50 F-9
D-4
F-32.5
D-851
F-351
D-901
F-351
D-NT1
F-NT1
D-NT1
F-NT1
D-<25
F-29
D-25 D-19.1
F-50 F-20.0
D-<25 D-17.3 D-11.1
F-35 F-10.0 F-2.6
D-46.2
F-19.2
D-12.3 D-<3
F-27 F-10.4
F<6.25
D-0.52 D-3.9
F-<0.25 F-10.7
D-35. 4
F-10.7
T24 Hr. Static
66
-------
Table 8. Kanawha River, West Virginia. Descriptive statistics for selected
toxic pollutants and other parameters measured from 1970 to 1984. Data were
obtained from STORE!.
Variable
Independent variables
Flow (cfs)
Month
River mile
Temp (F)
Year
N
:
560
782
782
483
782
Inorganics : (water analyses
Ag
Tissue Ag
As
Cd
Tissue Cd
CN (mg/1)
Tissue Cr
Cu
Tissue Cu
Hardness
Tissue Hg
Ni
Tissue Ni
Pb
Tissue Pb
Se
Zn
Tissue Zn
191
20
232
445
24
298
24
303
25
546
25
174
16
458
24
182
315
17
Mean
16967.14
6.41
43.57
14.92
1978.13
in ug/1;
1.96
0.31
3.46
2.97
0.17
0.02
0.80
18.72
0.83
63.42
0.12
18.40
0.72
29.00
2.63
1.95
38.71
18.92
Std Dev Minimum Maximum
19852.86
3.42
18.18
9.37
3.48
21
1.0
31.0
0
1970.0
1999.5
12.0
83.0
81.5
1984.0
tissue analyses in mg/kg)
1.61
0.10
3.56
6.06
0.10
0.11
0.65
46.59
0.36
23.86
0.08
53.43
0.48
37.36
0.97
1.87
60.58
2.95
Organics: (water analyses in ug/1; tissue analyses
Bromoform
Bis (2-ethylhexyl)
phthlate
Chloroform
Carbon tetrachloride
Tissue DDE
1 , 2-dichlorobenzene
1 , 3-dichlorobenzene
1 , 4-dichlorobenzene
1 , 1-dichloroethylene
Isophorone
Methylene chloride
Naphthalene
Tetrachloroethylene
Trichloroethylene
692
18
692
692
19
18
18
696
692
18
692
20
692
692
0.137
5.000
1.871
0.945
0.03
5.000
11.222
0.136
0.374
<5.000
0.427
4.600
0.256
0.257
0.199177
0
8.633832
1.394837
0.11
0
2.263666
0.414207
1.278239
0
2.934615
1.231174
0.538379
0.520622
0
0.1
0
0
0.0
0.0
0.0
0
0.0
6.2
0.0
0
0.4
3.0
1.3
0
2.2
13.0
in mg/kg)
0.100
5.000
0.100
0.100
0
5.000
5.000
0.100
0.100
<5.000
0.100
1.000
0.100
0.100
18.0
0.5
32.0
90.0
0.4
1.0
2.6
500.0
1.6
441.0
0.4
510.0
1.9
380.0
5.4
10.0
720.0
25.0
2.700
5.000
218.800
14.700
0.5
5.000
12.000
5.000
23.200
<5.000
73.500
5.000
6.500
5.300
67 =
-------
Table 9. Kanawha River, West Virginia. Results of correlation analyses for
selected inorganic ambient water quality data taken between 1970 and 1984.
Correlation coefficients, probability of type I error, number of samples
(lines 1-3, respectively). * = p<0.05. Data were obtained-from STORET.
Silver
Aresnic
Cadmium
Cyanide
Copper
Hardness
Lead
Nickel
Selenium
Zn
Flow
-0.10493
0.1924
156
-0.02843
0.6894
200
0.00314
0.9533
350
0.02357.
0.7482
188
0.02615
0.6926
231
-0.18778
0.0001*
427
0.00188
0.9717
358
0.12443
0.1536
133
0.05963
0.4582
157
0.13384
0.0363*
245
Month
-0.05575
0.4437
191
-0.06602
0.3167
232
0.00352
0.9409
445
0.19566
0.0007
298
0.04300
0.4559
303
0.06628
0.1219
546
0.03717
0.4274
458
-0.08338
0.2740
174
-0.05852
0.4326
182
0.02265
0.6888
315
River
Mile
0.31907
0.0001*
191
0.01672
0.8000
232
0.05558
0.2420
445
0.07899
0.1739
298
-0.01674
0.7717
303
-0.11761
0.0059*
546
0.13401
0.0041*
458
-0.02660
0.7275
174
-0.19646
0.0079*
182
-0.05641
0.3183
315
Temp
-0.03489 -0
0.7064
119
0.06115 -0
0.4381
163
0.03991 -0
0.4754
322
-0.00817 -0
0.9011
234
0.02378 -0
0.7175
234
0.20347 -0
0.0001*
405
-0.00010 -0
0.9985
326
-0.09647 0
0.2925
121
-0.06054 -0
0.5131
119
Year
.26980
0.0002*
191
.18381
0.0050*
232
.14077
0.0029*
445
.25880
0.0001*
298
.24487
0.0001*
303
.03615
0.3992
546
.34351
0.0001*
458
.09406
0.2170
174
.01790
0.8104
182
0.01277 -0.28339
0.8558 0.0001*
205 315
68
-------
Table 10. Kanawha River, West Virginia. Results of correlation analyses for
selected fish tissue data taken between 1970 and 1984. Correlation coeffi-
cients, probability of type I error, number of samples (lines 1-3, respectively),
* = p<0.05. Data were obtained from STORE!.
Month
Year
Tissue Ag
Tissue Cd
Tissue Cr
Tissue Cu
Tissue DDE
Tissue Hg
Tissue Ni
Tissue Pb
Tissue Zn
-0.48389
0.0306*
20
-0.36502
0.0795
24
-0.32547
0.1207
24
-0.16760
0.4233
25
-0.41770
0.0752
19
-0.01505
0.9431
25
-0.81142
0.0001*
16
-0.20593
0.3344
24
0.46756 '
0.0584
17
0.26993
0.2498
20
0.03910
0.8561
24
-0.86761
0.0001*
24
0.44563
0.0256*
25
-0.04398
0.8581
19
-0.13603
0.5168
25
-0.40475
0.1199
16
0.33722
0.1071
24
-0.19680
0.4490
17
69
-------
Table 11. Kanawha River, West Virginia. Results of correlation analyses for
selected organic ambient water quality data taken between 1970 and 1984.
Correlation coefficients, probability of type I error, number of samples
(lines 1-3, respectively). * = p<0.05. Data were obtained from STORET.
Pollutant
Month
Year
Broraoform
Bis (2-ethylhexyl)
phthalate
Chloroform
Carbon tetrachloride
1,2-dichlorobenzene
1,3-dichlorobenzene
1,4-dichlorobenzene
1,1-dichloroethylene
Isophorone
Methylene chloride
Naphthalene
0.05455
0.1517
692
0.00000
1.0000
18
0.05935
0.1188
692
0.06624
0.0816
692
0.00000
1.0000
18
0.41905
0.0835
18
-0.05485
0.1483
696
0.00037
0.9922
692
0.00000
1.0000
18
-0.03619
0.3418
692
0.03407
0.8866
20
0.03910
0.3044
692
0.00000
1.0000
18
-0.07477
0.0493*
692
-0.35924
0.0001*
692
0.00000
1.0000
18
-0.72411
0.0007*
18
0.10086
0.0077*
696
0.05127
0.1779
.692
0.00000
1.0000
18
-0.03433
0.3672
692
-0.37341
0.1049
20
71
-------
Table 11 continued. Kanawha River, West Virginia. Results of correlation
analyses for selected organic ambient water quality data taken between 1970
and 1984. Correlation coefficients, probability of type I error, number of
samples (lines 1-3, respectively). Data were obtained from STORET.
Pollutant Month Year
Tetrachloroethylene
Trichloroethylene
0.00816
0.8303
692
0.05687
0.1350
692
0.03133
0.4106
692
-0.10450
0.0059
692
Table 12. Kanawha River, West Virginia. Results of single classification
analyses of variance, p = probability of type I error. * = p<0.05, ** =
p<0.01, *** = p<0.001, ns = no significant differences. Blanks were not
tested. 'Data were obtained from STORET.
Independent Variables:
Dependent Month Year River Mile Ln Flow
Variables:
inorganics
arsenic ***
cadmium **
copper ***
tissue Cr ***
tissue Cu **
cyanide *** ***
hardness * ***
lead *** *
silver ** ***
selenium *
zinc *** ns
organics
carbon tetrachloride ***
chloroform *
1,3 dichlorobenzene ns ns
tissue 0,P' ODD ns
tissue P,P' DDT * ns
tissue P,P' DDE ns
tissue PCB 1254 ns
phenols ns *** ns
trichloroethylene ***
72
-------
Table 12a. Kanawha River, West Virginia. Concentration of some priority
pollutants in fish tissue at 3 locations. I = London Lock, river mile 83,
1980; II = downstream of St. Albans STP, river mile 45, 1980; III = Winfield
Lock, river mile 31, 1979. Analyses performed in EPA, Region III by Toxicant
Analysis Center Bay St. Louis, MI.
PRIORITY POLLUTANT I II III
PCB-1254 210 5140 3350
bis(2-ethylhexyl)phthalate ND 25 ND
di-n-butyl phthalate ND 35 ND
diethyl phthalate ND 70 ND
chlordane 60 1230 1430
trichlorofluoroethane 10 18 393
1,4-dichlorobenzene ND 100 ND
butyl benzyl phthalate ND 240 ND
1,1,2,2-tetrachloroethane ND 130 ND
dieldrin ND 130 ND
naphthalene ND ND 280
carbon tetrachloride ND 14 ND
chloroform ND 9 ND
toluene 20 19 ND
4,4'-DDT ND 40 ND
4,4'-DDE ND 80 ND
4.4'-ODD ND 80 ND
heptachlor epoxide ' ND 20 30
73
-------
Table 13. STORET records of analyses for toxic pollutants in ambient water
and fish tissue since January 1, 1982 in the Kanawha River, Delaware River,
and Buffalo Bayou (Houston Ship Channel).
Area
Water Tissue Total Analyses
parameters parameters analyses performed
Stations per station per station performed per station
Kanawha
Delaware
Houston Ship
9
9
7
22
9
30
22
0
3
7916
743
711
880
83
102
Channel
Table 14. Kanawha River, West Virginia. Analyses exceeding 1980 EPA
water quality criteria for protection of freshwater aquatic life since 1970.
Expressed as number of analyses and percent of total analyses.
Pollutant
1970-present
No. %
1980-present
No. %
Silver
Cadmium
Copper
Cyanide
Zinc
116
179
76
6
6
60.7
40.2
25.1
2.0
1.9
32
32
14
2
0
45.0
15.5
9.9
2;i
0
Table 15. Kanawha River, West Virginia. Analyses exceeding 10-5 incremental
cancer risk over the lifetime for water and fish consumption, and for fish
consumption only since 1979. Expressed as numbers of analyses and percent of
total analyses.
Pollutant
Chloroform
Carbon tetrachloride
1, 1-dichloroethylene
Arsenic *
Fish and water
No. %
145 20.9
25 3.6
121 17.5
230 99.1
Fish
No
1
0
1
230
only
%
0.001
0
0.001
99.1
1 Exceedances since 1970.
74
-------
Table 16. Kanawha River, West Virginia. Toxic pollutants potentially
present in toxic concentrations. List compiled from EPA (1984) and SCS
Engineers (1981). W, T = water, tissue; * = routinely monitored.
W T
W T
Cyanides
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
1,1-dichloroethene
2-methyl-2-pentenol
4-methyl-2-pentanone
PCB-1016
PCB-1221
PCB-1232
PCB-1242
FCB-1248
PCB-1254
PCB-1260
Acrylonitrile
Benzene
Bis (2-ethylhexyl) phthalate
Bromoform
Carbaryl
Carbon tetrachloride
Chloroform
ODD
DDE
DDT
Dichlorobenzene
Dimethyl butyl ether
Ethylbenzene
Isophorone
Methacrylate
Methanol
Methylene chloride
Naphthalene
Phenolics
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
75
-------
tr
o
w
tr
a
n
n
Q)
a
•d
fc
cd
Kanawha River, WV
1070-1084
Ln Flow (cfs)
-------
0)
£
*J
f.
4J
c
o
•rl
c
0)
u
c
o
u
u
c
•H
N
C
10
01
E
C
•H
01
01
tP
C
<0
£
U
/•N
lH
(0
C IM
-------
01
4J
o
c
01
o
o
(J
o
0)
Q4
10
0)
E
c
m
u
01
>
•H
o: .
2
n) O
10
C •«
|Q O
*
IP
O
0) <0
k-4 M
3 O
D> *J
•H (0
(u C
01
0)
A
ft*
4'.*5 -
4 -
3.5 -
2.5 H
2 -
1.5 H
Kanawha River, WV
1970-1984
00
Ln Flow (cfs)
-------
o
•H
•P
(0
c
01
o
o
o
o
c
01
"ft
c
10
01
E
V)
0»
<0
o
u
10
4)
(A
Kanawha River, WV
1970-1984
0)
•H
a.
(0
<0
c
<0
«T
01
3
o
d
o>
A
Month
-------
o
c
(0
c
•H
w
0)
u
<0
c
o
U)
id
0)
00
0)
•rt
a
n>
<0
c
(0
in
0>
a
o>
Kanawha River, WV
1970-1984
o
oo
Month
-------
01
c
o
c
01
o
o
u
0) _l
c
•H
M
0)
o>
c
AS
o
01
>
•H
10
3
<0
c
-------
M
01
•H
O
c
01
u
c
O
u
C
01
01
10
10
0)
tP
C
(0
u
0)
10
.c
10
c
t^
0)
D> '
Kanawha River, WV
1970-1984
I . 1
Q)
•^
0)
CN
00
I
60
70
River mile
-------
Kanawha River, WV
0)
.c
c
o
c
at
u
g
u
c
HI
(0
c
•H
U)
0)
O>
C
-------
Kanawha River, WV
c
o
•P
10
c
01
u
c
o
u
e
a
•H
E
•o
c
•at
4)
•H
(0
c
ID
X
O\
-------
ID
01
o
c
01
u
§
u
n
&
o<
o
u
u>
0)
D»
-l
•H
u,
Kanawha River, WV
0)
A
A
0
J. I..'
00
Year
-------
Kanawha River, WV
0*
o
io
)H
*J
c
01
u
O
u
01
•o
•H
c
(0
c
•H
Ul
0>
01
c
R)
£
U
0)
•a
03
SI
•H
<0
c
<0
. OO
Year
-------
Kanawha River, WV
4-1
•H
3
O
4-1
0)
O
O
u
•a
U)
a*
c
10
•0
cd
a>
•H
a
10
f.
2
10
c
10
0)
^
a
oo
Year
-------
Kanawha River, WV
(0
01
c
o
-H
4-1
ID
C
01
U
O
U
01
t-4
•H
10
(fl
01
O>
10
U
01
10
JC
2
-------
Kanawha River, WV
o
c
01
u
o
u
u
c
•rt
N
(0
01
o>
c
10
o
Q)
>
•H
10
x:
s
10
c
<0
01
k-l
3
D»
•H
(L.
\
0
i .
CTi
00
Year
-------
<0
at
4J
•H
c
o
c
01
u
o
u
o
01
Q.
C
CO
0)
o>
c
a
£
U
01
10
x:
-------
Kanawha River, WV
c
o
u
c
o
u
e
o
o
o
o
c
01
en
c
m
x:
u
01
•H
«
10
(0
c
V0
01
M .
5. Si
•H (U
S
U
0
-------
o
Kanawha River, WV
C
0)
o
o
o
0)
•a
U
a
o
XI
u
a
U
in
ID
o>
c
a
o
01
•rl
K
10
10
C
•0
Q>
•O
•H
h
0
F^
£
O
4)
O
CTv
Year
-------
o
•H
*J
c
0)
u
o
u
Kanawha River, WV
0.4 -r
i
0.38 -
01
c
0)
1* 2
g\
\
M k|
o U"
o ^^
•H
c rt
0)
U) lH
,
n c
I.I,. .
0.36 -
^-
0.34 H
0.32 -
0.3 -j.
or
0.28 -1
0.26 -
0.24 -
0.22 -
0.2 -
0.18 -
0.16 -
0.14 H
0.12 -|-
79
•H -H
Year
-------
Kanawha River, WV
O
c
01
O
O
u
3
•H
6
O
0)
D
U
(0
C
•H
Ul
01
&
10
•H 01
(n >,
ei
fi
U
o
3
n
n
1978
1981
1982
1983
Year
-------
Kanawha River, WV
o
4-1
c
01
o
o
o
I
Q,
o
u
0>
in
in
c
•ri
in
01
o<
c
id
U
0)
>
•H
PC
10
c
2
A)
C
fl
o
.
1981
Year
1982
1983
-------
APPENDIX D - CERCLA
-------
STRATEGY FOR IMPLEMENTATION
KANAWHA VALLEY SPECIAL REPORT RECOMMENDATIONS
ERRIS SITES
S.D.
KA
*1W*
,*••
f*2l
DNR
EPA
DNR
EPA
DNR
EPA
GROUP A
TO BE COMPLETED
6 MONTHS
0
0
5
0
1
3
0.
5
4
GROUP B
TO BE COMPLETED
1 YEAR
0
0
5
6
2
4
D
10
»
6
GROUP 4
TO BE COMPLI
2 YEARS
0
0
0
0
2
0
c
ETED
0
0
2
0
15
12
(+1)- ALL P.A. AND S.I. NUMBERS ARE ESTIMATES.
<*2)- EPA WILL CONDUCT P.A.. AND *.!.• TO REACH THE PLANNED GOALS.
August 1985
96
-------
STRATEGY FOR IMPLEMENTATION
KANAWHA VALLEY SPECIAL REPORT RECOMMENDATIONS
NON-ERRIS SITES
S.D.
PA
*M*2]
S.I.
^'Ull
DNR
EPA
DNR
EPA
DNR
EPA
GROUP A
TO BE COMPLETED
0 MONTHS
0
84
15
0
2
. 2
84
O*r
15
4
GROUP B
TO BE COMPLETED
1 YEAR
0
0
25
0
• 2
4
0
25
6
GROUP C
TO BE COMPLETED
2 YEARS
0
0
6
0
2
3
0
5
5
84
45
5
(+1)- ALL P.A. AND 8.1. NUMBERS ARE ESTIMATES.
( + 2)- EPA WILL CONDUCT P.A.» AND S.l.a TO REACN TNE PLANNED GOAL.
August 1985
97
-------
APPENDIX E
ENVIRONMENTAL ISSUES
-------
Environmental Issues
The report by the National Enforcement Investigation Center
(August 1984) identifies a number of areas in the various EPA programs
where additional investigations, permit actions, program reviews, or
enforcement actions are needed in the Kanawha Valley. Additional
issues have also been identified by EPA Region III as a result of the
preparation of the overview in Chapter 4. Past, current, and future
responses by regulatory agencies to these issues and needed actions
are discussed briefly below.
Water
The NEIC report indicates that the State's policy is to wait for
guideline promulgation prior to reissuing best available technology
permits to several organic chemical plants. NEIC urges that compre-
hensive permits be reissued to Monsanto, both FMC plants, and Union
Carbide at S. Charleston. West Virginia has reissued the Union Carbide
and Monsanto permits based on best professional judgment (BPJ). The
FMC permits will be issued in 1986. See Section 4.1 for details of
NPDES permit reissuance.
The report observes that Chemical Leaman, Coastal Tank Lines,
and Mason & Dixon Tank Lines have high potentials for toxic discharges
but no toxicant permit limits and urges modification of the permit to
include such limits. There are no effluent guideline regulations for
toxic pollutants for these industries. These facilities' permits have
bioassay conditions for toxicity screening and requirements to investi-
gate toxic results. The Coastal Tank Line and Mason and Dixon permits
were reissued in 1985. The Chemical Leaman permit will be reissued
in 1986. Application data on 129 toxic pollutants and other monitoring
information have been reviewed by the State and EPA to determine which
specific toxic pollutants should be limited.
NEIC identified the need to better assess permit limits for
meeting water quality standards and potential toxicity to aquatic
life. Water quality standards and other water quality-based criteria
will be more fully utilized in considering toxicant limitations for
reissued permits. EPA guidance issued September 1985 on toxicant
screening for water quality-based permits will aid in this effort.
The NEIC report notes that there are inconsistencies in permit
conditions for the major chemical plants. The absence of effluent
guidelines and plant differences are the major factors for any
inconsistency. Implementation of a toxicant control strategy by the
State will facilitate a more uniform and comprehensive approach in
screening and limiting toxicants.
98
-------
The report observes that many effluent bioassays demonstrate
toxicity and that the causes are not defined. Greater emphasis is
being placed on responding to reports of toxic bioassays. As explained
in Section 4.1, new permits require dischargers to provide information
on probable causes of toxicity and steps taken to reduce it. This is
generally true throughout the Region.
The NEIC report indicates that there are frequent spills and
leaks from chemical plants. Although these discharges are usually
short term and corrected soon after detection, in some cases, violations
of NPDES permit limits result. These violations are usually resolved
by informal contacts with the permittee. Depending upon the severity •
of the violation, regulatory action may include a written inquiry into
the circumstances regarding the incident issuance of an administrative
order may be taken. Many reissued permits require implementation of
best management practices (BMP) to better prevent such leaks and to
detect them more quickly. In addition to actions under NPDES, EPA
will continue to respond to the incidents under Section 311 of the
Clean Water Act as described below under Spills and Releases.
Water Monitoring and Water Quality
The NEIC report indicates that the presence of low concentrations
of toxic pollutants in the Kanawha River reduces the quantity and
quality of the fishery in the lower river. This review (described in
Chapter 5) found that numbers of individual fish and fish species
sampled in navigation locks were not statistically different upstream
and downstream of Charleston. This suggests that discharges to the
industrial section of the river may have less impact on the fishery
than the NEIC report implied. However, a more recent report by the
Army Corps of Engineers indicates that benthos diversity is lower
below the industrial area. This suggests that industrial dischargers
did have an adverse impact on biota. Contamination of fish tissue by
some priority pollutants was greater at locations downstream of the
industrial area.
Ambient water quality measurements indicate that many inorganic
pollutants were also present upstream of the industrial area. No
statistically significant improvement in numbers of fish species and
individuals was observed between 1978 and 1984. However, most non-
significant trends in fish populations were positive, suggesting that
as more data become available, statistically significant improvements
may emerge.
The NEIC report states that chronic toxicity potentially affects
aquatic life in the Kanawha River in the vicinity of the industrial
discharges. Bioassays recently performed by West Virginia and EPA
Region III confirmed that some effluents to the industrial section of
the river were indeed toxic. Bioassays performed by the EPA Duluth
Environmental Research Laboratory also showed that ambient river
99
-------
water near these discharges had chronic toxicity to water fleas and
fathead minnows. Some of this ambient chronic toxicity occurred
upstream of the tested discharges, suggesting that there may be other
additional sources of toxic pollutants.
The NEIC report points out the need for expanding the toxic
pollutant monitoring program, in particular by monitoring organic
pollutants at more than one location on the Kanawha. The present
organic pollutant monitoring station located at St. Albans is operated
by ORSANCO as a daily early warning of organic substances spills to
water users on the Ohio River. Although it would be desirable to
have more upstream data, the Kanawha is already well-monitored relative
to similar water bodies in other parts of the U.S. West Virginia DNR
has recently begun two intensive surveys on the Kanawha River. One
survey will analyze ambient river water at several stations within
the industrial area for benzene, toluene, methanol, and vinyl chloride.
These compounds are not presently monitored at St. Albans. The second
survey will study the incidence and types of liver tumors and external
lesions occurring in sensitive fish species sampled at four stations
in the industrial area and at a control station. Occurrence of these
tumors and lesions is believed to be a sensitive indicator of chronic
sublethal stress.
The NEIC report mentions potential problems with chronic toxicity
to aquatic life and/or bioaccumulation of toxic pollutants in fish.
Violations of water quality criteria for cyanide, manganese, lead,
cadmium, phenolic compounds, and iron were specifically discussed.
The present study compared ambient concentrations of toxic pollutants
with two sets of 1980 EPA criteria: those for protection of aquatic
life from chronic toxicity, and those associated with an incremental
lifetime cancer risk of 10~5 for aquatic life consumption. This study
confirmed the NElC's conclusion that cyanide and phenolic compounds
sometimes exceed the aquatic life criteria, but also found that
arsenic concentrations almost always exceed the level associated with
10~5 incremental lifetime cancer risk from aquatic life consumption.
Concentrations of all of these compounds except arsenic may be
improving. The State of West Virginia intends to begin analyses of
arsenic in fish tissue by 1986 to determine whether fish tissue contains
concentrations of arsenic that are consistent with the concentrations
observed in ambient water.
Air
The NEIC report states that an emissions inventory and exposure
assessment are needed in order to list chemicals of concern in priority
order. NEIC screened and ranked chemicals based solely upon health
effects data independent of emission levels and exposure projections.
APPC has initiated a comprehensive emissions inventory program. In
addition, West Virginia recently passed the Community Right to Know
Act which will require companies to list chemicals stored on-site.
100
-------
The NEIC report implies that there should be federal regulatory
limits for various volatile organic compounds (VOC's) in order to
reduce potential health impacts from substances in the ambient air.
Many toxic substances are indirectly limited by the emission controls
imposed for VOC's as part of the process to reduce ambient ozone
levels. This effort, however does not address health considerations
beyond those caused by ozone. It is also true that emissions of
relatively few additional substances may eventually be regulated
under §112 of the CAA, or limited indirectly by provisions of other
statutes. Nevertheless, ambient air standards for toxic chemicals
are not expected to be developed by the federal government in the
near future. EPA is accelerating its efforts to establish health
criteria and carcinogenic risk values for those substances believed
to be most toxic. The purpose of criteria development is to enable
State and local agencies to assess the risks to individuals and
populations affected by specific facilities and to establish control
limits necessary to reduce risks. Region Ill's multi-media study
planned for the Kanawha Valley will also evaluate exposure routes and
potential control measures for air toxicants.
The NEIC report states that there is a need for an assessment
of the current status of air quality in the Kanawha Valley. EPA
Region III, EPA Headquarters, and WV are conducting a multi-media
study with a focus on air toxicants. The study will be implemented
in three phases with goals of developing a risk assessment for the
Kanawha Valley, identifying possible control strategies, and imple-
menting controls. To assess air quality, EPA and the State will
perform preliminary dispersion modeling, verify emissions inventories,
identify monitoring locations, and calculate risk estimates. A status
report will be prepared that summarizes the screening work and its
results and is scheduled for release in August 1986.
An important issue involves the frequent occurrence of leaks and
air releases at the different plants. For example, the air releases
of methyl chloride at Union Carbide's South Charleston plant are note-
worthy. These releases indicate that there may have been deficiencies
related to the process, equipment, or operation and maintenance
procedures. EPA has inspected the facility for deficiencies and
documented its findings in an inspection report. The actions taken
to date by the APCC consist primarily of inspections and engineering
review of the process and process equipment in an effort to determine
if there are repetitive large releases. After the review, the APCC
attempts to obtain an agreement from the company to correct the problem.
This process has been only partially successful because there are no
EPA ambient or process standards for methyl chloride. In the absence
of Agency rulemaking which particularly regulates a specific substance
regarded as an "air toxicant", EPA's best authority to deal with such
releases comes from the emergency provisions of the various statutes.
101
-------
The criteria for taking action under such provisions must also be met
before an action can be taken. At present, West Virginia is compiling
an air emissions inventory with the assistance of EPA and will use this
to decide how and what pollutants to regulate. In addition, EPA is
redirecting its program and increasing support to State programs as
described in the National Strategy for Toxic Air Pollutants, June 4,
1985, which is summarized briefly in Chapter 5 of this report.
RCRA
The NEIC Report suggests that EPA should request RCRA Part B
applications from those industries in the Valley which NEIC ranked as
major sources of toxic substances. In particular, these facilities
include DuPont, FMC - Nitro, CST Fike, Union Carbide-Institute, Monsanto,
and Union Carbide - S. Charleston. The Part B contains detailed
information needed to identify the more comprehensive environmental
controls associated with final permit determinations. As indicated
in Table A-2, the Part B applications have been requested or "called
in" and permitting activities for all of these major facilities
are progressing.
Although ground water monitoring indicates that contamination has
occurred at some sites, EPA has not always taken immediate enforcement
action to require cleanups at interim status facilities. Prior to
1984, the law did not give EPA the authority under RCRA to require
corrective action for prior releases. The recent amendments in 1984
broaden EPA's authority and provide options for cleanup besides those
available under CERCLA. EPA guidance for implementing corrective
actions is being completed. All facilities receiving a RCRA permit
will be required to take corrective actions at all solid waste manage-
ment units where necessary by 1988. Assessing the extent of groundwater
contamination is a concern nationally. WV and many other states have
applied for grants under the Clean Water Act to increase their ability
to study and solve groundwater problems. The extent of groundwater
contamination at individual sites will also be evaluated under the
CERCLA investigations discussed below.
A review of the permit status of individual facilities indicates
that certain facilities are not targeted for RCRA permit issuance
until 1987 or 1988. This schedule is in accordance with the RCRA
National Permit Strategy. The National Strategy recognizes that a
large number of facilities require permits and the time needed to do
sound permit reviews is contingent upon the available resources at EPA
and the States. This recognition results in a need to issue permits
in a priority order. Therefore, land disposal permits are highest,
followed by treatment, followed by storage. These prioritites are
consistent with the concept that greater environmental benefits will
be gained by permitting land disposal facilities first. However, all
existing facilities must comply with Interim Status provisions as
explained in Section 3.2.
102
-------
TSCA
There are no specific compliance issues related to PCB's raised
in the NEIC Report. The Report correctly indicates that there are
no known point source discharges of PCB's in the Kanawha Valley, and
also notes the trend of decreasing PCB levels in fish samples during
the period 1969-1981. PCB levels in fish tissue in 1982 ranged from
0.16-1.3 ppm. Possible sources of contamination may be from sediments,
historical spills, or illegal discharges and disposal fo PCB's.
Additional fish tissue sampling is being performed by WV DNR to better
characterize contaminant levels.
A specific question which arises regarding PCB's is why EPA does
not perform more inspections to identify situations where spills could
potentially occur. The answer is that as many inspections are conducted
as available resources will allow. The use of the neutral (random)
selection process enables EPA to select inspection targets equitably
from the universe of facilities handling PCB's. The summary of completed
inspections is provided in Section 4.2.
FIFRA
There are no specific compliance issues raised in the NEIC Report
related to pesticides as they are regulated under FIFRA. When conducting
pesticide inspections, however, EPA does not evaluate the manufacturing
process for potential mishandling of chemicals or dangerous practices.
Under existing law, EPA's inspections are limited to the finished product,
its quality, and its labeling.
Spills and Releases
While the NEIC report notes that numerous chemical substances
were being emitted to the atmosphere, it also recognized that these
emissions were typically not a hazardous air pollutant as designated
by EPA regulations and therefore not enforceable under the CAA.
Further actions on air toxicants by EPA and the State of West Virginia
are discussed in Chapter 5. WV has developed and implemented a spill
alert program to respond to accidental spills and releases.
The NEIC Report notes that periodic spills and releases emit
pollutants into the environment. It is not possible for EPA and other
governmental agencies to control or manage all the various industries
and activities which generate spills to the point where they will
never occur. EPA will ensure that there will be proper notification
of releases, and that appropriate responses and follow-up enforcement
actions will be taken. These activities are presently on-going at
EPA. Regional Orders delineating internal procedures for spill response
enforcement have been revised to improve the thoroughness of follow-up
actions.
103
-------
CERCLA
The NEIC report notes that EPA was actively investigating those
sites currently listed in ERRIS. It also suggests that further
evaluations were needed to discover additional sites or investigate
the potential sites mapped by EPIC. The effort described in Chapter 4
is a major step towards achieving the additional activities viewed as
necessary. This effort has resulted in a detailed identification of
84 new potential hazardous waste sites. A framework for scheduling in
priority order the site-specific PA/SI's needed to determine long-term
remedial activities has also been achieved. The actual PA/SI's will
now be accomplished in an orderly fashion with existing resources.
A proposed schedule for entering the 84 newly identified sites into
ERRIS and completing the PA/SI's is included in Appendix D. The
implementation schedule also includes a tentative breakout of the work
between EPA and DNR.
EPA will not be performing all the preliminary assessments/site
investigations (PA/SI) immediately. While the completion of PA/SI's
in the Kanawha Valley could be expedited, it would involve shifting
resources from PA/SI's in other geographic areas of the Region where
the priorities for site-specific activities may be higher than at some
sites in the Kanawha Valley. However, all of these sites that are
considered high priority will be done expeditiously.
The NEIC report suggested that several hazardous waste sites
"appear to have a significant potential for long-term release of
toxic substances to the environment." CERCLA PA/SI's discussed above
will determine whether sites are releasing toxicants over a long-term
period. To attempt to identify potential environmental impacts of
such releases, water monitoring data were evaluated to determine
if these sites'currently affect water quality. In an attempt to
distinguish between existing impacts of point and non-point sources,
ambient concentrations were correlated with flow and river mile.
Concentrations of arsenic, cadmium, copper, cyanide, lead, silver,
and selenium did not correlate with flow or river mile, suggesting
that both point and non-point sources contribute to ambient levels.
Hazardous waste sites may be among the non-point sources which contribute
to these levels. These possible sources will be investigated during
PA/SI's. Similar analyses using concentrations of organic pollutants
were not possible because most organics were measured at only one
river location, and flow data were not taken simultaneously.
104
------- |