NCD003446721_20101006_Celeanse Corporation - Shelby Fiber_FRBCERCLA SPD_Supplemental Characterization and Long-Term Monitoring 2008 - 2010-OCR

Celanese -Background
♦ Large multi-constituent plume resulting from an active plastics
manufacturing plant
• 1,4-dioxane (referred to as diethylene dioxide)
• Ethylene glycol-degradation products
• TCE
11 Dow Therm TM -1, 1 Bi phenyl and Bi phenyl ether
♦ GW ROD signed in 1988 (Source ROD signed in 1989)
♦ P& T system with two tiers of extraction (inner tier and outer tier)
.. Inner tier -shut down on trial basis in 2004
• Outer tier -shut down in accordance with delisting in 1998 ( before 1,4-
dioxane was identified
Celanese -IDR
♦ Region 4's Concerns and Motivation for Conducting an IDR
■ Inner tier P& T system was shut down on a trial basis to evaluate MNA.
a Inner tier system has not been restarted.
■ Should it be restarted?
., If it should be restarted, should the system be modified?
11 Is another remedial approach more appropriate?
Celanese -IDR Findings
♦ Initial IDR Findings
., Remedy Effectiveness
• The IT system appears to have had minimal effectiveness when
operating.
• Diethylene oxide is a difficult contaminant to address. The ability of the
existing system to remove diethylene oxide is not known.
• The evaluation of an MNA remedy depends on the constituent of
concern being evaluated.
-Diethylene oxide: MNA does not appear to be a viable remedy.
-TCE: There is insufficient information to evaluate MNA.
-Ethylene Glycol: It is likely that MNA is an appropriate remedy.
Celanese IDR Findings
♦ Initial IDR Findings
■ Diethylene oxide plume is wide-spread at the site (much more so
than other contaminant, but wells sampled for diethylene oxide have
not recently been sampled for other contaminants of concern)
• Diethylene oxide plume needs to be delineated
■ Extent of ethylene glycol and Dowtherm TM contamination appears
relatively limited -additional sampling will help confirm
I! TCE is detected at the source area and over 1,000 feet
downgradient, but not in between
• Perhaps due to an off-site source
• Perhaps due to lack of sampling between two areas
Celanese IDR Recommendations
♦ Initial IDR Recommendations
.. Sample transition zone wells to determine if there is a link between the off-
site TCE and on-site TCE
" Source area investigation for TCE
Delineate diethylene oxide plume with EPA suggested monitoring wells and
determine if it is migrating beyond streams
• Collect samples that represent groundwater beneath the stream bed
• Collect surface water from the stream
• Confirm groundwater discharges to the stream as suggested by aquifer
model
Celanese IDR Remediation Strategies
♦ IDR Suggested Remedial Strategy
• Based on extent of diethylene oxide plume, determine need for passive
or active remediation
• If active, then utilize P& T with advanced oxidation (or perhaps on-site
water treatment facility)
• Limited or no merit in restarting P& T system
-Existing Inner Tier system provides negligible mass removal and
restarting it is not merited
-No information available on potential effectiveness of Outer Tier
system
-Neither designed to treat diethylene oxide
I
Celanese Grub DPT Investigation
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AECOM DPT SAMPLING LOCAT;QNS
J'J.VJml ""'
Celanese Stream Investigation
Celanese -Monitoring Well Installations
AECOM
' ,-_
FIGURE 2
DEEP MONITORING '.-VEU. LOCATION
Jl-65-NEW
'-""" -<>tl-'l"l<I». 1-.c,·1 i:ov. ~H~.C>. ,,1,:~~,1 C,.'l\..'1.IU~
w I
i
I •
Celanese Expanded GW Monitoring
• I041~1'0WW.
• ICX'TW,CT~\IIQJ.
2 W.~MnR-.C:
A-TUI
A:COM
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• "" '"" Miiii I 8"".£
PIGUKI
SAMPLE LOCAT:ON MAP
\
Celanese -Misc Items
♦ DQOs for new well near DD58-R
♦ QAPP -TICs
♦ QAPP -Demonstration of Capability (Diethylene
Dioxide and Tetrahydrofuran)
♦ EDD Submittals (Historic Data and Current Data)
♦ Sharepoint Website
Celanese Project Schedule
♦ Review Schedule and Worksheets
♦ Deliverables
11 TCE Memo and TD Source Area Work Plan
111 DPT Results and Remediation Work Plan
m Stream Investigation Results
♦ EPA 2011 Five-Year Review
♦ EPA ROD Amendment/ESD Schedule
Celanese IDR
♦ Passive Remediation???
■ Suggested Remedial Strategy
• Based on extent of diethylene oxide plume, is "passive" remediation an
acceptable remedy?
• What conditions need to be met in order to select "passive" remediation?
I
Celanese -Background
◊ Large multi-constituent plume resulting from an active plastics
manufacturing plant
a 1,4-dioxane (referred to as diethylene dioxide)
a Ethylene glycol-degradation products
a TCE
" Dow Therm TM -1, 1 Bi phenyl and Bi phenyl ether
~ GW ROD signed in 1988 (Source ROD signed in 1989)
❖ P& T system with two tiers of extraction (inner tier and outer tier)
11 Inner tier -shut down on trial basis in 2004
a Outer tier -shut down in accordance with delisting in 1998 ( before 1,4-
dioxane was identified
Celanese -IDR
~ Region 4's Concerns and Motivation for Conducting an IDR
" Inner tier P&T system was shut down on a trial basis to evaluate MNA.
,. Inner tier system has not been restarted.
Should it be restarted?
" If it should be restarted, should the system be modified?
" Is another remedial approach more appropriate?
Celanese ... IDR Findings
◊ Initial IDR Findings
0 Remedy Effectiveness
• The IT system appears to have had minimal effectiveness when
operating.
• Diethylene dioxide is a difficult contaminant to address. The ability of the
existing system to remove diethylene dioxide is not known.
• The evaluation of an MNA remedy depends on the constituent of
concern being evaluated.
-Diethylene dioxide: MNA does not appear to be a viable remedy.
-TCE: There is insufficient information to evaluate MNA.
-Ethylene Glycol: It is likely that MNA is an appropriate remedy.
Celanese IDR Findings
¢ Initial IDR Findings
., Diethylene dioxide plume is wide-spread at the site (much more so
than other contaminant, but wells sampled for diethylene dioxide
have not recently been sampled for other contaminants of concern)
• Diethylene dioxide plume needs to be delineated
11 Extent of ethylene glycol and Dowtherm TM contamination appears
relatively limited -additional sampling will help confirm
.. TCE is detected at the source area and over 1,000 feet
downgradient, but not in between
• Perhaps due to an off-site source
• Perhaps due to lack of sampling between two areas
Celanese IDR Recommendations
♦ Initial IDR Recommendations
" Sample transition zone wells to determine if there is a link between the off-
site TCE and on-site TCE
" Source area investigation for TCE
" Delineate diethylene dioxide plume with EPA suggested monitoring wells
and determine if it is migrating beyond streams
• Collect samples that represent groundwater beneath the stream bed
• Collect surface water from the stream
• Confirm groundwater discharges to the stream as suggested by aquifer
model
Celanese IDR Remediation Strategies
~ IDR Suggested Remedial Strategy
• Based on extent of diethylene dioxide plume, determine need for passive
or active remediation
• If active, then utilize P& T with advanced oxidation (or perhaps on-site
water treatment facility)
• Limited or no merit in restarting P& T system
..
,.·.,_ ...... +,. ,,~·. ~··t=-····1-1' 11 .~, ,l~~ 1-..... 1:L•:-· .. ,
-No information available on potential effectiveness of Outer Tier
system
-Neither designed to treat diethylene dioxide
Celanese Grub DPT Investigation
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GRUB Investigation Program
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. , .. .... INJECTIOl'I WEU. LOCATON , .. '"• 0 RECT PUSH SAMPI.E LOCATIO"' .. ,, .. , ... •"" ,, ....... ~··
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□ ,"" AUCUST ~ lH'tOUCI-I 6CPlEM8CR 11. 2009 . ..• C,O OPT LOCATIOIIIS
< . 3980:L&J,IP\.ESNW..VZE0
•'" !>II GAOUNOWA~ SAMPI.ES ANAL VZE0
' . 3 WEUS NW. YZEO . -
"--"" "'' "'
SCALE IN FETl
FIGURE 1
~COM SAMPLE LOCATION MAP
. CNA t«LllhOS.•HC/T~
&l~LBV, NO0UH CNIOU..,.
~ --,
GRUB Investigation DPT Refusal
~COM
LEGEND
Y-23• MON•TOR NG WEU LOCATION
fT-41• ~ECT10Nwt:LLLOCAT,o,,,i
L-13, O,RECT PUSH SA.UPlE LOCATION
[785 SQ! OPT (MODEL. 8010) REFUSAL ELEVATlOIII
795 ---OPT (MODEL 11010) ~FUSAI. ELEVAflON
CONTOUR
aore
SOi.i.E CONTOURS LEFT our tNTEJ'HIONAU. V
FOACtARITV
FIGURE 1
DTP REFUSAL ELEVATION
CONTOUR MAP
Diethylene Dioxide Data -Shallow
-·\ l•I• ---=-·,· 011(1~) \:
\ I ·. o
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I - -. .._,. ... -11 / 0 (IJ.!,.r,J.5) /
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~COM
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NOTE:
LEGEND
litO"l!TORlNG WELL LOCA TlON
INJECTION WEU LOCA 1lON
DIRECT PUSH SAMPLE LOCAllON
OIEnm.ENE QIO)(IDE CONCENTMTIONS IH -&AMP\.!! DEPT11 IN FEET BEJ.OWCAOUN:l
51.IRf-'CE
BOTTOM OF EXCAVATEO NU;.A
TOf> OI' HEOEPO$rreO STAISI.IZEO
RfMEDJA new ~
CONCENTRATlON CONTOOR
TtlELOC,,.Tl()N OFM--15 I\ND~IIINU: ~TE.
,oo ,oo
DIETHYLENE DIOXIDE CONCENTRATIONS
IN SHALLOW GROUNDWATER
Diethylene Dioxide Data -Deep
CC<Ae;(?T·J•I/O~-,. '
L l>O •C'f.'11111~.>!I~)
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......
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I
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I
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~COM·
LEGEND
v-ne 1,iONITORINGWEllLOCATION
IM.JECTIOH WELL LOCATION
DIRECT PUSH SAUPLE LOCA~
OIETI-M.ENE DIOXl'.lE
CONCEHTIV, TIONS f<I ~
(1$-25) SA.MP..E OEPT11 IN FE.ET llfLOW GR0UN:> su~=
'°=
80TT01,1 01' EXCAVATED~
TOP OF REDEPOSITED STA!ll.lZEO
REMEDIATION RESIOUOLS
CONCEN'TRAnoN CONTOUR
TtlE LOCATION Of 1,1.1~ "-"10 M.l&~ N'Pf'IOXJMATE.
SCAI.£ c-. FEET
OIETHYLENE DIOXIDE CONCENTRATIONS
IN DEEP GROUNDWATER
°"' HJIOINGS, ~ ·•UJIY.NOl'llllc.o.lQ. .....
Ethylene Glycol Data -Shallow
<I (1f.1'1
1-180 J.1ti. ''li-'gl
,,(n.:.n~, ~~• OIHI 0'4-$
0~5.o~ih1a1
<lj1!>-2$I
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~COM
LEGEND
MONllORINO Wf:U LOCATION
INJECTION WELL LOC,..TION
l-1Je DIRECT PUstl SAMPtE LOCAT10N
EnfYLE'-1: GL VCOl
CONCENTRATIONS IN ff¢
-10-
NOTr.:
SAMP\.E DEPTli IN FEET BEl.OW GR0..ND
'""''°' BOTTOr,i or l!XC,,\.VAT'fO AAEA
TOI' OF REOEPOSITEO ST Ml.lZEC A.EMEOIA, TlON RfSOIJ,O,L.S
TI-II! LOCATION or ,,1-1~ ANO r.l-10AAE APPROXJMA.Tf
,00
SCAl.£ IN FEIT
ETHYLENE GLYCOL CONCENTRATIONS
IN SHALLOW GROUNDWATER
C.....Ha.DCN05,1~
SHUGY.t.OM!Hc:ARa.JhA
Ethylene Glycol Data -Deep
······ . -~
... \ -0.5-0 5 • O !'rlha1 ... --.... -;
,. •" ' . .. ,.
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.. . ,. •>(=) ,, ... • ••
VO• .... ,. LEGEND ,~. l,IONITORING WELL LOCATION
• .1-11 ••• IM.JECTIOH WELL I.OCATION ~.,,. OIRfCT PUS!i SAMP\.E LOCA 110N .~,, ., ETHYLENE GLYCOL
CONCENTAATIONS IN n'9'\.
~m!,.2~) -~•ll oO.IJ (IWII) SNM'I.E OEPfl,,I IN FEET BELOW OAOUNO •.,.u SURF.-.cE
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TOP Of REDEPOSITED STASUZEO .f{21Jfl RE1,1El)l,,\TION RESIOUAI.S
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NOTE: .,...,. ~~.·& .. :n ., .. •1(21>:1$) THE LOCATION OF M-1, N;D M-11ARE N'PROXIMATE
••9• •TC~ .. l] ,, "' .. ·' 0,----]5
SCOJ..E IN F[CT
.-. •. -
., ETHYLENE GLYCOL CONCENTRATIONS
" ~COM IN DEEP GROUNDWATER
--·: _,
1;1,A"()I.D~.NCllM;ChA
'--, ·,-a,+ii;Ui,V,>IOATlic.o,ROI.INA -,·-
GRUB Investigation Conclusions
~ Work plan scope plus significant expanded work
completed
♦ No source identified
♦ Minimal detections in soil
~ Detections in shallow groundwater are at lower
concentrations than detections at elevation of well V-23
♦ Detections indicate residual groundwater contamination
at depth
~ Detections at well V-23 in most recent 18 months
suggest possible declining concentrations
~ Recommend long-term monitoring
Celanese Stream Investigation
Legend
,;i Surface WJler Sample<,
Stream Inflow Study
Map Projection: NC Fee!
Datum: NAO North Ameriean 1983
Source USGS, Blacksburg North 0 300 600 1 200 """""=~==· C Feet
Surface Water and
Stream lnnow
Locations
CN~ Holding$, 1/lc.lT,conil
Shelby. Nor1h Carohna
~COM
M3y 2010 80135442
Stream Inflow Results
CELA.NESE PROPERTY
"
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007
l "'
~
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oo,
002
0.01
RECREATION!
FIRE POND
T
&JB•BOTTOM ~ TER
WRFACEWATER
ST~EAM
NOTE: STREAM LENGTH= 4,510
BEGINNIIJGAT RECREATIONll'IRE ~O
R ESiOEN TIAL NEIGH60RHOOO
0 JOO 600
HORIZONTAL SCALE IN FEET
M'COM
GEORGE CAMP PRoPERTY
000
oo,
"'
0.01
FIGURE 3
SHELBY STREAM INVESTIGATION DATA
SEPTEMBER 2009
JUlY.,.,10
CNA HOlDINGS, NCmCOOA
SHELBY. NORTH CAROLINA
Ceianese Monitoring Well Installations
_.,.··
AECOM
T .--5CA.LI.:
FIGURE 2
DEEP MONITO~l:,.,tG WELL LOCATION IH35-NE\-.,
.... ,;<>;:<i
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'(,_
Cross Section Plan
.-r--· -i"\
---··
DD-58R
A'
11-65 11-112
11-40
B'
~COM
V•23 • YON>TOR:NO WE1..1. LOCATlON
Qf. 10 • .NJECTIOH Wl:U. LOCATION
PZ-10_., PIEZOl,l;£TERLOCAT:ON
A----A' CROSSSECT•ONLOCAT;QN
se,o.u: 1>, F(ET
CROSS SECTION LOCATION MAP
CNA .iolDt.OS. ,HCmC:()NA IHEIJIY. l"OFllll ~
Hydrographs LL and II Wells
800 C: 0 750 .,
"' > 700 "' iii
"LL" Hydrograph r=-----v
~ 650 "' -"' 600 ;: LL-175 LL-29_5
-0 C: 550 :,
0 ~ 500 Cl
Jan-04 Dec-04 Dec-05 Dec-06 Dec-07 Dec-08 Dec-09 Dec-10 ~ __ ,.o -
740
C: 738
0 ., 736 "' > "' iii
~ 734
"' -"' 732 ;:
-0
C: 730 :,
0 ~
Cl 728
726
Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Jan-09 Jan-10 Jan-11
-11-40 -11-65
B B'
' m, ' ' II~;,) 12,., 810 810
LL-175
800 ELEV. 792.&3 800 ll-295 ELEV. 792.GJ
790 IPZ-10 790
ELEV. 782.65'
780 780
111~0 770 ELEV. 75-4.w 770 11-65 ELEV. 754.9'9
760 11-112 760 ELEV. 7!>5.50'
' 750 750
740 740
~
730 730
~ PZ-lC 11-'0 720 0 1, .,,.,,., 720 t~,oou, _,.,,,,,. ~ 710 BTlf~ 710 a z 11 6~ I 700 -----. ".-rr· 700
690 LL-\ IC I "'"'' 690 0 GC6
""''J(-t, ~
680 680 .,,,...,.
670 670
660 660
650 11., :2 650 r ,--., ,,,_
640 tt>mg 640
630 630
Ll-175
620 I,~,,., 620 ~q,, ,,or.
610 ll!IU 610
600 600
590 590
580 580
570 570
560 560
550 550 LEGEND
540 540 ~LL-110 SAMPLE 1.0.
ELEV. 79163" GROUND SURFACE ELEVATION
(FEET, MSL)
530 530
OPT WELL
520 520 I SCREENED INTERV,\L
510 510 I GROUNDWATER ELEVATION LL-2~5
500 ,., 500 0016 OIETHYlENE DIOXIDE CONCENTRATION 1mgll.) I'•' w,= ANAL YT1CA.L DATE
490 10300g 490
" ,oo ,oo ,oo
~
HORIZONTAL SCALE IN FEET
" " ;o ""
VERTICAL SCALE IN FEET
VERTIC"'L FJ(AGGERATION = 13 33X
A:9COM CROSS SECTION B-8'
CNA 1-fOLD!NGS INCfTICONA
SHELBY, NORTH CAROLINA
' R 2010 M11'>4•~
DD-58R Area
A A' . -7 ~--V-23 CC-'3 W'f"IOX .. ATl:BITEIIOIJl',IDAAYJ
M-28 -EUV 1101'7 I=.,,~ 1=~N I x1,; .. o,7 CC-64 M4< CELANESE PROPERTY CLAUDE lAVENOER PROPERTY
810
r
U..CV.110IIO' nr,,,80<111(1 810
800 J ~ DD-58R 800
ELFV,/'l,&lO'
700 r 790 , ... ,,, ., r PP-70 [UV1Q"O'
780
~D:tcr =..-.,, '.,,,~
"-'.''['"'
780 . ,-~~. l0l3U rOT-1R .... '"~" ,~~ 11!lZT
i7'i 170 7 770 ~ ' ~m ~ ~r,-;,.,, i ~ 760 760 :i
~ rndo E
/i(t,r, ~" i 750 .,o;..,,., 750 J " LJlt~il'"' ._:I TD~IT IU;fl,l!IAl.1165" .. , . -7'0 CCJ~ 7◄ 0
~ "'"•""i.. n> IIIU' ""'°"' 730 ~ 730
R
720 1: J • .,.,: 720 oo:;,,\)6§
il roe, 710 R 710
r,
;;-JOI/Ir
700 ' 700
CELANESE PROPERTY CLAUDE LAVENDER PROPERTY
L,<,.VENCER l'IOAO
~XMATE 8rT1, &OUND,O,RYJ
LEGEND
r~a10N ~,o
G>IOJNOSU><f.-ct.UlaVl,[QN
~ J•FFT.U31 I
OPTWEU ~~ -..
~ &CR.EE'-ED lifEIIV.tJ. H0R20Nl'AI. $CALE IN FEET
i:.---10 ~ ~ • 0"0UNOW,'1FR; FlEV,.T-0'< ~COM CROSS SECTION A·A'
0,111 otnm.tJ<t tJOX.•OC co-,c(.NlllATO. 1"9\) V£RT,cA,l. SCALE IN F£El •·= .........._"'TICA.0,t,Ti 1/f:RTICA!. EXAOGER,\TION • 1!,X
O..O.HCllO..OS,,l'C/T'ICOJ4A
aHC..DY. NORT11 ~
,._._.._n,,,,,,.e-•----IIO~er---•o••o-•MoW•O•:Z:,,llPW.-
i
!
Celanese Expanded GW Monitoring
• -IKll'IIIIGWEI.L
.. D'TIW:110N \IIELL
·-· -.. -·
•
~
... -\ 8CALI!
Pl&U-.a
SAMPLE 1.0CATION MAP
a.AHCUll"'N,IIICJnoatM. _,,-,11Cllffl11:M0UIIA
LEGEND
s.wPI..E LCv.TON
• SURfi\CEY,'ATEA 5-\MPLE LOCATION
FORMER GRUB DISPOS4LAAEA
D GfOJN(•Y~•HERtlSE AESTRICTIONAAE,\
• --} PA:::PERTY OOlltlCllRY
N)TES· AEi:llAL A-IOTOFROM 000::LE Eo\ATH
~OTOr•ATED JULY 2C•:"'
N
i
k
1.000 500 0 1,000
Feet
AECOM
SAMPLE LOCATION r-.•lAP
Shelby, North Carolina
Celanese -Misc Items
♦ DQOs for new well near DD58-R
♦ QAPP -TICs
♦ QAPP -Demonstration of Capability (Diethylene
Dioxide and Tetrahydrofuran)
♦ EDD Submittals (Historic Data and Current Data)
♦ Sharepoint Website
Remaining Schedule Items
" 0 :.,. 1;.,..... ·~ r,,,,.,,
Shelby limeline Thu 8/6109 W@d 3114112
Routine Reports Wed 3/31/10 Fri 9130/11,
-January -June 2010 Semiannual Report Thu 9/30/10 Thu 9130110
' 3 July. December 2010 Semiannual Report Wed 3/31/10 Wed 3131110
~~ January -June 2011 Semiannual Report Fri 9/30/11 Fri 9/30/111
Monitoring Events Mon 9/13/10 Wed 3114112;
3 03 2010 Monitoring Event (incl. expanded characterization) Mon 9/13/10 Fri 9/24/10;
Receive 03 2010 data Mon 10/25/10 Mon 10/25/10
3 01 2011 Monitoring Event (incl. expanded characterization) Tue 3/1/11 Mon 31141111
Receive Q 1 2011 data Tue 4/12/11 Tue 4112111:
Develop long term monitoring plan Wed 4/13/11 Tue 6/21/11\
3 03 2011 Monitoring Event (Interim Plan) Mon 10/17/11 Fri 10l28l11j
Receive 03 2011 data Mon 11/28/11 Mon 11/28/11!
" Lo11g term monitoring plan approval Wed 11/9/11 Wed 11/9/11!
3 01 2012 Monitoring Event (Long Term Plan) Thu 311/12 Wed 3114112.
,; GRUB area Thu 8/6/09 Thu 8/12/10;
GRUB area investigation Thu 816109 Wed 8126109:
" -'-' GRUB Investigation Review Thu 8127109 Wed 6130/10:
" 3 Submit GRUB Review Thu 8112110 Thu 8112110,
,; TCE Tue 10126110 Mon 111141111
" Review 03 2010 TCE data Tue 10/26/10 Mon 11/29/10
Re\llew 01 2011 TCE data Wed 4/13/11 Tue 5/17/11,
TCE HH Wells memo Wed 5/18/11 Tue 6/14/11,
" Subml! TCE HH wens memo Wed 6115111 Wed 6115111:
~ Develop TD area work plan Mon 1/17/11 Fri 3/11/11i
" EPA approve work plan Mon 3/14/11 Fn 3/25/11 =~· -response to EPA comments Mon 4/11/11 Mon4/11/11
~ EPA approval of revised plans Tue 4/26/11 Tue 4126111
-TD area investigation (MIPTM and Geoprobe®) Wed 5111/11 Tue 617/11:
" tv:o deep (bedrock) wells in TD area Wed 6/8/11 Tue 6/28/11,
~ Receive lab data Wed 7/27/11 ~=~ ~~~~~ ~i " TD remediation work plan (possibly MNA) Thu 7128111
EPA approve work plan update Thu 9/22/11 Wed 10/12/11
response to EPA comments Thu 10127111 Thu 10127111
EPA approval of revised plans Fri 11/11/11 Fri 11/11/11
Start TD remediation {MNA anticipated) Mon 11/14/11 Mon 11/14/11, • Oietheylene Dioxide Mon 8/30/10 Mon 8130110 ,, -Subrrnt diett1ylene oxide discharge assessment memo Mon 8/30/10 Mon 8/30/10
EPA Costs Mon 1/17/11 Mon 1/16/12
CELANESE FI8ER OPERATIONS SITE ~~· PROJECT SCHEOULE
SHElllY. NORT« CA~OLINA October 2010
Celanese Project Schedule
♦ Review Schedule and Worksheets
♦ Deliverables
Ill TCE Memo and TD Source Area Work Plan
Ill DPT Results and Remediation Work Plan
ei Stream Investigation Results
♦ EPA 2011 Five-Year Review
♦ EPA ROD Amendment/ES □ Schedule
Celanese IDR
♦ Remediation Strategy???
" Suggested Remedial Strategy
• Based on extent of diethylene dioxide plume, is "active"
remediation merited?
0 What conditions would suggest that active remediation is not
merited?
AECOM AECOM One Midtown Plaza
1360 Peachtree Street
Suite 500
Atlanta, Georgia 30309
Letter of Transmittal
Attention: Beth Walden
Project reference: CFO Site, Shelby, NC
We are sending you the following:
Number of originals:
1
Number of copies:
0
Date: August 30 -------------
Project number: 60135442 -------------
Description:
Replacement pages that were modified in the current
revision (Revision 2) to address EPA comments
Enclosed are signed cover sheets, original copies of the pages that have been modified to address
EPA comments to the draft QAPP marked as Rev 2, and an annotated check list identifying how the
comments were addressed. Please return a copy of the signature page with your signature
accepting the revisions to the QAPP. If you have questions, please contact me at 404.965.9687 or
770.331.1502.
cc: -Steve Simpson, Celanese
PEM Carter, Ticona
David Mattison, NCDNER
Doug Sutton, Geotrans
'• Mattison, David
From: Mattison, David
Sent:
·To:
Friday, September 11, 2009 12:28 PM
[e-mail]
Subject: Re: tetrahydrofuran
Beth,
Yes, the analytical methods that Nardina is suggesting are acceptable to NC DENR.
Dave
David B. Mattison
Environmental Engineer
NC DENR Superfund Section
401 Oberlin Road, Suite 150
1646 Mail Service Center
Raleigh, NC 27699-1646
Office: [phone]
Mobile: [phone]
[e-mail]
Email correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
-----Original Message-----
From: "Walden. Beth@epamail .epa. gov" <Walden. Beth@epamail. epa .gov>
Date: Fri, 11 Sep 2009 11:36:20
To: Mattison, David<[e-mail]>
Cc: [e-mail]<[e-mail]>
Subject: Fw: tetrahydrofuran
Are the methods that Nardina is recommending, o.k. with the State?
Forwarded by Beth Walden/R4/USEPA/US on 09/11/2009 11:35 AM-----
Nardina
Turner/R4/USEPA/
us
08/17/2009 12:02
PM
To
Beth Walden/R4/USEPA/US@EPA
cc
Stephen Dyment/DC/USEPA/US@EPA
Subject
Re: tetrahydrofuran(Document
link: Beth Walden)
1
Ethylene Glycol: ,Although not a target of 8015C, this compound is
commonly analyzed by this method. However, the direct aqueous injection
option is the appropriate preparation procedure. My understanding is
that solid samples must, thus, be extracted, a preparation not discussed
in 8015C, so 8015C is not a good citation for prep of the solids. See
attached that I have kept in my reference materials from the MICE
(SW-846 help desk). Since the compound is not a target of the method,
the demonstration of capability by the laboratory, using their own SOP,
should be thorough before they receive any field samples (MDL study,
precision and accuracy).
(See attached file: EthyleneGlycolinSoil)
Diethylene Dioxide: This is the 1,4-Dioxane. Just adding SIM to the
8260 is not going to be sufficient. SIM allows you to zero in on
something to get a lower detection during analysis. The problem with
1,4-Dioxane is that it is very water-soluble, so getting it out of the
matrix and onto machine is the problem, not detecting it once it is in
analysis. There are several alternatives. Currently, CLP is doing this
compound as an Extractable (similar to 8270), there are modifications to
8260 at the preparation step that may allow 8260 (heated purge and
salting out are options, usually with surrogates spikes as QC such as
Deuterated Monitoring Compounds -if the Deuterated version of the
target is recovered, then you know the target analyte was successfully
purged), and there is a new method that is may be more difficult to
locate on the market, 8261A, the same one I suggested for
Tetrahydrofuran earlier.
For the two DowTherm, although they are not in 8270D, we·do the
1,1-Biphenyl through CLP Extractables. The Biphenyl Ether should also
be O.K. as an Extractable, but whenever the method does not include the
target, I would suggest having the laboratory document a Demonstration
of Capability before analyzing field samples. We are sometime
challenged on whether we used validated methods. Since there may not be
a validated method for all compounds, I believe a laboratory
Demonstration of Capability could go a long way to bolstering the data
package should there be any challenge.
Beth
Walden/R4/USEPA/
us
08/14/2009 01:59
PM
To
Nardina Turner/R4/USEPA/US@EPA
cc
Stephen Dyment/DC/USEPA/US@EPA
Subject
Re: tetrahydrofuran(Document
link: Nardina Turner)
2
Nardina,
I am confused by the Celanese Revised QAPP regarding appropriate
analytical methods:
Please see Table 3-1 and let me know what you think about their proposed
Methods for the parameters of interest.
[ attachment "Draft Final QAPPmkREV. doc" d.eleted by Nardina
Turner/R4/USEPA/US]
Nardina
Turner/R4/USEPA/
us
03/10/2009 09:53
AM
To
Beth Walden/R4/USEPA/US@EPA
cc
Stephen Dyment/DC/USEPA/US@EPA
Subject
Re: tetrahydrofuran(Document
link: Beth Walden)
Beth: I don't see it listed in 8260B, and the version posted for 8260B
dates back to 1996. The current VOA method is 8260(. For
Tetrahydrofuran, try 8261A. There are some compounds which do not
perform well in the routine VOA method. 8261A is a newer method. It
may be difficult to find on the market, but it is intended to correct
for matrix effects for some of the problem compounds. I would not
recommend adding in a compound which was removed or not included in
SW-846,as the performance is likely to be poor. -Nardina
Beth
Walden/R4/USEPA/
us
02/25/2009 09:43
AM
To
Nardina Turner/R4/USEPA/US@EPA
cc
Stephen Dyment/DC/USEPA/US@EPA
Subject
tetrahydrofuran
3
Mattison, David
From:
Sent:
To:
Cc:
Subject:
Glover, Everett [[e-mail]]
Tuesday, September 08, 2009 12:39 PM
[e-mail]; Mattison, David; [e-mail]
Simpson, Steven M., GlobalREM/US; Carter, PEM, Ticona/US; Dahlgren, Bryon; Peterman,
Jeff
Shelby -summary of contact with Andrew Pitner, NCDENR -Aquifer Protection Section
The following is a summary of a telephone conversation with Andrew Pitner, hydrogeologist with the NCDENR, Division of
Water Quality-Aquifer Protection Section, on September 3, regarding the construction of the deep well at the II-well
location. The conversation involved the borehole diameter for the section of the borehole drilled to set the 6-inch surface
casing to the approximate top of rock. The plan was to auger a 12-inch diameter borehole, and set and grouts the casing
in the 12-inch hole. However, the subsurface materials were too hard below approximately 42 feet to be penetrated using
the large augers planned for the task, but the drill crew was able to auger and ream an 8-inch hole to approximately 62
feet before encountering what was interpreted to be competent bedrock. Placing and grouting the 6-inch diameter casing
in an 8-inch diameter borehole was potentially not in compliance with the North Carolina Well Regulations which require a
2-inch annular space around the well casing. It is still unclear whether the 2-inch annular clearance applies to surface
casing, or only to the well casing itself. The deviation from plan was discussed with Andrew Pitner and he understood the
issues involved and was fine with the decision to grout the 6-inch casing in the 8-inch borehole. Subsequently, the well
was successfully constructed with a 2-inch screen and riser placed in a 6-inch diameter borehole that extended below the
bottom of the surface casing. The well was completed at approximately 112 feet below land surface. The well had good
recharge at that depth and developed quickly. By comparison, the adjacent II-wells are at approximately 40 feet and 65
feet below land surface. The new will well will be survey located in plan and elevation when the survey crew is on site
after the completion of this round of field work.
Subsequent to this discussion, AECOM received a copy of the well permit for the installation of the push-point samples on
the Camp property. This work is currently scheduled for the week of September 28.
If there are questions, please contact me. Thanks. ewg
Everett W. Glover, Jr. P.E.
Senior Program Director
D 404.965.9687 C 770.331.1502 (please note: new direct dial)
[e-mail]
AECOM
1360 Peachtree Street NE, Ste. 500 (please note: new address and contact information)
Atlanta, GA 30309
T 404.965.9600 F 404.965.9606
www.aecom.com
Please note: my email has changed to [e-mail]. Please update your address book accordingly.
Earth Tech's parent company, AECOM Technology Corporation, as it evolves to better serve its clients, is changing the name of Earth Tech, Inc. to
AECOM Technical Services, Inc. Earth Tech's legal structure will not change and Earth Tech's employees will be employees of AECOM Technical
Services, Inc. As a member of AECOM's global environmental business line, we are able to offer expanded depth and breadth of services drawing on
the experience and expertise of AECOM Technical Services and AECOM's staff.
This communication is intended for the sole use of the person(s) to whom it is addressed and may contain information that is privileged, c'onfidential or
subject to copyright. Any unauthorized use, disclosure or copying of this communication is strictly prohibited. If you have received this communication in
error, please contact the sender immediately. Any communication received in error should be deleted and all copies destroyed.
Ji Please consider the environment before printing this e-mail.
1
@EarthTech
A Tyco International Ltd. Company
Legend
0 WELL LOCATION
--CREEK
OU1 BURN AREA
OU1GRUBAREA
BUILDING
[~_-_·] PROPERTY BOUNDARY
l-7 RECREATION POND
[_J INDUSTRIAL POND
N
500 250 500 --c===----Feet
0
FIGURE 3-2
SITE BASE MAP
CNA Holdings, lnc./Ticona
Shelby, North Carolina
SEPTEMBER 2007 79750
-
H-Sg ~ @ PEW-1
H-79
J-59
V-23 ®
v~ ®
IT-7
®
IT-SR
IT-6
® IT-9
® rr-1
rr-2
(iJ K-28
Y-38
~ Y-7•
N-29
POLISHING
POND
POLISHING
POND
@) EarthTech
A Tyco International ltd. Company
Legend
® WELL LOCATION
[~_-_J PROPERTY BOUNDARY
(./.({/~I OU1 BURN AREA
~ OU1 GRUB AREA
N
100 50 0 100
Feet
FIGURE 3-3
CONTAMINATION SOURCE LOCATIONS
AND OU-2 EXCAVATION EXTENT MAP
CNA Holdings, lnc./Ticona
Shelby, North Carolina
SEPTEMBER 2007 79750
! I
.. ...............
0
.... , .... ,
.............
-...... .... ~
SW-6
-cll.002
...........................
----------------------·--··-··-··-··--------. ______ ~~: .
·-......... ; ..... ,
00-218 00-95
c0.002 -cll.002 KK-27
® KK-55 0.006
0.192.
z-12
.6 0.309
AA·S4
0.576
SW-3
0.0108
JJ-65
e.-cll.002 JJ--40 VY
<0.002
• MM-280
0.0231 • M'4-128
0.0128
LL-110
0.016
U-175
0.0191
.._~ = HH-n
ELLIOT W~ <0.002
<O.~ ~ H_H:48 @
,/. ~002 ,A /
/ ;\<~//~
SW-7
.0098
\
Legend
DI ETHYLENE OXIDE $ 0.007
• DI ETHYLENE OXIDE > 0.007
~ SURFACE WATER LOCATION
MONITORING WELL
EXTRACTION WELL
t PEW WELL
"' PIEZOMETER
D PARCEL WITH WATER RESTRICTION
--CREEK
D INDUSTRIAL POND
-RECREATION POND
~ BUILDING/STRUCTURE
,-------, L_ ____ j PROPERTY BOUNDARY
N
500 250 0
NOTES:
(1) CONCENTRATION UNIT: mg/L
(2) BOLD-FACED FONT: DETECTED
500
Feet
CONCENTRATION ABOVE NC 2L STANDARD
(3) 0.007 mg/LAS NC 2L STANDARD FOR
DIETHYLENE OXIDE
(4) HH AND ELLIOT WELL DATA IS FROM APRIL 2007
SAMPLING EVENT
/
/
'~~~ /f\r-""------_,;....._ ___ ;;;;;;.;.. ___ ....i.,_---1--------FI_G_U_R_E_5 ___ 15 ______ _.
DIETHYLENE OXIDE HORIZONTAL EXTENT MAP ~ Earth Tee h AUGUST AND SEPTEMBER 2006 DATA
A Tyco International Ltd. Company
/
CNA Holdings, lnc./Ticona
Shelby, North Carolina
SEPTEMBER 2007 79750
@EarthTech
A Tyco International Ltd. Company
Legend
■ SURFACE WATER LOCATION
® WELL LOCATION
--CREEK
D PROPERTY WITH WATER RESTRICTION
D BUILDING/STRUCTURE
[_°_-~_-_°] PROPERTY BOUNDARY
INDUSTRIAL POND
D RECREATION POND
NOTES:
(1) PROPERTIES WITH WATER RESTRICTION
SEARCHED BY KUBAL-FURR & ASSOCIATES AND
VERIFIED BY EARTH TECH.
(2) PARCEL BOUNDARIES AND PARCEL
INFORMATION PROVIDED BY CLEVELAND COUNTY
GIS.
N
1,000 500 1,000 ---=====------Feet 0
FIGURE 5-21
OFF-SITE PROPERTIES
WITH WATER USE RESTRICTION
CNA Holdings, lnc./Ticona
Shelby, North Carolina
SEPTEMBER 2007 79750
I
'• A:COM AECOM
One Midtown Plaza
1360 Peachtree Street, Ste. 500
Atlanta, Georgia 30309
Memorandum
To Beth Walden, EPA -via email
Dave Mattison, NCDENR -via email
cc Steve Simpson, Celanese
Subject Additional Investigation Plan
DD-58R Area
CFO Site, Shelby, NC
Document Control No. 0265B-292
AECOM Project 60135442
From Everett Glover
Date July 2, 2010
404.965.9687
404.965.9605
Page
tel
fax
This memo and attached figure present an expanded investigation approach for the area
downgradient of well DD-58R. The objective of the proposed work is to further delineate the extent
of diethylene dioxide detected at DD-58R, and is proposed in phases to allow the development of
additional information to guide further work activities. Phase I of the work will be conducted at the
downgradient Celanese property boundary to determine whether the diethylene dioxide has,
migrated to that location before engaging the adjacent property owner to gain access to private
property. If the property line well is clean, it will be added to the routine monitoring program and the
adjacent property owner will not be contacted.
Phase 1
The attached figure shows the location of well DD-58R with respect to the Celanese property
boundary and relevant utility line and highway right-of-way. The proposed approach is to locate a
new monitor well as close to the Lavender Road right-of-way line as practical while staying on
Celanese property taking into consideration the overhead power line that crosses Lavender Road in
the general area as shown on the attached figure. Well construction will be similar to that used in
well DD-58R and will consist of using 6.25-inch inside-diameter hollow-stem augers to the top of
rock and then using a 6-inch air hammer to install a 2-inch diameter poly-vinyl chloride (PVC)
monitoring well to the desired depth. The well is intended to monitor the transition zone/upper
bedrock similar to DD-58R. For estimating purposes, we assume the well to be no deeper than 80
feet. After installation, the well will be developed and sampled for diethylene dioxide. If the well
confirms that diethylene dioxide has not reached the property boundary, it will be added to the
routine monitoring program. If resampling verifies diethylene dioxide has migrated to the property
line, a Phase 2 plan for off-site investigations will be developed and submitted for your approval
prior to implementation.
shelby_ dd58r _ addn _ exp _rO _ 7 •2-1 0.docx
AECOM 2
Additional Investigation Plan
DD-58R Area
CFO Site, Shelby, NC
We are ready to initiate Phase 1 activity immediately upon your approval and field work should
occur within 2 to 4 weeks, contingent on the schedule for the drilling contractor. Actual timing will
be confirmed once the approval is received. The procedures for this work will be generally
consistent with those contained in the Work Plan and Field Sampling Plan for Supplemental
Investigation and Long-Term Groundwater Monitoring, Celanese Fibers Operations Site, Shelby,
North Carolina dated June 2010. A report of findings should be available to EPA within about 12 to
14 weeks of scope approval. This report will include a scope for Phase 2 activities, if needed.
If you have questions about this approach, please contact me.
Sincerely yours,
ewg
Everett W. Glover, Jr., PE
Senior Program Manager
[e-mail]
shelby _ dd58r _addn _ exp _rO _ 7-2-1 O.docx
~~-@ ~ ~~+(Di 1/
Install one well into the transition , I , CJ) '\ I zone/upper bedrock. Estimated at O :
0 I
I
I
I
I
I
I
I
I approximately 80 feet for budgeting o, lfJ ,
purposes. The location will be as close to __, +-' :
the NCDOT right-of-way line as practical. ....J 6 0J :
/ I lfJ (D I ~ LI) I
0 Approximate well
location Looking at air photos, this will probably CJ) 1.. f'.. ' vJ LJ [YJ I
(J v' / ~ {'.__ CS) I
.I_ ,~"'CJ-I require some clearing due to existing • lJl ;
vegetation. This will result in a well O O -5 8 R ~N O 0J '
~' " ,'
.µ ~ J I
0ro cpn /
-0) ,___, I approximately 150 feet closer to property -' .t> cJ lD __, ,
line than DD-58R. The specific location -• , ID , c<i
will be field determined at the time of well -i \ ? ISl o : :::n
construction and will be survey located 5 5 8 . 0 L\ ' o. 10 ;;; ~ : EE
subsequent to drilling. 6 -1.. ~ o._ : ~
(' 1'<53:_.2~1_'_ ---_' _:_1_?~----&"'? ! '")
'--~ 0 .>--?"' ----·------~~'l}p . f---------~ -/ < /_: ,\-'0 I;'~ . --/:~~~-~ ,,,-.,.,.. . ...--,.,,.,----~I ~
v·~l-Q · NCDOT 60-ft right-of-way <"
Claude Lavender property
-~,\\\ -~ '
~L\ .,-,-~ l-Y ,. o \) '2.,6
.. ICADD~icona_mon_wells0ct07.dgn 6/24/2010 8:43:23 AM
({) /]) ,' ,.._,o,
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(Q I
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,
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I
I
Mattison, David
From:
Sent:
To:
Subject:
Attachments:
[e-mail]
Thursday, July 02, 2009 1 :24 PM
[e-mail]; Mattison, David; [e-mail]
Fw: Shelby-Wells for Full TCL SVOCs and TICs
pic12048.jpg; pic15781.jpg
Forwarded by Beth Walden/R4/USEPA/US on 07/02/2009 01:23 PM-----
Stephen
Dyment/DC/US EPA/
us
07/01/2009 04:22
PM
"Glover, Everett"
<[e-mail]>
To
cc
Beth Walden/R4/USEPA/US@EPA,
"Dahlgren, Bryon"
<[e-mail]>,
"Peterman, Jeff"
<[e-mail]>,
"Simpson, Steven M.,
GlobalREM/US"
<steven.simpson_contractor@celane
se.com>
Subject
Shelby-Wells for Full TCL SVOCs
and TICS
In addition to wells and analytical suites recommended by Doug in the IDR report, I would
like to include a series of wells for full TCL SVOCs and TICs that could be sampled to
understand current flow conditions, plume configuration, and attenuation. The goal is to
focus SVOC analyses in the plant, GRUB/pond areas, with some down gradient transition zone
wells. Suggested wells are based on historical data (database dated July 2008), proximity to
wells with historical SVOCs hits, screened interval in shallow and transition zones, as well
as locations within facility and GRUB/pond areas. There may be some redundancy in here so I
can work with the project team to condense this
list, if appropriate. I would be interested to get feedback from Dave
Jenkins, Dave Mattison, and Jon Vail too. Wells highlighted in red are already planned for
sampling based on IDR recommendations.
My suggestions include:
1) F-55 (we've discussed this in the past regarding use of SIM to deal with dilution issues).
2) G-50
3) PEW-1
1
·~~
I ,. 4) PEW-3
5) PEW-4
6) J-29
7) H-79
8) V-23
9) K-28
8) 0-59
10) D-56
11) TI-2
12) IT-1,
13) IT-2
14) IT-3
15) IT-4
16) IT-5
17) IT-7
18) W-23
19) OT-5
20) M-44
21) T-35
22) I-57
23) J-59
24) D-88
25) V-65
26) 0-25
27) 0-33
28) Z-78
29) P-58
Doug's List from the IDR report.
(Embedded image moved to file: pic12048.jpg) (Embedded image moved to file: pic15781.jpg)
Stephen Dyment
U.S. EPA, Office of Superfund Remediation and Technology Innovation Technology Integration
and Information Branch 1200 Pennsylvania Ave., NW (5203P) Washington, DC 20460
Phone: [phone]
Cell: [phone]
Fax: [phone]
[e-mail]
Courier Delivery/Visitors:
2777 South Crystal Drive
4th Floor, 5-4614
Arlington, VA 22202
2
A:COM AECOM
One Midtown Plaza
1360 Peachtree Street, Ste 500
Atlanta, Georgia 30309
404.965.9600
404.965.9605
tel
fax
Meeting Action Item Summary
Client: CNA Holdinqs, Inc.
Proiect Name: Shelbv, NC Facilitv
AECOM Project Number: 60135442
Date: March 31, 2010
Location: Telecon
Meeting Purpose: Update EPA/NCDENR on status of project and
recent work
Prepared Bv: Everett Glover
In Attendance
Name Company Telephone E-mail Address
Beth Walden EPA 404-562-8814 walden.bethrmeoamail.eoa.aov
Dave Mattison NCDENR 919-508-8466 david. mattisonlmncdenr.aov
DouQ Sutton GeoTrans, Inc. 732-409-0344 dsuttonrr;-,,..,eotransinc. com
Steve Simoson Celanese 704-636-3919 steven.simoson contractorrn)celanese.com
Brvon Dahlaren AECOM 404-965-9657 brvon.dahlarenmlaecom.com
Everett Glover AECOM 404-965-9687 everett.nlovermlaecom.com
Action Item
Number Action Item Responsibility
0001 Confirm the TestAmerica locations to do analyses for AECOM
environmental samoles
0002 Submit technical memo on DPT work in GRUB area to AECOM
EPAINCDENR
0003 Doug Sutton is to discuss the procedure for diethylene dioxide Doug Sutton -Geo Trans
with Nardina Turner and orovide a recommendation
0004 Doug Sutton is to review the data and recommend a list of wells Doug Sutton -Geo Trans
for SVOC samplinQ
Doug Sutton is to review the data and recommend a list of wells Doug Sutton -Geo Trans
0005 for VOC sampling for resolution of the question of responsibility
for the TCE present at the HH-well location.
0006 Doug Sutton is to review the data and make a recommendation Doug Sutton -Geo Trans
on the need for continued metals samolina.
0007 Submit reference material to Doua Sutton to facilitate his review AECOM
0008 EPA to review timinq for a ROD modification EPA
\\usatls01\data\work\ProJects\79750\WIP\2009 Long Term
Mon\WP FSP\2010 mods & corresp\Shelby 3-31-
10_mtg_min_r1_4-7-10.doc -
AECOM
1455 Old Alabama Rd., Ste. 170, Roswell, GA 30075
T 770.990.1400 F 770.649.8721 www.aecom.com
March 30, 2009
Ms. Beth Walden
Remedial Project Manager
U.S. Environmental Protection Agency
61 Forsyth St. SW
Atlanta, Georgia 30303
Subject: Summary of Understandings Related to the Interim
Field Activities, March 2009
Celanese Fibers Operations Site
Shelby, North Carolina
AECOM Project 79750
Document Control Number 026SB-275
Dear Ms. Walden:
This letter documents the discussions and summarizes the agreements contained in the
attached email communications (Table 1) related to the field work initiated March 16, 2009.
The work was generally outlined in a document titled "Proposed Long-term Sampling Plan,
Celanese Fibers Operations Site -Shelby, North Carolina", Document Control Number -
026SB-269 dated January 26, 2009. As a result of EPA comments on the sampling plan
(email Walden to Glover dated February 25, 2009), the suite of wells was modified slightly with
some wells planned for sampling in the third quarter 2009 sampled in first quarter 2009 and
other wells added to the expanded sampling events planned for third quarter 2009 and first
quarter 2010. Thus, the March 2009 event is an interim or transitional event to satisfy the
semi-annual sampling requirement.
As a result of Nardina Turner's comments related in the email Walden to Glover dated March
17, 2009, the semi-volatile parameter list was retained as originally proposed for the March
event with the understanding that some expansion to the semi-volatile analytical suite would
be performed in the future. The sampling program implemented in March 2009 is shown on
Table 2.
We appreciate EPA's timely responses and negotiation on the approach to the field work to
assist in keeping the project generally on the planned schedule and in assisting in balancing
the fiscal resources available for the project.
If you have questions about the interpretations or the transitional sampling program
implemented, please contact us.
Yours sincerely,
?t:e~~Jr~-(J-
Project Manager
[e-mail]
Shelby_ interim_ samp _approach_ summary_ rO _ 3-30-09. doc
/4 Bryon ahlgren
Project Engineer
[e-mail]
Summary of Understandings Related to the Interim
Field Activities, March 2009
Celanese Fibers Operations Site
Shelby, North Carolina
Attachments
cc: Dave Mattison, NCDENR
QuickPlace Project Site
Theresa Purdy, Ticona
PEM Carter, Ticona
Steve Simpson, for Celanese
AECOM project file
Shelby _interim_ sam p _approach_ summary_ rO _ 3·30-09 .doc
Page2 I AECOM
Summary of Understandings Related to the Interim
Field Activities, March 2009
Celanese Fibers Operations Site
Shelby, North Carolina
Table 1
Summary of Email Communications Related to the March 2009 Field Event
Celanese Fibers Operations Site -Shelby, North Carolina
Email Author Date Subiect Comment
Walden to 25Feb09 EPA comments to provided Doug Sutton and
Glover Proposed Sampling Steve Dyment comments on the
A Plan Proposed Sampling Plan and
transmitted the Revised
Independent Design Review
Renart
Glover to 4Mar09 general response to provided general responses to
Walden comments to March the reviewers comments on the
B 2009 field program Proposed Sampling Plan with
revisions to the wells to be
samoled
Walden to 12Mar09 EPA response to provided concurrence with
Glover March Sampling Plan responses provided in the
C Comments 4Mar09 document with the
exception of the selection of the
semi-volatile analvtes
Glover to 13Mar09 semi-volatile data provides supplemental semi-
Walden revised to include volatile data and for further
D DOWTHERM™A discussion and finalization of
( 1, 1-biphenyl and semi-volatile analytical suite
biohenvl ether)
Walden to 17Mar09 Nardina Turner allowed deferral of expanded
Glover comment on analysis of semi-volatile
E supplemental compounds until a future date
DOWTHERM™A when the levels of
data DOWTHERM™A are reduced in
well F-55
Note: The semI-volatIle data and the Independent Design Review Report referenced In the emails are
not reproduced as part of the attachments to this letter.
Shelby_ interim_ samp _approach_ summary_ rO _ 3-30-09. doc
Page 3 I AECOM
Summary of Understandings Related to the Interim
Field Activities, March 2009
Celanese Fibers Operations Site
Shelby, North Carolina
Table 2
Field Sampling Program Implemented in March 2009
Celanese Fibers Operations Site -Shelby, North Carolina
voes+ Ethylene Field Well Diethylene DowThermA™
Oxide Glycol Parameters
C-49 X X
F-55 X X X X
G-50 X X X
1-57 X X X
K-28 X X X
T-35 X X
V-23 X X X
V-65 X X X
CC-33 X X
AA-54 X X X
DD-58R X X X
GG-61 X X
11-65 X X X
KK-55 X X X
IT-5 X X X
IT-6 X X X
IT-7 X X X
OT-2R X X X
PEW-1 X X X
PEW-3 X X X
PEW-4 X X X
TD-2 X X
TD-3 X X
TD-4 X X
Tl-2 X X X
SW-4 X X
SW-7 X X
Shelby _interim_ sam p _approach_ summary_ rO _ 3-30-09. doc
Page4 I AECOM
Glover, Everett
From:
Sent:
To:
Cc:
Subject:
Attachments:
[e-mail]
Wednesday, February 25, 2009 11 :08 AM
Glover, Everett
Dahlgren, Bryon; Dave Mattison; Peterman, Jeff; Simpson, Steven M., GlobalREM/US;
[e-mail]; [e-mail]; [e-mail];
Vail .Jonatha [e-mail]; Dyment. Stephen@epamail. epa. gov
RE: Oversight Bill and Proposed Sampling Plan
djs comments on draft sampling plan 022309.pdf; 2-25-09 HQComments.doc; revised
celanese 012109.pdf
djs comments on 2-25-09 revised celanese
draft sampling ... :omments.doc (61 K 012109.pdf ( ...
Hi Everett,
The following attachments provide the EPA comments on the Proposed Long-term Sampling Plan, dated Jan 26, 2009.
(See attached file: djs comments on draft sampling plan 022309.pdf)(See attached file: 2-25-09 HQComments.doc)
I have also attached the Revised Independent Design Report, dated Jan.
21, 2009.
(See attached file: revised celanese 012109.pdf)
Should you have any questions, please feel free to contact me.
Beth Walden
Remedial Project Manager
U.S. EPA Region 4
Atlanta Federal Center
61 Forsyth Street
Atlanta, Georgia 30303-3104
Phone: [phone]
Cell Phone: [phone]
Fax: [phone]
"Glover,
Everett"
<EVERETT.GLOVER@ To
aecom.com> Beth Walden/R4/USEPA/US@EPA,
"Dave Mattison"
02/25/2009 09 35 <[e-mail]>
AM cc
"Simpson, Steven M.,
Global REM/US"
<steven.srmpson_contractor@celane
se.com>, "Dahlgren, Bryon"
<[e-mail]>,
"Peterman, Jeff'
<[e-mail]>
Subject
1
RE: Oversight Bill and Proposed
Sampling Plan
A t./a
I am taking no news as good news and we are planning on being in the field March 16, 2009, for the first quarter sampling.
At that time, we will perform the following tasks.
Implement the long-term sampling program as outlined in
Document 026SB-269, dated January 26, 2009, using procedures
previously approved by EPA and consistent with past monitoring
events
Install stream elevation gauges using protocols similar to
the ones used for the existing long-term monitoring points; seven
gauge locations will be installed provided access agreements can
be completed by that time for three off-site locations.
Implement the pilot testing for collecting groundwater
samples as it enters the stream draining the recreation pond on
the southeast portion of the property; one or two points will be
evaluated at this time to develop and prove the procedure to be
used in the future ..
The groundwater monitoring and stream gauge installation will be implemented using procedures that have been used in
the past and approved by EPA. The pilot test will provide data for confirming the procedure included in the work plan and
field sampling plan, or to provide a modification to it so that the larger field investigation can be more efficiently completed
when it is implemented later this year.
II this is not acceptable, please notify us no later than Monday, March 9, 2009, so that the planning and mobilization can be
postponed. Also, please let us know whether EPA or NCDENR will be performing field oversight during the sampling so
that site security can be notified to be expecting the oversight team
If you have questions, please contact me. Later. ewg
Everett W. Glover, Jr. PE
Senior Program Director
D 770.990.1410 C 770.331.1502
eve rett.g [e-mail].
Please note: my email has changed to [e-mail]. Please update your address book accordingly.
This communication is intended for the sole use of the person(s) to whom it is addressed and may contain information that
is privileged, confidential or subject to copyright. Any unauthorized use, disclosure or copying of this communication is
strictly prohibited. If you have received this communication in error, please contact the sender immediately. Any
communication received in error should be deleted and all copies destroyed.
P Please consider the environment before printing this e-mail.
-----Original Message---
From: [e-mail] [mailto:[e-mail]]
Sent Thursday, February 19, 2009 10:25 AM
To: Glover, Everett
Subject: Oversight Bill and Proposed Sampling Plan
Hi Everett,
Please find attached the Oversight Bill for 2008. The costs associated with Paula Walraven are the State costs and not
her time.
2
I have spoken with Doug Sutton and his recollection which I now remember is ... the sampling schedule was rearranged so
that you weren't doing
two $70K events in the first two quarters. He and Stephen Dyment
should have comments, if any, to me by tomorrow.
Thanks,
Beth
(See attached file: CelaneseOversightBill 2008.PDF)
3
MEMORANDUM
TO: Beth Walden, USEPA Region 4
Kathy Yager, USEPA, OSRTI
FROM: Doug Sutton, Geo Trans, lnc.
February 23, 2009 DATE:
RE: Review of Sampling Plan for CNA Holdings/Ticona Facility, Shelby,
North Carolina
GeoTrans appreciates the opportunity to review the sampling plan for the above
mentioned site. My comments are as follows:
• The IDR report suggested continuing to sample the LL, MM, and NN clusters to
confirm that the observed contamination at depth is the result of well installation
and slow groundwater flow. The sampling plan suggests only sampling these
wells during the two expanded events. This may or may not be enough data to
confirm this. Conceptually, I believe that the sampling of these locations should
be included in the base long-term monitoring plan with the understanding that
they can be removed from that plan if the results clearly indicate continued
decreasing concentrations that would support the well-installation hypotl,esis.
• The sampling plan is not clear on what points will be used for collecting water
levels and developing potentiomctric surface maps. The IDR report had indicated
some new and existing surface water gauging stations to include the water level
monitoring.
• PZ-3, PZ-4, and PZ-13 were suggested as sampling locations in the,[DR report. It
is understood that these are not included in the sampling plan because they no
longer exist.
• FF-34 and FF-62 were suggested as sampling locations in the IDR report. It is
understood that these are not included in the sampling plan because they are 1)
redundant with suggested point OT-5, which is included in the plan, and 2) have
already been sampled for TCE with consistent undetectable levels.
• J-29 was suggested as a sampling location in the !DR report. It is understood that
it is not included in the sampling plan it has recently been sampled for TCE and
does not appear to be in ·the primary flow path for TCE.
• CC-33 was suggested as a sampling location in the IDR report. It is not included
in the sampling plan, but I believe that it should be part of the long-term
monitoring plan if the remedial strategy is to revisit source removal and monitor
for a declining trend. CC-33 is a shallow well in a primary migration pathway for
diethylene oxide and will provide some of the more timely information regarding
the effectiveness of source removal.
• Transitioning HH-48 and HH-77 from the existing sampling plan to the expanded
2009120 IO proposed sampling plan suggests that the site team will be able to
make a final determination whether or not this contamination is site-related or is
due to a localized off-site source by the end of 2010. It is realistic to assume that
the expanded 2009/20 IO sampling will provide the information necessary to
conclude whether or not the contamination at the HH wells are linked to the site.
Ifthc contamination detected at the HH wells is linked to the site, then the HH
wells will need to be moved to the long-term plan rather than just in the expanded
plan.
• Tetrahydrofuran is known to be present in the facility's wastewater but has not
been analyzed for in soil and groundwater samples. The presence of this chemical
in the wastewater does not necessarily mean that it is present in the site's soil and
groundwater, but if it is present, the expanded sampling to be conducted in
2009/2010 would be the appropriate time to determine ifit is present and to what
degree it may have migrated from the site. It should also be noted that there
appears to be no NCAC 2L standard for tetrahydrofuran. Tctrahydrofuran is an
8260B parameter, so it can be provided from the analyses suggested in the
sampling plan without further cost. It is just a matter of requesting it be analyzed
and reported. Similarly, site regulators could request that the entire parameter list
for 8260B and 8270C be analyzed for and reported if there is concern that other
contaminants are present on site. A compromise might be to analyze the target
compound list for both of these analytical methods (plus tetrahydrofuran for
8260B).
• IT-1, TT-2, TT-3, TT-4, EE-58, and 0-25 have relatively low diethylene oxide
concentrations compared to neighboring wells. lt is suggested that these wells be
removed from the plan, that K-58 be included, and that W-23 be moved from the
expanded to the baseline monitoring plan.
• The description of the surface water sampling, pa1ticularly for the southeastern
portion of the site, is ambiguous. During the December meeting we had discussed
sampling shallow groundwater as it discharges to surface water in an attempt to
determine where diethylene oxide is discharging to the stream and therefore
exiting groundwater. The plan as it is currently written docs not seem to satisfy
the objectives discussed during the December meeting. First, the plan refers to
surface water sampling. Second, the plan has all points located downb>radient of
the groundwater restricted-use area. Data from the plan, as it is written, would
A s/B
probably not yield sufficient evidence for delineating groundwater impacts and
would likely result in the need to install monitoring wells in this area.
U.S. ENVIRONMENTAL PROTECTION AGENCY
omce of Solid W•ste and Emergency Response
Office of Superfund Remediation and Technology Innovation
Technology Innovation Field Services Division
;1-1/e.
DATE: February 25, 2009
Stephen Dyment FROM:
TO:
Technology Integration and Information Branch
Beth Walden
Remedial Project Manager-CNA Holdings/Ticona Facility, Shelby North Carolina
U.S. EPA Region 4, Atlanta, GA
SUBJECT: Proposed Long-term Sampling Plan. Celanese Fibers Operation Site, Shelby North
Carolina. [Memorandum; dated January 26, 2009] .
Thank you for the opportunity to review the above referenced document. l trust that these comments will
be helpful to you during further development and review of site-specific work strategies at the Ticona
Facility. Please feel free to call me if you have any questions at 703-603-9903.
General Comments
1.) Table 2 provides a list of target compounds for analysis by SW-846 methods 8015B, 8260B, and
8270C. In the case of the 8260B and 8270C methods it would be relatively easy and no
additional cost to include all target compounds and tentatively identified compounds (TI Cs) in
the analytical results. Several compounds not included in the list arc of interest including
Tetrahyrofuran (THF) for 8260B which may prove particularly useful with regard remedy
effectiveness. Likewise the 8270C list is very limited and should include all target compounds
and T!Cs.
Since it appears that a local commercial laboratory will be performing the analyses it may be
beneficial to obtain a target compound list from them regarding the standard compound lists for
8260B and 8270C. Based on those lists we can review to ensure appropriate compounds are
being evaluated.
2.) Although approximate locations for supplemental surface water sampling have been provided, it
is unclear from the memorandum how and where supplemental near stream shallow groundwater
sampling for 8260B compounds will be conducted. As we discussed during the systematic
planning meeting and subsequent calls, one goal of the near stream sampling is to gain
understanding of the groundwater to surface water interactions. In other words how closely to
nearhy groundwater concentrations mirror those found in the stream along various Oow paths.
Do data indicate that contaminant transport is taking place primarily through surface water Oow
or groundwater to surface water discharge'/ It was my understanding that during the initial
sampling, efforts would be made to examine how sampling would be conducted for these near
ft B/B
stream ground water samples. It is also expected that a more comprehensive event will include
sampling within and down gradient of the restricted use area lo form a complete understanding of
this critical pathway.
3.) It is unclear when monitoring well and stream gauging measurements will take place but a series
of comprehensive measurement events were identified as a data need during planning. Every
effort should be made to collect water level measurements at all wells and surface water
locations included in the long term monitoring plan to confirm groundwater pathway
assumptions and strengthen the existing flow model. Any planned sampling events should
consider including water level measurements and extending the measurement beyond wells
identified in Table 1 to include other existing wells and new or existing surface water locations.
4.) Depending on the findings associated with near term sampling of the HH wells and nearby or up
!,'Tadicnt new wells, these wells may or may not be included in the long-term sampling plan. A
place holder for these wells should be included pending the evaluation planned for determining if
TCE in these wells can be considered a localized source. I highly recommend developing agreed
upon decision logic regarding evaluation of sampling results and up gradient sampling so that a
clear exit strategy with regards to these wells is outlined prior to sampling. The logic should
define "trigger points" such that within several sampling events including the placement and
sampling of an up gradient well identified in the !DR, determination of whether to include these
wells in the long-term monitoring plan or remove them from funire site activities can be made.
2
Glover, Everett
From:
Sent:
To:
Cc:
Glover, Everett
Wednesday, March 04, 2009 11 :02 AM
[e-mail]; Dave Mattison
Simpson, Steven M., GlobalREM/US
Subject: Shelby -general response to comments to March 2009 field program
Attachments: Shelby SVOC data -target wells_3-3-09.xls
Thank you for the comments on the sampling plan. We have developed the following general responses.
Page I of2
With regard to the March 2009 event, we will add well CC-33 for analysis for volatiles and diethylene oxide. However, we suggest
that other sampling modifications should be deferred until after the expanded sampling and other field work are complete so that
the long-term monitoring plan reflects the understanding developed from the current work effort.
The initial proposal had recommended two expanded characterization events, followed by a long-term plan. A baseline long-term
sampling plan was included in our development for budgeting and discussion purposes. However, the expectation was that when
the plan was implemented in 2010, it would be revised based on the further knowledge gained through the two expanded events.
One outcome of the January 15, 2009, conference call was an agreement to push back the expanded events into the second half
of 2009 and first half of 201 O as a cost balancing measure to accommodate earlier installation of the new deep II well. Thus, a
smaller scope "long-term" event would be performed for the first half 2009 event. An unintended consequence of this change is
that the long-term plan is being determined without the benefit of the expanded characterization data. A more fitting description of
the upcoming March 2009 event is an "interim or transition" sampling event, preceding the expanded events. Once the expanded
events are completed, the long-term plan will be revisited for initiation in the second half of 2010.
Retaining minimal changes to the scheduled interim March 2009 event is also consistent with the cost balancing strategy
developed as part of the accelerated installation of the new II well.
EPA has indicated that that MM, NN, and LL wells should be included in the long-term plan, with the understanding that they can
be removed if there is an appropriate justification. It is our expectation that the two expanded events, along with additional site
investigations, will provide this justification. The inclusion of these wells in the long-term plan starting in the second half of 2010
will be determined based on the work completed between now and then.
If the TCE analysis completed over the next 18 months indicates that the HH wells are site related, we will include them in the
long-term plan.
We are reviewing the value of THF analysis. If appropriate, we will include this parameter in the expanded characterization
events.
Wells K-58 and W-23 will be added into the expanded characterization plan. Based on the results obtained, these wells will be
considered for inclusion in the long-term plan.
The analytical suites proposed for this and the expanded characterization sampling are based on the historic data developed for
the site when the RI/FS was performed and when tentatively identified compounds (TICs) were measured on both water and soil
samples. The analytical suite has evolved over time with EPA concurrence to what would be included in the monitoring program.
There are established laboratory rates for this site and there will be additional costs associated with longer semi-volatile organic
compound (SVOC) list and with TICs ($95 per sample per method for TICs; $105 per sample for target compound list (TCL)
SVOC versus the cost for 1, 1-biphenyl and biphenyl ether). The 8260B suite could be expanded without cost impact, but looking
at the current list (which is based on an earlier version of the TCL list) compared to the current TCL list with expanded parameters
suggests that the additional compounds would not be expected based on plant operational history. With respect to the 8270G
analyses, the target wells (F-55, PEW-1, PEW-3, and PEWA) planned for this analysis have been tested for 8270 compounds
previously and the results indicate that additional monitoring for these parameters is not merited. Low-level detections of some
target analytes other than the 1, 1-biphenyl and biphenyl ether have been present at well F-55, however, the PEW wells have
shown no impact. The historic data are attached for your reference. Based on these data, we recommend that the site target
compounds of biphenyl ether and 1, 1-biphenyl be retained as the target list for 8270G analysis. This is consistent with the
"Sampling Uncertainties Wksht_Jan09" document developed after the December 5, 2008, meeting at the site
3/26/2009
Page 2 of2
(3 ziz.
Several comments were related to the surface water study. At this time we intend to complete a sampling point installation pilot
study in March 2009 concurrent with the interim sampling event. This study will investigate the methodology for collecting
groundwater infiltration samples as well as surface water concentrations along the creeks. These data will be used to refine the
approach outlined in the work plan and field sampling plan to be used in the larger field program to be implemented this summer.
We are scheduled to start field work March 16 on the interim sampling event which is intended to fulfill the semi-annual sampling
event under the current CERCLA sampling program and provide additional data for refining the expanded sampling events in the
second half of 2009 and the first half of 2010. The March event retains most of the plan commented on by EPA with the additions/
modifications described in the response to comments above. Concurrently, we will install additional surface water monitoring
points and perform the pilot test to gather information on approaches to collect groundwater as it discharges to the small surface
streams exiting the site. This information will be used to refine the work plan for the larger field event planned for later in the
summer.
Please respond by March 11, 2009, with your comments on this recommended approach. If we don't hear from you, we plan to
proceed with mobilization to the site on March 16 in order to stay on schedule to fulfill the semi-annual sampling requirements.
Please contact me if you have any questions. Talk with you later. ewg
Everett W. Glover, Jr. P .E.
Senior Program Director
D 770.990.1410 C 770.331.1502
everett.glover@.aecom.com
AECOM
1455 Old Alabama Road, Ste. 170
Roswell, Georgia 30076
T 770.990.1400 F 770.649.8721
www.aecom.com_
Please note: my email has changed to e'.'{erett,.g[0\l~[~.§fQfil .. GQQ'l. Please update your address book accordingly.
Earth Tee.h's parent company, AECOM Technology Corporation, as it evolves to better serve its clients. is changing the name of Earth Tech, Inc. to AECOM Technical
Services. Inc. Earth Tech's legal structure will not change and Earth Tech's employees will be employees of AECOM Technical Services, Inc. As a member of AECOM's
global environmental business llne, we are able to offer expanded depth and breadth of services drawing on the experience and expertise of AECOM Technical Services and
AECOM's staff.
This communication is Intended for the sole use of the person(s) to whom it is addressed and may contain information that is privileged, confidential or subject to copyright.
Af'ly unauthorized use, disclosure or copying of this communication Is strlctly prohibited. If you have received this communication In error, please contact the sender
Immediately. Any communication received in error should be deleted and all copies destroyed.
~ Please consider the environment before printing this e-mail
3/26/2009
Glover, Everett
From:
Sent:
To:
[e-mail]
Thursday, March 12, 200911:48AM
Glover, Everett
Page I of2
Cc: [e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]
Subject: Re:
Attachments: Copy of TCL VOASVOA.xls; EPA Response to March Sampling Plan Comments.doc
Everett,
As we discussed this morning, I am providing the EPA Response to your March 4th Comments as an attachment.
EPA approves the proposed "interim" sampling approach to implemented In the field next week. Please revise
the Interim Sampling Plan per the attached EPA comments.
Thanks for expediting the submittals.
Beth
-----"Glover, Everett" <[e-mail]> wrote: -----
To: Beth Walden/R4/USEPA/US@EPA
From: "Glover, Everett" <[e-mail]>
Date: 03/12/2009 10: 17AM
Subject:
Everett W. Glover, Jr. P .E.
Senior Program Director
D 770.990.1410 C 770.331.1502
E!y_eJ§l1Lglover@ae_c:orn.corn
AECOM
1455 Old Alabama Road, Ste. 170
Roswell , Georgia 30076
T 770.990.1400 F 770.649.8721
3/26/2009
Page 2 of2
Please note: my email has changed to everett.glovec@a€!C()m,con1 .. , Please update your address book accordingly.
Earth Tech's parent company, AECOM Technology Corporation, as It evolves to better seriie its clients, is changing the name of Earth Tech, Inc. to
AECOM Technical Services, Inc. Earth Tech's legal structure will not change and Earth Tech's employees will be employees of AECOM Technical
Services, Inc. As a member of AECOM's global environmental business line, we are able to offer expanded depth and breadth of services drawing on
the experience and expertise of AECOM Technical Services and AECOM's staff.
This communication is intended for the sole use of the person(s) to whom it is addressed and may contain Information that is privileged, confidential
or subject to copyright. Any unauthorized use, disclosure or copying of this communication is strictly prohibited. If you have received this
communication in error, please contact the sender immediately. Any communication received In error should be deleted and all copies destroyed.
J,,, Please consider the environment before printing this e-mail
3/26/2009
EPA Response to 3/4/09 Email from Everett Glover regarding the March 2009 Field Program.
The EPA Response is in balded text.
With regard to the March 2009 event, we will add well CC-33 for analysis for volatiles and
diethylene oxide. However, we suggest that other sampling modifications should be deferred
until after the expanded sampling and other field work are complete so that the long-term
monitoring plan reflects the understanding developed from the current work effort.
EPA Response: EPA agrees with the exception of the proposed semi-volatile analysis for
a subset of wells. Please see EPA response presented further below.
The initial proposal had recommended two expanded characterization events, followed by a long-
term plan. A baseline long-term sampling plan was included in our development for budgeting
and discussion purposes. However, the expectation was that when the plan was implemented in
2010, it would be revised based on the further knowledge gained through the two expanded
events.
One outcome of the January 15, 2009, conference call was an agreement to push back the
expanded events into the second half of 2009 and first half of 2010 as a cost balancing measure
to accommodate earlier installation of the new deep II well. Thus, a smaller scope "long-term"
event would be performed for the first half 2009 event. An unintended consequence of this
change is that the long-term plan is being determined without the benefit of the expanded
characterization data. A more fitting description of the upcoming March 2009 event is an "interim
or transition" sampling event, preceding the expanded events. Once the expanded events are
completed, the long-term plan will be revisited for initiation in the second half of 2010.
Retaining minimal changes to the scheduled interim March 2009 event is also consistent with the
cost balancing strategy developed as part of the accelerated installation of the new 11 well.
EPA Response: EPA is in agreement with this approach.
EPA has indicated that that MM, NN, and LL wells should be included in the long-term plan, with
the understanding that they can be removed if there is an appropriate justification. It is our
expectation that the two expanded events, along with additional site investigations, will provide
this justification. The inclusion of these wells in the long-term plan starting in the second half of
2010 will be determined based on the work completed between now and then.
EPA Response: EPA thinks the phasing out of MM, NN, and LL wells based on the two
expanded events is optimistic; however, the wells may be left out of the March 2009 event.
If expectations need to be tempered, then expectations can be tempered after the first
expanded event.
If the TCE analysis completed over the next 18 months indicates that the HH wells are site
related, we will include them in the long-term plan.
EPA Response: EPA may be optimistic in the case of the HH well historical detections,
but It is our hope that the results will be a pretty cut and dry result. .. little or no TCE
detected in these transition zone wells (suggesting no link) or a sufficient amount to
establish a link. It may be hard to come up with some reasonable criteria for the decision-
making process without doing some decent modeling/analytical analysis. As such, EPA
would like to see if the data makes the decision for us. After the data collection, the
stakeholders will need to better define the decision; e.g., if the TCE analysis completed
over the next 18 months indicates that the HH wells are site related, we will Include them in
the long-term plan. In other words we should define the sampling and need for upgradient
wells, clearly state X amount of sampling events/at X wells/at X screened interval, and
what concentrations are indicative of the term "site related".
We are reviewing the value of THF analysis. If appropriate, we will include this parameter in the
expanded characterization events.
EPA Response: EPA agrees to review the Celanese recommendation on this issue.
Wells K-58 and W-23 will be added into the expanded characterization plan. Based on the
results obtained, these wells will be considered for inclusion in the long-term plan.
EPA Response: EPA is In agreement.
The analytical suites proposed for this and the expanded characterization sampling are based on
the historic data developed for the site when the RI/FS was performed and when tentatively
identified compounds (TICs) were measured on both water and soil samples. The analytical suite
has evolved over time with EPA concurrence to what would be included in the monitoring
program. There are established laboratory rates for this site and there will be additional costs
associated with longer semi-volatile organic compound (SVOC) list and with TICs ($95 per
sample per method for TICs; $105 per sample for target compound list (TCL) SVOC versus the
cost for 1, 1-biphenyl and biphenyl ether). The 8260B suite could be expanded without cost
impact, but looking at the current list (which is based on an earlier version of the TCL list)
compared to the current TCL list with expanded parameters suggests that the additional
compounds would not be expected based on plant operational history. With respect to the 8270C
analyses, the target wells (F-55, PEW-1, PEW-3, and PEW-4) planned for this analysis have
been tested for 8270 compounds previously and the results indicate that additional monitoring for
these parameters is not merited. Low-level detections of some target analytes other than the
1, 1-biphenyl and biphenyl ether have been present at well F-55, however, the PEW wells have
shown no impact. The historic data are attached for your reference. Based on these data, we
recommend that the site target compounds of biphenyl ether and 1.1-biphenyl be retained as the
target list for 8270C analysis. This is consistent with the "Sampling Uncertainties Wksht_Jan09"
document developed after the December 5, 2008, meeting at the site.
The submitted spreadsheet indicated multiple hits of SVOC concentrations at well F-55
that exceed North Carolina Title 15 GW standards for naphthalene and 2-
methylnaphthalene. Phenol concentrations are increasing over time and approaching the
North Carolina Tille 15 GW standard of 0.3 mg/L (0.26 mg/Lin 2005 and 0.299 mg/L In
2007).
Reporting levels for the F-55 are as much as two orders of magnitude higher than
acceptable for several events presented In the spreadsheet, including the most recent
events. These levels of reporting would only be expected if there were a large positive
result somewhere within the scan, which required dilution of the sample. However, events
such as the October 2008 event show no detects reported that would explain the elevated
reporting levels. Therefore, these events are not useable for decision-making and
subsequent monitoring is warranted based upon the previous detects in F-55
P-cresol has also been above its standard of 0.0035 mg/L. The CLP SVOC list (plus
bi phenyl ether) would be appropriate lo monitor the effectiveness of any additional
characterization and removal of material based on the GRUB area investigation,
particularly at nearby V and IT wells.
At least analyze for the SVOCS that were detected in previous sampling above standards
at the Site unless a study has been conducted to demonstrate that the plume is stable and
decreasing. If cost is an Issue, perhaps Celanese can suggest a subset of wells that
would help them delineate these constituents and monitor their attenuation.
We could put the Issue to rest after a series of sampling events (say 2 or 3) show no
additional detections above appropriate regulatory thresholds or if it does not appear that
expected concentrations based on historical data are increasing.
Several comments were related to the surface water study. At this time we intend to complete a
sampling point installation pilot study in March 2009 concurrent with the interim sampling event.
This study will investigate the methodology for collecting groundwater infiltration samples as well
as surface water concentrations along the creeks. These data will be used to refine the approach
outlined in the work plan and field sampling plan to be used in the larger field program to be
implemented this summer.
We are scheduled to start field work March 16 on the interim sampling event which is intended to
fulfill the semi-annual sampling event under the current CERCLA sampling program and provide
additional data for refining the expanded sampling events in the second half of 2009 and the first
half of 2010. The March event retains most of the plan commented on by EPA with the additions/
modifications described in the response to comments above. Concurrently, we will install
additional surface water monitoring points and perform the pilot test to gather information on
approaches to collect groundwater as it discharges to the small surface streams exiting the site.
This information will be used to refine the work plan for the larger field event planned for later in
the summer.
EPA Response: EPA is in agreement
Glover, Everett
From:
Sent:
To:
Cc:
Subject:
Glover, Everett
Friday, March 13, 2009 12:54 PM
[e-mail]
Simpson, Steven M., GlobalREM/US
Shelby -SVOC analysis
Attachments: Shelby SVOC data including Dowtherm -target wells.xis
Page I of I
D 1(1
Attached is a revised table of SVOC results for the wells F-55, PEW-1, PEW-3, and PEW-4 submitted earlier. This revised table
includes the DOWTHERM™A components (1, 1-biphenyl and biphenyl ether). These analytes were intentionally left off the table
submitted earlier since they were already agreed-upon parameters and the ones that Steve Dyment had highlighted on the
uncertainty worksheets. This updated table supplies information that will help Nardina and you in looking at the data and assuring
yourselves that we know the reasons behind the elevated detections reported for some sampling events at well F-55. Also, I
discussed the situation with the laboratory manager at Davis & Floyd and he indicated that they had developed enough history to
know that well F-55 historically had to be diluted to get data on the 1, 1-biphenyl and biphenyl ether and it appeared they diluted
the sample before the original run to avoid overloading their analytical instrument. This resulted in the raised detection levels for
the other parameters.
I would like to talk with you after you and Nard in a have had a chance to review the data and discuss the need for additional SVOC
analysis further since we feel the data demonstrate that the SVOCs occurring at F-55 are not widespread. I will call you to discuss
this. For now, we are scheduling sampling in this area for the middle of the week so we can have a chance to discuss this and
agree upon a strategy. Talk with you soon. ewg
Everett W. Glover, Jr. P.E.
Senior Program Director
D 770.990.1410 C 770.331.1502
[e-mail]
AECOM
1455 Old Alabama Road, Ste. 170
Roswell, Georgia 30076
T 770.990.1400 F 770.649.8721
www.aecom.com
Please note: my email has changed to ~v~rett.glover@aecp,rn.co_rn. Please update your address book. accordingly.
Earth Tech's parent company, AECOM Technology Corporation, as It evolves to better serve its clients, is changing the name of Earlh Tech, Inc. to AECOM Technical
Seivfces, Inc. Earth Tech's legal structure will not change and Earth Tech's employees will be employees of AECOM Technical Services, lnc. As a member of AECOM's
global environmental business fine, we are able to offer expanded depth and breadth of services drawing on the experience and expertise of AECOM Teehnical Services and
AECOM's staff.
This communication Is intended for the sole use of the person(s} to whom it is addressed and may contain information that is privileged, confidential or subject to copyright.
Any unauthorized use, disclosure or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the sender
immediately. Any communication received in error should be deleted and all copies destroyed .
.,!; Please consider the environment before printing this e-mail
3/26/2009
Glover, Everett
From:
Sent:
To:
[e-mail]
Tuesday, March 17, 2009 11 :21 AM
Glover, Everett
Subject: Fw: Shelby -SVOC analysis
Attachments: Shelby SVOC data including Dowtherm -target wells.xis
~
Shelby svoc data
Including Dow ...
---Forwarded by Beth Walden/R4/USEPNUS on 03/1712009 11:00 AM --
Nardina
Turner/R4/USEPN
US To
Beth Walden/R4/USEPNUS@EPA
03/13/2009 01: 18 cc
PM
Subject
Re: Fw: Shelby -SVOC analysis
(Document link: Beth Walden)
Beth: The data only demonstrate that the high levels of the two main components are elevating the reporting levels of the
other analytes.
They don't demonstrate that those other analytes are not present -only that we can't determine whether or not they are
present This argues for continuing to monitor those analytes in the wells which perhaps are not as highly contaminated
and where better results might be obtained, especially since several SVOAs had been previously detected on the site.
As the levels of contamination in F-55 eventually drop in the course of the remediation, those contaminants would perhaps
re-appear. You could defer monitoring for the other analytes until the high levels of the main contaminants have been
brought down (i.e. decide F-55 is "bad"
regardless and continue to try and remediate), but the additional testing would have to be done at some point to ever be
sure the site was clean. -Nardina
Beth
Walden/R4IUSEPN
US To
Nardina Turner/R4/USEPNUS@EPA,
03/13/2009 01 :06 Stephen Dyment/DC/USEPNUS@EPA,
PM [e-mail], Jonathan
Vail/R4/USEPNUS@EPA
cc
Subject
Fw: Shelby -SVOC analysis
1
Fw: Re: Fw: Shelby -general response to comments to March 2009 field program
•
I of6
-. -Subject: Fw: Re: Fw: .Shelby -general response to comments to March 2009 field program
From: [e-mail]
Date: Thu, 5 Mar 2009 10:43:55 -0500
I • , ••. - - -• ---··•-• •·--•-_. ·-·
l!'.~.::Jenkins.Dave@ep~~i!,eP~:gC>v, clavid.,!!!atti~o.11_@1!':mail.net._.· ----·-•··•~-~
-----Forwarded by Beth Walden/R4/USEPA/US on 03/05/2009 10:41AM -----
To: Beth Walden/R4/USEPA/US@EPA
From: Stephen Dyment/DC/USEPA/US
Date: 03/05/2009 10:24AM
cc: [e-mail], Jonathan Vail/R4/USEPA/US@EPA
Subject: Re: Fw: Shelby -general response to comments to March 2009 field program
I guess they can get rolling but there are some lingering issues that you might want to resolve .......................... .
1) They really do not want to sample for the SVOCs do they. I am not sure what the process was for determining which
SVOCs would end up as COCs at the site so I can't speak to that.
I can say that the attached file of detected SVOC concentrations at well F-55 includes multiple hits that exceed North
Carolina Title 15 GW standards for naphthalene and 2-methylnaphthalene. Phenol concentrations are increasing over time
and approaching the North Carolina Title 15 GW standard of 0.3 mg/L (0.26 mg/Lin 2005 and 0.299 mg/Lin 2007). I
didn't look at results from other wells although I have the data base and can take a look soon.
This begs the question ........... "Is it solely cost that is driving their need to only look for 1,1 biphenyl and biphenyl ether"?
Also what are the action level for these compounds? I couldn't find one in the NC regs and there is no MCL for these. What
is driving the need to continue monitoring these and why only at F-55. It is entirely possible these compounds could show
up at nearby wells but if the P&T is going back on-line then maybe it isn't much of an issue. It's been a while since I
checked commercial lab prices for SVOCs but even the extra costs/sample provided are relatively low given the proposed
scope of work and estimated costs. We could put the issue to bed after a series of sampling events (say 2 or 3) show no
additional detections above appropriate regulatory thresholds or if it does not appear that expected concentrations based on
historical data are increasing. I would also think that the full SVOC list would be appropriate to monitor the effectiveness of
any additional characterization and removal of material based on the GRUB area investigation, particularly at nearby V and
IT wells.
2) I believe it is possible for the stakeholders to better define the decision "If the TCE analysis completed over the next 18
months indicates that the HH wells are site related, we will include them in the long-term plan". In other words we should
3/16/2009 1:18 PM
Fw: Re: Fw: Shelby -general response to comments to March 2009 field program
r
2 of6
define the sampling and need for up gradient wells, clearly state X amount of sampling events/at X wells/at X screened
interval, and what concentrations are indicative of the term "site related". Otherwise we will be fighting over when this
determination can be made and what the definition of "site related" will be.
Stephen Dyment
U.S. EPA, Office of Superfund Remediation and Technology Innovation
Technology Integration and Information Branch
1200 Pennsylvania Ave., NW (5203P)
Washington, DC 20460
Phone: [phone]
Cell: [phone]
Fax: [phone]
[e-mail]
Courier Delivery /Visitors:
2777 South Crystal Drive
4th Floor, 5-4614
Arlington, VA 22202
""Beth Walden---03/05/2009 09:15:51 AM---are we good to go based upon their response? -----Forwarded by Beth
Walden/R4/USEPA/US on 03/05/2009
From:
To:
Cc:
Date:
Subject:
Beth Walden/R4/USEPA/US
Stephen Dyment/DC/USEPA/US@EPA, [e-mail]
Jonathan Vail/R4/USEPA/US@EPA
03/05/2009 09: 15 AM
Fw: Shelby -general response to comments to March 2009 field program
are we good to go based upon their response?
-----Forwarded by Beth Walden/R4/USEPA/US on 03/05/2009 09: 14AM -----
To: Beth Walden/R4/USEPA/US@EPA, "Dave Mattison" <[e-mail]>
From: "Glover, Everett" <[e-mail]>
Date: 03/04/2009 11: 02AM
3/16/2009 1:18 PM
Fw: Re: Fw: Shelby -general response to comments to March 2009 field program
r
3 of6
cc: "Simpson, Steven M., GlobalREM/US" <[e-mail]>
Subject: Shelby -general response to comments to March 2009 field program
Thank you for the comments on the sampling plan. We have developed the following general responses.
With regard to the March 2009 event, we will add well CC-33 for analysis for volatiles and diethylene oxide. However, we
suggest that other sampling modifications should be deferred until after the expanded sampling and other field work are
complete so that the long-term monitoring plan reflects the understanding developed from the current work effort.
The initial proposal had recommended two expanded characterization events, followed by a long-term plan. A baseline
long-term sampling plan was included in our development for budgeting and discussion purposes. However, the expectation
was that when the plan was implemented in 2010, it would be revised based on the further knowledge gained through the
two expanded events.
One outcome of the January 15, 2009, conference call was an agreement to push back the expanded events into the second
half of 2009 and first half of 2010 as a .cost balancing measure to accommodate earlier installation of the new deep II well.
Thus, a smaller scope "long-term" event would be performed for the first half 2009 event. An unintended consequence of
this change is that the long-term plan is being determined without the benefit of the expanded characterization data. A
more fitting description of the upcoming March 2009 event is an "interim or transition" sampling event, preceding the
expanded events. Once the expanded events are completed, the long-term plan will be revisited for initiation in the second
half of 2010.
Retaining minimal changes to the scheduled interim March 2009 event is also consistent with the cost balancing strategy
developed as part of the accelerated installation of the new II well.
EPA has indicated that that MM, NN, and LL wells should be included in the long-term plan, with the understanding that they
can be removed if there is an appropriate justification. It is our expectation that the two expanded events, along with
additional site investigations, will provide this justification. The inclusion of these wells in the long-term plan starting in the
second half of 2010 will be determined based on the work completed between now and then.
3/16/2009 1:18 PM
Fw: Re: Fw: Shelby -general response to comments to March 2009 field program
r
4 of6
If the TCE analysis completed over the next 18 months indicates that the HH wells are site related, we will include them in
the long-term plan.
We are reviewing the value of THF analysis. If appropriate, we will include this parameter in the expanded characterization
events.
Wells K-58 and W-23 will be added into the expanded characterization plan. Based on the results obtained, these wells will
be considered for inclusion in the long-term plan.
The analytical suites proposed for this and the expanded characterization samplfng are based on the historic data developed
for the site when the RI/FS was performed and when tentatively identified compounds (TICs) were measured on both water
and soil samples. The analytical suite has evolved over time with EPA concurrence to what would be included in the
monitoring program. There are established laboratory rates for this site and there will be additional costs associated with
longer semi-volatile organic compound (SVOC) list and with TICs ($95 per sample per method for TICs; $105 per sample for
target compound list (TCL) SVOC versus the cost for 1,1-biphenyl and biphenyl ether). The 8260B suite could be expanded
without cost impact, but looking at the current list (which is based on an earlier version of the TCL Hst) compared to the
current TCL list with expanded parameters suggests that the additional compounds would not be expected based on plant
operational history. With respect to the 8270C analyses, the target wells (F-55, PEW-1, PEW-3, and PEW-4) planned for
this analysis have been tested for 8270 compounds previously and the results indicate that additional monitoring for these
parameters is not merited. Low-level detections of some target analytes other than the 1,1-biphenyl and biphenyl ether
have been present at well F-55, however, the PEW wells have shown no impact. The historic data are attached for your
reference. Based on these data, we recommend that the site target compounds of biphenyl ether and 1,1-biphenyl be
retained as the target list for 8270C analysis. This is consistent with the "Sampling Uncertainties Wksht_Jan09" document
developed alter the December 5, 2008, meeting at the site.
Several comments were related to the surface water study. At this time we intend to complete a sampling point installation
pilot study in March 2009 concurrent with the interim sampling event. This study will investigate the methodology for
collecting groundwater infiltration samples as well as surface water concentrations along the creeks. These data will be
used to refine the approach outlined in the work plan and field sampling plan to be used in the larger field program to be
implemented this summer.
3/16/2009 I: 18 PM
Fw: Re: Fw: Shelby -general response to comments to March 2009 field program
,·
•
5 of6
We are scheduled to start field work March 16 on the interim sampling event which is intended to fulfill the semi-annual
sampling event under the current CERCLA sampling program and provide additional data for refining the expanded sampling
events in the second half of 2009 and the first half of 2010. The March event retains most of the plan commented on by
EPA with the additions/ modifications described in the response to comments above. Concurrently, we will install additional
surface water monitoring points and perform the pilot test to gather information on approaches to collect groundwater as it
discharges to the small surface streams exiting the site. This information will be used to refine the work plan for the larger
field event planned for later in the summer.
Please respond by March 11, 2009, with your comments on this recommended approach. If we don't hear from you, we
plan to proceed with mobilization to the site on March 16 in order to stay on schedule to fulfill the semi-annual sampling
requirements. Please contact me if you have any questions. Talk with you later. ewg
Everett W. Glover, Jr. P.E.
Senior Program Director
D 770.990.1410 C 770.331.1502
[e-mail]
AECOM
1455 Old Alabama Road, Ste. 170
Roswell , Georgia 30076
T 770.990.1400 F 770.649.8721
www.aecom.com
3/1612009 I: 18 PM
Fw: Re: Fw: Shelby -general response to comments to March 2009 field program
6 of6
Please note: my email has changed to [e-mail]. Please update your address book accordingly.
Earth Tech's parent company, AECOM Technology Corporation, as it evolves to better serve its clients, is changing the name of Earth Tech, Inc. to
AECOM Technical Services, Inc. Earth Tech's legal structure will not change and Earth Tech's employees will be employees of AECOM Technical
Services, Inc. As a member of AECOM's global environmental business line, we are able to offer expanded depth and breadth of services drawing
on the experience and expertise of AECOM Technical Services and AECOM's staff.
This communication is intended for the sole use of the person(s) to whom it is addressed and may contain information that is privileged,
confidential or subject to copyright. Any unauthorized use, disclosure or copying of this communication is strictly prohibited. If you have received
this communication in error, please contact the sender immediately. Any communication received in error should be deleted and all copies
destroyed.
,!; Please consider the environment before printing this e-mail
Content-Type:
Shelby SVOC data -target wells_3-3-09.xls Content-Encoding: base64
application/msexcel
3/16/2009 I: I 8 PM
EPA Response to 3/4/09 Email from Everett Glover regarding the March 2009 Field Program.
The EPA Response is in bolded text.
With regard to the March 2009 event, we will add well CC-33 for analysis for volatiles and
diethylene oxide. However, we suggest that other sampling modifications should be deferred
until after the expanded sampling and other field work are complete so that the long-term
monitoring plan·refiects the understanding developed from the current work effort.
EPA Response: EPA agrees with the exception of the proposed semi-volatile analysis for
a subset of wells. Please see EPA response presented further below.
The initial proposal had recommended two expanded characterization events, followed by a long-
term plan. A baseline long-term sampling plan was included in our development for budgeting
and discussion purposes. However, the expectation was that when the plan was implemented in
2010, it would be revised based on the further knowledge gained through the two expanded
events.
One outcome of the January 15, 2009, conference call was an agreement to push back the
expanded events into the second half of 2009 and first half of 2010 as a cost balancing measure
to accommodate earlier installation of the new deep II well. Thus, a smaller scope "long-term"
event would be performed for the first half 2009 event. An unintended consequence of this
change is that the long-term plan is being determined without the benefit of the expanded
characterization data. A more fitting description of the upcoming March 2009 event is an "interim
or transition" sampling event, preceding the expanded events. Once the expanded events are
completed, the long-term plan will be revisited for initiation in the second half of 2010.
Retaining minimal changes to the scheduled interim March 2009 event is also consistent with the
cost balancing strategy developed as part of the accelerated installation of the new II well.
EPA Response: EPA is in agreement with this approach.
EPA has indicated that that MM, NN, and LL wells should be included in the long-term plan, with
the understanding that they can be removed if there is an appropriate justification. It is our
expectation that the two expanded events, along with additional site investigations, will provide
this justification. The inclusion of these wells in the long-term plan starting in the second half of
2010 will be determined based on the work completed between now and then.
EPA Response: EPA thinks the phasing out of MM, NN, and LL wells based on the two
expanded events is optimistic; however, the wells may be left out of the March 2009 event.
If expectations need to be tempered, then expectations can be tempered after the first
expanded event.
If the TCE analysis completed over the next 18 months indicates that the HH wells are site
related, we will include them in the long-term plan.
EPA Response: EPA may be optimistic in the case of the HH well historical detections,
but it is our hope that the results will be a pretty cut and dry result ... little or no TCE
detected in these transition zone wells (suggesting no link) or a sufficient amount to
establish a link. It may be hard to come up with some reasonable criteria for the decision-
making process without doing some decent modeling/analytical analysis. As such, EPA
would like to see if the data makes the decision for us. After the data collection, the
stakeholders will need to better define the decision; e.g., if the TCE analysis completed
over the next 18 months indicates that the HH wells are site related, we will include them in
the long-term plan. In other words we should define the sampling and need for upgradient
wells, clearly state X amount of sampling events/at X wells/at X screened interval, and
what concentrations are indicative of the term "site related".
We are reviewing the value of THF analysis. If appropriate, we will include this parameter in the
expanded characterization events.
EPA Response: EPA agrees to review the Celanese recommendation on this issue.
Wells K-58 and W-23 will be added into the expanded characterization plan. Based on the
results obtained, these wells will be considered for inclusion in the long-term plan.
EPA Response: EPA is in agreement.
The analytical suites proposed for this and the expanded characterization sampling are based on
the historic data developed for the site when the RI/FS was performed and when tentatively
identified compounds (TICs) were measured on both water and soil samples .. The analytical suite
has evolved over time with EPA concurrence to what would be included in the monitoring
program. There are established laboratory rates for this site and there will be additional costs
associated with longer semi-volatile organic compound (SVOC) list and with Tl Cs ($95 per
sample per method for TICs; $105 per sample for target compound list (TCL) SVOC versus the
cost for 1, 1-biphenyl and bi phenyl ether). The 8260B suite could be expanded without cost
impact, but looking at the current list (which is based on an earlier version of the TCL list)
compared to the current TCL list with expanded parameters suggests that the additional
compounds would not be expected based on plant operational history. With respect to the 8270C
analyses, the target wells (F-55, PEW-1, PEW-3, and PEW-4) planned for this analysis have
been tested for 8270 compounds previously and the results indicate that additional monitoring for
these parameters is not merited. Low-level detections of some target analytes other than the
1, 1-biphenyl and biphenyl ether have been present at well F-55, however, the PEW wells have
shown no impact. The historic data are attached for your reference. Based on these data, we
recommend that the site target compounds of biphenyl ether and 1, 1-biphenyl be retained as the
target list for 8270C analysis. This is consistent with the "Sampling Uncertainties Wksht_Jan09"
document developed after the December 5, 2008, meeting at the site.
The submitted spreadsheet indicated multiple hits of SVOC concentrations at well F-55
that exceed North Carolina Title 15 GW standards for naphthalene and 2-
methylnaphthalene. Phenol concentrations are increasing over time and approaching the
North Carolina Title 15 GW standard of 0.3 mg/L (0.26 mg/Lin 2005 and 0.299 mg/Lin
2007).
Reporting levels for the F-55 are as much as two orders of magnitude higher than
acceptable for several events presented in the spreadsheet, including the most recent
events. These levels of reporting would only be expected if there were a large positive
result somewhere within the scan, which required dilution of the sample. However, events
such as the October 2008 event show no detects reported that would explain the elevated
reporting levels. Therefore, these events are not useable for decision-making and
subsequent monitoring is warranted based upon the previous detects in F-55
P-cresol has also been above its standard of 0.0035 mg/L. The CLP SVOC list (plus
biphenyl ether) would be appropriate to monitor the effectiveness of any additional
characterization and removal of material based on the GRUB area investigation,
particularly at nearby V and IT wells.
At least analyze for the SVOCS that were detected in previous sampling above standards
at the Site unless a study has been conducted to demonstrate that the plume is stable and
decreasing. If cost is an issue, perhaps Celanese can suggest a subset of wells that
!·
I
would help them delineate these constituents and monitor their attenuation.
We could put the issue to rest after a series of sampling events (say 2 or 3) show no
additional detections above appropriate regulatory thresholds or if it does not appear that
expected concentrations based on historical data are increasing.
Several comments were related to the surface water study. At this time we intend to complete a
sampling point installation pilot study in March 2009 concurrent with the interim sampling event.
This study will investigate the methodology for collecting groundwater infiltration samples as well
as surface water concentrations along the creeks. These data will be used to refine the approach
outlined in the work plan and field sampling plan to be used in the larger field program to be
implemented this summer.
We are scheduled to start field work March 16 on the interim sampling event which is intended to
fulfill the semi-annual sampling event under the current CERCLA sampling program and provide
additional data for refining the expanded sampling events in the second half of 2009 and the first
half of 2010. The March event retains most of the plan commented on by EPA with the additions/
modifications described in the response to comments above. Concurrently, we will install
additional surface water monitoring points and perform the pilot test to gather information on
approaches to collect groundwater as it discharges to the small surface streams exiting the site.
This information will be used to refine the work plan for the larger field event planned for later in
the summer.
EPA Response: EPA is in agreement
Shelby -general response to comments to March 2009 field program
"
, Subject: Shelby -general response to comments to March 2009 field program
From: "Glover, Everett" <[e-mail]>
Date: Wed, 4 Mar. 2009 11 :02:28 -0500
::fo:,<c'#_alclfn.13~[e-mail]\;;I:,,gaye.Nf~tli.so'nl'.td~vid.111~ttis~n@ti~m~i(ri~tj-)f/•· · .. ·
<:c.0''sifu'psoii;.Steyen'Ni:i·orSb;1~Miu~·•,'2steven'.~iipp,;0Ii,15.3iitr~t(g:r@c~l.P1eS~e:coIIi~;:;•.~=····
Thank you for the comments on the sampling plan. We have developed the following general responses.
With regard to the March 2009 event, we will add well CC-33 for analysis for volatiles and diethylene oxide. However, we suggest that other sampling
modifications should be deferred until after the expanded sampling and other field work are complete so that the long-term monitoring plan reflects the
understanding developed from the current work effort.
The initial proposal had recommended two expanded characterization events, followed by a long-term plan. A baseline long-term sampling plan was
included in our development for budgeting and discussion purposes. However, the expectation was that when the plan was implemented in 2010, it would
be revised based on the further knowledge gained through the two expanded events.
One outcome of the January 15, 2009, conference call was an agreement to push back the expanded events into the second half of 2009 and first half of
201 Oas a cost balancing measure to accommodate earlier installation of the new deep II well. Thus, a smaller scope "long-term" event would be
performed for the first half 2009 event An unintended consequence of this change is that the long-term plan is being determined without the benefit of the
expanded characterization data. A more fitting description of the upcoming March 2009 event is an "interim or transition" sampling event, preceding the
expanded events. Once the expanded events are completed, the long-term plan will be revisited for initiation in the second half of 2010.
Retaining minimal changes to the scheduled interim March 2009 event is also consistent with the cost balancing strategy developed as part of the
accelerated installation of the new II well.
EPA has indicated that that MM, NN, and LL wells should be included in the long-term plan, with the understanding that they can be removed if there is an
appropriate justification. It is our expectation that the two expanded events, along with additional site investigations, will provide this justification. The
inclusion of these wells in the long-term plan starting in the second half of 2010 will be determined based on the work completed between now and then.
If the TCE analysis completed over the nex118 months indicates that the HH wells are site related, we will include them in the long-term plan.
We are reviewing the value of THF analysis. If appropriate, we will include this parameter in the expanded characterization events.
Wells K-58 and W-23 will be added into the expanded characterization plan. Based on the results obtained, these wells will be considered for inclusion in
the long-term plan.
The analytical suites proposed for this and the expanded characterization sampling are based on the historic data developed for the site when the Rl/FS
was performed and when tentatively identified compounds (TICs) were measured on both water and soil samples. The analytical suite has evolved over
time with EPA concurrence to what would be included in the monitoring program. There are established laboratory rates for this site and there will be
additional costs associated with longer semi-volatile organic compound (SVOC) list and with Tl Cs ($95 per sample per method for TlCs; $105 per sample
for target compound list (TCL) SVOC versus the cost for 1, 1 · biphenyl and biphenyl ether). The 8260B suite could be expanded without cost impact, but
looking at the current list (which is based on an earlier version of the TCL list) compared to the current TCL list with expanded parameters suggests that
3/16/2009 I :09 PM
Shelby -general response to comments to March 2009 field program
.. J
the additional compounds would not be expected based on plant operational history. With respect to the 8270G analyses, the target wells (F-55, PEW-1,
.., PEW-3, and PEW-4) planned for this analysis have been tested for 8270 compounds previously and the results indicate that additional monitoring for
these parameters is not merited. Low-level detections of some target analytes other than the 1, 1-biphenyl and biphenyl ether have been present at well
F-55, however, the PEW wells have shown no impact. The historic data are attached for your reference. Based on these data, we recommend that the
site target compounds of biphenyl ether and 1, 1-biphenyl be retained as the target list for 8270G analysis. This is consistent with the "Sampling
Uncertainties Wksht_Jan09" document developed after the December 5, 2008, meeting at the site.
2 of3
Several comments were related to the surface water study. At this time we intend to complete a sampling point installation pilot study in March 2009
concurrent with the interim sampling event. This study will investigate the methodology for collecting groundwater infiltration samples as well as surface
water concentrations along the creeks. These data will be used to refine the approach outlined in the work plan and field sampling plan to be used in the
larger field program to be implemented this summer.
We are scheduled to start field work March 16 on the interim sampling event which is intended to fulfill the semi-annual sampling event under the current
CERCLA sampling program and provide additional data for refining the expanded sampling events in the second half of 2009 and the first half of 2010.
The March event retains most of the plan commented on by EPA with the additions/ modifications described in the response to comments above.
Concurrently, we will install additional surface water monitoring points and perform the pilot test to gather information on approaches to collect
groundwater as it discharges to the small surface streams exiting the site. This information will be used to refine the work plan for the larger field event
planned for later in the summer.
Please respond by March 11, 2009, with your comments on this recommended approach. If we don't hear from you, we plan to proceed with mobilization
to the site on March 16 in order to stay on schedule to fulfill the semi-annual sampling requirements. Please contact me if you have any questions. Talk
with you later. ewg
Everett W. Glover, Jr. P.E.
Senior Program Director
D 770.990.1410 C 770.331.1502
[e-mail]
AECOM
1455 Old Alabama Road, Ste. 170
Roswell, Georgia 30076
T 770.990.1400 F 770.649.8721
www.aecom.com
Please note: my email has changed [e-mail]. Please update your address book accordingly.
Earth Tech's parent company, AECOM Technology Corporation, as it evolves to better serve its clients. is changing the name of Earth Tech, Inc. to AECOM Technical Services. Inc. Earth Tech's legal
structure will not change and Earth Tech's employees will be employees of AECOM Technical Services, Inc. As a member of AECOM's global environmental business line, we are able to offer expanded
depth and breadth of services drawing on the experience and expertise of AECOM Technical Services and AECOM's staff.
This communication is intended for the sole use of the person{s) to whom it is addressed and may contain information that is privileged, confidential or subject to copyright. Any unauthorizE!d use, disclosure or
copying of this communication is strictly prohibited. If you have received this communication in error, please contact the sender immediately. Any communication received in error should be deleted and all
copies destroyed.
P Please consider the environment before printing this e-mail
3/16/2009 I :09 PM
Shelby -general response to comments to March 2009 field program
.J
• Content-Description: Shelby SVOC data -target wells_3-3-09.xls
Shelby SVOC data -target wells_3-3-09.xls Content-Type: application/vnd.ms-excel
Content-Encoding: base64
3 of3 3/16/2009 1:09 PM
Dora Sheau-Yun Chiang
Everett W. Glover Jr.
Jeff Peterman
Joseph Harrigan
Bill DiGuiseppi
David S. Woodward
© 2008 Wiley Periodicals, Inc.
REMEDIAT/ON Winter2008
Evaluation of Natural Attenuation at
a 1,4-Dioxane-Contaminated Site
1,4-Dioxane entered the environment as a result of historic leaks and spills in the production
area at an industrial facility in the southeastern coastal plain. The areal extent of the 1,4-dioxane
plume is several hundred acres and is largely contained on the site. Land use adjacent to the plant
property is primarily undeveloped (wetlands or woods) or industrial, with a small area of mixed
land use (commercial/residential) to the southwest and north. The surficial aquifer is a relatively
simple hydrogeologic system with well-defined boundaries and is comprised of a 50-to 70-foot-
thick deposit of alluvia//fluvia/ sand and gravel that overlies an aquitard in excess of 100 feet thick.
A groundwater flow model, developed and calibrated using field-measured data, was used for
the fate-and-transport modeling of 1,4-dioxane. The flow-and-transport model, combined with
the evaluation of other site geoche/Tlical data, was used to support the selection of monitored
natural attenuation (MNA) as the proposed groundwater remedy for the site. Since the active
sources of contamination have been removed and the modeliflglfield data demonstrated that the
plume was stable and not expanding, the proposed MNA approach was accepted and appro~ed
by the regulatory agency for implementation in 2004. Subsequent accumulated data confirm that
concentrations in the 1,4-dioxane plume are declining as predicted by the fate-and-transport
modeling. © 2008 Wiley Periodicals, Inc.
INTRODUCTION
The chemical I ,4-Dioxanc is a cyclic ether that is highly water-soluble and is a suspected
carcinogen (Parales et al., 1994 ). I, 4-Dioxane was historically used as a stabilizer at 2 to 8
percent by volume of I, 1, I-trichloroethane (TCA; Mohr, 2001) and can be formed as an
undesired by-product from various manufacturing processes. Popoola (1991) investigated
the mechanisms of the reaction involving the formation of 1, 4-dioxane as a by-product
during the production of polyethylene terephthalate (PET). Diethylene glycol (DEG) and
1, 4-dioxane are among the compounds formed in the side reaction during the
esterification process and the subsequent polycondensation step.
There is no federal drinking water standard for 1,4-dioxane; however, it is classified
as a Group B2 (probable human) carcinogen (http:/ /www.epa.gov/iris/subst/0326.htm
and US EPA, 2008). Consequently, it has not been routinely analyzed in groundwater and
commonly not included in the cleanup objectives of regulatory orders (Mohr, 2001).
Stickney et al. (2003) conducted a review on the carcinogenicity of 1,4-dioxane and
indicated that the primary target organs for cancer via the oral route are the liver and nasal
Published online in Wiley lnterscience (www.interscience.wiley.com), DOI: 10.1002/rem.20189 19
Evaluation of Natural Attenuation at a 1,4-Dioxane-Contaminated Site
20
Exhibit 1. 1,4-Dioxane criteria in drinking water, residential soil, and nonresidential soil
Drinking Water/Groundwater Residential Soil Nonresidential Soil
Agency or State (µg/L) (mg/kg) (mg/kg)
WHO (1) 50/-
US EPA Region 3 (2) 6.1/-58 260
US EPA Region 6 (3) 6.1/-44 170 to 520
US EPA Region 9 (4) 6.1/-44 160
California 3/-0.0018 0.0018
Colorado 6.1/6.1 (March 2005)
3.2/3.2 (March 2010)
Florida -/3.2 23 38
Georgia -!-detection limit/0.03
Illinois 1 (or AOL)/-58 520
Maine 32/-
Massachusetts 50
Michigan 85 (residential) 530 7 (OW Protection)
350 (industrial) 56 (GW and SW interface)
2,400-3,400 ( direct contact)
34,000 (GW contact)
Notes:
(1) World Health Organization (WHO) (WHO, 2004).
(2) Region 3 Risk-Based Concentration Table (US EPA, 2007a).
(3) Region 6 Human Health Medium-Specific Screening Levels (US EPA, 2007b).
(4) Region 9 Preliminary Remediation Goals (US EPA, 2004).
AOL: above detection limit.
OW: drinking water.
GW: groundwater.
SW: surface water mg/kg: milligrams per kilogram.
µg/L: micrograms per liter.
-: not listed.
cavity; however, its toxic effects are still uncertain, and it is not clear whether
concentrations in drinking water as high as 0.1 milligram per liter (mg/L) would be
harmful. The U.S. Environmental Protection Agency Integrated Risk Information System
(IRIS) has not derived a reference dose (RID) or a reference concentration (RfC) for
1,4-dioxane, but derived an oral slope factor of 1.1 X 10-2 (mg/kg/day)rl based on the
increased incidence of nasal tumors in male Osborne-Mendel rats (http:/ /www.epa.gov/
iris/subst/0326.htm). As part of its systematic prioritization process, the US EPA is
currently reevaluating the health assessment for 1,4-dioxane. At this point, the US EPA
considers 1, 4-dioxane as an "emerging contaminant" because it is characterized as a
perceived, potential, or real threat to human health or the environment or lack of
published health standards (US EPA, 2008). Many regional and state regulatory agencies
have developed their own water, residential soil, and industrial soil criteria for
1,4-dioxane (US EPA, 2006), which are selectively shown in Exhibit I.
Remediation DOI: 10.1002.rem © 2008 Wiley Periodicals, Inc.
'·
The treatment of 1,4-dioxane has challenged environmental engineers because the
plume rapidly expands in size, potentially in advance of other contaminants, and is
relatively resistant to bio<legradation in the subsurface. In most cases, its behavior in the
subsurface results in a large, low-level dissolved plume. Thus, several research activities
have been undertaken in an attempt to develop better remediation approaches. Bernhardt
and Diekmann ( 1991) conducted an early assessment on 1 ,4-dioxane biodegradation and
indicated that strains isolated from forest soil or activated sludge grown on 1,4-dioxane,
tetrahydrofuran (Tl·IF), and other cyclic ethers could not be enriched or isolated when
1,4-dioxane was used as the sole carbon substrate.
An actinomycete, CB 1190, grown on 1,4-dioxane as the sole carbon source and
energy source, was isolated from a dioxane-contaminated sludge sample (Parales et al.,
1994). This CB I 190 degraded I , 4-dioxane and mineralized 59. 5 percent of the
1,4-dioxane to carbon dioxide (CO,). Mahendra and Alvarez-Cohen (2005) further
characterized CB 1190 and, hased on morphological, physiological, chemotaxonomic, and
phylogenetic evidence, proposed that strain CB 1190 be classified as a novel species,
Pseudonocardia dioxanivorans sp. nov.
Fam (2005) cultured a propanotroph (SL-D) from project sites in Salt Lake City,
Utah, that can utilize propane as a sole carbon source and aerobically degrade at•least 10
mg/L of 1,4-dioxane within days. Mahcndra and Alvarez-Cohen (2006) also verified the
cometabolic transformation of 1,4-dioxane for monooxygenase-expressing strains that
were induced with methane, propane, THF, or toluene. The kinetics of 1,4-dioxane
degradation and identification of the intermediates for cometabolic degradation of
1,4-dioxane by monooxygenase-containing bacteria were evaluated and indicated that the
intermediates would not cause an accumulation of toxic compounds in the environment
(Mahendra & Alvarez-Cohen, 2006; Mahendra et al., 2007). In addition, the
Pseudonocardia sp. Strain ENV478 was isolated by enrichment culturing on THF and found
to degrade 1,4-dioxane after growth on sucrose, lactate, yeast extract, 2-propanol, and
propane (Vainberg et al., 2006).
Shen et al. (2008) identified anaerobic biodegradation of 1,4-dioxane by sludge
enriched with iron-reducing microorganisms. The I ,4-dioxane biodegradation by
iron-reducing bacteria is enhanced by providing iron(lll) oxide + humic acids or
iron(III) + ethylcnediaminetctraacetic acid (EDTA). According"to this study, the humic
acids work as a catalyst to increase the biological activity of the iron-reducing bacteria for
1,4-dioxane degradation. This concept assumes that degradation of 1 ,4-<lioxane first
biologically transfers electrons to the humic acid by the iron-reducing bacteria. After the
humic acid is reduced, it could abiotically transfer electrons to the iron(lll), regenerating
the humic acid to the oxidized form.
These microcosm studies verify that aerobic 1,4-dioxane bioaugmentation and
biostimulation for 1,4-dioxane remediation may be possible. However, verification of
1,4-dioxane biodegradation in the field can be challenging because the monitoring of its
intermediate products is difficult and the supply of a carbon source for cometabolic
biodegradation of 1,4-dioxane may not be technically feasible or, at a minimum, would
not likely be cost-effective for the typical larg~, dissolved 1,4-dioxane plumes.
A recent summary of 1 , 4-dioxane treatment technologies is presented in a US EPA
document (US EPA, 2006) that included various case studies mainly utilizing ex situ
treatment technologi~s (such as advanced chemical oxidation processes). Research and
pilot studies of in situ 1,4-dioxane treatment technologies, using either enhanced
© 2008 Wiley Periodicals, Inc. Remediation DOI: 10.1002.rem
REMEIJIAT/ON Wi11ler 2008
The treatment of 1,4-
dioxane has challenged
environmental engineers
because the plume rapidly
expands in size, potentially
in advance of other con-
taminants, and is relatively
resistant to biodegradation
in the subsurface.
21
•.
Evaluation of Natural Attenuation at a 1,4~Dioxane-Contaminated Site
This article discusses a site
impacted by 1,4-dioxane as
a result of historic leaks and
spills in an indu~trial manu-
facturing plant.
22
biodegradation, chemical oxidation, or an in-well treatment technology, are ongoing,
with limited peer-reviewed publications available on the success or failure of in situ
treatment technologies at a field scale.
This article discusses a site impacted by 1 , 4-dioxane as a result of historic leaks and
spills in an industrial manufacturing plant. Its presence was not associated with chlorinated
solvents usage .. Instead, the 1,4-dioxane was produced and released to the environment as
an indirect by-product of a manufacturing process. A numerical fate-and-transport model
was established to predict the movement and attenuation of 1,4-dioxane, and the model
was later calibrated using field monitoring data. The calibrated model was used to estimate
the half-life of 1,4-dioxane in the subsurface and the rate of 1,4-dioxane degradation
under natural attenuation conditions. Based on the modeling results and long-term
monitoring, the rate of 1,4-dioxane attenuation at the site cannot be explained solely due
to nonbiological and abiotic mechanisms, thereby suggesting the potential pr~sence of
degradation mechanisms that have limited the migration rate and size of the 1, 4-dioxane
plume as demonstrated through the lack of plume expansion over years of monitoring.
SITE HISTORY
The manufacturing plant is located in the southeastern coastal plain. The lateral extent of
the 1,4-dioxane plume is several hundred acres, but the plume is largely contained on the
site. The land use adjacent to the site is primarily undeveloped (wetlands or woods) or
industrial, with a small area ofmixe<l land use (commercial/residential) to the southwest
and north. Throughout the plant's history, the process area was used to manufacture
intermediate chemicals used for the manufacture of industrial polymers.
Site characterization and 1,4-dioxane monitoring started in the early 1990s, and the
investigations provided an understanding of the general level of environmental impact to
the site from past industrial operations. This large data set represents a unique
opportunity for assessing 1,4-dioxane attenuation because it has typically only been
monitored for a much shorter period on chlorinated solvent release sites. The previous
investigations revealed concentrations of para-cymene, xylenes, and I ,4-dioxane in excess
of regulatory standards within the plant process area. Xylenes were also detected in a tank
farm area located northeast of the process area immediately adjacent to an excavated
noncontact eflluent and stormwater discharge canal (Exhibit 2); however, the extents of
para-cymene and xylenes were contained within short distances downgradient of the
identified source areas. 1,4-Dioxane has the largest spatial distribution of the
contaminants detected in groundwater, which is expected since I, 4-diox~e is miscible in
water, does not readily sorb to soil materials, and has a low intrinsic biodegradation
potential. Sources of 1 , 4-dioxane in groundwater were directly attributed to the leaks and
spills in the plant production area. The continuing sources were effectively eliminated
through the replacement of the process sewers and improved spill awareness and response
procedures. Based on data collected since the 1990s, the existing groundwater impact has
been generally limited and is not expanding. Additionally, the contaminant concentrations
in groundwater are not expected to result in surface-water quality exceedances nor pose
an unacceptable risk to potential receptors (i.e., the river adjacent to the site shown in
Exhibit 2). Thus, a monitored natural attenuation (MNA) approach for 1,4-dioxane
Remediation DOI: 10.1002.rem © 2008 Wiley Periodicals, Inc.
Exhibit 2. Site map
contamination in groundwater was considered feasible and was evaluated with the support
of a numerical groundwater fate-and-transport model.
SITE HYDROGEOLOGY
The site area (Exhibit 2) is located in the lower part of the adjacent river basin and is also
located near the confluence of two major rivers that are slow-moving, tidally influenced,
and brackish. The area of land between these two rivers is the most northern part of a
series of sand hills. On the site property, the sand hills have approximately 40 feet of relief.
To the east of the site, the sand hills are bounded by flat tidal wetland areas and to the
west by a cooling water impoundment. Due to the highly permeable nature of the shallow
sands, much of the 50 to 60 inches of average annual precipitation is available for direct
infiltration to the surficial aquifer, the sole source of fresh water in the area. This aquifer is
mainly composed of 50 to 60 feet of post-Miocene sands and gravels, which overlie the
Peedee Formation. An unconformity between the two formations is found between -30
to -40 feet mean sea level (ms!) or 50 to 60 feet below ground surface (bgs). The Peedee
is considered an aquitard, but it contains sandy and gravelly areas at the unconformity and
thin sand lenses containing brackish water at various elev.itions throughout its depth. To
the west of the site, a cooling water impoundment acts as a recharge area with a normal
pool elevation at approximately +9.5 feet msl. To the east of the site, the adjacent river
constitutes a discharge boundary for the aquifer with an average mean surface water level
© 2008 Wiley Periodicals, Inc. Remediation DOI: 10.1002.rem
REM ED/A TION Winter 2008
23
Evaluation of Natural Anenuation at a 1,4-Dioxane-Contaminated Site
.,
..
24
•
.,
0 11JOO ZIOO ----SCALE SN FEET
\
,., . h11 ,.,,
• • • _,_
UC.UC>
"'°'110,u,c ,,n~
"IXl.cl!D°'WCLL
~D WELL
,Ol(JtUl),l{lltt( CQNlQ.I'
~af[A rLOW CIAC(1I0W
Exhibit 3. Potentiometric map for upper portion of surficial aquifer (Summer 2007)
between +I. I and + I . 2 feet msl. A shallow, constructed channel drains east from the
process area and is the discharge channel for cooling tower blowdown and for storm water
collected on-site. This channel is a local discharge feature for the area it traverses.
Groundwater flows from the west to the northeast and southeast through the upper
surficial aquifer under the natural hydraulic gradient (Exhibit 3). An elevated area on the
potentiometric surface is located on the west side of the plant process area. For the lower
portion of the surficial aquifer, eight active production wells had created local cones of
Remediation DOI: 10.1002.rem © 2008 Wiley Periodicals, Inc.
depression during the time represented by this study. These eight production wells
included six nonpotable water wells, located in the east, south, and west of the plant
process area, and two potable wells, located to the far west of the plant process area. The
wells located south and west of the plant, including the two potable wells, were located
relatively far away from the impacted area and had little or no impact on the migration.
The production wells located east of the facility had some impact on the plume migration
and acted as extraction wells for contaminants upgradient of their capture zones.
Insufficient monitoring wells exist to define specific cones of depression around the
production wells.
Based on aquifer testing, the geometric mean and average hydraulic conductivity (K)
ranged from 383 to 413 feet per day (ft/ day) from wells screened in the lower portion of
the surficial aquifer. The Hazen Method was used to estimate the hydraulic conductivity of
the soil samples from depths ranging from Oto 5 feet to 51 to 52 feet bgs, which cover the
upper and lower portions of the surficial aquifer and the upper Peedee Formation. Using
the Hazen Method, K was calculated to be approximately 110 ft/ day for the upper
portion of the surficial aquifer, approximately 260 ft/day for the lower portion of the
surficial aquifer, and approximately 165 ft/day for the upper sandy portions of the Peedee
Formation. Groundwater flow near the river is affected by daily tidal fluctuations of
approximately 2 ft/ day near the site.
Groundwater elevations in the river and at five selected wells were continuously
monitored with automatic data loggers (AD Ls) to investigate tidal influence on the
groundwater elevations. The measurements generally indicated that the magnitude of the
tidal influence on groundwater levels decreases with distance between the wells and the
river. The fluctuations become negligible at approximately 1,700 feet inland in the deeper
portion of the surficial aquifer. In the shallow portion of the surficial aquifer, the tidal
influence is considerably lower in magnitude with distance inland. If a tidal influence
dissipation line is assumed to parallel that for the deeper surficial aquifer, then tidal
influence would become negligible within approximately 500 feet. Thus, away from the
drainage canal east of the process area, the tidal influence in the surficial portion of the
aquifer should be dissipated in the wetlands bordering the river.
SITE 1,4-DIOXANE DATA SUMMARY
I , 4-Dioxane data have been collected from groundwater monitoring wells since 1991 and
the data reveal that I , 4-dioxane is widely distributed across the central and eastern
portions of the site. The highest concentrations of 1,4-dioxanc were detected in the
process area and the tank farm area; however, the maximum 1,4-dioxane concentration
detected on-site has declined from 4.5 mg/Lin 1991 to 0.516 mg/Lin 2006, then to
0. 192 mg/Lin 2007. Exhibit 4 presents the iso-concentration contours for 1,4-dioxane
based on the 2007 monitoring data compared to the 1,4-dioxane extent in 2006.
To demonstrate that 1,4-dioxane concentrations are declining over time,
Mann-Kendall trend analyses have been performed yearly since 2003 on the data collected
during annual sampling events. Evaluation of the data from the 2007 sampling event
showed that 42 wells had sufficient data to analyze by the Mann-Kendall technique.
However, seven of these wells were consistently nondetect for I, 4-dioxane and were
excluded from the analysis resulting in 35 wells in the trend evaluation. This analysis,
© 2008 Wiley Periodicals, Inc. Remediation DOI: 10.1002.rem
Rl-:Mf:JJ/ATION Wimer :2008
The production wells lo-
cated east of the facility had
some impact on the plume
migration and acted as ex•
traction wells for contam•
inants upgradient of their
capture zones.
25
Evaluation of Natural Attenuation at a 1,4-Dioxane-Contaminated Site
26
I-
< -:::---. -: -·· I / c0.005 e,~-::--=-.t=":---.. ~ -=---I O,WtO ..o.ooi::: _. ---~
I I .-·a· -.-_ .:-.-i . n-q ,-:-~-------/ •.:_ _..:...::; ;:;-' _,,
• ,cQ.OQ5 ~ . ,:.¢,TW15
,
\ o~ o:(/..,.,,
- -G'W»B
.· ·-·
/';"" ·~•~i
.-J\.. . .,Yf
0 1200 2400
I ~---SCAlE IN FEET
0
e
'""""' MOHflORINO WELL
'""""""°" WEU.
. D OETECTIONLl.aT(U.005"9'1-)1DO.cr»nQ1..
L,;v~--~kl 0.010ff¢1DO.OIIUff9'1.
-0.100ff9(.ID1.0ff9'1.
- - -EXTENT OF 2COS 1,4-0l()XANE PU.ME
Exhibit 4. Extent of 1,4-dioxane (Summer 2007)
summarized in Exhibit 5, identified that 22 wells (63 percent) showed a downward or
stable trend, 13 wells (37 percent) showed no disc_ernible trend, and no wells showed an
increasing trend. The data that show a trend indicate that 1, 4-dioxane concentrations
within the'plume are declining or have stabilized. Therefore, natural processes (dilution,
dispersion, diffusion, and, to a lesser degree, sorption, and possibly degradation) are
continuing to attenuate the concentrations of 1 , 4-dioxanc arid minimize the potential for
migration and future risks to downgradient receptors (i.e., the adjacent river).
Remediation DOI: 10.1002.rem © 2008 Wiley Periodicals, Inc.
Exhibit 5. Mann-Kendall trend summary
No. of Wells Trend 2007
Count Downward 10
Stable 12
Upward 0
Scattered 13
Nondetect 7
Total Count 42
Percentage Downward 29
Stable 34
Upward 0
Scattered 37
Total 100
MODEL CONSTRUCTION
Flow Model Construction
In order to simulate groundwater flow at the site, the Modular Three-Dimensional
Groundwater Flow Model (MODFLOW) (McDonald & Harbaugh, 1988) was selected.
The flow model size is 21,000 feet by 20,000 feet, with a variable model grid spacing
ranging from a maximum of 100 feet to a minimum of 18 feet. The flow model comprises
four modeling layers: the upper surficial a9uifer (layer 1 ), the middle surficial a9uifer
(layer 2), the lower surfi~ial a9uifer (layer 3), and an upper, sandy Peedee Formation
layer (layer 4), which results in over 291,600 grid cells in the four-layer model.
The flow model calibration process was conducted to bring the simulated heads closer
to the measured heads: A set of 81 groundwater-level measurements from January 22,
2001, was selected as the flow model calibration target set. The generally accepted
industry standard target maximum 10 percent head difference criterion was used to
evaluate the flow model calibration and was based on the range of average measured
groundwater elevation (head) for the wells in each model layer. During the calibration
process, the model parameters that were adjusted included hydraulic conductivity, the
groundwater elevation setting in the drain cells (representing the wetlands), recharge, and
the pumping rate in three of the production wells. The simulated production well flow
rates were based on average pumping rates for the week when the groundwater-level
measurements were made. The flow rates in three production wells were reduced until a
better fit with water levels from nearby monitoring wells was attained. The calibrated
hydraulic conductivity field generally displayed significant heterogeneity both horizontally
and vertically. The calibration statistics show that the overall model has an absolute
residual mean (ARM) of 0. 7 feet, or 6.9 percent of the head range, which is less than the
target maximum of 10 percent of the head range. The simulated potentiometric surfaces
for each model layer also show general agreements with the site potentiometric maps in
the upper and lower portions of the surficial aquifer.
© 2008 Wiley Periodicals, Inc. Remediation DOI: 10, 1002.rem
REMEl)fAT/ON Winter 2008
27
Evaluation of Natural Attenuation at a 1,4-Dioxane-Contaminated Site
The particles were placed
in the higher concentration
portion of the plume, one
layer at a time, so that
particle movement for the
plume configuration could
be displayed.
28
Particle tracking analysis was performed with the calibrated flow model to evaluate
the existing pumping conditions with all eight production wells pumping and the future
"pumps-off' condition without pumping at the production wells. The facility planned to
turn off most of the production wells hut leave one or two wells on the western side of.
the site remote from the 1,4-dioxane-impacted area for potable water production.
1,4-Dioxane was selected as the solute to track the particle movements. Particle track
simulations were performed for each model layer for each pumping scenario. The
particles were placed in the higher concentration portion of the plume, one layer at a
time, so that particle movement for the plume cOnfiguration could be displayed. The
1,4-dioxane plume traveled from the plant process area vertically into the lower portions
of the surficial aquifer before horizontally traveling to the east. With the production wells
off, the flow path was shallower and migrated either to the canal or to the adjacent river.
Under the production well "pumps-on" condition, the flow path goes deeper below the
process area due to pumping from the more productive zones in the aquifer and migrates
to the upper sandy portions in the top of the Peedee Formation before traveling east.
Along the path cast, the two eastern production wells intercept part of the flow, with the
remainder traveling on to the canal and the adjacent river; however, under both scenarios,
the particle tracking plots show that the drainage canal east of the process area has a strong
influence on the local flow field.
· Transport Model Construction
The calibrated flow model was then used for solute transport model simulations. The
solute fate-and-transport modeling was performed with the MODFLOWT software
(Duffield et al., 1996) to evaluate the use of MNA as a partial or total remedy at the site.
The solute fate-and-transport model addresses sophisticated processes, including physical
transport and retardation mechanisms, as well as degradation mechanisms. It was
anticipated that physical mechanisms (advection, dispersion, dilution, etc.) are the
primary processes controlling the 1,4-dioxane plume movement at the site; however, the
fate-and-transport analysis and evaluation of 1,4-dioxane ·chemical data indicated that
degradation of 1,4-dioxane under the site conditions is possible. The degradation
half-lives for 1,4-dioxane were therefore first estimated based on literature reviews and a
kinetic study of historical chemical data collected since the early 1990s. Finally, solute
transport simulations were run under various scenarios, including with and without
degradation, and with and without the groundwater production wells pumping.
1,4-Dioxane Half-Life Analysis
Based on the historical data, 1,4-dioxane concentrations appear to decline over time. The
numerical simulation under the assumption of no degradation appears to underestimate
the decline in 1 , 4-dioxane concentrations measured in the field. The 1 , 4-dioxane
degradation half-life for use in the model simulation was evaluated based on the historical
field measurements at two layer I wells and four layer 3 monitoring wells. These wells
are located in different areas and at different depths relative to the plumes to represent
different groundwater flow and solute attenuation regimes. The time series of simulated
1,4-dioxane concentrations were plotted for each selected well, assuming no degradation
and degradation half-lives of three years, five years, and seven years (equivalent to
Remediation DOI: 10.1002.rem © 2008 Wiley Periodicals, Inc.
degradation constants of 0.231 /year, 0.139/year, and 0.099/year, respectively), and
compared to the measured 1,4-dioxane data. Overall, the numerical simulation of
1,4-<lioxane, with a seven-year degradation half-life (corresponding to a degradation rate
of0.099/year), better simulated the field measurements than other half-lives while
providing a conservative half-life estimation.
Fate-and-Transport Simulations
The initial concentrations for all four model layers were based on groundwater samples
collected from monitoring wells in June 2001 and from direct-push technology (DPT)
locations in November 2000. The initial concentrations were established in spreadsheets
with units of micrograms per liter (µg/L) and exported to Su,fer 7 (Golden Software, Inc.,
1999) for gridding and contouring. These observed concentration contours were then
interpolated for each model grid cell to achieve a numerical representation of the observed
concentration distribution. The following solute transport scenarios were evaluated:
Existing conditions with continuing operation of the existing production wells
• Without degradation
• With degradation
• Future pumps-off condition with degradation of 1,4-dioxane (Exhibit 6)
RESULTS AND DISCUSSION
Model Simulations Under Existing Pumping Conditions
With No Degradation
Assuming that degradation is not occurring, this transport simulation shows the
1,4-dioxane plume size persists for 40 years for all layers, and the plume in layer 4 has no
significant shrinkage after 40 years. This is probably due to the hydraulic conductivity in
layer 4 being lower than it is in the overlying surficial aquifer. Also, the flow path
indicated by the particle track flow evaluation travels down into layer 4 while migrating
east and then back upward toward the canal and the adjacent river. The plume appears to
be migrating toward the canal east of the process area, which is a significant hydraulic
discharge location.
· Model Simulations Under Existing Pumping Conditions
With Seven-Year Half-Life Degradation
Assuming a half-life of seven years, this transport simulation shows 1,4-dioxane
dissipating in less than 20 years in layers 1 and 2 and persisting over 20 years in layers 3
and 4. The layer 3 plume is greatly reduced in size after 20 years, and it appears it will fall
below the groundwater target level of0.007 mg/L within a few years beyond the 20-year
model time step. The layer 4 plume still has considerable lateral extent after 20 years, and
it appears it will fall below the target level within 40 years. The presence of the plume in
layer 4, the upper, sandy portion of the Peedee Formation, after 20 years is probably due
to the hydraulic conductivity being lower than that in the overlying surficial aquifer. In
addition, the flow path indicated by the particle track flow evaluation travels down into
© 2008 Wiley Periodicals, Inc. Remediation DOI: 10.1002.rem
REME/JIATION Winter 2008
The initial concentrations
for all four model layers
were based on groundwa-
ter samples collected from
monitoring wells in June
2001 and from direct-push
technology (DPT) locations
in November 2000.
29
Evaluation of Natural Attenuation at a 1,4-Dioxane-Contaminated Site
I.nyer J ln,'da/ Concenlralion
_,..,
' • '1 •
'" ,.
'" ~ 11)1 , \ 110,
~
/Ayer I T = JO Ye~~r,~ ' _...,
r_\ II) • -..
Exhibit 6. 1,4-Dioxane simulations under pumps-off scenario with 1,4-dioxane half-life of seven years
30 Remediation DO1: 10.1002.rem © 2008 Wiley Periodicals, Inc.
layer 4 while migrating east and then back upward toward the canal and the adjacent river.
Again, the plume appears to be migrating toward the canal east of the process area.
Model Simulations Under Pumps-Off Condition With Seven-Year
Half-Life Degradation
This transport simulation assumes the half-life is seven years and the production wells are
no longer active. The initial concentrations of the t, 4-dioxane plume and the 1, 4-dioxane
extent after ten years of natural attenuation for all four model layers are shown in
Exhibit 6. The simulation results show that l ,4-di<;>xane persists for 20 years without
significant plume shrinkage in layer 4. This is probably because the hydraulic conductivity
of the upper sandy portion of the Peedee Formation is lower than in the overlying surficial
aquifer. The 1,4-dioxane concentration within the plume declined to below the target
level within 40 years in layer 4, but the concentration drops below the target level in
layers 1 and 2 within 10 to 20 years. In layer 3, the 1 , 4-dioxane concentration within the
plume was mostly below the target level by 20 years. In agreement with previous
simulations, the 1,4-dioxane plume appears to be migrating toward the canal, which is
located east of the process area and is a significant hydraulic discharge location. This set of
plume plots, without the operation of the production well pumps, shows a slightly
different plume configuration over time when compared to the existing pumping
conditions. The plume under the existing pumping conditions shows a more southerly
migration; however, the approximate time for the plume to fall below the target level is
about the same for the simulations under both pumps-on and pumps-off conditions.
The process of estimating the degradation half-lives for 1,4-dioxane suggested that
degradation was occurring to some degree and that the nondegradation scenario, which is
the worst-case scenario, underestimated the decay of 1,4-dioxane concentrations
measured in the field (i.e., overestimated the plume extent and persistence). Thus, the
nondegradation scenario was not considered representative of ongoing conditions at the
site. Thus, degradation was interpreted as having a strong influence on controlling the
do~ngradient migration of 1,4-dioxane. The historical measured data for 1,4-dioxane, in
general, supported the simulated results that the 1,4-dioxane plume was stable or
decreasing in size and decreasing in concentration. Overall, the numerical simulation of
1,4-dioxane with a seven-year degradation half-life (corresponding to a degradation rate
of0.099/year) better simulated the field measurements.
Based on the fate-and-transport model and the continuing monitoring of groundwater
at the site, the use of MNA as the sole remedy following the completion of source control
was recommended and has been implemented and ongoing since 2004. The most recent
data collected in 2007 arc generally in line with the predicted concentrations based on the
seven-year half-life, and further support the fact that some degradation is occurring.
MNA Evidence Based on Field Measurements
As indicated previously, the groundwater monitoring data indicate that the 1,4.dioxane
concentrations are decreasing and the plume is not expanding. The behavior of
1,4-dioxane is consistent with the model simulations based on a seven-year half-life of
1,4-dioxane under the pumps-off condition. The geochemical conditions at the site were
also monitored in support of natural attenuation verification. Exhibit 7 presents the
© 2008 Wiley Periodicals, Inc. Remediation DOI: 10.1002.rem
REMEIJIATION Winter 2008
The historical measured
data for 1,4-dioxane, in
general, supported the
simulated results that the
1,4-dioxane plume was
stable or decreasing in
size and decreasing in
concentration.
31
Evaluation of Natural Attenuation at a 1,4-Dioxane-Contaminated Site
------7
I
0 600 1,,,
32
l
TW~. ~~-~~~-:.~~:~-~~ ~·-~ ..
rw,e_..,-:-
nv11 -54 ° -. =:.=-;. .;-.:~.. •=-::.:~.
•
0
•
0
·.102
'. \ ~\ ·. \
~}t?t~;'/
-101
LEGEt-o
ORP<=·50
-50<0RP<=O
()cQ~c:50
ORP,.50
QRPc50
U,Jtln rrN
Exhibit 7. Distribution of ORP (Summer 2007)
general distribution of oxidation-reduction potential (ORP) at the site. The site is
generally under reducing conditions based on evidence of negative OR.P measurements,
methane generation (data not shown) in the plant process and canal areas, and detections
of ferrous iron (Exhibit 8). The extent of negative ORP and ferrous iron correlates well
with the locations of reductions in 1,4-dioxane plume concentration and size, suggesting
the potential for biological attenuation of 1,4-dioxane. Although the geochemical
parameters indirectly verify the presence of biological activity or potential intrinsic_
biodegradation of 1,4-dioxanc, there is no direct evidence (such as monitoring of its
intermediate products or 1,4-dioxane-degrading microorganisms) to confirm the
biological degradation mechanisms of 1,4-dioxane. The Shen et al. (2008) paper on
anaerobic biodegradation of 1,4-dioxane by _iron-reducing microorganisms suggests the
Remediation DOI: 10.1002.rem © 2008 Wiley Periodicals, Inc.
Rf.'Mf,'/JIAT/ON Winter 2008
.... ~ .
OT~~ ~~~~~~F~~=--~·~·
1:,-________ .,_-i el \
-\ L ':::,· \ ' I _:... _::.::::_~~ '
F -· -::---..4 \ ' -----:.---~ ·, . = ,. 1--~:l~~;;i--~ \. "',
!
I i
H
6
I, .
I I I I
i I
I
iii
-::=-,;.~ ~:-12-1 0
--: ':.-
TW19 11 ·
IltV17 6,0~ --_ -:_:.:_.; ... -.· -~~---1 ;~i-:-;~.;-,.·
TWO 34
~
rf r,, ~--
1W13
~
l.EOENO
0 FERROUS IRON<=0,2 . fl • O.l•FERROUS IRON•\
\..J 0 1 c:FERROUS IRON•5
e FERROUS lRON••5
-FERROVS IRON• 1
Corcertratlcn Unts In mgll.
Exhibit 8. Distribution of ferrous iron (Summer 2007)
possibility of 1,4-dioxanc degradation under iron-reducing conditions. This mechanism
may be one of the contributors that control the 1,4-dioxane migration.
Another attenuating mechanism that is currently being widely discussed is diffusion of
the solute into immobile or nearly immobile porosity in fine-grained materials. The
surficial aquifer :it this site is predominantly fine, medium, and coarse sands and fine gravel
with a relatively small percentage of silt-and day-sized particles. Where present, these
finer materials are generally in the shallower portions of the aquifer and are not as
prevalent in the medium and coarse sands that comprise most of the saturated portion of
the surficial aquifer. Thus, it is expected that the impact of the immobile porosity is
relatively small on the 1,4-dioxane attenuation observed at the site.
© 2008 Wiley Periodicals, Inc. Remediation DOI: 10.1002.rem 33
Evaluation of Natural Attenuation at a 1,4-Dioxane-Contaminated Site
MNA is a viable consid-
eration after source re-
duction and control; how-
ever, MNA of 1,4-dioxane
is not yet a commonly ap-
proved approach because
1,4-dioxane is generally
considered to be biologi-
cally recalcitrant in ground-
water and the evidence of
natural biodegradation of
1,4-dioxane is limited.
34
CONCLUSION
The need for treatment of a large, diluted 1,4-dioxane plume has been challenging. MNA
is a viable consideration after source reduction and control; however, MNA of
1,4-dioxane is not yet a commonly approved approach because 1,4-dioxane is generally
considered to be biologically recalcitrant in groundwater and the evidence of natural
biodegradation of 1,4-dioxane is limited. In addition, no field-scale demonstration of
1,4-dioxane biodegradation has been documented in the literature. Additionally, because
1,4-dioxane is not regulated by the federal government, the fate and transport of
1,4-dioxane has not been well characterized at as many sites as other common
contaminants, such as chlorinated ethenes and ethanes.
The l ,4-dioxane plume at this site covers several hundred acres in size, which makes
pump-and-treat and other more aggressive treatment technologies cost-prohibitive.
However, because this study site has an abnormally long duration of 1,4-dioxane data
(since the 1990s), which demonstrates steady declines in concentration, M~A was
recommended and approved as the remedy for the site. This MNA recommendation was
based on a combination of long-term 1,4-dioxane monitoring data, geochemical data
collection, and a well-established fate-and-transport model that increases the confidence
level in understanding 1,4-dioxane behavior in the subsurface.
The groundwater flow model was developed and calibrated to acceptable levels with
an absolute residual mean in each model layer of less than IO percent of the head range.
Under the calibrated flow conditions, the dissolved 1,4-dioxane plume would likely travel
to the canal or to the adjacent river under the pumps-off condition. Under the production
well pumps-on condition, the flow path goes deeper below the process area into the top of
the upper sandy portion of the Peedee Formation before traveling east. Along the path
east, the two eastern production wells intercept part of the flow, with the remainder
traveling on to the canal and the adjacent river.
Two phases of solute transport simulations were undertaken. These were ( l)
estimating the site-derived half-life for 1,4-dioxane and (2) performing dissolved-phase
transport simulations. Half-lives of two, three, and seven years were evaluated for
1,4-dioxane. The l ,4-dioxane simulation results were also combined with the evaluation
of other site geochemical field data to support the selection of MN A as the proposed
groundwater remedy for the site (reported elsewhere). Since the active sources of
contamination had been removed and the modeling/field data demonstrated that the
concentrations were declining and that the plume was stable, the proposed MNA
approach was approved by the regulatory agency for implementation in 2004.
In general, the model simulations indicate that the impact of 1,4~dioxane degradation
is greater than that from production pumping. The production wells captured some of the
1,4-dioxane plume but had little influence on the cleanup times, with the simulations with
no degradation showing significantly longer cleanup times. The degradation scenarios are
considered valid for the site because the simulated 1,4-dioxane concentrations versus time
series match the observed data better than when degradation is not considered. The
predictions indicate that the 1,4-dioxane will migrate to the river, where it will discharge
as base flow; however, concentrations discharging to the river are expected to be
acceptable.
Remediation DOI: 10.1002.rem © 2008 Wiley Periodicals. Inc.
Since 2004, a long-term monitoring plan has been implemented to monitor the
groundwater and surface water conditions over time and to verify that the constituents in
groundwater are behaving as predicted. The 2007 data continue to indicate declining
concentrations within the plume and that the 1,4-dioxane plume is not expanding
(Exhibit 5), and the geochemical data (Exhibit 7 and Exhibit 8) verify the presence of
biological chemically reducing conditions suggesting that these conditions may be
contributing to the attenuation of the 1,4-dioxane plume. The monitoring activities will
continue to document the changes of the plume with time.
REFERENCES
Bernhardt, D., & Diekmann, H. {1991). Degradation of dioxane, tetrahydrofuran and other cyclic ethers by an
environmental Rhodococcus strain. Applied and Microbiology Biotechnology, 36, 120-123.
Duffield, G. M., Beregar, J. J., & Ward, 0. S. {1996). A modular three-dimensional groundwater flow and
transport model. User's manual, Version 1.23.
Fam, S. A. (2005, June). Rapid degradation of 1,4-dioxane using a cultured Propanotroph. Presented at the
Eighth International tn Situ and On-Site Bioremediation Symposium, Baltimore, Maryland. Golden
Software, Inc. (1999). Surfer 7. Golden, CO: Author.
Mahendra, S., & Alvarez-Cohen, L. (2005). Pseudonocardia dioxanivorans sp. nov., a novel actinomycete that
grows on 1,4-dioxane. International Journal of Systematic and Evolutionary Microbiology, 55,
593-598.
Mahendra, S., & Alvarez-Cohen, L. {2006). Kinetics of 1,4-dioxane biodegradation by
monooxygenase-expressing bacteria. Environmental Science and Technology, 40, 5435-5442.
Mahendra, S., Petzold, C. J., Baidoo, E. E., Keasling, J. D., & Alvarez-Cohen, L. (2007). Identification of the
intermediates of in vivo oxidation of 1,4-dioxane by monooxygenase-containing bacteria. Environmental
Science and Technology, 41, 7330-7336.
McDonald, M. G., & Harbaugh, A. W. (1988). A modular three-dimensional finite-difference ground-water
flow model. Denver, CO: U.S. Geological Survey.
Mohr, T. K. G. (2001). Solvent stabilizers. Republication copy. San Jose, CA: Santa Clara Valley Water District.
Parales, R. E., Adamus, J. E., White, N., & May, H. D. (1994). Degradation of 1,4-dioxane by an actinomycete
in pure culture. Applied and.Environmental Microbiology, 60, 4527-4530.
Popoola, A. V. (1991). Mechanism of the reaction involving the formation of dioxane byproduct during the
production of poly(ethylene terephthalate). Journal_ of Applied Polymer Science, 43, 1875-1977.
Shen, W.-R., Chen, H., & Pan, S. (2008). Anaerobic biodegradation of 1,4-dioxane by sludge enriched with
iron-reducing microorganisms. Bioreso~rce Technology, 99, 2483-2487.
Stickney, J. A., Sager, S. L., Clarkson, J. R., Smith, L.A., Locey, 8. J., Bock, M. J., et al. (2003). An updated
evaluation of the carcinogenic potential of 1,4-dioxane. Regulatory Toxicology and Pharmacology, 38,
183-195.
U.S. Environmental Protection Agency (US EPA). (2004). Preliminary remediation goals tables for Region 9.
Retrieved October 30, 2008, from http://www.epa.gov/region09/waste/sfund/prg/
© 2008 Wiley Periodicals, Inc. Remediation DOI: 10.1002.rem
H.EMEJJIATION Winter 2008
35
Evaluation of Natural Attenuation at a 1,4-Dim-.ane-Contaminated Site
36
U.S. Environmental Protection Agency {US EPA). {2006, December). Treatment technologies for 1,4-dioxane:
Fundamentals and field applications. EPA-542-R-06--009. Washington, DC: Office of Solid Waste and
Emergency Response.
U.S. Environmental Protection Agency (US EPA}. (2007a). Human health risk assessment-Risk-based
concentrations table for Region 3. Retrieved October 30, 2008, from http://www.epa.gov/region3
U.S. Environmental Protection Agency (US EPA). (20076). Human health medium-specific screening levels for
Region 6. Retrieved October 30, 2008, fromhttp://www.epa.gov/region6
U.S. Environmental Protection Agency {US EPA}. (2008, April). Fact sheet emerging contaminant-1,4
dioxane, solid waste and emergency response. EPA 505-F-07-004. Washington, DC: Author.
Vainberg, S., McClay, K., Masuda, H., Root, D., Candee, C., Zylstra, G. J., et al. (2006). Biodegradation of
ether pollutants by Pseudonocardia sp. Strain ENV478. Applied and Environmental Microbiology, 72,
5218--5224.
World Health Organization (\'VHO). (2004, July). 1,4-Dioxane-Background document for development of
WHO guidance for drinking-water quality, rolling revision of the WHO guidelines for drinking-water
quality, draft for review and comments. WHO/SDE/vVSH/04.08/120. Geneva, Switzerland: Author.
Dora Sheau-Yun Chiang, PhD, P.E., is a senior engineer for AECOM Environment in Roswell, Georgia.
She specializes in monitored natural attenuation evaluation, design, implementation, and data evaluation for
in situ bioremtdiation, in situ chtmical oxidation, and other in situ innovativt ttchnologits for treatment of
1.4-dioxane, chlorinated solvents, pttroleum compounds, and PAHs. Sht rectivtd htr BS and MS in chemistry
at Chung Yuan Univtrsity, Taiwan, htr MS in environmental enginetring at the Illinois Institute ofTtchnology,
and her PhD in environmental engineering at tht Georgia lnstitutt of Ttchnology.
Everett W. Glover Jr., P.E., is a stnior program dirtctor with AECOM Environment in Roswtll, Georgia.
He specializts in dirtction and participation in transactional due diligtnct evaluations, site characterization,
remedial evaluations, and regulatory liaison. He has over 15 years' exptritnce in invtstigating and rtmediating
1,4-dioxane-impacted sites in various geologic settings. Ht received his BS and MS in civil engineering at Wtst
Virginia Univtrsity.
Jeff Peterman is a project manager and senior gtologist with AECOM Environmtnt in Roswell, Georgia. Ht
is txptritnctd in environmtntal and construction project managemtnt with projtct txptrience in geologic and
hydrogtologic investigations, remtdial action plan prtparation, remediation system pilot testing and conceptual
design, construction oversight, remtdiation systtm optration and maintenance, undtrground storagt tank
removals, environmental site assessmtnts, rtport and permit prtparation, and rtgulatory ntgotiations. He
received his BS in geology at the University of Texas, Arlington.
Joseph Harrigan, P.G., is a project manager and senior hydrogeologist with AECOM Environment in Greenville,
South Carolina. He specializes in ptrforming 2D and 30 groundwater flow and transport modeling (MOOFLOW,
MT3D, MDDFLOW-Surfact, MODFLOWT, MODPATH, FLOWPATH, and MOC) for water resources investigations,
ftasibility studies, and rtmedial dtsigns using single-and multi-sptcits transport modeling. Ht is also ex-
perienced in the use of 3D visualization tools to support environmental, geophysical, and hydrological data
inttrpretation and rtporting. He rtceived his BA in gtology at Humboldt State University and his MS in geology
at the University of South Carolina.
Remediation DOI: 10.1002.rem © 2008 Wiley Periodicals, Inc.
Bill DiGuiseppi, P.G., is a principal hydrogeologist and corporate: Environmental Technical Practices Net-
work Leader with AECOM Environment in Denver, Colorado. He has over 20 years of experience in a diverse
set of remedial technologies, including pump-and-treat, soil vapor extraction/dual-phase extraction, in situ
bioremediation, and in situ chemical oxidation. In his work relating to 1,4-dioxane remediation, DiGuisc:ppi has
coauthored papers, chaired conference sessions, and been an invited speaker at national and regional confer-
ences. He received his BS in geology from George Mason University and his MS in geology from the University
of Utah.
David S. Woodward is the director of remediation technology for AECOM Environment in Mechanicsburg,
Pennsylvania. He specializes in monitored natural attenuation evaluations; the design and implementation of
a variety of in situ technologies; and sustainable remediation evaluations. He received his BS in earth sciences
from Frostburg State University.
© 2008 Wiley Periodicals, Inc. Remediation DOI: 10.1002.rem
REMJ,,'IJIATJON Winter 2008
37
Shelby -general response to comments to March 2009 field program
I of 3
Subject: Shelby -general response to comments to March 2009 field program
From: "Glover, Everett" <[e-mail]>
Date: Wed, 4 Mar 2009 11 :02:28 -0500
tJ'o: <[e-mail]>, "Dave Mattisori'"0<david.mattison@ncmail:net>
'cc: "Simpson, Steven M.; Globa!REM/US" <steven.sifopson _ contractor@celanese'.tom> --~---...; -•--•-n-•-•---~----•---•• -----•-•~·-• •--~~ -•~ -'•••-·•· ~---· .... ', ___ •-"----·-••••-•• •·••-•-----••••~•"'·•·••~-""-----• --••~¥•-"
Thank you for the comments on the sampling plan. We have developed the following general responses.
With regard to the March 2009 event, we will add well CC-33 for analysis for volatiles and diethylene oxide. However, we suggest that other sampling
modifications should be deferred until after the expanded sampling and other field work are complete so that the long-term monitoring plan reflects the
understanding developed from the current work effort.
The initial proposal had recommended two expanded characterization events, followed by a long-term plan. A baseline long-term sampling plan was
included in our development for budgeting and discussion purposes. However, the expectation was that when the plan was implemented in 2010, it would
be revised based on the further knowledge gained through the two expanded events.
One outcome of the January 15, 2009, conference call was an agreement to push back the expanded events into the second half of 2009 and first half of
201 O as a cost balancing measure to accommodate earlier installation of the new deep II well. Thus, a smaller scope "long-term" event would be
performed for the first half 2009 event. An unintended consequence of this change is that the long-term plan is being determined without the benefit of the
expanded characterization data. A more fitting description of the upcoming March 2009 event is an "interim or transition" sampling event, preceding the
expanded events. Once the expanded events are completed, the long-term plan will be revisited for initiation in the second half of 2010.
Retaining minimal changes to the scheduled interim March 2009 event is also consistent with the cost balancing strategy developed as part of the
accelerated installation of the new 11 well.
EPA has indicated that that MM, NN, and LL wells should be included in the long-term plan, with the understanding that they can be removed if there is an
appropriate justification. It is our expectation that the two expanded events, along with additional site investigations, will provide this justification. The
inclusion of these wells in the long-term plan starting in the second half of 2010 will be determined based on the work completed between now and then.
If the TCE analysis completed over the next 18 months indicates that the HH wells are site related, we will include them in the long-term plan.
We are reviewing the value of THF analysis. If appropriate, we will include this parameter in the expanded characterization events.
Wells K-58 and W-23 will be added into the expanded characterization plan. Based on the results obtained, these wells will be considered for inclusion in
the long-term plan.
The analytical suites proposed for this and the expanded characterization sampling are based on the historic data developed for the site when the RI/FS
was performed and when tentatively identified compounds (TICs) were measured on both water and soil samples. The analytical suite has evolved over
time with EPA concurrence to what would be included in the monitoring program. There are established laboratory rates for this site and there will be
additional costs associated with longer semi-volatile organic compound (SVOC) list and with TICs ($95 per sample per method for TICs; $105 per sample
for target compound list (TCL) SVOC versus the cost for 1, 1-biphenyl and bi phenyl ether). The 8260B suite could be expanded without cost impact, but
looking at the current list (which is based on an earlier version of the TCL list) compared to the current TCL list with expanded parameters suggests that
3/4/2009 2:33 PM
Shelby -general response to comments to March 2009 field program
2 of3
the additional compounds would not be expected based on plant operational history. With respect to the 8270C analyses, the target wells (F-55, PEW-1,
PEW-3, and PEW-4) planned for this analysis have been tested for 8270 compounds previously and the results indicate that additional monitoring for
these parameters is not merited. Low-level detections of some target analytes other than the 1, 1-biphenyl and biphenyl ether have been present at well
F-55, however, the PEW wells have shown no impact. The historic data are attached for your reference. Based on these data, we recommend that the
site target compounds of biphenyl ether and 1, 1-biphenyl be retained as the target list for 8270C analysis. This is consistent with the "Sampling
Uncertainties Wksht_Jan09" document developed after the December 5, 2008, meeting at the site.
Several comments were related to the surface water study. At this time we intend to complete a sampling point installation pilot study in March 2009
concurrent with the interim sampling event. This study will investigate the methodology for collecting groundwater infiltration samples as well as surface
water concentrations along the creeks. These data will be used to refine the approach outlined in the work plan and field sampling plan to be used in the
larger field program to be implemented this summer.
We are scheduled to start field work March 16 on the interim sampling event which is intended to fulfill the semi-annual sampling event under the current
CERCLA sampling program and provide additional data for refining the expanded sampling events in the second half of 2009 and the first half of 2010.
The March event retains most of the plan commented on by EPA with the additions/ modifications described in the response to comments above.
Concurrently, we will install additional surface water monitoring points and perform the pilot test to gather information on approaches to collect
groundwater as it discharges to the small surface streams exiting the site. This information will be used to refine the work plan for the larger field event
planned for later in the summer.
Please respond by March 11, 2009, with your comments on this recommended approach. If we don't hear from you, we plan to proceed with mobilization
to the site on March 16 in order to stay on schedule to fulfill the semi-annual sampling requirements. Please contact me if you have any questions. Talk
with you later. ewg
Everett W. Glover, Jr. P.E.
Senior Program Director
D 770.990.1410 C 770.331.1502
[e-mail]
AECOM
1455 Old Alabama Road, Ste. 170
Roswell, Georgia 30076
T 770.990.1400 F 770.649.8721
www.aecom.com
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Shelby -general response to comments to March 2009 field program
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Fw: Kay's input into article on natural attenuation of 1,4-dioxane
Sub}ect: F~: -KajS-il1pllt into artide-On natu~I ~ttefl-u3tion of 1 :4-d~oXane
From: [e-mail]
Date: Thu, 15 Jan 2009 12:05:27 -0500 iro: david.mattison@,0n:::c.::m.::a:,il:.c·":.c<:::<c_ ____________________________________________________________ _
I of 5
Forwarded by Beth Walden/R4/US~PA/US on 01/15/2009 12:03 PM
Kay
Wischkaemper/R4/
USEPA/US
01/13/2009 08: 44
AM
To
Dave Jenkins/R4/USEPA/US@EPA
cc
Ben Bentkowski/R4/USEPA/US@EPA,
Beth Walden/R4/USEPA/US@EPA, Bill
Osteen/R4/USEPA/US@EPA, Dave
Jenkins/R4/USEPA/US@EPA, Elliott
Jones/R4/USEPA/US@EPA, Glenn
Adams/R4/USEPA/US@EPA, JohnT
Wilson/ADA/USEPA/US@EPA, Martha
Otto/DC/USEPA/US@EPA
· Subject
Kay"s input into article on
natural attenuation of
1,4-dioxane{Document link: Beth
Walden)
Dave, Thanks for looking at this and firing off the eTMil. I strongly
support your observations and recommendations and in addition would like
to add that
nMNA TMY work at this site. may indeed be that MNA is the selected
remedy following a risk TMnagement decision of various components of
consideration such as a)the plume conformation (or architecture)
indicates the plume is not growing in aerial or vertical extent, b)
the time for an engineered remedy to restore groundwater is
equivalent to MNA, c) the suspected·use of groundwater for drinking
water in the area does not involve groundwater within the next 40
years, d) institutional controls are in place to prevent use of
contaminated groundwater, e) groundwater migration to surface water
is not causing an adverse effect on aquatic life, etc.
A figure,defining where in the plume the degradation is decreasing,
stable, scattered and Non-detects is very important. This would
involve a cross-sectional depiction as wells as an aerial depiction.
This is so important since if the plume is stagnating in the
downgradient portions of the plume, above the health based standard,
then MNA is not operating as a remedy to restore groundwater, it's
possibly not even containing groundwater.
Kay Wischkaemper, P.G.
Hydrogeologist
U. S. EPA Region 4 / Superfund Div/ Technical Services Section
10th Floor
61 Forsyth St., SW, Atlanta, GA 30303-8960
Phone: [phone]
FAX: [phone]
wischkaemper [e-mail]
1/26/2009 2:43 PM
Fw: Kay's input into article on natural attenuation of 1,4-dioxane
2 of5
Dave
Jenkins/R4/USEPA
/US
01/06/2009 03:06
PM
To
Glenn Adams/R4/USEPA/US@EPA
cc
Dave Jenkins/R4/USEPA/US@EPA,
Beth Walden/R4/USEPA/US@EPA,
JohnT Wilson/ADA/USEPA/US@EPA,
Martha Otto/DC/USEPA/US@EPA, Bill
Osteen/R4/USEPA/US@EPA, Kay
Wischkaemper/R4/USEPA/US@EPA, Ben
Bentkowski/R4/USEPA/US@EPA,
Elliott Jones/R4/USEPA/USOEPA
SUbject
Re: Fw: article on natural
attenuation of 1,4-dioxane
(Document link: Kay Wischkaemper)
DOES ANY ONE HAVE COMMENTS REGARDING THESE ISSUES? Please offer some
feedback,
Martha Otto, EPAHQ, called the following paper to my attention. (See
attached file: 081231 Evaluation of Natural Attenuation at a
1,4-Dioxane-Contaminated Site.pd£)
This paper describes natural attenuation of 1,4-dioxane at an
unidentified site on the Cape Fear River near Wilmington NC in EPAR4.
According to Javier Garcia EPAR4, this not a RCRA corrective action site
based on data in RCRA Info. The facility appears to be a RCRA
regulated as a hazardous waste generator. Beyond this I know nothing
about this site except what is in the article. The conclusions cited in
the paper may be valid. But based on the data presented, the methods
described should NOT become standard procedure for approving MNA
remedies in EPAR4.
First, the paper presents a very sketchy description of the background
data supporting MNA as a remedy. No trend graphs are presented.
Instead, the paper relies on Mann-Kendall analysis to tally the
degradation trends. The results are summarized in Exhibit 5 (p.9/19).
The site history (p.4/19) says the site has been under investigation
since the early 1990s. The introduction states the EPA approved MNA as
the remedy in 2004. So the conclusions in this trend analysis may be
based on 15 years of monitoring well samples.
Mann-Kendall trend analysis is a useful technique during the first few
years of any MNA investigation. However, I believe that it is important
to recognize that if statistics are required to see a trend in 15 years
of data, then degradation probably isn't fast enough clean the site in a
reasonable time. From Exhibit 5 (p.9/19) the degradation trend in 7ll
of the wells is either stable or scattered. With 15 years of record, I
would categorize the trend in these wells as Not Degrading. From
Exhibit 5 (p.9/19) the trend in only 29\ of the wells is downward. The
number of wells in which natural attenuation inconclusive or not
apparent is 2.5 times greater than the number of wells in which there is
a clear and meaningful trend of decreasing concentrations.
The Mann-Kendall analysis alone is an inadequate demonstration of the
effectiveness of MNA as a remedy. The interpretation of the data
presented above tends to weaken the statement on p.10/19 that ~eased on
the historical data, 1,4-dioxane concentrations appear to decline over
time.~ The appearance of contaminant declines over time is very
subjective not quantitative, and based on Exhibit 5, it is not very
1/26/2009 2:43 PM
Fw: Kay's input into article on natural attenuation of 1,4-dioxane
3 of5
encouraging.
Second, EPA guidelines regarding MNA clearly state that MNA should be
evaluated based on field observations not model results. But this paper
proceeds quickly from the sketchy description of degradation rates to
the predictions of a successful clean up based on the model results.
The 1,4-dioxane degradation half-life for use in the model simulation
was evaluated based on the historical field measurements at two layer
wells and four layer 3 monitoring wells• (p.10/19). Clearly, these 6
wells were selected from the 29t of wells with declining trends because
degradation was not apparent in the other wells. A half-life can't be
determined in wells where concentrations are not decreasing or the
results are too scattered to identify a trend. But Exhibit 5 shows that
711 of the wells are not behaving in a manner similar to the 6 wells
Selected. So model results based solely on what is presented in this
paper are not conclusive proof that MNA is a viable remedy for this
site. Essentially, the degradation rates used in the model are some of
the best possible rates which could have been selected at this site.
Data from 711 of the wells is ignored, and mod.el projections are based
on favorable degradation assumptions.
The report makes the following conclusions regarding the mod.el
simulations where the degradation rate was assumed to be zero:
Assuming that degradation is not occurring, this transport simulation
shows the 1,4-dioxane plume size persists for 40 years for all layers,
and the plume in layer 4 has no significant shrinkage after 40 years
n (p.11/19).
The report makes the following conclusions regarding the model
simulations where the degradation rate was assumed to be equivalent to a
half-life of 7 years: "Assuming a half-life of seven years, this
transport simulation shows 1,4-dioxane dissipating in less than 20 years
in layers 1 and 2 and persisting over 20 years in layers 3 and 4. The
layer 3 plume is greatly reduced in size after 20 years, and it appears
it will fall below the groundwater target level of 0.007 mg/L within a
few years beyond the 20-year mod.el time step. The layer 4 plume still
has considerable lateral extent after 20 years, and it appears it will
fall below the target level within 40 years.•
If degradation is not apparent in 711 of the wells after 15 years (2
half-lives) of monitoring, then clearly, the mod.el simulations where the
degradation rate was assumed to be zero are more likely to be correct.
MNA may work at this site. But the data needed to make this
determination is not presented in this paper. It seems more likely that
residual sources, as defined in ~source Zone Assessment and Remediation
•. (ISBN: 0-309-54664-8, NAS 2005, page 16/371) are present. EPA should
consistently consider the following definition when evaluating MNA:
SOURCE DEFINITION: The•-NRC committee -created a definition of
•source• that would capture the essence of a source as a reservoir
of contamination while making a distinction between the source zone
and the plume of contaminated groundwater_: A source zone is a
saturated or unsaturated subsurface zone containing hazardous
substances, pollutants, or contaminants that acts as a reservoir
that sustains a contaminant plume in groundwater, surface water, or
air, or acts as a source for direct exposure. This volume is or has
been in contact with separate phase contaminant {NAPL or solid).
Source zone mass can include sorbed and aqueous phase contaminants
as well as contamination that exists as a solid or NAPL.• (ISBN:
0-309-54664-8, Source Zone Assessment and Remediation NAS2005.pdf,
page 16/371).
Residual sources may be sustaining the 1,4-dioxane concentrations at 711
of the wells. Rather than evaluate the progress toward MNA as described
in this article, the MNA remedy at this site should be evaluated at the
next 5-Year Review according to the methods described below. If MNA is
not on track to clean the site in a reasonable time, the appropriate
site-specific contingency remedy should be implemented.
1/26/2009 2:43 PM
Fw: Kay's input into article on natural attenuation of 1,4-dioxane
4 of5
RECOMMENDATION:
l.) EPAR4 should avoid lTlllking regulatory decisions regarding MNA which
are based on model predictions.
2.) All sites with MNA remedies should be required to present
monitoring well data which demonstrates clear and meanin~ful
progress toward achieving the cleanup goal using MNA. This
evidence should be evaluated as described by John T. Wilson, EPA
Ada OK, in a paper titled KAil approach for Five Year Review to
see of MNA on track !or the clean up goal~ (National Association
of Remedial Project Monagers (NARPM) Annual Training Conference,
Portland, OR, 09JUL08.) The method requires parties to agree on
both a target clean up level and a targ@t clean up time, and
provides an unbiased means of demonstrating progress toward the
target clean up level. The method can Qe applied consistently
and comparably from site to site.
3.) The method also reqUires a groundwater monitoring program. with
data from monitoring wells properly located in the plume to
provide data regarding the progress of natural attenuation. But
it is important to recognize that monitoring wells measure
contaminant concentrations at points in a flow path and are not
modeled interpretations of contaminant concentrations in a flow
path. Over time the axis of a plume may move around the vicinity
of a well, but the sample results should demonstrate a clear and
meaningful decreasing erend in contaminant concentratione over
time. This approach eliminates all concerns regarding the
validity of any groundwater model.
David N.Jenkins
Hydrogeologist
Technical Support Section
Superfund Division
U.S. EPA Region 4, Atlanta
404-562-8462
(Embedded irnag"e moved to file: picOOl 70. jpg)
1/26/2009 2:43 PM
Fw: Kay's input into article on natural attenuation of 1,4-dioxane
5 of 5
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Comments on the Journal Article
On page 25 of the article, the maximum 1,4-dioxane concentration is reported to have ,
been 4.5 mg/Lin 1991, 0.516 mg/Lin 2006, and 0.192 mg/Lin 2007. That data appears
impressive in terms of the concentrations decreasing substantially over time until one
considers that source control occurred and that concentrations may have dramatically
declined predominantly due to that source control factor, especially since the maximum
concentrations cited all appear to be from the source area, regardless of when the
maximum concentration was measured (reference text on page 25 in the sentence
beginning "The highest concentrations of 1.4-dioxane ... ")
On pages 26 and 27, the article suffers from a data summarization problem and a
definition problem. Is there a serious problem lurking in the data that the sururnarization
covers up? There is no way to know for sure but I think there is, as explained below.
One might reasonably ask that given the concentration data shown on Exhibit 4 of the
article, how bad can the data summarization situation be? It could be quite a problem
when it comes to predicting contaminant cleanup times, as the selection of wells for
estimation of the contaminant half life (see the next paragraph of this review) is a
continuation of the data summarization problem. The definition problem I refer to is that
the article does not clearly indicate what a scattered trend is, although the context
indicates it is another way of saying the data are too variable to identify any potential
trend.
On page 28 the 1,4-dioxane halflife analysis discusses historical field measurements at
different wells in different layers. It is unclear from the analysis presented in the article if
these wells are representative or "best case" examples, or how the time-concentration
history of different wells varies over time. However, I believe that a rudimentary
mathematical analysis demonstrates that these wells are entirely or mostly in fact pulled
from the subset of wells with downward trends. Those wells are truly a "best case"
subset for evaluating contaminant halflife. Refer to Exhibit 5 in the article. On the basis
of only the classification of wells as "downward," or "stable" (since "scattered"
presumably means no trend is apparent, which is the same as "stable" as far as I am
concerned), an equitable breakdown of wells for estimation of an apparent overall half
life of 1,4-dioxane using time-concentration data would be a ratio of3 downward
trending wells to 7 wells with no apparent change in concentration over time (these no
change wells could reasonably be called wells where the 1,4-dioxane has a halflife of
infinity, but that would complicate the calculation of an overall half life using this
equitable data set). I question whether or not the evaluation of the 1,4-dioxane half life
considered the no trend wells at all, because even if the no trend wells are assumed to
have a half life of I 00 years, and an equitable mixture of no trend and downward trend
wells are used to calculate a 1,4-dioxane half life (7 no trend and 3 downward trend
wells), then the article's average half life of? years, if calculated on the basis of a
geometric mean, would require that for the 3 half lives determined from the downward
trending wells, the average halflife would be approximately 0.Q15 years. This halflife is
an absurdly low value. Below, I have included a summary of how I derived this average
half life for the three downward trending wells. Even if the 7 no trend wells are assumed
to each be monitoring ground water where the 1,4-dioxane halflife is 50 years, averaging
(geometric mean) these halflives with the halflives from the remaining 3 downward
trending wells would require the average halflife of the downward trending wells to be
about 0.1 years. That value is still absurd. So I think a large flaw in the evaluation
presented in this article is tied into the apparent degradation rate. There might be one or
two no trend wells that were considered in the half life calculations summarized in the
article, but the "black box" aspects of the paper don't allow one to evaluate if that is the
case. Again, based upon Exhibit 5, most of the wells that should be considered at this site
for calculating the half life are the no trend wells, and if that procedure wasn't done, the
halflife analysis summarized in the paper is fatally flawed.
Further commentary on the halflife analysis presented in the paper is that (I) it appears
odd that the middle surficial aquifer is not represented at all in the half life estimations
(reference text at the bottom of article page 28); (2) there are twice as many lower
surficial aquifer wells as upper surficial aquifer wells used in the half life estimation and
no explanation is given for why this should be the case, and (3) there is also no apparent
rationale for selection of the three different potential contaminant half life estimates. If
an apparent degradation rate constant of0.099/y (7 year halflife) is better than a rate
constant of0.139/y (5 year halflife), would an even lower rate constant be better than
0.099/y? Of course the monitoring data being matched to these apparently arbitrary
degradation rate constants are probably heavily biased in favor of the downward trending
wells to begin with, so these additional points are probably irrelevant, since I believe the
entire rate constant derivation is fatally flawed because of the selective subset of data
used to calculate the rate constant.
The contaminant transport modeling was apparently set up to consider 1,4-dioxane
contamination under a no degradation scenario and a degradation scenario using the
apparent half life based upon an interpretation of time-concentration data from the subset
of wells selected on some unspecified basis. The apparently better match between
observed and model-predicted concentrations using the assumed degradation halflife
then appears to be used to validate the selected half life. This is a sort of circular logic
process and, because a no degradation condition is equivalent to a halflife of infinity (see
my point above), fil!Y data set where there is some degree of degradation at all would
better match an assumed 7 year half life than a halflife of infinity. Would a halflife of
50 years or I 00 years or 500 years be an even better choice than 7 years?. Who knows?
Halflife calculation:
7 no trend wells with an assumed half life of I 00 years
Average halflife of7 years (rate constant of0.099/y)
3 wells with an average halflife that is unknown:
Geometric mean= 7 years = ( I 00• I 00• l 00• l 00• I 00• I 00• 100• average unknown half life•
average unknown halflife• average unknown halflife)°-1
Solve for the unknown.
Comments on Your Review
I don't totally concur with your review although I think you are correct overall when your
comments are applied to this specific paper. See the point by point discussion on some of
your comments which are presented below. Also, I don't see in the article that the
facility is regulated by EPA. As I mentioned to you last week, I think this is probably a
state lead facility and it is probably regulated under RCRA.
" ... if statistics are required to see a trend in 15 years of data, then degradation probably isn't fast
enough (to) clean the site in a reasonable time." l _________________________________ -
The Mann-Kendall analysis alone is an inadequate demonstration of the effectiveness of MNA as
a remedy. [ ______________________________________________________ _
If degradation is not apparent in 71 % of the wells after 15 years (2 half-lives) of monitoring, then
clearly, the model simulations where the degradation rate was assumed to be zero are more
' '
likely to be correct. L ________________________________________________ ,
Rather than evaluate the progress toward MNA as described in this article, the MNA remedy at
this site should be evaluated at the next 5-Year Review according to the methods described
below. l ________________________________________________________ _
' ' ' ' '
' '
'
'
' ' ' '
Comment: You are correct for some or
maybe most situations but not all
situations. There may be a very low rate
of decline that requires a statistical
analysis to "demonstrate" the trend and
degradation is entirely adequate because
initial concentrations are so low that it
doesn't matter that the change in
concentration is not discemable by
simply "eyeballing" a data set
Comment: If you are referring 10 this
paper in panicular, I agree. However,
there may be a condition at some oilier
site iu which a statistically-based trend
analysis alone is an adequate
de"monstration of MNA effectiveness. I
don't have specifics to offer, bul am
philosophically wary of making absolute
statements such as this one.
Comment: I totally agree with the first
part of this comment A reality check on
the half life is to apply it backwards. You
have sort of done that here. As to your
point that a zero degradation halflife
simulation would be more correct. it
makes iutuitive sense, but since it deals
with infinity, among other 1hings, I am
wary of stating it would be morc likely to
be correct You might state that in the
absence of any apparent degradation in
most oftl1e mouitoring wells, the only
reasonable approach to modeling the
contamination is lo assume there is no
degradation, as a generality.
Comment: If this facility is not
reb>ulated wider CERCLA, there is
probably not a 5-Year Review aspect that
the facilily musl comply with. 1l1is
comment probably needs lo be more
generic and less CERCLA-specific.
181 I I l I I l l I : : ii l I I I i I Ii I I : i i : : : i : I : l i i in l l l J l l I I Ii l ,~ i l n n I I I I I I~ In i : l l F
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NCAC Title I SA Subchapter 2L
I of I
Subject: NCAC Title 15A Subchapter 2L
rrom: [e-mail] ,
pate: Tue, 2 D~c 2008. 12:06:42_-0500 \
:ro: EVERETT.GLOVER@,cca:..:.e.:...co:..cin:..:.·:..:.c.:...om"-'----~-----------------------------'-.-J
Hi Everett,
EPA looks to standards and technological requirements from other federal
and state environmental and public health laws to help select CERCLA
cleanup levels and design response actions.
CERCLA Section 12l(d) (2) (A) requires that remedial actions comply with
any substantive standard, requirement, criteria, or limitation
11 promulgated11 under a state environmental or facility siting law that is
more stringent than any comparable federal standard, requirement,
criteria, or limitation that meets the ARARs threshold criteria.
Pursuant to this CERCLA section, only those substantive state standards
that are (l) identified by a state in a "timely11 manner, (2)
promulgated, and (3) more stringent than federal requirements may
qualify as ARARs. If a state standard meets these three threshold
criteria, it is a potential ARAR which EPA must evaluate on a
site-specific basis to determine if it is either "applicable" or a
"relevant and appropriate11 requirement, or a 11 to-be-considered: criteria
to ensure protectiveness of the response action, and whether
circumstances exist at the site to justify waiving the ARAR.
The bottom line for the Celanese Site in Shelby is the Title 15A,
Subchapter 2L.0106 is not an ARAR. I have verified this with our legal
counsel as well as the NC Remedial Section Chief. I think for our
meeting on Friday, we should focus on the technical concerns and moving
forward under the NCP. I don't know if there is much benefit to
discussing the NC standards in this meeting -other than telling CNA
that it is not an ARAR.
Please feel free to give me a call to discuss,
Beth
12/3/2008 12:05 PM
Re: Fw: Shelby -draft meeting agenda, site meeting, 8:00 AM, December 5, 2008
I of 4
Subject:-Re: Fw: Shelby -draft meeting agendi, site meeting, 8:00 AM, December 5, 2008
From: [e-mail]
Date: Wed, 12 Nov 2008 13:03:02 -0500
~o: [e-mail] · J
CC: [e-mail], [e-mail], [e-mail], [e-mail],
Campbell.Richard@~pamail.epa.g,_o_v ___________________________________ _
Some of the technical issues are directly impacted by the discussion of
enforceable standards. How can we develop a sampling program without
understanding what our action levels and COCs are? More importantly
what are the goals of additional work and what is our exit strategy and
performance metrics (ie how do we know when we are done?).
It seems to me that some of these issues can be identified and resolved
prior to a technical discussion. Perhaps in conjunction with the site
visit (before, after, or both) we have a conference call/internet
discussion to resolve outstanding issues. It is very difficult to have
a technical discussion without an agreement (EPA/NCDENR) as to what
uncertainties are priorities that we must resolve. Some of those
uncertainties will translate directly to enforceable standards while
others are information we need to make a decision regarding feasibility
of proposed remedy or optimization.
Stephen Dyment
U.S. EPA, Office of Superfund Remediation and Technology Innovation
Technology Integration and Information Branch
1200 Pennsylvania Ave., NW (5203P)
Washington, DC 20460
Phone, [phone]
Cell, [phone]
Fax, [phone]
[e-mail]
Courier Delivery/Visitors:
2777 South Crystal Drive
4th Floor, S-4614
Arlington, VA 22202
Beth
Walden/R4/USEPA/
us
11/12/2008 11, 36
To
Kathleen Yager/Rl/USEPA/US@EPA,
Dave Jenkins/R4/USEPA/US@EPA,
12/3/2008 7:56 AM
Shelby -minutes of a telecon with Doug Sutton
I of 2
Subject~Shelby -_ minutes-of a tel econ ~1th.I5o~g Sutton -
From: "Glover, Everett" <[e-mail]>
Date: Fri, 21 Nov 2008 17:16:06-0500
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S"'<Ed:Mck1nley@celanese,com>. _ _ -
~C:~'.Dahlgren, Bryon" <[e-mail]>, "Hamgan, Joe" <JOE.HARRIGAN@,..:a'--'e-'-c-'--om_.c'--'o_m_> ______ _
Doug Sutton, Steve Simpson, Bryon Dahlgren, Joe Harrigan and Everett Glover had a telephone conversation on November 13 to discuss of Doug's
comments on the groundwater modeling report. The objective was to address as many of the comments as practical before the meeting in order to
expedite the meeting scheduled for December 5. The attached meeting minutes were drafted by AECOM and reviewed and edited by Doug, and are
believed to present an accurate representation of the discussion. However, if there are additional questions or edits that need to be made, please contact
me.
I look forward to seeing everyone on December 5, and I hope everyone has a happy and safe Thanksgiving. Talk with y'all later. ewg
Everett W. Glover, Jr. P.E.
Senior Program Director
D 770.990.1410 C 770.331.1502
[e-mail]
AECOM
1455 Old Alabama Road, Ste. 170
Roswell, Georgia 30076
T 770.990.1400 F 770.649.8721
www.aecom.com
Please note: my email has changed [e-mail] Please update your address book accordingly.
Earth Tech's parent company, AECOM Technology Corporation, as it evolves to better serve its clients, is changing the name of Earth Tech, Inc. to AECOM Technical Services. Inc.Earth Tech's legal structure
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P Please consider the environment before printing this e-mail
jShelby _ telecon_record _rl _ 11-21-08.pdf Content-Description: Shelby _telecon _record _rl _ l l-21-08.pdf
'
12/3/2008 7:57 AM
Shelby -minutes of a telecon with Doug Sutton
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2 of2 12/3/2008 7:57 AM
Celanese NC ARARs
_Subject: Celanese NC ARARs
From: [e-mail]
Date: Mon, I Dec 2008 14:04:37 -0500 ;ro: [e-mail], [e-mail] .
FG:,-Ysager:[e-mail],[e-mail], [e-mail],
~pbell.Richard@~amail:epa,g~ov ___________________________________ ~
I of I
Hi Dave and Kevin,
Are you aware of 15A NCAC Rule 02L.0106 being an ARAR for a Federal
Superfund Site? Particularly subparts (kl (ll (ml (pp. 9-14l. Celanese
would like to follow the NC process. They think that they can submit a
request to NC DENR's Division Director that would allow for a corrective
action plan. The corrective action plan could demonstrate that they
would not have to achieve groundwater quality standards.
(See attached file, NC 2L.pdfl
Beth
NC 2L.pdf
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Content-Encoding: base64 I
12/3/2008 7:59 AM
Celanese Fibers, Shelby NC: Stream Classifications
·, Subject: Celanese Fibers, Shelby NC: Stream Classifications
From: Matthew Faerber <[e-mail]>
Date: Mon, 17Nov200811:17:13-0500
rfo: DA YID.MA [e-mail]
David,
As you can see on the map below, all of the streams immediately surrounding the project site are classified as "C" only.
I of3
Regards,
-Matthew
to?-l,117... ,,,, u' f't~-n,,e""
J
11/17/2008 12:55 PM
. Sh lb NC-Stream Classifications Celanese Fibers, e Y ·
2 of3
,
-.._
2564
,2533 ·· .. , I \ \ 2518~1140 /
N_anied Stre~m
Unnamed Stream
2218
-2480
2476
! .17 '
;
•,
·· .. •, · .. ··. ··· ...
··-··--. :--
! 2308
2209--
......
••• •• ,2228 ·•-. ..-----. ...... .. .
...
,:.:··
_: 2467
•·.· ..... ------. .....
.. ···
I l/17/2008 12:55 PM
Celanese Fibers, Shelby NC: Stream Classifications
Matthew L. Faerber
NC Department of Environment and Natural Resources
Division of Water Quality -Classification & Standards Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
919.807.6412 http,//h2o.enr.state.nc.us/csu
3 of3 11/17/2008 12:55 PM
The followina standards, criteria, or toxic concentrations are either adooted oer 15A NCAC 2L. MCL's. or are National secondani drinkina water
Current15A NCAC National 2L Standard or (")
Proposed Maximum Secondary
.,
~ Interim Maximum n Synonyms & Reference DRAFT Groundwater Contaminant Drinking s· Allowable 0 Other Info Dose (RfD) Standard Level (MCL) Water <C Concentration '" Standard ::,
(IMAC)
Pollutant CAS# mg/L mg/L ma/L mg/L ma/ka/day
1,4-Dioxane 123911 0.003 0.007 ND ND y p-Dioxane ND
•
IS n ar s. ee as: page or armropnate use m orma 10n. taddSlt f . f f
Carcinogenic Relative Source Calculated
Potency Factor Contribution Threshold Taste Threshold Odor Threshold
(CPF) (RSC) Concentration
maikaidav mgil mail mail
1.1e-2 1 0.2 0.003 ND 230 4
.