Five-Year Review Report
Second Five-Year Review Report
for the Allied Chemical and Ironton Coke Superfund Site
Lawrence County, Ohio
September 2004
PREPARED BY:
United States Environmental Protection Agency
Region 5
Chicago, Illinois
Approved by:
C
Richard C. Karl, Acting Director
Date:
q - / 3 - 0 ~
Superfund Division
Table of Con tents
Section Page
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... List of Acronyms 111
ExecutiveSummary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
Five-Year Review Summary Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
I . Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
I1 . Site Chronology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
I11 . Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Physical Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9
LandandResourceUse . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
History of Contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 0
InitialResponse . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Basis for Taking Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1.2
IV . RemedialActions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 8
Remedyselection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 9
Operation and Maintenance (O&M) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 0
V . Progress Since the Last Five-Year Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 8
VI . Five-Year Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -39
Administrative Components . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3.9
Community Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 0
DocumentReview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 0
DataReview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
SiteInspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
Interviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
VII . Technical Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
Question A: Is the remedy functioning as intended by the decision documents? . . . . . .4 5
Question B: Are the exposure assumptions. toxicity data. cleanup levels. and
remedial action objectives (RAOs) used at the time of the remedy still valid? . . . . 48
Question C: Has any other information come to light that could call into question
the protectiveness of the remedy? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4 9
Technical Assessment Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5. 0
VIII . Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
Section Page
IX. Recommendations and Follow-up Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1
X. Protectiveness Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1
XI. NextReview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
Appendices
I. Maps
1 - Site Location
2 - Property Boundaries I Operable Unit Locations
3 -Ground Water Contour Map
11. Photographs
1 - Site Re-Use
2 - Lagoon Conversion
3 - Biomass I Coke Fines
4 - Biomass I Coke Fines
5 - Biomass 1 Coke Fines
6 - Biomass 1 Coke Fines
7 - Biomass 1 Coke Fines
8 - Biomass I Coke Fines
9 - Floodwall Revegetation
10 - Lagoon Revegetation
11 - Fish Collected from Converted Lagoon
12 & 13 - Lagoon Before & After Wetland Conversion
14 - WWTP NPDES Monitoring Location
15 & 16- GDA
111. Other Supporting Documentation
1 - Site Inspection Checklist
2 - Sign-in Sheet for Pre-Inspection Meeting
3 - Five Year Review Public Notice
4 - First Five Year Review (1999)
List of Acronyms
AOC Administrative Order on Consent
ARARs Applicable or Relevant and Appropriate Requirements
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR
CIC
COCs
CPLA
EPA
GDA
GPM
ICs
MCLs
NCP
NPL
OAC
OEPA
O&M
ou
ou1
OU2
OU3
PRPs
RA
RAO
RCRA
RD
RI/FS
ROD
FWM
svoc
TBC
UAO
WWTP
Code of Federal Regulations
Community Involvement Coordinator
Contaminants of Concern
Coke Plant / Lagoon Area
United States Environmental Protection Agency
Goldcamp Disposal Area
Gallons Per Minute
Institutional Controls
Maximum Contamination Levels
National Contingency Plan
National Priorities List
Ohio Administrative Code
Ohio Environmental Protection Agency
Operation and Maintenance
Operable Unit
Operable Unit 1, Goldcamp Disposal Area
Operable Unit 2, Coke Plant / Lagoon Area
Operable Unit 3, Tar Plant
Potentially Responsible Parties
Remedial Action
Remedial Action Objective
Resource Conservation and Recovery Act
Remedial Design
Remedial Investigation/Feasibility Study
Record of Decision
Remedial Project Manager
Semi-volatile Organic Compound
To Be Considered
Unilateral Administrative Order
Waste Water Treatment Plant
Executive Summary
The remedies for the Allied Chemical and Ironton Coke Plant Site in Lawrence County, Ohio
included: excavation and proper disposal of contaminated soil, use of certain excavated materials
as alternative fuels, installation ofcontainment systems (slurry wall, RCRA cap, hydraulic extraction
systems), treatment of contaminated groundwater in an on-site waste water treatment plant, site-wide
groundwater monitoring system, and reuse of the properties (one area has been converted into a
wetlands and another area has been converted into an industrial use property and sold to the City of
Ironton and the State of Ohio Department of Transportation for use as a DOT facility).
The trigger for this Five-Year Review is the completion of the last Five-Year Review on August 27,
1999.
The assessment of this Five-Year Review found that the remedy at the Allied Chemical and Ironton
Coke Site is protective of human health and the environment because threats at the Site have been
addressed through excavation and disposal of contaminated soil, capping of contaminated soil,
maintaining inward hydraulic gradients within the former waste pit, maintaining a groundwater
capture zone beyond the boundary of the known extent of groundwater contamination, installation
of fencing and warning signs, and implementation of institutional controls.
Five-Year Review Summary Form
Site name (from WasteLAN): Allied Chemical and lronton Coke Superfund Site
EPA ID (from WasteLAN): OHDO4373021 7
Has site been put into reuse? YES NO
Region: 5
- - - - -- -- ---
NPL status: Final 0 Deleted Other (specify)
Remediation status (choose all that apply): 0 Under Construction Operating
Complete
Lead agency: rn EPA State Tribe Other Federal Agency
Multiple Operable Units
(OU)? rn YES
0 NO
State: OH
Construction completion date:
NIA
Review period: January, 2004 through August, 2004
CitylCounty: City of lronton I Lawrence County
Author name: Sharon Jaffess
Date of site inspection: July 28, 2004
Author title: Remedial Project Manager
- - - -
Type of review:
Post-SARA Pre-SARA NPL-Removal only
0 Non-NPL Remedial Action Site NPL Statenribe-lead
Regional Discretion)
Review number: 1 (first) 2 (second) 0 3 (third) 0 Other (specify)
Author affiliation: U.S. EPA, Region 5
Triggering action:
0 Actual RA On-site Construction at OU #- Actual RA Start at OU# -
0 Construction Completion Previous Five-Year Review Report
0 Other (specify)
Triggering action date (from WasteLAN): August 27, 1999
- - - - -- -
Due date (five years after triggering action date): August 27, 2004
Five-Year Review Summary Form, cont'd.
Issues:
Iron fouling of wells and protracted capture zone in one sector of the Site due to lowering of
pumping rate and higher than normal precipitation.
Coke fines from the Site were transported to Biomass Energy LLC (Biomass) at the nearby
South Point Superfund Site, and these coke fines were to be used as alternative fuel source
for an incinerator. Biomass has not yet received a permit to operate their proposed
incinerator and the coke fines are stored in a gutted building at the South Point Superfund
Site which doesn't provide protection from wind erosion and precipitation.
Recommendations and Follow-up Actions:
Honeywell has hired a contractor, Mole Master, to rehabilitate wells and piping, is increasing
extraction pumping rates, and will drill a replacement extraction well, if necessary.
Ohio EPA attempted enforcement action against Biomass. Biomass has not yet complied.
Ohio EPA has requested EPAYs assistance. EPA has discussed the issue with Honeywell.
Honeywell claims that because it sold the coke fines to Biomass, it is unable to take any
action. EPA will contact Biomass to alert them that the coke fines appear to be improperly
stored and to request that Biomass allow Honeywell to reclaim the material for proper
disposal, since the material is not being used as an alternative fuel.
Protectiveness Statement:
The remedy at the Allied Chemical and Ironton Coke Superfund Site is protective of human health
and the environment because threats at the Site have been addressed through removal of
contaminated soil, capping of contaminated soil, maintaining groundwater levels that cause inward
hydraulic gradients and capture all of the contaminated groundwater, installation of fencing and
warning signs, and implementation of institutional controls.
Other Comments:
None.
ALLIED CHEMICAL AND IRONTON COKE SUPERFUND SITE
LAWRENCE COUNTY, OHIO
FIVE-YEAR REVIEW REPORT
I. INTRODUCTION
The purpose of the Five-Year Review is to determine whether the remedy at a site is protective of
human health and the environment. The methods, findings, and conclusions of reviews are
documented in five-year review reports. In addition, five-year review reports identify issues found
during the review, if any, and identify recommendations to address them.
The United States Environmental Protection Agency (EPA) is preparing this Five-Year Review
Report pursuant to CERCLA §121 and the National Contingency Plan (NCP). CERCLA §121
states:
If the President selects a remedial action that results in any hazardous substances, pollutants,
or contaminants remaining at the site, the President shall review such remedial action no less
often than each five years after the initiation of such remedial action to assure that human health
and the environment are being protected by the remedial action being implemented. In addition,
if upon such review it is the judgment of the President that action is appropriate at such site in
accordance with section [104] or [106], the President shall take or require such action. The
President shall report to the Congress a list of facilities for which such review is required, the
results of all such reviews, and any actions taken as a result of such reviews.
EPA interpreted this requirement further in the NCP. 40 CFR §300.430(f)(4)(ii) states:
If a remedial action is selected that results in hazardous substances, pollutants, or contaminants
remaining at the site above levels that allow for unlimited use and unrestricted exposure, the
lead agency shall review such action no less often than every five years after the initiation of the
selected remedial action.
EPA, Region 5, conducted the Five-Year Review of the remedy implemented at the Allied Chemical
and Ironton Coke Superfund Site (Site) in Lawrence County, Ohio. This review was conducted by
EPA in consultation with Ohio EPA (OEPA) from January, 2004 through August, 2004. This report
documents the results of the review.
This is the second Five-Year Review for the Site. The triggering action for this statutory review is
the completion of the first Five-Year Review on August 27, 1999. This Five-Year Review is
required because hazardous substances, pollutants, or contaminants remain at the Site above levels
that allow for unlimited use and unrestricted exposure.
II. SITE CHRONOLOGY
Event
Ironton Solvay Coke Company builds a Coke
Plant.
Merger of companies creates Allied
Chemical.
Allied builds a Tar Plant.
Allied uses a sand and gravel pit (later called
the Goldcamp Disposal Area) to dispose of
Tar Plant process wastes. Other nearby
companies also use the pit for disposal.
Allied builds a series of lagoons to treat waste
from coking operations.
Allied prepared a closure plan for the
Goldcamp Disposal Area and submitted it to
the Ohio EPA. Closure work included a
groundwater investigation, removal of
standing liquids, and placement of a clean soil
fill.
Allied applies for a RCRA Interim Status
permit for the lagoons.
Allied ceases operations at lagoons because
no permit is issued (application was filed late
and facility failed to achieve RCRA Interim
Status).
Ohio EPA requests that the property be listed
on the NPL.
Site proposed for the NPL.
Final listing on the NPL.
EPA performs Site Assessment.
Phase I of a Remedial Investigation initiated
by EPA.
Date
1917
1920
1945
1945 - 1977
1970s
1977-1980
1981
1982
1982
December 1982
September 8, 1983
October 1983
Late October 1983
Event
Negotiations between Allied, EPA, and
OEPA concerning performance of the
Remedial Investigation and Feasibility Study
by Allied under Agency oversight.
Administrative Order on Consent for
RI/FS signed.
Draft RI Report submitted by Allied.
Final RI Report submitted by Allied.
Site divided into two operable units:
Goldcamp Disposal Area (GDA or OU1) and
Coke Plant/Lagoon Area (CPLA or OU2).
Administrative Order on Consent for
Removal Action, providing for the removal
of tanks at the Coke Plant.
OU1 Feasibility Study and Endangerment
Assessment completed.
EPA published notice of FS completion and
issued a Proposed Plan for public comment
forOUl.
EPA issued notice letters to Allied and
AMCAST pursuant to Section 122(e)(2)(A)
of CERCLA requesting a good faith offer for
implementation of the OU1 remedy
OU1 Public Meeting
OU1 Record of Decision (ROD) signed.
OU1 RI/FS Complete
Unilateral Administrative Order (V-W-89-
C-007) issued to Allied and AMCAST for
performance of Remedial Design and
Remedial Action (RD/RA) pursuant to the
ROD.
OU1 Pre-Design Investigation
Date
October 1983- April 1984
April 13, 1984
February 1985
July 1986
Late summer 1986
March, 1987
July 1988
August 8, 1988
Augusts, 1988
August 16, 1988
September 29, 1988
September 29, 1988
March 9, 1989
1990-1991
Event
Allied initiates OU2 FS
OU1 RD Start
OL2 ROD signed
OU2 Unilateral Administrative Order
(UAO) issued to Allied for performance of
OU2 Remedial Design and Remedial
Action (RD/RA).
OU1 Remedial Design
OU1 Design Report submitted and finalized
OU1 construction of perimeter barrier (slurry
wall)
OU1 RA Start
OU2 Pre-Design Field Investigation Reports
submitted for bioremediation, groundwater,
and beneficial waste fuel recovery
OU2 (Ice Creek) quarterly monitoring
program initiated
OU2 Submission of bioremediation and
groundwater and facilities engineering
preliminary design reports
OU1 construction of wells
OU 1 Remedial Action Monitoring Plan
submitted
OU2 Initiation of site preparation work,
including geotechnical field investigation in
support of remedial action facilities
construction and excavation and on-site
stockpiling of soils area No. 4
Date
Early 1989
March 9, 1989
December 28, 1990
July 1, 1991
1991-1993
September 1992 - December 1993
1993 - 1994
Jury 15, 1993
September 9, 1993
October 12, 1993
November 13, 1993
1994
April 1994
April 25, 1994
OU1 RD Complete May 10, 1994
OU2 Submission of bioremediation and May 14, 1994
groundwater intermediate design report
Event
OU1 construction of RCRA subtitle C
compliant cap, passive gas venting system,
groundwater extraction system, and other
general construction
OU1 Perimeter Barrier Installation Report
documents compliance with slurry wall
performance standards (1 x 10~8 cm/sec
permeability).
OU1 Cap/Pump and Treat Installation Report
documents that the cap permeability (1 x 10"7
cm/sec permeability) and performance
standards are met.
OU1 Well Installation Report documents
compliance with construction performance
standards and documents that the
groundwater pump and treatment system is
operational and functional.
OU1 EPA Final Inspection of construction
OU1 EPA determination of Operational
and Function
OU1 Remedial Action Report, documenting
completion of remedial actions for the GDA
(perimeter barrier / slurry wall construction,
well installation, multimedia cap,
groundwater collection system, and
groundwater treatment) submitted.
OU1 RA Report Final Approval & RA
Complete
OU2 initial phases of site soils field
investigation performed
OU2 Construction of stormwater retention
pond completed
OU2 & OU1 EPA issues ROD amendment
#1
Date
1995
March 1995
September 1995
January 1995
August 2, 1995
August 2, 1995
September 19, 1995
September 19, 1995
July 27, 1994 -June 13, 1995
July 3 1,1 995
July 31, 1995
Event
OU2 Submission of bioremediation and
groundwater pre- final design report
OU2 Remedial Action construction contract
awarded for bioremediation and groundwater
and facilities components
OU2 Allied submits petition to EPA to
review the OU2 remedy
OU2 Construction halted on in-situ
bioremediation component of remedy while
petition under evaluation
OU2 Excavation and back filling of AC Soils
area completed; materials disposed off-site
OU2 Lagoon No. 5 field characterization and
boring program completed
OU2 Start-up of modified waste water
treatment plant and groundwater pumping
system operations
OU2 Quarterly groundwater monitoring
program initiated
OU2 EPA issues ROD amendment #2
OU2 Removal of ROD Soils Area No. 4
stockpiled materials (previously excavated in
1995); materials disposed off-site
OU2 Excavation and backfilling of Neal
Junkyard portion of ROD Soils Area No. 1
completed; materials disposed off-site
OU2 Excavation and backfilling of ROD
Soils Area No. 1 (portion on Allied property)
and ROD Soils Area No. 3 (excluding Truck
Scale area) completed; materials disposed offsite
OU2 Excavation, backfilling, and on-site
stockpiling of Site Soils areas (delineated
between 1994-97) completed
Date
December 15, 1995
March 4, 1996
August 23, 1996
August 27, 1996
May 29, 1997
June 12, 1997
July 1997
August 18, 1997
September 4, 1997
September 30, 1997
April 30, 1998
May 25, 1998
July 31, 1998
Event
OU2 EPA issues ROD amendment No. 3
OU2 Excavation and backfilling of Tar Plant
ROD Soils Area Nos. 5,6, and 7 completed;
materials disposed off-site
Merger between Allied and Honeywell —
Honeywell takes ownership of the Site
OU2 Remediation of Lagoon No. 2 "hot
spots" completed, including excavation and
backfilling with clay materials removed from
Lagoon No. 5; excavated materials shipped to
Biomass facility for use as an alternative fuel
OU2 Remediation of Lagoon No. 5
completed, including excavation, backfilling
(with clean hard fill and stockpiled site soils
and crusher fines; erosion control and
revegetation)
OU2 Excavation and backfilling of remaining
Site Soils areas, including Truckers' Parking
Lot and area adjacent to East Tank Farm,
completed. Acceptable materials placed into
Lagoon No. 5; remaining materials disposed
off-site
OU2 Placement of final six-inch layer of
imported fill over excavated Lagoon No. 2
"hot-spot" areas
Tar Plant operations shut down.
Honeywell submits Tar Plant closure Site
Management Plan to Ohio EPA
Tar Plant decontamination and demolition
activities initiated pursuant to Ohio Cessation
of Regulated Operations
OU2 Floodwall slope restoration activities
completed
Date
September 30, 1998
November 16, 1998
1999
July 30, 1999
October 31, 1999
September 30, 2000
October 3 1,2000
December 3 1,2000
March 2001
May 29, 2001
May 3 1,2001
Event
OU2 Remediation of East Side Batteries Area
completed, including excavation, backfilling,
and regrading; acceptable excavated materials
placed along toe of Flood wall Slope in lagoon
area; remaining materials disposed off-site
OU2 Excavation and backfilling of ROD
Soils Area No. 3 - Truck Scale Area
completed; materials disposed off-site
OU2 Remediation activities for the "uplands"
portion completed
OU2 First wetlands assessment monitoring
performed
OU2 Lagoon Area Vegetation and Benthic
Macroinvertebrate Monitoring Report
submitted
Tar Plant designated OU3
OU3 EPA initiated negotiations with
Honeywell for performance of an RI/FS at the
Tar Plant
OU3 Administrative Order on Consent (V-W-
03-C-755) issued
OU3 RI/FS Work Plan submitted
OU3 RI/FS Work Plan revision submitted
OU2 Second wetlands assessment monitoring
performed
Site-Wide (OU1 and OU2) Groundwater
extraction, treatment, and quarterly
monitoring program, O&M activities
OU2 Ice Creek semi-annual monitoring
program
Date
October 3 1,2001
October 3 1,2001
November 30, 2001
July - August 2002
October 2002
March 2003
March 27, 2003
August 22, 2003
February 18, 2004
July 16, 2004
July - August 2004
On-going
On-going
III. BACKGROUND
Physical Characteristics
The Site is located in the city of Ironton, Lawrence County, Ohio (Map 1 and Map 2). It
encompasses approximately 95 acres, including the former Coke Plant and five former lagoons
(Coke Plant/Lagoon Area), the former Tar Plant, portions of the adjacent Ice Creek, and the
Goldcamp Disposal Area (GDA). The GDA is a former sand and gravel pit used for disposal of tar
plant waste and foundry sand. The Coke Plant/Lagoon Area (CPLA) is bordered on the south and
east by Ice Creek. Near the southern end of Ice Creek, at the point where it empties into the Ohio
River, lies the Village of Coal Grove. The Ohio River lies approximately 500 feet west of the former
Tar Plant. Both the former Tar Plant property and the GDA lie on a relatively flat alluvial terrace
above the 100-year flood level of the Ohio River. Portions of the CPLA lie within the 100-year flood
plain. Much of the Site area is covered by a fill that overlies the native soils.
Land and Resource Use
The City of Ironton, founded in 1849, encompasses 4.1 square miles along the banks of the Ohio
River. The City's population is 11, 211 (2000 census). It was once the largest center of pig iron
production in the world. Consequently, heavy industry flourished in Ironton in the last century.
Industries in Ironton include coal loading and processing, oil terminals, chemical manufacturing
and storage, and steel manufacturing.
The Site is located in the southeastern section of Ironton and is surrounded by other industries,
businesses, private residences, and waterways. The residential areas are northwest and along the
southern edge of the site. In addition to private homes, there is one elementary school, baseball
diamonds along the northern boundary of the Site, and seven other schools within 2 miles of the
Site. A cemetery lies northeast of the Site.
Directly adjacent to the Site, bordering the east and south, is Ice Creek, a tributary of the Ohio
River. Past Ice Creek to the, south is the Village of Coal Grove. A resident's junk yard (Neal
Junk Yard) also lies along 450 feet of the Site's southern boundary. The Ohio River lies
approximately 500 feet to the west of the Tar Plant.
The Village of Coal Grove's primary drinking water source is the Coal Grove well field. This
well field is only 2000 feet south of the Coke Plant area. In March 1988, volatile organic
compounds (primarily trichloroethylene) were detected in one of these wells. This contamination
was linked to another facility, the Tri-State Tank Cleaning facility.
Ironton, on the other hand, extracts 1 to 2 million gallons per day from the Ohio River to meet its
drinking water needs. Ironton's water intake is approximately 2 miles down river from the Site.
The Ohio river is also used by Honeywell for the discharge of treated wastewaters associated
with ongoing groundwater remedial actions.
This sector of the Ohio River is known as the Greenup Pool, which is just upstream of the
Greenup locks. This area is occupied by several municipalities in addition to Ironton and Coal
Grove: South Point, Ohio; Ashland, Kentucky, Catlettsburg, Kentucky, and Kenova, West
Virginia. The Greenup Pool is highly industrial and has more barge traffic than any other section
of the Ohio River according to the Ohio River Valley Water Sanitation Commission. Industries
along the Ohio River include steel mills, paper mills, coal processing facilities, manufacturers of
coke and coal products, chemicals, pottery, and tools. There are 51 National Pollution Discharge
Elimination System permits for this section of the Ohio River above the Greenup locks and dam.
Honeywell's Site Restoration Plan calls for placing as much of the Site into beneficial re-use as
feasible. Two parcels (approximately 1.1 acres in total) outside the GDA's slurry wall and cap
perimeter and the uplands parcel of the CPLA (approximately 37 acres in total) have been
deemed appropriate for industrial re-use and do not require any further action. These 37 acres
were conveyed to Ironton in the fall of 2002 as part of a Brownfields redevelopment effort. More
recently, Ironton conveyed part of this land to the State of Ohio Department of Transportation
(ODOT). ODOT has since constructed a county garage from which it will conduct its highway
maintenance activities, including, but not limited to, snow and ice removal, salt storage,
equipment maintenance and storage, pavement maintenance, and other roadway operations.
ODOT has also constructed office space for its county manager and clerical staff (Photograph 1).
The "lagoon area" section of the CPLA was originally constructed in the 1970s to serve as a
place for Allied to discharge and treat liquid wastes (previously the liquid wastes were
discharged directly onto swampy lands that discharged directly into Ice Creek). This area is
currently being converted into a wetlands system, taking advantage of its natural flooding
conditions and predisposition to wetlands-type vegetation (Photograph 2).
History of Contamination
The Coke Plant began operations in 1917. In 1920, when Allied Chemical and Dye Company
(Allied) was formed, the plant became a unit of its Semet-Solvay Division. In 1977, the Site and its
operating facilities were sold to McClouth Steel Corporation (McClouth) which operated the plant
as a subsidiary, Ironton Coke Corporation. McClouth filed for bankruptcy in 1980. Consequently,
the Coke Plant was shut down in 1982. Following closure of the plant, the property and facilities
were purchased by Iron City Fuels, hie. In March 1984, Allied purchased the Coke Plant property,
with the exception of the surface facilities which were retained by lion City Fuels. Iron City Fuels
continued to salvage material from these surface facilities until March 1985, at which time
ownership of these facilities were transferred to Allied (later to become known as AlliedSignal).
Today, the property is owned by Honeywell, as a result of a 1999 merger between AlliedSignal and
Honeywell.
Products from the coking operation included: crude tar, coke; light oil; and ammonia. During the
period from 1920 through the 1960s, wastewater and solid wastes generated in the coking process
were discharged into marshy areas east of the plant adjacent to Ice Creek. These waste streams
10
included: process wastewater, coke and coal fines; tar decanter sludges; boiler ash; and weak
ammonia liquor. Specific constituents present in these waste streams included: ammonia; benzene;
cyanide; metals; naphthalene; phenolics; and polynuclear aromatic hydrocarbons (PAHs). In the
early 1970s, a series of lagoons was constructed in the eastern area of the plant for the purpose of
treating these waste streams. In 1982, the Coke Plant and lagoon operations were shut down
following the McClouth bankruptcy filing.
Operations at the Tar Plant began in 1945 as a unit of Allied Chemical and Dy Company's Barrett
Division. The operations were designed to manufacture products from the crude tar produced in the
Coke Plant. Specific products from the operations included: phthalic anhydride; creosotes; pitches;
naphthalene; and anthracene. Generated wastes and residues were disposed in the nearby GDA, a
former sand and gravel pit, up until 1977 when the GDA was shut down. Following the GDA
shutdown, the Tar Plant continued to operate as a unit of Allied, and eventually transitioned to a unit
of AlliedSignaFs Engineered materials Sector in the mid-1980s. In 1998, the creosote product line
was sold to KMG-Bernuth, followed by the acquisition of various carbon material product lines by
Reilly Industries in 1999, and the sale of the naphthalene product line to Recochem in 2000. The
Tar Plant was shut down in December 2000, with the buildings, process structures, and land
remaining under the ownership of Honeywell, as a result of the 1999 merger between AlliedSignal
and Honeywell.
Initial Response
The Ironton Coke Site was placed on the NPL in September 1983. This assignment was made at the
request of OEPA, based upon the results of investigations conducted between 1978 and 1983. These
original investigations indicated the existence of groundwater contamination and its off-site
migration, potentially posing a threat to human health and the environment.
A remedial investigation and feasibility study (RI/FS) was subsequently initiated by EPA; however,
negotiations between EPA, OEPA, and Allied resulted in Allied taking over the project in 1984,
pursuant to an Administrative Order on Consent (AOC) signed on April 13, 1984. Following
completion gf the RI in 1986, EPA, OEPA, and Allied jointly agreed to divide the Site into two
operable units. This was done in order to expedite the completion of the FS for the GDA, designated
as OU1. Accordingly, the GDA FS was completed in August 1988 followed by the issuance of the
GDA Record of Decision on September 29,1988, and a Unilateral Administrative Order (UAO) on
March 9, 1989 for the performance fo the GDA Remedial Design and Remedial Action (RD/RA).
During the FS, the discovery of non-aqueous phase substances (NAPS) near the bedrock below the
GDA, required (as per the ROD) that a supplemental NAPS RI/FS be performed to determine if the
original ROD remedy would still be effective. The results of this supplemental investigation showed
the original remedy to be protective, with requirements added for the expansion of the planned
groundwater treatment system. An Explanation of Significant Difference (BSD) was issued by EPA
shortly thereafter to document this change to the GDA remedy.
11
The FS for the CPLA operable unit (OU2), was completed in July 1990. Prior to this, a UAO was
issued to Allied in March 1987 outlining the requirements for decontamination and demolition of
the Coke Plant processing facilities. The bulk of this demolition work was subsequently performed
by Allied during the late 1980s and early 1990s, prior to the start of remedial action construction
activities. The CPLA ROD was signed on December 28,1990, followed by the issuance of a UAO
on July 1, 1991 for the performance of the CPLA RD/RA.
Three subsequent ROD Amendments dated July 31, 1995; September 4, 1997; and September 30,
1998 provided modifications to the original CPLA ROD.
Basts for Taking Action
The 4-acre GDA was a 40 feet deep sand and gravel pit utilized by Allied for the disposal of Tar
Plant process chemical wastes from 1945 to 1977. Wastes included: anthracene residue; anthracene
salts; phthalic anhydride residue; and miscellaneous process wastes from the Tar Plant. The
distillation bottoms from the production of phthalic anhydride from naphthalene are a listed
hazardous waste (KO24). The GDA was also used by the Dayton Malleable Iron Company/Ironton
Iron, Inc. for the disposal of foundry sand containing heavy metals, phenolics, and oils.
The wastes in the GDA were infiltrated by groundwater and the groundwater traveled west toward
the Ohio River, with a northerly component toward Ironton Iron's production wells located only 100
feet to the north. The investigation confirmed contamination in the soil and groundwater. The offsite
production well showed benzene levels up to 36 parts per billion. Non-aqueous phase
substances (NAPS) were also found. The volume of contaminated soil within the GDA was
estimated to be approximately 300,000 cubic yards. The surface of the GDA, though previously
dewatered and capped with clay, was also found to be problematic because many substances oozed
up through the clay and pooled on the surface.
The following tables highlight contaminants found in the groundwater at the Site derived from the
various source areas including the GDA, CPLA, and Tar Plant.
12
Results of Groundwater Investigation
Chemical (ppb)
Benzene
Styrene
Toluene
Xylene
Ethylbenzene
Acenaphthene
Aniline
Benzo(a)pyrene
Benzo(g,h,i)perylene
Fluoranthene
Fluorene
2-Methylnaphthalene
4-Methylphenol
Naphthalene
Phenanthrene
Phenol
Pyrene
Arsenic
Lead
Cyanide
1983
ND-4,310
ND-9,700
ND-72
ND-23,000
RMD-370
ND-3,200
ND-290
ND-560
ND-160
ND-2,000
pJD- 1,800
ND-7,700
h
ND- 19,000
ND-4,400 >
ND
ND- 1,700
ND-57
ND-62
ND-22,000
1984
ND- 1,400
ND-38
ND-39
psfD-120
ND-35
ND-2,300
h
JND-47
^PD- 1,500
lND-890
^pIDD-330
Uo-3,400
h°
ND-110
^D
ND-70
psfD-50
pJD-2,800
1989
RMD-63
|ND
11-19
15-110
1- 1
p80-7,000
h 1
h 1
h 1
370-4,000
390-4,000 |
[410-11,000 1
h 1
1,600-29,000
1850-8,500
ho
[230-3,100
|_
h
WD-40
Comparison Value (ppb)
51
100'
2,000'
10,000'
700'
2,1002
.
0.053
1402
1,4002
1,4002
NA
NA
1402
1402
po,ooo4
1,0004
II4
|l55
200'
ND = Not Detected
ppb = Parts Per Billion
1 = U.S.EPA Maximum Contaminant Level (MCL)
2 = Comparison Value Calculated by ODH
3 = Cancer Risk Evaluation Guide by ODH
4 = ATSDR EMEG
5 = U.S.EPA Action Level
NA = None Available
13
Off-Site Groundwater Data
Chemical (ppb)
Benzene
1 .2-dichloroethane
Toluene
Xylenc
Pnenobcs
Naphthalene
Cyanide
Lead
Arsenic
Coal Grove Wells
ND
ND
ND
ND
ND
ND
ND
980
BDL
Monitoring Wells
ND-260
42
67
27
ND-90
ND
ND-830
—
BDL
Comparison Value ppb
5'
70-100'
2,000'
10,000'
20,000:
60-1401
200'
154
5-Il:
1 = L.S.EPA Maximum Contaminant Level (MCL)
2 = Compahson Value Calculated by ODH
3 = ATSDR EMEG
4 = U.S.EPA Action Level
ND = Not Detected
BDL = Below Detection Limit
ppb = pails per billion
Reference = IT Corporation, 1986
An endangerment assessment was conducted in 1986 which noted the following contaminants of
concern: benzene, naphthalene, phenolics, PAHs, cyanide, ammonia, sul fates, and chlorides. The
PAHs selected as indicator chemicals were: benzo(a)pyrene, benz(a)anthracene, dibenz(a4i)
anthracene, and chrysene. The risks are related to the carcinogenicity of PAHs and benzene and
the exposure pathways through groundwater (to the Ohio River and the production wells).
The CPLA OU consists of the area occupied by the former Coke Plant batteries and processing
facilities, the lagoon area, the Tar Plant area, and portions of Ice Creek (contaminated sediments).
The Tar Plant contained several areas in which the soils were contaminated with organic
chemicals as a result of spillage (approximately 2,000 cubic yards). The Coke Plant investigation
also showed several areas where soil was contaminated by spillage and general operations
(approximately 38,000 cubic yards).
In addition, the five lagoons that were used to receive process wastewater and solid hazardous
waste from the Coke Plant were confirmed to be highly contaminated. Lagoon 5 contained a
listed hazardous waste (Decanter Tank Tar Sludge, K087). Lagoons 1 and 3 also contained a
listed hazardous waste (Lime Kiln Sludge K060). Lagoons 1 through 4 contained approximately
457,000 cubic yards of contaminated materials. Lagoon 5 contained approximately 122,000
cubic vards of contaminated materials.
14
Sampling also demonstrated contamination of the sediments in Ice Creek (phenolics, PAHs in the
form of naphthalene, ammonia, and cyanide). The contaminated sediments totaled
approximately 150,000 cubic yards. In order to ascertain the effects of the sediment
contamination, 214 fish were collected. No neoplastic lesions were observed. Therefore, it was
concluded that the concentrations of site-related contaminants in the Ice Creek stream sediments
do not have an adverse effect on fish. In addition the water quality in Ice Creek was tested. The
analysis indicated that concentrations of chloride and ammonia were greater downstream of the
Site than upstream, but were still well below EPA Water Quality Criteria. The water was
analyzed for PAHs and none was detected.
Ice Creek Sediment Samples
CHEMICAL
Ammonia
Cyanide
Phenolics
Benzene
Naphthalene
CONCENTRATION (ppm)
0.22-390
ND-8.7
0.2-1.8
ND
ND-12
ND = Not Detected
ppm = Parts Per Million
Ice Creek Fish Data
Chemical
Bis-2-ethylhexyl phthalate
Di-n-butyl phthalate
Phenol
Concentration (ppm)
•»_
ND-17.4
ND-6.8
ND-15.9
ND = Not Detected
ppm = Parts Per Million
In summary, concerning OU1 and OU2, soil samples showed the on-site surface soil to be
contaminated with cyanide, phenolics, benzene, naphthalene, and benzo (a) pyrene (a polynuclear
aromatic hydrocarbon). Groundwater analysis detected a number of volatile and semi-volatile
organic compounds plus cyanide. Sediment samples from Ice Creek, a stream bordering the
lagoon area, contained low levels of cyanide, phenolics, and naphthalene.
15
The groundwater underlying the CPLA was similarly contaminated as the groundwater
underlying the GDA. The most prevalent groundwater contaminants included: phenolics;
ammonia; cyanide; chloride; naphthalene; and benzene. The potential impacts of contaminated
groundwater on the local populations were through the Coal Grove Well Field, through the
Ironton Public Water Supply Intake in the Ohio River, and through the Ironton Iron'Amcast
production wells.
Coal Grove Gronndwater Data
1988-1990
CHEMICAL [CONCENTRATION (ppb)
Raw Water from Wefls *2 and #3
cftics - 11 .*/ > nU^cKkLuriuovfjoi^ctuk^mnMte
rrichloroethene
1.0-17.0
ND-8.57
Finished Plant Water
cis- 1,2 DkhJoroethene
Bromoform*
BromodKhlofomethane*
Dibromochloromethane*
NTM).%
SD-7J5
ND-0.4
ND-2.24
COMPARISON VALUE (ppb)
70'
5'
70'
100'
300-700^
300-7001
ND = Not Detected ppb = parts per billion • = By-product of the chlorinadon process
1 = US EPA Maximum Contaminant Level ' 2 = Comparison Value Calculated by ODH
Ice Creek and Ohio River Surface Water
Chemical
Cyanide
S'aphthalene
Ammonia
Lead
\rsenic
Ice Creek
MD
ND
ND
?-6,400
4.5-11.6
MD-4.0
Ohio River
ND-94
ND-32
MD-12
200-900
13.8
2.1
Comparison Value ppb
200'
5-
140'
30.0001
15J
11:
KD = Not Detected ppb = parts per billion 1 = U.S.EPA Maximum Contaminant Level (MCL) /
2 = Comparison Vralue Calculated ' 3 = U.S.EPA Health Advisory / 4 = U.S.EPA Action Level
16
Ice Creek and Ohio River Sediment
Chemical (ppm) [ce Creek )hio River*
Carbon disulfide 0.012-0.1
Acenaphthene 15.4 EL
Anthracene EL
Benzo(a)anthracene 104 11.6
Benzo(a)pyrene W9.9
Benzo(b)fluoranthene
Benzo(g,h,i)perylene El
Benzo(k)fluoranthene E
Chrysene E
Dibenzo(a,h)anthracene 14.4 E
Fluoranthene 8.75
Fluorene 9.66 E
Indeno( 1,2,3-c,d)pyrene E
Naphthalene E
Phenanthrene 38.7 E
Pyrene
Arsenic |[ND-0.049 .002
Lead ND-0.53 0.014
Cyanide IND-O.11
ppm = Parts Per Million
ND = Not Detected
Reference = IT Corporation, 1986
* Data were only available for one Ohio River station.
17
A site-specific risk assessment was also performed in 1990. The results of the baseline
assessment (assuming no remedial actions taken and a reasonable maximum exposure scenario
involving hypothetical future on-site residents) showed unacceptable cancer risks to children and
adults attributable to potential exposure to PAHs in soils, and benzene and arsenic in
groundwater. Unacceptable non-cancer risks were also identified as a result of child/adult
potential exposure to cyanide in the groundwater. As specified by the Agency for Toxic
Substances and Disease Registry in their May 16, 1994 Public Health Assessment, the Site posed
a public health hazard because of the potential for long-term exposure to cyanide,
benzo(a)pyrene, and naphthalene in Site soils. The Site also posed an indeterminate public
health hazard because of the potential impact on a public water supply. The residents who obtain
their drinking water from the Coal Grove well field were potentially at risk of exposure to
chemicals originating from the Site.
IV. REMEDIAL ACTIONS
Remedy Selection
Two RODs were signed for this Site. The first was for OU1/GDA on September 29,1988. The
second was for OU2/CPLA on December 28, 1990. The remedial action goals in both RODs for
the Site were to minimize risks to public health and the environment from direct contact with
contaminated materials and to minimize the migration of contaminants into groundwater.
The major components of the OU1/GDA remedy included:
• Construction of a low permeability slurry wall encircling the GDA;
• Creating an inward groundwater gradient within the slurry wall boundaries;
• Installation of a multi-media RCRA-compliant cap over the surface of the GDA;
• Treating groundwater extracted from inside and outside of the slurry wall at a new on-site
treatment facility,
• Municipal water hook-up for in-plant potable and sanitary uses at Ironton Iron Inc.
• Monitoring Site groundwater, ..
• Securing the Site from unauthorized personnel and implementation of deed restrictions; and
• Non-aqueous phase substance (NAPS) investigation and implementation of the EPAapproved
remedy, if different than the present containment alternative.
The major components of the OU2/CPLA remedy included:
• Incineration of approximately 122,000 cubic yards of lagoon waste materials, and on-site reuse
of the waste heat generated during incineration (Waste Fuel Recovery);
• In-situ bioremediation of approximately 457,000 cubic yards of lagoon waste material;
• Prepared-pad surface bioremediation of approximately 40,000 cubic yards of contaminated
soil materials;
• Pumping and on-site treatment of groundwater,
• Monitoring of groundwater downgradient of Ice Creek and preparation of a contingency plan;
18
• Fencing, security, and deed restrictions; and
• Evaluation of the effectiveness of in-situ bioremediation, with a contingency for development
of an alternative remedial action for Lagoons 1 through 4.
The OU2/CPLA ROD was amended three times: July 31, 1995; September 4, 1997, and
September 30, 1998.
The ROD amendments allowed the following modifications:
• Revised the clean-up standards for benzo(a)pyrene and dibenz(a,h) anthracene in
groundwater for the GDA and CPLA;
• Excavation and storage on-site for eventual treatment or placement into the lagoon area of
135,000 cubic yards of soils found to be contaminated with low levels of PAHs during the
design phase;
• Replaced prepared-pad bioremediation of 40,000 cubic yards of soil with off-site disposal in
an approved landfill;
• Replaced in-situ bioremediation of 457,000 cubic yards of soil in Lagoons 1 through 4 with
hot spot excavation and wetland development; and
• Replaced incineration of Lagoon 5 materials with recycling, treatment, and/or disposal of the
KO87 listed waste in an approved off-site hazardous waste facility and the use of the
remaining material, excluding debris, as an alternative fuel.
Remedy Implementation
OU1/GDA
EPA issued a UAO on March 9, 1989 for performance of the GDA Remedial Design/Remedial
Action to Allied and AMCAST Industrial. A pre-design investigation occurred between 1990
and 1991 and the design documents were prepared between 1991 and 1993.
Remedial construction activities at the GDA began in July 1993 after completion of the remedial
design. Construction of the Perimeter Barrier was accomplished between 1993 and 1994. The
wells were constructed in 1994 and the cap, groundwater extraction system, and other general
construction activities occurred between 1994 and 1995.
Work included:
• Construction of a soil-bentonite perimeter barrier to enclose the capped GDA wastes. The
perimeter barrier is designed to provide a low permeability barrier to ground water in-flow
and contaminant migration. This "slurry wall" has a permeability of approximately 1 x 10"8
cm/sec which is superior to the 1 x 10~7 cm/sec permeability requirement. The Perimeter
Barrier Installation Report, dated march 1995, documents the compliance with the slurry wall
construction performance standards. One change to the slurry wall performance standards
has been that the slurry wall was not keyed into the competent bedrock due to concerns that
19
keying efforts would fracture ihe massive bedrock and affect its competence and water
bearing capabilities. This change was documented in the Perimeter Barrier Data Report dated
May 1992, the Design Report dated September 1992, and the Design Report Response dated
December 1992.
• Construction of a permanent cap incorporating a geosynthetic clay liner to minimize future
exposure of the buried waste and minimize infiltration. The cap is a RCRA Subtitle C
compliant cap with a permeability of less than 1 x 10 7cm/sec. The cap included a passive
gas venting system with capabilities for adding an emissions control system in the future, if
needed. The design of the cap and its features were presented in the Cap Data Report dated
March 1992, and the Design Report dated September 1992. The permeability performance
standard and the other cap performance standards listed in the Order have been met and are
documented in the Cap/Pump & Treat Installation Report, dated September 1995.
• Installation of groundwater pumping wells inside the slurry wall (PW-3 and PW-4) to
maintain an inward hydraulic gradient. Pursuant to information presented in the Design
Report dated September 1992, and the Design Report Response dated December 1992, EPA
revised the required groundwater drawdown from ten feet to one foot The revision to one
foot would still maintain the required inward gradient. Groundwater pumped from inside the
GDA slurry wall is treated in the on-site WWTP. The Well Installation Report, dated
January 1995, documents the compliance with the construction performance standards.
• Installation of groundwater pumping wells outside the slurry wall (PW-1 and PW-2) to
intercept and withdraw contaminated groundwater. Groundwater pumped from outside the
GDA slurry wall is treated in the on-site WWTP and discharged in compliance with the
NPDES permit. The Well Installation Report, dated January 1995, documents the
compliance with the construction performance standards.
• Construction of treatment add-ons to the existing WWTP (part of the Tar Plant operations)
to treat extracted groundwater from inside and outside the GDA, including biological and
carbon adsorption polishing systems; t
• Installation of wells to monitor the remedial action performance including the containment of
dissolved and free phase contaminant plume migration;
• Delineation of the NAPS layer and evaluation of potentially feasible technologies to address
this layer, and
• Construction of a perimeter security fence.
In addition, during the early stages of the RA, an alternative water supply was provided to
Ironton Iron Inc. Final inspection of the GDA remedy was conducted on August 2,1995. The
PRPs submitted a Remedial Action (RA ) Report on September 6,1995. It was revised on
September 14, 1995, and EPA approved the Final RA Report on September 19, 1995.
20
Installation of the remedial action components was performed in accordance with the design and
specifications contained in GDA Construction Contract No. 1 (perimeter barrier); No. 2 (well
installation); and No. 3 (general construction).
OU2/CPLA
EPA and Allied entered into a Consent Order in March 1987 requiring Allied to dismantle and
decontaminate the Coke Plant processing facilities. The bulk of this demolition work was
performed during the late-1980s and early 1990s prior to the start of the remedial action
construction activities for the rest of the CPLA. EPA issued a UAO to Allied on July 1,1991 for
the performance of the CPLA RD/RA.
An RD/RA Work Plan was prepared to document the overall management strategy for
performing the design, construction, operation, maintenance, and monitoring of the remedial
actions. Supplemental to the RD/RA Work Plan, additional documents were developed
including a Quality Assurance Project Plan, Health and Safety Plan, and a Permitting Plan (May
1992). To provide additional data for performance of the RD, technology specific Sampling and
Analysis Plans (SAPs) were developed for implementation of the pre-design field investigations.
The remedy was divided into three major components, including: bioremediation; Groundwater
and Facilities; and Waste Fuel Recovery (WFR). Accordingly, a combined SAP was prepared
for the Bioremediation and Groundwater and Facilities components, and a separate SAP was
prepared for the WFR component. These SAPs were issued in May 1992 and March 1992
respectively, and focused on the collection of additional field and treatability study information
to support the CPLA design outlined in the ROD and UAO.
With the exception of the in-situ bioremediation field pilot study which was formally started in
August 1991, the remaining supplemental investigations/studies were conducted between
January and July 1992. The results from each of the supplemental investigations were presented
in the respective Bioremediation, Groundwater, and WFR Pre-Design Data Summary Reports
(August 1993).
The designs of the three principal CPLA remedy components were to be prepared and submitted
in distinct phases: Preliminary, Intermediate, Pre-Final, and Final Design.
Preliminary designs were prepared for the respective components of bioremediation and
groundwater and were issued in November 1993 for the Agencies' review. The groundwater
document also included information to support the design of associated infrastructure and
facilities deemed common to the overall CPLA remedy, and was thus submitted as the
Groundwater and Facilities Preliminary Design. The designs were commensurate with an
approximate 30% level of completion, reflecting the incorporation of sufficient technical
information to determine the constructability and functionality of the proposed remedy
components to satisfy the CPLA clean-up goals and objectives. A WFR Preliminary Design was
not formally submitted, as various aspects (including air emission controls and additional pilot
testing) of the proposed technology were still being evaluated as part of continuing pre-design
activities.
21
Based on the inherent interdependencies that were observed to exist between the bioremediation
and groundwater and facilities designs, it was determined that a combined Intermediate Design
could be issued for these components. As such, the Bioremediation and Groundwater
Intermediate Design was submitted in May 1994 to reflect the Agencies' comments on the
respective preliminary designs, and to incorporate additional design information corresponding to
an approximate 60% level of completion. WFR pre-design activities continued throughout this
time and this portion of the design was placed on a deferred completion schedule relative to the
bioremediation and groundwater components.
The Pre-Final Bioremediation and Groundwater Design (corresponding to a 90% level of
completion) was submitted to EPA and OEPA in September 1995. Following EPA and OEPA
review and incorporation of comments, the Final Bioremediation and Groundwater Design was
submitted in December 1995 and was also issued to prospective contractors for bidding. WFR
pre-design activities were still ongoing, with considerations now being given to possible removal
of the beneficial energy recovery requirements and also to potential leasing of the thermal
treatment equipment. Based on the information available at that time, the WFR Design was
projected for completion in mid-1997.
During the preparation of the design, additional studies and investigations resulted in several
significant changes relative to specific information that was contained in the ROD, some of
which necessitated three ROD amendments. However, one significant change that was not
addressed by a ROD amendment was also made. This concerned the revision of the arsenic
clean-up goal for soils. As per the ROD, the arsenic clean-up goal for soils was established as
0.56 mg/kg- Based on a compilation of site-specific data collected during 1994, a petition was
submitted to EPA and OEPA in March 1995 to provide a statistical evaluation of site-measured
arsenic concentrations as compared to regionally established background concentrations. This
petition resulted in the Agencies' adoption of a revised clean-up goal of 15 mg/kg for arsenic in
soils.
Although actual construction activities in support of the Bioremediation and Groundwater
components were initiated in early 19% (with the award of the construction contract),
preliminary site preparation and characterization work was performed by Honeywell during
1994-1995, in parallel with the finalization of the CPLA design. Additionally, construction of
the CPLA Stormwater Collection/Management System was completed in 1995 following the
March 1995 issuance of the CPLA Stormwater Pollution Prevention Plan.
During early 1994, a drilling program was performed to gather geotechnical data to support the
design of foundations for the planned remedial action facilities. The drilling program focused on
areas west of the former coke oven battery locations, and in addition to providing the required
geotechnical information, resulted in the identification of soils materials potentially requiring
treatment. Additional sampling was performed to delineate the contamination of these "site
soils" which was followed by excavation and on-site stockpiling. Soils materials in the coal
overburden area were also excavated and separately stockpiled.
22
The "site soils" were found to encompass a wide-spread area generally located west and south of
the former coke oven batteries, although other pockets of contamination were encountered
throughout the course of remediation and were addressed as discovered. A detailed evaluation to
identify potential options for handling the "site soils" was made, as directed by the EPA and
OEPA. ROD Amendment #1 details the decision made for these "site soils:" placement into the
lagoon area. Approximately 23,500 tons were hauled to the lagoon area and backfilled into the
resultant excavation created by the subsequent remediation of Lagoon No. 5. The
characterization of the "site soils" was an ongoing process and spanned several years as new
areas of impacted materials were encountered as the Site remediation work proceeded.
Completion of the "site soils" remediation efforts areas was achieved in late 2000 with the
characterization and excavation of the Truckers' Parking Lot area and an area located adjacent to
the East Tank Farm. The materials removed from these areas (an additional 3,500 tons) were
hauled directly to the Lagoon No. 5 excavation.
Based on the results of chemical testing, only those "site soils" which contained carcinogenic
PAH concentrations less than 97 mg/kg and arsenic less than 15 mg/kg were disposed off-site as
non-hazardous solid waste at the Green Valley Landfill.
The coal overburden material (44,000 tons) was originally targeted for blending with the Lagoon
No. 5 materials to enhance the heating value of the streams to be fed into the on-site incinerator.
When it became apparent that the incineration remedy was to be eliminated (as per ROD
Amendment 3), alternate handling/disposal methods were investigated. As a result, and
following chemical and physical testing, these stockpiled materials were subsequently shipped
(between July 1997 - April 1998) to cement kiln facilities owned by Southdown, Inc., and to
power generation plants operated by Ohio Edison for consumption, as part of approved
alternative fuels programs. Hard debris (brick and concrete), along with soft debris (wood,
plastic, trash, etc.) were disposed off-site as non-hazardous solid waste at the Green Valley
Landfill located in Ashland, Kentucky.
Similar to the coal overburden materials and "site soils," Lagoons No. 2 and 4 had surficial
material that were initially characterized during,_the FS as having potentially beneficial fuel-grade
BTU levels. Since Lagoon No. 5 material was no longer going to be incinerated, these "Type D"
materials (17,700 tons) were screened to remove debris and then shipped (between September -
November 1997) to power generation plants operated by Ohio Edison. The debris material was
disposed of as non-hazardous solid waste at the Green Valley Landfill.
During the initial Site preparation activities, excavation work in the former area of the Coke
Plant Ammonia Concentration building revealed the presence of soils emanating a petroleumlike
odor and visual discoloration (green tinge). They were sampled in October 1995 and found
to contain elevated levels of total petroleum hydrocarbons (TPHC). Remediation of the AC
Building Soils, including excavation (approximately 6,000 tons), backfilling, and off-site
disposal (as non-hazardous solid waste) at the Green Valley Landfill was completed in May
1997.
23
There were also seven localized soils areas within portions of the Coke Plant and Tar Plant
identified during the RIPS that indicated that these soils were impacted with contaminants above
the ROD-specified soil clean-up levels and were additionally identified (as per the ROD) to be
excavated and subjected to prepared-pad bioremediation. These soils areas were called the
"ROD Soils" and were delineated as follows:
• ROD Soils Area 1 - south and southeast of Lagoon 1 and extending onto the Neal Junk Yard
property;
• ROD Soils Area 2 - within the perimeter of the Coke Plant East Tank Farm;
• ROD Soils Area 3 - adjacent to the CPLA Administration Building and extending into the
adjacent Truck Scale;
• ROD Soils Area 4 - west of the central portion of the former coke oven processing area;
• ROD Soils Area 5 - southern end of the Tar Plant and adjacent to Third Street;
• ROD Soils Area 6 - around the perimeter of the Tar Plant anthracene production facility,
• ROD Soils Area 7 - former Tar Plant waste loading area.
ROD Soils Area 4 was addressed first, and removed in 1995 as part of the Site preparation
activities. The materials (2,600 tons) were stockpiled on-site in a lined, covered, and bermed
area, to await construction and eventual treatment in the planned on-site prepared-pad
bioremediation facility. However, in accordance with ROD Amendment #2, these soils were
shipped off-site in late 1997 and disposed of as non-hazardous solid waste at the Green Valley
Landfill.
ROD Soils Area 1 included private property (Neal Junkyard). A limited characterization of the
Neal Junkyard was performed in 1992.as part of the Pre-Design field activities, with a three- .._
phased focused characterization program subsequently performed in May 19%, September 1996,
and January 1997. A multi-phased characterization program was also implemented on the
Honeywell portion of the property in April, July, and October of 1997. Excavation to a depth of
10 feet was completed (as with the other ROD Soils Areas). Excavation began in late 1997 and
was completed in May 1998, which included backfilling and regrading. Localized areas of
contaminated soils within this portion of the Site were also addressed at this time, and were
excavated (4300 tons) and placed into the on-site stockpile to await placement into Lagoon No.
5.
ROD Soils Area 3 was characterized in April 1997 in conjunction with the field program for
ROD Soils Area 1. 3,100 tons were excavated in early 1998 and disposed off-site at the Green
Valley Landfill, and the areas backfilled and regraded. This work did not include the area that
extended into the active Truck Scale facility. This portion was subsequently characterized in
August 2001, with excavation of the materials (900 tons) and backfilling in September 2001.
24
Similarly, the removed materials from the latter activity were disposed off-site as non-hazardous
solid waste at the Green Valley Landfill.
ROD Soils Area 5, 6, and 7 were fully characterized in April 1997. As per EPA and OEPA
agreement, the characterization of the full lateral extent was not required at that time due to the
ongoing Tar Plant operations, and was therefore restricted to encompass only the boundaries as
identified in the ROD. The areas were excavated to a uniform 5-foot depth and backfilled
between September and November 1998. The 4,700 tons of soil were disposed off-site as nonhazardous
solid waste at the Green Valley Landfill. Characterization of the remaining soils will
be performed as part of the new OU3 RI/FS work.
Additional remedial action/construction work at the Site included: installation of additional
groundwater extraction wells, additional monitoring wells, modification of the on-site WWTP,
floodwall slope restoration / east side of batteries remediation, and lagoon wetlands conversion
program. This work was completed as follows:
• Between May and August 1996, a series of new groundwater pumping and monitoring wells
were installed to support the groundwater migration control system. An additional pumping
well was installed in November 1996.
• The modifications to the on-site WWTP were required to meet NPDES permit requirements
and adequately treat groundwater from the Coke Plant, the Lagoon Area, and the Tar Plant.
Modifications included an iron/suspended solids removal system (consisting of aeration/pH
adjustment, clarification, and sand filtration), and a cyanide removal system (consisting of
carbon towers). The modifications were completed in 1997 and formal system start-up
occurred in June and July of 1997.
• The City of Ironton floodwall transects the Site in a north/south direction and was
constructed by the USAGE in the late 1930s, approximately 20 years after the start-up of the
coke plant. Over the course of operations, soils, debris, and process materials (including coal
and coke fines) accumulated in this area East of the Coke,Plant Batteries and on the outer
slope of the floodwall, extending in the direction of the Site that would eventually become
the lagoon area. A preliminary work plan was prepared in March 1999 to cleanup this area of
the Site. EPA and OEPA gave Honeywell approval to proceed and the work was initiated in
April 1999. Coal and coke materials were scraped off down to the underlying visually clean
soils and were then screened to removed trash, metal, and hard debris such as brick and
concrete. The screened coal and coke materials (35,000 tons) were subjected to physical
testing (BTU content) and then shipped off-site to the nearby Biomass facility (South Point,
Ohio) for planned consumption as an alternative fuel.1 Soft debris, including wood and other
'The materials that were shipped to the Biomass facility still remain stockpiled and have
not yet been processed in accordance with the original contractual agreement between Honeywell
and Biomass. These materials were designated to serve as feedstock to fire boilers located at the
25
miscellaneous materials were disposed off-site at the Green Valley Landfill. Metals debris
was pressure-washed and shipped to a local scrap metal recycler. Hard debris, including
brick and concrete, were pressure-washed and then chemically tested to confirm their
suitability for on-site use in the lagoon area. These materials were stockpiled and used as riprap
to provide erosion control in portions of the lagoon area. Hard tar (500 tons) was shipped
off-site (with Lagoon No. 5 hard tar) for consumption as alternative fuel in the Piney Creek
Light and Power Plant in Clarion, Pennsylvania. Material removal, regarding (including
backfilling the top portion to the original grade as per USAGE requirements), and
revegetation of the floodwall slope were completed in late-1999/early-2000.
Following the completion of the floodwall slope remediation and restoration activities, the
March 1999 work plan was modified in March 2000 and June 2000 to reflect the work
necessary for the East Side Batteries. In October 2000, Honeywell submitted an additional
proposal requesting that the materials to be removed from the East Side Batteries area now be
placed along the toe of the restored floodwall slope rather than being backfilled into Lagoon
No. 5. Following EPA and OEPA approval, field characterization and sampling was initiated
in January 2001. All of the removed material were stockpiled and chemically tested for
carcinogenic PAHs and arsenic, and subjected to BTU testing. 63,900 tons with measured
concentrations of carcinogenic PAHs less than 97 mg/kg and arsenic less than 15 mg/kg, and
low BTU value were taken to the base of the floodwall slope. Placement started immediately
adjacent to the northern side of the completed Lagoon No. 5 remediation area and proceeded
northward to the existing property fence line. Materials that were found to contain acceptable
fuel-grade BTU levels (4,800 tons) were shipped to Honeywell's Coke Plant facility in
Detroit, Michigan for use in fuel-blending operations, and then ultimately processed as an
alternative feedstock at the Tonawanda Coke Facility. Additionally, 3,800 tons of materials
were shipped to Intermodal Corporation for use as part of the approved alternative fuels
programs. Excavated coal and coke fines and soil materials with measured concentrations of
carcinogenic PAHs greater than 97 mg/kg and/or arsenic greater than 15 mg/kg were
disposed at the Green Valley Landfill. Honeywell also removed surface concrete slabs and
demolished subsurface foundations to a depth of 4 feet below grade. Protruding sections of
steel rebar were removed for shipment to a local scrap metal recycling facility. Below a
depth of 4 feet, only concrete and brick with carcinogenic PAHs less than 97 mg/kg and
arsenic less than 15 mg/kg were used as basement foundation backfill. From a depth of 4 feet
to the surface, concrete, brick, and other soil materials with carcinogenic PAHs less than 97
mg/kg and arsenic less than 15 mg/kg were used to back fill foundations. The area was
Biomass facility, however, the boilers and power generation components have not been
constructed to date. The un-processed materials are currently stored inside a concrete building
with a concrete floor. However, the building's roof is not intact, and the walls of the building are
not fully intact The material is subject to wind erosion, and precipitation. OEPA has attempted
enforcement actions against the owner of the Biomass facility, Mark Harris. Mr. Harris has not
complied with OEPA and this issue remains to be resolved. EPA will be working with
Honeywell and Biomass to resolve this problem (Photographs 3 through 8).
26
collectively regraded to provide for acceptable stormwater drainage. Regrading was done in
a way to separate property parcels to allow for certain portions to be sold and re-used.
Construction of the in-situ bioremediation system began in July 1996. Due to difficulties
with the excavation process (trenches could not be held open using a bio-polymer slurry,
unanticipated boulders and construction debris), Honeywell requested temporary cessation of
the work in August 1996 and submitted a petition for EPA review of the lagoon area remedy.
ROD Amendment No. 3 reflects the change in the lagoon area remedy. In-situ
bioremediation in Lagoon Nos. 1-4 was replaced with hot spot-excavation of isolated
highly-contaminated areas and conversion of the lagoon area into a wetland ecosystem. In
support of this change, a detailed Lagoon Materials Delineation Program was performed in
April and May of 1997 to provide sufficient analytical data for statistical evaluation of the
overall average concentration of carcinogenic PAHs that would remain in the Lagoon area.
EPA also required an ecological assessment of the lagoon area to gather sufficient
information to characterize the condition of the existing benthic invertebrate and vegetative
communities, ad to evaluate potential impacts to the species with respect to the measured
carcinogenic PAH levels in the lagoon materials. The field and laboratory testing was
conducted between September and November 1997, with the results presented in the
Reconnaissance Ecological Risk Assessment Report, dated January 1998 and revised in July
1998 and March 1999. The principal conclusions indicated that the residual levels would not
significantly impact the successful establishment of the planned wetland ecosystem with
regard to both aquatic and vegetative communities. Based upon EPA and OEPA approval of
the Risk Assessment Report, Honeywell submitted the Wetlands/Floodplain Conversion Plan
in September 2000 which required: construction of an overflow weir adjacent to Lagoon 4
and placement of rip-rap; permanent modification of the sluice gate adjacent to Lagoon 3 to
permit complete hydraulic connection with Ice Creek which allows for equalized
inflow/outflow during flood events; and adoption of an annual monitoring program to
evaluate the re-establishment of vegetation and to assess the condition of the biological
community. The construction of the erosion control measures have been completed and the
first annual monitoring program was conducted in July 2002. The second monitoring event
occurred in July 2003, and the third event occurred in July 2004.
The Lagoon No. 5 remediation was also revised pursuant to ROD Amendment 3. The
supporting documentation included an additional investigation program performed on
Lagoon 5 materials in May/June 1997. The contract for remediation of Lagoon 2 and 5 was
awarded in March 1998. Field work started in August 1998. Excavation was completed in
July 1999 with the removal of approximately 120,000 tons. The coal/coke fines (85,600 tons)
and segregated hard tar (16,000 tons) were shipped off-site to multiple outlets for
consumption as part of approved alternative fuels programs. Specifically, the coal/coke fines
were shipped to: Allegheny Power, Rurkola, Ohio Edison, Louisville Gas and Electric,
Cincinnati Gas and Electric, Dayton Power and Light, and the Biomass facility. The hard tar
was shipped to the Illinova Resource Recovery Facility and the Piney Creek Light and Power
Plant. The soft tar materials were KO87 listed wastes and were planned to be shipped to
27
available coke plant facilities, but due to acceptance criteria, the other plants would not
accept these 7,100 tons. They were therefore transported to Safety-KJeen Landfill in Samia,
Ontario for proper disposal. 500 tons did pass the acceptance criteria and was exempted as
KO87 waste and was sent to Citizens Gas and Coke for use as an alternative feedstock.
Work at Lagoon 5 was completed in October 1999 with final seeding.
Concurrent with Lagoon 5 work, excavation of Lagoon 2 hot-spots was initiated in
November 1998. This work was completed in June 1999, with the total quantity of materials
removed estimated at 9,500 tons (8,300 tons of hard tar and 1,200 tons of coal/coke fines).
The hard tar was shipped to Illinova Resource Recovery Facility for the alternate fuels
program and the coal/coke fines were blended with the fines from Lagoon 5 and shipped to
the various power plant facilities. 2,000 tons of clean (PAHs < 97 mg/kg and arsenic <15
mg/kg) material were placed in Lagoon 2. Backfilling of Lagoon 2 was completed in October
2000 with the final placement of a six-inch layer of imported fill materials over the entire
excavation.
TABULATED REMEDIATION SUMMARY
AREA MATERIAL
Coal Overburden
Surface of Lagoons 2 and 4 ("Type
D" Material )
"Site Soils"
Stockpile
Truckers Parking Lot / East Tank
Farm
Reject
Crusher Fines
AC Building Soils
ROD Soils Areas
Fkmdwall Slope Coal / Coke Fines
Hard Tar
.APPROXIMATE
QUANTITY (TONS)
44,400
17,700
23.400
3400
3,700
12,000
6.000
28,500
35.000
500
HANDLING .'" DISPOSAL
Southdown Cement Kim and Ohio Edison
(alternative fuel)
Ohio Edison (alternative fuel)
Lagoon 5 backfill
Lagoon 5 backfill
Green VaUey Municipal landfill
Lagoon 5 backfill
Green Valley Municipal Landfill
Green Valley Municipal landfill
Biomass
Piney Creek Power Plant (alternative fuel)
28
AREA / MATERIAL
East Side Batteries & Area above
floodwall
Coal & Coke Fines
Coal & Coke Fines
Lagoon 5
Coal & Coke Fines
Coal & Coke Fines
Coal & Coke Fines
Coal & Coke Fines
Coal & Coke Fines
Coal & Coke Fines
Coal & Coke Fines
Hard Tar
K087 Soft Tar
Exempted Soft Tar
Soft & Hard Debris
"Clean" Clay
Tarry Soils
Hard Tar
Lagoon 2 "Hot Spots"
Hard Tar
Coal/Coke Fines
Debris (excluding Lagoon 5)
Hard Debris (brick and concrete)
Soft Debris (wood, plastic, trash,
etc.)
p
Scrap Metal
APPROXIMATE
QUANTITY (TONS)
63,900
3,800
4,800
21,900
1,200
2,200
26,700
15,900
14,100
3,600
16,000
7,100
500
10,800
2,000
11,800
100
8,300
1,200
13,100
500
900
HANDLING / DISPOSAL
Backfill along toe of floodwall slope
Intermodal Corp. (alternative fuel)
Honeywell's Detroit Coke Plant (fuel blending) &
processed at Tonawanda Coke (alternative
feedstock)
Biomass
Allegheny Power (alternative fuel)
Ruhrkola (alternative fuel)
Ohio Edison (alternative fuel)
Louisville Gas & Electric (alternative fuel)
Cincinnati Gas & Electric (alternative fuel)
Dayton Power & Light (alternative fuel)
Illinova Resource Recovery /Piney Creek Power
Plant (alternative fuel)
Safety-Kleen Landfill - Sarnia Ontario
Citizens Gas & Coke (alternative feedstock)
Green Valley Municipal Landfill
Lagoon 2 Backfill
Southdown Cement Kiln (alternative feedstock)
Illinova Resource Recovery (alternative fuel)
Illinova Resource Recovery (alternative fuel)
Power Plants as per Lagoon 5 (alternative fuel)
Green Valley Municipal Landfill
Green Valley Municipal Landfill
.*_
Mansbach Recycling Facility
29
Operation and Maintenance (O&M)
O&M activities at the Site are extensive and include activities associated with
groundwater wastewater operations, monitoring systems, engineered structure maintenance,
landscaping, and security. The categories are further delineated in the following table.
Cost Item
On-Site Labor
Utilities
Permits
Carbon and
chemicals for
WWTP
Filter Cake
Disposal
WWTP
analytical
Site Security
Site
Maintenance
Administrative
CPLA and Ice
Creek
Monitoring
CPLA and Ice
Creek
Reporting
Wetlands
Survey and
Monitoring
CPLA
Pumping
System
Support
1999
$842,000
$140,000
$ 12,400
$141,300
$20,200
$180,400
$68,200
$163,900
$121,600
$42,000
$15,000
0
$15,000
2000
$842,000
$140,000
$12,400
$141,300
$20,200
$180,400
$68,200
$163,900
$121,600
$35,000
2001
$842,000
$140,000
$12,400
$141,300
$ 20,200
$180,400
$68,200
$163,900
$121,600
$35,000
S 9,000 $ 9,000
2002
$809,000
$140,000
$12,400
$141,300
$20,200
$180,400
$68,200
$163,900
$121,600
$ 35,000
$9,000
2003
$678,000
$140,000
$12,400
$141,300
$20,200
$180,400
$68,200
$163,900
$121,600
$35,000
$9,000
0 0 $25,000 $25,000
S 15,000 $ 15,000 $ 15,000 $ 15,000
30
Cost Item
Pumping Well
Replacement
GDA
Monitoring
GDA
Reporting
GDA Pumping
System
Support
GDA NAPS
Technology
Assessment
Laboratory
Analytical
Services
Taxes
ANNUAL
TOTALS
(rounded)
1999
0
$ 23,000
$ 17,000
$ 15,000
$ 5,000
$ 83,000
$ 13,000
$1.9 million
2000
0
$ 23,000
$ 17,000
$ 15,000
$ 5,000
$71,000
$ 13,000
$1.9 million
2001
$ 50,000
$ 23,000
$ 17,000
$ 15,000
$ 5,000
$ 75,000
$ 13,000
$1.95 million
2002
$ 50,000
$21,000
$ 16,000
$ 15,000
$ 5,000
$ 73,000
$ 13,000
$1.9 million
2003
0
$21,000
$ 16,000
$ 15,000
0
$71,000
$ 13,000
$1.7 million
Additional O&M information is broken down by Site areas:
CPLA
The 37-acre area known as the "uplands" part of the CokeTlant has been completely remediated
as of October 2001. Commensurate with the Brownfields sale of this parcel to the City of
Ironton in August 2002, O&M activities that had been performed by Honeywell are now being
undertaken by the City of Ironton. These O&M activities include: mowing and grounds keeping
of the grassed portions, and the monitoring and operation of the Stormwater Retention Pond.
The former CPLA Administration Building is currently unoccupied, but still serves as an
equipment storehouse and workshop area. The adjacent WWTP and East Tank Farm facilitate
the ongoing collection and treatment of Site groundwater and is staffed by control room operators
and maintenance personnel. A chain-link fence (including posted warning signs), which is
maintained by Honeywell, secures the entire perimeter of the "uplands" area and the lagoon area.
31
The lagoon area extends to the western edge of the East Side of Batteries area (including the
Ironton Floodwall). This entire property will be retained by Honeywell. Remedial actions were
completed in this area in October 2001. with the final placement of the excavated East Side
Batteries materials along the toe of the Floodwall Slope. As required by the ROD Amendment 3,
the future maintenance of the lagoon area includes annual assessments to determine that the
residua] materials left in the lagoons do not pose unacceptable risks to the biological and
vegetative communities. These assessments require sample collection, laboratory analysis, and
field evaluations to document the development of the wetland system and assess the health of the
ecosystem and benthic macroinvertebrates.
Other routine O&M activities that are performed in the lagoon area include periodic inspection
and repair of the perimeter fence and the outer dike wall that separates the lagoons from adjacent
Ice Creek, as well as other locations that are susceptible to potential erosional effects caused by
occasional flooding of the area. To minimize these concerns and to afford more controlled
ingress/regress of flood waters, an overflow weir was constructed adjacent to Lagoon 4, and the
sluice gale adjacent to Lagoon 3 has been permanently opened. Following flood events, any
debris that may accumulate is removed so that future flood water inflows/outflows remain
unobstructed, hi addition, two flood water sampling events were planned and implemented.
O&M activities were initiated in 2002 for the restored Floodwall Slope and included reseeding
the face of the slope, following patches made to areas initially observed as being impacted by
erosion. These areas were patched using imported fill materials. Honeywell continues quarterly
inspections of the Floodwall Slope and makes repairs as needed Honeywell has recently
installed additional vegetation test patches to determine the best type of vegetation to place on
the wall to minimize future erosional impacts and to enhance the aesthetics of the area
(Photograph 9).
OEPA also performed an O&M Inspection of the CPLA on June 10,2004. The floodwall slope,
upon which a significant quantity of coal/coke/soil materials were placed as part of the remedy,
must maintain structural as well as erosional stability. The inspection did not indicate any areas
. at which structural stability appeared to be in question. .At several locations, relatively small
erosional channels were observed, but, in most cases, these channels did not appear to be
enlarging or deepening substantially. The overall vegetative cover on the floodwall embankment
appeared to be in good condition. Several vegetative test plots were inspected and most locations
showed some positive qualities of vegetative growth. However, most locations also appeared to
show a negative effect of flood water encroachment to a specific elevation on the embankment,
with the exception of the honeysuckle plot. Honeywell will be providing recommendations for
full scale implementation of new revegetation efforts (based on the test plots) in the fall of 2004.
Subsequently, the floodwall will be revegetated with the plants that have been tested on-site and
shown to provide the best growth and coverage, hi the lagoon area, the inspection showed that
qualitatively, the wetland ecosystems appear to be continuing their evolution in a positive
fashion. A quantitative analysis of the ecosystem is part of a long-term monitoring program, that
began with a reconnaissance-level ecological assessment in late-1997, followed by the Lagoon
32
Area Wetlands/Floodplain Conversion Plan in September 2000, and performance of annual
ecological/ wetlands monitoring (which began in July 2002).
Based on the results of the 2002 and 2003 assessments, the development of a stable wetland plant
community in the lagoon areas is proceeding. The vegetative cover was observed to be
significantly high in all of the lagoon sampling areas, and most species were adapted to wetland
conditions. The development of a stable benthic macro-invertebrate community in the lagoon
areas is also proceeding. Organisms with low taxa tolerance values (highly sensitive to organic
pollution) were observed. However, the observed absence of the more-sensitive Lumbriculids
(ultraviolet light/PAH sensitive aquatic worms) still maintains a level of uncertainty relative to
potential impacts of ultraviolet light-enhanced phototoxicity of PAHs. However, such organisms
are also only present in very low numbers in the reference areas (only one was found). Water
chemistry parameters, as well as grain size, were comparable between the reference areas and
lagoon areas. Refer to photographs 10 through 13 concerning the wetlands revegetation program.
The success of the lagoon area remediation will be measured over the next few years. O&M for
the wetlands habitat is actually performed by natural processes. It is hoped that the ecosystem
will be restored and success will be achieved when it contains sufficient biotic and abiotic
resources to continue its development without any further assistance. It should contain a
characteristic assemblage of the species that occur in the reference area, it will contain an
appropriate community structure, it will consist of indigenous species to the greatest practicable
extent, and it will contain all functional groups necessary for the continued development and
stability of the system. It will also sustain reproducing populations, and will be resilient to
endure the normal periodic stress events in the local environment.
Groundwater Pumping. Treatment, and Monitoring
A site-wide pumping, treatment, and monitoring system is in operation which addresses the
GDA, CPLA, and the Tar Plant area, OU3. Map 3 shows the site-wide groundwater contours
and effectiveness of the system (inward gradient within the property boundaries).
•.?_ ^
The CPLA groundwater collection and treatment system has operated continuously since its startup
in August 1997, and provides for containment of site-impacted groundwater and treatment in
the on-site WWTP. Treated groundwater is then discharged to the Ohio River through NPDESpermitted
outfalls. The pumping wells that comprise the groundwater collection network include
four lagoon area wells (WE-2401, WE-2425, WE-2427, and WE-2428), and two Tar Plant area
wells (WE-618 and WE-1800). Evaluation of progress towards achievement of the established
Site groundwater cleanup standards is accomplished through quarterly performance of the CPLA
Compliance Monitoring program, ongoing since 1997. Presently, this program entails
groundwater sample collection from eight wells located around the downgradient perimeter of
the CPLA, including lagoon areas wells WE-2425, WE-2427, WE-2428, and MW-23, and Tar
Plant area wells MW-11, MW-17, MW-24, and MW-27. The field and laboratory results from
the groundwater monitoring program are presented in the quarterly monitoring reports submitted
to EPA and OEPA. The data includes chemical analysis as well as potentiometric data.
33
The reports received and reviewed since the last Five Year Review (1999) indicate that the
groundwater containment system continues to function effectively, and contaminant
concentrations have remained at or near previous levels.
Extraction well WE-618 was constructed for removal of separate-phase materials. Approximately
1,900 gallons of separate-phase material have been removed as of September 2003. In addition to
the monthly reporting of the amount of separate-phase material removed from WE-618 at the
Tar Plant, a monthly monitoring program (with quarterly reporting) for the presence of Non
Aqueous Phase Substances (NAPS) of six wells in the vicinity of the GDA is also ongoing.
On an as-needed basis, maintenance of the extraction wells includes removal and cleaning of the
pumps and discharge piping, along with routine inspections of other mechanical and electrical
components. Continual injection of sodium hypochlorite into pumping weH WE-618 is also
performed to minimize the potential effects of iron fouling within the well.
Within the WWTP, typical O&M activities include periodic cleaning of the sand filter, changeout
of carbon beds, and packaging and disposal of filter cake materials. Overall operations of the
pumping wells and the WWTP processes are continuously monitored from a central control
room, with daily lop prepared to document operational parameters such as groundwater flow
rates, system pressures, alarm warnings, and maintenance performed.
In order to monitor the performance of the on-site WWTP in removing contaminants from the
pumped groundwater and to demonstrate compliance with the established NPDES discharge
limits, samples are collected at selected process points and at outfalls internal and external to the
WWTP (Photograph 14). As required by the in-place NPDES permit, samples are collected at
the specified frequencies with analytical results compared to allowable daily maximum and
monthly average values. On a monthly basis, a summary report is submitted to the State of Ohio
to document measured concentrations of each monitored parameter with respect to the
established permit limits. Within the report, any excursions above the established limits are
noted, and as necessary, proposed plans for further investigation and/or corrective actions are
outlined.
The performance of the pumping system relative to its effectiveness in controlling the potential
migration of site-impacted groundwater is evaluated through the monthly collection of site-wide
groundwater levels. These water levels are used to construct groundwater contour maps from
which an assessment is made of the estimated limits of groundwater capture. On a quarterly
basis, the results of these assessments are presented in the monitoring reports. In conjunction
with the monthly water level collection, the above-grade portion of each of the Site monitoring
wells is inspected and repairs made, as necessary, to preserve their integrity.
The required duration of groundwater pumping and treatment is uncertain, but currently
estimated to require at least another twenty years of operation. The ROD contemplated at least
thirty years of groundwater extraction and treatment to achieve the cleanup standards. However,
the analytical results compiled to date do provide evidence of improving groundwater quality.
34
Specifically, within the northern portion of the lagoon area (near pumping wells WE-2425 and
WE-2427), measured concentrations of all monitored parameters are currently below the
established Site cleanup goals. Beginning in August 2002, the groundwater pumped from these
two wells is being discharged directly to the Ohio River without treatment in accordance with
NPDES Permit No. OIF00014*KD.
Groundwater Cleanup Standards:
Contaminant
Benzo(a)pyrene
Dibenz(a,h)anthracene
Arsenic
Ammonia
Phenolics
Benzene
Naphthalene
Nitrate
Total Cyanide
Cleanup Standard
200 ppt
300 ppt
50 ppb
30 ppm
4 ppm
5 ppb
300 ppb
10 ppm
200 ppb
ppt parts per trillion
ppb parts per billion
ppm parts per million
Data from the southern portion of the lagoon area (near wells WE-2401, WE-2428, and MW-23)
shows localized and elevated concentrations of benzene and ammonia. Similarly, groundwater
quality in the '•far Plant area (near MW-24) presently shows only carcinogenic PAHs to be above
the established Site cleanup goals. Results from periodic sampling of the Tar Plant pumping well
WE-1800 shows low levels of PAHs and elevated levels of benzene. Tar Plant pumping well
WE-618 has low levels of PAHs and VOCs. In addition, separate-phase materials were found in
former pumping well WE-617 (located adjacent to WE-618) in February 2000. WE-618 was
constructed for removal of separate-phase materials. Approximately 1,900 gallons of
separate-phase material have been removed as of September 2003. In addition to the monthly
reporting of the amount of separate-phase material removed from WE-618 at the Tar Plant, a
monthly monitoring program (with quarterly reporting) for the presence of Non Aqueous Phase
Substances (NAPS) of six wells in the vicinity of the GDA is also ongoing.
The ongoing groundwater collection and treatment operations will continue for the indefinite
future until such time as the measure groundwater quality meets the established Site cleanup
35
goals. As such the monitoring programs will also continue throughout this period. At such a
time when such operations are terminated, the requirements for post-operational monitoring will
be implemented (which will confirm the success of the remediation program).
Ice Creek
The Ice Creek Monitoring/Contingency Plan was prepared in December 1992 resulting in the
installation of monitoring wells ICMW1 - ICMW-5 in early 1993 to be used for detecting
potential contaminant migration towards the Coal Grove well field. In October 1993, quarterly
sampling of these wells was initiated. This program also included monitoring Coal Grove
pumping wells, numbers CG-3 and CG-4, other on-site monitoring wells, MW-5, MW-7, and
MW-10, and two surface water locations within Ice Creek, hi 2000, this monitoring program was
reduced to a semi-annual basis. To date, evaluation of the analytical results has indicated no
degradation of the Ice Creek surface water or the Coal Grove water qualities. This activity will
continue for the indefinite future in conjunction with the Site groundwater pumping operations
and the CPLA Compliance Monitoring Program.
GDA
Quarterly progress reports have been submitted on the GDA since 1995. The quarterly reports
address the RD/RA Monitoring Plan which includes groundwater monitoring for water levels and
quality, gas monitoring at the Site cap vents, and NAPS monitoring for migration analysis. In
addition the reports provide a summary of water pumped from the GDA that was treated and
discharged. Specifics of the quarterly reports include groundwater monitoring for water levels
and quality. Water levels are measured to monitor the progress of the groundwater extraction
process in its ability to achieve the desired inward gradient across the containment barrier, such
that the groundwater elevations within the containment is lower than the water table outside.
Except for a few fluctuations due to flooding events and maintenance or temporary shutdown of
an extraction well, groundwater levels have been consistently lower inside the slurry wall than
outside the slurry wall. A positive gradient, indicating flow from outside to inside has also been
maintained. Fortunately, the fluctuations that have occurred have been concentrated in the
northwest comer of the GDA where any outflow can be captured by another extraction well
located outside the slurry wall.
Groundwater quality is also measured inside and outside of the GDA. This monitoring provides
information on overall groundwater quality as well as the effectiveness of the pumping and
containment system. All groundwater samples are analyzed for BTEX, PAHs, TPHC, pH, total
and amenable cyanide, total phenols, ammonia, and arsenic. The parameter of free cyanide is
also included for the extraction wells because it is a monitoring parameter at the internal outfalls
in the WWTP where the water is eventually discharged.
36
As part of the groundwater level measurements, specific wells are also checked for the presence
of NAPS (free product). In addition, samples are collected from two monitoring wells and
specifically analyzed to determine the presence or contribution of NAPS to contamination in the
well. Groundwater samples from the two NAPS monitoring wells are analyzed for BTEX, PAHs,
TPHC, pH, total and amenable cyanide, total phenols, ammonia, and arsenic. Throughout the
quarterly monitoring, variable levels of VOCs and PAHs have been detected, while levels of
inorganics and ammonia have remained relatively constant.
Honeywell, as required by the U.S. EPA and Ohio EPA, reviewed and evaluated
emerging technologies which may be potentially applicable in addressing the NAPS outside the
limits of the GDA slurry wall. Pertinent information from the previous reviews (extending back
to 1996) is included in the document. As of the 2002 review of NAPS remediation technologies,
generally none of them are applicable to the GDA. The migration of dissolved-phase
constituents associated with the NAPS plume is controlled by a groundwater extraction system.
Based on field and laboratory tests, the NAPS materials are estimated to have a specific gravity
of approximately 2.6 and an estimated hydraulic conductivity in the range of 5 x 10 ~* to 5 x 10"5
centimeters per second. The overlying alluvial materials have an estimated hydraulic
conductivity of approximately 1 x 10"' centimeters per second. The NAPS materials are
relatively insoluble and immobile, comprised principally of semi-volatile and volatile organic
compounds. The impact of NAPS on groundwater quality in locations where NAPS have been
detected appears to be limited to 2 to 3 feet above the NAPS layer. Technologies considered
included in-situ bioremediation; soil flushing with steam, air, surfactants, and cosolvents;
chemical oxidation; slurry/sheet pile wall; dynamic underground stripping (DUS) and hydrous
pyrolysis/oxidation (HPO); injecting brine and surfactants; pulsed injection of ozone; and
pressure pulse technology.
OEPA conducted an O&M inspection at the GDA on June 10, 2004. In general, the O&M
inspection indicated that all basic landfill components are in good condition and functioning as
intended. The cap was found to be in good condition, well vegetated2, and there was no evidence
of settlement or rodent burrowing. All gas vents contained the appropriate screens and continue
to be stable. All access roadways were in generally good condition. No evidence of ponding or
excessive sediment deposition was observed in the surface water runoff ditches. The landfill
perimeter was examined, with no breaches to the perimeter fence observed3. All security signs
and gate locks were in place as required. Pumping well PW-4 is currently the only well being
pumped inside the slurry wall, and was pumping at 10 gpm at the time of the inspection. PW-3
has been in temporary shutdown mode since August 1998. As evidenced by the quarterly
2Some medium sized shrubs/trees had encroached upon the perimeter fence adjacent to
the railroad property and was observed in June 2003. This vegetation was removed by the time
of the 5 Year Review inspection in July 2004.
3Vehicle damage to the fence adjacent to the VFW property, that was observed during the
ispection, had been fixed by the June inspection, time of the 5 Year Review inspection in July 2004.
37
monitoring reports, the rate maintained by PW-4 has been effective in maintaining the required
inward hydraulic gradient at the GDA. During the July 2004 inspection, the same pumping rate
was observed. Refer to Photographs 15 and 16 to view the condition of the GDA.
V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW
This is the second Five-Year Review for the Site. The protectiveness statement from the Five-
Year Review conducted in 1999 stated: "EPA certifies that the remedy selected for the Site
remains protective of human health and the environment." It recommended continued
monitoring and maintenance of the Site to ensure that the RODs' requirements are met. A copy
of the 1999 Five-Year Review is included in Appendix 3.
Since completion of the 1999 Five Year Review, the following has been accomplished at the
Site:
• 37-acres of the upland portion of the Coke Plant has been transferred to the City of Ironton
(August 2002) and ultimately transferred to the State of Ohio Department of Transportation
(ODOT) for its maintenance facilities. As of July 2004, ODOT has almost completed
building its facilities.
• In October 2001, final placement of the excavated East Side Batteries materials was
completed along the toe of the floodwall slope;
• hi July 2002, annual wetland assessments were initiated as part of the CPLA O&M program;
• In 2002, Floodwall Slope O&M activities were initiated and include revegetation work;
• In December 2002T the Tar Plant was closed by Honeywell and ceased operating.
• The demolition of the Tar Plant structures was completed in early October 2003;
*. *.
• By December 2003, tank bottoms from the East Tank Farm were cleaned out, waste material
residues were removed from subsurface stormwater trenches, storage pads, and tank pads and
disposed off-site, underground process and utility piping were removed through excavation of
a series of trenches. During the course of these activities, samples of near-surface
soil materials (typically no deeper than 5 feet) were collected from each of the thirteen (13)
trenches and submitted for analysis of PAHs and arsenic. The analytical results for the
composites samples collected from within the limits of this ROD Soils area do show
measurable levels of PAH contamination. Following the removal of the underground piping,
the trenches were backfilled with the existing materials excavated from the trenches;
• In 2001, Honeywell submitted a groundwater pumping system evaluation report to address issues
brought up by EPA and OEPA during the 1999 Five Year Review (optimization of the
38
groundwater contaminant capture system). The conclusion derived from the groundwater
pumping system evaluation was that persistent lowering of the groundwater over the previous
few years was indicative of the groundwater extraction rate being greater than required for
capture and could be reduced. The report included a proposal for a new pumping scheme and a
monitoring program and an implementation plan if the groundwater levels begin to rise (short
term due to extended wet weather or long term due to changed conditions);
• In March 2002, as approved by EPA and OEPA, the groundwater pumping system was adjusted
to optimize the groundwater containment system;
• Honeywell has been submitting annual reviews of the NAPS remediation technologies;
• Honeywell has implemented a focused remediation effort involving DNAPL recovery via a
dedicated pumping system installed in Tar Plant pumping well WE-618 (initiated in September
2001); and
• Honeywell signed an AOC with EPA for performance of an RI/FS on the Tar Plant area in
August 2003 (the previous work performed for the Tar Plant was performed in accordance with
State of Ohio Cessation of Regulated Operations regulations). Honeywell submitted an RI/FS
Work Plan for the Tar Plant in February 2004 and is expected to begin RI/FS field work for the
Tar Plant by October 2004.
VI. FIVE-YEAR REVIEW PROCESS
Administrative Components
The EPA Remedial Project Manager (RPM), Sharon Jaffess, notified Ohio EPA and the PRP's
Project Coordinator (Richard Galloway, Honeywell) of the initiation of the five-year review process
in the winter of 2004. The EPA RPM headed the five-year review team, and was assisted by Ohio
EPA (primary contact for the review is Kevin O'Hara.). Kevin O'Hara also conducted an O&M
inspection at the Site in June,,2004, which covered many of the same elements as thisjeview.
The review schedule included the following components:
• Community Notification;
• Document Review;
• Data Review;
• Site Inspection;
• Interviews; and
• Five-Year Review Report Development and Review.
39
Community Involvement
In February 2004. the RPM discussed the need to notify the community that the five-year review
process was underway with the EPA Community Involvement Coordinator (CIC), Zenny Sadlon.
In June. 2004. the EPA Office of Public Affairs placed an ad in the local newspapers announcing that
the Five-Year Review was in progress and requesting that any interested parties contact EPA for
more information. A copy of the ad is in Appendix 3. Since the ad was issued, no member of the
community has voiced an interest in the Five-Year Review.
Document Review
This Five-Year Review consisted of a review of relevant documents including: Ironton Coke Plant
Site Groundwater Monitoring Reports (First Quarter 2002, Second Quarter 2002, Third Quarter
2002, Fourth Quarter 2002, First Quarter 2003, Second Quarter 2003, Third Quarter 2003, Fourth
Quarter 2003, First Quarter 2004); Ironton Coke Plant Site Lagoon Area Vegetation and Benthic
Macroinvertebrate Monitoring Report (October 2002); Groundwater Pumping System Evaluation
Summary Report (August 2001); CPLA/GDA Groundwater Modeling and Capture Zone Analysis
(March 1999); Tar Plant Site Management Plan (March 2001); Wastewater Treatment Facility
Operating Manual (1992); Separate-Phase Materials Evaluation Program (January 2001); CPLA
Groundwater Collection and Treatment System Remedial Action Implementation Plan (July 1996);
Monthly Reports (January 2000 - July 2004); Supplemental Ice Creek Monitoring Sampling Reports
(2003); February 2003 Flood water Sample Report (March 25, 2003); Lagoon Area
Wetlands/Floodplain Conversion Plan (September 2000); Report of Slope Stability Analysis
(February 1 2, 2 002); G DA U pdated A ir E missions E valuation (March 2 002); R econnaissance
Ecological Risk Assessment (March 1999); Record of Decision (9/29/88); Record of Decision
(12/28/90); Record of Decision Amendment #1 (7/31/95); Record of Decision Amendment #2
(9/4/97); Record ofDecision Amendment #3 (9/30/98); Unilateral Administrative Order V-W-89-C-
007 (3/9/89); Administrative Order on Consent V-W-03-C-755 (8/22/03); Division Survey Plat of
Tracts l,2,3,4r& 5 (Volume 492, Page 681 Lawrence County Recorder's Office).
Data Review .. «.
GDA
Since pumping operations began in late 1995, approximately 606.1 million gallons of
groundwater have been extracted from outside and within the GDA. The system continues to
operate and provide the necessary drawdown to maintain the inward hydraulic gradient. It should
be noted, however, that in August 2003, significant modification was made to the pumping
system: PW-2 was shut down and the PW-1A pumping rate was increased to 115 gpm. This
change was made because of the optimization study previously discussed, hi order to help in the
evaluation of the effectiveness of the system, Honeywell was tasked to prepare monthly
groundwater contour maps, based on the monthly measurements of the potentiometric data.
From September to November 2003, there was a visible decreased extent of the capture zone
north of PW-2. It was hypothesized that the problem could be related to the precipitation rate.
40
As suggested by OEPA's hydrogeologist, Honeywell was asked to reevaluate the system and
rates. This re-evaluation resulted in the development of a proposal to increase the pumping rate
at PW-1A by 20% (up to 145 gpm) and the re-establishment of pumping at PW-2 at a target rate
of20gpm.
Unfortunately, PW-1 A could not pump at a rate of 145 gpm. Due to observations concerning the
build-up of scale (iron bacteria), Honeywell contracted with Mole Master to perform cleaning of
the pumps and lines. These cleaning activities occurred between April 13 and 29, 2004. PW-1 A
and PW-2 pumping operations resumed with target pumping rates of 145 gpm and 20 gpm,
respectively. The target rate for PW-1 A represents an increase over the former rate of 115 gpm
(prior to line cleaning). Based on a May 2004 groundwater capture zone map, EPA and OEPA
have instructed Honeywell to increase the pumping rate at PW-1 A to 175 gpm and shut down
PW-2. Based on monitoring between July and August, EPA and OEPA may require Honeywell
to install a replacement well for PW-2, which will be capable of extracting more than 20 gpm
and ensuring adequate groundwater capture conditions north of PW-2.
Thirty-two wells are utilized for potentiometric level measurement. It is demonstrated by this
program that there is a positive gradient maintained (any leakage flows into the GDA
containment system, and then it is subsequently pumped out by the extraction well).
Thirteen wells inside and outside of the slurry wall are part of the groundwater quality
monitoring program. The wells are analyzed for PAHs, BTEX, arsenic, ammonia, total cyanide,
amenable cyanide, TPHC, phenolics, and pH. MW-29, located on the Transmar Coal Property,
off-site, continued to show non-detections, except for low levels of ammonia and PAHs. Also,
off-site wells at Ironton Iron continue to show very near or below non-detect levels, with the
exception of cyanide. Pumping wells inside the slurry wall, from 1995 through 2004, show a
generally constant level of PAHs, benzene, ammonia, and cyanide. Pumping wells outside of the
slurry wall also show a generally constant trend. The monitoring wells show highly variable
levels of PAHs, benzene, and ammonia, but very steady to declining trends for cyanide.
NAPS and Separate Phase Materials
Specific wells are checked for these non-aqueous phase substances (free product or NAPS)
which are known to be not entirely contained within the GDA slurry wall.
NAPS monitoring was originally planned to be conducted on a quarterly frequency; however,
since these wells are also included in the potentiometric measurement program, they are
monitored on the same monthly frequency.
Historically, the presence of NAPS had been determined by combined usage of the
Flexidip/Ullage Interface Probe, and collection of well-bottom samples via a stainless-steel cup
attached to a length of conduit. A revised monitoring procedure was developed in August 2000
that eliminated use of the probe, which was found to only be suitable for LNAPL, not DNAPL.
41
The most recent data continue to indicate consistent detections of NAPS only in GDA well
NMW-1A.
Beginning in September 2001, pumping and collection of DNAPL from WE-618 was initiated.
As of the end of June 2004, a total of approximately 2,472.5 gallons of DNAPL has been
removed and collected from WE-618. Since the start of this DNAPL pumping, the collected
materials (characterized as non-hazardous) have historically been shipped to Honeywell's Detroit
Tar Facility for recycling. However, beginning in the Third Quarter of 2004, and due to the
recent shutdown of the Detroit facility, the materials will now be managed as part of approved
off-site fuels blending programs.
Samples of groundwater are collected at 8 locations within the CPLA as part of the quarterly
program. Analysis is conducted for PAHs, volatile organics, arsenic, ammonia, cyanide, nitrate,
and phenolics. Groundwater quality in and around the lagoon area continues to show benzene
levels above the clean up standard and ammonia levels very near the clean up standard,
particularly in the southern portions of the lagoon area. Although elevated, benzene
concentrations are snowing a downward trend. The groundwater quality at the northern end of
the lagoon area (WE-24225 and WE-2427) remains below the cleanup standards since August
2002.
Tar Plant
While not the subject of this five year review, wells in the Tar Plant area are included in the
site-wide monitoring program. There appears to be acceptable water quality for all parameters,
with the continuing exception of PAHt in well MW-24. The level, however, represents an order
of magnitude decline from the all-time high level reported in 2003, and may represent progress
towards anticipated improvements in groundwater quality from the April 2003 clean-out and
wellhead modifications.
Ice Creek
Eight wells are sampled on-site and two Coal Grove pumping wells are sampled, hi addition,
surface water samples are collected from two locations in the creek. Samples are collected for
PAHs, volatile organic compounds, arsenic, ammonia, cyanide, nitrate, and phenolics.
There have been no exceedences to the cleanup levels in any of the wells.
Site-Wide Groundwater Containment
As per EPA and OEPA approval in January 2002, the first incremental adjustments to the sitewide
pumping system were made on March 8, 2002. The total site-wide extraction rate is
presently up to 380 gpm as compared to pre-adjustment rate of approximately 400 gpm. The
effects of the March 2002 pumping rate adjustment have been continuously evaluated, hi
42
October 2002 (following six months of operation), it was observed that adequate capture of siteimpacted
groundwater was being maintained, although certain areas between the GDA and the
Ohio River continued to show a somewhat protracted capture zone as compared to prior to
March 2002. These reduced capture conditions were believed attributable to residual
accumulation of groundwater within the aquifer resulting from increased precipitation during the
months of March - May 2002 (7" above normal levels). The October 2002 capture zone did
show improvement. Based on January 8, 2003 field data, it was observed that the site-wide
potentiometric surfaces rebounded slightly from October 2002, showing an average increase of
0.5 foot. This trend continued into April 2003, which showed an additional 1.2 foot rise in
elevation. The Ohio River and Ice Creek surface water elevations also showed rises above the
groundwater potentiometric surface, which creates a reverse flow effect and enhances the capture
zone. Based on July 2003 field data, site-wide water levels had remained generally consistent
with those from earlier in the year. However, the Ohio River and Ice Creek surface water
elevations showed marked decreases, which would have the effect of protracting the capture zone
along the Tar Plant and GDA boundaries along the Ohio River and Ice Creek. Actual measured
precipitation during January through June 2003 totaled approximately 7.25 inches above normal,
and caused flooding on the Site. Based on October 2003 field data, a decrease of approximately
0.6 feet was observed in the average site-wide potentiometric elevations as compared to the July
2003 measurements. The surface water elevations in Ice Creek and the Ohio River, however,
remained at their normal elevations. Therefore, decreased capture of impacted groundwater in
areas north of the GDA were noted. The total rainfall for 2003 indicated that it was the wettest
year on record since startup of the pumping operations in 1997. Additionally, there was a
flooding event in November 2003. With the exception of the areas north of the GDA, the
impacted groundwater within the CPLA and Tar Plant continues to be captured. Following
completion of cleaning of the pumps and lines, evaluation of the overall system will continue. If
there continues to be a protracted capture zone in this northern sector, EPA and OEPA will
likely require the drilling and operation of an additional extraction well.
Groundwater Chemistry
Quarterly monitoring over the last seven years has indicated generally improved conditions,
particularly in the northern portion of the lagoon area. Throughout the remaining areas ~of the
CPLA, localized groundwater contamination persists in the southern portion of the lagoon area
and the central area of the Tar Plant. The results of the Ice Creek program (since 1993) have
continually shown no degradation of the water quality in areas downgradient of the Site,
including the Coal Grove Well Field (even with the aforementioned protracted capture zone over
the past year).
GDA Vent Gas Sampling
Based on EPA and OEPA concurrence (May 2002), the GDA Vent Gas Sampling Program was
terminated. This was based on review of the the Air Emissions Evaluation report submitted in
March 2002. The principal conclusions from the evaluation (based on analytical data from 14
consecutive quarterly monitoring events) included the following:
• The emissions of VOCs from the four GDA vents are insignificant.
43
The ambient impact to the nearest public receptor due to emissions from the vents is
insignificant and orders of magnitude lower than the corresponding Maximum Allowable
Ground Level Concentration (MAGLC).
As stipulated by EPA and OEPA. Honeywell continues to maintain the gas vents, in the event
that future sampling is required.
Wetlands Monitoring
The monitoring program is annual and began in July 2002. Vegetation is lush and data collected
over the past two years is indicative of a successful natural revegetation. However, benthic
macroinvertebrate sampling, monitoring of the establishment of communities, and the
presence/absence of invasive species will have to be carefully monitored over the next few years.
Site Inspection
EPA and OEPA conducted a Site inspection on July 28, 2004. Personnel from Honeywell (the
PRP), Shaw Environmental (O&M contractor), OML, (O&M Contractor and Waste Water
Treatment Plant Operator) and Parsons Engineering (RI/FS contractor) accompanied the
regulatory team in the inspection. The purpose of the inspection was to assess the protectiveness
of the remedies, including the condition of fencing to restrict access, the integrity of the cap, the
condition of the extraction well system, the condition of the WWTP, the condition of the
monitoring wells, the effectiveness of land use restrictions, and the progress of the wetlands
restoration.
The following statements summarize the main topics covered during the inspection:
• The cap appeared to be in good physical condition and the grass cover was freshly mowed. This
is reflective of monthly reports and a previous Site inspection conducted by OEPA.
• Extraction and monitoring wells appeared to be in good condition and reflective of the monthly
reports. Iron fouling is an ever present problem requiring considerable maintenance.
• Site fencing was intact and appeared to be in good condition. Signs were in good condition.
• The Wastewater Treatment Plant operations are clean, neat, and orderly.
• The new vegetation plots on the flood wall seem to indicate a good vegetation mix for a large
scale future planting to improve stability and minimize erosion.
44
Interviews
Even during the amendments to the RODs, there has relatively been low community interest in
this Site. For example, there were no comments provided at the public meeting held in July 1997.
The RPM visited the information repository at the Briggs County Library (located within the City
of Ironton) in July 2003. The librarian reported that she couldn't recall the last time anyone
requested to look at the Site files. The library keeps the files in a reading room and the files are
currently in disarray.
The low community interest in this Site is further supported by the fact that neither the RPM nor
the CIC has been contacted by the community in recent years. Further, no community members
responded to the five-year review ad that invited readers to contact the CIC for more information
on the five-year review process. Therefore, the CIC and RPM decided not to conduct interviews
of local residents.
However, because of the city's interest in redevelopment, Sharon Jaffess and Kevin O'Hara
traveled to the Lawrence Economic Development Corporation (LEDC) office, located nearby, in
South Point, Ohio. The LEDC is a non-profit Community Improvement Corporation formed
under Chapter 1724, Ohio Revised Code. LEDC was formed in 1983 and was designated the
economic development agent for the City of Ironton and Lawrence County. Ms. Jaffess and Mr.
O'Hara met with the LEDC's Executive Director, Bill W. Dingus and a board member, Roger
Haley (who is a former Allied employee during the time the Coke Plant and Tar Plant were
operational). Mr. Dingus informed us that he was interested in the future utilization of Ice Creek
to expand the shipping capabilities of the region. Mr. Dingus was interested to know if there are
any outstanding issues related to the Site as it had previously affected Ice Creek. Ms. Jaffess
agreed to research the information and provide Mr. Dingus with such information.
VII. TECHNICAL ASSESSMENT
Question A: Is the remedy functioning as intended by the decision documents?
A review of the relevant documents results, and the results of the Site inspection indicate that the
remedies are functioning as intended by the RODs, the BSD, and the three ROD Amendments.
Through an extensive O&M program that includes groundwater monitoring, potentiometric
monitoring, chemical analysis, and NPDES discharge monitoring, the capture zone is generally
being maintained. A change in the pumping scheme to 300 gpm instead of 400 gpm (based on an
optimization study) accompanied by higher than normal precipitation, has resulted in a somewhat
protracted capture zone. This has been addressed through an increase in pumping rates (the
present rate is now up to 380 gpm) and may be further addressed by the incorporation of an
additional extraction well. The groundwater monitoring program also continues to demonstrate
the effectiveness of the slurry wall and visual inspection of the cap demonstrates that it continues
to be maintained in excellent condition. The wetlands development program is still in an early
phase, but the initial sampling reports are promising.
45
Institutional controls at this Site are effective. First, there is a perimeter fence and Site security.
Due to the operation of a WVVTP. there is also a constant presence on the Site by Honeywell
and or its contractors. Second, the various tracts of land owned by Honeywell comprising the
former coke plant and lagoon areas were consolidated into two tracts, one consolidating the tracts
located in the City of Ironton, which has been assigned tax parcel number 36-042-0300 and one
in the Village of Coal Grove, which has been assigned tax parcel number 29-050-0200. The
parcel within the City of Ironton has subsequently been subdivided into 4 individual taxable
parcels to assist with future brownfields redevelopment. The 5 parcels are as follows:
• Tract 5 (15.% acres), Village of Coal Grove
• Tract 4 (28.39 acres), City of Ironton
• Tract 3 (38.31 acres), City of Ironton
• Tract 2 (6.82 acres), City of Ironton
• Tract 1 (1.42 acres), City of Ironton
Tracts 4 and 5 encompass the lagoon area. Tract 3 includes the former coke plant area. Tracts 1
and 2 encompass the former administrative and truck parking areas, as well as the WWTP (Tract
2)-
The aforementioned 5 taxable parcels have been recorded (August 8,2002) with the following
environmental restrictions in the Lawrence County Recorder's Office (deed restrictions):
• There shall be no consumptive or other use of the groundwater underlying the real property
that is the subject of the EPA Order for any purpose other than compliance with the Order,
• There shall be no future use of the property that may interfere with the work to be performed
under the Order,
• There shall be no residential or recreational use of the property, including, but not limited to,
any construction of residences, excavation, grading, filling, drilling, mining, or other
construction or development, farming, placing (except as contemplated within the Order) of
any waste material at any portion of the property or any other activity which may damage or
impair the effectiveness of any remedial action undertaken pursuant to the Order, except
with the approval of the EPA;
The foregoing land use restrictions shall continue until such time as the same are released by
action of the EPA.
The deed restriction for the five tracts also states that the land use restrictions shall run with the
land in perpetuity:
• The property shall not be used for purposes of personal living, dwelling, or overnight
accommodations, whether such uses are in single family residences, apartments, duplexes or
other multiple residential dwellings, trailers, trailer parks, camping sites, hotels, motels, or
46
any other dwelling use of any kind, by the owner or occupant of the property, or anyone
occupying the property with the permission of the then owner of the property;
• The groundwater underneath the property shall not be used for human consumption,
irrigation, or other purposes that might bring it into contact with humans (except for test
purposes as required by law), and that neither it, nor its successors, will drill or install any
wells on the property for the purpose of extracting groundwater underneath the property for
human consumption, irrigation, or other purposes that might bring it into contact with
humans (except for testing purposes, as required by law), and that nor shall any existing
groundwater monitoring wells be abandoned except in compliance with applicable
regulations and with the prior specific knowledge and approval of the EPA; and that no
person shall in any way interfere with, or suffer or permit the interference with, the existence,
operation, and maintenance of existing groundwater monitoring wells.
Tracks 1 and 3 were purchased by the City of Ironton from Honeywell, with a portion of Tract 3
conveyed to the Ohio Department of Transportation for industrial re-use.
The GDA, located adjacent to the Tar Plant (and west of 3rd Street, or across the street from the
aforementioned tracts) is on a parcel owned and fully maintained by Honeywell. This parcel was
originally two tracts of land: 11.63 acres (originally owned by Marting Iron and Steel Company,
which was sold to Margaret V. Goldcamp on December 5,1938) and 0.04 acre adjacent to Third
Street (originally owned by Ashland Iron and Bridge Company, which was sold to Henry I.
Goldcamp on August 8, 1943). Allied Chemical and Dye Company signed an option agreement
for the disposal site on March 30,1955 and later purchased the property in June 1955. This
property became Honeywell's upon Honeywell's merger with Allied. The Unilateral
Administrative Order (V-W-89-C-007) dated March 9, 1989 required restrictions on this property
as follows:
• There shall be no consumptive or other use of the ground water underlying the property that
could cause exposure of humans or animals to the ground water underlying the GDA.
• There shall be no use of the area presently over the existing GDA pit ana, in the future, the
area to be enclosed by the slurry wall including but not limited to the construction,
installation, or use of any structures or buildings other than for the purpose of implementing
the remedial actions required by this Administrative Order.
• There shall be no use of the property that would allow the continued presence of humans at
the area presently over the existing GDA pit and, in the future, the area to be enclosed by the
slurry wall other than any presence necessary for implementation of the remedial actions
under this Administrative Order. Prohibited uses which would allow the continued presence
of humans at this particular real estate will include but not necessarily be limited to
recreational or educational uses.
• There shall be no installation, construction or use of any buildings, wells, pipes, roads,
47 .
ditches or any structures at the area presently over the existing GDA pit and, in the future,
the area to be enclosed by the slurry wall except as approved by the EPA as being consistent
with this Administrative Order.
The GDA property is completely fenced and requires operation and maintenance by Honeywell
into perpetuity (landscaping, mowing, quarterly groundwater monitoring, daily pumping system
observation and maintenance). Like the CPLA area, it is under constant security and monitoring
by Honeywell contract employees, stationed at the WWTP. These restrictions are being met.
Honeywell, as part of their OU3/Tar Plant work, has prepared a consolidation survey plat of the
properties comprising the GDA and the Tar Plant. This survey plat shows the consolidation of
all of Honeywell's parcels, including the GDA and Tar Plant property. Two new tax parcels
were created: Tract A, Tax No. 36-042-0100 (25.66 acres) and Tract B, Tax No. 36-042-0200
(11.88 acres). Tract A contains the GDA and the Tar Plant area. Tract B contains the portion of
the Tar Plant area property that extends to the Ohio River shoreline. The specific environmental
restrictions, mentioned above, are not contained on the survey plat. EPA will work with
Honeywell to ensure that as part of the OU3 Tar Plant work, the tract of land (parcel A) that
contains the Tar Plant and GDA reflects the required GDA deed restrictions on a revised survey
plat and in the deed.
Question B: Are the exposure assumptions, toxicitv data, cleanup levels, and remedial action
objectives (RAOs) used at the time of the remedy selection still valid?
There have been no changes in the physical conditions of the Site that would affect the
protectiveness of the remedy. The exposure assumptions, toxicity data, cleanup levels, and RAOs
used for remedy selections (and amended) are still valid.
Changes in Standards and To be Considered Cl'BC)
The soil clean-up levels established were:
• 0.97mg/kg for carcinogenic PAHs (10-6 excess cancer risk) [sum of
benzo(a)pvrene (B(a)P), benzo(a)anthracene (B(a)A), dibenzo(a4))anthracene
(D(aJ))A), and chrysene] and
• 0.56 mg/kg for arsenic (later revised to 15 mg/kg based on site-specific
background evaluation).
The groundwater clean-up levels established were:
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Contaminant
Benzo(a)pyrene
Dibenz(a,h)anthracene
Arsenic
Ammonia
Phenolics
Benzene
Naphthalene
Nitrate
Total Cyanide
Cleanup Standard
200 ppt
300 ppt
50 ppb
30 ppm
4 ppm
5 ppb
300 ppb
10 ppm
200 ppb
ppt parts per trillion
ppb parts per billion
ppm parts per million
There have been no changes in these ARARs and TBCs that affect the protectiveness of the
remedy.
Changes in Exposure Pathways. Toxicity. and Other Contaminant Characteristics
There have been no changes in the exposure assumptions that were used in the risk assessment
that would affect the protectiveness of the remedy. EPA considers the assumptions in the
baseline risk assessment to be conservative and reasonable in evaluating risk-based cleanup
levels. No change to these assumptions or to the cleanup levels developed from them is
warranted. There has been no change in the standardized risk assessment methodology that
would affect the protectiveness of thg remedy. Because the remedy implemented engineering
and institutional controls to prevent contact with contaminants that remain at the Site, changes in
contaminant toxicity would not impact the effectiveness of the remedy.
Question C: Has any other information come to light that could call into question the
protectiveness of the remedy?
No other events have affected the protectiveness of the remedy, and there is no other information
that calls into question the protectiveness of the remedy.
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Technical Assessment Summary
Based on a review of relevant documents, data, ARARs, risk assumptions, and the results of the
Site inspection, it appears to EPA that the remedy is functioning as intended by the RODs,
including the ESD and the three ROD Amendments.. There have been no changes in the
physical conditions of the Site that would affect the protectiveness of the remedy. There have
been no changes in exposure pathways or toxicity factors for the contaminants of concern which
would impact the effectiveness of the remedy. The remedies have been implemented in
accordance with the design plans, and in accordance with pre-design sampling which helped
effectuate better remedies. Once pumping rates are increased to previous levels, EPA expects the
capture zone to be fully protective. There is no other information available that calls into
question the protectiveness of the remedy.
VIII. ISSUES
Problem
• Capture Zone is protracted due to a reduction in pumping rates and higher than normal
precipitation;
• Coal and coke fines transported to the Biomass facility remain at the South Point facility and
have not yet been used for alternative fuel. The material was inspected as part of the field
inspection. It was stored in a building. However, the building is somewhat decayed and has
huge holes in the roof and there are large open cavities in the walls. The material is
completely exposed to the elements, most notably precipitation and wind. While the building
has a cement floor, there is nothing to prevent leaching of the material. It also appeared to
the OEPA inspector, that some of the material had been removed.
Resolution
• Honeywell is increasing the extraction rate of pumping wells. If the existing wells, which
were recently (summer 2004) rehabilitated cannot sustain the required pumping rates, an
additional extraction well will be installed.
• OEPA has already attempted enforcement action against the owner of the Biomass facility.
No resolution has been reached. EPA will contact the Biomass facility owner, and
Honeywell, to discuss proper disposal options, if the material is not going to be used as an
alternative fuel. EPA will also be requesting that Biomass place tarps over the building, and
board up the openings in the walls to prevent precipitation and wind exposure.
The aforementioned actions will be taken in the Fall of 2004.
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IX. Recommendations and Follow-Up Actions
Issue
Pumping
Rate
Coal and
Coke Fines
GDA Deed
Restrictions
Ice Creek
Potential
Use for
shipping
••*-_
Recommendation
s/
Follow-up
Actions
Continued
monitoring,
installation of a
new extraction
well
Contact Biomass
facility owner
Ensure GDA
restrictions are
recorded with the
Lawrence County
Recorder's Office
Lawrence
Economic
Development
Corp. interested in
future use of Ice
Creek and
requested
information on Ice
Creek as it relates
to the Site
Party
Responsible
Honeywell
EPA
Honeywell
EPA
Oversight
Agency
EPA
OEPA
EPA
OEPA
Milestone
Date
Fall
2004
Fall
2004
Fall
2004
Fall
2004
•SL
Affects
Protectiveness?
(Y/N)
Current
N
N
N
N
Future
N
N
N
N
X. Protectiveness Statement
The remedies at the Allied Chemical and Ironton Coke Site are protective of human health and
the environment because threats at the Site have been addressed through capping, maintaining
inward hydraulic gradients, maintaining an adequate groundwater contaminant capture zone,
installation of fencing and warning signs, and implementation of institutional controls (deed
restrictions).
XI. Next Review
The next Five-Year Review for the Allied Chemical and Ironton Coke Superfund Site is required
by August 2009, five years from the date of this review.
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