PB95-963154
                             EPA/AMD/R05-95/282
                             February 1996
EPA  Superfund
      Record of Decision Amendment:
      Allied Chemical/Ironton Coke
      Superfund Site, Ironton,  OH
      7/31/1995

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                  RECORD OF DECISION AMENDMENT
          ALLIED CHEMICAL/IRONTON COKE SUPERFUND SITE
                           IRONTON, OHIO
Valdas V. Adamkus
Regional Administrate/
Date

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                      RECORD OF DECISION AMENDMENT

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. A waste pit called the Goldcamp
Disposal Area is also part of the site. In addition, 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/remedial action (RD/RA) for the  GDA is through
a Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by  the Superfund Amendments and Reauthorization Act (SARA) of
1986 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 through a CERCLA Section 106 Unilateral Administrative Order
which was signed on July !„ 1991 and was issued to AlliedSignal, Inc. The  CPLA  remedy
was finalized through the ROD signed on December 28, 1990.

During the pre-design and design of the CPLA remedy,  new information has been identified
which has resulted  hi four fundamental changes to the CPLA ROD.  Change 4 will  also
affect the GDA ROD. 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.  A Proposed Plan was published on March 6,
1995, followed by  a 30 day  public comment period which ended  on April 4, 1995.  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  hi Ironton,  Ohio. The information used in U.S. EPA's assessment of these
changes is currently available at the above repository.

H.    REASONS FOR ISSUING THE ROD AMENDMENT

During the pre-design and design for the CPLA, new information was discovered hi which
fundamental changes to the original CPLA and GDA ROD's are required.  This ROD
Amendment documents four fundamental changes that will affect the CPLA ROD and one of
the four changes that will affect the GDA ROD.

The remedy as described hi  the original ROD for the GDA operable unit consists of the

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following:

       •     Installation of a Resource Conservation Recovery Act (RCRA) Subtitle C
             compliant cap over the waste pit.

       •     Construction of a slurry wall around the waste pit to limit infiltration of
             groundwater into the waste pit.

       •     Continuous extraction and on-site treatment of groundwater within the slurry
             wall/cap system.

       •     Extraction and on-site treatment of contaminated groundwater outside the
             slurry wall/cap containment system until groundwater cleanup standards have
             been met.  Implementation of deed restrictions, fencing, and security.

Construction of the GDA remedy is scheduled to be completed in August 1995 and operation
and maintenance of the slurry wall/cap and groundwater pump and treatment system is
expected to occur for thirty years.  The cost of the GDA remedy including capital cost  and
operation and maintenance is approximately $28 million over the life of the project.

The original CPLA ROD selected the following remedy:

       •     Incineration of approximately 122,000 cubic yards of lagoon waste materials
             and on-site re-use of the waste  heat  generated during incineration (Waste Fuel
             Recovery).

       •     In-situ bioremediation of approximately 457,000 cubic yards of lagoon waste
             material.

       •     Prepared pad  surface bioremediation of approximately 40,000 cubic yards of
             contaminated  soil materials.

       •     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 design for the bioremediation and groundwater pump and treatment systems will be
completed hi September  1995.  Site preparation for the bioremediation and groundwater
pump and treatment systems began hi March  1995.  Construction of the bioremediation and
groundwater pump and treatment system is scheduled to be completed hi late 1996.  The
bioremediation and groundwater pump and treatment systems are expected to operate for
thirty years. The design of the incinerator will be completed in mid-1997 and startup is
scheduled for early 1998. The cost of the CPLA remediation is approximately $150 million

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over the life of the project.

IH.    DESCRIPTION AND EVALUATION OF THE NEW 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 for the four
fundamental changes.  The U.S. EPA uses nine evaluation criteria as set forth in the National
Contingency Plan, 40 CFR Part 300.430, to evaluate the four fundamental changes and the
different alternatives associated with each 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 of 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 Permanence refers to the amount of risk remaining
at a site and the ability  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 Toxicitv. 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 feasibility  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
a 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 comment on the recommended alternative.

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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.
                             FUNDAMENTAL CHANGE 1

Alternative 1 - Removal of the waste heat boiler from the incineration process, thereby
eliminating the production of steam for the Allied Signal Tar Plant (waste fuel recovery).

The original ROD for the CPLA required the addition of a waste heat boiler to the
incineration process to produce steam for the AlliedSignal Tar Plant located on-site.  Waste
material to be incinerated includes 122,000 cubic yards of lagoon 5 waste which contains
K087 (Decanter Tank Tar Sludge from Coking Operations) listed hazardous waste.  In
addition, approximately  30,000 cubic yards of coal/coke fines which remain from the former
coke plant will be blended with the lagoon 5 waste.

The Resource Conservation Recovery Act (RCRA) regulations state that if K087 waste
material is recycled, the ash produced by the incinerator is classified as non-hazardous.
Removing the waste heat boiler and not producing  steam for the AlliedSignal Tar Plant
therefore, removes the incinerator ash exemption as described in the RCRA 40 CFR Part
261. With the elimination of the K087 exemption,  AlliedSignal will be required to submit an
acceptable delisting petition for the incinerator ash.  A delisting petition is a document
prepared by AlliedSignal which must show that the incinerator ash no longer contains K087
waste or other compounds'at hazardous levels.  If U.S. EPA determines that the incinerator
ash is no longer hazardous, it can be disposed of in a licensed solid waste landfill instead of
a hazardous waste landfill.  Therefore, prior to beginning the incineration process, levels that
can remain in the ash will be determined to ensure that the ash is non-hazardous.
Throughout the incineration, the ash produced will be sampled and analyzed to determine if
contaminants in the ash are above the delisting levels. If the ash cannot meet the delisting
levels, the ash will not be allowed to be disposed of in a non-hazardous waste landfill
without further treatment. If AlliedSignal cannot submit an acceptable delisting petition,
other options for the incinerator ash will be explored. Removal of the waste heat boiler  will
save approximately $3 million.

Alternative 2 - No Action (Retain the waste heat boiler in the incineration process).

In this alternative, the waste heat boiler would remain in the incineration process as
described hi the December 1990 ROD.

             Fundamental Change 1 - Comparative Analysis of Alternatives

In comparing Alternative 1  (remove waste heat boiler) and Alternative 2 (retain waste heat
boiler), Criteria 1,3,4 and 5 are equivalent and have no effect on the comparative analysis.
Criteria 2 (Compliance with ARARs), Criteria 6 (Implementability), and Criteria 7 (Cost)

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affect the comparative analysis. First, removal of the waste heat boiler would affect the
incinerator ash exemption pursuant to 40 CFR 261.3(c)(2)(ii)(B) and 40 CFR 261.6(a)(3)(vii)
as described in the original ROD.   Since removal of the waste heat boiler would eliminate
the recycling of K087 waste located in lagoon 5, the incinerator ash will have to be delisted.
If the incinerator ash can be delisted, which is pursuant to AlliedSignal submitting an
acceptable delisting petition, the ash will be disposed of in a licensed  solid waste landfill.
Second, if the waste heat boiler is removed, implementability would be improved since less
maintenance would be required. Finally, cost would be reduced by approximately $3 million
if the waste heat boiler is removed.

After comparing the removal of the waste heat boiler versus retaining the waste heat boiler
through the use of the nine criteria, removal of the waste heat boiler (Alternative  1) is the
selected remedy.  The State of Ohio concurs with the removal of the waste heat boiler.
No public comments were received concerning this change.
                            FUNDAMENTAL CHANGE 2

Alternative 1 - Removal of the ROD dismantlement provision for the incinerator.

In the December 1990 ROD, the U.S. EPA required that the incinerator be dismantled after
the incineration of the lagoon 5 waste and the coal/coke fines is complete.  U.S. EPA has
now determined that there is no environmental benefit gained by the dismantling of the
incinerator, provided it is not operated after the time the incineration of the lagoon 5 waste
and the coal/coke fines is completed.  Leaving the incinerator on the site will not interfere
with any other portion of the remedy.  Therefore, there is no reason for U.S. EPA to require
that the incinerator be dismantled.  However, once the incineration is complete for the
CPLA, AlliedSignal will not be allowed to operate the incinerator for the destruction of
waste or materials from the AlliedSignal Tar Plant or other sources without obtaining an
Ohio Environmental Protection Agency (Ohio EPA) permit.  The Ohio EPA permit process
includes public  involvement in the decision making.

Alternative 2 - No Action (Retain the dismantlement provision for the incinerator).

This alternative would require AlliedSignal to dismantle the incinerator after the incineration
of the site waste material has been completed.

            Fundamental Change 2 - Comparative Analysis of Alternatives

Comparing Alternative 1 (Removal of the dismantlement provision for the incinerator) and
the No Action Alternative (Remove the incinerator after completion of incinerating the
lagoon 5 waste  and coal/coke material) all the criteria  would be equivalent except the cost of
dismantling may be higher than the cost of leaving the incinerator on-site, but not operating.
U.S. EPA will  require AlliedSignal to obtain an Ohio  EPA permit if they choose to operate

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the incinerator after the cleanup is completed.

Alternative 1 is the only choice in this comparison; therefore, the U.S. EPA is removing the
incinerator dismantlement provision.  The Ohio EPA concurs and no public comments were
received concerning this change.
                            FUNDAMENTAL CHANGE 3

During the design phase for the CPLA, approximately 135,000 cubic yards of soil located
near the former coke plant and contaminated with PAHC above the 0.97 ppm cleanup
standard  were recently identified. The newly discovered contaminated soils,  identified as
the "site soils," are estimated to have an average PAHC concentration of 20 ppm.  The site
map in Figure 1 outlines the general area of the "site soils".  Table 1 lists the soil cleanup
standards for the CPLA.
TABLE 1
SOIL/WASTE CLEANUP STANDARDS
Contaminant
Arsenic
Benzo(a)pyrene
Dibenz(a,h)anthracene
Benz(a)anthracene
Chrysene
Cleanup Standard
(Site Soils)
0.56 ppm
Total of four must be less than
0.97 ppm
Cleanup Standard
(Lagoons)

Total of four must be less
than 0.97 ppm or the
alternative wetland
standard of less than 100
ppm
The cleanup standard for soil contamination listed hi the CPLA ROD states that the sum total
of foiir carcinogenic polynuclear aromatic hydrocarbons (PAH,.) must be less than 0.97 parts
per million (ppm).  The four PAHC are benzo(a)pyrene, dibenz(a,h)anthracene,
benz(a)anthracene, and chrysene.  The area located within 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.

Alternatives to address the "site soils" are addressed below:

Alternative 1 - Excavate and store the "site soils" on the AlliedSignal property for eventual
treatment or placement into the lagoon area.

As referenced in Table 1, two cleanup standards exist for the four PAHC hi the soil/waste
located hi the lagoon area.  The two cleanup standards  for PAHC are applicable to the
bioremediation. If the bioremediation cannot achieve the 0.97 ppm cleanup standard in a

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timely manner, but can meet the 100 ppm alternate cleanup standard, then the lagoons will
be flooded with waters from Ice Creek and turned into a wetland ecosystem.  The "site soils"
contain PAHC in the range of 20 ppm: therefore, treatment of the "site soils"  will be required
if the 0.97 ppm cleanup standard can be achieved.  If the alternate  cleanup standard of 100
ppm is applied, the "site soils" will be placed into the lagoons and  further treatment will not
be required.  Approximately 5000 cubic yards of "site soils" contain PAHC greater than 100
ppm. These soils will be disposed of off-site or treated in a to be determined manner.

The "site soils" will be excavated  and stored on-site until lagoon 5  is excavated during the
incineration phase. A portion of the  "site soils" will be placed into the lagoon 5 area after
excavation is complete and remaining "site soils" will be eventually placed  into the lagoon
area.  If the alternative cleanup standard of 100 ppm is chosen,  AlliedSignal must submit a
wetland ecosystem plan to ensure that a wetland is developed.  The cost of this alternative is
$2.9 million.

Alternative 2 - Excavate  and dispose of the 135,000 cubic yards of "site soils" in an off-site
landfill.

The average concentration of the "site soils" is approximately 20 ppm for PAHC and
preliminary results indicate that the "site soils" would pass the toxicity characteristic leaching
procedure (TCLP) test and could be disposed of in an off-site Subtitle D landfill.  The
concentration of the four PAHC after excavation would be under one part per  million.  The
cost of this alternative is $6.8 million.

Alternative 3 - Excavate  and treat the 135,000  cubic yards of "site soils" in the on-site
incinerator.

The 135,000 cubic yards of "site soils" will be blended with the 30,000 cubic yards
coal/coke fines and 122,000 cubic yards of lagoon 5 waste which includes the K087 listed
waste.  The additional 135,000 cubic yards of material will extend  the incineration from
three years to six years and add $47 million to the incineration cost.

Alternative 4 - Excavate  and treat the 135,000  cubic yards of "site soils" by  bioremediation.

This alternative would use bioremediation to treat the "site soils".   The "site soils" would be
placed into the lagoons immediately and treated through in-situ bioremediation. The "site
soils" will be treated to meet the 0.97 parts per million cleanup standard.  Dependent upon
the performance of the bioremediation, the 0.97 ppm standard may not be possible due to the
limitations of the bioremediation.  The  timeframe to complete the bioremediation  is
approximately 30 years and the additional "site  soils" would not affect the 30 year
timeframe.  The cost of the additional bioremediation including operation and maintenance
would be $17 million.

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             Fundamental Change 3 - Comparative Analysis of Alternatives

A discussion on the comparison of the four alternatives to address the newly discovered  "site
soils" is discussed below;  The best balance of the nine criteria is implementing Alternative
1, which is excavate and store the "site soils" .on the AlliedSignal property for eventual
treatment or placement into the lagoon area.

Criteria 1 (overall protection human health & environment) is met by the four alternatives.
Protection is achieved  by eliminating, reducing or controlling risks through treatment or
engineering controls.

Criteria 2 (compliance with ARARs) is required pursuant to Section  121(d) and no additional
ARARS as described in the original ROD would apply for the four alternatives.

Criteria 3 (long-term effectiveness and permanence) is best achieved  through alternative 3
(incineration) and alternative 4 (bioremediation).  Alternative 2 (disposal in off-site landfill)
and Alternative 1 (placement into lagoons) also meet the criteria but  not through treatment.
Alternative  1 will use treatment through bioremediation if the 0.97 ppm cleanup standard can
be achieved. If the bioremediation cannot achieve the 0.97 ppm standard, then the direct
contact  risk will be eliminated through flooding of the lagoons and the eventual wetland
environment.

Criteria 4 (reduction in toxicity, mobility, or volume through treatment) is best met through
Alternative 3 and Alternative 4 due to treatment by incineration and bioremediation.
Alternative  1 partially  meets the criteria if the bioremediation can reach the 0.97 ppm
cleanup standard.  Alternative 2 removes the "site soils" to an off-site landfill; therefore,
treatment is not a component.

Criteria 5 (short-term effectiveness) is met by the four alternatives.  Excavation of the "site
soils" will not produce air impacts due to the low concentration of constituents present in the
soil.  Storage of the "site soils" as described in Alternative 1 will not produce air impacts
and fugitive dust will be prevented through the use of engineering controls.

Criteria 6 (implementability) is fully met by Alternative 1,2 and 3 with Alternative 4 partially
meeting the criteria. If bioremediation of the "site soils" is started immediately, movement
of the "site soils" hi the lagoon area will be difficult due the  volume of material.  In
addition, the bioremediation may not be able to achieve the 0.97 ppm cleanup standard.

Criteria 7 (cost) varies widely for the four Alternatives.  Alternative  1  is the least  expensive
at $2.9  million.  If the bioremediation can achieve the 0.97 cleanup standard, the cost will
rise significantly.  Off-site disposal hi a Subtitle D landfill is $6.8 million and the  most
expensive alternative is incineration at $47 million.  Bioremediation of the "site soils" will be
approximately $17  million.
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Criteria 8 (support agency comments) has been determined and the Ohio EPA supports
Alternative 1.

Criteria 9 (community acceptance) will be addressed in the attached Responsiveness
Summary.  No public comments were received.
                            FUNDAMENTAL CHANGE 4

Alternative 1 - Revise the cleanup standard for the 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
the new safe drinking water standards of 200 ppt for benzo(a)pyrene and 300 ppt for
dibenz(a, h)anthracene.

The original ROD calculated a cleanup standard for benzo(a)pyrene and
dibenz(a,h)anthracene of 5 parts per trillion total  for both compounds.  The 5 ppt cleanup
standard was calculated through a risk assessment since drinking water standards had not
been developed at that time.  Drinking water standards called Maximum Contaminant Levels
(MCLs) for benzo(a)pyrene and dibenz(a,h)anthracene have now been developed through the
Safe Drinking Water Act. The MCL is U.S. EPA's maximum permissible level of a
contaminant in drinking water delivered to the public.  These levels are based upon several
factors,  including health effects and technology available to remove contaminants from
drinking water.  The MCLs for benzo(a)pyrene and dibenz(a,h)anthracene are 200 parts per
trillion and 300 parts per trillion respectively.  Nonaqueous phase substances (NAPS) are
present at the GDA, under and outside of the waste pit.  As described in the original ROD
for the GDA, the groundwater compliance boundary is the  edge of the GDA waste pit, just
outside the containment system.  This ROD Amendment does not change the intent of the
original  ROD which is to contain the GDA source area  through the use of a slurry wall,
multi-media cap, and installation of two wells inside the waste pit to maintain an inward
gradient.

As referenced hi the original GDA ROD, it may  not be technically feasible to achieve the
groundwater cleanup standards for the contaminated groundwater outside of the GDA due to
the presence of high levels of benzene and NAPS. The Agency will continue to evaluate the
data from the groundwater extraction and treatment system and will reevaluate the cleanup
standards every five years to determine if it is technically practicable to remediate the NAPS.

To ensure  that all constituents present in the groundwater are within U.S. EPA's acceptable
risk range, AlliedSignal must demonstrate that the groundwater is within the allowable risk
range prior to turning off the groundwater pump  and treatment system.  Table 2 is a list of
the groundwater cleanup standards.

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TABLE 2
GROUNDWATER CLEANUP STANDARDS
Contaminant
Benzo(a)pyrene
Dibenz(a,h)anthracene
Arsenic
Ammonia
Phenolics
Benzene
Naphthalene
Nitrate
Total Cyanide
Cleanup Standard
(Original ROD)
Total of two must be less
than 5 ppt
50 ppb
30 ppm
4 ppm
5 ppb
300 ppb
10 ppm
200 ppb
Cleanup Standard
(ROD Amendment)
200 ppt
300 ppt
No Change
No Change
No Change
No Change
No Change
No Change
No Change
ppt - parts per trillion ppb - parts per billion ppm - parts per million
Alternative 2 - No Action (Retain the original ROD cleanup standard for benzo(a)pyrene and
dibenz(a,h)anthracene of 5 parts per trillion for both constituents.

In this alternative, the cleanup standard for benzo(a)pyrene and dibenz(a,h)anthracene will
remain at 5 ppt total for both compounds.

          Fundamental Change 4 - Comparative Analysis of Alternatives

In comparing Alternative 1 and Alternative 2, the best balance of the nine criteria would be
Alternative 1. Alternative 1 and Alternative 2 are equivalent for Criteria 2, 3, 5, and 6.
Alternative 2 would be slightly more protective of human health and the environment
(Criterion  1), though both alternatives reduce the risk range to levels EPA deems protective
of human health and the environment.  Alternative 2 would be slightly more effective in
meeting  Criteria 4, but the cost of Alternative 1 will be as much as $4.1  million less
expensive.  The Ohio EPA supports Alternative 1.  No public  comments  were received
concerning this change.

IV.   STATUTORY DETERMINATION

The four fundamental changes to the original RODs meet the statutory requirements of
CERCLA  Section 121.  The selected changes  to the original RODs are protective of human
health and the environment, attain ARARs, are cost effective, utilize permanent solutions and
alternative treatment technologies to the maximum extent practicable,  and use treatment that
                                         10

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reduces the toxicity, mobility, or volume of contaminants as a principal element.

The following is a summary of how the fundamental changes meet each of the five
requirements.

Protection of Public Health and the Environment

The four fundamental changes to the original ROD will not affect the intent of the original
ROD.  Removing the waste heat boiler and incinerator dismantlement provision have no
bearing on protection of public health and the environment. If the bioremediation can meet
the 0.97 ppm PAHC cleanup standard, then the treated "site soils" will be at a 1 x 10"6 risk
level for direct ingestion.  If the bioremediation cannot reach the 0.97 ppm PAHC cleanup
standard for PAHC will  not affect public health or the environment since the lagoons will be
flooded and the direct contact risk will be eliminated.  Currently, the lagoons are supporting
a wetland environment and the addition of the "site soils" into the lagoon will not affect the
wetland environment.

The change in the groundwater cleanup standard for benzo(a)pyrene and
dibenz(a,h)anthracene to Safe Drinking Water MCL values does not adversely affect public
health and the environment since the groundwater will be required to be within the
cumulative risk range of 1 x 10"4 to 1 x 10"* for carcinogenic compounds prior to
discontinuing the groundwater pump and treatment system.

Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)

The selected remedy and the four fundamental changes described in this ROD Amendment
meet all applicable or relevant and appropriate requirements (ARARs) of Federal and State
statutes pursuant to CERCLA Section 121 (d)(l),  except where waivers of Federal or State
law are necessary.  The four fundamental changes will not require waivers  of Federal or
State statutes.

Removal of the waste heat boiler does affect the Prevention of Significant Deterioration
(PSD)  status as described in the Clean Air Act.  It has been determined that PSD would
apply to the incineration if steam is supplied to the tar plant from the incineration of the
CERCLA waste.  Since the waste heat boiler will be removed and steam will not be supplied
to the tar plant, the PSD regulations will not apply to the incineration. The removal of the
waste heat boiler also affects the incinerator ash since waste fuel recovery will not be used;
therefore, the ash must  be delisted for the K087 waste instead of using the exemption as
described in 40 CFR Part 261.

Implementation of fundamental change 2, 3  and 4 will meet the ARARs as described in the
original ROD and are not affected by new ARARs.
                                          11

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Cost-Effectiveness

The four fundamental changes taken as a whole will save approximately $4 million on the
cost of the total site remedy which could be as high as $190 million over the life of the entire
project.  Removal of the waste heat boiler will save $3  million due to a reduction in capital
cost and operation and maintenance during the life of the incineration.  The "site soils" were
newly discovered contamination which has added additional cost to the CPLA remedy.
While the total additional cost is difficult to estimate, it could exceed $3 million.  A cost-
effective  solution will be implemented in conjunction with the other CPLA remedy
components.  The change in the cleanup standards to  the MCLs for benz(a)pyrene and
dibenz(a,h)anthracene will save approximately $4.1 million  since the groundwater pump and
treatment system will not have to operate until the former 5 ppt cleanup standard is reached.
Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum
Extent Practicable

The four fundamental changes to the original remedy represent to the maximum extent
possible, the use of permanent solutions and alternative treatment technologies to the site
remedy.  Although removal of the waste heat boiler eliminates waste fuel recovery, the
cleanup will proceed faster and in a more cost effective manner.  Incineration and
bioremediation will apply to a minimum of 650,000 cubic yards of waste material and may
reach 738,000 cubic yards if the  "site soils" undergo remediation.

Preference for Treatment as a Principal Element

The statutory preference for treatment remains satisfied by the four fundamental changes.
The "site soils"  will be treated by bioremediation if the 0.97 ppm cleanup standard can be
achieved and if the standard is not achievable, the "site soils"  will be managed  in a way that
continues to protect public health and the environment.
                                          12

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       REFERENCE
       1. TOPOGRAPHIC MAP PREPARED BY
         EASTERN MAPPING CO. PITTSBURGH. PA.
         DECEMBER 1983. SCALE: T-200'

       2. ORIGINAL DWG. NO 83-1625-854 USED
         IN Rl REPORT. DATED JULY 1986.
    © 19»4 IT CORPORATION
;..**•
                                                       Reproduced from  „ ,
                                                       best available copy. ||!j

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                                  s.if.D.O.


                            95  JUL -6  A;; ICr- 37
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                    95 JUL -G  ;.;; ifr 37
       U.S. ROUTE 52
 SOON No. 2  x —
          LAGOON No. 5
          LAGOON No. 1
                            ...y.
-OHIO STATE
 ROUTE 243
                                        3 RD. STREET
                                        BRIDGE

             COAL GROVE
             WELL FIELD
mo
             NOTE:
               FIGURE REPRODUCED FROM THE
               CPLA RD/RA WORK PLAN,
               DATED MAY, 1992.
                                                                  Draft
                                                         *'
                                                           Reproduced from  §K|
                                                           hest available      1

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                          RESPONSIVENESS SUMMARY

A Proposed Plan was issued to the public on March 6, 1995 along with a fact sheet.  A
thirty day public comment period was held until April 4. 1995.  A public meeting on March
30,  1995 was used to explain in detail the four proposed changes to the original ROD and
accept public comments.  At the end of the public comment period, the Agency did not
receive any public comments.

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Pages

100 +


100+


100 +
Date

11/93


11/93


5/94
Title
ADMINISTRATIVE RECORD UPDATE

                                  Author

                                  IT Corporation
8
7
II
8
25 +
9
7
2
.24
21
15
3/95
12/94
. 8/94
2/95
9/94
9/94
9/94
10/94
10/94
12/94
12/94
Preliminary Design Report - Volume 1 & 2
Groundwater/Facilities Engineering

Preliminary Design Report - Volume 1 & 2
Bioremediation - CPLA

Intermediate Design Report - Volume 1 & 2
Groundwater & Bioremediation - CPLA

Proposed Plan Amendment

Project Report by AllicdSignal

Meeting Notes  for August  11 & 12
1994 Project Meeting

Meeting Notes  for Februry 2, 1995

Draft Isopleth Maps

Site Soils Investigation Data
Draft Report

Estimation of Areas and Quantities of
Site Soils

Site Soil Options

Reevaluation of the Site Soils
Cleanup Goals

Costs for Handling Site Soils

Site Soils Handling Approach
                                  IT Corporation


                                  IT Corporation


                                  U.S. EPA

                                  AlliedSignal

                                  IT Corporation


                                  IT Corporation

                                  IT Corporation

                                  IT Corporation


                                  IT Corporation


                                  AlliedSignal

                                  IT Corporation


                                  IT Corporation

                                  IT Corporation
Recipient

U.S. EPA


U.S. EPA


U.S. EPA


Public

U.S. EPA

U.S. EPA


U.S. EPA

U.S. EPA

U.S. EPA


U.S. EPA


U.S. EPA

U.S. EPA


U.S. EPA

U.S. EPA

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25
11
100 +
2/95
5/94
Revised Site Soils & ROD Soils
Delineation Plan

Drinking Water Regulations and
Health Advisories
1/94 to 1/95    CPLA Monthly Project Status Reports

March 5, 1995  Ironton Tribune Newspaper Ad
IT Corporation


U.S. EPA


AlliedSignal

U.S. EPA
U.S. EPA
Public
                                                                                    U.S. EPA

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   FROM :OMIO EPRx'l_EGRI_/'KONICfl F'.<       Sl«» T28 1303              1395.03-C-2    1OJ'*4   W130 P.O2
SUte of Ohio Environmental Protection Agency

P.O. Box 163669.1800 WaterMark Dr.
CoJunmus. onto 43216-3669                                                    .
(614) 644-3020                                                                         George V. Vomovtcn
FAX (614) 644-2329                                          .                                   Qovomor
       August 2, 1995
       Valdus V. Adamkus
       Regional Administrator
       U.S. EPA, Region V
       77 West Jackson Avenue
       Chicago, II60604

       Dear Mr. Adamkus:

       The Ohio Environmental Protection Agency (Ohio EPA) has received and reviewed the final
       Amendment to Die Records of Decision (ROD) tor the Allied Chemical/Ironton Coke Superfund
       site in Lawrence County, Ohio. TMs ROD Amendment includes changes to both the 19fift ROD
       for the Gold Camp Disposal Area (GDA) operable unit and the 1991 ROD for the Coke Plant
       Lagoon Area (CPLA) operable unit at this site.

       This ROD Amendment is comprised of four fundamental changes to the original remedy for this
       site. These changes are the following:

             *      Removal of die waste heat boiler from the CPLA incineration process, thereby
                    eliminating the production of steam for the AllicdSignal Tar Plant (waste fuel
                    recovery). Since this change eliminates the RCRA recycling exemption for the
                    incinerator ash, AltiedSignal must manage this ash as hazardous waste or USEPA
                    must delist so that it can be disposed of as solid waste.
             *      Removal of the ROD dismantlement provision for the CPLA incinerator.
                    This change was necessary since it was determined the Agencies did not
                    have the legal authority to require dismantlement of this unit  However,
                    before AluedSignai can operate the incinerator after completion of this
                    remedial action they are required to obtain all applicable permit* from
                    OhioEPA.

             *      Excavation and storage of approximately 135,000 cubic yards of recently
                    identified CPLA contaminated "site soils" for eventual treatment and/or
                    placement into the lagoon area.
     PrlntM on recycled ewer
     EPA 1613 (nv.M*)

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FROM :OHIO EPP/I_EGFU_/KOI'J ICR FX       Si^ T28 1303             1S3S• 08-02    10i*»S   tt!30 P.C3
    ValdusK-Adamkus
    Page 2
          *     Revision of the CPLA and GDA clean-up standard for the groundwater
                constituents benzo(a)pyiene and dibenzo(aji)anthracene tzom a total of 5 parts per
                trillionfopt) to the new safe drinking water standards (MCL) of 200 ppt for
                benzo(a)pyrene and 300 ppt for dibeozo(aji)anthracene.

    These changes represent a net cost savings to AlliedSignal of approximately $4 million dollars.

    The Ohio EPA believes these changes hnth are protective of human health and the environment
    and provide a reasonable approach to control costs on what has become one of the most
    expensive dcwi-ups iii ihc Stale of Ohio. Therefore, Ohio EPA concurs with this ROD
    Amendment.

    Sincerely,
    Ohio Environmental Protection

    DRS/KCKJ/mr

    cc:    Jan Carlson, Chief, DI
          Ray Dcaumicx, Section Maiiagei ,DERR
          Kay Gilmer Gossett, DERR.SEDO
          Catherine Stroup, Legal,CO
          Thomas Alcamo, USEPA, Region V
          John Kuhns, USEPA, Region V

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