NC0004952_Report_20031104

NPDES DOCUMENT ! CANNIN1i COVER SHEET
NPDES Permit:
NC0004952
Celanese Shelby Facility
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
(icror d,
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
November 4, 2003
This document is printed on reunae paper - ignore any
content on the reyrerse side

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Request to Modify Elements of the Record of
Decision (ROD) for Operable Unit 1 (OU-1) at the
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
EPA ID# NCD003446721
October 2003
Submitted to:
NOV1b)ECEOWErN
- 4 1003 IL))
U.S. Environmental Protection Agency
Region IV (Lead Agency)
DENR-WATER QUALITY
POINT SOURCE BRANCH
North Carolina Department of Environment and
Natural Resources (Support Agency)
Prepared by:
Celanese
Kubal-Furr & Associates
E A R T H `um T E C H
A Tyco Infrastructure Services Company

Post Office Box 273210
Tampa, FL 33688-3210
[phone]
FAX [phone]
Mr. Kenneth Lucas
Remedial Project Manager
U.S. Environmental Protection
Agency, Region IV
61 Forsyth Street
Atlanta, GA 30303
Dear Mr. Lucas:
Kubal-Furr & Associates
Environmental Management Services
November 3, 2003
Post Office Box 80247
Simpsonville, SC 29680-0247
[phone]
FAX [phone]
On behalf of CNA Holdings, Inc., we are pleased to enclose two copies of the document
entitled: "Request to Modify Elements of the Record of Decision (ROD) for Operable Unit 1
(OU-1) at the Celanese Fiber Operations Site, Shelby, North Carolina." By way of this letter, we
have also transmitted copies of the re . ort to both David Mattison with DENR and Mark McIntire
with DENR-DWQ-WQ for
Please contact
review of this docu
Sincerely,
Kubal-Furr & Associates
61,C
Jerry E f Kubal, P.G.
President
discuss any questions you may have following your
cc: Mr. David Mattison, NCDENR
Mr. Mark McIntire, NCDENR-DWQ-WQ
Mr. Steven F. Olp, Celanese Americas
Ms. PEM Carter, Ticona-Shelby ESHA
Mr. Everett Glover, EarthTech

Request to Modify Elements of the Records of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
CONTENTS
Section Page
1.0 INTRODUCTION 1
1.1 STATEMENT OF PURPOSE 1
1.2 REVIEW OF SITE HISTORY 1
1.3 SELECTED REMEDY IN THE OU-1 ROD 4
1.4 PROPOSED TREATMENT SYSTEM MODIFICATIONS 5
220 AGENCY REOUEST FOR INFORMATION 6
.1 INFLUENT 6
2.2 TREATMENT 7
2.3 EFFLUENT 8
2.4 SYSTEM STATUS 9
2.5 MONITORING 9
2_6 COST 10
2.7 SCHEDULE 11
2.8 SITE DESCRIPTION 12
3.0 SUMMARY 13
4.0 REFERENCES 14
TABLES
Table 1. Comparison of Inner Tier Ground -Water Quality and WWTP Effluent Quality
Table 2. Table 2. Iron and Manganese Concentrations in Simulated Wastewater Treatment Effluent
Table 3 Comparison of NPDES Sampling with Ground -Water Sampling
Table 4. CERCLA Sampling Matrix Following Proposed Modifications
FIGURES
Figure 1. CFO Site Plan —Shelby, NC
Figure 2. Mechanical Flow Diagram —Groundwater Treatment System (Plate P-02 from RD Report)
Figure 3. Proposed Modification to Groundwater Treatment Process
Figure 4. Groundwater Treatment System Piping Modifications

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Request to Modify Elements of the Records of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
ATTACHMENTS
Attachment 1. Talking Points —Proposed Modifications to Ground -Water Treatment
System —Celanese Fiber Operations Site —Shelby, NC (August 14, 2003)
Attachment 2. Letter From Ken Lucas (EPA), to Steve Olp, (Celanese), re: Talking Points Document
(September 12, 2003)
Attachment 3. Plan for Decommissioning the Ground -Water Treatment System at the CFO Site,
Shelby, NC.
ii

Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
1.0 INTRODUCTION
1.1 STATEMENT OF PURPOSE
CNA Holdings, Inc. (CNA)/Ticona has entered into discussions with the EPA Region IV (EPA) and the
State of North Carolina Department of Environment and Natural Resources (DENR) concerning proposed
modifications to the remedial alternative contained in the record of decision (ROD) for Operable Unit 1
(OU-1) at its site in Shelby, NC. The proposed modifications relate to the specific treatment unit and
processes described in the OU-1 ROD dated March 23,1988.
A formal request for consideration of the conceptual proposed modifications was initiated on behalf of
CNA by Kubal-Furr & Associates (Kubal-Furr) on August 14, 2003 with submittal to the EPA and DENR
of the document entitled: "Talking Points —Proposed Modifications to Ground -Water Treatment
System —Celanese Fiber Operations Site —Shelby, NC" ("Talking Points" [Attachment 1]). Subsequent
progress on the modifications included: (1) a conference call with the agencies on September 3, 2003; (2)
a request from the EPA to CNA on September 12, 2003 for additional information and clarification of
issues raised in the conference call; and, (3) a site visit of the Shelby facility on September 19, 2003.
The current document presents a formal request to the EPA to modify selected elements of the OU-1
ROD as described in more detail in later sections of this report. This request has been prepared in
accordance with current EPA guidance on conducting ROD reviews and preparing modifications and in
consideration of specific issues dealing with the Shelby site as discussed with the agencies during the
conference call and site visit. The document will discuss scope, performance and cost factors and is
intended to show that the proposed modifications: (1) will not affect the scope of the remedy selected in
the ROD; (2) that the performance and reliability will be equivalent, or greater, following the
modifications; and, (3) that continued long-term remedial actions at the CFO site will be implemented
more cost-effectively than currently is the case.
1.2 REVIEW OF SITE HISTORY
Ticona, an operating subsidiary of Celanese, owns and operates a polyester and engineering plastics
production facility in Shelby, North Carolina. CNA Holdings, Inc. also a subsidiary of Celanese, retains
management of environmental remediation matters for the site. The site consists of an approximate
450-acre piece of property which includes the main plant production area, wastewater treatment area,
1

Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
former waste disposal areas, and recreational areas. The plant is located in south-central Cleveland
County, bordered by NC Highway 198 to the west and Lavender Road to the south, approximately one
mile north of Earl and six miles south of Shelby. A site plan showing the location of production areas,
monitor wells, extraction wells, and other features is presented on Figure 1.
Operations at the site began in 1960 by Fiber Industries, Inc. (FII) a joint venture between Celanese and
ICI, and manufactured polyester chips and filament yarn. Celanese Corporation acquired ICI's interest in
1983, renaming it Celanese Fiber Operations (CFO), and continued the production and processing of
polyester polymer chips and fibers. The site has alternately been known as HNA Holdings, Inc., Hoechst
Celanese Corporation and Celanese Fiber Operations, the latter being the site name as listed on the
National Priorities List (NPL). The site will be referred to herein as the CFO site.
CNA and its predecessors have been conducting environmental investigations at the CFO site since 1981.
Remediation and clean-up activities based on these investigations have been on -going since 1988. The
site was proposed for listing on the NPL in October 1984 and work conducted since that time has
followed the formal RI/FS (remedial investigation/feasibility study) and RD/RA (remedial
design/remedial action) processes under CERCLA. The site was formally placed on the NPL in June of
1986.
A remedial investigation of the CFO site was completed in June of 1986 (S&ME, Inc., 1986). The
conclusions from the RI indicated the presence of organic and inorganic constituents in site soils,
sediments and ground water consisting of phthalates, phenols, polynuclear aromatic hydrocarbons,
ethylene glycol, and other semivolatile organics, volatile organics and metals. The RI concluded that the
probable sources of these constituents were from buried residual sludges from the Glycol Recovery Unit
(GRU) and buried burn pit materials.
Remedial activities at the CFO site were broken into two operable units: OU-1, consisting of ground-
water extraction, treatment and hydraulic control; and, OU-2, consisting of removal and treatment, via
on -site incineration, of contaminated source areas and stream sediments. OU-1 construction activities
began in October of 1988 and the extraction well system was placed in operation in August of 1989. The
ROD for OU-2 was issued on March 28, 1989. Site development activities at OU-2 began in September
of 1990 and active remediation and site restoration was completed by September of 1992.
2

Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
CNA continues to operate a long-term remedial action (LTRA) system at the CFO site as part of the
OU-1 ROD. The LTRA consists of two ground -water extraction and treatment systems identified as the
Inner Tier and Outer Tier systems. As part of this effort, CNA maintains and monitors the effectiveness of
the ground -water recovery and treatment system; collects quarterly ground -water levels and samples from
selected monitor wells and process points; and, reports the status of these activities to the EPA and DENR
on a semiannual basis.
On April 21, 1998, the Outer Tier portion of OU-1 was shut down as part of a partial delisting petition
approved by the EPA effective April 17, 1998 that deleted the Outer Tier extraction and treatment and
OU 2 source remediation from the NPL. The basis for the delisting of OU-2 included consideration of the
fact that all CERCLA response activities had been concluded at this operable unit and that the remedy
was protective of human health and the environment. The Outer Tier extraction well portion of OU-1 was
partially delisted on the following basis:
• Off -site domestic well sampling reported no detectable levels of Target Compound List (TCL)
organic constituents.
• A voluntary initiative by Hoechst Celanese, Corp. (HCC, now CNA) provided surrounding
residents downgradient of the CFO site with municipal water and plugged back supply wells,
thereby eliminating the human consumption exposure scenario.
• It would conserve a valuable ground -water resource and enhance the natural attenuation of
constituents remaining in the ground -water system by decreasing hydraulic gradients and
increasing the in -situ treatment times from the former source area toward the Outer Tier.
Currently, active ground -water recovery and treatment is only taking place at the Inner Tier, which was
designed to extract contaminated ground water from around the former source area remediated as part of
OU-2. Recovered Inner Tier ground water is treated biologically in a sequencing batch reactor (SBR)
which is capable of processing approximately 2500 gallons of water per day (gpd). The Inner Tier is
currently not capable of sustaining this flow rate due to a combination of the hydrogeological conditions
and geochemistry of the aquifer, and some probable iron fouling of the well screens.
3

MI
Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
The entire Outer Tier is being maintained in a "stand-by status" as part of the delisting process and can be
brought on line within a relatively short period of time if it is found necessary to provide hydraulic control
along the property boundary in the future. The Outer Tier wells and treatment system's functionality are
assured by performing routine monthly and quarterly system checks such as energizing the well pumps,
transfer pumps and blowers, verifying heater operation, etc. and performing maintenance activities as
required by the results/findings of the routine system checks.
I""* 1.3 SELECTED REMEDY IN THE OU-1 ROD
A Partial Consent Decree for OU-1 was entered on October 21, 1988. Section I(b), Statement of Purpose,
states: "(b) implement the remedial measure identified in the Record of Decision (ROD), signed March
23, 1988 and set forth in the Remedial Design Work Plan and Remedial Action Work Plan." While the
ROD and Remedial Design (RD) Report (S&ME, Inc, 1988) describe similar steps in the treatment of
recovered ground water, there is a discrepancy in the specific order in which the treatment steps are
presented in each. The ROD describes a remedy consisting of routing extracted ground water to a holding
tank followed by air stripping, biological treatment and carbon adsorption as required. The final RD
report describes similar steps but places air stripping after the biological treatment rather than before it.
The Remedial Action (RA) Report (RUST, 1993) for OU-1 indicates the only significant difference
between the RD and the system actually in place is the use of bladder and centrifugal pumps in the
extraction wells instead of pneumatic pumps.
RIO
The process presented in the RD report is the remedy that has been implemented at the CFO site. As
shown on Figure 2 taken from the RD report, it consists of the following steps:
am 1) Ground water is extracted from the Inner Tier and is routed to an equalization tank.
2) The pH is adjusted and coagulant added to facilitate iron removal.
3) The water is then routed to an inclined plate settling clarifier for iron removal.
4) The clarifier overflows to a biological treatment unit referred to as the sequencing batch reactor
(SBR).
5) Following treatment in the SBR, the treated ground water is routed through an air stripper.
6) After air stripping, the water is routed through a carbon adsorption unit prior to its discharge into
wastewater Polishing Pond A where it mixes with treated wastewater from the industrial
wastewater treatment plant.

Request to Modify Elements of the Record of Decision (ROD)
Pal Celanese Fiber Operations Site, Shelby, NC
Document Control Number 020SB-138
,,i, All of the treated wastewater, including the treated ground water, flows through a series of aerated
polishing ponds providing approximately 90 days detention time before it ultimately discharges through
the plant's NPDES Outfall 001. The treated effluent is then piped by gravity approximately two miles
faur
before it is discharged to Buffalo Creek. Sludge generated during the iron removal stage and from the
SBR are routed to a filter press where they are dewatered into a cake, tested annually for the full TCLP
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list of constituents and subsequently disposed of off -site as a non -hazardous waste. A block flow diagram
showing the steps in the existing and proposed ground -water treatment process is presented in Figure 3.
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1.4 PROPOSED TREATMENT SYSTEM MODIFICATIONS
The objectives for the OU-1 remediation are defined in the RD report as follows: "The objective of this
„w phase of the project is to prepare a Remedial Design (RD) for the groundwater extraction and treatment
system that will control further migration of the groundwater toward the site perimeter, and remove
contaminated groundwater for subsequent treatment and discharge."
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CNA's request to modify the OU-1 ROD is limited principally to the narrow issue of where biological
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treatment of extracted ground water is to occur. Currently, it takes place in the sequencing batch reactor
at the ground -water treatment building. CNA is proposing to reroute extracted ground water from the
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ground -water treatment building and SBR to the headworks of the site's existing wastewater treatment
facility for biological treatment (Figures 3,4). This proposed modification will provide an equivalent
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level of treatment for the extracted ground water and be much more cost effective than the current
scenario.
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CNA is not proposing any fundamental change to the scope of the ROD or its stated objectives. Ground -
as water extraction and treatment will continue and the basic pump and treat approach remains unaltered.
No alternate clean-up levels are being proposed with this modification request and .the clean-up levels
pm specified in the ROD continue to serve as the long-term remediation goals for ground water. Ground-
water quality will continue to be monitored; it will continue to be treated biologically; and, following
go treatment, will still discharge through the NPDES outfall with the rest of the plant's treated effluent.

Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
''"'a Document Control Number 026SB-138
2.0 AGENCY REQUEST FOR INFORMATION
In a letter dated September 12, 2003 (Attachment 2), the EPA and DENR requested clarification of
several items presented in the August 14, 2003 Talking Points document and discussed in the September
3, 2003 conference call. Review and elaboration on the various issues were also addressed during the
September 19, 2003 site visit.
The specific items raised in the September 12, 2003 correspondence from EPA are presented below in
italics followed by responses. A substantial amount of engineering evaluation and design consideration
have been required to address the various issues. In a desire to keep this document comprehensive, yet
readily accessible, each request for additional information is followed by a response that is either
complete or summarizes a more detailed analysis which may be contained in an attachment.
0.4
2.1 INFLUENT
Provide a table comparing the contaminants/concentrations present in the inner tier groundwater versus
those in the industrial wastewater being treated by the wastewater treatment plant
Specific data are not collected on the influent to the industrial wastewater treatment plant. However,
Fag
ethylene glycol, TOC, and VOCs data are collected on the Inner Tier influent and effluent ground water
on a quarterly basis. Additionally, a priority pollutant analysis is performed on the industrial wastewater
effluent once per permit cycle in the month prior to submitting the renewal application. The detected
chemicals in the ground -water influent and the corresponding effluent data for the ground -water treatment
system are summarized in Table 1. Corresponding data from the industrial wastewater effluent is
presented for comparison.
wo
During preparation of this document, impacts on the effluent concentration of iron and manganese were
evaluated to allay potential NPDES questions. Iron and manganese were found to be effectively removed
through the biological treatment process. Once oxidized, these materials are relatively insoluble and can
be removed with other process solids through existing unit operations. Table 2 presents a summary of the
projected removal of iron and manganese from the ground water by the site's aerobic wastewater
treatment plant. These results were simulated through bench -scale reactor testing by mixing ground water
from the Inner Tier wells with a sample of the plant's industrial wastewater and activated sludge, and then
aerating it for 24 hours.
6

Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
2.2 TREATMENT
Provide a table comparing the contaminants being treated by the existing treatment system, in
accordance with the Record of Decision, to those treated by the WWTP. Include in this comparison the
comparison of treatment technologies. This comparison should explain and demonstrate the ability of the
WWTP to replace the pH adjustment, coagulation, iron removal, biological treatment, air stripping, and
carbon adsorption functions performed by the existing groundwater treatment system. This comparison
should demonstrate that the proposed modification is not simply a way to address groundwater
contaminants by diluting them.
The Ticona Shelby Plant has operated both a ground -water treatment facility since 1989 and an industrial
wastewater treatment plant since the early 1970's. The ground -water treatment system consists of an
equalization tank, an inclined plate clarifier for iron removal, a sequencing batch reactor providing
biological treatment, sludge dewatering facilities, an air stripper, and granular activated carbon. The
effluent of this system has historically been combined with effluent of the industrial wastewater treatment
plant in Polishing Pond A, prior to tertiary filtration and discharge to the NPDES discharge.
As mentioned above, the aerobic biological process was simulated, in a recent bench scale test, to
determine whether oxidation, sedimentation, and filtration would occur to sufficiently remove iron.
Results indicated little to no impact on the effluent, with iron concentrations less than 0.1 mg/L (Table 2).
As the pump and treat system has progressed, the concentrations of VOCs and SVOCs requiring air
stripping, or granular activated carbon adsorption, have been reduced substantially. What remains of the
initial constituents of concern is primarily ethylene glycol, a highly degradable material. Removal of
ethylene glycol through the biological process is greater than 99%. A table providing a summary of
current ground -water quality is provided in Table 1.
As mentioned previously, unit operations provided at the ground -water treatment facility include
equalization, iron precipitation and removal, clarification, biological treatment via sequencing batch
reactor, air stripping of volatile organic compounds, and granular activated carbon absorption of other
organic materials. A block diagram comparing the current treatment process and the proposed
modifications is contained in Figure 3.
7

Request to Modify Elements of the Record of Decision (ROD)
mal Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
Under the proposed scenario, biodegradation will be provided in the facility's extended aeration activated
min sludge facility. Clarification will be provided along with separation of the return activated sludge. Iron
removal will be by incorporation into the biomass and removal through the current sludge wastage
pip
processes. Waste sludge will be processed as it is currently. Redirection of the ground water to the
industrial wastewater treatment plant allows the operation of a single sludge -processing unit.
Although the bulk of volatile organics have been removed from the ground water, it is known that
volatiles can be stripped through an activated sludge plant. Therefore, the air stripping unit process will
be replaced with the plant's aeration process. Hydrophobic materials that might be currently removed by
granular activated carbon will no doubt be removed through sorption into the biomass and removed
through normal sludge removal operations. Reference to these phenomena in activated sludge facilities
p.m can be found in a number of technical sources (EPA, 1982).
Mi, 2.3 EFFLUENT
Provide a table comparing the effluent monitoring requirements of the existing groundwater treatment
system to the monitoring requirements for the WWTP. The following questions should be answered in the
discussion: How does the existing NPDES monitoring requirements compare to the effluent monitoring of
FIR the existing groundwater treatment system? If the Superfund wastes were sent to the WWTP, would a
separate monitoring system be required to address contaminants present in the extracted groundwater?
Table 3 provides a comparison of the current effluent monitoring requirements of the ground -water
treatment system and the WWTP's NPDES permit. The ground -water treatment system effluent is
monitored quarterly and the WWTP effluent monitoring frequency varies from daily to semi-annually,
depending on parameter. As can be seen from Table 3, there is not a direct comparison between the
NPDES monitoring and the treated ground -water effluent monitoring. However, the overall impact of the
treated ground water is monitored through the existing NPDES monitoring since the ground water is part
of the permitted discharge. Furthermore, a priority pollutant analysis, which includes an analyte list
similar to the EPA Method 8260 analyte suite performed on the ground water, is performed on the
NPDES effluent every five years prior to permit renewal to see whether there are chemicals in the effluent
that would modify the permit testing requirements or would require regulation or specific monitoring.
Based on the parameters in the ground water, it is not anticipated that the NPDES requirements would
change if the ground water were redirected to the headworks of the WWTP. However, if review by

Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
NCDENR Division of Water Quality determined that additional testing was needed, then the additional
mei
testing would be performed.
not
2.4 SYSTEM STATUS
,•w Describe the future (post modification) disposition of the existing ground water treatment system. What
measures would be instituted to ensure the continuation of treatment operations should the industrial
plant operations be shut down?
The existing ground -water treatment system will remain in place but will undergo a systematic process of
idling. It will remain in idle status in the event it is needed in the future and will receive periodic
maintenance checks to assure its continued functionality.
The treatment systems components will be pressure washed and air dried. Equipment such as pumps will
be serviced in accordance with the vendors recommendations for equipment taken out of service and
placed in long-term storage. A plan for decommissioning the ground -water treatment plant has been
prepared and is contained in Attachment 3.
In the event the industrial plant operations were to shut down, CNA would retain responsibility for
continuing remedial actions at the site as successor to Hoechst Celanese Corporation. In this event,
Rim however, there would be no flow to the WWTP, and therefore, no need to continue its operation. In such
case, the ground -water treatment system would be reactivated, if necessary, and extracted ground water
+*�+ would be rerouted back to the ground -water treatment building for treatment until the CERCLA-related
clean-up goals were achieved, or until EPA approved an alternate remedial solution. Information in the
pm, literature and knowledge gained by CNA from operation of other sites suggests that the chemicals present
at this site can be naturally attenuated under the right geochemical conditions. Site -specific data are being
,,.q developed to determine whether monitored natural attenuation is a candidate remedy for this site.
2.5 MONITORING
Describe how the ground water being piped from the extraction wells to the WWTP will be monitored.
Who will assume this monitoring responsibility? Will it be done as part of the NPDES monitoring
requirements? Will there be any modifications to the quarterly and semi-annual monitoring of the well
MO; network?

Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
Ground water pumped from the Inner Tier extraction system enters a common header and is piped to the
ground -water treatment building. On a quarterly basis, CERCLA-related monitoring consists of
collecting both an Inner Tier combined influent sample (prior to treatment) and an Inner Tier effluent
sample (following treatment and before discharge to the polishing pond) to be analyzed for volatile
organics, total organic carbon and ethylene glycol. A similar combined influent sample will continue to
be collected on a quarterly basis from the rerouted ground water prior to its entry into the WWTP. There
will be no equivalent location to collect an Inner Tier effluent sample once it enters and becomes
combined with the existing WWTP flow.
In addition to the Inner Tier influent and effluent samples, samples of sludge from the filter press and
SBR are collected annually and analyzed for the full TCLP list of constituents to characterize the sludges
for proper disposal. Because the filter press and SBR will no longer be in service, the annual sludge
sampling from these process points will no longer be necessary.
CNA is the responsible party for the CERCLA-related remedial activities while Ticona is responsible for
NPDES sampling, compliance and reporting. These responsibilities will remain the same following
implementation of the proposed modifications.
CNA is currently responsible for the CERCLA-related ground -water monitoring which is conducted
quarterly and reported semiannually. No change is being proposed for the wells, parameters or frequency
of ground -water sampling and reporting under CERCLA. A matrix showing the sampling locations,
frequency and parameters to be analyzed following the proposed modifications is included as Table 4.
2.6 COST
Provide a table comparing the annual operation and maintenance costs of the existing system to those
costs anticipated in the Record of Decision. Also compare the annual cost incurred so far to the
anticipated cost after the modification. Include the initial capital costs to connect the groundwater
extraction system to the WWTP.
The ROD presented estimated construction and operation and maintenance (O&M) costs for the ground-
water extraction and treatment systems. However, neither the ROD nor the Final Feasibility Study (FS)
Report (S&ME, 1987) itemized the costs making up the estimated O&M. Both documents presented an
10

Awl
Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
estimated O&M expenditure of $1,069,230 for a 30-year operations period. The FS indicates that the
estimate was presented in 1987 dollars. This results in an approximate annual cost of $35,640 (1987
dollars). Escalating this cost at an average of 5% per year for the labor, materials, and services
composing traditional O&M activities would result in an average annual cost of about $77,800 in 2003
dollars.
Detailed information on historical operations and maintenance costs is not available. However, data are
available from 1999 through June 2003. Based on these data, the annual operation and maintenance costs
range between approximately $160,000 and $200,000. These are in the same order of magnitude as those
reported in the Five -Year Review Report (EPA, August 2001) for the 1996 through 1998 timeframes,
when less detailed information was available. Analysis of the post-1999 costs indicates that the annual
operating labor cost ranges between approximately $54,000 and $67,000, and annual maintenance labor
and materials ranges between approximately $28,000 and $52,000. The remainder of the annual cost is
for sampling, analysis, and reporting. The tracking of the maintenance labor and materials expenses did
not differentiate between the costs associated with the extraction system and the treatment system.
However, if we assume that at least a quarter of the labor maintenance and materials cost was associated
with the treatment system, then the annual cost savings would be on the order of $61,000 to $80,000, or
approximately 40% of the current annual operating cost.
Comparison of the ROD -estimated cost versus the actual costs shows the actual operation is significantly
more expensive than projected. Insufficient detail is presented in the available documentation of the FS
level cost to determine whether it represents a comparable work scope to actual O&M costs.
2.7 SCHEDULE
Please provide a schedule for implementation of the proposed modification.
Preliminary discussions have been held with Mark McIntire with the DENR Division of Water Quality,
Water Quality Section (DWQ-WQ) in the Raleigh Central Office and with Michael Parker with
DENR-DWQ-WQ in the Mooresville Regional Office about the permitting needs to implement the
proposed modifications. Both have indicated that they don't think the proposed changes would require an
NPDES permit modification, and may not need an Authorization to Construct (ATC) prior to
construction. The need for either of both of these items could significantly lengthen the schedule
presented below. Further discussions will be held with DENR-DWQ-WQ to verify the permitting
11

a�q
AMR
Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-138
requirements prior to commencing construction. Assuming that neither the NPDES permit modification
nor the ATC is needed, the following schedule is reasonable for modification of the system. This
schedule would be initiated after receipt of EPA and DENR approval to make the changes, and fulfillment
of the NPDES requirements.
• Engineering drawings, as needed, for contracting 30 days
• Contractor selection and contracting 30 days
• Piping modification to tie into WWTP 10 days
• Decommission GWTS (starting 3 months after modification) 30 days
2.8 SITE DESCRIPTION
Please prepare a site diagram showing pertinent site features and illustrating the proposed modification.
Include the site boundaries in the diagram; be sure to show whether the WWTP is within the site
boundaries or if it is "offsite".
A site plan showing the location of the plant production area, existing WWTP and the Groundwater
Treatment Facility are shown on Figure 1 along with the Inner Tier and Outer Tier extraction well
systems. A diagram showing the proposed modification rerouting ground water from the Inner Tier is
included as Figure 4. The WWTP, the Groundwater Treatment Facility and the polishing ponds are all on
property owned by Celanese. Further, from a CERCLA standpoint, the "site" has been defined to include
the entire parcel of land owned by Celanese and therefore, in this case, the site boundary and property
+tea boundary are synonymous.
RIM
ingl
,on 12

PM
Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
"" Document Control Number 026SB-138
3.0 SUMMARY
cm
In summary, CNA is requesting to modify very specific elements of the ROD for OU-1 at the Celanese
in+ Fiber Operations site in Shelby, NC. CNA's request to modify the OU-1 ROD is limited principally to the
narrow issue of where biological treatment of extracted ground water is to occur.
e
Currently, biological treatment of ground water takes place in the sequencing batch reactor at the ground-
water treatment building. Celanese is proposing to substitute biological treatment in the sequencing batch
reactor with biological treatment at the existing wastewater treatment. This document has demonstrated
that the proposed modification will provide at least an equivalent level of treatment for the extracted
cm
ground water and will be more cost effective.
xim
The objectives for the OU-1 remediation are defined in the Remedial Design Report as follows: "The
objective of this phase of the project is to prepare a Remedial Design (RD) for the groundwater extraction
ram+
and treatment system that will control further migration of the groundwater toward the site perimeter, and
remove contaminated groundwater for subsequent treatment and discharge." Celanese is not proposing
M' any fundamental change to the scope of the ROD or RD or the stated remedial objectives. Ground -water
extraction and treatment will continue and the basic pump and treat approach remains unaltered. No
WI alternate clean-up levels are being proposed with this modification request and the clean-up levels
specified in the ROD continue to serve as the long-term remediation goals for ground water. Ground-
water quality will continue to be monitored; it will continue to be treated biologically; and, following
treatment, will still discharge through, and be monitored at, the NPDES outfall with the rest of the plant's
cia+ treated effluent.
MR
PM
AM
Plor
Mel
pm 13

Awl
Request to Modify Elements of the Record of Decision (ROD)
Celanese Fiber Operations Site, Shelby, NC
Document Control Number 026SB-1 38
4.0 REFERENCES
RUST, 1993, Remedial Action Report —Operable Unit One Remedial Action —Celanese Shelby Fiber
Operations Superfund Site, (Document Control 85267-0394)
S&ME, 1988, Final Feasibility Study Report —Operable Unit 1—Ground-Water-Public Health
Assessment for Celanese Fibers Operations, (Document Control 85050A-0087)
S&ME, 1988, Remedial Design Report, (Document Control85050H-0114)
U.S. District Court for the Western District of North Carolina, October 24,1988, Partial Consent Decree,
United States of America v. Hoechst Celanese Corporation.
U.S. Environmental Protection Agency, Region IV, March 23,1988, Enforcement Record of Decision,
Summary of Remedial Alternative Selection, Celanese Fibers Operations Site, Shelby, North
Carolina.
U.S. Environmental Protection Agency, 1983, Fate of Priority Pollutants in Publicly Owned Treatment
Works: EPA 440/1-82/303.
U.S. Environmental Protection Agency, Region IV, 2001, Five -Year Review Report —Celanese Corp
(Shelby Fiber Operations) Site —Shelby, Cleveland County, North Carolina.
Westinghouse Environmental and Geotechnical Services, Inc., 1989, Project Operations Plan —Hoechst
Celanese/Shelby, NC Facility (Document Control 85050H-0132)
14

�1
Tables
n
n
n
n

1001
PEI
PEI
w•,
feml
fowl
foot
INNI
Table 1. Comparison of Inner Tier Ground -Water Quality and WWTP Effluent Quality
NPDES
Untreated
Groundwater
Treated
Groundwater
Flow, gpd
400,000
2,500
2,500
General Parameters (mg/L)
Biochemical Oxygen Demand
. 17
NA
NA
Chemical Oxygen Demand
172
NA
NA
Total Organic Carbon
21.2
2,145
514
Specific Organic Contaminants (mg/L)
2-butanone
NA
0.024
<0.005
acetone
NA
0.210
0.006
benzene
<0.002
0.018
<0.001
carbon disulfide
<0.002
0.0025
<0.001
chlorobenzene
<0.002
0.016
<0.001
cis-1,2-dichloroethene
<0.002
0.003
<0.001
ethylene glycol
NA
2016
<5
toluene
<0.002
0.0012
<0.001
trichloroethene
<0.002
0.0011
<0.001
Metals, (mg/L) °
aluminum
0.13
0.7
0.1
arsenic
<0.0005
0.008
<0.005
cadmium
<0.002
0.037
<0.002
chromium
<0.005
0.017
<0.005
copper
0.014
0.071
0.01
iron'
0.2
460
3
lead
<0.002
0.052
<0.003
manganese b
<0.01
98
3
nickel
<0.01
0.494
• <0.015
zinc
0.047
0.8
0.02
gpd - gallons per day
mg/L - milligrams/liter
' Metals data on groundwater quality is several years old. Values given are
order of magnitude, based on most recent data.
° Testing performed to simulate effluent impacts indicated that iron and manganese
were less than detection levels. This seems to imply that the bulk of iron and
manganese in the groundwater is in a form that can be incorporated with the
sludge and removed through normal operations of the wastewater treatment plant.
Request to Modify Elements of the Record of Decision
Celanese Fiber Operations Site, Shelby, NC

WI
fon
Mil
PM
FM
WI
f ml
Table 2. Iron and Manganese Concentrations in Simulated Wastewater Treatment Effluent
Sample
Iron
mg/L
untreated ground water
710
return activated sludge
1.8
influent wastewater
0.55
reactor
-
simulated effluent
<0.1
Pol mg/L - milligrams/liter
ml - milliliter
Manganese
Volume
Initial Reactor
Iron
Initial Reactor
Manganese
mg/L
ml
mg/L
mg/L
110
0.44
0.019
18.75
4.44
0.69
1500
0.90
0.22
1481.25
0.27
3000
5.61
0.01
0.92
<0.015
Request to Modify Elements of the Record of Decision
Celanese Fiber Operations Site, Shelby, NC

WI
Mil
full
PM
fr
furl
MEI
MT
Awl
IR
Mg
fon
FIEI
MR
Table 3 — Comparison of NPDES Sampling with Ground -Water Sampling
WWTP NPDES Sampling
Inner Tier Ground -water
Sample Parameters
Unit
Sample Parameters
Unit
daily flow rate
MGD
TOC
mg/L
temperature
Celsius
Volatile organics
(Method 8260)
mg/L
pH
units
ethylene glycol
mg/L
residual chlorine
mg/L
BODE, 20°C
lb/day
ammonia nitrogen
mg/L
total suspended residue
lb/day
fecal coliform (geometric
mean)
#/100mL
dissolved oxygen
mg/L
total nitrogen
mg/L
total phosphorus
mg/L
oil & grease
mg/L
chronic toxicity
P/F
COD
mg/L
total copper
mg/L
TSS
mg/L
Request to Modify Elements of the Record of Decision
a+ Celanese Fiber Operations Site, Shelby, NC

1 1 1 1 1 1 I 1 ] l J 1 1 1 1 1 1 1 1
Table 4. CERCLA Sampling Matrix Following Proposed Modifications
1st Quarter 2nd Quarter 3rd Quarter 4th Quarter
Monitoring TOC VOC Eth. Glycol TOC VOC Eth. Glycol TOC VOC Eth. Glycol TOC VOC Eth. Glycol
Location (9060) (82608) (GC/FID) 9060 (8260B) (GC/FID) 9060 (82608) (GC/FID) (9060) (82608) (GC/FID)
Process Points
ITC! J J J J J J J J J J J J
OTCI (OT Pumping Discontinued on 4/21/98)
Monitor Wells
C-49 J
K-28 J J
P-58 J
T-35
V-23 J J
AA-54
CC-33 J - - J
EE-58 J - J
FF-34 J J
FF-62 J J
GG-61 J J
HH-48 J J
HH-77
Notes:
TOC = Total Organic Carbon
VOC = Volatile Organic Compounds
Eth. Glycol = Ethylene Glycol •
GC/FID = Gas Chromatograph/Flame Ionization Detector
ITCI = Inner Tier Combined Influent
OTCI = Outer Tier Combined Influent
Request to Modify Elements of the Record of Decision
Celanese Fiber Operations Site, Shelby, NC

Figures

A-39 0
�F Plant
Production
T-' :r' Area
27/D-35/
D-56/D-88
-3
OF-55 Th10TI-2
PEW-3M• 1
PEWS 1 ,
G50/G5% • �!�
U-38
Recreation Pond
SW-5
W-8
Y-38/Y-74J
N-29/N-5
O 3
Property Bound
KK-27/KK-55
PZ-12
AA-41 /AA-54
O
8• —O41, AL 7\
PZ-
7B PZ-7A \
O AkPZ-6B
P-31/P-58
Polishing Pond
4-28/K-=p____,
IT c
/IT▪ -5 • > .17 2m/0 59 1
V-23N- -6 ti f i 1
Ia
IT-7 O
IT-8R O
IT-9 O C-33/C 64�
4
OT-10 i
1 a
e
laes
a
28/M-04
Sludge] n
Food
R-17/R-42
X-32
T-17/T58/ '- • PZ-8
T-85 O
Scale in Feet
0 350 700
OT-6A_PZ-10
,1PZ-6A
Q 33 O
OT-4
OT-6
PZ-5B ti 0 GG-25/GG39/
GG-61
OT-
PZ-5A
PZ-9
�F-23/FF-34
FF-62
PZ-1
PZ-3
Elliott
1
I-48/HH-741
Legend
O Monitor Well
A. Piezometer
▪ Surface Water Location
• Outer Tier Extraction Well
• Inner Tier Extraction Well
• PEW Extraction Well
o Residential Well
Creek / Stream
■ Building / Structure
Kubal-Furr & Associates
—Environmental Consultants —
Figure 1. CFO Site Plan
CNA Holdings, Inc./Ticona
Shelby, North Carolina

SODIUM HYDROXIDE PUMP
Y-P-1001
0-2. GPM 50'THD
1800 RPM1/2 HP
METERING TYPE
EQUALIZATION TANKS
Y-V-1000,Y-V-1007
3000 GAL
7'0 x 10'H
EPDXY LINED CARBON STEEL
EQUALIZATION MIXER
Y-M-1000
IMPELLER SS
1.5 HP
CENTRIFUGAL PUMPS
Y-P-1002,Y-P-1003,Y-P-1004
Y-P-1005,Y-P-1007,Y-P-1008
25 GPM 50'TDH
1.5HP
SEQUENCING
BATCH REACTOR
Y-V-1001
12' x 30' x 12'H
EPDXY LINED CARBON STEEL
SURGE TANK
Y-V-1002
4500 GAL
8'0 x 13'H
STAINLESS STEEL
AIR STRIPPING TOWERS
Y-V-1003.Y-V-1008
1441 x 14'H
FIXED MEDIA
FRP
SLUDGE PUMP
Y-P-1006
25 GPM 50'TDH
1.5 HP
POSITIVE DISPLACEMENT
CARBON COLUMNS
Y-V-1004,Y-V-1005,Y-V-1006
48"0 x 117" H
INNER TIER
WELL WATER
0
NaOH
55 GAL DRUMS
0
OUTER TIER
WELL WATER
POSSIBLE
METAL
TREATMENT
= ADDED LATER AS NEEDED
Y-V-1007 Y-P-1007
POLYMER`
PAC NUTRIENTS
4
hae
Y-V-1008 Y-P-1008
AIR STRIPPING
INLINE FILTER
LEGEND
AC - ANALYTICAL CONTOUR
AE - ANALYTICAL ELEMENT
AT - ANALYTICAL TRANSMITTER
VENT
LAH - LEVEL ALARM HIGH
LAL - LEVEL ALARM LOW
LC - LEVEL CONTROL
GATE VALVE NORMALLY OPEN
GATE VALVE NORMALLY CLOSED
CHECK .VALVE
CENTRIFUGAL PUMP
BLOWER
METERING PUMP
POSITIVE DISPLACEMENT PUMP
DRAIN
F TREATMENT EFFLUENT TO POLISHING
Y-V-1002. Y Y-P-1004 POND, COOLING TOWER OR IRRIGATION
Y-V-1003 Y-P-1005
AIR STRIPPING
3" CS
2" CS
NON -HAZARDOUS
TO WASTEWATER DIGESTER
HAZARDOUS SLUDGE
TO DISPOSAL
BACKWASH TO
WASTEWATER
DIGESTER
POND BACKWASH
1
Y-V-1004
Y-V-1005
Y-V-1006
TREATMENT EFFLUENT TO POLISHING
POND, COOLING TOWER OR IRRIGATION
TREATMENT EFFLUENT TO POLISHING
POND, COOLING TOWER OR IRRIGATION
Figure 2.
Hoechst' Celanese
Hoechst gel
SHELBY. NC
SCALE
NTS
MECHANICAL FLOW DIAGRAM
GROUNDWATER TREATMENT SYSTEMS
(Source: Remedial Design Report, S&ME, 1988) 92.
FLE4050C40
SHEET NO.
P-02

1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
Figure 3. Proposed Modification to Groundwater
Treatment Process
Groundwater from
Tier I and Teir II
Extraction Wells
Equalization Tanks
Inclined Plate Settler
Sequencing Batch
Reactor
Air Stripper
Granular Activated
Carbon
New Plpelne
Sludge Removed to
Holding Tank
Sludge Dewatering
and Disposal
ti
Ticona/KOSA
Industrial and Sanitary
Wastewater
Equalization Basins
1
Extended Aeration
Basins with Brush
Aerators
1
Clanfiers
Polishing Pond A
Polishing Pond B
Legend
Systems to be Mothballed for
future use
New piping to allow groundwater to be
treated in WWTP
Polishing Pond C
Pressure Sand
Filtration
♦
NPDES Discharge
Sludge Removed
to Settling Basin
Sludge Removal
and Disposal

EARTHT E C H
0' 100' 200'
SCALE
LEGEND:
OT-6 -t EXISTING OUTER TIER EXTRACTION WELL
IT-5 -I EXISTING INNER TIER EXTRACTION WELL
DECOMMISSIONED LINE OR STRUCTURE
NEW LINE
ASB AERATION SLUDGE BASIN
EQB EQUALIZATION BASIN
CL CLARIFIER
FLOW DIRECTION
OCT 2003
FIGURE 4
GROUNDWATER TREATMENT
SYSTEM MODIFICATION
KOSA/TICONA FACILITY
SHELBY. NORTH CAROLINA
40064.30.501

Attachment 1
"Talking Points —Proposed Modifications to Ground -Water
"" Treatment System —Celanese Fiber Operations Site— Shelby, NC
(August 14, 2003)

Awl
0?-6 5 - 1 —6
n•►
Post Office Box 273210
Tampa, FL 33688-3210
[phone]
FAX [phone]
Mr. Kenneth Lucas
U.S. EPA, Region 4
61 Forsyth Street
�.., Atlanta, GA 30303
Kubal-Furr & Associates
Environmental Management Services
August 14, 2003
Post Office Box 80247
Simpsonville, SC 29680-0247
[phone]
FAX [phone]
Dear Ken:
n
As you requested, attached is a hard copy version of the document entitled: "Talking
Points —Proposed Modifications to Ground -Water Treatment System —Celanese Fiber Operations
Site —Shelby, North Carolina" dated August 2003. I've also provided to you via email, a pdf
version of this same document.
The purpose for preparing the Talking Points is to provide both the EPA and the DENR with
sufficient information for a conceptual understanding of current conditions and proposed
modifications to the existing ground -water treatment system. It's not intended to be an exhaustive
presentation of issues at this point but one that will allow further discussion as to the appropriate
mechanism for effectuating this change at the Shelby facility.
Please give me a call after you've had a chance to review this information so that we can discuss
the next steps in the process. I would suggest we try and schedule a conference call with yourself,
DENR and Celanese representatives at your earliest convenience.
r�l
fon
Sincerely,
Jerry F. Kubal, P.G.
cc: David Mattison, DENR
Steve Olp, Celanese -Acetate
PEM Carter, Ticona-Shelby
Everett Glover, EarthTech

forl
Talking Points —Proposed Modification to Ground -Water Treatment
System —Celanese Fiber Operations Site —Shelby, North Carolina
Background
Ticona, an operating subsidiary of Celanese, owns and operates a polyester and
engineering plastics production facility in Shelby, North Carolina. CNA Holdings, Inc.
(CNA), also a subsidiary of Celanese, retains management of environmental matters for
the corporation
Operations at the site began in 1960 by Fiber Industries, Inc. (FII). Celanese
Corporation bought the facility from FII in 1983, renaming it Celanese Fiber Operations
(CFO). The site has alternately been known as HNA Holdings, Inc., Hoechst Celanese
Corporation and Celanese Fiber Operations, the latter being the site name as listed on the
NPL.
CNA currently operates a long term remedial action (LTRA) system at the CFO site,
designated as Operable Unit 1 (OU-1) in the Record of Decision (ROD), which consists
of two ground -water extraction and treatment systems identified as the Inner Tier and
Outer Tier systems. OU-1 became operational in August 1989. A second operable unit,
OU-2, consisted of excavation, incineration, stabilization and reburial of treated sludge
and other waste materials.
Current Ground -Water Treatment System
On April 21, 1998, OU-2 and the Outer Tier portion of OU-1 were shut down as part
of a partial delisting petition approved by the EPA effective April 17, 1998. Currently,
active ground -water recovery and treatment is only taking place at the Inner Tier, which
was designed to extract contaminated ground water from around a former source area
remediated as part of OU-2. A process flow diagram showing the current ground -water
treatment system is summarized on Attachment A.
Recovered Inner Tier ground water is treated biologically in a sequencing batch
reactor (SBR) which is capable of processing approximately 2500 gallons of water per
day (gpd). The Inner Tier is currently not capable of sustaining this flow rate due to a
combination of the physical make-up and geochemistry of the aquifer and biofouling of
the well screens. Therefore, even though the Outer Tier is not actively recovering ground
water, Outer Tier well OT-1R is still pumped to provide make-up water for the ground-
water treatment system and for process water used for back -flushing filters.
The remainder of the Outer Tier system is being maintained in "stand-by status" as part
rt
of the delisting agreement and can be brought on line within a relatively short period
of
time if it is found necessary to provide hydraulic control along the property boundary.
The Outer Tier wells and treatment system's functionality is assured by performing
routine monthly and quarterly system checks such as energizing the well pumps, transfer
Ticona/Shelby-Talking Points
1 August 2003

pumps and blowers, verifying heater operation, etc. and performing maintenance
activities as required by the routine system checks.
Water extracted from the Inner Tier, including make-up water as required from the
Outer Tier, is first routed to an equalization tank. At this point the pH is adjusted and
coagulant added to facilitate iron removal. Sludge generated during the iron removal
stage and from the SBR are routed to a filter press where they are dewatered into a cake,
rim tested annually for the full TCLP list of constituents and subsequently disposed of off -site
as a non -hazardous waste.
Fel Following treatment in the SBR, the treated ground water is routed through an air
stripper followed by carbon adsorption. At this point, the treatedground water is routed
to the existing industrial wastewater system where it enters a series of polishing ponds
and ultimately discharges through the plant's NPDES Outfall 001, continuing on to
Buffalo Creek.
'i' Ticona is currently permitted to discharge up to a monthly average of 800,000 gpd of
treated wastewater through Outfall 001. Representative flows used for the recent permit
renewal are 450,000 gpd as dry weather flow and between 600,000 and 750,000 gpd as
wet weather flow. An input of 2500 gpd from the ground -water treatment system
amounts to slightly more than one half of one percent of the dry weather flow.
Proposed Modifications to Ground -Water Treatment System
rim The proposed modifications would be to discontinue use of the Inner Tier treatment
e of
system as presented on Attachment A and route the Inner Tier water to the he
adworks the plant's industrial wastewater treatment plant (WWTP).The Outer Tier system would
Agreement. A process
be maintained in standby in accordance with the Partial Delisting g B.
flow diagram of the system after the proposed changes is shown on Attachment
The source of the ground -water impact being addressed is the former disposal of plant
process wastes. This has impacted ground water with generally the same suite of
chemicals that are currently processed in the WWTP. Thus, the existing treatment plant
r—+ should be able to satisfactorily treat the recovered ground water and a preliminary
evaluation was performed to estimate the treatment that would be received by a combined
wastewater stream consisting of the industrial wastewater and the extracted ground water
rim (Attachment C).
The analysis was based on a "projected" wastewater stream constructed by combining
0.1 the loadings from the industrial wastewater and the extracted ground water using the
most recent data available (January 2003 thru APril 2003). The analysis presented d
Attachment C demonstrates the viability of redirecting the small stream of extracted
ground water from the ground -water treatment unit to the head of the plant's industrial
wastewater treatment plant for treatment. It is our opinion that this modification can be
made without adversely affecting compliance with the NPDES permit.
rag
Ticona/Shelby-Talking Points 2 August 2003

F
The physical changes needed to divert the combined Inner Tier influent would be to
repipe the collection, header to the headworks of the WWTP. If needed, a small booster
pump station would be added to provide the needed lift to the WWTP. The preliminary
evaluation suggests that this will not be needed. In this scenario, the Outer Tier well(s)
1.1 that are currently being pumped for make-up water for the Inner Tier treatment system
would be idled, and the entire ground -water treatment system would be taken off line and
placed in a stand-by mode in the event that it was needed in the future.
Preliminary discussions have been held with state water quality personnel to identify
actions needed to address NPDES issues, and it appears that it would be a simple process
Rol to make the change from their perspective. They would need to see some data
(Attachment C) to assure themselves that the change would not result in NPDES
violations, but a permit modification would not be needed. Additionally, an Authorization
0.1 to Construct (ATC) would not be needed for a simple piping change.
r
Ticona/Shelby-Talking Points
3 August 2003

Pal
Attachment A.
Current Process Flow Diagram—Ticona, Shelby, NC
(
Outer Tier
Extraction
Wells
..
.1.0,
co
�>
g p
2
c
Inner Tier
Extraction
Welts
4/ Equalization
Tank
pH adjustment/
Coagulant
addition
Iron Removal
4�2500 gpd
Sequencing
Batch Reactor
(Biological)
Sludge/Non-
hazardous/
Off -site disposal
Air Stripper
)
s25oo gpd
Ticona/KOSA
Process
Waters
75,000 gpd (dry
Wastewater
Treatment Plant
(Biological)
d
Polishing Ponds
A/B/C
__1
NPDES Outfall 001
v
a
v)
0
0
0
0
in
v-
ir
Buffalo Creek

Poll
c
Attachment B.
Proposed Process Flow Diagram--Ticona, Shelby, NC
Outer Tier
Extraction
Wells
Maintain In
` Stand-by Mode J
If Pumping Resumed
Inner Tier Ticona/KOSA
Extraction ► Process
Wells Varies Waters
(current avg < 1500 gpd)
Wastewater
Treatment Plant
(Biological)
T
Row Rate To Be Determined
Carbon
Adsorption
Polishing Ponds
A/BIC
NPDES Outfail 001
•0
O.
0
0
0
0
0
Buffalo Creek

PSI
PIM
Attachment C.
Ticona Combined Effluent Evaluation
As a preliminary evaluation of the viability of incorporating the inner tier groundwater into the plant's
industrial wastewater treatment plant, an evaluation was performed to estimate the treatment that would
be received by a combined wastewater stream consisting of the industrial wastewater and the extracted
groundwater. As a basis for this evaluation, relevant data on the two wastewater streams from the period
of January 2003 through April 2003 were reviewed. This timeframe was selected since it represented the
most recently available data. The analysis was based on a "projected„ wastewater stream constructed by
combining the loadings from the industrial wastewater and the extracted groundwater during the period of
January 2003 and April 2003. The data are summarized in the following table.
flow (MGD)2
minimum
Daily
Wastewater
Influent
maximum
average
median
0.196
Daily
Wastewater
Effluents
0.265
Daily
Groundwater
0.0002
Daily Combined
Influent
(Projected)
0.834
0.492
chemical oxygen
demand (COD)
(lbs/day)2
minimum
0.489
0.824
0.512
0.529
0.003
0.0018
0.0019
0.198
0.836
0.494
0.491
maximum
average
median
1433
111
10
11,954
4881
4479
744
152
1510
12,069
330
321
86
86
4965
4581
biochemical
oxygen demand
(BOD5) (lbs/day)
minimum
12
maximum
average
median
— The data on the effluent includes the impacts of discharge of the treated groundwater into the wastewater
polishing ponds after aerobic biological treatment of the groundwater.
— The values represent the minimum, maximum, etc. of the daily values for type of information, and are not
directly additive across the rows.
The plant routinely measures BOD5 and COD on the effluent, and COD on the influent. The control
parameter in the plant's NPDES permit is BOD5. In order to estimate the impacts of adding the
groundwater stream to the wastewater stream at the head of the wastewater treatment plant, the data were
evaluated to estimate the overall removal efficiency of the treatment plant, and a relationship between
BOD5 and COD. The overall efficiency was calculated by comparing the influent COD (lb/day) of the
plant's industrial wastewater and the effluent COD (lb/day) of the entire flow that discharges through the
NPDES effluent point. This simplified approach does not account for the residency time of the
wastewater in the system, or the effects of precipitation and storm water on the open wastewater basins;
however, when calculating an average efficiency over approximately 4 months of daily data, it is
expected to give an approximate estimate of the efficiency of the overall wastewater system. This
analysis estimated that the average COD removal efficiency of the treatment system was 92.83%.
Since the control parameter for the NPDES permit is BOD5, the BOD5 and COD data were compared to
determine whether there was a predictable correlation between the two parameters. Comparison of the
76
36
35
Att C/Ticona/Shelby-Talking Points
1 August 2003

mit
Attachment C.
Ticona Combined Effluent Evaluation
data showed appreciable scatter. The BOD5:COD ratio ranged from 0.0472 to 0.2468 with an average
value of 0.1061 and a median value of 0.1. As part of this evaluation, the BOD5:COD ratios were plotted
against the COD to see whether the ratio was a function of COD. This evaluation also resulted in
appreciable data scatter with the best -fit line showing a slightly decreasing trend at higher COD values.
However, this trend was not considered significant enough to warrant using different ratios for different
COD ranges. As a result of the scatter in the data, use of some standard deviation around the mean was
selected as a conservative approach for estimating the BOD5:COD ratio that would be used for predicting
the impact of adding the groundwater to the head of the wastewater treatment plant. For this analysis, a
value representing the mean plus two standard deviations was selected. This resulted in a BOD5:COD
ratio of 0.1796 being used for analysis of the combined wastewater stream.
The plant's NPDES permit (NC0004952) contains discharge limits for BOD5 of 83 lbs/day as a monthly
average, or 203 lbs/day for a daily maximum. Using a BOD5:COD ratio of 0.1796, this establishes an
allowable COD of 462 lbs/day for a monthly average or 1130 lbs/day for a daily maximum to remain in
compliance with the permit. As shown in the following table, the predicted COD levels are below the
allowable levels to maintain permit compliance applying a conservative conversion factor based on a
value two standard deviations above the mean of the measured data.
flow (MGD)
minimum
Daily
Wastewater
Influent
0.196
Daily
Groundwater
0.0002
maximum
0.834
0.003
average
median
0.492
0.489
0.0018
0.0019
chemical oxygen
demand (COD)
(lbslday)
minimum
1433
10
maximum
average
median
11,954
4881
biochemical
oxygen demand
(BOD5) (lbs/day)
minimum
4479
152
86
86
Daily
Combined
Influent
(Projected)
0.198
0.836
0.494
0.491
1510
12,069
4965
4581
Daily
Combined
Effluent
(Projected)1
108
865
356
328
Monthly
Average
Combined
Effluent
(Projected)1
19 •
54
maximum
1
average
median
— Based on an overall average COD removal efficiency of approximately 93% and a BOD5:COD ratio of
0.1796
In summary, the analysis presented in the preceding paragraphs demonstrates the viability of redirecting
the small stream of extracted groundwater from the groundwater treatment unit to the head of the plant's
industrial wastewater treatment plant for treatment. It is our opinion that this modification can be made
without adversely affecting compliance with the NPDES permit.
155
64
80
64
61
59
Att C/Ticona/Shelby-Talldng Points 2
August 2003

MI
Attachment 2
Letter from Ken Lucas (EPA) to Steve Olp (Celanese)
re: Talking Points Document (September 12, 2003)

SEP 12 2003 17:14 FR GLOBAL REMEDIATION 704 554 2407 TO 78132653649 P.02/03
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY . r ;!
REGION 4 ' _
ATLANTA FEDERAL CENTER 1Ie4--+ .. - . '', i ;
.;I 1
61 FORSYTH STREET I , s 1, I
ATLANTA. GEORGIA 3030348960 t1 L j 20
Mr. Steve Oip
Celanese Corporation
2300 Archdale Drive
Charlotte, North Carolina 28210
Subject: "Talking Points --Proposed Modifications to Ground -Water Treatment System
Celanese Fiber Operations Site --Shelby, North Carolina"
Dear Mr. OIp:
The purpose of this letter is to present concerns which must be addressed prior to further
consideration of the proposed modifications to the existing ground -water treatment system as
presented in the, 'Talking Points —Proposed Modifications to Ground -Water Treatment System --
Celanese Fiber Operations Site --Shelby, North Carolina", dated August 2003.
The U. S. Environmental Protection Agency (EPA), in consultation the North Carolina
Department of Environment and Natural Resources (NCDENR), has reviewed the document and
request clarification with respect to several matters. These matters are identified below:
Influent - Provide a table comparing the contaminants/concentrations present in the
recovered inner tier groundwater versus those in the industrial wastewater being treated
by the wastewater treatment plant (WW" rP).
Treatment - Provide a table comparing the contaminants_beine treated by the existing
treatment system, in accordance with the Record of Decision, to those treated by the
WWTP. Include is this comparison the comparison of treatment technologies. This
comparison should explain and demonstrate the ability of the WWTP to replace the'pil
adjustment, coagulation, iron removal, biological treatment, air stripping, and carbon
adsorption functions performed by the existing groundwater treatment system. This
comparison should demonstrate that the proposed modification is not simply a way to
address the groundwater contaminants by diluting them.
Effluent - Provide a table comparing the effluent monitoring requirements of the existing
groundwater treatment system to the monitoring requirements for the WWTP. The
following questions should be answered in the discussion: How do the existing NPDES
monitoring requirements compare to the effluent monitoring of the existing groundwater
treatment system? If the Superfund wastes were sent to the WWTP, would a separate
monitoring system be required to address the contaminants present in the extracted
groundwater?
,ntaarnet Address (VRLJ • nalp:llwww.epagov
natyctte/RsoyetaN.. Pdnivd MIA vegetable on ese d Mint an nevoid Pspar Mni mum 30% P0sla:aremanott
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5LN id dribs iY:i5 t-K ULUi3HL t&MEDIHiIUN 704 554 2407 TO 76132553649 P. 03/03
Sep-12-01 01 Moe Free -North Svaertund [phone] T011T P.003/003 F-T36
System Status - Describe the future (post modification) disposition of the existing
ground water treatment system. What measures would be instituted to ensure the
continuation of treatment operations should the industrial plant operations be shut down?
Monitoring - Describe how the ground water being piped from the extraction wells to the
WWTP will be monitored. Who will assume this monitoring responsibility? Will it be
done as part of the NPDES monitoring requirements? Will there be any modifications to
the quarterly and semi-annual monitoring of the well network?
Cost - Provide a table comparing the annual operation and maintenance costs of the
existing system to those costs anticipated in the Record of Decision. Also compare the
annual cost incurred so far to the anticipated cost after the modification. Include the
initial capital costs to connect the groundwater extraction system to the WWTP.
Schedule --Please provide a schedule for implementation of the proposed modification,
Site Description - Please prepare a site diagram showing pertinent site features and
illustrating the proposed modification. Include the site boundaries in the diagram; be
sure to show whether the WWTP is within the site boundaries or if it is "offsite."
Please prepare a revision, or supplement, to the Talking Points document which addresses
each ofthe concerns identified above. EPA, in consultation with NCDENR, will use this
information to assist in a determination of the feasibility of the proposed ;modification to the
existing treatment system. Additionally, the September 19, 2003 site visit may reveal additional
matters which will influence EPA's and NCDENR's determination ofthe feasibility of the
proposed modification. I look forward to our meeting on -site next week. If you have any
questions, feel free to call me at 404-562-8953.
Sin erely
Kenneth A. Lucas
Remedial Project Manager
North Site Management Branch
2
** TOTAL PAGE.03 **

Attachment 3
Decommissioning Plan
Groundwater Treatment System
Ticona (CFO) Facility, Shelby NC

rail
pp,
The groundwater treatment process is being proposed for modification to allow the Ticona on -site
Mil wastewater treatment system to treat the extracted groundwater. Once the modification has been
completed, the existing groundwater treatment system will no longer be in use. However, the system will
mot be maintained in functional condition for potential future use, if needed. This plan outlines how the
treatment system will be taken out of service in order to maintain the system in operable condition.
fool
Decommissioning each unit in the order listed in the following paragraphs should allow wash water to
travel from the head of the plant to the effluent without washing units more than one time. The procedure
is presented in outline, step-by-step format.
Decontamination
A wash -down area large enough to clean each piece of equipment will be identified. The selected area
will contain the water from the cleaning procedures and will also have a way of transporting this water to
/El a treatment unit. The most likely location will be inside the treatment building. An area outside the
treatment building could be ringed with sandbags and lined with polypropylene, with a small sump pump
located at the low end of the area, if the inside area is not practical.
A pressure washer will be used for decontamination. After pressure washing, each piece of equipment
WI
will be rinsed with process water and allowed to air dry.
m
Treatment System
mil Treat all water remaining in the system following normal operating procedure. Decant the batch reactor
system and pump remaining sludge to the digester.
r•
SIudge Treatment System
mil
Pressure wash the clarifier and pump wash water to the batch reactor. Remove polymer feed line and
flush all lines. Flush head assembly by placing polymer input tube into a container of mineral oil.
Fing
Operate pump until head assembly is clear of polymer and lubricated with oil. Metering pumps for
caustic and nutrients can be cleaned in the same manner.
PM
Drain clarifier and sludge pump. Air dry completely. Coat the interior surface of the pump with mineral
mit oil. Clean all surfaces of the filter press completely and air dry.

Batch Reactor
Pressure wash the interior of batch reactor, and rinse with process water. Pump water through system and
discharge to the head of the wastewater treatment facility. Air-dry all exposed surfaces.
Storage Tanks
Pressure wash the interior of each of the storage tanks (inner tier, outer tier, decant and sludge tank).
Pump the mixture through the system and discharge to the head of the wastewater treatment facility.
Rinse with process water and pump to Pond A. Air-dry tank interior with forced air by placing a fan or
blower at the tank entrance.
Pumps and Valves
Disconnect pumps and pressure wash interiors, rinse with tap water. Air dry completely. Treat interior
surfaces as recommended by the equipment manufacturer for storage of out of service equipment. Also
coat interior surfaces of valves where possible.
pH probes
Remove pH probes and clean as per normal procedure. Cap and store the probes for possible reuse
Air Strippers
Remove and dispose media from strippers in accordance with applicable regulations. Pressure wash
interior and air dry.
Carbon Filters
Backwash filters then remove media, pressure wash vessels, if possible, and air dry. Dispose the media in
accordance with applicable regulations.
Miscellaneous
Remove all drums of material from the ground -water treatment area and use surplus at the existing
wastewater treatment plant.

Lock out and tag out the motor control center (MCC). Provide sufficient heat to protect the building from
freezing, and check building periodically.
pmq
fool