NCD003446721_19880310_Celeanse Corporation - Shelby Fiber_FRBCERCLA ROD_Draft Enforecement Record of Decision-OCR

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DECLARATION FOR THE ENFORCEMENT RECORD OF DECISION
SITE: CELANESE FIBERS OPERATIONS
SHELBY, NORTH CAROLINA DRAFT
Statement.'?.!. Purpose:
This decision document represents the selected remedial action for this site developed in accordance with CERCLA as amende .. d., by SARA, and to the extent practicable, the National Contingency Plan. ,i t\}e State of North Carolina ~ concurs with the selected remedy. ', __ /
Statement of Basis
This decision is based upon the administrative record for the Celanese Fibers Operations Site. The attached index identifies the items which comprise the administrative recos~ upon which the selection of a remedial action is based.
Description of Selected Remedy:
*This is Operable Unit One of the Remedial Actions to be undertaken at the Site. It is a control measure to mitigate the threat of off-site migration (via groundwater) of contamination by organic compounds. The FS for the contaminant source control is in progress.
*Groundwater Contamination
Installation of extraction wells into bedrock at the perimeter of the site.
Installation of shallow extraction wells directly downgradient of source area.
Pumping of contaminated water from interior wells to common holding tank then to the air stripping tower.
All contaminated water transported from the air stripping tower to the biological treatment system.
Water requiring additional treatment pumped to carbon adsorption filtration unit.
All water is to be discharged to the existing wastewater treatment system as long as current NPDES permit limitations are not violated.
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Declaration
The selected remedy is protective of human health and the environment, attains Federal and State requirements that are applicable or relevant and appropriate, and is cost-effective. This remedy satisfies the preference for treatment that reduces toxicity, mobility, or volume as a principal element. Finally, it is determined that this remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable.
Date Lee A. DeHihns, III
Acting Regional Administrator
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DRAFT
ENFORCEMENT RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CELANESE FIBERS OPERATIONS SITE
SHELBY, NORTH CAROLINA
Prepared By:
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
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1.0 INTRODUCTION
2.0 SITE HISTORY
3.0 GROUNDWATER CONTAMINANTS
4.0 DISCUSSION OF ARARS
TABLE OF CONTENTS
5.0 SUMMARY OF PUBLIC HEALTH EVALUATION
6.0 ENFORCEMENT ANALYSIS
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7.0 ALTERNATIVE EVALUATION
8.Q RECOMMENDED ALTERNATIVE
9.0 COMMUNITY RELATIONS HISTORY
PAGE NUMBER
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1.0 INTRODUCTION
~-.:i,,, ..• ;:-;.::.-;! "·
lf.. ENFORCEMENT RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CELANESE FIBERS OPERATIONS. SITE
SHELBY, CLEVELAND COUNTY, NORTH CAROLINA
,·-,.-.-.
The Celanese Fibers Operations Site was proposed for inclusion on the National Priorities List (NPL) in October 1984. A Remedial Investigation (RI) and Feasibility Study (FS) have been conducted at the site. Due to unusual waste characteristics at the site, more information will be required in order to select a permanent remedy for the contaminated soils and the source material. As a result, this site has been separated into Operable Units. Operable Unit l, Groundwater Remediation, will be addressed now. A remedial alternative for the source and soils remediation will be selected in approximately one year.
The RI report for the whole site ,1a·s finalized and presented ··to·· the public on July 21, 1987 in a public meeting. The FS, which develops and examines alternatives for remediation of the site was issued in draft form to the public on January 19, 1988. A public meeting to present the results of the FS was held on February 3, 1988 in Shelby, North Carolina.
This Record of Decision has been prepared to summarize the remedial alternative; selection process and to present the selected remedial alternative for the · groundwater at the site.
Site Location and Description
The Celanese Fibers Operations (CFO) site is a 450-acre property occupied by a polyester raw-material production facility (Figure 1-1). The site is located in south-central Cleveland County on North Carolina Highway 198. It is approximately one mile north of Earl, North Carolina and six miles south of Shelby. The nearest major city is Charlotte, North Carolina, 35 miles east of Shelby.
The plant facilities consist of the plant production area, area, former waste disposal areas, land farm area, and the farm areas to the south of the main plant.£:¥· garE I 25.
wastewater treatment
recreations and tree
The majority of the land surface reflects cultural modification by construction, and by cutting and filling. The original soil profile has probably been either truncated or covered across much· of the site, and was never conclusively identified as undisturbed during the field investigations of the RI. The plant production area is predominantly covered with buildings and paved or gravelled areas. However, to the east, toward the waste water treatment area, the site becomes more open, with the majority of the land covered by impoundments, with grass and access roads in between. The sludge land farm is north of the plant production area and overgrown with coarse grasses. The recreation area and tree farm to the south have no facilities related to the plant processes.
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SCALE ( FEET)
0 4000
2000
I ~-R{PRODUCED FROM BLACKSBURG 7 1/ 2 MIN, QUADRANGLE (1971) .... __ ...:,_;,__;r-----. _ _;_ _______________________ ,--:------------,
FIGURE 1-1
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SOIL & MATERIAL ENGINEERS INC. SITE LOCATION MAP I CFO/ SHELBY, N.C. I ~ S&ME JOB NO.1175-85-0S0A
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I•.2. Site History
Fiber Industries, Inc., a joint venture of Celanese Corporation and Imperial Chemicals, Inc., was the original owner of the plant and operated it from 1960 until 1983 when the Celanese Corporation bought out the facility. Celanese now operates it as Celanese Fibers Operations (CFO).
Operations at the Shelby facility began in April of 1960. Manufacturing operations included the production of polyester polymer chip and filament yarn. The principal chemicals involved in polymer production are dimethyl terephthalate and ethylene glycol. Other small quantity additives include titanium dioxide and antimony.
The CFO waste treatment plant was constructed in phases concurrent with the manufacturing plant. During part of the early years, chemical wastes were discharged through a ditch draining in a generally easterly direction. The ditch began near the western edge of what is now known as the former drum storage area, and travelled east to the ·northeast corner of the pr~seuc· emergency spill ponds. The ditch was replaced with pipes when the waste treatmeµt plant became fully operational in the mid-1960's. In 1973, the plant was expanded with the addition of a polishing pond, two emergency spill ponds, and an additional aeration basin. The treated effluent from the waste treatment plant is piped to a discharge point on Buffalo Creek.
The concrete-lined portions of the waste treatment facility-include a chromate reduction pond which is no longer in use, a digester, three equalization basins, two aeration basins, and two clarifiers •. The unlined plant units include the three polishing ponds,·two sludge ponds, and two emergency spill ponds.
In addition to the discharge from the wastewater treatment plant, the Celanese facility also discharges alum treated bandcaster water directly to Buffalo Creek. Bandcaster water is used to cook the polymer products. Both of these discharges are covered by permits from the North Carolina Department of Natural Resources.
Several areas around the plant have been used for waste disposal. Normal plant wastes (primarily polyester and miscellaneous trash) were disposed of in old burning pits located just north of the aeration basins. North and east of the burning pits, Glycol Recovery Unit (GRU) sludge was buried during the early 1960's in trenches. West of the GRU sludge burial area is a former drum storage and staging area. Solutions which failed to polymerize were stored here during the early 1960's. The drums were removed in the mid-1960's and the storage area was backfilled. Two soak-away ponds located west of the existing aeration basins were used to contain treated sanitary sewage during the period from 1960 to 1969.
Four areas of buried waste are located to the north and outside of the main plant perimeter fence. The polymer and fiber landfill contains primarily non-hazardous inert materials such as excavation spoil, polymer, and waste yarn. The construction debris landfill contains items such as old cinder
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blocks and steel strapping bands. Approximately 21 acres of the northwest quadrant of the property have been issued permits by the. North Carolina __..?" Department of Natural Resources for sludge disposal since 1978.
In the period from 1970 to 1978, approximately 2000 to 3000 drums of waste chemicals and solvents, including lab packs, were stored temporarily in the area known as the drum storage area near the former burning pits. All drums were removed from the area by 1978 and sent to outside disposal facilities.
Investigation of the Celanese Fibers Operations Site began in October 1981 when CFO contracted with the firm Soil & Material Engineers, Inc. (S&ME) to install 23 groundwater monitor wells •. In conjunction with the groundwater monitor well installation program, SME also conducted a hydrogeologic evaluation. Subsequently, CFO initiated a groundwater sampling and analysis program under the supervision of Davis & Floyd Laboratories, Inc.
Soil & Material Engineers, Inc. also conducted an electromagnetic survey and excavated test pits at the site.
In October 1984, CFO was proposed for EPA's National Priorities List. Also in October 1984, there were a series of meetings between the U.S. Environmental Protection Agency (EPA) and CFO to discuss the preparation of a Work Plan for a Remedial Investigation (RI) and Feasibility Study (FS) by CFO's contractor, S&ME. Concurrent with this, EPA's contractor, Camp Dresser & McKee, Inc.(CDM) ,· prepared a report that .included a review of the data collected during previous ! site investigations and identified information deficiencies and data gaps to provide a basis for development of Remedial· Investigation activities. These events resulted in the submission of. a draft Work Plan by S&ME, on behalf of CFO, with a final Work Plan submitted to EPA in November 1985.
3.0 Groundwater Contaminants
On-Site Monitor Wells
The monitor wells (Figure 3-1) existing at the start of the RI were sampled as the initial field operation (Phase I and IA). Select monitor wells from this group and the monitor wells installed during the RI were sampled during the Phase II and !IA events. The Phase II and !IA wells were generally in background locations and near the site'£ perimeter to provide data on the groundwater quality as it entered and exited the site.
Analyses of these samples showed varying results between the two sampling periods, with variations' occurring in both compounds identified and concentrations of the same compound in one well on separate dates. Due to the variation in data, and the location of wells selected for analysis (typically on or near the plant's perimeter), mappable trends in groundwater quality were not identified. However, the data show that compounds similar to those identified in the probable source area were detected in the groundwater. These include phthalates (concentrations to 380 ug/1), ketones (concentrations to 2100 ug/1), benzene (concentrations to 60 ug/1) and other non-phenolic aromatic compounds, and members of the chlorinated ··ethene/ ethane groups
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Figure 3-1
PROPERTY
LINE
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LECWO
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• ROCX MONITOR WELLS •.
LETTERS REPRESENT WELL DESlGNATIONS
FIGURE
MONITOR WEI.I.
LOCATION MN'
CFO / SHELBY. N.C.
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.-1 LAKE MURRAY PLASTICS, INC.
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19 BOB DOVER
-· 21 B. OF ED, NO, 3 SCHOOL
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79 JAMES ROBERT ELLIOTT 80 LARRY STEIN
81 JACKIE LAMBERT
82 CHILDREN'S HOME 100 BESS W, LAVENDER
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B. OF ED. NO. 3 SCHOOL
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(concentrations to 90 ug/1). Of these groupings, members of the phthalate and ketone groups were measured more frequently and at higher concentrations.
Examination of the groundwater quality data shows that the deeper wells in the nests frequently have the higher concentration of organic compounds, suggesting introduction of the compounds to the groundwater in a recha~ge ZO£_e or through/-~~=---the relic· fracture system in the saprolite. Figure53-1A§h~w; the locations of on and off-site monitor wells used in this analysis. Table 3-1 summarizes the groundwater quality data.
Monitor wells in the waste-water treatment plant area and the western terrace of the lawn, however, generally have higher concentrations of contaminants in the shallow wells. This is apparently due to the wells' locations within or near the probable source areas. Groundwater quality data for monitor wells J, CC, O, and K within the probable source area most clearly indicates this occurrence.
Elevated chromium levels were reported at several on-site monitor wells during-the Phase II and IIA sampling events. It appears that plant operations have contributed to the chromium potential, however, naturally occurring chromium in the soil and rock are also possible sources.
Groundwater contamination is predominantly in the area underlying the western
' terrace of the lawn and wastewater treatment plant based on the analytical · sampling results. However, there are volatiles, semi-volatiles and metals which! appear to trend from this area to the south-southeast toward monitor well nest T, and are reported at other areas on certain sampling events.
Off-Site Monitor Wells and Supply Wells
Groundwater quality was measured at 19 off-site locations shown on Figure 3-2, during the Phase I and IA groundwater sampling episodes. Concentrations of volatile organic compounds (VOCs) were measured in seven of the off-site wells during the Phase II groundwater sampling episodes.
During Phase I sampling, phthalate compounds were detected in eleven of the off-site wells at concentrations typically ranging between 10 and 40 ug/1. Exceptions were the Hopson and Tom wells which reported di-N-butyl phthalate at 83 ug/1 and bis(2-ethylhexyl) phthalate at 440 ug/1, respectively. None of the phthalate compounds detected exceeded EPA water quality crit.eria.
Comparison of Volatile Organic Compound (VOC) analysis for both sampling episodes showed inconsistencies in both detected compounds and concentrations. Phase I detected Hazardous Substance List (HSL) VOCs in 11 of the 19 wells sampled at concentrations generally less than 80 ug/1. Exceptions were noted at the Dover well where methylene chloride and acetone were reported at 680 ug/1 and 111 ug/1, respectively, and at the Long well where methylene chloride was reported at 967 ug/1. Phase II sampling consisted of re-sampling seven of the wells showing higher concentrations of VOCs. The phase II sampling detected VOCs in four of the seven wells in concentrations ranging from 5 to 14 ug/1. With the exception of James Elliott's well, which consistently detected trichloroethene. (TCE), no HSL volatile organic compounds were detected during Phase II above proposed or existing standards.
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4.0 Discussion of ARARs
Safe Drinking Water Act Maximum Contaminant Levels (MCLs) are the ARARs for groundwater at the federal level. In a project meeting April 16, 1987, EPA indicated they would probably defer to state criteria when more stringent than federal. North Carolina is presently amending their administrative code which establishes contaminant levels. In groundwater and expects the amendments to go to the Environmental Management Commission in December, 1987 for approval. These amendments establish more stringent criteria for some compounds with federal MCLs and add 46 additional compounds. For the purposes of this document, the proposed North Carolina criteria are considered the ARARs for groundwater. In discussions with personnel of the North Carolina Division of Environmental Management, they have indicated that specific requests may be needed for compounds for which standards have not been set.
Comparison of Groundwater to ARARs
The water quality standards for North Carolina groundwater were adopted from the Environmental Protection Agency Standards.
The groundwater quality documented during the RI indicated that the following parameters from Table 2-2 exceeded the standard in at least one monitor well during sampling Phase II or IIA.
Substances
* 1,1-dichloroethene
* 1,1-dichloroethane
* trans-1,2-dichlorothene
* benzene
* methylene chloride
* ·vinyl chloride
* chloroform
* chlorobenzene
* carbon tetrachloride
Substances
0 phenols
0 tetrachoroethylene
0 chlordane
0 chromium
0 barium
0 iron
0 manganese
0 nickel
0 selenium
0 chloromethane
Total No. of Occurrences Above!
Existing or Proposed· Standards
1
2
1
10
17
1
9
5
2
Total No. of Occurrences Above
Existing or Proposed Standards
2
1
2
40
2
4
4
13
1
2
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The majority of the compounds, detected during the RI above the standard, occurred in wells located in the vicinity of the wastewater treatment area, predominantly in monitor well nest CC, and in the monitor well nest at location T south southeast of this area.
5.0 Summary of Public Health Evaluation
A suite of indicator parameters was chosen, according to the guidelines put forth in the Superfund Public Health Evaluation Manual (EPA, 1986), for toxological interpretations and review purposes. Generally, this process directs the selection of chemicals which best represent the hazards associated with the site based on concentration in the environmental medium of concern and a relative toxicity constant. Application of this process, which is discussed in detail in the.Public Health Assessment in Appendix A of the FS report, resulted in the selection of benzene, trichloroethylene (TCE), bis(2-ethylhexyl)_p_hthalate, lead, and chromium as the indicator chemicals. These were -J;'v·eiope'ci· by consideiing .th~ p~imary routes of exposure as groundwater and contact with surface and near surface soils.
Several assumptions were made in performing the health evaluation. It was assumed that chemicals present at the site could be transported off-site in groundwater and be consumed by persons within a 1-mile radius of the site. Further, it was assumed that off-site groundwater concentrations of indicator chemicals would equal the mean concentrations present at the site. . !
. . A comparison of the total daily indicator chemical intakes for an adult and child was made by assuming a daily water ingestion of; 2 liters/day for adults and 1 liter/day for children. With the exception of bis(2-ethylhexyl) · phthalate, this resulted in.the estimated total daily intakes of indicator chemicals exceeding that allowed by ARARs for both children and adults.
The greatest non-carcinogenic health risks associated with potential indicator chemical exposure are due to ingestion of lead. In particular, young children (less than 6 years old) may be very sensitive to the neurotoxic effects of lead and should be considered the receptor population at greatest risk of developing lead intoxication (EPA, 1984).
The non-carcinogenic health risks associated with the calculated exposures to benzene, bis(2-ethylhexyl) phthalate, and trichloroethylene are considered minimal. There is no human evidence to suggest that exposure to these chemicals at the calculated mean concentrations in groundwater would cause chronic health effects.
Trichloroethylene, benzene and bis (2-ethylhexyl) phthalate are considered potential carcinogens. Estimates of the cancer risk associated with potential exposure to these compounds are considered low. However, the calculated risk due to exposure Cc benzene is higher than the risks associated with exposure to bis ( 2-ethylhexyl) phthalate and trichloroethylene. It is noted that _the concept of "acceptable risk" due to chemical. exposure is subject to much controversy, but the calculated cancer risks for exposure to trichloroethylene and benzene are somewhat above the level considered acceptable by the EPA, while the risk for bis(2-ethylhexyl) phthalate is below this level.
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The public health evaluation concluded that there is the potential for exposure to the indicator chemicals at levels above accept~gle concentration levels and some potential for carcinogenic risk above the 10 risk level by down-gradient users based on a conservative scenario. Due to this potential, the No Action alternative is considered not viable at the CFO/Shelby site.
6.0 Enforcement Analysis
The Celanese Site was added to the NPL in June of 1986 and EPA assumed lead responsibility for the site at that time. The Celanese Company has operated a plant on that site since 1960. Celanese initiated groundwater studies in 1981. Negotiations for the RI/FS consent agreement were concluded with the signing of the·document by both EPA and Celanese on March 10, 1986.
Negotiations to develop a consent decree for Celanese to perform the Remedial Design/Remedial Action are under way •
. ::::,.. ~~~ ... --7 .O Ground.wa-ter Remedial Alternatives
Remediation of the groundwater can be initially divided i.nto two areas of remedial effort: those areas with high Total Organic Carbon (TOC) concentrations near the suspected sources, and· those with lower TOC concentrations which are more remote from the source and near the property boundary.
Remedia.l technologies for controlling groundwater contamination problems generally utilize one of the following techniques:
B.
c.
D.
E.
F.
G.
Capping -involving an impermeable cover to reduce infiltration of water.
Groundwater pumping -involving extraction of water from and possibly injection of water into wells to capture a plume or alter the direction of groundwater movement.
Subsurfac~ drains -consisting of gravity collection systems designed to intercept groundwater.
Subsurface barriers -consisting of a vertical wall of low permeability materials constructed underground to divert groundwater flow or minimize leachate generation and plume movement.
In-situ treatment to biologically or chemically remove or attenuate contaminants in the subsurface.
Surface treatment of contaminated g~oundwater after it has been removed. This includes air-stripping, activated carbon treatment, etc.
The "No Action: alternative involves monitoring only, no active treatment.
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These technologies can be used singularly or in combination to control groundwater contamination.
A. Capping
The use of capping as a groundwater remediat.ion technique is detrimental to moving the residual contaminants to a removal point. Due to the high water solubility of ethylene glycol and other compounds present in the contaminated soil, they lend themselves to a soil leaching technology and subsequent ·collection through groundwater pumping stations. Precipitation will serve as a continuing natural solvent to sustain this leaching action. In addition the potential for utilization of supplemental spray irrigation of either treated or recycled groundwater would provide for acceleration and increased efficiency of the soil leaching program. Therefore, the utilization of capping would interrupt the ability of either natural or man-made systems to enhance. the leaching, arfc!''\:ii'ppi:'i1g is not being considerecl further in conjunction with the groundwater remediation.
B. Groundwater Pumping
Groundwater pumping techniques involve the active manipulation and management of groundwater in order to contain or remove a plume or to. adjust groundwater levels in order to limit formation of a plume. Types of wells used in management of contaminated groundwater include wellpoints, vacuum wells, and deep wells. The selection of the appropriate well type depends upon the depth of contamination and the hydrologic and geologic characteristics of the-aquifer involved.
Well systems are versatile and can be used to contain, remove, divert, or limit development of plumes under a variety of site conditions. groundwater pumping is most effective at sites where underlying aquifers have high intergranular hydraulic conductivity. However, it has been used with varying effectiveness at sites with moderate hydraulic conductivities and where pollutant movement is occurring along fractured or jointed material.
Where plume containment or removal is the objective, ei_ther extraction wells or a combination of extraction and injection wells can be used. The use of extraction wells alone is best suited to situations where contaminants are soluble with water, where the hydraulic gradient is sufficiently steep, the hydraulic conductivity is adequate, and where quick removal is not necessary.
A combination of extraction and injection wells is frequently used in containment or removal where the hydraulic gradient is relatively flat and hydraulic conductivities are moderate, or to accelerate the removal time frame. Groundwater pumping systems are the most versatile and flexible of the groundwater control technologies. Operational flexibility is high since pumping rates can be modified to adjust to changes in flow rate. System performance is generally good provided the wells are properly designed and maintained.
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c.
D.
E.
F.
At the CFO/SHELBY facility, groundwater pumping provides a viable
control and remediation technology for clean-up of the groundwater
contamination present. Its utilization in conjunction with treatment
of contaminated groundwater provides the potential. for a remediation
program allowing for containment of the existing contamination to its
present boundaries. This technology is, therefore, retained for
further consideration.
Subsurface Barriers
The term subsurface barriers refers to a variety of methods whereby
low permeability cut-off walls or diversions are installed below
ground to contain, capture, or redirect groundwater flow. The most
commonly used subsurface barriers are slurry walls, particularly the
soil~bentonite type slurry wall, Less common are cement-bentonite or
concrete:•s-J,urry walls, grouted barriers, and sheet pile cut-offs.
Subsurface Collection Drains
Subsurface collection drains include any type of buried conduit used
to collect and convey discharge by gravity flow. Subsurface
collection drains essentially function like an infinite line of
extraction wells and can perform many of the same functions as wells.l
They can be used to contain or remove a plume, or lower. the !
groundwater table. The decision to use drains ·or pumping is generally
based on cost effectiveness and implementability analysis. For
shallow contamination problems, drains can be more cost effective than
pumping. The biggest drawback to the use of subsurface drains is that
they are normally limited to shallow depths.
Again, due to the geologic conditions, topography of the site, extent
of contamination and availability of more technically feasible and
cost effective technologies, subsurface collection drains are not
being considered further.
In-Situ Treatment
In-Situ treatment of the contaminated ground water does not
appear to offer a potential for technologically or cost effectively
treating the groundwater conditions. The physical difficulty and high
costs associated with providing the nutrients and oxygen required to
stimulate and sustain aerobic biological activity within the existing
groundwater would be extensive. Therefore, this technology is
eliminated from further discussion.
Surface Treatments
Air Stripping
Air stripping is the mass transfer process in which volatile
contaminants in water or soil are transferred from their combined
state to a gaseous state. Four commonly used methods for air
stripping liquids are the packed column, cross-flow tower, coke tray
aeratoc, and diffused air basin procedures.
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Air stripping is most commonly accomplished in a packed tower equipped with an air blower. The packed tower works on the principle of counter-current flow where the water stream flows down through the packing while the air is blown upward, and is exhausted through the top. Volatile, soluble components have an affinity for the gaseous phase and tend to leave the aqueous stream for the gaseous phase. In the cross-flow tower, water flows down through the packing as in the counter-current packed column; however, the air is pulled across the water flow by a fan. The coke tray aerator is a simple, low maintenance process requiring no blower. The water being treated is allowed to trickle through several layers of trays. This produces a large surface area for gas transfer. Diffused aeration stripping and induced draft stripping use aeration basins similar to standard wastewater treatment aeration basins. Water flows through the basin from top to bottom or from one side to another with the air dispersed ___ Sh_r:<)Ugh diffusion at the bot tom of the basin. The. air to~w.ate'r "I'a·tio is significantly lower than in either the packed column or the cross-flow tower units.
Air stripping is normally utilized to remove volatile organics from aqueous waste streams. Generally components with Henry's Law constants greater than 0.003 can be effectively removed by air stripping. The waste feed stream must be low in suspended solids and may require pH adjustment to reduce solubility and improve transfer to I the gaseous phase.
Stripping is sometimes only partially effective in groundwater treatment and must be followed by other processes such as biological treatment and carbon adsorption. The combined use of air stripping followed by other applicable processes can be an effective means of removing the contaminants from groundwater.
In recent years, air stripping has gained increasing use. It has been used cost effectively for the treatment of low concentrations of volatiles or as a pre-treatment step prior to subsequent treatment technologies. Equipment for air stripping is relatively simple, start-up and shut-down can be accomplished quickly, and the modular des_ign of packed towers makes them somewhat mobile in their application.
An important consideration in the utilization of the air stripping technology is the implications of the air pollution which may result from the stripping operation itself. The gaseous stream generated during air stripping may require collection and subsequent treatment.
Because of the concentrations of volatile organics present in the contaminated groundwater at the site, air stripping may be applicable both as a prima·ry and supplemental remediation technology. Therefore, this treatment technology will be retained for further consideration.
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Activated Carbon Treatment
The process of adsorption onto activated carbon involves contacting a waste
stream with the carbon, normally by flow through a packed bed reactor. The
activated carbon process can be designed to selectively adsorb hazardous
constituents by a surface attraction phenomenon in which organic molecules are
attracted to the internal pores of the carbon granules.
Adsorption depends upon the strength of the molecular attraction between
adsorbent and adsorbate, molecular weight, type and characteristics of the
absorbent, electrokinetic charge, pH, and surface area. Once the micropore
surfaces are saturated with organics, the carbon is spent and must either be
replaced with virgin carbon or removed, thoroughly regenerated, and replaced.
The time to reach breakthrough or exhaustion is the single most critical
operating parameter. Carbon_ lo.\lg'l:vln:.!>.a_lanced ag,iins_t __ influ!"n.t,, concentration
governs operating economies. In the event that the carbon is regenerated
on-site, the supernatent from this process will be processed through the system
constructed for treating the site groundwater.
Activated carbon adsorption is a well-developed technology which is widely used
in the treatment of hazardous waste steams. It is especially well suited for
the removal of mixed organics from aqueous wastes. ·Since carbon adsorption isi
an electrical interaction phenomenon, the polarity of the waste compounds wilit
determine the effectiveness of the adsorption process •. The more hydrophobic ·
(insoluble) a molecule is, the more readily the compound is adsorbed. As a
result, low solubility humic and fulvic acids which are pr.esent in the.
groundwater can adsorb to the activated carbon more readily than many waste
contaminants and result in rapid carbon exhaustion. Also, some metals and
inorganic species have shown excellent to good adsorption potential. These
include antimony, arsenic, bismuth, chromium, tin, silver, mercury, cobalt,
zirconium, chlorine, bromine and iodine. Activated carbon can also be utilized
in the powdered form which offers the advantages of greatly increased surface
area availability and reduced costs.
Carbon adsorption technology can be used either in conjunction with or
following biological treatment and/or gravity filtration. Its purpose in this
application is to remove the refractory organics which cannot be biologically
degraded. The biological treatment and/or granular media filtration steps
prior to carbon adsorption reduce the organic and suspended solids load to the
carbon adsorption units. Reduction of organic and suspended solid load
minimizes carbon usage and regeneration costs. Air stripping has also been
applied prior to carbon adsorption in order to reduce a portion of the-volatile
contaminants and reduce the organic load to the carbon adsorption units.
Activated carbon usage is easily implemented into or along with other treatment
systems. The process is well suited to mobile units as well as to on-site
construction. Space requirements are small and start-up and shut down are ·-.... rapid.
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Regeneration of spent carbon for reuse is the highest operating cost associated with the utilization of carbon adsorption technology. In addition, high capital costs can be associated with its use. Both capital and operating costs can be substantially reduced through pretreatment of the waste prior to its treatment with carbon adsorption.
Activated carbon treatment will not be utilized in a primary remedial technology role at the site, but may be used as a supplementary technique in conjunction with other clean-up technologies. This technology will be retained for further consideration.
Precipitation/Flocculation
Precipitation is a physiochemical process where some or all of a substance in solution is transformed into a solid phase. The technology is based upon alteration of the chemical equilibrium relationships affecting the solubility of an inorganic species. Removal of metals as hydroxides or sulfides is the most common precipitation application in wastewater treatment.
Precipitation is applicable to the removal of most metals from wastewater, including zinc, cadmium, chromium, copper, lead, manganese, and mercury. Certain anionic species such as phosphate, sulfate and fluoride can also be removed by precipitation. The technology is useful for most aqueous hazardous ' waste streams. However, organometallic complexes with metals can inhibit · precipitation. Cyanide and other constituents may also complex with metals, thereby, reducing the treatment efficiency of precipitation.
Precipitation and flocculation are well-established technologies. A disadvantage is that precipitation is non-selective and that compounds other than those targeted may be removed. Both precipitation and flocculation are non-destructive and generate a large volume of sludge which must be disposed ultimately,
This technology will be retained for further consideration.
Biological Treatment
Biological treatment is utilized to remove organic matter from a waste stream through microbial degradation. The most common type of biological treatment is aerobic (in the presence of oxygen). A number of biological treatment processes exist which are used for the treatment of aqueous hazardous wastes. They include conventional activated sludge, modifications of the activated sludge process, pure oxygen activated sludge, extended aeration, and contact stabilization. Fixed-film systems include rotating biological discs and trickling filters.
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In the conventional activated sludge process, waste flows into an aeration basin where it is aerated for several hours. During this time, a suspended active microbial population aerobically degrades the organic matter in the waste stream along with producing new cells. A simplified equation for this process is:
Organics+ o2 ----> co2 + H20 + new cells
The cells produced during aeration along with other precipitated materials form a sludge which is settled out in a clarifier. The clarified water then goes to disposal or further treatment.
Fixed-film systems involve co~tact of the aqueous waste stream with microorganisms attached to some inert medium such as rock or specially designed plastic material.
_ Biological treatment has considerable flexibility due to thee,,ad,ety· of processes available and the adaptability of the microorganisms themselves. Most organic chemicals are considered biodegradable, although the ease of biodegradation varies widely. Several general observations can be made with regard to the ease of treatability of organics by aerobic biological treatment:
o Unsubstituted non-aromatics or cyclic hydrocarbons are preferred over unsubstituted aromatics.
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Materials with unsaturated bonds such as alk_enes are preferred over materials with saturated bonds.
Soluble organics are usually more readily degraded than insoluble materials. Biological treatment is more efficient in removing dissolved or colloidal materials, which are readily attacked by enzymes. This is not true for fixed-film treatment systems which preferentially treat suspended matte~.
The presence of optional groups effects biodegradability. Alcohols, aldehydes, acids, esters, amides, and amino acids are more biodegradable than corresponding alkanes, olefins, ketones, dicarboxylic acids, nitrites, and chloroalkanes.
o Halogen-substituted compounds are the most refractory to biodegradation.
Industrial type wastes may not be readily amenable to biological treatment; however, microorganisms can be acclimated to degrade many compounds that are initially relatively non-biodegradeable.
Additionally, heavy metals may be inhibitory to biological treatment, but the biomass can be acclimated, within limits, to tolerate elevated concentrations of metals.
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The completely mixed activated sludge process is the most widely used with high
organic loads, and high purity oxygen systems have advantages for hazardous
waste site remediation. However, a number of other parameters influence the
performance of the biological treatment system. These parameters are the.
concentration of suspended solids, oil and grease, organic load variations,
and temperatures.
Biological treatment has not been as widely used in hazardous waste site
remediation as activated carbon adsorption, filtration and
precipitation/flocculation. However, the process is well established for a
wide variety of organic contaminants.
Although biological treatment can effectively treat a wide range of organics,
it has several disadvantages in conjunction with hazardous waste site
applications. The reliability of the process can be impaired by "shock" loads
of toxics. In addition start-up times can be slow if the organisms need to be
acclimated to the wastes and th~· ,f/:ttenfion time can b,f long-''tor complex
wastes. The existence of an acclimated culture can dramatically decrease
start-up and detention time.
Rotating biological contactors have the advantages for use at hazardous waste
treatment sites in that they are compact, can handle large flow variations and
high organic shock loads. In addition they-do not require the use of
mechanical aeration equipment.
The sludge produced in biological waste treatment process may be a hazardous
waste itself due to the sorption and concentration of toxic and hazardous
compounds contained in the wastewater. If the sludges are hazardous, it must
be ·disposed of in a RCRA-approved manner. If the sludge is non-hazard.ous,
disposal should conform with state sludge disposal guidelines. Biological
treatment has been screened and determined to be a viable treatment alternative
for the site contamination present. A more detailed discussion of its use is
included in the remedial action portion of this report.
Ion Exchange
Ion exchange is a process where the toxic ions present in a waste stream are
removed by being exchanged with relatively harmless ions held by the ion
exchange material. Ion exchange resins are primarily synthetic organic
materials containing ionic functional groups to which exchangeable ions are
attached. These synthetic resins are structurally stable (can tolerate a range
of temperature and pH), exhibit a high exchange capacity, and can be utilized
to selectively exchange ions.
Ion exchange can be used to remove a wide range of inorganic species from water
such as:
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all metallic elements when present as soluble species, either anionic
or cationic
inorganic anions such as halides, sulfates, nitrates, cyanides, etc.
o organic acids such as carboxylics, sulfonics, and some phenols
0 organic amines
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Sorptive resins can also remove a broad range of polar and non-polar organics. A practical upper limit for ion exchange is about 2,500 to 4,000 mg/1 (ppm). Suspended solids in the feed stream should be low, less than 50 mg/1 (ppm) to prevent plugging the resin, and the waste stream must be free of oxidants,
Ion exchange is a well established technology for heavy metal removal and hazardous anion removal from dilute waste solutions, A problem which exists with the ion exchange technology is the disposal of contaminated regeneration solutions. Consideration should be given to selection of these solutions when evaluating the technology.
Based. on the data available for this screening, the contaminants present, amenability of other treatment technologies, and costs, ion exchange is not being considered for further evaluation as a remedial technology at CFO/SHELBY.
Filtration
Filtration is a physical process where suspended solids are removed from solution by forcing a fluid through a porous medium. Granular media filtration is normally used for treating aqueous waste streams. The filter media (generally sand) is contained within a basin and is supported by an underdrain system which allows the filtered liquid to be drawn off while retaining the filter media in place. As the wastewater laden with suspended solids passes through the filter media, the solids become trapped on top of and within the bed. To prevent plugging, the filter is backwashed at high velocity to dislodge the solids, The backwater produced contains high concentrations of solids and requires further treatment.
The granular media filtration process is only marginally effective in treating colloidal size particles, Filtration equipment is relatively simple,·readily available, easy to operate and control, and to integrate with other treatment tech.nologies, There is also extensive experience with the operation of granular media filters at hazardous waste sites,
Although granular media filters are a cost effective and efficient treatment technique in a wide variety of applications, filtration as a primary remedial technology does not appear to be needed, Therefore, this technology is eliminated from further consideration.
G, NO ACTION ALTERNATIVE
A number of consideration must be made in evaluating the effects of choosing a No Action Alternative. Under the No Action Alternative, groundwater would remain contaminated with substances that may be regulated by local, state, and federal laws. The No Action Alternative would not provide remedial action to reduce mobility, toxicity or volume-of contaminated soil. Possible socioeconomic impacts of the. No Action Alternative include the following:
* *
*
*
*
Decline in property values
Expenditure for legal services
Depressed area growth
Restricted access to site
Public and environmental exposures
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The Remedial Investigation concluded that groundwater contamination
had not migrated past the site boundaries at that time. However, the
investigation did not identify a constraint to off-site migration if
the measured groundwater contamination was not abated.
The Public Health Assessment was presented in Appendix A of the
Feasibility Study and evaluated the effects of exposure to selected
indicator compounds at the average concentration measured in the site
monitor wells. Due to the fact that four out of five indicator
compounds were above acceptable contaminant levels, and due to the
proximity of off-site private wells used for residential drinking
water supplies, the health assessment concluded that the No Action
Alternative was not viable at the site.
8.0 Recommended Alternative
The·"recommended alternative for remediation of groundwater contam.±nation at .the
Celanese Fibers Operations Site includes extraction of contaminated water and
treatment in an on-site treatment system. This alternative will cost
approximately $2 million, including operation and maintenance costs for an
estimated 30 year period (Table 8-1).
The groundwater remediation program will consist of removing the groundwater
through two tiers of extraction wells, and subsequently treating the water with
a combination of treatment techniques in a specified sequence. The first tier
of wells will be constructed near the eastern perimeter of the property as
shown on Figure 8-1. A second tier of extraction wells-will be installed in
the area of highest contaminant concentration within the interior .of the plume,
also shown on Figure 8-1. The first tier of extraction wells will be located
in a zone of lower contaminant concentration than the second tier of wells, and
therefore, the treatment of the pumped groundwater will not need to be as
extensive or complex as that associated with the interior plume groundwater
remediation effort.
The areal and vertical extent of the plume to be removed was developed from the
total organic carbon (TOC) concentrations. A review of the data indicated that
the bulk of the contamination in the groundwater appeared to be in the
intermediate depths (30 to 50 feet) to rock (50 to 80 feet). Furthermore, the
total organic carbon plume in general incorporates most of the areas showing
elevated metals concentrations. Thus, the groundwater extraction system
proposed for removing the total organics present should also be capable of
removing the metals involved.
The groundwater treatment alternatives being proposed can initially be divided
into two areas of remedial effort. Those areas with high TOC concentrations
near suspected contaminant sources, and those with lower TOC concentrations
more removed from the sources.
Table 8-2 lists some of the constituents identified in the groundwater at the
site, and applicable primary and secondary treatment technologies. The primary
treatment technologies proposed for treating the extracted groundwater are air
stripping and biological treatment.
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Table 8-1
Cost Estimate
Ground-Water Extraction System
Objectives: To intercept
ground water
area.
and treat
emanating
the existing contaminated
from the primary source
Ground Water Extraction System
Installation
A. Well Installation · (maximuii( ·o'f"'t"6 wells)
B. Trenching/Electrical
C. All Weather Road
D. Ground-Water Treatment System
Subtotal
D. Engineering Fees (10% capital costs)
E. Permitting (5% Capital Costs)
F. Contingency (20% capital costs)
Subtotal
G. Operation and Maintenance (30 year.period)
Total
!
-~$177, 820
$160,000
$125,000
$250,000
$712,820
$72,000
$36,000
$142,000
$962,820
$1,069,230
$2,032,050
NOTE I
1I IF. BURN PITS, GLYCOL RECOVERY SLUDGE PITS >ND AAEA OF GRU SLUDGE Ill AC KING WERE T ,XEN FROM HISTORICAL AERIAL PHOTOS,
-----
PERIMETER
EXTRACTION
WELLS
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' I --"I GGe 't
PROPERTY --►-..______
LINE_,/' ...... ..______
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E -EOU/ll.lZATION BASIN C -CLMIFIER
D -DIGESTER
NJ AERATION BASIN SP SLUDGE POND EP EMERGENCY POND .rr POUSI/ING rotlO
---
"' " •~ u', 7 !·, ; ;. ~
,;~~
I •• t.: OJ
\"' <;J ~
,, i '
f hi ',; 2 3.
< U Vl
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Table 8-2 Primary/Secondary Treatment Technologies For Selected Compounds Found in Extracted
Ground Waters
Constituent
Chromium
Acetone
----· Other 'Ketones
Carbon Tetrachloride
Chloroform
1,1 -Dichloroethene
1,1 -Dichloroethane
Trans-1,2-Dichloroethene
Methylene Chloride
Methyl Chloride
Trichloroethene
Benzene
Chlorobenzene
Toluene
Vinyl Chloride
Phenol
DowTherm
Penanthrene
Anthracene
Chrysene
Nitro-Di-N-Propylamine
Di-N-Butyl Phthalate
Bis (2-Ethyl hexyl
Phthalate)
Chloroethane
1,2-Dichlor9ethane
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Bromodichloromethane
Tetrachloroethene
1,2 Dichloropropane
Bromoform
1,1,2,2-Tetrachloroethane
2-Chloroethylvinyl ether
Dibromochloromethane
Ethyl benzene
1,2-Dichlorobenzene
Styrene
with• pH adjust~ent
Primary Method
of Treatment
Precipitation*
Air Stripping
Air stripping
Air stripping
Air stripping
Air stripping
Air stripping
Air stripping
Air stripping
Air stripping
Air stripping
Air stripping
Air Stripping
Air Stripping
Air stripping
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Air stripping
Air stripping
Air stripping
Air stripping
Air Stripping
Air stripping
Air Stripping
Air Stripping
Air Stripping
Air stripping
Air Stripping
Air stripping
Air stripping
Air Stripping
Secondary Method
of Treatment
.Biological --~~, ··-'""aio'iogica1
· Biological-
_Biological
Biological·;
None Known: I
Biological
Biological
Biological
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Air Stripping
Air Stripping
Air Stripping
Air Stripping
None Known
None Known
Biological
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Table 8-2 indicates that the constituents present in the groundwater are
amenable to either one or more of the proposed treatment technologies being
considered.
The groundwater treatment alternative recommended for the areas with high total
organic carbon concentrations (interior wells) will consist of air stripping
and biological treatment, followed by carbon adsorption, if needed. The
extracted groundwater will be pumped from the interior tier of wells to a
common equalization/sedimentation tank where suspended solids will be removed.
Utilization of the equalization/sedimentation tank will minimize the suspended
solid material present, and will provide a blended stable flow stream from the
four extraction wells for the subsequent groundwater treatment
The equalized flow will then be pumped to the air stripping tower where the
volatile organic fraction will be removed or reduced.
Volatiles present in the groundwate-r00such as· vinyl chloride; methylene
chloride; 1-1-dichloroethene, 1,1-dichloroethane; trichloroethene; etc. should_
be reduced 90 to .98 percent by air stripping. Semi-volatile removal should
range between 30 to 80 percent at ambient air temperatures.
The stripping tower effluent will then be pumped to a biological treatment
system. No specific biological treatment process has been selected. As the
data from the pumping test are evaluated in the terms of expected variations i,;i
concentrations, flow variations, constituents, etc., a decision will be made !
regarding the preferred method of biological treatment.17=·
. ~
The effluent from the biological treatment will be discharged to a carbon
adsorption unit designed for this anticipated flow. This unit will be used as
a final treatment step to remove refractory organics that may remain after
biological treatment.
Effluent from the treatment system will be discharged to the existing
wastewater treatment plant for discharge under the existing North Carolina
NPDES discharge permit. In cases where metals, such as chromium, are present
in the treatment system effluent above allowable discharge levels, the effluent
will be passed through a chemical precipitation step prior to final discharge.
The groundwater treatment alternative proposed for the areas of lower total
organic carbon concentration (perimeter wells) will consist of air stripping
followed by carbon adsorption. Because of the low concentration of
constituents expected in this area and their general amenability to the use of
air stripping for removal, the utilization of biological treatment is not
anticipated. Thus, the effluent from the air stripping unit will be discharge
to a carbon adsorption unit for final treatment prior to discharge. The carbon
unit will be designed to handle the anticipated maximum flow from the perimeter
well system. Again, should problems with metals be encountered, a
precipitation step will. be added to the treatment sequence being employed.
Treated water from the groundwater treatment system will be discharged in the
same manner as discussed previously for the groundwater from the interior of
the plume.
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This recommended alternative meets the requirements of the National Oil and Hazardous Substances Contingency Plan (NCP) 40 CFR, 300.68(j) and the Superfund Amendments and Reauthorization Act of 1986 (SARA). This alternative permanently and significantly reduces the mobility of hazardous contaminants in the area groundwater. The recommended alternative for the source material will be determined at the end of the additional studies.
Technical Evaluation
Performance of a remedial action is determined basically by its effectiveness and its life expectance in performing its specified function. Effectiveness refers to the degree to which an action will meet the remediation goal, which is a reduction of toxicity, mobility, or volume of contamination or the removal of exposure routes. The effective life is the length of time this level of effectiveness can be maintained.
·RotR-·the' groundwater extractfon system and groundwater treatment system proposed can be considered to be effective in their remedial efforts. They address the questions of reduction of toxicity, mobility, and volume of contamination in a very positive manner.· In addition, they also have a positive effect on the removal of a potential exposure route, the ground water.
Reliability is. the degree of assurance that the particular remedial action , being considered will meet or exceed the expectations for its performance, the' likelihood that mechanical and process failure will occur, and the consequenceb of such failures. This is directly related to the complexity of the equipment and process selected for the remediation effort. Important considerations concerning reliability are operation and maintenance requirements,· and the demonstrated performance of similar applications. •
In the case of the groundwater remediation, the simplicity of the groundwater exfraction system provides it with a high reliability factor. Also, the treatment technologies selected for subsequent treatment of the ground water are all well known, tested, and accepted technologies which provides reliability to the proposed treatment plan.
Health and safety takes into account the potential threat to health and safety of site personnel both during the implementation of the remedial action alternative and during its operation.
Remedial technologies were evaluated with respect to a number of safety risks including the need for personnel to handle contaminated or hazardous materials and the possibility of the production of toxic gases or airborne contaminants.
Operating conditions for the processes were also considered along with their effect on safety.
Construction of the interior tier of wells presents the greatest potential for encountering contaminated materials. The work area will be monitored with air monitoring equipment to identify the need for respiratory equipment, and dermal protection will be provided during the field operations. Construction of the perimeter line of wells is expected to produce a lesser potential for exposure because of the lower concentration of groundwater;< contaminants in that area • .,._~---However, health and safety considerations simila~ to those for the interior tier of wells ~il! ~2 maintained.
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Trenching activities for pipe and electrical supply line construction, where used, and general grading for the treatment facility construction are not generally expected to encounter contaminated materials. However, operations in the area adjacent to the former disposal areas may encounter contaminated soils. These operations will be monitored similar to the interior. well construction activities to identify proper safety procedures.
All personnel involved in construction and operation of the extraction and treatment syste·m will be trained in accordance with the governing OSHA provisions contained in 29 CFR 1910.120.
The extraction and treatment alternative was evaluated with regards to its implementability. These considerations include such things as difficult engineering requirements, availability of equipment, and permit, treatability, or pilot study requirements. Also included is the time required to attain the desired results for the particular remedial alternative being proposed. The groundwater extraction and treatment alternative uses available .. t.echnologies ·chat do not require unusual engineering specialities for ·;:i-~·sii:'n .. and does not require specialty equipment to implement. However, pump testing of the aquifer-is planned to provide input for the extraction well design and bench scale treatability studies are anticipated to verify the treatment technologies to be used. The implementation of this alternative will continue for several years with the completion of the activity identified by monitoring that verifies that the contaminant levels have been reduced to the ARARs specified by the regulatory agencies. The duration of the cleanup can be shortened by the · ! successful removal and treatment/destruction of the source, and by accelerated leaching by irrigation.
This combination of treatments is the most efficient and cost-effective remedy. It is also the most technically feasible of the groundwater remedial alternatives discussed in Section 7.0 of this document.
Consistency with Other Environmental Laws
* Occupational Safety and Health Administration (OSHA)
A health and safety plan will be developed during remedial design and will be followed during field activities to assure that regulations of OSHA are followed.
* Endangered Species Act
*
The recommended remedial alternative is protective of species listed as endangered or threatened under the Endangered Species Act. Requirements of the Interagency Section 7 Consultation Process, 50 CFR, Part 402, will be met, The Department of the Interior, Fish and Wildlife Service, will be consulted during the remedial design and additional source characterization studies to assure that endangered or threatened species are not adversely impacted by implementation of this remedy.
Ambient Air Quality Standards
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*
*
The groundwater treatment system will be designed and monitored to assure that air emissions meet all state and Federal standards,
National Pollutant Discharge Elimination System (NPDES)
Discharge from the treatment system will flow into the existing wastewater treatment system. This practice will continue only so long as the discharge from the wastewater treatment system stays within the existing NPDES permit,
Safe Drinking Water Act (SWDA).
Maximum Contaminant Levels (MCLs) established under the SOWA were found to be relevant and appropriate to remedial action at the Celanese Fibers Operations Site and will be considered the cleanup criteria except in instances where the North Carolina State MCLs are more stringent.
*Resource Conservation and Recovery Act (RCRA)
*
*
*
The recommended remedy for groundwater contamination is not regulated under RCRA, therefore it does not apply,
Floodplain Management Executive Order 11988
The CERCLA areas do not lie within a floodplain, and, thus are not subject to the. requirements of E.D. 11988,
Department of Transportation (DOT)
Transport of hazardous substances is regulated by the DOT,
State Drinking Water Standards
Maximum Contaminant Levels established by the State of North Carolina as given in 15 NCAC 2L were found to be relevant and appropriate in all instances where the state MCL is more stringent than the SOWA MCL.
Specifically, for the purposes of this remedy, all compounds detected in the groundwater which are not naturally occurring must be removed from groundwater until the concentration of that compound has fallen below the lowest analytical method detection limit published by EPA for that particular compound.
9,0 Community Relations
A public meeting was held on September 24, 1985 to present the draft RI/FS work plan to interested parties.
Two information repositories have been established for the site, one in Earl, North Carolina and one in Shelby.
A public meeting was held on July 21, 1986 to present the findings of the Remedial Investigation to interested citizens,
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On February 3, 1988, a public meeting was held to discuss the results of the
Feasibility Study with interested citizens. At that time, EPA also presented
the preferred remedial alternative.
Numerous questions were asked at the meeting and a number of comments have been
received. Few comments were on the selected alternative. The majority of the
comments received were actually requests to have private wells sampled. These
requests are being handled by the Cleveland County Health Department in concert
with the North Carolina Department of Human Services.
The public did show a desire for remediation of the site. No opposition from
the public is expected if the recommended remedial alternative is implemented.
A Responsiveness Summary has been prepared to summarize community concerns and
EPA's community relations activities.
GLENN/Richer:Rod Disk Doc CF0-1 & CF0-2:Draft a/o 8 & 10 March 1988
GLENN HANKE GREEN ORC STONEBRAKER TOBIN DEHIHNS
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