PB97-963155
EPA/541/R-97/173
January 1998
EPA Superfund
Record of Decision Amendment:
Allied Chemical & Ironton Coke
Ironton, OH
9/4/1997
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RECORD OF DECISION AMENDMENT #2
ALLIED CHEMICAL/IRONTON COKE SUPERFUND SITE
Ironton, Ohio
PTTPPOSF
This decision document, together with the Allied Chemical/Ironton Coke Record of Decision
(ROD) dated December 28, 1990, and the first Allied Chemical/Ironton Coke ROD
Amendment dated July 31, 1995 (ROD Amendment #1), presents the selected remedial action
for the Allied Chemical/Ironton Coke site. The cleanup remedy for the site has been
developed in accordance with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980, as amended by the Superfund Amendments and Reauthorization Act
of 1986 (CERCLA), and, to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) and Agency Policy.
The State of Ohio concurs with the cleanup decisions embodied in ROD Amendment #2.
BASIS
The decision to further amend the Allied Chemical/Ironton Coke ROD and ROD Amendment
#1 and select a modified remedial action is based upon the administrative record. The attached
index lists the items that comprise the administrative record for ROD Amendment #2.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by im-
plementing the response actions selected in the ROD, ROD Amendment #1 , and ROD
Amendment #2, may present an imminent and substantial endangerment to public health,
welfare, or the environment.
OF TTTF. PEMFDY
The remedy selected for the site is a final remedial action. It consists of:
• Incineration of approximately 122,000 cubic yards of lagoon waste materials and on-
site re-use of the waste heat generated during incineration.
• In-situ bioremediation of approximately 457,000 cubic yards of contaminated soil
materials.
• Off-site disposal of approximately 40,000 cubic yards of contaminated soil material,
referenced as the "ROD Soils."
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• Pumping and on-site treatment of groundwater.
• Downgradient groundwater monitoring of Ice Creek and preparation of a contingency
plan. Implementation of deed restrictions, fencing and security.
nRSrRTPTION OF THE MOnTFTFT) REMF.DY
The cleanup remedy selected for the 40,000 cubic yards of Rod Soils by ROD Amendment #2
consists of:
• Replacing prepared pad bioremediation with off-site disposal in an approved landfill.
STATUTORY DRTRRMTNATTONS
The selected remedy is protective of human health and the environment, complies with, at a
minimum, federal and state requirements that are legally applicable or relevant and appropriate
to the remedial action, and is cost-effective. Off-site disposal does not meet the requirement
of reduction of toxicity, mobility, or volume through treatment. Since the ROD Soils are not
as contaminated as previously thought, off-site disposal instead of treatment through
landfarming is justified.
The remedial action selected in the ROD and unchanged by ROD Amendments #1 and #2 will
result in a hazardous substance remaining on-site above health-based levels. Therefore, a
"Five-Year Review" will be conducted after commencement of the remedial action and every
five years thereafter to ensure that the remedy continues to provide protection of human health
and the environment.
WilliamE. Muno, Director // / Date
Superfund Division ^
-2-
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RECORD OF DECISION AMENDMENT #2
ALLIED CHEMICAL/IRONTON COKE SUPERFUND SITE
INTRODUCTION
The Allied Chemical/Ironton Coke Superfund Site, located in Ironton, Lawrence County, Ohio
is approximately 95-acres in size. The site consists of a dismantled Coke Plant which operated
from 1920 to 1982 and five lagoons which received process wastewater and hazardous solid
waste from the former Coke Plant. A 4-acre waste pit called the Goldcamp Disposal Area is
also part of the site and an operating AlliedSignal Tar Plant is within the site boundaries. The
Allied Chemical/Ironton Coke site is divided into two operable units, the Goldcamp Disposal
Area (GDA) and the Coke Plant/Lagoon Area (CPLA).
The GDA Record of Decision (ROD) which describes the GDA site remedy was executed on
September 29, 1988. The remedial design -smedial action (RD/RA) for the GDA is through a
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended Section 106 Unilateral Administrative Order. The Unilateral
Administrative Order (UAO) was issued to AlliedSignal, Inc. and Amcast Industrial
Corporation on March 9, 1989. AlliedSignal has complied with the UAO.
The CPLA RD/RA is also being performed through a CERCLA Section 106 Unilateral
Administrative Order which was signed on July 1, 1991 and was issued to AlliedSignal, Inc.
The CPLA remedy was finalized through the ROD signed on December 28, 1990 and
subsequently amended on July 31, 1995.
Pursuant to CERCLA Section 117 and the National Contingency Plan (NCP), Section
300.435(c)(2)(I), the United States Environmental Protection Agency (U.S. EPA) is publishing
this ROD Amendment. The ROD Amendment by the United States Environmental Protection
Agency (U.S. EPA) is a result of new information discovered during the remedial design and
remedial action. This ROD Amendment describes a fundamental change to the CPLA ROD.
The change is for a group of soils designated as the "ROD Soils" in the December 1990 ROD
for the CPLA. A Proposed Plan was published on July 15, 1997, followed by a 30 day
public comment period which ended on August 15, 1997. This ROD amendment will become
part of the Allied Chemical/Ironton Coke Administrative Record (NCP 300.825(a)(2)), which
is available for review at the Briggs Lawrence County Library, located in Ironton, Ohio. The
information used in U.S. EPA's assessment of this change is currently available at the above
repository.
H. REASONS FOR ISSUING THE ROD AMENDMENT
During the design and construction for the CPLA remedy, new information was discovered
that supports a fundamental change to the original 1990 CPLA ROD. Additional sampling and
analysis for a group of soils classified as the ROD Soils determined that carcinogenic
1
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polynuclear aromatic hydrocarbons (PAHC) within the ROD Soils was not as high as
previously thought. The lower level of PAHC within the ROD Soils allowed the Agency to
revisit the remedy for the ROD Soils. Correspondence and drawings dated March 25, 1997
and June 24, 1997 show sample locations and analytical results for the ROD Soils.
The remedy as described in the original ROD for the CPLA operable unit contains the
following components:
• Incineration of approximately 122,000 cubic yards of lagoon waste materials and on-
site re-use of the waste heat generated during incineration.
• In-situ bioremediation of approximately 457,000 cubic yards of contaminated soil
materials.
• Prepared pad surface bioremediation of approximately 40,000 cubic yards of
contaminated soil material, referenced as the "ROD Soils."
• Pumping and on-site treatment of groundwater.
• Downgradient groundwater monitoring of Ice Creek and preparation of a contingency
plan. Implementation of deed restrictions, fencing and security.
The cleanup standard for soil contamination listed in the CPLA ROD states that the sum total
of four PAHC must be less than 0.97 ppm. The four PAHC are benzo(a)pyrene,
dibenz(a)anthracene, benz(a)anthracene and chrysene. The area located with the five lagoons
also has an alternative cleanup standard of 100 ppm for the four PAHC if the bioremediation
cannot achieve the 0.97 ppm in a timely manner. At the former coke plant property,
excavation of ROD Soils will cease when the 0.97 ppm value for PAHC has been reached or to
a maximum depth of 10 feet. At the operating tar plant, excavation will be to a maximum
depth of 5 feet. All excavated areas will be backfilled with clean fill.
The 1995 ROD Amendment made four changes to the 1990 ROD and they are as follows:
• Removal of the waste heat boiler from the incineration process for lagoon 5.
• Removal of the dismantlement provision for the incinerator.
• Excavate and store on-site for eventual treatment or placement into the lagoon area,
135,000 cubic yards of soils referenced as the "Site Soils."
• Revise the cleanup standard for groundwater constituents benzo(a)pyrene and
dibenz(a,h)anthracene at the GDA and CPLA from a total of 5 parts per trillion (ppt) to
safe drinking water standards of 200 ppt for benzo(a)pyrene and 300 ppt for
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dibenz(a, h)anthracene.
The groundwater pump and treatment system for the CPLA began operation on June 1997 and
is treating approximately 200 gallons per minute of groundwater through metals precipitation,
carbon adsorption and UV oxidation. The design for in-situ bioremediation and prepared pad
surface bioremediation is completed and construction began on those facilities on March 3,
1995. In August 1996, the U.S. EPA agreed to halt construction of all bioremediation
facilities at a request by AlliedSignal. The Agency has been evaluating other alternatives to
bioremediation and will either conclude that bioremediation construction should resume or
present new alternatives shortly. The incineration of lagoon 5 is also being re-evaluated and it
appears that different technology at a lower cost may be available. Cost of the CPLA remedy
is well over $100 million over the life of the project.
HI. DESCRIPTION OF THE NEW ALTERNATIVES
In the original ROD, the 40,000 cubic yards of soil contaminated with PAHC compounds,
classified as the ROD Soils, was to be bioremediated through the use of a prepared pad. These
ROD soils are affected by this ROD Amendment. Prepared pad bioremediation is sometimes
referred to as landfarming. A thin layer of contaminated soil is spread over a prepared pad
and nutrients are added to facilitate the growth of naturally occurring soil microorganisms.
These microorganisms break down and metabolize the contaminants to acceptable levels. The
concentration of PAHC compounds was thought to be from approximately 250 parts per million
(ppm) to 1000 ppm. It is expected to take 12 years for the landfarming to reach the 0.97 ppm
PAHC cleanup value and cost $4.8 million. The ROD Soils are located at the AlliedSignal Tar
Plant and former location of the AlliedSignal coke plant (see Figure 1).
During additional characterization of the ROD Soils (see documents in administrative record
dated March 25, 1997 and June 24, 1997), it was discovered that the soils were not as
contaminated as previously thought. Sampling results showed that most samples were at 100
ppm or below for PAHC compounds. The lower than anticipated contamination allowed a re-
evaluation of the landfarming treatment option. Further analysis demonstrated that most of the
ROD Soils would pass the toxicity characteristic leaching potential (TCLP) test, thereby
classifying the ROD Soils as non-hazardous. Even though the ROD Soils are classified as
non-hazardous, they still must be disposed of off-site in a Subtitle D landfill. Since alternative
treatment options were not superior to landfarming for the ROD Soils, off-site disposal in a
landfill is being evaluated against landfarming.
IV. EVALUATION OF THE ALTERNATIVES
The Administrative Record, located at the Briggs Lawrence County Library, is available for
review and contains the information which was used to evaluate the alternatives. The U.S.
EPA uses nine evaluation criteria as set forth in the National Contingency Plan, 40 CFR Part
300.430, to evaluate the fundamental change and the different alternatives associated with the
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change. The alternative for each fundamental change which complies with Criteria 1 and 2,
achieves the best balance among Criteria 3-7, and considers Criteria 8 and 9 is the one chosen.
The nine evaluation criteria are listed below:
Criteria 1 - Overall Protection of Human Health and Environment addresses whether or not a
remedy provides adequate protection and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engineering controls, or institutional
controls.
Criteria 2 - Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
addresses whether or not a remedy will meet all other Federal and State environmental statutes
and/or provide grounds for issuing a waiver.
Criteria 3 - Long-Term Effectiveness and P^ i^anence refers to the amount of risk remaining
at a site and the abib'ty of a new remedy to maintain reliable protection of human health and
the environment over time once cleanup standards have been met.
Criteria 4 - Reduction of Toxicity, Mobility, or Volume through Treatment is the anticipated
performance of the treatment technologies that may be employed in a remedy.
Criteria 5 - Short-Term Effectiveness refers to the speed with which the remedy achieves
protection, as well as the remedy's potential to create adverse impacts on human health and the
environment that may result during the construction and implementation period.
Criteria 6 - Implementability is the technical and administrative feasibib'ty of a remedy,
including the availability of materials and services needed to implement the chosen solution.
Criteria 7 - Cost addresses the estimated capital and operation and maintenance costs, as well
as present-worth cost. Present worth is the total cost of an alternative in terms of today's
dollars.
Criteria 8 - Support Agency Acceptance indicates whether, based on its review of the ROD
Amendment, the support agency (usually a state environmental agency) concurs with, opposes
or has no commeni on tne recommended alternative.
Criteria 9 - Community Acceptance will be assessed in the Record of Decision following a
review of the public comments received on the Proposed Plan Amendment.
Overall Pmfer.tinn nf Human Health and Environment
In comparing off-site disposal of the ROD Soils to landfarming, both alternatives are
protective of human health and the environment. Landfarming will reduce the PAHC to the
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0.97 ppm cleanup standard through treatment and off-site disposal will remove the ROD Soils
to an approved landfill where they will be managed.
Compliance with Applicable nr Relevant and Appropriate Requirements
Compliance with applicable or relevant and appropriate requirements (ARARs) must be met
for every alternative. As was described in the 1990 ROD, landfarming will require waivers of
portions of the Ohio Administrative Code (OAC). Pursuant to CERCLA Section 121 (d),
waivers of ARARs are allowed under limited circumstances. The waivers are appropriate
since compliance with such requirements is technically impracticable from an engineering
perspective and landfarming will attain a standard of performance that is equivalent to that
required under the otherwise applicable standard, requirement, criteria, or limitation, through
use of another method or approach. The following is a list of ARARs that require waiver for
the landfarming option:
• OAC 3745-27-07, Location Criteria for Solid Waste Disposal Facility. Placement of
the ROD Soils after landfarming back on-site would not meet the requirements of this
rule. Landfarming is expected to achieve concentrations of PAHC below risk based
levels, therefore, waiving of this rule would be justified.
• OAC 37454-27-08, Construction Specifications for Sanitary Landfills. Placement of
the ROD Soils after landfarming in an engineered unit would not meet the design
criteria presented in this rule. Landfarming is expected to achieve concentrations of
PAH,, below risk based levels, therefore, waiving of this rule would be justified.
Off-site disposal in a landfill would require compliance with the State's regulatory equivalent
of RCRA 40 CFR Part 261, Toxicity characteristics. Preliminary testing and analysis of the
ROD Soils indicates that the soil will pass the toxicity characteristic leaching potential which
would allow disposal in a RCRA Subtitle D landfill. ROD Soils which do not pass the TCLP
test would require disposal in a RCRA Subtitle C landfill. Ohio Revised Code (ORC) 3734-03
- Open Burning or Dumping, OAC 3745-27-05 - Authorized, Limited, and Prohibited Solid
Waste Disposal Methods and OAC 3745-54-13 - General Waste Analysis are applicable to off-
site disposal.
Disposal off-site for soils which do not pass TCLP will also require compliance with the
CERCLA Off-site Rule, 40 CFR 300.440. Waste which contains CERCLA hazardous
substances or pollutants or contaminants must be managed in a U.S. EPA approved facility.
I^nng-Term Efferfivp.np'.ss and Permanenre
Both alternatives meet the requirements of Long-Term Effectiveness and Permanence.
Landfarming would reduce the PAHC levels to acceptable levels that would minimize risk to
public health and the environment. Off-site disposal would remove the ROD Soils to a landfill
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and be managed in a way that is protective of public health and the environment.
Reduction of Toxicity, Mobility, or Volume through Treatment
Landfarming of the ROD Soils would meet the criteria for reduction of toxicity, mobility, or
volume through treatment. Landfarming will reduce levels of PAHC compounds to acceptable
risk levels. Off-site disposal of the ROD Soils does not include treatment and would not
reduce the toxicity, mobility, or volume through treatment.
Short-Term Effectiveness
Both landfarming and off-site disposal of the ROD Soils are effective in the short term. Both
options require excavation of the ROD Soils and impacts to public health and the environment
are not anticipated due to the nature of PAHC compounds which do not volatize into the air
easily. Since consumption of the ROD Soils is not probable, both alternatives will meet the
short term effectiveness requirement. However, off-site disposal is more effective in the short
term because it removes the contaminated soils immediately, thereby reducing the time until
protection of public health is achieved by as much as twelve years.
Implementahility
Both alternatives can be implemented and both technologies have been used at a number of
Superfund sites. Off-site disposal within an approved landfill is used at many Superfund and
non Superfund sites. Landfarming has proved to be effective in reducing PAHs to acceptable
levels. Off-site disposal of the ROD Soils would begin immediately and be completed during
the fall of 1997. Landfarming is scheduled to take 12 years to complete.
C!nst
The cost associated with landfarming is $4.8 million compared with $2.6 million for off-site
disposal. The off-site disposal option includes a contingency that 5 percent of the ROD Soils
will require disposal within a hazardous waste Subtitle C landfill.
Support Agency Acceptance
The Ohio EPA supports the off-site disposal of the ROD Soils.
Community Acceptance
No public comments were received on the proposed plan.
In comparing the alternatives to the nine criteria, the best balance of the criteria would be off-
site disposal of the ROD Soils in an U.S. EPA approved landfill. Due to the PAHC
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concentrations within the ROD Soils being at levels below 100 ppm and the time saved along
with the $2.2 million cost savings, off-site disposal is the best approach.
V. STATUTORY DETERMINATIONS
The off-site transport and disposal of waste containing hazardous materials without treatment is
the least favored alternative remedial action where practicable treatment technologies are
available. Based upon the new information that the ROD Soils are not as contaminated as
previously thought, deviating from the landfarming treatment option is justified. The
timeframe to complete the ROD Soils excavation will be a few months compared with 12 years
for the landfarming along with a $2.2 million cost savings.
Off-site disposal of the ROD Soils is protective of human health and the environment since the
ROD Soils will be managed in an U.S. EPA approved landfill. Remaining soils will meet the
PAHC cleanup standard or be at a depth which wil! not affect public health or the environment.
Compliance with ARARs, specifically the State equivalent of RCRA 40 CFR Part 260 to 271,
ORC 3734-03, OAC 3745-27-05 and OAC 3745-54-13 will be met with off-site disposal of the
ROD Soils. Disposal of soils containing CERCLA hazardous substances must meet the
CERCLA Off-Site Rule, 40 CFR 300.440. AlliedSignal is expected to spend over $100
million on the CPLA, and off-site disposal of the ROD Soils is a cost effective solution since
$2.2 million is saved compared with landfarming.
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CPIA ROD SOLS AREAS
ALUCD9CMAL.
MUMUSTIMM. NEW JERSEY
UMTS OF
CPIA ROD SOU AKEAS
IKBMOIOCY
CORWRATION
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
ALLIED CHEMICAL AND IRONTON COKE SITE
IRONTON, LAWRENCE COUNTY, OHIO
OPERABLE UNIT #2: COKE PLANT/LAGOON AREA
UPDATE #8
AUGUST 25, 1997
DATE
04/00/91
02/00/96
03/08/96
04/10/96
05/15/96
06/20/96
06/24/96
08/23/96
AUTHOR
U.S. EPA/
OSWER
International
Technology
Corporation
Alcamo, T.,
U.S. EPA
Alcamo, T.,
U.S. EPA
RECIPIENT
TT.S. EPA
TITLE/DESCRIPTION
PAGE?
Alcamo, T.,
U.S. EPA
Gupta, S.,
International
Technology
Corporation
U.S. EPA
Ford, R..
AlliedSignal,
Inc.
U.S. EPA
Ford, R.,
AlliedSignal,
Inc.
Ford, R.,
AlliedSignal,
Inc.
Fo.d, R.,
Al1i edSigna1,
Inc .
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
File
Alcamo, T.,
U.S. EPA and
K. Gilmer.
Quick Reference Fact
Sheet: "Guide to Addres-
sing Pre-ROD and Post-
ROD Changes" (Publication
9355.3-02FS-4)
Neal Junkyard Delin-
eation Workplan
Letter re: U.S. EPA's
Acceptance of the Neal
Junkyard Delineation
Workplan
Letter re-. U.S. EPA's
Acceptance of the Bid
Specification for Work
Item 1 Construction and
Neal Junkyard Delineation
Program
Letter re: U.S. EPA's
Acceptance of the Lagoon
2 Material Segregation/
Excavation Workplan
Letter Forwarding
Attached Figures from
the Neal Junkyard
Delineation Program
Investigation
Table: Summary of Neal
Junkyard Samples; TPHC.
TCLP, and Hazardous
Characteristic Testing
Letter Forwarding
Attached Petition to
Amend the Record of
26
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9 08/27/96 Alcamo, T.
U.S. EPA
Ohio EPA
Ford, R..
AlliedSignal.
Inc.
Decision for the Ironton
Coke Plant CP/LA
Operable Unit
Letter re: Shutdown of
the Current Bioremediation
Construction
Allied Chemical/Ironton Coke AR
Operable Unit #2
Update #8
Page 2
flQ. DATS
AUTHOR
RECIPIENT
TITLB/DESCRIPTION
PAGES
10 10/25/96
11 01/28/97
12
13
02/19/97
02/26/97
Shott, D.,
International
Technology
Corporation
Lewis, M.,
AlliedSignal,
Inc.
Shott, D.,
International
Technology
Corporation
Alcamo, T.,
U.S. EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Ford, R.,
AlliedSignal,
Inc.
Letter Forwarding
Attached Drawing re:
Neal Junkyard Delineation
Program Boring Locations
and Analytical Results
Letter Forwarding
Attached Survey Map of
Neal Junkyard Area w/
Previously Surveyed
Sample Point Locations
Letter Forwarding
Attached ROD Soils Delin-
eation Work Plan
Letter re: U.S. EPA's
Comments on the February
19, 1997 ROD Soils Delin-
eation Work Plan
12
14
03/25/97
03/28/97
Shott, D.,
International
Technology
Corporation
Alcamo, T.,
U.S. EPA
16 05/06/97 U.S. EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ford, R.,
AlliedSignal,
Inc.
File
Letter Forwarding
Attached Revised Drawing
for Neal Junkyard
Delineation
Letter re: U.S. EPA/OEPA
Conclusions Concerning
the Tar Plant ROD Soils
(UNSIGNED)
Table: Summary of Coke
Plant ROD Soils Samples
(Areas l and 3); TPHC,
TCLP, and Hazardous
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Characteristic Testing
17
05/28/97
U.S. EPA
File
18
19
06/23/97
06/24/97
Ford, R.,
AlliedSignal,
Inc.
.Shott, D. ,
International
Technology
Corporation
Alcamo, T.,
U.S. EPA and
K. GiInner,
Ohio EPA
Alcamo, T.,
U.S. EPA and
.". Gilmer,
Ohio EPA
Table: Summary of Tar
Plant ROD Soils Samples
(Areas 5, 6, and 7)•
Total PAHs, Arsenic,
TCLP, and Hazardous
Characteristic Testing
Letter Forwarding
Attached Lagoon PAH Data
Table and Sample Location
Map
Letter Forwarding
Attached April 1997 ROD
Soils Delineation Program
Analytical Results
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Allied Chemical/Ironton Coke AR
Operable Unit #2
Update #8
Page 3
NO. DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
26 07/15/97
Alcamo, T.
U.S. EPA
21 07/15/97 Alcamo, T.
U.S. EPA
Ford, R.,
AlliedSignal,
Inc.
Ford, R.,
n~~ iedSignal,
Inc.
Letter re: U.S. EPA's
Review of the April 1997
ROD Soils Delineation
Program Analytical Results
Letter re: Lagc.on Area
Carcinogenic Polynuclear
Aromatic Hydrocarbons
Data Table
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