NCD003446721_19911122_Celeanse Corporation - Shelby Fiber_FRBCERCLA SPD_Trial Burn Report correspondence-OCR

I
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
··James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. McKenzie Mallary
Remedial Project Manager .
22 November 1991
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
RE: Celanese Fibers Operations NPL Site
Shelby, Celveland County
Comments on the Trial Burn Report
Dear Mr. Mallary:
William L. M.eyer
Director
Attached are comments from the North Carolina Division of Environmental
Management on the Trail Bum Report for the above site. If you have any questions, please
contact me at [phone]. ·
CVJ /acr
Attachment
Sincerely,
Uvv'vlukc L~~
Charlotte V. Jesnea'
Superfund Section
An £.qua! Opoorrunity Affirrn.?.avt: :.,:'.Jon Employer
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Department of Environment, Health, and Natural Reso,,,.. es -c:;/
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Division of Environmental Management
512 i'-lorrh Salisbury Street • Raleigh, North Carolina 27604
James G. t'-.1.irtin, Governor
William W. Cobey, Jr., Secretary
George T Everen, Ph.D.
Director
Re;..'1unal Oihct,
A~hevillt
70-;,':.51-6}08
FJytm:villt
919/4fl6•1.'i41
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Raleigh
919:733-2314
WJ~hin;:.on
9!9.'941">-6451
\X'ilminpon
9)9.'395-390::J
\\'inHon-Salem
919/ii96-7007
October 10, 1991
M E M O R A N D U M
TO: Bill Meyer, Director
Division of Solid Waste Management
FROM: ~/eorge T. Everett 4-Ji°'--~
SUBJECT: Celanese Fibers NPL Site
Trial Burn Report
Cleveland County
Project #91-59
The Division of Environmental Management has completed
the review of the subject document and offers the following
comments and recommendations.
1. While the emission rates for benzene, carbon
disulfide, chloroform, and methylene chloride are
demonstrated to be greater than estimated on the
air permit application, the actual emissic-ns are
less than the exemption lev·els contained in 1 SA
NCAC 2H .0610.
2. Air Permit No. 6943 was issued on December 19,
1990. Acceptable Ambient Limits (ML's) for
benzene, chloroform, methylene chloride, .and
chromium VI were not effective until May 1, 1991.
Thus, the facility did not have a regulatory
obligation to comply with the AAL's contained in
.1100 (b) for those pollutants in Decembe,~ 1990.
The only applicable AAL at the time
of permit issuance was the AAL for carbon
disulfide. Projected (and now demonstrated)
emissions of carbon disulfide were below the
exe~ption level. Air Permit No. 6943 required
compliance with .. 0610(h) in Section A. Specific
Conditions and Limitations No. 1.
. ~ .. . · -, ... ____ ' . .
····-·· ,,·-··-· ·-·· ,. ·-· •
3. Total chromium was measured during testing, not
chromium VI. In the past, the APB has used the
factor of 1/279 of total chromium as an estimate
for chromium VI. This factor was submitted by
Duke Power Company in support of the Lincoln
Combustion Turbine Station. Duke referenced EPA
document EPA-450/2-89-001, Estimating Air Toxics
Emissions from Coal and Oil Combustion. While not
specifically applicable to the Hoechst Celanese
Test Burn, it appears to be the best referenc;e
available for determining chromium VI from total
chromium. The APB has previously provided the
Technical Support Branch this reference for its
use as a factor for determining potential chromium
VI emissions for other projects.
4. Based on the above information, the APB has
determined that no further permit ting action is
necessary or required the Hoechst Celanese air
permit No. 6943.
If there are any questions, please advise.
GTE/sbp/CELANESE.SWM
cc: Lee Daniel
Steve Tedder
Mooresville Regional Office
Central Files
Groundwater Files
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary 21 November 1991
MEMORANDUM
TO:
FROM:
RE:
Mike Kelly, Deputy Director
Division of Solid Waste Management
Lee Crosby, Chief
Superfund Section
Celanese Fibers Operations
Shelby, Cleveland County -r l"i a I 6u.Yh "Pi+
William L. Meyer
Director
The following information is provided in response to Bill Meyer's 12 November 1991
note to which I received on the 15th regarding the Celanese site in Shelby. Charlotte
J esneck has drafted an abbreviated sequence of events on the trial bum and the trial burn
data for Celanese. Attachments show the interaction between the Division of
Environmental Management (DEM), the Hazardous Waste Section and the US
Environmental Protection Agency (EPA). The DEM 10 October 1991 response, which
precipitated Bill Meyer's note, addresses the final trail burn data for Celanese. In the case
of Celanese, an air permit was actually issued and the Air Quality staff ensured compliance
with the permit. The full scale burn of the waste began on July 15. The incineration was
planned for six months at that time. The incineration of waste will continue through the end
of 1991.
Both Charlotte Jesneck and I have had numerous conversations with personnel in the
Air Quality Section, including their legal counsel, about permitting and substantive
requirements under the federal Superfund Act. However, we still receive comments
occasionally stating that a permit is required. Based on conversations, my understanding is
that Lee Daniels, the Air Quality Section Chief, and his Branch Heads know that
substantive permitting requirements must be met, but administrative requirements do not
have to be met. Also, the Air Quality Section has called us to give us comments verbally
on data before written comments were received because we requested their expertise on
evaluating the data. DEM Air Quality personnel have been very involved with both the
National Priorities List Aberdeen Fairway #6 site removal action and the Celanese site
remedial action.
LC/acr
Attachments
An Equal Opporrunity Affirmative Action Employer
MEMORANDUM
TO:
FROM:
RE:
19 November 1991
Lee Crosby, Chief
Superfund Section
Charlotte Jesneck, Branch Head
Inactive Sites Branch
Celanese Corporation
Shelby, Cleveland County
Update on Incineration
•
\
Celanese is incinerating glycol recovery unit sludges at the Shelby facility as part of
the NPL site remediation. The trial burn was conducted in accordance with RCRA even
though the material is not a RCRA hazardous waste. The main contaminant, ethylene
glycol, is not even a CERCLA hazardous substance. The following is a summary
incineration activities at the site. Several memoranda are attached for reference.
19 December 1990
30 April 1991
28 May 1991
5 June 1991
11-13 June 1991
10 July 1991
30 July 1991
31 July 1991
Air Quality permit is issued.
Run one of trial burn was conducted.
Results of first run are received.
Hazardous Waste Section and Superfund Section comments are
forwarded to EPA. The data is thrown out because of the
presence of the spike compound in the control blank.
The trial burn in reconducted. Three trial burn runs are
conducted -one per day. EPA's oversite contractor selects one
run to be sent to the lab for non-CLP analysis to expedite the
results. EPA audit samples are included. The data from the
other two runs will get full QA/QC.
The results of the June Run 2 are received. Copies are
forwarded to DEM and the Hazardous Waste Section.
DEM comments on the Run 2 data are received.
DEM comments are forwarded to EPA. Hazardous Waste
Section has no comments.
.:========--------•
1 September 1991
4 October 1991
10 October 1991
•
Final Trial Burn Report with full QA/QC is received. Copies
are forwarded to DEM and the Hazardous Waste Section on 16
September 1991 after receiving additional copies from EPA.
Hazardous Waste Section indicates no comments on the trial
burn.
DEM comments on remaining trial burn data are received.
DEM indicates no further permitting action is required.
• iOR'nrillOLINA
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DEPARTMENT OF HUMAJ RESOURCES
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_J · 0 K O Return For your intormnt1on eep
=i □ · 1 0 For your approval File For your s1gna ure
=1.Note and see me a.bout this, Please
=:J Prepnre a reply
0 Your signature. D My signature
/·D Send me a copy of reply
~our comment■
0 Taki'~harge of this , Please
~uach reque■ted information
CJ Initial and route to
HR 86 3/78
' I -,_ 1 1991 c:i h Carolina \~ OC 1 -c,:.:1
ealth, and Natural Reso'Cges j;}
:ntal Management '\/~-~ ,. . UH-£
leigh, North Carolina 27604 ·l{Et,CJ¥tu
Cea NOV li.v,;jeti99,1 D.
Director
smruND SECTION
::,ber 1 0, 1 9 91
ir
vaste Management
~~~
i Site
\Y/insmn·SJlem
9)9/896-7007 The Division of Environmental Management has completed
the review of the subject document and offers the following
comments and recommendations.
1. While the emission rates for benzene, carbon
disulfide, chloroform, and methylene chloride are
demonstrated to be greater than estimated on the
air permit application, the actual emissions are
less than the ex.,m~~' --1.s contained in 1 SA
, on December 1 9,
'imi ts ( AAL' s) for
\ne chloride, and
:until May 1, 1991.
have a regulatory
AAL's contained in
in December 1990.
:ime
AAL for carbon
~ow demonstrated)
were below the
'<'o. 69 4·3 required
,tion A. Specific
·-~----,-----·------·-·· ···--------
·-c·:·--==------------. --•=-~=-"=--====----=._c---~-=====cc:;~~ (Ii • ~t\lNth\
State of North Carolina v, oci 1 7 1991 ~j
Department of Environment, Health, and N°atural Resol_[5:es i':;°o/
. Division of Environmental Management ,~ :}ffe'---Y . . .~ . <'1:"-.
512 North Salisbury Street• Raleigh, North Carolina 27604 ·1 -PM±S,5· ,.
James G. Manin, Governor __ George T ·Everett, Ph.D.
· ·-·William W. Cobey, Jr., Secretary -t<t:Gl:.I V E'.Dor
Regional Office~
Asheville
704/251-6208
Fayetteville
9191486-1541
Moorcwille
704/663·1699
Raleigh
919:733-2314
\)?a~hington
919.~46-6481
\'(l;lmington
919/395-3900
\'('inston.Salem
9191896-7007
October 10, 1991 NOV 1 5 1991
SU~ERRIND SECTION
MEMORANDUM
TO: Bill Meyer, Director
Division of Solid Waste Management
FROM: '{tr George T. Everett 4.-J"'---~
SUBJECT: Celanese Fibers NPL Site
Trial Burn Report
Cleveland County
Project #91-59
The Division of Environmental Management has completed
the review of the subject document and offers-the following
comments and recommendations.
1. While the emission rates for benzene, carbon
disulfide, chloroform, and methylene chloride are
demonstrated to be greater than estimated on the
air p~rmit application, the actual emissions are
less than the exemption· levels contained in 1 SA
NCAC 2H _-061 0.
2. Air Permit No. 6943 was issued on December 19,
1990. Acceptable Ambient Limits (AAL's) for
benzene, chloroform, methylene chloride, and
chromium VI were not effective until May 1, 1991.
Thus, the facility did not have a regulatory
obligation to comply with the AAL' s contained in
.1100 (b) for those pollutants in December 1990.
The only applicable AAL at the time
of permit issuance was the AAL for carbon
disulfide. Projected (and now demonstrated)
emissions of carbon disulfide were below the
exemption level. Air Permit No. 6943 required
compliance with .0610(h) in Section A. Specific
Conditions and Limitations No. 1.
PO Ho\ 29535. R.,l<.'igh, North Carohn;i 27626-0535 "frlq1hone· 919-733-7015 I Pnllurion PrL·n•11111)n PJ\"'-
An EquJ! Opponunltv Al1inn,1tiv,· Auim1 Employt·r
• •
3. Total chromium was measured during testing, not
chromium VI. In the past, the APB has used the
factor of 1/279 of total chromium as an estimate
for chromium VI. This factor was submitted by
Duke Power Company in support of the Lincoln
Combustion Turbine Station. Duke referenced EPA
document EPA-450/2-89-001, Estimating Air Toxics
Emissions from Coal and Oil Combustion. While not
specifically applicable to the Hoechst Celanese
Tesf Burn, it appears to be the best reference
available for determining chromium VI from· total
chromium. The APB has previously provided the
Technical Support Branch this reference for its
use as a factor for determining potential chromium
VI emissions for other projects.
4. Based on the above information, the APB has
determined that no further permitting action
necessary or required the Hoechst Celanese
permit No. 6943.
If there are any questions, please advise.
GTE/sbp/CELANESE.SWM
cc: Lee Daniel
Steve Tedder
Mooresville Regional Office
Central Files
Groundwater Files
is
air
• •
MEMORANDUM
TO:
FROM:
RE:
3 June 1991
File·
Charlotte Jesneck, Branch Head
Inactive Sites Branch
Celanese Fibers Operations NPL Site
Shelby, Cleveland County
Post-Excavation Soil Sampling/Trial Burn Information
·on 7 March 1991, a meeting was held in Shelby to discuss several aspects of the
· · · remedial action plan for the above site. During this meeting, Celanese indicated they would
conduct any necessary post-remediation soil sampling the Siate may r:equire at the time of
delisting from the National Priorities List.
I telephoned Ken Mallary, the EPA Remedial Project Manager for the site, today to
discuss the issue of post remediation soil sampling. Since the Remeeial Irivestigation Report
indicates polynuclear aromatic hydrocarbons (P AHs) are present at various depths in the
soil column in the remediation zone, I feel follow-up sampling will need to be conducted
at some point to verify the residual post-remediation levels are low enough to protect public
health and the environment. As I discussed with Mr. Mallary, these PAHs compounds have
low mobility and may not be caught in the groundwater extraction system. In addition, their
depth of occurrence varies at the site.
We also discussed the pending trial burn. As of. today, the trial burn is scheduled for
10 June 1991 and will run 3 days. EPA's oversite consultant, Roy F. Weston, Inc., is
conducting split sampling during the mini and trial burns. The laboratory blank for the mini
burn data was contaminated with napthalene. Since naphthalene was the spike for
determining removal efficiency, the data could not be considered valid. Celanese may be
· using perchloroethylene during the trial burn to determine removal efficiency.
Mr. Mallary also mentioned that the mini-burn stack sample data indicated the
presence of elevated chromium and arsenic. Celanese plans to prepare a predicted
emissions model before conducting the trial burn. Mr. Mallary said that.he would send me
a copy of the model for review.
CVJ/acr
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• ·---------·--····----•
State of North Carolina
Department of Environment, Health, and Natural Resources
· Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
· James G. Martin, Governor
William W. Cobey, Jr., Secretary
'ID: Olarlotte Jesneck
SUperfund Section
Jillle.5, 1991
FRCM: Jill McCal::e -~
Hazardous Waste Section
REFERENCE: Hoechst Celanese -Shelby, NC
Mini-'lrial Burn Report
William L. Meyer
Director
We have completed our review of the Final Report on the mini-trial burn =nducted at
Hoechst Celanese in Shelby, North carolina. 'Ille trial burn was to demonstrate
compliance with RCRA incineration standards while burning CERCIA waste at the
Celanese site. 'Ihis Final Report clearly shows that the rotary kiln incinerator did
not pass the perforrrance standard of 99.99% destruction and removal efficiency.
'Iherefore, in a=rdance with RCRA incinerator regulations, the incinerator did not
pass this trial burn.
If Hoechst Celanese decides to =nduct another trial burn, we would strongly
recommend that a different FOHC is chosen. Naphthalene is a poor FOHC choice because
of its tendency to disassociate into other hazardous =nstituents, as is indicated by
the large =ncentrations of volatiles in the vosr results (Table 7).
The actual report itself has several serious omissions and errors. A trial burn
report should present in much more detail the nature of the incinerator and APC
equipment, the characteristics of the spiked waste stream, the precise sequence of
events throughout the trial burn, and the calculations used to arrive at the results
in the report. Several of the tables presented in the reporlhave either erroneous
or misleading infonnation =ncerning the data =llected at the trial burn (i.e.
Tables 2, 5, and 7). In addition, a few of the discussions on the stack emission and
process stream results (pages 5-6) have misinterpreted the test data and/or produced
in=rrect deductions from the test data results.
JPM/rrb/77
cc: William L. Meyer
Jerome H. Rhodes
William F. Hamner
Daniel L. Bius
An Equal Opportunity Affirmative Action Employer
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•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
.James G. Martin,. Governor
William W, Cobey, Jr., Secretary
FAX TRANSMITTAL RECORD
William L Meyer
Director
From: ____________ , Solid Wa.ste Management Division
, Solid Waste Section ------------
, Hazardous Waste Section ------------
( t c, r: /4i IJc Jc's /I c c,(t , Superfund Section
Date:
To:
Re:
7
1:5 (/ ( r'l { dn,rl1ft1fs
No. of Pages (Including Cover) 3-
Division of Solid Waste Management
Hazardous Wa.ste Section
Superfund Section
Solid Waste Section
Confirm receipt of document(s)
[phone]
[phone]
[phone]
[phone]
•===\;/~~(4~~).:'.~;;,=t\=·==
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State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
... William • W. Cobey, Jr., Secretary .
Mr. McKenzie Mallary
Remedial Project Manager
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
5 June 1991
RE: Celanese Fibers Operations NPL Site
Shelby, Celveland County
Comments on the Mini-Trial Burn Testing Report.
Dear Mr. Mallary:
William L. Meyer
Director
The North Carolina Division of Solid Waste Management has reviewed the above
report. Comments are attached. Please contact me_ at [phone] if you have any
questions.
Si,;c"ely, 1;
}!=!:;""~ Superfund Section
CVJ/acr
Attachment
• •
Division of Solid Waste Management
Superfund Section and,Hazardous Waste Section Comments
Celanese Fibers Operations NPL Site
Mini-Trial Burn Testing Report
1. Any compounds · used as spikes to determine removal efficiency must be
demonstrated to be more difficult than ethylene glycol to decompose by thermal
treatment.
2. Table 2: Ethylene glycol is not a POHC.
3. Page 5: Chromium volatilizes at 2900°F. Chromium is not likely to be found in the
gaseous form in the stack gas.
4. Page 6: The report states that since ethylene glycol was present at a concentration
of 3,200 ppm in the feed sample and was not detected in the ash sample, the
incinerator is effectively destroying hazardous compounds in the waste feed system.
This comparison at best only demonstrates that ethylene glycol has volatilized and
.is not left in the ash.
5. Table 5: Please clarify how 47% recovery was calculated for ethylene glycol based
on the values given in the table.
6. Table 7: The concentrations of volatile organic compounds detected (i.e. benzene
and toluene) raise questions about the combustion efficiency of the incinerator and
raise concerns about protection of human health.
7. A memorandum with additional Hazardous Waste Section comments is attached.
.. -~<j·;:~.~~~ ..
/,y'<;" r· 1 ., ,,. ~\
!~ ~\1/fr)j) 1<\ifij __ ;~/41
. "\,.',:·.~--~~~.:::>·
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management ·
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William· W. Cobey, Jr., Secretary
'ID: Charlotte Jesneck
SUperfund Section
June 5, 1991
· FRCM: Jill McCal:e ff''
Hazardous Waste Sectio~
REFERENCE: Hoechst Celanese -Shelby, NC
Mini-Trial Burn Report
William L. Meyer
Director·
We have completed our review of the Final Report on the mini-trial burn conducted at
Hoechst Celanese in Shelby, North carolina. The trial burn was to demonstrate
compliance with RCRA incineration standards while burning CERCI.A waste at the
Celanese site. 'Ihis Final Report clearly shws that the rotary kiln incinerator did
not pass the perfoD1BI1ce standard of 99.99% destruction and removal efficiency.
'Iherefore, in a=rdance with RCRA incinerator regulations, the incinerator did not
pass this trial !::urn.
If Hoechst Celanese-decides to conduct another trial burn, we would strongly
recommend that a different POHC is chosen. Naphthalene is a poor POHC choice because
of its tendency to disass=iate into other hazardous constituents, as is indicated by
the large concentrations of volatiles in the vosr results {Table 7).
'Ihe actual report itself has several serious omissions and errors. A trial burn
report should present in much ITDre detail the nature of the incinerator and APC
equipment, the characteristics of the spiked waste stream, the precise sequence of
events throughout the trial b.rrn, and the calculations used to arrive at the results
in the report. Several ,of the tables presented in the report have either erroneous
or misleading infomation concerning the data collected at the trial burn (i.e.
-Tables 2, 5, and 7). In addition, a few of the discussions on the stack emission and
process stream results {pages 5-6) have misinterpreted the test data and/or produced
in=rrect deductions from the test data results.
JPH/rrb In
co: William L. Meyer
Jerome H. Rhodes
William F. Hamner
Daniel L. Bius
An Equal Opportunity Atllnnat!ve AcHon Employer
. -<.• 51,._T( ,;·...,,
/'"' ,-:' '.:$i:j . .,,, ru,\r~<""' 0y· ~J ! 1·· "'
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•
State of North Carolina
Department of Environment, Health, and Natural Resources .
Division of SoLid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James. G. Marlin, Governor
William W. Cobey, Jr., Secretary
William L. Meyer
Direclor
FAX TRANSMITTAL RECORD
From: ____________ , Solid Waste Management Division
, Solid Waste Section
Date:
To:
Re:
------------
, Hazardous Waste Section ------------
lhur /o/lc Jo..s11cclr , Superfund Section
. r: /6) 9/
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__ C~e~l~C/_M~C_S=e~, _ ___Lf½_,.__,___,_/_,...n__,_,'____,.,h~· l.LL._,t l'1 CCI Wf ~ 'I' v1 /5 !
(Y',. e m_o o f /c, I e; ,.{ d 11c.
Co i/f r:5 C{ tr:o (I
No. of Pages (Including Cover)
/
Division of Solid Waste Management
Hazardous Waste Section
Confirm receipt of document(s)
[phone]
[phone]
Superf1md Section [phone]
· Solid Waste Section [phone]
•
" State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Marlin, Governor
William W. Cobey, Jr., _Secretary
MEMORANDUM
TO:
FROM:
10 July 1991
Lee Daniel, Chief
Air Quality Section
Lee Crosby, Chief D V
Superfund Section f7
URGENT
William L. · Meyer
Director
RE: Request for Immediate Review of Celanese Corporation NPL Site
Trial Burn Data
111e US Environmental Protection Agency notified us today of plans to give Celanese
Corporation the go ahead to proceed with incineration of ethylene glycol contaminated soils
at their National Priorities List site in Shelby, Cleveland County. Celanese anticipates
commencing the burn at the end of this week.
We have just today received the remainder of the trial burn test data. A copy of the
data is attached for your review. Due to the plans for commencing the burn at the end of
this week, we would appreciate your immediate attention to this matter. We are also
sending Keith Overcash in the Mooresville Regional office a copy of the data. Charlotte
Jesneck with our office has already spoken with Richard Lassiter in your office and also with
Keith Overcash. If you wish to relay in comments verhally and then follow up in writing,
please contact Charlotte Jesneck or me at 733-2801. We greatly appreciate your assistance
in this matter.
LC/acr
Enclosure
MEMORANDUM
TO:
FROM:
RE:
10 July 1991
File
Charlotte Jesneck, Branch Head
Inactive Sites Branch
Celanese Corporation NPL Site
Shelby, Cleveland County
Today I sent copies of the trial burn data for the Celanese NPL site to Jill McCabe
with the Hazardous Waste Section, Keith Overcash with the Mooresville Regional office Air
Quality Section and Lee Daniels, Chief of the Air Quality Section.
O/acr
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•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
. William W. Cobey, Jr., Secretary
Mr. McKenzie Mallary
Remedial Project Manager
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
31 July 1991
RE: Celanese Fibers Operations NPL Site
Shelby, Celveland County
Additional Comments on the Mini-Trial Burn Testing Report
Dear Mr. Mallary:
William L. Meyer
Director
Attached are comments from the North Carolina Division of Environmental
Management Air Quality Section regarding the above document. Please contact me at (919)
733-2801 if you have any questions.
CVJ/acr
Attachment
Sincerely,
. I I, ~ /), ,
u-\.,t,A.i//-f..'1/,} . .:, f /«·•~'--ck-
Charlotte V. J esneck
Superfund Section
• ·fttGtlVED
JUL :io 1991
State of North Carolina
Department of Environment, Health, and Natural SUPERfllND SECTION
Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor Air Quality Section
July 26, 1991
George T. Everett, Ph.D.
.. William W. Cobey, Jr., Secretary _
MEl·IORANDln~
To:
Through:
From:
Subject,
Lee Crosby
Lee Daniel
Earl McCune
Hoechst Celanese
Shelby, Cleveland County, North Carolina
Preliminary Review of 1-lini Burn Testing
Performed on June 13, 1991 by
Industrial and Environmental Analysts, Inc.
Director
A report of Test 2 in a series of three tests has been submitted to this
division ,for ·review. The report provides a summary of the sampling and
analytical data from the test conducted on June 13·, 1991. More complete process
information will be submitted with the report covering the entire series of
tests.
The testing in this portion of the trial burn include EPA Method 5 for
particulates and hydrogen chloride, Modified Method 5 for semivolatile organics,
EPA multimetals train for metals, and a volatile organic sampling train (VOST)
for principle organic hazardous constituents (POHC) and products of incomplete
combustion (PIC).
The particulate emission standard that applies to the subject facility is-15A
NCAC 2D .0505, CONTROL OF PARTICULATES FROM INCINERATORS. The maximum charge
rate stated in Permit No. 6943 is 5000 pounds per hour, for which the
particulate emission limit is 4.0 pound per hour. The particulate emission rate
demonstrated by the test results was 0.225 pound per hour.
Asheville
704f.l51-6208
Fayeneville
919/486-1541
Mooresville:
704/663-1699
Regional Offices
Raleigh
919/733-2314
Washington
9191946-6481
Pollution Prevention Pays
Wilmington
919/395-3900
P.O. Box 29535, Raleigh, North Carc!ina 27616-0535 Telephone [phone]
An Equal Opix>mmity Affirmative ktion Employer
\\'1i11$Con-Salem
919/761-2351
Lee Crosby
July 12, 1991
Page 2
• •
The toxic pollutant .emission rates were compared to the de minimus threshold·
limits set in 15A NCAC 2H .0610, PERMIT REQUIREMENTS FOR AIR TOXIC POLLUTANTS.
The report presented the emission rates in pounds per hour. Since no actual
operating data was given, the operating time used to calculate emission rate in
pounds per day and pounds per year was assumed to be 8 hours per day and 365
days per year. No pollutant emission rate exceeded the de minimus values.
Hexavalent chromium was estimated to be 1/279 of the total chromium emissions.
This factor was submitted by Duke Power Company in support of the Lincoln
Combustion Turbine Station. Duke referenced EPA document EPA-450/2-89-001,
Estimating Air Toxics Emissions from Coal and Oil Combustion.
The emission· rates were compared 1·1i th the anticipated emission rates calculated
in the permit application. The emission rates of the following compounds were
greater than expected; benzene, carbon disulfide, chloroform, a~d methylene
chloride.
cc: Harlan Britt
• . <?.:'.~'.{~.-·:c····· ·-.. , ... _,._.
/~' r.· .1 -,_ "'i\ " lt·r ····"' n< ;~ .',·( ):;Jr ~l \-,}D <t:1,;Jl {, .,. -%1/ :.:·~,"'.::~ .,._•:: .. -
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
.. .William .W. Cobey, Jr., Secretary
MEMORANDUM
TO:
FROM:
RE:
16 September 1991
Jerry Rhodes, Chief
Hazardous Waste Section
Lee Crosby, Chief / C...,..,
Superfund Section/'
Celanese Fibers NPL Site
Shelby, Cleveland County
Request for Review of Trial Burn Report
William L. Meyer
Director
Attached is a copy of the Trial Burn Report for the Hoechst Celanese Corporation
site in Shelby. This report contains the remainder of the data for the three test burns
conducted. Please return all comments to our office so that we may submit one package
to the US EPA. Incineration of wastes has commenced at the site based on the results of
the first trial burn run. Since incineration has already begun, we would appreciate your
review as soon as is possible. Thank you for your assistance.
LC/acr
Attachments
. ..--:~~~~~~.~~, ~i ... r..~>; r:· ' ,_ ~\
t.~ _;i.;t,'lf/j~\
l~ /ri M§i '\'.t"<-_;~ . 'i' / ~.~ .. /
•
State of North Carolina ,
Department of Environment, Health, and Natural Resour:ces
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-76S7
James G. Martin, Governor .
· William W .. ·eobey, Jr., Secretary
MEMORANDUM
TO:
FROM:
RE:
16 September 1991
Perry Nelson, Chief
Groundwater Section
Lee Crosby, Chief # V
Superfund Section /'
Celanese Fibers NPL Site
Shelby, Cleveland County
Request for Review of Trial Burn Report
William L. Meyer
Director
Attached are two copies of the Trial Burn Report for the Hoechst Celanese
Corporation site in Shelby. This report contains the remainder of the data for the three test
burns conducted. Please forward one copy to Lee Daniels of the Air Quality Section and
one copy to the Mooresville Regional Office Air Quality Section Chief for review. Please
return all comments to our office so that we may submit one package to the US EPA.
Incineration of wastes has commenced at the site based on the results of the fi~st trial burn
run. Since incineration has already begun, we would appreciate your review as soon as is
possible. Thank you for your assistance.
LC/acr
Attachments
•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary -October 4, 1991
KEMORAND1JH
TO:
FROM:
Lee Crosby, Chief
Superfund Section
Jerome H.
Hazardous
Rhodes, Chief
Waste Section
!ti f.
William L. Meyer
Director
REFERENCE: Hoechst-Celanese Corporation -Shelby, North Carolina
Trial Burn Report
We have completed our review of .the report on the trii,l _burn.=-,~---.-,---
~onducted at the Hoechst-Celanese Corporation in Shelby, North
Carolina during the week of June 10, 1991. The trial burn,was to
_ ;.: __ demoni.-t.r ate~omp--1 i ant,E:_-_: 19-J;;Ji: ... .RC1¥4~ncin7_ra:t.j,,.<i'n . sj:and~?_Yh:ci_Je ~ur:nci'.19.:;___.,,,.---
CERCLA -Y"'-.§te at the Celane~~.:;i:t_e. _Tfiis Trial Burn ~eport: indica t"es _ _ -----that-the -incinerator has-passec.:a11::·the performance.c stal]_dcw.ds ... ,---· ------_, -" ....,.
required by-·'RCRA. --_.-~---, ____ ·. ----c'o-· ·_-:-· ___ ---::--· --___ _ _,~_;.:;::.;;:;:::~-:---....:'. _ -• -
.. _:,:...~::-,_ ... :::=-~·:, -_ ~--=-::~:~ If you have any questions, please contact Jill McCabe of my staff.
JHR/JBM/mb/113
cc: William L. Meyer
William F. Hamner
Daniel L. Bius
Jill B. McCabe
An Equal Opporrunity Affirmative Action Employer
MEMORANDUM
TO:
FROM:
RE:
=====-=-··=-=---=======
19 November 1991
File
Charlotte Jesneck, Branch Head
Inactive Sites Branch
Celanese Corporation
Shelby, Cleveland County
Incineration/Fixation
•
I telephoned Ken Mallary with US EPA Region rv (404/347-7791) today to get an
update on the ongoing site remediation. Mr. Mallary said Celanese will likely complete the
incineration in late December. As they excavate the waste, they have discovered the extent
of contamination is more extensive. Approximately 4,000 cubic yards have been excavated
to date for incineration.
Fixation of the ash is planned for the end of this month through January 1992. Mr.
Mallary said he will be receiving a work plan for the fixation and he will forward a copy to
us.
CJ/acr
•
Westinghouse Environmental
and Geotechnical Servioos, Inc.
October 10, 1991
• •
Suite 700
3980 DeKalb Technology Parkway, N.E
Atlanta, Georgia 30340
[phone]
Fax [phone]
-/ri::l·1..
Mr. McKenzie Mallary Oc-,.1.•".lflp:D u. s. EPA / t.;.A
345 Courtland Street, NE S, 1 ;9 Atlanta, Georgia 30365 'lJP[RF!J. '9/
Subject: Solidification of Burn Pit Material Wos[Cho"'
Hoechst Celanese, Shelby, North Carolina
Westinghouse Project ALW-T-002
Document Control Number T002-0340
Dear Mr. Mallary:
This letter is in response to the questions that you raised
during our phone conversation yesterday regarding our October 8th
letter on this subject (Westinghouse document number T002-0338).
There is no known reason why the burn pit material used in the
Chem-Bond tests had no detectable concentrations of ethylene
glycol. Every possible attempt was made to have all of the
material be as consistent and homogeneous as possible. As
outlined in the previous letter, all of the material used in the
solidification tests was from the same area of the burn pit
stockpile. This area was identified from the preliminary
sampling as having the highest concentration of ethylene glycol.
Two batches (approximately 4 cubic yard each) of the material
were removed from the stockpile. Both batches were processed
(individually) through the power screen and shredder. They were
then divided into smaller piles for the tests.
The preliminary sample of burn pit material that was identified
as having the highest concentration of ethylene glycol was SH-SO-
03-12. The initial verbal results of the total ethylene glycol
analysis from the on-site lab was 15 mg/kg at field conditions.
The decision to use this location to obtain the 4 cubic yards
needed for the testing was made based on this verbal result. The
final analytical result after QA/QC procedures for SH-SO-03-12
was <10 mg/kg. Two additional samples, SH-SO-03-12A and SH-SO-
03-12B, were taken from the same location. These samples were
tested at elevated pH levels over several days for total ethylene
glycol. This results of these tests indicate ethylene glycol
concentrations ranging from <10 mg/kg to 544 mg/kg. The attached
table lists all of the analytical results for these samples.
These and the other results of the field testing are consistent
with the earlier bench scale studies (one for Portland cement,
A Westinghouse Electric Corporation subsidiary.
~olidificationl
October 10, 1991
Document Control
Page 2
Burn Pit Material •
Number T002-0340
and one for Chem-Bond). In both bench scale studies, the
ethylene glycol concentrations in the unsolidified burn pit
material were below detection limits. The concentrations
increased in both studies with increased pH. In the cement bench
scale study, the ethylene glycol concentration, as measured by
the modified TCLP extraction method, was 110 mg/1. The complete
bench scale test results were documented in Westinghouse document
numbers 85050N-0292 (March 1991), and 85050N-0311 (April 1991).
Selected field test samples have already been sent to IEA for
full regulatory TCLP analysis. The samples tested in both bench
scale studies passed the TCLP regulatory limits very easily.
As we discussed yesterday, the reason solidification was chosen
for the burn pit material was to control the metals and low level
organics from leaching out of the material. This goal is
accomplished with Portland cement. Since ethylene glycol was not
identified by the initial sampling, an arbitrarily low acceptance
limit of 10 ppm was initially chosen for the leachate. In
retrospect, this seems unduly restrictive since the remediation
is not a clean closure and since the inner tier extractions
system is proximate to where the solidified material will be
placed.
The purpose of the field testing done last month was not to
compare Portland cement to Chem-Bond, but rather to take a more
thorough look at what levels of ethylene glycol could be expected
to leach out of each, and to re-examine what would be a suitable
acceptance criteria. Westinghouse and Hoechst Celanese feel that
a ethylene glycol leach limit of 300 ppm is conservative and
protective considering how the TCLP acceptance criteria were
developed. We believe this limit could be achieved with Portland
cement. Furthermore, the use of Portland cement is specified in
the approved Project Operation Plan, and its use would have a
positive impact on the schedule and cost of the project.
We hope that we answered your questions fully. If you have any
other questions regarding this proposal, please call us.
?!;!,#-
Project Manager
cc: Steve Olp, HCC/Shelby
John McBride, HCC/Shelby
Terry Elnaggar, GDC
~~W. ~-r.qL
Everett w. Glover, Jr., P.E.
Project Director
·-Solidification tr
October 10, 1991
Document Control
Page 3
Burn Pit Material •
Number T002-0340
ANALYTICAL RESULTS FOR SAMPLE SB-SO-03-12A
Date Total EG
Analyzed pH (mg/kg)
Sample SB-SO-03-12A
9/17 12 40.1
9/18 12 25.0
9/19 12 35.7
9/23 12 14.2
9/24 12 24.4
9/17 12.8 42.8
9/18 12.8 65.3
9/19 12.8 270
9/23 12.8 163
9/24 12.8 544
sample SB-SO-03-12B
9/17 12 <10
9/18 12 <10
9/19 12 <10
9/23 12 <10
9/24 12 <10
9/17 12.8 <10
9/18 12.8 31.5
9/19 12.8 62.6
9/23 12.8 66.8
9/24 12.8 121
WestinghouSe Enviromle!ll3t
and Gemctlnical Services. Inc.
• ••
Su1:.e 700
)980 Oel<aJo recnno1oqy Parl!Way, N.E.
;.:~ma. Georo,a 30340
,,041458-9309
fax 140.Sl 458.!3438
FAX TRANSMISSION TO FOLLOW
-Ce/ahese
Date:
To:
From:
Number of Pages to Follow: --.:'3==-------
Comments/Special Instructions:
> Wesnn.,nousa EJec'Jic Corporauon suOSJo,ary.
~lN~ll~ 3SnOH9N!1S3M WOd~
•
Westinghouse Environmental
and Geotechnical Servires, Inc.
October 8, 1991
Mr. McKenzie Mallary
U.S. EPA
345 Courtland street, NE
Atlanta, Georgia 30365
• 8 "l'<-c
fJc; ,l:lvk_h Sa ./ . f..-1_,; ~f.ff) ' 199 .
Suite 700 iJ4'/) .!'r.-,,_ 1/
3980 DeKalb Technology'~a,'llt'f)J,E.
Atlanta, Georgia 30340 l(/1//
[phone]
Fax [phone]
Subject: Solidification of Burn Pit Material
Hoechst Celanese, Shelby, North Carolina
Westinghouse Project ALW-T-002
Document Control Number T002-0338
Dear Mr. Mallary:
Field testing of solidification process and agents was conducted
at the Hoechst Celanese site in Shelby, N.C. during the weeks of
September 9th and 16th. The purpose of this testing was to
evaluate the effectiveness of Portland cement and Hazco's
Chem-Bond as solidification agents for the burn pit material in
field conditions and processes.
The existing burn pit stockpile was sampled at 18 different
locations, and two samples of unexcavated material were taken
from the exclusion zone. These samples were analyzed for total
ethylene glycol at field pH and an elevated pH.
Approximately four cubic yards of material was taken from the
location that showed the highest concentration of total ethylene
glycol. This material was then divided into eight batches. Four
of these batches were solidified with Portland cement in
percentages of 10.3%, 12.4%, 20.4%, and 25.3%. The remaining
four were solidified with Chem-Bond in percentages of 9.7%,
14.5%, 17.8%, and 27.7%. A detailed description of the test
procedures is attached.
For each of the eight solidified batches, samples of the
unsolidified burn pit material were tested for total ethylene
glycol at field and elevated pH. Samples of the solidified
material were tested for ethylene glycol at field pH by total
ethylene glycol, and the modified TCLP test. Selected solidified
samples have been sent to IEA for full regulatory TCLP analysis.
The results of the ethylene glycol analyses are in the attached
table. These tests show that the samples solidified with
Portland cement leached less than 100 ppm of ethylene glycol.
The proposed North Carolina drinking water standard for ethylene
glycol is 7 ppm. Based on the Toxicity Rule, the EPA guideline
A Westinghouse Electric Corporation subsidiary.
Solidification' Burn Pit Material •
October 8, 1991
Document Control Number T002-0338
Page 2
for groundwater in this type of exposure pathway would be 700
ppm. Westinghouse and Hoechst Celanese therefore propose that
burn pit material be solidified with 10% Portland cement, with an
allowable leach of 300 ppm as measured by the modified TCLP test
method using distilled water for the extraction. This proposed
concentration is less than half of what the EPA guidelines would
require.
This proposal is consistent with the approved Project Operation
Plan, which called for solidification with cement. In addition,
the Shelby source remediation (Operable Unit 2) is not intended
to achieve a clean closure. Operable Unit 1 will continue to
treat the groundwater that is affected by the source area. It is
intended that Operable Unit 1 will continue to operate until the
groundwater has been restored to a level of quality consistent
with all applicable standards and regulations.
If you have any questions regarding this proposal, please call
us. Your prompt response will be greatly appreciated.
j~jj~
Glenn Boylan
Project Manager
cc: Steve Olp, HCC/Shelby
John McBride, HCC/Shelby
Terry Elnaggar, GDC
~uwJ;f(J), ~()_
Everett w. Glover, Jr., P.E.
Project Director
• • SOLIDIFICATION TEST PROCEDURES
On September 12, 1991, sampling of burn pit materials for
solidification verification was undertaken. Two grab samples of
burn pit material were taken from unexcavated areas within the
exclusion zone (SH-S0-03-03 and SH-S0-03-04). Grab samples of
burn pit material, SH-S0-03-05 through SH-S0-03-22, were taken
from various locations on the existing burn pit stockpile. Each
location was marked with a stake, flagged, and numbered. Each
sample was taken from 1 foot to 1 1/2 feet below the surface of
the pile. Samples SH-S0-03-03 and SH-S0-03-04 were taken at
approximately 1 1/2 feet and 3 feet respectively, below the
surface elevation. All samples were placed into clean glass
containers, sealed, and labeled.
Each of the 20 samples were analyzed for Total Ethylene Glycol at
both field pH and at an elevated pH {pH 12). It was determined
from these tests that burn pit from the north-northeast portion
of the stockpile, near sample point SH-S0-03-12, contained the
highest level of ethylene glycol.
An approximately four cubic yard sample of burn pit material near
sample point SH-S0-03-12 was collected and processed through the
closed-loop screening/shredding system. Material output through
this system was sized under 1/2" to 3/4". This burn pit material
was then separated into four equal 1-yard piles and placed on a
plastic liner. As the four piles (12C, 12A, 12E, 12F) were being
divided, approximately 40-50 scoops of the material were place
into four separate mixing bowls. After sufficient mixing of each
bowl, four composite samples were collected from each bowl.
These burn pit blank samples, collected utilizing one clean spoon
per mixing bowl, were placed into clean glass containers, sealed
and labeled. Each of these 16 samples (12C-l, 12C-2, 12C-3, 12C-
4, 12D-l, 12D-2, etc.) were analyzed for Total Ethylene Glycol at
both field pH and at an elevated pH {pH 12).
Each of the 1-yard piles were then mixed through the augers with
various quantities of Portland cement. Four composite samples
were obtained from each mixture, placed into clean glass
containers sealed and labeled. Each of these 16 samples (12C-5,
12C-6, 12C-7, 12C-8, 12D-5, 12D-6, etc.) were to be analyzed for
Total Ethylene Glycol (at field pH) and Leach Ethylene Glycol (by
Modified TCLP). The following chart shows the percent mixtures
of Portland Cement to burn pit materials.
Pile % cement
12C 20.4%
12C 10.3%
12E 25.3%
12F 12. 4%
Page 1
• • SOLIDIFICATION TEST PROCEDURES
Each of these percentages were calculated by Terry Elnagger (GDC)
by varying the cement flow rate (determining the rate prior to
solidification) and weighing the solidified materials as it exits
the auger system.
The following samples were sent to IEA on September 30, 1991 to
be analyzed for full regulatory TCLP: 12C-8, 12D-6, 12E-6, 12F-6.
Although field compacted solidified materials have been checked
with a pocket penotrometer (gauge reads maximum level), specific
percentage of cement with burn pit materials were not tested for
compressive strength during this trial plan.
These same procedures were repeated in order to analyzed
solidified burn pit materials with various percentages of
Chem-Bond. Sample numbering remained consistent with the system
used for the cement samples.
All analyses done by the IEA mobile lab were consistent with
earlier testing. The following chart shows the percent mixtures
of Chem-Bond to burn pit materials:
Pile
12G
12H
12I
12J
% Chem-Bond
9.7%
14.5%
17.8%
27.7%
The following samples were sent to IEA on September 30, 1991 to
be analyzed for full regulatory TCLP: 12G-7, 12H-8, 12I-7, 12J-7.
In addition to the above testing of both blank burn pit materials
and solidified burn pit materials, two blank burn pit materials
were obtained (12A and 12B) from the location (point 12) where
all future sampling was to take place. These samples were
analyzed for over a week for Total Ethylene Glycol at an elevated
pH of both 12 and 12.8. A Total Ethylene Glycol (at field pH)
was also obtained on the first day of testing.
Page 2
SAMPLE
SH-S0-03-12C-l
SH-S0-03-12C-l
SH-S0-03-12C-2
SH-S0-03-12C-2
SH-S0-03-12C-6
SH-S0-03-12C-7
SH-S0-03-12C-8
SH-S0-03-12C-6
SH-S0-03-12C-7
SH-S0-03-12C-8
SH-S0-03-120-1
SH-S0-03-120-1
SH-S0-03-120-2
SH-S0-03-120-2
SAMPLE
DATE
9/18
9/18
9/18
9/18
9/19
9/19
9/19
9/19
9/19
9/19
9/18
9/18
9/18
9/18
SOLIDIFCATION TEST RESULTS
DESCRIPTION
Composite-Test Pile C
Composite-Test Pile C
Composite-Test Pile C
Composite-Test Pile C
Composite-Mixed Pile C
Composite-Mixed Pile C
Composite-Mixed Pile C
Composite-Mixed Pile C
Composite-Mixed Pile C
Composite-Mixed Pile C
Composite-Test Pile D
Composite-Test Pile D
Composite-Test Pile D
Composite-Test Pile D
% AGENT
20.4% PC
20.4% PC
20.4% PC
20.4% PC
20.4% PC
20.4% PC
ANALYSIS
Total
Total
Total
Total
Total
Total
Total
Leach
Leach
Leach
Total
Total
Total
Total
ANALYSIS
pH DATE
F
12
F
12
F
F
F
12
12
12
F
12
F
12
9/24
9/26
9/27
9/27
9/23
9/23
9/23
9/24
9/24
9/24
9/26
9/26
9/27
9/27
RESULTS
(mg/kg)
38.9
53.8
84.5
95.6
46.7
22.7
42.6
49.5
39.4
60.3
41. 3
115
59.2
49.5 ------------------------------------------------------------------------------------------------
SH-S0-03-120-6
SH-S0-03-120-7
SH-S0-03-120-8
SH-S0-03-120-6
SH-S0-03-120-7
SH-S0-03-120-8
9/19
9/19
9/19
9/19
9/19
9/19
Composite-Mixed Pile D
Composite-Mixed Pile D
Composite-Mixed Pile D
Composite-Mixed Pile D
Composite-Mixed Pile D
Composite-Mixed Pile D
10. 3% PC
10. 3% PC
10.3% PC
10.3% PC
10.3% PC
10.3% PC
Page 1
Total
Total
Total
Leach
Leach
Leach
F
F
F
12
12
12
9/24
9/24
9/24
9/25
9/25
9/25
178
97.1
154
79.2
99.2
72.8
•
•
SAMPLE
SAMPLE
DATE
SOLIDIFCATION TEST RESULTS
ANALYSIS RESULTS
DESCRIPTION % AGENT ANALYSIS pH DATE (mg/kg) ------------------------------------------------------------------------------------------------
SH-S0-03-12E-l 9/18 Composite-Test Pile E Total F 9/24 60.2
SH-S0-03-12E-l 9/18 Composite-Test Pile E Total 12 9/26 72.0
SH-S0-03-12E-2 9/18 Composite-Test Pile E Total F 9/27 12. 0
SH-S0-03-12E-2 9/18 Composite-Test Pile E Total 12 9/27 237 ------------------------------------------------------------------------------------------------SH-S0-03-12E-6
SH-S0-03-12E-7
SH-S0-03-12E-8
9/19
9/19
9/19
Composite-Mixed Pile E
Composite-Mixed Pile E
Composite-Mixed Pile E
25. 3% PC
2 5. 3% PC
25.3% PC
Total
Total
Total
F
F
F
9/23
9/23
9/23
173
58.9
45.2 ------------------------------------------------------------------------------------------------
SH-S0-03-12E-6
SH-S0-03-12E-7
SH-S0-03-12E-8
9/19
9/19
9/19
Composite-Mixed Pile E
Composite-Mixed Pile E
Composite-Mixed Pile E
25.3% PC
25. 3% PC
25.3% PC
Leach
Leach
Leach
12
12
12
9/24
9/24
9/24
78.2
65.2
59.0 ------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
SH-S0-03-12F-l 9/18 Composite-Test Pile F Total F 9/24 116
SH-S0-03-12F-l 9/18 Composite-Test Pile F Total 12 9/24 44.7
SH-S0-03-12F-2 9/18 Composite-Test Pile F Total F 9/27 68.2
SH-S0-03-12F-2 9/18 Composite-Test Pile F Total 12 9/27 237 ------------------------------------------------------------------------------------------------
SH-S0-03-12F-5 9/18 Composite-Mixed Pile F 12.4% PC Total F 9/19 203
SH-S0-03-12F-6 9/18 Composite-Mixed Pile F 12.4% PC Total F 9/19 182
SH-S0-03-12F-7 9/18 Composite-Mixed Pile F 12.4% PC Total F 9/19 184
SH-S0-03-12F-8 9/18 Composite-Mixed Pile F 12.4% PC Total F 9/19 89.6 ------------------------------------------------------------------------------------------------
SH-S0-03-12F-5 9/18 Composite-Mixed Pile F 12.4% PC Leach 12 9/23 23.0
SH-S0-03-12F-6 9/18 Composite-Mixed Pile F 12.4% PC Leach 12 9/23 40.2
SH-S0-03-12F-7 9/18 Composite-Mixed Pile F 12.4% PC Leach 12 9/23 39.3
SH-S0-03-12F-8 9/18 Composite-Mixed Pile F 12.4% PC Leach 12 9/23 25.0 ------------------------------------------------------------------------------------------------
Page 2
•
•
SAMPLE
SH-S0-03-12G-l
SH-S0-03-12G-l
SH-S0-03-12G-2
SH-S0-03-12G-2
SH-S0-03-12G-6
SH-S0-03-12G-7
SH-S0-03-12G-8
SH-S0-03-12G-6
SH-S0-03-12G-7
SH-S0-03-12G-8
SH-S0-03-12H-1
SH-S0-03-12H-1
SH-S0-03-12H-2
SH-S0-03-12H-2
SAMPLE
DATE
9/20
9/20
9/20
9/20
9/20
9/20
9/20
9/20
9/20
9/20
9/20
9/20
9/20
9/20
SOLIDIFCATION TEST RESULTS
DESCRIPTION
Composite-Test Pile G
Composite-Test Pile G
Composite-Test Pile G
Composite-Test Pile G
Composite-Mixed Pile G
Composite-Mixed Pile G
Composite-Mixed Pile G
Composite-Mixed Pile G
Composite-Mixed Pile G
Composite-Mixed Pile G
Composite-Test Pile H
Composite-Test Pile H
Composite-Test Pile H
Composite-Test Pile H
% AGENT
9.7% CB
9.7% CB
9.7% CB
9.7% CB
9.7% CB
9.7% CB
ANALYSIS
Total
Total
Total
Total
Total
Total
Total
Leach
Leach
Leach
Total
Total
Total
Total
ANALYSIS RESULTS
pH DATE (mg/kg)
F
12
F
12
F
F
F
9.7
9.8
9.9
F
12
F
12
9/26
9/26
9/27
9/27
9/24
9/24
9/24
9/25
9/25
9/25
9/26
9/26
9/27
9/27
<10
47.8
<10
<10
17.9
15.2
13.7
<10
<10
<10
<10
<10
<10
<10
------------------------------------------------------------------------------------------------
SH-S0-03-12H-6
SH-S0-03-12H-7
SH-S0-03-12H-8
SH-S0-03-12H-6
SH-SO-OJ-12H-7
SH-S0-03-12H-8
9/20
9/20
9/20
9/20
9/20
9/20
Composite-Mixed Pile H
Composite-Mixed Pile H
Composite-Mixed Pile H
Composite-Mixed Pile H
Composite-Mixed Pile H
Composite-Mixed Pile H
14.5% CB Total
14.5% CB Total
14.5% CB Total
14. 5% CB· Leach
14.5% CB Leach
14.5% CB Leach
Page 3
F
F
F
9.0
9.0
9.0
9/25
9/25
9/25
9/25
9/25
9/25
<10
<10
<10
<10
<10
<10
•
•
SAMPLE
SAMPLE
DATE
SOLIDIFCATION TEST RESULTS
ANALYSIS RESULTS
DESCRIPTION % AGENT ANALYSIS pH DATE (mg/kg) ------------------------------------------------------------------------------------------------SH-S0-03-121-1 9/20 Composite-Test Pile I Total F 9/26 <10
SH-S0-03-121-1 9/20 Composite-Test Pile I Total 12 9/26 <10
SH-S0-03-121-2 9/20 Composite-Test Pile I Total F 9/27 <10
SH-S0-03-121-2 9/20 Composite-Test Pile I Total 12 9/27 <10 ------------------------------------------------------------------------------------------------
SH-S0-03-121-6 9/20 Composite-Mixed Pile I 17.8% CB Total F 9/25 <10
SH-S0-03-121-7 9/20 Composite-Mixed Pile I 17.8% CB Total F 9/25 <10
SH-S0-03-121-8 9/20 Composite-Mixed Pile I 17.8% CB Total F 9/25 <10 ------------------------------------------------------------------------------------------------
SH-S0-03-121-6
SH-S0-03-121-7
SH-S0-03-121-8
9/20
9/20
9/20
Composite-Mixed Pile I
Composite-Mixed Pile I
Composite-Mixed Pile I
17.8% CB
17.8% CB
17.8% CB
Leach
Leach
Leach
8.9
9.0
9.0
9/26
9/26
9/26
<10
<10
<10 ------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
SH-S0-03-12J-l 9/20 Composite-Test Pile J Total F 9/26 <10
SH-S0-03-12J-l 9/20 Composite-Test Pile J Total 12 9/26 <10
SH-S0-03-12J-2 9/20 Composite-Test Pile J Total F 9/27 <10
SH-S0-03-12J-2 9/20 Composite-Test Pile J Total 12 9/27 <10 ------------------------------------------------------------------------------------------------SH-S0-03-12J-6
SH-S0-03-12J-7
SH-S0-03-12J-8
9/20
9/20
9/20
Composite-Mixed Pile J
Composite-Mixed Pile J
Composite-Mixed Pile J
27.7% CB
27.7% CB
27.7% CB
Total
Total
Total
F
F
F
Unable to analyze
w/o greatly
diluting sample ------------------------------------------------------------------------------------------------
SH-S0-03-12J-6
SH-S0-03-12J-7
SH-S0-03-12J-8
9/20
9/20
9/20
Composite-Mixed Pile J
Composite-Mixed Pile J
Composite-Mixed Pile J
27.7% CB
27.7% CB
27.7% CB
Leach
Leach
Leach
9.1
9.2
9.0
9/27
9/27
9/27
<10
<10
<10 ------------------------------------------------------------------------------------------------
Page 4
•
•
Westinghoose Envimrreilal
anct Gfliedlnital 8erVm. Inc.
·•
5ui:e 700
3980 De<alD lecnnolooy P3n<way. N.E
~:ianra. G.01111a :m,o
, ,04" 58-9309 <,
'"' 1,!()41458-9438
FAX TRANSMISSION TO FOLLOW
Date:
To:
From:
Number of Pages to Follow: ---'-----
Comments/Special Instructions:
• 11,-.~., .. ,.,,,.,,,.., c;:r.,...,,,.. r,v,.,.. ...... ,,.,. ,.,,.,...,,..,;.,..,, 11:10. 38l:ld
•
QC'! 17 \991
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James C. Martin, Governor
William W. Cobey, Jr., Secretary
Ceorge T Everett, Ph.D.
Director
Rq,~onal O/fice\
t\\heville
?CWJ:51·6208
Fayem:ville
9191486-1541
,\\onrcwille
704/663-1699
Raleigh
91')/733-2314
Wa\hingt1>11
'.l19fl).\6 6-IHI
Wilmi11gt(,r1
'WJl3'.J5-3\}(XJ
\Vin,t(m-S;ilem
919/8%-7()'.)7
October 10, 1991
MEMORANDUM
TO: Bill Meyer, Director
Division of Solid Waste Management
FROM: ~( George T. Everett ~°'--~
SUBJECT: Celanese Fibers NPL Site
Trial Burn Report
Cleveland County
Project #91-59
The Division of Environmental Management has completed
the review of the subject document and offers the following
comments and recommendations.
1. While the emission rates for benzene, carbon
disulfide, chloroform, and methylene chloride are
demonstrated to be greater than estimated on the
air permit application, the actual emissions are
less than the exemption levels contained in 1 SA
NCAC 2H .0610.
2. Air Permit No. 6943 was issued on December 19,
1990. Acceptable Ambient Limits (AAL's) for
benzene, chloroform, methylene chloride, and
chromium VI were not effective until May 1, 1991.
Thus, the facility did not have a regulatory
obligation to comply with the AAL' s contained in
. 1100 ( b) for those pollutants in December 1990.
The only applicable AAL at the time
of permit issuance was the AAL for carbon
disulfide. Projected ( and now demonstrated)
emissions of carbon disulfide were below the
exemption level. Air Permit No. 6943 required
compliance with .0610(h) in Section A. Specific
Conditions and Limitations No. 1.
PO. Box 29535, R.1leigh, North Carolina 271i26-05.15 "Jt'.lephune 919-733-7015 I Pollution Pn:vrntior1 Pay,
An Eriu~I Opponu11ity AltitrnJtiw Action l:mployer
• •
3. Total chromium was measured during testing, not
chromium VI. In the past, the APB has used the
factor of 1/279 of total chromium as an estimate
for chromium VI. This factor was submitted by
Duke Power Company in support of the Lincoln
Combustion Turbine Station. Duke referenced EPA
document EPA-450/2-89-001, Estimating Air Toxics
Emissions from Coal and Oil Combustion. While not
specifically applicable to the Hoechst Celanese
Test Burn, it appears to be the best reference
available for determining chromium VI from total
chromium. The APB has previously provided the
Technical Support Branch this reference for its
use as a factor for determining potential chromium
VI emissions for other projects.
4. Based on the above information, the APB has
determined that no further permitting action
necessary or required the Hoechst Celanese
permit No. 6943.
If there are any questions, please advise.
GTE/sbp/CELANESE.SWM
cc: Lee Daniel
Steve Tedder
Mooresville Regional Office
Central Files
Groundwater Files
is
air
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary October 4, 1991
MEMORANDUM
TO:
FROM:
Lee Crosby, Chief
Superfund Section
Jerome H.
Hazardous
Rhodes, Chief
Waste Section
114/(
William L. Meyer
Director
REFERENCE: Hoechst-Celanese Corporation -Shelby, North Carolina
Trial Burn Report
We have completed our review of the report on the trial burn
conducted at the Hoechst-Celanese Corporation in Shelby, North
Carolina during the week of June 10, 1991. The trial burn was to
demonstrate compliance with RCRA incineration standards while burning
CERCLA waste at the Celanese site. This Trial Burn Report indicates
that the incinerator has passed all the performance standards
required by RCRA.
If you have any questions, please contact Jill McCabe of my staff.
JHR/JBM/mb/113
cc: William L. Meyer
William F. Hamner
Daniel L. Bius
Jill B. McCabe
An Equal Opportunity Afflrmadve Acdon Employer
James G. Martin, Governor
William W. Cobey, Jr., Secretary
MEMORANDUM
TO:
FROM:
RE:
16 September 1991
Jerry Rhodes, Chief
Hazardous Waste Section
Lee Crosby, Chief / C.,,,
Superfund Section ,1
Celanese Fibers NPL Site
Shelby, Cleveland County
Request for Review of Trial Burn Report
William L. Meyer
Director
Attached is a copy of the Trial Burn Report for the Hoechst Celanese Corporation
site in Shelby. This report contains the remainder of the data for the three test burns
conducted. Please return all comments to our office so that we may submit one package
to the US EPA. Incineration of wastes has commenced at the site based on the results of
the first trial burn run. Since incineration has already begun, we would appreciate your
review as soon as is possible. Thank you for your assistance.
LC/acr
Attachments
....... 9AT, '-,. J' ,,.. ..........
. •• •...,6 ~"'"'"•• ~ .... 6~~.". ,\i.1. ~;\
\':\ ,. C ~ .~(. I: ~> .• :. .... ~ ,,,.,...,.,.,c•'_. ·-·~
• •
State of North Carolina
Department of Environment, Health, and Natural Resdu~ces
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor .
· William W. Cobey, Jr., Secretary
MEMORANDUM
TO:
FROM:
RE:.·
16 September 1991
Perry Nelson, Chief
Groundwater Section
Lee Crosby, Chief IV
Superfund Section f'
Celanese Fibers NPL Site
Shelby, Cleveland County
Request for Review of Trial Burn Report
William L. Meyer
Director
Attached are two copies of the Trial Burn Report for the Hoechst Celanese
Corporation site in Shelby. This report contains the remainder of the data for the three test
burns conducted. Please forward one copy to Lee Daniels of the Air Quality Section and
one copy to the Mooresville Regional Office Air Quality Section Chief for review. Please
return all comments to our office so that we may submit one package to the US EPA.
Incineration of wastes has commenced at the site based on the results of the first trial burn
run. Since incineration has already begun, we would appreciate your review as soon as is
possible. Thank you for your assistance.
LC/acr
Attachments
• r_'•::. STAT£~¾,. .•·...,"' .,. ..... ,,.. -1o, l'!l;_ ,. ~ . "'-lpi\ /5 fVjtcs'.l-~ s:i ~~YJ_:f/41) -~~;.,.7
•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. McKenzie Mallary
Remedial Project Manager
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
31 July 1991
RE: Celanese Fibers Operations NPL Site
Shelby, Celveland County
Additional Comments on the Mini-Trial Burn Testing Report
Dear Mr. Mallary:
William L. Meyer
Director
Attached are comments from the North Carolina Division of Environmental
Management Air Quality Section regarding the above document. Please contact me at (919)
733-2801 if you have any questions.
CVJ/acr
Attachment
Sincerely,
/
Ju~id£YJ/v,,~'-c{ .-/'
Charlotte V. Jesneck
Superfund Section
• •
State of North Carolina
Department of Environment, Health, and Natural
Division of Environmental Management
·kt.Ct.IV ED
JUL :IO 1991
SUPERFOND SECTION Resources
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor
William W. Cobey, Jr., Secretary Air Quality Section
July 26, 1991
MEMORANDUM
To:
Through,
From,
Subject:
Lee Crosby
Lee Daniel
Earl McCune
Hoechst Celanese
Shelby, Cleveland County, North Carolina
Preliminary Review of Mini Burn Testing
Performed on June 13, 1991 by
Industrial and Environmental Analysts, Inc.
George T Everett, Ph.D.
Director
A report of Test 2 in a series of three tests has been submitted to this
division for review. The report provides a summary of the sampling and
analytical data from the test conducted on June 13, 1991. More complete process
information will be submitted with the report covering the entire series of
tests.
The testing in this portion of the trial burn include EPA Method 5 for
particulates and hydrogen chloride, Modified Method 5 for semivolatile organics,
EPA multimetals train for metals, and a volatile organic sampling train (VOST)
for principle organic hazardous constituents (POHC) and products of incomplete
combustion (PIC).
The particulate emission standard that applies to the subject facility is 15A
NCAC 2D .0505, CONTROL OF PARTICULATES FROM INCINERATORS. The maximum charge
rate stated in Permit No. 6943 is 5000 pounds per hour, for which the
particulate emission limit is 4.0 pound per hour. The particulate emission rate
demonstrated by the test results was 0.225 pound per hour.
Asheville
7041151-6208
Fayetteville
919/486-1541
Mooresville
704/663-1699
Regional Offices
Raleigh
919/733-2314
Washington
919/946-6481
Pollution Prevention Pay,;
Wilmington
919/395-3900
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
Winston8alem
919/761-2351
Lee Crosby
July 12, 1991
Page 2
• •
The toxic pollutant emission rates were compared to the de minimus threshold
limits set in 15A NCAC 2H .0610, PERMIT REQUIREMENTS FOR AIR TOXIC POLLUTANTS.
The report presented the emission rates in pounds per hour. Since no actual
operating data was given, the operating time used to calculate emission rate in
pounds per day and pounds per year was assumed to be 8 hours per day and 365
days per year. No pollutant emission rate exceeded the de minimus values.
Hexavalent chromium was estimated to be 1/279 of the total chromium emissions.
This factor was submitted by Duke Power Company in support of the Lincoln
Combustion Turbine Station. Duke referenced EPA document EPA-450/2-89-001,
Estimating Air Toxics Emissions from Coal and Oil Combustion.
The emission rates were compared with the anticipated emission rates calculated
in the permit application. The emission rates of the following compounds were
greater than expected; benzene, carbon disulfide, chloroform, and methylene
chloride.
CC: Harlan Britt
• _.<,::·::: ;'-::['.~::~~
(~"' ,. ~ " '1-
1~ :uiir.i;: ~ ~~ b ·;i1 ! I;. g \\:'i:11· ? ·•,;,':,~·.,;:?:}:/
•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
Jame~ G. Martin, Governor
William W. Cobey, Jr., Secretary
MEMORANDUM
TO:
FROM:
10 July 1991
Lee Daniel, Chief
Air Quality Section
Lee Crosby, Chief DC/
Superfund Section f,
URGENT
William L. Meyer
Director
RE: Request for Immediate Review of Celanese Corporation NPL Site
Trial Burn Data
The US Environmental Protection Agency notified us today of plans to give Celanese
Corporation the go ahead to proceed with incineration of ethylene glycol contaminated soils
at their National Priorities List site in Shelby, Cleveland County. Celanese anticipates
commencing the burn at the end of this week.
We have just today received the remainder of the trial burn test data. A copy of the
data is attached for your review. Due to the plans for commencing the burn at the end of
this week, we would appreciate your immediate attention to this matter. We are also
sending Keith Overcash in the Mooresville Regional office a copy of the data. Charlotte
Jesneck with our office has already spoken with Richard Lassiter in your office and also with
Keith Overcash. If you wish to relay in comments verbally and then follow up in writing,
please contact Charlotte Jesneck or me at 733-280 I. We greatly appreciate your assistance
in this matter.
LC/acr
Enclosure
.J
•
MEMORANDUM
TO:
FROM:
RE:
10 July 1991
File
Charlotte Jesneck, Branch Head
Inactive Sites Branch
Celanese Corporation NPL Site
Shelby, Cleveland County
•
Today I sent copies of the trial burn data for the Celanese NPL site to Jill McCabe
with the Hazardous Waste Section, Keith Overcash with the Mooresville Regional office Air
Quality Section and Lee Daniels, Chief of the Air Quality Section.
CJ/acr
i .<>·:.~i.~\,:~¼
/o.' r ! ,~_"-\
\-~ ,;J, ;\ ·.: "'~· :s ~-, : ' 'Jr "l ., _,, •D ! $t~P--
\~.i,,:_~·-~~:~-:.~}-/
•
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. McKenzie Mallary
Remedial Project Manager
US Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
5 June 1991
RE: Celanese Fibers Operations NPL Site
Shelby, Celveland County
Comments on the Mini-Trial Burn Testing Report.
Dear Mr. Mallary:
William L. Meyer
Director
The North Carolina Division of Solid Waste Management has reviewed the above
report. Comments are attached. Please contact me at [phone] if you have any
questions.
s;,.,m[y, . iJ
}!::::!;""~
Superfund Section
CVJ/acr
Attachment
• •
Division of Solid Waste Management
Superfuncl Section and Hazardous_ Waste Section Comments
Celanese Fibers Operations NPL Site
Mini-Trial Burn Testing Report
1. Any compounds · used as spikes to determine removal efficiency must be
demonstrated to be more difficult than ethylene glycol to decompose by thermal
treatment.
2. Table 2: Ethylene glycol is not a POI-IC.
3. Page 5: Chromium volatilizes at 2900°F. Chromium is not likely to be found in the
gaseous form in the stack gas.
4. Page 6: The report states that since ethylene glycol was present at a concentration
of 3,200 ppm in the feed sample and was not detected in the ash sample, the
incinerator is effectively destroying hazardous compounds in the waste feed system.
This comparison at best only demonstrates that ethylene glycol has volatilized and
is not left in the ash.
5. Table 5: Please clarify how 47% recovery was calculated for ethylene glycol based
on the .values given in the table.
6. Table 7: The concentrations of volatile organic compounds detected (i.e. benzene
and toluene) raise questions about the combustion efficiency of the incinerator and
raise concerns about protection of human health.
7. A memorandum with additional Hazardous Waste Section comments is attached.
_ ... _.--:~:-,:~:~~~~~--;:~~
~-!~1t~))
\·,'.·.~·-·;:?!}:.-fl
• •
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Solid Waste Management
P.O. Box 27687 · Raleigh, North Carolina 27611-7687
James G. Martin, Governor
William W. Cobey, Jr., Secretary
'ID: Ola.rlotte Jesneck
Superfund Section
June 5, 1991
FRCM: Jill McCare .. {y('°'
Hazardous Waste Sectiot
REFERENCE: Hoechst Celanese -Shelby, NC
Mini-Trial Burn Report
William L. Meyer
Director
We have completed our review of the Final Report on the mini-trial burn conducted at
Hoechst Celanese in Shelby, North carolina. 'Tue trial burn was to demonstrate
compliance with RCRA incineration stc,ndards while burning CERCIA waste at the
Celanese site. 'Illis Final Report clearly shCMs that the rotary kiln incinerator did
not pass the performance standard of 99. 99% destruction and removal efficiency.
Therefore, in a=rdance with RCRA incinerator regulations, the incinerator did not
pass this·trial rum.
If Hoechst Celanese decides to =nduct another trial burn, we would strongly
re=mmend that a different FDHC is chosen. Naphthalene is a poor FDHC choice because
of its tendency to disassociate into other hazardous =nstituents, as is indicated by
the large =ncentrations of volatiles in the vosr results (Table 7).
'.Ihe actual report itself has several serious omissions and errors. A trial burn
report should present in much more detail the nature of the•incinerator and APC
equipment, the characteristics of the spiked waste stream; the precise sequence of
events throughout the trial rum, and the calculations used to arrive at the results
in the report. Several ,of the tables presented in the report have either erroneous
or misleading information =ncerning the data =llected at the trial burn (i.e.
Tables 2, 5, and 7). In addition, a few of the discussions on the stack emission and
process stream results {pages 5-6) have misinterpreted the test data and/or produced
incorrect deductions from the test data results.
JPM./rrb/77
=: William L. Meyer
Jerome H. Rhodes
William F. Hamner
Daniel L. Bius
An Equal Opportunity Affirmative Acdon Employer
MEMORANDUM
TO:
FROM:
RE:
•
3 June 1991
File
Charlotte Jesneck, Branch Head
Inactive Sites Branch
•
Celanese Fibers Operations NPL Site
Shelby, Cleveland County
Post-Excavation Soil Sampling/Trial Burn Information
On 7 March 1991, a meeting was held in Shelby to discuss several aspects of the
remedial action plan for the above site. During this meeting, Celanese indicated they would
conduct any necessary post-remediation soil sampling the State may require at the time of
delisting from the National Priorities List.
I telephoned Ken Mallary, the EPA Remedial Project Manager for the site, today to
discuss the issue of post remediation soil sampling. Since the Remedial Investigation Report
indicates polynuclear aromatic hydrocarbons (PAHs) are present at various depths in the
soil column in the remediation zone, I feel follow-up sampling will need to be conducted
at some point to verify the residual post-remediation levels are low enough to protect public
health and the environment. As I discussed with Mr. Mallary, these PAHs compounds have
low mobility and may not be caught in the groundwater extraction system. In addition, their
depth of occurrence varies at the site.
We also discussed the pending trial burn. As of today, the trial burn is scheduled for
10 June 1991 and will run 3 days. EPA's oversite ccrnsultant, Roy F. Weston, Inc., is
conducting split sampling during the mini and trial burns. The laboratory blank for the mini
burn data was contaminated with napthalene. Since naphthalene was the spike for
determining removal efficiency, the data could not be considered valid. Celanese may be
using perchloroethylene during the trial burn to determine removal efficiency.
Mr. Mallary also mentioned that the mini-burn stack sample data indicated the
presence of elevated chromium and arsenic. Celanese plans to prepare a predicted
emissions model before conducting the trial burn. Mr. Mallary said that he would send me
a copy of the model for review.
CVJ/acr