NCD003446721_20080414_Celeanse Corporation - Shelby Fiber_FRBCERCLA RA_Semi-Annual Reports OU-1 1998 - 2008-OCR

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NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R Matthews, Director
Ms. Beth Walden
Remedial Project Manager
Division of Waste Management
April 14, 2008
Superfund Remedial & Site Evaluation Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, ll th Floor
Atlanta, Georgia 30303
RE: Operable Unit #1 -Semiannual Report, July 2007 -December 2007
Celanese Corpor~tion NPL Site
Shelby, Cleveland County, NC
. Dear Ms. Walden:
Michael F .. Easley, Governor
William G. Ross Jr., Secretary
The North Carolina Department of Environment and Natural Resources (NC DENR) Superfund
Section has received the Operable Unit #1 -Semiannual Report, July 2007 -December 2007 for
the Celanese Corporation National Priorities List (NPL) Site. The Superfund Section has
reviewed this document and offers the following attached comments.
The NC DENR Superfund Section appreciates the opportunity to comment on this document. If
you have any questions or comments, please feel free to contact me at [phone].
Attachment
Tfeg/1(~
David B. Mattison
Environmental Engineer
NC DENR Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] I FAX [phone]\ Internet http://wastenotnc.org
An Equal Opportunity/ Affirmative Action Employer-Printed on Dual Purpose Recycled Paper
•
Ms. Beth Walden
Celanese Corporation NPL Site
Operable Unit #l -Semiannual Report,
July 2007 -December 2007
April 14, 2008
Page l
Operable Unit #1-Semiannual Report
July 2007 -December 2007
CELANESE CORPORATION NPL SITE
Table of Contents -List of Figures
•
I. Please correct the List of Figures to indicate that the titles of Figure 6 and Figure 7 are
"Ethylene Glycol and TOC at Well IT-6 and V-23" and "Ethylene Glycol and TOC at
Well F-55".
Table 3 Quarter 3, 2007 -Groundwater Analytical Summary
2. According to the laboratory analytical data submitted as Appendix A, the detections of
acetone in groundwater at monitoring wells P-58, T-35, AA-54, CC-33, EE-58,FF-34,
FF-62, GG-61, HH-48, HH-77 and TD-3 are incorrectly reported in Table 3. Please
correct these oversights.
Table 4 PEW Related Analytical Summary
3. According to the laboratory analytical data submitted as Appendix A, the detection of
acetone in groundwater at monitoring well PEW-3 is incorrectly reported in Table 4.
Please correct these oversights.
Table 6 Quarter 3, 2007 -MNA Data
4. The laboratory analytical result for the nitrate-nitrogen analysis of groundwater sample V-
. 23 was inadvertently omitted from Table 6.
Appendix A Analytical Data Packages, Field Data, and Sampling Logs
5. The Field Data and Sampling Logs were inadvertently omitted from Appendix A. Please
correct this oversight.
• •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4
61 Forsyth Street
4WD-TSS
SUBJECT:
FROM:
Atlanta, Georgia 30303-3104
MEMORANDUM
OU1 Semi-Annual Report July 2006-December 2006
David N. Jenkins, Environmental Scientist
Technical Support Section, Superfund Division
THROUGH: Scott Sudweeks, Chief, Technical Support Section,
TO:
Superfund Division
Beth Walden, Remedial Project Manager
Beth,
September DRAFT-, 2007
~ .,,,.,_.,
.,. --<,"-~• . . -. ' .•• J .. f,__Sl~-v ,., . ..,~-·'¥ .•
I read the letter response dated August 14, 2007 to EPA comments regiircli_ng;the OU1 Semiannual report
for the Celanese site dated March, 2007 as you requested. I also revieweo m:(letters to you dated June
4, 2007 and August 9, 2007. The second letter concerns the Status'Update and'Gonceptual Path
Forward for the Celanese site dated July 3, 2007. Here my comments. Please call"m'e'.at 404-562-8462 .•• ~ ~ ? if you have any questions. · "~'.,
;..'". ' -·::,.:c~>~-
GENERAL COMMENT· ,. : ' "" ,..,. '-':;: ;'
EPA must decide whether Monitored Natural Attenuation (MNA)'is-an,;{~p'i6priate remedial measure for
the remaining groundwater contamination, whethef___lhe groundwahirpumping system which has been off
for since March 2004 should be restarted, or whether other remedial:rrieasures should be implemerited.
EPA agreed to allow the pumping wells to be shut-9ff, fo~ a0study of M·N;f ·C::elanese maintains that MNA
has been shown to be effective and appropriate as 'a.remedial'ineasure f6rJhe conditions at this site. I
have recommended that EPA should not agree with ttiis,conclusi6n'.··Reasor1s-for this recommendation
are re-stated in this memo. +" · ·.. ~ • ,-: \..,·_:--~
, S-~'',"'> ~-~: :-·'. •: ·~· '.,. '.
Many of the comments in this letter ~re repetiti9_ns or rephrased comments from previous letters. These
comments were written to helpLmEi,'focus on thifJ~sues. Th'~y'are offered for the record and need not be
repeated to Celanese or EarthTecltunless yo·u·find,them pal"licularly informative. EPA has been over
these issues with Earth Tech before:;,Efforti;;tiy-the;Technical"Services Section regarding this site over the "' ,, ....... ,. __ , -'·-..,_, . ·" "7
last year have not be7~,1r,r,ocJ~<;l~e. T~~.§~me arguments are presented by both sides in each meeting or
phone conference'/8greement,<1h~_,understa_nding seem to be present during the meetings, but each
letter or report r~peats'the Celan'ese'p_ositiorithat they have proven MNA is working and they have done
enough. Each time;the arguments 'seem to gei a,little better, but this is not resulting in a cleanup at the
site. ~J~-"'< \,_ :, ,,r·,-" '~i-'o,___ --_:: __
Remediation at this site"•must be moved,beyond endless sets of technical rebuttal memos. It is my
opinion Iha ar~id} yea,rs'Jg:determine whether MNA is a viable remedial measure for this
site. Celan showri;t~aJ:M~Awill be effective in a reasonable amount of time. Source material
remains on contritiuting,to groundwater contamination. After 3 years the best argument
being offer that pumping doesn't clean up the site any faster than MNA. This argument is
not an ade to reject the remedy prescribed in the ROD.
Regarding clean-up time estimates at monitoring well V23, if concentration trends observed when the
pumps were off remain the same, groundwater quality in this area will not reach the North Carolina ARAR
for centuries (D. Jenkins letter 04JUN07). This probably would not be considered to be a reasonable
cleanup time by anyone, and better evidence for shorter cleanup times has not been presented by
Celanese. Consequently, EPA should not set aside the ROD and approve a remedial measure (MNA}
which may require centuries to achieve the remedial goals. Figure 1 O of the August 14 2007 letter from
EarthTech shows that if concentration trends observed since 2004 continue, the NC ARAR for ethylene
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glycol (14mg/L) will not be achieved for centuries in this area either. The source for contamination at F55
has not been found.
EPA and Celanese should be focused on clean-up, not arguments of whether the pumps should be
restarted. But in 3 years since the pumps were turned off, Celanese has not made an effective proposal
for source control, groundwater containment or groundwater remediation. The pumps are in place
already and are capable of removing contaminant mass from the aquifer. The pumps should be re-
started to minimize further contaminant migration. This is the remedial measure defined in the ROD. The
site is not clean, and EPA should not appear to be avoiding the remediation at this site which was defined
in the ROD for OU1. The pumps have been off for 3 years and MNA can not be·shown to achieve clean-
up in a reasonable period of time based on the data available. Alternative rem'edlal measures other than
MNA evaluated can be evaluated while the pumps are on. Ai)!'
REGARDING TCE SOURCES: <,;'.~;;,;_;J~~
The relationship between TCE observed on-site and in off-site monitoring wells off!site wells HH48 and
HH77 is not clear for the same reasons that the status of the ethylene glycol plumes•isi'unclear. The
groundwater flow system has not been defined adequately tq,,.ElliV1fnate Celanese as thei~~rce of TCE.
Celanese maintains that the TCE in the off-site wells is not,~Jt[related beq~;use TCE de~ra"2,~~on should
have progressed further during travel to the offs1te wells whIch:are 3,600,feeHrom the known;source
areas. Celanese also argues that if the contamination was sourc:1!,relatedrother site contaminants
particularly diethylene oxide (1,4-dioxane) should be present in ihese'.weils. The August 14, 2007 letter -"•'"?•,, "\'~'"°"''°t'" does not discuss the on-site concentrations of TCJ.i~QiE~. have beeri'(?.t:>\erved. The _data from the .
monitoring well network are not a_dequate to def1netlb,Eifl_~~/P.~hs follow13,a"~Y the various plumes at this
site. EPA should not reach any final conclusions reg?r.dIng 1thit,so\!rce of'l~e,TCE in groundwater in off-
site wells until the groundwater flow system is betteraefined aliaJproblerns 'reJated to the migration of the
two ethylene glycol plumes are addressed~-. • ::"·. .;I:> · ",;--::· ·, ,r.4#;~;;;~.-·,._,_ ·\: --~-'\ ~l~tt}~~--. •"
Recommendation for monitoring,Well network expansion:
A phased program should be deJighed to close· gaps in th~texisting monitoring well network. The initial
phase might include installation"orta-series o!'small.djamete1:[1iezometers be installed at numerous, ,.,.,.,<I'-,:... .-•' -· , .. , ..... , -;,:.,.-_,,. carefully selected locations throughouhlhe:site,NSome;piezometers should be installed in nests which <,,,:,.,;.,(_,,.__., ·•,.;·/ ~":"-.',·':-S~:> includes screens at varioUsTelevationsYsowertical hydraulic\gradients can be evaluated. These ,,,,..~\~:•.·.<,.•-•-, ,._.·s·'·-piezometer nests should·be·located in thtFvicinity of F55, V23, IT6, and at least at two locations in the
vicinity of the pO,!]QS;;i=our piezoffiID,e,r, ne1t-\cic<'!tions around the sides of the ponds may be required.
These piezometeis:would be intendedJor de"pth"to water measurements only. The data would be used to ~-,=•· 'i'• -~, . . determine water level'elevations and groundwater flow directions. Water quality samples would not be
collected from the p~zoineters. In the "second phase, monitoring wells constructed to be suitable for
sampling should be insia"[e.~-at selecte~I1.§cations. The groundwater monitoring network should be
supplemen pprbpriate number of staff gauges in the ponds and streams near the site.
Another ar uld ::\l~~ii:d for vertical monitoring nests is in the vicinity of the off-site
monitoring nd HH7i¥bne line of evidence offered as proof that TCE contamination in these
wells is not is shown in Figures 11 and 12 of the August 14, 2007 letter. Modeled particles
from the kn TCE source area near TD-3 and TD-4 discharge to the streams and do not flow to
these off-site wells. But the pathways do pass within 300-500 feet of the wells. Other than the two off-
site wells themselves, there are no other monitoring wells in the vicinity to which groundwater levels and
groundwater flow directions might be validated. There is no way to test the sensitivity of the model results
versus observations in the real world. Figure 13 on the August 14, 2007 letter shows TCE concentrations
in have varied greatly, but for the last 20 years typically have been between 50µg/L and 500µg/L. There
is no evidence in Figure 13 that the source is weakening. There may be seasonal effects occurring at
these wells, or some other cyclic effect, but the concentrations are not decreasing. The concentrations
typically are 60-100 times the MCL. If they have been at this level for 2 decades where has the plume
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gone down gradient? Celanese maintains that the absence of other site related contaminants at HH48
and HH77 proves the plume is not related to Celanese. Further, Celanese maintains that the apparent
absence of TCE degradation products ·in these wells points to a local source, not a source at the plant
more than 2,000 feet up gradient. These are logical arguments, but Celanese does not have monitoring
wells in the TCE plume down gradient from TD3 and TD4 which show TCE degradation either.
Groundwater flow directions in the area between the off-site wells HH48 and HH77 and Celanese
property-line wells OT5, PZ9 and GG39 should be better defined laterally and vertically. Figures 4 and 5
in the OU1 Semi-Annual Report July 2006-December 2006 show incomplete contours in this area. Staff
gauges in the streams both north and south of HH48 and HH77 might help define shallow groundwater
flow directions near the streams and help fill in the contours for this area. ,,'';,, ,,,.t~'t'
REMAINING ISSUES REGARDING GROUNDWATER CONTAMINATION:t::;
The remainder of this memo addresses various issues regarding the grot.fttciw'~ter flow system and MNA
of ethylene glycol at this site. These issues are either raised directly in1tfre~·Celanese letter of August 14,
2007 or are related to previous letters and reports. These points have Ileen raisea;in,some degree in
previous memos. Consequently, these are offered for your und,er!tanding of the site}ZlQP for the record
in support of EPA decisions regarding this site. The_ subseq~E:lntccm1ments need not bei(gl)::'arded to the
Celanese or to EarthTech unless you find them part1cularly4tQformat1ve. ,.-, '\\?::'" ~:-:;:~ ~.::.:ff/? ~,~~
Issue: Is MNA working in the ethylene glycol plumes? \'.. ·, .. ,~¢:1V
The second paragraph of the August 14, 2007 letter from Celanese7'staies "Documents submitted in
recent months presented our position that a moni/oie(IJJ,Jtural attenfi'~,tj~.[1 remedy is an appropriate
alternative to reactivation of the Inner Tier (IT) extr1J_c;tion;~!l(f,!reatment!§y§!em." EPA is not looking for
an appropriate alternative to the remedy prescribedi[n)the'RQDcfo~ OU1 ."iE_[?A is looking for remediation
of the site which restores groundwater to unrestricted:beneficfaU:ise;in,a reas"5nable period of time. EPA
reviews remedies for effectiveness, protectiveness, eti:Fin thefs'.Yeai.Review process. EPA encourages -" --·v-»'s.",··~'!',"""-' '~"'"',;,;,.<;. f:'"'"-">C'< ,._~.,;;;.»-Optimization of remedial measures..<1El;'A'has,riever agreed,tci'ii permanent rejection of the OU1 ROD . ..,. ==·,· '%"'•"•"'\ -y,;:;,~:»-F urther, if the assessment of the.l~&Tsystem described oh;page 3 of the August 14, 2007 letter
suggesting that the pumping system captured,qn)y 30 per~'l\~_t_of the contaminated flow paths is accurate,
and if natural attenuation is an appropriate ;:ilteriiative to this\itiefficient capture system, then the
recommended remedy should be a:F'&T system\,.,hich··.captures'the other 70 percent of the flow paths.
~,_.112~~•...... ':}.::tir-,.---•-•"'-t~~¢-~
Celanese has been,aware'fici'rri\their earliest proposals to use MNA at this site that EPA does not have
guidelines for Ml,'i~~;here ethyle'n;r;g1yco1"Ts1ibe, contaminant. EPA has guidelines for Monitored Natural
Attenuation of BT~J$.,and chlorinated'~otvent'con,Rounds. EPA has often stated that approval of an MNA
remediation at this'site,will require Celanese to 'step beyond the existing guidelines and apply the
methods which work'fdr/other contaminants in innovative ways if necessary. EPA has always maintained -,,;:;-;.~,/"h --~-... ,.. that if MNA was not demonstrated to be[effective at the site, the original pump and treat (P&T) remedy
Id b ,,,f¾t~ wou e r c<!itW
~_}'-_./~~;;
Proving tha effective.remedial measure at this site is up to Celanese, not EPA. EPA has
never argu al attenuafi6n isn't working at this site. Natural attenuation processes always
work some ry site to some degree. But natural attenuation is a collection of natural
processes, ial measure. Monitored Natural Attenuation is a remedial measure recognized by
EPA. MNA must be demonstrated by lines of evidence described in the EPA guidelines. Two of the 3
lines of evidence (contaminant degradation versus time and contaminant degradation versus distance)
require data from monitoring wells in the plume. EPA has challenged the lines of evidence for MNA
presented by Celanese. EPA estimates of degradation versus time (D. Jenkins letter 04JUN07) indicate
that centuries may be required before groundwater quality near monitoring well V23 approaches the NC
ARAR for ethylene glycol by relying on natural attenuation alone. Groundwater flow directions are the
basis for degradation versus distance estimates. EPA has challenged the groundwater flow directions
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presented on water level contour maps. These challenges are primarily due to inadequacy of the
monitoring well network.
The first line of evidence, contaminant degradation versus time, utilizes samples from a single well over
time. Celanese can not utilize this approach because the data for wells V23, IT6 and F55 show
concentrations which have been increasing until recently. Even if recent downward concentration trends
continue, groundwater concentrations may not reach the NC ARAR for ethylene glycol for centuries.
The second line of evidence, contaminant degradation versus distance, requires comparison of
contaminant concentrations in pairs or a series of wells between the source area(and the discharge area
for groundwater. Contaminant concentration changes along the flow path provide'estimates of
contaminant degradation rates versus distance from the source. If the water;°in'lhe second well didn't fiow
through the screen of the first well, the results of the calculations are invalkll'\;Ef'A has challenged
groundwater fiow directions based on water level contour maps prepare'clifor t~is•1_il',, and questioned
interpretations of groundwater fiow directions between monitoring wells''' Celanesif presented evidence of
degradation versus distance at selected wells on Figure 33 of the.coU'i Semi-Annu~!1°feport dated March
2007. The title of Figure 33 is "Ethylene Glycol changes with,gisiance and time". Celanese argues on
page 3 of the August 14, 2007 letter that "The report discussici'f?was not intended to assett/hat these
wells are along a shared flow path". But this is the intent of'ciegradation,v~fsus distance calc:ulations as
described in the EPA guidelines for MNA. The title of Figure 33,:ihe natu"r'e'°of the text discussion related
to this figure, and the purpose of the report as a justification of MNA:aiii'v.iere easily construed as making
exactly this interpretation. The groundwater flow,system at this sitii"isihot defined well enough to prove
degradation versus distance estimates. The monl\9:rlng,~eJLQetwork sh'o~J.~ be improved and
supplemented with additional wells so that estimates,of contaminant degfaaation versus distance can be
made according to EPA guidelines. ·/. :'.i'tf"'-'~ -~':':,
<7;4t~½. ";\!,, ~.{til)>· ~-~~-~\~,,
Issue: Is the horizontal ground':)'.'a,\~r.flow{iY.~tem deV!!~td'well enough to prove MNA is feasible?
A water level contour map is not[11cjuded in tt\~:rnany figuri~ contained in this letter from Celanese dated
August 14, 2007, but water lev~ltcontour maps,,are availablelin earlier reports. EPA has challenged many
of these maps, some of which showed contours\beneath thei1i:,i>nds as if they didn't exist, or showed "I ' ... ,"-'· ,.,,., ---'·--~ contours which crossed the streams-as.if thefweren:_t.the_re. These features can aller groundwater flow
directions and contamiriaril'migratiori"'dire'cfitns and stioulaibe considered when evaluating contaminant
migration pathways £~~t;~1'~mzc;,~.!;,:>t,, ""-'~~ ~/J/jl~~---~~~1~~~ ·\\~
EPA has challen1rea interpretations'of.naturaPiittenuation versus distance between monitoring wells
because the wells'i:hbsen could not li1dhown to:lie on the same fiow path. EPA has raised many
questions about the gro'undwater flow system at this site, about the distribution of contamination, about
degradation rates, travelffTmes, flow pattiilbetween monitoring wells, leakage and water table mounds
beneath th E~Aihas conci1:ided that the monitoring well network is not adequate for an MNA
demonstrat e sligge~Js;i/i\th'e letter dated August 14, 2007 (p.3) that the monitoring well
network m been a"clequate for the P& T remedy either. The system began pumping in
August, 19 ed until March 2004. Groundwater model calculations by EarthTech indicate that
the pumpin lured slightly less than 30 percent of the contaminated flow paths from the
source are . ave been far more effective if the monitoring well network had detected this
inefficiency during the 15 years of pumping rather than making this determination from a model years
after the system is turned off. Further, if the monitoring well network was so inadequate it was unable to
detect the failure of the pumping wells to capture and contain the plume for years, then the basis on
which EPA agreed that the wells could be shut off for an investigation of MNA was false. The plume was
not contained and contaminant migration from the source area was occurring. It seems clear that what
ever remedy is performed at this site during the next few years the monitoring well network must be
improved.
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Issue: Is the vertical groundwater flow system defined well enough to prove M NA is feasible?
EPA has noted previously that the site is located on a ridge between two surface water streams, a
situation in which vertical movement downward should be expected. The groundwater modeling work
performed for Celanese reached this same conclusion. The text on page 3 of the August 14, 2007 letter
states "Figure 9 indicates that particles tend to travel into the intermediate bedrock then travel towards the
creek and reemerge before reaching the creek." Figure 9 clearly shows downward flow paths through the
Deep Saprolite, the Shallow Bedrock and the upper portion of the intermediate bedrock before the
pathways turn more horizontal in the middle of the Intermediate Bedrock layer.
Figure 12 show another example of potential vertical groundwater flow at this site~,lt is important to note
that the vertical exaggeration on these figures is 20 to 1, so the effects of vertica'ilti'ow are exaggerated in •u,-,."'.""" these figures. But the model results show there is a strong vertical component!to groundwater flow. This
is consistent with the topographic setting of the site, and may explain the'ta'ffure>to detect contamination in
the DPT holes samples around monitoring well F55 in September, 2006. i1( co'nt~7ninant migration is
vertically downward, DPT holes 100-300 feet away from F55 might-~ea's-bnably beT!l"lcpected not to be
contaminated. The holes were not in the flow path from the source:llf the model is'/ight, the groundwater
modeling network is not adequate to reliably predict contami~afif;n-\lgration pathways. 'i"it~-~-~ vicinity of
monitoring well V23, contaminant degradation rates maybe,be[much slowe_r than suggeste\iiJiy Figure 33
of the August 14, 2007 letter because the down gradient wells'.'!'j:_Y not .~t}_i\;the flow path directly from
the source area. '"--...:·;":.,., lt/.,❖ t>-v~,,-,~-"-~b~ll?'
The failure to detect ethylene glycol in the 4 DPT\S.<l_[!IPJEl~ collected·n~pr F55 in September 2006
(Celanese letter August 14, 2007, page 6) illustrate?,fk~ymr~lem wit~f1:1~A demonstrations at this site.
When ethylene glycol concentrations at F55 were greater than-1,1,000 mgll?(August 14, 2007 page 6),
samples from four DPT holes a 100-300 of feet away~~e_re <ifng/_GJ~The DP,:T'holes found no plume and
no gradual degradation of contaminaJtC?!li]tl),t~ontamin~t~n,s}l1)PIY'tv")f[t)jit there. Celanese can't prove
whether the plume degraded before:getting•to"the DPT wells;;hadn't gotten to the DPT holes yet, or
whether the plume is migrating i_n,iqme other'dJ~ction (lati(ally or vertically) and won't ever go near the
DPT holes. The monitoring we!lJrr~iwork musfp~ improve'iljtb,provide monitoring wells in the two
ethylene glycol plumes, and the''l:CE plume s·olthat.contamiiiaht degradation versus time and distance • . ~.._,,,,_;,_ A:f:-;::;.,;.,~i:;.-., -·., -:"c' "•, ,,.~,,,_~, • • can be monitored, degradation rates,can be:calculated;)and.clean-up times can be estimated under
various potential remediatii:Jncscenarios°:'-:"·;""" •.• O:.,t? .
-$:~\1rt:.~~~t~, --:-\_-~'~,__
Issue: Is ~atur,!I~Jtenuation wo1;,~/.'}g fast,:el)__ough? . .
The pumping system operated at theIsIte for 15,years at the site, but was turned in 2004. Celanese . -,~,* . \.<.-.._~ . ',; ~-·, . presents some interesting, new arguments in the:letter of August 14, 2007. On page 1 the letter states in ""'--.,,."·'" . ·.'' regard to the pump system: "While some'mass was being removed, the concentrations at the former
source area were not detlining under the"pumping scenario any faster than they have under the recent
MNA demo iocliWith the weiisiturned off." ~,",-1::~ti'
EPA has n hethef1one:remedial method used at this site is faster than another. However, I
stated in m June 4, 2007 that:
V23 indicates that if natural attenuation rates remain unchanged, ethylene glycol
/rations in V23 will still be approximately 5,000 mg/L 27 4 years from now."
In my letter dated August 9, 2007 I stated that
" ... 300 years from now, the ethylene glycol concentration in well V23 may still be 360 times
greater than the North Carolina ARAR. A remedy which requires centuries to return
groundwater to unrestricted beneficial use does not constitute a demonstration that
Natural Attenuation is working, effective or adequate as a remedial measure".
Elsewhere in the same letter
"The time required to return the groundwater beneath this site to unrestricted beneficial use by
natural attenuation only probably should not be considered a reasonable time as required
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by the National Contingency Plan (NCP) which guides EPA remediation policy. The rate
of apparent degradation probably would not be considered by most observers to be
sufficient to return the groundwater resource to beneficial use in a reasonable period of
time."
Whether MNA is faster or slower than the original pump and treat remedy probably can not be
demonstrated with the available data. Further, the argument is irrelevant because the P&T remedy is the
remedy defined in the ROD. The data seem to show that neither method works very fast, but if
groundwater beneath the site can not be returned for beneficial use for 2-3 centuries, then clearly MNA
alone is not an adequate remedial measure. The source area remediation is incomplete and source
control measures should be implemented to remove or greatly weaken the sourcEVso that MNA can
remediate residl1al contamination in a reasonable period of time. EPA guidelffies for MNA require source ,...~,,"-'.;:;::",.. control measures be implemented before MNA can be approved as a reinedialimeasure. Celanese ,.-,,,._.,,-~"-~-..
should be directed to remediate the sources of groundwater contamina,t_i§rf. ·(th,,_
/~ ,-, ~ .. ~,_..
-$· ~,) ---... .;-, Issue: Is it necessary to improve the monitoring well netw!!rk?.--',.,.;,,
EPA guidelines for MNA and Evaluation of Capture Zones around'Pump and Treat Systems both
specifically require that the effectiveness of the remedial me~"!r/l're be based on field obsilft'ations, not
model results or calculations. For both of these remedial rrie~~yr,es, th~.n,itessary field ob!i~rvations are
obtained from monitoring wells with well screens installed at tti'ii';proper'locations and at the proper depths
to detect the contamination and track the progress,~! the remediati_o,L;EPA has maintained that the
existing monitoring well network is inadequate for{deinonstration of'MNA. Celanese is now suggesting
that the monitoring well network may never have be~·n-acteq~ate for pr8yip_g the effectiveness of the
capture zone around the pumping system either. \:&\ '""'I:.:~,. ~t,
¾."~_:,, /2~{(~~-" ::,~ ~~~
EPA has maintained in numerous comment letters thatthe groundwater flow directions at the site have
not been adequately defined. EPA.ha.sibeen concerneii:ihat1mounding~beneath the unlined ponds has ~·_3'-~~ -,;;-.--~, ,---~•-•, .,,
not been considered properly o~,._vy_~ter level co[ltour map~fp:Cesented in previous reports. The ponds are
unlined, so groundwater moundsiare likely to exist beneath,the ponds. Groundwater mounds created by
leakage from ponds may alter grb:fin_dwater fl6w19irections. ,.El\ksome of water level contour maps
prepared for this site have shown w~).J,_l_!l{E_;l;corit6ur1 •. ~r.i,yg'across the ponds as if the ponds did not
exist. ·"'"':'., ~:'..: ....... ·-.,.. ,-
-_;~:Q~t1~ ~ "~:'h,
EPA contends th§IJ(ex1sting water"'levEl[ cont~u~,.maps do not define groundwater flow directions
sufficiently to demonstrate that pairs"tt1monit6ring well screens are along the same flow path, making
calculations of degr~clation versus distance impossible. The groundwater monitoring network must be •. -·. P•• expanded. "' ~ 1x,,
,L~,;' Issue: Mu oring:well netw_ork measure vertical groundwater flow and the vertical
distributio ination?,,,{\',\_:r·
EPA guider captur'e•zor\e' delineation and MNA strongly emphasize the need to base
decisions r e remediaf"measures on field observations not on model results or calculations.
However, and calculations can quantify evidence of how ground water the flow system
works and Is in understand in the flow system. Figures 9 and 12 of the August 14, 2007
letter shows that vertical groundwater flow paths probably occur at this site. Vertical flow must be
considered in the design of the monitoring well network expansion.
Page 6 June 6, 2008 {2:05PM) C:\Documents and Settingsldmattison\My Documents\Documents\2008\NPL Site
Oocuments\Celanese Corporation\OU1 SemiAnnual Rept 0703EPA RESPONSE to Comments-Rev1.doc
DRAFT search for -and resolve questions before final print
• ® EarthTech
A 1:qca International Ltd. Company
M::;. [?.~;th \Nrilden
F<emedia! Proje:::t Manager
U ~;. f.:'.:vir0nmE"1tal Protection Agency
,:3·; F.:_:(_:;yth St. SVV
,/l..ti;-:::r',[;:, G·::or9in ~-0303
•
1455 Old Alabama Road
Suite 170
Roswell, GA 30076
C,,!c1nese Fibers Operations Site -SheiL;y, No!'!h Carn!in;;
~~f;.1Sponse to Comments OU-1 Sei11i~n;-1ua! nepo;t
· . .!u!y 2006 -December 2006
E,rt1, Tech Project No. 79750
D•JCurnent Control Number: 02GSB-25<J
P 770.990. 1400
F 770.649.8721
www.earthtech.com
·:hr~r·::-·. ye,;_; f:,;;· y[)Ut ;-:~-:tnments received via er:1c1il 00. w'u!y ·1 :3. 2007. ·. ·'.-!·:::_; i;:::!f.T r:r~..vides our
rs;~µc,nse ~11 thos;:: c . .-~n1nients and also provides 2.ciOft:cr:ai ~echnic::~: j:·i· .. ~:;:;_~,:!ti:_~/; · .sup~orting the
r~::>i-:•()nSGfL s,);:1t~ .:::~ -~;,i:-_; information was extractsr.i fr1.1r:·~ thi~ c.:onc,::~/'._ic.:> n:i:-1:\-~_.; :-r.•(>011 being
::!e·-1e]~]µ::~1J i\:•r (h.:'.: •::;{'-~ '.r,1hit:r. 1.:·-1ill be delivered to yOl! iri ti':~ i~Das fuki:.~-
L\:.:~U(,lC17t~; ;:;:/"J.:nit~~>i ii': ~e::;cnt months presented oui position the~-~;· ;r;1y-,;;:c._i :;:Jur~-; dHenuation
(MNi\) n~rnedy l:~ mi ;:ippropri3te alternative to r82di•.1at!on of thE _:,1t:.'Y -~ :r.:>t· n-;-;: sxi~action and
tre8tr1~-::::ri·,: sys~em_ VVe unch::rstand that EPA is nvt in f~l!I 3gre.E::rnent 'Aiif: ~;~:•.~ ;_:;~:;):·(_·,acr.. We also
unck-;:~~?.:"",::.I. thnt thr1re may be administrative reasonc to ~eur:ti'Jatr: the ·1 T s·;::r(2rn. Ho\~it.:;ver, based
o~: th~,:, (t:~12 v1hici1 exist, it is our opinion that the t'ViNP. npprr:,2ch c~~1r0nt)y /~:e/:ig studied is
c:quh:3\nr:t le, Hit:: effectiveness of the IT oµerat:ci, aiternative. \,Vl;b~! sci:-n-3 r.ia:-;.c_. was being
rerr;,::;vei.1, t(1c:~ ccncentratio'ns at the former soun_~E-are;:.; w,::Jt·u r.ct doc:Hi··:i!lfJ u:~der the pumping
s,.,en2.rio an1/ faster than they have under the rece11t MNA demor.stratior: par;,:d with the wells
:u,·,,:,d off. !n a letter dated July 3, 2007 (Documen: Cor,trnl ;,;umber 02GS8-252), an approach
was proposed that includad implementing the expanded rnc,nitorir.g r,·o!;rn!n t/1c:t EPA. suggested
::ind initiating a for.used feasibility study (FS) to ct•aracte;iw t!le conditions i,1 '.l1s fo,rner source
area, and to evaluate other remediation options Ce,2ne~2 wpul,; !ike to wcrk with the EPA to
implement an approach that meets the Agency's admin:strativE n:c)eds a,;d allows development c,f
meaningful technical data that will result in a bette·r long-ten11 solution fer the site. We recommend
that EP.'\ ilpprove the expanded characterization and monitsrin9 approach currently being
considered. We believe that it is a better use of res0urcr,s and will b8 equa!ly protective of human
health c1nd the environment. In addition, the developrrn,rit of tiless data along with a review of
a•,ailable remediation approaches will optimize the time required for site clc,an up and c!osure.
The following general discussions are presented as background for some of the responses
presented in this letter and are borrowed from information in a future submittal describing the
conceptual site model.
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) • Celanese F°f1Je'fs10p:er~tions Site -Shelby, North Carolina
Response to Comments OU-1 Semiannual Report
July 2006 -· December 2006
Earth Tech Project No. 79750
Document Control Number: 026SB-254
Page No. 2
General Groundwater Flow Discussion
Looking at the site data related to diethylene oxide a1~d r,·1eihc:me: provides good indicators of the
direction of groundwater movement away from the sol.lrce are3s sines; t:·,e diethylene oxide is
known to be a component of the glycol recovery uni\ bottoms (GRUB) formally disposed in the
area, and the methane represents the final degradation product ircm the m1aercbir, degradation of
the ethylene glycol Figures 1 and 2 show the general meas of ir.ipac.t of the diethylene oxide and
ethylene glycol, respectively. 1
Diethylene oxide is the best tracer for groundwater movement at the site since :t is miscible, has a
low retardation factor, and is detectible at 0.002 milligrams per liter (mg/LJ. Thus, it migrates with
the water and demonstrates the directions of flow from a scurce area. f=igure ·1 demonstrates the
portions of the site where diethylene oxide has been detected and sho,its that flow from the former
disposal area does impact the wells referenced in the report and in th0 comments. Figures 3
through 5 show cross section views of the distribution of the diethylene oxide.
Comparing diethylene oxide's physical properties io those of eti1y:ene glycol shows that the
ethylene glycol is also miscible but has an even lower retardation factor than diethylene oxide.
Thus, it should be more widely distributed than the diethylene oxide udess there is some other
factor working to retard its movement. At this site, all ihe data ,;uggest t'1at biodegradation is the
factor that effectively controls the migration of the ethylene glycol p!un;s). Cross sections are
presented on Figures 6 and 7 which show the distribution of ethylene g!yco! measured during the
January 2007 sampling event. From these it can be seen that the ethylene, glycol is very limited in
extent as compared to diethylene oxide.
Methane is the final degradation product of a large portion of the organic material from the former
GRUB disposal area. Its presence in groundwater is not uncommon, but the site data indicate that
high concentrations exist in groundwater downgradient from the former source area. The locations
of wells showing impact are shown on Figure 2 and indicate the impact from the former source
area encompasses the IT wells, wells K-28, N-29, 0-25, and CC-33 with lesser impacts shown at
wells W-23 and 0-33 even further downgradient. The wells showing the greatest impact are the IT
and the V wells immediately downgradient of the former GRUB source.
Evaluation of Former Groundwater Extraction System
To help in the assessment of the effect of restarting the extraction system, an analysis was made
of the relative effectiveness of the system when it was operating. To investigate the approximate
efficiency of the extraction system the groundwater model developed for the site was used to
simulate the capture efficiency of the system. The detailed model development, calibration, and
' For this presentation, the methane data were first normalized against the detection level by
dividing the result by the mean of the non-detect concentrations, and then, by defining "impact"
being anything greater than 10 times the normalized detection level to filter out general variations
in the data and to account for ambient levels of methane that can exist in groundwater due to other
natural organics.
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• @EarthTech
A "tqco International Ltd. Company
• Celanese Fibers Operations Site -Shelby, North Carolina
Response to Comments OU-1 Semiannual Report
July 2006 -December 2006
Earth Tech Project No. 79750
Document Control Number: 026SB-254
Page No. 3
results will be presented in the conceptual site model report to be submitted in the near future. The
assessment presented here is being provided in advance of the complete model documentation
because of the relevance to the comments.
Figures 8 and 9 present a simulated transport and fate assessment for particles which originate in
the former GRUB source area. For the purpose of this assessment, particles were introduced at
and just upgradient of the locations of the IT wells. The wells were then pumped at flow rates
based on the average flow rates observed between July 2003 and February 2004 which ranged
from approximately 40 to 340 gallons per day (gpd) per well. The assessment indicates that
slightly less than 30% of the particles from the former source area were captured by the extraction
wells. As shown in Figure 8, the remaining particles eventually travel to discharge points along the
creeks. The colors shown in the figure correspond to the model layer that the particle is in during
each point in its travel. This is shown more clearly in Figure 9, which is a composite cross section
of the same data. Figure 9 indicates that the particles tend to travel into the intermediate bedrock,
and then travel toward the creek and reemerge prior to reaching the creek. 2
Because the majority of the particles from the former source area are interpreted to bypass the
extraction system and be transported downgradient during operation, the extent of the ethylene
glycol plume is controlled by natural degradation. Once the system was deactivated the mass of
material moving downgradient was increased by approximately 30%. As the data following shut
down show, only a short period of time was required for the microbial communities to adjust to the
increased mass and altered hydraulic conditions. Once this adjustment was complete, no
significant change in the plume size or magnitude was observed. This interpretation and the
observed data are consistent.
Discussion of Comments
Monitored Natural Attenuation Approach
With the regard to ethylene glycol, the comments focus on establishing adequate evidence of
degradation versus distance and degradation versus time. In our opinion, each of these lines of
evidence has been adequately established over the past few years of work. This is supported by
the discussion and information presented in the general groundwater flow discussion.
With respect to degradation versus distance the comments include a presentation which connects
wells V-23, IT-6, K-28, 0-25, and W-23. The report discussion was not intended to assert that
these wells are along a shared flow path. The case presented in the report is that the highest
concentrations are located at adjacent wells V-23 and IT-6 and that the remaining wells (K-28,
0-25, and W-23) establish a range of downgradient locations which all demonstrate a decline in
'
' Since this is a composite cross section showing all of the modeled particle tracks, it incorporates
data both in the foreground and in the background of the cross section. This results in particles
appearing to emerge above the ground surface when they actually represent an area where the
ground surface is higher than in the cross section.
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• ® EarthTech
A 'tf./CO International Ltd. Campany
• Celanese Fibers Operations Site -Shelby, North Carolina
Response to Comments OU-1 Semiannual Report
July 2006 -December 2006
Earth Tech Project No. 79750
Document Control Number: 026SB-254
Page No. 4
concentrations away from the former source area in the flow field impacted by the source. This is
shown in plan view on Figures 1 and 2.
In previous comments, EPA expressed some concern that the current network of wells may not
provide a complete coverage of potential flow paths and there is some potential that preferential
flow paths may be present that the monitoring well network does not address. No investigation can
evaluate every possible flow path, but the objective is to monitor an adequate number of locations
so that significant gaps do not exist in the monitoring coverage. Based on the groundwater model
information summarized earlier in this document, it is our opinion that the flow direction from the
source has been documented to show that the monitoring well network is adequate.
In the September 12, 2006, meeting EPA indicated that an "alley" in the area between wells IT-6
and K-28 was their specific concern (Meeting Minutes Document Control #026SB-231) related to
monitoring. Prior to this meeting a direct push technology (DPT) investigation had been proposed
and performed in the area EPA indicated was of concern (work plan approved by EPA via email
April 5, 2006, Document Control #026SB-214). The field work included the installation of three
direct push monitoring locations with the specific purpose of addressing the EPA's concern. The
results of this investigation were presented in Document Control #026SB-229 (Summary of DPT
Results and Proposed Monitoring Well Locations, October. 10, 2006). Direct push locations
DPT-5, DPT-6, and DPT-7 were placed in the potential flow path identified as a concern by EPA
and not addressed by the existing monitoring well network. The result of ethylene glycol analysis
for each of these locations was non-detect at 7 mg/L. Furthermore, field data collected at these
locations showed that the groundwater was anaerobic and reducing which are the conditions
conducive to the presence of methane representing the areas that are downgradient in the flow
field from the former source area and had been remediated by natural processes.
These most recent comments suggest that a new well should be added. Celanese remains willing
to install this well and will work with EPA to agree on the appropriate location.
The EPA comments suggest that the low concentrations observed downgradient of the former
source area are not evidence of natural attenuation because the low concentrations probably result
from the former extraction. In prior comments (026SB-215, June 2006) EPA stated, "It would be
surprising if the ethylene glycol plume was not expanding after the system of capture wells was
turned off." Shortly after the extraction system was deactivated, wells 0-25 and K-28
downgradient of the extraction network showed increases in ethylene glycol concentrations. This
reflects the change in hydraulic conditions with the pumps off. If the recently deactivated system
was the only mechanism for controlling the ethylene glycol, then these increases would have been
maintained, at a minimum, and would likely be expected to increase the longer the extraction
system remained inactive until a stable concentration was reached at approximately the same
concentration as the source. However, the concentrations declined and became non-detect by the
April 2007 sampling event. This is because the natural biological activity had time to acclimate to
the new conditions and degrade the mass which traveled to these points. The concentrations
remain low because the natural attenuation processes remain in equilibrium with the mass
transport. Because the degradation is occurring prior to reaching these locations near the Inner
Tier, there is no reasonable potential for ethylene glycol plume to have any significant expansion.
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• ® EarthTech
A tqca International Ltd. Company
• Celanese Fibers Operations Site -Shelby, North Carolina
Response to Comments OU-1 Semiannual Report
July 2006 -December 2006
Earth Tech Project No. 79750
Document Control Number: 026SB-254
Page No. 5
The EPA comments suggest that the locations of the ponds are not accounted for in the placement
of groundwater level contours. This concern was discussed in the September 12, 2006, meeting.
The groundwater flow model was calibrated using the potentiometric head in the wells between
and adjacent to the ponds and the average water level in the ponds. The water levels in the ponds
are controlled by the plant discharge weir; therefore, the elevations are stable within a small range.
For the calibration water levels used, the potentiometric head in the wells ranged from
approximately 8 feet to 18 feet lower than the pond elevations. In order to calibrate the model,
hydraulic conductivities which accurately reflect observed data must be established. These values
were determined to be in the range of 10·5 to 10·8 centimeters per second (cm/sec). This indicates
that the hydraulic conductivity of the material is sufficiently low to serve as a liner. Calibration with
the average pond elevations and measured potentiometric head in the adjacent monitor wells
produces results which account for the ponds and provide reasonable correlation with observed
conditions. Since the modeled contours are similar to those interpreted in the reports, the reported
contours are considered representative of the conditions with the ponds in place.
With regard to changes in concentration with time, the comments present charts for wells IT-6 and
V-23. These wells are located immediately downgradient of the former source area. The OU-2
remedial action objective was waste removal and not clean closure. Therefore, residual soil impact
was expected. The result of this impact is that equilibrium has been established at these wells for
the time being. It is worth noting that the concentrations at well V-23 have not significantly
changed during the operation period of the extraction system or since it was deactivated. The
concentrations at well V-23 ranged from 2,550 to 7,700 mg/L (excluding a single outlier non-detect)
in the period of operation and ranged from 2,180 to 8,200 mg/L since extraction ceased. Although
the concentrations at IT-6 were non-detect at the time of the system deactivation, the recently
observed levels remain below the single value observed during operation of the extraction system
(5,450 mg/Lin September 2001 ). Therefore, it is not apparent that extraction was causing the area
to reach lower concentrations more quickly than the current operating mode.
The path forward for the site presented in Document Control Number 026SB-252 dated July 3,
2007, proposed a focused feasibility study to evaluate the merits of alternative activities to address
the impacted soil not removed during the OU-2 remediation. This correspondence also proposed
initiation of a statistical monitoring program that meets the data gathering approach recommended
by the EPA in our meeting held on February 1, 2007. The intent of the feasibility study and
sampling program are to provide the EPA with the information and data necessary to demonstrate
plume stability and to determine compliance with the guidance for MNA. The groundwater data
collected under this recommended sampling approach will not be meaningful if the extraction
system is restarted since pumping will change the dynamics that the monitoring is intended to
evaluate. Celanese would like to work with the EPA to identify an approach that meets the
Agency's administrative needs while allowing the implementation of the proposed approach to
develop the meaningful technical data that should result in a better long-term solution for the site.
Well F-55 Area
The conditions at well F-55 are unique and different from those in the former GRUB source area,
and represent a condition in an operational production facility. Recent data have shown that the
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8/14/2007
• @EarthTech
A tqca International Ltd. Company
• Celanese Fibers Operations Site -Shelby, North Carolina
Response to Comments OU-1 Semiannual Report
July 2006 -December 2006
Earth Tech Project No. 79750
Document Control Number: 026SB-254
Page No. 6
ethylene glycol concentrations have declined to a concentration of 4750 mg/L after having reached
a high value of 11,500 mg/Lin November 2006 (see Figure 10). The DPT evaluation performed in
September 2006 included installation of four DPT sampling locations downgradient of F-55 and did
not detect ethylene glycol at the detection level of 7 mg/L, but did show the impacts from the
ongoing biodegradation which resulted in anaerobic and reducing conditions. Subsequently, the
industrial chemical process sewer system in this area was investigated by excavating and
exposing sections of the line and performing a closed-circuit television inspection of a portion of the
main sewer and laterals that lead from the production lines inside the plant. Based this work, the
sewer and laterals appear to be intact and are not a source of leaking which could result in the
detections noted at this well (see attached summary memo; submitted without appendix containing
DVD of sewer video). There are no other ongoing sources of potential release in the area. These
data indicate that the impact is both localized and being controlled by natural processes. The
recommended approach is to install the monitoring wells recommended in the DPT report
(Document Control #026SB-229 dated October 10, 2006) to confirm control of this area of impact.
Presence of Trichloroethene (TCE) in Off-Site Wells
The only TCE detections at or above the concentrations noted at the HH wells are at wells TD-3
and TD-4. These detections were reported to EPA when they were first discovered in 1998. The
HH wells are not directly downgradient of the TD wells and there is no apparent flow path that
would allow TCE to travel from one location to the other. Figures 11 and 12 demonstrate the flow
paths from the well TD-3 and TD-4 locations based on a particle track analysis using the calibrated
flow model. As the figures show, there are no flow paths from the TD well location which approach
the HH well locations. Well M-44 is in the flow path from the TD-3/TD-4 area and was analyzed for
TCE in September 2001. TCE was detected at a concentration of 0.0012 mg/L. Wells R-17 and
R-42 located further downgradient were also analyzed at the same time and the results were non-
detect at 0.001 mg/L. The trace detection at well M-44 supports the model prediction of flow path
and also demonstrates that in addition to the flow paths not reaching the HH wells that the
concentrations have declined by orders of magnitude.
As discussed previously in this document, diethylene oxide detections serve as an excellent tracer
compound. If TCE were being transported from the site to the HH wells then diethylene oxide
detections would also be expected. Diethylene oxide has not been detected at the HH wells. In
addition, through the history of the site monitoring no significant concentrations of TCE or daughter
products have been noted at the site at locations on the groundwater flow path to the HH wells.
Lastly, the historic data at the HH wells indicates that during the early sampling events, the shallow
well detected TCE where the deeper well was non-detect, or was of a lower concentration than the
shallow well. With time, this trend reversed so that the deeper well generally has a higher
concentration than the shallow well. This is consistent with a surface release in the vicinity of the
well location which slowly migrates downward reducing the shallow concentrations while increasing
the deeper concentrations. These trends are shown on Figure 13.
There is a significant amount of physical evidence that the HH area is unrelated to the site and no
evidence beyond coincidence of proximity suggesting that they are related. If EPA will provide
L:\work\Projects\79750\WordProc\response to 2H2006 comments r1_8-14-07.doc
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8/14/2007
• ® EarthTech
A 'tf./CO International Ltd. Company
•
Celanese Fibers Operations Site -Shelby, North Carolina
Response to Comments OU-1 Semiannual Report
July 2006 -December 2006
Earth Tech Project No. 79750
Document Control Number: 026SB-254
Page No. 7
formal, specific comments so that we can better understand which information has not been
adequately presented, we will provide additional information or re-submit data as requested.
Other Comments
We apologize for the collation error regarding Appendix B. A replacement appendix has been sent
for replacement of the section in your document.
Though not addressed by the specific comments, the introduction to the comments questioned the
need to consider other site contaminants in regard to appropriate remedial measures. As
presented in our July 3, 2007, letter, a site conceptual model document is being prepared which
addresses other parameters. Furthermore, the risk assessment, which addresses all chemicals
detected at the site, is being submitted under separate cover, and demonstrates that the existing
site conditions with the wells off do not present an unacceptable risk to human health or the
environment.
The site presents several complexities both from a technical and from an administrative standpoint.
We request a meeting to discuss the responses to your comments and to cooperatively develop an
approach that addresses the administrative and technical complexities. We will contact you within
2 weeks of your receipt of this letter to discuss scheduling a meeting to discuss the information
presented and confirm a path forward. However, if you have questions in the interim, please
contact us.
Sincerely,
Earth Tech, Inc,
Bryon Dahlgren
Project Engineer
cc: Dave Mattison, NCDENR
PEM Carter, Ticona, Shelby
Tim Brooks, Ticona, Shelby
Steve Simpson, for Celanese
L:\work\Projects\79750\WordProc'response to 2H2006 comments rt_B-14-07,doc
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fr=~l~~r.~ ft-
Project Manager
8/14/2007
• •
FIGURES
Alt ~ @~""
~~ ~
00,
~ '\~
I ! i I ! ...___
...... " ., .. , .. ,
-----------------------·-··---·-·-··-----·-.__ • -J-
')J I
JJ ...
"'<0002 JJ"' .,,, .. oooz
@) EarthTech
A Tyco International Ltd. Company
Legend
DIETHYLENE OXIDE EXTENT
DIETliYLENE OXIDE
@ <0.0070
e >0.0070 (GW 2L)
MONITORING WELL
EXTRACTION WELL
PEW WELL
PIEZOMETER
--CREEK
BUILDING/STRUCTURE
D INDUSTRIAL POND
-RECREATION POND
[~~:J PROPERTY BOUNDARY
N
500 250 0
NOTES:
500
Feet
(1) CONCENTRATION UNIT: mg/L
(2) BOLD-FACED FONT: DETECTED
CONCENTRATION ABOVE GW 2L
FIGURE 1
DIETHYLENE OXIDE HORIZONTAL EXTENT MAP
SEPTEMBER 2006 DATA
CNA Holdings, lnc./Ticona
Shelby, North Carolina
JULY 2007 79750
£ 0
~ 0;
IT-tA
17.0.
IT-8 lt.O.
~ ( -
N· ~
: ,~-
0-"3 ' ..... ' . '
\
Legend
METHANE IMPACT
METHANE
0 0.000320 . 0.050000
• 0.050001 . 30.000000
MONITORING WELL
EXTRACTION WELL
PEW WELL
PIEZOMETER
__ CREEK
BUILDING/STRUCTURE
~ INDUSTRIAL POND
-RECREATION POND
,··-··7 PROPERTY BOUNDARY l--·-··
N
i
250 125 0 250
Feet
NOTE: RATION UNIT: mg/I. HOWING
(1) ~~;;c~s CRITERI~ ~t~E TIME f~PACT ABOUT ONE-HAL
FIGURE 2 OF
APPROXIMATE AR~ECTION LEVEL MES MEDIAN METHANE>lOTI JAN 2007 DATA
, lnc./Tlcona
CNA HoldN~ Carolina 79750 Shelby,
JULY 2007
A (West)
850 ~-2:.!.7 ________________ T+•-=-3 __ _,..,__
r--=(
..J (/)
:I:
<O.
800
<O.
750
ai 700 .. u.
.E
C _g .. > ~ 650
600
550
500
LEGEND
Ground Surface
Casing
Sap Screen
Deep Sap Screen
TZ Screen
Shallow BR Scrn
lntermed BR Scrn.
Deep BR Scm.
X X Top of TZ
+ + Top of BR
~ Fracture Locations
... Shallow Sap GW Elev. ... ... Deep Sap GW Elev . ... ... TZGWElev .
"' "' Shallow BR GW Elev
"' "' lntnned BR GW Elev.
"' "' Deep BR GW Elev.
_J s11allow Sap I w,1110 '''"="'
shallow BR
_____J
NOTES:
(1) All units in mg/L
w a.
(2) Samples collected in September 2006,
otherwise noted next to concentration value
(3) Groundwater Elevations measured in January 2007
EARTH ©T EC H
A 1:J/CD INTERNATIONAL LTD. COMPJ4NY
Figure 3
A' (East)
C 0 ;:: -C I! I-
"' u e "' .. Ill
Diethylene Oxide September 2006
Vertical Extent A-A'
CNA Holdings, lnc.fTicona
Shelby, North Carolina
July 2007 79750
...I 1/)
:E
850
800
750
t 700
u..
-= C: :8 ~ ..
iii 650
600
550
500
B (South) B' (North)
CC-33 IT•S IT-SR IT-7 V-23 IT-5 IT-4 K-28 l--------+--------~M~-2~8~---------,-...:..,-::--T7--7 :-,-~=--111-N-29
o.o{-0.1s J I I 0-~0 ·-j~ __J
LEGEND -Ground Surface
Caslng
Shallow Sap Screen
Deep Sap Screen
TZ Screen
Shallow BR Scrn
lntermed BR Scrn.
Deep BR Scrn.
X X Top ofTZ
+ + Top of BR .,. ... Fracture Locations
• SapGWElev . • • Deep Sap GW EJev . • • TZGWElev .
• • Shallow BR GW Elev
• • lntrmed BR GW Elev . • • Deep BR GW Elev.
shallow Sap I w,n 10 •'•"="
shallow BR
-'! s 1· 0.90 IT-3 0.03 ...,-apro 1te
0.1 :E ~ CIO M
~=============~;::==:::!0~-~38~1~0~=============~~~====~0;•;96~~;· <0.00 ~
Transition Zone
Bedrock
NOTES:
(1) All units in mg/L
(2) Samples collected in September 2006,
otherwise noted next to concentration value
(3) Groundwater Elevations measured in January 2007
EAR TH @)T EC"
A tqca INTERNAT10NAL LTD COMRIWY
5
00-150
<0.00
00-218
Figure 4
Diethylene Oxide September 2006
Vertical Extent B-B'
CNA Holdings, lnc./Ticona
Shelby, North Carolina
July 2007 79750
~ Ill ::E
850
800
j 700
u..
.E
C .S! .; t w 650
600
550
500
C (South)
Ground Surface
Casing
Shallow Sap Screen
Deep Sap Screen
TZ Screen
Shallow BR Scrn
lntermed BR Scm.
Deep BR Scrn.
X X Top ofTZ
+ + Top of BR
'!-i, Fracture Locations
• Shallow Sap GW Elev . ... ... Deep Sap GW Elev . • ... TZ GWElev . ... ... Shallow BR GW Elev ... ... lntrmed BR GW Elev . ... ... Deep BR GWElev .
shallow Sap I Woll ID plm=ot
shallow BR
0.029 NN-240
0.006 NN-280
NOTES:
(1) All units in mg/L
(2) Samples collected September in 2006,
otherwise noted next to concentration value
(3) Groundwater Elevations measured in January 2007
C' (North)
0.016 0.309
LL 10 PZ 2
Bedrock MM-170
0.019 LL-175
0.023 MM-280
0.094 LL-295
EARTH©T EC
A 'tJ/CO INTEIINATIONAL LTD COMPt4.NY
"
Figure 5
Diethylene Oxide September 2006
Vertical Extent C-C'
CNA Holdings, lnc./Ticona
July 2007
Shelby, North Carolina 79750
..J (/)
:E
850
800
750
.; 700 .,
u..
.!:
C .2
j
~ 650
600
550
500
A (West)
-27
X X
+ +
'!-.,
•
"' "' "' "' "' "' "' "' "' "'
LEGEND
Ground Surface
Casing
Sap Sc,een
Deep Sap Sc,een
TZ Screen
Shallow BR $c,n
lntermed BR Scrn.
Deep BR Sc,n.
Top ofTZ
Top of BR
Fracture Locations
Shallow Sap GW Elev .
Deep Sap GW Elev.
TZGWElev.
Shallow BR GW Elev
lntrmed BR GW Elev.
Deep BR GWElev.
shallow Sap I Woll ID pl•"="'
shallow BR
T -3
8,440
NOTES:
(1) All units in mg/L
(2) Samples collected in January 2007,
otherwise noted next to concentration value
(3) Groundwater Elevations measured inJanuary 2007
EARTH ©T EC M
A -er,ca INTfRNATIONAL LTD. COMPANY
A' (East)
Figure 6
Ethylene Glycol January 2007
Vertical Extent A-A'
CNA Holdings, lnc./Ticona
Shelby, North Carolina
Ju 2007 79750
B (South) B' (North)
850
CC-33 IT-9 IT-SR IT-7 V-23 IT•S IT·4 K-28 M-28
800 ii------;180.J J --J 56.
T < -y• Saprolite I •
< < <
""' "' "' u 'f 750 <
Transition Zone
..I fl)
:E .. QI QI
700
u.
.5
,:: 5 ~ LEGEND Bedrock 7a > -Ground Surface QI 650 iii Casing
Shallow Sap Screen
Deep Sap Screen 00-150
TZ Screen
Shallow BR Scm
600 lntenned BR Scm.
Deep BR Scm.
X X Top of TZ
+ + Top of BR
,;. ' Fractu·re Locations
T Sap GWElev. 00-21
550 "' "' Deep Sap GW Elev.
"' T TZGWElev. ., ., Shallow BR GW Elev
T T lntrmed BR GW Elev. ., ., Deep BR GW Elev.
500
shallow Sap NOTES: Figure 7 I w,n ID pOum,ot
(1) All units in mg/L ~ Ethylene Glycol January 2007
(2) Samples collected in September 2006, E A R T H T E C H Vertical Extent B-8' otherwise noted next to concentration value
(3) Groundwater Elevations measured inJanuary 2007 A 'fl/CO INTERNATIONAL LTD. COMPANY CNA Holdings, lnc./Tlcona
Shelby, North Carolina
shallow BR July 2007 79750
E--l E--l E--l
2000 feet
E A R T H ® T E C N
A 1:1/f:D INTERNATIONAL LTD. COMPANY
Figure 8
Simulated Transport
By Particle Tracking from GRUB Area
CNA Holdings, Inc / Ticona
Shelby, NC
Former GRUB Source Area
1
Shallow Saprolite / -----
Sapro te
1
I I
I
/ Deep a.drock
VI I Ill
2000 feet
E A R 1 H ® T E C H
AU/CD INTERNATIONAL LTD. COMPANY
Figure 9
Simulated Transport By Particle Tracking
from GRUB Area -West to East Section
CNA Holdings, Inc I Ticona
Shelby, NC
Ethylene Glycol Concentrations at Well F-55
-0
CJ 100000 Jt:, • -(!) ...I 10000 -• ----Cl) -. ~ . . . -~ ---~ C: Cl 1000 -.... -
Cl) E -->, 100 .c: ' ' ' ' -w '1/. ~ ¾ ~ 7o ~ 7'57. ~ ~ 7_> ~ ~ ¾ Oa 0-?, ~ Va Va Vo. 15' Oa Vo.> '57 '57 iS 15'
Date •
E A R T H @ T E C " Figure 10
Ethylene Glycol at Well F-55
A n,r:a iNTERNATTONAL LTD. COMPANY CNA Holdings, Inc/ Tirona
Shelby. NC
2000 feet
E A R T H €) T E C H
A n,r:a V'ITERNATiONAL LTD. COMPANY
Figure 11
Simulated Transport By Particle Tracking
from TD-3 and TD-4
CNA Holdings, Inc/ Ticona
Shelby, NC
•
•
•
•
2000 feet
-----=====~F~igj,'.;'u~re 12 rt"cle Tracking
rt By Pa I f n I:;;\ T E C N EARTH'=/
m, COM,'l"NY INTERNATiOf'IAL . An,r:a
Simulated Transpo -West to East Sec D 3 and TD-4 from T • /Ticona
CNA Holdings, Ince
Shelby. N
Trichloroethene at Wells HH-48 and HH-77
1 --~---------------------------------~
~ 0.1
Cl .§. .. C: a, = a, e 0 :E 0 ~ 0.01
0.001
Note: values at 0.005 and 0.010 are
non-detect
Date
E A R T H €) T E C H
A 'tlfr:D ;JJTEJ1NATTOl'IAL LID. COMPANY
--+-HH-48
~HH-77
Figure 13
Trichloroethene Changes with Time
Wells HH-48 and HH-77
CNA Holdings, Inc I Ticona
Shelby, NC
•
•
• •
ATTACHMENT
•
® Eartl'ITech
A 'tyco International ltd. Company
April 27, 2007
Steve Simpson
Celanese
1085 Lakeview Rd.
Salisbury, NC 28147-8004
Subject: Technical Memorandum
CCTV of Chemical Sewer
Ticona Plant, Shelby, NC
Earth Tech Project No. 79750
Document Control No. 026SB-249
Dear Mr. Simpson:
1.0 Introduction and Purpose
•
1455 Old Alabama Road P 770.990.1400
Suite 170 F 770.649.8721
Roswell, GA 30076 earthtech.com
At 8:40 AM on March 28, 2007, Jeff Peterman and Dave Winans of Earth Tech met the crew from
Bio-Nomic Services at the Shelby Plant. The purpose of the field effort was to have Bio-Nomic
Services televise as much of the 10-inch chemical sewer adjacent to E Building and several of the
laterals extending from the barometric sumps to the 10-inch chemical sewer as practical. The
Closed Circuit Televising (CCTV) provided a view of the pipe interior to investigate whether major
structural defects were present in the line.
2.0 Current Activities
The following section chronicles the activities that occurred on March 28, 2007.
2.1 10-inch Chemical Sewer
Jeff Peterman, Dave Winans and the Bio-Nomic Services crew met Rick Jolley with Ticona at the
4-way stop at the southeast corner of the polymer building. PEM Carter joined us and took us to
the Polymer Conference Room where we met Roger Raines and viewed a safety video related to
the polymer area.
We then met Ticona personnel in the Polymer Area Canteen where we provided a lock-out/ tag-out
lock on Box #66. Jeff Peterman also signed the hot work permit. We then broke for lunch at
11 :00 AM, to coincide with Mundy's lunch hour.
Bio-Nomic Services prepared their equipment for the CCTV work on the 10-inch line. Mundy cut
an access opening into the 10-inch steel sewer at the north end of the line, adjacent to monitoring
well F55 (see Photo 1).
L:\work\Projects\79750\WordProc\CCTV Tech Memo.doc
•
® EarthTech
A 1:f/CD lntemational Ltd. Company
•
Mr. Steve Simpson
April 27, 2007
Page 2
At 1 :25 PM the crawler camera was installed into the sewer (see Photo 2). After going about 5 feet
to the south, the camera encountered a 4-inch lateral protruding into the 10-inch sewer. The
protrusion extended approximately half-way into the 10-inch sewer, and therefore the camera was
unable to proceed any further south. The crawler camera was removed and a push camera was
prepared.
The push camera was inserted into the 10-inch sewer at 1:45 PM (see Photo 3). This smaller
camera was able to pass by the 4-inch lateral and proceed further down the line approximately
90 feet from the point of entry. The camera was removed and a stiffer cable was attached which
allowed the push camera to go further down the 10-inch line toward GBB monitoring well. The
push camera was now able to be pushed approximately 183 feet from the point of entry. This was
the extent of the camera's communication cable. The camera was removed.
2.2 6-inch lateral to Barometric Sump
At 2:45 PM the push camera was installed into the 6-inch lateral from the most northerly
Barometric Sump (Sump #1 ). This line was clogged with a white chalky material that made it
difficult to push and also coated the camera lens, making it difficult to see. The camera was able
to go only 15 feet into the 6-inch lateral before it needed to be removed.
A water hose was connected to the containment area drain that is connected to the Sump #1
lateral. The white chalky material was present in this location also.
A floor drain line from the E Building also connects to the 6-inch lateral. This floor drain line had a
clean-out which was used to insert the push camera into the line (see Photo 4). The camera was
pushed approximately 34 feet from west to east along the 6-inch line. Water was continuously run
to help flush out some of the white chalky material. There were a number of 45 degree bends in
the 6-inch lateral which limited the distance the camera was able to go.
2.3 Dye testing investigation
Dye was placed into the opening in the 10-inch chemical sewer (see Photo 5). Water from the
6-inch lateral was left running. Bio-Nomic Services staff removed manhole covers on every
manhole between the location where dye was inserted and the headworks of the wastewater
treatment plant (WWTP). The intent was to find a manhole that was connected to the 10-inch
chemical sewer such that it could be used as a point of entry for the CCTV. Dye was not seen in
any manhole. The only place dye was seen was in a rectangular vault with grating just upstream
of the parshall flume structure at the WWTP headworks (see Photo 6).
At 5:30 PM the crawler camera was inserted at this location and was directed upstream back
toward the area of G88 monitoring well (and the 4-way stop). The camera was able to go only
25 feet before a pipe fitting was encountered, preventing it from moving forward. This piping had a
significant coating of jelly-like material on the pipe wall.
L:\work\Projects\79750\WordProc\CCTV Tech Memo.doc
•
@EarthTech
A tqco International ltd. Company
•
Mr. Steve Simpson
April 2 7, 200 7
Page 3
Since there was no other entry point into the 10-inch chemical sewer, Mundy was given the
approval to seal the opening in the 10-inch line they had cut earlier in the day.
2.4 Laterals from Barometric Sumps #2 and #3
The piping at the Barometric Sumps south of the 6-inch lateral was disconnected by Mundy
personnel to allow camera access into the laterals between the sumps and the 10-inch chemical
sewer. The Bio-Nomic Services crew installed the push camera into the laterals and was able to
run completely to the connection point with the 10-inch chemical sewer in both lines. These lines
did not have the white chalky material found in the 6-inch line from Sump #1. There was
tuberculation (localized corrosion at scattered locations resulting in knob like mounds) on the
interior of both pipes that was very hard and was not impacted by the camera movement.
3.0 Results of the CCTV Work
The CCTV investigation did not identify any major piping problems in the lines that were able to be
televised. No separated welded pipe joints were found. The inverts of the lines were intact. The
connections of laterals to the 10-inch chemical sewer appeared to be sound. Coatings and
tuberculation were present in much of the system, which inhibited the detection of minor cracks in
pipe walls. However, since the piping network is comprised of steel pipe, cracking is not as likely
as with other non-metallic pipe materials.
The Bio-Nomic Services crew and Earth Tech personnel packed up the equipment, signed out of
the polymer area, and left the Shelby Plant at 6:30 PM.
A CD copy of the sewer video and a copy of the Bio-Nomic field data are attached for reference.
Figure 1 identifies the general area surveyed. If you have quesiions on the evaluation, please
contact us.
Sincerely,
Earth Tech, Inc.
-=-~~fv
Dave Winans, P.E.
Senior Environmental Engineer
cc: PEM Carter, Ticona/Shelby
Tim Brooks, Ticona/Shelby
L:\work\Projects\79750\Woro'Proc\CCTV Tech Memo.doc
~WN)j(IJ. ~-ft
Everett W. Glover, Jr. P.E.
Project Manager
• •
Photo #2 -Insertion of Crawler Camera
L:\worl<.\Projects\79750\WordProc\CCTV Tech Memo.doc
• •
Photo #3 -Push Camera Equipment
Photo #4 -Cleanout Access to 6-inch Lateral
L:\work\Projects\79750\WordProc\CCTV Tech Memo.doc
• •
Photo #5 -Dye Placed in 10-inch Sewer
,,
';", -~ ,·
.... • . . , .. I 0r.~¾"9.t.r J;o:;'.,_j
Photo #6 -WWTP Location where Dye was seen
L:\work\Projects\79750\WordProc\CCTV Tech Memo.doc
• •
BIO-NOMIC FIELD DATA
• •
B10-NOMIC SERVICES, INC.
Specializing in today's needs for errvironmen/a/ protection. 0 516 Roundtree Road• Charlotte, North Carolina 28217-2133 • (704)-529-0000 • Fax [phone]
April 4, 2007
Everett W. Glover, Jr., PE
Earth Tech
1455 Old Alabama Rd. Suite 170
Roswell, GA 30076
Greer, SC 29650
RE: CCTV Inspections
TICONA Shelby Plant
Dear Everett,
Please find enclosed 3 DVD's and three sets of reports for the CCTV work we completed on 3f28//2007.
Thank you for your business. Please let us know if we can help in any way.
Thanks again,
Buddy Anderson
A Carylon Company
• • 0 Blo-Nomlc Service, Inc.
516 Roundree Road, Chartolla, NC 28217
Tel.: (800) 782~798-Fax: [phone]
Upstream
EARTH-TECH F55
CHEMICAL LINE INSPECTION ~;;:u••m
,•~"~..,=--, PSpellM s.p-111 Refar.Me Dllfll TIIM Location jStrfft Nw and nuJDbtr) Localny ~---~i=======~-~! / 3fl6/l007 111:24:00PM I ~I HWY=~'~ .. ~--------~IIF.s"H"E"La~v-NC=-------~
r''=""°='~""=""""=~de="='="------------~.s",a...,.,a=•~m~•=•~""°="~•~•m~.,='---Rlmtolnv•rt ,=•~-=•~•'~"'~•~•-~ Rlmtoonus.
L_ _________________ Jl~Fc,55~---------"-------'-----~-----~
oowrmr,am ManhoM NllfflNf Rim to Invert Grade to 111¥,rt RIIR to Oracle UN of.._, DI~ Floll,Conttol Height rl GSB=~-------~ r-----, .===="'---~ ,c===~-~ I Downstream 11 Not contro11ect f rt 1~0"--'---· -Shape ... rial Ln. Method """ Jolnl Lenplh folaj LAnplh Lenqth Survepcl C°""'9f Star1 Co.intw Encl T9e-I Media NumMr
--~ j Cm1tar 11 steet Pipe ---~ I II II 6 !I 0000 jl 735 ii BI0-032807-AB1
V
re~•~-~•~-~ r"'~---~ r_,~,..., __ ,_,-_'""""'-------------------~ ~I --~ll~0ry __ ~I ~I a_1=_•_ic_se_FN_1CE_s ____________ ~
Fig.
cc:::::::: 0.0
0.0
Code
AEP
MWL
Description
Access Point -End of Pipe
Water Level
5. I TSI Tap, Saddle: Intruding
5.9 MSA Survey Abandoned
PosHlon Comment
UPSTREAM FSS
3
CAMERA BLOCKED BY INTRUDING TAP
•
Q Blo-Nomlc Service, Inc.
516 Rou-... Road, Charlotte, NC 28217
Tel.: [phone] -Fax: [phone]
•
Upstream
EARTH-TECH F55
CHEMICAL LINE INSPECTION ~;;tream
tP:e,IOc,Ho-"'----Pipeline Seg,nent Rm,.nce Date TtrM Location {Strff1 NatM and number) r.""'~"'-'Ny6-=--------
'--------' cl ________ __,)/ 31'28/2007 / j 1:24:00 PM ! '-'I HWY='-"'96,,,_ ________ _,l(..,s,cH,eE""LBe.Y,_N,,,c"---_______ ..J
s'="""'=''--'""'=otlon='-'"'"""'"b _____________ .,u,,p,,,,...=m'-'""=""°"=cc•ee•m,.,bo=• ___ ~•e,im,,to=I"'"'"""~--Grade to tnvert Rim to Grade
'---------------------' '-'I F~s,,s ________ _, L _____ _, L--------'L------'
aOown=e,"o_"o,'e,mc::M,n=ho=""":::'m,-,be:,:•c_ __ ~Ae,lmc:to=lncc"cc"c_ __ -"G"""'='°='"ec"cc"'--0•,.,•mc:to=--=•,.,,..:e•c___ U• of S-r Olrtdlon floW Control H•lpht
Ll G,c88e,c_ _______ __J '-----.....1 '-------' L. ____ __J '-------' I t::iaMistream I I Not controlled I ;.cl 1"'0=---
S!i!P! .... rial
'-------' I Circular 11 steef Pipe
Ln. Method Pipe Jotnl Lanpth TQtal Length Length 6UfY!Y!d couma, Start Counttr End Tapt I Media Number '--------' I I I I I 6 jl 0000 I j 735 I I BI0-032807.AB1
"p-""""""='----5-wef C!!!PY Pre-Cleanl
LI ___ _JI I I ~~: "'<,,•:::•"'=""---.,,w.,,,"="""-'--;-==:::•=·-==-"'-------------------
LI __ _JI Lj o,y __ ___JI LI e_10-_N_o_M1c_s_E_RV_1ce_s ____________ ____,
1 z..· '. !. . ' . ~ . . ..
·. ' ' r,_;~~ • • ~ .:'\ ' ~ ;r.~ l •
. ~ 'i.
' ' -~-' t ~~-=. ,'
' " ,
' ' ~•-i'. ,''•I ,.! :'ir.'•-='.:. . •\', ~ +:•, ~,.
Fig. Code Description Position Comment
0.0 AEP Access Point -End of Pipe UPSTREAM F55
0.0 MWL Water Level
-5.1 TSI Tap, Saddle: Intruding 3
--•5.9 MSA Survey Abandoned CAMERA BLOCKED BY INTRUDING TAP
• • 0 Blo-Nomlc Service, Inc.
516 Rounctree Road, Char1otle, NC 28217
Tel.: [phone] • Fax: [phone]
Upstream
EARTH-TECH G88 R N~
Downstream CHEMICAL LINE INSPECTION WWTP HEADV'w
,=•~•N~..,...=~M~-~--~ ~C..e,e,m,e,-=,:-='"--~ ;,-=="-=e,•-----~ ;,'"''"'e:'f=C=='-----DrainapAru jL A_L_B_RE_DE_MA_N_N __ _,J LI u_-_,os._1_a_J1 ___ ~I I TtCONA JI EARTH-TEOi Ii 10-a-1EMICAL LN
CHEMICAL UNE
INSPECTION
,'-... = ... ~--Plpellne ae,-n1 RefaNnct l)a TllM LoCadon (h'Nt NW and 11'"81Nr) .=""'="aclly<=~---------~---J LI --------~If Yl8f2007 If s:22:00 PM I 1.21 HWY='--"'98"'-________ _JI LI s="=E~L~•v=Nc~--------'
;:,•~-~~-~~!a' .. "!"~ua,.__ ____________ ~ Upstrum Manl'lofe Number Rlmtotnv,rt Gl'llde to lnYln Rim to Grad•
LI R~EV=E~R~S~E~S~ET=UP~------------~' ~1 Ge,88"'-'R'-______ _J L_ ____ _J ~----~~----~
DownetrHm Manhole Numbeir Rim to lnHrt ••::-=••:clnv='""--, oR,clmc,lo,cOe,-=--~ UN of a.-r otrecuon l'"wwr""''"e=H"EA"'rm=o"Ra,K"'s""Rc=~~ .=~=~--,.... .-I Process f I upstream Fio., Control H1lgtrt
11 Not a>ntrolled [ "'I 1"'0""----
.... pe ,...,... Ln. Me1hod Pipe Jotnt Unglh Tota Unqtb Lenpa. SUrv-,.d Coimt.r Start coumo, EM Tape I Med .. Numbtr
~-~' Cscular "Steel Pipe I~--~ I I I / I 26 I I 2855 If 10536 11 Bl0-032807--A81 -
V
,=C=~•=-~--,=w,~-=•~--,, ......... """""""-"'lt1f,e~e,11,,.ale,lo.e,, ___________________ ~
I LI __ _,I LI nr, __ _,J IL•_1=_M_1C_SE_,..,_1CE_s ___________ __,
Ftg. Code Description
•0.0 AOC Access Point -other Special Chamber
0.0 MWL Water Level
26.2 MSA Survey Abar-.ed
Position Comment
DOWNSTREAM WNTP HEADWORKS
CAMERA BLOCKED BY 45 DEGREE TURN
• • 0 Bio-Nomlc Service, Inc.
516 Roundlree Road, Char1otte, NC 28217
Tel.: [phone]. Fax: [phone]
EARTH-TECH ~:;·~ ti~
CHEMICAL LINE INSPECTION Down•tream WWTPHEADVII
,=•=•N~oyon=="'='"'~--~ r"""'1<m===·-=~-~r-=="-="-'-----~ r•--_,y_c ______ ~ Drainage Arn ~I A_L_B_R_E_DE_MA_N_N __ ~I ~I u_._1os_.,_8J_1 ___ ~I I r1coNA 11 EARTH-TECH 1110· CHEMICAL LN a-lEMICAL LINE
INSPECTION
r•~IO~No.~--" Pte-11,,. a.p,ent Rmre,-Om Tlcne Location (Strfft Naine and number) Locallty ~---~:::! :====:::::::::::::::::==:::====1 '"'13fl""-81200=~,-,I I 5:12:00 PM I ~I HWY=~'oo~--------~' r.1 SHef;;Es'Laacv"N"c"°"-------~
r."es""'='-='°'="ec'°"sss"'1a'"='II~•-------------Upstream Manhofe Numbu Rlm to Invert Grffll to Invert Rim w GrHe
~l·R~EV=E~R=se=se=r~u=•-------------~l l~G=88=R~------~ ~----~ ~----_J ~----~
Flow Control Height 11 Na controlled I ~I 1~0~--, -stiae-...,.. Ln. Method Pipe Joint:.... Total length LenpOI Surt'eyecl CDUIIWr start Countar End Tape I lffcfla Number
~-~/Ciroular lfsteefPipe '~--~I II 1126 112555 1)10536 IIBI0-032807-AB1
s ... , cmgory PN<leanl:7 Cleaned W.ather Addltloftlll Information ~~~ I 11 ~";. _J ~I --~I ~I °'Y __ ~I ~I e_10>10_M_1c_SE_RV_1ce_s ___________ ~
Fig. Code Description
0.0 AOC Access Point· Other Special
Chamber
0.0 MWL Water Level
~26.2 MSA Survey Abandoned
Position Comment
DOWNSTREAM WWTP HEADWORKS
CAMERA BLOCKED BY 45 DEGREE TURN
~LFOFl-ll«:H
•.
EJ ooi
0
•
1$1.FQ/Fe,..INOj
CJ,I..EU W'CE91 P0WT
llS I.FOF 1CMNCH
51lFOf4--INCH
51 lF OF 4-IHCH
""'""' "'""'
00000
LEGEND:
UNE8 THloT WERE TE..EWIED
E] """'"-"-""'
PLAN VIEW
""""
=I AERATION IIAIIIN
""""' """""'" ~ .. ~ ,.._
""""'""
Ej
\ I~: I
""''"" -~
@EarthTech
tional ltd. Company A f:rpa lntema
I
---"""""'
N
FIGURE 1
SITE LAYOUT
• • @EarthTech
A "fqco International Ltd. Company
July I 0, 2007
Ms. Beth Walden
Remedial Project Manager
U.S. Environmental Protection Agency
61 Forsyth St. SW
Atlanta, Georgia 30303
Subject: Celanese Fibers Operations Site -Shelby, North Carolina
OU-I Semiannual Report
July 2006 -December 2006
Earth Tech Project No. 79750
Document Control Number: 026SB-246
Appendix B Replacement Pages
Dear Ms. Walden:
1455 Old Alabama Road
Suite 170
Roswell, GA 30076
P 770.990.1400
F 770.649.8721
earthtech.com
The above referenced report was submitted to you in March of this year. We have determined that there
was a collation error in the preparation of Appendix B and a complete set of trend charts were not
provided as a result. A complete replacement of Appendix B is enclosed for each report.
Please contact me at [phone] if you need additional information or have questions.
Sincerely,
Earth ch,
. nD
Project Engineer
cc: Mr. Dave Mattison, NCDENR
Mr. Steve Simpson, CNA Holdings, Inc.
Ms. PEM Carter, Ticona Shelby
C:\Dornments and Seuings1Hryon.1Jahlgrenl/Je.sklop\CNA Fo!ders\shclhylCHRCLA Reportsl02 211 200612/l 2006 replace pages /cu er.doc 711012007
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• Q • •
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4
61 Forsyth Street
Atlanta, Georgia 30303-3104
4WD-TSS
SUBJECT:
MEMORANDUM
OU1 SemiAnnual Report July 2006-December 2006
David N. Jenkins, Environmental Scientist
June 4, 2007
FROM:
Technical Support Section, Superfund Division
THROUTH: Scott Sudweeks, Chief, Technical Support Section,
TO:
Superfund Division
Beth Walden, Remedial Project Manager
Beth,
I have read the OU1 Semiannual report for the Celanese site dated March, 2007 as you requested. Here
my comments. Please call me at 404-562-8462 if you have any questions.
The document reviewed is titled:
Earth Tech, 2007. Operable Unit 1 -Semiannual Report July 2006 -December 2007, CNA
Holdings/TICONA, Celanese Fiber Operations, Shelby, NC; Earth Tech, Inc., 1455 Old Alabama
Road, Suite 170, Roswell, Georgia 30076.
GENERAL COMMENT:
There are many issues regarding this report which need to be evaluated.
1. Is MNA a viable remedial measure for ethylene glycol as claimed in this report?
2. Has the claim that MNA is viable been supported by properly interpreted, site-specific
observations?
3. Should ethylene glycol be the focus of remedial measures and measure of success?
4. Are other contaminants being addressed by past and current remedial measures?
COMMENT REGARDING THE EFFECTIVENESS OF MNA AT THE CELANESE SITE:
EVIDENCE FOR DEGRADATION VERSUS DISTANCE:
The report concludes (section 4, p. 19) that MNA is a viable technology for remediation of ethylene glycol
at this site. The last paragraph of Section 3.4 includes these two statements:
"Ethylene glycol concentrations are generally stable to declining, with some fluctuations reported
in wells at the former source areas. . .. The results of these analyses provide evidence of
biological activity which clearly indicate that natural attenuation is responsible for the
ethylene glycol changes in concentration."
The last statement is undoubtedly true because the pumps are off and no other remedial measure is in
progress at this time. But an elaborate sampling program wasn't necessary to make this statement.
Whether natural attenuation is occurring is rarely, if ever, in doubt, but it is the rate of attenuation which is
important. The EPA guidelines for Monitored Natural Attenuation require estimates of the rate of
attenuation and general estimates of the time required for clean up which returns the groundwater
resource to unrestricted beneficial use. Further, this statement may not be wrong, but the supporting data
presented in this report is not adequate to definitively support the statement that MNA is a viable
technology at this site. Text on page 6 states "The MNA monitoring has shown ethylene glycol reduction
with time and distance from the source ... ". Degradation versus distance probably is occurring at this
site, as it does at all sites, but it is not proven by the graphs contained in this report.
There are two "lines of evidence" commonly used for demonstrations of MNA. These are contaminant
degradation versus distance and contaminant degradation versus time. Of these, interpretation of
contaminant degradation versus distance might be said to be difficult under the best circumstances, tricky
under complex circumstances and impossible under some circumstances, primarily because it is hard to
make the measurements in the right place. Degradation versus distance assumes that contamination is
measured at two or more points along a fiow path. The change in contamination between these points is
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()
assumed to be degradation by various natural attenuation processes. The difficulty arises in getting two
or more well screens in the same flow path between Points A and B. If the groundwater at Point A never
goes to Point B, comparing the contamination at these two points is pointless and may be misleading.
The evidence for degradation versus distance presented in this report has this problem.
Figure 33 shows ethylene glycol changes with time and distance at wells V23, IT6, K28, 025 and W23. A
line drawn on Figure 2 connecting these points shows that there is no possible groundwater flow path
between these points.
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The red line drawn on the figure above is not a possible groundwater flow path between the monitoring
wells shown on Figure 33. Unfortunately, the cross-sections presented in Figures 6 and 7 do not pass
through the screens of the well used in Figure 33, so a similar flow path can't be demonstrated in a cross-
section view. In a cross-section view, the flow path through the well screens used to show MNA should
be parallel to the groundwater fiow direction arrows like those shown on Figures 6 and 7.
It may be possible to demonstrate contaminant degradation versus distance at this site using the
available data, but this demonstration is not made in this report. A demonstration of degradation versus
distance should be attempted using pairs or groups of wells which can be shown on maps and cross-
sections to be along similar groundwater flow paths. This effort should help determine whether additional
monitoring wells are needed to insure that monitoring points are located properly down gradient from the
source area. The locations for any additional wells should include estimates of travel time and
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2007\NPL Site Documents\Celanese Corporation\OU1 SemiAnnual Rept 0703.doc
.. • •
contaminant degradation, and sh_ould be located along groundwater flow paths from contaminated wells
in the source area.
EVIDENCE FOR DEGRADATION VERSUS DISTANCE AFTER PUMP & TREAT REMEDIATION:
The application of the degradation versus distance line of evidence described in the EPA guidelines
regarding MNA should be applied carefully and should be documented fully at sites where pump & treat
systems were operated and have been turned off. The low concentrations in the down gradient wells
shown on Figure 33 probably are not evidence of natural attenuation. The concentrations probably are
low because extraction wells operated in the center of the plume for many years. The purpose of these
wells was to concentrate contamination and bring ii to the wells for extraction and treatment, and not let
the contamination reach the down gradient wells. While all of the contamination was not removed from
the aquifer by the pump & treat system, it is well documented that this system limited contaminant
migration. The Outer Tier of wells was shut off years before the Inner Tier of wells was shut down,
because the Outer Tier of wells was clean, and contamination was concentrated around the wells of the
Inner Tier.
Even if the wells selected in this report (Figure 33) to demonstrate contaminant degradation versus
distance were along the same flow path, this report does not estimate groundwater flow velocities, and
does not attempt to estimate contaminant travel times between the monitoring wells selected to
demonstrate MNA. Consequently, the report does not demonstrate that low contaminant concentrations
observed in the down gradient wells could be the result of degradation which occurred during migration
from the Inner Tier wells toward the Outer Tier wells under the hydraulic conditions which occurred after
the wells were shut off. The concentrations s_hown on Figure 33 may be low simply because
contaminated groundwater has not had enough time to reach the wells after the pumps were turned off.
RECOMMENDATION: Use water level contour maps (like Figure 2) and geologic cross-sections with
flow lines and equi-potential lines (like Figure 6) to select pairs or groups of wells which can be shown on
to be along similar groundwater flow paths between the source and natural discharge areas. Estimate
groundwater velocity between these points, estimate contaminant migration time between these points
and predict when contamination should be expected to arrive at these points based on the distance,
velocities and time since the pumps were shut off. Then evaluate the change in contaminant
concentrations which occurs over the distance between the wells.
Please note that water level contours (like Figure 2) and equi-potential lines (like Figure 6) should be
drawn and interpreted as carefully as possible. The equi-potential lines shown on Figures 6 and 7
probably are not be perfectly vertical as shown. Many well pairs on these figures have half a foot
difference in water levels, indicating some vertical hydraulic gradient is present, but this is not shown in
the equi-potential lines, and not conveyed by the groundwater flow arrows shown on these cross-
sections. The water level contour maps (like Figure 2) are drawn beneath the ponds and lagoons as if
these had no impact on the water table. Leakage from the ponds and lagoons is likely to create mounds
on the water-table which will alter groundwater flow directions. These flow direction changes must be
considered when selecting well pairs with screens along the same flow path for comparison of
degradation versus distance.
EVIDENCE FOR DEGRADATION VERSUS TIME:
Evaluations of degradation versus time are often easier to demonstrate than degradation versus time
because the comparisons are made in a single well screen. The assumption is that the flow paths
through the well are stable and unchanging over time. Regrettably, at the Celanese site this is not true
because the P& T remedial measure deliberately and successfully altered groundwater flow paths and the
distribution of contamination in the aquifer for nearly 15 years. So at this site, even degradation versus
time at a single well must be evaluated carefully because groundwater flow paths and contaminant
migration pathways may be different before and after the pumps were turned off.
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• •
Regarding evidence for ethylene glycol degradation versus time, Figure 11 shows ethylene glycol
concentrations are stable or decreasing slightly in V23, but are increasing notably in monitoring well IT6.
The data in Appendix C shows that RECENT ethylene glycol concentrations in IT6 are higher than in
September 2001. Based on groundwater flow directions shown on Figure 2, it appears that
contamination from V23 is migrating toward IT6. A change in the distribution of contamination was
expected after the P& T system shut-off. The important questions are how far will the plume expand? Will
the monitoring well network adequately detect the changes? Will the expansion stop before all of the gain
accomplished by 15 years of pumping is lost? These questions regarding migration rates and
degradation rates are not answered in the current document.
Regarding the degradation rates and the effectiveness of MNA for long-term remediation at this site, the
data presented in Figure 11 show that ethylene glycol concentrations in V23 may be decreasing slowly.
The data from Fi ure 11 are re-lotted in the followin fi ures:
Dec--04 Dec--05 Dec--06
• IT6 +-V23 · • NCARAR
"" 1,000 1D.000 1 DD.ODO
Days
• ITG +-V23 • NCARAR
PlotlodNO • 50 :I; ol 1oP<JfW'lj mt ;r1u~,--~-~-~-------~-----------~-~--~---,---,------.--~
I 'A~ l!i:IA
• start .,O' e r-c,c.;..;~·~ __ !_Or_ (da ~ @1:l (t\l'l'Ol:CT "CJ~ 14-;-;;
The upper graph shows the ethylene glycol data plotted versus sample date for wells IT6 and V23. The
upper graph shows exactly the same data in the same style as the concentration trends shown in blue on
Fipure 11. The lower graph also shows the same data, but plotted as elapsed time in days after January
1', 2004. The X-axis of the lower graph includes approximately 274 years, which is 100,000 days when
the X-axis is logarithmic and the time is measured in days. The ,dashed line through the data for V23
indicates that if natural attenuation rates remain unchanged, ethylene glycol concentrations in V23 will still
be approximately 5,000 mg/L 27 4 years from now.
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2007\NPL Site Documents\Celanese Corporation\OU1 SemiAnnual Rept 0703.doc
• •
The lower graph indicates at least two things:
The time required to return the groundwater beneath this site to unrestricted beneficial use by
natural attenuation only probably should not be considered a reasonable time as required
by the National Contingency Plan (NCP) which guides EPA remediation policy. The rate
of apparent degradation probably would not be considered by most observers to be
sufficient to return the groundwater resource to beneficial use in a reasonable period of
time.
The stability of the concentrations and longevity of the plume probably indicates a source for
ethylene glycol remains present in the aquifer. This source could be the result of 15
years of successful operation of the P& T system which had concentrated contamination
into a relatively small area. Now that the pumps are off, this contamination is free to
move under the re-established natural hydraulic gradients.
Whether the P& T system should remain off should be re-evaluated. The potential application of
enhanced attenuation measures to reduce the longevity of the source should be evaluated.
COMMENT REGARDING EVIDENCE FOR DEGRADATION VERSUS TIME AT F55:
Regarding evidence for ethylene glycol degradation versus time, Figure 13 shows ethylene glycol
concentrations are increasing in monitoring well F55. The release around F55 is believed to be different
from the other area of concern around the Inner Tier wells. Also, well F55 probably is far enough away
from the pumping wells that those effects can be ignored at this well. However, the situation has been
apparent for years, and concentrations from this newer release continue to increase. This situation
should be resolved soon. Appropriate remedial measures should be proposed and implemented.
Concentration trends generally have been increasing at F55 since contamination was first observed
(Figure 13). No clean-up time by natural attenuation can be projected by any method when
concentrations are increasing.
COMMENT REGARDING TCE IN ON-SITE AND OFF-SITE GROUNDWATER:
The report states that TCE contamination in the off-site wells HH48 and HH77 is not considered to be site
related. EPA has listened to arguments on this point in the past, but has not been fully convinced and, to
my knowledge, has only agreed to hear the evidence, but has not agreed yet that the off-site TCE
contamination is not site related. I have reviewed the EarthTech letter report dated October 10, 2006
regarding TCE in off-site wells near the Celanese site. I have also considered information in e-mails from
Everett Glover and Byron Dahlgren of EarthTech dated Nov 8, 9 and 13, 2006 and phone calls on Oct 27
and Nov 9, 2006. A draft letter on this issues to EPA RPM Ken Lucas was prepared, but not finalized due
to Mr. Lucas' transfer.
Regarding the off-site TCE, justification for dismissing Celanese from responsibility for the TCE seems to
have been that TCE has been detected on-site, but typically at concentrations less than observed in the
Elliot wells. If any degradation occurred along the 3,600 foot pathway between the Celanese buildings
and the wells, off-site concentrations should be lower than on-site concentrations, not higher, and
degradation products should be more apparent down gradient. But past concentrations on-site have
been much higher. Table 1 of the EarthTech letter dated October 10, 2006, shows that in 1998, the TCE
concentration in well TD-3 was 1.2 mg/L. This concentration is 240 times the MCL for TCE and 2.5 times
greater than the maximum concentration for TCE reported in the off-site well HH-77. In the current report,
Table 3 shows that TCE has been detected on-site in TD4 twice at concentrations about 540 times the
MCL. Table 3 shows that TCE has been detected on-site in TD3 twice at concentrations about 40 times
the MCL.
A TCE release has occurred on-site. The release has been known at least since 1998. Until the
groundwater flow paths are evaluated in a manner similar to that described elsewhere in this memo, the
potential for a connection between the site and the off-site HH wells remains unclear.
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2007\NPL Site Documents\Celanese Corporation\OU1 SemiAnnual Rept 0703.doc
• •
COMMENT REGARDING APPENDIX B AND APPENDIX C:
I was initially puzzled by the choice for the starting point on the X-axes used on all figures in Appendix B.
All 72 graphs presented in Appendix B begin in January 1980, yet the oldest data shown on any of these
graphs appears to have been obtained after 1996. If data obtained in the first 16 years shown on these
graphs is available, ii might be useful and should be shown.
Oddly, Appendix G shows a considerable amount of TOG data beginning as early as November, 1981.
These data are not graphed in Appendix B, even though the data is within the range of the X-axes of the
figures in Appendix B. If TOG is considered a surrogate for ethylene glycol, might these data be useful
for evaluating natural attenuation if plotted in Appendix B?
The fact that none of the data are shown in Appendix B seemed odd at first, until it was noted that all 9
pages of graphical results shown in Appendix B are identical. All 72 graphs show exactly the same
results from one monitoring well, ITS. One page of these graphs would have been sufficient.
Presumably, some other wells were samples since 1980, but the concentration trends versus time are not
presented in Appendix B as indicted by the title of this Appendix. ·
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2007\NPL Site Documents\Celanese Corporation\OU1 SemiAnnual Rept 0703.doc
• ® Earthlech
A tqca International Ltd. Company
March 29, 2007
Ms. Beth Walden
Remedial Project Manager
U.S. Environmental Protection Agency
61 Forsyth St. SW
Atlanta, Georgia 30303
•
Subject: Celanese Fibers Operations Site -Shelby, North Carolina
OU-I Semiannual Report
July 2006 -December 2006
Earth Tech Project No. 79750
Document Control Number: 026SB-246
Dear Ms. Walden:
On behalf of CNA Holdings, Inc., Earth Tech, Inc. is pleased to enclose two copies of the referenced
report. We have also transmitted a copy of the report to David Mattison with NCDENR for his review.
Please contact us at [phone] if you need additional information or have questions.
Sincerely,
Earth Tech, Inc.
'ft:emi/!~: JI~ t-
Project Manager
cc: Mr. Dave Mattison, NCDENR
Mr. Steve Simpson, CNA Holdings, Inc.
Ms. PEM Carter, Ticona Shelby
~~
Bryon Dahlgren
Project Engineer
C:1/Jocumenls nnd Se1ri11g.IIH0·on.n(lh/grf'nl/Je.1k10p\CA'A Fold1'rslfhell~1·1CERCLA R!!pons102 2II 2006\211 2006 coverlet/er.doc 3129/2007
m,
• ® EarthTech
A tqca International Ltd. Company
October 30, 2006
Mr. Kenneth Lucas
Remedial Project Manager
U.S. Environmental Protection Agency
61 Forsyth St. SW
Atlanta, Georgia 30303
•
1455 Old Alabama Road P 770.990.1400
Suite 170 F 770.649.8721
Roswell, GA 30076 earthtech.com
Subject: Celanese Fibers Operations Site-Shelby, North Carolina
OU-1 Semiannual Report
January 2006-June 2006
Earth Tech Project No. 79750
Document Control Number: 026SB-232
Dear Mr. Lucas:
On behalf of CNA Holdings, Inc., Earth Tech, Inc. is pleased to enclose two copies of the
referenced report. We have also transmitted a copy of the report to David Mattison with NCDENR
for his review.
We are in receipt of your comments received October 23 and 24, 2006, via email related to the
direct push investigation downgradient of wells F-55 and K-28 which contained some comments
that would impact information presented in the report. We will respond to the comments in a
response to comment letter in the near future and a formally developed report in calendar first
quarter 2007 making a formal request for modification of the remedy from pump and treat to
monitored natural attenuation. The future report will address the information requested in your
comments and will utilize the results of the update of the site specific risk assessment and the
development of the groundwater fate and transport model where appropriate.
Please contact us at [phone] if you need additional information or have questions.
Sincerely,
Earth Tech, Inc.
<p wd:/ w. /:Jt,w< ti
Everett W. Glover, Jr. P.E.
Project Manager
cc: Mr. Dave Mattison, NCDENR
Mr. Steve Simpson, CNA Holdings, Inc.
Ms. PEM Carter, Ticona Shelby
l: 1work\Projects\79750lWordProcl! H 2006 coverlerter.doc
Bryon Dahlgren
Project Engineer
10/30/2006
@EarthTech
A 'tqca International Ltd. Company
1-·larch 31, 2006
•
Mr. Kenneth Lucas
Remedial Project Manager
U.S. Environmental Protection Agency
6 I Forsyth St. SW
Atlanta, Georgia 30303
•
1455 Old Alabama Road
Suite 170
Roswell, GA 30076
Subject: Celanese Fiber Operations Site -Shelby, North Carolina
Response to NCDENR Comments on Semi Annual Rep011
Earth Tech Project No. 79747
Document Control Number: 026SB-2 I 0
Dear Mr. Lucas:
This purpose of this letter is to respond to NCDENR 's comments on the referenced report
which were provided through your e-mail to Everett Glover. A copy of the comments is
attached for reference. We agree with the comments as presented and provide specific
responses below.
Comment l: Table of Contents
There is a typob'Taph1cal error in the title of Figure 7. The correct title is Hydrological Cross
Section A-A' October 2005.
Comment 2: Groundwall'r Quality CERCLA Monitoring Wells
The text should be changed as indicated. Four groundwater samples were mitially reported as
having detections of acetone. However, three of the detections were revised to non-
detections during the validation process because of presence of acetone in associated trip
blanks. The data tables were revised to reflect this change, hut the reference to four
detections in the text was inadvertently lcll. The procedure that allowed this to occur has
been revised.
Comment 3: Groundwater Quality C~:RCLA Monitoring Wells
The text should be changed as indicated. During sample collection a few additional total
organic carbon samples were collected which were associated with the monitored natural
attenuation (MNA) program and not with the CERCLA sample program. In a few cases, the
results from these additional samples were included in Table 2. These cases include the
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"
P 770.990.1400
F 770.649.8721
earthtech.com
• @EarthTech
A "tf./CO International Ltd. Company
• Mr. Kenneth Lucas
lJ.S. Environmental Protection Agency
March 31, 2005
Page 2
wrong result being reported for well V-23, and additional data values being reported for wells
K-28 and CC-33. A revised version of Table 2 is attached. This version of Table 2
accurately reflects the CERCLA sampling program and the associated data presented in
Appendix A. The magnitudes of the results were not s1gmlicantly changed by these
corrections and none of the report conclusions are changed.
The exact changes are as fo11ows:
We11 CC-33: No associated total organic carbon sample. reported value was changed from I
mg/L to NA.
We11 K-28: The additional sample from 7/25/2005 was removed. The value removed was
2,030 mg/L. The value of 1,900 mg/L was retained.
Well V-23: The incorrect result of9,900 rng/L was replaced with the correct result of9,870
mg/L.
Comment 4: PEW--Related Samples
There is a punctuation error in this section. The text should be changed as indicated.
Comment 5: Review of Selected Historical Water-Quality Data: Monitoring Well V-23
The text should be changed as indicated. The results for MEK have been below the detection
limit (<0.005 mg/L) for the last 5 samples.
Comment 6: Table 2, Quarter 3, 2005 Groundwater Analytical Summary
As previously indicated, these data arc associated with the MNA program and not the
CERCLA sampling program. The data have been removed and a revised copy of Table 2 is
attached.
Comment 7: Table 2, Quarter 3, 2005 Groundwater Analytical Summary
As previously indicated, the total organic carbon data reported for we11 V-23 was associated
with the incorrect sample. The correct total organic carbon value is 9,870 rng/L, as indicated
in Appendix A. A revised copy of Table 2 is attached.
Thank you for providing these comments. As described above. the primary sources of error
which contributed to these issues were confusion regarding multiple samples and data values
and an error in the data management procedures. We have adapted procedures to limit the
potential for repeating of these errors in future reports.
C:\/)oc·umc11/s and Si'lli11g1·\B1.1'011. !Jahlgrf'II \f)r,.d .. top\CNA /-'o/dcr.1·L1/i,,fh;·1,(.'FRCLA Rcpunsl]/1 ."!005\U'A ropmise ( .ER( 'L. 1
repor/ 2/ / 2005.doc 0313 J /()6
sr
• ® EarthTech
A tqca lnlernal1onal Ltd. Company
Please contact us if you need additional information.
Sincerely,
Earth Tech, Inc.
-~~{V-~~
l:verctt W. Glover, Jr. P.E.
Project Manager
cc: Dave Mattison, NCDENR
Steve Simpson, C:NA Holdings, Inc.
PEM Carter, Ticona Shelby
~l\1r. Kenneth Lucas
U.S. Environmental Protection Agency
March 3 1, 2005
Page 3
60,hlgc"
Project Engineer
C:\Documents and Sctri11gsiB1J·o11 Dahlgn•11\fJcs~top\CNA Fnlrfers\shelb_1·\('ERCL! Rcpnrtsll!J J()(}5\U'A rcspo11.1c C/:.RO.,J
report 2// 1005.dnc 03/3 I /{)(J
"
• •
-----Original Message-----
From: Lucas. Ken@epamail. epa. gov [_t!l§_~-~---~-~ _:,.-~.':1,~_'.::_~---·.,.15_~_r:t~E:I2.9_~~t.l __ ~ ep_~ ___ : ___ g_~_~]
Sent, Wednesday, March 22, 2006 3,35 PM
To: Glover, Everett
Cc, [e-mail]
Subject: Celanese Semi Annual Report
Everett:
I have received the comments below from NCDENR relevant to most
recent Semi Annual Report (July 2005-December 2005).
Please review the comments and make the appropriate corrections to
your files so that similar errors will not be carried forward into
subsequent documents. You may at your discretion resubmit a revised
Semi Annual Report, or alternatively a letter report confirming that
the corrections have been made. If you elect the later option, a
copy of the letter report will be appended to the Semi Annual Report
for the record.
Thanks
Operable Unit #1 -Semiannual Report
July 2005 -December 2005
CELANESE CORPORATION NPL SITE
Table of Contents
1. Please correct the Table of Contents to indicate that the
titles of Figure 7 is ''Hydrological Cross Section A-A' October
2005".
Section 3.2 Ground-Water Quality CERCLA-Monitoring Wells
2. In accordance with the data presented in Table 2, Table 3 and
Appendix A, please correct the first paragraph of this section
to state "Of the 13 CERCLA-rnonitoring well samples analyzed
during the reporting period, seven had volatile organics
reported above the detection level (Table 2). The most
frequently reported volatiles included xylene (four
detections), trichloroethene (TCE)and benzene (three
detections each), toluene (two detections), and acetone (one
detection)."
3. In accordance with the data presented in Table 2, Table 3 and
Appendix A, please correct the second and third sentences of
the last paragraph of this section to state ''K-28 was reported
to contain 1,900 mg/Land 2,750 mg/L TOC during the 3rd and 4'"
Quarters, respectively. V-23 was reported to contain 9,870
mg/Land 9,260 mg/L TOC during the 3rd and 4th Quarters,
respectively."
PEW-Related Samples
C:\Dornme11ts and Set1i11gs\JJ1yo11.!Jaltlgre11\Deskwp',C:\'✓l Foldcn,·\shclb)·ICERCI.A R,,poris\2/I 2005\U'A rc.1po11se CENCI.A
report 21/ 2005.doc 03/31/06
• •
4. Please correct the fourth sentence of the second
paragraph of this section to state ''The other DowTherm ATM
component, 1,1-biphenyl,was detected in samples from F-55 and
PEW-3."
Section 4.0 Review of Selected Historical Water-Quality Data
Monitoring Well V-23
5. Please correct the first sentence of the second
paragraph of this section to state ''The V-23 MEK data have
generally fluctuated in a narrow range below 1 mg/L, and the
last 17 sample results have all been reported below 0.5 mg/L,
with the last 5 samples reported below the detecti.on li.mit
(<0.005 rng/L) ."
Table 2 Quarter 3, 2005 Groundwater Analytical Summary
6. Table 2 indicates that a groundwater sample was collected from
monitoring well K-28 on July 25, 2005. However, laboratory
analytical results for this groundwater sample could not be
located in Appendix A. Please clarify this discrepancy.
7. Table 2 indicates that the groundwater sample collected from
monitoring well V-23 contained 9,900 milligrams per liter
(mg/L)total organic carbon (TOC). However, the laboratory
analytical results included as Appendix A indicate that the
groundwater sample collected from monitoring well V-23
contained 9,870 mg/L TOC. Please clarify this discrepancy.
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial Site Evaluation Branch
u. S. Environmental Protection Agency, R4
Sam Nunn -Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303
phone, 404-562-8953
fax , 404-562-8788
C:1/Jocume1Jls and SC'Ui11g\\lJ1:i·011./Jnhlgn·n\!Jr•.1k1oplC,\'A Fuldcrshhdb)·\CJ:·RcLA Report.11211 2005\EPA rt•.1p(i11.1(' CERC/.A
report 211 2005.t!oc 03/3 / /()6 ,,.
Parameter Unit
acetone ma/L
benzene mq/L
2-butanone mg/L
carbon disulfide mq/L
chlorobenzene mall
cis-1,2-dichloroethene mall
eth~ !benzene mall
toluene mall
trichloroethene mg/L
x~lenes mall
total oraanic carbon ma/L
NA -Not Analyzed
mg/L -milligrams per Liter
Note: Detections are balded.
Data Table late 2005.xls
EPA Drinking
Water Standard
--
0.005
--
--
0.1
0.07
0.7
1.0
0.005
10
--
Table 2
CNA Holdings Inc. / Ticona Shelby Facility
Quarter 3 2005
Groundwater Analytical Summary
Earth Tech Project No. 79750
North Carolina C-49 K-28 P-58
2L Standard 7/26/2005 7/26/2005 7/20/2005
0.7 <0.005 0.78 <0.0074
0.001 <0.001 0.011 <0 001
4.20 <0.005 0.45 <0.005
0.7 <0.001 <0.001 <0.001
0.05 <0.001 <0.001 <0.001
0.07 <0 001 <0.001 <0 001
0.550 <0.001 <0.001 <0.001
1.0 <0.001 0.002 <0 001
0.0028 <0.001 <0.001 <0.001
0.53 <0.002 0.0056 <0.002 --NA 1,900 NA
Page 1 of 2
T-35 V-23 AA-54
7/20/2005 7/28/2005 7/21/2005
<0.0066 <0.005 <0.005
<0.001 0.014 <0.001 • <0.005 <0 005 <0.005
<0.001 0.0059 <0.001
<0.001 <0.001 <0.001
<0.001 <0.001 <0 001
<0.001 0.002 <0.001
<0 001 0.0065 <0.001
0.0016 <0.001 <0.001
<0 002 0.011 <0.002
NA 9,870 NA
•
3/31/2006
Parameter Unit
acetone mq/L
benzene mq/L
2-butanone moil
carbon disulfide mq/L
chlorobenzene moll
cis-1,2-dichloroethene mq/L
ethvlbenzene mg/L
toluene mq/L
trichloroethene mg/L
xylenes mq/L
total orqanic carbon mq/L
NA -Not Analyzed
mg/L -milligrams per Liter
Note: Detections are balded.
Data Table late 2005.xls
EPA Drinking
Water Standard
--
0.005
--
--
0.1
0.07
0.7
1.0
0.005
10
--
Table 2
CNA Holdings Inc./ Ticona Shelby Facility
Quarter 3 2005
Groundwater Analytical Summary
Earth Tech Project No. 79750
North Carolina CC-33 EE-58 FF-34
2L Standard 712512005 7122/2005 712112005
0.7 <0.005 <0.005 <0.005
0.001 0.0018 <0.001 <0.001
4.20 <0.005 <0.005 <0.005
0.7 <0.001 <0.001 <0.001
0.05 0.0024 <0.001 <0.001
0.07 0.0028 <0.001 <0.001
0.550 <0.001 <0 001 <0.001
1.0 <0.001 <0.001 <0.001
0.0028 <0 001 <0.001 <0.001
0.53 <0 002 0.0026 <0.002
--NA NA NA
Page 2 of 2
FF-62 GG-61 HH-48 HH-77
7/2512005 712112005 712012005 7120/2005
<0.0059 <0.005 <0.005 <0.015
<0.001 <0.001 <0.001 <0.003 • <0.005 <0.005 <0.005 <0.015
<0.001 <0 001 <0.001 <0.003
<0 001 <0.001 <0 001 <0.003
<0.001 <0 001 <0 001 <0 003
<0 001 <0 001 <0.001 <0.003
<0 001 <0.001 <0.001 <0 003
<0 001 <0.001 0.18 0.35
<0.002 <0.002 <0.002 0.017
NA NA NA NA
•
3/3112006
I • ..;;:;&='i;h
NCDEMR
•
North Carolina Department of Environment and Natural Resources
Dexter R Matthews, Director Division of Waste Management
March 22, 2006
Mr. Ken Lucas
Remedial Project Manager
Superfund Remedial & Site Evaluation Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 11th Floor
Atlanta, Georgia 30303
RE: Operable Unit #1 ...: Semiannual Report, July 2005 -December 2005
Celanese Corporation NPL Site
Shelby, Cleveland County, NC
Dear Mr. Lucas:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
The North Carolina Department of Environment and Natural Resources (NC DENR) Superfund
Section has received the Operable Unit #1 -Semiannual Report, July 2005 -December 2005 for
the Celanese Corporation National Priorities List (NPL) Site. The Superfund Section has
reviewed this document and offers the following attached comments.
The NC DENR Superfund Section appreciates the opportunity to comment on this document. If
you have any questions or comments, please feel free to contact me at [phone].
Attachment
Sincerely,
(j)J?>//(~
David B. Mattison
Environmental Engineer
NC DENR Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] I FAX [phone] I Internet http://wastenotnc.org
An Equal Opportunity/ Affirmative Action Employer-Printed on Dual Purpose Recycled Paper
I
Mr. Ken Lucas
March 22, 2006
Page 1
•
Operable Unit #1-Semiannual Report
July 2005 -December 2005
CELANESE CORPORATION NPL SITE
Table of Contents
•
I. Please correct the Table of Contents to indicate that the titles of Figure 7 is
"Hydrological Cross Section A-A' October 2005".
Section 3.2 Ground-Water Quality
CERCLA-Monitoring Wells
2. In accordance with the data presented in Table 2, Table 3 and Appendix A, please correct
the first paragraph of this section to state "Of the 13 CERCLA-monitoring well samples
analyzed during the reporting period, seven had volatile organics reported above the
detection level (Table 2). The most frequently reported volatiles included xylene (four
detections), trichloroethene (TCE) and benzene (three dete.ctions each), toluene (two
detections); and acetone (one detection)."
3. In accordance with the data presented in Table 2, Table 3 and Appendix A, please correct
the second and third sentences of the last paragraph of this section to state "K-28 was
reported to containl,900 mg/Land 2,750 mg/L TOC during the 3'd and 4th Quarters,
respectively. V-23 was reported to contain 9,870 mg/Land 9,260 mg/L TOC during the
3'd and 4th Quarters, respectively."
PEW-Related Samples
4. Please correct the fourth sentence of the second paragraph of this section to state "The
other DowTherrn A™ component, 1,1-biphenyl, was detected in samples from F-55 and
PEW-3."
Section 4.0 Review of Selected Historical Water-Quality Data
Monitoring Well V-23
5. Please correct the first sentence of the second paragraph of this section to state "The V-23
MEK data have generally fluctuated in a narrow range below I mg/L, and the last 17
sample results have all been reported below 0.5 mg/L, with the last 5 samples reported
below the detection limit (<0.005 mg/L)."
Mr. Ken Lucas
March 22, 2006
Page 2
Table 2
• •
Quarter 3, 2005 Groundwater Analytical Summary
6. Table 2 indicates that a groundwater sample was collected from monitoring well K-28 on
July 25, 2005. However, laboratory analytical results for this groundwater sample could
not be located in Appendix A. Please clarify this discrepancy.
7. Table 2 indicates that the groundwater sample collected from monitoring well V-23
contained 9,900 milligrams per liter (mg/L) total organic carbon (TOC). However, the
laboratory analytical results included as Appendix A indicate that the groundwater sample
collected from monitoring well V-23 contained 9,870 mg/L TOC. Please clarify this
discrepancy.
• ® EarthTech
A 1:qco International ltd. Company
March 16, 2006
Mr. Kenneth Lucas
Reme<lial Project Manager
U.S. Environmental Protection J\gL'.llCY
61 Forsyth St. SW
Atlanta, Georgia 30303
•
Sub1cct: Celanese Fibers Operations Site -Shelby, North Carolina
OU-] Semiannual Report
July 2005 -December 2005
Earth Tech Project No. 79750
Document Control Number: 02(,SB-208
Dear Mr. Lucas:
On behalf of CNA Holdings, Inc., Earth Tech. Inc. is pleased to enclose two copies of the referenced
report. We have also transmitted a copy of the report to David Mattison with NCDENR for his review.
Please contact me if you need any additional information or have any questions.
Sincerely,
Earth Tech, Inc.
1)~?.5~
Everett W. Glover, .Ir. P.E. ~
Project Manager
cc: c-·lr. Dave Mattison, NC:DENR
Mr. Steve Simpson, CN.". lloldings. Inc.
Ms. !'EM Carter. Ticona Shelby
C·'1/)oc11111c11/.1 O!l{f S,:11111~., ,//1y,m.! hrhl.v.n,11 :/ h•.1~10;•,( ,\_ J l·,,i,1, ·!, ,.1//1·//'.1'1( FIN'/.,-/ Nepon.1 ':.l / I ~'//051..:'I I _'U05 ro1 ('rl,:lh"r dru
fl/.\
• &·':f'A -~"-~-~ NCDENR
•
North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director
Mr. Ken Lucas
Remedial Project Manager
Division of Waste. Management August 17, 2005
Superfund Remedial & Site Evaluation Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 11 th Floor
Atlanta, Georgia 30303
RE: Operable Unit #1 -Semiannual Report, January 2005 -June 2005
Celanese Corporation NPL Site
Shelby, Cleveland County, NC
Dear Mr. Lucas:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
The North Carolina Department of Environment and Natural Resources (NC DENR) Superfund
Section has received the Operable Unit #I -Semiannual Report, January 2005 -June 2005 for
the Celanese Corporation National Priorities List (NPL) Site.· The Superfund Section has
reviewed this document and offers the following attached comments.
The NC DENR Superfund Section appreciates the opportunity to comment on this document. If
you have any questions or comments, please feel free to contact me at [phone].
Attachment
Sincerely,
19 avid .d. rna.ctx.s,ru / d
David B. Mattison ¥
Environmental Engineer
NC DENR Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] I FAX [phone] I Internet http://wastenotnc.org
An Equal Opportunity I Affirmative Action Employer-Printed on Dual Purpose Recycled Paper
Mr. Ken Lucas
August 17, 2005
Page I
•
Operable Unit #1 -Semiannual Report ·
January 2005 -June 2005
CELANESE CORPORATION NPL SITE
Table of Contents
•
I. Please correct the Table of Contents to indicate that the titles of Table 2, Table 3 and
Table 4 are "Summary of Selected CERCLA-Related Water-Quality Constituents (I st
Quarter 2005)", "Summary of Selected CERCLA-Related Water-Quality Constituents
(2nd Quarter 2005)", and "Summary of Selected PEW-Related Water-Quality
Constituents ( I st Quarter 2005)", respectively.
Section 3.2 Ground-Water Quality
2. Please correct the last two sentences of the last paragraph of Section 3.2 to state
"Benzene, methylene chloride and toluene results from well F-55 were assigned an "X"
qualifier by the laboratory to indicate a higher reporting limit due to matrix interference.
The "X" qualifier had no effect on data usability."
Table 2 Summary of Selected CERCLA-Related Water-Quality Constituents (I st
Quarter 2005)
3. Please revise Table 2 to include the laboratory analytical results for all samples collected
for the I st Quarter 2005 groundwater sampling event, including all samples collected for
quality assurance/quality control (QNQC) purposes. Although it may seem redundant to
include all analytical results in table format when the individual laboratory analytical
results are included in Appendix A, the use of the table format allows the reader to
quickly scan the laboratory analytical results and/or easily reference the results for
comparison to groundwater standards, QNQC purposes, verification of data included in
attached figures, etc. Therefore, Table 2 should be revised to include the laboratory
analytical results for all samples collected for the I st Quarter 2005 groundwater sampling
event. Please note that Table 2 may continue to only display the laboratory analytical
results for those contaminants that are detected, but should include the results for all of
the samples collected during the given sampling event.
Post Office Box 273210
Tampa, FL 33688-3210
813-265-2338
FAX-265-3649
Mr. Kenneth A. Lucas
U.S. EPA Region IV
Atlanta Federal Center
6 I Forsyth Street
Atlanta, GA 30303-8960
• • Kubal-Furr & Associates
Environmental Management Services
May 16, 2005
Post Office Box 80247
Simpsonville, SC 29680-0247
864-962-9490
FAX-962-5309
SUPERFUND SECTION
Re: Letter of April 14, 2005 to Steve Olp-Comments on OU-1 Semiannual Report
July 2004 -December 2004
Dear Ken:
On behalf of Celanese, I have been asked to respond to comments received from the EPA on the July 2004 -
December 2004 Operable Unit I Semiannual Report prepared by Kubal-Furr & Associates. As requested,
provided below are item-by-item responses to the specific comments in your letter.
Response to Specific Comments
1. TCE Plume at HH48 and HH77
The TCE plume referred to is located on the property formerly owned by Mr. Elliott. During the early part of
the RI/FS, abandoned drums labeled with TCE were found on Mr. Elliott's property, which is the suspected
source of the TCE found in this isolated area. The specific source of the drums and how much may have been lost
has never been determined. This issue was resolved to the satisfaction of the EPA (i.e., an isolated source
unrelated to the CFO site) some 20 years ago although Celanese has had to continue to monitor the TCE
concentrations semiannually along with its monitoring of other, on-site monitor wells.
You'll note that the text in each semiannual report describing the TCE at these locations is attributed to an
isolated source unrelated to Celanese. The agency is correct in its assertion that this is a different plume in terms
of its location and composition (TCE not ethylene glycol) and Celanese has no plans to investigate this plume
further.
We're not certain of the intended outcome of the discussion about an Excel spreadsheet. Did the agency want
us to prepare our tables a certain way, submit an Excel spreadsheet, or what exactly? Further elaboration on this
comment/request by the agency would be helpful.
2. Benzene Plume at V23 and K28 --
When .the Inner and Outer Tier and the ground-water treatment system were operating, the semiannual report
histo'rically evaluated pumpage, treatment efficiencies, and trends in water quality conditions. The remedy at the
,, -• • Mr. Kenneth A. Lucas -2 -May 16, 2005
time was pump and treat and the purpose of the semiannual report was to present information on how well this
system was accomplishing its objective of cleaning up the ground water to meet the ARARs. A more appropriate
place to discuss attenuation of benzene would be in the monitored natural attenuation report; either that, or
perhaps combine the MNA and semiannual reports so all data/discussion could be found in one place. As an
aside, although the focus of the work plan for the MNA demonstration project is oriented toward the degradation
of ethylene glycol, it states that all constituents found at the site in excess of the remediation goals (including
benzene) will be remediated to the satisfaction of all ARARs as specified in the ROD.
3. Table of Contents
There are only four tables in the report, not six, and it appears they are all correctly labeled in the table of
contents except for use of the word "Data" rather than "Constituents." Do we need to issue replacement pages to
correct this word?
4. Work Performed 2nd Qtr. 2004-Free Product DowTherm®A Bailing-Well F-55
A table summarizing the product removal at F-55 is attached. The values presented in the most recent
semiannual report are correct based on these data and it appears the earlier semiannual reports may have been in
error. In the early days of this bailing program, the work was done by both Kubal-Furr and, on occasion,
Ticona. It's possible that some of these data were not reported or available when the earlier reports were
prepared. The attached table should be an accurate indication of total product removed since March of 2002.
5. Table 2 -Summary of Selected CERCLA-Related Water-Quality Constituents
Can the agency be more specific about the analyses they want presented in this request? We report the duplicates
but typically do not report samples such as trip blanks, equipment blanks, or field blanks. If there is a problem with
those QA/QC samples, they are discussed in the data assessment summary report as to their affect on data usability.
We don't place all the sample results in the tables unless a well has a reportable result and then only include
constituents that were detected. Otherwise, we would just be reproducing the lab reports in our tables. More
specificity by the agency as to this comment would be useful.
Ken, I believe this covers all the items addressed in your letter. Please give me a call after you've had a
chance to review this information if you have any questions or want to discuss these items further.
Sincerely,
Kubal-Furr & Associates
-i&/4-?1{__
Jerry E.1Kubal, P.G.
Presideht
cc: .AJavid Mattison, DENR
Dan Flynn, Esq., Rich Hanlon, Rick Ramirez, Steve Olp, Celanese
PEM Carter, Ticona
Everett Glover, EarthTech
Kubal-Furr & Associates
•,,
J
OowTherm Recovery Ticona Shelby, Well F-55
Product Bailer Product Cumulative Cumulative
Date DTW (ft) DTP (ft) (ft) Dia (in) Removed (in) Volume (Gal) Volume (L) Volume (Gal) Volume (L)
3/1/02 40.69 N/A N/A 1.6 48 0.42 1.58 0.42 1.58
3/20/02 N/A N/A N/A 1.6 12.5 0.11 0.41 0.53 1.99
4/29/02 N/A N/A N/A 1.6 22 0.19 0.72 0.72 2.72
5/23/02 N/A N/A N/A 1.6 81 0.71 2.67 1.43 5.39
6/4/02 N/A N/A 0 1.6 0 0.00 0.00 1.43 5.39 • 12/12/02 40.93 56.79 1.71 0.75 150 0.29 1.09 1.71 6.47
2/25/03 40.41 57.75 0.75 0.75 113. 75 0.22 0.82 1.93 7.29
3/12/03 40.32 58.2 0.34 0.75 28.5 0.05 0.21 1.98 7.50
5/13/03 39.61 58.28 0.25 0.75 11.75 0.02 0.09 2.01 7.59
8/8/03 38.2 57.8 0.73 0.75 44 0.08 0.32 2.09 7.90
10/8/03 37.38 58.3 0.24 0.75 24.5 0.05 0.18 2.14 8.08
3/1/04 34.03 58.4 0.14 0.75 20 0.04 0.14 2.18 8.23
5/20/04 37.33 58.41 0.13 0.75 18 0.03 0.13 2.21 8.36 8/5/04 37.42 . >58.54 0 0.75 51.5 0.10 0.37 2.31 8.73
11/8/04 37.22 58.2 0.34 0.75 64 0.12 0.46 2.43 9.19
2/10/05 37.04 57.48 1.06 0.75 67.5 0.13 0.49 2.56 9.68
•
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
4WD SRSEB
Mr. Steve Olp
CNA Holdings, Inc., c/o Celanese
2848 Cherry Road -Suite I 00
Rock Hill, SC 29730
f5)[g@(g0\YJ[g~
llll APR 2 0 2005 lW
SUPERFUND SECTION
IAPR 1 4 2005.
Subject: ... EPA's comments on Kubal-Furr Associates, 2005, Operable Unit 1 Semiannual
Report July 2004 -December 2004, CNA Holdings, lnc./Ticona, (F.K.A.
Celanese Fiber Operations) Shelby, North Carolina, Kubal-Furr Associates,
Simpsonville, SC 29680-0247, March 2005.
Dear Mr. Olp:
The purpose of this letter is to transmit the U.S. Environmental Protection Agency's
comments on the OU I Semiannual report, July 2004 -December 2004. Please provide a written
response to each of the concerns identified below:
I. TCE Plume at HH48 & HH77
The text on page 9 refers to TCE concentrations at HH48 and Hl-177. Graphs showing
TCE concentrations in these wells are presented in Attachment 2. TCE concentrations in
these wells arc consistently much greater than the MCL. The lateral and vertical extent of
the TCE plume is not presented. No graphical infom1ation regarding the concentrations
ofTCE degradation products is presented. Is natural attenuation working on this plume?
Figures 2 and 3 show that these wells are located far from the Inner Tier pumping wells
and would never have been controlled by this extraction system. This is a different plume
both in terms of it's location.and it's composition (TCE not ethylene glycol).
Your response should include historical information related to this plume, which is not
detailed in this report, that will answer the following questions:
I) What is the source?
2) How big is it?
3) Where is it going?
Internet Address (UAL) • http://www.epa.gov
• •
Additionally, sample results displayed in an EXCEL spreadsheet would facilitate
reviewofthe records for exceedances of the MCLs and detect exceedances even if these
were not originally chemicals of concern.
2. Benzene Plume at V23 & K28
Attachment 2 shows that there is a benzene plume at V23 and K28. Concentrations at
both wells are irregularly approaching the MCL. But these reports contain no discussions
of natural attenuation of benzene and do not present any interpretation of these data. The
benzene plume should be evaluated according to EPA guidelines for MNA ofBTEX
compounds.
3. Table of Contents
Please correct the Table of Contents to indicate that the titles of Table 4, Table 5 and
Table 6 are "Summary of Selected CERCLA-Related Water-Quality Constituents (3rd
Quarter 2004)", "Summary of Selected CERCLA-Related Water-Quality Constituents
(4th Quarter 2004)", and "Summary of Selected PEW-Related Water-Quality
Constituents (3rd Quarter 2004)", respectively.
4. Work Performed 2nd Qtr. 2004 -Free Product DowTherm®A Bailing -Well F-55
Review of the previous semiannual reports (July 2002 -December 2002, January 2003 -
June 2003, July 2003 -December 2003, and January 2004-June 2004) indicates that the
actual total amount ofDowTherm®A recovered as of December 2002, June 2003,
December 2003, and June 2004 was 5.6-liters (L), 6.7-L, 7.2-L, and 7.47-L respectively.
Therefore, the total amount ofDowTherm®A recovered by December 2004 should be
8.30-L rather than the 9.19-L cited in the third sentence of this section. Please correct the
second and third sentences.
5. Table 2 -Summary of Selected CERCLA-Related Water-Quality Constituents
Please revise Table 2 to include the laboratory analytical results for all samples collected
for the 3rd Quarter 2004 groundwater sampling event, including all samples collected for
quality assurance/quality control (QA/QC) purposes.
2
• •
As stated previously, please provide a written response to each of the above comments
within 30-days of your receipt of this letter. If you have any questions, please call me at 404-
562-8953.
Enclosure
cc: David 8. Mattison, NC DENR
~
Kenneth A. Lucas
Remedial Project Manager
Superfund Remedial and Site Evaluation Branch
Jerry Kubal, P.G., Kubal-Furr & Associates
Dave Jenkins, SRTSB
3
• &iiA •
NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R. Matthews, Director
Mr. Ken Lucas
· Remedial Project Manager
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, I I th Floor
Atlanta, Georgia 30303
Division of Waste Management
March 30, 2005
RE: Operable Unit #1 -Semiannual Report, July 2004-December 2004
Celanese Corporation NPL Site
Shelby, Cleveland County, NC
Dear Mr. Lucas:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received and reviewed the Operable Unit #1 -Semiannual Report, July 2004 -
December 2004 for the Celanese Corporation National Priorities List (NPL) Site. The Superfund
Section offers the following attached comments.
The Superfund Section of the NC DENR appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at' (919) 733-
2801, extension 349.
Attachment
Sincerely, <v _:_;: !31{ yJ6
David B. Mattison
Environmental Engineer
NC Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone [phone] \ FAX [phone] \ Internet http://wastenotnc.org
An Equal Opportunity/ Affirmative Action Employer-Printed on Dual Purpose Recycled Paper
Mr. Ken Lucas
March 30, 2005
Page I
•
Operable Unit #1 -Semiannual Report
July 2004 -December 2004
CELANESE CORPORATION NPL SITE
Table of Contents
•
I. Please correct the Table of Contents to indicate that the titles of Table 4, Table 5 and
Table 6 are "Summary of Selected CERCLA-Related Water-Quality Constituents (3rd
Quarter 2004)", "Summary of Selected CERCLA-Related Water-Quality Constituents
(4th Quarter 2004)", and "Summary of Selected PEW-Related Water-Quality
Constituents (3rd Quarter 2004)", respectively.
Work Performed
2nd Quarter 2004
Free Product DowTherm®A Bailing-Well F-55
2. Review of the previous semiannual reports (July 2002 -December 2002, January 2003 -
June 2003, July 2003 -December 2003, and January.2004-June 2004) indicates that the
actual total amount ofDowTherrn®A recovered as of December 2002, June 2003,
December 2003, and June 2004 was 5.6-liters (L), 6.7-L, 7.2-L, and 7.47-L respectively.
Therefore, the total amount ofDowTherrn®A recovered by December 2004 should be
8.30-L rather than the 9.19-L cited in the third sentence of this section. Please correct the
second and third sentences of this oversight.
Table 2 Summary of Selected CERCLA-Related Water-Quality Constituents (3rd
Quarter 2004)
3. Please revise Table 2 to include the laboratory analytical results for all samples collected
for the 3rd Quarter 2004 groundwater sampling event, including all samples collected for
quality assurance/quality control (QNQC) purposes.
\ l
I •~--.~ ~·· -]r: __ _
NCDENR
•
!Jorth Carolii72 Department of Environment a,,d !~atural Resources
Mr. Ken Lucas
Remedial Project Manager
Superfund · Branch
Waste Management Division
US EPA Region IV
6 I Forsyth Street, I I th Floor
Atlanta, Georgia 30303
September 15, 2004
RE: Operable Unit #1 -Semiannual Report, January 2004-June 2004
Celanese Corporation NPL Site
Shelby, Cleveland County, NC
Dear Mr. Lucas:
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received and reviewed the Operable Unit #I -Semiannual Report, January
2004 -June 2004 for the Celanese Corporation National Priorities List (NPL) Site. The
Superfund Section offers the following attached comments.
The Superfund Section of the NC DENR appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349.
Attachment
Sincerely,
1)Jl'J/;;£ ,c~n~
David B. Mattison, CHMM
Environmental Engineer
NC Superfund Section
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1
Mr. Ken Lucas
September 15, 2004
Page I
• •
OPERABLE UNIT #1 -SEMIANNUAL REPORT,
JANUARY 2004 -JUNE 2004
CELANESE CORPORATION NPL SITE
Table of Contents
I. Please correct the Table of Contents to indicate that the titles of Table 4, Table 5 and
Table 6 are "Summary of Selected CERCLA-Related Water-Quality Constituents (I st
Quarter 2004)", "Summary of Selected CERCLA-Related Water-Quality Constituents
(2 nd Quarter 2004)", and "Summary of Selected PEW-Related Water-Quality
Constituents (I st Quarter 2004)", respectively.
2. Please correct the Table of Contents to indicate that the title of Figure I is "Site Location
Map".
Work Performed
2nd Quarter 2004
Free Product DowTherm®A Bailing-Well F-55
3. Review of the previous semiannual reports (July 2002-December 2002, January 2003 -
June 2003, and July 2003 -December 2003) indicates that the actual total amount of
DowTherrn®A recovered in December 2002, June 2003 and December 2003 was 5.6
liters (L), 6.7 L, and 7.2 L, respectively. Therefore, the total amount ofDowTherrn®A
recovered by June 2004 should be 7.47 L rather than the 8.35-L cited in the fourth
sentence of this section. Please correct this oversight.
Analytical Test Results
CERCLA-Monitor Wells
4. Please correct the last sentence of the second paragraph of this section to state, "Affected
monitor well samples shown in Table 4 included K-28, P-58, CC-33, FF-34, FF-62, and
GG-61."
Table 3 Inner Tier Production Data (January 2004 -February 2004)
5. The Average Daily Flow (ADF) data given in Table 3 for January 2004 and February
2004 does not agree with the CNA Holdings, Inc. (CNA) production records included as
Attachment 2. Please clarify this discrepancy.
• •
Mr. Ken Lucas
September 15, 2004
Page 2
6. Please correct the note given at the bottom of Table 3 to state, "Average Daily Flow
based on CNA production records (Attachment 2), calculated as total flow divided by
the number of days in the month."
Table 4 Summary of Selected CERCLA-Related Water-Quality Constituents (I 't
Quarter 2004)
7. Please revise Table 4 to include the laboratory analytical results for all samples collected
for the I SI Quarter 2004 groundwater sampling event, including all samples collected for
quality assurance/quality control (QNQC) purposes.
Table 5 Summary of Selected CERCLA-related Water-Quality Constituents (2 nd
Quarter 2004)
8. Please revise Table 5 to include the laboratory analytical results for all samples collected
for the 2nd Quarter 2004 groundwater sampling event, including all samples collected for
QNQC purposes.
Table 6 Summary of Selected PEW-Related Water Quality Constituents (I st Quarter
2003)
9. Please revise Table 6 to include the laboratory analytical results for all samples collected
for the I SI Quarter 2004 groundwater sampling event, including all samples collected for
QNQC purposes.
i • &,?'A .;;;;;;;;;;:;:-;;,:~-,"-~-~-•
NCDENR
North Carolina Department of Environment and Natural Resources
Dexter R /0atthews, Director
Mr. Ken Lucas
Remedial Proj eel Manager
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 11 th Floor
Atlanta, Georgia 30303
RE: Operable Unit #I -Semiannual Report, July 2003 -December 2003
Celanese Corporation NPL Site
Shelby, Cleveland County, NC
Dear Mr. Lucas:
Michael F, Easley, Governor
William G. Ross Jr , Secretary
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received and reviewed the Operable Unit #1 -Semiannual Report, July 2003 -
December 2003 for the Celanese Corporation National Priorities List (NPL) Site. The Superfund
Section offers the following attached comments.
The Superfund Section of the NC DENR appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349.
Attachment
Sincerely,
VJttfffe':~,.~
David B. Mattison, CHMM
Environmental Engineer
NC Superfund Section
1646 Mail Service Cenier. Raleigh, l~orth Carolina 27699-1646
Phone [phone] I F/\X 819-715-3605 I Internet http//wastenotnc.org
Mr. Ken Lucas
April 21, 2004
Page I
OPERABLE UNIT #1 -SEMIANNUAL REPORT,
JULY 2003 -DECEMBER 2003
CELANESE CORPORATION NPL SITE
Table of Contents
•
I. Please correct the Table of Contents to indicate that the titles of Table 4, Table 5 and
Table 6 are "Swnmary of Selected CERCLA-Related Water-Quality Constituents (3'd
Quarter 2003)", "Swnmary of Selected CERCLA-Related Water-Quality Constituents
(4th Quarter 2003)", and "Summary of Selected PEW-Related Water-Quality
Constituents (3'd Quarter 2003)", respectively.
2. Please correct the Table of Contents to indicate that the title of Figure 1 is "Site Location
Map".
Work Performed
4th Quarter 2003
Free Product DowTherm®A Bailing-Well F~55
3. Review of the previous semiannual reports (July 2002 -December 2002 and January
2003 -June 2003) indicates that the total amount of DowTherm®A recovered in
December 2002 was 5.6 liters rather than the 6.5 liters cited and that the total amount of
DowTherm®A recovered in June 2003 was 6.7 liters rather than the 7.6 liters cited.
Likewise, the total amount ofDowTherm®A recovered by December 2003 should be 7.2 liters rather than the 8.1 liters cited in the fourth sentence of this section. Please clarify
these discrepancies.
Analytical Test Results
Discussion of Analytical Test Results
CERCLA-Monitor Wells
4. Please correct the second sentence of the second paragraph of this section to state, "V-23
and K-28 reportedly contained only two of the same volatiles: benzene (0.014 mg/L
[milligrams per liter] and 0.0075 mg/L, respectively) and toluene (0.0060 mg/Land
0.0016 mg/L, respectively)."
PEW-Related Samples
5. Please correct the second sentence of the second paragraph of this section to state, "1,1-
Biphenyl was reported as present in well PEW-3 (0.039 mg/L) as was biphenyl ether
(0.15 mg/L)."
I •
Mr. Ken Lucas
April 21, 2004
Page 2
Table 3
• •
Inner Tier Production Data (July 2003 -December 2003)
6. The Average Daily Flow (ADF) data given in Table 3 for October 2003, November 2003
and December 2003 does not agree with the CNA Holdings, Inc. (CNA) production
records included as Attachment 1. Please correct this oversight.
Table 4 Summary of Selected CERCLA-Related Water-Quality Constituents (3rd
Quarter 2003)
7. Please revise Table 4 to include the laboratory analytical results for all samples collected
for the 3rd Quarter 2003 groundwater sampling event, including all samples collected for
quality assurance/quality control purposes.
Table 5 Summary of Selected CERCLA-related Water-Quality Constituents (4'h
Quarter 2003)
8. Please revise Table 5 to include the laboratory analytical results for all samples collected
for the 4th Quarter 2003 groundwater sampling event, including all samples collected for
quality assurance/quality control purposes.
Table 6 Summary of Selected PEW-Related Water Quality Constituents (3 rd Quarter
2003)
9. Please revise Table 6 to include the laboratory analytical results for all samples collected
for the 3rd Quarter 2003 groundwater sampling event, including all samples collected for
quality assurance/quality control purposes.
North Carolina
Department of Environment and Natural
Resources
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Mr. Ken Lucas ·
Remedial Project Manager
Superfund Branch
Waste Management Division
US EPA Region IV
6 I Forsyth Street, I 1th Floor
Atlanta, Georgia 30303
October 15, 2003
RE: Operable Unit #1 -Semiannual Report, January 2003 -June 2003
Celanese Corporation NPL Site
Shelby, Cleveland County, NC
Dear Mr. Lucas:
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received and reviewed the Operable Unit #1 -Semiannual Report, January 2003
-June 2003 for the Celanese Corporation National Priorities List (NPL) Site. The Superfund
Section offers the following attached comments.
The Superfund Section of the NC DENR appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349.
Attachment
Sincerely, PJ gHJ~~/1
David B. Mattison." t~MM
Environmental Engineer
NC Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: v.•ww.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ 10% POST CONSUMER PAPER
Mr. Ken Lucas
October 15, 2003
Page I
•
OPERABLE UNIT #1 -SEMIANNUAL REPORT,
JANUARY 2003 -JUNE 2003
CELANESE CORPORATION NPL SITE
Table of Contents
•
I. Please correct the Table of Contents to indicate that the titles of Table 4, Table 5 and
Table 6 are "Summary of Selected CERCLA-Related Water-Quality Constituents (1 st
Quarter 2003)", "Summary of Selected CERCLA-Related Water-Quality Constituents
(2nd Quarter 2003)", and "Summary of Selected PEW-Related Water-Quality
Constituents (I st Quarter 2003)", respectively.
2. Please correct the Table of Contents to indicate that the title of Figure I is "Site Location
Map".
Work Performed
I st Quarter 2003
OU-I Monitor Well Sampling
3. Please revise the second sentence of this section to state, "The samples were analyzed in
the field for pH, temperature, conductance and turbidity; and, by the laboratory for
volatile organic compounds (VOCs) using EPA Method 8260B."
2nd Quarter 2003
Monitor Well Sampling
4. Please revise the second sentence of this section to state, "These wells were analyzed in
the field for pH, temperature, conductivity and turbidity; and, by the laboratory for
TOC by Method 9060."
Free Product DowTherm®A Bailing-Well F-55
5. Review of the previous semiannual report (July 2002 -December 2002) indicates that the
total amount of DowTherrn®A recovered by December 2002 was 5.6 liters rather than the
6.5 liters cited in the second sentence of this section. Likewise, the total amount of
DowTherrn®A recovered by June 2003 should be 6.7 liters rather than the 7.6 liters cited
in the fourth sentence of this section. Please clarify these discrepancies.
Mr. Ken Lucas
October I 5, 2003
Page 2
• •
Analytical Test Results
Discussion of Analytical Test Results
PEW-Related Samples
6. Please correct the fifth sentence of the first parai,'Taph of this section to state, "PEW-4
reportedly contained the volatiles benzene (0.0040J mg/L) and cis-1,2-dichloroethene
(0.0039J mg/L)."
Table 4 Summary of Selected CERCLA-Related Water-Quality Constituents (I st
Quarter 2003)
7. Please revise Table 4 to include the laboratory analytical results for all samples collected
for the I st Quarter 2003 groundwater sampling event, including all samples collected for
quality assurance/quality control purposes.
Table 5 Summary of Selected CERCLA-related Water-Quality Constituents (2nd
Quarter 2003)
8. Please revise Table 5 to include the laboratory analytical results for all samples collected
for the 2nd Quarter 2003 groundwater sampling event, including all samples collected for
quality assurance/quality control purposes.
Table 6 Summary of Selected PEW-Related Water Quality Constituents (I st Quarter
2003)
9. Please revise Table 6 to include the laboratory analytical results for all samples collected
for the I st Quarter 2003 groundwater sampling event, including all samples collected for
quality assurance/quality control purposes.
North Carolina •
Department of Environment and Natural
Resources
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Mr. Ken Lucas
Remedial Project Manager
Superfund Branch
Waste Management Division
US EPA Region IV
6 I Forsyth Street, 11 th Floor
Atlanta, Georgia 30303
•
June 20, 2003
RE: Operable Unit #1 -Semiannual Report, July 2002 -December 2002
Celanese Corporation NPL Site
Shelby, Cleveland County, NC
Dear Mr. Lucas:
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received and reviewed the Operable Unit #I -Semiannual Report, July 2002 -
December 2002 for the Celanese Corporation National Priorities List (NPL) Site. The Superfund
Section offers the following attached comments.
The Superfund Section of the NC DENR appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349.
Attachment
David B. Mattison, CHMM
Environmental Engineer
NC Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ 10% POST CONSU~lER PAPER
Mr. Ken Lucas
June 20, 2003
Page I
•
OPERABLE UNIT #1 -SEMIANNUAL REPORT,
JULY 2002 -DECEMBER 2002
CELANESE CORPORATION NPL SITE
Analytical Test Results
Discussion of Analytical Test Results
CERCLA-Monitor Wells
•
I. Please correct the third sentence of the third paragraph of this section to state, "Monitor
well CC-33 reportedly contained cis-1,2-dichloroethene (0.0025 mg/L) and
trichloroethene (0.0059 mg/L)."
Process Point Samples
2. Please correct the second sentence of the first paragraph of this section to state, "The 3rd
Quarter Inner Tier influent sample reportedly contained the volatiles acetone (0.12 mg/L),
benzene (0.031 mg/L), chlorobenzene (0.017 mg/L), 2-butanone (0.026 mg/L), cis-1,2-
dichloroethene (0.0044 mg/L), toluene (0.001 I mg/L), trichloroethene (0.0037 mg/L),
vinyl chloride (0.0015 mg/L), chloromethane (0.0016 mg/L) and carbon disulfide (0.0061
mg/L)."
PEW-Related Samples
3. Please correct the fifth sentence of the first paragraph of this section to state, "Chloroform
was reported as present at PEW-I (0.0022 mg/L), and PEW-I and PEW-4 reportedly
contained benzene (0.0021 mg/Land 0.0041 mg/L, respectively), cis-1 ,2-dichloroethene
(0.0014 mg/Land 0.010 mg/L, respectively) and trichloroethene (0.0062 mg/Land 0.017
mg/L, respectively)."
Table 4 Summary of Selected CERCLA-Related Water-Quality Data (3'd Quarter
2002)
4. Please revise Table 4 to include the laboratory analytical results for all samples collected
for the 3rd Quarter 2002 groundwater sampling event, including all samples collected for
quality assurance/quality control purposes.
,,
Mr. Ken Lucas
June 20, 2003
Page 2
Table 5
• •
Summary of Selected CERCLA-related Water-Quality Data (41h Quarter
2002)
5. Please revise Table 5 to include the laboratory analytical results for all samples collected
for the 4th Quarter 2002 groundwater sampling event, including all samples collected for
quality assurance/quality control purposes.
Table 6 Summary of Selected PEW-Related Water Quality Constituents (3rd Quarter
2002)
6. Please revise Table 6 to include the laboratory analytical results for all samples collected
for the 3rd Quarter 2002 groundwater sampling event, including all samples collected for
quality assurance/quality control purposes.
Figure 5 Potentiometric Surface Map, Shallow Saprolite, November 7, 2002
7. Figure 5, as submitted, is the Potentiometric Su,jace Map, Deep Saprolite/Upper
Bedrock, August 1, 2002. However, Figure 5 should be Potentiometric Su,jace Map,
Shallow Saprolite, November 7, 2002. Please correct this oversight.
• • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ·-----
REGION 4 ' ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW \· Ii ' 11 I I ' I( ATLANTA, GEORGIA 30303-8909
NOV -4 2002
4WD-NSMB
Mr. Steve Olp
Sr. Remediation Manager
Celanese Americas Corp-:·
2300 Archdale Dr.
P.O. Sox 32414
Charlotte, NC 28232
SUBJ: Celanese NPL Site
· Shelby, NC
Dear Mr. Olp:
October 30, 2002
The Environmental Protection Agency (EPA) has reviewed the September 26,
2002 Operable Unit #1 -Semiannual Report, January 2002 -June 2002. The report
does not have to be revised, but these comments should be incorporated into the next
report. In addition, please send two copies of the next semiannual report to EPA
instead of one. ,
If you have any questions, please give me a call at 404-562-8824.
Sine
/ Gi elle S. Bennett
Remedial Project Manager
cc: David Mattison, NC DENR
John Blanchard, B& V
Jerry E. Kubal, Kubal &.Furr
......
Recycled/Recyelabl• • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)
• •
OPERABLE UNIT #1 -SEMIANNUAL REPORT, JANUARY 2002 -JUNE
2002
CELANESE CORPORATION NPL SITE
Table of Contents
1. Please correct the Table of Contents to indicate that the title of Figure 1 is "Site
Location".
2. Please include a list of acronyms.
Work Performed
3. Please define the acronym "PEW" in the second sentence of this section.
1st Quarter 2002
OU-1 Process Point Sampling
4. Please define the acronyms "GC/FID" and "TCLP" in the second and third
sentences of this section
Analytical Test Results Discussion of Analytical Test Results
Process Point Samples
5. Please correct the first sentence of the second paragraph of this section to state,
"While no volatiles were reported above the detection level in the Inner Tier
effluent sample for the 1st Quarter, the Inner Tier effluent sample reportedly
contained the following qualified volatile results in the 2nd Quarter: acetone
(0.020 mg/L} and 2-butanone (0.0058 mg/L)."
6. Please correct the third sentence of the second paragraph of this section to
state, "Inner Tier effluent TOC was reported as 12.1 mg/L and 12.9 mg/L for the
1st and 2nd Quarters, respectively."
PEW-Related Samples
7. Please correct the first paragraph of this section to state, "Of the four PEW-
related samples collected (three samples plus one duplicate) during the 1st
Quarter, three (PEW-1, PEW-1 duplicate and PEW-4) had more than one
volatile or semivolatile constituent reported as present. Benzene was reported
as present at PEW-4 (0.005 mg/L); chloroform at PEW-1 (0.0025 mg/L) and
PEW-1 duplicate (0.0023 mg/L); cis-1,2-dichloroethene in PEW-1 (0.0018
mg/L), PEW-1 duplicate (0.0017 mg/L) and PEW-4 (0.008 mg/L); methylene
chloride in PEW-1 duplicate (0.0015 mg/L), PEW-3 (0.0013 mg/L) and PEW-4
(0.0018 mg/L); and, trichloroethene in PEW-1 (0.0064 mg/L), PEW-1 duplicate
(0.0055 mg/L} and PEW-4 (0.0078 mg/L)."
- 1 -
• • Review of Selected Historical Water-Quality Data
8. Is anything proactive being planned for the offsite TCE?
' Table 1
'
2002 Sampling Matrix -CNA Holdings, lnc.fTicona -Shelby, NC
9. Please define the multiple acronyms used in Table 1.
Table 3 Inner Tier Production Data, January 2002 -June 2002
L
10. The values given for average daily flow (ADF) for well lT-9 in Table 3, with the
exception of January 2002, do not agree with the values given for ADF for well
IT-9 in Attachmen(1. Please clarify this discrepancy.
Table 4 Summary of Selected CERCLA-related Water-Quality Data~(1•1
Quarter 2002)
11. In accordance with the Table of Contents, please correct the title of Table 4 to
state, "Summary of Selected CERCLA-related Water-Quality Data (1 st Quarter
2002)".
12. In accordance with the laboratory analytical results included in Attachment 2,
please correct Table 4 to indicate that the sample collected from groundwater
monitoring well K-28 contained no detectable concentrations of carbon disulfide
at a laboratory detection limit of 0.0011 milligrams per liter (mg/L).
13. In accordance with the laboratory analytical results included in Attachment 2,
please correct Table 4 to indicate that the sample collected from groundwater
monitoring well V-23 contained no detectable concentrations of benzene at a
laboratory detection limit of 0.0011 X mg/L, no detectable concentrations of
carbon disulfide at a laboratory detection limit of 0.0053X mg/L, no detectable
concentrations of chlorobenzene at a laboratory detection limit of 0.00S0X mg/L,
no detectable concentrations of 1,2-dichloroethane at a laboratory detection limit
of 0.00S0X mg/L, and no detectable concentrations of trichloroethene at a
laboratory detection limit of 0.00S0X mg/L.
14. Please revise Table 4 to define the laboratory qualifier "X".
15. In accordance with the laboratory analytical results included in Attachment 2,
please correct Table 4 to indicate that the Inner Tier influent sample contained
no detectable concentrations of trichloroethene at a laboratory detection limit of
0.0020 mg/L.
16. · Please include the remediation goal for each constituent. ·
- 2 -
Table 5 • • Summary of Selected CERCLA-related Water-Quality Data (2nd
Quarter 2002)
17. In accordance with the Table of Contents, please correct the title of Table 5 to
state, "Summary of Selected CERCLA-related Water-Quality Data (2nd Quarter
2002)".
18. In accordance with the laboratory analytical results included in Attachment 2,
please correct Table 5 to indicate that the Inner Tier influent sample contained
0.037 mg/L benzene and 0.024 mg/L chlorobenzene.
19. In accordance with the laboratory analytical results included in Attachment 2,
please correct Tab1e 5 to indicate that the Inner Tier effluent sample contained
0.020 mg/L acetone.
20. Please revise the last column heading in Table 5 to state, "Inner Tier ~ffluent
(Duplicate)".
' 21. In accordance with the laboratory analytical results included in Attachment 2,
please correct Table 5 to indicate that the duplicate Inner Tier effluent sample
contained 0.030 mg/L acetone.
Table 6 Summary of Selected PEW-Related Water Quality Constituents (1 st
Quarter 2002)
22. In accordance with the laboratory analytical results included in Attachment 2,
please correct Table 6 to indicate that the duplicate PEW-1 sample contained
0.0015 mg/L methylene chloride.
23. In accordance with the laboratory analytical results included in Attachment 2,
please correct Table 6 to indicate that the PEW-4 sample contained 0.0078 mg/L
trichloroethene.
Figure 1
24. The "V" for well V-23 looks like a check. Please correct.
-3 -
North Carolina • Department of Environment and Natural
Resources
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Dexter R. Matthews, Director
Ms. Giezelle Bennetl
Remedial Project Manager
Superfund Branch
Waste Management Division
US EPA Region IV
61 Forsyth Street, 11 th Floor
Atlanta, Georgia 30303
•
October 21, 2002
RE: Operable Unit #1 -Semiannual Report, January 2002 -June 2002
Celanese Corporation NPL Site
Shelby, Cleveland County, NC
Dear Ms. Bennett:
The Superfund Section of the North Carolina Department of Environment and Natural Resources
(NC DENR) has received and reviewed the Operable Unit #1 -Semiannual Report, January 2002
-June 2002 for the Celanese Corporation National Priorities List (NPL) Site. The Superfund
Section offers the following attached comments.
The Superfund Section of the NC DENR appreciates the opportunity to comment on this
document. If you have any questions or comments, please feel free to contact me at (919) 733-
2801, extension 349. ·
Attachment
Sincerely,
Dcu.;1-.cl.. .6 . rflrJ},i..s~ / d)_
David B. Mattison, CHMM
Environmental Engineer
NC Superfund Section
1646 Mail Service Center, Raleigh, North Carolina 27699-1646
Phone: [phone] \ FAX: [phone] \ Internet: www.enr.state.nc.us
AN EQUAL OPPORTUNITY\ AFFIRMATIVE ACTION EMPLOYER -50% RECYCLED/ 10% POST CONSUMER PAPER
Ms. Giezelle Bennett
October 21, 2002
Page I
•
OPERABLE UNIT #1 -SEMIANNUAL REPORT,
JANUARY 2002 -JUNE 2002
CELANESE CORPORATION NPL SITE
Table of Contents
•
1. Please correct the Table of Contents to indicate that the title of Figure 1 is "Site
Location".
Work Performed·
2. Please define the acronym "PEW'' in the second sentence of this section.
I st Quarter 2002
OU-1 Process Point Sampling
3. Please define the acronyms "GC/FID" and "TCLP" in the second and third sentences of
this section
Analytical Test Results
Discussion of Analytical Test Results
Process Point Samples
4. Please correct the first sentence of the second paragraph of this section to state, "While no
volatiles were reported above the detection level in the Inner Tier effiuent sample for the
1st Quarter, the Inner Tier effiuent sample reportedly contained the following qualified
volatile results in th~ 2nd Quarter: acetone (0.020 mg/L) and 2-butanone (0.0058 mg/L)."
5. Please correct the third sentence of the second paragraph of this section to state, "Inner
Tier effiuent TOC was reported as 12.1 mg/Land 12.9 mg/L for the 1st and 2nd Quarters,
respectively."
PEW-Related Samples
6. Please correct the first paragraph of this section to state, "Of the four PEW-related
samples collected (three samples plus one duplicate) during the 1st Quarter, three (PEW-
!, PEW-I duplicate and PEW-4) had more than one volatile or semivolatile constituent
reported as present.· Benzene was reported as present at PEW-4 (0.005 mg/L);
chloroform at PEW-I (0.0025 mg/L) and PEW-I duplicate (0.0023 mg/L); cis-1,2-
dichloroethene in PEW-I (0.0018 mg/L), PEW-I duplicate (0.0017 mg/L) and PEW-4
(0.008 mg/L); methylene chloride in PEW-I duplicate (0.0015 mg/L), PEW-3 (0.0013
Ms. Giezellc Bennett
October 21, 2002
Page 2
• •
mg/L) and PEW-4 (0.0018 mg/L); and, trichloroethene in PEW-I (0.0064 mg/L), PEW-I
duplicate (0.0055 mg/L) and PEW-4 (0.0078 mg/L)."
Table I 2002 Sampling Matrix -CNA Holdings, Inc.fficona -Shelby, NC
7. Please define the multiple acronyms used in Table I.
Table 3 Inner Tier Production Data, January 2002 -June 2002
8. The values given for average daily flow (ADF) for well IT-9 in Table 3, with the
exception of January 2002, do not agree with the values given for ADF for well IT-9 in
Attachment I. Please clarify this discrepancy.
Table 4 Summary of Selected CERCLA-related Water-Quality Data (1 st Quarter
2002)
9. In accordance with the Table of Contents, please correct the title of Table 4 to state,
"Summary of Selected CERCLA-related Water-Quality Data (I st Quarter 2002)".
I 0. In accordance with the laboratory analytical results included in Attachment 2, please
correct Table 4 to indicate that the sample collected from groundwater monitoring well
K-28 contained no detectable concentrations of carbon disulfide at a laboratory detection
limit of0.0011 milligrams per liter (mg/L).
11. In accordance with the laboratory analytical results included in Attachment 2, please
correct Table 4 to indicate that the sample collected from groundwater monitoring well
V-23 contained no detectable concentrations of benzene at a laboratory detection limit of
0.00IIX mg/L, no detectable concentrations of carbon disulfide at a laboratory detection
limit of 0.0053X mg/L, no detectable concentrations of chlorobenzene at a laboratory
detection limit of 0.00S0X mg/L, no detectable concentrations of 1,2-dichloroethane at a
laboratory detection limit of 0.00S0X mg/L, and no detectable concentrations of
trichloroethene at a laboratory detection limit of 0.00S0X mg/L.
12. Please revise Table 4 to define the laboratory qualifier "X".
13. In accordance with the laboratory analytical results included in Attachment 2, please
correct Table 4 to indicate that the Inner Tier influent sample contained no detectable
concentrations of trichloroethene at a laboratory detection limit of 0.0020 mg/L.
• •
Ms. Giezelle Bennett
October 21, 2002
Page 3
Table 5 Summary of Selected CERCLA-related Water-Quality Data (2 nd Quarter
2002)
I 4. In accordance with the Table of Contents, please correct the title of Table 5 to state,
"Summary of Selected CERCLA-related Water-Quality Data (2nd Quarter 2002)".
15. In accordance with the laboratory analytical results included in Attachment 2, please
correct Table 5 to indicate that the Inner Tier influent sample contained 0.037 mg/L
benzene and 0.024 mg/L chlorobenzene.
I 6. In accordance with the laboratory analytical results included in Attachment 2, please
correct Table 5 to indicate that the Inner Tier effluent sample contained 0.020 mg/L
acetone.
17. Please revise the last column heading in Table 5 to state, "Inner Tier Effluent
(Duplicate)".
18. In accordance with the laboratory analytical results included in Attachment 2, please
correct Table 5 to indicate that the duplicate Inner Tier effluent sample contained 0.030
mg/L acetone.
Table 6 Summary of Selected PEW-Related Water Quality Constituents (I st Quarter
2002)
19. In accordance with the laboratory analytical results included in Attachment 2, please
correct Table 6 to indicate that the duplicate PEW-I sample contained 0.0015 mg/L
methylene chloride.
20. In accordance with the laboratory analytical results included in Attachment 2, please
correct Table 6 to indicate that the PEW-4 sample contained 0.0078 mg/L
trichloroethene.
• Kubal-Furr & Associates •
Environmental Management Services
Post Office Box 273210
Tampa, FL 33688-3210
[phone]
FAX [phone]
[e-mail]
Ms. Giezelle S. B·ennett
Remedial Project Manager
U.S. Environmental Protection
Agency, Region IV
61 Forsyth Street
Atlanta, GA 30303
Dear Giezelle:
September 26, 2002
Post Office Box 80247
Simpsonville, SC 29680-0247
[phone]
FAX [phone]
[e-mail]
On behalf of CNA Holdings, Inc., we are pleased to enclose a copy of the report entitled:
"Operable Unit 1-Semiannual Report-January 2002-June 2002-CNA Holdings,
Inc.-Shelby, North Carolina." By way of this letter, we have also transmitted a copy of the
report to David Mattison with NCDENR for his review.
Please contact me at 813-265-2338 to discuss any questions you may have following your
review of this document.
Sincerely,
Kubal-Furr & Associates
df/(4,.0~
I Jerry E. Kubal, P.G.
President
cc: Mr. David Mattison, NCDENR /
Mr. Steven F. Olp, Celanese Americas
Ms. PEM Carter, Ticona-Shelby ESHA
Post Office Box 273210
Tampa, FL 33688-3210
[phone]
FAX [phone]
kfatpa@eart hli n k. net
•
Ms. Giezelle S. Bennett
Remedial Project Manager
U.S. Environmental Protection
Agency, Region IV
61 Forsyth Street
Atlanta, GA 30303
Dear Giezelle:
Kubal-Furr & Associates.
Environmental Ma11agement Services
March 25, 2002
;VCP tJt13 9'/(,, ?'zf
:i.eJ. Aw Z-n/4.
Post Office Box 80247
Simpsonville, SC 29680-0247
[phone]
FAX [phone]
[e-mail]
M~.r, 2 6 2002
. ,:ON
On behalf of CNA Holdings, Inc., we are pleased to enclose a copy of the report entitled:
"Operable Unit 1-Semiannual Report-July 2001-December 2001-CNA Holdings,
Inc.-Shelby, North Carolina." By way of this letter, we have also transmitted a copy of the
report to Grover Nicholson with NCDENR for his review.
Please contact me at 813-265-2338, to discuss any questions you may have following your
review of this document.
Sincerely,
Kubal-Furr & Associates
<~/tt_?~-
Jerry E. Kubal, P .G.
President
cc: Mr. Grover Nicholson, NCDENR /
Mr. Steven F. Olp, Celanese Americas
Ms. Pem Carter, Ticona-Shelby ESHA
Post Office Box 273210
Tampa, FL 33688-3210
8 I 3/265-2338
FAX/265-3649
[e-mail]
Mr. Jerry McMurray
Ticona, Shelby Plant
Post Office Box f!:7
Shelby, NC 28151
Dear Jerry:
• . Kubal-Furr & Associates •
Enviro11,ne11tal Management Services
August 13, 1999
1120 W. Butler Rd., Suite Q
Greenville, SC 29607
864/277-0977
FAX/277-6626
[e-mail]
RECEIVED
AUG 16 1999
SUPERFUND SECTION
(!_eJ~~ AJ/L ~
We are pleased to enclose a copy of the remedial action summary report entitled: "Operable
Unit 1-Semiannual Report, January 1999-June 1999, HNA Holdings, Inc., Shelby, NC. As you
requested, copies have also been shipped directly to the EPA (Mr. McKenzie Mallary, 2 copies),
and to the North Carolina Department of Environment and Natural Resources (Mr. Bruce
Nicholson).
Sincerely,
Kubal-Furr & Associates
Jf~b~
Presife~~ul
cc: Mr. Ken Mallary, EPA /
Mr. Bruce Nicholson, NCDENR, Superfund Branch
•
February 17, 1998
Mr. McKenzie Mallary, Remedial Project Manager
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-3014
Dear Mr. Mallary:
• Hoechst Celanese
Textile Fibers
Hoechst Celanese Corporation
PO Box 87
Shelby, NC 28151-0087
704 482 2411
RECEIVED
FEB 19 1998
SUPERFUND SECTION
Enclosed please find two bound copies of the "Operable Unit 1 Semiannual
Report -July 1997 to December 1997" for the HNA Holdings, Inc. (formerly
known as Hoechst Celanese Corporation) Shelby Site. This status report has
been prepared by Kubal-Furr & As5ociates on behalf of HNA Holdings, Inc. and
submitted to.the EPA as specified in the EPA-approved "1995 Annual Operating
Status Report -Operable Unit 1 Remedial Action -Hoechst Celanese Shelby
Site."
If I can be of any assistance, please contact me at [phone].
With Kind Regards,
CJto'f~l_
Jeff Randolph
Sr. Environmental Engineer
cc: Mr-:;Bwce NJ~hglson,_N_G Division of Solid Waste Management
Enclosure
MJR:98:016.doc
Hoechst (0
August 25, 1998
Mr. McKenzie Mallary, Remedial Project Manager
U.S. Environmental Protection Agency, Region 4
North Site Management Branch
61 Forsyth Street, SW
Atlanta, GA 30303-3014
Dear Mr. Mallary:
• Hoechst Celanese
Textile Fibers
Hoechs! Celanese Corporation
PO Box 87
Shelby, NC 28151-0087
704 482 2411
RECEIVED
AUG 26 1998
SUPERFUN0 SECTION
Enclosed please find two bound copies of the "Operable Unit 1 Semiannual Report -January 1998 to June 1998" for the HNA Holdings, Inc. (formerly known
as Hoechst Celanese Corporation) Shelby Site. This status report has been
prepared by Kubal-Furr & Associates on behalf of HNA Holdings, Inc. and submitted to the EPA as specified in the EPA-approved "1995 Annual Operating
Status Report -Operable Unit 1 Remedial Action -Hoechst Celanese Shelby
Site."
If I can be of any assistance, please contact me at [phone].
With Kind Regards,
HNA Holdings, Inc. c~~~~
Jeff Randolph
Sr. Environmental Engineer
Enclosure
MJR 98:043.doc
Hoechst CS