PB98-963144
EPA 541-R98-156
March 1999
EPA Superfund
Record of Decision Amendment:
Allied Chemical & Ironton Coke
Ironton, OH
9/30/1998
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RECORD OF DECISION AMENDMENT #3
ALLIED CHEMICAL/IRONTON COKE SUPERFUND SITE
Ironton, Ohio
PURPOSE
This decision document, together with the Allied Chemical/Ironton Coke Record of Decision
(ROD) dated December 28, 1990, the first Allied Chemical/Ironton Coke ROD Amendment
dated July 31, 1995 (ROD Amendment #1), and the second ROD Amendment dated September
4, 1997 (ROD Amendment #2), 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
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) and Agency Policy.
It is anticipated that the State of Ohio will concur with this decision. A written confirmation is
expected and will be added to the administrative record upon receipt.
BASIS
The decision to further amend the Allied Chemical/Ironton Coke ROD and ROD Amendments
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 #3.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site, if not addressed by
implementing the response actions selected in the ROD, ROD Amendments #1 and #2, and ROD
Amendment #3, may present an imminent and substantial endangerment to public health,
welfare, or the environment.
DESCRIPTION OF THE REMEDY
The remedy selected in the 1990 ROD, 1995 ROD Amendment #1, and 1997 ROD Amendment
#2 for the site is a final remedial action. The major components of the selected remedy include:
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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2
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.
Through ROD Amendment #3 the following components of the selected remedy are being
modified:
Replace in-situ bioremediation of 457,000 cubic yards of soil in Lagoons 1-4 with hot
spot excavation and wetland development.
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Replace incineration of Lagoon 5 materials with recycling, treatment, and/or disposal of
the KO87 listed waste in an approved off-site hazardous waste facility and the use of the
remaining material, excluding debris, as an alternative fuel.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal
and state requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. Hot spot excavation and wetland development of the 457,000 cubic
yards of soil in Lagoons 1-4 only partially meets the requirement of reduction of toxicity,
mobility, or volume through treatment. Since the soils in Lagoons 1-4 are not as contaminated as
previously thought and hot spot excavation can achieve an alternate clean-up level proposed in
the original ROD, as well as the beneficial contribution of wetland development to valuable
ecological habitat, these changes are justified. However, the use of recycling, treatment and/or
disposal of the Lagoon 5 materials does satisfy the statutory preference for treatment as a
principal element of the remedy and employs permanent solutions and alternate treatment
technologies to the maximum extent possible.
The remedial action selected in the ROD and by ROD Amendments #1, #2, and #3 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.
William E. Muno, Director/ ' Date
Superfund Division
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RECORD OF DECISION AMENDMENT #3
ALLIED CHEMICAL/IRONTON COKE SUPERFUND SITE
I. 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. Figure 1 is a map of the Coke Plant and Lagoon areas. A 4-
acre waste pit called the Goldcamp Disposal Area (GDA) 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 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/remedial action (RD/RA) for the GDA is being
implemented 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 UAO 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
and September 4, 1997.
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 U.S. EPA is a result of new information
discovered during the RD/RA for the CPLA operable unit. This ROD Amendment describes a
fundamental change to the CPLA ROD. A Proposed Plan was published on December 1, 1997,
followed by a 30 day public comment period which ended on January 2, 1998. Only public
comments in support of the proposed plan were received during the public comment period. This
ROD Amendment will become part of the Allied Chemical/Ironton Coke Administrative Record
(NCP 30.825(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.
II. REASONS FOR ISSUING THE ROD AMENDMENT
The remedy as described in the original ROD for the CPLA operable unit contained the
following components:
Incineration of approximately 122,000 cubic yards of lagoon waste materials and on-site
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re-use of the waste heat generated during incineration, referenced as Lagoon 5 soils;
In-situ bioremediation of approximately 475,000 cubic yards of contaminated soil
materials, referenced as Lagoon 1-4 soils;
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; and
Downgradient groundwater monitoring of Ice Creek a/id preparation of a contingency
plan. Implementation of deed restrictions, fencing, and security.
Based upon new information discovered during the pre-design and design for the CPLA operable
unit, the 1995 ROD Amendment #1 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"; and
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
dibenz(a,h)anthracene.
Additional sampling and analysis for a group of soils classified as the ROD Soils determined that
carcinogenic polynuclear aromatic hydrocarbons (PAHC) within the ROD Soils was not as high
as previously thought. The lower level of PAHC allowed the agency to revisit the remedy for the
ROD Soils. This resulted in the 1997 ROD Amendment #2 which made a single change to the
1990 ROD for the CPLA operable unit that is as follows:
Replacing prepared pad bioremediation of the approximately 40,000 cubic yards of ROD
Soils with off-site disposal in an approved landfill.
ROD Amendment #3 addresses requests from AlliedSignal that the U.S. EPA revise and replace
the treatment of 457,000 cubic yards of Lagoon 1-4 soils from in-situ bioremediation to hot spot
excavation and wetland development and revise the treatment of 122,000 cubic yards of Lagoon
5 soils from incineration to containment. While U.S. EPA does not believe containment of
Lagoon 5 is appropriate, U.S. EPA does believe that modifying the requirement to incinerate
Lagoon 5 is appropriate.
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In the 1990 ROD for the CPLA operable unit Lagoons 1 -4 soils were required to be treated by in-
situ bioremediation. Through bioremediation, naturally occurring microorganisms are used to
break down the contaminants to levels which are protective of public health and the environment.
Water fortified with oxygen and nutrients is distributed throughout the lagoons to accelerate the
growth of the microorganisms. During the design phase for the in-situ bioremediation, sampling
demonstrated that levels of PAHC compounds were not as high as previously thought. In
addition, several pilot tests indicated that achieving the 0.97 parts per million (ppm) cleanup
standard established in the 1990 ROD through in-situ bioremediation would be difficult. This
proposed change is based upon using the alternative wetland cleanup standard that is provided in
the 1990 ROD for the CPLA operable unit. The CPLA ROD states that the cleanup standard for
soil is 0.97 ppm for PAHC. This standard was based on a direct contact exposure pathway and
assumed residential land use. An alternative cleanup standard of 97 ppm for PAHC was
provided in the CPLA ROD. The CPLA ROD provided for utilization of the 97 ppm PAHC
cleanup standard if the in-situ bioremediation would not achieve the 0.97 ppm clean-up standard
in a timely manner and the threat of direct contact from lagoon soils through residential land use
was eliminated by flooding Lagoons 1-4 to create a wetland. An assessment of the Lagoon 1-4
area indicates that the area is more likely to be an ecological area then a residential area in the.
future due to its close proximity to Ice Creek and the fact that this low-lying area has
historically served as a flood water storage area. AlliedSignal requested that the U.S. EPA allow
utilization of the alternative cleanup standard of 97 ppm for PAHj prior to development of the
wetland. Based upon a review of the sampling data gathered from Lagoons 1-4 during design
and the unlikelihood that in-situ bioremediation would achieve the .97 ppm cleanup standard for
PAHC, the U.S. EPA evaluated two options for the Lagoon 1-4 soils:
In-situ bioremediation (the original selected remedy); and
Excavation of materials above 97 ppm PAH,, ("hot spot excavation") and subsequent
wetland development.
The 1990 ROD for the CPLA operable unit required incineration of approximately 122,000 cubic
yards of wastes from Lagoon 5. In addition, an estimated 8,800 cubic yards of tarry soils
excavated from near the former coke plant and placed on top of Lagoon 5 were to be incinerated.
Based on studies during the design it was determined that Lagoon 5 contains a soft tar; a hard tar;
coal/coke fines and debris. The soil boring data indicated that the soft tar, which is a listed
hazardous waste (KO87) and considered by the U.S. EPA to be a principal threat at the site, was
physically distinguishable from the hard tar and coal/coke fines, and was located within a
discrete area of Lagoon 5. This indicates that the material in Lagoon 5 could be separated during
excavation. Based upon the soil boring data and the fact that the remedy for Lagoon 5 had not
yet been implemented, the U.S. EPA decided to review the remedy and proposed four options for
evaluation. The four options included:
1. On-site incineration of Lagoon 5 and the tarry soils (the original selected remedy);
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2. Construction of a RCRA Subtitle C containment cell in Lagoon 2 for the 122,000 cubic
yards of material in Lagoon 5 and the tarry soils;
3. Recycle back to coke plants the soft tar, which is classified as KO87, with the remaining
coal/coke fines and hard tar in Lagoon 5 being used as an alternative fuel. If it appears
that the capacity is not available at coke plants to recycle the KO87, treatment and/or
disposal of the material off-site in an approved hazardous waste facility might be
necessary. The 8;800 cubic yards of tarry soils on top of Lagoon 5 will be separated by
screening into three types of material (tar, debris, and product for use in cement kilns).
The tar will be used as an alternative fuel. The debris, which consists of clean brick and
concrete, will be placed back on-site into the excavated Lagoon 5. Additional product
from the tarry soils will be sent to cement kilns for use in their processes; and
4. Recycle back to coke plants the soft tar (K.O87) and cap the remaining material in
Lagoon 5.
III. 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. In the National
Contingency Plan (NCP), 40 CFR Part 300.430, the U.S. EPA has established nine criteria that
assist in determining the most appropriate remedial alternative to be selected for a site. The
criteria are designed to select a remedy that will be protective of human health and the
environment, attain Applicable or Relevant and Appropriate Requirements (ARARs), utilize
permanent solutions and treatment technologies to the maximum extent practicable, and be cost
effective. The relative performance of the proposed fundamental changes mentioned above has
been evaluated using the nine criteria set forth in the NCP as the basis of comparison. These
nine criteria are summarized below:
Threshold Criteria
The selected remedy must meet the following threshold criteria:
1. Overall Protection of Human Health and the Environment addresses whether a
remedy provides adequate protection and describes how risks are eliminated, reduced or
controlled through treatment, engineering controls or institutional controls.
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2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARsl
addresses whether a remedy will attain applicable or relevant and appropriate
requirements under federal environmental laws and state environmental or facility siting
laws or provide grounds for issuing a waiver.
Primary Balancing Criteria
The balancing criteria are used to compare the effectiveness of the remedies.
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3. Long-term Effectiveness and Permanence refers to the amount of risk to maintain
reliable protection of human health and the environment over time once cleanup goals
have been met.
4. Reduction of Toxicitv. Mobility or Volume Through Treatment is the anticipated
performance of treatment technologies that may be employed in a remedy to reduce the
harmful effects of principal contaminants, their ability to move in the environment, and
the amount of contamination present.
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 during the construction and implementation period.
6. Implementability is the technical and administrative feasibility of a remedy, including
the availability of materials and services needed to implement the chosen solution.
7. Cost addresses the estimated capital and operation and maintenance (O&M) costs,
evaluated as the present worth cost. Present worth is the present value of the capital and
future O&M costs of an alternative based on the time value of money.
Modifying Criteria
These criteria deal with support agency and community response to the alternatives.
8. State Acceptance indicates whether, based on its review of the FS, the previous ROD
and ROD amendments, and the Proposed Plan, the support agency (in this case, the
OEPA) concurs with, opposes, or has no comment on the recommended alternative.
9. Community Acceptance is assessed in the Record of Decision based upon a review of
the public comments received on the FS report, the previous ROD and ROD
amendments, and the Proposed Plan.
The nine criteria were used to evaluate and compare the options for the remediation of Lagoons
1-4 and Lagoon 5.
EVALUATION OF REMEDY FOR LAGOONS 1-4
The two options considered for remediation of Lagoons 1-4 were:
In-situ bioremediation; and
Excavation of materials above 97 ppm-PAHc ("hot spot excavation") and subsequent
wetland development.
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Threshold Criteria
1. Overall Protection of Human Health and the Environment
Both options are protective of human health and the environment. If in-situ bioremediation can
achieve the original .97 or the alternative 97 ppm PAHC cleanup standard it is protective. Hot
spot excavation of approximately 6,800 cubic yards of material in Lagoons 1-4 will achieve the
alternative cleanup standard of 97 ppm as described in the 1990 ROD for the CPLA operable
unit. In addition, wetland development as part of the excavation option will contribute to
valuable ecological habitat, while continuing ecological studies will over time demonstrate
protection to ecological receptors. The 97 ppm cleanup standard will also result in residual risks
within U.S. EPA's acceptable risk range (IXIO'MXIO"6) based on a direct contact exposure to a
future resident, even though this type of land use is not reasonably anticipated in the future.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Compliance with applicable or relevant and appropriate requirements (ARARs) must be met for
each option. The original selected remedy, as described in the 1990 ROD for the CPLA operable
unit, component of in-situ bioremediation, complied with all ARARs, except for those that
required waivers. ARARs requiring waivers for the in-situ bioremediation, are listed in the 1990
ROD and include:
OAC 3745-57-03, Landfill Design and Operating Requirements. For in-situ
bioremediation leaving hazardous waste in place, does not specifically meet the
requirements of this rule; and
OAC 3745-54-18, Location for Hazardous Waste Facilities. In-situ bioremediation
involves leaving hazardous waste on-site in areas that do not meet Ohio's siting
requirements.
For the hot spot excavation/wetland development option off-site treatment or disposal in a
landfill would require compliance with the State's regulatory equivalent of RCRA 40 CFR Part
261, Toxicity Characteristics. Toxicity characteristic leaching potential (TCLP) testing and
analysis will help determine the off-site treatment or disposal destination of the excavated soils.
Ohio Revised Code (ORC) 3724-03 Open Burning and Dumping, OAC 3745-27-05 Authorized,
Limited, and Prohibited Solid Waste Disposal Methods, and OAC 7345-54-13 general Waste
Analysis are applicable to off-site disposal. Any fuel blending of hazardous waste conducted on-
site in order to meet operational and material handling parameters for off-site treatment facilities
will need to meet the substantive requirements for tanks set forth in 40 CFR Part 264 Subpart J.
These regulations deal primarily with the design of the tank and require that any tank in which
hazardous waste is placed must have sufficient structural integrity and corrosion protection such
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that it will not rupture, collapse, or leak. If the material in the tank contains free liquid by the
paint filter test, SW-846 Method 9095, the requirements under the state equivalent of §264.193
for secondary containment and leak detection systems and the requirements for ignitable wastes
under §264.198 will also apply.
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Off-site disposal for excavated soils which do not pass the TCLP will also require compliance
with the CERCLA Off-site Rule, 40 CFR 300.440, rules for Transporters of Hazardous Waste,
40 CFR Part 263, and the Land Disposal Restrictions of 40 CFR Part 268. Waste which contains
CERCLA hazardous substances or pollutants or contaminants must be managed in a U.S. EPA
approved facility. If this waste is disposed of outside the United States, the rules pertaining to
Export of Hazardous Waste, 40 CFR Part 262 Subpart E, will apply rather than the Land
Disposal Restrictions.
Primary Balancing Criteria
3. Long-term Effectiveness and Permanence
Both options meet the requirements of Long-term Effectiveness and Permanence. Hot spot
excavation will quickly reduce the PAHg contamination to achieve the alternative 97 ppm PAHC
cleanup standard that would minimize risk to public health and the environment over the long-
term. For in-situ bioremediation, even though it may be difficult, over the long-term and given
enough time it may be possible to achieve either the original .97 ppm PAHC or the alternative 97
ppm PAHC cleanup standards. Ecological studies of the wetland restoration over time would
ensure that the habitat continues to pose no ecological threat.
4. Reduction of Toxicitv. Mobility or Volume Through Treatment
In-situ bioremediation fully meets the criterion for reduction of Toxiciry, Mobility or Volume
Through Treatment. Hot spot excavation and wetland development partially meets the criterion.
Off-site disposal of excavated soils would not reduce toxicity, mobility, or volume through
treatment. However, wetland development could potentially reduce low levels of contamination
left after excavation by natural filtering processes occurring within the wetland.
5. Short-term Effectiveness
In-situ bioremediation is partially effective in the short-term, while hot spot excavation is an
effective short term solution. Both require excavation 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. In-situ bioremediation is considered less effective in the short-term because it will
take a number of years to clean Lagoons 1-4 to either the original .97 ppm PAHC or the
alternative 97 ppm PAHC clean-up standards. Excavation and off-site disposal is effective in the
short term because it removes the contaminated soils immediately.
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6. Implementabilitv
Hot spot excavation and wetland development fully meets the criterion for Implementability.
Excavation is known, easily applied engineering, while wetland development will require no
specific technology. However, in-situ bioremediation would be more difficult to implement due
to difficulty in distributing oxygen and nutrients through a series of trenches to the
microorganisms in the soils. The in-situ bioremediation pilot tests conducted at the site
identified this implementation problem. Results of the pilot tests indicate that in-situ
bioremediation may not actually be able to achieve the original .97 ppm PAHC or the 97 ppm
PAHC alternative cleanup standard in a timely manner.
7. Cost
The cost of the in-situ bioremediation is $30 million. The cost of excavation and wetland
development is $1.2 million. The cost saving for changing the remedy from in-situ
bioremediation to hot spot excavation and wetland development in Lagoons 1-4 is approximately
$29 million.
Modifying Criteria
8. State Acceptance
The Ohio Environmental Protection Agency (Ohio EPA) supports the hot spot excavation and
subsequent wetland development in Lagoons 1-4.
9. Community Acceptance
Only public comments in support of the proposed plan were received during the public comment
period.
EVALUATION FOR LAGOON 5 REMEDY
The four options considered for remediation of Lagoon 5 included:
1. On-site incineration of Lagoon 5 and the tarry soils;
2. Construction of a RCRA Subtitle C containment cell in Lagoon 2 for the 122,000 cubic
yards of material in Lagoon 5 and the tarry soils;
3. Recycle back to coke plants the soft tar, which is classified as KO87 with the remaining
coal/coke fines and hard tar in Lagoon 5 being used as an alternative fuel. If it appears
that the capacity is not available at coke plants to recycle the K.O87, treatment and/or
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disposal of the material off-site in an approved hazardous waste facility might be
necessary. The 8,800 cubic yards of tarry soils on top of Lagoon 5 will be separated by
screening into three types of material (tar, debris, and product for use in cement kilns).
The tar will be used as an alternative fuel. The debris, which consists of clean brick and
concrete, will be placed back on-site into the excavated Lagoon 5. Additional product
from the tarry soils will be sent to cement kilns for use in their processes.; and
4. Recycle back to coke plants the soft tar (KO87) and cap the remaining material in Lagoon
5.
Threshold Criteria '
1. Overall Protection of Human Health and the Environment
All four options are protective of human health and the environment. By utilizing containment
or excavation and treatment all four options will provide protection from contamination in
Lagoon 5, containment by preventing exposure to the contaminants and excavation by removing
the contaminants.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Compliance with applicable or relevant and appropriate requirements (ARARs) must be met for
all four options. Option 1 and 3 comply with all ARARs. Option 2 does not comply with OAC
3745-54-18, Location for Hazardous Waste Facilities. Option 4 does not comply with OAC
3745-27-07, Other Criteria for Solid Waste Disposal Facilities. Both options involve siting a
containment unit in a floodplain. Because Options 2 and 4 do not comply with ARARs they will
not be carried forward through the analysis.
For Options 1 and 3 off-site disposal in a landfill would require compliance with the State's
regulatory equivalent of RCRA 40 CFR Part 261, Toxicity Characteristics. Toxicity
characteristic leaching potential (TCLP) testing and analysis will help determine the off-site
disposal destination of the excavated soils. Ohio Revised Code (ORC) 3724-03 Open Burning
and Dumping, OAC 3745-27-05 Authorized, Limited, and Prohibited Solid Waste Disposal
Methods, and OAC 7345-54-13 General Waste Analysis are applicable to off-site disposal. Any
fuel blending of hazardous waste conducted on-site in order to meet operational and material
handling parameters for off-site treatment facilities will need to meet the substantive
requirements for tanks set forth in the state equivalent of 40 CFR Part 264 Subpart J. These
regulations deal primarily with the design of the tank and require that any tank in which
hazardous waste is placed must have sufficient structural integrity and corrosion protection such
that it will not rupture, collapse, or leak. If the material in the tank contains free liquid by the
paint filter test, SW-846 Method 9095, the requirements under the state equivalent of §264.193
for secondary containment and leak detection systems and the requirements for ignitable wastes
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under the state equivalent of §264.198 will apply.
Off-site disposal for excavated soils which do not pass the TCLP will also require compliance
with the CERCLA Off-site Rule, 40 CFR 300.440, rules for Transporters of Hazardous Waste,
40 CFR Part 263, and the Land Disposal Restrictions of 40 CFR Part 268. Waste which contains
CERCLA hazardous substances or pollutants or contaminants must be managed in an U.S. EPA
approved facility. If this waste is disposed of outside the United States, the rules pertaining to
Export of Hazardous Waste, 40 CFR Part 262 Subpart E, will apply rather than the Land
Disposal Restrictions.
Primary Balancing Criteria '
3. Long-term Effectiveness and Permanence
Options 1 and 3 meet the requirements of Long-term Effectiveness and Permanence. Both
require excavation which will eliminate the contamination from Lagoon 5.
4. Reduction of Toxicity. Mobility or Volume Through Treatment
Option 1 would reduce toxicity, mobility, or volume through incineration of the materials in
Lagoon 5. Option 3 would reduce toxicity, mobility, or volume through any recycling of KO87
materials and the use of the other materials as an alternative fuel.
5. Short-term Effectiveness
Options 1 and 3 are effective in the short-term. Engineering controls exist to control impacts to
public health and the environment due to volatization of any wastes during excavation in Options
1 and 3. Off-site recycling in Options 3 is effective in the short term because it removes the
contaminated soils immediately.
6. Implementabilitv
Options 1 and 3 are fully implementable. Excavation is known, easily applied engineering.
Incineration is a proven technology at many sites. Recycling or off-site treatment and/or
disposal facilities that can accept the materials from Lagoon 5 and currently have the capacity to
handle the volume of material anticipated from Lagoon 5 exist.
7. Cost
Present worth costs for Option 1 are $30.7 million. Option 3 present worth costs are $ 9 million.
The cost savings in changing the remedy for Lagoon 5 from Option 1 incineration to Option 3
recycling/alternative fuels is approximately $22 million.
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Modifying Criteria
8. State Acceptance
The Ohio Environmental Protection Agency (Ohio EPA) supports Option 3 for remediation of
Lagoon 5.
9. Community Acceptance
Only public comments in support of the proposed plan were received during the public comment
period.
IV. DESCRIPTION OF THE SELECTED ALTERNATIVE
The selected revision for the 457,000 cubic yards of waste material in Lagoons 1-4 includes hot
spot excavation and wetland development. The hot spot excavation includes the use of an
alternative cleanup standard for carcinogenic PAIL, established in the 1990 ROD for the CPLA
operable unit. The 1990 ROD provided an alternative cleanup standard of 97 ppm for PAH,, if
the chosen remedy of in-situ bioremediation could not achieve the original cleanup standard of
0.97 ppm in a timely manner. The selected change would achieve the 97 ppm alternative
cleanup standard with hot spot excavation of approximately 6,800 cubic yards of material.
Coal/coke fines and hard tar discovered during the excavation of Lagoons 1-4 will be used as an
alternative fuel. Soil from the excavation will be disposed of off-site in a solid waste landfill if
the material is non-hazardous. If coal/coke fines, hard tar, or soils are determined to be
hazardous they will be treated and/or disposed of appropriately.
After excavation, a wetland ecology will be developed in the Lagoon area. To ensure that the
material remaining after the excavation is protective of ecological receptors, a wetland
development workplan and yearly ecological reconnaissance will be required.
The selected revision of the incineration of material from Lagoon 5 includes recycling of soft tar
back to coke plants, incineration of hard tar, off-site disposal of hard tar and debris commingled
with soft tar at an approved hazardous waste landfill, and the use of the remaining coal/coke fines
as an alternative fuel. Lagoon 5 contains soft tar and hard tar along with coal/coke fines and
debris. The soft tar, which is a tar decanter sludge from the coke plants, is KO87 listed waste.
Pursuant to RCRA regulations, KO87 listed waste may be recycled back to coke plants. If it
appears that capacity is not available at coke plants to recycle the KO87, and the soft tar cannot
be recycled, it will be treated and/or disposed off-site in an approved hazardous waste facility.
Hard tar will be sent to an electric utility incinerator. Prior to shipment, testing must demonstrate
that the hard tar is non-hazardous through the use of the Toxicity Characteristic Leaching
Potential (TCLP) test. Some hard tar may be blended on-site to meet operational and material
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handling requirements of the incinerator facility. Any fuel blending of hazardous waste
conducted on-site in order to meet operational and m-terial handling parameters for off-site
treatment facilities will need to meet the substantive requirements for tanks set forth in the state
equivalent of 40 CFR Part 264 Subpart J. These regulations deal primarily with the design of the
tank and require that any tank in which hazardous waste is placed must have sufficient structural
integrity and corrosion protection such that it will not rupture, collapse, or leak. If the material in
the tank contains free liquid by the paint filter test, SW-846 Method 9095, the requirements
under the state equivalent of §264.193 for secondary containment and leak detection systems and
the requirements for ignitable wastes under the state equivalent of §264.198 will also apply.
Large debris and hard tar commingled with soft tar that does not meet the acceptance criteria of
the recycling facility will be disposed off-site at an approved hazardous waste landfill. The
coal/coke fines present in Lagoon 5 will be used as an alternative fuel for boilers. Prior to its
use as an alternative fuel, testing must demonstrate that the fines are non-hazardous through the
use of the Toxicity Characteristic Leaching Potential (TCLP) test. If the alternative fuel is
hazardous, it will be treated and/or disposed in an approved hazardous waste facility.
Uncontaminated brick and concrete uncovered during the excavation of Lagoon 5 will be used as
clean fill in Lagoon 5. Other types of debris discovered during the excavation will be disposed
of off-site in an approved landfill.
The 8,800 cubic yards of tarry soils on top of Lagoon 5 will be separated by screening into three
types of material (tar, debris, and product for use in cement kilns). The tar will be used as an
alternative fuel. The debris, which consists of clean brick and concrete, will be placed back on-
site into the excavated Lagoon 5. Additional product from the tarry soils will be sent to cement
kilns for use in their processes. Other types of debris excavated from Lagoon 5 will require
disposal off-site in a landfill. The 30,000 cubic yards of site soils which was excavated near the
former coke plant will also be placed in the Lagoon 5 excavation to achieve grade for the wetland
development.
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 new information that the materials in Lagoons 1-4 are not as
contaminated as previously thought and that the bioremediation will not achieve clean-up in a
timely manner, changing the remedy for Lagoons 1-4 to hot spot excavation and wetland
development is justified. Hot spot excavation is readily implementable and will achieve the
alternate cleanup standard identified in the 1990 ROD for the CPLA operable unit in a
substantially shorter timeframe than bioremediation.
The remedial options for lagoons 1-4 are roughly equivalent in complying with the nine criteria,
with the selected option slightly preferable. Both are protective and comply with ARARs.
While the hot spot excavation and wetland development only partially meets the criteria for
Reduction of Toxicity, Mobility, and Volume Through Treatment, the removal, off-site disposal,
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13
and wetland development are effective technologies that are readily implementable as opposed to
in-situ bioremediation, which is difficult to implement and, based on pilot studies, questionably
effective. In addition, cost savings associated with the change are substantial, with the hot spot
excavation and wetland development potentially more effective in reducing contamination at a
reduced cost.
For Lagoon 5 waste material, the incineration and recycling/alternative fuels options fully meet
all the criteria and are comparable; however, the recycling/alternative fuels option is easier to
implement, can be completed in a timeframe that is two years'shorter than incineration, and
result in a cost savings of over $20 million. The recycle option also treats and disposes of the
Lagoon 5 material off-site which is easier to implement than incineration on-site. Therefore,
modifying from the incineration option to the recycling/alternatives fuels option is justified.
Off-site disposal and treatment of soils from Lagoons 1-5 is protective of human health and the
environment since the soils will be managed in appro /ed facilities. Remaining soils will meet
the PAHC alternative cleanup standard or be at a depth which will not affect human health or the
environment. The use of recycling, treatment and/or disposal of the Lagoon 5 materials does
satisfy the statutory preference for treatment as a principal element of the remedy and employs
permanent solutions and alternate treatment technologies to the maximum extent possible.
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
Lagoon soils. Disposal of soils containing CERCLA hazardous substances must meet the
CERCLA Off-Site Disposal Rule, 40 CFR 300.440 and the Land Disposal Restrictions, 40 CFR
Part 268. If this waste is disposed of outside the United States, the rules pertaining to Export of
Hazardous Waste, 40 CFR Part 262 Subpart E, will apply rather than the Land Disposal
Restrictions. In addition, any fuel blending of hazardous waste conducted on-site in order to
meet operational and material handling parameters for off-site treatment facilities will need to
meet the substantive requirements for tanks set forth in the state equivalent of 40 CFR Part 264
Subpart J. These regulations deal primarily with the design of the tank and require that any tank
in which hazardous waste is placed must have sufficient structural integrity and corrosion
protection such that it will not rupture, collapse, or leak. If the material in the tank contains free
liquid by the paint filter test, SW-846 Method 9095, the requirements under the state equivalent
of §264.193 for secondary containment and leak detection systems and the requirements for
ignitable wastes under the state equivalent of §264.198 will also apply. The two changes
outlined in ROD Amendment #3 could result in a total savings of approximately $50 million.
VI. DOCUMENTATION OF SIGNIFICANT CHANGES
One of the provisions of the Proposed Plan for ROD Amendment #3 addressed the type of
treatment for the material from Lagoon 5. Some of the material in Lagoon 5, specifically the soft
tar, K.O87, has been identified by the U.S. EPA as a principal threat, and the preference is for
treatment of these materials. The Proposed Plan recommended the recycling of soft tar back to
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14
coke plants and the use of the remaining coal/coke fines and hard tar as alternative fuel. The
Proposed Plan also identified that, if the soft tar could not be recycled, due to capacity at coke
plants or other reasons, the soft tar would be treated and/or disposed off-site in an approved
hazardous waste facility.
During the development of ROD Amendment #3, the potentially responsible party pursued
contracting for the recycling option as well as incineration (offsite or onsite) of the KO87 soft tar
waste. The contracting activities determined that the capacity of the facilities which could accept
the soft tar was so limited that recycling could take from 4 to 6 extra years to complete and that
incinerating the soft tar could take from 2 to 2 V* extra years to complete. As a result, soft tar
would need to be stored on site for long periods, and the completion of the remedy would be
substantially delayed. In addition, the potential high ash content of the soft tar due to its mixing
with other debris in the Lagoon 5 landfill, resulted in many of the off-site recycling and
commercial incinerator hazardous waste facilities being unable to accept the material because of
their quality specifications. As a consequence, U.S. EPA estimates that a portion of the soft tar
cannot actually be recycled.
To examine recycling and treatment options further the responsible party excavated about 20 yd3
of tar material from Lagoon 5 to have it analyzed by the few recyclers and treatment facilities that
expressed interest in accepting the materials. During the excavation it was discovered that
separating the soft and hard tar was more difficult than originally anticipated. However, the
responsible party was able to separate a variety of relatively unique waste streams and examined
treatment and disposal options for each. The waste streams included: "clean" soft tar, which is
primarily KO87 hazardous waste; non-commingled hard tar; large debris commingled with
KO87; "dirty" soft tar, which is KO87 waste mixed with hard tar, coal/coke fines, and ash; and
coal/coke fines. Treatment and disposal options included: the Acme Recycling Center, a coke
oven in Chicago, Illinois; a commercial cement kiln incinerator called Giant Resource Recovery
Co.; a non-hazardous electric utility incinerator called Baldwin Thermal Treatment in Baldwin,
Illinois; Safety Kleen (Laidlaw) landfill in Corunna, Canada; and alternative fuel sources for the
coal/coke fines. Representatives from these facilities visited the Ironton site to perform on-site
inspections and collect waste profiles. After visiting the site, Giant Resource Recovery was
eliminated as an option because their acceptance criteria and quality requirements could not be
met by the materials present in Lagoon 5.
After receiving feedback from each of the potential disposers, a receptor for each waste stream
was identified. "Clean" soft tar, which is KO87 waste that meets the, acceptance criteria and
quality requirements to be recycled for use in coke ovens, will be shipped to Acme. The only
limiting factor is the capacity of the recycler to accept the waste. If the recycler's capacity is
delaying the excavation, "clean" soft tar will be disposed at Laidlaw in Canada until the issues
are resolved. Non-commingled hard tar will be sent to Baldwin. Prior to shipment, testing
must demonstrate that the hard tar is non-hazardous through the use of the Toxicity
Characteristic Leaching Potential (TCLP) test. Some hard tar may be blended on-site to meet
operational and material handling requirements of the incinerator facility. Large debris
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15
commingled with KO87 will be sent to Laidlaw. "Dirty" soft tar will be sent to Acme unless it
does not meet their acceptance criteria and quality requirements, i.e. fine contents and debris size,
in which case it will disposed off-site at Laidlaw. Coal/coke fines, which is the bulk of material
in Lagoon 5, as mentioned previously, will be used as an alternative fuel. Presently, there are a
number of facilities interested in and have the capacity to handle the coal/coke fines.
The ARARS for this modification of ROD Amendment #3 remain those described in the
discussion of ARARS for that ROD Amendment.
Therefore, U.S. EPA is clarifying the remedy selected in ROD Amendment #3 to off-site
recycling of the "clean" soft tar at the Acme facility. Hard tar will be treated off-site at the
Baldwin facility. Coal/coke fines will be used as an alternative fuel. The remaining material
including large debris commingled with KO87 waste and "dirty" soft tar which fails to meet the
specifications for recycling will be disposed off-site in compliance with State and Federal
hazardous waste regulations. It is currently anticipated that this last category of material would
be sent to a facility operated by Laidlaw Corporation in Corunna, Canada. As part of the off-site
disposal at the Canadian facility, following stockpiling of the material, samples will be collected
for analytical testing for parameters required by the disposal facility. These tests will be
performed to determine a 15 psi penetration. This is a compressibility standard established by
the facility to aid in material placement options. It may become necessary to stabilize the
material to meet the compressibility standard and because at different times during the removal
of the soft tar handling the material may be difficult due to warm weather and fluidity of the tar.
Cement or fly ash will be added as a stabilizing agent. The stabilization will generally be
performed in the lagoon area; however, it may become necessary to perform the mixing process
in vessels near where the soft tar material will be stockpiled for shipment.
This modification in the selected remedy will not fundamentally alter the selected remedy with
respect to scope, performance or cost. The same amount of soft tar, hard tar, and coal/coke fines
will be removed from Lagoon 5 and managed off-site. Lagoon 5 will still be excavated, some
soft tar will be recycled, the hard tar will still be treated, coal/coke fines will still be used as an
alternative fuel, and uncontaminated debris will still be used either in cement kilns or placed
back on-site into the excavated Lagoon 5, as approved in ROD Amendment #3.
Although the off-site disposal of some of the soft tar only partially meets the criteria for
reduction of toxicity or volume through treatment, it does provide greater short term
effectiveness and is more implementable than recycling and incineration. The requirements for
off-site disposal can be easily met, eliminating concerns with the "quality" of the soft tar and its
acceptability at a recycling facility. In addition, the schedule for completion of the selected
remedial action will be maintained. The modification to off-site disposal is in compliance with
ARARs and the State of Ohio has been informed of the modification and concurs. On-site
blending of hard tar to meet operation and material handling requirements of the off-site
incinerator will meet the substantive requirements of the state equivalent of 40 CFR Part 264
Subpart J. Overall cost and timeframes of the project are hard to estimate given the various
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16
waste streams and treatment/disposal options. Some recent figures submitted by the PRP which
examined the costs of incineration, recycling, or off-site disposal of just the soft tar material
ranged from $5.9 million for the off-site disposal to $8.1 million for incineration. Costs are
expected to fall within this range. Timeframes were also examined and ranged from 13 months
to complete to 2 years for the incineration and over 5 years for the recycling option. Timeframes
are expected to fall between 13 months and 2 years.
Information pertaining to this modification will become part of the administrative record file
located at Briggs Lawrence County Library, located in Ironton, Ohio.
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DRAWN I CS
LAGOON 3
COKE
AR
COKE PLANT AND
LAGOON AREAS
PREPARED FOR
ALLIEDSIGNAL INC.
MORRISTOWN. NEW JERSEY
INTERNATIONAL
TECHNOLOGY
CORPORATION
© t984 IT CORTOR* T\0n
LL COPYRIGHTS RESERVED
Do Mol Scd4 Dik OrairXg'
-------
0.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
ALLIED CHBMICAL/IRONTON COKE SUPBRFUND SITE
IRONTON, LAWRENCE COUNTY, OHIO
OPERABLE UNIT #2: COKE PLANT/LAGOON AREA
UPDATE #9
DECEMBER 3, 1997
NO. DATE
1 00/00/00
AUTHOR
AlliedSignal,
Inc.
RECIPIENT
U.S. EPA
PAGES
00/00/(J£ AlliedSignal, U.S. EPA
3 00/00/00
4 00/00/00
5 00/00/00
AlliedSignal,
Inc.
AlliedSignal,
Inc.
AlliedSignal,
Inc.
U.S. EPA
U.S. EPA
U.S. EPA
6 00/00/00
7 06/22/92
U.S. EPA
Federal
Register
File
Public
Drawing: Ironton Coke
Plant Lagoon No. 5
Field Characterization:
Visual Analysis of
Tar Materials
.Dcauing: Ironton Coke
Plant LagJon No. 5
Field Characterization:
Boring Locations
Drawing: Ironton Coke
Plant Lagoon No . 5
Field Characterization:.
Benzene Analysis of
Materials
Drawing: Ironton Coke
Plant Lagoon No. 5
Field Characterization:
Proposed Boring
Locations
Drawings : Ironton Coke
Plant Lagoon No. 5
Boring Locations,-
Visual Analysis of Tar
Materials; HNU Analysis
Of Materials; Benzene
Analysis of Materials
Outline re: Removal
Options and Criteria
at the Allied Chemical/
Ironton Coke Site
40 CFR Parts 261, 266,
and 271: Hazardous Waste
Management System;
Identification and
Listing of Hazardous
Waste; Exclusions; Final
Rule (FR: Vol. 57, No.
120; pp. 27880-27888)
10
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Allied Chemical/Ironton Coke AR
Operable Unit *2
Update #9
Page 2
DAIB
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
8 08/18/92 Federal
Public
08/09/96
10
08/23/96
Lewis, M.,
AlliedSignal,
Inc.
Ford, R.,
AlliedSignal,
Inc.
11
12
09/30/96
11/11/96
Ohio EPA
Lewis, M.,
AlliedSignal,
Inc.
13
11/13/96
14
11/21/96
Lewis, M.,
AlliedSignal,.
Inc.
Ford, R.,
AlliedSignal,
Inc.
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
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 E-PA
40 CFR Parts 261 et al: 24
Identification and
Listing of Hazardous
Waste; CERCLA Hazardous
Designation; Reportable
Quality Adjustment;
Coke By-Products Waste
(FR: Vol.57, No. 160;
pp. 37284-37306)
Letter: K087 Remediation 4
Alternative Costs for
the Coke Plant/Lagoon
_ Operable Unit at
e AllieH" Chemical/
Ironton Coke Site
Letter re: Allied's 20
Request for U.S. EPA/
OEPA's Review of
Attached Peti tion .to
Amend the Record of
Decision for the
Ironton Coke Plant
CP/LA Operable Unit
Construction and 108
Demolition Debris Rules
(Chapters 3745-37 and -
3745-400 of the Ohio
Administrative Code)
Letter Forwarding 2
Attached Drawing re:
Conceptual Design of
a Hazardous Waste Cell
in Lagoon 4 at the
Allied Chemical/Ironton
Coke Site
Letter re: Access Road 2
Between the Cell and
Floodwall Berm at the
Allied Chemical/Ironton
Coke Site w/Attached
Drawing
Letter Forwarding 2
Attached Table re:
Cost Estimates for
Lagoon 5 Options at the
Allied Chemical/Ironton
Coke Site
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Allied Chemical/Ironton Coke AR
Operable Unit #2
Update #9
Page 3
HO.
15 11/21/96
16
12/13/96
17
AUTHOR
Ford, R.,
AlliedSignal,
Inc.
Ford, R.,
AlliedSignal,
Inc.
Bewis,"M.,
AlliedSignal,
Inc.
18
01/17/97
19
02/20/97
Arbesman, P.,
AlliedSignal,
Inc.
AlliedSignal,
Inc.
20
03/13/97
U.S. EPA
21
03/14/97
Internat ional
Technology
Corporation
RECIPIENT
A]cano, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Alcamo, T.,
U.S. EPA
TITLB/DB9CRIPTION PAGES
Muno, W.,
U.S. EPA
U.S. EPA
File
U.S. EPA
Letter Forwarding
Attached Table re:
Carcinogenic PAH Levels
within Lagoons 1-4 at
the Allied Chemical/
Ironton Coke Site
Letter Forwarding
Attached Drawing re:
Proposed Lagoon 5 Area
Cell at the Allied
Chemical/Ironton Coke
Site
'COVer Letter Forwarding
Boring Logs, Trench Logs,
Boring and Trench
Location Drawing and
Photographs from the
August 1993 WFR Predesign
Investigation at the
Allied Chemical/Ironton
Coke Site
Letter re: Allied's
Petition to Amend the
Record of Decision for
the Allied Chemical/
Ironton Coke Site
Drawing: Proposed
Sampling Locations for
the Lagoon Materials
Delineation Program at
the Allied Chemical/
Ironton Coke Site
Outline of Proposed
Lagoon 5 Field Charac-
terization at the
Allied Chemical/Ironton
Coke Site (DRAFT)
Letter Forwarding
Attached Draft Lagoon
Materials Delineation
Workplan for the Coke
Plant/Lagoon Area at
the Allied Chemical/
Ironton Coke Site
16
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Allied Chemical/Ironton Coke AR
Operable Unit #2
Update #9
Page 4
22
PATH
03/31/97
AOTHOR
Shott, D.,
International
Technology
Corporation
23 06/23/97
Ford, R.,
AlliedSignal,
Inc.
24
07/15/97
Alcamo, T.,
U.S. EPA
25
08/13/97
26
08/28/97
27
10/03/97
Shott, D.,
International
Technology
Corporation
Shott, D.,
International
Technology
Corporation
Alcamo, T.,
U.S. EPA
28
10/14/97
Lewis, M.,
AlliedSignal,
Inc.
RBCIPTJHMT
Alcamo, T.,
U.S. ^PA and
K. Gilmer,
Ohio EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Ford, R.,
AlliedSignal,
Inc.
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA '
U.S. EPA
Gilmer, K.,
Ohio EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
TITLK/D83CRIPTION PAGES
Letter Forwarding 3
Attached (1) Revised
Page 1 and (2) Revised
Figure 1: Proposed
Sampling Locations for
the Draft Lagoon
Materials Delineation
Workplan for the Allied
Chemical/Ironton Coke
Site
Letter Forwarding 8
Attached (1) Revised
Table 3: Lagoon 1-4
.SxM^jle Points and (2)
Sample Location Map
for the AlliedSignal
Coke Plant/Lagoon Area
Site
Letter re: the Lagoon 2
Area Carcinogenic Poly-
Nuclear Aromatic Hydro-
Carbons (PAH) Data Table
for Lagoons 1-4 at the
Allied Chemical/Ironton
Coke Site
Letter Forwarding 7
Attached Revised PAH
Data Table and Sample
Location Map for the
Allied Signal Coke
Plant/Lagoon Area Site
Letter Forwarding 23
Attached Summary of
Data from the May-June
1997 Lagoon No 5 Field
Characterization Program
at the Allied Chemical/
Ironton Coke Site
Letter re: Tar Decanter 3
Sludge (K087) within
Lagoon 5 and Different-
iating Between Hard Tar
and Soft Tar at the
Allied Chemical/Ironton
Coke Site
FAX Transmission 4
Forwarding Attached
October 7, 1997 Draft
Meeting Notes re:
AlliedSignal/Ironton
Coke Site
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Allied Chemlcal/Ironton Coke XR
Operable Unit ft 2
Update #9
Page 5
NO. PATH
29 10/27/97
30 10/28/97
31 10/29/9.7
MOTOR.'
Lewis, M.,
AlliedSignal,
Inc.
Ford, R.,
AlliedSignal,
Inc.
Lewis, M.,
AlliedSignal,
Inc.
32 11/04/97 Moschell, M.,
Ohio EPA
33
11/05/97
34
11/10/97
Shott, D.,
International
Technology
Corporation
Muno, w.,
U.S. EPA
35 12/01/97 Lewis. M.,
AlliedSignal,
Inc.
RKCIPTBNT
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Alcamo, T.,
U.S. EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Gilmer, K.,
Ohio EPA
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
Arbesman, P.,
AlliedSignal,
Inc.
Alcamo, T.,
U.S. EPA and
K. Gilmer,
Ohio EPA
TITIiH/DBSCmPTION
Letter re: Tarry Soils
Pile at Lagoon 5 at the
Allied Chemical /Ironton
Coke Site
Letter re: Origin of
Waste Tar in Lagoon 5
at the Allied Chemical/
Ironton Coke Site
PAijBS
.
Forwarding"" Attached
Table re : Summary of
Hazardous Characteristic
Testing for Tarry Soils
at the Allied Chemical/
Ironton Coke Site
Memorandum re: Allied's '
Hazardous Waste Determin-
ation for Hard Tar at
the Allied Chemical/
Ironton Coke Site
Letter re : Summary of
the May 27 - June 12,
1997 Lagoon No. 5 Field
Characterization Program
at the Allied Chemical/
Ironton Coke Site
Letter re: U.S. EPA's
Review of Allied's
August 23, 1996 Petition
to Amend the December
1990 Record of Decision
for the Coke Plant/
Lagoon Area at the
Allied Chemical /Ironton
Coke Site
\
Letter re: Estimated
Costs for the Allied
Chemical /Ironton Coke
Site w/Attached Lagoon
No. 5 Proposed Final
Grading Plan Drawing
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U.S. ENVIRONMENTAL PROTECTION AGENCY
ADMINISTRATIVE RECORD
FOR
ALLIED CHEMICAL/IRONTON COKE SITE
OPERABLE UNIT #2
IRONTON, LAWRENCE COUNTY, OHIO
UPDATE #10
SEPTEMBER 29, 1998
NO. DATE
1 12/00/97
2 07/21/98
3 09/16/98
4 00/00/00
AUTHOR
U.S.. EPA
Hunt, M. ,
AlliedSignal,
Inc.
Hunt, M.,
AlliedSignal,
Inc.
U.S. EPA
RECIPIENT
Public
Mankowski, M.,
U.S. EPA
Mankowski, M.,
U.S. EFA
Public
T, ITT.H /OBSCRIPTIQN PAGES
Fact Sheet: Proposed 12
ROD Amendment #3 for
the Allied Chemical/
Ironton Coke Site
Letter re: Lagoon 2/5 21
Remediation at the Allied
Signal/Ironton Coke Site
w/ Attachments
Letter re: Lagoon 2/5 90
Remediation (Tar Excava-
tion/Disposal) at the
AlliedSignal/Ironton
Coke Site w/ Appendices
I-XI)
Record of Decision Amend-
ment for Operable Unit
#2 at the Allied Chemical/
Ironton Coke Site
(PENDING)
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