NCD003446721_19911122_Celeanse Corporation - Shelby Fiber_FRBCERCLA SPD_Comments 1990 - 1991-OCR

•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. McKenzie Mallary
Remedial Project Manager
22 November 1991
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Celanese Fibers Operations NPL Site
Shelby, Celveland County
Comments on the Trial Burn Report
Dear Mr. Mallary:
William L. Meyer
Director
Attached are comments from the North Carolina Division of Environmental
Management on the Trail Burn Report for the above site. If you have any questions, please
contact me at [phone].
CVJ/acr
Attachment
'
Sincerely,
Charlotte V. Jesn
Superfund Section
An Equal Opportunity Affinnative Action Employer
James G. Martin, Governor George T Everett, Ph.D.
Director ____ \'ililliam W'. Cobey, Jr., Secretary
Rr/..,,;onal Office,
A~hrvilh:
704/251-6208
F~yeneville
919!4S6-IS41
Monrtwillr
704.'663•Hi9Y
Ralrigi,
919,733.2314
\\'-J,hin:,.'lon
919'941')-6481
\\'ilminf,'lOn
9)9.'395-3~.xl
\\'1in;mn-Salem
919.'S96-70J7
October 10, 1991
M E M O R A N D U M
TO: Bill Meyer, Director
Division of Solid Waste Management
FROM: %
1
Gecirge T. Everett ~°"'-~
SUBJECT: Celanese Fibers NPL Site
Trial Burn Report
Cleveland County
Project #91-59
The Division of Environmental Management has completed
the review of the subject document and offers the following
comments and recommendations.
1. While the emission rates for benzene, carbon
disulfide, chloroform, and methylene chloride are
demonstrated to be greater than estimated on the
air· permit application, the actual emissions are
less than the exemption levels contained in 1 SA
NCAC 2H .0610.
2. Air Permit No. 6943 was issued on December 19,
1 990. Acceptable Ambient Limits ( AAL' s) for
benzene, chloroform, methylene chloride, and
chromium VI were not effective until May 1, 1991.
Thus, the facility did not have a regulatory
obligation to comply with the AAL' s contained in
.1100 (b) for those pollutants in December 1990.
The only applicable AAL at the time
of permit issuance was the AAL for carbon
disulfide. Projected ( and now demonstrated)
emissions of carbon disulfide were below the
exemption level. Air Permit No. 6943 required
compliance with .0610(h) in Section A. Specific
Conditions and Limitations No. 1.
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• •
3. Total chromium was measured during testing, not
chromium VI. In the past, the APB has used the
factor of 1/279 of total chromium as an estimate
for chromium VI. This factor was submitted by
Duke Power Company in support of the Lincoln
Combustion Turbine Station. Duke referenced EPA
document EPA-450/2-89-001, Estimating Air Toxics
Emissions from Coal and Oil Combustion. While not
specifically applicable to the Hoechst Celanese
Test Burn, it appears to be the best reference
available for determining chromium VI from total
chromium. The APB has previously provided the
Technical Support Branch this reference for its
use as a factor for determining potential chromium
VI emissions for other projects.
4. Based on the above information, the APB has
determined that no further permitting action is
necessary or required the Hoechst Celanese air
permit No. 6943.
If there are any questions, please advise.
GTE/sbp/CELANESE.SWM
cc: Lee Daniel
Steve Tedder
Mooresville Regional Office
Central Files
Groundwater Files
20 August 1991
MEMORANDUM
TO: File
FROM: Charlotte Jesn(}Ck, Branch Head
Inactive Sites Branch
RE: Celanese NPL Site
Shelby, Cleveland County
•
Telephone Conversation with K. Mallary (US EPA) to Relay
Comments on the Ongoing Site Remediation
I telephoned Ken Mallary with US EPA Region IV at [phone] to discuss the
ongoing remediation at the Celanese site in Shelby. I asked Mr. Mallary about the present
disposition of the excavated stream sediment. Mr. Mallary told me that only part of the 110
cubic yards of sediment to be removed ( according to the ROD) were excavated, centrifuged,
and then stockpiled for later fixation in the area of the burn pit excavation. The liquids
separated from the sediment were pumped to the plant's waste water treatment system. Mr.
Mallary feels that greater than 110 cubic yards of sediment would have to be excavated to
remove the polynuclear aromatic compounds. This excavation may damage the stream
biota. EPA is considering in lieu of excavating additional sediment, conducting a bioassay
to determine if the P AHs are impacting the stream biota. Celanese would conduct coring
along the stream to determine the depth or depths of P AH contamination zones if the
bioassay demonstrates there is an impact. I suggested that both of these options be
completed regardless of the outcome of the bioassay. The core samples may reveal that
P AH contamination is limited in extent and not require additional extensive excavation. Mr.
Mallary will contact me if this option is to be pursued.
We also discussed the treatability study for fixation of burn pit residuals and ash. I
told Mr. Mallary that the data I had was incomplete. The study appears to have been
conducted on the burn pit residuals and not the ash. Separate fixation studies will be
necessary for both. No total concentration pretreatment data was provided in which to
compare the effectiveness of the fixation agent. If contaminants are present in the
pretreated material, none will be detected in the fixed material leachate. This does not
provide any demonstration of effectiveness of the bonding agent. Also, the TCLP extract
was only analyzed for ethylene glycol. Several other contaminants are present in the burn
pit residuals. The effectiveness of fixation of these compounds needs to be demonstrated
as well.
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File
Celanese NPL Site
20 August 1991
Page 2
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In addition to these problems, the TCLP method was modified by eliminating pH
adjustment with acetic acid. Celanese feels that the acetic acid causes false positive shows
for ethylene glycol and that since ethylene glycol is more soluble at higher pHs, the modified
TCLP is a more conservative approach. I told Mr. Mallary that we would need some
demonstrated chemical evidence regarding this issue. Mr. Mallary told me that he should
be receiving additional fixation data any day now, and will send a copy of the new data and
also any evidence regarding the modified TCLP to me for review.
CVJ/acr
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• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. McKenzie Mallary
Remedial Project Manager
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
16 April 1991
RE: Celanese Fibers Operations NPL Site
Comments on February 1991 Quarterly Report
Dear Mr. Mallary:
William L. Meyer
Director
We have reviewed the above document and are forwarding the following comments
to you:
1. Please provide information on why the Elliott well 1s only sampled for
trichloroethene and vinyl chloride.
2. Correlation between TOC concentrations and total volatile and semivolatile
hazardous organic compound concentrations needs to be demonstrated
through comparison of analytical results if TOC analysis is to be used to
monitor the effluent.
If you have any questions, please contact me at [phone].
Sincerely,
c~)~
Charlotte V. Jesn{{k . -
Superfund Section
CVJ/acr
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•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. McKenzie Mallary
Remedial Project Manager
24 September 1990
US Environmental Protection Agency
Region IV
345 Courtland Street,NE
Atlanta, GA 30365
RE: Comments on the Celanese Fibers Operations NPL Site
August 1990 Quarterly Report
Dear Mr. Mallary:
William L. Meyer
Director
The Celanese August 1990 Quarterly Report has been reviewed and the following
comments are offered:
1. A map should be provided with well locations and quarterly TCL/TAL data.
The extent of the contaminant plume should be depicted on the map. This
information is necessary for the reader to understand the relationship of
extraction system to the configuration of the contaminant plume as it changes
overtime. This map should be added to Section 4.0 on "Groundwater
Quality."
2. The report indicates insufficient drawdown is being achieved in some wells at
the site. Cross-sectional diagrams depicting the actual drawdown achieved
including well designations needs to also be provided in Section 4.0.
3. Trimethyl silanol has been detected in several samples. The report indicates
in some cases the compound may be a laboratory contaminant. The industrial
and laboratory usage of this compound should be investigated and provided
in the next quarterly report.
• • i\1r. McKenzie M:lilary
24 Scp1c111ber 1990
Page 2
Most of the rnmmcnts submiued for the previous quarterly report were not :1cldressed
1n the August 1990 Quarterly Report. We are, therefore, resubmitting some of these
comments.
2801.
1. TOC is being used at the site to measure the amount of hazardous organic
constituents in the innuent :md effluent. A correlation study of TOC to the
hazardous organic compounds present in the groundwater is necessary before
TOC can be used as a measure of the total concentration of these compounds,
This comparison/study should be added to the report.
2. The effluent discharge was only analyzed once during the quarter for VOCs
and semi-VOCs. These analyses should be done more frequently until
problems with SBR are rectified and the TOC-contaminant correlation
determination is complete.
If you have any questions concerning these comments, please contact me at (919) 733-
Sincerely,
I 7)· 7 l (_)"v.,vJ,,...!,, '._, (· /; v·,<.{,>(_
Clnrlotte Jesnec
Superfund Section
CJ/acr
•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. McKenzie Mallary
Remedial Project Manager
21 June 1990
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
RE: Comments on the Celanese NPL Site Third Quarterly Report
Dear Mr. Mallary:
William L. Meyer
Director
Our office has reviewed the Celanese Third Quarterly Report. We are providing the
following comments.
1. A polishing pond is shown in Figure l-3 to be the last treatment step for the
inner tier groundwater. The report does not indicate whether this pond is
lined and how the sludge generated at this point is collected and disposed.
2. Page 1-12 indicates that the pH of the influent is raised to 7.5 to precipitate
iron. If other metals require removal at this stage (for instance, if chromium
or other metal concentrations increase in the influent during the period of
groundwater extraction and treatment) the pH may have to be raised higher
for precipitation.
3. Page 1-12 also states that the precipitated iron sludge will be disposed at an
off-site facility. The report should indicate what type of facility is to be used
for sludge disposal.
, • • Mr. McKenzie Mallary
21 June 1990
Page 2
4. Page 1-13 states that one SBR cycle is completed each day. The length of this
treatment or other aspects of the entire treatment system need to be altered
in order to completely remove the contaminants from the extracted
groundwater. Acetone, diethylphthalate, and benzoic acid are still present in
the effluent.
5. Page 2-12 states that acetone, present in the effluent, is assumed to be a
breakdown product of ethylene glycol. This is unlikely since the ethylene
glycol structure has 2 carbons and acetone has 3. Also, samples collected
during the Remedial Investigation in9icate acetone is present in the
groundwater.
6. The report does not indicate if it has been necessary to waste any of SBR
sludge. If wasting the sludge has not been necessary, it is likely that the
biomass is not sufficiently prolific. If the biomass is not prolific, the amount
of new biomass generated will likely not be sufficient to replace the older
microorganisms which have expended their life span.
7. Page 1-13 indicates that nutrients are added to maintain a 100:5:1 ratio for
BOD, ammonia-nitrogen, and phosphorous, respectively. With a one day SBR
cycle and the BOD test requiring five days, an explanation of how the amount
of daily nutrient additions is determined needs to be supplied in the report.
8. TOC is being used at the site to measure the amount of hazardous organic
constituents in the influent and effluent. A correlation study of TOC to the
hazardous organic compounds present in the groundwater is necessary before
TOC can be used as a measure of the total concentration of these compounds.
This comparison/study should be added to the report.
9. Page 2-1 indicates that ammonia and phosphorous are present in the influent.
The report is not clear whether the concentrations given on page 2-2 are
before or after ammonia and phosphorous addition. If these concentrations
are before addition, are there other discharges to the system which would be
providing ammonia and phosphorous to the influent before ammonia and
phosphorous are added? Please clarify.
I 0. Explain how ammonia and phosphorous are added to the system. Page 2-2
indicated 1 to 6 quarts of ammonia-nitrogen have been added when needed.
Please indicate to what volume of influent this is added.
I • • Mr. McKenzie Mallary
21 June 1990
Page 3
11. Page 2-2 states that BOD analysis was performed 2 times or less this quarter.
How is it possible to determine daily nutrient additions based on the BOD,
ammonia-nitrogen, phosphorous ratios if BOD analysis is only performed
twice in a quarter? Please explain.
12. When evaluating the reasons for the frequent biomass upsets, the degree of
toxicity of ethylene glycol to the biomass should be considered. Page 2-3
indicates groundwater from well IT-1 had a concentration of 2.6% ethylene
glycol on February 26, 1990. It seems clear that at these levels, the
contaminants in the influent are either .toxic to the biomass or are causing
organic overloading to the SER. Under these conditions biomass upset could
easily occur.
13. Page 2-3 indicates well IT-1 was shut down because of elevated concentrations
of contaminants in the well affecting the biomass. The report does not
indicate whether groundwater extraction from the well has recommenced.
The pre-SER equalization tank should be used to dilute concentrations of
contaminants down to levels acceptable to the biomass. The COD values of
the influent prior to discharge to the SER need to be monitored daily to
prevent biomass upset. The use of the well IT-1 should not be discontinued.
14. Page 2-9 mentions that the carbon filter system seems to be ineffective. It
may be possible that if the SER contents have not had sufficient time to settle
prior to discharge, bacteria may be saturating the carbon filter.
15. The effluent discharge was only analyzed once during the quarter for VOCs
and semi-VOCs. These analyses should be done more frequently until
problems with the SBR are rectified and the TOC-contaminant correlation
determination is complete.
16. Pages 2-13 through 2-14 indicate a TCLP extraction was performed on SBR
sludge and filter press sludge samples. The leachate from these samples is
said not to contain any TCLP contaminants. It is not clear whether the
leachate was analyzed for the contaminants listed in the TCLP method or for
the compounds known to be present in the groundwater. The TCLP leachate
analyses should include those compounds known to be present in the
groundwater.
• •
Mr. McKenzie Mallary
21 June 1990
Pa&e 4
17. Page 7-1 states that pumping in the inner and outer tier wells produced little
or no drawdown in most on-site wells during the third quarter. It appears the
extraction system is not effectively capturing the contaminant plume. The
extraction system will need to be altered to successfully remediate
groundwater.
Please contact me at (919)-733-2801 if you have any questions regarding these comments.
Sincerely,
Charlotte Jesneck
Superfund Section
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. McKenzie Mallary
Remedial Project Manager
28 March 1990
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Comments on Celanese Fibers Operations Site Quarterly Status Report
Dear Mr. Mallary:
William L. Meyer
Director
The Celanese Quarterly Status Report has been reviewed and the following
comments are offered.
1. When comparing influent and effluent contaminant concentrations, the carbon
filter and air stripping treatment of groundwater does not appear effective.
Also, the only sample data available (November 3, 1989) on the effluent
indicates elevated concentrations of hazardous organic compounds are being
released in the effluent. Measures to prevent the release of contaminated
water need to be taken. The groundwater treatment system needs to be ·
altered to improve the effectiveness of organic contaminant removal prior to
any further extraction and discharge of groundwater.
2. A few hazardous organic constituents have been identified in private well
samples. Each of the compounds present needs to be evaluated immediately
to determine if the compound poses a health threat. The report also indicates
30 or more ppb of "unknowns" are present in two of the residential wells. An
effort should be made to identify these compounds and determine the health
threat they pose.
• • Mr. McKenzie Mallary
28 March 1990
Page 2
If any of the compounds present in drinking water are determined to pose
a health threat, an alternative water supply needs to be provided to the
residents. If the compounds are determined not to pose a health threat,
continued regular monitoring of these wells should be performed until
groundwater remediation is complete in that area.
If you have any questions concerning these comments, please contact me at (919)
733-2801.
CV /acr
Sincerely,
Charlotte Varlashkin
Superfund Section
• •
27 March 1990
MEMORANDUM
TO:
FROM:
RE:
File
Charlotte Varlashkin
Superfund Section
Extension of Review Period for the Celanese Quarterly Report for O.U.1,
February 1990
I spoke with Ken Mallery of EPA Region IV today to request additional time in
reviewing the Celanese Quarterly Report and the SBR Operational Study. Ken said that
there would not be a problem in extending the deadline for comments on the reports to
April 6, 1990.
CV /acr
• •
6 March 1990
MEMORANDUM
TO:
FROM:
RE:
File
Charlotte Varlashkin
Superfund Section
Delay in Comments on the Celanese 30% Remedial Design and Sequential
Batch Reactor Sampling Report
I telephoned Ken Mallary of US EPA Region IV to let him know that additional
time is required to review the Celanese 30% Remedial Design and the Sequential Batch
Reactor Sampling Report. I told him we would submit comments by March 21. Ken
said that March 21 would be okay.
CV /acr
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• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. Ken Mallary
Remedial Project Manager
12 January 1990
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Celanese Fibers Operations
Comments on Air Sampling Protocols
Dear Mr. Mallary:
William L. Meyer
Director
The Celanese Fibers Operations Air Sampling Protocols
package has been reviewed and the following comments are
offered.
(1) The EPA SW-846 method 0030 only covers sample capture
techniques and not recovery and analysis. Analytical
methods for the recovered sample should include EPA
approved methods for all volatile organic compounds
present in the groundwater.
(2) The report indicates that the sample cartridges will
be shipped to a laboratory for analysis. This
procedure will produce a situation where air stripper
emissions are not known for a period of time.
• •
Mr. Ken Mallary
12 January 1990
Page 2
All site assessment and remediation plans should
consider substantive permitting requirements. Local,
state, and federal ~ir permitting authorities should
be contacted to confirm that these air emissions
sample collection and analysis procedures are
acceptable. A copy of the Air Sampling Protocols is
being forwarded to the North Carolina Air Quality
Section. Additional comments may follow at a later
date. In addition, Gary McAllister with the US EPA
Office of Air Quality Planning and Standards Emission
Measurement Branch (919/541-1062) has also offered to
assist in suggesting alternative sample collection
techniques.
If you have any questions, please contact me at
[phone].
CV/acr
Sincerely,
i'l,tv1/UM 1GL/li~
Charlotte Varlashkin
Superfund Section
. "., • •
January 10, 1990
To: Celanese Corporation NPL Site File
Shelby, Cleveland County
and
Charlotte Varlashkin
From: Bruce Nicholson~kl
Subj: Comments on Air Sampling Protocols for Air Stripping System
Operable Unit #1
I discussed the method proposed by ~/estinghouse with Gary
McAllister, U.S. EPA, Office of Air Quali.ty Planning and Standards,
Emission Measurement Branch. Mr. McAllister is an expert in
volatile organics air sampling. He indicated to me that
Westinghouse's proposed method (EPA SW-846 method 0030) should work
for the air stripper; however, the method only covers sample
capture techniques and not recovery and analysis. From the list of
compounds in the groundwater it may require a number af analysis
methods. [We may want to ask for the list of target compounds and
what methods they propose to use for analysis.]
The method captures volatile compounds on an adsorbent
cartridge. The cartirdges must be shipped to a laboratory, the
voc·s recovered and analyzed for the specific compounds. This may
take a week or two to accomplish. The result is an integrated
value of emissions over the length of the sampling period. This
may be unacceptable from a permitting point of view. That is, you
do not know what the air strpper emissions are for at least a week,
and then you only know an integrated value, not an instantaneous
value.
If our object is to obtain a more instantaneous value and one
that can be used onsite he suggested two alternatives:
1. A grab sample could be drawn into a tedlar bag, and an on-site
gas chromatograph could be used to obtain immediate results for
a few specified target compounds such as benzene and some
chlorinated solvents. This is close to EPA method 18 published
in 40 CFR, Part 60, Appendix A.
2. A sample could be drawn through a flame ionization analyzer
for a measurement of total hydrocarbon emissions. Although
this is less compound specific it will give an indication
whether the stipper is meeting air emission standards. For
example if you have a 0.5 lb/hr benzene standard and the total
hydrocarbon emissions are 0.3 lb/hr you know you are meeting
the benzene standard. This is close to EPA Method 25A
published in 40 CFR, Part 60, Appendix A.
• •
Mr. McAllister said he would be happy to serve as a point of
contact for Michelle Glen and/or Westinghouse if they have any
questions concerning the above methods. His number is
[phone]. In our comments, we may want to suggest that they
contact him for further information.
BIN/mem/celanesl