NEIC
OVERVIEW OF ENVIRONMENTAL POLLUTION
IN THE KANAWHA VALLEY
West Virginia
August 1984
National Enforcement Investigations Center, Denver
J.S. Environmental Protection Agency
Office of Enforcement
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT AND COMPLIANCE MONITORING
Properly Of 1
EPA Library
RTPNC 27711
OVERVIEW OF ENVIRONMENTAL POLLUTION
IN THE KANAWHA VALLEY
West Virginia
August 1984
James R. Vincent
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
I. INTRODUCTION M
II. SUMMARY OF FINDINGS II-l
ENVIRONMENTAL CONDITIONS II-l
SOURCES OF POLLUTION II-4
ENVIRONMENTAL CONTROL PROGRAMS 11-10
III. BACKGROUND III-l
DESCRIPTION OF THE STUDY AREA III-l
PREVIOUS STUDIES III-3
STUDY METHODS III-8
IV. ENVIRONMENTAL CONDITIONS IV-1
AIR QUALITY IV-4
WATER QUALITY IV-10
HAZARDOUS WASTE DISPOSAL IV-17
V. SOURCES OF TOXIC SUBSTANCES V-l
POINT SOURCES V-l
IDENTIFICATION OF MAJOR INDUSTRIAL SOURCES V-8
IDENTIFICATION OF HAZARDOUS WASTE SITES OF CONCERN . . V-16
VI. SOURCES OF TOXIC SUBSTANCES - UPPER KANAWHA VALLEY . . . VI-1
MAJOR INDUSTRIAL SOURCES VI-1
VII. SOURCES OF TOXIC SUBSTANCES - CENTRAL KANAWHA VALLEY . . VII-1
MAJOR INDUSTRIAL SOURCES VII-1
VIII. SOURCES OF TOXIC SUBSTANCES - LOWER KANAWHA VALLEY . . . VIII-1
MAJOR INDUSTRIAL SOURCES VIII-1
IX. ENVIRONMENTAL CONTROL PROGRAMS IX-1
ENVIRONMENTAL STANDARDS IX-1
ENVIRONMENTAL MONITORING IX-5
SOURCE CONTROL PROGRAMS IX-9
REFERENCES
TABLES
1 Multi-Media Rating of Major Industrial Sources of
Toxic Substances II-6
2 Hazardous Waste Disposal Sites of Potential Concern
Not at Major Industrial Plants II-8
3 Air Quality Trends IV-6
4 Summary of Toxic Substances Contributions
by Source/Pathway V-2
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CONTENTS (Cont.)
5 Municipal Wastewater Treatment Plants V-5
6 Wastewater Discharge Rating Criteria V-ll
7 Air Emissions Rating Criteria V-13
8 Hazardous Waste Management Rating Criteria V-14
9 Site Contamination Rating Criteria V-15
10 Multi-Media Rating of Major Industrial Sources
of Toxic Substances V-17
11 Summary of Industrial Wastewater Discharges V-19
12 Hazardous Waste Disposal Sites of Potential
Concern Not at Major Industrial Plants V-20
13 Changes in El kern Metals Company Products VI-5
14 Products List, E. I. duPont De Nemours and Company .... VI-15
15 Product List, Union Carbide, South Charleston VII-6
16 Products List, Union Carbide, Institute VII-22
17 List of Products, Monsanto Company VIII-11
18 List of Principal Raw Materials, Monsanto Company VIII-12
19 Products List, Fike Chemicals, Inc VIII-17
FIGURES
1 Location Map - Kanawha Valley Study Area 1-5
2 Locations of Major Industrial Sources II-7
3 Locations of Hazardous Waste Disposal
Sites of Concern II-9
4 Dissolved Oxygen Profiles in the Kanawha River IV-11
5 Locations of Major Industrial Sources V-18
6 Locations of Hazardous Waste Disposal
Sites of Concern V-21
7 Area Map - Upper Kanawha Valley VI-2
8 Location Map - Alloy Area VI-3
9 Location Map - Glasgow Area VI-9
10 Location Map - Belle Area VI-10
11 Area Map - Central Kanawha Valley VII-2
12 Location Map - South Charleston Area VII-4
13 Location Map - Institute Area VII-20
14 Area Map - Lower Kanawha Valley VI11-2
15 Location Map - Nitro Area VIII-3
16 Location Map - Amos Power Plant VIII-24
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I. INTRODUCTION
The Kanawha Valley, traversed by the Kanawha River and centered on
Charleston, is a major industrial area in central West Virginia. Five
large industrial complexes and numerous smaller industrial plants are in
the long, narrow valley. Major industrial facilities primarily produce
organic and/or inorganic chemicals. About 220,000 persons live and work
in the valley.
Development of the chemical industry in the valley began with the com-
pletion of the major FMC plant in South Charleston in 1915. Major indus-
trial expansion continued in the 1920s, 1930s and during World War II.
Until about 10 years ago, the Union Carbide plant in South Charleston was
the largest petrochemical complex in the world. Although both industrial
activity and population have declined slightly in recent years, the valley
remains one of the largest industrial complexes in the United States.
With the industrial development came severe environmental degradation.
Large volumes of chemical wastes and other pollutants were discharged to
the Kanawha River resulting in gross pollution. At times, the river could
not support even pollution tolerant fish populations. Taste and odor prob-
lems were severe in public water supplies obtained from the river. Bene-
ficial uses of the river were severely impaired.
Degradation of air quality was also a major problem. Emissions of air
pollutants from chemical plants, powerplants, other manufacturing facili-
ties, and urban areas were often trapped in the narrow valley by adverse
meteorological conditions, resulting in severe air pollution in the urban
areas.
Large volumes of hazardous wastes and other waste residuals were dis-
posed of in landfills, dumps, and surface impoundments that were not prop-
erly designed, constructed, or maintained to adequately contain the toxic
substances present in the wastes. As a result, toxic pollutants were
released to the air, to surface water, and to groundwater.
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1-2
Improvements in environmental quality began to be observed about 1960
and continued as various environmental control programs were implemented.
Federal, State, and local legislation and regulations coupled with major
municipal and industrial expenditures for plant improvements and pollution
controls resulted in major reductions in releases of pollutants to the
environment. During the last 25 years, major improvements in water quality
have been achieved and water quality now meets most applicable water quality
criteria most of the time. Sport fish are again present in the river.
Similar improvements in air quality have also been achieved.
Although much progress in enhancement of the environment has been
achieved, several environmental problems have not been fully resolved.
Toxic substances continue to be released to the environment in wastewater
discharges and air emissions and are present in large volumes in hazardous
waste disposal sites. The presence of these toxic substances in the envi-
ronment pose actual and potential impacts on aquatic life in the Kanawha
River. Toxic substances in the air pose potential health risks at some
locations under adverse meteorological conditions. Inactive hazardous waste
disposal sites pose a long-term potential for release of toxic substances
to the environment.
Most of the pollution controls implemented to date have concentrated-
on reducing releases of traditional pollutants such as oxygen-demanding
substances in water and suspended particulates in air. Although these con-
trols did produce substantial ancillary reductions in releases of toxic
pollutants, they were usually not specifically designed to reduce toxic
releases. Legislation since the mid-1970s at both the Federal and State
level has specifically targeted control of toxic substances. Environmental
control programs springing from this legislation are just now beginning to
be fully implemented.
The environmental problems of the Kanawha Valley have received much
regulatory attention during the past 15 years and numerous environmental
studies have been done. This activity is continuing. In 1977, the
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National Enforcement Investigations Center (NEIC) conducted a multi-media
environmental overview of the Kanawha Valley. This study summarized avail-
able information on the presence of toxic substances in the valley environ-
ment and the sources of these substances. A major conclusion of the study
was that available data on toxic substances were limited, especially data
on ambient air, air emissions, and hazardous waste disposal. Since 1977,
additional information has been compiled on toxic substances in these media
as well as in ambient water and wastewater discharges.
In July 1983, NEIC, with the concurrence of EPA Region III, Philadel-
phia, Pennsylvania, began an update of the 1977 overview study to evaluate
the progress that had been made to date in the control of toxic substances
and provide the basis for a coordinated plan for future actions. This re-
port summarizes the results of the study update. Specific study objectives
were:
1. Define present environmental conditions and any identifiable
trends as characterized by the quality of ambient air, surface
waters, groundwaters, and drinking water supplies and by biologi-
cal data on aquatic life.
2. Define major sources of toxic substances that impact environmen-
tal conditions.
3. Define past, present, and proposed future remedial measures and
programs for control of toxic substances.
4. Define any additional remedial measures and/or programs or revi-
sions of existing programs that appear to be needed to adequately
manage toxic substances and meet applicable environmental cri-
teria and standards.
The report focuses primarily on toxic substances, those chemical sub-
stances which pose a substantial potential or actual hazard to human health
or the environment when present in relatively small quantities or low con-
centrations. The term "toxic substances" is often used indiscriminately to
describe a wide variety of chemical substances, many of which may not pose
a hazard but are perceived to pose a hazard. Various references discussed
in this report use the term "toxic substances" in a broad context; in such
discussions, the term is used in the context explicitly expressed in the
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reference. Whenever possible, however, the report uses specific terminology
keyed to environmental laws to identify the substances present in the envi-
ronment. For example, when discussing wastewater discharges or surface
water or groundwater, "priority pollutants" refers to the group of 65 or-
ganic and inorganic chemical substances and heavy metals classified as toxic
pollutants*. "Hazardous wastes", another term frequently misused, in this
report refers to specific types of industrial, municipal, and commercial
solid or liquid wastes that have been identified as hazardous wastes by
EPA5"*.
Geographically, the study encompassed the narrow developed valley of a
60-mile reach of the Kanawha River extending from Winfield Dam to Alloy
[Figure 1]. This area includes major industrial facilities at Alloy, Belle,
South Charleston, Institute, and Nitro. Area population is in excess of
220,000 persons, primarily located in Charleston and adjacent communities.
The scope of the study was confined to the evaluation of available
data and information compiled from the published literature and from State
and Federal regulatory agency files coupled with interviews with key State
and EPA Regional regulatory personnel.
Section II summarizes the findings of this study including the most
significant environmental problems, the causes or sources of these prob-
lems, existing environmental control programs, and needed program revisions
and additions. Background data are presented in Section III including a
description of the study area, condensed descriptions of selected previous
studies and a summary of study methods. Environmental conditions, trends,
and problem areas are discussed in Section IV.
There are numerous known or potential sources of toxic substances in
the Kanawha Valley including municipal and industrial wastewater discharges,
* Defined by Section 307(a) of the Clean Water Act and listed in 40 CFR
Part 401.15.
** Identified in lists promulgated under Section 3001 of the Resource Con-
servation and Recovery Act (RCRA) of 1976 and codified in 40 CFR
Part 261.
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t)
'"g-J-argf^ V .^»\« <
V OotMoV JBik <=«« ( WCI.H, wXl. "
\ ^^. -»-4 u,,7 VjL«-**»» "»'
A T: J,M"I - Th~.-»- ' ^-__
Figure 1. Location Map - Kanawha Valley Study Area
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1-6
industrial air emissions, and hazardous waste disposal sites. Section V
discusses how an inventory of such sources was prepared and major sources
identified.
Sections VI through VIII discuss major sources of chemical substances
for each of three study subareas (upper, central, and lower Kanawha Valley).
Toxic substances handled at the facility, emitted to the air, discharged in
wastewaters and/or stored, treated, or disposed of in hazardous wastes are
defined within the scope of available data.
The final section (Section IX) discusses State and EPA regulatory pro-
grams for control of toxic substances, their current status, and sugges-
tions for additions and modifications.
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II-l
II. SUMMARY OF FINDINGS
ENVIRONMENTAL CONDITIONS
Air and water quality in the Kanawha Valley have improved markedly
over the past two decades. State and Federal environmental pollution con-
trol programs coupled with major expenditures by industrial facilities and
municipalities for pollution controls have been successful in achieving
major reductions in pollutants released to the environment. Air and water
quality defined by traditional pollutant parameters (such as dissolved
oxygen in water and suspended particulates in air) are generally better
than applicable regulatory limits. However, some regulatory limits are
occasionally not met indicating the need for further controls on tradi-
tional pollutants. Of more concern, however, is the presence of various
potentially toxic chemical substances in the environment for which no regu-
latory limits have been established.
Although general environmental conditions have substantially improved,
there remain several environmental problems of concern to the public and
environmental agencies. Various volatile organic chemicals, some with known
or suspected human health effects at relatively low concentrations, are
known to be emitted to the atmosphere from area industries and have been
detected in the ambient air of the valley. Collection of air monitoring
data has recently begun but there are no Federal regulatory limits for these
chemicals from which an assessment of potential impacts can be made. The
presence of low levels of toxic pollutants in the Kanawha River results in
low levels of contamination of fish with toxic substances and contributes
to reduced quantity and quality of the fishery in the lower river. The
presence of large volumes of hazardous wastes containing toxic substances
at inactive and/or abandoned disposal sites has resulted in the contamina-
tion of surface and groundwaters (including private drinking water supplies)
with toxic substances at some sites and poses the potential for long-term
release of toxic substances to the environment.
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II-2
Air Quality
Present air quality [based on periodic ambient air monitoring by the
West Virginia Air Pollution Control Commission (WVAPCC)] is in compliance
with all applicable primary ambient air quality standards designed to pro-
tect human health. Suspended particulates and sulfur dioxide were formerly
far in excess of regulatory limits.
Unitl mid-1984 there were no current data on ambient air concentrations
of various volatile organic chemicals (VOCs) known to be emitted from area
industries in significant amounts. Several of these substances, such as
benzene, chloroform, carbon tetrachloride and vinyl chloride are known to
or suspected of having the potential to cause serious health effects at low
concentrations. Past monitoring (1977) and recent air modeling studies
have shown the potential for occurrence of elevated levels of several of
these chemicals in the ambient air. There are no Federal or State regula-
tory limits on volatile organic chemicals in ambient air. In the absence
of a Federal regulatory program, the WVAPCC has begun ambient monitoring
for VOCs to evaluate the significance of present levels. However, the lack
of regulatory limits hinders problem definition.
Water Quality
Water quality in the Kanawha River has made a dramatic improvement
from the gross pollution of the past and now meets most applicable regula-
tory limits most of the time. Dissolved oxygen, a critical characteristic
with regard to impacts on aquatic life, consistently meets or exceeds limits
in the Kanawha River. The river is water quality limiting with respect to
oxygen demanding pollutants.
Although water quality is generally good, violations of several water
quality criteria occur often enough to be of concern and indicate the need
for additional water pollution controls. Violations of criteria for pH,
cyanide, manganese, lead and cadmium occurred a few times (<15%) during
1979-81. Criteria for phenolics and iron were violated more frequently
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(15-49%). The pH, iron and manganese violations were attributed to non-point
sources (abandoned coal mines). Cyanide, cadmium, lead and phenolics are
most typically from industrial sources although non-point sources may con-
tribute significant amounts of heavy metals. Cyanide and lead concentra-
tions occasionally reach levels that could cause chronic or acute toxicity
in aquatic life.
Observed concentrations of carbon tetrachloride and chloroform, both
toxic organic pollutants, averaged more than 1.0 (jg/Jd during 1979-81 with
peak concentrations of 15 and 219 ug/£, respectively. The periodic high
levels suggested that spills may have been occurring. There have been no
recent reports of such spills.
Aquatic Life
When water quality was severely degraded in the Kanawha River, the
lower river supported only pollution tolerant aquatic life. With the
improvements in water quality have come improvements in the sport fishery
throughout the river with significant game fish populations present in the
lower river. However, the quality of the fishery still decreases downstream
from Charleston in comparison with the upper river indicating pollution is
still impacting the fishery.
Low levels of several toxic pollutants have been observed in fish flesh.
PCB concentrations have decreased from past levels but samples taken near
Charleston still approach FDA temporary tolerance limits for PCBs in edible
fish. Chlordane levels in some fish samples approach FDA action levels for
pesticide residues in fish flesh.
Bioassays of several major industrial wastewater discharges indicated
that the effluents were moderately to highly toxic to aquatic life. This
indicates that there is a potential for chronic toxicity effects on aquatic
life in the Kanawha River in the vicinity of the discharges.
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Hazardous Waste Disposal
Hazardous wastes which frequently contain toxic substances are known
or suspected to have been disposed of at at least 50 sites in the study
area. Most of these sites were not designed, constructed or maintained to
adequately contain these wastes. At several sites, toxic substances have
leached into ground and surface waters. Contamination of several private
water supply wells has occurred. Leachate has also contaminated several
small streams tributary to public water supplies.
Disposal sites include landfills, ponds, open dumps and strip mines.
Some sites were operated onsite by industrial facilities or offsite for
their use. Other disposal occurred at municipal dumps and landfills pri-
marily receiving municipal refuse.
Remedial measures to contain or remove hazardous wastes have been taken
at only a few sites. Only one site (Fike Chemical) is a Superfund priority
site. Several of the sites under active investigation appear to have a
significant potential for long-term release of toxic substances to the
environment. Evaluations of these sites are continuing.
SOURCES OF POLLUTION
Toxic substances are released to the Kanawha Valley environment from
numerous point and non-point sources. Important point sources are indus-
trial manufacturing plants and hazardous waste disposal sites. Important
non-point sources are abandoned coal mines, residential and commercial
facilities, transportation and urban runoff.
There are nearly 200 industrial facilities in the study area but an
evaluation of these facilities using multi-media rating criteria (see Sec-
tion V) indicated that only 19 are considered major sources of toxic sub-
stances. The major sources are listed alphabetically in Table 1 which shows
the relative significance of releases of toxic substances through air, water
and hazardous waste pathways for each source. Facility locations are shown
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II-5
in Figure 2. In general, these major sources discharge toxic pollutants in
their wastewaters, emit potentially toxic chemical substances to the air,
generate and/or dispose of substantial quantities of hazardous wastes and
have some degree of site contamination.
There are 20 municipal wastewater treatment plants in the study area.
The South Charleston plant receives large volumes of industrial wastewaters
from Union Carbide and is considered a major industrial source [Table 1],
The other 19 plants collectively do not discharge significant amounts of
toxic substances relative to industrial sources.
Air emissions of volatile organic compounds from industrial plants are
the largest source of toxic substances. Wastewater discharges and spills
and leaks at chemical plants also contribute significant amounts of toxic
organic pollutants to surface waters. Significant but undefined amounts of
toxic substances are present in the large volumes of hazardous wastes dis-
posed of by industrial plants.
There are about 43 hazardous waste disposal sites of potential concern
in the study area. .Seventeen of the sites are associated with and located
at or near major industrial facilities. The other 26 sites are listed alpha-
betically in Table 2 which indicates the type of site and status of reme-
dial action. Site locations are shown in Figure 3.
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Table 1
MULTI-MEDIA RATING OF MAJOR INDUSTRIAL SOURCES OF TOXIC SUBSTANCES
Map3
Key Facility Name
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Allied Chemical
Appalachian Power- Amos Plant
Appalachian Power-Kanawha R. Plant
Avtex Fibers
Chemical Leaman Tank Lines
Coastal Tank Lines
Diamond Shamrock
DuPont
El kern Metals
FMC
FMC
Fike Chemicals/CST
Kincaid Enterprises
(Chemical Formulators)
Mason & Dixon Tank Lines
Monsanto
S. Charleston Sewage Treatment Co.
Union Carbide
Union Carbide-Technical Center6
Union Carbide
Wastewater Discharges
City
Nitro
Nitro
Cedar Grove
Nitro
Institute
Nitro
Belle
Belle
Alloy
Nitro
S. Charleston
Nitro
Nitro
St. Albans
Nitro
S. Charleston
Institute
S. Charleston
S. Charleston
Toxics
Load
0
4
2
1
1
1
3
4
3
2
5
4
1
1
4
7
7
0
8
Effluent
Toxicity
0
0
0
0
1
0
3
3.
0
2
4
4
2
0
2
1
2
0
0
Air Emissions
Process
10
0
0
0
NDC
ND
5
10
10
0
6
1
ND
ND
3
ND
9
ND
8
Combustion
0
30
20
0
0
0
0
10
10
0
10
0
0
0
4
0
10
0
5
Haz.
Waste
Mgmt.
0
2
0
9
4
4
3
13
0
11
6
11
4
4
14
3
17
7
14
Site
Contamin.
1
1
1
6
2
2
7
7
6
4
6
9
7
2
8
1
8
5
7
a See Figure 2 for source locations.
b Plant closed. Ratings reflect site contamination and runoff.
c ND - No data
d Includes Goff Mountain Landfill and private trucking operations
e Includes Ward Hollow and Holz Pond waste disposal area
en
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I
~^l
FIGURE 2 Locations of Major Industrial Sources
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Table 2
HAZARDOUS WASTE DISPOSAL SITES OF POTENTIAL CONCERN
NOT AT MAJOR INDUSTRIAL PLANTS
Map
Key
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
a
b
c
a File
80
4
5
124
-
52
126
-
6
8
9
128
1
45
113
20
74
31
-
-
-
81
82
41
-
77
No. Site Name
Charleston Municipal Landfill
Chelyan Oil Company
Don's Disposal Service
Dowell
General Electric Charleston Apparatus Service
Georges Creek
Givaudan Virginia
Heizer Creek
Holms & Madden Landfill
Kanawha Block Company
Kanawha County (Western) Landfill
Libby-Owens-Ford
Manila Creek
Mai lory Airport Landfill
Markay Chemical
Mink Shoals Landfill
Nitro Municipal Landfill
Nitro Sanitation
NL Industries
Poca Strip Mine Pits
Republic Steel
Smith Creek Dump
South Charleston Municipal Landfill
Tacketts Creek
Union Oil - Cabin Creek
Vimasco
City
Charleston
Cabin Creek
Charleston
Nitro
Charleston
Port Amherst
Belle
Poca
Charleston
Charleston
Cross Lanes
Charleston
Amherst
S. Charleston
St. Albans
Mink Shoals
Nitro
Nitro
Charleston
Poca
Nitro
S. Charleston
S. Charleston
St. Albans
Cabin Creek
Nitro
Typeb
M
ON
P
ON
ON
P
ON
M
M
P
M
ON
OF
M
ON
M
M
M
ON
M
P
P
M
OF
OF
ON
Status0
1C
AI
1C
1C
ND
1C
1C
AI
1C
AI
1C
ND
AI
1C
RAC
AI
AI
AI
RAC
AI
ND
AI
AI
1C
AI
RAC
See Figure 3 for site locations.
Type of
Status:
Facility: Off - Industrial onsite; OF - Industrial off site; M - Municipal; P
ND - no data; AI - Active investigation/ 1C - Inves.
tigation compJet
e; RAC -
- Private
Remedial action
complete;
00
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o
FIGURE 3 Locations of Hazardous Haste Disposal Sites of Concern
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11-10
ENVIRONMENTAL CONTROL PROGRAMS
Environmental Standards
Present water quality standards do not include specific numerical
limits on a number of toxic organic pollutants present in the Kanawha River.
However, limits on specific pollutants can be established on a case-by-case
basis for specific discharges. A review of ambient monitoring data, fish
and benthic organism data, effluent data, etc. is needed to determine if
specific water quality criteria should be promulgated or if the case-by-case
approach is adequate. Environmental impacts of concern include possible
chronic toxic effects on aquatic life and fish flesh contamination.
There are no Federal or State ambient air quality standards for eval-
uating the significance of ambient levels of various volatile organic chem-
icals present in the valley atmosphere. The West Virginia Department of
Health is developing a list of chemicals of concern based on the relative
health effects and emissions volumes of these chemicals. The West Virginia
Air Pollution Control Commission has requested technical assistance from
EPA in identifying and prioritizing volatile organic chemicals that pose
the most significant health risks. EPA has provided a preliminary screen-
ing and prioritizing of a number of substances. In the absence of regula-
tory standards, identification of those chemicals known to be emitted in
the valley and that pose significant health risks is the first major step
in development of a control program. There is, thus, a need for early com-
pletion of the list of chemicals of concern and the ranking of this list.
Completion of an emissions inventory and exposure assessments will be needed
to accomplish this.
Environmental Monitoring
Until 1984, there was no current monitoring of ambient air levels of
volatile organic chemicals by regulatory agencies. Data on ambient air
levels were needed as a basis for identifying the need for emission controls.
The Air Pollution Control Commission obtained an analytical instrument and
has begun the needed monitoring.
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11-11
Ambient water levels of toxic organic pollutants in the Kanawha River
are currently routinely monitored at only one location downstream from all
sources of toxic pollutants. It is probable that higher levels of toxic
pollutants occur at several upstream locations near industrial plants.
There is a need for an expanded toxic pollutant monitoring program to in-
clude several upstream locations with monitoring frequencies adequate to
assess quality under several river flow conditions, especially low flows.
Monitoring data are needed to assess the adequacy of NPDES permit condi-
tions and water quality standards and to evaluate potential chronic toxi-
city to aquatic life. The Department of Natural Resources is planning an
expanded biological monitoring program that is needed to evaluate biological
conditions near industrial discharges.
Extensive hazardous waste disposal site investigation activity is un-
derway in the valley. In addition, several sites are being investigated
for dioxin contamination as part of the national dioxin program. Completion
of these site investigations is needed to define the extent of environmental
contamination present at each site so that hazard assessments can be com-
pleted and remedial action prioritized.
Source Control Programs
Comprehensive NPDES permits which regulate toxic pollutants were issued
by EPA Region III to the Diamond Shamrock, duPont and Union Carbide Insti-
tute major chemical plants in 1981. Comprehensive draft permits were pre-
pared for Monsanto and FMC- Nitro plants. The NPDES permit program was
delegated to the West Virginia Department of Natural Resources (DNR) in May
1982. DNR has not re-issued comprehensive permits to several major chemical
plants. DNR policy is to wait for EPA promulgation of effluent guidelines
for the organic chemicals industry. It is probable that final promulgation
will be delayed, possibly into 1986. Reissue of comprehensive permits to
Monsanto, FMC at both Nitro and South Charleston and Union Carbide at South
Charleston is needed now to achieve adequate control of discharges of toxic
pollutants from these major chemical plants. The permits should include
Best Management Practices (BMP) conditions and bioassay requirements
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11-12
comparable to the 1981 EPA permits. Issue of comparable permits to all
seven plants would eliminate the current major differences in permit
requirements between plants.
Effluent bioassays required by NPDES permits indicate that some efflu-
ents have moderate to high toxicity to aquatic life. Spills of toxic or
hazardous pollutants are periodically reported by some plants. Followup
action is needed to determine if existing permit conditions can be used to
minimize these problems.
Although wastewater discharges from chemical tank truck cleaning facil-
ities are small in volume, pollutant concentrations are frequently high and
variable. Various toxic substances are hauled by the tank trucks. These
facilities have the potential to discharge significant amounts of toxic
pollutants. Current NPDES permits issued by EPA do not limit these pollu-
tants. Revised permits with comprehensive controls on toxic pollutants are
needed for Chemical Leahman, Coastal, and Mason and Dixon Tank Lines.
An updated (1981 base) inventory of process and fugitive emissions of
volatile organic chemicals from major chemical plants is being compiled by
the Air Pollution Control Commission. In combination with the new ambient
air monitoring, this inventory will form the basis for a new emissions con-
trol program for volatile chemicals. Completion of this inventory is needed
as soon as practicable. A mid-1984 target date has been established for
completion. A West Virginia legislative provision that prohibits state air
pollution control requirements from being more stringent than federal re-
quirements is a possible impediment to the new emissions control program.
Both the Deaprtment of Natural Resources (DNR) and EPA Region III oper-
ate portions of the RCRA program. Under Phase I interim authorization, DNR
enforces interim status standards and also administers the RCRA permit pro-
gram for treatment and storage facilities under Phase II A and B authoriza-
tion. EPA administers the land treatment and disposal permit program pend-
ing full authorization of the West Virginia program. Numerous enforcement
actions have been taken by DNR in the study area and several permits are
under development.
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About 43 inactive hazardous waste disposal sites of potential concern
have been identified in the Valley. Seventeen are located at major indus-
trial facilities. Nearly half of the other 26 were municipal dumps or
landfills that also accepted hazardous wastes. Investigations have been
completed at 12 of the 26 sites and 11 are under active investigation.
Information compiled to date suggest that at least 10 of the 43 sites will
probably warrant some form of remedial action. Environmental problems of
concern include contamination of private drinking water wells and discharge
of leachate to streams tributary to public water supply intakes. Only one
site (Fike Chemicals) has been placed on the Superfund national priority
list to date. This list includes only those sites that have been found to
pose a high potential or actual hazard to the public and the environment.
Completion of active site investigations could result in higher ratings for
some sites.
Several factors have impeded the progress of remedial actions at sites
with known environmental problems. Because most of the sites are not on
the Superfund priority list, CERCLA funds cannot be used to conduct remedial
work at the site or to negotiate with responsible parties for site cleanup.
State matching funds have not been available for existing Superfund sites
and immediate removal actions. A state response fund has been enacted and
will be implemented in January 1985. This will allow the State to make
independent immediate removal actions.
Under state law, DNR can issue Administrative Orders to site owners
requiring monitoring of site contamination to define the extent of environ-
mental problems. They also have the authority to issue remedial orders re-
quiring site cleanup. Four remedial orders have been issued.
Both state and EPA program files indicate that a number of enforcement
"actions such as Notices of Deficiencies and Administrative Orders have been
initiated. In some cases, the compliance problem has been clearly resolved.
In other cases, monitoring data indicate problems continue. There is need
for a multi-media compliance tracking system to ensure that effective fol-
lowup actions are taken whenever timely compliance with enforcement actions
is not achieved.
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III. BACKGROUND
DESCRIPTION OF THE STUDY AREA
The Kanawha Valley is the narrow, winding valley of the Kanawha River
in west-central West Virginia surrounding the capitol city, Charleston.
The Kanawha River traverses the western foothills of the Appalachian Moun-
tains for 97 miles from its origin at Gauley Bridge at the confluence of
the New and Gauley Rivers to its confluence with the Ohio River at Point
Pleasant, West Virginia, northwest of Charleston. The study area encom-
passed the 60-mile section of the valley between Alloy and Winfield [Figure
1, Section I]. The study area boundaries were selected to encompass all
major sources of pollution and the urban areas impacted by this pollution.
Because the river traverses mountainous country, the valley is rela-
tively narrow, reaching a maximum width of only about 1 mile in the study
area. The area of the valley floor in the study area is less than 50 sq.
mi., much of which is developed for urban, industrial, or residential uses.
The elevations of flanking mountains range from 300 to 1,300 feet above the
valley floor. This particular topography tends to hold air pollutants from
industrial and municipal sources in the valley in close proximity to popu-
lated areas.
The total population of the study area is about 220,000. Population
densities are low in the upper and lower thirds of the valley with most
population concentrated in Charleston and adjacent communities in the
central valley.
Streamflow in the Kanawha River can be highly variable ranging from
flooding conditions in late winter and spring to low flows in late summer
and fall. Extreme low flows range from about 600 cfs near Belle to about
1,500 cfs at Winfield Dam. This contrasts with average flows of about
11,000 cfs near Belle and 15,000 cfs at Winfield Dam. These flows are
influenced by releases from upstream storage reservoirs, power generation,
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III-2
and the effects of the navigation dams in the study area. Water quality
standards are based on minimum flows of 1,896 cfs at Mile Point 72 near
Diamond and 1,960 cfs at Charleston.1 The Kanawha River is navigable
throughout the study area with slack water provided by London, Marmet, and
Winfield Dams. Major tributaries that join the Kanawha River within the
study area are the Elk, Coal, and Pocatalico Rivers.
Public water supplies in the study area are obtained entirely from
surface waters. A major portion of the study area (about 180,000 popula-
tion) is in the Kanawha Valley District of the West Virginia Water Company
that obtains water from the Elk River.2 This system serves most of the
valley between Belle and Nitro. There are eight small water supply systems
serving a population of about 20,000 in the upper valley upstream of Belle.2
These systems obtain water from the Kanawha River upstream of all major
chemical manufacturing facilities. St. Albans Water Department serves about
20,000 persons in St. Albans with water obtained from the Coal River. St.
Albans has an auxiliary intake near the mouth of the Coal River in backwater
from the Kanawha River for use in times of extremely low streamflow in the
Coal River.
There are no longer any public water supplies using Kanawha River water
downstream from Belle. The Nitro area was formerly served by a West Vir-.
ginia Water Company facility using Kanawha River water. Severe taste and
odor problems necessitated a high level of water treatment including acti-
vated carbon columns. This plant has been closed and service is provided
from the Elk River source.
Kanawha River water is used by the various large industrial facilities
for cooling water and some process water. Some industrial use of ground-
water may also be occurring. Groundwater is also used for private water
supplies to scattered residences and small commercial facilities.
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III-3
PREVIOUS STUDIES
Because of the concentration of chemical industries in the Kanawha
Valley and their environmental impacts, various studies have been conducted
of environmental pollution and its sources over the past 25 years. The
state of West Virginia initiated a phased program to reduce pollution of
the Kanawha River in 1958. As a result, discharges of oxygen demanding
substances to the river were reduced by 89% between 1958 and 1976. To
assist in achieving this waste load reduction and to provide for additional
water quality enhancement, EPA has conducted a number of receiving water
and waste source investigations during the past decade. Recent studies
have focused more on toxic substances in the environment and have included
evaluations of air quality and emissions sources and of hazardous waste
handling and disposal as well as water pollution aspects. Previous studies
that provided data used in this report are discussed below.
In 1972, plant inspections and effluent sampling were conducted at 40
industrial facilities in the valley by EPA's National Field Investigation
Center in Cincinnati.3 4 These inspections provided basic information on
processes, raw materials, products, wastewater treatment and control prac-
tices, and effluent characteristics. Data on toxic substances in the ef-
fluents were usually limited to heavy metals. No organic analyses were
performed.
In 1975, effluent samples collected by EPA Region III from major waste-
water discharges from chemical plants in the valley were analyzed for
organic compounds by NEIC.5 Limited data on toxic substances in these
effluents were developed in this study.
As part of a study to develop methods of measuring organic vapors in
ambient air, an EPA contractor conducted special sampling at 15 locations
in the Kanawha Valley in 1975. The study yielded only qualitative data.6
Reconnaissance inspections of major wastewater dischargers in the val-
ley were made by Region III staff in the 1975-77 period. Trip reports of
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III-4
these inspections provided data on pollution control practices and process
changes.7 Reconnaissance inspections of specific air pollution sources in
major facilities were also made by Region III staff during the same time
period. Inspection reports provided some data on emissions of toxic
substances.8
An EPA funded reconnaissance sampling study in 1975 of potential
sources of emissions of nitrosamines in the Kanawha Valley detected nitro-
samines near Belle and South Charleston.9
In February 1977, a large spill of toxic carbon tetrachloride occurred
in the Kanawha River. This prompted an EPA sampling survey of the river
and selected industrial effluents.10 Organic analyses of these samples
provided an inventory of toxic organic chemicals present in the river.
Data on wastewater treatment practices at eight major industrial faci-
lities were compiled by an EPA contractor in 1977 as part of an areawide
water pollution control planning study.11
During 1977-1979, NEIC conducted a series of plant inspections and
monitoring studies at major sources of pollution in the valley. These
studies were multi-media and included evaluations of processes, pollution
control practices (air, water, solid waste, and hazardous materials) and
effluent characteristics. Preliminary to this series of plant studies, in
1977, NEIC conducted a compilation and evaluation of available data on toxic
substances in the Kanawha Valley. Aerial photographs of all major sources
of pollution in the valley were taken. This study identified major sources
of toxic substances and made recommendations for the subsequent plant
inspections. The study report, published in February 1978, formed a major
basis for the current NEIC effort to update the 1977 work.12
A partial evaluation of the FMC Corporation plant at South Charleston
was conducted in February 1977 as the result of a major carbon tetrachloride
spill.13 14
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III-5
Detailed plant inspections and monitoring surveys were conducted at
Fike Chemicals, Inc., Coastal Tank Lines, Inc. and the Cooperative Sewage
Treatment (CST), Inc. facilities in Nitro in late 1977.15 As a result of
these inspections, major enforcement actions were initiated against Fike
Chemicals and CST. NEIC has continued to provide technical support to these
actions and has made several plant visits since 1977. In 1980, Fike Chemi-
cals was inspected for a hazardous waste site evaluation.16 This site was
eventually included on the Superfund priority list.17
Reconnaissance inspections were conducted in 1977 at Chemical Formu-
lators, Inc. (now Kincaid Enterprises), FMC Corporation, and Monsanto Com-
pany in Nitro and at Du Pont in Belle.18 19 20 21 No sampling was performed
but detailed information on processes and pollution control practices was
obtained. An NEIC hazardous waste site evaluation was conducted at Chemi-
cal Formulators in I960.22
NEIC conducted detailed plant inspections and monitoring surveys in
1978 at the Union Carbide facilities in Nitro and South Charleston and at
the South Charleston Sewage Treatment Company.23 24 25
In 1977 and again in 1983, the West Virginia Air Pollution Control
Commission (WVAPCC) compiled detailed inventories of emissions of air pol-
lutants from industrial facilities based on data submitted by the indus-
tries.26 27 These inventories were supplemented by information in EPA Region
III files.26
Special ambient air monitoring was conducted at various locations in
the Kanawha Valley in 1977 under an EPA contract to detect levels of toxic
substances present near industrial complexes.28
In May 1980, EPA promulgated consolidated Permit Regulations (40 CFR
Part 122) that, among other requirements, imposed significant new responsi-
bilities on industrial sources of toxic substances. All facilities that
were in industrial categories that typically used or produced toxic sub-
stances and had NPDES permits were required, as part of the permit renewal
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process, to sample their effluents for toxic pollutants and submit these
data to EPA. Most of the major industrial facilities in the Kanawha Valley
were included in this requirement and submitted permit applications to
EPA.29 In 1982, EPA delegated the NPDES permit program to the West Vir-
ginia Department of Natural Resources (DNR). Recent data are thus present
in the DNR files.30 This information includes reports on periodic compli-
ance inspections by DNR at major facilities.
Regulations promulgated under the Resource Conservation and Recovery
Act (RCRA) required all facilities that generate, transport, or manage
(treat, store, or dispose) hazardous wastes to notify EPA in 1980 of their
activities.31 Hazardous waste management facilities were also required to
submit simple permit applications that summarized the types and capacities
of hazardous waste units present at the facility and the types and volumes
of hazardous wastes handled.32 These EPA files were a major source of data
on hazardous waste activity in the valley.
EPA contractors, under the direction of the Office of Policy and Re-
source Management, in 1981 conducted a major, short-term pilot study of the
application of toxics integration procedures to a geographical area (the
Kanawha Valley). The study was multi-media and based primarily on avail-
able data. Both point and non-point sources were evaluated. Estimates of
releases of toxic substances to each media were made for all major sources.
Where site-specific data were not available, estimates of releases were
based on data on similar sources of pollution at other locations or on na-
tional average data. Environmental modeling was used to estimate ambient
levels of toxic pollutants because of a lack of ambient monitoring data.
Potential or known environmental problems were identified by comparing act-
ual or estimated environmental levels of toxic substances to available cri-
teria or standards. Potential control strategies were evaluated. This
study was primarily a pilot test of toxics integration methodology under
development for application to larger geographical areas. A draft contrac-
tor report33 was prepared but not published.
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III-7
As part of the toxics integration pilot project, EPA Region III con-
ducted a 5-day sampling survey in June 1981 of five stations on the Kanawha
River near Institute, five wastewater discharges from the Union Carbide
plant at Institute and one discharge from Chemical Leaman Tank Lines at
Institute. Samples were analyzed for purgeable organic compounds.34 An
evaluation of the impact of wastewater discharges on the Kanawha River was
also prepared.35
In 1982, EPA's Office of Water Regulations and Standards contracted an
evaluation of the impact of proposed effluent guidelines for the organic
chemical industry on water quality in the Kanawha River.36 The study, using
water quality models, simulated water quality in the river for present con-
ditions, with best practicable treatment (BPT) in place at organic chemical
plants and with best available technology (BAT) in place. The study eval-
uated the impacts of effluents from the Du Pont plant at Belle and the Union
Carbide plant at Institute based on actual effluent data. The impacts of
effluents from the Fike Chemicals, FMC, and Monsanto plants at Nitro were
estimated based on national average effluent characteristics rather than
plant-specific data. No evaluation of the impacts of the Diamond Shamrock
plant at Belle or the Union Carbide plant at South Charleston was attempted
as the Diamond Shamrock plant recycles process wastewaters and the Union
Carbide plant discharges to a municipal wastewater treatment works.
In 1982, DNR compiled data on hazardous wastes generated in West Vir-
ginia based on a survey of known generators.37 The inventory provides data
on types and volume of wastes generated by county, by industrial category
and by physical state. Information on reuse and on locations of treatment
and disposal (onsite vs. offsite and movement in and out of state) were
also compiled.
NEIC provided technical assistance to EPA Region III in 1982 in the
development of a draft NPDES permit for the FMC Corporation plant at Nitro.
A plant inspection provided current information on processes and pollution
control practices.38
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III-8
The Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (Superfund) resulted in much activity by EPA and West Virginia
during the past 3 years to inventory, inspect and evaluate inactive hazard-
ous waste disposal sites in the Kanawha Valley. To date, about 50 known or
potential sites have been investigated and detailed evaluations have been
performed on 15 sites.39 Fike Chemicals is the only site receiving a high
enough hazard rating to be named to the Superfund priority list, but other
sites are being considered for remedial measures.
An investigation of two inactive hazardous waste landfills (Smith Creek
and South Charleston Municipal Landfill) was conducted in 1981 as an Ohio
University Master's thesis project.40 The study developed data on landfill
contents and actual and predicted long-term environmental contamination.
In response to new information on sources and hazards of dioxin con-
tamination, EPA began a national investigation of dioxin contamination in
1983. The study targeted as a top priority for investigation those chemi-
cal manufacturing facilities that made certain organic chemicals that
potentially contained dioxin as a by-product. Sites where wastes from the
manufacture of these chemicals were disposed of were also given top priority.
In the Kanawha Valley, six sites were investigated including Fike Chemicals
and Monsanto at Nitro, Union Carbide at Institute and three associated waste
disposal sites. Preliminary EPA results have not been released.41 Monsanto
has announced that Company sampling has shown dioxin contamination at the
100 ppb level present in one area of its plant site.42
STUDY METHODS
Three basic approaches were used to compile available data which were
contained primarily in the published literature and regulatory agency files.
An extensive literature search was conducted to identify all useful pub-
lished literature. A key element of this search was a computer search of
selected commercial literature databases that allowed review of keywords
and abstracts of several million documents in the environmental field.
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III-9
Both geographical and subject search terms were used to yield the broadest
possible literature coverage. About 200 documents were identified as of
possible interest to this study.
Abstracts for the 200 documents were otained and reviewed and useful
items identified. These documents were then obtained from libraries around
the country when not available in the extensive NEIC library microfiche
holdings. The documents were reviewed as received and secondary references
cited by the documents obtained when appropriate. This literature search
supplemented a less extensive search that had been performed for the 1977
NEIC study.
The second major element of the data compilation activity was a
detailed file search. The file search encompassed the air, water and haz-
ardous waste program files at EPA Region III in Philadelphia and the files
of three West Virginia State agencies: Department of Natural Resources
(water and hazardous waste), Air Pollution Control Commission (air) and
Department of Health (drinking water).
Because an extensive search of EPA Region III files had been conducted
for the 1977 NEIC studies; this file search concentrated on updating infor-
mation filed since 1977 and on those program areas for which much new data
had been generated since 1977 (such as hazardous waste site investigations).
Available information was compiled on ambient air and water and biological
populations to aid in defining environmental conditions. Most data avail-
able through 1981 had been identified and summarized by the 1981 Toxics
Integration Project.33 The file search thus concentrated on recent data.
The 1977 NEIC study developed an inventory of potential point sources
of toxic substances in the Kanawha Valley and identified all major
sources.12 The Toxics Integration Project updated information on the major
sources and also estimated the significance of non-point sources of toxic
substances.33 The file search concentrated on verifying the current inven-
tory of sources of toxic substances and updating information on these
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sources. Recent data on air emissions, wastewater discharges and hazardous
waste management at major sources were compiled. This included NPOES per-
mit applications, permits, self-monitoring data and inspection reports,
RCRA permit applications and inspection reports, hazardous waste site
investigation reports and air emission inventories.
The third major element of the data compilation phase involved per-
sonal interviews with key EPA and West Virginia program personnel. Infor-
mation on past, present and proposed future environmental control programs
was obtained along with applicable environmental regulations and program
procedures.
Compiled data on environmental levels of toxic substances were com-
pared to appropriate criteria, guidelines and standards to define the rela-
tive magnitude of known or potential environmental problems. Because moni-
toring data on actual environmental levels of toxic substances were very
limited, predicted levels developed by model simulations in previous studies
were used in several cases to identify potential problems.
Available data on environmental levels or sources of toxic substances
are not adequate to prepare mass balances for any of the toxic pollutants.
The Toxics Integration Project developed estimates that are believed ade-
quate to identify which toxic pollutants may be of concern in the valley,
which environmental pathways from source to receptor are important and the
relative significance of various classes of point and non-point sources of
toxic pollutants.
Rating criteria were developed and applied to point sources of toxic
substances to define the relative magnitude of releases of toxic substances
to the environment from major sources. The rating criteria were based on
the relative magnitude of toxic substances present in air emissions and
wastewater discharges, hazardous waste management activity and site
contamination.
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IV-1
IV. ENVIRONMENTAL CONDITIONS
Chemical substances are present in large quantities in the Kanawha
Valley. The bulk of this volume is raw material or products of the various
chemical manufacturing plants. Chemical substances are also used by non-
chemical manufacturers, commercial establishments and residents in and
around their homes in many common products including pesticides, cleaning
agents and paints. This situation is not unique to the Kanawha Valley but
is shared with other areas of the country which have concentrations of
chemical manufacturing plants.
Releases of chemical substances to the environment from the various
industrial, commercial and residential activities are inevitable and, to
some degree, unavoidable. Some of these chemicals are hazardous or have
known or suspected toxicity or health effects. The quantity of such
releases, the types of chemicals and the pathways they follow are all impor-
tant in determining environmental impacts and resulting effects on man.
Within the Kanawha Valley, chemical substances are present to some
degree in ambient air, the inside air of homes and industrial plants, sur-
face waters including the Kanawha River and its tributaries, the suspended
and bottom sediments of these surface waters, contaminated groundwater aqui-
fers, public drinking water supplies, and fish and other aquatic life. All
of these media are important because they represent pathways by which chemi-
cal substances are transported through the environment and by which they
may ultimately impact on man.
In the past, controls on releases of chemical substances and other
pollutants to the environment were inadequate and serious environmental
impacts occurred. Inadequate controls on emissions of air pollutants pro-
duced severe degradation of air quality in the Kanawha Valley urban areas.
Large volumes of pollutants, including toxic substances, were discharged to
surface waters in industrial and municipal wastewaters and in contaminated
stormwater runoff. This resulted in major degradation of water quality in
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IV-2
the Kanawha River. Improper disposal of large volumes of hazardous wastes
also contaminated surface and groundwaters and surface soils near disposal
sites.
Over the past 25 years, implementation of various pollution abatement
measures to control traditional air and water pollutants (such as suspended
particulates in air and oxygen demanding substances in water) have resulted
in major improvements in air and water quality. Concurrent with this
improved control of traditional pollutants has been a reduction in releases
of toxic substances to the environment.
Recent improvements in man's understanding of the adverse health and
environmental effects of low levels of chemical substances have led to leg-
islation, regulations, and activities directed toward minimizing the pres-
ence of hazardous chemicals in the environment. This regulatory thrust,
coupled with improved control technology and disposal practices, has also
resulted in major reductions in releases of chemical substances to the
Kanawha Valley environment. However, because of past disposal practices
and the persistence of many chemical substances, coupled with deficiencies
in present regulatory programs, several environmental problems remain.
Controls on traditional air pollutants have been successful in achiev-
ing major enhancement of air quality such that air quality is now better
than required by ambient air quality standards for all regulated pollu-
tants. All regulated air quality parameters are in compliance with primary
ambient air quality criteria designed to protect public health.
Although the air pollution control program has been successful in
reducing traditional air pollution, a major area of concern remains. Var-
ious chemical substances (including some with known or potential toxic or
health effects) have been detected in Kanawha Valley ambient air. These
substances are not now regulated by State or Federal air pollution control
programs. Available data on ambient air concentrations of chemical sub-
stances in the valley are very limited and outdated. Reductions in emis-
sions of chemical substances of concern have occurred in recent years but
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IV-3
current emission levels are not fully defined. Past studies have shown
that the potential for adverse health effects may be present at some loca-
tions in the valley, but present data are inadequate to assess present con-
ditions. There is a need for an assessment of the current status of air
quality and emission levels of chemical substances.
Water quality conditions essentially parallel air quality. Water pol-
lution control programs have been successful in achieving major reductions
in discharges of conventional water pollutants with an associated enhance-
ment of water quality. Prior to the 1970s, water quality in the Kanawha
River was severely degraded and most water uses were seriously impaired.
Water quality in the River now meets applicable water quality standards
most of the time. Most water uses have been restored and fishing quality
and quantity have improved. However, several environmental problems related
to water quality remain.
The lower main stem of the Kanawha River is no longer designated (since
1981) or protected for public water supply use. This reflects the diffi-
culty and economic impact of achieving and maintaining water quality suit-
able for a public water supply.
Although aquatic life and fish populations in the River have substan-
tially improved during the past 15 years, the sports fishery has not achieved
its potential quality if additional control of point and non-point sources
of pollution were achieved. Samples of fish from several locations in the
River exhibit elevated levels of several toxic pollutants. Although observed
levels of toxic pollutants in the River are below concentrations known to
cause acute toxicity in aquatic life, previous studies suggest that there
may be potential problems with chronic toxicity to aquatic life and/or bio-
accumulation of toxic pollutants in fish. The studies also suggest that
potential health hazards from consumption of fish with elevated levels of
toxic substances may be present. Data are inadequate to fully evaluate the
effects of toxic pollutants on aquatic life in the River.
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Bioassays of wastewater effluents from several industrial facilities
have shown the discharges to be moderately to highly toxic to aquatic life.
Spills and leaks of toxic pollutants at industrial plants periodically re-
sult in the releases of such pollutants to the River. Current NPDES per-
mits for several major industrial plants do not limit toxic pollutants pre-
sent at significant levels in their wastewater discharges. West Virginia
water quality standards do not limit several toxic pollutants periodically
present at significant levels in the Kanawha River. Collectively, these
factors may be contributing to adverse environmental impacts on aquatic
life and beneficial water uses.
In the past, large volumes of industrial solid and liquid wastes, fre-
quently containing hazardous and/or toxic substances, were disposed of in
landfills, pits, ponds, lagoons, open dumps and other disposal sites that
were not properly designed, constructed and/or maintained to adequately
contain these wastes. As a result, toxic substances have been released to
the air, surface water and groundwater surrounding these sites. Large vol-
umes of toxic substances are still present at some of these sites. Because
of the persistent nature of these substances, several of the sites pose
long-term potential or actual sources of releases of toxic substances to
the Kanawha Valley environment. In several instances, leachate from inac-
tive disposal sites has contaminated private water supply wells.
In the following discussion, available data on air and water quality
are summarized and compared to applicable regulatory criteria and stand-
ards. Trends in environmental quality and problem areas are highlighted.
Monitoring needs are also identified.
AIR QUALITY
Suspended particulates and sulfur dioxide are the air pollutants that
have historically caused the most severe air quality degradation in the
Kanawha Valley. Installation of air pollution controls, plant and/or pro-
cess shutdowns, plant modernizations and other factors as the result of air
pollution regulations and economic incentives have substantially reduced
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emissions of these pollutants over the last 20 years. As shown in Table 3,
derived from the 1982 Annual Report of the West Virginia Air Pollution Con-
trol Commission43 (WVAPCC), maximum and average ambient levels of both of
these pollutants have been sharply reduced.
The WVAPCC monitors ambient air quality at 11 locations in the study
area which corresponds approximately to the Kanawha Valley intrastate air
quality control region (Region IV). Parameters routinely monitored include
total suspended particulates, sulfur dioxides, carbon monoxide, nitrogen
oxides and ozone. Parameters monitored vary from station to station. Moni-
toring data are used to assess compliance with national primary and second-
ary ambient air quality standards established by EPA and designed to pro-
tect public health. Air quality is now in compliance with all primary
ambient standards at all monitoring locations. As shown in Table 3, major
reductions in suspended particulate levels have occurred. Sulfur dioxide
levels (annual mean) are only about one-fourth of the primary standard.
Carbon monoxide, nitrogen oxides and ozone levels are also well below
applicable limits.
With respect to hazardous air pollutants, EPA has established regula-
tions for only five pollutants of which only two (benzene and vinyl chlor-
ide) have been of concern in the valley. These regulations are emission .
limits rather than ambient air standards. Vinyl chloride is no longer
manufactured in the valley. Although it is still used in one plant, emis-
sion levels are reportedly very low in comparison with the previous manu-
facturing emissions. EPA promulgated regulations for fugitive emissions of
benzene from organic chemical plants in June 1984.
There are numerous chemical substances emitted to the atmosphere of
the Kanawha Valley in significant amounts. Many of these are volatile
organic compounds (VOCs) which have suspected or known human health effects
at relatively low ambient concentrations. Several substances such as ben-
zene and vinyl chloride are suspected or known human carcinogens. Emis-
sions of VOCs to the atmosphere are believed to be about an order of magni-
tude greater in total weight than releases of VOCs to water and
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Table 3
AIR QUALITY TRENDS43
Total Suspended Participate Matter
(micrograms per cubic meter)
Maximum Value
Annual Geometric Mean
Location
1965
1982
1965
1972
1977
1982
Montgomery
Charleston
S. Charleston
Nitro
1012
722
899
667
137
167
148
184
379
261
172
145
153
108
-
81
71
93
84
68
60
65
63
54
Sulfur Dioxide
(micrograms per cubic meter)
Location
Arithmetic Mean
1968
1970
1975
1980
1982
N. Charleston
S. Charleston
Nitro
60
43
57
34
46
43
26
19
37
26
21
17
18
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IV-7
groundwater.33 The significance of the levels of VOCs present in the valley
cannot be evaluated with present information.
Unfortunately, monitoring data on ambient levels of VOCs are very
limited and dated. This is due to the combined effects of a lack of suit-
able monitoring methods, the expense of sample analyses and no regulatory
limits to compare with the data.
In 1975, a reconnaissance survey of ambient air near chemical plants
in the Kanawha Valley detected nitrosamines near Belle and South Charleston.9
A source of nitrosamine emissions at Belle was identified and abated. Vinyl
chloride was detected in South Charleston. Manufacture of vinyl chloride
has since ceased.
Special ambient air sampling in mid-1975 was conducted at about 15
locations in the Kanawha Valley by Research Triangle Institute (RTI) under
contract to EPA.6 The Kanawha Valley was one of several locations sampled
as part of a study to develop techniques for measuring carcinogenic vapors
in ambient atmospheres. Volatile organic compounds detected included ben-
zene, carbon tetrachloride, chlorobenzene, chloroform, dichlorobenzene,
methyl chloride, methylene chloride, naphthalene, tetrachloroethylene,
1,1,1-trichloroethane and toluene. Concentrations were not given.
RTI conducted additional ambient air sampling in the valley in late
1977 under an EPA contract.28 Short-term sampling was conducted during 2-
to 4-day periods in late September, late October and mid-November at nine
locations. Numerous halogenated organics, volatile organics and polynuclear
aromatic compounds were detected at widely varying concentrations. Quanti-
tative data were developed on only part of the samples and compounds.
Ambient concentrations were observed to vary significantly between
sampling periods and among locations. Highest concentrations generally
occurred during the October sampling. Organic compounds with the higher
concentrations included benzene, toluene, naphthalene, acetophenone, ethyl
-------
IV-8
acetate, methylene chloride, chloroform, carbon tetrachloride, 1,1,1-tri-
chloroethane and tetrachloroethylene. The highest concentrations of most
of these compounds occurred in South Charleston and St. Albans, although
higher concentrations were also detected for some compounds in Belle,
Charleston, Institute and Nitro.
Benzene had the highest concentration (71.8 ug/m3) in St. Albans in
October, but also exceeded 3 ug/m3 in South Charleston, 2 ug/m3 in Institute
and 1 ug/m3 in Nitro. Toluene concentrations ranged up to a peak of 2.9
ug/m3 in St. Albans. Other high concentrations in St. Albans were naph-
thalene (4.7 ug/m3) and ethyl acetate (6.9 ug/m3). Acetophenone (5.0 ug/m3)
and naphthalene (3.8 ug/m3) were elevated in South Charleston. Methylene
chloride was highest in South Charleston (11.3 and 9.8 ug/m3) but also
ranged from 1.6 to 4.1 ug/m3 in Belle, Charleston, Institute and Nitro.
Carbon tetrachloride was found at trace amounts at most locations
(<0.1 ug/m3) except at St. Albans (3.63 ug/m3) and South Charleston (2.22
ug/m3).30 Manufacture of carbon tetrachloride in South Charleston has
ceased since the 1977 sampling. Ambient air modeling by the Toxics Inte-
gration Project in 1981 suggested worst case 24-hour concentrations of car-
bon tetrachloride might exceed 10 ug/m3 based on continued manufacture and
various simplifying assumptions.33
Chloroform levels observed by RTI ranged from <0.12 ug/m3 at most loca-
tions to a high of 2.16 ug/m3 in South Charleston.28 Toxics Integration
Project modeling suggested peak concentrations in the range of 8 to 26 ug/m3
might be possible near industrial facilities in Belle and Institute.33
The 1977 RTI ambient air study is believed to be the latest evaluation
of levels of volatile organic compounds in the valley by regulatory agen-
cies. Several industries may be collecting data on selected parameters,
but such data were not available for this study. There have been signifi-
cant changes in emissions of volatile organics since 1977 due to plant
closings, process changes, etc. The 1977 data are thus probably not repre-
sentative of current conditions.
-------
IV-9
The observed levels of several volatiles were substantially above
normal atmospheric levels for non-industrial areas. There are no regula-
tory limits to assess the significance of the observed concentrations; how-
ever, these levels are high enough to be of concern when compared with data
on levels of volatile organic compounds believed to have potential chronic
health impacts.
It is clear from the range of values observed in the short-term study
and predicted by modeling that much more ambient data obtained under a var-
iety of meteorological conditions are needed to assess present levels of
volatile organic compounds in the valley atmosphere. The WVAPCC is obtain-
ing an analytical instrument to begin such monitoring.
The WVAPCC monitors regularly for lead in ambient air. Ambient levels
in 1980 were in the range of 0.34 to 0.77 ug/m3.33 The observed levels in
1982 were in the range of 0.11 to 0.40 ug/m3.43 These levels compare favor-
ably with the ambient air standard of 1.5 ug/m3.
The WVAPCC also monitors rainwater as an assessment of possible acid
rain effects in the valley. The pH of normal rainfall is generally con-
sidered to be about 5.6. The observed pH of rainfall ranged from 3.6 to
5.6 in Charleston and 3.3 to 5.7 at Guthrie near the study area.43 Analy-
sis of the rainwater indicated sulfates were the primary constituent. Moni-
toring and analytical methods were not described.
Several attempts have been made to use health data to identify possible
problem areas with possible air pollution implications. A study of mor-
tality data for one area of North Charleston was conducted by the Depart-
ment of Health in early 1982.44 The study concluded that for the 1970-79
period, mortality due to malignant neoplasms was significantly greater than
expected. Data were apparently not evaluated for the effects of occupa-
tional exposure, smoking habits and other factors that could influence mor-
tality rates. The study was conducted because of concerns about possible
adverse health impacts of air pollution but available data evaluated were
not adequate to determine the potential causes of the excess mortality.
-------
IV-10
An occupational health study of a Belle chemical plant was conducted
in 1978 and 1979 to evaluate the occurrence of possible excessive levels of
eye lesions and neoplasms.45 Data were not adequate to determine the cause
of the unusual levels of these health problems that were observed.
WATER QUALITY
Water quality in the Kanawha River is protected by West Virginia water
quality standards for water contact recreation, industrial water supply,
agricultural water supply, propagation and maintenance of fish and other
aquatic life and water transport, cooling and power.1 Zone one of the river
from its origin at Gauley Bridge downstream to Mile Point 72 near Diamond
is also protected for public water supply. Zone two, the lower 72 miles of
the river, is not protected for public water supply. This use was dropped
for zone two in 1981. The lower river has not been used as a water supply
since the Nitro plant was closed in the mid-1970s. St. Albans has an auxil-
iary intake near the mouth of the Coal River in the Kanawha River backwater.
This intake could conceivably use some Kanawha River water during extreme
low flows on the Coal River.
The water quality standards specify both narrative and numerical cri-
teria on a variety of water quality characteristics including several toxic
pollutants (arsenic, cadmium, copper, cyanide, chromium, lead, mercury,
zinc and several pesticides).1 Numeric criteria have not been established
for toxic organic pollutants other than the pesticides. In the past, severe
water quality degradation and widespread noncompliance with water quality
standards for the lower river were common. As the result of pollution con-
trol programs, major enhancement of water quality has occurred. This is
best demonstrated by dissolved oxygen levels in the river. Before 1970,
zero dissolved oxygen levels frequently occurred in the river during summer
low-flow periods. As shown in Figure 4, dissolved oxygen levels progres-
sively improved during the 1970s as loads of oxygen demanding pollutants
discharged to the river were reduced.11 This improvement has continued.
For the 1979-81 period, dissolved oxygen levels in the river averaged 8.6
mg/£ and there were no violations of the 4.0 mg/£ minimum limit.46
-------
9 =-
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/^
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s
A
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\
»
\
Ar^
r/
^SS
~ /
/
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i
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i
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I I I I 1
x- ««. '
I I I I I I I I I I I I I 1 I I I I ill
1/8/1967
10/19/19)1
I/IS-8/16/1973
1/21/1978
10
20
30
KANAWHA RIVER MILE POST
-------
IV-12
Although good dissolved oxygen levels are now achieved, the river is
water quality limiting for oxygen demanding pollutants. Waste load alloca-
tions have been assigned to major wastewater dischargers.
For most other water quality parameters, water quality meets or exceeds
applicable numerical criteria all or most of the time based on periodic
monitoring by the Department of Natural Resources, Water Resources Division.46
For the 1979-81 period, a few (<15%) violations of criteria occurred for
pH, cyanide, manganese, lead and cadmium. For phenolics and iron, viola-
tions were more frequent, in the 15-49% range. Fecal coliform criteria
were violated more than half the time. The pH, iron and manganese problems
were attributed to coal mining impacts. No particular quality trends were
reported.
Although violations of the cyanide and lead standards are infrequent,
they are of some concern. Modeling of ambient concentrations in the lower
Kanawha River for various flow conditions was performed as part of an EPA
assessment of the environmental impact of proposed effluent guidelines for
the organic chemicals industry.36 This study indicated the potential for
discharges of cyanide from chemical plants to produce chronic effects on
aquatic life during low streamflow conditions both for present wastewater
discharge and when best practical treatment or control technology (BPT) had
been installed. Installation of best available pollution control techno-
logy (BAT) would eliminate this adverse effect. The same study indicated
the potential for a low level of increased health risk associated with con-
sumption of possible arsenic-contaminated fish from the river. This risk
was present at all levels of pollution control including BAT but BAT would
reduce the risk to the 10~6 level at low flow conditions. If the river
were to be used as a public water supply, the risk level would be higher.
Observed lead concentrations in the river over the 1978-1981 period
have ranged from <20 ug/£ (the detection limit) to 120 ug/£.33 Maximum
concentrations in various reaches ranged from 60 to 120 ug/£. These maxi-
mum values are significantly higher than the water quality standard of
25 pg/£ and may exceed chronic or acute toxic levels for aquatic life.47
During the June 1981 EPA survey, lead was <5 ug/£.
-------
IV-13
Prior to 1979, data on the presence and concentrations of toxic organic
pollutants in the Kanawha River were practically non-existent. Since 1979,
more data have become available but still are limited, especially during
critical low-flow periods. The main sources of data are the Ohio River
Valley Water Sanitation Commission (ORSANCO) organic detection system moni-
tor, data on intake water quality submitted with NPDES permit applications
and a short-term stream sampling survey conducted by EPA in June 1981.
These data are summarized in the Toxics Integration Project report33 and
the 1979-1981 DNR 305(b) water quality report.46
ORSANCO operates a number of organic detection monitors on the Ohio
River and major tributaries to serve as an early warning system to detect
spills of organic chemicals in the river system. The Kanawha River monitor
(designated as at St. Albans) is north of Nitro downstream of all chemical
plant wastewater discharges. Monitoring, which began in 1979, is for purge-
able halogenated organic compounds. Although the primary purpose of the
monitor is spill detection, the frequency of sampling and length of moni-
toring record provide data on the frequency and level of occurrence of these
compounds in the lower river and some indication of trends.
For the 1980-81 period, the monitor detected eight compounds (bromodi-
chloromethane, carbon tetrachloride, chloroform, dichloroethane, 1,2-di-
chloropropane, methylene chloride, tetrachloroethylene and trichloroethyl-
ene) in more than 50% of the 257 samples analyzed.46 Chloroform (90%) and
carbon tetrachloride (83%) were the most frequently detected. Most com-
pounds detected were at levels less than 1 pg/£ in most samples. About
two-thirds of the chloroform samples, however, were in the 1-10 ug/£ range
with six samples exceeding 10 ug/£. About half of the carbon tetrachloride
samples were in the range of 1-10 ug/£. There were a total of 14 instances
representing four compounds that exceeded 10 ug/£.
Carbon tetrachloride in the 190 samples taken by ORSANCO during 1979
and 1980 ranged from <0.1 to 14.7 pg/£ with a median concentration of 1.3
ug/£.33 The median concentration decreased from 2.1 ug/£ in 1979 to 1.1
ug/£ in 1980, probably reflecting the shutdown of carbon tetrachloride
-------
IV-14
production at FMC in South Charleston in 1980. Observed concentrations
during the June 1981 EPA short-term survey were in the 0.2 to 0.6 ^g/£
range.35
ORSANCO data for 1979-80 showed chloroform levels ranging from <0.1 to
219 (jg/£ with a median of 1.5 pg/2.33 The high value was produced by an
apparent chloroform spill of unknown origin. Median chloroform concentra-
tions increased from 0.8 ug/£ in 1979 to 2.0 ug/£ in 1980. Observed levels
during the 1981 EPA survey were in the 0.9 to 2.2 [iq/l range.35 Chloroform
concentrations for the water intake at the long-term monitoring of chloro-
form at the Union Carbide plant intake in Institute averaged about 41 ug/£
for the 1977-80 period.33 NPDES permit application data for 1979-80 at the
same intake averaged <10 ug/£.33 An average value of 132 |jg/£ at a plant
intake in Nitro has also been reported in a permit application.33 These
data indicated that significant levels of chloroform were continuously pre-
sent in the river with substantially higher peaks periodically occurring.
Peak values were below levels considered to be acutely or chronically toxic
to aquatic life.47 Mean concentrations posed a low level (10~7) of health
risk for ingestion of aquatic organisms contaminated with chloroform. If
the river were evaluated as a source of drinking water, the risk level would
increase to the 10~5 level.
The 1983 effluent guidelines study indicated there may be a potential
low health risk associated with consumption of contaminated fish from the
river based on modeled concentrations of benzene, chloroform and 2,4-dini-
trotoluene under present wastewater discharge conditions.36 This risk dis-
appears at the BAT treatment level.
In the above discussion, various potential impacts on aquatic life
have been projected based on observed pollutant levels and water quality
criteria based on scientific studies. In a specific stream situation, var-
ious factors such as synergistic effects of multiple pollutants, etc. may
cause aquatic life to respond differently than predicted. Biological
studies of aquatic life in the stream are the only means of fully assessing
the impact of water quality.
-------
IV-15
A comprehensive EPA biological study of the river in the mid-1960s
documented the major impacts of pollution on the lower river in comparison
to upstream locations.48 At London Dam, 13 miles upstream from Charleston
(but downstream of the Belle industrial complex), 9 to 25 taxa were present
including caddisflies, mayflies and dragonflies, all pollution-sensitive
organisms. In contrast, at Winfield Dam 30 miles downstream from Charles-
ton and downstream of all industrial complexes, only 1 to 9 taxa were
observed and these were almost entirely pollution-tolerant aquatic earth-
worms and midges. Recent benthic data indicate similar macroinvertibrate
populations at London Dam but much improved populations at Winfield Dam.46
In 1980, there were 15 taxa present at London and 13 at Winfield. For 1981,
London had 29 taxa and Winfield had 21. For both years, the diversity index
was lower at Winfield than at London. An even lower diversity index was
present at the mouth of the r.iver near Henderson. These data indicate that,
although benthic organism populations have substantially improved in the
lower river over the last 10 to 15 years, the impacts of pollution are still
measurable.
Data on fish populations also show similar trends. In the 1960s, a
diverse fish population was present in the upper river indicating various
desirable gamefish. In contrast, fish populations in the lower river were
predominantly pollution-tolerant rough fish less desired by fishermen.
Sport fishing for catfish did occur in the lower river but the fish were
often tainted with a displeasing taste and/or odor.48 A comparison of fish
sampling data for the 1968-80 period at London and Winfield Dams indicates
that desirable gamefish populations at Winfield increased dramatically in
the late 1970s and are now similar in numbers to London Dam.36 The quality
and quantity of the fishery at London also improved during this period. A
record striped bass was caught near Charleston in 1982 and hourly catch
rates in bass tournaments have increased substantially in recent years.36
Given the increase in the quality of the Kanawha sport fishery, it is
probable that consumption of fish from the river is increasing. Contami-
nation of fish with toxic substances thus becomes of greater concern. Fish
samples from the river are periodically monitored by various agencies.
-------
IV-16
Data for PCBs were available for the 1969-81 period.33 46 In the past,
high levels of PCBs were detected from fish collected at Winfield. For the
1968 to 1970 period, PCB levels averaged above 2 ppm with a maximum of
14 ppm.33 In 1981, two fish samples at Winfield averaged about 0.7 ppm
PCBs. The Food and Drug Administration (FDA) has established a temporary
tolerance limit of 5 ppm for PCBs in edible fish flesh.49 In 1977, FDA
revised the temporary tolerance limit downward to 2 ppm. This limit was
stayed indefinitely in 1979. Comparison of the observed PCB levels in fish
to these limits indicate that potential health hazards from consumption of
fish caught at Winfield were present in the past, but recent data indicate
a lesser risk, although as recently as 1979 a level of 10 ppm was observed.
Data on PCBs in fish at London for the 1979-81 period indicate average
levels of about 1 ppm with a maximum of 3 ppm.33 46 For the 1969-74 per-
iod, PCBs in fish samples from near Charleston showed the highest average
levels of 3.3 ppm with a maximum of 13 ppm.33 Recent (1981) data indicate
PCBs remain high in this vicinity. Two samples obtained near the State
capitol had PCB levels of 1.6 and 2.4 ppm, respectively.46
There are no known point sources of PCBs in the Kanawha Valley. Spill
logs maintained by EPA indicate periodic small spills of PCBs from trans-
formers and capacitors are presently occurring.50 Past releases of PCBs
may have contaminated bottom sediments in the river.
Fish samples in 1981 obtained near the State capitol contained concen-
trations of chlordane, a pesticide, averaging about 0.2 ppm.46 The FDA
action level for fish flesh is 0.3 ppm. Chlordane levels in fish samples
from other river locations were lower. Chlordane is used for termite con-
trol around residential and commercial buildings and is a persistent chlor-
inated hydrocarbon.
No data were available on concentrations of toxic organic pollutants
such as carbon tetrachloride and chloroform in fish.
-------
IV-17
Most of the permits issued to major dischargers of industrial
wastewaters in the valley require that periodic bioassays be conducted on
the wastewater effluents. These bioassays are short-term (usually 96-hour)
tests of the acute toxicity of the wastewaters to aquatic life. Through
application factors, they can give some measure of the potential chronic
toxicity effects of the effluents as well. Data reported to EPA and DNR
indicate that several of the major wastewater discharges regularly or per-
iodically exhibit moderate to high levels of acute toxicity.7 30 In most
cases, the cause of the toxicity has not been defined. Data are also inade-
quate to assess the impact (acute or chronic) on aquatic life in the river
although there are some known impacts, as discussed above.
HAZARDOUS WASTE DISPOSAL
Large volumes of solid and liquid industrial wastes are generated by
industrial facilities in the valley. Substantial amounts of these wastes,
especially those generated by chemical plants, have been designated as haz-
ardous wastes by EPA and/or DNR because they are corrosive, ignitable,
reactive or contain toxic substances. In the past, large volumes of hazard-
ous wastes were disposed of in landfills, pits, ponds, lagoons, open dumps,
strip mines and other disposal sites that were not properly designed, con-
structed or maintained to adequately contain these wastes. Other poor dis-
posal practices resulted from ignorance on the part of the waste generator.
In a few cases, illegal waste disposal was knowingly conducted.
As a result of this past inadequate disposal, toxic substances are
being released to the environment in significant amounts from many loca-
tions. There are at least 50 sites that are suspected of containing toxic
hazardous wastes. Groundwater contamination has occurred at some hazardous
waste sites and poses problems that regulatory agencies are investigating.
Fortunately, use of groundwater for drinking water supplies is minimal in
the valley. However, in several cases, private drinking water supplies
have been contaminated. This posed unacceptable health risks to residents
and alternate water supplies were obtained, sometimes at significant cost
to residents.
-------
IV-18
Other environmental problems associated with hazardous waste sites
include migration of toxic chemicals in leachate into surface streams, con-
tamination of surface soils at sites with subsequent transport of toxic
chemicals in surface runoff, emission of volatile organic compounds to the
air, fires and explosions. Several small streams tributary to the Coal
River near the St. Albans water supply intake receive leachate. The air
emissions, fires and explosions were more of a problem when sites were
active but these hazards remain a potential problem. The large volumes of
wastes present at several of the larger sites, coupled with the persistent
nature of the toxic substances, pose a long-term potential for major
releases of toxic substances to the environment.
Various remedial measures are being taken by regulatory agencies, site
owners and waste generators to abate the release of toxic substances from
inactive hazardous waste sites. In some cases, such as the Poca Drum site
(an illegal dump of drums of hazardous wastes in a strip mine), immediate
removal actions are taken by regulatory agencies to remove the source of
contamination. Another site (Fike Chemical) has been placed on the Super-
fund priority list for major remedial action. For most sites, however,
site investigations ranging from preliminary assessments to full site
investigations involving environmental and waste sampling and monitoring
well installation have been conducted. A few sites have not yet been
investigated. In most cases, little actual remedial work to remove or con-
tain contamination has been accomplished. This is due to the relatively
young age of the hazardous waste site program, the complexity and high cost
of remedial measures needed and legal complications where responsible
parties have been identified. There is a well-defined need to complete the
full site investigations where warranted so that the most hazardous sites
can all be identified and remedial work begun.
Many of the environmental problems associated with hazardous wastes
occur at inactive sites. However, industrial facilities continue to gen-
erate, store, treat and dispose of major volumes of hazardous wastes in the
valley. Hazardous waste management practices are much improved, but nation-
wide experience of regulatory agencies administering the hazardous waste
-------
IV-19
management program established by RCRA suggests that current disposal
practices may still pose environmental problems in some cases. Both EPA
and DNR are actively assessing current practices in the valley.
-------
V-l
V. SOURCES OF TOXIC SUBSTANCES
Chemical substances, including toxic or potentially toxic substances,
are released to the environment of the Kanawha Valley from numerous point
and non-point sources. An evaluation of these various types of sources was
conducted by the Toxics Integration Project in 1981 and estimates were made
of the releases of 15 toxic substances to ambient air, surface waters and
in hazardous waste disposal [Table 4].33 This evaluation indicated that
industrial manufacturing plants and hazardous waste disposal sites were the
most important point sources. Important non-point sources include aban-
doned coal mines, residential and commercial facilities, transportation and
urban runoff. Other sources/pathways were considered minor. Municipal
wastewater treatment facilities were considered together with industrial
facilities by the Toxics Integration Project.
In the following discussion, additional details are presented on each
type of source including the pathways by which toxic substances are
released to the environment. Details are presented on the preparation of
an inventory of all known and potential point sources and the subsequent
rating of individual sources to identify major sources of toxic substances.
Major industrial and hazardous waste facilities are listed. Detailed dis-
cussions on the major sources are presented by area in Sections VI-VIII.
POINT SOURCES
Industrial
Industrial manufacturing plants are the most important sources of
toxic substances in the Kanawha Valley. Many of these facilities handle,
transport, consume, and produce large volumes of toxic substances. It is
inevitable and unavoidable that some of these substances are released to
the environment from such facilities.
Industrial wastewaters are a common pathway for transport of toxic
substances from industrial plants. These include process wastewaters, cool-
ing water, and miscellaneous utility and other waste streams. The volume
-------
Table 4
SUMMARY OF TOXIC SUBSTANCES CONTRIBUTIONS BY SOURCE/PATHWAY33
(loads in ton/year)
Source/Pathway
Acrylonitrile Arsenic Benzene
Cadmium
Carbon
Tetrachloride
Chloroform
Lead
Industrial Point Sources
Air Emissions
Wastewater Discharges
Hazardous Waste Disposal
Spills
Non-Point Sources
Residential & Commercial
Air Emissions
Transportation
Air Emissions
Inactive Coal Mines
Mine Drainage
Urban Runoff
34
1
5
4.3
95-204
10
2.4
52
13
30
12
16
11.9
10.3-17.5
291
7.3
6.5
0.6
0.7
323
17
2.8
1.0
46
6.3
10.3-113
Source/Pathway
Mercury
Vinyl
Chloride
Chlorine
Formaldehyde
Nickel
PAHs
Perchloro
ethyl ene
1,1,1-Trl-
chloro-
ethane
Industrial Point Sources
Air Emissions
Wastewater Discharges 0.51
Hazardous Waste Disposal 0.06-27
Spills
Non-Point Sources
Residential & Commercial
Air Emissions
Transportation
Air Emissions
Inactive Coal Mines
Mine Drainage 0.12
Urban Runoff 0.03
31
0.35
0.05
0.6
3.1
168
5.7
11.8
22
3.1
151
2.4
4.5
0.36
2.5
123
0.12
139
IV
-------
V-3
and types of toxic substances in the wastewaters are affected by the
process/ products, in-process controls, spill control practices, site con-
tamination and wastewater treatment units present at the facility.
Wastewaters may be either discharged directly to surface waters after
treatment (if required) at the industrial plant or they may be discharged
to a municipal sewer system for treatment at a municipal wastewater plant
(indirect discharge). In the latter case, the volume and types of toxic
substances reaching surface waters are also affected by the type and effi-
ciency of treatment provided at the municipal plant. In the Kanawha Val-
ley, all major industrial sources of toxic substances, except the Union
Carbide plant at South Charleston and the nearby Technical Center, dis-
charge wastewaters directly to surface waters. The two Union Carbide facil-
ities discharge their process wastewaters to the South Charleston wastewater
treatment plant.
Because large volumes of chemical raw materials or products are often
handled or stored, spills and leaks of chemical substances may occur within
an industrial plant site. Stormwater runoff or groundwater may become con-
taminated in such cases and transport these substances offsite. This was
more of a problem in the past when material handling and maintenance proce-
dures were not adequate. The increased use of best management practices
(BMPs) for control of spills and leaks has reduced this problem. However,
past spills and leaks may have seriously contaminated a plant site, often
with chemicals no longer used or produced at the site.
Many industrial plants, especially chemical manufacturers, generate
large volumes of hazardous wastes that may contain chemical substances.
These wastes are often stored and/or treated onsite prior to ultimate dis-
posal. Disposal may be either at the industrial plant site or at some
other location. Both storage and treatment activities are potential
sources of spills or leaks of chemical substances. Disposal poses a higher
hazard for release of toxic substances to the air, surface water or ground-
water. This was especially true of past onsite disposal practices that did
not adequately contain hazardous wastes.
-------
V-4
Many industrial processes emit air pollutants to the atmosphere. Air
pollutants are also emitted by raw material and product storage facilities,
material handling areas and transportation facilities. As in the case of
industrial wastewaters, the volumes and types of toxic substances emitted
are a function of factors such as process/product combinations and air pol-
lution controls. As shown in Table 4, industrial air emissions are the
largest source of toxic substances in the Kanawha Valley. Emission rates
shown in Table 4 are based on 1977 emission inventories.33 A Department
of Health evaluation, based on preliminary data on 1981 emission rates at
seven chemical plants, suggests that current hydrocarbon emission rates may
be less than 30% of the rates shown in Table 4.51 Current air emissions
would still be much higher than other sources of toxic substances.
Municipal
Municipal wastewater treatment plants that receive significant indus-
trial wastewaters can be important sources of chemical substances. Com-
bined sewer overflows and sewer system bypasses can also be important if
the sewers contain industrial wastes.
Municipal wastewater treatment plants usually treat wastewaters con-
sisting primarily of domestic sewage and commercial wastewaters. Such
wastewaters usually contain low levels of some chemical substances used in
the home and in commercial establishments. If the volume of wastewater is
large, the contribution of chemical substances could be significant.
There are 20 municipal wastewater treatment plants in the study area.
The South Charleston plant receives a majority of its wastewater from the
Union Carbide industrial plant in South Charleston. Wastewater character-
istics in its large flow (about 7 mgd) are more typical of industrial
wastewaters, so it is considered an industrial point source for purposes of
this study.
The 19 municipal wastewater treatment plants [Table 5] collectively
discharge about 15 mgd of combined domestic, commercial and minor volumes
-------
V-5
Table 5
MUNICIPAL WASTEWATER TREATMENT PLANTS
Municipality/District Receiving Stream
Flow (mgd) Type Treatment*
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
Belle
Charleston
Chesapeake
Dunbar
East Bank
East Kanawha PSD
Fairview PSD
Glasgow
Marmet
Montgomery
Nitro
Poca
Pratt
Smithers
St. Albans
Union PSD (Rocky
Fork - Plant A)
Union PSD (Koontz
Dr. - Plant D)
Union PSD
(40th St.)
Winfield
Kanawha
Kanawha
Kanawha
Kanawha
Kanawha
Little
Coal Ri
Kanawha
Kanawha
Kanawha
Kanawha
Pocatal
River
River
River
River
River
Guano Creek
ver
River
River
River
River
ico River
Paint Creek
Kanawha
Kanawha
Indian
River
River &
Creek
Rocky Fork Creek
Pocatal
Armours
Kanawha
ico River
Creek
River
Total
0.
8.
0.
1.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
1.
0.
0.
0.
0.
15.
20
50
349
10
125
10
20
22
25
45
40
075
050
24
5
65
255
32
035
019
secondary
secondary
primary
secondary
primary
secondary
primary
primary
primary
primary
secondary
secondary
primary
secondary
secondary
secondary
secondary
secondary
secondary
(AS)
(AS)
(TF)
(AS)
(AS)
(AS)
(AS)
(TF)
(AS)
(AS)
(AS)
* AS - activated sludge; TF - trickling filter
-------
V-6
of industrial wastewaters.33 Data on the actual contribution of toxic sub-
stances from these facilities are not available. Estimated contributions
based on typical toxic pollutant concentrations at treatment plants in simi-
lar urban/suburban settings indicate the municipal sources in the Kanawha
Valley are minor relative to industrial sources.
Hazardous Waste Disposal Sites
Hazardous waste disposal sites have the potential to be major sources
of toxic substances. Many hazardous wastes contain high concentrations of
toxic substances. If not adequately contained, these substances may be
released to the environment through ground and surface waters and air
emissions.
Mose hazardous waste disposal sites in the Kanawha Valley are land-
fills. Hazardous wastes have been placed in the landfills in liquid or
solid form, in bulk or in containers. Ultimately, liquids move from the
landfills into the environment unless adequate containment measures have
been used as are now required for active landfills. This movement is in
the form of leachate which may be the hazardous waste liquid itself or,
more commonly, the liquids diluted by precipitation or groundwater perco-
lating through the landfill.
Because containment measures were not adequate at most of the earlier
landfills, contamination of ground and/or surface waters has become a prob-
lem at a number of locations. If a landfill contains large volumes of per-
sistent chemical substances, the landfill will continue to be a source of
these substances for many years unless remedial measures are initiated to
minimize or eliminate leachate migration.
Inactive hazardous waste landfills are a major problem. These were
usually the earlier sites that had the poorest containment. Records of
what hazardous wastes are present at a site are often sketchy or non-
existent. Because of the age of the landfills, chemical substances have
had a longer time to migrate into the environment.
-------
V-7
Hazardous waste disposal sites may be located at an industrial plant
(onsite disposal) or at another non-industrial location (offsite disposal).
The offsite disposal facilities include sites operated by an industry for
their own waste disposal; commercial or public landfills that primarily
received non-hazardous wastes such as household trash and garbage, but also
some hazardous wastes; and the commercial hazardous waste facilities re-
ceiving wastes from many sources. Onsite disposal is discussed with indus-
trial point sources in this report while the offsite disposal facilities
are discussed separately.
The actual concentrations of toxic substances in hazardous wastes being
disposed of in the Kanawha Valley are not known. The contributions of toxic
substances from industrial waste disposal shown in Table 4 reflect the total
volume of wastes containing the substance.33 Actual contributions of each
substance would usually be much lower than shown.
Non-Point Sources
Coal mining has been and is a major industrial activity in the Kanawha
River Basin. There are several hundred active mines and thousands of inac-
tive mines in the basin. In 1979, there were 73 active deep mines, 39 ac-
tive surface mines and 12 preparation plants along the mainstem Kanawha
River and its small tributaries.48 There were 976 abandoned deep mines and
352 abandoned surface mines. Larger numbers were present in the drainage
areas of major tributaries.
Active coal mines and preparation plants are regulated by the NPDES
permit program. Available data indicate these mines are not significant
sources of toxic pollutants. Drainage from some inactive deep mines and
numerous inactive surface mines is a major non-point source of pollution.
This drainage is often acidic and contains high levels of iron, manganese
and suspended sediments. This drainage impacts water quality in the Kana-
wha River and has produced violations of water quality standards for pH,
iron and manganese. The sediments also affect water clarity and bottom
strata with adverse impacts on aquatic life. As shown in Table 4, the mine
drainage also contributes significant loads of arsenic, cadmium, lead, mercury
and nickel, all toxic pollutants.
-------
V-8
Residential and commercial land uses were estimated to be major
non-point sources of benzene, perchloroethylene (tetrachloroethylene) and
1,1,1-trichloroethane [Table 4].33 Perchloroethylene is in common use as a
dry cleaning agent. Trichloroethane is widely used as a degreaser. Sur-
face runoff from urban areas was estimated to contribute significant loads
of arsenic, cadmium, lead, mercury and nickel, predominantly lead
[Table 4].33 Air emissions from transportation activities, including fuel
handling and combustion in mobile sources, contribute significant amounts
of benzene and lead.
IDENTIFICATION OF MAJOR INDUSTRIAL SOURCES
There are about 200 manufacturing facilities and several hundred more
commercial facilities in the Kanawha Valley. Only a relatively small num-
ber of these facilities potentially release significant amounts of toxic
pollutants into the environment. In order to identify which facilities
were major sources, an inventory of all known industrial facilities was
prepared. A rating system was then used to define major sources.
An inventory of all known manufacturing facilities in the study area
had been prepared for the 1977 NEIC study.12 Data from several sources
were used to update this inventory. This included a 1981 directory of West
Virginia manufacturers;52 a 1983 directory of chemical producers;53 EPA's
Permit Compliance System (PCS), a computer file of NPDES permit data;54
EPA's Hazardous Waste Data Management System (HWDMS), a computer file of
RCRA permit applicants;55 a listing of all generators and transporters of
hazardous waste and hazardous waste management facilities that notified EPA
in 1980 of their activities31 and EPA and DNR files.
The 1977 inventory listed 206 manufacturing facilities with addresses
in the study area. Comparison with the 1981 manufacturing directory indi-
cated that only nine new facilities had been added since 1977 but 60 facil-
ities were no longer listed. Most of these changes were small plants. Av-
tex was the only major industrial facility to cease manufacturing opera-
tions. There were no new major industries.
-------
V-9
There were 442 NPDES permits listed for Fayette, Kanawha and Putnam
counties.54 Most of these were for coal mines, municipal wastewater treat-
ment plants and domestic waste discharges and most were located outside the
study area. Only 21 of the industrial dischargers and seven of the munici-
pal wastewater treatment plants were considered major facilities by the
permit prgram. All but two of the major permits are located in the study
area.
Comparison of the manufacturing directory with the NPDES and RCRA per-
mit lists indicated that there were three chemical transportation trucking
firms and two powerplants that were potentially major sources of pollution.
Rating criteria were then developed to define the relative signifi-
cance of actual or potential releases of toxic substances to the environ-
ment through air, water or hazardous waste pathways. The criteria were
developed for those specific pathways identified by the Toxics Integration
Project as being significant in the Kanawha Valley and for which data were
available for most significant sources. These included toxic pollutant
loads (organic toxic pollutants and heavy metals) in wastewater effluents,
effluent toxicity as measured by bioassay testing, air emissions of vola-
tile organic chemicals and other pollutants from processes, emissions of
sulfur dioxide and suspended particulates from combustion sources, hazard-
ous waste management activities and site contamination.
The rating criteria were designed to group facilities by their rela-
tive degree of activity for each pathway. The intent was to identify the
facilities with the most significant potential for release of chemical sub-
stances to the environment so that they could be reviewed in detail. The
criteria were not designed to compare a facilities rating with any fixed
numbers to suggest that the facility was "good" or "bad". A high rating
number indicates that the facility has a significant potential for release
of chemical substances to the environment but does not necessarily mean
there are any major environmental problems associated with the facility.
-------
V-10
Wastewater discharges to surface waters were assigned ratings based on
the relative magnitude of the total loads of toxic organic pollutants* and
of heavy metals** discharged and on effluent toxicity [Table 6]. The
ratings were based on data reported in NPDES permit applications as summar-
ized by the Toxics Integration Project.33 These data were supplemented by
recent EPA and DNR file data including compliance monitoring samples and
self-monitoring data submitted by the permit holder. Daily maximum values
were used because long-term data were only available for a few sources and
then only for a few pollutants. The daily maximum values reported in the
permit applications usually represented only a few samples, often only one.
Long-term averages could thus be significantly different (higher or lower)
than these single samples. Effluent toxicity data were obtained from efflu-
ent bioassay results reported to EPA and DNR as required by NPDES permits.
The Air Pollution Control Commission is in the process of reviewing
emissions inventory data, based on 1981 emission levels, recently received
from major Kanawha Valley plants. When finalized in 1984, the 1981 inven-
tory will update the 1977 inventory and will be the most current information
available. The data currently being reviewed by the WVAPCC do not include
fugitive emissions for all facilities or process data on two major plants.
These will be added by mid-1984.
Because the 1981 inventory was not yet available, air emissions data
for rating sources were incomplete. Ratings were based on data in the 1977
NEIC report12 and on a Department of Health comparison of 1977 and 1981
emission rates for seven chemical plants.51 The latter comparison was based
on preliminary data subject to change and is a conservative estimate of
total 1981 emissions for each plant because fugitive emissions were omitted.
* Toxic pollutants in this report are synonymous with the 65 toxic pol-
lutants defined pursuant to Section 307(a) of the Clean Water Act and
published in 40 CFR Part 401.15.
** As used in this report, heavy metals does not include iron as iron is
not an EPA priority pollutant.
-------
V-ll
Table 6
WASTEWATER DISCHARGE RATING CRITERIA
Rating*
0
1
2
3
4
5
Rating
0
1
2
3
4
Total Load
(Ib/day)
Toxic Organic Pollutants Heavy Metals
Toxic Pollutant
<1
1-2
2-5
5-10
10-25
>25
Effluent Bioassay
Effluent Toxicity
non-toxic
low .
moderate
high
extreme
Loads
<1
1-2
2-5
5-10
10-25
>25
Toxicity
LC50 (% Effluent)
100
71-100
41-70
21-40
0-20
Rating values were assigned for both the toxic
organic pollutants and the heavy metals and
summed to get the total rating.
-------
V-12
Criteria used to assign relative ratings to emissions of air pollut-
ants are shown in Table 7. Process emissions include all emissions from
point sources and include all reported compounds such as sulfur dioxide,
particulates, hydrogen sulfide, etc. as well as volatile organic compounds.
No distinctions were made between types of substances or their relative
potential toxicity. Combustion emissions rated were limited to sulfur
dioxide and suspended particulates, the traditional air pollutants of most
concern in the valley. Combustion emissions originate from fuel combustion
in powerplants for energy production. Higher ratings than indicated in
Table 7 were assigned to the two coal-fired, thermal-electric powerplants
because of their large sulfur dioxide emissions relative to other facilities.
RCRA permit application data and site inspection reports were used to
define current hazardous waste management activity at each facility. Rela-
tive ratings were assigned using the criteria in Table 8. The criteria are
based on the volume of wastes handled, stored and treated and on the volume
and type of disposal. The criteria did not distinguish among categories of
wastes and their relative toxicities or hazards.
An evaluation was made of the relative potential for site contamina-
tion to release toxic substances to the environment. For facilities with
inactive waste disposal sites, rating points were assigned [Table 9] based
on the degree of certainty that hazardous wastes were present, the area of
the site, and extent of environmental problems as indicated by site inves-
tigation reports.39 Additional points were assigned if there was known
groundwater or surface runoff contamination or if there was a high proba-
bility of such contamination.
-------
V-13
Table 7
AIR EMISSIONS RATING CRITERIA
Rating
0
1
2
3
4
5
6
7
8
9
10
Process Emissions
(T/year)
<25
25-50
50-100
100-250
250-500
500-750
750-1000
1000-1300
1300-1600
1600-2000
>2000
Combustion Emissions*
(T/year)
<100
100-200
200-500
500-1000
1000-1500
1500-2000
2000-2500
2500-3000
3000-3500
3500-4000
>4000
* sulfur dioxide + total suspended particulates
-------
V-14
Table 8
HAZARDOUS WASTE MANAGEMENT RATING CRITERIA
Rating
0
1
2
3
4
5
Rating
0
1
2
3
Volume Handled
Tons/year
<10
10-50
50-100
100-200
200-500
>500
Storage Capacity
Capacity (gallons)
<5,000
5,000-10,000
10,000-25,000
>25,000
Treatment Capacity
Rating* Capacity (gallons/day)
0 <1,000
1 1,000-10,000
2 10,000-100,000
3 >100,000
Disposal Capacity
Land Application Landfill Surface Impoundment
Rating** (acres) (acre-feet) (gallons)
0 <1
1 1-10
2 10-25
3 >25
* Add 3 points for an
** The highest rating
<1
1-5
5-10
>10
incinerator.
value obtained for all
<1,000
1,000-5,000
5,000-10,000
>10,000
three columns
-------
V-15
Table 9
SITE CONTAMINATION RATING CRITERIA
Rating Conditions
Inactive Hazardous Waste Onsite Disposal
0 No onsite inactive disposal
1 Disposal site has low probability of containing hazardous
wastes
2 Possible hazardous wastes, small area (<1 acre)
3 Possible hazardous wastes, larger area
4 Known hazardous wastes
5 Known hazardous wastes, known major environmental problems
Groundwater Contamination
0 No known or probable contamination
1 Significant potential for contamination
2 Known contamination
Surface Runoff Contamination
0 No known or probable contamination
1 Significant potential for contamination
2 Known contamination
-------
V-16
Based on this evaluation of available data, 19 industrial facilities
were selected as major sources of toxic substances. These facilities are
listed alphabetically in Table 10 which shows the relative significance of
releases of toxic substances through air, water and hazardous waste path-
ways for each source. Facility locations are shown in Figure 5. In general,
these major sources discharge toxic pollutants in their wastewaters, emit
potentially toxic chemical substances to the air, generate and/or dispose
of substantial quantities of hazardous wastes and have some degree of site
contamination. Wastewater volumes and toxic pollutant loads for each facil-
ity are summarized in Table 11.
IDENTIFICATION OF HAZARDOUS WASTE SITES OF CONCERN
About 50 inactive disposal sites known to or suspected of containing
hazardous wastes have been identified in the study area. Preliminary as-
sessments have been completed at all but three sites. Based on these pre-
liminary assessments, seven sites have been eliminated from further inves-
tigation because they were found not to be a problem or because there was
inadequate information to verify the existence of the site.
Seventeen of the sites of concern are located at the 19 major indus-
trial sources listed in Table 10. The nature of the sites is discussed in
Sections VI, VII, and VIII by industrial facility.
The 26 sites of concern not at major industrial facilities are listed
alphabetically in Table 12. Locations are shown in Figure 6. Ten of the
disposal sites were operated and/or owned by municipalities and primarily
disposed of domestic refuse but did receive some quantities (large in some
cases) of industrial and hazardous wastes. Eight of the sites were pri-
vately owned and received industrial wastes. Five sites were privately
owned and received industrial wastes. Three sites were operated by indus-
tries for disposal away from their plants.
Site investigations have been completed at nine sites. Various stages
of site investigations are active at 11 sites. Remedial actions have been
completed at three sites, and three sites have not yet been investigated.
-------
Table 10
MULTI-MEDIA RATING OF MAJOR INDUSTRIAL SOURCES OF TOXIC SUBSTANCES
Map3
Key Facility Name
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Allied Chemical
Appalachian Power-Amos Plant
Appalachian Power-Kanawha R. Plant
Avtex Fibers
Chemical Leaman Tank Lines
Coastal Tank Lines
Diamond Shamrock
DuPont
El kern Metals
FMC
FMC
Fike Chemicals/CST
Kincaid Enterprises
(Chemical Formulators)
Mason & Dixon Tank Lines
Monsanto
S. Charleston Sewage Treatment Co.
Union Carbide
Union Carbide-Technical Center6
Union Carbide
Wastewater Discharges
Toxics
City Load
Nitro
Ni tro
Cedar Grove
Nitro
Insti tute
Nitro
Belle
Belle
Alloy
Nitro
S. Charleston
Nitro
Nitro
St. Albans
Nitro
S. Charleston
Institute
S. Charleston
S. Charleston
0
4
2
1
1
1
3
4
3
2
5
4
1
1
4
7
7
0
8
Effluent
Toxicity
0
0
0
0
1
0
3
.3
0
2
4
4
2
0
2
1
2
0
0
Air Emissions
Process Combustion
10
0
0
0
NDC
ND
5
10
10
0
6
1
ND
ND
3
ND
9
ND
8
0
30
20
0
0
0
0
10
10
0
10
0
0
0
4
0
10
0
5
Haz.
Waste
Mgmt.
0
2
0
9
4
4
3
13
0
11
6
11
4
4
14
3
17
7
14
Site
Contamin.
1
1
1
6
2
2
7
7
6
4
6
9
7
2
8
1
8
5
7
a See Figure 5 for source locations.
b Plant closed. Ratings reflect site contamination and runoff.
c ND - No data
d Includes Goff Mountain Landfill and private trucking operations
e Includes Ward Hollow and tiolz Pond waste disposal area
-------
i
CO
FIGURE 5 Location of Major Industrial Sources
-------
Table 11
SUMMARY OF INDUSTRIAL WASTEWATER DISCHARGES
Map
Key3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Facility Name
Allied Chemical
Appalachian Power - Amos Plant
Appalachian Power - Kanawha River Plant
Avtex Fibers
Chemical Leaman Tank Lines
Coastal Tank Lines
Diamond Shamrock
Dupont
El kern Metals
FMC
FMC
Fike Chemical s/CST
Kincaid Enterprises (Chemical Formulators)
Mason & Dixon Tank Lines
Monsanto
South Charleston Sewage Treatment Company
Union Carbide
Union Carbide - Technical Center
Union Carbide
City
Nitro
Nitro
Cedar Grove
Nitro
Institute
Nitro
Belle
Belle
Alloy
Nitro
S. Charleston
Nitro
Nitro
St. Albans
Nitro
S. Charleston
Institute
S. Charleston
S. Charleston
Flow
(mgd)
0.1
19.6
421
0.8
0.01
0.005
0.1
62
109
2.5
50
0.02
0.05
0.003
7.5
7.0
126
1.4
113
Organic Toxic
Pol 1 utants
(Ib/day)
<1
1
1
0
<1
1
1
2
0
0
12
6
<1
1
2
2
118
0
5
Heavy
Metals
(Ib/day)
<1
7
3
2
<1
<1
3
3
7
2
4
1
1
<1
3
78
2
0
88
a See Figure 5 for source locations.
b Plant closed. Contaminated surface runoff.
-------
Table 12
HAZARDOUS WASTE DISPOSAL SITES OF POTENTIAL CONCERN
NOT AT MAJOR INDUSTRIAL PLANTS
Map
Key File No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
a
b
80
4
5
124
-
52
126
-
6
8
9
128
1
45
113
20
74
31
-
-
-
81
82
41
-
77
See Figure 6
Type of Facij
Site Name
Charleston Municipal Landfill
Chelyan Oil Company
Don's Disposal Service
Dowel 1
General Electric Charleston Apparatus Service
Georges Creek
Givaudan Virginia
Heizer Creek
Holms & Madden Landfill
Kanawha Block Company
Kanawha County (Western) Landfill
Libby-Owens-Ford
Manila Creek
Mai lory Airport Landfill
Markay Chemical
Mink Shoals Landfill
Nitro Municipal Landfill
Nitro Sanitation
NL Industries
Poca Strip Mine Pits
Republic Steel
Smith Creek Dump
South Charleston Municipal Landfill
Tacketts Creek
Union Oil - Cabin Creek
Vimasco
for site locations.
!ity: ON - Industrial onsite; OF - Industrial
City
Charleston
Cabin Creek
Charleston
Nitro
Charleston
Port Amherst
Belle
Poca
Charleston
Charleston
Cross Lanes
Charleston
Amherst
S. Charleston
St. Albans
Mink Shoals
Nitro
Nitro
Charleston
Poca
Ni tro
S. Charleston
S. Charleston
St. Albans
Cabin Creek
Nitro
of/site/ N - Muni
L
Type
M
ON
P
ON
ON
P
ON
M
M
P
M
ON
OF
M
ON
M
M
M
ON
M
P
P
M
OF
OF
ON
cipal;
Status0
1C
AI
1C
1C
ND
1C
1C
AI
1C
AI
1C ,
ND
AI
1C
RAC
AI
AI
AI
RAC
AI
ND
AI
AI
1C
AI
RAC
P - Private
Status: ND - no data; AI - Active investigation; 1C - Investigation complete;
RAC - Remedial action complete;
i
(X)
-------
FIGURE 6 Locations of Hazardous Haste Disposal Sites of Concern
-------
VI-1
VI. SOURCES OF TOXIC SUBSTANCES - UPPER KANAWHA VALLEY
For purposes of this report, the Upper Kanawha Valley is defined as
the developed narrow valley of the Kanawha River between Alloy at the head
of navigation (river mile 90.7) and Marmet Dam northwest of Belle, river
mile 67.7 [Figure 7]. This 23-mile reach of the valley is very narrow and
winding and is flanked on both sides by mountains with elevations ranging
up to 1,400 feet above river level. The entire navigation pools of the
Marmet and London Dams are located in this valley reach.
The population of the upper valley is small. Numerous small towns and
villages are scattered along the valley. Montgomery, with a population of
about 2,500, is the largest community. Large industrial facilities are at
Alloy and Belle. A few smaller industrial plants are scattered along the
river. Numerous coal mines are located along this valley reach at varying
distances up to several miles from the river. Coal preparation plants and/
or barge or train loading facilities service many of these mines.
MAJOR INDUSTRIAL SOURCES
There are four major industrial plants in the upper valley. The
duPont organic chemicals plant at Belle is the largest and most significant
from both the toxic substances and classical pollutants viewpoints. Other
major facilities are a coal-fired thermal electric powerplant, a ferro-
alloy plant and an organic chemicals plant.
El kern Metals Company. Alloy (RM 89.7)
El kern Metals Company operates a ferro-alloy plant at Alloy on the north
bank of the Kanawha River [Figure 8]. The plant was operated by Union Car-
bide Corporation prior to July 1981. The plant has been in operation since
1934 with significant expansions in 1941 and 1951. Plant modernization has
continued during the past 15 years. Employment was about 1,250 persons in
1972 with about 1,450 required for full production.3 Production capacity
was in the range of 160,000 to 190,000 tons of alloys per year. Employment
had been reduced to about 900 in 1981.52
-------
Figure 7 Area Map - Upper Kanawha Valley
-------
VI-3
-" NION CARBIDE'X
Figure 8 Location Map - Alloy Area
-------
VI-4
In 1972, the plant had 15 electric arc furnaces for alloy production.3
Electric power was obtained from hydroelectric plants on the New River and
an onsite, coal-fired powerplant. Raw materials were batch loaded into the
furnaces, smelted, and the molten metal cast in molds for sale to customers.
Raw materials in 1972 included coal, coke, charcoal, dolemite, lime, lime-
stone, millscale, silicate of soda, produced metals, produced slags, chrome
ore (El Paso, Amopa, Comilog, Mamativan, Chilean and Turkish), sand (silica
and zirconium), North Carolina gravel and Winona quartz.3 Byproducts were
several "throw away" slags including ferrochrome silicon, silicomanganese,
ferrochrome and ferromanganese slags.
Finished products have apparently been similar during the plant's his-
tory. However, from a toxic substances viewpoint, a major change occurred
during the past few years. As shown in Table 13, ferrochrome alloys are no
longer produced.53 The plant thus no longer handles chrome ore, and
releases of chromium to the environment should have decreased.
Water use at the plant was about 100 mgd in 197712 and 109 mgd in 1981.
Water supply is obtained from the Kanawha River. Most of the water is used
for non-contact cooling in the powerplant (75 mgd) and furnaces (33 mgd).
Other water uses (less than 1 mgd total) were for an air pollution scrubber
on one furnace, bottom ash sluicing at the powerplant, slag and quartz wash
water and sanitary purposes.
In 1972, scrubber and tap washing waters were treated in a series of
two small settling ponds. Settled sludge was disposed of in the Company's
Jarrett Branch landfill. Bottom ash was sluiced to another series of three
settling ponds with solids removed to the landfill. Sanitary wastewaters
were treated in a small biological treatment plant. Cooling waters were
not treated. Aerial photographs of the plant recorded in October 1977
showed the two series of settling ponds to still be in use.12 An additional
long rectangular pond had been constructed at the north end of the plant in
1977 which was apparently an additional treatment facility for slag and
quartz wash waters.
-------
VI-5
Table 13
CHANGES IN ELKEM METALS COMPANY PRODUCTS
Product
calcium-barium-si 1 icon
calcium-barium-silicon-aluminum
calcium-silicon
ferroboron
ferrochrome - low carbon
ferrochrome-si 1 icon
ferromanganese
ferromanganese-si 1 icon
ferrosilicon
hypercal
silicomanganese
silicon, metal
silicon-manganese-zirconium
silicon-titanium
strontium-si 1 icon
zirconi urn-si 1 icon
zirconium - 35-40%
1972
X*
_**
X
-
X
X
X
X
X
X
X
X
X
X
X
-
X
1983
X
X
X
X
-
-
X
X
X
-
X
X
-
X
-
s
-
* X = produced that year
** - = not produced
-------
VI-6
A new NPDES permit (5-year BAT) was issued to El kern in March 1982 which
limits discharges of pollutants from the plant's eight outfalls. Five of
the outfalls (001-005) discharge non-contact cooling water and some storm
runoff. Metals that may be present in the runoff are limited by the permit.
One outfall (006) serves the bottom ash sluice system. This is a closed
recycle system that rarely discharges. Outfall 007 discharges about 0.2
mgd of filter backwash and slag and quartz wash water. Outfall 008 is
Jarretts Branch, a small stream draining the landfill described below.
Effluents from six outfalls were sampled in 1972.3 Outfall 007 was
not yet constructed. Outfall 008, Jarretts Branch, also was not sampled.
The only toxic substance present in significant amounts was chromium which
was discharged at 21 kg (47 lb)/day. Bioassays detected no toxicity in
plant effluents.
As part of their NPDES permit requirements, Union Carbide must period-
ically monitor for As, Ba, Cd, Cr, Hg, Ni, Pb and Zn. In April 1977, the
plant reported an average chromium discharge of 48 lb/day.33 This discharge
was reduced to about 1 pound per day of chromium in 1983.30
Emissions from all but one of the furnaces were controlled by dry bag
dust collector systems.3 The one furnace was controlled by a scrubber, as
previously discussed. In 1972, reuse of the collected dust was being inves-
tigated, indicating a probable high metal content. Disposal was not
reported in the 1972 report, but was probably to the Jarrett Branch land-
fill.60 Flyash from the powerplant was controlled by electrostatic precip-
itators with disposal to the Jarrett Branch landfill.
Significant air emissions include sulfur dioxide from coal combustion
in the powerplant and heavy metals present in particulate emissions passing
furnace control equipment. Furnace emissions of heavy metals were not
defined. Powerplant emissions of sulfur dioxide were reported as 225 ppm
in 107,000 acfm in 1974.12
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VI-7
The Elkem Metals plant does not generate any listed hazardous wastes.
Ferro-alloy wastes originally listed as hazardous under RCRA have been tem-
porarily delisted by EPA.
Elkem disposes of large volumes (about 400,000 yd3/year) of solid
wastes in the Jarrett Branch landfill that extends for about a mile along
Jarrett Branch, a small stream that flows from a hollow extending east of
the plant [Figure 8]. When the plant began operations, the landfilled mate-
rial was the "throw away" slags from the furnace operations.56 As pollution
control requirements increased, other wastes such as flyash, bottom ash and
air pollution control dusts were also landfilled. Apparently, some erosion
of landfilled solids into Jarrett Branch has occurred in the past with move-
ment of solids and some heavy metals into the Kanawha River.12 The NPDES
permit requires periodic monitoring of Jarrett Branch. Recent metals dis-
charges have been small.
Solid wastes landfilled along the edge of the Kanawha River were noted
in the 1977 aerial photographs. Surface runoff from this area and from ore
stockpiles is a potential source of heavy metals. The NPDES permit con-
tains best management practices (BMP) requirements to minimize such runoff
contamination.
In summary the NPDES permit appears to adequately control discharges
of toxic substances from this plant. Discharges of chromium have decreased
substantially in the last 5 years. Air emissions of sulfur dioxide are
substantial. There do not appear to be any current hazardous waste problems.
If EPA terminates the temporary delisting of several ferro-alloy wastes,
some landfill improvements might be needed to meet permit standards.
Appalachian Power Company, Kanawha River Plant. Glasgow (RM 78.3R)
This is a 430-MW coal-fired thermal electric powerplant which began
operation in 1953 and operates continuously.
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VI-8
Condenser cooling is provided by once-through use of Kanawha River
water. Water use was 420 mgd in 1972, of which only 1.4 mgd was treated
for boiler feed, bearing cooling and sanitary uses.3
Bottom ash was sluiced to storage ponds north of the plant [Figure 9].
Overflow averaging 0.07 mgd was discharged to the river. The bulk of the
bottom ash was hauled away for fill. Flyash was collected dry and hauled
to a storage area east of the plant. Drainage from the coal storage area
was pumped to the river and it averaged only 6 gpm.
Analysis of the ash pond effluent in 1972 showed low levels of copper,
chromium, lead, nickel and zinc to be present. Higher levels of these
metals were present in the coal storage drainage but discharge loads were
small. Less that 5 Ib/day of heavy metals were discharged by the power-
plant. Current conditions at the powerplant are believed to be relatively
unchanged from 1972.
Combustion of coal in the plant boilers releases large volumes of sul-
fur dioxide to the atmosphere. The amount was not determined in this study.
Appalachian Power initially notified EPA in 1980 that the powerplant
was a hazardous waste generator and storage facility.31 Metal cleaning
wastes and waste oil were the reported wastes. Appalachian Power has with-
drawn the notification because the metal cleaning wastes have been deter-
mined to not be RCRA hazardous wastes and the small amounts of waste oil
are burned as fuel in the boilers.32
Diamond Shamrock Chemical Company, Bell (RM 69.3R)
Diamond Shamrock Chemical Company operates an organic chemical plant
at Belle adjacent to the duPont chemical plant [Figure 10]. The plant was
initially operated by Belle Alkali as a chlorine-caustic plant in 1920.
Facilities for chlorination of methane to methyl chloride and methylene
were added in 1932. After World War II, production of chlorine and caustic
was stopped. The plant was converted to a methanol starting in 1969.
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VI-9
APPALACHIAN POWER CO
KAN A W HA R'." 'pt A N T'"^;/
BOTTOM ASH
^~^- : i ~-v -^5*Nxxsr '^
%1\./-E-^^
'c. ^^-' i,1. .i
-------
VI-10
ANAEROBIC PO
Figure 10.. Location Map - Belle Area
-------
VI-11
Raw materials in 1972 were chlorine, brought in by barge, and methanol,
piped directly from the duPont plant.3 Products manufactured include meth-
ylene chloride, chloroform, carbon tetrachloride, muriatic acid and an
intermediate product of methyl chloride. Production was estimated to be in
the range of 200 to 250 tons/day in 1976. Carbon tetrachloride production
was about 1.5 to 2.5 tons/day.
Current products are methyl chloride, methylene chloride, chloroform
and hydrochloric acid.53 A byproduct, carbon tetrachloride residue stream,
is sold to another company for refining.29
Water use in 1972 was about 8 mgd which was primarily used for non-
contact cooling.3 A small (0.002 mgd) process stream from a gas scrubber
was discharged untreated. Diamond Shamrock made major changes in 1981. A
recycling cooling system was installed and all non-contact once-through
cooling water use was stopped. A phosphate-based inhibitor is used in the
cooling system. Slowdown averaging about 0.1 mgd is discharged untreated
through Outfall 003 to the Kanawha River. The small amount of process waste
is treated by a steam stripper and/or carbon column and batch discharged to
Outfall 003. Contaminated storm runoff from process areas is collected and
treated with process wastes. Non-process area runoff is discharged through
Outfall 004. There are no other wastewater discharges.
The NPDES permit for the facility limits chloroform and carbon tetra-
chloride in the wastewater treatment unit effluent. The combined Outfall
003 effluent and Outfall 004 stormwater discharges are monitored for these
two compounds. Outfall 003 is also monitored for methylene chloride.
Analysis of the Outfall 003 discharge in 1983 indicated all toxic organics
except methylene chloride (44 ug/£) were below detection limits.30 All
other toxic pollutants except lead (3.56 mg/£, 3 Ib/day) were at low levels.
Semi-annual analysis of the Outfall 003 effluent for all priority pollu-
tants is required. Best management practices are also prescribed in the
permit.
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VI-12
Company monitoring of the two plant effluents in mid-1983 indicated
that process discharges of toxic pollutants were very low (<1 Ib/day).
However, the storm runoff had significant contamination (0.7 to 1.27 mg/£)
with chloroform. Effluent toxicity, as measured by a bioassay in 1981, was
high (LC50 = 32%).30
Diamond Shamrock has achieved BAT level control of process wastewaters
and has drastically reduced wastewater discharges since 1980. However,
stormwater runoff is still contaminated with toxic organic pollutants.
Groundwater under the site is known to be contaminated with chloroform,
carbon tetrachloride and other organic chemicals from past spills and leaks
and poor treatment practices. This contaminated groundwater infiltrates
drains and sewers and may contribute to the contamination of stormwater.
Diamond Shamrock reported four spills of hazardous substances from 1980 to
1982.50 The BMP plan required by the permit should fully address these
spill and contamination problems.
Emissions of volatile organic chemicals from Diamond Shamrock process
sources were in the range of 500 tons/year in 1981, up slightly from 1977.51
Principal compounds emitted are chloroform, methyl chloride and methylene
chloride. Combustion emissions are relatively small as the plant does not
have a coal-fired powerplant.
There are two possible hazardous waste disposal sites at this faci-
lity.39 A small surface impoundment was used in the past as part of the
wastewater treatment system. The impoundment contents have been excavated
and removed and replaced with clean fill. Contaminated groundwater under
the plant masks any possible residual contamination from the impoundment.
The other site was located on the location now occupied by the waste-
water treatment plant.39 This site was once occupied by an aluminum chlor-
ide plant operated by Givaudan Virginia Corporation in the late 1930s.
There appears to be a low probability of any residual hazardous wastes from
this operation.
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VI-13
Wastewater treatment sludges and spent activated carbon are treated as
RCRA hazardous wastes and shipped offsite along with other listed process
hazardous wastes for disposal.30 32 Wastes are stored for less than 90
days so a RCRA permit is not required.
In summary, Diamond Shamrock has reduced process wastewater discharges
of toxic organic pollutants to BAT levels. However, contamination of sur-
face runoff is significant. Groundwater contamination is a problem. Air
emissions of potentially toxic volatile organic chemicals are substantial.
Hazardous waste management does not appear to be a problem.
E. I. duPont de Nemours and Company, Inc., Belle (RM 68.5R)
The duPont plant is a large chemical production facility situated on
about 104 acres along about 1 mile of the Kanawha River [Figure 10]. The
plant began operation in 1926 with the only product being ammonia. Various
products have been added through plant expansions; about 25 organic and
inorganic chemicals are now produced.53 Peak employment reached about 5,000
around 1945. Employment is now about 1,200.52 Plant operations are con-
tinuous and relatively uniform.
In July 1976, substances identified by duPont as handled, used as raw
materials or produced as final product, intermediate or byproduct at the
Belle plant and present on an EPA-proposed hazardous substance list,
included the following:12
acetic acid hydrochloric acid
acetic anhydride hydrogen cyanide
acetone cyanhydrin methyl mercaptan
aluminum sulfate methyl methacrylate
ammonia monomethylamine
ammonium chloride phosphoric acid
ammonium hydroxide potassium hydroxide
aniline propyl alcohol
antimony potassium tartrate sodium hydroxide
antimony trioxide sodium hypochlorite
calcium hypochlorite sodium methylate
chlorine sodium nitrite
cupric formate styrene
cyclohexane sulfuric acid
dimethyl amine triethyl amine
formaldehyde trimethylamine
vanadium pentoxide
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VI-14
A list of products submitted to EPA in late 1977 is presented in
Table 14.12 Comparison with a products list in the 1983 Directory of Chem-
ical Producers indicates that current products are similar.
Water use has been reduced by about two-thirds in the last decade.
Total wastewater discharges have decreased from 175 mgd in 19723 and 115
mgd in 197712 to about 62 mgd in 1983.30 Treated wastewater is discharged
through three outfalls to the Kanawha River. Most contaminated process
wastewaters are discharged to the main treatment plant and then to Outfall
062. An activated sludge biological treatment plant with flow equalization
treats about 2 mgd of process wastewaters. Most water use is for non-
contact cooling. There are 46 outfalls from this plant. Many of these are
low-volume discharges such as utility line drains or strainer backwash lines.
The NPDES permit requires only flow monitoring for 35 of the utility
outfalls.30 Toxic substances limited for Outfall 062 are copper, chloroform
and methylene chloride with monthly monitoring. Semi-annual monitoring of
Outfall 062 for all toxic pollutants is also required. Best management
practices are required by the 5-year BAT permit issued in October 1981.
DuPont expects to meet the BAT limits with existing treatment and pollution
controls.
Bioassays of effluents from Outfalls 017 and 046 in February and April
1983 showed 100% survival of test organisms.30 These outfalls contain some
treated process wastewaters but are primarily cooling water. Bioassays of
treated process wastewater from Outfall 062 in February and April had an
LC50 of 28% and 29.5% effluent, respectively, indicating moderate to high
toxicity. The March 1983 toxic pollutant analysis detected bromoform, di-n-
butyl phthalate, toluene and trichlorofluoromethane, all at <10 ug/2.
Arsenic (8 ug/£), copper (50 ug/£), nickel (40 ug/£) and zinc (100 ug/£)
were all at or below approximate BAT levels. Of possible concern was a
total cyanide concentration of 284 ug/£. Phenols were detected at 51 |jg/£.
Toxic organic pollutants discharged totaled <2 Ib/day. Heavy metal dis-
charges were about 3 Ib/day, a substantial reduction from the average copper
discharge of 74 Ib/day in 1976.12 Cyanide discharged was about 5 Ib/day.
-------
VI-15
Table 14
PRODUCTS LIST12
E. I. DU PONT DE NEMOURS AND COMPANY
Belle, West Virginia
Agriculture Chemical Intermediate F-3259, F-3455
Ammonia
Benlate
Benomyl
Bis-para-aminocyclohexyl-methane
Carbon monoxide
Dimethylacetamide
Dimethylether
Dimethylformamide
Dimethylsulfate
Ethylene glycol
Formaldehyde
Formamide
Hydrogen
Hydroxyacetic acid
Methacrylate
Methyl methacrylate
n-Butyl methacrylate
2-Ethyl hexyl methacrylate
Methacrylic acid
Ethyl methacrylate
Methyl amines
Monomethylamines
Dimethyl amines .
Trimethyl amines
Methylenedianaline
Methyl formate
Small lots manufacturing products
Sodium styrene sulfonate
Vazo
-------
VI-16
DuPont periodically reports spills of oil or hazardous substances from
the Belle facility. Many are very small but about 29,000 Ib of methanol
and methacrylate were spilled in January 1981.50 About 35 spills were re-
ported during a 2-year period in the mid-1970s.12 Only 15 spills were re-
ported during 1980-82.50 Nevertheless, a periodic review of the BMP plan
may be appropriate to determine methods of achieving further reductions in
spill frequency.
Waste disposal facilities and practices in use at Belle in mid-1972
included a biological (activated sludge) wastewater treatment plant, an
anaerobic pond, incineration, burning of liquid organic wastes in the power-
house, barging of flyash to a local landfill, barging of brines to the Gulf
of Mexico and onsite deep well disposal of brine and organic wastes.3 In
late 1977, barging of flyash and brines had been discontinued.12 In addi-
tion to incineration and wastewater treatment, some deep well disposal was
continuing. Various waste materials were disposed of by contractors. These
were transported out of state by truck, rail and barge for disposal by land-
fill or incineration.
Most process wastewater streams were discharged to the biological plant
for treatment. Treated flows were in the range of 2 to 3 mgd. Treatment
units included neutralization, three isolation tanks for storage of spills,
a large equalization tank, a cooling tower, phosphorus feed, five aeration
units and five final clarifiers. Waste activated sludge was pumped to the
anaerobic pond. A 65% increase in treatment capacity was completed in 1977.
The anaerobic pond is in a side valley of Simmons Creek, about 0.6
mile north of the main plant site [Figure 10]. Originally built for flyash
disposal, the pond was converted to treatment of organic wastes. In 1977,
it was used for disposal of waste activated sludge. In 1972, some process
wastes were also pumped to the pond.3
The pond was formed by construction of a dam from cinders and clay and
rock fill. A cinder keyway through the dam allows the pond contents to
continuously seep through the dam where they are collected in a sump and
piped to the biological treatment plant.
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VI-17
In aerial photographs taken in October 1977, areas adjacent to the
pond appeared to be used for disposal of various solid and liquid wastes.12
An apparently active disposal area was located north (uphill) of the pond.
Black 55-gallon drums were neatly stacked beside three upright cylindrical
tanks at the north edge of the disposal area. A pile of randomly dumped
drums were at the south edge of the area. Unknown solid wastes were dumped
in the area. Near the north end of the pond, rusting containers had been
dumped down the hillside.
A diversion ditch had been constructed around the pond to prevent sur-
face runoff from adjacent hillsides from reaching the pond.
Near the west end of the dam forming the anaerobic pond, a small pond
was diked off on the hillside. It contained a reddish brown liquid in con-
trast to the black anaerobic.pond contents. Unknown solid wastes had been
dumped into the pond on the west side. A 1973 duPont drawing labeled the
pond as a "waste retention" pond.
An active landfill operation was present south of the dam. A white
material had been placed against the toe of the dam. Gray material with
the appearance of bottom ash and/or flyash was being deposited downstream
from the dam.
In 1981, duPont notified EPA that a wide variety of solid and liquid
industrial wastes, including toxic pollutants and hazardous wastes, had
been disposed of in nine different landfill areas in the Simmon's Creek and
anaerobic pond vicinity.39 Disposal dates ranged from 1929 to as recently
as 1977. Some of these areas were detected in the photographs discussed
above.
The volumes of wastes disposed of were not known. The landfills were
not lined. Seven of the areas were uphill from the anaerobic pond where
leachate and surface runoff would presumably carry pollutants into the pond.
However, two landfills totaling about 13 acres in area are located down-
stream from the anaerobic pond and would drain to Simmon's Creek.
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VI-18
DuPont has also reported parts of the main plant site were used for
waste landfills in the past. Groundwater contamination from spills and
leaks, as occurred at the adjacent Diamond Shamrock plant, is probable.
Two deep wells, 1,500 and 5,300 feet deep, respectively, were pre-
viously used for waste disposal. Injected wastes were primarily brines but
included soluble organic materials such as aniline, aromatic amino compounds,
and chlorinated and brominated derivatives of benzene. A 1972 State permit
limited the total volume to be injected to 137 million gallons/ year. In
late 1977, the deepest well (No. 2) was still in use. Materials and volumes
discharged to the well were not documented in files reviewed. It is prob-
able that process changes and diversion of wastes to biological treatment
have occurred.
Materials barged to the. Gulf were wastes from spent glycol recovery
and from production of benylate benomyl fungicide and sodium styrene sul-
fonate (SSS). The wastes contained sodium tetraphthalate, ethylene glycol,
SSS, chlorides, sulfates, other organics, antimony and low levels of cad-
mium and mercury. Current disposal of these wastes was not documented.
In the 1980 Part A RCRA permit application, duPont reported extensive
hazardous waste handling facilities including about 500,000 gallons of con-
tainer storage, 2,700,000 gallons of tank storage, 12,000 gpd of tank treat-
ment capacity and 4,600 gpd of distillation column capacity.32 Incineration
capacity of 3,000 gph was also reported. In 1981, about 500,000 gallons of
wastes were incinerated in the powerhouse boilers.
Hazardous waste generation of about 144,000 tons/year was reported.
Ignitable and corrosive wastes accounted for all but 4,000 tons/year of
these wastes. Spent solvents and lead wastes accounted for 700 tons/year.
A source of nitrosamine emissions was discovered at the Belle plant in
1975. These emissions are now flared. Nitrosamines were also present in
the anaerobic pond.
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VI-19
In late 1977, duPont reported that 49 hydrocarbon compounds were
emitted to the atmosphere from the Belle plant.12 Ten of these compounds
(analine, butyl isocyanate, carbon monoxide, dimethyl sulfate, ethyl chloro-
formate, HCN, methyl chloroformate, methylene chloride, methylene dianiline
and mono methylamine) are considered by duPont to have serious toxicity.
A Department of Health evaluation of 1977 and 1981 preliminary emis-
sions data for the duPont plant indicates that 1977 hydrocarbon emissions
of about 2,700 tons/year from process sources were about halved by 1981.5l
Compounds with the largest emissions included methanol, dimethyl ether,
formaldehyde, methyl formate, ammonia and mixed methyl amines.
Data showed that nitrogen oxides emissions from the three boilers were
more than 850 Ib/hour in 1977.12 Combustion emissions of sulfur dioxide,
suspended particulates and nitrogen oxides were in the range of 10,000 tons/
year in 1981.51
In summary, the duPont plant at Belle has substantially reduced dis-
charges of toxic pollutants in process wastewaters. Spills and leaks,
coupled with groundwater contamination, still pose a potential for release
of significant amounts of toxic or hazardous pollutants. Process and com-
bustion emissions are large. There are large volumes of hazardous wastes
landfilled onsite. The environmental hazard associated with these land-
fills has not been fully assessed. The plant is a large generator and han-
dler of hazardous wastes.
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VII-1
VII. SOURCES OF TOXIC SUBSTANCES - CENTRAL KANAWHA VALLEY
For purposes of this report, the Central Kanawha Valley is defined as
the developed valley of the Kanawha River between Marmet Dam at Marmet
(river mile 67.7) and St. Albans (river mile 46) [Figure 11]. This 22-mile
reach of the valley is wider and less winding than the Upper Kanawha Valley
but is still relatively narrow with a maximum valley floor width of about 1
mile. Flanking mountains decrease in height above the valley floor moving
downstream. Average mountain heights are less than 600 feet in the
Charleston vicinity.
A large majority of the Kanawha Valley population is concentrated in
this central area. The cities of Charleston, South Charleston, Ounbar,
Institute and St. Albans have a combined population of about 115,000. Urban
and industrial developments are concentrated along the valley floor with
residential areas divided between the valley and adjacent hillside and
tributary valley suburbs.
Major industrial facilities are located along the Kanawha River at
South Charleston and Institute. Several small industrial plants are scat-
tered up and down the valley.
The municipal water supply for most of the area is provided by the
West Virginia Water Company. Raw water is obtained from the Elk River.
St. Albans obtains its water supply from the Coal River. Most industrial
water is obtained from the Kanawha River. This valley reach encompasses
the upper half of the Winfield Dam navigation pool.
MAJOR INDUSTRIAL SOURCES
There are six industrial facilities of interest in the central valley.
Union Carbide Corporation dominates the area with three major facilities
and several associated storage, service and waste disposal facilities.
These facilities are interrelated but, for convenience, the peripheral
facilities will be discussed under the closest major plant. The complexity
-------
Figure 11 Area Map - Central Kanawha Valley
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VII-3
of the Union Carbide operation is indicated by the fact that eight different
corporate divisions are operative at the two chemical manufacturing plants.
The South Charleston chemical plant [Figure 12] occupies Blaine Island
and about 1 mile of the south bank of the Kanawha River. Two bulk chemical
storage areas occupy about 0.5 mile of the north bank of the river in North
Charleston. These units will be collectively discussed as the South
Charleston plant.
A large research facility known as the Technical Center is on about
630 acres to the southwest of the South Charleston plant [Figure 12]. Three
waste disposal impoundments (Wards A and B and Holz Pond) are also located
on Technical Center grounds and are discussed with the Technical Center.
The third Union Carbide major facility is the large chemical plant at
Institute. The adjacent Goff Mountain landfill and the Private Trucking
Operations facilities are discussed with the Institute plant.
South Charleston's municipal wastewater treatment plant receives large
volumes of industrial wastewater from Union Carbide's South Charleston plant
and the Technical Center. The plant is operated by the South Charleston
Sewage Treatment Company (SCSTC), a subsidiary of Union Carbide. The facil-
ity can essentially be considered an industrial source.
FMC Corporation operates three separate facilities collectively known
as the South Charleston plant downstream from Union Carbide [Figure 12].
Chemical Leaman Tank Lines operates a tank truck maintenance and cleaning
facility adjacent to Union Carbide in Institute.
The following sections discuss the raw materials, products, water uses,
wastewater treatment, wastewater discharge characteristics, air emissions
and hazardous waste disposal practices at each of these six facilities as
they effect releases of toxic substances to the environment.
-------
Figure 12 Location Map - South Charleston Area
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VII-5
Union Carbide Corporation, South Charleston (RM 54.6-56.2)
Union Carbide's South Charleston Plant is a large petrochemical plant
producing more than 500 different chemicals, plastics and fibers from deri-
vatives of natural gas and petroleum. The diversity of products is indi-
cated by the fact that the following Union Carbide divisions operate pro-
duction facilities at the plant: coatings materials, ethylene oxide deri-
vatives, polyolefins, silicones and urethane intermediates, solvents and
coatings materials, and specialty chemicals and plastics.53
The plant occupies an area of about 230 acres. Production facilities
are on 1.25-mile-long Blaine Island and about a 1-mile reach of the south
bank of the Kanawha River [Figure 12]. Two storage facilities occupy about
0.5 mile of the north river bank.
Production at the plant is continuous. An average of about 8,000,000
Ib. of intermediates and products were reportedly used in the processes or
produced for sale to customers each day in 1971.3 Employment in 1981 was
about 1,500.52 Production at this location began in 1929.
The list of raw materials, intermediates and final products used or
produced at the South Charleston plant is voluminous. A partial listing of
products is given in Table 15.53
More than 450 raw materials were received at South Charleston in 1977
including the following priority pollutants: acrylonitrile, benzene, ethyl-
ene dichloride, isophorone, nickel, vinyl chloride and zinc chloride.12 In
late 1976, Union Carbide estimated that about 65 of 300 compounds listed in
an EPA-proposed Hazardous Substance List were handled at South Charleston.
At the same time, a preliminary review of the 65 priority pollutants by
Union Carbide indicated that only four (acrylonitrile, haloethers, isophor-
one and vinyl chloride) were known or believed to be present in wastewater
discharges.12
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VII-6
Table 15
PRODUCT LIST
UNION CARBIDE, SOUTH CHARLESTON53
Coatings Materials Division
Ethyl silicate
Plastics and Resins
Polyvinyl chloride resins
Ethylme Oxides Derivatives Division
2-(2-[2-Ethoxyethoxy] ethoxy) ethanol
General and Compounded Products
UCON Hydrolubes (HB series, LB series)
Polyolefins Division
Plastics and Resins
Ethylene-vinyl acetate copolymer resins
Silicones and Urethane Intermediates Division
1-Chlorobutane
Polyether polyols for non-urethane applications
Polyether polyols for urethane applications
Polypropylene glycol
N,N,N',N'-retramethyl-l,3-butanediamine
Solvent and Coating Materials Division
Alcohols, Fatty and Higher Synthetic
2,6-Dimethyl-4-heptanol
2-8utoxyethyl acetate
n-Butyl acetate
Oiacetone alcohpl
2-(2-Ethoxyethoxy) ethyl acetate
Ethylene glycol diacetate
Mesityl oxide
2-Methoxyethyl acetate
Methyl isobutyIcarbinol
Triethylene glycol diacetate
Specialty Chemicals and Plastics Division
n-Butoxypropanol
t-Butyldiethanolamine
t-Butylethanolamine
Oeanol
2-(Oiethylamino) ethanol
2-(2-Diethylaminoethoxy) ethanol
Dimethylaminoethoxyethanol
l-(Dimethylamino)-2-propanol
N,N-Dime thy I -1,3-propanediamine
1,4-Dioxane
Oipropylene glycol
2-(Methylamino) ethanol
Methyl vinyl ether
2,4-Pentanedione
Pesticides
2-Et.r>y I -1. 3-nexanediol
Plastic i zers
Tetraetnyiene glycol di (2-ethylhexanoate)
Plastics and Resins
Polyvinyl acetate resins
Prop ioofienone
n-PropOiyorooanol
Propylene glycol
General and Compounded Products
Polyglycol amines
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VII-7
A major change in products occurred in 1980 with cessation of production
of vinyl chloride monomer.
Water use has been substantially reduced in the last decade. Total
water use was about 222 mgd in 19723 and 143 mgd in 1976.12 All but 4 mgd
of water use in 1976 was for non-contact cooling purposes. In July 1983,
water use was about 118 mgd with 4 mgd of process wastewater discharged to
the South Charleston Sewage Treatment Company for treatment (see discussion
in the following section).30 Cooling waters are discharged directly to the
Kanawha River through 22 outfalls. The plant at one time had 91 active
landfalls.12
The NPDES permit applicable to these discharges was issued by EPA in
1975 and expired in January 1980.30 Permit conditions continue in effect
under the Administrative Procedures Act. The permit does not directly limit
any toxic pollutants. Cooling waters must be monitored for total organic
carbon (TOC) and phenolics and two outfalls are monitored semi-annually for
vinyl chloride. Bioassays are required quarterly on six outfalls and on a
composite sample of the other discharges.
Frequent TOC excursions in recent monitoring data indicate that spills
and leaks into cooling waters are a problem.30 Union Carbide periodically
monitored its cooling water outfalls for organic chemicals during the last
half of 1976.12 Gas chromatograph analysis detected 29 specific organic
chemicals. The frequency of detection ranged from 1 to 23 times during the
180-day period. Observed concentrations ranged from 1 to 385 ppm. Acetone
was the most frequently detected and the highest concentration. None of
the chemicals detected were priority pollutants. The continued occurrence
of TOC excursions indicates the need for improved BMPs to control spills
and leaks. The new permit for this facility should require a BMP plan.
In 1976, phenols averaged about 22 Ib/day for the total cooling water
discharge.12 About 13 Ib/day were discharged in July 1983.30 Bioassays of
cooling water discharges have detected acute toxicity in the past.12 Bio-
assays of five main outfalls in November 1982 indicated no significant
toxicity.30
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VII-8
The Toxics Integration Project prepared estimates that indicated
significant discharges of chloroform (5 Ib/day), chlorine (95 Ib/day), lead
(46 Ib/day) and nickel (42 Ib/day) from this plant were possible.33 The
lead and nickel discharges appear high. These pollutants should be
addressed by a BAT permit.
Union Carbide also monitors the process wastewaters discharged to the
South Charleston Sewage Treatment Company. Gas chromatograph analyses in
1976 detected 44 specific organic chemicals in average concentrations rang-
ing from 2 to 954 ppm.12 Acrylonitrile, a priority pollutant, was dis-
charged at an average concentration of 192 ppm.
A wide variety of air pollutants are emitted from this plant. Numerous
organic compounds were emitted to the atmosphere from 19 source areas with
numerous emission points in 1977.12 More than 50 of these compounds had
known toxicities ranging from slightly toxic to carcinogenic. Compounds of
special concern included acrylonitrile, benzene, dioxane, isophorone and
vinyl chloride.
The emission of most concern was vinyl chloride, a known human car-
cinogen. Vinyl chloride monomer was produced at South Charleston until
1980. Large (30 Ib/hour) emissions of vinyl chloride prior to 1977 were
reduced about 90% in 1977 by a process change and incineration of vents at
the steam plant.12 Cessation of monomer production eliminated most of the
remaining emissions although monomer is imported and used in polyvinyl
chloride resin production.
A Department of Health comparison of 1977 and preliminary 1981 hydro-
carbon emissions data indicated that process emissions have been substan-
tially reduced from about 4,800 tons/year in 1977 to about 1,300 tons/year
in 1981.51 Fugitive emissions data were not yet available. The largest
emissions included propylene oxide, acetone, methanol, isopropanol, methyl
acetate and vinyl acetate.
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VII-9
There are two. powerplants at this facility. The Island Powerhouse has
nine boilers ranging in design capacity from 95 to 330 million Btu.12 Vari-
ous fuels including coal, natural gas, liquid waste and waste gases can be
used. In 1975, an average of 15,000 to 25,000 gallons/day of miscellaneous
hydrocarbon residues were incinerated.
The Mainland Power Station has two boilers rated at 200 million Btu
each. They can burn natural gas or coal. Combustion emissions from both
powerplants are estimated to be about 3,000 tons/year, primarily sulfur
dioxide and nitrogen oxides.
Flyash slurry from the powerplants containing about 100,000 Ib/day of
solids is pumped to a disposal pond south of the Technical Center [Figure 12]
(see the Technical Center discussion for more details).
Chemical wastes (both solid and liquid) are transported to the Goff
Mountain Landfill adjacent to the Union Carbide Institute Plant (see later
section on this plant). In 1977, non-chemical solid wastes (lumber, paper,
scrap polymer) were landfilled in the "Fillmont" area or were sent to an
undefined landfill operated by Kanawha County.
The South Charleston plant is a major generator of hazardous wastes.
The Part A RCRA permit application reported over 10 million tons per year
were generated.32 However, these are primarily industrial wastewaters
treated at the SCSTC and not hazardous wastes requiring disposal. The plant
has about 100,000 gallons of container storage and 500,000 gallons of tank
storage. A surface impoundment treatment unit with 100,000 gallons capa-
city was planned for 1983 construction. A new hazardous waste incinerator
for a new silicones process recently received a RCRA permit. Two neutrali-
zation facilities with a capacity of about 8 mgd adjust pH on wastewater
streams. Two other smaller neutralization units are planned. Non-
halogenated wastes with heat value are burned in the steam plant for supple-
mental fuel. Vinyl chloride vents are scrubbed and sent to the Island
Powerhouse.
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VII-10
At the North Bulk Terminal on the north side of the river, 10,000
gallons of container storage is available. A fume incinerator is also pre-
sent. It is designed to burn organic vapors from the cleaning of chemical
barges. Wastes with heat value are sent to the steam plant. Some wastes
go to Goff Mountain landfill.
In summary, the Union Carbide South Charleston Plant is a major petro-
chemical facility that handles numerous hazardous and/or toxic substances.
Available information indicates that direct discharges of toxic organic
substances to the Kanawha River in plant wastewaters are relatively small.
Only a few priority pollutants are discharged. The potential for spills of
toxic substances exists. Leaks of various organic chemicals occur fre-
quently. Air emissions also contain toxic substances. Vinyl chloride
emissions have been essentially eliminated. Emissions from incineration of
organic pollutants in the powerhouse have not been defined. The plant dis-
poses of large volumes of solid and hazardous wastes in disposal ponds and
landfills.
South Charleston Sewage Treatment Company, South Charleston (RM 56.2L)
South Charleston Sewage Treatment Company (SCSTC), a subsidiary of
Union Carbide, operates a wastewater treatment plant owned by the City of
South Charleston. The facility is a joint venture between Union Carbide
and the City to treat process wastewaters from Union Carbide's South
Charleston Plant and Technical Center and municipal wastewaters from the
City. It is adjacent to the South Charleston Plant [Figure 12].
The plant began operation in 1963. It provided primary treatment of
both industrial municipal wastewaters and secondary treatment of about one-
third of the effluent. Facilities to provide secondary treatment of all
flows were completed in 1968. Additional facilities were completed in 1977.
The plant is designed for separate primary treatment of municipal and
industrial wastes. The two primary effluents can then be mixed for second-
ary treatment or handled separately. In 1977, the two effluents received
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VII-11
separate secondary treatment. Treated effluents were combined before dis-
charge. This mode of operation was in use in July 1983.30
Municipal primary treatment units in 1977 included a grit chamber, two
primary clarifiers, a sludge thickener and vacuum sludge filters.12 Both
pre- and post-chlorination were provided. Primary sludge was thickened and
then dewatered on the filters. Filter cake was hauled to a South Charles-
ton landfill in 1977.12 The location was not given in the file. There was
no sludge digestion. Municipal sludges were wasted to the industrial treat-
ment system in February 1983.30 Municipal grit was disposed of at Don's
Disposal, a private landfill.30
Chlorinated primary effluent received secondary treatment (activated
sludge process) in the Aero Accelerators. These units provided both aera-
tion and secondary clarification. Waste activated sludge was pumped to the
industrial influent. Effluent from the Aero Accelerators was discharged to
the plant outfall.
No data were present in the file on toxic substances in the municipal
wastewaters. There were no reported Major Contributing Industries on the
municipal system. The manufacturing directory did not list any significant
potential industrial sources of toxic substances with South Charleston
addresses other than plants with known direct surface discharges.52 Muni-
cipal flow was about 2 mgd in September 197612 and 2.5 mgd in July 1983.30
The South Charleston population is about 16,000. There appears to be no
significant industrial flow in the municipal system.
Existing municipal flow in 1977 was about one-third of design flow.
Apparently, the municipal system was usually operated with only one primary
clarifier and one Aero Accelerator in use at one time. Aerial photographs
taken in late September and mid-October 1977 showed the No. 2 clarifier and
accelerator were not in operation.12
Process wastewaters from Union Carbide's South Charleston Plant were
conveyed to the treatment plant in a redwood flume.12 These wastewaters
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VII-12
could be pumped to one of the four large holding tanks for spill contain-
ment or for emergency storage during power outages.
Process wastewaters from the redwood flume were pumped to a grit cham-
ber and then to two primary clarifiers operated in parallel. Industrial
grit was landfilled in Union Carbide's "Fillmont" area in 1977.12 In 1983,
this grit was disposed of in the Holz Pond near the Technical Center [Fig-
ure 12].30 Primary industrial sludge (including municipal and industrial
waste activated sludge), containing about 20,000 Ib/day of solids, was
pumped to the Holz Pond. Municipal primary sludge was included in this
waste stream in February 1983.30 No sludge thickening was provided. Return
supernatant from Holz Pond was discharged to the treatment plant influent.
Primary effluent was neutralized by chemical additions and conveyed to
the equalization tanks. It was then released to the large, rectangular
aeration basin. Basin effluent flowed through three final clarifiers oper-
ated in parallel. Clarified effluent then went to the plant outfall. Acti-
vated sludge was returned to the aeration basin with waste sludge combined
with primary industrial sludge for pumping to Holz Pond.
In 1977, the average industrial flow treated was in the range of 4 to
6 mgd.12 Industrial flow was about 4 mgd in July 1983.30 Plant flows have
thus been similar for a number of years.
The current NPDES permit, which expired in 1983, limits phenolics,
copper and methyl chloride with weekly monitoring. Vinyl chloride is moni-
tored quarterly. An April 1983 modification to the permit required weekly
monitoring for organic toxic pollutants in May 1983. Quarterly bioassays
of the final effluent were also required. The NPDES file did not yet con-
tain the results of this extra monitoring.30
A vinyl chloride concentration of 0.58 ppm was measured in the efflu-
ent in December 1977.12 In February 1983, vinyl chloride was only 1.3 ug/£
reflecting the shutdown of vinyl chloride production at Union Carbide.30
-------
VII-13
During the 1972 EPA survey, no heavy metals, cyanide or phenol were
measured in the plant effluent.3 In July 1977, a 96-hour LC50 of 38% was
measured.12 The LC50 of bioassays in February 1983 ranged from 75 to 100%
indicating low toxicity.30
As discussed in the previous section, numerous organic compounds
including acrylonitrile, a priority pollutant, have been detected in the
Union Carbide process wastewaters discharged to the treatment plant. Cur-
rent data are inadequate to assess the removal of these substances in the
treatment process.
No data were available on air emissions. However, because the indus-
trial influent contains volatile organic compounds, emissions from the aera-
tion basins could be significant.
Because of the presence of toxic substances in the process wastewaters
treated by the plant, any bypassing would result in the discharge of toxic
substances to the Kanawha River. Industrial sludges currently landfilled
would also contain toxic substances.
FMC Corporation, Industrial Chemical Division, South Charleston (RM 54-55L)
FMC Corporation operates this major chemical plant occupying three
production areas in South Charleston [Figure 12]. The main production area
is the east plant adjacent to Union Carbide's South Charleston plant. The
two other production areas are adjacent to the converted Naval Ordnance
Center.
Completed in 1915, this plant was the first major chemical plant in
the Kanawha Valley. Production is continuous with little seasonal varia-
tion. Employment in 1981 was about 1,300.52
A 1977 list of products included ammonia, carbon disulfide, carbon
tetrachloride, chlorine, cyanuric acid, hydrogen peroxide, sodium hydroxide,
-------
VII-14
dichloro-5-triazine-2,4,6-(lH, 3H, 5H) trione, sodium salt and
l,3,5-trichloro-s-triazine-2,4,6-(lH, 3H, 5H) trione.12 Most products were
manufactured at the east plant. Chlorinated dry bleach was made at the
central plant and hydrogen peroxide at the west plant. Principal raw mate-
rials were salt brine, coal, urea, sulfur and natural gas. By 1983, produc-
tion of carbon disulfide, carbon tetrachloride, dichloro-5-triazine-2,4-6-
(1H, 3H, 5H) trione, and sodium salt had ceased and hydrogen production had
been added.53
An annual average of 95 mgd of cooling water was withdrawn from the
Kanawha River in 1977 through intakes at the east end and central produc-
tion areas.12 The only treatment was coarse screening and chlorination.
About 3 mgd of process, sanitary and drinking water was obtained from the
West Virginia Water Company. Cooling water intakes were downstream of
wastewater discharges from Union Carbide's South Charleston Plant and the
South Charleston Sewage Treatment Company.
In early 1977, wastewaters were discharged through 26 outfalls, 25 of
which discharged to the Kanawha River and one to Davis Creek about 0.5 mile
above its confluence with the river. Eight outfalls were considered to be
major with the remainder discharging non-contact cooling water, condensates
or surface runoff. Very little wastewater treatment was provided. As noted
during the 1972 EPA survey, the potential for spills was high at the plant.12
A large discharge of carbon tetrachloride detected in the Kanawha River
in February 1977 allegedly originated at the FMC plant.13 14 As a result
and because of requirements for reductions of pollutants discharged by July
1977, various wastewater treatment and control measures were implemented in
1977. These included consolidation of minor discharges, construction of a
neutralization facility at the east plant and installation of spill control
facilities.
A flyash pond provided settling and partial neutralization of some
plant wastes in early 1977 including flyash from plant boilers, calcium and
magnesium carbonate slurry from brine purification and some process
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VII-15
wastes from hydrogen peroxide and chlorinated bleach production. The pond
discharged to Davis Creek through Outfall 029. Treated flow was about 1.5
mgd in 1976.12 A flow of about 3 to 4 mgd was being discharged in July
1983.30
Toxic substances limited by the NPDES permit for Outfall 029 include
arsenic, hexavalent chromium, lead and chlorine. Discharges of the first
three totaled less that 1 Ib/day on the average in 1976.12 Chlorine dis-
charged averaged 6,540 Ib/day, about half the 1975 discharge. The 1972
survey detected 16 Ib/day of chromium in the flyash pond effluent. In mid-
1983, discharges of arsenic, chromium and lead were about 2 to 4 Ib/day.30
Chlorine discharges have been reduced to about 1,400 Ib/day.33
During the investigation of the February 1977 carbon tetrachloride
discharge, samples were obtai.ned from the FMC cooling water intake and seven
outfalls for organic analysis.10 Organic compounds detected in the waste-
water discharges that were not detected in the intake included di-m-butyl
ether, carbon tetrachloride, chloroform, dichlorobenzene, methyl methacryl-
ate, 2-methyl-2-pentenol, benzene, naphthalene, 4-me-2-pentanone and numer-
ous other unidentified aromatic compounds. Five of these compounds are
priority pollutants. Concentrations were not determined.
During 1983, the FMC South Charleston plant experienced frequent prob-
lems with noncompliance with their NPDES permit.30 A major problem was
frequent pH excursions which indicated that spills and leaks into wastewater
discharges were occurring. At times, pH in several discharges reached such
acid or basic levels that the discharge could be considered a hazardous
waste under RCRA. Spills, leaks and upsets at the ammonia plant also caused
permit violations.
Quarterly bioassays indicated that two effluents, Outfall 018 from the
chlor-alkali plant and Outfall 029 from the flyash pond exhibited periodic
extreme toxicity to aquatic life.30 For Outfall 018, the observed LC50 in
1982 ranged from 7.4 to 48%. For Outfall 029, the LC50 ranged from 2.5 to
65%. Similar toxicity was observed in the first half of 1983.
-------
VII-16
There are three inactive landfills onsite.39 These reportedly received
alumina, asbestos and bleach powders that are hazardous wastes. FMC has
also reported disposing of hazardous wastes in the past at a number of now
inactive disposal sites around the valley.
In the Part A RCRA permit application, FMC reported generation of about
200 tons/year of hazardous wastes based on 1981 experience.32 About 20,000
gallons of container storage capacity and 240,000 gallons of tank storage
are present at the facility. The large settling pond was initially listed
as a hazardous waste surface impoundment but this listing was withdrawn
based on a determination that wastewaters discharged to the pond were not
hazardous wastes.
Emissions of hydrocarbons in 1977 were large, about 2,500 tons/year.51
Major emissions were carbon tetrachloride (1,060 tons/year), aromatic sol-
vent (C9 to C12) (910 tons/year) and carbon disulfide (530 tons/year). Due
primarily to the shutdown of carbon disulfide and carbon tetrachloride pro-
duction and a major reduction in aromatic solvent emissions, emissions were
reduced to less than 900 tons/year in 1981.51 Chlorine and chloramine emis-
sions were significant in 1981.
Combustion emissions (primarily sulfur dioxide and nitrogen oxides)
from four boilers in the powerplant were estimated to be about 8,000 tons/
year.51
In summary, FMC has reduced discharges of priority pollutants and
chlorine from past levels but effluents are still toxic to aquatic life.
Spills and leaks of product or raw materials into cooling water discharges
are a major problem. Fluctuations in effluent pH are wide. At times, some
effluents have the corrosive characteristic of hazardous wastes due to
extreme pH. A new NPDES permit is needed for this facility that would
include BMP provisions to control spills and leaks of toxic or hazardous
substances.
-------
VII-17
Union Carbide Corporation - Technical Center
Located on the south rim of the Kanawha Valley [Figure 12] on a 670-acre
site, the Technical Center is Union Carbide's largest corporate center for
engineering, research and development, and data processing. Center facil-
ities include office buildings, laboratories, pilot plants and a powerplant.
There are about 4,600 employees.
The Center does not manufacture any products but does produce some
chemicals in developmental quantities. Various products/processes that
have been developed at the Center include several polyethylene and ethylene
processes, catalysts, pesticides, latexes, urethane foams and surfactants.
A large amount of engineering and plant construction and renovation is based
at the Center.
There are three industrial waste-disposal facilities on Technical
Center grounds [Figure 12]. The Holz Pond surface impoundment is currently
active.32 The Lower Ward Flyash Pond (Ward "B") and the Ward "A" Flyash
Pond are inactive. These ponds have received wastes from the South Charles-
ton and Institute plants.
The Lower Ward Flyash Pond was an impoundment formed in a portion of
Ward Hollow adjacent to the Technical Center. It was used until 1964 to
dispose of flyash from the South Charleston plant and a lime sludge from an
acid neutralization step of a chemical process.32 The filled pond has been
covered with soil and incorporated into a parking area. The filled pond
was roughly 400 by 800 feet.
The Ward "A" Flyash Pond, upstream of the lower pond, was used from
1964 until 1972 to dispose of the same type of wastes (flyash and lime
sludge).32 The filled pond now is covered with several feet of water and
is a wildlife area. The pond is roughly 800 by 2,000 feet.
-------
VII-18
The active Holz Pond is southwest of Ward "A" in a hollow tributary to
Davis Creek.32 Wastes are pumped to the impoundment from the South Charles-
ton plant or are hauled to the pond by truck. Pond supernatant is piped to
the South Charleston Sewage Treatment Company (SCSTC) for treatment. Wastes
disposed of in Holz Pond include:
1. Flyash from powerplants at the South Charleston plant
2. Grit from the industrial units of the SCSTC
3. Biological treatment sludges from both the industrial and domestic
units of the SCSTC
4. Biological treatment sludges from the Union Carbide Institute
plant waste treatment works
5. Treatment lime
The Pond has a storage capacity of 600 million gallons. About 3 mil-
lion tons/year of wastes are discharged to the pond. This includes car-
riage water that is decanted off, treated at the SCSTC and discharged to
the Kanawha River. Lime is added (about 600 tons/month) to the pond influ-
ent to prevent odors and precipitate heavy metals. Part of the lime is
removed with the supernatant that has a total organic carbon concentration
of 300 to 400 ppm.
Four groundwater monitoring wells have been installed and monitored
quarterly for more than a year. No unusual groundwater quality changes
have been reported.
Wastewaters from the Technical Center discharge either to Davis Creek
(and thence to the Kanawha River) or to the SCSTC.30 Non-contact cooling
water, stormwater runoff from non-contaminated areas, vacuum jet discharges
and roof drains discharge through a sewer (Outfall 003) to Davis Creek.
This discharge is monitored for TOC and can be pumped to the industrial
side of the SCSTC in the event of a spill or other contamination. The
diversion occurs automatically at a TOC level of 50 mg/£. This discharge
averages about 0.9 mgd.
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VII-19
Outfall 008 is a storm sewer that conveys surface runoff and the
overflow from Ward "A" Flyash Pond to Ward Branch of Davis Creek. Flow
averages about 0.5 mgd of which about 80% is overflow of Kanawha River water
from a fire system. Some non-contact cooling water formerly discharged
through Outfall 006 (inactive) is also present.
Seepage from the dike for the Lower Ward Flyash Pond (about 0.02 mgd)
is collected (Outfall 009) and discharged to the SCSTC. Sanitary wastes
and highly contaminated runoff from the pilot plant areas averaging about
0.3 mgd are also discharged to the SCSTC.
Most of the contaminated wastewaters from this facility are regulated
by the NPOES permit for the SCSTC. Other wastewaters appear to be minor
*
potential sources of toxic substances although spills and leaks to cooling
waters could occur. The new NPDES permit for this facility should include
BMP conditions for this reason.
The Center generates about 400 tons/year of a wide variety of hazard-
ous wastes.32 Most of these wastes are disposed of in a Brule incinerator
onsite. EPA is now processing a RCRA permit application for this
incinerator.
No emissions data were available for the Technical Center. The types
of products and raw materials handled suggest that emissions could be sig-
nificant. Due to the nature of the facility, emissions are probably highly
variable.
Union Carbide. Institute Plant (RM 48.1-49.6R)
Union Carbide operates this large chemicals plant about 8 miles down-
river from their South Charleston plant. Production facilities occupy most
of the southeastern portion of the 775-acre plant site [Figure 13]. Waste-
water treatment facilities and the Private Trucking Operations are to the
west and the Goff Mountain chemical landfill to the north.
-------
0«». l-lll 'KfJ /( '-
>lnd,,;SV,%)\\.g\f 'i/".Hi
Figure 13 Location Map - Institute Area
-------
VII-21
The Institute plant was originally built for the U.S. Government during
World War II to produce butadiene and styrene. Union Carbide purchased the
plant in 1947 to make other chemicals. Various processes have been added
over the years. In 1972, annual production was about 1.5 million tons of
basic and intermediate materials.3 The products included chemical additives
for gasoline, jet fuels, water-based paints, cheese, baked goods, and other
foods. More than 100 chemicals were made for the textile finishing industry
and more than 90 for pharmaceutical companies. Several agricultural chemi-
cals were produced including the insecticide SEVIN. Major products reported
in 1983 are listed in Table 16.53
A listing of raw materials, intermediates and final products provided
by Union Carbide in early 1978 included more than 350 compounds.12 The
principal raw materials were natural gas, chlorine, caustic, ethylene oxide,
naphthalene, alcohols, amines and air. Priority pollutants among the 350
compounds were acrylonitrile, benzo(a)pyrene, benzene, carbon tetrachloride,
chlorobenzene, chloroform, chlorophenol, chrome, copper, dichlorobenzene,
dichlorophenol, dicyclopentadiene, isophorone, methyl chloride, methylene
chloride, naphthalene, nickel, silver, toluene and trichlorophenol.
The South Charleston and Institute plants apparently interchange var-
ious chemicals. An undated listing of hazardous materials stored at South
Charleston and Institute contained more than 600 substances.12 Many of
these were identified by trade names or mixture numbers. Their actual chem-
ical makeup was not defined. The hazardous material listing also indicated
that the materials were moved by various combinations of tank truck, tank
car and barge. Some materials were purchased, some moved between the two
plants and some transported to customers. For the priority pollutants,
storage tanks were reported as less than 100,000 gallons in size except for
vinyl chloride which was stored in tanks in the 100,000 to 500,000 gallon
volume range.
The Institute plant operates continuously with little production var-
iation. Employment in 1981 was about 1,860.52
-------
VII-22
Table 16
PRODUCTS LIST53
UNION CARBIDE, INSTITUTE
Agricultural Products Group
Hydrogen
Isocyanates, organic
Methyl isocyanate
1-naphthol
Pesticides
Bromoxyni1
Carbaryl
Thiodicarb
Phosgene
Rubber processing chemicals
N-Phenyl-1-naphthylamine
1,2,3,4-Tetrahydronaphthalene
Solvents and Coating Materials Division
Acetone
Alcohols, fatty and higher synthetic
2.6-Oimethyl-4-heptanol
5-Ethyl-2-nonanol
2-(2-Butoxyethoxy) ethyl acetate
Isophorone
Isovalerone
Methyl isobutylcarbinol
Methyl isobutyl ketone
2,6,8-Trimethyl-4-nonanone
Coatings Material Division
Hydroxyethyl cellulose
Specialty Chemicals and Plastics Division
l-Butoxyethoxy-2-propanol
Ethylene glycol monohexyl ether
Glutaraldehyde
Phenylglycol ether
Polyethylene oxide
General and Compounded Products
Caprolactone polyols
Specialty glycol ethers
Ethylene Oxide Derivatives Division
Alkylbenzene, linear
Hydrochloric acid
Surface - Active Agents - Nonionic
Alcohols, mixed linear, ethoxylated
Nonylphenol, ethoxylated
General and Compounded Products
Methoxypolyglycols
(Carbowax®)
Linda Industrial Gases Division
Acetylene
Si.Iicones and Urethane Intermediate Division
1-Chlorobutane
Ethylidene norbornene
Methyl chloride
Polyether polyols for non-urethane applications
Polyether polyols for urethane applications
4-Vinyl-l-cyclohexene
5-Vinyl norbornene
-------
VII-23
Water use at the plant in 1977 was about 290 mgd.l2 Except for 1 mgd
purchased from the municipal supply, all water was withdrawn from the
Kanawha River. Two in-plant water treatment facilities provided about 5.8
mgd for process water and boiler feed. Cooling water use averaged about
280 mgd.
In 1977, the plant had 11 active outfalls regulated by the NPDES per-
mit.12 Six discharged directly to the Kanawha River and five to Goff Branch,
a small tributary draining the chemical landfill area. Outfall 001 was the
effluent from the wastewater treatment plant. One outfall was water screen
backwash water and the remaining nine were classified as non-contact cooling
water discharges. These discharges had some contamination, however, from
leaks, spills and undetected process connections.
The wastewater treatment plant has been expanded and modified several
times since it was placed in operation in 1963. In 1972, treatment units
included an equalization basin, three aeration basins (activated sludge
process), two final clarifiers and a sludge storage basin. Primary sludge
from the equalization basin and waste activated sludge were pumped to the
sludge holding basin, then to nearby sludge drying beds. Dried sludge was
landfilled at an adjacent site. It was not clear if this was immediately
adjacent to the wastewater treatment plant or at the Goff Mountain chemical
landfill.
Major modifications in the treatment system were completed in 1977.
Two primary clarifiers, an emergency holding pond, a neutralization capa-
bility, a sludge thickener and a third final clarifier were constructed.
Three sludge ponds had previously been added northeast of the treatment
plant between 1972 and 1977. In late 1977, primary sludge and waste acti-
vated sludge were thickened and pumped via pipeline to Union Carbide's South
Charleston Plant for pumping to the Holz Pond in South Charleston. This
sludge disposal practice is continuing.32 In January 1978, Union Carbide
reported that about 7 million gallons of activated sludge were stored in
two sludge ponds northeast of the treatment facility.12 This sludge was
being trucked to the Holz Pond for disposal.
-------
VII-24
During the 1972 survey, an average of 5.8 mgd of treated process
wastewaters were discharged.3 These contained daily loads of about 100 Ib
of phenols, 330 Ib of cadmium, 14 Ib of zinc, 12 Ib of copper and small
amounts of lead, nickel and chromium. A bioassay yielded a 96-hour TLM of
9% indicating the effluent was highly toxic.
Phenol was the only priority pollutant limited by the initial NPDES
permit and this limit was effective July 1, 1977.12 Wasteload reports sub-
mitted to the State indicated average phenol loads discharged had been
reduced to less than 10 Ib/day in 1977. Quarterly bioassays in 1977 showed
TLm's of 16 to 35% indicating the effluent was still moderately to highly
toxic.
Sampling of the cooling water discharges in 1972 detected a phenol
load of 42 Ib/day.3 DMR data indicated phenol loads were reduced to average
and maximum daily loads of 8 and 60 Ib, respectively, in 1976.l2
Sampling of the Institute Plant effluents in 1975 resulted in the
detection of 37 organic compounds including the priority pollutants
dichlorobenzene, dinitrotoluene, and bis(2-chloroethyl) ether.12 Ten of
the substances had known toxic effects.
Analysis of the treatment plant effluent in March 1977 detected 13
specific organic compounds.12 Bis(2-chloroethyl) ether, carbon tetra-
chloride, ethyl benzene and toluene, all priority pollutants, were present
in low levels. Dichlorobenzene isomers were present at higher levels.
Concentrations were not determined.
In 1981, EPA Region III developed a comprehensive NPDES permit for the
Institute plant.29 The permit included BAT limits for toxic pollutants
that were developed based on Best Professional Judgment (BPJ) procedures,
bioassay requirements, semi-annual priority pollutant monitoring and exten-
sive BMP requirements. The permit was issued in September 1981. An eviden-
tiary hearing was requested by Union Carbide. Issues raised included analy-
tical and variability aspects of the toxic pollutant limits. The evidentiary
-------
VII-25
hearing was settled in March 1983 and all permit conditions became effective
in May 1983.
The new permit covers a total of 42 outfalls. Nineteen are storm
drains. The permit requires development of a BMP plan to minimize pollu-
tant discharges in storm runoff. A monitoring program to develop TOC, am-
monia nitrogen and pH data on storm runoff is required. There are 16 tank
farm drains regulated by the permit. A BMP plan is to be developed to mini-
mize pollutants in these discharges. There are no numerical limits on toxic
pollutants in the storm drains or tank farm drains.
Several toxic pollutants were regulated in the main outfalls (001,
002, 003 and 005) by the 1983 (BPT) permit limits. Beginning July 1, 1984,
BAT limits reduced allowable discharges and limit additional toxic pollu-
tants. For the main wastewa.ter treatment plant effluent, chloroform was
limited. Additional pollutants limited in 1984 included acrylonitrile,
benzene, naphthalene, toluene, isophorone and carbaryl. Monthly monitoring
is required except for chloroform which is monitored three times per week.
Phenolics were limited in 1983 in Outfalls 002, 003 and 005. Chloro-
form in Outfall 005 was also limited. In 1984, limits were added for iso-
phorone in Outfall 003 and toluene, naphthalene, benzene, ethylbenzene and
carbaryl in Outfall 005.
Due to the delayed effective date of the permit, the semi-annual com-
prehensive effluent analysis for priority pollutants had not been completed
and bioassay results had not been reported. The BMP plan was not required
until 1984. When all of these requirements have been complied with, much
additional information on wastewater discharges of toxic pollutants will be
available.
The Institute plant is a major source of air pollutants. A 1977 emis-
sions inventory listed about 80 organic compounds that were emitted to the
atmosphere from various sources.12 Fifty-nine had toxicity ratings ranging
from slightly toxic to highly toxic. Five were suspected carcinogens. Ten
were priority pollutants.
-------
VII-26
The 1977 hydrocarbon emissions were more than 11,000 tons/year, the
largest volume from a chemical plant in the valley.51 Largest emissions
were methane, ethane, 2-methyl butane, cyclopentadiene, benzene, tetralin,
vinyl norbornene, ethylidene norbornene, ethylene oxide, propylene oxide,
and 2-ethyl hexaldehyde. Preliminary 1981 data indicated process emissions
of hydrocarbons were less than 2,000 tons/year in 1981.
The Institute plant has two boiler houses with eight boilers each.
All units can burn process residue. Combustion emissions from the two
boiler houses are about 9,000 tons/year, primarily sulfur dioxide and nitro-
gen oxides.51
Flyash from the boilers for at least the last decade had been disposed
of in surface impoundments adjacent to Finney Creek about 1.5 miles east of
the Institute plant [Figure 13].12 This was a contract operation. In 1977,
the contractor was Cunningham Realty Company.12 The ponds were operated by
Hatfield-Henson Enterprises in 1983. About 2 to 3 mgd of flyash slurry was
pumped to the ponds in a pipeline.12 Pond supernatant was discharged to
Finney Creek. This discharge was regulated by an NPDES permit. Solids in
the effluent periodically exceeded permit limits.30 There was no treatment
of the supernatant.
Effluent from one flyash pond (not defined) was sampled by EPA in Feb-
ruary 1972.3 Analysis for heavy metals showed only trace amounts. No
organic analyses were performed.
The Institute plant is a major generator of hazardous wastes and other
similar industrial wastes. The RCRA Part A permit application lists nearly
100 different wastes.32 These wastes are primarily disposed of in two ways.
Dilute aqueous wastes are treated in the main wastewater treatment plant.
Solid wastes, process sludges, concentrated liquid wastes and other con-
taminated waste materials are disposed of at the Goff Mountain chemical
landfill just north of the manufacturing area [Figure 13]. Wastes are
accumulated in dumpsters at about 20 locations around the plant for short
periods of time and then hauled to the landfill.
-------
VII-27
The Goff Mountain landfill has been in operation since 1967. The
landfill accepts wastes only from Union Carbide and handles wastes from the
South Charleston plant as well as Institute.32 Except for a few container-
ized polymer wastes that are buried in the containers, all wastes are mixed
with thin layers of earth as they are received and spread in thin lifts on
the landfill surface. A 2 to 3-foot clay liner is under all fill material.
Leachate and surface runoff from the active area are collected in a pond
and discharged to the Institute plant wastewater treatment facility. Sur-
face runoff from the surrounding hillsides is diverted around the landfill.
Four monitoring wells have been installed and sampled as required by RCRA
interim status standards. No significant groundwater contamination has
been reported. The landfill is apparently a well run operation with a low
potential for release of toxic substances to surface or groundwaters. No
air emissions data were available. The landfill has a permitted capacity
of 146 acre feet.
Because surface impoundments at the wastewater treatment plant receive
hazardous wastes, monitoring wells have also been installed at that loca-
tion as required by RCRA.32 These wells have detected significant ground-
water contamination, primarily heavy metals, in excess of drinking water
standards. No data on organic chemicals other than pesticides were reported
although such chemicals could be present. It is not clear whether the con-
tamination resulted from impoundment leaks or, more likely, past disposal
of industrial wastes in the area.
Solid wastes from the plant have also been disposed of at other onsite
locations. In their RCRA Part A permit application, Union Carbide indi-
cated three past landfill areas were present in the northeast part of the
main manufacturing area.32 Contents were not given. One area was about
350 by 775 feet. A 15-acre site west of the wastewater treatment plant was
reportedly used for disposal of inert (non-chemical) wastes in 1972.3 Some
sludge could also have been disposed of in the vicinity of the treatment
plant in the past. At the treatment plant site, construction of the third
final clarifier was delayed in 1976 by unstable soil conditions.12 Ashes,
waste oil and other materials were reportedly dumped in the area in the
past.
-------
VII-28
In 1977, undefined solid wastes were disposed of by contract at two
offsite landfills operated by the Kanawha County Regional Development Auth-
ority (Cross Lanes) and by the City of Huntington.
Union Carbide also operates a Private Trucking Operations (PTO) faci-
lity west of the wastewater treatment plant [Figure 13]. Various contract
truckers haul chemicals for Union Carbide in large tank trucks. To prevent
contamination of chemicals, the tanks are cleaned to remove residuals from
the previous load. Wastewaters are discharged to the adjacent wastewater
treatment plant. In 1977, pretreatment was provided which apparently in-
volved a small surface impoundment.12
Union Carbide initially submitted a RCRA notification for the PTO fa-
cility based on the fact that many of the chemicals hauled would be consid-
ered hazardous wastes if discarded.32 Washwaters could contain any of the
chemicals used or produced by Union Carbide. The notification was later
withdrawn on the basis that the drained tank trucks met the definition of
empty containers.32
The PTO facility has an incinerator for burning organic vapors from
tank cleaning.32 This unit is not considered a RCRA incinerator. No emis-
sions data were available.
A potential problem exists with the PTO site. Union Carbide has noti-
fied EPA that a wide variety of chemical wastes from the Institute plant
were buried at the site from 1950 to 1970.39 Wastes included the full range
of plant products as well as intermediates, catalysts and residue materials,
some of which were incinerated at the site. No data on groundwater contami-
nation or possible leachate migration to the Kanawha River were available.
In summary, Union Carbide's Institute plant is a major handler and
producer of toxic substances. Wastewater discharges of toxic pollutants
have been substantially reduced and are regulated by a comprehensive NPDES
permit. Air emissions, although substantially reduced in recent years, are
still major. Large volumes of hazardous wastes are generated and disposed
-------
VII-29
of in the Goff Mountain chemical landfill. Groundwater contamination has
been detected at the wastewater treatment plant site. Past disposal of
hazardous wastes at the Private Trucking Operation site has probably con-
taminated groundwater at that location.
Chemical Leaman Tank Lines, Inc., Institute (RM 48R)
Chemical Leaman Tank Lines, Inc. operates a large truck terminal and
tank cleaning facility in Institute north of Union Carbide's wastewater
treatment facility [Figure 13]. The facility has been in operation since
1962. Employment increased from 112 in 1962 to 250 in 1972.3 The terminal
was the base for 173 tank trailers and 110 truck tractors in 1972.
The functions of the terminal are the repair and maintenance of the
truck tractors and the clean.ing of the tank trailers. A wide variety of
chemicals are hauled to, from and in the Kanawha Valley for various firms.
Empty trailers are returned to the terminal for cleaning before dispatch to
the next job. Cleaning procedures vary depending on the type of substance
last hauled.
Any liquid product remaining in the tank trailer ("heels") was drained
into drums for "proper disposal" in 1972.3 This included reclamation of
pure products for reuse or disposal by combustion or in proper landfills.
Disposal sites were not specified. Heels and waste treatment sludges are
now hauled out-of-state for disposal.29
A recirculating system was used for cleaning tanks that had transported
materials requiring detergent cleaning. Detergent from a holding tank was
impinged upon the inside of the tank trailer and returned to the holding
tank. Disposal of depleted detergent solution was not defined.
After detergent cleaning, the tank trailer was then flushed with hot
water which drained out of the trailer to a floor drain and then to holding
tanks. Some tank trailers were cleaned with steam rather than the two-step
detergent and hot water washes. Steam condensate drained from the trailer
to the floor drain.
-------
VII-30
Tractor and trailer exteriors were washed and rinsed by a traveling
high pressure water system. Wash waters were collected in another tank by
a floor drain system. All washwaters from both exterior washing and tank
cleaning (except recirculated detergents) were then pumped to the waste-
water treatment plant.
About 30 to 50 tanks were cleaned daily in 1972. Chemicals hauled in
the tank trucks were representative of the various raw materials and pro-
ducts of area chemical plants and included numerous priority pollutants.
The types of chemicals vary substantially with time.
Water is obtained from the municipal supply. All water except escap-
ing steam and wastewater sludge is treated in the wastewater treatment plant.
In 1972, the treated flow was about 0.25 mgd.3 Treatment units included a
blending tank, a mixing and .coagulation tank (alum addition), a primary
settling tank, a skimming device, a trickling filter with some recircula-
tion, a secondary settling tank and a chlorine contact tank. Sludge from
the settling tanks and surface skimmings were transferred to a sludge hold-
ing tank for eventual transport by tank trailer to "authorized" disposal
sites in Ohio or Pennsylvania.
EPA sampling of the plant effluent in February 1972 found high chemi-
cal oxygen demand (543 mg/£) and phenol (3.2 mg/£).3 Analyses for cyanide
and heavy metals detected only chromium (0.45 mg/£) in a significant con-
centration. No organic analyses were performed.
The Company reported some planned changes to EPA in 1972. Tanks haul-
ing phenols or acid wastes would be steam cleaned and the condensate col-
lected in a holding tank for offsite disposal. No acid or phenol wastes
would be treated at this site. Sludge was planned to be hauled to Union
Carbide for burning. It was not documented if these changes have been
implemented.
The NPDES permit for this facility limits conventional pollutants,
phenols and hexavalent chromium.29 No toxic organic pollutants are limited.
Effluent bioassays are required. Recent company monitoring data indicate
-------
VII-31
the effluent is in the range of 0.01 to 0.015 mgd.30 Wastewater
concentrations are very high. Maximum levels of BOD, COD and oil and
grease of 810, 1,160 and 106 mg/2, respectively, have been reported. A
96-hour bioassay yielded a LC50 of 78%. Two 24-hour bioassays gave LC50's
of 95 and 100%.
It is clear that a number of toxic organic pollutants could be present
in tank cleaning washwaters. The high pollutant concentrations in the plant
effluent indicate that these pollutants could be discharged in significant
amounts even though the flow volume is low.
Chemical Leaman initially notified EPA as a RCRA facility.32 This
notification was subsequently withdrawn on the basis that tank heels were
the only RCRA wastes handled and these would be stored less than 90 days
before disposal.
-------
VIII-1
VIII. SOURCES OF TOXIC SUBSTANCES - LOWER KANAWHA VALLEY
The Lower Kanawha Valley is defined for this report to be the valley
of the Kanawha River between St. Albans (river mile 46) and Winfield Dam
near Winfield (river mile 31.1) [Figure 14]. The lower 31 miles of the
Kanawha River are outside the study area [Figure 1]. The physical charac-
teristics of the lower valley are similar to the central valley at
Charleston.
The population of the lower valley is low with a majority in the vicin-
ity of Nitro (population about 8,000). Almost all of the industrial faci-
lities are also concentrated at Nitro.
Municipal water supply is furnished by the West Virginia Water Company
and is obtained from the Elk River. Kanawha River water is no longer used
for the municipal supply at Nitro. Most industrial water supplies are
obtained directly from the Kanawha River with some from the municipal supply.
The lower valley encompasses the downstream half of the Winfield Dam
navigation pool. There is much barge traffic carrying chemicals to and
from the central and upper valley chemical plants.
MAJOR INDUSTRIAL SOURCES
There are nine major industrial sources of toxic substances in the
lower valley. These facilities include four chemical plants, a closed vis-
cose rayon staple plant, two chemical trucking firms and a very large coal-
fired powerplant.
Allied Corporation. Nitro (RM 43.2R)
Allied Corporation operates a sulfuric acid and hydrofluoric acid
plant at Nitro at the southwest corner of the industrial complex [Figure 15].
In 1972, the plant was producing 380 tons/day of sulfuric acid and 36 tons/
day of hydrofluoric acid.3 Employment was 60 people.
-------
VIII-2
.-
_.. -CHARLESTON
«**!"" (B.-P.O.)
C«r*T Ort-jr-
Figure 14 Area Map - Lower Kanawha Valley
-------
VIII-3
MONSANTO
r?f^:'ST/r
C.-A.HX"?* $'/.//,.
! ffll
MASON
OIXON
FIKE CHEMICA
COASTAL TANKER
CHEMICAL FORMULATORSv;C*x
/ v \ r{-
>-\-t r
Figure 15 Location Map - Nitro Area
-------
VIII-4
Raw materials were sulfur and fluorospar. A byproduct was calcium
sulfate. There were no other products manufactured but the facility was a
soda ash distribution point.
About 4.8 mgd of water was obtained directly from the Kanawha River.
About 4.2 mgd of water was used for cooling purposes and returned to the
river untreated. The remainder was used to sluice calcium sulfate residues
to two settling ponds operated in series. The overflow from these ponds
went to a third pond and then to the river. The three ponds in use in 1972
are shown in Figure 15, the topographical map. Aerial photographs taken in
October 1977 showed that a fourth pond had been constructed adjacent to the
river.12 The easternmost pond had been dewatered. The calcium sulfate
waste was apparently being sluiced to the middle original pond. Clarified
water was then pumped out of the middle existing pond. The function of the
new pond was not apparent but. may have been for additional settling for any
surplus pond .water.
Sampling of the plant's four wastewater streams in 1972 detected high
fluoride levels (10-13 mg/£) in the hydrofluoric acid plant cooling water
and the settling pond effluent.3 These flows totaled about 0.9 mgd. Trace
levels of heavy metals were detected.
Analysis of samples from two of Allied's discharges in February 1977
detected nine specific organic compounds in one sample and 11 in the
other.12 Nine of these were priority pollutants including benzene, carbon
tetrachloride, chlorobenzene, chloroform, dichlorobenzene isomer, 1,1,2-
trichloroethane, tetrachloroethylene and trichloroethylene. Because none
of these substances were reportedly used or produced by Allied, they may
have been in their intake water. Intake samples were apparently not
analyzed.
Exhaust gases from the sulfuric acid process pass through a Brinks
mist eliminator before discharge to the atmosphere. About 1,700 to 1,800
ppm of sulfur dioxide were being vented when the plant was inspected in
August 1975.12 About 6,000 Ib/day of sulfur dioxide were being emitted
-------
VIII-5
with the plant operating at half capacity. There were no data on possible
emissions of hydrogen fluoride.
The calcium sulfate residues discharged to the settling ponds are not
considered to be hazardous wastes. The residues are allowed to solidify
and are then broken up by a contractor, removed from the ponds and sold as
road fill.30
The Allied Chemical plant does not appear to be a significant source
of hazardous wastes or of toxic pollutants in wastewater discharges. Air
emissions of sulfur dioxide are significant.
Avtex Fibers. Inc., Nitro (RM 42.3-42.7R)
This inactive plant occupies about 140 acres between the Allied Cor-
poration and FMC plants [Figure 15]. Constructed by American Viscose in
1938 and acquired by FMC Corporation in 1963, the plant was sold to Avtex
in 1976. Avtex stopped operations in 1980. During this entire period, the
basic manufacturing process remained unchanged and the plant produced only
viscose rayon staple.
Principal raw materials were dissolving cellulose pulp, caustic soda,
carbon bisulfide, zinc sulfate and sulfuric acid (obtained from the adja-
cent Allied Corporation plant). Anhydrous sodium sulfate was marketed as a
byproduct.
The plant operated continuously year around. Production capacity was
about 120,000 tons/year. Employment was about 1,000.
Water use at the plant averaged about 9 mgd in 1977.12 Most of this
was withdrawn from the Kanawha River and treated for process water and
boiler feed. This water use was a major reduction from the 1973 average of
38 mgd.3 Currently, only contaminated surface runoff and site drainage
averaging less than 1 mgd are discharged.30
-------
VIII-6
In 1977, process wastewaters were treated in a treatment plant employ-
ing both physical-chemical and biological processes. Treatment units in-
cluded an emergency storage lagoon, four neutralization tanks in series,
two primary clarifiers in parallel, two aeration chambers in parallel, a
final clarifier, an excess sludge aerobic digester and a sludge thickener.
Zinc was removed as zinc hydroxide in the primary clarifiers. The zinc-rich
primary sludge was dewatered on two rotary vacuum filters. Filter cake was
disposed of in an adjacent Avtex landfill until about 1976. A new landfill
across the river along Scary Creek was used after 1976.32 Digested waste
activated sludge was discharged to the plant outfall. Flyash from the
boiler house also was discharged to the plant outfall and bypassed the
treatment plant.
Zinc is the only priority pollutant limited by the NPDES permit. Dur-
ing the 1972 EPA survey, no wastewater treatment was operating and the plant
was discharging 8,700 Ib/day of zinc.3 The new treatment facility reduced
the zinc discharge to a reported daily average of 79 lb.12 This suggests
that more than 4 tons/day of zinc was being landfilled in 1977.
Quarterly bioassays of the plant effluent were required. No toxicity
was shown by these tests in 1976 in contrast to high toxicity in 1972.12
No bioassays on current discharges were reported.30
In mid-1983, the Avtex discharge was frequently not in compliance with
permit pH limits. Both high and low pH values were reported.30 The efflu-
ent was high in BOD and COD. Storm events were often reported as the cause.
Current treatment was not defined.
Process emissions of air pollutants were large and uncontrolled.
Hydrogen sulfide emissions in mid-1977 were about 682 Ib/hour. Carbon bi-
sulfide emissions were much higher, about 6,200 Ib/hour. Some sulfur diox-
ide was also emitted by the process. Plant shutdown has thus produced a
major reduction in air pollution.
-------
VIII-7
A large waste disposal area occupied the southwest one-third of the
plant site. In addition to the zinc sludges previously discussed, rejected
batches of alkali cellulose crumbs and viscose solution were reportedly
disposed of in this area. Aerial photographs taken in October 1977 showed
the presence of large deposits of solid waste.12 A pond containing a dark
liquid was in the center of the filled area. This pond reportedly over-
flowed to an outfall along the south edge of the plant site that also
received effluent from Chemical Formulators, Inc. and the Cooperative Sew-
age Treatment, Inc. industrial wastewater treatment plant. In 1972, this
overflow had a pH of 13. Other small ponds of dark liquid were present
throughout the fill area. Near the parking lot were two pits, one contain-
ing a green liquid and the other a yellow-green liquid.
Several piles of drums were dumped near the south edge of the disposal
area. Two solid waste piles were noted near the southeast corner of the
plant site. Two piles of a white substance were present in the old power-
house ruins. White material was present on the ground around the anhydrous
sulfate storage building.
Avtex notified EPA in 1980 of hazardous waste operations based on the
two landfills.32 The notification was withdrawn based on plant closure,
closure of the two landfills and a determination that the material was not
hazardous.
In summary, closure of the Avtex plant has eliminated a major air pol-
lution source. Site runoff continues to be a water pollution source. Data
are inadequate to fully assess the surface and groundwater pollution poten-
tial of inactive waste disposal sites containing large volumes of zinc and
other pollutants.
FMC Corporation, Organic Chemicals Division, Nitro (RM 42.6R)
FMC operates this plant on a small 14-acre site between Avtex and Mon-
santo [Figure 15]. It produces inorganic and organic phosphorus compounds.
Initial production began in 1930. The plant has been operated by FMC since
1951. Employment in 1981 was about 200.52
-------
VIII-8
Principal products in 1977 were reportedly phosphorus trichloride and
oxychloride and triaryl, tributoxyethyl and tributyl phosphates.12 Products
also included hydrochloric acid and tri-p-cresyl, tri-isopropylphenyl and
tri(2-ethylhexyl) phosphates. The 1983 Directory of Chemical Producers
indicates that products are still about the same.53 A substantial number
of plasticizers were produced at this plant in the past but are no longer
made. Raw materials were butyl alcohol, butyl cellosolve, sodium hydrox-
ide, chlorine, oxygen, phenol, phosphorus, propylene and cresylic acid.
Arsenic was present as a contaminant in the phosphorus. Of these products
and raw materials, only arsenic and phenol are priority pollutants.
About 2.4 mgd of water was withdrawn from the Kanawha River and used
for once-through cooling without treatment in 1977.12 Treated water averag-
ing 0.4 mgd was purchased from West Virginia Water Company (Elk River water)
and used for domestic and process water, cooling tower makeup and boiler
feed.
Process wastewaters were treated in a system consisting of neutraliza-
tion tanks, an equalization basin, two aerated lagoons in series, and a
final clarifier. Ammonia was added as a nutrient. All activated sludge
was returned to the first aerated lagoon.
A short-term NPDES permit was issued to FMC by EPA Region III in 1980
with a 1981 expiration date.29 An evidentiary hearing was requested by FMC
to consider an issue of net limits on suspended solids. This hearing was
settled in January 1983. Permit limits continue in effect under the Admin-
istrative Procedures Act.
Toxic pollutants limited by the expired permit include arsenic, hexa-
valent chromium and phenolics.30 Quarterly effluent bioassays are also
required.
In 1972, phenols discharged were several hundred pounds per day.3
Phenol was reduced to less than 10 Ib/day in 1977.12 Arsenic and chromium
were less than 1 Ib/day. Effluent toxicity was a problem in 1972. Toxi-
city had been reduced somewhat in 1976 (TLm 40 to 100%).
-------
VIII-9
Sampling of the FMC effluent for organics in 1975 detected 14 specific
compounds (primarily phenolics).12 Most were at low levels.
Monitoring data for 1983 indicate that FMC periodically exceeds the
arsenic limit and has had oil and grease violations. Operational deficien-
cies in the treatment facility were noted during a May 1983 DNR inspection.30
Some pH excursions have occurred. Several bioassays show LC50's ranging
from 58 to 100% on the final effluent. Treatment plant effluent before
mixing with cooling water was extremely toxic (LC50 = 7.8%)
A new permit is needed for this facility to incorporate current permit
regulations and include permit conditions comparable to other valley chem-
ical plants. NEIC prepared a draft of a permit for this facility as techn-
ical assistance to EPA Region III.38
FMC has reported hazardous waste container storage capacity of 50,000
gallons and tank treatment capacity (neutralization) of 0.2 mgd.32 About
200,000 tons/year of corrosive wastes are neutralized and discharged to the
waste treatment plant. About 80 tons/year of other hazardous wastes are
stored in containers for offsite disposal.
FMC has reported two past landfill areas at the plant site totaling
about 0.6 acre in size.30 Wastes landfilled were apparently "doss", a gray
sand byproduct of aluminum chloride production, iron, "salts" and fuming
aluminum chloride residuals on the doss.39
Process emissions of air pollutants are low, less than 20 tons/year.51
Combustion emissions are also small.
In summary, this plant does not produce any priority pollutants and
discharges of these pollutants (from raw materials) are small. Air emis-
sions are small. Hazardous waste disposal does not appear to be a current
problem. Past site contamination is not defined.
-------
VIII-10
Monsanto Company, Nitro (RM 41.4-42.5)
Monsanto operates an industrial chemicals plant on about 240 acres
adjacent to the FMC organic chemicals plant [Figure 15]. Production faci-
lities and the wastewater treatment plant extend for about 1 mile along the
river (Figure 15).
The plant began operations in 1921. Monsanto has operated the plant
since 1929. Reportedly, products are more than 40 major kinds of organic
chemicals including rubber antioxidants, vulcanizing agents, rubber inter-
mediates and accelerators, oil additives, pre-vulcanizing inhibitors, plas-
ticizer antioxidants, animal feed antioxidants, paper sizing agents, poul-
try feed supplements, herbicides, resin modifiers, and refined tall oils.22
In late 1977, Monsanto reported 47 products listed by trade name in Table
17. Raw materials used in production of these chemicals exceeded 100 and
included alcohols, acids, caustics, oils, crude tall oil and numerous
organic and inorganic salts. Principal raw materials reported by Monsanto
in late 1977 are listed in Table 18.
Monsanto produced the herbicide 2,4,5-T at this plant until 1969.39
Production of this herbicide has been associated with the highly toxic
byproduct dioxin.
Plant operations are continuous year around. Except for tall oil,
most chemicals are produced in intermittent batch processes. Annual pro-
duction capacity was in the range of 350 million Ib in 1977.12 Employment
in 1981 was about 680.52
Cooling water averaging about 6 mgd is withdrawn from the Kanawha River
and returned to the river untreated through Outfall 002. Water for domes-
tic, process and other uses averages about 1.5 mgd and is purchased from
the West Virginia Water Company (Elk River water). All domestic and process
wastewaters, spills and leaks, and surface runoff from plant areas are col-
lected and pumped to a treatment facility for ultimate discharge to the
Kanawha River through 001.
-------
VIII-11
Table 17
LIST OF PRODUCTS
MONSANTO COMPANY
Nitre, Vest Virginia
Santocure NS Pellets
M HA Acid
Calcium MHA
Maul
Santoquin
Sodium MET
Unmilled.Santowhite Crystals
Santoflex AW
Santogard PVI
Flectol H
Sulfasan R
Thiofide
Santowhite Powder
Santocure Pellets
Santonox R
Santovar A
Santocure NS Pellets
Santocure Powder
50% Sodium MBT
Santocure NS Powder
Santosize 70T
Santoflex DD
M-530
PC-1244
PC-1344
Thiotax
Mersize 70-TFL
Mersize 77-T
Mersize 77-TFL
Santosize 77
Rosin Size KIP 70
Monsize
Mersize 603 Adduct
Sulfasan R Wax Pellets
Multiflow
BTH
CDEC
TORUFA
UFA Bleached
Emtall 730
Emtall 786 - Pitch
Emtall 743 - SFA
Emtall 729
Emtall 731.
Emtall 753-V
Emtall 745
PVI Waxed Pellets
-------
VIII-12
Table 18
LIST OF PRINCIPAL RAW MATERIALS
MONSANTO COMPANY
Nitro, Vest Virginia
Acetic Acid, Glacial
*Acrolein
Acrylate, 2-Ethyl Hexyl
N-Butyl Alcohol
Ammonia, Anhydrous
Ammonia, Aqua
Benzoyl Peroxide
Butyraldehyde
Calcium Chloride
Carbon Bisulfide
Carbon Black
Chlorine
Clay
Clenzolene
Coal
Kerosene
Cresol, IBM
* 2 ,3-Dichloropropene
Die thy la mine
Dow Corning Fluid
Ethyl Acrylate
Dicalite 4200
Skellysolve (Heptane)
*Hydrogen Cyanide
Hydroquinone
Lime
Methocel
Rule 66 Mineral Spirits
Morpholine
Muriatic Acid
Nitrogen
No. 2 Fuel Oil
Crude Tall Oil
Phosphoric Acid
Polyethylene Glycol
Potassium Chloride
Pyridine
Soda Ash
S.A.B.S.
Sodium Chloride
Stearic Acid
Molten Sulfur
Sulfur Dichloride
Sulfuric Acid
Sulfur Monochloride
Tertiary Amylene
* Toluene
* Trichloroethylene
Varsol 2
White Crude Scale Wax
Liquid Crystal Wax
Xylene
Foam, Fire
Toluene Sulfonic Acid
Fumaric Acid
Muriatic Acid
Dodecyl Aniline
Para Phenetidine
Potassium
Hydroxide
Sodium Sulfite
Acetone
Phthalic Anhydride
Tertiary Butylamine
Methanol
Phthalic Anhydride
50% Formalin
Methyl Mercaptan
Aniline Oil
Cyclohexylamine
Cyclohexyl Mercaptan
Disod. Phosphate (DSP)
CO2
Sodium Alkyl Benzene Sulphonates
Priority Pollutants
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VIII-13
Prior to 1977, the wastewater treatment facility consisted of three
primary settling lagoons, a limestone neutralization pit and three aerated
lagoons. Substantial modifications were completed in 1977. Treatment units
in series included a spill/surge lagoon, an emergency overflow lagoon, a
covered equalization pond/primary settling lagoon, the limestone pit, neu-
tralization facilities, an aerated activated sludge basin and a final
clarifier.12 Effluent from the final clarifier could either be discharged
directly to the river or to a large aerated lagoon for additional treat-
ment. Excess activated sludge was pumped to an aerated lagoon for aerobic
digestion and long-term storage. Primary sludge was stored in the equali-
zation pond where it was settled. Many years capacity was available. In
1982, sludge was reportedly removed annually and disposed of in the Mon-
santo landfill.30
Toxic substances limited by the NPDES permit for Outfall 001 include
chromium and cyanide.30 No loads have been reported but average limits are
1 Ib/day each. Quarterly bioassays are required. A TLm of 3.3% to 5.4%
was reported in 1976.l2 The 1972 EPA survey yielded a TLm of 7.6%.3 This
effluent was thus highly toxic to test organisms. Phenols were measured at
5 Ib/day in 1972. A DNR bioassay in March 1983 indicated the effluent was
moderately toxic (LC50 = 44%).30
No toxics are limited for Outfall 002. Bioassays in 1975 indicated
some toxicity was present (TLm of 24 to 76%).12
Analysis of the Outfall 001 discharge for organics in 1975 detected 31
specific organic compounds.12 About half of these had some reported toxic
effects. Tetrachloroethylene, a priority pollutant, was present at a con-
centration of 0.9 mg/£.
The list of raw materials [Table 18] includes five priority pollutants
(acrolein, dichloropropene, cyanide, toluene and trichloroethylene). File
data did not indicate that these pollutants had been detected in plant
effluents.12
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In 1981, the Toxics Integration Project estimated Monsanto discharges
of toxic pollutants to be about 2 Ib/day for organics and 3 Ib/day of heavy
metals.33
In 1982, EPA Region III had completed a comprehensive draft BAT permit
for the Monsanto plant. Monsanto objected to some of the permit conditions
with most of the objections related to national litigation on EPA permit
regulations. This litigation has now been settled. The current Monsanto
NPDES permit expired in 1981. Renewal of the permit based on the Region
III draft is needed to ensure comprehensive control of toxic pollutants
from this source comparable to BAT permits for other major chemical plants
in the valley.
Hydrogen sulfide off-gases from a reactor were passed through a sulfur
recovery unit and then to an. incinerator in 1977.12 Other off-gases were
also incinerated. There was no sulfur dioxide control on the incinerator
emissions. Maximum sulfur dioxide emission rates were about 300 Ib/hour.
The incinerator-sulfur recovery system was equipped with an emergency flare.
An emergency flare was also present for control of HCN storage emissions.
Other air pollution controls included baghouses on most process units for
product recovery.
In late 1977, Monsanto reported that 64 hydrocarbon compounds were
emitted to the atmosphere, most in very small intermittent amounts.12 Daily
emissions of toluene were 250 Ib and trichloroethylene, 30 Ib. Small
amounts of acrolein, formaldehyde, carbon disulfide and HCN were also
emitted.
The plant had five boilers (two on natural gas, three on coal) and a
tall oil furnace.12 The furnace burned pitch and natural gas. About 82,000
tons/year of coal with a sulfur content of 0.75 to 1.09% were burned.
About 28 tons/day of flyash were disposed of offsite by a contractor.
Various solid wastes were disposed of in a landfill on Monsanto property
northeast of the wastewater treatment plant.12 In late 1977, Monsanto
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VIII-15
reported that wastes disposed of annually included 900 tons of filter cake,
1,100 tons of pitch, 240 tons of residue and 1,650 tons of trash. The fil-
ter cake and pitch were considered by Monsanto to be "relatively harmless"
while the residue was "relatively harmless to slightly toxic". All three
were described as practically insoluble.
Monsanto is a major generator of hazardous wastes. Wastes are dis-
posed of by neutralization and wastewater treatment, incineration, burning
as fuel in the utility boiler or offsite disposal.32 No onsite landfilling
was reported. About 1,000 tons/year of ignitable wastes and spent non-
halogenated solvents are burned in the boiler. About 25 tons/year of acro-
lein and HCN wastes are incinerated. About 175,000 tons/year of corrosive
wastes (primarily dilute wastewaters) are neutralized and treated at the
wastewater treatment plant. Other hazardous wastes (primarily ignitables)
totaling less than 500 tons/year are stored in tanks and containers for
offsite shipment. Hazardous waste management units include about 21,000
gallons of container storage capacity, 45,000 gallons of tank storage, two
surface impoundments totaling 14 million gallons, and an incinerator with a
capacity of 0.5 tons/hour.
Monsanto has reported three past landfills onsite.32 Two are small
areas. One is on the north side of the manufacturing area near the Kanawha
River and the other is on the west side of the wastewater treatment plant.
The third area is shown as a "past solid waste landfill" and occupies about
20 acres on the west side of Armour Creek northeast of the water treatment
plant [Figure 15]. There is some controversy as to whether wastes disposed
of in the main landfill were hazardous wastes.
Monsanto conducts groundwater monitoring in the vicinity of the sur-
face impoundments as required by RCRA interim status standards. Low pH
(4.6) and several heavy metals exceeding drinking water standards have been
observed.
Because of past production of 2,4,5-T herbicide, EPA and Monsanto have
surveyed the plant site for possible dioxin contamination. Monsanto
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VIII-16
reported that dioxin was detected at a concentration of about 100 ppb in
soil at one plant location.42
In summary, the Monsanto plant appears to have only small discharges
of toxic pollutants in wastewater discharges. Although improved from past
observations of extreme toxicity, treated wastewater continues to exhibit
some toxicity to aquatic life. Current process emissions of organic chemi-
cals are not documented but are believed to be significant. Combustion
emissions of sulfur dioxide are major. Groundwater and site contamination
is an emerging but only partially defined problem.
Fike Chemicals, Inc., Nitro
Fike Chemicals, Inc. (Fike) operates a small chemicals plant in the
southeastern part of the Nitro industrial complex [Figure 14]. The plant
began operations in 1953 as the Roberts Chemical Company. It has been Fike
Chemicals, Inc. since 1971.
The plant is on a compact 11-acre site adjacent to Coastal Tank Lines,
Inc., Vimasco Corp. and a truck tractor maintenance facility operated by
Chemical Leaman Tank Lines, Inc. Inadequate pollution control and waste
disposal practices at this complex of chemical producers and transporters
has produced documented pollution of the groundwater system with toxic sub-
stances. Surface runoff from the area is also contaminated with toxic sub-
stances. Potentially toxic organic chemicals are being released to the
atmosphere.
The Fike plant is a small-volume firm that specializes in the develop-
ment of new chemicals, in custom chemical processing and in specialty chem-
icals. About 50 different products were manufactured at the site in 1977.1S
Table 19 lists products reported in 1983.53 At least 13 chemicals produced
or used by Fike in 1977 were priority pollutants.15
All processes in 1977 were small (5,000 Ib/day) batch-type operations
with reaction times that were as long as a week.15 This resulted in inter-
mittent wastewater discharges. Wastewaters from the plant were disposed of
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VIII-17
in two ways. Treatable wastewaters were discharged to the Cooperative Sewage
Treatment, Inc. (CST) facility for treatment and discharge to the Kanawha
River. Highly contaminated wastewaters were discharged to an "evaporation"
pond at the southwest corner of the site. Poor housekeeping practices at
the plant were prevalent, and it is probable that some of the highly contam-
inated wastewaters were discharged to the CST facility.
Table 19
PRODUCTS LIST53
FIKE CHEMICALS, INC.
Nitro, West Virginia
Allyl cyanide
Bis (2-hydroxyethyl) formamide
Crotononitrile
2,3-Dichloropropene-l
Dithio-oxamide
1,2-Ethanedithiol
Ethyl fluoroacetate
Ethyl formamide
2-Ethyl-4-methylimidazole
Fluoroacetamide sodium amide
Hexamethy1phosphorami de
N-2(2-Hydroxyethyl) formamide
Methoxytriethyleneglycol acetate
N-Morpholyl formamide
Pesticides
EXD
Sodium fluoroacetate
1,2-Propanedithiol
1,3-Propanedithiol
Rubber Processing Chemicals
Di-n-butyldithiocarbamic acid, zinc salt
1,3-D-n-butylthiourea
Diethyldithiocarbamic acid, zinc salt
l,3-Diethyl-2-thiourea
1,3-Dimethylthiourea
2-Imidazolidine thione
Sodium amide
Sodium ehtylate
Sodium methyl ate
Thiobenzyl alcohol
Ziram
The Cooperative Sewage Treatment facility was originally constructed
to provide treatment for wastewaters from Fike Chemical and Coastal Tank
Lines. The plant also served Vimasco Corp. and Atlas Steel Container.
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VIII-18
Atlas has ceased operation. Vimasco does not discharge wastewaters to the
CST. Coastal Tank Lines now has its own treatment system (see following
discussion). In 1977, the CST was treating wastes from Fike and Coastal.15
The CST was a biological treatment system in 1977 but pollutant
removals equivalent only to primary treatment were being achieved.15 Aver-
age BOD and COD concentrations (760 and 2,980 mg/£, respectively) were very
high for a treated effluent. Thirty-seven organic compounds were identi-
fied in the Fike discharge to the CST and 13 in the Coastal discharge.
Both discharges were highly toxic to aquatic life. Seventeen compounds
detected in the CST effluent had known toxic effects. The CST effluent was
also highly toxic to aquatic life.
Additional treatment units, including activated carbon filters, have
been installed at the CST since 1977. In mid-1983, effluent flow (entirely
from Fike Chemical) averaged 0.024 mgd, about half of the 1977 flow. The
effluent was still extremely toxic (LC50 = 8%).30 In most of the first
half of 1983, phenol load limits in the NPDES permit had been violated.
Other waste characteristics were periodically high, indicating either in-
adequate treatment or treatment system overloads.
The NPDES permit for the CST was issued in February 1982 for 5 years.
The permit contains requirements for monthly bioassays of the final efflu-
ent. If a bioassay yields an LC50 of less than 50%, a toxicity reduction
plan was to be submitted within 30 days. No plan was noted in the file.
Extreme effluent toxicity continued through 1983.
The NPDES Permit does not contain specific numerical limits on toxic
organic pollutants. Given the toxicity of the effluent and high COD, this
facility could be a significant discharge of toxic organic pollutants.
In 1977, chemicals had been spilled on the ground surface at many spots
in the processing area.15 Some wastewaters had been placed in steel drums
that were allowed to rust out with subsequent spillage onto the ground.
The entire processing area was so contaminated with unknown chemicals that
it was probable that surface runoff was highly contaminated and that
leaching of chemicals into the groundwater was occurring.
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VIII-19
Air pollution controls were minimal.15 Only two of four scrubbers
were operational during the 1977 monitoring survey. Nauseating odors were
present throughout the survey. Various toxic chemicals were emitted to the
atmosphere. Emissions in 1981 were estimated at less than 50 ton/year,
primarily hydrogen sulfide.51
Two methods of solid waste disposal were used in 1977.1S Paper and
trash were hauled to a sanitary landfill by a disposal contractor. Drums,
still bottoms and various reaction byproducts were disposed of onsite in an
unlined pit. Materials were not regularly covered with earth. The drums
rusted, allowing their contents to flow onto the ground. Once the pit was
full, a bulldozer was used to crush the drums and backfill the pit. This
disposal method allowed toxic chemicals to leach into the ground and the
groundwater system. The pit in use in October 1977 had a volume of about
53,500 ft3 and was about 40% full. The volume of materials previously dis-
posed of onsite in this manner was not documented.
There were two "evaporation" ponds on the site in 1977.l5 The old
pond had been in use for about 8 years. It was of unlined earth construc-
tion and had a surface area of about 15,100 ft2 and an average depth of
1.5 ft. In addition to the Fike wastewaters, the "evaporation" pond in the
past received sludge from the CST treatment facility and concentrated ini-
tial rinsewaters from the Coastal Tank Lines, Inc. tank trailer cleaning
operations.
A new "evaporation" pond was constructed in September 1977. It had an
estimated volume of 43,500 ft3. Coastal rinse waters and CST sludge were
being discharged to the new pond during the October 1977 survey.
Computations showed that if there was no seepage from the old pond, no
evaporation or precipitation, the pond would fill to the level observed in
about 35 processing days. It would overflow in an additional 23 processing
days. In this geographical area, precipitation exceeds evaporation. There-
fore, it was evident that the pond contents seeped into the ground. Based
on October 1977 effluent rates, the new pond would be expected to fill in
about 30 working days. Thus, this pond could only function for a long time
period if it seeped.
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VIII-20
During the NEIC survey, samples were taken of the old pond contents
and from three monitoring wells near the pond. Twenty-one organic compounds
were detected in the pond contents including five priority pollutants. Ten
of the same compounds including four priority pollutants were found in the
monitoring well closest to the pond, confirming that there was seepage from
the pond to the groundwater. Arsenic, cadmium and lead were also found in
both the pond and the groundwater. Other organic chemicals were detected
in the wells but not in the pond, indicating groundwater contamination from
sources other than the pond.
Site investigations since 1977 have further documented the contamina-
tion of the plant site and underlying groundwater with numerous toxic chem-
icals.16 39 The Fike Chemicals site has been named to the Superfund
national priority list as a result.17 Fike Chemical has prepared a remedial
action plan but site contamination has not yet been abated.39
Coastal Tank Lines, Inc., Nitro
Coastal Tank Lines, Inc. (Coastal) operates a truck terminal adjacent
to the Fike plant [Figure 14]. The Company hauls finished chemical pro-
ducts and raw materials for numerous chemical firms. Empty tank trailers
are returned to the terminal for cleaning and repair before resuming ser-
vice. About 70 truck tractors and 107 tank trailers were serviced by the
Coastal terminal in 1977.15
About 25 trucks and trailers were washed per day, 6 days per week in
1977. The empty trailers normally contained only 5 to 10 gallons of the
material hauled when they returned to the terminal.
The interior of the trailers first received a pre-rinse, using water
that had been used for a final rinse. After the pre-rinse, a cleaning solu-
tion was added to the interior of the trailers; this solution was recycled
to the cleaning solution makeup tank. The trailers then received a final
wash, and this water was recycled and used for the pre-rinse. When the
cleaning solution was spent, it was pumped to a tank trailer dedicated for
this use. Occasionally the cleaning solutions overflowed the makeup tank
and discharged to the CST treatment plant.
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VIII-21
In 1977, Coastal had two ways of disposing of the waste from washing
the trucks.15 First, the pre-rinse water was pumped into a 5,000-gal. truck
trailer (discussed above) and dumped into the Fike evaporative pond along
with the spent cleaning solution. Second, after the final washwater was
transferred to the pre-rinse tank, any excess was discharged to the CST
sewer. The tank trailer was discharged about three times in a 48-hour
period.
Coastal installed its own wastewater treatment system in 1980 and no
longer discharges to the CST or to the Fike lagoon.30
The treated effluent is regulated by an NPDES permit. No toxic organ-
ic pollutant limits are included in the permit. Quarterly bioassays are
required.
The company indicates that flow is only about 0.005 mgd. However,
COD, oil and grease, and phenol levels are very high, indicating inadequate
treatment.30 This small discharge could be a significant source of toxic
pollutants.
Residual chemical "heels" present in the truck tanks when returned for
cleaning are supposed to be drained and collected in containers for offsite
recycling or disposal as hazardous wastes. A state NPDES inspection indi-
cated the possibility that heels were sometimes discharged to the waste-
water treatment plant.30
Coastal initially notified EPA as a RCRA generator and storage facil-
ity.32 The notification has been withdrawn on the basis that hazardous
wastes will be stored less than 90 days.
Kincaid Enterprises, Nitro
Kincaid Enterprises (formerly Chemical Formulators) operates a small
(22 employees) chemical plant adjacent to Coastal [Figure 14]. In 1977,
the plant produced methoxychlor, maleic hydrazine, maleic hydrazine 30 and
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VIII-22
Bordeaus mixture as products and anisole as an intermediate for making
methoxychlor.18 All products were batch made. Raw materials included
phenol, methyl chloride, trichloroacetaldehyde, aluminum catalyst, hydra-
zine hydrate, sulfuric acid, maleic anhydride, diethanolamine, copper sul-
fate and lime. All of these materials and products are hazardous and five
are priority pollutants. In 1983, the plant reported only anisole, chloro-
neb and methoxychlor as products.53
In 1972, the plant also formulated and packaged a variety of insecti-
cides from purchased pesticide materials.3 These operations have been dis-
continued.
Water supply was obtained from two sources. Well water was used for
makeup in a noncontact recirculating cooling water system. Process water
averaging about 150,000 gal./month was purchased from the West Virginia
Water Company.
All process wastewater and most storm runoff was treated in the plant's
treatment facility prior to discharge to the outfall sewer that also conveys
the CST effluent to the Kanawha River. In 1972, treatment units included a
primary settling tank with pH adjustment for aluminum precipitation, an
oil-skimming unit, a secondary settling (holding) tank, a spray aeration
and trickling filter unit, and a final clear well.3 Effluent from the
trickling filter flowed to the clear well where it could either be recycled
to the process units or discharged to the outfall. This arrangement pro-
duced intermittent discharges to the river outfall. Frequently, no effluent
was discharged for days.
The treatment system was modified in late 1977.18 A phenol treatment
unit, sludge dewatering ponds, a final treatment pond and two carbon columns
on the final effluent were added.
The 1972 EPA survey found low levels of lead, cyanide, cadmium, chrom-
ium, and nickel in the plant effluent.3 Higher levels of zinc (10 mg/£)
and copper (0.7 mg/£) were observed. Phenol was very high at 2,500 mg/£.
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VIII-23
This was a discharge of 55 Ib/day on the day sampled. Self-monitoring data
for the first half of 1977 showed that phenol concentrations ranged from
420 to 3,450 mg/£ for the 11 days of discharge. The maximum load discharged
was 316 Ib/day. A state survey in September 1976 found an even higher 4,180
mg/£ of phenol in a short-term discharge. Arsenic, cadmium and lead were
present at low levels. Chromium at 0.9 mg/£ and copper at 1.3 mg/S. were
higher. Methoxychlor was present at a 5 mg/£ level.
It is apparent from this data that past intermittent discharges from
Chemical Formulators contained substantial amounts of toxic substances.
Emissions from the two methoxychlor reactors were vented through scrub-
bers in 1977.18 Emissions can contain HC1 fumes. No data on present emis-
sions were available.
Paper, trash etc. were hauled by a private contractor to a landfill.
Onsite disposal in an unlined pit was used for solid wastes (primarily sod-
ium phenolate) generated by the processes.18
In 1980, part of the site was flooded for an extended period of time
by wastewaters contaminated with phenols and pesticides. The plant site is
listed as an inactive hazardous waste disposal site as a result.39
Appalachian Power Company, John E. Amos Plant, Nitro (RM 39.5L)
Appalachian Power Company operates this very large, coal-fired, thermal
electric powerplant north of Nitro [Figure 16]. The plant has three gener-
ating units, two rated at 800 MW each and one at 1,300 MW. The units were
placed in operation between 1971 and 1973.
The plant has a recirculating cooling system with three large natural
draft hyperbolic cooling towers. Makeup water is withdrawn from the Kanawha
River and treated with sulfuric acid.
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Figure 16 Location Map - Amos Power Plant
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VIII-25
Bottom ash is sluiced to ponds northwest of the powerplant. Cooling
tower blowdown also flows to these ponds. Pond effluent is pumped with
flyash to a large pond southwest of the powerplant on Little Scary Creek.
Excess blowdown (about 7.5 mgd) is discharged to the Kanawha River.
Flyash pond effluent averaging about 12.1 mgd flows down Little Scary
Creek to the Kanawha River opposite the Monsanto Company facility.
The flyash pond effluent makes up essentially all flow in Little Scary
Creek. Arsenic concentrations in the effluent exceed water quality criteria
for arsenic in tributaries of the Kanawha River. In 1977, the water quality
standards were revised to increase the arsenic limit for Little Scary Creek
to 200 (jg/JiL This is about 4 Ib/day of arsenic.
The flyash lagoon had about a 15-year storage capacity in 1977.12
Bottom ash pond capacity was not specified.
About 25,000 tons/day of coal with a sulfur content of 0.9% were burned
at full operation in 1977. This resulted in the discharge of large volumes
of sulfur dioxide through the plant's two very tall stacks.
Initially, the powerplant was listed as a RCRA storage facility be-
cause metal cleaning waste believed to be hazardous wastes were stored in a
surface impoundment.32 The wastes were found to pass the EP toxicity test
(they are nonhazardous) so the notification was withdrawn. The plant also
generates some waste oil and solvents. These are reused as boiler fuel.
Mason and Dixon Tank Lines, Inc., St. Albans (RM 43.5L)
Mason and Dixon operates a truck terminal for the cleaning and repair
of bulk chemical tank trucks across the river from Allied Chemical in Nitro
[Figure 15]. In 1972, about 50 employees including truck drivers were based
at the terminal.3 This facility is thus much smaller than either the Chem-
ical Leaman or Coastal terminals previously discussed.
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VIII-26
Specific tank cleaning procedures were not described in available in-
formation, but they are apparently similar to those used by Chemical Leaman
and Coastal.12 About 10 tanks were cleaned daily in 1972.3
A wide variety of chemicals is carried by the tank trucks. Thus, many
chemicals would be included in the tank drainage and washwater.
The wastewater treatment plant was operated in a batch mode one shift/
day in 1972, although cleaning operations occurred around the clock.3
Wastewaters were discharged to a 10,000-gal. holding tank. They were then
treated in 3,500-gal. batches in primary holding tanks. The wastewater was
then passed through an air flotation unit and an activated sludge package
plant with post-chlorination. Sewage was discharged to the activated sludge
plant. Sludge disposal was not specified. The average flow treated was
about 0.011 mgd.
When inspected by EPA in 1972, the treatment system was producing a
poor quality effluent as indicated by high BOD (2,450 mg/£), COD (7,050
mg/£) and suspended solids (850 mg/£). Phenols, cyanide and copper were
present at low levels.
The treatment system is still producing poor quality effluent and has
been issued a notice to comply by DNR as a result.30
The current wastewater discharge permit does not limit any specific
toxic pollutants but does require quarterly bioassay testing. The July
1983 tests showed the effluent was extremely toxic (5-16%).30 This should
trigger a permit condition requiring complete analysis of the effluent for
toxic organic pollutants. No results were yet present in the file.
It is apparent that Mason and Dixon is experiencing the same kind of
problems in producing acceptable effluent quality as the other tank truck
cleaning operations. This discharge could be a significant source of toxic
substances.
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IX-1
IX. ENVIRONMENTAL CONTROL PROGRAMS
Environmental conditions, their causes, and their effects in the
Kanawha Valley are of local, state, and national concern. Agencies at all
levels of government are involved in programs to control and regulate acti-
vities that exert an effect on the environment. This section reviews the
activities of West Virginia State and Federal agencies as they relate to
environmental control programs. Where needs are identified, suggestions
are made for program changes or additions. Control programs are divided
into three categories (environmental standards, environmental monitoring
and source control programs) in the following discussion with subdivision
by media.
ENVIRONMENTAL STANDARDS
Environmental standards or criteria have several purposes. They form
benchmarks against which existing environmental conditions can be measured.
They specify acceptable ambient air quality to protect human health and
acceptable water quality to protect human health and other beneficial water
uses. They are often used by regulatory agencies to determine the need for
more stringent controls on sources of air or water pollution. They may
form the regulatory basis for specific limits on sources of pollution.
Environmental standards are based on scientific study and consider
health risks among other factors. They are defensible in regulatory actions.
They are useful for objective evaluations of environmental problems of public
concern. This is especially important with respect to the emotional issues
surrounding toxic substances in the environment.
Water Quality
Section 303 of the Clean Water Act requires that water quality stand-
ards be established for all surface waters of the United States. These
standards consist of designated uses of stream segments based on water uses
to be protected and water quality criteria for each designated use. The
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criteria specify levels of water quality that must be maintained or exceeded
to protect each water use.
EPA is given the responsibility to develop and publish information on
water quality required for various uses and other guidance for the develop-
ment and promulgation of water quality standards. The states are given the
responsibility of designating the water uses to be protected in their
streams and establishing associated water quality criteria.
The West Virginia Department of Natural Resources (DNR) established
water quality standards for the waters of the Kanawha Valley as required by
the Clean Water Act. These were subsequently approved by EPA. Specific
water quality criteria included in these standards gave limited attention
to toxic organic pollutants.
Section 304 of the Clean Water Act, amended in 1977, required EPA and
the states to give more attention to a series of specific toxic pollutants
known as priority pollutants. EPA was required to develop and publish rec-
ommended criteria for 65 priority pollutants for protection of human health
and aquatic life. Recommended criteria were published in a series of cri-
teria documents during 1980. A summary of the water quality criteria was
published in the Federal Register on November 28, I960.47
In 1981 and again in early 1984, DNR revised their water quality cri-
teria to include limits on several additional chemical substances. The
present water quality criteria contain specific numerical limits on some
toxic pollutants (heavy metals, PCBs and six pesticides) but do not contain
specific limits on several toxic organic pollutants detectable in the river.
The water quality standards do contain a section, however, which provides
for the case-by-case establishment of "safe concentration values" for speci-
fic toxic pollutants for wastewater discharges into waters classified for
propagation of aquatic life. The safe concentration values are to be based
on biological studies, published literature and/or bioassays.
As discussed in Section IV, the quality of the sport fishery in the
Kanawha River declines from the upper reaches to the lower river. Some
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contamination of fish with toxic pollutants has been detected. Recent
studies33 36 have suggested the potential exists for contamination of fish
with other toxic pollutants. Several industrial wastewater discharges have
been shown to be toxic to aquatic life. There is a need to conduct a com-
prehensive review of biological data including fish flesh analyses; data on
ambient water quality, especially toxic organic pollutants; effluent bio-
assay data; and effluent concentrations of toxic organic pollutants. Based
on this review, a determination could then be made if additional toxic
organic pollutant criteria should be included in the water quality stand-
ards to enhance propagation and maintenance of a sport fishery and to mini-
mize potential health hazards from consumption of contaminated fish. Revi-
sion of the current water quality standards to include specific criteria
for toxic organic pollutants of concern in the Kanawha River consistent
with EPA guidance would provide a rational basis for programs to control
sources of these specific substances, would ensure protection of water uses,
and would provide benchmarks for assessing existing water quality.
Air Quality
A similar regulatory pattern exists with respect to air quality. The
Clean Air Act requires EPA to establish primary and secondary air quality
standards for several air pollutants to protect human health. The states
are required to develop implementation plans that prescribe control mea-
sures to achieve these standards.
EPA promulgated the required air quality standards and the West Vir-
ginia Air Pollution Control Commission (WVAPCC) developed an EPA-approved
State Implementation Plan (SIP). The SIP addressed control of sulfur diox-
ide, total suspended particulates, carbon monoxide, nitrogen oxides, hydro-
carbons and ozone, the only pollutants for which EPA established air qual-
ity standards. Implementation of this SIP, which required various air pol-
lution controls, has resulted in major air quality enhancement as discussed
in Section IV. Further air pollution controls are apparently needed to
achieve complete compliance with secondary air quality standards for total
suspended particulates.
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The Clean Air Act takes a different approach to control of hazardous
air pollutants, those pollutants that pose a hazard to human health but for
which ambient air criteria have not been established. The Act requires EPA
to establish national emissions standards for each class of major indus-
trial sources of designated hazardous air pollutants. EPA has established
emissions standards for only five hazardous air pollutants of which asbestos,
benzene and vinyl chloride are emitted from sources in the Kanawha Valley.
National emission standards have limited application in reducing emissions
of chemical substances in the Kanawha Valley.
In June 1984, EPA promulgated final regulations to control fugitive
emissions of benzene from new and existing refineries and organic chemicals
plants and emissions from product storage. This will impact benzene emis-
sions in the valley in the future.
The Clean Air Act also requires EPA to establish new source perform-
ance standards that control emissions of a variety of air pollutants from
new facilities in a number of major industrial categories. These have only
limited application in reducing emissions from existing facilities.
It does not appear likely that EPA or the Clean Air Act will move any-
time soon toward establishing ambient air standards for the various unregu-
lated volatile organic chemicals known or suspected to be present in the
Kanawha Valley atmosphere. Recognizing this fact, both the WVAPCC and the
West Virginia Department of Health (DOH) are taking steps to address con-
cerns about the potential health effects of present ambient levels of chem-
ical substances. DOH is reviewing preliminary data from an inventory of
process emissions of volatile organic chemicals from chemical plants being
compiled by WVAPCC. Health effects data on chemicals emitted in significant
amounts are being reviewed with the intent of identifying a list of chemi-
cals of concern for the Kanawha Valley. These would be chemicals emitted
in significant amounts that have adverse health effects at low ambient con-
centrations. DOH then intends to request WVAPCC to implement a program to
reduce emissions of these chemicals of concern to the lowest levels prac-
tical consistent with available air pollution control technology.
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In a similar approach, WVAPCC has submitted preliminary emissions data
from two major plants to EPA with a request that the compounds be reviewed
from a toxicological viewpoint so a priority ranking of the compounds can
be made. This ranking would be used by WVAPCC in selecting specific pro-
cesses and/or emission points to be addressed first by a technology-based
emissions control program. EPA has provided a preliminary screening and
prioritizing of a number of substances.
There is a need for early completion of both the DOH list of chemical
air pollutants of concern and the prioritization of these pollutants as
requested by WVAPCC. This would provide a rational basis for focusing a
volatile organic chemicals emissions control program on those sources with
the most important potential health impacts. Completion of the emissions
inventory and the conduct of some exposure assessments will be needed as
part of this effort.
Since 1979, the WVAPCC enabling legislation has contained a provision
prohibiting the WVAPCC from establishing air pollution control requirements
more stringent than Federal requirements. This may pose a possible legal
impediment to an aggressive WVAPCC control program for volatiles.
ENVIRONMENTAL MONITORING
Monitoring of ambient environmental conditions and of pollution sources
is an important part of all environmental control programs. Ambient moni-
toring is needed to assess environmental quality with respect to the stand-
ards previously discussed and to identify trends and problem areas. It is
also useful in identifying sources of pollution. Monitoring of pollution
sources is needed to assess compliance with applicable limits on pollutant
emissions or discharges, to define pollutant loads, to assist in interpre-
tation of ambient data and to evaluate the efficiency of pollution controls.
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Air Quality
Air quality (criteria pollutants) is routinely monitored by WVAPCC at
11 locations in the Kanawha Valley air quality control region.43 This moni-
toring is necessary to assess compliance with ambient air standards and the
State Implementation Plan.
Prior to 1984, the most recent known monitoring of ambient levels of
volatile organic chemicals by a regulatory agency was done by an EPA con-
tractor in late 1977.28 Recognizing the need for ambient monitoring of
these volatile pollutants as a basis for assessing environmental impacts
and the need for source controls, WVAPCC obtained a GC/MS analytical instru-
ment and began such ambient monitoring in 1984.
Water Quality
Several types of water quality monitoring are routinely conducted by
the West Virginia Department of Natural Resources, Water Resources Divi-
sion. Monitoring of ambient water quality for parameters regulated by the
water quality standards is conducted at several stations on the Kanawha
River and its major tributaries. Monitoring frequencies vary by parameter
and range from monthly to annually. Biological monitoring is conducted at
several locations on the Kanawha River. Fish populations and benthic organ-
isms are periodically sampled at London, Marmet and Winfield Locks. Fish
samples are also obtained near Charleston and analyzed for contamination
along with fish from the three locks. A program of in-situ bioassays at
several river locations is planned for initiation soon. These bioassays
are needed to evaluate potential acute or chronic toxicity to aquatic life
predicted by past studies.33 36
The only routine monitoring of toxic organic pollutants in the river
is conducted by ORSANCO at a location downstream from Nitro and all chemi-
cal plants. The primary purpose of this monitor is to serve as an early
warning of any chemical spills in the Kanawha River drainage moving down-
stream into Ohio River drinking water supplies. Although these data are
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useful in evaluating both long and short-term chemical concentrations in
the lower river, the single monitoring location does not appear adequate to
fully assess ambient levels of toxic organic pollutants in the river. Two
modeling studies have indicated that significantly higher chemical concen-
trations than observed at the ORSANCO monitor location probably occur at
several upstream locations near major industrial wastewater discharges.33 36
Ambient monitoring of toxic organic pollutants at several river locations
(including the three biological monitoring stations at the locks) and under
several river flow conditions, including seasonal low flow, is needed to
assess the adequacy of NPDES permit limits, assess potential chronic toxi-
city problems and provide a basis for review of the adequacy of water qual-
ity standards.
The Department of Health monitors the quality of public drinking water
supplies. Chemical contamination of these surface supplies is not a prob-
lem and routine monitoring appears adequate.
ERA does not conduct routine ambient water quality monitoring in the
Kanawha Valley. Special studies are conducted as needed. A limited ambi-
ent monitoring study was conducted on the Kanawha River in June 1981 in
support of the Toxics Integration Project.33
DNR routinely conducts compliance monitoring at municipal and indus-
trial facilities which have wastewater discharges regulated by NPDES per-
mits. This monitoring normally includes sampling and analysis of effluents
for pollutants regulated by the permit. It may also include analysis for
other toxic pollutants not limited by the permit and an effluent bioassay
test may be run. NPDES permit holders are required to periodically sample
and analyze their effluents for regulated pollutants. Some permits also
include effluent bioassay test requirements. The monitoring by both DNR
and permit holders is used to assess compliance with permit requirements
and to define discharges of pollutants from each source. Monitoring results
are also the major basis for administrative or enforcement actions in cases
of noncompliance with permit requirements.
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EPA (Region III) routinely conducts compliance monitoring at a few of
the major NPDES permitted facilities each year. This monitoring is con-
ducted in an oversight role and supplements the ONR regular program.
Hazardous Wastes
There are two types of environmental monitoring being conducted in the
Kanawha Valley as part of hazardous waste control programs. The major
activity is associated with inactive hazardous waste disposal sites. As
discussed in more detail in a following section, under the authority of the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA
or "Superfund"), both EPA and DNR are conducting site investigations at
about 50 sites in the valley. These are typically conducted by contractors
(field investigation teams or FITs) although both EPA and DNR have site
investigation teams. Additional site investigations have recently been
conducted at seven locations as part of EPA's national investigation of
sites potentially contaminated with dioxin.
Environmental monitoring as part of a hazardous waste site investiga-
tion typically involves sampling and analysis of surface soils, leachate,
surface waters where present, any exposed hazardous wastes and any nearby
wells. Where appropriate, new monitoring wells may be installed and sam-
pled. Air emissions may also be sampled. The intent is to define the
extent of environmental contamination at each site and assess the degree of
hazard present.
Environmental monitoring data on inactive hazardous waste sites are
the primary basis for assessing the significance of the hazard present at
the site and for prioritizing remedial actions. Preliminary site investi-
gations have been completed at all but three sites in the valley. Detailed
site investigations including environmental monitoring are underway at a
number of potentially significant sites. Completion of these investigations
at an early date is needed to provide the basis for focusing remedial
actions on the sites with environmental contamination or hazards of the
most concern.
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Interim status standards (40 CFR Part 265), promulgated by EPA under
authority of RCRA, require that active hazardous waste management facilities
that have surface impoundments, landfills or other land disposal facilities
must install monitoring wells and monitor groundwater in the vicinity. At
least three facilities in the valley are required to conduct groundwater
monitoring.
SOURCE CONTROL PROGRAMS
Wastewater Discharges
The primary program for regulation of industrial and municipal waste-
water discharges is the National Pollutant Discharge Elimination System
(NPDES) permit program established by Section 402 of the Clean Water Act.
This is a joint Federal-State program. EPA is required to establish over-
all program guidance and regulations and develop and publish various guide-
lines. Permit program regulations have been published by EPA in 40 CFR
Parts 122 through 125. Effluent guidelines on which permits are based are
contained in 40 CFR Parts 400 to 460.
Administration of the NPDES permit program in West Virginia was dele-
gated by EPA to the Department of Natural Resources in May 1982. DNR has
promulgated their own regulations governing operation of the NPDES program.
DNR receives permit applications from dischargers, develops permit condi-
tions, issues the permits, monitors compliance with permit conditions, and
takes enforcement actions to achieve compliance when necessary.
EPA retains program overview. This is conducted by the Region III
office in Philadelphia. Region III conducts selected compliance monitoring
inspections and provides technical assistance to DNR. In some cases, EPA
can also initiate enforcement actions against dischargers to achieve
compliance.
At the national level, EPA is required to develop and promulgate regu-
lations (effluent guidelines) that specify what pollutants must be limited
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IX-10
for each type of industry and what volume of each pollutant may be
discharged. Similar effluent standards are promulgated for municipal
discharges.
EPA promulgated effluent guidelines for most industrial categories in
the mid-1970s. These guidelines gave limited attention to toxic substances
because analytical methods did not exist for many of them and little was
known of their presence in wastewaters or the environment.
As the result of a 1976 court settlement concerning a suit filed by
the Natural Resources Defense Council (NRDC) and the 1977 amendments to the
Clean Water Act, EPA was required to develop effluent guidelines for 34
industrial categories that gave special attention to 65 toxic pollutants.
This list of toxic pollutants was subsequently expanded to the 129 "prior-
ity pollutants" that include the toxic organic pollutants, pesticides and
heavy metals discussed throughout this report.
Development of effluent guidelines for priority pollutants proved to
be a difficult, complex and expensive task. As a result, promulgation of
guidelines for most industrial categories slipped several years behind the
original schedule. Final guidelines have been promulgated for most major
industry types but are still not available for the organic chemicals indus-
try that is of major importance in the Kanawha Valley.
EPA issued the initial NPDES permits to Kanawha Valley industries in
the mid-1970s based on the early effluent guidelines. Most permits had
few, if any, limits on toxic pollutants.
In May 1980, EPA revised its NPDES permit regulations to require most
industrial dischargers to submit data on priority pollutants in their efflu-
ents as part of their permit applications. EPA or DNR have now received
such data from most major industrial dischargers in the Kanawha Valley.
The Clean Water Act requires all industrial dischargers to achieve
effluent limitations for priority pollutants based on best available
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IX-11
technology (treatment or process control) (BAT) by July 1, 1984. The EPA
effluent guidelines recently promulgated or under development (organic chem-
icals) prescribe BAT for priority pollutants.
About 1980, as the initial permits began to expire, and in order to
allow industrial facilities adequate time to design and construct any needed
BAT control facilities, EPA Region III began to develop draft BAT permits
for major chemical facilities. Because effluent guidelines were not avail-
able, permit conditions were based on the best professional judgment (BPJ)
of the permit writer and available information as authorized for such cases
by Section 402(a)(l) of the Clean Water Act. These draft permits were com-
prehensive and included numerical limitations on specific toxic pollutants,
effluent bioassay monitoring requirements and best management practices
(BMP) conditions designed to minimize discharges of toxic pollutants from
ancillary activities such as spills and leaks, raw material and product
storage and solid and hazardous waste disposal.
The BPJ draft permits were initially opposed by several major indus-
trial facilities. The new permit regulations were unfamiliar and imposed
substantially increased monitoring, analysis and reporting requirements on
the permittee. Key provisions of the permit regulations were being liti-
gated at the national level. Valley industries had a history of requesting
evidentiary hearings to oppose specific permit limits. Nevertheless, EPA
Region III continued negotiations with major industries. Several unresolved
evidentiary hearings were settled. In 1981, comprehensive BAT permits were
issued by EPA to Diamond Shamrock, duPont and the Union Carbide facility at
Institute. NEIC provided assistance to Region III in the development of a
comprehensive permit that was issued to Fike Chemical as part of the settle-
ment of litigation against that facility.
By mid-1982, Region III had developed comprehensive draft BAT permits
for Monsanto and (with NEIC technical assistance) for the FMC facility at
Nitro. Extended negotiations were held with both companies but agreement
on permit conditions had not been reached when the NPOES permit program was
delegated to DNR in May 1982.
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IX-12
DNR has elected not to issue any BPJ permits to the remaining major
chemical plants in the valley. Their policy is to await the promulgation
of final effluent guidelines for the organic chemicals industry. These
guidelines were scheduled to be promulgated in March 1984. It now appears
that there may be substantial delays in final promulgation. It is likely
that these guidelines will be extensively litigated, extending indefinitely
their effective date. Also, it is probable that the guidelines will apply
to only part of the wastewater discharges from the plants remaining to be
permitted. BPJ permit procedures will thus need to be used for these per-
mits regardless of effluent guideline status.
Litigation on the permit regulations has been settled and regulation
revisions promulgated to implement the settlement. This is expected to
substantially reduce the incidence of evidentiary hearing requests and
improve acceptance of new permit conditions.
Comprehensive BAT permits have been issued to about half of the major
chemical plants in the valley. Present permits for the other chemical
plants do not provide comprehensive controls on toxic pollutants. This
produces major differences in regulatory requirements between plants with
and without comprehensive permits and does not achieve adequate overall
control of toxic pollutants from industrial pollutants. There is thus a
major need to proceed with the issue of BAT permits to all major facilities.
EPA has substantial technical information from which BAT permit limits
can be developed and can provide technical assistance to DNR if requested.
Draft permits have already been nearly completed for Monsanto and FMC -
Nitro.
Compliance monitoring data, self-monitoring data, spill reports, the
ORSANCO monitoring data and effluent bioassays all indicate that all per-
mits for chemical plants should contain comprehensive BMP provisions to
minimize spills and leaks of toxic pollutants. Effluent bioassay require-
ments are also needed.
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IX-13
Monitoring data and spill reports also indicate the need to evaluate
BMP plans where they have been required to see if they have been adequate
in preventing spills or if modification is needed. Also, moderate to high
levels of toxicity have been detected by effluent bioassays at several facil-
ities. It was not clear from file information whether actions are being
taken to reduce effluent toxicity in these cases.
Air Emissions
Emissions of criteria pollutants such as sulfur dioxide and suspended
particulates are regulated by State Implementation Plans (SIPs) prepared by
the WVAPCC and approved by EPA. The SIP specifies control measures for
existing and new stationary sources of emissions of criteria pollutants.
There is no Federal air permit program analagous to the NPDES permit pro-
gram for water.
Because there is currently no regulatory program prescribed by the
Clean Air Act that can be effectively applied to control of many of the
volatile organic chemicals emitted from valley sources, the WVAPCC has begun
a multi-activity program to address these emissions. The first step is the
updating of the 1977 hydrocarbons emission inventory. All major chemical
industry facilities and all powerplants (thermal electric and industrial
plant) have been requested to submit an inventory of process and combustion
emissions based on 1981 data. This inventory covers all emissions of vola-
tile organic chemicals from process point sources such as stacks and emis-
sions of numerous other pollutants.
The combustion emissions data are basically complete and are expected
to be finalized by the WVAPCC in 1984. Process emissions data are incom-
plete for two major facilities. A complete process emissions inventory
will be available from WVAPCC in 1984.
Fugitive emissions from various diffuse sources such as valve leaks
can be significant sources of volatile organic chemicals. The WVAPCC began
requesting fugitive emissions data from valley industries about October
1983. These data will not be available until mid-1984.
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As recognized by WVAPCC, there is a major need for this complete
inventory of process and fugitive emissions as a basis for developing an
emissions control program for volatile organics.
Active Hazardous Waste Management Facilities
EPA has promulgated regulations under RCRA that specify what chemicals
and industrial wastes are hazardous wastes (40 CFR Part 261) and establish
operating procedures for waste generators and transporters (40 CFR Parts
262 and 263). Regulations have also been promulgated (40 CFR Part 265)
that specify procedures that facilities that store, treat or dispose of
hazardous wastes must follow in the interim period until they are issued a
RCRA permit. These "interim status standards" specify general operating
procedures and minimum facility standards. West Virginia has promulgated
similar regulations and is now enforcing the interim status standards under
an interim authorization from EPA.
All facilities that store, treat or dispose of RCRA hazardous wastes
(TSD facilities) are required to apply for a RCRA permit. This is a two-
step operation. All existing TSD facilities have submitted a simple permit
application (Part A) that defines their activities in general terms. Upon
EPA request, the facility must submit a much more detailed permit applica-
tion (Part B) within 6 months of the request. A RCRA permit is then pre-
pared and issued.
West Virginia (DNR) has also received interim authorization from EPA
to administer part of the RCRA permit program. This includes authority to
issue permits to storage and treatment facilities including incinerators
(Phase IIA and B). EPA is currently administering the permit program for
land treatment and disposal. West Virginia is seeking full program
authorization.
Administration of the RCRA program will involve several State agen-
cies. DNR will be the lead agency and issue permits. Basic permitting
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IX-15
regulations are in place including permitting standards for storage, treat-
ment and disposal facilities. The WVAPCC will regulate air emissions from
hazardous waste management facilities. Regulations for incinerators are in
place. Department of Health, Department of Highways, the Public Services
Commission, Water Resources Board (groundwater standards for disposal facil-
ities) and the Office of Oil and Gas also have some RCRA program responsi-
bilities.
In the interim, until full authorization is received from EPA, DNR is
conducting interim status inspections under interim Phase I authorization
and State authority. Administrative violations result in the issuance of a
Notice of Deficiency to the facility. This is the simplest enforcement
response. If technical violations or a hazardous situation is detected, an
Administrative Order is issued requiring the facility to correct the problem
in a specified time. For example, a State Administrative Order was used
to correct a hazardous situation at Markay Chemical in St. Albans. If an
Administrative Order is not complied with, litigation may then be pursued
to secure compliance and fines may be assessed.
Previously State or Federal agencies did not have a hazardous waste
site permit program. In the 1960s and early 1970s, disposal of hazardous
wastes was covered by an industrial waste permit issued by DNR. Because of
the general lack of knowledge nationally on adequate hazardous waste dis-
posal practices, permit requirements were not very stringent. Disposal
practices were inadequate and some of these sites now pose an environmental
hazard.
EPA and DNR have promulgated permit standards for all types of hazard-
ous waste management facilities. EPA Region III has issued a RCRA permit
to a new incinerator to be constructed at the Union Carbide facility in
Institute. Part B applications have been called in by Region III and DNR
on several major facilities. Major industrial facilities that were assigned
high hazardous waste management ratings by this study are candidates for
priority issuance of RCRA permits. If not already called in, Part B appli-
cations should be called in for these priority facilities to expedite permit
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IX-16
processing. Final RCRA permits are needed for all major hazardous waste
management facilities to minimize releases of toxic substances to the
environment.
Inactive Hazardous Waste Disposal Sites
As part of a major national effort the past 5 years, a major EPA-State
activity has been directed toward the identification of disposal sites poten-
tially containing hazardous wastes. These sites were identified by a vari-
ety of means. Some of the sites had industrial waste or NPDES permits from
DNR. A Congressional inquiry of 50 major national chemical corporations
produced a list of disposal sites known as the Eckhardt list. The 1982 DNR
hazardous waste survey identified several previously unknown sites. Several
additional sites were identified by firms notifying EPA in 1981 of past
disposal activities, as required by Section 103(c) of CERCLA.
Activity to locate additional disposal sites is continuing. EPA's
Environmental Photographic Interpretation Center in Vint Hill, Virginia,
recently completed a review of historic aerial photographs of a major por-
tion of the study area.57 Photographs from 1938 to 1977 were examined for
potential disposal sites. A total of 92 potential sites were identified.
Many of these correspond to known disposal sites but others may warrant
further investigation.
Inactive disposal sites are not subject to the provisions of RCRA but
are addressed by CERCLA. The National Contingency Plan58 sets forth
detailed procedures to be followed by EPA in investigating an inactive dis-
posal site and in seeking appropriate remedial action. In general, when a
site has been discovered, a preliminary assessment is made to evaluate the
extent of the hazard associated with a site. Where the hazard warrants
such action, immediate removal of the hazard may be undertaken. Where a
hazard is less imminent but still substantial, a planned removal may be
undertaken. This is removal of the hazard during a relative short period
of time but not immediately upon discovery. CERCLA encourages voluntary
remedial actions by generators, site owners/operators or other private par-
ties in both cases.
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IX-17
Where the site poses a long-term hazard to the health or environment,
remedial actions to remove or contain the contamination may be appropriate.
Again, CERCLA encourages volunteer remedial actions. Remedial actions may
also be taken by EPA using Superfund monies but only if the site has been
listed on the National Priority List. Such actions require notification of
responsible parties (generators of disposed hazardous wastes, site owners
and/or operators) who are given the opportunity to take remedial actions.
If the responsible parties refuse, then EPA may proceed with a remedial
action. Litigation will then be pursued to recover cleanup costs from re-
sponsible parties. Such remedial actions require matching funds from the
State (usually 10%). Remedial actions also require detailed site investi-
gations to document the extent of the problem and the subsequent develop-
ment of a remedial action plan.
States may undertake actions under CERCLA based on a cooperative agree-
ment or contract with EPA. In West Virginia, ONR has taken several CERCLA
actions. In the study area, an immediate removal action was conducted at
the Poca Drum site to remove 75 drums of hazardous material illegally dumped
in a strip mine.
A major problem exists for disposal sites that pose substantial long-
term threats to the environment that warrant remedial actions but are not
on the National Priority List. If the sites do not warrant immediate or
planned removal actions or voluntary cleanup is not done by the responsible
parties, no effective action can be taken at this time under CERCLA. In
the study area, there are probably at least 10 sites that may warrant some
form of remedial actions. Only one (Fike Chemical) has been determined to
have a high enough hazard to place it on the National Priority List. The
other sites cannot progress beyond detailed site investigations at this
time.
There have been several other obstacles to completion of remedial
actions at appropriate sites. State matching funds have not been available.
A State response fund has now been enacted and will be available in 1985.
Detailed investigations have not been completed at about half the sites and
preliminary assessments have not been completed at three sites.
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IX-18
West Virginia State statutes provide an alternate approach to CERCLA.
Where preliminary assessments indicate a potential problem, DNR may issue
an Administrative Order requiring the site owner/operator to conduct a site
investigation and monitoring to document the extent of site and groundwater
contamination. Where the results of the investigation document a major
problem, DNR may issue an order requiring a remedial action. Four remedial
orders have been issued.
There is a definite need to complete detailed investigations under
CERCLA at all sites with potentially significant environmental problems.
This may document additional problem sites that qualify for Superfund prior-
ity listing. It also allows prioritization of remedial actions at the other
sites.
Where a significant hazard exists but it does not appear the site will
make the National Priority List, appropriate actions under State legislation
should be pursued to secure early remedial actions. To conserve available
State and Superfund monies, voluntary remedial actions should be negotiated
where possible.
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REFERENCES
1. West Virginia Administrative Regulations, State Water Resources Board;
Chapter 20, Article 5, Code of West Virginia; Effective June 7, 1977;
amended July 26, 1981; April 11, 1984.
2. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, Drinking Water Program Files.
3. United States Environmental Protection Agency, National Field Investi-
gations Center, Cincinnati, Ohio, July 1972. Report of Industrial
Investigations, Major Industrial Facilities, Kanawha Valley, West
Virginia.
4. United States Environmental Protection Agency, National Field Investi-
gations Center, Cincinnati, Ohio, July 1972. Report of Industrial
Investigations, Minor Industrial Facilities, Kanawha Valley, West
Virginia.
5. United States Environmental Protection Agency, National Enforcement
Investigations Center, Denver, Colorado, 1975. Archival Files, Labor-
atory Support.
6. United States Environmental Protection Agency, Environmental Sciences
Research Laboratory, Reseach Triangle Park, North Carolina, June 1977,
The Measurement of Carcinogenic Vapors in Ambient Atmospheres,
EPA-600/7-77-055.
7. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, NPDES Permit Program Files.
8. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, Air Program Files.
9. Pellizzari, E. D. , January 1976, Identification and Estimation of
N-Nitrosodimethylamine and Other Pollutants in the Baltimore, Maryland
and Kanawha Valley Areas. Progress Report, prepared by Research Tri-
angle Institute. EPA Contract 68-02-1228.
10. United Stated Environmental Protection Agency, Office of Water Supply
Cincinnati, Ohio, Memorandum Report, Carbon Tetrachloride Survey,
March 31, 1977.
11. James M. Montgomery, Consulting Engineers, Inc., May 1977, Reston,
Virginia. Waste-Zoads and Waste Treatment and Management of Major
Industrial Discharges to the Kanawha River.
12. United States Environmental Protection Agency, National Enforcement
Investigations Center, Denver, Colorado, February 1978, A Summary of
Toxic Substances Information for the Kanawha Valley, West Virginia,
EPA-330/1-77-013.
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REFERENCES (cont.)
13. United States Environmental Protection Agency, National Enforcement
Investigations Center, Denver, Colorado, March 1977, Carbon Tetra-
chloride Spill Evaluation, FMC Corporation, South Charleston, West
Virginia, EPA-330/2-77-008.
14. United States Environmental Protection Agency, National Enforcement
Investigations Center, Denver, Colorado, June 1977, Evaluation of
Carbon Tetrachloride Discharges at FMC Corporation, South Charleston
East Plant, South Charleston, West Virginia, EPA-330/2-77-013.
15. United States Environmental Protection Agency, National Enforcement
Investigations Center, Denver, Colorado, February 1978, Compliance
Monitoring and Wastewater Characterization of Fike Chemicals, Inc.,
Coastal Tank Lines, Inc. and Cooperative Sewage Treatment, Inc., Nitro,
West Virginia, EPA-330/2-78-002.
16. United States Environmental Protection Agency, National Enforcement
Investigation Center, Denver, Colorado, June 1980, Hazardous Site
Inspection, Fike Chemicals, Inc., flitro, West Virginia, EPA-330/2-80-022.
17. United States Environmental Protection Agency, Washington, D. C., Sep-
tember 1983, National Priorities List promulgated under authority of
the Comprehensive Environmental Response, Compensation and Liability
Act.
18. United States Environmental Protection Agency, National Enforcement
Investigations Center, 1977, Reconnaissance Inspection Report - Chemi-
cal Formulators, Inc., Nitro, Vest Virginia.
19. United States Environmental Protection Agency, National Enforcement
Investigations Center, 1977, Reconnaissance Inspection Report, FWC
Corporation, Nitro, West Virginia.
20. United States Environmental Protection Agency, National Enforcement
Investigations Center, 1977, Reconnaissance Inspection Report, Monsanto
Company, Nitro, West Virginia.
21. United States Environmental Protection Agency, National Enforcement
Investigations Center, 1977, Reconnaissance Inspection Report, DuPont
Company, Belle, West Virginia.
22. United States Environmental Protection Agency, National Enforcement
Investigations Center, Denver, Colorado, June 1980, Hazardous Site
Inspection, Chemical Formulators, Inc., Nitro, West Virginia,
EPA-330/2-80-023.
23. United States Environmental Protection Agency, National Enforcement
Investigations Center, Denver, Colorado, March 1979, Compliance Evalua-
tion and Wastewater Characterization, Union Carbide Company, South
Charleston, West Virginia, EPA -330/2-79-013.
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REFERENCES (cont.)
24. United States Environmental Protection Agency, National Enforcement
Investigations Center, Denver, Colorado, May 1979, Compliance Evalua-
tion and Wastewater Characterization, Union Carbide Company, Institute,
West Virginia, EPA-330/2-79-014A.
25. United States Environmental Protection Agency, National Enforcement
Investigations Center, Denver, Colorado, March 1979, Compliance Evalua-
tion and Wastewater Characterization, South Charleston Sewage Treatment
Company, South Charleston, West Virginia, EPA-330/2-79-015.
26. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, Air Program Files.
27. West Virginia Air Pollution Control Commission, Charleston, West Vir-
ginia, 1981 Emissions Inventory (draft), 1983.
28. Pellizzari, Edo D. , June 1978, Analysis of Organic Air Pollutants in
the Kanawha Valley, West Virginia and the Shenandoah Valley, Virginia,
Research Triangle Intitute, Research Triangle Park, North Carolina.
29. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, NPDES Permit Application Files.
30.. West Virginia Department of Natural Resources, Charleston, West Vir-
ginia, NPDES Permit Program Files.
31. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, 1983, List of Facilities Notifying EPA of Hazardous Waste
Management Activities.
32. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, RCRA Permit Program Files.
33. Arthur D. Little, Inc., and Versar, Inc. , September 1981. Final Draft
Report, An Integrated Geographic Study of Potential Toxic Stubstance
Control Stragegies in the Kanawha River Valley, West Virginia, EPA
Contracts 68-01-6160 and 68-01-6271. United States Environmental Pro-
tection Agency, Office of Policy and Resource Management, Washington,
D. C.
34. United States Environmental Protection Agency, Region III, Central
Regional Laboratory, Annapolis, Maryland, August 1981, Laboratory
Report - GC/MS Analyses for the Kanawha River Toxics Integration Geo-
graphic Study.
35. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, July 1981, Region III Pilot Study, Kanawha Valley, West
Virginia.
36. Dal ton, Dal ton, Newport, January 1983, Draft Report, Detailed Water
Quality Analysis for the Organic Chemicals and Plastics Industry on
the Kanawha River, EPA Contract 68-01-6195, United States Environmental
Protection Agency, Office of Water Regulations and Standards, Washing-
ton, D. C.
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REFERENCES (cont.)
37. West Virginia Department of Natural Resources, Divison of Water
Resources, Charleston, West Virginia, July 1982, West Virginia Haz-
ardous Waste Survey.
38. United States Environmental Protecton Agency, National Enforcement
Investigations Center, Denver, Colorado, NPDES Permit Program Files,
1982.
39. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, Uncontrolled Hazardous Waste Site Program Files.
40. Hughart, Joseph L. , Masters Thesis, Hydrologic Investigations of Haz-
ardous Waste Landfills near South Charleston, West Virginia, Ohio
University, Columbus, Ohio, March 1982.
41. United States Environmental Protection Agency, Region III, Philadelphia,
Pennsylvania, Dioxin Program Files.
42. Monsanto Company, Nitro, West Virginia, October 1983, press release
concerning dioxin contamination of Nitro plant site.
43. West Virginia Air Pollution Control Commission, Charleston, West
Virginia, 1982 Annual Report.
44. West Virginia Department of Health, Office of Health Planning and Eval-
uation, Charleston, West Virginia, January 1982, North Charleston
Cancer Mortality, 1970-1979.
45. Albert, Daniel M. , M.D., et. al., Increased Incidence of Choroidal
Malignant Melanoma Occurring in a Single Population of Chemical Workers,
Harvard Medical School and the Children's Hospital Medical Center,
Boston, Massachusetts, and National Institute for Occupational Safety
and Health, Cincinnati, Ohio, 1982.
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48. United States Environmental Protection Agency, Region III, Philadelphia,
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49. United States Food and Drug Administration, Washington, D. C. , Regu-
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50. United States Environmental Protection Agency, Region III, Emergency
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REFERENCES (cont.)
51. West Virginia Department of Health, Charleston, West Virginia, October
1983. Comparison of the 1977 Emissions Inventory with Preliminary
1981 Emissions Data for Selected Industrial Facilities.
52. West Virginia 1980-1981 Manufacturing Directory.
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54. United States Environmental Protection Agency, Office of Water Enforce-
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55. United States Environmental Protection Agency, Office of Solid Waste,
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56. Pellot, James H. and Curtis, William J; "Jarrett Branch Industrial
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57. United Stated Environmental Protection Agency, Environmental Photo-
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58. United States Environmental Protection Agency, Office of Solid Waste
and Emergency Response, Washington, D. C., July 1982, National Con-
tingency Plan, 47 FR 31180, July 16, 1982.
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