NCD003446721_19880323_Celeanse Corporation - Shelby Fiber_FRBCERCLA ROD_Enforcement Record of Decision - Summary of Remedial Alternative Selection-OCR

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ENFORCEMENT RECO~ OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CELANESE FIBERS OPERATIONS SITE
SHELBY, NORI'H CAROLINA
Prepared By:
u.s. Environmental Protection Agency
Region IV
Atlanta, Georgia
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1 .O INTROOOCTION
2.0 SITE HISTORY
3. 0 GROUNDWATER CONTAMINANTS
TABLE OF CONTENTS
4.0 DISCUSSION OF CLEANUP CRITERIA (ARARS)
5.0 SUMMARY OF PUBLIC HEALTH EVALUATION
6.0 ENFORCEMENT ANALYSIS
7.0 ALTERNATIVE EVALUATION
a.a RECOMMENDED ALTERNATIVE
9.0 COOMUNITY RELATIONS HISTORY
1.0 RESPONSIVENESS SUMMARY
2.0 ALMINISTRATIVE RECORD INDEX
3.0 STATE CONCURRENCE
ATTACHMENTS
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1,0 INTRODUCTION
ENFORCEMENT RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CELANESE FIBERS OPERATIONS SITE
SHELBY, CL!'NELAND COUNTY, NORTH CAROLINA
The Celanese Fibers Operations Site was proposed for inclusion on the National
Priorities List (NPL) in October 1984, · A.Remedial Investigation (RI) and
Feasibility Study (FS) have been conducted at the site. Due to unusual waste
characteristics at the site, more information will be required in order to
select a permanent remedy for the contaminated soils and the. source material,
As a result, this site has been separated into Operable Units. Operable Unit
1, Groundwater Remediation, will be addressed now. A remedial alternative for
the source and soils remediation will be selected in approximately one year.
The RI report for the whole site was finalized and presented to the public on
July 21, 1987 in a public meeting, The FS, which.develops and examines
alternatives for remediation of the site was issued in draft fom, to the public
on January 19, .1988. A public meeting ·to present the results of the FS was
held on February 3, 1988 in Shelby, North Carolina.
This Record of Decision has been prepared. to summ.arize the remedial alternative
selection process and to present the selected remedial alternative for the
groundwater at the site.
Site Location and Description
The Celanese Fibers Operations (CFO) site is a 450-acre property occupied by a
polyester raw-material production facility (Figure 1-1), The site is located
in south-central Cleveland County on North Carolina Highway 198. It is
approximately one mile north of Earl, North Carolina and six miles south of
Shelby. The nearest major.city is Charlotte, North Carolina, 35 miles east of
Shelby, .
' The plant facilities consist of the plant production area, wastewater treatment
area, former waste disposal areas, land fam. area, and the recreations and tree
farm areas to the south of the main plant.
The majority of the:land surface reflej::ts cultural modification by
construction, and by'clitting ,frid filHng. The .ori.ginal soil profile has
probably been either truncated or .·covered across much of· the site, and was
never conclusively identified as undisturbed during the field investigations of
the RI, The plant production,area is predominantly covered with buildings and
paved or gravelled. areas. However, ·to the east, toward the waste water
treatment area, .the site becomesrr,ore. open,s-with the ir,ajority of the. land
covered by impoundments, with grass apd access roads .,in between. The sludge
land farm is north of the plant producti,on area and-Clllergrown with coarse
grasses. The recreation area and tree .fam to. the.south have no facilities
related to the plant processes·.
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·-.. · --
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N
SCALE ( FEET)
0
2000
•: .... , ,,.......___ REPRODUCED FROM BLACKSBURG 7 1/ 2 MIN. QUADRANGLE 11971 l
SOIL & MATERIAL ENGINEERS INC.
FIGURE 1-1
SITE LOCATION MAP
CFO/SHELBY,N.C.
-~ _"---
--~:\ '.v
.. , ... ·-<
'\/''·.
·:-.;
4000
S& ME JOB NO.1175-85-0S0A
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~-Q_ Site History
Fiber Industries, Inc., a joint venture of Celanese Corporation and Imperial
Chemicals, Inc., was the original owner of the plant and operated it fran 1960
until 1983 when the Celanese Corporation oought out the facility. Celanese now
operates it as Celanese Fibers Operations (CFO). -. Operations at the Shelby facility began in April of. 1960. Manufacturing
operations included the production of polyester polymer chip and filament
yarn. The principal chemi9als involved in polym.er production are dirr.ethyl
terephthalate and ethylene glycol. Other small quantity additives include
titaniu1n dioxide a~d antirr.ony •.
" The CFO waste treatment plant was constructed in phases·concurrent with the
manufacturing plant:._ During par.t ·of 'the early years, chemical wastes were
discharged through·a_ditch drain"ing in a generally easterly direction. The
ditch began near the western edge of what is now known as the former drum
storage area, and travelled east to the northeast corner of the present
emergency spill ponds. The ditch was replaced with pipes when the waste
treatment plant became fully operational in the mid-1960's. In 1973, the plant
was expanded with the addition of a-polishing pond, two emergency spill ponds,
and an additional aeration basin. The treated effluent fran the waste
treatment plant is piped to a discharge point on Buffalo Creek.
The concrete-lined portions of the waste treatment facility include a chrmate
reduction pond which is no longer in use, a digester, three equalization
basins, two aeration basins, and two clarifiers. The unlined plant units
include the three polishing ponds, two sludge ponds, and two emergency spill
ponds.
In addition to the discharge fran the wastewater treatrr.ent plant, the Celanese
facility also discharges alum treated bandcaster water directly to Buffalo
Creek. Bandcaster water is used to cook the polymer products. Both of these
discharges are cavered by permits fran the North Carolina Department of Natural
Resources.
Several areas around the plant have been used for waste disposal. Nom<al plant
wastes (prirr.arily polyester and miscellaneous trash) were disposed of in old
burning pits located just north of the aeration basins. North and east of the
burning pits, Glyco+ Recavery Unit (GRU) sludge was buried during the early
1960's in trenches. West of the GRU sludge burial area is a former drum
storage and staging area. Solutions which failed to polymerize were stored
here during the early 1960's. The drums were remaved in the mid-1960's and the
storage area was backfilled. Two soak-away ponds located west of the existing
aeration basins were used to contain treated sanitary sewage during the period
fran 1960 to 1969.
Four areas of buried waste are located to the north and outside of the main
plant perimeter fence. The polymer and fiber landfill contains prirr.arily
non-hazardous inert materials such as excavation spoil, polym.er, and waste
yarn. The construction debris landfill contains items such as old cinder
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LEGEND
PROPERTY
LINE
SC.U<nm
0 400 800
~
81 SINGLIE WELL LOCATIONS + MULTIPLE WELL LOCATIONS
• ROCK MONITOR wnLS
LETTERS REPRESENT wnL OES1GNATIONS
FlGURE
MONITOR wnL
LOCATION MN'
Cf'O / SHELBY, N.C.
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100
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'-~< ~-~----WELL SURVEY BOUNDARY
WELL
NO. OWNER
1 LAKE MURRAY PLASTICS, INC.
2 MOORE T. PARK
3 GRAHAM & MOORE T. PARK 14 KAY COBB (GENE BETTIS)
19 808 DOVER · 21 8. OF ED. NO. 3 SCHOOL
30 JOE HOPSON 34 WINFORD OLIVER 38 CLAUDE OLIVER 39 MAX LONG
53 HARVEY LEE TOM 69 LINDA HART
79 JAMES ROBERT ELLIOTT 80 LARRY STEIN
81 JACKIE LAMBERT 82 CHILDREN'S HOME
100 BESS w. LAVENDER
101 NEW HOPE BAPTIST CHURCH 102 CLAUDE LAVENDER
,----
Figure 3,c2.
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LEGEND
"• SAMPLED WELL LOCATION
tc.utnm 0 700 1400 ~
FIGURE
OFFSITE WELL LOCATION MAP
CFO / SHELBY, N.C.
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blocks and steel strapping bands. Approximately 21 acres of the northwest
quadrant of the property have been issued permits by the North Carolina
Department of Natural Resources for sludge disposal since 1978.
In the period fran 1970 to 1978, approximately 2000 to 3000 drums of waste
chemicals and solvents, including lab packs, were stored temporarily in the
area known as the drum storage area near the fem.er burning pits. All drums
were remo.,ed fran the area by 1978 and sent to outside disposal facilities.
Investigation of the Celanese Fibers Operations Site began in October 1981 when
CFO contracted with the firm Soil & Material Engineers, Inc. (S&ME) to install
23 groundwater monitor wells. In conjunction with the groundwater monitor well
installation program, SME also conducted a hydrogeologic evaluation.
Subsequently, CFO initiated a groundwater sampling and analysis program under
the supervision of Davis & Fioyd Laboratories, Inc. ·
Soil & Material Engineers, ·Inc.'also conducted an electranagnetic survey and
excavated test pits at .the site. ·:·
. . .
In October 1984, CFO was proposed for-I;:PA's National Priorities List. Also in
October 1984, there were a·seriefi of roeetings between the u. s. Envirorm,ental
Protection Agency. (EPA) and CFO to discuss ,the .•prepar-ation of a Work Plan for a
Remedial Investigation (RI) and Feasibiiity Study (FS) by CFO's contractor,
S&ME. Concurrent with this, EPA's contractor, Camp Dresser & McKee, Inc.(CI:M),
prepared a report that included a rev1ew of the data collected during previous
site investigations and identified information deficiencies and data gaps to
pro.,ide a basis for developnent of Remedial Investigation activities. These
events resulted in the sutrnission of a.draft Work Plan by S&ME, on behalf of
CFO, with a final Work Plan subr,itted-to EPA in No.,ember 1985.
3.0 Groundwater Contaminants
On-Site Monitor Wells
The monitor wells (Figure 3-1) existing at the start of the RI were sampled as
the initial field operation (Phase I and IA). Select monitor wells frcr11 this
group and the monitor wells installed during the RI were sampled during the
Phase II and IIA events. The Phase II and IIA wells were generally in
background locations and near the site's perimeter to pro.,ide data on the
groundwater quality as it entered and exited the site.
Analyses of. these samples showed varying results between the two sampling
periods, with variations occurring in both ccr11pounds identified and
concentrations of the same canpound in one well on separate dates. • Due to the
variation in·data, and the location of wells selected for analysis (typically
on or near the plant's perimeter), mappable trends in groundwater quality were
not identified. However, the data show that canpounds similar to those
identified in the probable source area were detected in the groundwater. These
include phthalates (concentrations to 380 ug/1), ketones (concentrations to
2100 ug/1), benzene (concentrations to 60 ug/1) and other non-phenolic arcr11atic
ccr11pounds, and members of the chlorinated ethene/ethane groups
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(concentrations to 90 ug/1). Of these groupings, members of the phthalate and
ketone groups were measured·more frequently and at higher concentrations. ; ,. ..
Examination of the groundwater quality data.shows that the deeper wells in the
nests frequently have the higher concentration of organic canpounds, suggesting
introduction of the car,pouna,:; to the_ groun_dwater in a recharge zone or through
the relic fracture system in the saprolite. Figures 3-1 and 3-2 show the
locations of on and off-site inonitor wells used in this analysis. Table 3-1
summarizes the groundwater·quaiity data.
Monitor wells in the waste-water treatment plant area and the western terrace
of the lawn, however, generally have higher concentrations of contaminants in
the shallow wells. This is apparently due to the wells' locations within or
near the probable source areas. Groundwater quality data for monitor wells J,
CC, 0, and K within the probable source area most clearly indicates this
occurrence.
Elevated chranium levels were reported at several on-site monitor wells during
the Phase II and IIA sampling events. It appears that plant operations have
contributed to the chraniurn potential, however, naturally occurring chraniurn in
the soil and rock are also possible sources.
Groundwater contamination is predaninantly in the area underlying the western
terrace of the lawn and wastewater treatment plant based on the analytical
sampling results. However, there are volatiles, semi-volatiles and metals which
appear to trend fran this area to the south-southeast toward monitor well nest
T, and are reported at other areas on certain sampling events.
Off-Site Monitor Wells and Supply Wells
Groundwater quality was measured at 19 off-site locations shown on Figure 3-2,
during the Phase I and IA groundwater sampling episodes. Concentrations of
volatile organic canpounds (voes) were measured in seven of the off-site wells
during the Phase II groundwater sampling episodes. Phase II sampling consisted
of re-sampling seven of the wells showing higher concentrations of voes.
During Phase I sampling, phthalate car,pounds were detected in eleven of the
off-site wells at concentrations typically ranging between 10 and 40 ug/1.
Exceptions were the Hopson and Tan wells which reported di-N-butyl phthalate at
83 ug/1 and bis(2-ethylhexyll phthalate at 440 ug/1, respectively. None of the
phthalate canpounds detected exceeded EPA water quality criteria.
Canparison of Volatile Organic Canpound (VOC) analysis for both sampling
episodes showed inconsistencies in both detected canpounds and concentrat_ions.
Phase I detected Hazardous Substance List (HSL) voes in 11 of the 19 wells
sampled at concentrations generally less than 80 ug/1. Exceptions were noted
at the Do.ler well where methylene chloride and acetone were reported at 680
ug/1 and 111 ug/1, respectively, and at the Long well where methylene chloride
was reported at 967 ug/1. The phase II sampling detected voes in four of the
seven wells in concentrations ranging frm, 5 to 14 ug/1. With the exception of
James Elliott's well, which consistently detected trichloroethene (TCE), no HSL
volatile organic canpounds were detected during Phase II above proposed or
existing standards.
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4,0 Discussion of Cleanup Criteria (ARARs)
Safe Drinking Water Act Maximum Contaminant Levels (MCLs) are the Applicable or
Relevant and Appropriate Standards (ARARs) for groundwater at the federal
level. In a project meeting April 16, 1987, EPA indicated they would probably
defer to state criteria when more stringent than federal. Maximum contaminant
levels were established by the State of North Carolina as given in 15 NCAC 2L.
These amendments established more stringent criteria for some compounds with
federal MCLs and add 46 additional compounds. For the purposes of this
document, the North Carolina criteria are considered the ARARs for groundwater.
In discussions with personnel of the North Carolina Division of Environmental
Management, they have indicated that specific requests rr,ay be needed for
compounds for which standards have not been set.
Comparison of Groundwater to ARARs
The water quality standards for North Carolina groundwater were adopted from
the Environmental Protection Agency Standards.
The groundwater quality documented during the RI indicated that the following
parameters exceeded the standard in at least one monitor well during sampling
Phase II or IIA,
Substances
* 1,1-dichloroethene
* 1,1-dichloroethane
* trans-1,2-dichlorothene
* benzene
* methylene chloride
* vinyl chloride
* chloroform
* chlorobenzene
* carbon tetrachloride
Substances
0 phenols
0 tetrachoroethylene
0 chlordane
0 chromium
0 barium
0 iron
0 manganese
0 nickel
0 selenium
0 chloromethane
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Total No. of Occurrences Abolle
Existing or Proposed Standards
1
2
1
10
17
1
9
5
2
Total No; of Occurrences Abolle
Existing or Proposed Standards
2 ,, 1
2
40
2
4
4
13
1
2
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The majority of the canpounds, detected during the RI above the standard,
occurred in wells located in the vicinity of the wastewater treatment area,
predaninantly in monitor well nest CC, and in the monitor well nest at location
T south southeast of this area.
5.0 Summary of Public Health Evaluation
A suite of indicator parameters was chosen, according to the guidelines put
forth in the Superfund Public· Health Evaluation Manual· (EPA, 1986), for
toxological interp~etations and review purposes. Generally, this process
directs the selection of chemicalS,)itJ.ich best·.represent the hazards associated
with the site based on concentration in the environmental medium of concern and
a relative toxicity constant. Application of this process, which is discussed
in detail in the Public Health Assessment in Appendix A of the FS report, .
resulted in the s~iection of benzene, ·trichloroethylene (TCE), '
bis(2-ethylhexyl) .phthalate, lea_d,. ai:id. chr_anium as the indicator chemicals.
These were developed'by considering, the'primary routes ·of exposure as
groundwater and contact with.surface_ar:icl near surface.soils.
Several assumptions were made in perfoi:-Iiiing the health.evaluation. It was
assumed that chemicals present· at the site could be transported off-site in
groundwater and be consumed by personswithiri a 1-mile radius of the site.
Further, it was assumed that off-site groundwater concentrations of indicator
chemicals would equal the mean concentrations present at the site.
A canparison of the total daily_ indicator chemical intakes for an adult and
child was made by assuming a daily w_ater ingestion of 2 liters/day for adults
and 1 liter/day for children. With the exception of bis(2-ethylhexyl)
phthalate, this resulted in the estimated total daily intakes of indicator
chemicals exceeding that allowed by ARARs for both children and adults.
The greatest non-carcinogenic health risks associated with potential indicator
chemical exposure are due to ingestion of lead. In particular, young children
(less than 6 years old) may be very sensitive to the neurotoxic effects of lead
and should be considered the receptor population at greatest risk of developing
lead intoxication (EPA, 1984).
The non-carcinogenic health risks associated with the calculated exposures to
benzene,_bis(2~ethylhexyl) phthalate, and trichloroethylene are considered
minimal. There is no human evidence to suggest that exposure to these
chemicals at the calculated mean concentrations in groundwater would cause
chronic health effects.
Trichloroethylene, benzene and bis (2-ethylhexyl) phthalate are considered
potential carcinogens. Estimates of the cancer risk associated with potential
exposure. to these canpounds are considered low. However, the calculated risk
due to exposure to benzene is higher than the risks associated with exposure to
bis (2-ethylhexyl) phthalate and trichloroethylene. It is noted that the
concept of "acceptable risk" due to chemical exposure is subject to much
contrO'versy, but the calculated cancer risks for exposure to trichloroethylene
and benzene are sanewhat above the level considered acceptable by the EPA,
while the risk for bis(2-ethylhexyl) phthalate is below this level.
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The public health evaluation concluded that there is the potential for exposure
to the indicator chemicals at levels above accept~le concentration levels and
sane potential for carcinogenic risk above the 10 risk level by
down-gradient users based on a conservative scenario. Due to this potential,
the No Action alternative is considered not viable at the CFO/Shelby site.
6.0 Enforcement Analysis
The Celanese Site was added to the NPL in June of 1986 and EPA assumed lead
responsibility for the site at that time. The Celanese Canpany has operated a
plant on.that site since 1960. Celanese initiated groundwater studies in
1981. Negotiations for the RI/FS consent agreement were concluded-with the
sighing of the document by both EPA.and Celanese on March 10, 1986.
Informal negotiatiops to develop a consent decree for Celanese to perform the
Remedial Design/Reniedial Action are under way. · Formal negotiations will
canmence shortly a·fter the ROD is signed.
7.0 Groundwater Remedial' Alternatives
Remediation of the groundwater can be initially divided into two areas of
rerr.edial effort: those areas with high Total Organic Carbon (TOC)
concentrations near.the suspected sources, and those with.lower TOC
concentrations which are more 'remote fran=the source and near the property
boundary~ · ·
Remedial technologies for controlling groundwater contamination problems
generally utilize one. of-the following techniques:
A. Capping -involving an impermeable caver to reduce infiltration of
water.
B. Groundwater pumping -involving extraction of water fran and possibly
injection of water into wells to capture a plume or alter the
direction of groundwater ma.ement.
c. Subsurface drains -consisting of gravity collection systems designed
to intercept groundwater.
D. Subsurface barriers -consisting of a vertical wall of low
permeability materials constructed underground to divert groundwater
flow or minimize leachate generation and plume ma.ement.
E. In-situ treatment to biologically or chemically rema.e or attenuate
contaminants in the subsurface.
F. Surface treatment of contaminated groundwater after it has been
rema.ed. This includes air-stripping, activated carbon treatment,
etc.
G. The "No Action: alternative involves monitoring only, no active
treatment.
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These technologies can be used singularly or in canbination to control
groundwater contamination.
A. Capping
The use of capping as a groundwater remediation technique is
detrimental to m011ing the residual contaminants to a rem011al point.
Due to the .high water solubility of ethylene glir,col and other
canpounds present in the contaminated soil, they lend themselves to a
soil leaching technology and ~ubsequent collection through groundwater
pumping stations. Precipitation will serve as a continuing natural
solvent to sustain this leaching action. ·_In addition the potential
for utilization of supplemental spray irrigation of either treated or
recycled groundwater wou:).d pr011ide for a·cceleration and increased
efficiency of the soil leaching program. Therefore, the utilization
of capping would interrupt the ability of either natural or man-made
systems to enhance the leaching, and capping is not being considered
further in conjunction with the groundwater remediation.
B. Groundwater Pumping
Groundwater pumping techniques involve the active manipulation and
management of groundwater in order to contain or rem011e a plume or to
adjust groundwater levels in order to limit formation of a plume.
Types ·of wells used in management of contaminated groundwater include
wellpoints, vacuum wells, and deep wells. The selection of the
appropriate well type depends upon the depth of contamination and the
hydrologic and geologic characteristics of the aquifer involved.
Well systems are versatile and can be used to contain, rem011e, divert,
or limit developnent of plumes under a variety of site conditions.
Groundwater pumping is most effective at sites where underlying
aquifers have high intergranular hydraulic conductivity. However, it
has been used with varying effectiveness at sites with moderate
hydraulic conductivities and where pollutant m011ement is occurring
along fractured or jointed material.
Where plume containment or rem011al is the objective, either extraction
wells or a canbination of extraction and injection wells can be used.
The use of extraction wells alone is best suited to situations where
contaminants are soluble with water, where the hydraulic gradient is
sufficiently steep, the hydraulic conductivity is adequate, and where
quick rem.011al is not necessary.
A canbination of extraction and injection wells is frequently used in
contaim.ent or rem011al where the hydraulic gradient is relatively flat
and hydraulic conductivities are moderate, or to accelerate the
rem011al time frame. Groundwater pumping systems are the most
versatile and flexible of the groundwater control technologies.
Operational flexibility is high since pumping rates can be modified to
adjust to changes in flow rate. System performance is generally good
pr011ided the wells are properly designed and maintained.
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At the CFO/SHELBY facility, groundwater pumping pr<Nides a viable
control and remediation technology for clean-up of the groundwater
contamination present. Its utilization in conjunction with treatment
of contaminated groundwater pr<Nides the potential for a remediation
program allowing for containment of the existing contamination to its
present boundaries. This technology is, therefore, retained for
further consideration.
c. Subsurface Barriers
The term subsurface barriers refers to a variety of methods whereby
· low permeability cut-off walls or diversions are installed below
ground to contain, capture, or redirect groundwater flow. The most
camionly used subsurface barriers are slurry walls,,particularly the
soil-:-bentonite type slurry wall. Less COl'll'.on are cement-bentonite or
concrete slurry walls, grouted barriers, and sheet pile cut-offs,
This technology is eliminated, as other, more permanent remedies are
readily available.
D, Subsurface Collection Drains
Subsurface collection drains include any type of buried conduit used
to collect and convey discharge by gravity flow, Subsurface
collection drains essentially function like an infinite line of
extraction wells and can perform, many of the same functions as wells,
They can be used to contain or rem<Ne a plume, or lower the
groundwater table, The decision to use drains or pumping is generally
based on cost effectiveness and implementability analysis, For
shallow contamination problems, drains can be more cost effective than
pumping. The biggest drawback to the use of subsurface drains is that
they are normally limited to shallow depths.
Again, due to the geologic conditions, topography of the site, extent
of contamination and availability of more technically feasible and
cost effective technologies, subsurface collection drains are not
being considered further.
E, In-Situ Treatment
In-Situ trea_t:ment of the contaminated ground water does not
appear to offer a potential for technologically or cost effectively
treating the groundwater conditions. •The·physical difficulty and high
costs associated with pr<Niding the nutrients and oxygen required to
stimulate and sustain aerobic biological activity within the existing
groundwater would be extensive. Therefore, this technology is
eliminated fran further discussion.
F. Surface Treatments
Air Stripping
Air stripping is the mass transfer process in which volatile
contaminants in water.or,soil are transferred fran their canbined
state to a gaseous state. Four COl'll',only used methods for air
stripping liq!,!ids are t~e pac~ed column, cross-flow tower, ~oke tray aerator, and diffused a1r·bas1n procedures. . ·
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Air stripping is most canmonly accomplished in a packed tower equipped
with an air blower. The packed tower works on the principle of
counter-current flow where the water stream flows down through the
packing while the air is blown upward, and is exhausted through the
top. Volatile, soluble cCI11ponents have an affinity for the gaseous
phase and tend to leave the aqueous stream for the gaseous phase. In
the cross-flow tower, water flows down through the packing as in the
counter-current packed column; however, the air is pulled across the
water flow by a fan. The coke ·tray aerator is a simple, low
maintenance process requiring no blower. The water being treated is
allowed to trickle through several layers of trays. This produces a
large surface area ·for·gas transfer. Diffused aeration stripping and
induced draft stripping use aeration basins similar to standard
wastewater treatment aeration basins. Water flows through the basin
from top· to bottom or from one side to anotherwith the air dispersed
through diffusion at· -the bottan of the basin. The air to water ratio
.is significantly lower than·in·either the packed column.or the
cross-flow tower uni ts. .. ·
' Air stripping is normally utilized to rem011e volatile organics frar,
aqueous waste streams. Generally cm.ponents with Henry's Law
constants greater than 0.003 can be effectively rem011ed by air
stripping. The waste feed stream must be low in suspended solids and
may require pH adjustment to reduce solubility and imprOlle transfer to
the gaseous phase •.
Stripping is sometirr-es only \,artially effective in groundwater
treatment and must be followed by other processes such as biological
treatment and carbon adsorption. The combined use of air stripping
followed by other applicable processes can be an effective means of
rro.0\/ ing the contaminants from groundwater.
In.recent years, air stripping has gained increasing use. It has been
used cost effectively for the treatment of low concentrations of
volatiles or as a pre-treatment step prior to subsequent treatment
technologies. Equipment for air stripping is relatively simple,
start-up and shut-down can be accomplished quickly, and the modular
design of packed towers makes them somewhat mobile in their
application. ·
An important consideration in the utilization of the air.stripping
technology is the implications of the air pollution which may result
from the stripping operation itself. The gaseous stream generated
during air stripping may require collection and subsequent treatment.
Because of the concentrations of volatile organics present in the
contaminated groundwater at the site, air stripping may be applicable
both as a primary and supplemental remediation technology. Therefore,
this treatment technology will be retained for further consideration.
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Activated Carbon Treatment
The process of adsorption onto activated carbon involves contacting a waste
stream with the carbon, normally by flow through a packed bed reactor. The.
activated carbon process can be designed to selectively adsorb hazardous
constituents by a surface attraction phen001enon in which organic molecules are
attracted to the internal pores of the carbon granules.
Adsorption depends upon the strength of the molecular attraction between
adsorbent and adsorbate, molecular weight, type and characteristics of the
absorbent, electrokinetic charge, pH, and surface area. Once the micropore
surfaces are saturated with organics, the carbon is spent and must either be
replaced with virgin carbon or removed, thoroughly regenerated, and replaced.
The time to reach breakthrough or exhaustion is the single most critical
operating parameter. Carbon longevity·balanced against influent concentration
governs operating econ001~es. In the event that the carbon is regenerated
on-site, the supernatant frOOI this process wil~ be processed through the system
constructed for treating the site groundwater. ·
Activated carbon adsorption ,l.s a well-developed technology which is widely used
in the treatment of hazardous waste;.steams. It ·is especially well suited for
the removal of mixed organics ,fran''.aqueous wastes. Since carbon adsorption is
an electrical interaction·phenanencm, the.polarity of the waste c001pounds will
determine the effectiveness of the.adsorption p:rocess. The more hydrophobic
(insoluble) a molecule.is,·the more readily the c001pound is adsorbed. As a
result, low solubility humic·and fulvic acids which are present in the
groundwater can adsorb to the· ac.tivat:ed cirrbon more .rea~ily than many waste
contaminants and result· in rapid carbon .exhaustion. 'Also, sm.e metals and
inorganic species have shown excellent to'good adsorption potential. These
include antimony, arsenic, bismuth, chranium, tin, silver, mercury, cobalt,
zirconium, chlorine, .branine and iodine. Activated carbon can also be utilized
in the powdered form which offers the advantages of greatly increased surface
area availability and reduced costs: · ·
Carbon adsorption technology can be used either in conjunction with or
following biological treatment and/or gravity filtration. Its purpose in this
application is to remove the refractory organics which cannot be biologically
degraded. The biological treat:ment and/or granular media filtration steps
prior to carbon adsorption reduce the organic and suspended solids load to the
carbon adsorption units. Reduction of organic and suspended solid load
minimizes carbon usage and regeneration costs. Air stripping has also been
applied prior to carbon adsorption in order to reduce a portion of the volatile
contaminants and reduce the organic load to the carbon adsorption units.
Activated carbon usage is easily implemented into or along with other treatment
systems. The process is well suited to mobile units as well as to on-site
construction. Space requirements are small and start-up and shut down are
rapid.
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Regeneration of spent carbon.·for reuse is the highest operating cost associated
with the utilization of carbon adsorption technology, In addition, high
capital costs can be associated with its use. Both capital and operating costs
can be substantially reduced through pretreatment of the waste prior to its
treatment with carbon adsorption.
Activated carbon treatment will not be utilized in a primary remedial
technology role at the site, but may be used as a supplementary technique in
conjunction with other clean-up technologies. This technology will be retained
for further consideration.
Precipitation/Flocculation
Precipitation is a physiochemical process where sane or all of a substance in
solution is transformed into a solid phase. The technology is based upon
alteration of the chemical equilibrium relationships affecting the solubility
of an inorganic species. Rern011al of metals as hydroxides or sulfides is the
most canrnon precipitation application in wastewater treatment.
Precipitation is applicable to the rern011al of most metals fran wastewater,
including zinc, cadmium, chranium, copper, lead, manganese, and mercury.
Certain anionic species such as phosphate, sulfate and fluoride can also be
rern011ed by precipitation. The technology is useful for most aqueous hazardous
waste streams. However, organro.etallic canplexes with metals can inhibit
precipitation. Cyanide and other constituents may also canplex with metals,
thereby, reducing the treatment efficiency of precipitation.
Precipitation and flocculation are well-established technologies. A
disadvantage is that precipitation is non-selective and that canpounds other
than those targeted may be rem011ed. Both precipitation and flocculation are
non-destructive and generate a large volume of sludge which must be disposed of
ultimately.
This technology will be retained for further consideration.
Biological Treatment
Biological treatment is utilized to rern011e organic matter fran a waste stream
through microbial degradation. The most c<XIIIl'.on type of biological treatment is
aerobic (in the presence of oxygen). A number of biological treatment
processes exist which are used for the treatment of aqueous hazardous wastes.
They include conventional activated sludge, modifications of the activated
sludge process, pure oxygen activated sludge, extended aeration, and contact
stabilization. Fixed-film _systems include rotating ·biological discs and
trickling filters. ·
In the conventional activated sludge proc~~~·;·,waste flows into an aeration
basin where it is aerated for several hours.· During this time, a suspended
active microbial population aerobically _degrades .the organic matter in the
waste stream along with producing new cells, · A s'lmplified equation for this . . . process is: . '
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Organics+ o2 ----> co 2 + H20 + new cells
The cells produced.during aeration along with other precipitated materials form
a sludge wnich is settled out in a clarifier. The clarified water then goes to
disposal or further treatment.
Fixed-film systems involve contact of the aqueous waste stream with
microorganisms attached to S(llle inert medium such as rock or specially designed
plastic material.
Biological treatment has considerable flexibility due-to the variety of
processes available and the adaptability of the microorganisms themselves.
Most organic che1nicals are consider~ biodegradable, although the ease of
biodegradation varies widely. Several general observations can be made with
regard to the ease of treatability of. organics by'aerobic biological treatment:
0
0
0
0
Unsubstituted non~ar=tics.or cyclic hyd~ocarbons are preferred over
unsubstituted armatics. -'
1 '
Materials with unsaturated bonds such as alkenes are preferred over
materials with saturated bonds;
Soluble organics are usually more readily degraded than insoluble
materials. Biological treatment is more efficient in removing
dissolved or colloidal materials, which are readily attacked by
enzymes. This is not true for fixed-film treatment systems which
preferentially treat suspended matter.
The presence of optional groups effects biodegradability. Alcohols,
aldehydes, acids, esters, amides, and amino acids are more
biodegradable than corresponding alkanes, olefins, ketones,
dicarboxylic acids, nitrites, and chloroalkanes.
o Halogen-substituted C(lllpounds are the most refractory to
biodegradation.
Industrial type wastes may not be readily amenable to biological treatment;
however, microorganisms can be acclimated to degrade many C(lllpounds that are
initially relatively non-biodegradeable.
Additionally, heavy metals may be inhibitory to biological treatment, but the
bi(lllass can be acclimated, within limits, to tolerate elevated concentrations
of metals.
The C(lllpletely mixed activated sludge process is the most widely used with high
organic loads, and high purity oxygen systems have advantages for hazardous
waste site remediation. However, a number of other parameters influence the
performance of the biological treatment system. These parameters are the
concentration of suspended solids, oil and grease, organic load variations,
and temperatures.
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Biological treatment has not been as widely used in hazardous waste site
remediation as activated carbon adsorption, filtration and
precipitation/flocculation. However, the process is well established for a
wide variety of organic contaminants.
Although biological treatment can effectively treat a wide range of organics,
it has several disadvantages in conjunction with hazardous waste site
applications. The reliability of the process can be impaired by "shock" loads
of toxics. In addition start-up times can be slow if the organisms need to be
acclimated to the wastes and the detention time can be long for cm,plex
wastes. The existence of an acclimated culture can dramatically decrease
start-up and detention time.
Rotating biological contactors have the advantages for use at hazardous waste
treatment sites in that they are·cm.pact, can handle large flow variations and
high organic shock loads •. In addition they-do not require the use of
mechanical aeration equipment.
The sludge produced in biological waste treatment process may be a hazardous
waste itself due to the sorption and concentration of ·toxic and hazardous
canpounds contained in the wastewater. If the sludges are hazardous, it must
be disposed of in a RCRA-appro,,,ed manner. · If the ·.sludge is non-hazardous,
disposal should conform with state sludge disposal guidelines. Biological
treatment has been screened and determined-to be a viable treatment alternative
for the site contamination'present. A more detailed discussion of its use is
included in the remediaiaction portion of this report.
Ion Exchange
Ion exchange is a process where the toxic ions present in a waste stream are
remwed by being exchanged with relatively harmless-ions held by the ion
exchange material. Ion exchange resins are primarily synthetic organic
materials containing ionic functional 'groups to which exchangeable ions are
attached. These synthetic'resins are structurally stable (can tolerate a range
of temperature and_pH), exhibit a high exchange capacity, and can be utilized
to selectively exchange ions. ·
Ion exchange can be used to remwe a wide range of inorganic species fran water
such as:
0
0
0
0
all metallic elements when present as soluble species, either anionic
or cationic
inorganic anions such as halides, sulfates, nitrates, cyanides, etc.
organic acids such as carboxylics, sulfonics, and sane phenols
organic amines
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Sorptive resins can also rem0ve a broad range of polar and non-polar organics.
A practical upper limit for ion exchange is about 2,500 to 4,000 mg/1 (pµn).
Suspended solids in·the feed stream should.be low, less than 50 rog/1 (pµn) to
prevent.plugging the resin, and the waste.stream roust be free of oxidants.
Ion exchange is a well established technology ·for heavy metal rem0val and
hazardous anion rem0val fran dilute waste solutions. A problem which exists
with the ion exchange-technology is the disposal of contaminated regeneration
solutions. Consideration should be given to selection of these solutions when
evaluating the technology •.
Based on the data available for this screening, the contaminants present,
amenability of other treatment technologies, and costs, ion exchange is not
being considered for further evaluation as a remedial technology at CFO/SHELBY,
Filtration
Filtration is a physical process where suspended solids are rero011ed fran
solution by forcing a fluid through a porous medium. Granular media filtration
is normally used for treating aqueous waste streams. The filter media
(generally sand) is contained within a basin and is supported by an underdrain
system which allows the filtered liquid to be drawn off while retaining the
filter media in place. As the wastewater.laden with suspended solids passes
through the filter media, the solids becane trapped on top of and within the
bed, To prevent plugging, the filter is backwashed at high velocity to
dislodge the solids. The backwater produced contains high concentrations of
solids and requires further treatment.
The granular media filtration process is only marginally effective in treating
colloidal size particles. Filtration equiµnent is relatively simple, readily
available, easy to operate and control, and to integrate with other treatment
technologies. There is also extensive experience with the operation of
granular media filters at hazardous waste sites.
Although granular media filters are a cost effective and efficient treatment
technique in a wide variety of applications, filtration as a primary remedial
technology does not appear to be needed, Therefore, this technology is
eliminated fran further consideration.
G, NO ACTION ALTERNATIVE
A number of consideration must be made in evaluating the effects of
choosing a No Action Alternative. Under the No Action Alternative,
groundwater would remain contaminated with substances that may be
regulated by local, state, and federal laws. The No Action
Alternative would not pr0vide remedial action to reduce mobility,
toxicity-or volume of contaminated soil. Possible socioeconanic
impacts of the No Action Alternative include the·following:
* * * *
*
Decline in property values
Expenditure for legal services
Depressed area growth
Restricted access to site
Public and environmental exposures
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The Remedial Investigation concluded that groundwater contamination
had not migrated past the site boundaries at that time. However, the
investigation did not identify a constraint to off-site migration if
the measured groundwater contamination was not abated.
The Public Health Assessment was presented in Appendix A of the
Feasibility Study and evaluated the effects of exposure to selected
indicator car.pounds at the average concentration measured in the site
monitor wells. Due to the fact that four out of five indicator
car.pounds were above acceptable contaminant levels, and due to the
proximity of off-site private wells used for residential drinking
water supplies, the health assessment concluded that the No Action
Alternative was not viable at the site.
8.0 Recanmended Alternative
The recanmended alternative for remediation of groundwater contamination at the
Celanese Fibers Operations Site includes extraction of contaminated water and
treatment in an on-site treatment system. This alternative will cost
approximately $2 million, including operation and maintenance costs for an
estimated 30 year period (Table 8-1).
The groundwater remediation program will consist of remo.ing the groundwater
through two tiers of extraction wells, and subsequently treating the water with
a canbination of treatment techniques in a specified sequence. The first tier
of wells will be constructed near the eastern perimeter of the property as
shown on Figure 8-1. A second tier of extraction wells will be installed in
the area of highest contaminant concentration within the interior of the plume,
also shown on Figure 8-1. The first tier of extraction wells will be located
in a zone of lower contaminant concentration than the second tier of wells, and
therefore, the treatment of the pumped groundwater will not need to be as
extensive or canplex as that associated with the interior plume groundwater
remediation effort. ·
The areal and vertical extent of the plume to be remo.ed was developed fran the
total organic carbon (TCX:) concentrations. A review of the data indicated that
the bulk of the contamination in the groundwater appeared to be in the
intermediate depths (30 to 50 feet) to rock (50 to 80 feet). Furthermore, the
total organic carbon plume in general incorporates most of the areas showing
elevated metals concentrations. Thus, the groundwater extraction system
proposed for remo.ing the total organics present should also be capable of
remo.ing the metals involved.
The groundwater treatment alternatives being proposed·can initially be divided
into two areas of.remedial effort. Those areas with high TCX: concentrations
near suspected contaminant sources,_ and those with lower TCX: concentrations
more remo.ed fran the sources.
Table 8-2 lists sane of tlie constituents identified in the groundwater at the
site, and applicable primary and secondary·treatment technologies. The primary
treatment technologies proposed for treating the.extracted groundwater are air
stripping.and biological treatment.
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Table 8-1
Cost Estimate
Ground-Water Extraction System
Objectives: To intercept
ground water
area.
and treat
emanating
the existing contaminated
from the primary source
Ground Water Extraction System
Installation
A. Well Installation (maximum of 16 wells)
B. Trenching/Electrical
C. All Weather Road
D. Ground-Water Treatment System
Subtotal
D. Engineering Fees (10% capital costs)
E. Permitting (5% Capital Costs)
F. Contingency (20% capital costs)
Subtotal
G. Operation and Maintenance (30 year period)
Total
J
$177,820
$160,000
$125,000
$250,000
$712,820
$72,000
$36,000
$142,000
$962,820
$1,069,230
$2,032,050
NOTE I
' {---
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TIIE BURN PITS, GLYCOL RECOVERY SLUDGE PITS ANO AREA OF GRU SLUDGE 1 RACKING WERE T>KEN FROM HISTORICAi. AERIAi. PHOTOS,
PERIMETER
EXTRACTION
WELLS
0
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• M
SCU {f"[(TI 0 1.50 JOO t:::H
!.L!
C:t.:
'J..
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.____:--___________ _:_ __ ...:...,.._;, _____ __l,__ __ _
------

-
--

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Table 8-2
Primary/Secondary Treatment Technologies For
Selected Compounds Found in Extracted
Ground Waters
Constituent
Chromium
Acetone
Other Ketones
Carbon Tetrachloride
Chloroform
1,1 -Dichloroethene
1,1 -Dichloroethane
Trans-1,2-Dichloroethene
Methylene Chloride
Methyl Chloride
Trichloroethene
Benzene
Chlorobenzene
Toluene
Vinyl Chloride
Phenol
DowTherm
Penanthrene
Anthracene
Chrysene
Nitro-Di-N-Propylamine
Di-N-Butyl Phthalate
Bis (2-Ethyl hexyl
Phthalate)
Chloroethane
l,2-Dichlor9ethane
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Bromodichloromethane
Tetrachloroethene
1,2 Dichloropropane
Bromoform
1,1,2,2-Tetrachloroethane
2-Chloroethylvinyl ether
Dibromochloromethane
Ethyl benzene
1,2-Dichlorobenzene
Styrene
* with pH adjustment
Primary Method
of Treatment
Precipitation*
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Biological
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
Air Stripping
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Secondary Method
of Treatment
Biological
Biological
Biological
Biological
· Biological
None Known.
Biological
Biological
Biological
Air Stripping
Air Stripping
Air Stripping
Air stripping
None Known
None Known
Biological
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Table 8-2 indicates that the constituents present in the groundwater are
amenable to either one or more of the proposed treatment technologies being
considered.
The groundwater treatment alternative reccrnmended for the areas with high total
organic carbon concentrations (interior wells) will consist of air stripping
and biological treatment, followed by carbon adsorption, if needed. The
extracted groundwater will be pumped frat\ the interior tier of wells to a
ccrnmon equalization/sedimentation tank where suspended solids will be remwed.
Utilization of the equalization/sedimentation tank will minimize the suspended
solid material present, and will prwide a blended stable flow stream fran the·
four extraction wells for the subsequent ~roundwater treatment . .
The equalized flow will then be pumped to the· air stripping tower where the
volatile organic fractio~ will be remwed or reduced.
Volatiles present in the groundwater,such as vinyl chloride; methylene
chloride; 1-1-dichloroethene, 1,1-dichloroethane; trichloroethene; etc. should
be reduced 90 to 98 percent by air stripping. Semi-volatile remwal should
range between 30 to 80 percent-at ambient air temperatures.
The stripping tower effluent will then be pumped to a biological treatment
system. No specific biological treatment process has been selected. As the
data fran the pumping test.are evaluated in the terms of expected variations in
concentrations, flow variations, constituents, etc., a decision will.be made
regarding the preferred method of biolog'ical treatment.
The effluent fran the biological treatment will be discharged to a carbon
adsorption unit designed for this anticipated flow. This unit will be used as
a final treatment step to remdve refractory organics that may remain after
biological treatment.
Effluent fran the treatment·system will be discharged to the existing
wastewater treatment plant for discharge under the existing North Carolina
NPDES discharge permit. In cases where metals, such as chranium, are present
in the treatment system effluent abwe allowable discharge levels, the effluent
will be passed through a ~hemical precipitation step prior to final _discharge.
The groundwater treatment alternative proposed for the areas of lower total
organic carbon concentration (perimeter wells) will consist of air stripping
followed by carbon adsorption. Because of the low concentration of
constituents expected in this area and their general amenability to the use of
.· air stripping for remwal, the utilization of biological treatment is not
anticipated. Thus, the effluent fran the air stripping unit will be discharge
to a carbon adsorption unit for final treatment prior to discharge. The carbon
unit will be designed to handle the anticipated maximum flow fran the perimeter
well system. Again, should problems with metals be encountered, a
precipitation step will be added to the treatment sequence being employed.
Treated water fran the groundwater treatment system will be discharged in the
same manner as discussed previously for the groundwater fran the interior of
the plume.
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This recarrnended alternative meets the requirements of the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) 40 CFR, 300.68(j) and the
Superfund Amendments and Reauthorization Act of 1986 (SARA). This alternative
permanently and significantly reduces the mobility of hazardous contaminants in
the area groundwater. The recar.mended alternative for the source material will
be determined at the end of the additional studies.
Technical Evaluation
Performance of a remedial action is determined basically by its effectiveness
and its life expectance in performing its specified function. Effectiveness
refers to the degree to which an action will meet the remediation goal, which
is a reduction of toxicity, mobility, or volume of contamination or the removal
of exposure routes. The effective life is the length of time this level of
effectiveness can be maintained.
Both the groundwater extraction system and groundwater treatment systerr,
proposed can be considered to be effective in their remedial efforts. They
address the questions of reduction of toxicity, mobility, and volume of
contamination in a very positive manner. In addition, they also have a
positive effect on the removal of a potential exposure~route, the ground water.
Reliability is the degree of assurance that the particular remedial action
being considered will meet or exceed the expectations for its performance, the
likelihood that mechanical and process failure will occur, and the consequences
of such failures. This is directly related to the canplexity of the equipnent
and process selected for the remediation effort. Important considerations
concerning reliability are operation and maintenance requirements, and the
demonstrated performance of similar applications.·
In the case of the groundwater rerr,ediation, the simplicity of the groundwater
extraction system provides it with a high reliability factor. Also, the
treatment technologies selected for subsequent treatment of the ground water
are all well kna.m, tested, and accepted technologies which provides
reliability to the proposed treatment plan.
Health and safety takes into account the potential threat to health and safety
of site personnel both during the impleroentation of the remedial action
alternative and during its operation.
Remedial technologies were evaluated with respect to a number of safety risks
including the need for personnel to handle contaminated or hazardous materials
and the possibility of the production of toxic gases or airborne contaminants.
Operating conditions for the processes were also considered along with.their
effect on safety.
Construction of the interior tier of wells presents the greatest potential for
encountering contaminated materials. The work area will be monitored with air
monitoring equipnent to identify the need for respiratory equipnent, and dermal
protection will be provided during the field operations. Construction of the
perimeter line of wells is expected to produce a lesser potential for exposure
because of the lower concentration of groundwater contaminants in that area.
However, health and safety-considerations similar to those for the interior
tier of wells will be maintained.
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Trenching activities for pipe and electrical supply line construction, where
used, and general grading for the treatment facility construction are not
generally expected' to encounter contaminated materials. However, operations in
the area adjacent to the fonner 'disposal areas may·encounter contaminated
soils. These operations will be.monitored similar to the interior well
construction activiti.es to identify,.proper safety procedures.
All personnel involved, in·. construction and 0P3rati~n of the extraction and
treatment system will'~ trained in accordance with the g011erning OSHA
pr011isions contained in, 29'CFR 1910.120. · ·
The extraction and treatment·alternative was evaluated with regards to its
implementability. These considerations include such things as difficult
engineering requirements, availability of equiµnent; and pennit, treatability,
or pilot study requirements. Also included is ~he time required to attain the
desired r¢sults for the particular remedial alternative being proposed. The
groundwater extraction and treatment alternative uses available technologies
that do not require unusual engineering specialities for design and does not
require specialty equip11ent to implement. However, pump testing of the aquifer
is planned to pr011ide input for the extraction well design and bench-scale
treatability studies are _anticipated to verify the treatment technologies to be
used. The implementation of this.alternative will continue for several years
with the ca11pletion of the activity identified by monitoring that verifies that
the contaminant levels have been reduced to the ARARs specified by the
regulatory agencies. The duration of the cleanup can be shortened by the
successful rem011al and treatment/destruction of the source, and by accelerated
leaching by irrigation.
This cO!lbination of treatments is the most efficient and cost-effective remedy.
It is also the most technically feasible of the groundwater remedial
alternatives discussed in Section 7.0 of this document.
Consistency with Other Environmental Laws·
* Occupational Safety and Health Administration (OSHA)
A health and safety plan will be developed during remedial design and
will be followed during field activities to assure that regulations of
· OSHA are· followed.
* Endangered Species Act
The rec011mended remedial alternative is protective of species listed
as endangered or threatened under the Endangered Species Act.
Requirements of the Interagency Section 7 Consultation Process, 50
CFR, Part 402; will be met. The Department of the Interior, Fish and
Wildlife Service, will be consulted during the remedial design and
additional source characterization studies to assure that endangered
or threatened species are not adversely impacted by implementation of
this remedy.
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Ambient Air Quality Standards
The groundwater treatment system will be designed and monitored to
assure that air emissions meet all state and Federal standards.
National Pollutant Discharge Elimination System (NPDES)
Discharge fran the treatment system will flow into the existing
wastewater treatment system. This practice will continue only so long
as the discharge fran the wastewater treatro.ent system stays within the
existing NPDES permit.
Safe Drinking Water Act (SWDA)
Maximum Contarninant Levels (MCLs) established under the SCWA were
found to be relevant and appropriate to remedial action at the
Celanese Fibers Operations Site and will be considered the cleanup
criteria except in instances where the North Carolina State MCLs are
more stringent.·
Resource Conservation and Recwery Act (RCRA)
The recal\11\ended remedy for groundwater contamination is not regulated
under RCRA, therefore it does not apply.
Floodplain Management Executive Order 11988
The CERCIA areas do not lie within a floodplain, and, thus are not
subject to the requirements of E.D. 11988.
Department of Transportation (COT)
Transport of hazardous substances is regulated by the oor. we do not
anticipate this alternative requiring transportation of materials
off-site.
State Drinking Water Standards
Maximum Contaminant Levels established by the State of North Carolina
as given in 15 NCAC 2L were found to be relevant and appropriate in
all instances where the state MCL is more stringent than the SCWA MCL.
Specifically, for the purposes of this remedy, ·all canpounds detected
in the groundwater which are not naturally occurring must be rernO<Jed
fran groundwater until the concentration of that canpound has fallen
below the lowest analytical method detection limit published by EPA
for that particular canpound.
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9,0 Canrnunity Relations
A public meeting was held on September 24, 1985 to present the draft RI/FS work
plan to interested parties.
Two information repositories have been established for the site, one in Earl,
North Carolina and one in Shelby.
A public meeting was held on July 21, 1986 to present the findings of the
Remedial Investigation'to interested citizens,·
On February 3, 1988;.a public meeting was held to discuss the results of the
Feasibility Study with interested citizens. At that:time, EPA also presented
the preferred remedial alternative.
Numerous questions were ·asked at the meeting and a number of canrnents have been
received, Few canrnents were on the selected alternative. The majority of the
canrnents received were .actually requests·to have private wells sampled. These
requests are being handled by the C.leveland County Health Department in concert
with the North Carolina Department of Human Services:,-
' The public did show a desire for, remediation of .the site. No opposition fran
the public is expected if the recarar,ended remedial alternative is implemented,
A Responsiveness Summary has been prepared to summarize canrnunity concerns and
EPA's canrnunity relations activities.
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'.. -~TIACHMENT
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I 1,0 RESPONSIVENESS SUMMARY
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Celanese Fibers Operations Site, Shelby, North Carolina
Responsiveness SUll'J1'.ary
This corrmunity relations responsiveness surrrnary is divided into the following
sections:
Section I.
Section II.
Section III.
Section IV.
CNerview. This section discusses EPA's preferred alternative
for rerr·edial action and likely public reaction to this
alternative.
Background on -CO!ITT,uni tY i:nvol verne~t -and~ Concerns. This sect ion
provides a brief history of corrmunity interest and concerns
' '
raised during remed'ial activities at the Celanese Fibers
~erations site.
Surrar,ary of major, comi>eiits received during -the Public Carroent
Period and' the -EPA.' responses to -the CO!l'rnents. Both the carment
and EPA's response are·provided.
Remaining Concerns. This section describes remaining crnmunity
concerns that EPA should be aware of in conducting the rerr,edial
design and rem.edial action at the Celanese Site.
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1,
2.
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Overview
At the time of the public weeting and the beginning of the public canment
period, EPA presented its preferred alternative to the public. This
alternative specified in the Record of Decision (00D) includes:
extraction of contaminated groundwater and treatment of the contaminated
water.
The canmunity favors remedial action though few citizens expressed a
preference for a parti'cular process.
History of Cmmunity"c6ncerns
Citizens of the Earl/Shelby area have expressed great interest in
activities relating to the.Celanese Fibers Operations site. The citizens
of Earl, North·carolina, with the assistance of Diana Travis and other
staff members of the_Clean Water Fund of North Carolina, organized the
United Neighbors For Cleanup-at Earl because·of their concern about the
quality of water for their families. Les Brown, Conservation Chair of
the Broad River Sierra Group of Boiling Springs, has also expressed an . .
interest in the site. Many_ newspaper articles have been written by Donna
Clemmer of the The.Shelbf.Star concerning contamination at the site.
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3.
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SUITT11ary of Public Ccmr,ents Received During Public CCJITl'ent Period and
Agency Responses
Carments raised during the February 3, 1988 Celanese Public Meeting are
surrrnarized briefly below:
Questions and corcu,ents by participants fell into five general areas: the
adequacy of the proposed conceptual remedy to protect human health and
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the environment, the current potential .i!l'pact upon area residents and
their property, the potendal for. clea!"}up activities to adversely impact
nearby residents, the desire to be informed of test results on individual
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wells, and finally, the availability.of an EPA Technical Assistance Grant
(TAG) to the community. The comments and questions from the public and
fran representatives·of Celanese Fibers q;>erations who attended the
meeting are SUI1'Il'.arized below, followed by EPA's response to each major
point or question.
Adequacy of Proposed RemedY.to.Proi:.ect Hurran.Heali:.h"and.the
Environm.ent
Citizens raised numerous questions and concerns about how the
proposed remedy would ensure that air and water quality were
protected. Specific issues raised included:
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How will metals like lead, chranitnT, and other potential
carcinogens be rerroved from contaminated ground water?
EPA: Air Stripping will be the first ~tep followed by
biological treatment and, if needed, activated carbon treatment
and precipitation. The water would then receive additional
treatment in the CFO wastewater treatment facility. Any water
discharged fran the facility must continue to m.eet current
permit standards.
Will an ion exchange alternative be considered in treatment?
EPA: This is part of the chemical action involved in carbon
absorption.
Will the air-stripping unit simply remove contaminants fran the
groundwater and discharge them to the air?
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EPA: Yes. The air stripper will remcwe contaminants to
achieve quality safe for drinking. The air stripping tower
remcwes volatile and sane extractable organic canpounds by
blowing air through water. This will result in some discharge
to air, however they will quickly disperse so as to be
undetectable in the atrr,osphere.
What standards will be applied to ensure air quality, since
North Carolina has no:air.toxic regulations? Participants
asked if EPA would adhere to North Carolina's proposed
regulations. In stressing the need for a standard, one citizen ' . .. ~. . ',.
suggested EPA follo,i the National Academy of Sciences (NAS)
recOffi!T,erided air quality standards. . ~ . . . ... . . ..:. ; . , .. '
EPA: ·. EPA will look at North Carolina's proposed regulations . '
, ) ~ .
and the NAS suggested_'standards but will rely on Federal air . ,· . . ~
quality regulations to ens~re protection of hooan health.
What action will be taken to monitor and ensure that air
quality standards are·· enforced; would stack tests, for example,
be done on the air stripper?
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EPA: The actual system to monitor and protect air quality will
be developed in the design stage of this process. EPA will
present the design to citizens and seek public carment.
Will additional off-site properties be tested to ensure that
contamination does not migrate to them?
EPA: Yes. At the.design stage; in July,,EPA will have a . . '
clearer picture of which wells would be best to sample.
Citizens will have an opportunity at that time to comment on
the design.
Are the proposed groundwater pump tests experirr.ental or a
procedure that has been tried in similar circumstances?
EPA: Pump tests are performed as a matt~r of routine at other
sites in order to design extraction systems that will gather
all the contaminated ground water without adversely affecting
private wells.in the area.
,r, . '. ..,
Since-the more c~ntaminated interior ground water flows toward
and eventually would mix with exterior levels, will EPA's
two-tiered well extraction system misrepresent groundwater
treatment results?
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-7-
EPA: That might have been the case if the results were used to
measure contaminant reductions in one location or the other,
however the water will be judged as a whole. Both areas will
be subjected to treatment and must be cleaned up to acceptable
standards.
One citizen recommended that a carbon adsorption unit(s) should
be part of the ground-water treatment design to ensure its
capability to remcwe contaminants that may not have settled out
or been remcwed .by the a_ir. stripping' unit(s).
EPA: The carbon treatment unit(s) will ,be part of the
treatment design. Water at that st~ge of the process may
already have been cleaned up and the carbon treatment would be
redundant at that point. Neve_rtheless a carbon treatment
unit(s) will be installed.
How often will the effluent from the wastewater treatment plant
be tested? Can the facility's current system handle the water
that will come fran groundwater treatment and still protect the
streams where discharge will occur?
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B.
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EPA: This has not been determined as yet; EPA would welcome
suggestions as to the frequency of testing or an appropriate
monitoring schedule. It could be continuous for a period of
time.
How will residue from the thermal treatment of soils and
sludges be handled and how will air quality be assured?
EPA: Because more information is needed on the best rrethods
for physically extracting the soils and sludges, as well as
treating them, EPA has not yet decided the specifics of how
residues from thermal processes will be handled. This will be
determined after further materials testing and during the
design stage for this phase of the cleanup.
Current ·Potential Irr,pact on. Health and Property of. Area ·Residents
Residents raised the following questions or observations about how
the site may already have impacted or will impact their health or
property:
Is our water safe for drinking,· for other uses?
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-9-
EPA: EPA is confident that the RI/FS studies are thorough and
that the source of the contamination has been found. One
off-site well that has demonstrated contaminant levels of
concern, possibly stemming from contamination from the site,
will be treated at the company's expense. For peace of mind
any resident who wishes could use bottled water for drinking,
but EPA is not recorrrnending this as necessary.
Several ·residents state? .that they had not received results
from prior tests of their· well water and requested that testing
be done, -,
EPA:' Most·of tne tests· refer.red to were conducted by the
C~eveland County, Heal th Departrrent. Citizens were encouraged
. , ~ t . ;
to·write to·the County, and ask for the results. EPA would also
request copies of thes~ test results and will assist residents
who inquire, in interpreting the test results. The point was
also stressed to residents requesting tests to be done, that
requests should be directed to the Cleveland County Health
Departrrent in writing. record of the request may later help
EPA assist residents in receiving or. interpreting infomation.
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One resident qu~stioned the current standards applied to the
discharges of Celanese wastewater into the creek. ,The person
noted that there was no life in the creek, and that animals had
died.
EPA: The discharges are regulated under a pemit issued by the
State of North Carolina •. Concerned residents can request a
copy of the pemit from the State Departroent of Hman Resources
or Mr. Hanke at EPA would send a copy of the permit upon
written request. In addition, citizens can provide input to
the standards to be met under the permit at the time of its
renewal. It was believed that the renewal date was 1990.
Residents asked about Celanese's current waste handling methods
and the possibility of future problems of the same nature.
William Mayrose, CFO/Shelby Plant Manager: Wastes currently
generated are not stored on-site. They are transported to a
licensed waste facility.
C. Potential.Adverse Impacts on Adjacent Properties"from the Cleanup
Activities
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In addition to concerns about air quality mentioned earlier in this
document, residents expressed concern about the impact of waste
cleanup activities on their water supplies or nearby streams and
ponds. These concerns were addressed as follows:
Will ~umping to remove ground~water decontamination cause a
drop in the water table and potentially cause wells to go dry?
EPA: This is a matter EPA has w~·ighed carefully and in order
to determine• the means to.-protect area wells, a pump test will
be conducted. This y,ill .involve digging a test well, pumping
at Vi"-rious rates, and monitoring area wells to see the effects
of the pumping. The extraction system will be designed based
on information gained .-from this t~st.
Will excavation cause ~rosion and the run-off of contaminated
water down the hillsides and onto adjacent properties?
EPA: No. Stormwater diversion and collection systems will be
part of the cleanup design so that no releases of materials
being cleaned up will occur.
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D.
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Availability.of Technical Assistance Grants (TAGs)
Several meeting participants ,expressed interest in receiving
technical assistance grants and the following questions were raised:
What is the timing for start-up of the TAG program; will that
be sufficient time for the ccrnmunity to be involved in shaping
the decision on the CFO cleanup? Is. there anything the
=,unity can do to speed up the process? Can EPA re-open its
decision process once, or if, carmunity succeeds in getting a
grant?
EPA: A National workshop in Dallas the second week of February
is expected to resolve some lingering questions about
implementing the TAG program, for example questions regarding
financial arrangements. The process of applying for TAGs is
expected to be in place in about six weeks. EPA Region IV will
distribute fact sheets on how to apply. The design phase for
the CFO site will not have been decided by that time. EPA
anticipates having a proposed remedial design by July 1988.
EPA's policy and that of Congress is not to hold up Superfund
cleanups for technical assistance grants. EPA Region IV will
do everything possible to see that this coomuriity receives
priority attention when applying for the TAG.
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Would it be feasible for Celanese·to award a TAG to the
community?
EPA: Celanese would have to respond to that. William Mayrose,
CFO Plant Manager: Celanese has a technical resource on the
project and is hiring Clean Sites, Inc. as a second independent
resource. The company sees no reason to bring in a third
technical resource.
For further detail and clarification on all comments raised during the
meeting, interested persons can refer to.the public meeting transcript.
The corrment period on·the Feasibility started on February 3, 1988 (the day of . . . . . .
the public meeting) and closed on February 24, 1988 •. One set of comments was
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received on Febru~y 25, 1988. These will be addressed here with the other
written comments received:
L Thirteen residents wi:-ote·to request.i:heir·wells be sarrpled.
EPA Response: A sampling effort.is underway under the initiative of the
Cleveland County Health Department. The Health Department, in
conjunction with the State of North Carolina, have begun sampling wells
as requested by these citizens.
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2.
3.
4.
5.
Two citizens.wrote.to express concern ooer possible changes in air
quality near the site due to the'air stripping process.
EPA Response: The groundwater.,.treatment system will conform to
applicable or appropriate and relevant air quality standards.
Three.citizens.wrote to.express concern about possible waste burial sites
near the site.
EPA Response: A nurober of off-site burial areas have been investigated
by the State of North Carolina. These reports are available from the
State. Any infornation on burial sites not previously investigated
should be forwarded to the state superfund office.
Three people wrote to request addit.i6nai. inforn.ation. on. Technical
Assistance Grants:
EPA Response: These requests were handled directly by the US EPA Region
IV Public Affairs Branch with a letter giving current information on the
status of the TAG.
EPA Response: These people were referred to the two site repositories.
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6.
7.
8.
One resident wrote to ask "with·the .. sludge remOJal, and the well water
treatment,· is it the opinion the in sar,e humber of years, water treatment
will no longer be r~quired?"
EPA Response: Yes. The Agency's plan is to implement a permanent remedy
at the subject site. Therefore, at some time in the future, we
anticipate mOJing from active treatment to monitoring of groundwater.
A representative from the.Sierra Club wrote to ask the following
questions: "How about taking the water from the carbon adsorption unit
back to the ground via irrigation, etc. This will loop the waste for
re-cleaning and will restore groundwater levels."
EPA responses: The preferred alternative will result in the water being
cleaned" to the· applicable or appropriate and relevant standards,
therefore, no "re-cleaning" will be necessary. Additionally, recharge in
the area is fairly slow, therefore a discharge to the surface would'
probably not impact water table levels significantly.
One family had the following three guestions/cmments:
A. "Our main concern is long-range testing.of off-site wells to
ensure safety of drinking water for citizens."
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EPA Response: This question will be answered as part of the
Remedial Design,
"HCM will tli.e water "table '6e ·effecteci"bY pumping groundwater in
ttie cleanup proc:ess·(air stripping)?"
EPA Response: The effect of the pumping on the water table
level in the surrounding wells will be determined as part of
the pump test at the site. The system will be designed so as
to minimize this possibility.
C, The third question concerned·tectinical Assistance.Grant
availability.
EPA Response: This question was answered with a letter to the
. . . . . .. ' .. ; .,
questioner explaining the'current status of these grants.
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A letter was received on FebruarY 2s; 1988. from ttie United Neighbors for
Cleanup. They had the following guest.ions/ccmnents:
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A.
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All.neighboring drinking water wells should be tested now for a
full range of organic and· inorganic cherr,icals, and the results
should be explained in an informai meeting between the users of
those wells and representatives of EPA.and/or other·agencies.
These representatives sh~uld.have the.expertise to answer
questions about potential health effects of.individual
chemicals and synergistic effects.of·car.bined chemicals •
EPA Response: It is our u·~derstanding that a program has been
set up in conjunction with the Cleveland County Health
Department to have private wells sampled as requested. We
would be happy to assist in the evaluation of any analytical
results from this program and to speak or meet with any well
owners about those results. As before, we are also available
for such assistance in formal or informal public meetings to
discuss. these results as they beccrne available. Also, the
results of any such analyses may shed scrne light on the
groundwater hydrology of the area, and we would be eager to
review any results on that basis as well.
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c.
A regular well testing schedule should be instituted, with
wells in each neighborhood tested aver a period of years to
monitor any mavernent.of contamination off-site. Even if the
proposed groundwater pumping and treatment operates to prevent
further mavement off-site, there has not been enough testing to
assure that the contamination has not already passed the site
boundaries.
EPA Response: It has been determined that a randOOI selection
of off-site wells will be included as part of the operation and
maintenance (O&M) sampling plan. The O&M Plan is considered
part of the Remedial Design and will be available for public
cmment in mid-July.
During the February 3 meeting, we were told.that Celanese plans
to clean up Mr. James Elliott's well. However, at that time,
Mr. Elliott had never been informed of that promise.· We
request written confirmation.of the promise, including
information about the procedure for cleanup.and a timetable for
irnplerrenta tion.
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EPA response·:. The agreement with Celanese to remediate the
Elliott well was confirmed in writing the day of the public
meeting. Written confirnation .. of the agreement will be
forwarded to both information repositories . . '
D. The ·Record··of Decision should include ·a provision for the
suPrilYirig"of.dririkirig'water·at the·expense'of Celanese to any
neighbors. whose. welis -are. contaminated. 6Y. cherr,icais. from the
site; The burden·of·proof.should be on the owners of the site
to prove that any contaminants. did. NOT. coo.e from the Superfund
site, not on the.rieighbors.to.prc,,ie.they·did;
EPA Response: It will be difficult for CFO or their
consultants to positively "prove" that any contamination found
at sme future date in a nearby private well did not originate
from the site. This is the situation that currently exists
with the Elliott well; it will be extremely difficult and
costly for CFO to demonstrate, with reasonable certainty, that
contamination found in this well is not site specific. In
these situations, the best that can be done is to evaluate the
existing data, and try to come to a reasonable conclusion based
on that data as to whether or not any observed contamination is
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site specific, The selected remedial action will be designed
to prevent further contaminant transport from the site, and
since groundwater mavement and contaminant transport is
relatively slow, the time between now and the implementation of
·the remedial action should not be sufficient to allow
widespread further contamination. Therefore, the concern
regarding future contamination, while understandable, is based
on events that are unlikely to occur.
E. -Any level of-grounciwater·contamination attributable.to the site
should be cleaned.up, even.if.it does not.exceed current
drinking.water-standards:. ·scientific-knowledge of the effects
of ·1ong.:.tern, exposure -to low levers -of contaminants is
incar,plete; anif the. cailpanY' should be. responsible for remav ing
• • -: • • - • -• - • J ' • • • • any contamination .it caused.
EPA Response: Groundwater clean-up goals may be set in a
number-·of · ways, sar,e-of which are ·consistent with the concept . . .
of remediation to backgJ'.'ound levels. Often, however, clean-up
goals for extraction wells located on-site are set at drinking
water standards or sar,e other health-based criteria. In such a
case, contaminant transport from the waste site to any off-site
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-21-
·water supply wells will further reduce concentrations and
prOll'ide an additional rr,argin of safety. Finally, EPA
regulations allow for setting of alternate concentration limits
under appropriate circumstances, and it is therefore not
possible for EPA to rule out such a possibility. The
determination of groundwater clean-up goals will be based on
site-specific application of applicable or relevant and
appropriate regulations in a manner that is protective of
public health and the environrr.ent. Therefore, the 15 NCAC 2L
standards of the State of North Carolina are considered the
appropriate clean-up criteria for this site.
F. Surface water exits tli.e site.in.several strews; Each stream
and its sediment. sli.oulci' be. tested, dJei:-tiri-,e;. to. ensure that
contamination is not· leaving b:f that route •. In addition, the
recreation pond.on-site.sli.ould.be tested.(or; if tests have
been conducted, we request that tli.ey·by made available), and
the discharge from the.pond.that passes.tli.i:-ougli. adjacent
property shouid.be·monitored·over time;
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· EPA Response:. Testing of these media was conducted during the
Remedial Investigation (RI) at the site. This information is
currently available to the public in the RI report located in
the two site informcltion repositories.
G. The Record of Decision.should.include a. pr6vision for modeling
of any pump and freai: system.for groundwclter'i:6 determine the
effect it may have·on·supplies in neighboring.wells. If the
treatment lowers the wa.i:er.i:a.ble or.causes clnya.dverse effects,
the.company.should pcly.for providing an.clii:ernate supply of
water to affeci:eci.neighbors·i:o·avoid.creating·a new problem
while solving an·existing"one:
EPA Response: The concern expressed regarding the effects of
any groundwater extraction system installed at the site on
nearby private wells is a valid one. The remedial design will
take into account aquifer characteristics and hydrologic
response to stress as determined by the proposed pump test to
be conducted at the site. Agency review will also help insure
that the pump and treat system will not adversely affect water
quality or yield in private wells in the vicinity.
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Carrnunity air should not be used to clean a Superfund site.
Any air stripping of groundwater should be done in a closed
system. Sirrply ri,.eeting current North Carolina air toxic
regulations is not enough, since such-regulations do not
exist. The company should be required-to use measures that
avoid ANY degradation of coomunity water or air quality.
EPA Response: Remedial Design will take into account the
potential for exposure_ to volatile. organics from operation of a
treatment system which inc~udes air stripping of contaminated
groundwater. In general, the exposure via this route is
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expected to be"minimal, due to the high degree of dispersion
available relative to the mass_ of volatile ·organics rem011ed
from the groundwater. When the relatively low yield of the
surficial'aquifer at the site is taken into account, the volume
of water to be treated on a daily basis will be small, and the
quantity of volatiles ·emitted likewise srr,all. We are not sure
what is intended fo this cooment by reference to a closed
system in an air stripper; a closed system will result in the
buildup of volatile organics in the air used to strip the
contaminated water so that the stripper will be rendered
ineffective. The only way to completely eliminate sooe air
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emissions would be to treat the air leaving the stripper
column, and i't is extreirely unlikely that the risk associated
with the emissions frm, the stripper would warrant such
sophisticated treatment.
A plan needs to be-in place for controlling potential emissions
caused by disturbance·of.the soil during the materials handling
investigation: ·this.pian needs to be available for public
corrment and.EPA.response·before the.work begins. The crnmunity
should not be re-exposed during.this process.
EPA Response: This concern will be addressed as part of the
Operable Unit II Feasibility Study to be conducted at the site.
We request written answers.to cooments raised in earlier
meetings. (SpecificallY; see the transcript of the July 21,
1987, public -rr,eeting on. the Celanese Remedial Investigation,
which contains. i-ii.ui,erous. questions -and .. corrrnents. )
EPA Response: Questions and corrments raised at the July 21,
1987 Public Meeting to present the RI report were, for the
large part, addressed at that tim.e. Four written crnm.ents were
received by the RP~ and each crnment had a written response.
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There have been reports of additionai off-site burial areas.
The Record.of Decision·shouid include a pr011ision for
investigation of.any of these.reported to.the EPA.in the
future.
EPA Response: The State of North Carolina has responded
diligently to requests for investigation of additional
suspected hazardous waste burial areas. These requests will
continue to be forwarded to the State for action, therefore it
is inappropriate to include such a pr011ision in_the Record of
Decision for the site.
Proposed rerr,ecties.that discharge-treated·water·to·surface water
strearr,s -should. not -increase. the· 1evei. of -contarr,inai:ion in those
streams. -The existing -NPDES pem,ii: should be reviewed to
ensure -that all -cherr,icals. found -in -the groundwater will be
monitored, that perrr,itted-levels avoid any deterioration of
surface water guaiity; and that·ri,_onitorinc;(by°the EPA or the
state is adequate to ensure that the permit conditions·are met.
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-26;..
EPA Response: Any remedial action which would involve
discharge of treated groundwater to a surface stream, either
through the existing NPDES discharge to Buffalo Creek or to
some other stream, will be coordinated with the NPDES programs
at the State and Federal levels. We would expect that any flow
from a groundwater extraction and treatment system will not
significantly increase flow through the present NPDES
discharge, which is permitted 850,000 gallons per day. The
permit monitoring conditions may need to be revised to reflect
the possible presence of groundwater contaminants; it should be
noted, however, that if treated groundwater is to be discharged
through an NPDES discharge, effluent 1c.onitoring will be done by
the facility and not by the State or EPA. A schedule for the
1c.onitoring will be included as part of the rmedial design at
the site.
General comments were made concerning the following:
A. Notice of meetings.and availabilit,j,"of.clocurr,ents for review
prior to meetings.has been poor.
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EPA Response: . All statutory cam,unity relations requirements
have been met. However, in light of the dissatisfaction of the
CO!T'lllunity, future planning will include additional' notification
and review times.
The citizens request that EPA tell them whether or not their
water is safe to drink;; ·that if contamination occurs that
Celanese will ·clean it up at the expense of the company and
that the ROD.contain all of this.
EPA Response: A letter was sent to seventeen residents whose
wells were sampled during the RI interpreting the results.
This letter stated that, based on currently available
information, all the wells but four could be presumed to be
"safe". Tl')ose four were re-sampled by the Agency in August
1987. TCE was confirmed.in one well above MCLs and, as a
result, it has been remediated. Two wells were found to have
unacceptable levels of methylene chlcir:_ide. These results are
believed to be probable analytical artifacts and not
contamination emanating from the site. The fourth well
reportedly had unacceptable concentrations of arsenic. The
footnote to the data reported an "R" which indicated unreliable
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data. Additionally,· wells u·pgradient and around the site have
been abandoned due to high levels of arsenic. It is believed
that these concentrations of arsenic are a naturally occurring
phenorr.ena in the Shelby area.
The ROD is only a decision document, therefore, questions of
liability cannot be incorporated.
Questions were raised concerning the availability of Technical
Assistance Grants.and a request "that anY decision made on the
clean-up options at.this point include a provision for changes
on add i tionai public . cornnent. "
EPA Response: The current infom,ation available on Technical
Assistance Grants was reiterated as well as the current EPA
policy that Records of Decision not be delayed or postponed
while awaiting the Technical Assistance Grants. The public has
been infom-ed that they will be given an opportunity to corrrrent
on the detailed remedial design.
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4. Remaining Concerns
. . The only_rernaining concerns at .the.site are, drinking water. quality and
Technical Assi~tance Grants. The water. qualitY. concerns will be addressed
as soon as sawpling·results are received. The concern over TAGs will be
addressed as soon as the rnechanism,for awarding these is in place.
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I ATTACHMENT
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I 2. 0 ADMINISTRATIVE RECORD INDEX
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PRELIMINARY DRAFT INDEX: Celanese Fiber Operations (CFO)
Administrative Record
Remedial Project Manager: Michelle Glenn
Note: This is a PRELIMINARY draft index. It will be replaced by a
more detailed draft index in 2-3 weeks.
06-01-85 Memo submitting the Draft
Celanese Fiber Operations
To: Simpson, Gary Soil
From: Clarke, Meredith
Final Report for the
Site.
& Materials Engineers
U.S. EPA
07-22-85 Final Forward Planning Study for the CFO site
Prepared by: Camp, Dresser, & McKee (CDM).
11-01-85 Work Plan for Celanese Fiber Operations
Prepared by: Soil & Materials Engineers (S&ME)
12-06-85 Memo stating approval of Work Plan submitted by
Soil & Materials Engineers
To: Engelman, Susan Celanese Corporation
From: Devine, Thomas W. U.S. EPA
12-12-85 Summary report of activities at Celanese Fiber
Operations Site during November, 1985.
To: Anderson, Meredith C. U.S. EPA
From: Glover, Everett w. Soil & Materials
Engineers
01-01-86 Community Relations Plan
Prepared by H. Michael Henderson, U.S. EPA
01-08-86 Memo forwarding final Community Relations Plan
to information repositories and government
agencies.
To: Perry, Doug (and others)
From: Anderson, Meredith C. U.S. EPA
01-10-86 Summary of work completed at the Celanese Fiber
Operations Site during December, 1985
To: Moore, Ben U.S. EPA
From: Barone, John C. Soil & Materials Engineers
EPA-HEOION IV
ATLAJiTA, GA
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PRELIMINARY DRAFT INDEX: Celanese Fiber Operations (CFO)
Administrative Record
01-16-86 Monthly Status Report: Summary of work completed
at the Celanese Fiber Operations Site during
December, 1985.
To: Anderson, Meredith C. U.S. EPA
From: Glover, Everett w. Soil & Materials
Engineers
01-21-86 Final Project Operations Plan for the CFO Site
Prepared by: Soil & Materials Engineers
02-07-86 Summary of meeting held to discuss details of
sampling and analytical programs at the Celanese
Fiber Operations Site.
To: File
From: Glover, Everett w. Soil & Materials
Engineers
02-11-86 Monthly Status Report: Summary of work completed
at the Celanese Fiber Operation Site during
January, 1986.
To: Townsend, Gena U.S. EPA
From: Glover, Everett w. Soil & Materials
Engineers
02-17-86 Memo discussing visit to properties that possibly
received wastes from the Celanese Fiber Operations
site.
To: File
From: DeRosa, Pat North Carolina CERCLA unit
02-26-86 Sample Analyses Request
To: North Carolina State Laboratory of Public
Health
From: DeRosa, Pat North Carolina CERCLA unit
03-04-86 Monthly Status Report: Summary of work performed
at the Celanese Fiber Operations Site during
February, 1986.
To: Townsend, Gena U.S. EPA
From: Glover, Everett w. Soil & Materials
Engineers
03-04-86 Memo forwarding overview of sampling activities
at the Celanese Fiber Operations Site.
To: Clarke, Meredith U.S. EPA
From: Vick, Hugh C.
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PRELIMINARY DRAFT INDEX: Celanese Fiber Operations (CFO)
Administrative Record
03-10-86 Memo forwarding executed copy of consent order
between the U.S. EPA and the Celanese Corporation.
To: Engelman, Susan Celanese Corporation
From: Ravan, Jack E. U.S. EPA
03-21-86 Memo summarizing community relations activities
at the Celanese Fiber Operations Site.
No Date
To: Townsend, Gena U.S. EPA
From: Anderson, Meredith C. U.S. EPA
Report discussing overview (conducted during
24-26, 1986) of sampling activities at the
Celanese Fiber Operations Site.
To: File
From: Sloan, Fred U.S. EPA
March
03-31-86 Memo enclosing an article from the Shelby Star:
"Soil and Water Sampling Completed at Celanese
Dumps."
To: Townsend, Gena U.S. EPA
From: Spangler, Carl M. Celanese Corporation
04-06-86 Sample Analyses Request
To: North Carolina State Laboratory of Public
Health
From: DeRosa, Pat North Carolina CERCLA unit
04-07-86 Memo discussing the need to resample 35 wells
because data was erased at sampling lab.
To: Townsend, Gena U.S. EPA
From: Lerme, J.A. Celanese Corporation
04-08-86 Sample Analyses Request
To: North Carolina state Laboratory of Public
Health
From: DeRosa, Pat North Carolina CERCLA unit
04-08-86 Monthly Status Report: Summary of work at the
Celanese Fiber Operations Site during March, 1986.
To: Townsend, Gena U.S. EPA
From: Barone, John C. Soil & Materials Engineers
04-09-86 Memo summarizing site inspection at the Bettis
property.
To: File
From: DeRosa, Pat North Carolina CERCLA unit
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PRELIMINARY DRAFT INDEX: Celanese Fiber Operations (CFO)
Administrative Record
04-09-86 Memo forwarding an article from the Shelby Star
that discusses the Celanese dumps.
To: Lucia, Shirley Celanese Corporation
From:' Townsend, G.D. U.S. EPA
04-14-86 Memo enclosing a Shelby Star newspaper article
that discusses resampling of some monitoring
wells.
To: Townsend, Gena U.S. EPA
From: Spangler, C.M. Celanese Corporation
04-15-86 Memo forwarding trip reports, inspection reports,
and sample analyses at several properties near the
Celanese Fiber Operations site.
To: Anderson, Meredith C. U.S. EPA
From: DeRosa, Pat North Carolina CERCLA unit
04-30-86 Memo describing overview visit at the
Celanese Fiber Operations site.
To: Townsend, Gena U.S. EPA
From: Pierce, Jeffrey A. Camp, Dresser, & McKee
05-07-86 Oversight and Technical Support Work Plan for
the Remedial Investigation/Feasibility Study at
the Celanese Fiber Operations site, Vol. I.
Prepared by: Camp, Dresser, and McKee
05-08-86 Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during April, 1986.
To: Townsend, Gena U.S. EPA
From: Glover, Everett W. Soil & Materials
Engineers
05-16-86 Memo enclosing report on overview of sampling
activities at the Celanese Fiber Operations site.
To: Townsend, Gena U.S. EPA
From: Sloan, Fred U.S. EPA
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PRELIMINARY DRAFT INDEX: Celanese Fiber Operations (CFO)
Administrative Record
06-05-86 Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during May, 1986.
To: Townsend, Gena U.S. EPA
From: Glover, Everett W. Soil & Materials
Engineers
07-01-86 Memo discussing an oversight inspection during
June 23-25, 1986 at the Celanese Fiber Operations
Site.
To: Pierce, Jeff Camp, Dresser, & McKee
From: Wilson, Charlie Camp, Dresser, & McKee
08-08-86 Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during July, 1986.
To: Townsend, Gena U.S. EPA
From: Glover, Everett w. Soil & Materials
Engineers.
09-10-86 Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during August,
1986.
To: Townsend, Gena U.S. EPA
From: Glover, Everett w. Soil & Materials
Engineers
10-10-86 Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during September,
1986,
To: Townsend, Gena U.S. EPA
From: Glover, Everett W. Soil & Materials
Engineers
10-14-86 Memo to confirm change of date for Feasibility
study Plan.
To: Townsend, Gena U.S. EPA
From: Lucia, Shirley Soil & Materials Engineers
10-23-86 Memo enclosing results of Region IV analyses of
split samples for the Celanese Fiber Operations
site.
To: Townsend, Gena U.S. EPA
From: Hooper, Charlie U.S. EPA
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PRELIMINARY DRAFT INDEX: Celanese Fiber Operations (CFO)
Administrative Record
10-31-86
12-09-86
01-10-87
02-09-87
02-12-87
02-12-87
02-18-87
Memo forwarding trip
and analyses results
reports, inspection reports,
to a local information
repository.
To: Perry, Doug
From: Moore, Ben
Cleveland Co. Public Library
U.S. EPA
Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during November,
1986.
To: Moore, Ben U.S. EPA
From: Glover, Everett w.
Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during December,
1986.
To: Moore, Ben U.S. EPA
From: Glover, Everett w. Soil & Materials
Engineers
Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during January,
1987.
To: Moore, Ben U.S. EPA
From: Glover, Everett W. Soil & Materials
Memo forwarding documents for an information
repository.
To: Lavender, Jackie Celanese Information
Repository
From: Moore, Ben U.S. EPA
Memo forwarding documents for an information
repository.
To: Perry, Doug Cleveland Co. Memorial
Library
From: Moore, Ben U.S. EPA
Memo offering comments on the Feasibility study
Work Plan.
To: Moore, Ben
From: Swallow,
Hazardous Waste
U.S. EPA
June A. North Carolina
Management Branch
6
Solid and
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PRELIMINARY DRAFT INDEX: Celanese Fiber Operations (CFO)
Administrative Record
02-23-87 Memo offering comments on the draft Remedial
Investigation Report for the Celanese Fiber
Operations site.
To: Moore, Ben U.S. EPA
From: Pietrosewicz, Chuck Agency for Toxic
Substances and Disease Registry
02-23-87 Memo offering comments on the Draft Remedial
Investigation Report for the Celanese Fiber
Operations site.
To: Glover, Everett w. Soil & Materials
Engineers
From: Moore, Ben U.S. EPA
03-06-87 Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during February,
1987.
To: Moore, Ben U.S. EPA
From: Everett, Glover W. Soil & Materials
Engineers
03-09-87 Memo regarding the possible impacts of new
legislation on the remedial activities at the
Celanese Fiber Operations site.
To: Pullen, Jim Celanese Corporation
From: Tobin, Patrick M. U.S. EPA
04-10-87 Monthly Status Report: summary of work at the
Celanese Fiber Operations site during March, 1987.
To: Moore, Ben U.S. EPA
From: Glover, Everett w. Soil & Materials
Engineers
04-24-87 Memo containing corrections to the Draft Remedial
Investigation Report for the Celanese Fiber
Operations site.
To: Moore, Ben U.S. EPA
From: Glover, Everett w. Soil & Materials
Engineers
05-01-87 Final Feasibility Study Work Plan for the Celanese
Fiber Operations site.
Prepared by: Soil & Materials Engineers
05-11-87 Monthly Status Report: Summary of work at the
Celanese Fiber Operations site during April, 1987.
To: Moore, Ben U.S. EPA
From: Glover, Everett W. Soil & Materials Engineers
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PRELIMINARY DRAFT INDEX: Celanese Fiber Operations {CFO)
Administrative Record
05-14-87 Memo discussing the submittal of the Final
Remedial Investigation Report for the Celanese
Fiber Operations site.
To: Moore, Ben U.S. EPA
From: Glover, Everett W. Soil & Material Engineers
06-01-87 Final Remedial Investigation Report, Vol I-Text,
tables, and figures.
Prepared by: Soil & Materials Engineers
06-01-87 Final Remedial Investigation Report, Appendices-
Vols. I and II.
Prepared by: Soil & Materials Engineers
06-23-87 Memo discussing an upcoming public meeting for
the Celanese Fiber Operations site.
To: Thompson, Hagan U.S. EPA
From: Moore, Ben U.S. EPA
11-12-87 Transcript of Public Meeting: Celanese Fiber
Operations Site.
Prepared by: Camp, Dresser, & McKee
01-01-88 Feasibility Study Fact Sheet.
Prepared by: U.S. EPA
02-26-88 Final Feasibility Study Report and Public Health
Assessment: Operable Unit One-Groundwater.
Prepared by: Soils & Materials Engineers
03-23-88 Record of Decision for the Celanese Fiber
Operations site.
Prepared by: U.S. EPA
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3.0 STATE CONCURRENCE
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North Carolina Department of Human Resources
Division of Health Services
P.O. Box 2091 • Raleigh, North Carolina 27602-2091
James G. Martin, Governor
David T. Flaherty, Secretary
Ronald H. Levine, M.D., M.P.H.
23 March 1988
Ms. Michelle Glenn
SUperfurrl Project Manager
Erwironmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: Record of Decision
Celanese Fibers Operations NFL Site
Shelby, North carolina
Dear Ms. Glenn:
We have reviewed the Record of Decision for Celanese Fibers
Operations in Shelby, North carolina. '!his office =ncurs with the
selected remedy.
WIM/tb/ ibm-42
Sincerely,
J J · ~)1/yJ I t ( l.f_c-,,-, -:7' //--i=y.,vt.../
William L. Meyer, Chief
Solid Waste Management Section
State Health Director