NCD003446721_20110223_Celeanse Corporation - Shelby Fiber_FRBCERCLA SPD_Meetings 2009 - 2011-OCR

Five-Year Update Meeting
Celanese Fibers Operations Site
Shelby, NC
February 23, 2011
Meeting Agenda
• Introductions-15 min
• Safety orientation and site orientation -30
• min
• Site tour - 1 hour
• Post-tour meeting and discussions - 2 hours
• Lunch (provided on site if desired and time
al lows) -working
• Finalize action items and data needs -15
• min
• Adjournment
Sh el by_ 2011 _ 5-Yr _orientation_ r0 _ 2-9-11 2
Shelby _2011_5-Yr _orientation_r0_2-9-11 LEGEND -STREAM L WATER USE RESTRICTION AREA PARCEL [~=] PROPERTY BOUNDARY NOTES AERIAL PHOTO FROM GOOGLE EARTH PHOTO DATED JULY 2008 N 1,000 500 0 1,000 Feet A:COM Shelby, North Carolina CNA Holdings, Inc mcona Shelby North Carolina 3
2006 Five-Year Recommendations
Finding
Several voes and SVOCs hav·e deiection limits·
above the NC.-2L groundwater standards
Recommendation
Evaluate analyticai methods, such as EPA
I -- • , methods 502.2 anp 606, to obtain lower
ll detection limits · ~----~--------------,-------------------
The 24 month shubdown period for the
groundwater treatmen!'system _has expired.
However, the MNA modeling has not been
completed. --__ , ..... ....._
The PRP has requested an extension. In the
interim, complete the MNA modeling, provide a
recommendation for MNA applicability and
decide if the groundwater treatment system
should be restarted ..
Ade9uacy of existing MW network_ to confirm the ii Improve the MW network to confirm the extent of
extent_ of the initi<!I plume and new F-55 plume ;1 the initial plume and F-55 plume and provide ,,
during the treatment syste_rh shutdown. !! sentinel wells. '----"--'----'------'--'----------·'-----------..
EG and 1, 1-biphenyl were not identified in the
ROD as COCs. However, these constituents
have been detected above the NC 2L
groundwater standards consistently during this
five-year review period.
Consider EG and 1, 1-biphenyl for inclusion as
Site COCs.
-~------------------',~---------------------! Reconnaissance of downgradient area for new
I· 9rinking.water wells has only been conducted
, orice since the last review.
The EPA previously approved removal of metals
from the routine monitoring list. However, a
formal change has not been completed to
document metals have been eliminated as
COCs for the Site
Complete the deed·revieW and perform a regular
reconnaissance of potential downgradient
drinking wells. . .
Complete a formal change (i.e. ESD)
documenting elimination of metals as Site
COCs.
I Cs wer~ not included as part of the remedies for Ii Implement I Cs in the form of deed restrictions to
OU1 and 2. I prevent potential future exposure pathways to
,_ ________________________ -_ •l contaminated groundwater or the source area
Shelby _2011_5-Yr _orientation_r0_2-9-11
Status
Ongoing. Arsenic and manganese were added to
the expanded sampling to provide data for
preparation of ESD to officially remove metals
from the sampling program.
On Hold. Pending EPA action.
4
2006 Five-Year Recommendations
Finding , Recommendation
I Reports consider the ·presence oiTCE at HH-48
.
1
and. HH-77 to be a local source and not related ,
II to Site activities. i'
·I i L
Increase in concentrations of TCE at HH-48 and
HH-77 and proximity to residential areas.
I
investigate to confirm and reach concurrence
regarding responsibility of TCE at these
locations. ·
Vapor intrusion is an emerging pathway of
concern and additional evaluation may be
necessary.
Shelby _2011_5-Yr _orientation_r0 _2-9-11
Status
Ongoing. TCE is being investigated through the
expanded sampling program currently being
implemented with the last round of data to be
gathered during March 2011. A technical memo
summarizing the findings from the data is
scheduled for submittal in June 2011.
Ongoing. II is unlikely tha_t vapor intrusion is an
issue. The house was built before approximately
1960 and is thought to be slab-on-grade
construction and would not have emphasized
low ventilation and reduced air exchange rates.
The HH wells are located about 60 to 80 feet
from the house and at a ground surface
elevation approximately 2 to 3 feet lower than
the house. The TCE conce·ntrations are
greater and increasing at depth. Groundwater at
depth is not a vapor intrusion issue. Ownership
of problem will first have to be established prior
to additional work being performed.
5
Near-term Planned Activities
• Submittal of the TD Area Work Plan -due
March 11, 2011
• Last expanded sampling event -early to mid-
March
• Submittal of the semi-annual report of
activities -due March 31, 2011
• Install GRUB Area pilot pumping system -
when approved by EPA
• Implement TD Area investigation -when
approved by EPA -tentatively scheduled
May 2011
Shelby _2011_5-Yr _ orientation_rO _2-9-11 6
Meeting Wrap-up
• Identification and agreement on action
items
• Identification of additional data needs and
timing
• Adjournment
Sh el by_ 2011 _ 5-Yr _orientation_ r0 _ 2-9-11 7
A:COM AECOM
1360 Peachtree Road
Atlanta, Ga 30309
404-965-9600
404-965-9605
tel
fax
Meeting Minutes
Client: Celanese
Proiect Name: Shelby
AECOM Proiect Number: 60135442
Date: 10/06/10, annroximatelv 10:15 am until 1:15 om
Location: AECOM Office, Atlanta
Meetina Puroose: Site review and RPM transition to Luis Flores
Preoared Bv: Dahlaren
Document Control Number 026SB-299
In Attendance
Name Company Telephone E-mail Address
Brvon Dahlaren AECOM 404-965-9657 brvon.dahlqrenraJaecom.com
Steve Dyment -by EPA [phone] [e-mail]
ohone
Luis Flores EPA 404-562-8807 Flores.luislfi)eoamail.eoa.aov
Everett Glover AECOM 404-965-9687 everett.Qlover(a)aecom.com
Dave Jenkins EPA [phone] Jenkins.dave"'•enamail.ena.nov
David Mattison -by NC [phone] [e-mail]
ohone DENR (cell ohone)
Steve Simpson Celanese 704-636-3919 steven.simpson [e-mail]
Doug Sutton -by Geo Trans 732-409-0344 [e-mail]
phone
Beth Walden EPA 404-562-8814 Walden. beth ""enamail. ena. nov
Action Item Action Item Responsibility Number
0001
0002
0003
0004
0005
shelby epa meeting atlanta act 06 2010_r0.docx
AECOM
Summary
Meeting Minutes
EPA/NCDENR Meeting, October 6, 2010
CFO Facility, Shelby, NC
2
The meeting was started with an introduction of Luis Flores and the existing project participants.
Beth Walden started the presentation.
The Record of Decision (ROD) is an old format and is based on total organic carbon (TOC). It is
very broadly worded so that "any contaminant" can be considered.
The Outer Tier (OT) was intended to address trace level organics at the perimeter through pump
and treat (P&T), air stripping/carbon. Water restrictions and potable water service were provided
downgradient and detections were no longer reported, therefore the OT was delisted. Diethylene
dioxide was not in identified prior to delisting.
Recent work has included an Independent Design Review (IDR) and optimization assessment
Final revised I DR was submitted in early 2009 after December 2008 meeting at plant site. AECOM
and Celanese developed a work plan to address IDR comments and is currently implementing the
plan
Doug Sutton reviewed the IDR conclusions and recommendations (see slides)
Diethylene dioxide -Luis Flores asked about the source of the diethylene dioxide. Steve Simpson
explained the chemical process by which diethylene dioxide is produced as a by-product from
ethylene glycol and that the glycol recovery unit bottoms (GRUB) material is the original source.
GRUB material was removed in the early 1990s, the plant's disposal procedures changed around
1970/1971 and the DMT process that resulted in the diethylene dioxide production is no longer
used.
Doug Sutton
Diethylene dioxide plume is large, was noted after OT delisting
500 feet past OT
May discharge to creek, IDR conclusion was that more study is needed.
Ethylene glycol and Dow Therm are limited at the site, additional data are needed to confirm.
Work since IDR has been completed to address IDR issues, stream study report delivered to EPA
at this meeting.
Delineation of diethylene dioxide plume through additional wells is very difficult because of the
terrain and topography. It is not practical to put wells in many locations. Hydraulic assessment is
an available alternative.
Passive or active remediation strategy for diethylene dioxide needs to be considered. Issue is more
policy than technical. Insufficient data to assess effectiveness of OT, but it is not likely to be
effective and a new P&T system would be required if that is the option.
Original source of ethylene glycol and diethylene dioxide is GRUB. Ethylene glycol has been stable
at V-23 for roughly 15 years at 6,000 to 8,000 milligrams per liter (mg/L). At the adjacent former
Inner Tier extraction well lT-6, the ethylene glycol concentration has fiuctuated generally between
500 mg/L and 2000 during the same time period
shclby epa meeting atlanta oct 06 201 O_rll.docx
AECOM
AECOM DPT investigation of former GRUB area
Meeting Minutes
EPA/NCDENR Meeting, October 6, 2010
CFO Facility, Shelby, NC
3
No GRUB was found. GRUB is very easy to identify visually. Continuous screening of DPTs did
not identify GRUB.
Soil samples have very few detections of either diethylene dioxide or ethylene glycol.
Ethylene glycol was in some groundwater. Diethylene dioxide was in most groundwater.
Scope of work I number of DPT locations significantly increased in field over initial work plan. Some
of the added locations were installed to DPT refusal. The maximum depth was around 48 feet.
Concentrations of both ethylene glycol and diethylene dioxide in groundwater increased with depth.
Detections are significantly deeper than disposal depths of GRUB.
The DPT refusals indicated a clear trough in the top of rock through the area that is interpreted as
constraining the highest detections.
Conversation focused on this trough area.
• It appears likely that dissolved material is collected in this low area.
• Soils data was non-detect
• Concentrations in shallow areas are lower than deeper concentrations in the trough
These results suggest that the mass is concentrated in this groundwater area.
Beth Walden
Is there product? Doug Sutton. Everett Glover, Bryon Dahlgren agree that there is no product.
Both ethylene glycol and diethylene dioxide are miscible.
Dave Jenkins indicated that contours presented as part of the DPT assessment suggest that part of
the plume may be migrating to the immediate southeast. Everett Glover stated that historic data
from wells in this area indicate that ethylene glycol does not migrate far in this direction before
degrading. The expanded characterization events may demonstrate that there is a pocket of high
concentrations in an inhibitory zone and downgradient degradation is happening. If this is
established MNA may be appropriate.
Stream Study
Everett Glover described the stream study. Data show that no detections of diethylene dioxide are
present in locations immediately downstream of the recreation pond. Detections are then noted in
groundwater and surface water at the same location, demonstrating that groundwater is discharging
to the stream and that the stream is capturing groundwater.
Downgradient of the Celanese property concentrations are generally stable in surface water,
indicating that low concentrations in groundwater are still entering the surface water.
The conclusion is that the stream is capturing groundwater containing diethylene dioxide.
The stream study technical memo providing greater detail on the work was provided to EPA.
Five Year Review
General discussions were held about the upcoming Five-Year Review that will be due in August
2011. There was a concern expressed by EPA that they could not adequately address the question
of protectiveness without a greater understanding of the potential of groundwater use immediately
beyond the end of the property covered by the groundwater use restriction.
EPA offered that a oilot oumoina test could be irnolemented with a minimum of administrative
shclby cpa meeting atlanta oct 06 20!0 _rO.docx
AECOM Meeting Minutes
EPAJNCDENR Meeting, October 6, 2010
CFO Facility, Shelby, NC
4
requirements to determine whether removal of the more highly impacted groundwater just
downgradient of the former GRUB area would be a viable remedial approach.
EPA offered that they thought that the site would require a ROD amendment make the ROD current
for future activities at the site and if that was the case, it would have to go through the full
administrative process including development including work plan development, feasibility study,
proposed plan, and public notice.
At the conclusion of the meeting, two complete copies of the Quality Assurance Project Plan
(QAPP) were given to EPA to replace versions provided to them in as insert pages to the August
version.
These meeting minutes were prepared from the collective memory and notes of Everett Glover and
Bryon Dahlgren. If you have questions, please contact the writer at 404.965.9657.
Submitted by:
Bryon Dahlgren, Project Engineer
shclhy cpa meeting utlanta oct 06 201 0_r0.docx
. October 6, 2010 -Celanese Fiber Project Update . 1
Celanese -Background
♦ Large multi-constituent plume resulting from an active plastics
manufacturing plant
■ 1,4-dioxane (referred to as diethylene dioxide)
■ Ethylene glycol-degradation products
■ TCE
• Dow Therm TM -1, 1 Bi phenyl and Bi phenyl ether
♦ GW ROD signed in 1988 (Source ROD signed in 1989)
♦ P& T system with two tiers of extraction (inner tier and outer tier)
• Inner tier -shut down on trial basis in 2004
■ Outer tier -shut down in accordance with delisting in 1998 ( before 1,4-
dioxane was identified
: October 6, 2010 -Celanese Fiber Project Update 2
Celanese -IDR
♦ Region 4's Concerns and Motivation for Conducting an IDR
• Inner tier P& T system was shut down on a trial basis to evaluate MNA.
• Inner tier system has not been restarted.
• Should it be restarted?
• If it should be restarted, should the system be modified?
• Is another remedial approach more appropriate?
October 6, 2010 -Celanese Fiber Project Update 3
Celanese -IDR Findings
♦ Initial IDR Findings
■ Remedy Effectiveness
• The IT system appears to have had minimal effectiveness when
operating.
• Diethylene dioxide is a difficult contaminant to address. The ability of the
existing system to remove diethylene dioxide is not known.
• The evaluation of an MNA remedy depends on the constituent of
concern being evaluated.
-Diethylene dioxide: MNA does not appear to be a viable remedy.
-TCE: There is insufficient information to evaluate MNA.
-Ethylene Glycol: It is likely that MNA is an appropriate remedy .
. October 6, 2010 -Celanese Fiber Project Update 4
Celanese IDR Findings
♦ Initial IDR Findings
■ Diethylene dioxide plume is wide-spread at the site (much more so
than other contaminant, but wells sampled for diethylene dioxide
have not recently been sampled for other contaminants of concern)
• Diethylene dioxide plume needs to be delineated
■ Extent of ethylene glycol and Dowtherm TM contamination appears
relatively limited -additional sampling will help confirm
■ TCE is detected at the source area and over 1,000 feet
downgradient, but not in between
• Perhaps due to an off-site source
• Perhaps due to lack of sampling between two areas
October 6, 2010 -Celanese Fiber Project Update --5
Celanese IDR Recommendations
♦ Initial IDR Recommendations
• Sample transition zone wells to determine if there is a link between the off-
site TCE and on-site TCE
• Source area investigation for TCE
• Delineate diethylene dioxide plume with EPA suggested monitoring wells
and determine if it is migrating beyond streams
• Collect samples that represent groundwater beneath the stream bed
• Collect surface water from the stream
• Confirm groundwater discharges to the stream as suggested by aquifer
model
October 6, 2010 -Celanese Fiber Project Update , 6
Celanese IDR Remediation Strategies
♦ IDR Suggested Remedial Strategy
• Based on extent of diethylene dioxide plume, determine need for passive
or active remediation
• If active, then utilize P&T with advanced oxidation (or perhaps on-site
water treatment facility)
• Limited or no merit in restarting P& T system
-Existing Inner Tier system provides negligible mass removal and
restarting it is not merited
-No information available on potential effectiveness of Outer Tier
system
-Neither designed to treat diethylene dioxide
October 6, 201 O -Celanese Fiber Project Update --_ 7
Celanese Grub DPT Investigation
October 6, 2010 -Celanese Fiber Project Update · 8
\
GRUB Investigation Program
<. ,,..
I
AS'COM
v»e ~ITOR<NOWEU.LOC,,,,,li,00
""• INJECTIOHWEU.LOCATON
'"• D•RECT PUSH 5AA!PlE LIXATION
""" SU1Ul,A,R'I' OF GRU8 AREA !NYESTIGAT•ON
AUGUST 2$ THROUOH ~ 111, 200II
600PTUX:,..110NS
39 80:L &UIPI..E.8 NU,i. Y'ZEO
61 GROUNOWA TER SAl,IPLES .\NAL VZEO
3 WEU8 NW.VZED
"' "'
SCALE If/ f"£CT
FIGURE 1
SAMPLE LOCATION MAP
CHA HOLD..ae, INC/T~ RCI..WT,-CMOUMA
October 6, 2010 -Celanese Fiber Project Update 9
\
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/ I; 'l
'I
I I I
GRUB Investigation DPT Refusal
\ \ \ \
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/ I
11-2~ . /
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. _ _le, -__;,./ () ri~ X •-
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V-n_ MON1TOR•NO WEU LOCATION
FT-.0• INJECTIONWCULOCATION
l-ll, DIRECTPUSHSAMPI.E:UX:,.TION
(79511111 OPT (MOCIELIIOIO) REFUSAL ELEVATION
795---OP'T(MCIOELIIOIO)RU'USAL~ATlON COH,OUR
""" SOME comouRS LEFT our IKl'iHTlOK,\1.1. y
FOR a.AAITY.
"' 00 '"
sc,.u IN FECT
FIGURE 1
OTP REFUSAL ELEVATION
CONTOUR MAP
~HOUI..OS.OIIC/'l',eoN,A.
SH(UY, NOltTH CAIIDUNA
October 6, 2010 -Celanese Fiber Project Update 1 O
//
Diethylene Dioxide Data -Shallow
1/
I /
■N-11
A:COM )
LEGEND V~. MONfTORJNG WEU. LOCATION
rT.,t♦ INJECTION WEU. LOCATIOH
l•13• OIRECTPV&HSAMPI..ELOCAn::>N
01ErnY\.£NE OIOXIOE CONCENTRATIONS lN -(1WII) 8AMPL..!. OEF'Tk IN F!l!T 111!:LOW GROUND
-10-
"""
'""'""' 80TTOU OF EXCAVATED~
TOP OF REDl!:POSrTED STABI.IZEO
REMEOIATION RESOUALS
CONCENTRA llON CONTOI.IR
THE LOCATIOH OF W.15 ANO M,18ARE APPROXIMATE.
'"" ,oo
SCAJ..E IN f[CT
DIETHYLENE DIOXIDE CONCENTRATIONS
IN SHALLOW GROUNDWATER
October 6, 2010 -Celanese Fiber Project Update . . 11
I I
'I /1
Diethylene Dioxide Data -Deep
' \ ' '
\
'I\: lJ \:"'\ \.)
;-\
1,i>,~
\._I I
¥coM/
LEGEND
v~ MONfTORINO WEU. LOCA:n::w rr.... l>l.JECTION waL LOCATION
L-1le DIRECT PUS11 BAMP1.E LOCATlCIN
• "'™"-"" """"' CONCENTRATIONS IN fro\.
t•WSl SAMA.!!DePnilNFW8eLOWOAOUN:1
-\0 -
NOTE:
.. ,.,...,.
BOTTOt.l OF EXCAVATED AAU
TOP OF AEO£POSITE0 STABI..IZE.D
RElilEOLo\TlON RESIOUAlS
THE LOCATION OF .... ,r, AHO .... II AAE APPROXJMA.TE,
' " " "'
SCA!.£ IN FETT
DJETHYLENE DIOXIDE CONCENTRATIONS
IN DEEP GROUNDWATER
QjA. HCllDNJe, ~ tHEUll'.-fHCAADU,i,\
October 6, 2010 -Celanese Fiber Project Update 12
I '
Ethylene Glycol Data -Shallow
•1,1.11 <7111 ... , • .J)
I A=COM· ( I
•
-10-
NOT?::
LEQEND
MONITORNO W!:LL LOCATIOH
ll'UECTION WEU. LOCATION
DIRECT PUSH SAMPlE LOCA.llOH
m-M.ENE GLYCOL CONCENTRATIONS IN n¢
SAMPU DEPrn IN FEET BELOW GROUND
"""""'
!IOTIOM Of' !XCAVATW~
TOP OF REDEPOSITED STABl.lZEO
REMEDIATION REaOJAUI
CONCftmWON CONTOUR
Tl-1!: LOCATION OF M-15 NCI M-19 A.Re N"PROXIMA~
0 " "
SCAL! IN r((T
ETHYLENE GLYCOL CONCENTRATIONS
IN SHALLOW GROUNDWATER
°"'NOlr.Gl,.IIIQ'nCOOl,O.
~.NORTH~
_ October 6, 2010 -Celanese Fiber Project Update 13
' ,
Ethylene Glycol Data -Deep
0.Mle•~)
\
"' -~✓ -~
/ /
"' ·-, I
L.•o• .M,-10
-._
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,~.
•••
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4
(16-a)
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LEGEND
WONITOR.NG WELL LOCATION
INJECTION WEl.L LOCATION
DIRECT PUSH SAMPLE LOCATION
l!.nM.ENl!.Ot.YCOI.
CONCENl'RATIONS .. 11'9'1.
SNr,FI..E OEP™ IN FEET l!E.L.OW GROUND
"""'"' IIOTTOMOF exCAVATEOAREA
TOP OF REDEP0$1TED $TABLIZED
REMEotATION RESIOIJ>,LS
"""""""'TION "°'"""'
THI!: LOCATION Of' M-15 Nl.D "-10NU:.Af"PRCl.lOMATe:.
0 " "' ,00
SCIJ..E 1H FEIT
ETHYLENE GLYCOL CONCENTRATIONS
IN DEEP GROUNDWATER
a.... >O..D>IGS, l'fCl'T~ »e.JIY,NOR'TH~
. October 6, 2010 -Celanese Fiber Project Update 14
GRUB Investigation Conclusions
♦ Work plan scope plus significant expanded work
completed
♦ No source identified
♦ Minimal detections in soil
♦ Detections in shallow groundwater are at lower
concentrations than detections at elevation of well V-23
♦ Detections indicate residual groundwater contamination
at depth
♦ Detections at well V-23 in most recent 18 months
suggest possible declining concentrations
♦ Recommend long-term monitoring
October 6, 2010-Celanese Fiber Project Update 15
Celanese Stream Investigation
October 6, 2010 -Celanese Fiber Project Update 16
-· Stream
Stream Inflow Study
Source: USGS, Sbcksburg Nath 0 ,00 ""' ,,200 CNA Holdlf'lgs, lncJTicon.a
Shelby, North Caroline
May 2010 110\35442
October 6, 2010 -Celanese Fiber Project Update 17
Stream Inflow Results
CELANESE PROPERTY
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008
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I
R ESIOOITIAL NEIGHBORHOOO
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-···-STREAM
NOTE: STREAM LENO™~ 4,5Hl'
BEGINNING AT RECREATIClNlflRE PONO
------~-----------·-·i-
a JOO 600
HORIZONTAL
SCALE IN FEET
Ai'COM
y
GEORGE CAMP PROPERTY
0"'
0,.
oo,
o"' ~ S! 0.05 -< I
0.0< i
""
FIGURE 3
SHELBY STREAM INVESTIGATION DATA
SEPTEMBER 2009
CNA HOLDINGS, INCmCCf,IA
SHELBY, NORTH CAROLINA
October 6, 2010 -Celanese Fiber Project Update 18
Celanese -Monitoring Well Installations
AECOM
FIGURE 2
DEEP MONITORING WELL LOCATION 11-65-NEW
'""'
October 6, 2010-Celanese Fiber Project Update 19
Cross Section Plan
A'
Ai'COM
V-23 e
OT-10f
PZ-10..,
l,IONJTQRINO WE.U. lOCATl()tj
IPUECTIOJI 'Nl:U. 1.0CATlON
PIEZOMETEA LOCATION
A---A' CROSSS£CT•ONLOCATION
CROSS SECTION LOCATION MAP
CNA1"0Un,i0$,I~ ll1tlll', ~ CNIIClUNA
October 6, 2010 -Celanese Fiber Project Update 20
Hydrographs LL and II Wells
C: 800
0 750 :i:, ~/ "' > 700 ., w
~ 650 ., -"' 600 ~ _/ "C C: 550 ::, ____./ 0 ~ 500 Cl
Jan-04 Dec-04
740
c: 738
0
1 w
~ .s ;
"C C: ::,
0
c'.5
736
734
732
730
728
726
__,,/"
Dec-05
"LL" Hydrogra11h
V
~ ---\ __,,/" LL-110 LL-175 LL-295
\/
Dec-06 Dec-07 Dec-08 Dec-09 Dec-10
"II" H hs
Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Jan-07 Jan-08 Jan-09 Jan-10 Jan-11
-11-40 -11-65
i1J __ ,.o -
October 6, 2010 -Celanese Fiber Project Update 21
B B'
' = ' ' ,(~,;)~" ' 810 810
LL-175
800 ELEV. 792.63 BOO LL~295 El.EV. 792.63
790 .,,--IPZ-10 -790
ELEV. 782.65' . '
780 / 780
11140 770 ELEV. 754.99' / 770 11--65 I ELEV. 7S"-99'
760 ll-112. ' 760 ELEV. 755.50'
750 ' 750
740 740
~
730 730
~ PZ•H: 11-:0 ~ 720 ll.1'.' 11!-:,(,7 720 c,,1oc,,o;,
C 0'•.'1406 i ~ 710 a, .. ., 710 a z II G'i z
Q 700 ---· 0~ 700 i 0;,1;,,)'J" ~ ,., < iii 690 LL-110 -690 " o om <J'i·IJ'C;, •=
680 680 ,,,, ....
670 670
660 660
650 11-112 650 ((•;•,\
.1aJ.: I•
640 ,om,:r 640
630 630
ll-175
620 00\Sl 620 :m-2\)0G
610 ... ,, .... 610
600 600
590 590
580 580
570 570
560 560
550 550 LEGEND
540 540 ~LL-110 SA.MPLEI.D
ELEV. 792.63' GROUND SURF ... CE ELEVATION
(FEE1, MSL)
530 530
DPT WELL
520 520 I SCRCCNCD INTERVAL
510 510 ! GROUNDWATER ELEVMION
LL-2!J0
500 u iJU12 500 0 016 DIETHYLENE DIOXIDE CONCENTRATION (mg/L) O\J,1'J.'I;., °"""' ANALYTICAL DATE
490 fDlCl(lj)" 490
0 "" "" =
HORlZONTAL SCALE IN FEET
0 " "' w
VERTICAL SCALE IN FEET
VERTICAL EXAGGERATION• 13.33X
AE'COM CROSS SECTION 8-8'
CNA HO!.OINCS. INC/TICONA
SHElBY, NORTH CAROllNA ,o ..,,. ... ~
l:l_,,_"-VMTLANTA C..oc1 fllas\79750 ~yOooo S.C-, 8-8 11).2{110,0wg. •=100 :IQ,00 PM. -
DD-58R Area
A A'
' = ' ~--CC-33 ~TESIIE~
V-23 M-28 1CUV.J10J0' II.EV 110 IV' =~~ V-o5 CC<!< M-4' CELANESE PROPERlY CLAUDE LAVENDER PROPERTY n£V.l10 17 EILV 11011V 810
,J
ti.ty.llCIUO' 810
800 i~ll7 800
790 ' ' 790 ,. ! ,,,o,.,:,,; \ PP•70
' ' ' ELEV 1A4' m•• --. 5 'r• •. ' i ~ 780 780 ··~ "-Im»• Qi~i m•• \ OT-1R
tu,"IMl'l ' UfV.Tl'OV' \ g 770 .... , 770 ~
~ \
760 ! • -"" ----·--· -; 760 ~--' I
~ m.,, 8 ~ \
i 750
,& ,~ 750 J '" • .. .-,.<iG, ~W,~ m~• l!U"~OOf'
740 -~ ------I 740
~ .,~~9..
TON•" .. ~
730 ' 730 . ,
720 013'1 720
CW,l.tlti
710 m~• 710
TOl10"
700 ··--·-----------· ---· - -700
CELANESE PROPERTY ClAUOE LAVENDER PROPERTY ~--~Tlo81TEIIOUNDARY)
LEGEND f~ ~" P-EV,a102CI' 0M0l."'1 IIIJMF,>Q; =ATIQN (Fl'FT,IISl) --• ,m = -
I &alUNEO•NrERVAI. H0R:20NTAI. SCAl.f IN FEET
• " ~ .. • GROIJNDW"rtR EUV"'TO<I AS'COM CROSS SECTION A·A' ... OCnrn.£1E DOlliOE co,,cc,mto,u;w im,;;I.J VERTICAi. SCA,I..E l>I FEET ,_ .--.'>1'1C40ATli VEflnc::,tJ,. ElVoOGEJUIT101<1 • IP:
eNA H0lDIHQ:S, ~ ~--™CUIO!.l',IA -
L-Tl.N{TIIC.-~ -er-_.....,,o.aio -_,,o•a:i.
October 6, 2010-Celanese Fiber Project Update 22
I
I
Celanese Expanded GW Monitoring
~. { ... "' ~ . ~}~;,' 1 rl / ) ' ··~ , -"-
\
-:·1
/ . ..-• -~WW.
♦--m lll!FICIEIIIUUI..._.
Pl&UB•
&AMPLE LOCATION MAP
.....
October 6, 2010 -Celanese Fiber Project Update 23
Expanded Sampling Program
LEGEND
• SAMPLE LOCATION
• SURFACEW,HEA &,IJPl.E LOC\TION
--FORMER GRUB OISP05'l AREA D GAOJN0WHERUSE AESTAICTI0IO,REA I D PFCf'ERTY BOUN~RY
1-PTES·
AEAi..L ~OTO FAOIAGOOOLE EARTH. ~OTO DATED JULY 2c,:,e
N
i
1,000 500 0 1,000
Feet
A:COM
SAMPLE LOCATION MAP
Shelby, North Carolina
Celanese -Misc Items
♦ DQOs for new well near DD58-R
♦ QAPP-TICs
♦ QAPP -Demonstration of Capability (Diethylene
Dioxide and Tetrahydrofuran)
♦ EDD Submittals (Historic Data and Current Data)
♦ Sharepoint Website
October 6, 2010 -Celanese Fiber Project Update 25
Remaining Schedule Items
,o 'o t•ol< N•mo I :~=i-S,le~!~n~:•R_eP9r~s __ _ __ _ _ _
_ 2 __ ;!!3 Jar:iuary -J~~e 2Q1_.Q_?em_ia_nnual f3~p_ort _
_,_
1
•:3 July -December 2010 Semiannual Report
' :3 January -June 2011 Semiannual Report =~~) Monitoring Events
6 1:3 03 2010 Monitoring Event (ind. expanded characterization) =1] R·eceiv~_g-~ iQ16 ~~~ ---~---_--. _--: ----_ -· -_ .
4 ~3 01 2011 Monitoring Event (incl. expanded characterization) ·
~1~7-~=~:t~a~g2ffmi~nltorfng pian. -----------------
11 ·:3 03 2011 Monitoring Event (Interim Plan) -,~--1 Receive 03 2011 data
=-~~] Long te:r_m· ri,Onft~(i_rig-~la/1 apP.rova1.
1< •:3 01 2012 Monitoring Even_t (Long_Term Plan) -,~--II GRUB-area -------~------------
~6__ GRUB ?'r_eaf~w~s_t_ig?lip_n __
_11 _
1
13 GRUB Investigation Review
1e 3 Submit GRUB Review
-19-TCE
-,,-·3
=~j
:'6 ,3
-217.3
-2a~3-• -~-
-30-
-Jl-
-~2-
-33-
-·:s-o-
Review Q3 2010 TCE data
Review Q1 2011 TCE data
TCE HH Wells memo
Submit TCE HH wells memo
Oeveiop to area work-Plall
EPA approve work plan
response to EPA comments __ _
-~~~r~1f~:~t~~~~~~~~~5and Geo~r~~~ -------------r·--·
two deep (bedrock) wells in TD area _
Receive lab data
TD ren1ediatior'l work plarl (posSibly MNA)
EPA approve work plan.update
reSROnse ~o EPA coni"m-enis
EPA approval of revised plans
Start TD remediation (MNA antici)?ated)
Oietheylene Dioxide
Submit diE!thYlene Oxide-discharge assessment mefllo
_EPAC<?_sts_ _ ____ -----·-----------
CB.N-IESE FIBER OPEAAllONS SITE
SHELBY. NORTH CAAOllNA
-~ l ____ '"_'~~~----·-J TIIUBN09 Wed 3/14112
Wed-Ji31/1Cl. -Fri9/3011ij
Thu 9/30/10 Th[!9{:J.Oi10i
WedJ/31110 Wed. 3/31/10
1
,
Fri 9/30/11 Fri 9/30/11
Mon 9/13/10 Wed 311·4/12j
Mon 9/13/10 Fri 9/24/10i
Mon ioi2s/16 Mon 10/25/10•
Tue 311111 . --MOn ":3/14111
Tue 4/12/11 Tue 4/12/11
Wed 4/13/11 Tue 6/21/11
Mon 10/17/11 Fii'{0/28/11
Mon 11/28/11 Mon 11/28/11
-Wed11/9/11 Wed 11/9/11
Ytiu-311/12 Wed-37i~j2
fliu 8/6i69 · Thu 8/12/10
Thu 8/6/09 WedS/26/09
Thu Bi27!09 Wed-6/30/-10
Thu 8/12/10 Thu 8/12/10
Tue 10/26/10 Mon 11/14/11
Tue 10/26/10 Mon 11/29/10
Wed 4/13/11 Tue 5/17/11
Wed 5/18/11 Tue 6/14/11
Wed 6/15/11 Wed 6/15/11
Mon 1111/11 -Fri 3/11111
Mon 3/14/11 Fri 3125/11
Mon 4/11/11 Mon 4/11/11
Tue 4/26/11 Tue 4/26/11 ·· -wed 5/11,11 ----~6/1/)}
Wed 6/8/11 Tue 6/28/11
Wed 7/27/11, Wed 7/27/11
Thu 7/28/11 Wed 9/21/11
Thu 9/22/11 Wed 10/12/11
Thu 16m111 TFiu·iohi1i i
Fri 11/11/11
Mon 11/14/11
Mon 8/30/10
Mon 8/30/10.
Mon.1/17111
Fri 11/11/11
Mon 11/14/11
--Mon a/30110 Mon e,30110
Mon 1/16/12
~OJECT SCHEDULE
OcloOet 2010
October 6, 2010 -Celanese Fiber Project Update 26
Celanese Project Schedule
♦ Review Schedule and Worksheets
♦ Deliverables
■ TCE Memo and TD Source Area Work Plan
■ DPT Results and Remediation Work Plan
■ Stream Investigation Results
♦ EPA 2011 Five-Year Review
♦ EPA ROD Amendment/ES □ Schedule
October 6, 2010 -Celanese Fiber Project Update 27
Celanese IDR
♦ Remediation Strategy???
■ Suggested Remedial Strategy
• Based on extent of diethylene dioxide plume, is "active"
remediation merited?
• What conditions would suggest that active remediation is not
merited?
October 6, 2010-Celanese Fiber Project Update
I. AECOM
AECOM
1455 Old Alabama Road, Suite 170
T 770.990.1400 F 770.649.8721 www.aecom.com
Meeting Minutes via email
Client: Celanese
Proiect Name: Celanese Fiber Ooerations Site
AECOM Proiect No.: 79750
Document Control No.: 026SB-280
Date: June 9, 2009, 9:00 AM to 11 :30 AM
Location: Teleconference
Meetina Pumose: Resoonse to EPA Comments
Prenared Bv: Everett Glover
In Attendance
Name Comoanv Teleohone E-mail Address
Beth Walden EPA 404-562-8814 walden.beth""enamail.ena.nov
Dave Jenkins EPA 404-562-8462 ;enki ns. dave1meoamail. eoa. aov
Steve Dvment EPA 703-603-9903 dvment.stenhen""ena.nov
Jon Vail EPA 706-355-8611 vail.ionathan1meoa.oov
Dave Mattison NCDENR 919-508-8466 david. mattison"" ncdenr. nov
Steve Simnson Celanese 704-636-3919 steven.simoson contractor1mcelanese.com
Everett Glover AECOM 770-990-1410 everett.nlover""aecom.com
Brvon Dahloren AECOM 770-990-1420 brvon.dahloren1maecom.com
Summary
CORRECTIONS AND OMISSIONS
These minutes are the writer's interpretation of the events, discussions, and transactions that took place
during the meeting. If there are any additions and/or corrections to these minutes, please inform the
writer within 14 days. These minutes were compiled from various sources subsequent to the meeting
and may not precisely reflect the sequence of all discussions.
PURPOSE OF MEETING
The purpose of this meeting was to develop a response to EPA comments to the draft Work Plan and
QAPP and to establish a preliminary schedule.
ITEMS OF DISCUSSION
• The first discussion was in regard to analytical monitoring suites. EPA stated that additional
work needed to be done to establish the site characterization after the inner tier (IT) wells were
turned off. EPA stated that the analysis lists presented in the work plan were unclear and that
TCL volatiles and TCL semivolatiles, including tentatively identified compounds (TICs), should
be included in the sampling program.
• AECOM stated that the 8260 analysis identified in the work plan would be for the TCL list.
• A significant portion of the time was spent discussing appropriate analytical lists for
semivolatiles.
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Page 2
o The draft work plan calls for analysis of Dow Therm A® components (biphenyl ether and
1, 1-biphenyl) at select wells.
o AECOM stated that characterization of semivolatile parameters has been completed at
the site over the course of work completed since the 1980s. Semivolatile parameters
have been removed from the list of identified chemicals of concern (COCs) for the site.
Because this work has already been completed, the additional cost of TCL semivolatiles
was not considered appropriate.
o EPA stated that the analysis was necessary for establishing current site
characterization and that the cost increase could be minimized or eliminated through
negotiations with the laboratory.
o After discussion, Beth Walden asked if the EPA and ONER participants were in
agreement that the semivolatile parameters should be analyzed. All participants on the
phone agreed. Beth stated that it was EPA's position that the semivolatile parameters
needed to be included.
o Celanese agreed that the analysis would be included.
o AECOM requested that EPA identify a list of wells that would provide adequate
characterization for TCL semivolatiles. These wells would be included for semivolatile
analyses during the two expanded characterization events scheduled for late 2009 and
early 2010. After these two events, the parameter list will revert to sampling the
DOWTHERM'"A parameters of 1, 1-biphenyl and biphenyl ether, unless modifications
are warranted.
o Steve Dyment stated that he would provide a list of wells within a few weeks.
o There was discussion on the value for doing TIC analysis since they had been
performed during the initial characterization, and are an additional $95 per sample.
EPA proposed having the analyst review the chromatograms and determine which
would be evaluated for Tl Cs. This is the approach that will be followed in the
supplemental characterization. As the analyses are completed, the analyst will review
each chromatogram and those that, in his or her professional judgment, show
significant deviation from baseline for non-target compounds will be evaluated by library
search to tentatively identify the 10 most significant non-target peaks.
o The next sampling event is scheduled for September 2009.
• The plan for activities associated with the GRUB area investigation was discussed.
0
0
0
0
0
EPA requested that a decision logic be established for responding to data in the field.
AECOM agreed that a decision diagram would be prepared and submitted as part of
the response to comments. ·
AECOM stated that the diagram would work with in-field assessments, including visual
assessment of the soil or materials identified.
It is expected that the high concentrations of ethylene glycol, and the distinct visual
properties of GRUB material will provide the primary guidance in the field. Further, the
highly localized elevated detections of ethylene glycol at wells V-23 and IT-6 limit the
expected location of remaining material.
AECOM clarified that the established budget includes funding to collect approximately
twice the planned number of samples, so that additional investigation can be completed
as findings direct. Steve Dyment stated that knowledge of the funding to adapt the
plans helped address the comment.
• One of the goals of the expanded characterization events is to determine if a TCE pathway
exists between the site and the HH wells. If the data indicate there is no pathway then work
associated with the Shelby site at the HH wells will be discontinued. AECOM will establish
decision logic for interpreting the results of the expanded characterization events. The draft
logic diagram will be submitted with the response to comments.
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Page 3
• A work plan for future activities at wells TD-3/TD-4 will be drafted after the expanded
characterizations are complete.
• The stream inflow investigation associated with the unnamed tributary draining from the base of
the recreation/fire water pond was discussed. The EPA comments were made before the pilot
study report was submitted to EPA/NCDENR on May 13, 2009. After discussing the approach
outlined in the pilot study report, EPA/NCDENR were satisfied with the approach. The pilot
study report was subsequently posted on the Celanese SharePoint site.
• A revision-marked update of the draft documents will be placed on the SharePoint site for final
review. Final hard copies will be submitted once the revisions are accepted.
• The current schedule is to proceed with installation of the II well in late July to early August
2009 and start the GRUB area investigation in late August 2009. The next sampling event is
tentatively scheduled for September 2009.
• Beth Walden requested that a simple table of the schedule of events be prepared to facilitate
the EPA/NCDENR planning for oversight during field activities. This will be provided after
verification of work plan approval and scheduling with the drilling subcontractor.
If you have corrections or additions to the minutes, please contact the writer at 770-990-1410 or at
[e-mail].
Everett W. Glover, Jr., P.E.
Program Manager
cc: All Attendees
Project File, AECOM, Atlanta
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